Your Private Tutor Online Safety & Safeguarding Policy

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Your Private Tutor Online Safeguarding Statement:
“Safeguarding is everyone's responsibility at Your Private Tutor Online. We are dedicated to safeguarding and promoting the welfare of children and young people, and we expect all Directors, staff, and tutors to share this commitment.”

1. OBJECTIVE
This document outlines the Safeguarding Policy and Procedures of Your Private Tutor Online. It defines our commitment to safeguarding practices, aligning with statutory responsibilities, government guidelines, and best practices.

This policy provides a framework to support all individuals interacting with Your Private Tutor Online, protect them from abuse and maltreatment, and clarify organizational expectations.

We implement rigorous risk management processes to identify situations requiring professional judgment to protect students from harm.

Our organization will manage risks and minimize abuse likelihood by:

Providing up-to-date safeguarding policies and procedures reflecting current legislation and guidance.
Implementing robust recruitment, selection, and appointment procedures for staff and tutors.
Promoting and using safer working practices for Directors, staff, tutors, and students.
Offering induction and ongoing training for staff and tutors.
Fostering a culture of vigilance in all organizational areas.
Protecting students from harm.
Ensuring avenues to raise safeguarding concerns.
Handling allegations or incidents per policies and procedures.
Reporting allegations or incidents to relevant authorities.
All Directors, staff, and tutors must read this policy and its supporting procedures and know the steps to take if a safeguarding concern arises.

2. WHO IS THIS POLICY FOR?
This policy is for Tutors, Schools, Parents, Students, and Your Private Tutor Online staff. "Staff" refers to both Your Private Tutor Online staff and tutors throughout this policy.

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3. CONTENTS
1.OBJECTIVE
2.WHO IS THIS POLICY FOR?

3.CONTENTS
4.DEFINITIONS OF ABUSE
4.1 Abuse
4.2 Types of abuse and neglect
4.2.1 Physical abuse
4.2.2 Emotional abuse
4.2.3 Sexual abuse
4.2.4 Neglect
4.2.5 Child Exploitation
4.2.6 Child on Child Abuse
4.2.7 So-called 'honour'-based abuse
4.2.7.1 Female Genital Mutilation (FGM)
4.2.7.2 Forced Marriage
SAFER RECRUITMENT
5.1 Interview
5.1.1 ID Verification
5.1.2 Health Declaration
5.1.3 Verified Employment History
5.1.4 University and Grade Declaration
5.2 Criminal Background Checks
5.2.1 New Tutors
5.3 Reference Checks
5.4 Overseas Checks
5.5 Tutor Training (including Prevent and Online Safety training)
5.6 Online Searches
6. ONLINE SAFETY
7. SOCIAL MEDIA ACCEPTABLE USE
7.1 Acceptable Use
8. SAFEGUARDING STUDENTS OF DIFFERENT AGES
9. SAFEGUARDING INTERNATIONAL STUDENTS
10. WHAT TO DO IF YOU HAVE A SAFEGUARDING CONCERN
10.1 Reporting
10.2 Disclosure
10.3 Emergency responses
10.4 Allegations against staff
10.5 DBS Requirement and Duty to Report
10.6 Learning Lessons
10.7 Low Level Concerns
11.ANTI-BRIBERY AND CORRUPTION
11.1 Offence
11.2 Definitions of Bribery and Corruption
11.3 Scope
11.4 Gifts and Hospitality
11.5 Policy
12.WHISTLEBLOWING
13.SAFEGUARDING GOVERNANCE
13.1 Your Private Tutor Online Board of Directors
13.2 Your Private Tutor Online Leadership Team
13.3 Your Private Tutor Online Named Designated Safeguarding Officer and Deputies
13.4 Your Private Tutor Online Staff and Tutors
14. COMPLAINTS
15. QUALITY ASSURANCE AND REVIEW
16.UNDERPINNING LEGISLATION AND GUIDANCE
16.1 Legislation
4. DEFINITIONS OF ABUSE
All staff must recognize abuse and neglect indicators, understanding that children can be at risk both inside and outside of school, home, and online. Professional curiosity and awareness are crucial for the early identification of abuse and neglect, enabling staff to identify children needing help or protection.

