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Safeguarding Policy

Overview
All children and young people have the right to protection from any kind of abuse and the right to exist in a safe and friendly environment whilst using Xerrion’s services. 

We are committed to providing the highest standard of safeguarding. The safety of our students is our paramount concern. 

This policy relates to all students using our services regardless of gender, age, ethnicity, nationality, religion or disability. We understand that the child’s needs are paramount. We are committed to providing as far as is reasonably practicable, an environment that is safe from any kind of harm, for all those under the age of 18. While harm is rare whilst using our platform, all staff and tutors working with us are advised to maintain an attitude of ‘it could happen here'.

Our website, courses, trainings, lesson, quizzes, tests have all been designed to ensure our students learn in a safe environment.

Definitions
Safeguarding: The overarching principles are that all staff have the responsibility to safeguard under-18s, be vigilant and know to report concerns, including small ones, or allegations and who to contact both within and outside of Xerrion platforms. All staff and tutors must be trained in Safeguarding to the level of Basic Awareness.

Child Protection: Part of the Safeguarding process. It focuses on protecting individual children or young people identified as suffering or likely to suffer from significant harm. This includes child protection procedures which detail how to respond to concerns about a child or young person, using referral processes to other agencies. Safeguarding and child protection sit alongside each other, however, Xerrion is not an investigating agency. Any allegation or suspicion of abuse or significant harm will normally be carried out by the social services or police.

Minor: Any person under the age of 18 is a minor by law. The age of adulthood in the UK is 18. We refer to minors as child(ren) and sometimes as young people, to acknowledge that older teenagers have some awareness and responsibilities of adults but are not legally adults. Typically, we may refer to 16-17-year- olds as young people.

Designated Safeguarding Person (DSP): A named or named member(s) of staff trained to Advanced Safeguarding Levels and keeps in close contact with Senior Management.

Duty of Care: This is the responsibility of all staff and Tutors to protect under-18 from direct harmful behaviour, for example, emotional abuse, physical abuse or any other physical harm, sexual abuse and neglect.

Best practice: This is a term we use to define professional procedures that are accepted as being correct or most effective.

Type of Abuse: This is one definition of child safeguarding: “The process of protecting children from abuse or neglect, preventing impairment of their health and development, and ensuring they are growing up in circumstances consistent with the provision of safe and effective care that enables children to have optimum life chances and enter adulthood successfully”.

The 4 main types of harm are:
Sexual abuse 
Physical abuse
Emotional abuse 
Neglect

And more specifically could be:
Domestic violence
Inappropriate supervision by staff or volunteers
Bullying, cyberbullying, acts of violence and aggression 
Victimisation
Self-harm
Unsafe environments and activities Crime
Exploitation (including Child Sexual Exploitation) Radicalisation
FGM (Female Genital Mutilation)

Legislation
Our website and coordinating policies have been developed to ensure we comply with all relevant safeguarding legislation.

This safeguarding policy should be read in conjunction with our General Terms and Conditions, Student Terms and Conditions, our Privacy Policy and our Cookie Policy. 

Aims of Policy
We aim to include best practice advice and policies from accreditation, governmental and charity bodies (such as the Tutors Association, Keeping Children Safe in Education and NSPCC), into existing policies such as this Safeguarding Policy and Staff Code of Conduct and compliance with statutory guidance.

Have effective systems in place ensuring that our facilities, procedures, and activities take account of the students’ health, safety and welfare requirements. This is overseen by the designated Xerrion senior management. 

Follow safer recruitment procedures with all the required checks carefully, for all staff, ensuring the suitability of our tutors to work with students under the age of 18.

Ensure students have a clear channel of communication in time of need by ensuring that all staff and tutors understand general child safeguarding principles.

Xerrion seeks to provide the best service possible and provide a safe experience in which children can learn.
This policy aims to ensure we safeguard all users of Xerrion (including all Users, Students and Tutors) whilst they engage with our courses, trainings, lesson, quizzes, tests.
This policy outlines the responsibilities of all users of Xerrion (including all Users, Students and Tutors) and it is important that all have familiarised themselves with this policy and our Terms and Conditions.
Alongside this policy, users of Xerrion (including all Users, Students and Tutors) must comply with The Tutors' Association Child Protection Policy, whether or not they are a member of The Tutors' Association, and all relevant legislation and government guidance.
If any User has a concern regarding child protection, they must contact Xerrion immediately.
Contravention of any of the terms contained within this policy may result in immediate removal of access to and permanent barring from our services.

