Spires’ Safeguarding Policy
Introduction
Spires is an online platform that connects experienced and reputable self-employed private tutors with prospective students, companies and institutions.
We do not maintain educational premises, and we do not hold or arrange events at which children are likely to be present. The tutors we work with are not employed by our company, and are responsible for the conduct of their own tutoring. All of the tutoring arranged through our platform takes place online.
Scope
This policy is intended to promote the welfare of young people (used to refer to any minors, including children) or otherwise vulnerable persons who use our services, and the children of adult service-users. It is also intended to act as a guide for the self-employed tutors we represent, introduce or work with in any other legitimate manner, to help them follow our approach to safeguarding.
This policy applies to anyone working with or on behalf of our company, including senior managers, directors, employees, contractors and tutors. We expect any tutor, mentor, coach or other individuals who we introduce (including where we act as an employment agency) to comply with this policy, wherever possible and appropriate, and to take prompt and effective action in the event of a safeguarding concern arising.
Legal Framework
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in the United Kingdom. However, it is understood and intended that this policy will apply to our employees, agents, contractors and other connected parties wherever they work across the world. In this event, we expect the policy to be followed to the fullest extent permissible in any given jurisdiction, with the intention of safeguarding children and young people. Where we operate outside of the UK we undertake to:-
Comply with local laws, regulations, instructions from law enforcement agencies, rulings by any legitimate judicial authority or similar;
Refer any matters of criminal conduct, especially in relation to safeguarding, (as applicable in the local jurisdiction) to the local authorities responsible for policing and law enforcement;
Wherever local legislation permits, or is ambiguous or indifferent (for example, but not limited to, activity in disputed territories, activities ongoing during a change of government or political structure and activities taking place when local legislation is amended, added to or repealed), we undertake to follow this guidance to the fullest extent possible in order to safeguard children, young people and vulnerable adults (according to the broadest definition applied by either local or UK legislation).
A summary of the key UK legislation and guidance is available from nspcc.org.uk/childprotection.
Supporting Documents
This policy statement should be read alongside our Terms and Conditions and Privacy Policy, and the following policy documents, included as appendices:
Role description for the nominated safeguarding lead
Recruiting the right people to volunteer or work with children
Responding to concerns about a child's welfare
Storing child protection records
Code of conduct for all staff, contractors and tutors
Managing concerns about or allegations made against staff or tutors
Managing concerns about or allegations made against a child or young person
Keeping children safe online
Whistleblowing and complaints
We recognise that:
The welfare of children is paramount in all the work we do and in all the decisions we take.
Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.
All children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse.
Some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues.
Extra safeguards may be needed to keep children who are additionally vulnerable safe from abuse.
Adults may also be vulnerable, for a variety of reasons including (but not limited to) age and disability, and are deserving of the same care, attention and protection.
We will seek to keep children and young people safe by:
Valuing, listening to and respecting them.
Appointing a nominated child protection lead for children and young people.
Adopting child protection and safeguarding best practice through our policies, procedures and code of conduct for staff, contractors and tutors.
Developing and implementing an effective online safety policy and related procedures.
Providing effective management for staff, contractors and tutors through supervision, support, training and quality assurance measures so that all staff and tutors know about and follow our policies, procedures and behaviour codes confidently and competently.
Contact details
Nominated safeguarding lead:
Name: Vyvyan Almond
Role: Head of Policy
Phone: 0203 905 5272
Nominated deputy safeguarding lead:
Name: Rosie Holme
Role: Tutor Manager
Phone: 0208 138 4440
NSPCC Helpline
0808 800 5000 - Open 10am-4pm Monday to Friday
If a child, young person, or any person is in immediate danger, call 999 (for a person in the UK).
This policy, and our good practice, will be reviewed annually.
This policy was last reviewed on: 14/01/25
Role Description For The Nominated Safeguarding Lead
Purpose of the Role
To take the lead in ensuring that appropriate arrangements for keeping children and young people safe are in place at the company.
To promote the safety and welfare of children and young people involved in the company’s activities at all times.