Staff must identify children who might benefit from early help, providing support as soon as problems emerge at any stage in a child’s life.

Recognising abuse and neglect requires understanding that these issues are rarely isolated events and typically overlap. Staff are trained to recognize abuse indicators through experience and training, ensuring they can identify cases needing intervention. Uncertain staff should consult the Designated Safeguarding Lead (DSL) or deputy.

Staff must understand that children may not feel ready or know how to report abuse, exploitation, or neglect, and may not recognize these experiences as harmful. Children might feel embarrassed, humiliated, or threatened against reporting due to vulnerability, disability, sexual orientation, or language barriers. Professional curiosity and consultation with the DSL or deputy are essential if concerns arise.

Technology plays a significant role in many safeguarding issues, with children at risk online and offline. Abuse and other risks often occur concurrently in both environments. Children can also abuse peers online, involving abusive messages, non-consensual sharing of images, and distribution of unwanted content.

Staff must be aware of broader safeguarding issues that put children at risk, such as drug and alcohol misuse, missing education, serious violence, radicalization, and the sharing of explicit images.

Safeguarding and promoting children’s welfare is defined as:

• Protecting children from maltreatment.

• Preventing impairment of children’s mental and physical health or development.

• Ensuring children grow up in safe, effective care environments.

• Enabling all children to achieve the best outcomes.

The term 'children' refers to anyone under 18.

(Keeping Children Safe in Education (KCSIE), DfE, September 2023)

While all children should be protected, Your Private Tutor Online recognizes that some groups are at higher risk of harm, both online and offline. These groups include:

• Children needing social workers

• Children absent from education: Programme leads at Your Private Tutor Online can view pupils' attendance through their tutor account. They can:

• Check live lesson attendance.

• Download attendance reports showing pupil attendance and authorized absences.

Dedicated Education Partnerships Managers contact programme leads or school representatives to address attendance concerns. Tutors can log attendance concerns via CPOMS for follow-up by the safeguarding team.
Electively Home Educated (EHE) children
Children requiring mental health support
Looked after children and care leavers
Children with Special Educational Needs or Disabilities (SEND) or health issues: These children may face additional challenges, such as:
Misinterpreting abuse indicators as related to their condition.
Increased risk of peer isolation or bullying.
Disproportionate impact from bullying without outward signs.
Communication barriers and difficulty reporting challenges.
Difficulty distinguishing fact from fiction online, potentially repeating harmful content or behaviorus.
Your Private Tutor Online requires schools to provide a redacted summary of a child's EHCP needs to share with tutors, ensuring understanding of the child's individual needs and related safeguarding concerns.

4.1 Abuse
Abuse is the maltreatment of a child. It can involve inflicting harm or failing to prevent harm. Harm includes non-physical ill-treatment and the impact of witnessing domestic abuse. Abuse can occur in families, institutions, communities, or online. Children may be abused by adults or peers.

If child abuse is reported, Your Private Tutor Online’s Designated Safeguarding Lead (DSL) will follow the 1989 Children Act process, considering section 47 (significant harm risk) or section 17 ('child in need'). This may involve referrals to Children’s Social Care, police, or early help services, depending on the risk severity.

4.2 Types of abuse and neglect
4.2.1 Physical abuse
Involves actions like hitting, shaking, or poisoning. Physical harm can also result from fabricated or induced illness by a parent or carer.

4.2.2 Emotional abuse
Persistent emotional maltreatment causing severe effects on a child's development. It includes making children feel worthless, limiting their social interaction, and serious bullying.

4.2.3 Sexual abuse
Forcing or enticing a child into sexual activities, including physical contact and non-contact activities like viewing sexual images. Technology can facilitate abuse, and women and children can also perpetrate it.

4.2.4 Neglect
Persistent failure to meet a child's basic needs, resulting in serious impairment. This includes providing inadequate food, shelter, supervision, or medical care, and unresponsiveness to emotional needs.

4.2.5 Child Exploitation
Both child sexual and criminal exploitation are forms of abuse. Staff are trained to recognize and report signs of exploitation according to Your Private Tutor Online’s safeguarding procedures.

