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Safeguarding Children and Young People Policy


Bright Light Education UK LLP carries out activities which brings tutors into regular contact with children. This includes providing tutoring in the student’s home, in the tutor’s home and within the school environment. It also includes online tutoring, in which tutoring is provided by a human tutor over the Internet. Bright Light Education UK LLP takes its responsibilities to safeguard and protect the interests of all young children very seriously.


‘The Client’ agrees to the purchase of tutoring services on behalf of ‘the Student’. ‘The Student’ is the person who receives the tutoring service through sessions of tutoring, either in person or online.

The term “Bright Light Education UK LLP” or “us/we/our” refers to the Partners of Bright Light Education UK LLP.

A “child” is anyone under the age of 18.

Scope of this policy:

This policy applies to those who are in one way or another connected to the work of Bright Light Education UK LLP.

Our Tutors must be qualified teachers with enhanced DBS checks (unless stated otherwise on the tutor profile). Before we allow tutors to join our network, we interview them to ensure that their teaching values are in line with our own. We also require them to sign an Agreement with us to show their commitment and professional attitude towards teaching. We require two references. All our Tutors are self-employed. Whilst every care and reasonable effort is made to check the suitability of the Tutors, we strongly recommend that the Client make their own enquiries and checks. Bright Light Education UK LLP holds no responsibility for the tutors’ insurances, policies and teaching methods.

Purpose and aims of this policy:

To protect children and young people who receive services from Bright Light Education UK LLP from harm.


All children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or gender identity, have a right to equal protection from all types of harm or abuse.

Legal considerations:

This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely:

Keeping children safe in education (2020, 2021, 2022) (KCSIE)
Working together to safeguard children (2018)
Prevent duty guidance for England and Wales (2015)
Channel duty guidance: protecting vulnerable people from being drawn into terrorism (2019)
Multi-agency statutory guidance on FGM (2020)
Children Act (1989)
Data Protection Act (1998) and GDPR (2018)
Human Rights Act (1998)
Sexual Offences Act (2003)
Children Act (2004)
The Protection of Freedoms Act (2012)
Safeguarding Vulnerable Groups Act (2006)
Children and Families Act (2014)
Conduct of Employment Agencies and Employment Business Regulations (2003)
Protection of Children Act (1999)/Criminal Justice and Court Services Act (2000)
Care Standards Act (2000)
The Police Act (1997)
The Children (Protection from Offenders) (Miscellaneous Amendments) Regulations (1997)
The United Convention on the Rights of the Child (1991)
The Rehabilitation of Offenders Act (1974)
Health and Safety at Work etc Act (1974)

Key Contacts:

Designated Safeguarding Lead (DSL): Danielle Okumura (Partner)


Telephone: +44 7774 102624

Related Policies:

Code of Practice for Tutors and Tutoring Companies

Online Teaching Policy

Complaints and Whistleblowing Policy

Designated Safeguarding Lead:

The Partner, Danielle Okumura, has been appointed the Designated Safeguarding Lead (DSL). The DSL takes lead responsibility for safeguarding and child protection. Training is required for this role.


1) Every pupil should feel safe and protected from any form of abuse and neglect. Bright Light Education UK LLP is committed to safeguarding and promoting the welfare of children and young people and requires everyone who comes into contact with children and their families to share this commitment.

2) Keeping children safe in education (September 2020) (KCSIE) defines safeguarding and promoting the welfare of children as protecting children from maltreatment; preventing impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.

Bright Light Education UK LLP will:

Follow local inter-agency procedures when required.
Ensure that we practise safer recruitment in checking the suitability of staff and tutors to work with children and young people. See our separate Safer Recruitment Policy;
Be alert to signs of abuse and protect each child from any form of abuse, whether from an adult or another pupil;
Deal appropriately with every suspicion or complaint of abuse and support children who have been abused in accordance with his / her agreed child protection plan;
Design and operate procedures which, so far as possible, ensure that tutors and others who are innocent are not prejudiced by false allegations;
Be alert to the needs of children with physical and mental health conditions;
Operate robust and sensible health and safety procedures.
Assess the risk of children being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology, based on an understanding of the potential risk in the local area;
Consider and develop procedures to deal with any other safeguarding issues which may be specific to individual children in the local areas.

Application and Accessibility:
This Policy must be read, understood and agreed to by all our Tutors and Clients. It is available via our website and is available as a hard copy on request.

The DSL receives regular training every two years. Many of our tutors are practising teachers within schools and have had appropriate safeguarding and child protection training within the last two years, as part of their school training. We ask our tutors to inform us of their latest training received by their school when they join Bright Light Education UK LLP. For tutors who have not recently received training at their school, we offer “Safeguarding Young People” and “Child Protection in Education” training through a third-party such as the training package offered to Corporate Members of The Tutors’ Association (through EduCare) and Qualified Tutor.