Duties and responsibilities
Take a lead role in developing and reviewing the company’s safeguarding and child protection policies and procedures.
Take a lead role in implementing Spires’ safeguarding and child protection policies and procedures: ensuring all safeguarding and child protection issues concerning children and young people who take part in Spires’ activities are responded to appropriately.
Make sure that everyone working with or for children and young people at Spires, including the board of directors, understands the safeguarding and child protection policy and procedures and knows what to do if they have concerns about a child’s welfare.
Make sure children and young people who use the company’s services, and their parents, know who they can talk to if they have a welfare concern and understand what action the organisation will take in response.
Receive and record information from anyone who has concerns about a child who uses the company’s services, and ensure reports are stored securely.
Take the lead on responding to information that may constitute a child protection concern, including a concern that an adult involved with Spires may present a risk to children or young people. This includes: assessing and clarifying the information - not investigating
making referrals to statutory organisations as appropriate
consulting with and informing the relevant members of the organisation’s management
following the organisation’s safeguarding policy and procedures.
Liaise with, pass on information to and receive information from statutory child protection agencies such as: the Local Children's Safeguarding Board (LSCB)
the Local Authority Designated Officer (LADO)
the police.
This includes making formal referrals to agencies when necessary.
Consult the NSPCC Helpline when support is needed, by calling 0808 800 5000 (10am-4pm, Mon-Fri) or emailing [email protected].
Store and retain child protection records according to legal requirements and the organisation’s safeguarding and child protection policy and procedures.
Work closely with the company directors to ensure they are kept up to date with safeguarding issues and are fully informed of any concerns about organisational safeguarding and child protection practice.
Report regularly to the company directors on issues relating to safeguarding and child protection, to ensure that child protection is seen as an ongoing priority issue and that safeguarding and child protection requirements are being followed at all levels of the organisation.
Be familiar with and work within inter-agency child protection procedures developed by the local child protection agencies.
Be familiar with and work within inter-agency child protection procedures developed by any educational settings we work in (e.g. schools) and share these with Spires staff working in those places - seeking the name and contact details of the safeguarding lead in the setting and how to report any concerns, then sharing this with Spires staff before they start work. Make the setting aware that Spires also have safeguarding policies and part of working together means that as well as reporting concerns to them, staff may make reports to Spires as well, and these may be passed on to other authorities. Share DBS status of staff/contractors/tutors with any settings they may go to work in - this should be made clear to all staff/contractors/tutors when working for Spires.
Be familiar with issues relating to child protection and abuse, and keep up to date with new developments in this area.
Attend training in issues relevant to child protection and share knowledge from that training with everyone who works with or for children and young people at Spires.
Attend team meetings, supervision sessions and management meetings as arranged.
Responding To Concerns About The Welfare Of A Child Or Vulnerable Adult
Spires take safeguarding seriously and staff will be trained to notice signs where the welfare of a young person or vulnerable adult may be at risk. Staff, contractors and tutors for Spires should report their concerns directly to the safeguarding lead and/or deputy lead ([email protected]).
It is important to remember that perpetrators can be adults but they can also be other young people - there is no specific identity of a perpetrator.
Any concerns should be reported without delay to allow thosereporting to make the most accurate report of what raised the concern - delaying making a report can lead to forgotten or altered details.
All concerns should include only the facts of what raised the concern. Assumptions or interpretations should not be included. For example, if a person was crying the report should state that they were crying, not that they were sad or upset as this is an interpretation of the situation.
If there are concerns about a young person or vulnerable adults, or a disclosure is made by them, it should be taken seriously and listened to. It is important not to ask leading questions, any questions should be very open and not suggestive of anything. For example, if they say "[name] hurt me yesterday", responding "did they hit you?" would not be appropriate, but repeating back "hurt you?" would allow the person to respond openly in their own words.
It is very important to never promise to keep things secret, or not to tell others. Instead, we should be open with young people and vulnerable adults so that they can talk to us, but if we have concerns for their welfare, we might have to talk to others. It should be made clear that this will only be done with a view to keeping them safe and getting them support.