Safeguarding Policy for YourPrivateTutorOnline.com
4.2.6 Child-on-Child Abuse
All staff at YourPrivateTutorOnline.com (YPTO) are aware that children can abuse other children at any age (often referred to as child-on-child abuse), and that it can occur both within and outside their educational setting and online.

All staff receive training to recognize the indicators and signs of abuse, understand how to identify it, and know how to respond to reports in accordance with YPTO's safeguarding procedures.

Child-on-child abuse may include, but is not limited to:

Bullying: Including cyberbullying, prejudice-based, and discriminatory bullying.
Abuse in intimate personal relationships: Sometimes referred to as 'teenage relationship abuse.'
Physical abuse: Including hitting, kicking, shaking, biting, hair pulling, or other forms of physical harm.
Sexual violence: Referring to offences under the Sexual Offences Act 2003, such as rape, assault by penetration, sexual assault, and causing someone to engage in sexual activity without consent.
Sexual harassment: Such as sexual comments, remarks, jokes, and online sexual harassment.
Child-on-child sexual violence and sexual harassment can happen both inside and outside educational settings. YPTO maintains a zero-tolerance approach to sexual violence and sexual harassment, stating clearly that it is never acceptable and will not be tolerated.

4.2.7 Honour-Based Abuse (HBA)
So-called 'honour'-based abuse (HBA) includes incidents or crimes committed to protect or defend the honour of the family and/or community. This can include female genital mutilation (FGM), forced marriage, and practices such as breast ironing. HBA often involves a network of family or community pressure and can include multiple perpetrators.

All forms of HBA are abuse, regardless of the motivation, and should be handled and escalated as such. All staff are trained to recognize the signs of HBA and how to report it.

4.2.7.1 Female Genital Mutilation (FGM)
All staff have a legal obligation to report to the Designated Safeguarding Lead (DSL) any cases where it is known that FGM has been carried out on a child, in line with our safeguarding procedures.

4.2.7.2 Forced Marriage
A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats, or any other form of coercion is used to compel a person to marry. Threats can be physical, emotional, or psychological. Lack of full and free consent may occur if the person cannot consent, for example, due to learning disabilities. Some perpetrators may use perceived cultural practices to coerce a person into marriage.

Since February 2023, it has been illegal for anyone under the age of 18 to marry, or for anyone to conduct or facilitate such a marriage, including non-binding, unofficial 'marriages' as well as legal marriages.

5. Safer Recruitment
5.1 Interview
All tutors must successfully pass an interview before being admitted to the platform. Each tutor is also subject to periodic lesson observations as a secondary control.

5.1.1 ID Verification
Tutors must provide proof of two types of identification during their interview. The first must be their UK passport, and the second can be one of the following UK-issued documents: biometric residence permit, birth certificate, adoption certificate, marriage or civil partnership certificate, or a driving license from any country. These documents will be verified by the YPTO interviewer.

5.1.2 Health Declaration
YPTO requires all tutors to self-declare their physical and mental fitness to deliver lessons by signing the Terms and Conditions.

5.1.3 Verified Employment History
At the interview, YPTO discusses the candidates' employment history from the age of 16. Their university placement is verified, and references are obtained as a secondary control. Any gaps or inconsistencies are noted and explained.

5.1.4 University and Grade Declaration
The academic requirements set by YPTO for becoming a tutor are as follows:

Must be studying at or have recently graduated (within the last 3 years) from one of the universities we recruit from.
Must verify this with their active registered university email address or graduation certificate.
Must have a minimum of one A/A* or 7/8/9 in a core subject at GCSE level.
Core subjects include Maths, English, and Sciences.
5.2 Criminal Background Checks
All tutors must have a valid enhanced Criminal Background check to tutor on the platform.

A criminal background check is considered valid if it:

Is an up-to-date enhanced DBS check.
Is issued in the UK.
Details Children's Barred List information.
Is relevant to the tutor’s place of work and previous address history.
Tutors need a valid, enhanced DBS check, which must be renewed every three years.

