Online Safety & Safeguarding

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Safeguarding Policy and Procedures

November 2021


  1. Introduction


  1. Scope and Purpose of the Policy


  1. Definitions of Abuse


  1. Online Safety


  1. Safeguarding Governance – Roles and Responsibilities


  1. Dealing with a Safeguarding Concern or Disclosure


  1. Sharing Information


  1. Safeguarding Allegations Against Directors, Staff or Tutors


  1. What staff and tutors should do if they have concerns about poor or unsafe practice within MTW


  1. Recruitment, Selection and Training


  1. Complaints


  1. Quality Assurance and Review


  1. Underpinning Legislation and Guidance



Appendix A – MTW Safeguarding Concern Template


Appendix B – Guide on submitting a Safeguarding Concern


1. Introduction

MyTutorWeb Ltd (MTW) was founded to offer life-changing tuition for all. Our site was developed with the aim of ensuring that high-quality lessons take place in a safe environment and this is reflected in a number of key built-in features.  

We are committed to ensuring the highest possible standard of personal safety, wellbeing and safeguarding of each student and tutor using MTW.

This policy and the supporting procedures seek to ensure that MTW undertakes its responsibilities regarding safeguarding children and young people. This policy establishes a framework to support all those who come into contact with MTW, protect them from abuse and maltreatment of any kind and clarifies the organisation’s expectations.

2. Scope and Purpose of the Policy

This policy applies to all aspects of MyTutorWeb Ltd (MTW) in relation to tutoring services. The policy and supporting procedures apply to all Directors, staff, tutors, and all other people who conduct work on behalf of MTW.

MTW acknowledges its duty of care to safeguard and promote the welfare of children and young people and is committed to ensuring safeguarding practices reflect statutory responsibilities, government guidance and reflects best practice.

The purpose of this policy is to ensure that, regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation or socio-economic background, all students have a positive experience of MTW through the services, support or activities they engage in.

Safeguarding Statement:

Safeguarding is everyone’s business – MyTutorWeb is committed to safeguarding and promoting the welfare of children and young people and expects all Directors, staff and tutors to share this commitment.

MTW will ensure that good governance and quality standards are maintained within the organisation and establish clear policies and procedures based on legislation and guidance. We will apply robust risk management processes for the identification of situations which may require the organisation to make professional judgements to protect students from harm.

Confidentiality is essential to the environment of trust with our students, but this will be balanced against the organisation’s duty to protect children and young people.  

The organisation will collectively manage risks and reduce the likelihood of abuse by:

It is the responsibility of all directors, staff and tutors to read this policy and supporting procedures and know what to do in the event of a safeguarding concern.

This policy and supporting procedures should be read alongside the following policies and procedures:

3. Definitions of Abuse

Children are considered to be abused or at risk of abuse by parents/carers when the basic needs of the child are not being met through acts of either commission or omission.  Children includes everyone under the age of 18 (KCSIE, 2021).

Knowing what to look for is vital to the early identification of abuse and neglect. All staff will be aware of indicators of abuse and neglect through their experience and training so that they are able to identify cases of children who may be in need of help or protection. If staff are unsure, they should always speak to the designated safeguarding lead (or deputy).  

All staff should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and consensual and non-consensual sharing of nudes and semi-nudes images and/or videos can be signs that children and young people are at risk.

Safeguarding and promoting the welfare of children and young people is defined as:

(Keeping Children Safe in Education (KCSIE), DfE, September 2021)  


Is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children (KCSIE, 2021, para 26).

Types of abuse and neglect

Physical abuse

A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse

The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person.

It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children.

These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Sexual abuse

Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.

They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue (also known as peer on peer abuse) in education and all staff and tutors should be aware of it and adhere to this policy and procedures in dealing with it.


The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Peer on Peer / Child on Child Abuse

Children can abuse other children (often referred to as peer-on-peer abuse) and it can take many forms. It can happen both inside and outside of school/college and online. It is important that all staff recognise the indicators and signs of peer-on-peer abuse and know how to identify it and respond to reports. This can include (but is not limited to): bullying (including cyberbullying, prejudice-based and discriminatory bullying); abuse within intimate partner relationships; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexual violence and sexual harassment; consensual and non-consensual sharing of nude and semi-nude images and/or videos; causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party; upskirting and initiation/hazing type violence and rituals. Addressing inappropriate behaviour (even if it appears to be relatively innocuous) can be an important intervention that helps prevent problematic, abusive and/or violent behaviour in the future. (KCSIE 2021, pg 135)

Sexual Violence and Sexual Harassment between children

Child on child sexual violence can happen both inside and outside of education settings. For the purposes of this policy and procedures when referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003 specifically, rape, assault by penetration, sexual assault and causing someone to engage in sexual activity without consent.

