Effective from: 08/10/2025
1. Policy Statement
Twoition Ltd is fully committed to safeguarding the welfare of all children, young people, and vulnerable adults we work with. The safety and wellbeing of our learners are our highest priority.
Twoition Ltd operates as an education employment business under the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003. This ensures that all tutor recruitment, engagement, and placement processes comply with statutory safeguarding and safer recruitment standards.
Key Principles:
- The welfare of the learner is paramount.
- All learners, regardless of age, disability, gender identity, race, religion, sex, or sexual orientation, have the right to equal protection from harm.
- Safeguarding is everyone’s responsibility.
- We operate a culture of vigilance, openness, and transparency.
- Confidentiality has limits: tutors must never promise confidentiality if a learner shares information indicating they or others are at risk.
This policy explains how we protect learners during tutoring sessions (in-person and online) and beyond, and how we work closely with parents, carers, and external agencies.
This policy is written with reference to the following statutory guidance and legislation:
- Working Together to Safeguard Children (HM Government, 2023)
- Keeping Children Safe in Education (Department for Education, 2024)
- Children Act 1989 and Children Act 2004 (Section 11 duties)
- Education Act 2002 (Section 175 duties)
- Data Protection Act 2018 and UK GDPR
Twoition Ltd recognises its duty under Section 11 of the Children Act 2004 to ensure that all functions and services are carried out with regard to the need to safeguard and promote the welfare of children.
2. Scope
This policy applies to everyone delivering tuition or representing Twoition Ltd, including:
- Self-employed tutors and subcontractors
- Company employees (including directors or owners who also tutor)
- Administrative or support staff
- All individuals, regardless of their contractual status, must comply fully with this policy and complete the required safeguarding and data protection training.
3. Safer Recruitment
Twoition Ltd follows strict recruitment procedures to ensure all tutors are suitable to work with learners, including:
- Proof of identity, address, and qualifications.
- Enhanced DBS check with Children’s Barred List and registration on the DBS Update Service.
- Two verified professional references.
- Completion of safeguarding training before starting.
- Disclosure of any criminal charges or investigations.
- Structured interview and full work history review.
Safeguarding expectations are clearly communicated throughout recruitment.
4. Roles and Responsibilities
Designated Safeguarding Lead (DSL):
Rebecca Bennett
Email: contact@twoition.co.uk | Phone: 07368 622727
Deputy DSL:
Matthew Jones
Email: mattjones@twoition.co.uk
The DSL holds overall responsibility for ensuring compliance with this policy. All tutors and staff must report safeguarding concerns immediately to the DSL or deputy if the DSL is unavailable. Everyone shares responsibility for keeping learners safe.
5. Equality, Diversity & Inclusion
Twoition Ltd is committed to ensuring all learners are treated fairly and protected equally, regardless of their background or personal characteristics. We recognise that some learners, including those with special educational needs and disabilities (SEND), or mental health challenges, may be more vulnerable and require extra support.
6. Types of Abuse and Safeguarding Concerns
Tutors should be aware of the following risks:
- Physical, emotional, sexual abuse, and neglect
- Bullying and cyberbullying
- Online abuse, exploitation, grooming
- Radicalisation and extremism
- Child sexual and criminal exploitation
- Domestic abuse
- Peer-on-peer abuse
- Self-harm and mental health concerns
If unsure about a situation, always report concerns to the DSL.
7. Code of Conduct for Tutors
All tutors must:
- Prioritise learner safety and wellbeing.
- Maintain professional boundaries at all times.
- Never meet learners in person without parental consent and ensure safe locations.
- Use only approved, secure platforms (e.g., Zoom, Google Meet) for online sessions.
- Ensure sessions occur in safe, appropriate environments.
- Dress professionally during sessions.
- Avoid physical contact except in emergencies.
- Never promise confidentiality—report concerns immediately.
- Maintain professional communication boundaries outside sessions.
8. Online Tutoring Safety
- All online sessions must use secure, password-protected platforms.
- Sessions may be recorded with explicit, informed consent from parents/guardians and learners.
- Parents are encouraged to observe sessions.
- Recordings are stored securely, accessed only by authorised personnel, and deleted when no longer needed.
- Lesson recordings, where consent has been obtained from parents/guardians and learners, are retained for a maximum of one year for quality assurance or safeguarding review purposes.
- After this period, recordings are securely deleted unless they form part of an active safeguarding record, in which case they will follow the retention schedule outlined in Section 13.