An enhanced DBS check can be updated by:

Applying for a new enhanced DBS Certificate.
Asking YPTO to check the Update Service, provided the tutor is registered.
When a DBS check reaches 2 years and 11 months old, the tutor will be blocked from accepting new work until an updated DBS has been completed and verified by YPTO. If a lesson was accepted before the 2 years and 11 months deadline and takes place after the tutor's expiry date, YPTO reserves the right to reallocate this work to another tutor.

5.2.1 New Tutors
New tutors joining the platform must have an updated Enhanced DBS Check with the Child Barring Service, unless they are registered on the DBS Update Service prior to starting. Tutors who teach or reside in Scotland, Wales, Northern Ireland, or abroad may be subject to additional checks.

YPT uses Sterling, a certified screening provider, to conduct new criminal background checks. Sterling provides a traffic light result indicating whether a tutor has convictions before sending a certificate to the individual. YPTO uses this result to determine appointments.

All tutors must upload a copy of their DBS certificate to their YPTO account once issued.

Tutors will not be allowed to join the platform until YPTO has received the results of their DBS check. Tutors will have an additional 3 months from the point of going live to upload a copy of their certificate, during which time they will be supervised through lesson observations and by a teacher in the school.

Tutors on the Update Service must provide a copy of the original DBS certificate to YPTO so a check can be conducted before they gain access to the platform.

For tutors requiring a new check, YPTO will cover the initial cost during onboarding. Tutors have the option to pay upfront or repay the cost in installments over 10 lessons. If tutors do not repay the full cost within one year, they must make a one-off payment of the outstanding amount.

As an organization using disclosure information to assess an applicant’s suitability for employment, YPTO undertakes to treat all applicants fairly and not discriminate unfairly against any subject of a disclosure on the basis of a conviction or other information revealed.

YPTO is committed to the fair treatment of its staff, potential staff, or users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependents, age, physical/mental disability, or offending background.

A disclosure will only be requested after a thorough risk assessment indicates it is proportionate and relevant to the position. For positions where a disclosure is required, all application forms, job adverts, and recruitment briefs will state that a Disclosure will be requested.

Unless the position allows us to ask about the entire criminal record, we will only ask about "Unspent" convictions as defined in the Rehabilitation of Offenders Act 1974.

We ensure all involved in the recruitment process have been trained to identify and assess the relevance and circumstances of offences and have received appropriate guidance and training in relevant legislation related to the employment of ex-offenders.

Having a criminal record will not necessarily bar individuals from working in specific industries; it depends on the nature of the position and the circumstances and background of the offences.

Checks will also be made on the applicant’s academic and vocational qualifications, and further checks will be made on the TRA Teacher Services system to ensure they are not prohibited from teaching under a teacher prohibition order.

5.3 Reference Checks
All tutors must submit a minimum of two reference checks before gaining access to the platform.

Reference checks must:

Be from previous employment, an academic source, or a recognized professional known to the applicant for a minimum of six months.
Confirm dates of employment.
Confirm that the candidate is suitable to work with children.
5.4 Overseas Checks
YPTO collects an individual’s address history for the past five years to identify if any additional and overseas checks are required. YPTO defines overseas as "residing outside the UK for more than three months in one country."

This information is requested during onboarding. If an overseas address is provided, the tutor is flagged into a "holding" phase before being allowed on the platform, allowing YPTO to identify the necessary check. If an overseas check is not viable, YPTO conducts a suitable risk assessment to inform the decision on whether to proceed with the appointment, as outlined in KCSIE 2023, para 281.

5.5 Safeguarding Training (including Prevent and Online Safety Training)
YPTO believes training and raising awareness of safeguarding issues, policies, and procedures are fundamental to maintaining a safer environment and organization.

Appropriate safeguarding training is provided to all staff and tutors to assist them in:

Preventing abuse.
Recognizing abuse.
Recording concerns.
Responding appropriately to allegations of abuse.
Knowing who to inform.
Understanding when information can be shared.

All staff and tutors at YPTO (YourPrivateTutorOnline) undergo mandatory safeguarding training as part of their induction. This training, tailored to their roles and responsibilities, is refreshed annually. Safeguarding training is considered a continuous process to enhance skills and knowledge through bulletins, meetings, and awareness training sessions.

