Safeguarding Policy and Procedure

  1. Introduction
  2. Host Tutor and Staff Guidelines
  3. Child Protection Procedures
  4. Safer Recruitment
  5. Designated Personnel


InTuition Languages (ITL) is committed to providing a secure and friendly environment where all members of the community, whatever their background or character, are protected from harm and respected by others.

All staff and any other adults involved with ITL accept and recognise their responsibilities:

  • to safeguard the welfare of children who join the school and any of its programmes;
  • to continually develop awareness of any issues which might harm these children;
  • to not make staff or any other adults involved with the School unnecessarily vulnerable to suspicion of any form of abuse

We will endeavour to safeguard children as follows:

  • by adopting child protection guidelines and accepted procedures
  • by providing children with expected codes of behaviour and ensuring they understand what those are, especially bullying
  • by sharing information about child protection and good practice
  • by sharing information about any concerns.
  • by providing effective management for staff and teachers through supervision, support and training.
  • by respecting and valuing children and listening to their concerns.
  • by appointed a Designated Safeguarding Lead who has overall responsibility for the safeguarding and welfare of all students.
  • by ensuring that appropriate action is taken in the event of incidents / concerns of abuse, and support provided to the individuals who raise or disclosure the concern.
  • by ensuring that detailed confidential records of any safeguarding concerns are maintained.

Please note:

  • A child in the context of this policy refers to anyone under the age of 18 who has joined an InTuition Languages course, or is visiting the school
  • This policy applies to all children regardless of gender, ethnicity, nationality, disability, sexual orientation or religion
  • This policy has been formulated in accordance with the provisions of the Children Act

1989, the Human Rights Act 1998, and the United Nations Convention on the Rights of the Child (ratified by the United Kingdom Government in 1991)

Statement of Principles

  1. All children have rights. No-one can take away a child’s right to be safe.
  2. All children have the right to say ‘No’ if any person tries to do something to them which they feel is wrong.
  3. All children have the right to get help against bullies by enlisting the support of friends or by telling an adult.
  4. All children must feel they can tell an adult of any incident that frightens or confuses them or makes them unhappy.
  5. All children must know that if they go to an adult for help, they will be believed and supported.
  6. All children have the right to be treated with respect and to be safeguarded from harm. We recognise that:
  • Some children may be especially vulnerable to abuse
  • Children who are abused or neglected may find it difficult to develop a sense of self-worth and to view the world in a positive way. Whilst at school, their behaviour may be challenging
  • Children can be victims and perpetrators of abuse
  • Children who harm others may have been abused themselves
  • Allegations can be made against staff, however careful and safe our recruitment practices

This policy will be updated annually and known to everyone working with children and young people within the school’s teaching network.

This Policy and others are posted on our website:

This policy is in line with statutory guidance for schools and colleges;  Keeping Children Safe in Education (2022), Working Together to Safeguard Children (2022) and  London Child Protection Procedures.


  1. Host Tutor and Staff Guidelines

Training and Induction

All Head Office and teaching staff complete Basic Safeguarding Awareness (Level 1) as a standard element of induction.

Safe Practice

Safe working practice ensures that students are safe and that all staff:

  • Are responsible for their own actions and behaviour and should avoid any conduct which would lead any reasonable person to question their motivation and intentions;
  • Work in an open and transparent way;
  • Ensure they teach in an environment with open doors, in full view of others where possible to avoid situations that could be open to question
  • Discuss and/or take advice from school management over any incident which may give rise for concern;
  • Record any incidents or decisions made;
  • Apply the same professional standards regardless of diversity issues;
  • Are aware that breaches of the law and other professional guidelines could result in criminal or disciplinary action being taken against them.

One-to-one contact with students

When hosting and teaching a student, teachers should take care to maintain best Safeguarding practice:

  • Avoid sitting or standing in close proximity to the student. Always leave exit routes clear for a student to leave the room if they wish.
  • Avoid all unnecessary physical contact; apologise immediately if accidental physical contact occurs. Touching may be appropriate when a student is in distress and needs comforting: use your professional judgement when you feel a student needs this kind of support.
  • Avoid any conduct that could be seen as a sexual advance.
  • Avoid displays of affection.
  • Report any incident that causes you concern to the DSL, maintaining your own separate written record.

