SAFEGUARDING & CHILD PROTECTION PROCEDURES
Peppo Tutors takes safeguarding very seriously and has set out below procedures that should be followed to safeguard children and young people. These procedures should be read in conjunction with Peppo’s Safeguarding Policy and its Conduct of Behaviour Guidelines.
The procedures are not exhaustive and therefore if an incident occurs that is not covered in these procedures you are advised to contact Peppo.
What procedures are taken on recruitment?
The following steps will be taken on recruitment of any Peppo Personnel (as defined in the Safeguarding Policies):
No direct tutoring work with children can begin without receipt of a satisfactory reference and an enhanced DBS clearance for the tutor;
Each tutor will be subject to a video interview;
Each tutor will be required to provide a full career history;
An enhanced DBS check is carried out for all Peppo Personnel (unless they can produce a recent enhanced DBS certificate) and will be updated on a three yearly basis or on a ‘live’ basis for those registered with the DBS update service; and
Information on Safeguarding is received by all Peppo Personnel;
Peppo keeps a single central record of all DBS checks. It will handle the information in strict confidence and will only convey the information to persons entitled to receive it.
What should a tutor do if a safeguarding concern is made/observed?
Where safeguarding or child protection disclosure has been made by a child/adult, or a safeguarding or child protection concern is observed, the following action must be taken:
the tutor should listen very carefully to what the child or adult is saying and should:
reassure the child/adult that they have done the right thing in speaking-out;
find an opportunity to explain that it is likely that the information will need to be shared with others who need to know;
not promise to keep it a secret; and
ask questions for clarification only.
the tutor must immediately make a note of the disclosure or concerns, where possible, using the exact words of the child (if this needs to be paraphrased, this must be made clear that it has been paraphrased) including names, dates and times;
the tutor must immediately notify their contact at Peppo, provide them with a full description of their concern and with the written transcript. Delay could prejudice the welfare of a child. If their usual contact at Peppo is not available they must notify Adrian Levy, the founder and CEO of Peppo;
All Peppo Personnel should feel able to raise concerns and know that such concerns will be taken seriously. However, if a person feels unable to raise an issue with Peppo or feels that their genuine concerns are not being addressed they should call the NSPCC helpline on 0808 800 5000 or e-mail them on email@example.com or, in an emergency which may involve criminal activity, call the police.
What shouldn’t a tutor do if a safeguarding concern is made/observed?
It is imperative that action is taken promptly (and certainly on the day the matter has been raised) and so a tutor should not delay in notifying any concerns. It is also important to remember that it is not the role or the responsibility of the tutor to investigate the matter or to decide whether any abuse has occurred. That is the task for the professional child protection agencies following a referral from Peppo.
How will Peppo deal with safeguarding information?
The need to share information about child protection is paramount and overrides any duty of confidentiality. However, it is important that safeguarding concerns and information about vulnerable children are handled carefully:
where information is stored electronically, steps must be taken to ensure that this is kept secure, e.g. use of computer password, and password lock when leaving the computer unattended;
wherever documents are posted, the envelope must be marked “Strictly Private and Confidential”; and
information about children must be shared on a “need to know” basis only.
Will lessons be recorded?
All lessons will be recorded and, subject to any technological difficulties, available for play back to child, tutors, parents and appropriate Peppo Personnel for up to 14 days. The recordings will remain the property of Peppo and Peppo may allow any appropriate agencies access to the recordings.
What happens in circumstances where inappropriate language is being used during a teaching session?
The use of inappropriate language is unacceptable from either the tutor, the child, the parent or any other person. The person using inappropriate language should be asked to stop using such language during the teaching session. If the language continues then the session should be terminated immediately and the matter reported to Peppo.
What happens where there is inappropriate behaviour during a teaching session?
Please see Conduct of Behaviour Guidelines for some examples of inappropriate behaviour. Behaving inappropriately is unacceptable from either the tutor, the child, the parent or any other person. The person behaving inappropriately should be asked to stop immediately. If the behaviour continues then the session should be terminated immediately and the matter reported to Peppo.
Any display of indecent or pornographic images is unacceptable and may be an offence under English law. Any tutor witnessing the display of such images by or in the presence of a child should immediately terminate the session and follow the procedure set out under the section headed “What should a tutor do if a safeguarding concern is made/observed?”. Any child witnessing such images should immediately terminate the session and report this matter to a parent or responsible adult, who should inform Peppo immediately.
Date of procedures: January 2021
SAFEGUARDING & CHILD PROTECTION POLICY
Peppo Tutors takes safeguarding very seriously whilst it is committed to furthering the educational attainment of the children and young people that it tutors it acknowledges that the welfare of the child is of paramount importance. Children have the right to be treated with respect in a safe and nurturing environment and protected from any kind of abuse.