Prevent Duty
YPTO takes its duty under section 26 of the Counter-Terrorism and Security Act 2015 seriously and is committed to preventing individuals from being drawn into terrorism. All staff and tutors receive mandatory annual Prevent training, which is updated each August before the new academic year or when guidance or legislation changes.

Online Safety and Training
Recognizing the integral role of the internet in young people’s lives, YPTO ensures that all staff are trained to identify online harms and report concerns to the Designated Safeguarding Lead (DSL). Training includes understanding how YPTO protects children and staff on its platform. YPTO maintains records of all completed training and uses a "pass rate" system to confirm the status of all courses.
5.6 Online Searches
As part of YPTO's commitment to safeguarding, we may perform online searches on shortlisted candidates and tutors to gather information that may require further exploration during interviews or pre-appointment checks. All information collected will comply with GDPR and data protection laws.

6. Online Safety
At YPTO, we adopt a comprehensive approach to online safety, aiming to protect staff, tutors, and students in their use of technology, specifically on our platform. The platform is designed to ensure that lessons occur in a secure environment, featuring several key safety elements and a defined set of policies and procedures for students, parents/responsible adults, and tutors. We have established mechanisms to identify, intervene in, and escalate concerns where necessary, following the filtering and monitoring standards set by the DfE and KCSIE 2023.

We have put in place mechanisms to identify, intervene in, and escalate concerns appropriately.

As highlighted in KCSIE 2023 (para 136), YPTO recognizes the extensive range of issues categorized under online safety, grouped into four main areas:

Content: Exposure to illegal, inappropriate, or harmful content, such as pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalization, and extremism.
Contact: Harmful online interactions with other users, including peer pressure, commercial advertising, and adults posing as children or young adults with the intent to groom or exploit them for sexual, criminal, financial, or other purposes.
Conduct: Personal online behavior that increases the likelihood of harm, such as making, sending, and receiving explicit images (e.g., consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images, and online bullying).
Commerce: Risks like online gambling, inappropriate advertising, phishing, and financial scams.
YPT ensures that online safety is a continuous and integrated theme throughout the development and implementation of all our services, policies, and procedures.

7. Social Media Acceptable Use
Social media refers to any online platform enabling people to interact directly. It allows sharing of information, ideas, and views and includes both mainstream and non-mainstream platforms. Examples of mainstream social media are Facebook, LinkedIn, Twitter, Google+, Instagram, Snapchat, and YouTube, which are moderated to prevent extremist material from being uploaded. Non-mainstream social media, such as Bitchute, 4chan, and Reddit, lack significant moderation, potentially exposing young people to extremist material and making them susceptible to radicalization.

7.1 Acceptable Use
YPTO staff and tutors should recognize that content uploaded to social media is not private. Even if restricted to ‘friends’, it can still be reposted or distributed beyond the intended recipients. Therefore, staff and tutors using social media should maintain professionalism and respect.

Staff and tutors should not upload any content to social media sites that:

Is confidential to the company or its staff.
Constitutes bullying.
Involves unlawful discrimination, harassment, or victimization.
Brings the company into disrepute.
Contains lewd, sexually explicit, threatening, or similarly inappropriate or offensive comments, images, or video clips.
Undermines the reputation of the school and/or individuals.
Is defamatory or knowingly false.
Breaches copyright.
Is otherwise unlawful.
Staff and tutors on the platform should be aware of professional and social boundaries and should not accept or invite ‘friend’ requests from students or ex-students under the age of 18 or from parents on their personal social media accounts, such as Facebook. All communication with parents should be through the YPTO platform.

Any content or online activity raising a safeguarding concern must be reported to the YPTO safeguarding team via our online case management system (CPOMS).

Following any report of inappropriate use of social media, the company will conduct an investigation, which may lead to removal from the platform or disciplinary action.

8. Safeguarding Students of Different Ages
YPT recognizes that it provides tuition across a wide range of age groups.

YPT is committed to ensuring that their staff and tutors are adequately trained and prepared to recognize the different types of abuse that can impact different age groups.

Additionally, YPTO acknowledges its safeguarding responsibilities towards tutors, providing support and advice through open and easy methods of communication and supporting tutors with lesson observations and feedback.