It is rare that we can be 100% sure that something is or is not taking place, but it is not our place to investigate. The role of those working with children is to be aware of the signs that welfare may be at risk and to report those concerns to those with the authority and experience in doing so - such as the Local Children's Safeguarding Board or the police. In this way, we safeguard children and allow any investigations to be done through the proper channels.
Who to report to
Who to report concerns to will depend on the situation.
Reports about concerns raised whilst working in the capacity of staff or contractors with Spires can be made directly to the safeguarding lead and deputy lead. This should be done by completing the form and sending it securely to the safeguarding email address (or handed directly to the safeguarding lead/deputy lead if seeing them in person).
If working through Spires, but in a school, college or other educational setting, their internal safeguarding procedures should be followed and a report to Spires should be made as normal. This should be shared with the safeguarding lead at the setting so that they are aware.
Tutors who work with young people or vulnerable adults - online or in person (including in a family-based residential setting) - are encouraged to report directly to the Local Children's Safeguarding Board (LCSB) where the young person or vulnerable adult lives, and/or report to the NSPCC helpline on 0808 800 5000 (Mon-Fri, 10am-4pm). If the person they are concerned about lives abroad, they should try to contact the local authorities where that person lives as this is where the concern will need to be dealt with.
Note that there are some occasions where the police should be contacted, as well as reports being made. If there is reason to believe the young person or vulnerable adult is in immediate danger, the police can be contacted. A report should be made in the usual way to safeguarding leads/bodies, but the police can be contacted in order to protect that person from harm.
If it is ever unclear about who to report to, or how, instead of leaving the concern unreported, it is important to check. For staff/contractors/tutors of Spires, this can be the safeguarding lead or deputy lead. For those who work for themselves, this can be checked with the NSPCC helpline.
Storing Child Protection Records
The introduction of GDPR does not change the way child protection records should be stored. The Spires team will follow the guidance for storing data - outlined by the NSPCC.
When Spires works with others (including young people and vulnerable adults, and their carers), Spires may collect and store data about these people in order to reasonably provide services.
Additionally, some data may be collected for the purposes of child protection - this is to protect the young people concerned. It should be noted that in these cases, data may be shared with appropriate agencies or authorities such as the Local Children's Safeguarding Board (LCSB), or the police. This will only ever be shared for the purpose of safeguarding.
Personally identifiable data may be kept by Spires for as long as is necessary and appropriate to carry out business and provide a service. After this time, as per GDPR, users can request their data be deleted. However, data relating to child protection may be kept for longer.
In such cases, Spires will keep data for as long as is appropriate to retain the data. Generally, educational settings keep records until any person turns 25.
All physical records will be securely stored - locked away in a secure space that only the safeguarding team can access. And digital records will be stored in password-protected folders on computers with password protection and software to prevent hacking and viruses.
Preventing And Responding To Bullying
We recognise that bullying can take many forms. Anyone can engage in bullying behaviour and anyone can be bullied. It is important to remember that perpetrators can be adults but they can also be other young people - there is no specific identity of a perpetrator.
When trying to prevent bullying, it is important to make it clear to others that we treat them equally and without judgement and to teach them that this is how everyone should be treated. The Spires staff, contractors and tutors will always treat others, with respect - regardless of their identity.
If bullying is seen or disclosed it will be reported as a safeguarding concern to the relevant person. For example, the safeguarding lead at Spires, or for the educational setting they are in.
Keeping Children Safe Online
We recognise some of the work we do with young people takes place online, and that keeping young people safe online is equally as important as keeping them safe in person.
One of the key things Spires does is to only ever interact with the young people and vulnerable adults using their services through agreed means and times - arranged through a responsible adult - for example, a parent or carer, or through a school representative. Note that an adult may have vulnerabilities but still be able to arrange their own tuition - this should be considered when booking.
Staff, contractors and tutors of Spires will not contact young people or vulnerable adults using their services through social media platforms or through their own personal profiles. The only time staff, contractors or tutors will talk to young people or vulnerable adults through social media is if they contact Spires’ company profiles in order to seek support or ask about their services.