What is the basis of this policy?
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. In this policy, “children or young people”, mean anyone who has not yet reached their 18th birthday and, “Peppo Personnel” mean tutors, members of staff (including managers, directors, paid staff, agency staff), consultants, interns or other persons working on behalf of Peppo (regardless of whether they are Peppo employees).
What is the purpose and application of this policy?
The purpose of this policy is to provide protection for the children and young people who receive Peppo’s tutoring service as well as the safety and wellbeing of our tutors. This policy should be read alongside the Safeguarding Procedures and Conduct of Behaviour guidelines. This policy applies to all Peppo Personnel.
What is Peppo’s commitment?
Peppo is committed to providing a safe environment for children and recognises that:
the welfare of the child/young person is of paramount importance;
all children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse;
all suspicions and allegations of inappropriate behaviour will be taken seriously and responded to swiftly and appropriately; and
working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.
How will Peppo seek to safeguard children and young people?
Peppo will seek to safeguard children and young people by:
valuing them, listening to and respecting them;
recruiting tutors and staff safely, ensuring all necessary checks are made;
adopting safeguarding procedures and conduct of behaviour guidelines;
recording, storing and using information professionally and securely, in line with data protection legislation;
sharing information about child protection and good practice with children, parents, staff and tutors;
sharing information about concerns with agencies and schools who need to know, and involving parents and children appropriately;
providing effective training for tutors and staff;
using our procedures to manage any allegations against Peppo Personnel; and
building a safeguarding culture where Peppo Personnel, children, young people and their families, treat each other with respect and are comfortable about sharing concerns.
What is the role of Peppo Personnel?
It is essential that all Peppo Personnel are aware of their duties concerning safeguarding and ensure that:
the safety and wellbeing of the child is promoted;
this policy and the Safeguarding Procedures and Conduct of Behaviour guidelines are read, understood and complied with; and
where Tutoring occurs within a school or other third-party organisation, the policies of that organisation are respected
It is also essential that Peppo Personnel should be alert to the signs of child abuse (the main categories of which are set out in the appendix) and should report any concerns about a child or someone else’s behaviour promptly. It is not the role or responsibility of Peppo Tutors to investigate allegations of harm or risk of harm.
Will this policy be updated?
We are committed to reviewing our policy and good practice annually and will update this policy if appropriate.
Who are the key contacts?
Given the importance that we place on safeguarding the key contact is Peppo’s founder and CEO, Adrian Levy. He can be contacted at:
Should you wish to discuss any matter with a third party then please contact the NSPCC helpline on 0808 800 5000.
Date of Policy: January 2021
FORMS OF ABUSE
Four Main Categories
The following set out the four main categories of abuse.
A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:
provide adequate food, clothing and shelter (including exclusion from home or abandonment)
protect a child from physical and emotional harm or danger
ensure adequate supervision (including the use of inadequate care-givers)
ensure access to appropriate medical care or treatment It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve:
conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person
not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate
age or developmentally inappropriate expectations being imposed on children
interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction
seeing or hearing the ill-treatment of another
serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.
Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone (Working Together 2018)
Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to psychological, physical, sexual, financial and emotional.
As highlighted above, Domestic Abuse is generally treated as falling under emotional abuse. The cross- government definition (2014) of domestic violence and abuse is as follows:
Peppo Tutors considers that domestic abuse is a child protection issue and that if children witness or hear domestic abuse, this must be treated as a child protection matter, even if they are not directly involved in the incidents. The Adoption and Children Act 2002 states that impairment can be caused by seeing or hearing the ill treatment of another.
Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve:
• physical contact, including assault by penetration (for example, rape or oral sex) or non- penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.
• non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse
Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children (Working Together 2018)
In addition to the above concerns, children self-harming or expressing suicidal ideas must be treated as safeguarding and child protection issues.
Child Criminal Exploitation
Where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence. The victim may have been criminally exploited even if the activity appears consensual. Child criminal exploitation does not always involve physical contact; it can also occur through the use of technology.
Child Sexual Exploitation
Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.
County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of ‘deal line’. They are likely to exploit children and vulnerable adults to move and store the drugs and money, and they will often use coercion, intimidation, violence (including sexual violence) and weapons.
Any concerns about radicalisation and extremist views or behaviours in children and young people must be reported as a safeguarding concern. Extremism goes beyond terrorism and includes people who target the vulnerable – including the young – by seeking to sow division between communities on the basis of race, faith or denomination; justify discrimination towards women and girls; persuade others that minorities are inferior; or argue against the primacy of democracy and the rule of law in our society.
Female Genital Mutilation (FGM)
Concerns that a child has been, or may be about to be, subjected to FGM, fall under this policy and must also be reported as a safeguarding concern.
