This policy sets out how The National Society for Education, Mentoring and Media (NSEMM) safeguards and promotes the welfare of all children, young people, and adults at risk who use our services.
NSEMM is a registered charity (no. 1209673) providing pay-what-you-can tutoring, mentoring, and educational support to students aged 7 to 18. We deliver services primarily online through the NSEMM Learn platform, with in-person provision through Community Education Networks when operational. We operate across England and Scotland.
This policy applies to all NSEMM trustees, employees, volunteers, and anyone acting on behalf of NSEMM. It also applies to partner organisations and external professionals who interact with NSEMM's safeguarding systems.
This policy should be read alongside NSEMM's Student Welfare and Protection Policy, Code of Conduct, Complaints Policy, and Data Protection Policy.
Why This Policy Matters
Many of the students NSEMM works with may be vulnerable due to their age, circumstances, or support needs. Safeguarding is not a compliance exercise - it is central to our charitable mission. Every decision we make, from recruitment to service delivery to data handling, is informed by our duty to protect the children and young people in our care.
2. Legislative Framework
This policy is grounded in the following legislation and statutory guidance.
Primary Legislation
Children Act 1989 (and 2004 amendment)
Children (Scotland) Act 1995
Care Act 2014
Human Rights Act 1998
Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR)
Equality Act 2010
Counter-Terrorism and Security Act 2015 (Prevent Duty)
Mental Health Act 2025 (Royal Assent 18 December 2025; phased implementation over 8–10 years)
Public Interest Disclosure Act 1998
Statutory Guidance
Keeping Children Safe in Education 2025 (KCSIE 2025), in force from 1 September 2025
Working Together to Safeguard Children 2023, updated June 2025
Working Together to Improve School Attendance 2024 (statutory)
Relationships Education, Relationships and Sex Education (RSE) and Health Education guidance, July 2025 (statutory from 1 September 2026)
National Guidance for Child Protection in Scotland 2021
Additional Guidance
Charity Commission: Safeguarding and Protecting People for Charities and Trustees (2022)
Charity Commission: Strategy for Dealing with Safeguarding Issues in Charities
DfE: Generative AI - Product Safety Expectations (January 2025)
DfE: Plan Technology for Your School self-assessment tool (September 2024)
Cyber Security Standards for Schools and Colleges
NCVO Safeguarding Resources and Best Practices
Thirtyone:eight Safeguarding Standards
Forthcoming Legislative Changes
The Children's Wellbeing and Schools Bill completed its Lords third reading on 9 February 2026 and returned to the House of Commons on 11 February 2026. Royal Assent is expected by Easter 2026 with implementation from late 2026–2027. Key provisions relevant to NSEMM include:
Multi-Agency Child Protection Teams (MACPTs) in every local area, with education representation
A consistent child identifier pilot using the NHS number
A strengthened statutory duty to share information for safeguarding purposes
Education formally embedded within local safeguarding partnerships
A mandatory register of children not in school
NSEMM will review this policy against the Act once enacted and prepare for compliance during the implementation period.
3. Definitions
Child: Anyone under the age of 18, in accordance with the Children Act 1989 and KCSIE 2025. All NSEMM students fall within this definition.
Adult at risk: An adult who has needs for care and support, is experiencing or at risk of abuse or neglect, and as a result of those care and support needs is unable to protect themselves (Care Act 2014, section 42).
Safeguarding and promoting the welfare of children means:
Protecting children from maltreatment, including in online environments
Preventing impairment of children's mental and physical health or development
Ensuring children grow up in circumstances consistent with the provision of safe and effective care
Providing help and support to meet the needs of children as soon as problems emerge
Taking action to enable all children to have the best outcomes
This definition reflects Working Together to Safeguard Children 2023 (as updated June 2025).
Abuse: A form of maltreatment of a child. Someone may abuse a child by inflicting harm or by failing to act to prevent harm. Abuse can take place wholly online, partly online, or entirely offline. Children may be abused by adults or by other children (child-on-child abuse).
4. Core Principles
NSEMM's safeguarding practice is guided by the following principles:
The welfare of the child is paramount. Every decision about a child's safety takes precedence over other considerations, including the wishes of parents, organisational convenience, or reputational concerns.
Safeguarding is everyone's responsibility. Every trustee, employee, and volunteer at NSEMM has a role in safeguarding. No one should assume someone else has reported a concern.
It could happen here. NSEMM does not assume that safeguarding concerns only arise in other organisations. We maintain constant vigilance and treat every concern seriously.
Early intervention is more effective than crisis response. Identifying and addressing concerns as soon as they emerge produces better outcomes than waiting for situations to escalate.
Listen to the child. Children should feel safe to disclose concerns and be confident they will be taken seriously. Their voice is central to safeguarding decisions, and their wishes and feelings are considered when determining actions.
Professional curiosity. Staff should think critically about information they receive, ask questions, and not take what they see or hear at face value. A questioning approach helps identify concerns that might otherwise be missed.
Cultural competence. Safeguarding approaches must be sensitive to cultural, linguistic, and religious differences, while maintaining clear standards for the protection of all children regardless of background.
Transparency and accountability. Safeguarding decisions are documented, auditable, and open to scrutiny. The cryptographic audit trail in NSEMM Protect exists because safeguarding records may be subject to legal or regulatory review, and the integrity of those records must be beyond question.
Promoting a Culture of Safeguarding
Principles alone are not sufficient - they must be embedded in organisational culture through deliberate, sustained action. NSEMM actively promotes a safeguarding culture through:
Regular safeguarding training for all staff and volunteers, with annual updates reflecting current guidance and learning from cases
Standing safeguarding items in team meetings, creating routine opportunities to discuss emerging concerns, share observations, and reinforce expectations
An open communication environment where staff feel safe to raise concerns, ask questions, and challenge practice without fear of reprisal
Involvement of children and young people in shaping safeguarding practice where appropriate, ensuring their perspectives inform how we work
Accessible safeguarding resources through our platforms, including the NSEMM Support help centre and internal knowledge base
Leadership modelling of safeguarding behaviours, with trustees and senior staff demonstrating the standards expected of everyone
Recognition and discussion of good safeguarding practice, reinforcing that vigilance and professional curiosity are valued
Systematic learning from incidents, near-misses, and case reviews, ensuring that every experience - positive or negative - strengthens our approach
This culture is not self-sustaining. It requires active maintenance, honest self-assessment, and willingness to adapt when practice falls short of standards.
5. Safeguarding Leadership and Arrangements
Designated Safeguarding Lead (DSL)
Adrian Angol-Henry serves as NSEMM's Designated Safeguarding Lead.
Has the same access and authority as the DSL within NSEMM Protect
Acts as DSL when the DSL is unavailable due to leave, illness, or any other reason
The Deputy DSL role exists to ensure there is no single point of failure in safeguarding leadership. If neither the DSL nor Deputy DSL is available, the matter should be escalated directly to the Chair of Trustees.
Board of Trustees
All NSEMM trustees share collective responsibility for safeguarding governance and oversight. This includes:
Approving and reviewing safeguarding policies at least annually, with a mid-year check
Monitoring safeguarding performance through regular DSL reports
Ensuring adequate resources are allocated to safeguarding activities
Completing safeguarding training appropriate to their governance role
Reporting serious safeguarding incidents to the Charity Commission as required
Ensuring that safeguarding remains central to NSEMM's strategic direction
Local Authority Designated Officer (LADO)
The NSEMM is based in the City of Nottingham. The primary Local Authority Designated Officer (LADO) contact for NSEMM is through Nottingham City Council, whose LADO service manages and oversees allegations relating to adults who work with children in the Nottingham City area. Referrals for Nottingham City can be made via the online referral form or by contacting [email protected] or calling 0115 876 5166.
