Our Policies

  • 1. Policy Statement & Purpose

    Summit Education is committed to safeguarding and promoting the welfare of children. We provide 1:1 or 1:2 tutoring, mentoring and re-engagement sessions (typically 120–180 minutes) for children and young people aged 5–18 who are out of, or at risk of disengagement from, education. Safeguarding is everyone’s responsibility; we operate a culture of vigilance, transparency and professional curiosity.

    2. Scope

    • Applies to the proprietor (Robert Williams) and any future staff, volunteers, contractors, agency workers, or third parties.

    • Applies to all activities, including sessions in outdoor/community settings, homes, libraries and other venues.

    • Covers all forms of harm: abuse, neglect, exploitation, online risks, contextual/extra-familial harm, radicalisation.

    3. Legal & Policy Framework

    • Keeping Children Safe in Education (current version)

    • Working Together to Safeguard Children (current version)

    • Education Act 2002 s175/157; Children Act 1989/2004

    • Counter-Terrorism and Security Act 2015 (Prevent duty)

    • Data Protection Act 2018 & UK GDPR; Human Rights Act 1998; Equality Act 2010

    • Non-School Alternative Provision Voluntary National Standards (DfE)

    4. Roles & Responsibilities

    Designated Safeguarding Lead (DSL): Robert Williams. The DSL leads on safeguarding, case management, referrals, record-keeping, training oversight, safer recruitment, allegations management liaison with the LADO, and policy review. In the absence of other staff, the DSL may also be the case manager; where appropriate the commissioner/school DSL will be consulted.

    • All adults working with Summit Education must: follow this policy; report concerns immediately; maintain professional boundaries; complete required training.

    • Commissioners/schools retain safeguarding responsibility for placed pupils and must receive timely updates on attendance, concerns and incidents.

    5. Definitions & Thresholds

    • Abuse: physical, emotional, sexual; neglect; child-on-child abuse (incl. bullying, sexual violence/harassment).

    • Extra-familial harm: exploitation (CSE/CCE), serious violence, county lines, online harms.

    • Early Help: providing support as soon as a need emerges to prevent escalation.

    • Significant harm: threshold for statutory intervention via Children’s Social Care.

    6. Safer Working Practice

    • Professional boundaries at all times; no social media contact with pupils; use professional contact routes only.

    • Plan sessions to maximise visibility: open/public areas where appropriate; dynamic risk assessment for any 1:1 in secluded areas.

    • No gifts or favouritism; avoid lone closed-door situations; never promise confidentiality—explain duty to share safeguarding concerns.

    • Use school/commissioner-approved communication; all session notes recorded promptly and securely.

    7. Safer Recruitment & Vetting

    We follow Summit Education’s Safer Recruitment Policy. As proprietor/DSL, Robert Williams holds an enhanced child workforce DBS and subscribes to the Update Service. Any additional staff/volunteers will be vetted (enhanced DBS with barred list where applicable), reference-checked, trained and supervised proportionately to role risk. A personnel & vetting record (SCR-equivalent) is maintained.

    8. Induction, Training & Supervision

    • DSL: Safeguarding Level 3 (updated at least every 2 years) and Prevent awareness.

    • All adults: safeguarding and Prevent training appropriate to role; annual refreshers/updates.

    • Regular supervision/reflective practice focusing on safeguarding, boundaries and well-being.

    9. Recognising & Responding to Concerns

    • Listen, reassure, do not investigate; record verbatim key words, time/date, injuries/behaviour; sign and date notes.

    • Immediate danger/emergency: call 999; then inform the DSL/commissioner.

    • Non-urgent concerns: inform DSL immediately (same day); DSL decides Early Help vs. referral to Children’s Social Care.

    • Inform the child/parent as appropriate unless doing so places the child at increased risk or undermines a criminal investigation.

    10. Reporting Routes & Referrals

    The DSL will consult the placing school/commissioner DSL and, where threshold is met, make referrals to Children’s Social Care and/or the Police. For allegations about adults working with children, the DSL will contact the Local Authority Designated Officer (LADO) within one working day.

    11. Managing Allegations & Low-Level Concerns

    • Allegations that meet the LADO threshold (harm, possible offence, or behaviour indicating risk) → report to LADO within 1 working day.

    • Record and act on low-level concerns to address patterns early; refer to Managing Allegations Policy & Low-Level Concerns guidance.

    • If the allegation concerns the proprietor, consult LADO directly and inform the commissioner.

    12. Information Sharing & Record-Keeping

    • Share information lawfully, proportionately and on a need-to-know basis to safeguard children.