Child Protection Policy

Confidentiality and Disclosure of Information

If you have concerns regarding the potential abuse of a child, it is not permitted by law to keep these concerns to yourself. Therefore, confidentiality may be breached if withholding information may damage the wellbeing of a child.

All information collected on any child will be kept secure and access limited to the appropriate individuals and agencies.

Identifying child abuse

Child Abuse is most often used to describe ways in which children are harmed – usually by adults – with damage to their physical or mental health. There are four broad categories of abuse as follows:

  • Physical: through hitting, shaking, squeezing etc.;
  • Sexual: through inappropriate touching or contact with a child;
  • Emotional: through persistent lack of attention, unrealistic adult demands;
  • Neglect: failing to provide basic needs of food, proper clothing, safe supervision

It can be difficult to identify child abuse as it has various forms. Below are some typical indicators to watch for:

  • Unexplained injuries;
  • A child describing an abusive act that has happened to them;
  • Another child telling you of their concern about a friend / fellow student;
  • Sexually explicit behaviour in games / activities;
  • Serious distrust of adults;
  • Difficulty in making friends / socialising with other children

The last two might appear naturally as the school and its programmes are new and strange environments for visiting children who typically only stay for 2 or 3 weeks. However, in extreme forms, these might be indicators of a deeper problem.

Child sexual exploitation (CSE) is a form of sexual abuse where children are exploited for money, power or status. Consent for sexual activity cannot be given under such a context, even where a child believes that they have provided consent. CSE can take place online and may not involve physical contact. Potential indicators of CSE may include:

  • Children who appear with unexplained gifts or new possessions
  • Children who associate with other your people involved in exploitation
  • Children with older boyfriends or girlfriends
  • Children who become pregnant, or who suffer from STIs
  • Children who misuse alcohol and drugs
  • Children who go missing for long periods of time or regularly come home late
  • Children who miss classes or drop out of school

Female genital mutilation (FGM) is a crime in the UK; there is a legal duty to report it if you know it has happened to anybody under 18.


Bullying, defined as wilful and repeated behaviour which has the purpose of making another person unhappy, is not tolerated in any form at our school.

Identifying bullying

Bullying can take many different forms. It may be physical, emotional, name- calling, showing a lack of respect for another’s property, excluding somebody from a social group; there are many possibilities. One person ‘having a joke’ is another person suffering bullying. Sometimes it is obvious, sometimes it is done subtly and in such a way that children will be worried about telling staff what is happening. For this reason it is vital that staff are vigilant in noticing changes in behaviour of children, particularly if they become withdrawn.

Photography and Images

The vast majority of people who take or view photographs or videos of children do so for entirely innocent, understandable and acceptable reasons. Sadly, some people abuse children through taking or using images, so we must ensure that we have some safeguards in place.

To protect students:

  • Seek their consent for photographs to be taken or published (on our website or in newspapers or publications)
  • Seek parental consent (this is indicated on the Parental Consent Form)
  • Use only the student’s first name with an image
  • Ensure students are appropriately dressed
  • Encourage students to say if they are worried about any photographs that are taken of them

In any of the above situations, immediately log and record what has happened, what you have seen, suspected or been told. Then inform the DSL directly. The DSL will then discuss the matter with the Managing Director, who will take appropriate action which may involve external agencies and contacting agents / parents.

Please bear in mind the above guidelines if considering posting photos or videos of students aged under 18 to social media sites.


Host Tutors have a responsibility to the children in their care to know what they are doing during their stay with them. This includes all online activities.

Risks to children who use the internet include:

  • Exposure to inappropriate materials, for example pornographic pictures and videos
  • Physical danger and sexual abuse
  • Cyberbullying
  • Addiction and obsessive use
  • Losing control over sensitive pictures and other media
  • Damage to online reputation
  • Illegal or inappropriate behaviour, for example, exposure to hate mail or offensive images
  • Viruses
  • Copyright infringement

Bearing in mind the above, host tutors are required to install parental control software on their internet access points.