Because NSEMM operates nationally and supports children and vulnerable beneficiaries across the UK, it may be necessary to make referrals to other local authority LADOs depending on the location of the child or young person concerned. The role of the LADO is to coordinate and manage allegations that an adult who works with children has harmed, may have harmed, or poses a risk of harm to a child.
The DSL at NSEMM is responsible for identifying and contacting the appropriate LADO for the area where the child or young person resides or where the incident occurred, and ensuring that referrals are made promptly in accordance with statutory safeguarding guidance.
6. Risk Assessment and Management
NSEMM maintains a systematic approach to safeguarding risk assessment, recognising that effective safeguarding requires structured identification, assessment, and mitigation of risks - not just reaction to concerns as they arise.
Safeguarding Risk Register
NSEMM maintains a dedicated safeguarding risk register that identifies, assesses, and tracks mitigation strategies for safeguarding risks across all activities. The register is reviewed quarterly by the DSL and reported to the Board of Trustees. It covers the following risk categories:
Online safety risks - including content exposure, generative AI, cyberbullying, grooming, and platform vulnerabilities
Staff and volunteer conduct risks - including boundary violations, inappropriate relationships, and professional misconduct
Environmental risks - including venue safety for Community Education Network sessions and home working environments for tutors
Activity-specific risks - risks particular to tutoring, mentoring, and educational delivery
External partnership risks - risks arising from working with schools, local authorities, and other organisations
Data protection risks - including recording, storage, transmission, and sharing of personal and safeguarding information
Organisational risks - including leadership continuity, resource constraints, and governance gaps
Risk Assessment Process
Each identified risk is assessed using a likelihood-and-impact matrix, producing an overall risk score that determines the priority of mitigation action. The process follows a structured cycle:
Identification - through staff consultation, incident review, sector intelligence, regulatory updates, and case learning
Evaluation - assessment of likelihood and impact using consistent criteria
Prioritisation - ranking risks by overall score to focus resources where they are most needed
Mitigation - development of specific, time-bound actions to reduce risk to an acceptable level
Monitoring - regular review of risk status and mitigation effectiveness, with escalation where risks exceed acceptable thresholds
Reporting - quarterly risk reports to the Board of Trustees, with immediate escalation of critical or emerging risks
Activity-Specific Risk Assessments
NSEMM conducts detailed risk assessments for each core service area. These are living documents, updated whenever circumstances change or new risks are identified.
Tutoring services: Covering student-tutor interaction boundaries, online platform safety and monitoring, session recording and data protection, age-appropriate content, emergency response during sessions, and home working environment standards for tutors.
Mentoring services: Covering confidentiality boundaries and disclosure management, emotional wellbeing support and professional limits, power dynamics in mentoring relationships, record-keeping and information sharing, and crisis intervention procedures.
Community Education Networks: Covering venue safety and safeguarding standards at library premises, staffing ratios and supervision arrangements, child protection and adult supervision requirements, emergency procedures aligned with venue protocols, and partnership agreements with library services outlining respective safeguarding responsibilities.
Dynamic Risk Assessment
NSEMM staff are trained to conduct dynamic risk assessments during service delivery - real-time evaluation of changing circumstances that may affect a child's safety. This includes recognising changes in a student's presentation, behaviour, or environment during a session; taking immediate safety measures where a risk is identified; escalating urgent concerns through the reporting channels described in Section 9; documenting the assessment and any actions taken; and debriefing with the DSL after any dynamic risk event to capture learning.
Dynamic risk assessment is a professional skill that improves with practice and supervision. It is reinforced through training, case discussion, and reflective practice.
7. NSEMM Protect: Safeguarding Case Management System
NSEMM operates a custom-built dedicated safeguarding case management system called NSEMM Protect, accessible at protect.nsemm.org.uk. This section describes the system and its role in safeguarding practice. Understanding the system is important because it underpins how concerns are reported, triaged, investigated, and shared.
Why a Separate System?
Safeguarding data is among the most sensitive information an education provider handles. NSEMM Protect is deliberately isolated from all other NSEMM systems for the following reasons:
Data segregation: Safeguarding records are stored in a separate database with field-level encryption. No other NSEMM application can directly access this data.
Access restriction: Only the DSL and Deputy DSL have full system access. Staff can submit concerns but cannot browse cases or view reports submitted by others.
VPN requirement: The Protect management dashboard is only accessible via the NSEMM network.
Cryptographic audit trail: Every action in the system - every view, edit, export, and share - is logged with a cryptographic signature and linked together
Who Can Access What
Role
Access Level
DSL / Deputy DSL
Full access to all cases, reports, persons, audit logs. Can manage cases, create referrals, export data, and share externally.
Staff
Can submit concerns and quick notes. Can only view reports they have submitted or cases they are assigned to.
Public (anonymous)
Can submit concerns via the public reporting form.
External agencies
Scoped, read-only access to specific cases via the external agency portal, with per-case permissions set by the DSL to export referrals out of NSEMM Protect and into their own system.
Every time a DSL or Deputy DSL accesses a case or report, they must provide a documented reason for access (for example, "Reviewing new concern for triage" or "Preparing referral to social services"). This reason is recorded in the audit trail. If no reason is provided, the system refuses access. This ensures every data access has a documented, defensible purpose.
Key System Capabilities
The following capabilities are referenced throughout this policy:
Auto-scoring: When a concern is submitted, the system automatically calculates a severity score based on the categories selected, keywords in the description, whether immediate danger is flagged, and other risk factors. This ensures the most urgent concerns are surfaced first. The DSL can always override the automated score.
Duplicate detection: The system automatically checks new submissions against existing reports using phonetic name matching and multi-factor similarity scoring to prevent fragmented case management.
Immutable chronology: Case timelines are append-only and version-controlled. Original entries are never overwritten — edits create new versions with the original preserved. This is critical because chronologies may be used as evidence in legal proceedings.
SIF/CTF interchange: The system can export and import safeguarding data in Safeguarding Interchange Format (SIF) and Common Transfer File (CTF-XML) format, supporting the KCSIE 5-business-day transfer deadline when a child moves between education providers.
Redaction system: Before sharing data externally, the DSL can apply preset or custom redaction profiles to remove sensitive information. Named redaction profiles (for example, "For police sharing" or "For school transfer") can be created and reused.
External agency portal: For ongoing collaboration with partner agencies, the DSL can create scoped accounts granting read-only access to specific cases with configurable permissions.
Body map: The reporting form includes an interactive anatomical diagram for recording injury locations and details.
Automated notifications: The system sends email, in-app, and push notifications for new concerns, deadline alerts, and case updates. Urgent notifications (immediate danger reports, SLA breaches) bypass quiet hours settings.
8. Recognising Abuse and Neglect
All NSEMM staff and volunteers must be able to recognise the signs and indicators of abuse and neglect. Abuse can take many forms and children may experience more than one type simultaneously.
Physical Abuse
Physical abuse is deliberately causing physical harm to a child. This includes hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates symptoms of illness or deliberately induces illness in a child.
Indicators may include: unexplained injuries, bruises or marks in unusual locations (such as the torso, back, or face), injuries inconsistent with the explanation given, reluctance to change clothes or expose skin, flinching at sudden movements, and fear of going home.
Emotional Abuse
Emotional abuse is the persistent emotional maltreatment of a child that causes severe and persistent adverse effects on the child's emotional development. It may involve conveying to a child that they are worthless, unloved, or inadequate; imposing age-inappropriate expectations; causing children to feel frightened or in danger; or exploiting or corrupting children.
Indicators may include: excessive withdrawal or aggression, low self-esteem, difficulty forming relationships, age-inappropriate behaviour, self-harm, and a persistent need for approval or attention.
Sexual Abuse
Sexual abuse involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence. Activities may involve physical contact including penetrative and non-penetrative acts, or non-contact activities such as involving children in looking at or producing sexual images, watching sexual activities, or encouraging children to behave in sexually inappropriate ways. Sexual abuse includes abuse of children through sexual exploitation.