9. Safeguarding International Students
YPT acknowledges that international students use and access the platform. YPTO applies the same reporting approach to international students as it does to those in the UK.

The YPTO safeguarding team will always endeavor to follow the same policy and procedures and notify the relevant local authority equivalent where possible.

10. What to Do If You Have a Safeguarding Concern
10.1 Reporting
It is crucial to report any safeguarding concerns to YPTO so that our Safeguarding Team can investigate thoroughly. All safeguarding concerns will be investigated within 24 hours of YPTO receiving the report.

To help the Safeguarding Team respond and refer appropriately, please follow the guidance below:

Remember that concern forms are used in court cases and inquests as evidence.
Reports should be objective and detailed.
If you cannot access our CPOMS portal, contact a member of the YPTO team for assistance in making a report.
Alert the team as soon as possible. Dealing with urgent concerns can take several hours, so the earlier we start, the better.
To report a safeguarding concern to YPTO:

YPTO staff and tutors: all concerns need to be reported via CPOMS.
Parents/carers/schools: please use our external YPTO Safeguarding Reporting Form.
If you cannot access CPOMS or the reporting form, please get in touch via live chat or phone:
+44 (0) 203 773 6020 - Monday-Sunday, 8 am-7 pm
+44 (0) 203 950 9586 - Out of hours Safeguarding
10.2 Disclosure
Once a disclosure has been made or a concern shared, the Safeguarding Team will review the information, seek advice if necessary, and decide to:

• Keep detailed records of the concern with no further action at this time.

• Liaise with the host school’s Designated Safeguarding Lead.

• Make a child protection referral to Children’s Social Care.

• Make a police referral.

• Make a referral to an Early Help service (consent from the child/family will always be sought before any referral to an Early Help service is made).

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

Once the decision to make a referral is made, the Safeguarding Team will contact the relevant Children’s Social Care Team and make a telephone referral, followed up in writing within 24 hours.

10.3 Emergency Responses
If a child is identified as being at immediate risk of harm, the tutor will immediately contact the Designated Safeguarding Lead, who will, in turn, contact the police for the area where the risk is located using 999. This is particularly important when the child is being tutored at home without an independent school teacher present.

Within one working day of a referral being made, a local authority social worker should acknowledge receipt to the referrer and decide on the next steps and type of response required.

Where tutors deliver tuition to children and young people in a school or college, the YPTO DSL/Deputy must inform the school’s DSL of any safeguarding concerns.

10.4 Allegations Against Staff
YPT acknowledges its duty to report concerns or allegations against its directors, staff, tutors, volunteers, or contractors. All directors, staff, tutors, volunteers, or contractors must comply with the relevant Code of Conduct to promote safer working practices.

Allegations of abuse against directors, staff, tutors, volunteers, or contractors can be made by either a child or an adult and should be reported immediately to YPTO’s DSL. Allegations against the DSL should instead be reported to another member of the leadership team, who will arrange for a senior staff member to take the DSL’s place in response to the allegation.

This guidance should be followed when any YPTO representative has:

Behaved in a way that has harmed a child, or may have harmed a child.
Possibly committed a criminal offense against or related to a child.
Behaved towards a child or children in a way that indicates they may pose a risk of harm to children.
Behaved or may have behaved in a way that indicates they may not be suitable to work with children, including behavior inside or outside of YPTO.
(KCSIE 2023 para 355-356)

YPTO will address all allegations or concerns appropriately and promptly, referring all safeguarding concerns or allegations about its directors, staff, or tutors immediately to the appropriate local authority designated officer (LADO) following local safeguarding procedures and statutory guidance, as outlined in Working Together to Safeguard Children, 2018.

YPTO will consider immediate suspension (without prejudice) if a safeguarding allegation is made against any director, staff member, or tutor pending investigation when there is cause to suspect that another child(ren) is/are at risk of harm from their continued contact with children, in line with KCSIE 2023 recommendations.

Suspension will also be considered even if the allegation is not linked to their role or activity with YPTO.

