Safeguarding Policy

Safeguarding & Child Protection Policy · Version 1.0

Date of issue: 25 May 2026
Next review date: 25 May 2027
Designated Safeguarding Lead (DSL): Jack Powell (Head Tutor & Founder)
Deputy Safeguarding Lead: Connor O’Donnell (Business & Digital Operations)
Approved by: Jack Powell & Connor O’Donnell (Directors)

This policy applies to all staff, contractors, volunteers, and any individual acting on behalf of Clearmark Tutoring. It must be read, understood, and followed by everyone involved in the delivery of our services.

1. Policy statement

Clearmark Tutoring is committed to safeguarding and promoting the welfare of all children and young people who use our tutoring services. We recognise that safeguarding is everyone’s responsibility and that the welfare of the child is paramount.

This policy has been developed in accordance with the following statutory guidance and legislation:

Keeping Children Safe in Education (KCSiE) 2024 — Department for Education statutory guidance for schools and colleges. While private tutoring businesses are not directly bound by KCSiE, we adopt its standards as best practice.
Working Together to Safeguard Children 2023 — HM Government inter-agency guidance on safeguarding and promoting the welfare of children.
Children Act 1989 and 2004 — establishing the legal framework for child welfare in England and Wales.
The Education Act 2002 (Section 175) — duty to safeguard and promote the welfare of children.
Safeguarding Vulnerable Groups Act 2006 — governing the DBS barring scheme.
Counter-Terrorism and Security Act 2015 — Prevent duty guidance.
UK GDPR and Data Protection Act 2018 — governing the processing of personal data, including children’s data.

We will take all reasonable steps to ensure that children are protected from harm, abuse, and exploitation while in our care, whether sessions are delivered online or in person.

2. Scope

This policy applies to:

All tutoring sessions delivered by Clearmark Tutoring, whether online or in person
All directors, employees, contracted tutors, volunteers, and any individual working on behalf of the business
All students under the age of 18, including those with special educational needs and disabilities (SEND)
All communications with students, parents, and carers
All digital platforms and tools used in the delivery of sessions

3. Key safeguarding principles

We operate on the following principles, drawn from Working Together to Safeguard Children 2023:

The welfare of the child is paramount. Every decision we make prioritises the child’s safety and wellbeing.
Safeguarding is everyone’s responsibility. All individuals associated with Clearmark Tutoring are responsible for identifying and responding to safeguarding concerns.
A child-centred approach. We listen to children, take their views seriously, and act in their best interests.
Early identification and intervention. We are vigilant to signs of abuse, neglect, or exploitation and will act promptly on concerns.
Information sharing. We will share safeguarding information with relevant agencies when necessary to protect a child, in accordance with data protection law.

4. Designated Safeguarding Lead (DSL)

The Designated Safeguarding Lead for Clearmark Tutoring is Jack Powell, Head Tutor & Founder.

The DSL is responsible for:

Taking the lead on all safeguarding concerns and referrals
Liaising with the local authority children’s services (Wirral LADO, Liverpool MASH, or the relevant local authority for the child’s home area)
Maintaining secure safeguarding records
Ensuring all staff and contractors receive appropriate safeguarding training
Ensuring this policy is reviewed and updated annually
Acting as the primary point of contact for parents, carers, and external agencies on safeguarding matters

The Deputy Safeguarding Lead is Connor O’Donnell. Connor will act in Jack’s absence and is responsible for ensuring safeguarding procedures are followed in relation to business operations, data handling, and digital platform security.

Contact for safeguarding concerns: info@clearmarktutoring.co.uk

5. Safer recruitment and DBS checks

Clearmark Tutoring is committed to safer recruitment practices. All individuals who have direct contact with children, or who have access to children’s personal data, must undergo the following checks before commencing work:

5.1 Required checks

Enhanced DBS check with barred list check. All tutors and any individual who will have unsupervised contact with children must hold a current Enhanced DBS certificate checked against the children’s barred list. DBS certificates will be obtained through an approved umbrella body or the DBS Update Service.
Identity verification. Original identity documents will be verified in person or via certified copies before engagement.
Qualification verification. Original qualification certificates (QTS, PGCE, degree certificates) will be verified for all tutors.
Right to work. All individuals will provide evidence of their right to work in the UK.
References. Two professional references will be obtained for all tutors, at least one from their most recent employer or educational institution. References will specifically ask about the individual’s suitability to work with children.
Self-declaration. All individuals will complete a self-declaration form confirming they are not disqualified from working with children under the Childcare (Disqualification) Regulations 2018.

5.2 Ongoing monitoring

DBS checks will be renewed every three years, or more frequently if the individual subscribes to the DBS Update Service (recommended).
Any change in circumstances that may affect an individual’s suitability to work with children must be reported to the DSL immediately.
A single central record of all DBS checks, training dates, and qualifications will be maintained securely by the DSL.