    • Maintain a secure safeguarding file for each child (chronology, referrals, actions, outcomes).

    • Retain records per statutory guidance and commissioner expectations; store digitally with access controls.

    13. Online Safety & Digital Conduct

    • Reinforce safe, responsible use of technology during sessions; address cyberbullying, harmful content and contact.

    • No direct messaging with pupils on personal accounts; use approved channels via school/commissioner.

    • Report online harms via the same safeguarding routes; preserve evidence where safe to do so.

    14. Prevent Duty (Risk of Radicalisation)

    • Remain alert to radicalisation indicators (vulnerability, need for belonging, exposure to extremist material).

    • Record concerns and consult DSL; DSL to consider Prevent referral/CHANNEL via local pathway in discussion with commissioner.

    15. Behaviour, Physical Contact & Reasonable Force

    • Use de-escalation and relational approaches; never use corporal punishment.

    • Physical intervention only as a last resort to prevent immediate harm; record and report to commissioner same day.

    • Follow behaviour plans and agreed strategies from the home school where provided.

    16. Health, Safety, Ratios & Off-Site/Outdoor Activity

    • Dynamic and written risk assessments for each venue/route/activity (weather, terrain, traffic, public interactions).

    • Typical ratio 1:1 or 1:2 as commissioned; ensure visibility and line-of-sight where possible.

    • Emergency procedures agreed (meeting points, contact tree); carry charged phone and basic first aid kit.

    • Medical needs and consents checked before sessions; medication only administered per written plan/consent.

    17. Attendance, Missing Child & Transport

    • Mark attendance each session; notify commissioner promptly (aim within 30 minutes of no-show).

    • If a child is missing/unexpected absence: escalate per commissioner protocol and, where required, Police 999.

    • Transport by private vehicle only if authorised, insured for business use, risk assessed, and consented.

    18. Photography, Video & Publicity

    • No images or video without explicit written parental/carer consent and commissioner approval.

    • No posting of images on personal or organisational social media without written approvals; store agreed media securely.

    19. Whistleblowing & Complaints

    • Whistleblowing routes available for any adult to raise concerns about practice/safeguarding (internally to DSL, to LADO, or Police).

    • Complaints are logged, investigated promptly, and outcomes shared with commissioners; escalate as per commissioner procedure where applicable.

    20. Equality, Diversity & Inclusion

    Summit Education upholds the Equality Act 2010. We make reasonable adjustments for disability, consider individual needs including SEND/SEMH/EBSA, and avoid discriminatory practice. Safeguarding responses are child-centred and proportionate.

    21. Monitoring & Review

    • Policy reviewed at least annually and following statutory updates, local learning, or incidents.

    • Implementation monitored via case reviews, commissioner feedback, and supervision notes.

    • Next scheduled review: November 2026 (or earlier if guidance changes).

  • 1. Purpose & Statement of Commitment

    Summit Education is committed to equality of opportunity, fair treatment and an inclusive culture for all children, families, commissioners, and any adults who work with us. We oppose discrimination, harassment and victimisation in all forms and actively promote equity, dignity and respect across our tutoring and re‑engagement practice (typically 1:1 or 1:2 sessions, 120–180 minutes, in community and outdoor settings).

    2. Scope

    • Applies to learners (aged 5–18), parents/carers, commissioners, visitors, and all adults working for or on behalf of Summit Education (including the proprietor, contractors, volunteers and partner personnel).

    • Covers all activities, including teaching, assessment, outreach, off‑site/outdoor sessions, communications, data handling, recruitment and procurement.

    3. Legal & Policy Framework

    • Equality Act 2010 (protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation).

    • Public Sector Equality Duty (as relevant to our commissioned work with schools/LAs).

    • Human Rights Act 1998; UK GDPR/Data Protection Act 2018; SEND Code of Practice; KCSIE; DfE Non‑School AP Voluntary Standards.

    4. Definitions

    • Equality: ensuring people are not treated less favourably because of a protected characteristic.

    • Equity: recognising different needs and removing barriers through reasonable adjustments and targeted support.

    • Inclusion: creating enabling environments where everyone feels safe, respected and able to participate and progress.

    5. Roles & Responsibilities

    • Proprietor (Robert Williams): leads on policy implementation, training, monitoring, and addressing any breaches; ensures reasonable adjustments; reviews annually.

    • All adults working with Summit: uphold this policy; challenge prejudice; report incidents; adapt practice to individual needs.