Criminal Records:

Our tutors must hold an Enhanced Disclosure and Barring Service (DBS) check and be signed up to the DBS Update Service.


All activities or assignments involving children should be planned in advance to ensure they take into account the age range and ability of the participants.

Physical Contact:

On no account should any tutor have any physical contact with a child unless it is to prevent accident or injury to themselves or anyone else (e.g. to prevent a fall), or in the case of medical assistance being needed (e.g. to administer first aid), or to provide nursing or other general care, in which case the prior consent of the affected person should be requested where possible. Where appropriate, consent from parents or those with parental or caring responsibility should be obtained.

If a child is hurt or distressed, the tutor should do his/her best to comfort or reassure the affected person without compromising his/her dignity or doing anything to discredit the person’s own behaviour. The tutor should inform the parent or guardian at the earliest possible time.

Adult presence:

If a parent/teacher is not able to be present, then there should always be another adult in the home or close environment when a child is being tutored, for the “protection” of the tutor as well as the child.


Communication with children is vital in establishing relationships built on trust. Those working with children should listen to what they are saying and respond appropriately. Children are entitled to the same respect as any adult. It should also be made clear to them what standards of behaviour and mutual respect are expected from them.

Those working with children should behave appropriately, ensure that language is moderated in their presence and should refrain from adult jokes or comments which are clearly unsuitable.


If tutoring online, tutors must make it clear to the Client how their online tutoring is delivered, and the nature of the technology used. Videos should be switched on so that both Client and tutor can be seen during the lesson. Both Clients and Tutors are not permitted to record lessons (apart from some software which automatically records the whiteboard lesson for the Tutor, but it does not record the child image).

Behaviour and Abuse:

We should all aim to promote an environment of trust and understanding. Those working with children should not tolerate unsociable behaviour but should try to ensure good working relationships.

The tutors of Bright Light Education UK LLP have a strict duty never to subject any child to any form of harm or abuse. This means that it is unacceptable, for example, to treat a child in any of the following ways:

to cause distress by shouting or calling them derogatory names
to slap
to hold them in such a way that it causes pain, or to shake them
to physically restrain them except to protect them from harming themselves or others
to take part in horseplay or rough games
to allow or engage in inappropriate touching of any kind
to do things of a personal nature for the person that they can do for themselves (this includes changing clothing, or going to the toilet with them unless another adult is present)
to allow or engage in sexually suggestive behaviour within a person’s sight or hearing, or make suggestive remarks to or within earshot
to give or show anything which could be construed as pornographic
to seek or agree to meet them anywhere outside of the normal workplace without the full prior knowledge and agreement of the parent, guardian or carer.
to engage with them online in an unacceptable manner.

It is illegal for a teacher/tutor to enter into a sexual relationship with a student, even if the student is over the age of consent (i.e. over 16). Tutors, like school teachers, are operating in a similar position of trust and thus must also abide by this law.

Suspicions of Abuse:

Allegations against a tutor who may have behaved in a way that has or may have harmed a child, or committed a criminal office either against or related to a child, or behaved towards a child in a way that suggests he or she is unsuitable to work with children, should be reported immediately to the LADO (Local Authority Designated Officer) or DCPO (Designated Child Protection Officer) in the local authority where the incident is alleged to have taken place.

Child Protection Incidents:

A Child Protection incident usually includes some of the following scenarios but this list is

not intended to be a formal and all-inclusive definition. A typical CP incident is when: –

a tutor receives some information about a child or young person either from the child
directly or from another source, which could potentially cause serious harm to the child, either physically or psychologically.

a tutor observes a situation (e.g. risk in a child’s environment which could potentially cause serious physical or psychological harm).
a company/agency and/or parent receives information about a tutor either from the child directly or from another source, that could potentially cause serious harm to the child, either physically or psychologically.

Recording a Child Protection Incident:

All Child Protection incidents must be reported to the DSL as soon as possible. It is essential to:

Speak individually with all parties concerned
Write a record of all conversations
Write up all telephone conversations with a written report to send to LADO/Child Protection Unit (at the local authority where the incident took place) who will deal with the allegation.

All allegations should be dealt with expeditiously, thoroughly, fairly and with common sense and professional judgement. Any investigation should be carried out as quickly as possible and a decision reached as to whether the allegation is borne out or not supported. Dependent on this the outcome of the investigation could have one of three outcomes: a)unsubstantiated, b) substantiated in part or in whole but can be dealt with by disciplinary procedures. c) substantiated and requiring formal referral in the first instance to the LADO (Local Authority Designated Officer) or DCPO (Designated Child Protection Officer.)

