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. Detailed internal procedures supporting this policy are set out in a separate Safeguarding Standard Operating Procedures document available to all NSEMM staff.
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. NSEMM's safeguarding records are maintained with robust technical controls to ensure their integrity cannot be compromised.
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 via the NSEMM Protect reporting form.
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)
NSEMM is based in the City of Nottingham. The primary LADO contact is through Nottingham City Council. As we operate nationally, referrals to other local authority LADOs may be necessary depending on where a student or staff member is located. The DSL is responsible for identifying and contacting the appropriate LADO.
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. Risk categories include online safety, staff and volunteer conduct, environmental safety (including venues for Community Education Networks), activity-specific risks for tutoring and mentoring, external partnership risks, data protection, and organisational resilience.
Risk Assessment Process
Each identified risk is assessed using a likelihood-and-impact approach, producing an overall risk score that determines the priority of mitigation action. Risks are identified through staff consultation, incident review, sector intelligence, and regulatory updates. They are evaluated, prioritised, mitigated through specific time-bound actions, monitored for effectiveness, and reported to the Board quarterly with immediate escalation for critical or emerging risks.
Activity-Specific Risk Assessments
NSEMM conducts detailed risk assessments for each core service area – tutoring, mentoring, and Community Education Networks. These are living documents, updated whenever circumstances change or new risks are identified. They cover the specific safeguarding risks associated with each activity, including interaction boundaries, platform safety, session environment standards, confidentiality management, venue safety, and emergency procedures.
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 or behaviour, taking immediate safety measures, escalating urgent concerns, and documenting the assessment and actions taken.
7. How We Manage Safeguarding Concerns
NSEMM Protect
NSEMM operates a dedicated custom safeguarding case management system called NSEMM Protect, accessible at protect.nsemm.org.uk. This system is deliberately separate from all other NSEMM platforms. Safeguarding records are stored in their own database, isolated from other organisational data, with strong encryption and access controls.
Only the DSL and Deputy DSL have full access to the system. Staff can submit concerns but cannot browse cases or view reports submitted by others. Every action in the system is logged in an immutable audit trail that cannot be tampered with, ensuring the integrity of safeguarding records for any future legal or regulatory review.
Why a Separate System
Safeguarding data is among the most sensitive information an education provider handles. Keeping it in a separate, dedicated system with its own security controls, access restrictions, and audit mechanisms ensures that the standard of protection matches the sensitivity of the information. It also means that safeguarding records are not affected by changes, incidents, or access decisions in any other part of NSEMM's technology infrastructure.
What the System Does
NSEMM Protect supports the full safeguarding workflow:
Concern submission – anyone can submit a concern through the online reporting form, or staff can submit concerns and quick notes through their staff accounts
Triage and assessment – submitted concerns are prioritised by severity so the most urgent matters are addressed first. The DSL reviews each concern and decides on the appropriate response
Case management – where a concern requires formal investigation, the DSL creates a case that tracks all related information, actions, and outcomes in a single chronological record
External sharing – when information needs to be shared with local authorities, police, or other agencies, the system supports secure, auditable sharing with controls to ensure only the necessary information is disclosed
Record keepingand auditing – all records are maintained with appropriate retention periods and are protected against unauthorised access, modification, or deletion
Detailed operational procedures for NSEMM Protect are set out in the internal Safeguarding Standard Operating Procedures.
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. 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); deepfakes and manipulated media; and 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, family members, NSEMM staff and volunteers, school staff, external professionals, and members of the public.
This is the primary route for all safeguarding concerns. The form is accessible to anyone without needing an account, works on mobile devices, supports anonymous reporting, and provides an auto-generated reference number for tracking. On submission, the DSL is immediately notified.
Before the form loads, an emergency information screen displays contact numbers for emergency services and key support organisations, ensuring anyone in immediate crisis is directed to the right help first.
The form includes a Quick Exit button that immediately navigates to a neutral website if the reporter's safety may be at risk.
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, not ask leading questions, record what was said as soon as possible using the child's own language, submit the concern through NSEMM Protect as soon as practicable, and not investigate or confront anyone.
5. Report Concern Button in NSEMM Learn
The NSEMM Learn platform includes a "Report Concern" button that links directly to the Protect reporting form.
If a Child Is in Immediate Danger
Call 999. Do not wait for the DSL. Ensure the child's immediate safety, then report through NSEMM Protect as soon as possible afterwards.
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. However, it does make it difficult for investigation and follow up
10. What Happens When a Concern Is Reported
When a concern is submitted through NSEMM Protect:
It is prioritised. The system assigns an initial severity based on the information provided. This ensures the most urgent concerns are surfaced to the DSL first. The DSL can adjust the severity at any time based on their professional judgement.
The DSL is notified immediately. Concerns involving immediate danger trigger urgent notifications regardless of time of day.
The reporter receives confirmation. If contact details were provided, the reporter receives a confirmation with their reference number.