Indicators may include: age-inappropriate sexual knowledge or behaviour, physical symptoms in genital or anal areas, withdrawal or changes in behaviour, reluctance to undress, and sexually explicit language or behaviour.
Neglect
Neglect is the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy as a result of maternal substance abuse, or once a child is born through failure to provide adequate food, clothing, shelter, supervision, medical care, or emotional nurturing.
Indicators may include: poor hygiene or appearance, frequent hunger, inadequate clothing, untreated medical conditions, frequent absence or lateness, and a child being left alone or unsupervised.
Child-on-Child Abuse
Children can abuse other children. This is sometimes referred to as peer-on-peer abuse. NSEMM recognises that child-on-child abuse can take many forms, including bullying (including cyberbullying), physical abuse, sexual violence and sexual harassment, upskirting, sexting (youth-produced sexual imagery), and initiation-type violence and rituals.
Child-on-child abuse is never dismissed as "banter," "just having a laugh," or "part of growing up." All concerns are taken seriously and addressed through this policy.
Online Abuse
Abuse can take place wholly or partly online. NSEMM recognises that children may be at risk from:
Sexual abuse, exploitation, and grooming online
Cyberbullying and online harassment
Exposure to harmful content including pornography, violence, and self-harm material
Misinformation, disinformation, and conspiracy theories (recognised as safeguarding harms under KCSIE 2025, para 135)
Deepfakes and manipulated media
Algorithmic manipulation and radicalising content
9. How to Report a Concern
The Golden Rule
If you are concerned about a child's safety or welfare, report it. Do not wait to be certain. Do not investigate. Report.
A concern can be anything — something a child says, something you observe, a change in behaviour, something that just feels wrong. You do not need evidence. You do not need to be sure. The DSL will assess the concern and decide what action is needed.
Who Can Report
Anyone can report a safeguarding concern about a child connected to NSEMM:
Students themselves
Parents, guardians, and family members
NSEMM staff and volunteers
School staff and educational professionals
External professionals
Members of the public
How to Report
1. NSEMM Protect Online Form (Primary Channel)
Available 24/7 at: https://protect.nsemm.org.uk/report-concern
This is the primary route for all safeguarding concerns. The form is:
Accessible to anyone without an account
Available on mobile devices
Supports anonymous reporting
Protected by Cloudflare Turnstile (anti-bot verification)
Equipped with a Quick Exit button that immediately navigates to a safe website and auto-submits whatever has been entered so far
Auto-saves progress every 30 seconds, with draft recovery if the reporter returns within 7 days
On submission, the DSL is immediately notified by email, push notification, and in-app alert. An auto-generated reference number (format: NSEMM-YEAR-REP-XXXX) is provided to the reporter for tracking.
When the DSL is unavailable, or if the concern is about the DSL
4. Through Any NSEMM Staff Member
Any tutor, mentor, or staff member can receive a disclosure. Staff who receive a disclosure must:
Listen calmly and take the child seriously
Not promise confidentiality — explain that they may need to tell someone who can help
Not ask leading questions — let the child speak in their own words
Record what was said as soon as possible, using the child's own language
Submit the concern through NSEMM Protect as soon as practicable
Not investigate or confront anyone
Staff can also submit Quick Notes through the system — short observations such as voice of the child (what the child said in their own words), observations (something noticed), disclosures (something told to the staff member), or general concerns.
5. Report Concern Button in NSEMM Learn
The NSEMM Learn platform includes a "Report Concern" button that links directly to the Protect reporting form. When used, it auto-populates the reporter's details and session information, creating a direct link between the tutoring session and the safeguarding concern.
If a Child Is in Immediate Danger
Call 999. Do not wait for DSL authorisation. Ensure the child's immediate safety, then report through NSEMM Protect as soon as possible afterwards.
Safety Features of the Reporting Form
The NSEMM Protect reporting form includes several safety-critical features:
Emergency gate: Before the form loads, an emergency information screen displays contact numbers for 999, 111, Samaritans (116 123), Childline (0800 1111), and NSPCC (0808 800 5000). The reporter must acknowledge this before proceeding. This ensures anyone in immediate crisis is directed to emergency services first.
Quick Exit: A prominent button immediately navigates to a neutral website (such as Google) and auto-submits whatever has been entered, marked as a quick exit submission. This is designed for situations where the reporter's safety may be at risk if they are seen completing the form.
Auto-submit on abandonment: If a draft is left incomplete for more than 24 hours, the system auto-submits the partial information to the DSL. The rationale is that if someone started reporting a concern but could not finish, the partial information may still be critical.
Draft recovery: Reporters can resume a saved draft within 7 days.
Anonymity
The reporting form supports fully anonymous submissions. While named reports are preferable (they allow for follow-up and clarification), NSEMM will never refuse to act on a concern because the reporter wishes to remain anonymous.
10. Reporting and Response Pipeline
What Happens When a Concern Is Submitted
Auto-scoring: The system automatically calculates a severity score based on the categories selected, risk factors flagged, and keywords detected in the description. This uses on-server semantic text analysis — no personal information is shared with any third party during this process. The score determines where the concern appears in the DSL's review queue.
Duplicate detection: A background check runs against existing reports to identify potential duplicates, preventing fragmented case management.
DSL notification: The DSL and Deputy DSL receive immediate notification via email, push notification, and in-app alert. Concerns flagged as involving immediate danger trigger urgent notifications that bypass quiet hours.
Reporter confirmation: If the reporter provided an email address, they receive a confirmation with their reference number.
Audit logging: The submission is recorded in the cryptographic audit trail.
Minor concern — general observation, low-risk welfare matter
Within 5 working days
The DSL can override any auto-assigned severity at any time.
DSL Review Workflow
On reviewing a concern, the DSL will take one of the following actions:
Action
Outcome
Convert to case
Creates a new investigation in Protect, with the concern as the primary linked report
Link to existing case
Attaches the concern to an ongoing investigation
No further action
Closes the concern with documented review notes and reasoning
Request follow-up
Adds follow-up questions or actions to the concern
Archive
Moves to archived status after resolution
Every decision is recorded with the DSL's reasoning and preserved in the audit trail. The report status is updated and, where the reporter provided contact details, they are kept informed of progress as appropriate.
Review Deadlines
Each concern has an auto-calculated review deadline based on its category and severity. The system tracks compliance and alerts the DSL when deadlines approach (6 hours before) and when they are breached. SLA compliance is reported in the analytics dashboard.
11. Case Management and Investigation
Case Lifecycle
When a concern requires formal investigation, the DSL creates a case (called an "Investigation" in NSEMM Protect). Cases follow this lifecycle:
OPEN → UNDER INVESTIGATION → REFERRED / MONITORING → RESOLVED → CLOSED → ARCHIVED
Status
Meaning
Open
Active case, initial assessment underway
Under Investigation
Formal investigation in progress
Referred
Referred to external agency, awaiting response
Monitoring
Ongoing monitoring after initial intervention
Resolved
All actions completed, outcome recorded
Closed
Formally closed with documented outcome and rationale
Archived
After retention period — data pseudonymised
Linking Concerns to Cases
A critical feature of NSEMM Protect is the many-to-many relationship between concerns and cases:
One concern can be linked to multiple investigations (for example, a report about two children may feed into two separate cases)
One investigation can aggregate multiple related concerns over time
When a concern is linked to a case, it is locked to preserve evidence integrity. The case priority is automatically recalculated based on the highest severity across all linked concerns.
If a concern is later unlinked from a case, the link is soft-deleted — the historical record of the link, including when it was made, by whom, and why it was removed, is permanently preserved. This ensures the full history of investigative decisions is available for audit or legal review.