Xerrion Responsibilities
Xerrion does not require every staff member to have a background check to use the Website. However, if a staff member is working directly with children under the age of 18, then they will be required to have an enhanced check provided by the Disclosure and Barring Service, Disclosure Scotland or Access Northern Ireland, before being able to work with them. It is entirely at the student’s discretion as to whether they determine having a background check is part of their selection criteria.
Xerrion will take precautions we consider reasonable to protect Students' and Tutors' information.
Xerrion will constantly monitor each class and its in courses, trainings, lesson activity, we will ban anyone who is behaving inappropriately. 
Xerrion will protect all data in accordance with all relevant legislation and our Privacy Policy. 
Xerrion will monitor activity wherever possible on the Website, social media pages and courses, trainings, lesson, quizzes, tests. 
Xerrion does so in the hope of stopping misuse and to ensure we safeguard all users.
Xerrion may review any courses, trainings, lesson, quizzes, tests at any time for the purposes of improving our service or where a Complaint or Safeguarding Report has been made.
Xerrion will deal with reports of possible illegal activity promptly, focusing on the safety and wellbeing of Users. Xerrion will allow access to UK law enforcement of any data where a criminal offence may have occurred in relation to a specific Lesson.
Xerrion will regularly review this policy to ensure they are best suited to safeguarding all users.

Student Responsibilities
Students under the age of 18 must be represented by a parent or legal guardian who gives consent for them to receive tuition. Xerrion is not responsible for any dispute regarding parental consent.
Students must ensure they have their webcam switched on for at least the first five minutes of the first lesson of a Course, to allow Xerrion to verify that they are under 18. If they cannot or do not wish to switch on their video for whatever reason, they must email safeguarding09@gmail.com to verify another way at least 24 hours prior to the start of the course.
Students must ensure that all of their personal details and contact information are accurate and up to date.
Students must ensure that there is no inappropriate communication between themselves, another Learner or User, or Staff and report any unsolicited communications from the Tutor if appropriate.
Students must exercise their own judgement regarding the accuracy of the information provided on the Website. 
Students must use their own judgement about the services. 
Students must immediately report to Xerrion any defamatory, offensive or illegal material they view on our Website, Social Media pages or courses, trainings, lesson, quizzes, tests.
Students must ensure the physical environment is safe and not inappropriate. For example, the environment should be in a neutral room, not a Childs bedroom.
Students must ensure that Tutors are treated with respect and are not subjected to abusive behaviour or language.
Students must ensure no improper suggestions are made to, or by, the Tutor.
Students are responsible for their own security in conjunction with our services, both online and offline.
Students must report any Complaint immediately.
Students must report any safeguarding concerns or illegal activity immediately.

Staff Responsibilities

Xerrion will cancel Lessons if no parent or legal guardian is present during a Lesson with a Learner who is under 18 and they or the Learner do not feel comfortable to continue.
Xerrion is responsible for ensuring that the information provided on the Website, social media pages and courses, trainings, lessons, are accurate and in no way misleading. They must update this information promptly to maintain its accuracy.
Xerrion must immediately deal with any defamatory, offensive or illegal material they view on our Website, or when it has been brought to their attention.
Xerrion staff must disclose any criminal convictions or cautions they may have to Xerrion, including any criminal convictions or cautions received at any time after having registered a tutor account on the Website and for as long as the Tutor remains registered.
Xerrion staff must take every precaution to ensure that they work in a safe environment and are responsible for taking out and maintaining their own insurance policies to cover the work they undertake.
Xerrion must ensure that their environment does not display any inappropriate images or documents when conducting a session, and that Tutors are appropriately dressed.
Xerrion staff must treat students fairly and without prejudice or discrimination; whatever their age, culture, ability, gender, language, racial origin, religious belief and/or sexual identity.
Xerrion must ensure all reasonable steps are taken to protect children from harm, discrimination and demeaning treatment and to respect their rights.
Xerrion must value students and take their contributions seriously.
Xerrion must ensure they work in partnership with parents and children – which is essential for the protection of children.
Xerrion must ensure the language they use is appropriate and not offensive or discriminatory.
Xerrion must ensure no improper suggestions are made to, or by, the Student.
Xerrion staff must ensure that any contact or communication they have with the Student is appropriate to their role and confined to the field for which they have been selected.
Xerrion must ensure that there is no inappropriate communication between themselves and the Student and report any unsolicited communications from the Student if appropriate.
Xerrion staff are responsible for their own security in conjunction with our services, both online and offline.
Xerrion staff must report any Complaint immediately.
Staff must report any safeguarding concerns or illegal activity immediately to Xerrion.