6. Recognising and responding to safeguarding concerns

6.1 Types of abuse and neglect

All staff and contractors must be aware of the four main categories of abuse, as defined in Working Together to Safeguard Children 2023:

Physical abuse: deliberately causing physical harm to a child, including hitting, shaking, burning, or otherwise causing physical injury.
Emotional abuse: persistent emotional maltreatment causing severe and adverse effects on a child’s emotional development, including conveying to a child that they are worthless, unloved, or inadequate.
Sexual abuse: forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening, including non-contact activities such as viewing sexual images.
Neglect: persistent failure to meet a child’s basic physical or psychological needs, likely to result in serious impairment of the child’s health or development.

Staff must also be aware of specific safeguarding issues including (but not limited to): child sexual exploitation (CSE), child criminal exploitation (CCE), county lines, online abuse, peer-on-peer abuse, so-called ‘honour-based’ abuse, forced marriage, female genital mutilation (FGM), radicalisation and extremism, and domestic abuse affecting children in the household.

6.2 What to do if you have a concern

If any member of Clearmark Tutoring has a safeguarding concern about a child, they must:

Listen carefully and calmly. Do not question the child or investigate. Allow them to speak freely. Do not promise confidentiality — explain that you may need to share information to keep them safe.
Record the concern immediately. Write down exactly what was said or observed, using the child’s own words where possible. Record the date, time, and context. Do not include opinions or interpretations — record facts only. Use the Clearmark Tutoring Safeguarding Concern Form (Appendix A).
Report to the DSL without delay. Contact Jack Powell (DSL) immediately. If Jack is unavailable, contact Connor O’Donnell (Deputy DSL). Do not discuss the concern with anyone other than the DSL/Deputy DSL.
DSL will assess and act. The DSL will assess the concern and determine the appropriate course of action, which may include: monitoring the situation and recording further observations; contacting the child’s parents or carers (unless doing so would place the child at further risk); making a referral to the local authority children’s services; or contacting the police in the event of an immediate risk to the child.

6.3 Referral routes

The DSL will make referrals as follows, depending on the child’s home local authority:

Wirral: Wirral Integrated Front Door (IFD) — 0151 606 2008. Out of hours: Emergency Duty Team — 0151 677 6557.
Liverpool: Liverpool MASH (Multi-Agency Safeguarding Hub) — 0151 233 3700. Out of hours: Careline — 0151 233 3700.
Other local authorities: The DSL will contact the relevant local authority children’s services via their published referral route.
Police: If a child is in immediate danger, call 999. For non-emergency concerns, call 101.
NSPCC Helpline: 0808 800 5000 (for adults who are concerned about a child).
Childline: 0800 1111 (for children and young people).
LADO (Local Authority Designated Officer): For allegations against staff. Wirral LADO — 0151 666 4582. Liverpool LADO — 0151 233 1985.

6.4 Allegations against staff

If a safeguarding allegation is made against any member of Clearmark Tutoring (including the founders), the following procedure applies:

The allegation must be reported immediately to the LADO in the relevant local authority. The LADO will advise on next steps.
If the allegation is against the DSL (Jack Powell), Connor O’Donnell must report directly to the LADO without consulting Jack.
The individual against whom the allegation is made will be suspended from all contact with children pending the outcome of the LADO investigation.
The business will cooperate fully with any investigation by the LADO, police, or children’s services.
Clearmark Tutoring will not carry out its own investigation into the allegation. Investigation is the responsibility of the LADO and/or police.
Accurate records of the allegation, all actions taken, and the outcome will be maintained securely for the duration required by the LADO’s guidance (a minimum of the individual’s working life plus 10 years, or until the individual reaches age 75, whichever is longer).

7. Online safety and virtual sessions

Clearmark Tutoring delivers tutoring sessions online. The following safeguards apply to all virtual sessions:

7.1 Session conduct

All online sessions will be delivered via a reputable, encrypted video conferencing platform (e.g. Zoom, Google Meet, or Microsoft Teams) with password-protected meeting rooms.
Session links will be shared only with the student and their parent/carer. Links will not be reused across different students.
Tutors must deliver sessions from a professional, appropriate setting. Backgrounds should be neutral and free from personal or inappropriate content.
Students must be in a shared family space where a parent or carer is within earshot, wherever reasonably practicable. For students under 13, a parent or carer must be present in the room or within immediate earshot at all times.
Sessions will not take place in a student’s bedroom unless no alternative is available and the parent/carer has given written consent and is within earshot.
Screen-sharing will only be used for educational purposes.
Chat functions should be used only for educational content during sessions. Any concerning messages will be reported to the DSL.

7.2 Recording of sessions

Online sessions may be recorded for safeguarding purposes. The following conditions apply:

Parents/carers will be informed that sessions may be recorded, and written consent will be obtained at enrolment.
Recordings are made solely for safeguarding protection — to protect both the student and the tutor.
Recordings will be stored securely on an encrypted platform and will be accessible only to the DSL and Deputy DSL.
Recordings will be retained for a maximum of 30 days and then automatically deleted, unless they are required in connection with a safeguarding concern, complaint, or investigation, in which case they will be retained for the duration required.
Recordings will not be shared with any third party unless required by law, a safeguarding investigation, or a court order.
Parents/carers may request that sessions are not recorded, in which case a parent/carer must be present in the room or within earshot for the duration of the session.

