| Document details | |
|---|---|
| Status | Version 5.2, in force from 29/10/2026 |
| Owner | DSL |
| Applies to | Staff, volunteers, pupils and families |
| Next review | October 2027, or sooner if the law or guidance changes |
Parts A, B and D are on this page. Part C, the leads' procedures, is on a separate restricted page for the safeguarding leads and the trustees: Safeguarding Policy: leads' procedures.
This policy sets out how NSEMM keeps safe the children, young people and adults at risk who use our services.
Who it applies to
What we do
Who this policy protects
These meanings come from the law and guidance in D1.
Students who may be more vulnerable. Many of our students may be more vulnerable because of their age, circumstances or support needs, for example family difficulties or trauma, being socially isolated, having English as an additional language, or academic stress. A4 lists other children who may need extra care.
Other policies
If a child is in immediate danger, call 999.
Our safeguarding team
| Role | Name | |
|---|---|---|
| Designated Safeguarding Lead (DSL) | Adrian Angol-Henry, Chief Executive Officer | [email protected] |
| Deputy DSL | Socks Ansell, Chief Education Officer | [email protected] |
| Lead Trustee for Safeguarding | Amelia Hutton | [email protected] |
If your concern is about the DSL or the Deputy, follow A6.
Other contacts
| For | Contact |
|---|---|
| Report a concern (anyone, 24 hours a day, you can stay anonymous) | protect.nsemm.org.uk/report-concern |
| Allegations against staff or volunteers: Nottingham City Council LADO | 0115 876 5166 |
| Police (non-emergency) | 101 |
| NHS (non-emergency) | 111 |
| Anything else | nsemm.org.uk/contact |
More helplines are in D2.
Amelia Hutton is not the DSL.
Abuse can happen online or in person, by adults or by other children, and a child can be going through more than one kind at once. These are the kinds of harm to watch for. The signs are in B7.
It can happen here. The biggest risk is thinking it couldn't: that a tutor we know, a volunteer we like, or a small charity like ours is the exception. We don't rule anyone out, and a concern about someone we trust is reported like any other.
| Where it happens | What to watch for |
|---|---|
| In NSEMM | a tutor, volunteer or member of staff harming a child, or crossing boundaries: contact outside our systems, gifts, secrets, favouritism, or meeting up |
| At home | physical, emotional or sexual abuse; neglect; domestic abuse, including in a young person's own relationship; so-called "honour-based" abuse, female genital mutilation and forced marriage |
| From other children | bullying, including online and prejudice-based bullying (picking on someone for their race, religion, disability, sex or sexuality); sexual harassment and sexual violence; misogyny and violence against women and girls; sharing nudes or semi-nudes, including AI-made ones; upskirting (taking a photo up someone's clothes); initiation or hazing (humiliating "joining" rituals) |
| Outside the home | criminal and sexual exploitation, including county lines; modern slavery and trafficking; serious violence; radicalisation; an adult the child doesn't know approaching them or trying to take them away |
| Online | online abuse and grooming; being asked for nude images; harmful content, misinformation and conspiracy theories; deepfakes (fake images or videos made with AI); sextortion (being blackmailed over sexual images, often for money); being drawn into hacking, fraud or other cybercrime |
| The child's own wellbeing | mental health problems, self-harm and suicidal thoughts |
| School and going missing | being missing from education, often absent, home educated or in alternative provision (taught somewhere other than a school); running away or going missing from home |
| Children who may need extra care | children with special educational needs, disabilities or health conditions; children with a social worker; children in care, children who used to be in care, and care leavers; young carers (children who look after someone at home); children who are lesbian, gay or bisexual, or questioning their gender, who are more likely to be bullied; a family that has lost or may lose its home; a parent or other family member in prison; a child going through the courts (giving evidence, or in family proceedings); a child under 16 (under 18 if disabled) living for 28 days or more with someone who is not a parent or close relative (private fostering) |
Report abuse by another child like any other concern, even when it looks like banter.
If you are worried about a child, report it in the time set in B1. Don't wait until you are sure, and don't investigate it yourself.