10.5 DBS Requirement and Duty to Report
Under legal obligations to make referrals to the Disclosure and Barring Service (DBS), YPTO will report any concerns regarding unsafe practices by its directors, staff, or tutors to the DBS. This applies when an individual has engaged in conduct that has harmed (or is likely to harm) a child, or if a person poses a risk of harm to a child (KCSIE 2023, para 403).

10.6 Learning Lessons
YPTP is committed to learning from any incidents, with guidance from the Local Authority Designated Officer (LADO) to identify improvements to our procedures and prevent similar events in the future. This includes lessons about suspension and reinstatement after suspension (KCSIE 2023, para 420-421).

10.7 Low-Level Concerns
We aim to create a culture where all concerns about adults working on behalf of YPTO are addressed promptly and appropriately.

A low-level concern, while not insignificant, is any concern—no matter how small—that an adult working in or on behalf of YPTO may have acted in a way that:

Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and
Does not meet the harm threshold or is otherwise not serious enough to warrant a referral to the LADO.
If YPTO dismisses a director, staff member, or tutor due to relevant conduct, risk of harm, or receiving a caution or conviction for a relevant offense (or the individual resigns or leaves under similar circumstances), a referral to the DBS will be made by the DSL.

11. Anti-Bribery and Corruption
Bribery, in the context of YPTO’s business, is the offering or accepting of any gift, loan, payment, reward, or advantage for personal gain as an encouragement to do something dishonest, illegal, or a breach of trust. Bribery is a criminal offense.

The Company prohibits any form of bribery. We require compliance with the highest ethical standards and applicable anti-bribery laws from everyone associated with our business. Integrity and transparency are paramount, and we maintain a zero-tolerance stance towards corrupt activities of any kind, whether by YPTO employees or third parties acting on our behalf.

11.1 Offense
It is a criminal offence to:

1.Offer a bribe
2.Accept a bribe
3.Bribe a foreign official
4.Fail to prevent a bribe as a commercial organization
If found guilty of bribery, one could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.

11.2 Definitions of Bribery and Corruption
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption, involving the giving or receiving of money, gifts, meals, entertainment, or anything else of value to induce someone to act dishonestly or illegally.

11.3 Scope
This policy applies to all YPTO employees, regardless of seniority or location. It also extends to anyone working for or on our behalf, such as self-employed individuals or those under agency arrangements. We encourage this policy’s application where our business involves third parties, such as suppliers and contractors.

11.4 Gifts and Hospitality
While giving and receiving gifts and hospitality without expectations in return can foster positive relationships with third parties, it must be proportionate and properly recorded. This does not constitute bribery.

Gifts include money, goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context), services, or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining, meals, or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality becomes a gift if the host is not present.

No gift or hospitality should be given or accepted without prior written approval from Bertie Hubbard (CEO). A record will be made of every instance in which gifts or hospitality are given or received.

11.5 Policy
It is prohibited to directly or indirectly offer, give, request, or accept any bribe to gain commercial, contractual, or regulatory advantage for the Company, or to gain personal advantage in an unethical manner.

It is also prohibited to influence a foreign public official with a bribe. If offered a bribe, or if a bribe is solicited, do not agree unless your immediate safety is at risk. Immediately contact [insert name/position] to take necessary action. You may be asked to provide a written account of events.

If you suspect an act of bribery or attempted bribery, report it to [insert name/position]. You may be asked to provide a written account of events. Appropriate checks will be made before engaging with suppliers or other third parties to reduce the risk of breaching our anti-bribery rules. All transactions, including any sponsorship or donations, will be transparent and legitimate.

YPTP takes breaches of this policy seriously and will thoroughly investigate any incidents. Disciplinary action, including dismissal, will be taken against employees found guilty of bribery, and similar actions will be taken against contractors or agency workers.

12. Whistleblowing
Staff and tutors should feel able to raise concerns about poor or unsafe practices and potential failures in YPTO’s safeguarding regime. Whistleblowing procedures are in place, reflected in staff and tutors’ induction, training, and code of conduct, allowing concerns to be raised with YPTO’s leadership team.

