Our safeguarding policy and procedures have been created in line with the NSPCC’s safeguarding checklist. This version was updated in August 2020. The next update is due in August 2021.
This document covers the following safeguarding areas:
Third Space Learning (TSL) works with children, teachers and schools through one-to-one online maths tuition.
The purpose of this policy statement is:
This policy statement applies to anyone working on behalf of Third Space Learning, including senior managers and the board of trustees, the tutors we employ through our subsidiary, Third Space Global and third party tutor centres, paid staff, volunteers, sessional workers, agency staff and students.
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in the UK and internationally, namely:
We believe that:
We recognise that:
We will seek to keep children and young people safe by:
Alongside adhering to best practice safeguarding measures, TSL is set up to provide additional built-in safeguards compared to most teaching, and organisations working with children:
We recognise that these additional safeguards do not mean that TSL can ignore or be complacent about other elements of safeguarding best practice. The rest of this document highlights these other elements of safeguarding best practice.
The training will use examples, wherever possible, from both teachers at schools in the UK and anonymised recordings from our own tuition sessions.
We are committed to regular child protection training for all other staff (non-tutors), and have a regular feedback process to allow for opportunities to reflect on practice. We hold an annual training session with all staff after every annual review of our safeguarding policies and procedures.
The vast majority of TSL’s interactions with children come through our online one-to-one maths tuition. These sessions have a teacher or staff member present in the room at the same time as the sessions, in a role TSL call the Timeslot Supervisor. As such, TSL’s services do not fall under the definition of a ‘regulated activity’ (as defined by the UK government’s Keeping Children Safe in Education (KCSIE) document).
There can be exceptions where a teacher or member of staff is not present: for example if a pupil is asked to study from home as a measure to manage Coronavirus infection. In these cases, the parent or carer would be the Timeslot Supervisor and, as an additional measure, we train our tutors and have procedures that allow us to react in the event that a safeguarding issue arises and we can’t contact the Timeslot Supervisor.
The Timeslot Supervisor has the primary responsibility for the welfare and safety of a child during sessions. This is in-line with most schools’ policies and makes the most sense (they are, unlike our tutors, physically present in the room and better know how to bring help in the event of danger.)
There are 3 scenarios where the Timeslot Supervisor might be involved in a child safeguarding issue during a tuition session are:
In each case, we expect the Timeslot Supervisor to follow their own safeguarding policy and procedures and, in the event, an allegation is made against a tutor, that they notify Third Space Learning as soon as practical. Third Space Learning will then follow our procedure to deal with an allegation made against a staff member/tutor.
Should a child disclose, during a session, information that leads the tutor to reasonably believe that the child may be a victim of abuse, the tutor will record everything said and “Red Flag” the incident immediately for action by our UK Support team/Designated Safeguarding Officer and follow the guidelines given to the tutor during safeguarding training. (This training, in line with UK safeguarding guidance, is not to be judgemental/sound shocked/display emotion but to allow the child to explain in their own words whatever is upsetting them). The UK Support team will then follow the Procedure for children at possible risk of abuse.
“Red Flag” is a system whereby a tutor notifies the UK Support Team that a session being delivered requires review and sign-off. Reasons for a tutor to raise a “Red Flag” include the tutor suspecting a potential safeguarding incident; but also having issues or concerns about child behaviour (i.e. uncooperative, rude etc) or that the tutor has made a mistake in teaching the lesson. When a Red Flag incident is related to child protection then it acts as ‘our cause of concern’ form.
Once received from the Tutor (via the Red Flag process), TSL will report a child protection issue concern first to the pupil’s class teacher (as indicated on the TSL platform) as soon as practical and normally within 24 hours of the incident. We commit to working with that teacher, or a designated contact from the school, to provide any information we have that relates to child protection issues. We will not, ordinarily, make our initial contact with social services, or the police, about safeguarding concerns.
We believe this school-first approach is best, in most circumstances, because the pupil’s teacher is much better placed to investigate any child protection concerns. They have a better relationship with the pupil, have lots more context than a tutor can gain over a voice-only internet connection and will be better able to provide the child an encouraging environment in which to talk. Furthermore, in the event that the school decides the local authority or police need to be involved, then they are likely to already know the best people to contact.