- Unauthorized recording or sharing of sessions is a serious breach and must be reported.
- Tutors and learners must maintain a professional environment and appropriate dress.
8a. Tutor Accountability and Consequences for Non-Compliance
All tutors representing Twoition Ltd — including contractors, employees, and directors — are personally responsible for maintaining the highest standards of safeguarding, professionalism, and data protection.
Tutors must:
- Comply with all Twoition Ltd policies, including Safeguarding, Data Protection, Privacy, and Conduct.
- Report any safeguarding or data breach concerns immediately to the Designated Safeguarding Lead (DSL).
- Maintain professional boundaries and confidentiality at all times.
- Keep all learner information secure and use it only for tuition purposes.
Failure to comply with these obligations may result in:
- Suspension or termination of the tutoring agreement or contract.
- Referral to external authorities such as the DBS, LADO, or the police if safeguarding or legal concerns arise.
- Removal from the Twoition Ltd tutor register and refusal of future work opportunities.
Accountability extends to online and in-person settings and includes conduct outside sessions if it impacts learner safety or the company’s reputation.
9. Responding to Safeguarding Concerns
If a learner discloses a concern:
- Listen calmly and attentively.
- Avoid leading questions or pressuring for details.
- Reassure the learner they did the right thing by speaking up.
- Explain that you must report the concern to help keep them safe.
- Record the disclosure factually, including exact words, time, date, and any observations.
- Report immediately to the DSL.
10. Emergency Safeguarding Protocol
If a learner is in immediate danger:
- Ensure their immediate safety.
- If online, check the learner’s environment and stay connected if safe.
- Call emergency services (999) if there is a risk to life or safety.
- Inform the DSL as soon as possible.
- Document all actions taken and communications.
11. Allegations Against Staff & Whistleblowing
Concerns about staff behaviour should be reported immediately to the DSL. All allegations are taken seriously and referred to the Local Authority Designated Officer (LADO) as required.
Tutors and staff can raise concerns safely without fear of retaliation through our whistleblowing procedures. Neutral suspension may be applied during investigations to protect all parties.
12. Referral and External Support
The DSL will make referrals to:
- Local Authority Children’s Services for child protection concerns.
- Police for criminal matters or immediate danger.
- LADO for staff allegations.
- NSPCC Helpline for advice.
- CEOP for online exploitation concerns.
13. Confidentiality and Data Protection
- Safeguarding records are stored securely and separately, with access strictly limited.
- Data handling complies with UK GDPR and Data Protection Act 2018.
- Records are retained according to statutory guidance and securely destroyed when no longer needed.
- In line with Twoition Ltd’s Data Protection and Privacy Policy, safeguarding and child-protection records will normally be retained until the learner reaches the age of 25 (or longer if required by ongoing legal or safeguarding proceedings).
- All records are stored securely and separately from other learner information and are permanently deleted or confidentially destroyed once the retention period ends.
- All staff receive training on confidentiality and data protection.
14. Training and Supervision
- All tutors must complete safeguarding training before working with learners and refresh every two years or as regulations change.
- Tutors are encouraged to raise concerns and seek support.
- Training records are maintained and reviewed regularly.
15. Safeguarding During In-Person or Offsite Sessions
- Risk assessments must be completed before all sessions.
- Written parental consent is required, detailing session information.
- Tutors must not be alone with a learner unless prior agreement exists.
- Sessions should occur in visible, safe, and accessible locations.
16. Complaints and Safeguarding
Any complaint involving safeguarding is handled under this policy to ensure proper care and protection.
17. Monitoring, Evaluation, and Review
This policy will be reviewed annually or following any safeguarding incident or legislative change.
Safeguarding and Child Protection Policy v1.0
Reviewed by: Rebecca Bennett, DSL/Operations and Growth Manager
Last reviewed: 08/10/2025
Next review due: 08/10/2026
18. Contact Details
Twoition Ltd DSL:
Name: Rebecca Bennett
Email: contact@twoition.co.uk
Phone: 07368 622727
Key Safeguarding Contacts:
- NSPCC Helpline: 0808 800 5000
- Childline (for children): 0800 1111
- LADO (Local Authority Designated Officer):
St Helens LADO Contact
Telephone: 01744 671252
Email: sthelenslado@sthelens.gov.uk - CEOP: https://www.ceop.police.uk/safety-centre