Sexual harassment is unwanted conduct of a sexual nature that can occur online and offline and both inside and outside education settings. Child on child sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated degraded or humiliated and/or create a hostile, offensive or sexualised environment. (Sexual violence and sexual harassment between children in schools and colleges, DfE, Sept 2021)

Child Protection

Is one part of safeguarding and promoting the welfare of children and refers to the activity that is undertaken to protect children who are suffering, or at risk of suffering significant harm.

Significant Harm

The definition of significant harm is not prescriptive. The interpretation will depend largely on professional judgement, based on the known facts. It can include inappropriate touching, an assault, or a series of compounding events e.g., bullying. Other factors to be considered include the age and vulnerability of the child, the degree of force used, the frequency of the harm, the nature of the harm in terms of ill treatment, and the impact on the child’s health and development.

Annexes  A & B of KCSIE 2021 contains important additional information about specific forms of abuse and safeguarding issues. MTW require all staff and tutors to read the annexes in conjunction with this policy and supporting procedures.

4. Online Safety

MTW takes a holistic approach to online safety that aims to protect staff, tutors and students in their use of technology, and specifically our site. All communication between tutors and students take place via our site. This means that personal details about the student and their parents/carers (including email addresses and telephone numbers) remain private and confidential and are not visible to the tutor. We have established mechanisms to identify, intervene in and escalate any concerns where appropriate.

As outlined in KCSIE 2021 MTW recognise the considerable breadth of issues classified within online safety, which have been categorised into the following four areas:

MTW ensures online safety is a constant running and interrelated theme through the development and implementation of all our services, policies and procedures.

5. Safeguarding Governance – Roles and Responsibilities

MTW is committed to providing support to all those involved with the organisation. A clear structure of safeguarding accountability supports everyone to understand their individual and collective responsibilities for safeguarding children and young people.

MTW will ensure it has arrangements in place to fulfil its commitment and duty to safeguard children and young people in accordance with legislation and statutory guidance.

MTW Board of Directors

Directors play a vital role in ensuring that they are legally compliant in order to manage the organisation’s resources effectively and provide a long-term vision and protect the organisation’s reputation and values.

In order to fulfil these responsibilities, the Board of Directors may delegate some or all of these responsibilities’ individual directors or members of the leadership team.

Directors are responsible for:

MTW Leadership Team

The leadership team will ensure a commitment to safeguarding is integral in the delivery of all its services, activities and contracts. They will assist in the safer recruitment and selection of staff and tutors.

The Leadership Team will ensure that:

MTW Named Designated Safeguarding Officer and Deputies

The Named Designated Safeguarding Officer (DSO) and Deputy Designated Safeguarding Officers (DDSO) will be provided with the appropriate level of training to enable them to fulfil their responsibilities in supporting and guiding staff and tutors on safeguarding matters. The training should be updated every two years. They are responsible for responding to initial concerns or disclosures.

The Named Designated Safeguarding Officer and Deputies will:

Designated Safeguarding Officer

Name: Will Beaton

Phone: 0203 773 6020


Deputy Designated Safeguarding Officer

Name: Dilpreet Bhagrath

Phone: 0203 773 6025


Deputy Designated Safeguarding Officer

Name: Georgia Cohen

Phone: 0203 773 6020


Designated Safeguarding Champion

Name: Frederika Ofong

Phone: 0203 773 6020


Designated Safeguarding Champion

Name: Mia Boddington

Phone: 0203 773 6025


Designated Safeguarding Champion

Name: Elva Tucker

Phone: 0203 773 6020


Further information on the role and responsibilities of the Designated Safeguarding Lead, Deputies and Champions in the context of schools can be found in the statutory guidance KCSIE 2021, Annex C.

MTW Staff and Tutors

All MTW staff and tutors have a shared responsibility to safeguard and promote the welfare of children and young people. They should know how to recognise, respond to, report and record any safeguarding concerns.

All staff and tutors are responsible for following the organisation’s safeguarding procedures for reporting any concerns relating to abuse or neglect or suspected abuse or neglect of any child or young person immediately.

In an emergency staff and tutors will be expected to report urgent concerns directly to the relevant statutory agency.

6. Dealing with a safeguarding concern or disclosure

This policy and the following procedures have been developed to:

We must be alert to the risks from:

Staff or tutors may have suspicions that a person is either

because of behavioural, emotional and/or physical factors; or symptoms or conversations and/or written evidence which indicate that abuse or neglect may have taken place, or an individual may disclose information that causes a concern for their safety and welfare.

When making difficult judgements around possible signs and symptoms of abuse and neglect it is crucial that all available information and presenting injuries or behaviours are seen in context. e.g., is the change in behaviour a result of a sudden illness, recent bereavement or exam anxiety?

When information is shared with you which causes concerns of possible abuse, your requirement is to accept the information being shared without influencing it, as well as providing support and reassurance to the child and managing expectations.