Case Closure
Closing a case requires the DSL to document:
Outcome: What was the result of the investigation
Reason: A minimum 50-character explanation of why the case is being closed
Actions taken: Summary of all actions taken during the investigation
Lessons learned: What, if anything, should inform future practice (optional but encouraged)
Follow-up: Whether follow-up monitoring is required, and if so, the date and scope
A closed case can be reopened within 30 days if new information emerges. After 30 days, a new case must be created with a cross-reference to the original.
Legal Hold
When a case is subject to legal proceedings (for example, a court order, police investigation, or regulatory inquiry), the DSL can place a legal hold on the case. This prevents archival, pseudonymisation, or any automated data processing until the hold is lifted. Legal holds can have an optional expiry date and are logged in the audit trail.
Risk Assessment
The DSL can record a formal risk assessment on any case, including the risk level (critical, high, medium, or low), identified risk factors, and a mitigation plan. Risk assessments create a timestamped event in the case chronology.
SLA Tracking
Each case has a Service Level Agreement (SLA) deadline based on its priority:
Priority
SLA Deadline
Critical
24 hours
High
3 working days
Medium
7 working days
Low
14 working days
The system tracks SLA compliance and generates alerts when deadlines approach or are breached. SLA performance is reported as part of the safeguarding quality assurance framework.
12. Information Sharing
Principles
NSEMM follows the seven golden rules for information sharing set out in Working Together to Safeguard Children 2023:
Data protection legislation is not a barrier to sharing information for safeguarding purposes
Be open and honest about why, what, how, and with whom information will be shared (unless doing so would place a child at risk)
Seek advice from the DSL or other professionals if in doubt
Where possible, share information with consent, but recognise that safeguarding may override the need for consent
Consider safety and wellbeing — share information based on the need to protect children, not the need to avoid sharing
Share necessary, proportionate, relevant, adequate, accurate, timely, and secure information
Keep a record of the decision and the reasons for it
How Information Is Shared in NSEMM Protect
All information sharing through NSEMM Protect is tracked and auditable:
Data sharing log: Every external share is recorded with what was shared, with whom, the legal basis (GDPR), the method, and a scheduled deletion date.
Redaction: Before sharing externally, the DSL can apply redaction profiles to remove information that is not necessary for the recipient. Preset levels include full (no redaction), anonymised (reporter identity and contact details removed), and summary-only (all identifying details removed).
Secure OTP sharing: For one-off external sharing, the system generates a secure link with a 6-digit one-time password sent to the recipient via a separate channel. Access is time-limited, view-limited, and revocable.
External agency portal: For ongoing collaboration, the DSL can create scoped accounts with per-case permissions controlling what each external user can see and export.
When Information Will Be Shared Without Consent
NSEMM will share information without consent where:
There is risk of significant harm to a child
A child is in immediate danger
Sharing is required by law (for example, a court order)
Sharing is necessary to prevent crime or protect public safety
Consent cannot be obtained because seeking it would increase risk to the child
All decisions to share information without consent are documented with the reasoning and legal basis.
No Sharing with Third Parties for AI or Data Processing
NSEMM does not share safeguarding information with any third-party AI, analytics, or data processing service. The auto-categorisation of concerns in NSEMM Protect uses on-server semantic text analysis that runs entirely on NSEMM's own infrastructure. No safeguarding data leaves NSEMM's systems except through the formal sharing mechanisms described above, under the relevant safeguarding legislation, and to the relevant local authority or agency.
13. Working with External Agencies
Multi-Agency Working
Effective safeguarding requires collaboration across agencies. NSEMM works with:
Local authority children's services — for child protection referrals, assessments, and support. NSEMM's primary local authority is Nottingham City Council, but as a national service, referrals may be made to any local authority depending on the child's location.
Police — for criminal investigations and immediate safety concerns
NHS services — for medical and mental health support
Schools — to coordinate safeguarding responses for shared students
LADO — for allegations against staff or volunteers (see Section 14)
NSPCC — for specialist advice and support
Charity Commission — for serious safeguarding incident reporting as required
Referrals
When a case requires external involvement, the DSL creates a formal referral in NSEMM Protect. Referral types include: police, children's social services, adult social services, LADO, NSPCC, schools, NHS, mental health services, and partner organisations.
Each referral tracks:
The target agency and contact details
The reason for referral and information shared
Whether consent was obtained (and if not, the justification)
Acknowledgement and response from the agency
The outcome
KCSIE 5-Business-Day Transfer Requirement
When a child moves between education providers, KCSIE requires safeguarding files to be transferred within 5 working days. NSEMM Protect automatically calculates this deadline and can export safeguarding data in SIF (Safeguarding Interchange Format) and CTF-XML (Common Transfer File) formats for compliant transfer.
Information Sharing with Police
NSEMM recognises that police may request safeguarding information, but is clear that voluntary compliance is voluntary — regardless of how the request is framed. NSEMM will make its own independent assessment of each request and is not obliged to comply unless legally compelled.
Verification: Every police request — without exception — is independently verified by the DSL via the force switchboard or a confirmed secure police email address before any information is disclosed. NSEMM will not act on unverified requests.
Parental consent: NSEMM will always seek parental consent before releasing information to the police unless there is a court order, production order, warrant, or an imminent serious safeguarding risk. If parental consent cannot be obtained or is overridden, the reasons are documented.
Voluntary disclosure will only be considered where all of the following conditions are met:
The request is in writing
The request is signed or authorised at a reasonably senior level
The requesting officer and their reviewing supervisor are clearly identified
A legitimate policing purpose is stated with a clearly limited scope
The legal or statutory basis for the request is specified
The DSL is satisfied that disclosure is necessary and proportionate
NSEMM will not voluntarily disclose information where:
The request is ambiguous, oral only, or lacks officer identity verification
The request seeks broad or unspecified personal data without circumscribed scope
Disclosure would conflict with safeguarding the child
The legal or statutory basis is not provided
Compelled disclosure occurs only where:
NSEMM receives a court order, production order, or statutory notice with a circumscribed scope and stated legal basis
There is an imminent serious harm or safeguarding emergency, documented in NSEMM Protect in accordance with this policy
In all cases, NSEMM will disclose only the minimum information necessary to fulfil the specific and circumscribed purpose of the request. All police information requests, whether complied with or declined, are recorded in NSEMM Protect with the request details, the DSL's assessment, the decision, and the reasoning.
14. Managing Allegations Against Staff and Volunteers
Scope
This section applies to allegations that any NSEMM trustee, employee, or volunteer has:
Behaved in a way that has harmed a child, or may have harmed a child
Possibly committed a criminal offence against or related to a child
Behaved towards a child 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 (the "transferable risk" criterion introduced in KCSIE)
Immediate Response
On receiving an allegation:
Within 2 hours: Assess immediate risk. If necessary, suspend the staff member's access to NSEMM systems and remove any unsupervised access to children. This is a neutral act and not a presumption of guilt.
Within 24 hours: Contact the LADO for guidance. For NSEMM's base location, this is Nottingham City Council LADO. For allegations involving staff or students in other local authority areas, the appropriate LADO should be contacted.
Within 24 hours: Inform the Chair of Trustees if the allegation involves the DSL. If the allegation is about the DSL, the matter should be reported directly to the LADO without informing the DSL.
As directed by LADO: Follow LADO guidance on investigation, suspension, and referral to police or children's services.
If the Allegation Concerns the DSL
If a safeguarding concern or allegation is made about the DSL (Adrian Angol-Henry), it must be reported directly to:
The Deputy DSL (Socks Ansell, [email protected]), who will escalate to LADO, or
The LADO directly, or
The Chair of Trustees
The DSL must not be informed of the allegation until the LADO has provided guidance.