    • Commissioners/Placing Schools: share relevant information to inform reasonable adjustments and risk assessments; collaborate on support plans and reviews.

    6. Admissions, Access & Reasonable Adjustments

    • Referrals considered on individual need; decisions are transparent and non‑discriminatory.

    • We make reasonable adjustments for disability and health needs (e.g., adapted routes, timings, rest breaks, communication formats, sensory‑friendly locations, travel support, access to toilets).

    • We will consider alternative venues or remote components where appropriate to meet access needs without compromising safeguarding or quality.

    7. Inclusive Curriculum & Teaching

    • Teaching plans reflect learner interests, strengths and culture; materials avoid stereotypes and are age‑appropriate.

    • Literacy/numeracy support is embedded; EBSA/SEMH aware approaches (graduated response, relational practice, predictable routines).

    • Assistive technology and alternative formats (e.g., visual schedules, simplified language) used where helpful.

    8. Outdoor/Community Contexts

    • Routes/venues chosen with accessibility in mind (surfaces, gradients, seating, shelter, toilets, public transport links).

    • Adaptations to enable participation (e.g., shorter loops, quieter areas, headphones, staggered start times).

    • Weather and sensory considerations included in risk assessments; dignity and privacy respected during breaks.

    9. Language, Communication & Cultural Sensitivity

    • Use clear, respectful, person‑first language (or learner‑preferred terms); avoid assumptions about identity or family structures.

    • Provide information in accessible formats on request (large print, easy read).

    • Interpretation/translation arranged through commissioners where required.

    10. Preventing Harassment, Bullying & Victimisation

    • Zero tolerance for harassment or bullying (including racist, sexist, homophobic, transphobic, ableist or faith‑based abuse, and online harms).

    • Incidents are recorded, addressed promptly, and reported to commissioners/parents as appropriate; safeguarding routes used where necessary.

    • Support and restorative approaches are offered alongside proportionate consequences.

    11. Recruitment, Training & Development

    • Safer, fair recruitment based on merit and role requirements; no discrimination in adverts, selection or terms.

    • Commitment to CPD on equality, SEND/SEMH, trauma‑informed practice, anti‑racism and cultural competence.

    • Reasonable adjustments in recruitment and during work activities are provided on request.

    12. Data, Confidentiality & Reporting

    • Personal data handled lawfully and minimally in line with UK GDPR; equality information collected only where necessary and with clear purpose.

    • Incident and access‑need records are kept securely and shared on a need‑to‑know basis with commissioners/parents.

    • We will use anonymised data and feedback to identify barriers and inform improvement.

    13. Complaints & Escalation

    • Concerns can be raised with the proprietor (informally or via Complaints Policy).

    • Safeguarding‑linked concerns follow the Safeguarding/Managing Allegations policies; LADO contacted where thresholds are met.

    • Whistleblowing routes are available for public‑interest disclosures.

    14. Monitoring, Objectives & Review

    • We set practical equality objectives (e.g., improved access to outdoor routes, increased learner voice, adjustments turnaround times) and review progress with commissioners.

    • We welcome learner and parent/carer feedback and incorporate learning into practice.

    • Policy reviewed at least annually or earlier following legislation or service changes. Next scheduled review: 12 months from approval

  • Policy Statement

    Summit Education is committed to handling personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy outlines how personal data is collected, stored, used, and protected.

    Lawful Basis for Data Collection

    - Personal data is collected only for legitimate interests, including safeguarding, communication with referrers, and progress monitoring.
    - Data is collected with consent from the referring school, parent/carer, or local authority.

    Types of Data Collected

    - Basic identification details (name, age, school)
    - Contact information (where necessary)
    - Session notes and progress reports
    - Safeguarding or behavioural concern logs

    How Data Is Stored

    - Data is stored digitally on a password-protected device or encrypted cloud service.
    - Physical documents are kept in a locked file (if used).
    - Only I have access to this information.

    Data Sharing

    - Data is only shared with authorised individuals on a need-to-know basis.
    - No data is shared for marketing or commercial use.
    - Safeguarding concerns are shared immediately, per the Safeguarding Policy.

    Retention of Data

    - Personal data is retained for one academic year post-provision unless required longer for legal reasons.

    Rights of the Data Subject

    - Individuals have the right to access, correct, or delete their data.
    - Requests are responded to within 30 days.

    Data Breach Procedure

    - In case of a data breach, the ICO and affected individuals are notified within 72 hours if required.

    Policy Review

    This policy is reviewed annually or after relevant changes in legislation or practice.