Spires will also advise tutors connecting to families through Spires to follow this guidance.
Spires uses Not Safe For Work (NSFW) AI systems to check all resources shared with or sent to young people and vulnerable adults to ensure they are appropriate. Content should not include anything which could harm young people or vulnerable adults, or expose them to harm. For example, anything depicting illegal activity, violence or extreme views.
Recruiting The Right People To Volunteer Or Work With Children
All staff, contractors and tutors working with Spires will be considered for recruitment without discrimination to their identity (race, sex, gender, age, disability, pregnancy/maternity, religious belief, or sexual orientation).
Spires engages in work with young people and vulnerable adults - a criminal background check is required by all employees and contractors. This will be indicated in any advertisements.
Tutors connected to families through Spires are directed to seek criminal background checks.
After the checks, applicants are required to provide at least two references who can be contacted. If the role is working directly with children, at least one referee should be for a role where the applicant has worked or volunteered with children.
Applicants will be given an opportunity to declare any prior convictions including any child protection investigations - regardless of their outcome. This can be written and delivered in a confidential way - for this to be reviewed by the safeguarding team at Spires.
ID will be required from applicants to confirm identity - these should be viewed in person wherever possible as this helps to check the authenticity of the documents.
The criminal background checks required for staff, contractors and tutors include:
A DBS check - note that an enhanced check is required for anyone who will or may have direct contact with young people. These checks should be put on the update service so that Spires can check their status periodically - if a check is not on the update service, a new one will be required every year.
An overseas police check for any staff, contractors or tutors who have lived abroad in the past 5 years.
Please note that a DBS check is not used to check the right to work in the UK - this is done separately.
Codes Of Conduct For All Staff, Contractors And Tutors In Relation To Safeguarding
All staff, contractors and tutors working with Spires are expected to follow the general code of conduct laid out by company policy.
With regards to safeguarding this includes:
Engaging with safeguarding policies laid out by Spires - including attending training when it is offered.
Complete a criminal background check as laid out in Spires' safeguarding policy.
Treating all service users (regardless of age or other identifiers) with equal respect.
Not contact service users from personal accounts - including online communication (e.g. emails and social media), or in person.
If staff, contractors or tutors have an existing personal relationship with any service users or their families/carers, this should be declared to management and safeguarding staff as soon as is possible. We understand that not having contact with existing friends or family would not be possible, but by declaring any connections, we can be aware that communication may occur.
staff, contractors and tutors with Spires must not have a sexual or romantic relationship with any young person under the age of 18. They should also not start such a relationship with a service user when the user turns 18 after contact with them prior to their birthday.
When tutoring young people or vulnerable adults in their homes (online or in-person), the tutorials should ideally take place in a communal space (for example, a living room, kitchen or office) - this should ideally be a quiet and calm space, but one which others could access if they wanted to check-in.
When tutoring young people or vulnerable adults online, this should be arranged through a responsible adult such as their parent, carer or teacher. That adult should have the time and date of the tutorial, and a link to join. They do not need to join for the length of the tutorial but this allows them to check in on the tutor and student should they wish to. Adults responsible for the welfare of a child should never be prevented from being able to access a tutorial if they wish to do so.
The contents of a tutorial should be kept confidential from others (other than where there is a lawful reason for the contents to be shared, e.g. if the tutor genuinely believes that one or more persons is at risk, or may be at risk, of harm).
Live online tutorials will be recorded. Any recordings will be securely stored for one year, after which time they are automatically deleted. They will be provided to those requesting them, and a record that the tuition is being recorded would be made for transparency. Recordings will always be made available to the client on request, other than where doing so is reasonably believed to increase the risk of harm to any person (in which case, Spires will take appropriate action, in line with this policy).
The person providing an online tutorial should be in a secure space and should be alone - not caring for or joined by others. If part of the tutorial includes another person being with them or joining the call, this must be communicated ahead of time to the client cooking the call. For example, a colleague who joins the tutorial to provide specific information about a topic.