Good practice for the use of internet during Young Learner placements includes:

  • Guiding children as to what internet use is acceptable and what is not. Providing clear objectives when the internet is used during lessons.
  • Planning internet use to enrich and extend learning activities
  • Encouraging children to report any materials that make them feel uncomfortable to their host tutor
  • Maintaining adult supervision of internet access at all times

Host tutors should maintain professional boundaries when engaging with Young Learners online, especially on social media. Connecting or ‘friending’ students aged under 18 on social media is not considered appropriate.

Prevent (UK only)

ITL has certain obligations under the Counter Terrorism and Security Act 2015 to help counter radicalisation among students of all ages. The Prevent strategy is the cornerstone of the UK government’s counter-radicalisation programme. It is important that all staff members and host tutors are aware of the need to implement Prevent, and appropriately trained in its application.

  • All host tutors and staff members must complete Prevent online training
  • The risk of radicalisation will be managed by:
    • Promoting a safe and tolerant environment via the clear outlining of behaviour expectations
    • Challenging radical views where they are espoused; the Prevent lead should be involved in this process where possible
    • Preparedness to react to upset caused by local or international news events (e.g. terrorist attacks)
    • Recognising signs of vulnerability to influence by extremist views


  1. Child Protection Procedures

What to do if a child discloses sensitive information to you

  1. Receive
  • Stay calm and listen to what the child is saying to you. Accepting what is being said without judgement, and take it seriously.
  1. Reassure
  • Let the child known that they have done the right thing by sharing the information with you. Thank them for telling you.
  • Explain that you must inform other people about the information disclosed: do not promise to keep anything secret.
  • Explain that the people you share the information with have the job to protect and help children.
  1. React
  • Do not push for more information. Do not make assumptions or interpretations of what you are told.
  • Don’t ask leading questions. Let the child explain in their own words and own time what has occurred.
  • Do not ask the child to repeat what they have told you to another person.
  • Discuss your concerns at the earliest possibility with the DSL, who will report further to the LADO in your area.
  1. Record
  • Make a note, as detailed as possible, of any conversations with the child. Use the actual words used by the child. If necessary draw a picture or diagram to show bruises or other marks which the child shows to you.
  • Record statements and observable things, not your assumptions or interpretations.
  • Do not destroy any notes made.
  • If you are not happy with our management of the disclosure, you may report your concerns directly to the LADO yourself.

What to do if abuse is suspected

  • Continue to monitor the child’s behaviour, making a note of particular concerns.
  • Discuss concerns with the DSL.
  • If you are still concerned about the child’s welfare, information must be passed to the relevant agency. Reporting suspected abuse is to protect the child – you are not ‘reporting’ the child’s parents.
  • If you or the DSL has contacted your local Social Services, they should inform you that they are responding to what you have told them. It is not likely that you will be told what action they are taking.

How to react if you suspect bullying

  • Investigate all reports, however seemingly trivial.
  • Ensure that all reports of suspected bullying are logged and that the follow-up is also log
  • Once it has been established that bullying has taken/ is taking place, explain to the
  • person acting unkindly that their actions have been precisely that and tell them the effect it has had on another / others.
  • Ask them to consider an appropriate way of putting things right and, if necessary, support
  • them in making an apology.
  • Ensure that any apology / reconciliation is done with staff present so that it can be accurately record
  • Should the incident be more serious, conduct no-blame meetings with both parties (bully and bullied). The aim is to clarify the situation through discussion and allow both sides to work out a solution that is satisfactory to them both. This will be recorded by the supervising teacher. (B. Under-18s should not be asked to sign any documents). Send details to the DSL, who will inform agents / parents of both parties what has happened and how it has been resolved.
  • If, after this meeting, the bullying continues, then it must be seen as deliberate and require a more serious respons The DSL will take immediate action to protect the bullied person and begin procedures to restrict the activities of the bully. Decisions will be made which could involve the bully being removed from the site, perhaps to another one. The DSL will keep agents / parents of both parties fully informed.
  • Any further incidents of bullying by the same person would result in them having to leave the school and/or programme and return home as quickly as possibl

Whom to contact

  1. InTuition Designated Safeguarding Lead (DSL)

Name: Alexa Randell

Position: Director of Studies

Contact number: +44 7546 309501


If the DSL is unavailable, contact the Designated Member of Staff:

Simon Thorley | +44 7809 218336 |

  1. Referral Agencies

Contact the police (999 / 112) if you think a child is in immediate danger. If a child is not in immediate danger, call 101 and ask for the Safeguarding Coordination Unit (UK only).