Investigation and Outcomes
Investigations follow LADO guidance and may run parallel to police or children's services investigations. All investigations are documented in NSEMM Protect. Possible outcomes include:
Substantiated: Sufficient evidence to prove the allegation
Unsubstantiated: Insufficient evidence to prove or disprove
Unfounded: Evidence that the allegation is untrue
Malicious: Evidence that the allegation was deliberately false
In all cases, lessons are learned. Even unsubstantiated allegations may reveal procedural weaknesses, training gaps, or organisational culture issues that should be addressed.
Referral to DBS and Regulatory Bodies
Where a staff member or volunteer is dismissed or resigns following a substantiated allegation, NSEMM will refer the matter to the Disclosure and Barring Service (DBS) and any relevant regulatory body. Resignation does not prevent referral.
15. Low-Level Concerns
Definition
Low-level concerns are behaviours by staff or volunteers that do not meet the threshold for a formal allegation but which give cause for unease. They might include:
Being overly personal in conversations with students
Boundary issues in online communication
Inconsistent application of safeguarding procedures
Sharing inappropriate personal information
Physical contact that makes others uncomfortable
Failure to follow recording or reporting requirements
Why Low-Level Concerns Matter
Patterns of low-level behaviour can escalate to serious safeguarding issues. Recording and reviewing low-level concerns allows the DSL to identify emerging patterns, provide early support and training, take preventive action before harm occurs, and maintain an organisational culture where safeguarding standards are visible and enforced.
Process
Report: Share the concern with the DSL (or Deputy DSL). Staff should trust their instincts — if something feels wrong, report it.
Record: The DSL records the concern confidentially in NSEMM Protect.
Assess: The DSL determines the appropriate response: informal conversation with the staff member, additional training or support, formal recording for pattern monitoring, or escalation to formal procedures if the concern is more serious than initially assessed.
Monitor: The DSL reviews low-level concern records regularly for emerging patterns.
Low-level concerns are managed supportively and developmentally, not punitively. The aim is to maintain high standards and protect both children and staff through early intervention.
16. Safer Recruitment
Principles
NSEMM employs all staff (rather than engaging self-employed contractors) specifically to ensure full control over working practices, safeguarding compliance, and organisational accountability. This is a deliberate safeguarding decision.
All recruitment follows safer recruitment principles. No one begins working with children until all required checks are satisfactorily completed.
Pre-Employment Checks
All staff and volunteers undergo:
Enhanced DBS check with barred list check (England and Wales) or PVG Scheme membership (Scotland)
Right to work verification with original document inspection
Identity verification against photographic identification
Reference checks — minimum two references including most recent employer, with specific safeguarding questions and direct telephone verification
Employment history review — full chronological employment history with explanations for any gaps
Qualification verification through appropriate professional bodies where applicable
Self-declaration of any convictions, cautions, or relevant information
Overseas checks for individuals with significant overseas residence or employment
DBS Renewal
NSEMM requires DBS checks to be renewed every 3 years, or maintained through the DBS Update Service (preferred). The DBS Update Service allows NSEMM to check the status of an existing DBS certificate at any time, providing continuous assurance rather than point-in-time checks.
Safeguarding in Interviews
All interviews include:
Safeguarding-focused questions assessing knowledge, values, and judgement
Scenario-based assessment of responses to safeguarding situations
Exploration of motivation for working with children and young people
Panel interviewing to ensure robust and fair assessment
Ongoing Suitability
Recruitment checks are not a one-off exercise. NSEMM maintains ongoing suitability through:
Annual self-declaration of continued suitability, including any new convictions, cautions, or concerns
Continuous professional development in safeguarding
Performance management that explicitly includes safeguarding competence
The low-level concerns framework (Section 15)
Induction
All new staff and volunteers complete a structured induction programme before beginning any unsupervised work with children. The induction covers:
This safeguarding policy and all related procedures, with a signed acknowledgement of understanding
Practical training on recognising abuse and neglect, responding to disclosures, and using NSEMM Protect to report concerns
The Code of Conduct, including professional boundaries, online communication standards, and session environment expectations
KCSIE 2025 Part 1 (or the current equivalent)
Technology training relevant to their role, including NSEMM Learn, session recording, and platform safety features
Introduction to the DSL and Deputy DSL, with clear guidance on when and how to escalate concerns
Emergency procedures, including what to do if a child is in immediate danger
Induction is documented in the NSEMM HR system, and completion is verified before the staff member is permitted to deliver sessions independently.
Probationary Period
All new staff serve a probationary period during which safeguarding competence is explicitly assessed. This includes:
Extended probationary periods for roles carrying significant safeguarding responsibility
Regular supervision meetings with safeguarding as a standing agenda item
Direct observation of at least two sessions by the DSL or a qualified reviewer during the first month
Session recording review for safeguarding compliance, professional boundaries, and session environment standards
Feedback collection from students and, where appropriate, parents or guardians
Formal safeguarding competence assessment before confirmation of employment
Where safeguarding concerns arise during probation, the probationary period may be extended or terminated. The threshold for action during probation is deliberately lower than for confirmed staff — early identification of unsuitability is a safeguarding measure, not a punitive one.
17. Training and Professional Development
Mandatory Training
All NSEMM staff and volunteers must complete the following before beginning any work with children:
NSEMM safeguarding policy and procedures
Recognising abuse and neglect — signs, indicators, and response
How to report a concern through NSEMM Protect
Online safety and digital safeguarding
The Code of Conduct and professional boundaries
KCSIE 2025 Part 1 (or equivalent briefing for the current academic year)
Training is delivered internally and refreshed annually. All staff receive an annual safeguarding update that covers changes to legislation and guidance, learning from recent cases and near-misses, emerging risks and trends, and any changes to NSEMM's own procedures.
Role-Specific Training
Tutoring staff receive additional training on:
Online session management and professional boundaries
Session recording and monitoring responsibilities
Recognising academic pressure and mental health indicators
Safe use of generative AI tools in education
Mentoring staff receive additional training on:
Confidentiality and disclosure boundaries
Emotional support within professional limits
Crisis recognition and referral pathways
Building trusted relationships within safeguarding parameters
DSL and Deputy DSL maintain advanced training including:
Advanced child protection and multi-agency working
Investigation and case management
NSEMM Protect system administration
Legal and statutory framework (updated as legislation changes)
Mental Health First Aid (MHFA) accreditation
Training Records
All safeguarding training is tracked in the NSEMM HR system, which syncs training completion data with NSEMM Protect. This means the DSL can verify that any staff member who submits a concern or is assigned to a case has current safeguarding training. Training records include the course, date of completion, and expiry date.
Trustees
All trustees complete safeguarding training appropriate to their governance role, including awareness of their collective responsibility for safeguarding oversight and their duty to report serious safeguarding incidents to the Charity Commission.
18. Online Safety
NSEMM's Digital Environment
NSEMM delivers services primarily online through the NSEMM application suite. The platforms relevant to student interaction are:
Reporting form only — for submitting safeguarding concerns
Auth
auth.nsemm.org.uk
Yes — single sign-on, two-factor authentication
Support
support.nsemm.org.uk
Yes — help centre and ticket system
All other NSEMM applications (Admin, HR, Staff PWA, Careers, Donate) are internal or public-facing and do not involve direct student interaction.
Session Recording
All tutoring sessions conducted through NSEMM Learn are recorded for safeguarding and quality assurance purposes. Session recordings provide:
A complete record of tutor-student interactions
Evidence in the event of a safeguarding concern or complaint
Material for quality assurance and professional development
Retention: Session recordings are retained for a minimum of 180 days. Recordings are retained beyond this period where there is an active safeguarding investigation, legal proceedings, or where the DSL determines extended retention is necessary. Immediate deletion can be requested in writing for under-18s, except where exceptional circumstances apply (such as an active investigation).
Access: Session recordings are stored with encryption and access controls. Only authorised staff can access recordings, and access is logged.