Staff and tutors should:

Staff and tutors should not:

When responding to a concern or disclosure of sexual violence or sexual harm, staff and tutors MUST NOT view or forward illegal images of a child.

You should complete and submit the Safeguarding Concern Form (found here) to the safeguarding team as soon as possible.

Once a disclosure has been made or a concern has been shared, the Designated Safeguarding Officer (or Deputy) will consider the information, if necessary, taking advice, and will make a decision to either:

Where a child is suffering, or is likely to suffer from harm, it is important that a referral to children’s social care (and if appropriate the police) is made immediately.

Once an incident of sexual violence or sexual harassment has been disclosed the Designated Safeguarding Officer (or Deputy) should make an immediate risk and needs assessment. This may be done with the school DSO. The risk and needs assessment should consider:

Once the decision is made to make a referral the Designated Safeguarding Officer (or Deputy) will contact the relevant Children’s Social Care Team and make a telephone referral. This must be followed up in writing within 24 hours.

Within one working day of a referral being made, a local authority social worker should acknowledge receipt to the referrer and make a decision about the next steps and the type of response that is required. This will include determining whether:

It is important to note that where tutors are delivering tuition to children and young people in a school or college, the MTW DSO/ Deputy must inform the school’s Designated Safeguarding Lead/ Officer.

7. Sharing Information

Effective sharing of information between MTW, schools, colleges, local authorities and other statutory services is essential for the early identification of need, assessment and intervention in order to keep children safe.

Fears about sharing information cannot be allowed to stand in the way of the need to safeguard and promote the welfare of children and young people identified as being ‘at risk of abuse or neglect’.

Personal information held by MTW is subject to a legal duty of confidentiality and will not normally be disclosed without the consent of a child’s parent/carer.  However, the right to confidentiality and respect for private and family life (Article 8, Human Rights Act, 1998) is not absolute.

The only exceptions to this are where confidentiality can be overridden either by a court order or other legal authority (e.g. Prevent Duty), or in the public interest i.e. in order to safeguard a child.

Public interest justifications usually relate to disclosures to prevent significant or serious harm to third parties or to prevent or to prosecute a serious crime. e.g. suicide pacts, terrorist threats.

MTW recognises that information sharing between key organisations is essential to safeguard children and young people at risk of abuse, neglect and exploitation.

MTW will ensure that where staff or tutors need to share special category personal data, they are aware that the Data Protection Act 2018 includes ‘safeguarding of individuals at risk’ as a condition that allows practitioners to share information without consent.

MTW will ensure that confidential information is only shared where it is lawful and ethical to do so. All staff and tutors must be clear about situations when they can share information with appropriate agencies i.e. when they believe a child is at risk of harm.

MTW staff and tutors will give due regard to relevant legislation and guidance when making decisions on sharing information including the following:

The Children’s Code

The Children’s Code (or the age-appropriate design code) is a statutory code of practice that articulates how online services likely to be accessed by children should comply with the UK GDPR when using children’s data. The code sets out 15 flexible standards that allow children to explore, learn and play online. It ensures that the best interests of the child are the primary consideration when designing and developing online services. The code standards are:

The concept of the best interests of the child comes from Article 3 of the United Nations Convention on the Rights of the Child (UNCRC). MTW is committed to working in the best interests of the child and ensures the use of their data does not have a negative impact on their rights under the UNCRC.

The code applies to ‘information society services likely to be accessed by children’, and contains practical guidance on how to share data fairly and lawfully, it does not impose any additional barriers to data sharing. MTW will use the code’s 15 standards to review and, where necessary, update our ongoing data sharing arrangements.  

8. Safeguarding Allegations Against Directors, Staff or Tutors

MTW recognises its duty to report concerns or allegations against its directors, staff, or tutors. All directors, staff and tutors must comply with the relevant Code of Conduct when performing their role in order to promote safer working practices.

Allegations of abuse against directors, staff or tutors can be made by either a child or an adult and should be made immediately to the DSO.  Allegations made against the DSO should instead be made to another member of the leadership team who will inform the other team members. Another suitable senior member of staff will then be appointed to take the place of the DSO in response to the allegation.

MTW recognises that there are two levels of allegation/concern as outlined in KCSIE 2021, Part 4, these are:

  1. Allegations that meet the harms threshold
  2. Allegations/concerns that do not meet the harms threshold – referred to as ‘low level concerns’.

MTW will deal appropriately and promptly with all allegations or concerns and refer all safeguarding concerns or allegations about its directors, staff or tutors immediately to the appropriate local authority designated officer (LADO) in accordance with local safeguarding procedures and practical guidance.