  1. Advice and support (UK only)

The NSPCC: 0800 800 500

Childline: 0800 1111

What InTuition will do when you report suspected abuse

Action by the DSL

In cases of allegations being made against a host tutor or member of staff, the DSL must:

  1. Contact the CEO immediately to inform him of any allegation and to agree what actions are necessary. If the CEO is not contactable, she should contact the most senior member of staff available, as long as the allegation is not against that member of staff. If the allegation is against one of the staff members mentioned, she should not involve either party in this procedure or any decisions, but inform them of the allegation as per the guidelines in the key documents below (namely Dealing with Allegations of Abuse against teachers and other staff).
  2. In agreement with the CEO, contact the Local Authority Designated Officer (LADO) immediately and follow the advice they giv The LADO will depend on the location of the Homestay Tutor. For details:
  3. Keep a record of the allegation to include: date received, the form of communication the allegation was received (by email / letter/ telephone call); the student’s name; the member of staff concerned; the nature of the allegation and confirmation that the document Allegations against Staff members is read and the procedures on the Flowchart following:
  4. All written records of the incident/allegation should be stored in a highly secure and confidential location.
  5. For all cases, it is essential to cross reference with the official advice listed below (Dealing with Allegations of Abuse against Teachers and other Staff) at:
  6. This gives advice on:
  • Duties as an Employer/employee;
  • Initial considerations;
  • Supporting those involved;
  • Confidentiality;
  • Resignations and compromise agreements;
  • Record-keeping; References;
  • Timescales;
  • Oversight and monitoring;
  • Suspension;
  • Information sharing;
  • Action following criminal investigation or prosecution;
  • Action on Conclusion of a case;
  • Learning lessons;
  • Actions in respect of unfounded or malicious allegations.
  1. She must agree with the LADO exactly how each incident should be concluded. The DSL should also read and bear in mind the key points below:
  • If an allegation is made against a host teacher (or member of staff) the quick resolution of that allegation should be a clear priority to the benefit of all concer At any stage of consideration or investigation, all unnecessary delays should be eradicated.
  • Allegations that are found to have been malicious should be removed from personnel records and any that are not substantiated, are unfounded or malicious should not be referred to in employer references.
  • Students that are found to have made malicious allegations are likely to have breached school behaviour policies. The school should therefore consider whether to apply an appropriate sanction, which could include referral to the police if there are grounds for believing a criminal offence may have been commi
  1. The school must refer details to the Disclosure and Barring Service (DBS) when a person alleged to have committed abuse has resigned, or been dismissed, to protect other children from potential harm.
  1. Safer Recruitment Policy

InTuition Languages operates a Safer Recruitment Policy. For full details, see the separate Recruitment Policy .

  1. Designated Personnel

Named personnel with designated responsibility for Safeguarding


Designated Safeguarding Lead

Designated Staff

Designated Prevent Lead


Alexa Randell

Simon Thorley

Alexa Randell


Named personnel with designated responsibility regarding allegations against head office staff


Designated Senior Manager

Deputy Designated Senior Manager


Simon Thorley

Alexa Randell

 Dates the Safeguarding Policy is reviewed

Review Date

Changes made/Details of action plan

By Whom

June 2023

DSL cover arrangements added

Simon Thorley

April 2021

Changes to designated personnel

Simon Thorley

February 2018

Changes to designated personnel

Reference to Safer Recruitment Policy added

Section on E-safety added

DSL contact details changed

Simon Thorley

Evelyn Feeney

February 2017


Norman Renshaw

Brenda Ashton

February 2016


Norman Renshaw

Brenda Ashton