Platform Safety Measures
NSEMM Learn incorporates:
Authentication and authorisation through NSEMM Auth (SSO with optional two-factor authentication)
Cameras enabled throughout all tutoring sessions
Professional communication standards enforced through the Code of Conduct
Prohibition of personal social media contact between staff and students
A "Report Concern" button linking directly to NSEMM Protect
Content Risks
In accordance with KCSIE 2025, NSEMM recognises the following categories of online content risk:
Content: Being exposed to harmful material, including misinformation, disinformation, conspiracy theories, pornography, violence, self-harm, and radicalisation content
Contact: Being subjected to harmful interaction, including grooming, cyberbullying, and harassment
Conduct: Engaging in harmful behaviour online, including sexting, harassment, and sharing harmful content
Commerce: Being exposed to commercial risks including gambling, phishing, financial fraud, and aggressive advertising
Filtering and Monitoring
NSEMM applies age-appropriate filtering within its platforms. Where students access NSEMM services through their own devices and home internet connections, NSEMM provides guidance to parents and carers on internet safety but cannot control the home filtering environment.
NSEMM conducts periodic self-assessment against the DfE's "Plan Technology for Your School" framework (September 2024), adapted for our context as an online education provider, to ensure our filtering and monitoring approach meets current standards.
Cyberbullying
Cyberbullying through NSEMM platforms is treated as a safeguarding concern and addressed through this policy. NSEMM's response includes immediate intervention to stop the behaviour, support for the affected child, appropriate consequences for the perpetrator, and ongoing monitoring.
19. Generative AI in Education
NSEMM's Use of AI
NSEMM uses generative AI tools for educational content generation, specifically for producing exam questions, revision resources, and learning materials. These tools are integrated into the NSEMM Learn platform.
Safeguarding Boundaries
AI is not used in any context involving personal information, safeguarding data, or student-identifiable information. This is a deliberate and non-negotiable design decision. Specifically:
AI tools process only educational content (subject matter, question formats, mark schemes) — never student names, records, or personal data
The NSEMM Protect safeguarding system does not use AI. The auto-categorisation of concerns uses on-server semantic text analysis that runs entirely on NSEMM's own infrastructure, not a third-party AI service
No safeguarding information is shared with any AI provider, cloud AI service, or third-party data processor
Safeguarding information is shared only with relevant local authorities and agencies under safeguarding legislation through the formal mechanisms described in Section 12
AI Content Safeguards
NSEMM's AI tools for educational content incorporate:
Age-appropriate filtering based on the student's declared date of birth
Content blocking of harmful, inappropriate, or dangerous material
Protection against jailbreaking (attempts to circumvent safeguarding controls)
Complete input and output logging with user identification
Automatic flagging of content with safeguarding implications, routed to NSEMM Protect for DSL review
These safeguards align with the DfE's "Generative AI: Product Safety Expectations" guidance (January 2025), which sets out the capabilities and features expected in AI products used in educational settings.
20. Specific Safeguarding Concerns
This section provides guidance on specific safeguarding issues that staff should be aware of. It is not exhaustive — staff should consult KCSIE 2025 Part 2 and Annex B for comprehensive information.
Child Sexual Exploitation (CSE)
CSE is a form of sexual abuse where a child is manipulated or coerced into sexual activity in exchange for something — such as gifts, money, attention, affection, or status. The child may not recognise the exploitative nature of the relationship. CSE can occur online and offline, and children can be exploited by individuals or groups.
Child Criminal Exploitation (CCE) and County Lines
CCE involves children being groomed and exploited to commit crimes, often drug-related. County lines is a specific form of CCE where criminal gangs use children to transport drugs between urban and rural areas. Indicators include unexplained money or possessions, changes in behaviour, missing episodes, and signs of physical assault.
Female Genital Mutilation (FGM)
FGM is illegal in the UK and constitutes a criminal offence. There is a mandatory reporting duty requiring professionals to report known cases of FGM in under-18s to the police. NSEMM staff who discover that FGM has been carried out on a child under 18 must report this to the police (via 101) and to the DSL.
Radicalisation and the Prevent Duty
Under the Counter-Terrorism and Security Act 2015, NSEMM has a duty to have due regard to the need to prevent people from being drawn into terrorism. Staff are trained to recognise signs of radicalisation and to report concerns through normal safeguarding channels. The DSL will assess whether a Prevent referral to the local authority Channel programme is appropriate.
Honour-Based Abuse
So-called "honour-based" abuse encompasses crimes committed to protect or defend the perceived honour of a family or community. This includes FGM, forced marriage, and practices such as breast ironing. Staff should be aware that disclosures of honour-based abuse may place the child at increased risk if the family becomes aware, and should consult the DSL before taking any action that might alert family members.
Modern Slavery and Trafficking
Children can be trafficked for sexual exploitation, labour exploitation, criminal activity, or domestic servitude. Trafficking does not require movement across borders — it can occur within the UK. Indicators include appearing to be controlled by others, signs of physical abuse, fear of authorities, and working excessive hours.
Serious Violence
Staff should be aware of indicators that a child may be involved in serious violence, including unexplained injuries, possession of weapons, changes in friendship groups, decline in attendance, and increased absence.
Self-Harm and Suicide
Self-harm and suicidal ideation are safeguarding concerns. Staff who become aware that a child is self-harming or expressing suicidal thoughts must report through NSEMM Protect. The DSL will assess the level of risk and determine the appropriate response, which may include referral to specialist mental health services.
NSEMM does not use physical discomfort techniques (such as holding ice cubes or snapping rubber bands) as coping strategies for self-harm, as these reinforce self-destructive behaviour.
Upskirting
Upskirting is a criminal offence under the Voyeurism (Offences) Act 2019. It involves taking a photograph or video under a person's clothing without their knowledge or consent. Any reports of upskirting are treated as a safeguarding concern.
21. Missing and Absent from Education
NSEMM recognises that being absent or missing from education can be a warning sign of safeguarding concerns, including sexual abuse, sexual exploitation, and child criminal exploitation. This aligns with KCSIE 2025, which clarifies that absence (not just being "missing") is a recognised indicator.
Early Warning Indicators
NSEMM monitors for:
Frequent cancellations: Three or more cancellations per month without valid explanation
No-show patterns: Repeatedly failing to attend scheduled sessions without notice
Pattern absences: Consistent absence around specific topics, times, or circumstances
Sudden changes: Dramatic shifts in previously reliable attendance
Response Protocol
Stage 1 — First absence: Tutor documents absence. Immediate attempt to contact the student through normal channels.
Stage 2 — Second consecutive absence: Contact with parent or guardian within 24 hours. Discussion to understand reasons and offer support.
Stage 3 — Three or more instances: Automatic DSL review. Comprehensive risk assessment considering all available information. School notification where applicable.
Stage 4 — Persistent concerns: Formal safeguarding referral to the appropriate local authority. Multi-agency response as required.
Information Sharing with Schools
Where NSEMM works alongside a student's school, attendance information is shared with the school's designated contact to enable coordinated safeguarding responses and avoid working in isolation.
School Attendance Coding
Where NSEMM activities are relevant to school attendance recording, the following codes apply:
Code B (Educated off-site): For supervised educational activities delivered by NSEMM as part of a planned, agreed programme with the school
Code C (Authorised absence): For NSEMM-facilitated educational visits, university visits, interviews, or other approved educational activities
NSEMM will provide written confirmation of attendance at NSEMM activities to schools on request, to support accurate attendance recording. This is coordinated through the school's designated contact.
22. Gender Identity
NSEMM's Position
NSEMM is a registered charity providing educational services, not a school. The DfE's draft guidance on gender questioning children (2023) is non-statutory and directed at schools. NSEMM is not bound by it. NSEMM has developed its own evidence-based approach, grounded in the positions of leading professional bodies in child development and paediatrics.