If a child is in immediate danger, call 999 first. You don't need anyone's permission. Then report it to us when it is safe.
| Way to report | Where | Use it for |
|---|---|---|
| Protect form | protect.nsemm.org.uk/report-concern | Any concern, day or night |
| Report Concern button | NSEMM Learn | Any concern (it opens the Protect form) |
| Tell a member of staff | In person, on a call or in a lesson | Any concern (they must pass it on, B1) |
Concerns are always reported through Protect. Email is not a way to report a concern. For an urgent concern, phone the DSL or the Deputy as well (B3).
The Protect form needs no account and works on a phone. You can stay anonymous. It starts with emergency numbers, has a Quick Exit button, gives you a reference number and tells the DSL straight away.
Anyone can report: pupils, parents and carers, staff, volunteers, schools, other professionals and the public. If you stay anonymous we still act, but giving your name helps us follow up.
If the Protect form isn't working, the safeguarding page shows our phone numbers and a short backup form. The DSL and the Deputy get an email and a text straight away, with no personal details in it. A concern about the DSL or the Deputy follows A6.
Nobody at NSEMM is allowed to stop, delay or put off someone who wants to report a concern. Doing so can be a crime. If it happens, report that too.
You can also go straight to children's social care or the police at any time. Please tell us if you do, so we have it on our records.
If you are worried about how anyone working or volunteering for NSEMM behaves towards a child, report it the same way (A5). We refer allegations to the LADO (C2, leads and trustees only).
If the concern is about the DSL or the Deputy, don't send it to them. Report it in Protect. Protect sends it to Amelia Hutton, our Lead Trustee for Safeguarding, and not to the DSL or the Deputy. She contacts the LADO. You can also tell the LADO yourself at any time (Nottingham City Council, 0115 876 5166).
Protect also sends any concern that names the DSL or the Deputy away from them, so nobody handles a concern about themselves.
If you are unhappy with a decision the DSL makes, ask the Lead Trustee for Safeguarding to review it ([email protected]).
The DSL checks new concerns every day, including weekends and bank holidays. The DSL reviews each concern within 1 day if it is critical, 3 days if high, 7 days if medium and 14 days if low.
Records are kept in NSEMM Protect, a separate system that only the DSL and the Deputy have full access to. Nobody can delete or write over a record. If a record is changed, the original stays, so we can always see what was changed, by whom and when. We don't use AI on Protect records, and we only share them to safeguard and protect children (A8).
If you need to share information to keep a child safe, share it. Data protection law does not stop you.
Our legal basis. We share safeguarding information under UK GDPR Article 6(1)(f) (legitimate interests), or Article 6(1)(c) where the law requires it, and Article 6(1)(d) in an emergency. For sensitive information we also rely on Article 9(2)(g) and the Data Protection Act 2018, Schedule 1, Part 2, paragraph 18 (safeguarding of children and of individuals at risk). This lets us share without consent when that is the right thing to do. The Children Act 2004, section 16LA, applies to our work for schools, and we follow it for all our work.
We share with families, schools, health services, children's social care, the police, the LADO, the NSPCC, other charities and the Charity Commission, following Working Together to Safeguard Children, the DfE's Information Sharing Duty guidance and the ICO's guide to sharing information to safeguard children.
Where and how
Contact
Language
Online safety
Before the first lesson, a parent or carer accepts our tutoring agreement, gives emergency contacts, and is told in writing that lessons are recorded and how we use information (our Privacy Notice).
We record every online lesson. This protects pupils and tutors, means no tutor is ever alone and unrecorded with a pupil, and helps us check the quality of teaching. We only teach recorded lessons.
Missing lessons can be a warning sign of harm, including sexual abuse, sexual exploitation and child criminal exploitation. Most missed lessons are about money, time or practical problems, so when a pupil misses a lesson we check in with the family to make sure they're OK.