The DSL reviews the concern and decides on the appropriate response. This may include creating a formal investigation, linking the concern to an existing case, requesting further information, referring to an external agency, or determining that no further action is needed. Every decision is documented with the DSL's reasoning.
The reporter is kept informed of progress as appropriate, within the constraints of confidentiality and safeguarding.
Everything is recorded in an immutable audit trail. Original records are never overwritten – edits create new versions with the original preserved.
The DSL reviews all incoming concerns daily, including weekends and bank holidays during term time. Detailed response procedures and timescales are set out in the internal Safeguarding Standard Operating Procedures.
11. 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
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 custom-built on-server text analysis that runs entirely on NSEMM's own infrastructure. No safeguarding data leaves NSEMM's systems except through the formal sharing mechanisms described in this section, under the relevant safeguarding legislation, and to the relevant local authority or agency.
12. Working with External Agencies
Multi-Agency Working
Effective safeguarding requires collaboration across agencies. NSEMM works with local authority children's services (Nottingham City Council as primary, but any local authority depending on the child's location), police, NHS services, schools, the LADO, NSPCC, and the Charity Commission.
Referrals
When a case requires external involvement, the DSL creates a formal referral through NSEMM Protect. Each referral records the target agency, the reason for referral and information shared, whether consent was obtained (and if not, the justification), and the agency's response and 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 can export safeguarding data in standard interchange formats to meet this requirement.
Information Sharing with Police
NSEMM recognises that police may request safeguarding information, but is clear that voluntary compliance is indeed that – 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 and/or consent from the young person before releasing information to the police unless there is a court order, production order, warrant, or an imminent serious safeguarding risk. If parental consent and/or consent from the young person 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 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 with the request details, the DSL's assessment, the decision, and the reasoning.
13. 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.
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. 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.
14. 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, or 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.
Assess: The DSL determines the appropriate response: informal conversation, additional training, formal recording for pattern monitoring, or escalation to formal procedures.
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.
15. 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
Minimum two references including most recent employer, with specific safeguarding questions and direct telephone verification
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; and panel interviewing to ensure robust and fair assessment.
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, practical training on recognising abuse and responding to disclosures, the Code of Conduct, KCSIE 2025 Part 1, technology training for their role, introduction to the DSL and Deputy DSL, and emergency procedures. Induction 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 regular supervision with safeguarding as a standing agenda item, direct observation of sessions, session recording review, feedback collection, and formal safeguarding competence assessment before confirmation of employment. Where safeguarding concerns arise during probation, the probationary period may be extended or terminated.
Ongoing Suitability
Recruitment checks are not a one-off exercise. NSEMM maintains ongoing suitability through annual self-declaration, regular supervision incorporating safeguarding performance, continuous professional development, performance management that explicitly includes safeguarding competence, and the low-level concerns framework (Section 14).
16. 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 covering 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, and 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, and 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, legal and statutory framework updates, and Mental Health First Aid (MHFA) accreditation.
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.
Training Records
All safeguarding training is tracked in the NSEMM HR system. This ensures that anyone working with children has current, verified safeguarding training. Training records include the course, date of completion, and expiry date.
17. Online Safety
NSEMM's Digital Environment
NSEMM delivers services primarily online through the NSEMM application suite. The student-facing platforms are NSEMM Learn (learn.nsemm.org.uk) for tutoring sessions, homework, messaging, and progress tracking; NSEMM Auth (auth.nsemm.org.uk) for secure login with optional two-factor authentication; and NSEMM Support (support.nsemm.org.uk) for the help centre and ticket system. The Protect reporting form is also publicly accessible for submitting safeguarding concerns.
Session Recording
All tutoring sessions conducted through NSEMM Learn are recorded for safeguarding and quality assurance purposes. Recordings provide a complete record of interactions, evidence in the event of a concern, and material for quality assurance. Recordings are retained for a minimum of 180 days and longer where there is an active safeguarding investigation or legal proceedings. Access to recordings is restricted and logged.
Platform Safety Measures
NSEMM Learn incorporates secure 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, and a "Report Concern" button linking directly to NSEMM Protect.
In business continuity situations where NSEMM Learn is unavailable, sessions may be conducted directly through Lessonspace. The same safeguarding standards apply.
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, adapted for our context as an online education provider.
Cyberbullying
Cyberbullying through NSEMM platforms is treated as a safeguarding concern. NSEMM's response includes immediate intervention, support for the affected child, appropriate consequences for the perpetrator, and ongoing monitoring.
18. 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 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 11
AI Content Safeguards
NSEMM's AI tools for educational content incorporate age-appropriate filtering, content blocking of harmful or inappropriate material, protection against attempts to circumvent safeguarding controls, complete input and output logging, and automatic flagging of content with safeguarding implications for DSL review.
These safeguards align with the DfE's "Generative AI: Product Safety Expectations" guidance (January 2025).