In forced marriage, one or both spouses do not consent to the marriage and some element of duress is involved. Duress includes both physical and emotional pressure and abuse.
‘So-called’ Honour-Based Violence
The term “honour crime” or “honour-based violence” embraces a variety of crimes of violence, including assault, imprisonment and murder where their family or their community is punishing the person. They are being punished for (actually or allegedly) undermining what the family or community believes to be the correct code of behaviour. In transgressing this correct code of behaviour, the person shows that they have not been properly controlled to conform by their family and this is to the “shame” or “dishonour” of the family.
Contextual Safeguarding is an approach to understanding, and responding to, young people’s experiences of significant harm beyond their families. It recognises that the different relationships that young people form in their neighbourhoods, schools and online can feature violence and abuse.
CONDUCT OF BEHAVIOUR GUIDELINES
Peppo Tutors takes safeguarding very seriously and has set out below some behavioural guidelines that should be followed to safeguard children and young people. These guidelines should be read in conjunction with Peppo’s Safeguarding Policy and its Safeguarding Procedures.
What behaviour is expected of Peppo Personnel?
Peppo Personnel (which includes tutors and is defined in Peppo Safeguarding Policy) should always maintain appropriate professional boundaries and behaviour with a child that they teach. It is not a relationship of equals and so they must ensure that this unequal balance of power is not used for personal advantage or gratification.
Peppo Personnel must:
General: Treat all children and young people with respect and be sensitive to their needs. Treat students fairly and without prejudice and discrimination.
Appearance: Wear clothes which are appropriate for their role, that are not viewed as offensive, revealing or provocative, do not contain political affiliations or other contentious slogans and are not considered discriminatory or culturally insensitive.
Teaching Environment: If on-line, ensure that their environment does not display any inappropriate images or items capable of being viewed by the child during the teaching session and that there is no inappropriate background noise or language. If in-person, avoid being alone with the child. All in person sessions must happen in a public place or in an office with a door open, ensuring there are other people present in the vicinity. Under no circumstances should a child visit the tutor’s home.
Physical contact: Avoid any physical contact with a child during an in-person lesson.
Communication: Only communicate with a child in a professional manner. All language should be appropriate and not offensive or discriminatory. They should only have contact with a child they are tutoring at the times and in the venues or in the on-line manner that has been pre-agreed.
Child’s Information: Treat all information and data about a child with sensitivity.
Gifts: Avoid giving gifts to a child even when supporting positive behaviour. If a tutor wishes to give a gift it should be discussed in advance with the parent or responsible adult or with the school.
Infatuation: Occasionally a child may develop an infatuation with an adult who works with them. Peppo Personnel must deal with these situations sensitively and appropriately to maintain the dignity and safety of all concerned. The relevant person should report the incident
Report: Report any incidents or concerns that a child may be at risk. See Peppo Safeguarding Procedures.
Peppo Personnel must not:
General: Discriminate against or harass a child or any Peppo Personnel on the basis of that person’s age; disability; gender reassignment; marriage or civil partnership; pregnancy or maternity; race; religion or belief; sex; and/or sexual orientation.
Relationship: Engage in, or attempt to engage in, a sexual or inappropriate relationship with a child. Make suggestive or provocative comments to a child or about a child whether in front of them or via email, text or otherwise (including discussing their own sexual relationships).
Communication: Communicate with a child outside of a teaching session including by social media, which includes (but is not limited to) ‘WhatsApp’, ‘Facebook’, ‘Snapchat’, ‘Tik Tok’ and ‘Twitter’.
Alcohol/Drugs: Be under the influence of alcohol or other substances when tutoring or otherwise working on activities involving children.
Photographs: Take photographs of a child without permission from Peppo, the child and the parents or responsible person.
Child’s Information: Transfer the personal data of a child to third parties without express permission from Peppo, the child and the parents or responsible person. Disclose information about a child on-line or otherwise.
Tutor’s information: Reveal excessive personal details to a child you are tutoring (for example, your address, e-mail address or phone number).
Peppo Personnel who fail to conduct themselves as required may be barred from Peppo website with immediate effect. Any serious breaches may result in a referral being made to the police or the relevant Local Authorities Designated Officer. Any recordings may be provided by Peppo to the police or relevant agencies.
What behaviour is expected of a child being tutored?
A child being tutored by Peppo should behave in the same respectful manner as is expected of them at school.
The child should treat the tutor with respect and fairness and not subject them to abusive behaviour or language and should not make any inappropriate suggestions to the tutor. The child should attend the lesson on time. The child should not seek to contact the tutor outside of the session whether by social media or otherwise. The child should report any concerns about a tutor to a parent or person or responsible person.
A parent or responsible person should be present or available during a tutor session.
Date of Guidelines: January 2021