If staff or tutors feel unable to raise issues with their manager, or believe their concerns are not being addressed, alternative whistleblowing channels are available:

General guidance on whistleblowing can be found via: Advice on Whistleblowing.
The NSPCC’s dedicated helpline is available for concerns about child protection failures: 0800 028 0285 (8:00 AM to 8:00 PM, Monday to Friday), email: help@nspcc.org.uk.
YPTP’s whistleblowing policy can be found here.

13. Safeguarding Governance
YPTP is committed to supporting all those involved with the organization. A clear structure of safeguarding accountability ensures everyone understands their individual and collective responsibilities for safeguarding children and young people.

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

13.1 YPTO Board of Directors
Directors ensure legal compliance, effective management of resources, long-term vision, and protection of the organization’s reputation and values. Responsibilities may be delegated to individual directors or leadership team members.

Directors are responsible for:

Approving all safeguarding policies and supporting procedures
Ensuring adequate resources for effective safeguarding practices and training
Ensuring effective reporting and auditing processes are in place and regularly reviewed
Receiving regular safeguarding reports from the leadership team
Developing a culture promoting effective safeguarding practices
13.2 YPTO Leadership Team
The leadership team integrates safeguarding into all services, activities, and contracts, assisting in safer recruitment and selection of staff and tutors.

The Leadership Team will ensure:

Safeguarding and a culture of vigilance are embedded in all organizational areas, including partners and contractors
Clear and effective communication pathways for safeguarding are shared with all staff, tutors, and customers
Proposed changes to safeguarding policies and procedures are presented to the Board for approval
The Named Designated Safeguarding Officer and Deputies have sufficient resources to fulfill their responsibilities
Safe recruitment and selection practices are implemented in line with the safer recruitment policy
Coordination of investigations into concerns and allegations against staff or tutors
13.3 YPTO Named Designated Safeguarding Lead and Deputies
The Named Designated Safeguarding Lead (DSL) and Deputy Designated Safeguarding Lead (DDSL) will receive appropriate training to support and guide staff and tutors on safeguarding matters. Their training is updated every two years.

The DSL and Deputies will:

Provide accessible support and guidance to all staff, tutors, and directors on safeguarding matters
Manage all safeguarding reports and liaise with statutory services during investigations
Report allegations against directors, staff, or tutors to the relevant Local Authority and DBS
Ensure accurate records of all safeguarding concerns and secure storage of records
Provide quality assurance and review for all safeguarding concerns
Inform governance bodies of serious safeguarding incidents as appropriate
Ensure adoption, implementation, and auditing of all safeguarding policies
Liaise with school DSLs on safety and safeguarding matters, particularly online and digital safety involving YPTO tutors, when deciding whether to make referrals to relevant agencies
To contact DSL e-mail yourprivatetutoronline@gmail.com
Further information on the role and responsibilities of the DSL and Deputies in the context of schools can be found in the statutory guidance KCSIE 2023, Annex C.

13.4 YPTO Staff and Tutors
All YPTO staff and tutors share the responsibility to safeguard and promote the welfare of children and young people. They should recognize, respond to, report, and record any safeguarding concerns.

Staff and tutors must follow YPTO’s safeguarding procedures for reporting concerns about abuse or neglect. In emergencies, they are expected to report urgent concerns directly to the relevant statutory agency.

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

15. QUALITY ASSURANCE AND REVIEW
YPTP 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.

16. UNDERPINNING LEGISLATION AND GUIDANCE
16.1 Legislation

Children Act 1989
Human Rights Act 1998
United Nations Convention on the Rights of the Child, 1991
Sexual Offences Act 2003
Female Genital Mutilation Act 2003
Children Act 2004
Safeguarding Vulnerable Groups Act 2006
The Forced Marriage (Civil Protection) Act 2007
The Mental Capacity Act 2005
The Equality Act 2010
Children and Families Act 2014
Anti-Social Behaviour, Crime and Policing Act 2014
Modern Slavery Act 2015
Counter Terrorism and Security Act 2015
Children and Social Work Act 2017
Data Protection Act 2018
Voyeurism (Offences) Act 2019
Domestic Abuse Act 2021
Children’s Code (issued under S125 DPA 2018, effective Oct 2021)
The Marriage and Civil Partnerships Act 2022