Safeguarding Policy


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



You are referred to as ‘the Client’. You agree to the purchase of tutoring services on behalf of ‘the Student’. ‘The Student’ may be yourself or another person. The Student is the person who receives the tutoring service through sessions of tutoring.

The term “Bright Light Education Ltd” or “us/we/our” refers to the Directors of Bright Light Education Ltd.

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 Ltd.
Please note that our tutors are not employed by Bright Light Education Ltd. These tutors are, however, qualified and experienced primary school teachers (unless otherwise stated on their online tutor profile). We recommend that you as a Client deal directly with the tutor and that you request from them the appropriate policies that you require.


Purpose and aims of this policy:

  • To protect children and young people who receive services from Bright Light Education Ltd.



  • All children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or 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:

  • 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)


Criminal Records:

Our tutors must hold an Enhanced Disclosure and Barring Service (DBS) check.



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 is not able to be present, then there should always be another adult in the home 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 Ltd 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 recorded. 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.)



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 in the Directors’ homes or 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 Ltd is working, may be required to sign a non-disclosure agreement. The requirement for confidentiality is emphasised.


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 Ltd 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 Ltd 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 Ltd 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 Directors of Bright Light Education Ltd 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 Directors of Bright Light Education Ltd.


Updated: 24thMarch 2020