We count a lesson as missed only when the miss was on the pupil's or family's side: a family no-show, a family cancellation with no reason, or a lesson the DSL or Deputy has flagged as unexplained. We never count a lesson the tutor missed, or one lost to a problem on the tutor's side or with our systems. The full list is in C7 (leads and trustees only).
| Stage | When | What happens |
|---|---|---|
| 1 | The first missed lesson | The tutor records it and tries to contact the family |
| 2 | Two missed lessons in a row | A member of staff contacts the parent or carer within 24 hours to understand why and offer support |
| 3 | Three or more missed lessons in 30 days | The DSL reviews the pattern and completes a risk assessment, telling the school where that applies |
| 4 | When the DSL decides | A referral to the local authority, only where we believe a child isn't getting a suitable education, or isn't attending because of a welfare, child protection or safeguarding concern |
We also look out for lessons missed around particular topics or times, and sudden changes in a pupil who used to be reliable.
This count is about the child's welfare. If a family has a funded place, the CEF Access Policy, section 10.3a, counts missed lessons separately for the place.
Every child of compulsory school age must get a suitable full-time education. A child is missing education if they are of compulsory school age, aren't on a school roll and aren't getting a suitable education any other way, for example at home. This puts them at risk, because the people who would notice harm may no longer see them.
Our lessons are extra help alongside school, never a replacement for it. We are not an alternative provider and we don't provide "education other than at school".
The same goes for home education. Parents who choose to home educate are responsible for their child's education. We are not a home school, and we don't provide or replace that education. Home-educated pupils can have lessons at the standard price, alongside the full-time education their parents arrange. The Fund is for extra help alongside school, so it doesn't cover lessons for home-educated pupils.
When an application says a child isn't in education or isn't attending school, the system flags it to the DSL automatically. If you work or volunteer with us and notice anything else that suggests a child may be struggling or missing school, report it through Protect in the time set in B1. Anyone else can report it in the same way (A5).
If a family tells us their child isn't in education, the application lets them know we may contact their local council's education team to help find the right support. If there is a safeguarding concern, the DSL may also contact the council's safeguarding team. We keep their application open unless there is a safeguarding reason not to, but having a tutor doesn't solve a child missing school. The DSL's steps are in C11 (leads and trustees only).
Before anyone works with pupils, we check:
Nobody works with children until every check is done. The system won't place anyone with a pupil until HR has verified their DBS check.
| Role | DBS check the role needs |
|---|---|
| Anyone, paid or volunteer, who tutors, teaches, mentors or regularly helps in lessons (supervised or not), the DSL and Deputy, the CEO and the CEdO | Enhanced with the children's barred list |
| Trustees who do not tutor, and staff who see safeguarding information but don't work with pupils | Enhanced without the barred list. The law doesn't allow a barred-list check for these roles |
| Roles with occasional indirect contact | Standard, if the recruitment risk assessment says so |
| Staff with no contact with pupils | Basic |
Other rules
Safeguarding records say what was seen or heard, in order, with who wrote them. They are never overwritten. How long we keep them is set only in the Data and Privacy Policy, Annex (rows S1 to S6). How the safeguarding leads look after them is in C10 (leads and trustees only).
Training for everyone who works or volunteers with us, and for trustees, is in B6.
If a child is in immediate danger, call 999 first (A5).
When to report. Report a concern as soon as you can, within the hour if you are able to, and in any case the same day. This applies to everyone, and the rest of this policy and our other policies point here.
Report everything. If you work or volunteer with us, or you are a trustee, and you become aware of a safeguarding concern, report it through NSEMM Protect. Don't filter concerns before you report them. The DSL decides what happens next.
Not reporting is gross misconduct and can lead to dismissal or removal from your role (People Policy, section B5.12). It also breaks the Code of Conduct and the Volunteer Agreement.
A concern can be something a child says, something you see, or a change in how they behave. You do not need proof.
If a child tells you something
Three things you also report outside NSEMM yourself. For each one, also report it in NSEMM Protect at the same time, and add the reference number you were given.
Abuse you witness. Apart from FGM (above), report abuse you see happen in Protect straight away. The DSL decides whether the police are called. If anyone is in immediate danger, call 999.
Why we ask you to report these yourself. For these three, the law can put the duty to report on you personally, so telling the DSL isn't always enough on its own. To keep it simple and make sure nothing is missed, we ask everyone to report these themselves, including tutors aged 16 and 17, and to tell the DSL too.