The exceptions where we might not deal with the school in the first instance include:
TSL will ensure a written record is made and kept of the incident and our actions, alongside a digital copy of all relevant online tuition sessions. This will be done in accordance with our Child protection records retention and storage policy. The school involved in the incident will be given a copy of these records.
Furthermore, TSL is responsible for reviewing and updating, where necessary, our safeguarding policies and procedures to ensure it is in line with latest safeguarding advice and legislation. In addition TSL will ensure we have a written behaviour code and that all staff have read and agreed to.
This policy statement should be read alongside our organisational policies and procedures, including:
Designated Safeguarding Officer
Name: Jenni Hoy
Phone/email: 0203 771 0096 / jenni.hoy@thirdspacelearning.com
Deputy child safeguarding lead
Name(s): Bryan Tookey
Phone/email: 0203 771 0094 / 07926 223 751 / bryan.tookey@thirdspacelearning.com
Senior lead for safeguarding and child protection
Name: Tom Hooper
Phone/email: 0203 771 0095
NSPCC Helpline: 0808 800 5000
We are committed to reviewing our policy and good practice annually.
This policy was last reviewed on: 07th September 2020
There are 3 main procedures that cover the most likely scenarios where Third Space Learning could become involved in a child protection issue:
This document includes procedures for all three of these scenarios. The procedures outlined are not an exhaustive list; therefore, if a potential incident occurs that is not covered in this document you are advised to contact the TSL Designated Safeguarding Officer.
Introduction to procedure
Almost all interactions with children are through online 1-2-1 tuition, where a teacher or other member of staff is physically present in the room with the child. It is therefore extremely unlikely that a TSL tutor will encounter a child who is in immediate danger. However unlikely, there are plausible circumstances in which a child doing tuition may be in immediate danger, for example:
Immediate actions
The tutor should try to establish either through the child or, the responsible adult the following:
The tutor must then immediately contact the dedicated in-session TSL Support Team and report the emergency. The tutor must then try to stay in contact with the child (unless this puts them in more danger) and provide updates to the child / responsible adult and to the TSL Support Team .
The in-session TSL Support Team must contact either the school directly, or, if appropriate call 999 for the police or an ambulance, making sure they have the details of the school name and address, the child’s name, and year group, as well as the nature of the emergency (the tutors do not have the school information and hence the need to use the in-session TSL Support Team ).
Where possible, the TSL Support Team must then report what they are doing to the tutor and
They should also make sure the Designated Safeguarding Officer is made aware of the incident (or, in their absence, Deputy child safeguarding lead or the member of TSL’s board who has responsibility for safeguarding.)
Follow up actions
Once any immediate danger has been resolved the tutor and the in-session Support Team will complete a written report, based on the TSL Red Flag system, that includes the following details:
These details, plus any recordings, will then be made available to the school and any UK authorities as directed by the school or TSL’s Designated Safeguarding Officer.
Maintenance of records
The record of the incident shall be stored in accordance with TSL’s Child protection records retention and storage policy.
Introduction to procedure for dealing with direct disclosure
The entirety of our interactions with children is through 1-2-1 online tuition and therefore the most likely way Third Space Learning will become involved in a potential safeguarding issue is to be told something directly by the child that indicates they are being abused or at risk of being abused. Other procedures deal with cases where the child is in immediate danger.
Recognising and Responding to an indication of child abuse
As per our safeguarding training, when the tutor recognises a child protection issue, they should:
Interacting with the Timeslot Supervisor
The Tutor should decide whether the child is so upset that they can’t continue the tuition or that they need the responsible adult in the room (the Timeslot Supervisor) to help calm them down. (If the child is in immediate danger, please follow procedure 1.)
Mostly this is done by asking the child to get the responsible adult and telling them that the child is upset and might not be able to continue. The tutor would communicate this to the Timeslot Supervisor through the TSL platform (rather than phone them). If the child is unable to get the Timeslot Supervisor, then the tutor should contact the TSL Support Team, who can then contact the school directly.