If a child is in immediate danger or is at risk of harm, a referral should be made to children’s social care and / or the police immediately. If a crime is committed, this should be reported within one working day. Anyone can make a referral in these circumstances.

Tutors must report to the police known cases of Female Genital Mutilation in under 18s.

Making a Referral:

Confirmation of any referrals made to LADO/Child Protection Unit (at the local authority where the incident took place) and details of the decision as to what course of action will be taken should be received from the local authority within one working day. If this is not received, the DSL should contact children’s social care again.

If after a referral the child’s situation does not appear to be improving, the DSL (or the person that made the referral) should press for reconsideration to ensure their concerns are addressed and that the child’s situation improves.

Where relevant, Bright Light Education UK LLP will co-operate with the Channel panel and the police in providing any relevant information so that each can effectively carry out its functions to determine whether an individual is vulnerable to being drawn into terrorism. Bright Light Education UK LLP will respond to requests for information from the police promptly and in any event within five to ten working days.

Dealing with allegations against teachers, Headteachers, volunteers and other staff
Local authorities have designated a particular officer, or team of officers, to be involved in the management and oversight of allegations against people that work with children (Designated Officer(s)). The Designated Officer(s) will be informed immediately and in any event within one working day of all such allegations that come to the attention of the DSL.

Detailed guidance is given to tutors to ensure that their behaviour and actions do not place children or themselves at risk of harm or of allegations of harm to a child. This guidance is contained in the Code of Practice for Tutors and Tutoring Companies.

Tutors should also feel able to follow Bright Light Education’s separate whistleblowing policy to raise concerns about poor or unsafe safeguarding practices and that such concerns will be taken seriously. The NSPCC whistleblowing helpline is available for tutors who do not feel able to raise concerns about child protection failures internally.

Informing Parents and Schools:
Parents and schools where we work, will normally be kept informed as appropriate of any action to be taken under these procedures. However, there may be circumstances when the Designated Safeguarding Lead will need to consult the Designated Officer(s), children’s social care and / or the police before discussing details with parents.

In relation to Channel referrals, the DSL will consider seeking the consent of the pupil (or their parent / guardian) when determining what information can be shared. Whether or not consent is sought will be dependent on the circumstances of the case but may relate to issues such as the health of the individual, law enforcement or protection of the public.


The safety of the people we work with is paramount and we are committed to providing a safe environment within which to work. Those working with children should ensure all appropriate risk assessments and security checks have been carried out prior to any assignment.

Any equipment used must be safe and only used for the purpose for which it is intended. Users should be adequately trained. Appropriate insurance should be up-to-date and adequate to cover such assignments.


All personal information regarding children is highly confidential and should only be shared with appropriate people on a need to know basis. Information is stored by the Partners of Bright Light Education UK LLP via a secure online file hosting service.

Anyone who is likely to have access to confidential material regarding children, or any of the bodies on behalf of whom Bright Light Education UK LLP is working, will be required to sign a non-disclosure agreement. The requirement for confidentiality is emphasised.

The DSL will open a child protection file following a report to her of a child protection concern about a child. The DSL will record all discussions with both staff/tutors and external agencies, decisions made and the reasons for them and detail of the action taken.

Contact outside of work:

Contact should not be made with any of the children with whom we are working for any reason unrelated to the particular work.

Gifts and inducements:

On no account should anyone from Bright Light Education UK LLP give a child a gift or buy refreshments etc which could be in any way considered as a bribe or inducement to enter into a relationship with the Bright Light Education UK LLP person or give rise to any false allegations of improper conduct against the individual.

Communicating this policy and concerns:

Those working with by Bright Light Education UK LLP will be made aware of this policy.

Furthermore, a copy of this policy will be made available to all relevant bodies with whom we work and will be made available to parents and carers of children with whom we plan to work.

Breach of this policy:

Failure to follow the guidelines in this policy is considered a serious offence and will be investigated thoroughly.

Implementation, monitoring and review of this policy:

The Partners of Bright Light Education UK LLP have equal responsibility for implementing and monitoring this policy, which will be reviewed on a regular basis following its implementation (at least annually) and additionally whenever there are relevant changes in legislation or to our working practices.

This policy has been drawn up with guidance from The Tutors’ Association.

Any queries or comments about this policy should be addressed to either Danielle Okumura or Charlotte Badenoch, the Partners of Bright Light Education UK LLP.

Updated: 7th September 2022

Get In Touch

Telephone: +44 7774 102624


Hours: M-F: 9am – 5pm