A low-level concern is behaviour by someone who works or volunteers with us that isn't serious enough for an allegation but still makes you uneasy. For example:
Report it through NSEMM Protect like any other concern, including a mistake of your own. We handle these with support, and we want to hear about them. How the DSL responds is in C10 (leads and trustees only).
Your setting. Be in a quiet, professional setting with no other adults visible. Use a neutral background that shows no personal information, and dress appropriately. Keep clear sight lines.
Public spaces. No tutoring from public spaces without the DSL's agreement.
Platform. Use only NSEMM's online classroom. Do not use personal video tools, direct messages, personal email or social media, during or after a session.
Group lessons. Before the lesson starts, ask pupils to keep their cameras off, and use the leader controls to switch off any pupil camera that is on. Do not begin with a pupil's camera on.
Messages outside NSEMM. If a current or former student contacts you outside NSEMM (for example on social media or personal email):
The DSL may contact the parent and the platform.
Screenshots. Never screenshot or save images of a child, or harmful images. You may screenshot a worrying text message only to add it to your Protect report. Then delete it from your device.
Language. Teach mainly in English (A9). If you need another language for more than a word or a quick explanation, agree it with a safeguarding lead first.
Mentoring. Before mentoring starts, the mentor, the student and their parent sign an agreement about confidentiality. At the first session, explain that you can't keep something confidential if it is a safeguarding concern. After each session, write short factual notes and store them securely.
Cyberbullying on NSEMM's platforms is a safeguarding concern, so report it. We step in straight away, support the child being bullied, deal with the child responsible and keep an eye on it afterwards.
If a child is in immediate danger in a lesson, call 999, keep them safe and don't leave them alone if they are at risk. Then report it through Protect and contact the DSL.
If it is urgent but not an emergency, report it through Protect marked as immediate danger, which sends urgent alerts, and phone the DSL or the Deputy as well. Urgent means any risk of harm soon: for example sextortion, threats of self-harm, a child scared to go home, or online grooming. If you are not sure, treat it as urgent.
Medical incidents. Record every one in Protect, however small. For urgent medical advice call 111, or 999 in an emergency, and contact the parent or carer straight away. You don't need a parent's consent for emergency treatment that is in the child's best interests, but always try to reach them and record that you did.
Your position of trust with pupils is covered in the People Policy, section B5.9.
If a student asks you to use a different name or pronouns, use them. It is a matter of respect, and on its own it isn't a safeguarding concern.
When a student asks, a member of staff has a short, supportive check-in with them, and the DSL updates their record. There is no waiting period, and the student can change their mind at any time. Any request has to come from the student themselves.
We don't tell parents or carers without the student's agreement, unless the DSL has a specific safeguarding concern, the law requires it, or not telling them would put the student at risk. This is the same test we use for any decision about sharing with parents. If the student wants to tell their parents, a member of staff can help.
We don't suggest or encourage social transition, so don't raise the subject unless the student does. We don't give medical advice. If a student is struggling, we offer pastoral support and point them to their GP or NHS services.
In our records we use the student's chosen name day to day, and keep their legal name in legal and safeguarding records. We record biological sex only where the law or safeguarding needs it. We will review this section if the DfE updates its guidance on gender-questioning children.
At 16 or 17 you are still a child in law, so the rules that protect pupils protect you too.
Before you start
If you tutor one to one
Looking after you
Before you start any work with children
Every year you complete an update. It may be a bulletin, briefing, meeting or e-learning, and it covers:
Extra training by role
Training is recorded in the HR app, with the course, date and expiry date.