19. 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. Upskirting is a criminal offence under the Voyeurism (Offences) Act 2019. Any reports of upskirting are treated as a safeguarding concern.
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.
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.
20. 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 per month without valid explanation), no-show patterns, consistent absence around specific topics or times, and sudden changes 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.
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.
21. 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.
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) 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 as a routine audit entry. This is a 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. 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
Registered 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 a routine audit entry
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.
22. 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 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 in treatment decisions, the replacement of "nearest relative" with a "nominated person" role giving patients greater choice, and increased protections for autistic people and those with learning disabilities through a raised detention threshold. 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.
23. 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.
24. 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, no tutoring from public spaces without specific DSL authorisation, clear sight lines maintained, emergency intervention capability, and a "Report Concern" button available within the platform.
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 with NSEMM staff present and identifiable throughout, minimum staffing ratios maintained, pre-session safety checks conducted, emergency procedures aligned with library protocols, and written agreements with library services outlining safeguarding responsibilities.
25. Emergency Procedures
Immediate Danger
Trained first aiders must be present at all NSEMM activities. For the avoidance of doubt, medical and other healthcare students are not considered first aiders unless they have completed BLS and are competent in the relevant first aid skills required in the situation; or hold a recognised first aid qualification.
Hold a recognised first aid qualification, or
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 direct contact to the DSL
Urgent Concerns
For concerns requiring urgent DSL action but not emergency services:
Submit through NSEMM Protect at protect.nsemm.org.uk/report-concern, flagging the concern as involving immediate danger (this triggers urgent notifications)
All medical incidents, regardless of severity, must be recorded on the NSEMM Protect reporting form. Submit through NSEMM Protect at protect.nsemm.org.uk/report-concern, flagging the concern as involving immediate danger (this triggers urgent notifications)
Urgent clinical need (requires same-day medical assessment but not immediately life-threatening)
Contact 111 or 999 for advice where appropriate.
If advised to attend urgent care or hospital, parents must be contacted immediately and asked to mobilise the child to hospital themselves where possible.
NSEMM staff must not transport children in personal vehicles.
Location of hospital/UTC must be recorded.
Parental contact must be attempted immediately after emergency services are contacted.
If 999 advises self-transport, staff should accept this assessment, but must get a reference number *if possible, *and parents should be contacted first to mobilise the child where possible.
If Parents Cannot Be Contacted
If parents cannot be reached and urgent medical assessment is required:
Two NSEMM adults must accompany the child.
Travel must be via a trackable registered taxi, not a personal vehicle.
Time of departure and arrival must be recorded.
The destination (hospital, UTC, or as directed by 111/999) must be logged.
Parental consent is not required in an emergency where medical treatment is necessary in the child’s best interests, but parental contact must always be attempted and documented.
Monitoring
The DSL reviews all incoming concerns daily, including weekends and bank holidays during term time. The system provides automated alerting to ensure urgent matters are surfaced immediately regardless of time of day.
26. 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)), vital interests (Article 6(1)(d)), legitimate interests (Article 6(1)(f)), and substantial public interest (Schedule 1, Part 2 DPA 2018) for processing special category data.
How Records Are Stored
All safeguarding records are stored in NSEMM Protect, which provides encryption for sensitive data, a separate database isolated from all other NSEMM systems, strict access controls with documented reasons for every access to sensitive data, and an immutable audit trail that detects any tampering with records.
Recording Standards
All safeguarding records should be factual (based on observation, not interpretation), chronological, clearly attributed to the person who recorded the information, proportionate, and immutable (original records preserved even when updates are made).
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
10 years
Other safeguarding records
10 years
Session recordings
180 days minimum; extended during active investigations
Audit logs
10 years
When records reach the end of their retention period, personal identifiers are removed through pseudonymisation. Records subject to legal proceedings are exempt from disposal until proceedings conclude.
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.
Subject Access Requests
Subject access requests involving safeguarding records are managed through NSEMM Protect with a 30-day response deadline, identity verification, and assessment of any applicable exemptions.
27. Quality Assurance
Performance Monitoring
NSEMM monitors safeguarding performance through real-time reporting within NSEMM Protect, monthly DSL reports to trustees covering case activity, trends, and response performance, quarterly performance analysis reviewing patterns, emerging risks, and intervention effectiveness, and an annual safeguarding audit providing a comprehensive review of policy, practice, and outcomes.
Session Monitoring
Tutoring sessions are subject to random quality reviews conducted approximately bi-monthly. Reviews 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, near-miss analysis, review of unsubstantiated cases for procedural lessons, and integration of learning into training and policy updates.
External Reporting
NSEMM reports safeguarding activity externally through the Charity Commission annual return, serious incident reports where statutory thresholds are met, and contribution to local safeguarding arrangements as appropriate.
28. 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, and 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.
29. 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, and 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.
Staff Acknowledgement
All staff and volunteers are required to confirm that they have read and understood this policy. This acknowledgement is recorded and refreshed annually.