NSEMM's core position is that using a young person's chosen name and pronouns is a matter of basic respect and dignity. Education providers routinely accommodate preferred names — shortened names, middle names, entirely different names — without clinical assessment, waiting periods, or parental consultation. NSEMM applies the same principle to names and pronouns associated with gender identity. This is not a clinical intervention and it does not constitute initiating or facilitating social transition.
Evidence Base
NSEMM's approach is informed by:
The Society for Research in Child Development (SRCD) has published evidence that social acceptance, including the use of chosen names and pronouns, is associated with improved mental health outcomes for gender-diverse young people, including reduced depression, anxiety, and suicidal ideation. The SRCD found that transgender youth who could use their chosen name in school settings were 56% less likely to report suicidal behaviour. The SRCD's position, grounded in developmental science, is that respecting a young person's identity supports their wellbeing and does not cause harm.
The Royal College of Paediatrics and Child Health (RCPCH) has emphasised that gender-diverse children and young people deserve compassionate, respectful care. The RCPCH supports approaches that listen to children and young people, respect their experiences, and avoid unnecessary barriers to basic social recognition. The College's position recognises that the use of a preferred name is a low-risk, high-benefit practice that falls well within the scope of supportive care.
Further peer-reviewed evidence supports this approach. Russell et al. (2018, Journal of Adolescent Health) found that chosen name use was associated with significant reductions in depressive symptoms, suicidal ideation, and suicidal behaviour among transgender youth, with each additional context in which the chosen name was used associated with a 29% decrease in suicidal ideation.
Neither SRCD nor RCPCH supports the characterisation of chosen name and pronoun use as a form of social transition requiring clinical oversight, waiting periods, or mandatory parental consent. NSEMM's view is that where peer-reviewed evidence indicates that using a student's chosen name and pronouns is protective for mental health, and no evidence of harm exists sufficient to justify refusal, the welfare of the child requires accommodation.
What Happens When a Student Requests a Chosen Name or Pronouns
The request is respected. Staff use the student's chosen name and pronouns as a matter of course. This is not treated as a process, an application, or a safeguarding event.
A brief welfare check-in takes place. The DSL or a designated member of staff has a supportive conversation with the student to ensure they are well, to understand their wishes, and to offer any additional support. This is a pastoral check-in, not an assessment or gatekeeping exercise.
The DSL is informed. The change of student information is logged in NSEMM Protect as an audit entry. This is a routine data change record, not a safeguarding concern — it is logged because all changes to student information are logged.
Systems are updated. The student's chosen name is used across all day-to-day NSEMM systems (Learn, messaging, session records). The student's legal name is retained in legal and safeguarding records for statutory and identification purposes.
No waiting period. NSEMM does not impose a waiting period. The student is reminded that they can change their mind at any time, and any change — in either direction — will be respected without question.
No proactive initiation. NSEMM will not suggest, encourage, or initiate social transition. All requests must come from the student. Staff should not speculate about a student's gender identity or raise the topic unless the student has done so.
Parental Involvement
Parental involvement in a student's use of a chosen name or pronouns is the student's choice. NSEMM encourages students to involve their parents or carers, and will offer to support that conversation where helpful. However, NSEMM will not inform parents or carers of a student's chosen name or pronoun use without the student's consent, unless:
The DSL identifies a specific safeguarding concern that necessitates parental involvement (for example, if the student is at risk of harm)
There is a legal requirement to share information with parents (for example, a court order)
The student is assessed as being at risk from the non-disclosure itself
These exceptions are safeguarding decisions, not gender-specific policies. They apply the same threshold as any other decision about sharing information with parents — the test is whether non-disclosure creates or sustains a risk to the child, not whether the information relates to gender identity.
Recording
Chosen name is used in all day-to-day systems and communications
Legal name is retained in legal records, safeguarding records, and official documentation
Biological sex is recorded for safeguarding and legal purposes where required, in accordance with the Equality Act 2010 as interpreted by the Supreme Court in For Women Scotland (2025)
The change is logged as an audit entry in NSEMM Protect
What This Section Does Not Cover
NSEMM is an education provider. We do not provide medical advice, clinical referrals for gender services, or any form of clinical intervention. If a student raises concerns about their gender identity that go beyond the use of a chosen name and pronouns — for example, if they are experiencing significant distress — NSEMM's role is to provide pastoral support and, where appropriate, signpost to specialist services such as their GP or NHS gender identity services.
Regulatory Context
KCSIE 2025 states that updated DfE guidance on gender questioning children is expected. Should that guidance be published, NSEMM will review it for any provisions that apply to education providers beyond schools. NSEMM's position will continue to be guided by the best available developmental science and the positions of SRCD and RCPCH.
23. Mental Health and Wellbeing
Recognition
Mental health difficulties can be both a cause and a consequence of safeguarding concerns. NSEMM staff are trained to recognise indicators of mental health difficulties, including significant changes in behaviour or mood, withdrawal from activities or relationships, expressions of hopelessness or low self-worth, excessive anxiety or fearfulness, decline in academic engagement, and self-harm or suicidal ideation.
The Mental Health Act 2025
The Mental Health Act 2025 received Royal Assent on 18 December 2025 and will be implemented over 8–10 years. Key changes relevant to NSEMM include:
Enhanced rights for children and young people: Children's views must be more central to treatment decisions. NSEMM staff should be aware that students subject to the Act have strengthened rights to participate in decisions about their care.
Nominated person: The Act replaces "nearest relative" with a "nominated person" role, giving patients (including young people) greater choice in who supports them.
Increased protections for autistic people and those with learning disabilities: The Act raises the detention threshold to "serious harm," providing stronger protections against inappropriate detention.
NSEMM will update training when the new Code of Practice is published (expected 2026–2027).
NSEMM's Approach
NSEMM's primary role is educational. Our approach to mental health is:
Signpost, not treat: We direct students and families to appropriate professional support rather than providing direct mental health intervention
Recognise and report: Mental health concerns are treated as potential safeguarding indicators and reported through NSEMM Protect
Coordinate: We work with schools, families, and health services to ensure students receive appropriate support
Support ongoing: We maintain a supportive educational environment while specialist support is accessed
The DSL holds Mental Health First Aid (MHFA) accreditation and can provide initial support and appropriate referral.
24. Domestic Abuse
Recognition
Domestic abuse is a significant safeguarding concern affecting children who witness or experience it. NSEMM recognises that domestic abuse includes physical, emotional, psychological, sexual, financial, and technological abuse, and that children are victims of domestic abuse in their own right — not merely witnesses.
Indicators in Children
Staff should be alert to: unexplained injuries, fear of going home, regression in behaviour, sleep disturbances, withdrawal, academic decline, age-inappropriate sexual knowledge, and taking on adult caring responsibilities.
Response
When domestic abuse is suspected or disclosed:
Assess immediate safety of the child and non-abusive family members
Report through NSEMM Protect
Do not take actions that might escalate the situation or alert the abusive family member
The DSL will determine appropriate referral, which may include children's social services, police, and specialist domestic abuse services
Ongoing support is provided to the child within NSEMM's educational setting
Staff must not promise complete confidentiality, but should reassure the child that information will only be shared with people who need to know in order to help keep them safe.
25. Service-Specific Safeguarding
Tutoring Services
All tutoring sessions are delivered through NSEMM Learn with the following safeguarding measures:
Cameras enabled throughout all sessions
Automatic session recording with secure storage
Professional backgrounds and appropriate dress required (see Code of Conduct)
No tutoring from public spaces without specific DSL authorisation
Clear sight lines maintained throughout sessions
Emergency intervention capability for high-risk sessions
"Report Concern" button available within the platform
In business continuity situations where NSEMM Learn is unavailable, sessions may be conducted directly through Lessonspace. The same safeguarding standards apply — sessions must still be recorded and the DSL must be notified of the platform switch.