| Concern | Signs or examples |
|---|---|
| Physical abuse: hitting, shaking, burning, poisoning, or a carer making up or causing illness | Unexplained injuries or marks in unusual places, explanations that don't fit, not wanting to show skin, flinching, fear of going home |
| Emotional abuse: persistent treatment that makes a child feel worthless, frightened or unloved | Withdrawal or aggression, low self-esteem, difficulty with relationships, behaviour that doesn't fit their age, self-harm, a constant need for approval |
| Sexual abuse: forcing or enticing a child into sexual activity, with or without contact, including images | Sexual knowledge or behaviour that doesn't fit their age, physical symptoms, withdrawal, not wanting to undress, sexualised language |
| Neglect: persistent failure to meet basic needs, including during pregnancy through substance misuse | Poor hygiene, hunger, unsuitable clothing, untreated illness, often absent or late, being left unsupervised |
| Domestic abuse: physical, emotional, sexual, financial or technological. A child is a victim in their own right | Injuries, fear of going home, regression, poor sleep, withdrawal, falling work, sexual knowledge, adult caring roles |
| Child-on-child abuse: physical or sexual violence, sexual harassment, initiation or hazing | Any sign in this table, where another child is causing it |
| Bullying, including online and prejudice-based bullying | Not wanting to come to lessons, lost or damaged things, unexplained marks, upset after being online, going quiet in group lessons |
| Sharing nudes or semi-nudes (including AI-made ones), and upskirting | Secrecy about a phone, distress after being online, worry that an image will be shared |
| Sexual exploitation, including for money, and sextortion (threats to share real or AI-made images) | Unexplained money or gifts, requests for images, secrecy online, distress after using a device, panic about something being "found out" |
| Criminal exploitation and county lines | Unexplained money or possessions, behaviour change, going missing, signs of assault |
| Cybercrime: a child drawn into hacking, fraud or other online crime | Unexplained money or gaming items, talk of "easy money" online, new older contacts online |
| Serious violence | Unexplained injuries, carrying weapons, new friendship groups, falling attendance |
| Online abuse | Grooming, harassment, harmful content, misinformation and conspiracy theories, deepfakes, radicalising content. The risks come from content, contact, conduct, commerce and AI-enabled harm |
| Misogyny and violence against women and girls, from other children or adults | Misogynistic language, online harassment, coercive control, exploitation in sexual or romantic relationships |
| Radicalisation | Report any worry, even without clear signs |
| "Honour-based" abuse, including FGM, forced marriage and breast ironing | Report any worry, even without clear signs |
| Modern slavery and trafficking, which can happen within the UK | Report any worry, even without clear signs |
| Homelessness, or a family at risk of losing its home | Frequent moves, tiredness, hunger, talk of eviction or staying with friends, nowhere quiet to work |
| A family member in prison | A parent suddenly absent, money worries, secrecy or shame, changes in behaviour |
| Self-harm and suicidal thoughts | Report any worry, even without clear signs |
| Mental health | Changes in mood or behaviour, withdrawal, hopelessness, anxiety, falling engagement, self-harm |
What to do differently
Look at the whole picture. Harm can come from home (domestic abuse, substance misuse, hardship), the community (gangs, exploitation), other children and online spaces, and children may suffer several harms at once. This is called contextual safeguarding. Upskirting is a crime.
Most of our lessons are online. If a session is held in person, it is either:
In-person sessions are not recorded, so these rules apply instead.
Staff and venue
First aid
Urgent medical need (same-day assessment, not life-threatening)
If the parent can't be reached and urgent assessment is needed
Our library sessions (the Learning Outreach Network) are paused at the moment.
Law
Data protection grounds we use
Statutory guidance
Other guidance
Changes we are working through
| Service | Contact |
|---|---|
| Childline | 0800 1111, childline.org.uk |
| NSPCC Helpline (adults worried about a child; professional advice) | 0808 800 5000 |
| NSPCC Whistleblowing | 0800 028 0285 |
| Samaritans | 116 123 |
| Beat (eating disorders) | 0808 801 0677, beateatingdisorders.org.uk |
| Shore Space (Lucy Faithfull Foundation), for young people worried about their own sexual thoughts | shorespace.org.uk |
| Internet Watch Foundation, to report child sexual abuse images online | report.iwf.org.uk |
| CEOP, to report online sexual abuse or grooming to the police | ceop.police.uk |
Whistleblowing at NSEMM. How to raise a concern about wrongdoing, and how you are protected, is in our Whistleblowing Policy. A safeguarding concern about the DSL follows A6.