Parent / Responsible Adult responsibilities.
The parent/responsible adult will be responsible for the selection of the course and make any reasonable checks to ensure the course is suitable for the student (including, if required, reviewing the tutor’s CRB/DBS certification documentation).
The parent/responsible adult will ensure the student is fully aware of the Xerrion’s Safeguarding Policy.
The parent/responsible adult will always be responsible for the welfare of the student during the session.
The parent/responsible adult will always be responsible for the physical environment of the pupil during the session ensuring it is safe and appropriate.
The parent/responsible adult will, if they consider it appropriate, be present or available during a tutor session so any concerns encountered by the student can be reported as soon as possible and ensure the student and tutor are behaving in an appropriate manner.
The parent/responsible adult will ensure that tutors will be treated with respect and fairness by the student and will not be subjected to abusive behaviour or language.
The parent/responsible adult will ensure that no improper suggestions are made by either the tutor or student.
The parent/responsible adult will ensure the student has no inappropriate communication with Xerrion staff outside the Online messaging and lesson sessions.
The parent/responsible adult will report any unsolicited communications between the tutor and student if appropriate.
The parent/responsible adult will report any dispute with staff of Xerrion in accordance with procedures set out in this document.
The parent/responsible adult will report any inappropriate behaviour or illegal activity by Xerrion staff in accordance with procedures set out in this document.

Reported Breach of Safeguarding Policy
Any Student, User or Staff Member reported for a breach of our Safeguarding Policy will be immediately suspended from the site until the matter reported has been investigated by the appropriate authority. We will inform them of their suspension and seek guidance where required. The Student or Tutor reporting the breach may be informed of the resolution, if appropriate.
Xerrion reserves the right to make a final decision on action taken for minor breaches of our Safeguarding Policy.
Any Student or Tutor reported for illegal activity whilst using the Xerrion services may be barred from the service, reported to the police and any other relevant organisations.

Reporting and Responding to a Safeguarding Concern
Xerrion recognises that the Children Act 1989 states that the welfare of the child is the paramount concern. It also recognises that hasty or ill-informed decisions in connection with a member of staff can irreparably damage an individual’s reputation, confidence and career. Staff and tutors are given guidance through the signing up period before tutoring begins.
All staff and tutors have a duty of care and must follow the 5 ‘R’s:
Recognise – Respond – Record – Report - Refer

Recognising a safeguarding concern
Staff and tutors are given basic training in recognising signs that could be cause for concern. We also advise of free online courses that are available to tutors about safeguarding. 

Responding to a concern or an allegation
All staff and tutors must be prepared to respond to allegations of abuse or neglect. Child abuse does not necessarily have to be physical or sexual. It can also be emotional or psychological, or due to the neglect of a child’s physical or emotional needs.

If a tutor is approached by a student who wishes to make a disclosure about what could be a safeguarding matter, the staff or tutor must prioritise this above any other duty they have at the time. 
They must take the learner to a private place within view but out of earshot of other people. They must not interrogate or interview the child, avoiding leading questions. Promises of confidentiality must not be given but that only those people whose responsibility it is to know, and act will be told.
Any member of staff or tutor with an issue or concern relating to safeguarding or child protection, including but not limited to allegations of child abuse, should discuss it immediately with a member of the Xerrion Safeguarding team/person.

Anyone who hears an allegation of abuse against another member of staff or tutor or has concerns about the behaviour of another member of staff or tutor, must report the matter immediately to the DSL or DSP. 

The DSP or DSL will decide on an appropriate course of action. At no point should an attempt be made to investigate the situation. This will be undertaken by Social Services and/or the Police as necessary.
Xerrion is an ‘agent of referral’ and not of investigation.

Recording of an Allegation
A full record must be made as soon as possible detailing the nature of the allegation using the ‘Safeguarding Incident/Concern Form’. Record in writing everything that was said, using the child’s own words. Note the place, date, time, and names of persons to whom the information was given. Include The nature of the alleged abuse, A description (if applicable) of any injuries observed, An account of the allegation. The Referral Form - ‘Safeguarding Incident/Concern Form’ can be obtained from the DSP/DSL. Copies are available on the staff noticeboard. The completed form must be signed and dated by the staff making the report and given to a DSP/DSL as soon as possible. A student must not be asked to write the report or sign a report.

Refer a concern or allegation
The Designated Safeguarding team/person will decide on a course of action and where appropriate refer the case to outside authorities, usually either the police or social services.

Do not confront any person against whom an allegation has been made. The Designated Safeguarding Team will guide you and your team in dealing with any allegation or suspicion of abuse, and if applicable, report allegations and incidents of abuse to the LADO (Local Area Designated Officer) at the local County Council Children’s Social Services.

Any staff that have any queries relating to this policy or the implementation of it should contact a member of the Safeguarding team/person.

Updating our Policies and Procedures
This Safeguarding Policy and our Procedures will be reviewed by Xerrion on a regular basis to ensure it is adequate and relevant to safeguarding standards. Xerrion will comply at all times with our obligations under the DPA and the GDPR in relation to the student’s personal data.

 

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