Staff, contractors and tutors are encouraged to speak to management and the safeguarding team at Spires if they are ever unclear about matters of conduct. It is better to have a conversation ahead of time and clarifying anything they are unclear about.
Any and all devices used by staff, contractors and tutors of Spires which are used to carry out business on behalf of the company may be recalled or checked. Company devices can be recalled and checked at any time. Personal devices used for business purposes may be requested as part of an investigation by an independent authority, e.g. police. Where tutors use their own devices when delivering tuition through, or via an introduction from Spires, they consent for those devices to be investigated as part of any necessary safeguarding investigation by relevant authorities or agencies.
Any devices used to carry out online tutorials should have antivirus software and anti-malware software installed.
Whistleblowing Policy For All Staff, Contractors And Tutors In Relation To Safeguarding
When reporting safeguarding concerns it is important to follow the proper procedures.
When working with Spires, this means that reports should be made by any responsible adult through the reporting procedure laid out in this policy - reporting to the safeguarding lead and/or deputy lead. Staff, contractors and tutors are welcome to ask the safeguarding team for updates on what they have done. The team are not obliged to share specific details of actions taken but can share whether the report has been acted upon or referred internally or to external authorities/agencies. If a report has not been acted on or referred to relevant authorities and the staff member/contractor feels it should have been, another report can be made and a discussion should be held with the safeguarding team. Staff, contractors and tutors are encouraged to have discussions with the team as they may be aware of more information than the staff member/contractor. Again, the team will not necessarily share specifics as these may be confidential but will aim to have a discussion around the concern raised and explain the actions taken.
If the staff member or contractor still has concerns, the child protection report should be made to the Local Children's Safeguarding Board (LCSB) where the young person lives (or the relevant board if the concern is about a vulnerable adult (in other jurisdictions the relevant authority will vary). At this time, the staff or contractor may tell the board that they did make a report to Spires but they feel it hasn't been passed along appropriately. This will help to ensure the report is passed along securely to the appropriate authorities.
It is not appropriate to go directly to the media or to post on social media. This will be treated as whistleblowing, in line with Spires’ general company whistleblowing policy and may result in disciplinary action and/or dismissal.
Managing Concerns About Or Allegations Made Against Staff, Contractors Or Tutors
Allegations made against staff, contractors or tutors at Spires will be taken seriously.
All allegations against staff, contractors and tutors will be passed along to independent authorities to investigate - for example, the Local Children's Safeguarding Board (LCSB) - and the person the allegation has been made against may be suspended from their duties whilst the authorities investigate. Advice on this will be taken from the LCSB or other authorities who have been notified.
Whilst any investigations are taking place (by the relevant independent authorities) other staff, contractors and tutors will not be informed of the nature of why the person is not working - this is to maintain confidentiality and allow the proper investigations to take place. If the authorities need to talk to other staff, contractors or tutors, this should be kept confidential.
Any allegations proven to be truthful will lead to disciplinary action or dismissal - dependant on the nature of the allegation and any historical incidents. Again, advice will be sought from the relevant authorities. Any truthful allegations may be passed on to future employers seeking a reference.
Any allegations proven to be false will remain on a record but the outcome of any and all independent investigations will be included with it.
It is important that any and all allegations are taken seriously and investigated fully by the appropriate authorities. This ensures that we uphold our duty to safeguard young people. It also helps to ensure that any false allegations are investigated and the truth can come out - clearing the name of the person concerned.
Managing Concerns About Or Allegations Made Against Other Young People Or Vulnerable Adults
We recognise that perpetrators can be adults but they can also be other young people - there is no specific identity of a perpetrator.
If an allegation is made against a young person or vulnerable adult it will be reported as a safeguarding concern to the relevant person. For example, the safeguarding lead at Spires, or for the educational setting they are in. In some cases, it will be necessary to refer the matter to external authorities or agencies, such as social workers, the police or international authorities.
It is important that any and all allegations are taken seriously and investigated fully by the appropriate authorities. This ensures that we uphold our duty to safeguard young people. It also helps to ensure that any false allegations are investigated and the truth can come out - clearing the name of the person concerned.