The Tutor should tell the Timeslot Supervisor about the child protection incident at the time, with the following exceptions:
The Tutor must complete a Red Flag report. For serious or urgent cases, they must immediately inform the TSL Support Team that this is a serious or urgent Red Flag issue. For other issues, complete the Red Flag issue as normal and it will be picked up by the TSL Support Team within the next working day.
A written report (submitted directly into the app as part of the notes and part of the Red Flag process) must include:
Maintenance of records
The record of the incident shall be stored in accordance with TSL’s Child protection records retention and storage policy.
The aims of this procedure are:
This procedure applies to:
What to do if an allegation is made or information is received
If the person who is the subject of the accusation is still working with children, then the concern needs to be discussed immediately with a manager and the Designated Safeguarding Officer. One of these (either the manager or Designated Safeguarding Officer) should then, in a sensitive manner, remove the staff member involved in the allegation from direct contact with children
It should then be explained to the person, in private, that there has been a complaint made against him/her, although the details of the complaint should not be given at this stage. The person should be informed that further information will be provided as soon as possible but that, until consultation has taken place with the relevant agencies and within the organisation, they should not be working with children. It may be best, under the circumstances, for the person to return home (if working from a Third Space Learning office) on the understanding that the manager or Designated Safeguarding Officer will telephone him/her later in the day.
The information provided to him/her at this stage will need to be very limited. This is because discussions need to take place first with other agencies who may need to be involved, such as the local authority children’s social care department or the police.
If the person is a member of a trades union or a professional organisation, he/she should be advised to make contact with that body. Arrangements should also be made for the member of staff or volunteer to receive ongoing support in line with the responsibilities the organisation has towards his or her welfare.
Conducting an investigation
Once any urgent necessary steps have been taken, attention can be given to dealing with the full implications of the allegations.
There are up to three possible lines of enquiry when an allegation is made:
If the allegation is made by a child or family member to a member of staff/tutor, or if a member of staff observes concerning behaviour by a colleague at first hand, this should be reported immediately to the staff member’s manager and the Designated Safeguarding Officer; Third Space Learning’s lead on handling the allegation.
If a staff member has received an allegation or observed something of concern about their own manager, the staff member should report the allegation or concern to the person more senior to their manager.
If the person who is the subject of the concern is a Designated Safeguarding Officer, the matter should be reported to the designated officer’s manager.
Issues that will need to be taken into account are:
This procedure assumes the child is not in immediate danger. In the event that the child is in immediate danger, follow Procedure 1.
When to involve the local authority designated officer or team
TSL will report the allegation to the school in the first instance (assuming the school did not inform us). Where the accusation is serious (see below for a definition), TSL expect’s the school to either contact the designated officer or team (formerly known as the LADO) at the local authority where the child goes to school (within one working day) or instruct TSL to do so. In the event that this does not happen, TSL will contact the local authority directly. A serious accusation would be where the person in question:
The local authority designated officer or team may be told of the allegation from another source. If this is the case, then the first information received by TSL may be when the local authority makes contact in order to explain the situation.
Whoever initiates the contact, there will be a discussion between the local authority designated officer or team and the TSL Designated Safeguarding Officer to share information about the nature and circumstances of the allegation, and to consider whether there is any evidence to suggest that it may be false or unfounded.
TSL will cooperate fully with schools, local authorities and police, including offering to have the TSL Designated Safeguarding Officer take part in local authority strategy discussion.
Dealing with a criminal offence
If there is reason to suspect that a criminal offence may have been committed (whether or not the threshold of ‘significant harm’ is reached), the local authority designated officer or team will contact the police and involve them in a similar strategy discussion. (Note that the relevant police might be the police forces of India or Sri Lanka.)
The Designated Safeguarding Officer and any other representative from Third Space Learning should cooperate fully with any discussion involving the police and should ask for similar cooperation from the police in terms of the sharing of information relevant to the person’s employment.