7.3 Communication with students

All communication with students under 18 must be through official business channels (business email, the video platform, or a business WhatsApp number). Personal phone numbers and personal social media accounts must never be used.
Parents/carers must be copied on or have access to all written communications with their child.
1-to-1 messaging with students (e.g. WhatsApp, text) should be avoided. Where it is necessary (e.g. rescheduling), the parent/carer must be included in the conversation.
Staff must not connect with students on personal social media accounts.

8. In-person session safeguards

When in-person sessions commence (from September 2027), the following additional safeguards apply:

For sessions in the student’s home, a parent or carer must be present in the property at all times. The tutor must never be alone in a closed room with a child without the parent’s knowledge and proximity.
For sessions at a hired venue, the venue must be appropriate for working with children (adequate supervision, accessible, DBS-checked staff at the venue if applicable).
Tutors must carry their DBS certificate and photo ID to all in-person sessions and make them available to parents upon request.
Any physical contact with students is prohibited except in an emergency (e.g. first aid).
If a session takes place in a public venue, the tutor must ensure the student is collected by the designated parent/carer or authorised adult before leaving.

9. Photography and use of images

Photographs or video recordings of students will not be taken without prior written consent from the parent/carer.
If photographs are taken for marketing purposes (e.g. website, social media), a separate Photography Consent Form must be signed.
Students will never be identified by name alongside a photograph without explicit written consent.
Screenshots of online sessions will not be taken.
If a student appears in the background of marketing content (e.g. a boot camp group photo), parental consent must be obtained before use.

10. Prevent duty

Clearmark Tutoring is aware of its responsibilities under the Counter-Terrorism and Security Act 2015 (Prevent duty). While the statutory Prevent duty applies to specified authorities (including schools), we adopt the following as best practice:

All tutors will be trained to recognise signs of radicalisation and extremism.
Any concerns about a child being drawn into extremism will be reported to the DSL, who will follow the referral route set out in Section 6.3 and, if appropriate, contact the local Prevent team or the national Prevent helpline (0800 011 3764).
We will promote British values of democracy, the rule of law, individual liberty, and mutual respect and tolerance.

11. Training

All tutors and staff must complete recognised safeguarding training before commencing work with Clearmark Tutoring. As a minimum, this must include Level 2 Safeguarding Children training from a recognised provider (e.g. EduCare, NSPCC, or equivalent).
The DSL (Jack Powell) must complete DSL-level safeguarding training, renewed every two years.
Prevent awareness training must be completed by all tutors and staff.
Annual safeguarding refresher training is mandatory for all individuals working with children.
Training records (including dates, provider, and certificate references) will be maintained on the single central record.

12. Record-keeping and confidentiality

All safeguarding records will be stored securely, separately from general student records, and accessible only to the DSL and Deputy DSL.
Electronic safeguarding records will be password-protected and encrypted.
Physical records (if any) will be stored in a locked cabinet accessible only to the DSL and Deputy DSL.
Safeguarding information will only be shared on a strictly need-to-know basis, in the best interests of the child, and in accordance with data protection legislation.
Safeguarding records will be retained in line with IRMS (Information and Records Management Society) guidance: records relating to safeguarding concerns will be retained for the duration of the individual’s involvement with the business plus 25 years, or until the child reaches age 25, whichever is longer.

13. Whistleblowing

Any individual who has concerns about the conduct of a colleague, contractor, or either of the founders in relation to safeguarding should:

Report concerns to the DSL (or Deputy DSL if the concern is about the DSL).
If they are not satisfied with the response, or if the concern involves both founders, report directly to the LADO in the relevant local authority.
Contact the NSPCC Whistleblowing Helpline on 0800 028 0285 if they feel unable to raise concerns internally.

Clearmark Tutoring will not tolerate any retaliation against individuals who raise safeguarding concerns in good faith. Whistleblowers are protected under the Public Interest Disclosure Act 1998.

14. Use of mobile phones and personal devices

Tutors’ personal mobile phones must not be used to contact students directly. All communication must go through business channels.
Personal devices must not be used to photograph or record students.
If a tutor uses a personal device to deliver online sessions (e.g. a personal laptop), the device must be password-protected and have up-to-date antivirus software.
Students’ personal data must not be stored on personal devices. All student data must be stored on secure, encrypted business platforms.

15. Policy review

This policy will be reviewed annually by the DSL and Deputy DSL, or sooner if there is a change in legislation, statutory guidance, or following a safeguarding incident.

The review date is recorded at the top of this document. Any updates will be communicated to all staff and contractors.

16. Contact

If you have a safeguarding concern about a child involved with Clearmark Tutoring, please contact us immediately at info@clearmarktutoring.co.uk.

If a child is in immediate danger, call 999.