MTW is committed to creating and sustaining an open and transparent culture in which all concerns about adults (including allegations that do not meet the harms threshold) are shared responsibly with the right person, recorded and dealt with in accordance with our policies and procedures. This organisation wide approach to safeguarding will ensure we are able to identify concerning, problematic or inappropriate behaviour early; minimise the risk of abuse;  and ensure that adults working in or on behalf of MTW are clear about professional boundaries and act within these boundaries, and in accordance with the ethos and values of MTW.

It is a matter of policy that any director, staff member or tutor, against whom a safeguarding allegation is made, will be suspended without prejudice immediately pending investigation. This will be the case even if the allegation is not linked to their role or activity with MTW. Such instances will be rare occasions and any decision to suspend will not be taken lightly. The decision will be taken after full discussions with the Managing Director, in consultation with the HR Department.  

During any investigation of an allegation against a director, staff member or tutor suspended from the workplace, MTW recognises that it has a continuing duty of care. It will ensure a link person is nominated (not connected to the investigation) to provide support and guidance and be able to signpost those suspended to other external support networks. e.g. local trade union reps, Occupational Health, G.P., Samaritans etc.

DBS Requirement and Duty to Report

Under legal duties to make referrals to the Disclosure and Barring Service, MTW will report any concerns about unsafe practice by any of its directors, staff or tutors to the Disclosure and Barring Service (DBS).


If at any time MTW dismisses a director, member of staff or tutor due to relevant conduct, risk of harm or receiving a caution or conviction for a relevant offence (or the person has resigned or left that post in circumstances where they may have been removed), then a referral to the Disclosure and Barring Service will be made by the DSO.

9. What staff and tutors should do if they have concerns about poor or unsafe practices within MTW

Staff and tutors should feel able to raise concerns about poor or unsafe practice and potential failures in MTW’s safeguarding regime. Appropriate whistleblowing procedures, which are suitably reflected in staff and tutors’ induction, training and the code of conduct, are in place for such concerns to be raised with MTW’s leadership team.

Where a staff member or tutor feels unable to raise the issue with their manager or feels that their genuine concerns are not being addressed, other whistleblowing channels are open to them:

Also Refer to the Whistleblowing Policy and Code of Conduct.

10. Recruitment, Selection and Training

Recruitment and Selection

MTW is aware of its responsibility for ensuring that it carries out appropriate safer recruitment practices for all positions within the organisation. The Safeguarding Vulnerable Groups Act 2006 requires the organisation to carry out specific vetting (enhanced DBS and barred list checks) on staff or tutors if they work with children and young people.

In order to deter unsuitable individuals and inappropriate behaviour MTW will highlight the Safeguarding statement (see section 2) to tutors throughout the recruitment process.


MTW believes that training and raising awareness of safeguarding issues, policies and procedures is fundamental to the development and maintenance of a safer environment, safer organisation and safer staff/ tutors. It will ensure that appropriate safeguarding training is provided to all staff and tutors to assist them in:

Safeguarding training at the appropriate level to the role and responsibilities held will be a mandatory element of all inductions for staff and tutors. Furthermore, safeguarding training will not be regarded as a 'once only' activity, but as an ongoing development of skills and knowledge of safeguarding practices.

Monitoring the working practice of staff and tutors will be undertaken not less than once per year through the appropriate supervision mechanisms such as appraisals to ensure the requirements of this policy and supporting procedures are being met.

11. Complaints

If a complaint is identified as a potential safeguarding concern, then the Safeguarding Procedures will be followed.

12. Quality Assurance and Review

MTW is committed to striving for excellence in the provision of all its services. We do this by actively reviewing the safeguarding systems in place.

We use an electronic recording system to capture all relevant data that supports the evidencing and monitoring of compliance in safeguarding. This quality assurance mechanism is a crucial and integral part of the governance structure.

The leadership team will review the safeguarding policy and supporting procedures annually to ensure they continue to reflect legislation and guidance. Any amendments to the policy and supporting procedures will be submitted to the Directors for approval.

13. Underpinning Legislation and Guidance



This document is an update by the Safer Recruitment Consortium of a document previously published for schools by the Department for Education and Skills (DfES). It was initially issued as those working with children had expressed concern about their vulnerability and requested clearer advice about what constitutes illegal behaviour and what might be considered as misconduct. Education staff asked for practical guidance about which behaviours constitute safe practice and which behaviours should be avoided. This safe working practice document is NOT statutory guidance from the Department for Education (DfE); it is for employers, local authorities and/or the Three Safeguarding Partners to decide whether to use this as the basis for their code of conduct / staff behaviour guidelines.

An addendum was published in response to Covid-19 in April 2020.

Appendix A

MTW Safeguarding Concern Form

Appendix B

Guidance on completing the Safeguarding Concern Form

It is important that this concern form is fully completed in a timely manner. The details are important. To help the Designated Safeguarding team respond and refer appropriately you should follow the guidance below.

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