Discussions with the police should also explore whether there are matters that can be acted on in a disciplinary process while the criminal investigation takes place, or whether disciplinary action must wait until the criminal process is completed.
If the child’s parents/carers do not already know about the allegation, TSL’s Designated Safeguarding Officer will discuss with the school and the local authority designated officer whether TSL needs to be involved in this process.
The person at the centre of the allegation should be informed as soon as possible after the initial consultation with the local authority designated officer or team. However, if a strategy discussion within the local authority children’s social care team or the police is needed, this might have to take place before the person concerned can be spoken to in full. The police and children’s social care department may have views on what information can be disclosed to the person.
Only limited information should be given to the person in question, unless the investigating authorities have indicated that they are happy for all information to be disclosed or unless there is no need for involvement from these statutory agencies.
The Designated Safeguarding Officer will need to keep in close communication with the local authority designated officer or team and the other agencies involved in order to manage the disclosure of information appropriately.
If the initial allegation does not involve a possible criminal offence, the Designated Safeguarding Officer and manager of the person at the centre of the allegation should still consider whether formal disciplinary action is needed.
If the local authority children’s social care department has undertaken any enquiries to determine whether a child or children are in need of protection, the Designated Safeguarding Officer should take account of any relevant information from these enquiries when considering whether disciplinary action should be brought against the person at the centre of the allegations.
The following timings should be kept to wherever possible, depending on the nature of the investigation:
If a criminal investigation is required, it may not have been possible to make decisions about initiating disciplinary proceedings or about the person’s future work arrangements until this is concluded. The police are required to complete their work as soon as reasonably possible and to set review dates, so the Designated Safeguarding Officer should either liaise with the police directly or via the local authority designated officer or team to check on the progress of the investigation and criminal process.
The police are also required to inform the employer straight away if the person is either convicted of an offence or acquitted or, alternatively, if a decision is made not to charge him/her with an offence or to administer a caution. In any eventuality, once the outcome is known, the Designated Safeguarding Officer should contact the local authority designated officer or team to discuss the issue of disciplinary proceedings.
If the allegation is substantiated and if, once the case is concluded, Third Space Learning dismisses the person or ceases to use their services, or the person ceases to provide his/her services, the Designated Safeguarding Officer should consult with the local authority designated officer or team about referral of the incident to the Disclosure and Barring Service (DBS). This should take place within a month.
Where an investigation concludes that a tutor has caused a child to be abused, then TSL will review all recordings of tuition between that tutor and other pupils at any school that the tutor may have taught in the past.
If this review finds further incidents of potential or actual abuse, then these will be flagged and shared with the local school, local authority and police, as appropriate, and a fuller investigation into those other occasions will be carried out.
If no other further incidents are detected in this review, then, TSL will contact the schools who have had sessions with the tutor and inform them that:
All those involved in dealing with the allegation should keep clear notes of the allegations made, how they were followed up, and any actions and decisions taken, together with the reasons for these.
These notes should be compiled gradually as the situation unfolds, with each entry being made as soon as possible after the event it describes. The notes should be signed and dated by the person making them, and the person’s name should be printed alongside.
The notes should be kept confidentially on the file of the person who is the subject of the allegation. Discussion should take place with the local authority designated officer or team to determine whether any aspects of the notes may not be shared with the person concerned. If there are no reasons not to do so, a copy of the records should be given to the individual.
The notes should be held on file for indefinitely, whether or not the person remains with Third Space Learning for this period.
Designated Safeguarding Officer: Jenni Hoy
Contact Number: 0203 771 0096
Contact Email: jenni.hoy@thirdspacelearning.com
Designated Safeguarding Officer: Bryan Tookey
Contact Number: 0203 771 0094
Contact Email: bryan.tookey@thirdspacelearning.com
Designated Safeguarding Officer: Tom Hooper
Contact Number: 0203 771 0095
Contact Email: tom@thirdspacelearning.com
NSPCC Helpline: 0808 800 5000 – help@nspcc.org.uk
Child line: 0800 1111(textphone 0800 400 222) 0808 800 5000 or help@nspcc.org.uk