Mentoring Services
Mentoring sessions operate with additional safeguarding considerations:
Informed consent: Mentors, students, and parents/guardians sign agreements establishing confidentiality boundaries and disclosure obligations before mentoring begins
Confidentiality limits: Mentors explain at the outset that confidentiality cannot be maintained where safeguarding concerns arise
Note-taking: Factual notes are taken during or after each session, stored securely with restricted access
Disclosure management: Mentors are trained to create safe environments for disclosure while understanding their obligation to report through NSEMM Protect
Community Education Networks (Library Sessions)
Community Education Network sessions are currently paused, with plans to resume. When operational:
Sessions are held at council library premises
NSEMM staff are present and identifiable throughout
Minimum staffing ratios are maintained
Pre-session safety checks are conducted
Emergency procedures align with library protocols
Written agreements with library services outline safeguarding responsibilities
26. Emergency Procedures
Immediate Danger
If a child is in immediate danger:
Call 999. This does not require DSL authorisation.
Ensure the child's immediate safety
Do not leave the child alone if they are at immediate risk
Report through NSEMM Protect as soon as it is safe to do so
Follow up with telephone contact to the DSL
Urgent Reporting (Within 1 Hour)
For concerns requiring urgent DSL action but not emergency services:
Submit through NSEMM Protect at protect.nsemm.org.uk/report-concern
Flag the concern as involving immediate danger (this triggers urgent notifications that bypass quiet hours)
NSEMM Protect provides automated monitoring and alerting:
Immediate danger reports trigger urgent notifications to the DSL and Deputy DSL via email, push notification, and in-app alert, bypassing quiet hours
SLA-approaching alerts fire 6 hours before a review deadline
SLA breach alerts fire when deadlines are missed
Daily dashboard review ensures no concern goes unaddressed
Critical case alerts for unassigned high-priority cases
The DSL reviews all incoming concerns daily, including weekends and bank holidays during term time. The automated alerting system ensures urgent matters are surfaced immediately regardless of the time of day.
27. Data Protection and Record Keeping
Principles
NSEMM processes safeguarding data in compliance with the Data Protection Act 2018 and UK GDPR. The lawful bases for processing safeguarding data are:
Legal obligation (Article 6(1)(c)) — NSEMM has statutory duties to safeguard children
Vital interests (Article 6(1)(d)) — where processing is necessary to protect someone's life
Legitimate interests (Article 6(1)(f)) — the legitimate interest in safeguarding children
Substantial public interest (Schedule 1, Part 2 DPA 2018) — for processing special category data (such as health information) for safeguarding purposes
How Records Are Stored
All safeguarding records are stored in NSEMM Protect, which provides:
Field-level encryption for sensitive data including subject details, medical information, additional needs, risk factors, and case notes
Separate database that cannot be accessed by any other NSEMM application
VPN-only access to the management dashboard
Cryptographic audit trail with chain-hashing that detects any tampering with the record
Role-based access ensuring staff can only see what they need to
Documented access reasons for every view of sensitive data
Recording Standards
All safeguarding records should be:
Factual — based on what was observed, said, or reported, not interpretation
Chronological — events recorded in order with accurate timestamps
Attributed — clear identification of who recorded the information and when
Proportionate — sufficient detail for safeguarding purposes without unnecessary personal information
Immutable — original records preserved even when updates are made (NSEMM Protect enforces this through version-controlled, append-only chronologies)
Retention
Record Type
Retention Period
Child protection records
Until the subject reaches age 25, or 6 years from case closure (whichever is longer)
Incident records
3–6 years
Other safeguarding records
6 years
Session recordings
180 days minimum; extended during active investigations
Audit logs
7 years
Pseudonymisation and Archival
When a record reaches the end of its retention period, NSEMM Protect automatically:
Marks the case as archived
Replaces personal identifiers with pseudonymous tokens
Preserves a hash of the original data for verification if needed
Records the pseudonymisation date and time
Records under legal hold are exempt from pseudonymisation until the hold is lifted.
Data Breach
If a data protection breach involves safeguarding information, it is treated as both a data protection incident and a safeguarding concern. The DSL assesses the safeguarding implications while the data breach is managed under the Data Protection Policy. NSEMM Protect includes structured data breach tracking with automatic calculation of the 72-hour ICO notification deadline.
Subject Access Requests
Subject access requests involving safeguarding records are managed through NSEMM Protect, which provides a structured SAR workflow with a 30-day response deadline, identity verification, and processing tracking. The DSL assesses whether any exemptions apply (for example, where disclosure would prejudice a criminal investigation or endanger a child).
28. Quality Assurance
Performance Monitoring
NSEMM monitors safeguarding performance through:
Real-time dashboard: NSEMM Protect provides live statistics on active cases, pending reviews, SLA compliance, and critical alerts
Weekly digest: Automated summary of new concerns, case activity, and performance metrics
Monthly DSL report to trustees: Covering case volumes, trends, response times, and any serious incidents
Quarterly performance analysis: Deeper review of patterns, emerging risks, and effectiveness of interventions
Annual safeguarding audit: Comprehensive review of policy, practice, and outcomes
Session Monitoring
Tutoring sessions are subject to random quality reviews conducted approximately bi-monthly. Reviews are conducted by the DSL or qualified reviewers and assess safeguarding compliance alongside educational quality. Targeted monitoring may be applied for staff under development or following concerns.
Learning from Cases
NSEMM applies learning from all safeguarding cases, not only those with serious outcomes. This includes:
Case reviews for all substantiated concerns
Near-miss analysis to identify systemic improvements
Review of unsubstantiated cases for procedural lessons
Integration of learning into training and policy updates
Charity Commission annual return including safeguarding information
Serious incident reports to the Charity Commission where statutory thresholds are met
Contribution to local safeguarding arrangements as appropriate
29. Whistleblowing
Purpose
NSEMM is committed to an environment where staff, volunteers, students, and families can raise concerns about safeguarding failures or potential wrongdoing without fear of reprisal. Whistleblowing is protected under the Public Interest Disclosure Act 1998.
What Can Be Reported
Whistleblowing concerns include:
Safeguarding failures or inadequate child protection responses
Criminal activity or illegal behaviour within the organisation
Danger to health and safety
Breach of legal or regulatory obligations
Cover-up of wrongdoing or failure to report serious concerns
External channels (where internal channels are inappropriate, insufficient, or where the concern involves the DSL and trustees):
Charity Commission
Local Authority Designated Officer (LADO)
Police (for criminal activity)
NSPCC Whistleblowing Helpline: 0800 028 0285
Protections
No detriment will be suffered by anyone raising a concern in good faith
Confidentiality is maintained where possible and safe
All concerns are acknowledged within 48 hours
A thorough investigation is conducted appropriate to the nature of the concern
The whistleblower is kept informed of progress where possible
30. Policy Review and Governance
Review Cycle
This policy is:
Approved by the full Board of Trustees
Reviewed annually with a comprehensive review at the 12-month anniversary
Checked at the 6-month mid-year point for any legislative changes, operational developments, or learning from cases that require interim updates
Updated immediately if a significant legislative change, serious incident, or systemic issue requires it
Version Control
All policy versions are retained. Changes between versions are documented with the date, nature of the change, and the reason.
Responsibilities
Person
Responsibility
DSL
Drafting policy updates, implementing changes, reporting to trustees
Deputy DSL
Supporting the DSL, deputising in policy matters
Board of Trustees
Approving policy, providing strategic oversight, holding the DSL to account
All staff and volunteers
Reading, understanding, and following this policy
Staff Acknowledgement
All staff and volunteers are required to confirm that they have read and understood this policy. This acknowledgement is recorded in the HR system and refreshed annually.