  • 1. Mission & Scope

    Mission. Summit Education provides calm, high-quality tutoring and re-engagement support that helps young people return to sustained education. We put safeguarding first in every decision.

    Scope. This policy applies to:
    • The proprietor (Robert Williams)
    • Any future employees, contractors, sessional tutors, volunteers, work-placement/trainee staff
    • Agency/supply staff placed with Summit Education
    • Third-party providers delivering services on Summit’s behalf

    It covers safer recruitment, pre-employment checks, induction, training, record-keeping, and ongoing monitoring.

    2. Principles & Legal Framework

    • Recruiting is a safeguarding activity. We prevent, deter, and detect risk by design.
    • We follow Keeping Children Safe in Education (current version), Working Together to Safeguard Children, the Rehabilitation of Offenders Act 1974 (Exceptions Order), Data Protection Act 2018/UK GDPR, Equality Act 2010, and the Voluntary National Standards for Non-School Alternative Provision.
    • We work with the Local Authority Designated Officer (LADO) on allegations/concerns about adults working with children.
    • We maintain a personnel & vetting record (Single Central Record equivalent) even as a sole trader.

    3. Roles & Responsibilities

    • Proprietor/DSL: Robert Williams – leads safer recruitment; Designated Safeguarding Lead (DSL); ensures policy implementation and annual review; oversees checks and records; liaises with LADO/commissioners.
    • Commissioners/Agencies: must evidence KCSIE-compliant vetting for named workers supplied to Summit.

    4. When We Recruit (or Commission)

    This policy applies whenever Summit:
    • Engages contractors/sessional tutors
    • Hosts volunteers/trainees
    • Uses agency staff
    • Partners with third parties

    This policy always applies, regardless of duration.

    5. Advertising & Candidate Information

    All adverts/commissioning briefs include:
    • Safeguarding statement: “Summit Education is committed to safeguarding and promoting the welfare of children. All roles are subject to safer recruitment checks including an enhanced DBS (with children’s barred list where applicable).”
    • Job/role description; person specification; safeguarding responsibilities; duty to promote the welfare of children and uphold British Values.
    • Application form requirement (CVs are not accepted alone).

    6. Applications & Shortlisting

    • Candidates complete an application form in full (full employment history, gaps explained, declarations, referees).
    • Shortlisting strictly against person specification.
    • Proportionate open-source (online) checks on shortlisted candidates to identify potential safeguarding/reputation risks (per KCSIE).

    7. References

    • Two references: one from current/most recent employer (and, where applicable, a role involving work with children).
    • Sought directly and verified; anomalies clarified and recorded.
    • Ask about: suitability to work with children, safeguarding/allegations, relevant disciplinary history (including expired warnings related to safeguarding), capability, and (where lawful) attendance.
    • May contact additional previous employers if concerns/gaps arise.
    • Aim to obtain references before interview to probe issues appropriately.

    8. Interviews & Selection

    • Identity checked at interview; interviews in person or secure video.
    • Structured questions test motivation to work with children, safeguarding scenarios, professional boundaries, behaviour management, values and British Values.
    • Candidates must explain employment gaps/anomalies and any DBS disclosures; demonstrate how they keep children safe.

    9. Conditional Offer & Pre-Employment Checks

    Any offer is conditional on satisfactory checks:
    • Enhanced DBS with children’s barred list (for regulated activity) and Update Service status where used
    • Identity and Right to Work
    • Essential qualifications (original certificates)
    • Professional status as applicable (e.g., prohibition, Section 128 for management)
    • Overseas criminality checks where lived/worked overseas 3+ months in last 5 years
    • Employment history verified (gaps accounted)
    • Health declaration (fitness)
    Where positive disclosures exist: complete a documented, role-specific risk assessment and consult the LADO as appropriate before confirming appointment/engagement.
    Start work only when checks are satisfactory. Exceptionally (and only if risk-assessed), supervised start may occur pending a non-DBS check.

    10. Contractors, Agency & Third-Party Staff

    • Agencies must confirm in writing completion of all KCSIE checks for the named individual, including enhanced DBS + children’s barred list (if applicable), identity, right to work, qualifications, references, and prohibition/Section 128 where relevant. Verify arriving worker matches cleared individual.
    • Contractors/third-party staff in regulated activity require the same checks; those not in regulated activity are supervised and vetted to role risk.
    • For venue/host staff (e.g., libraries), Summit ensures safe supervision arrangements and includes conditions in risk assessments.

    11. Volunteers & Trainees

    • Role risk-assessed to determine checks.
    • Regular/unsupervised work → enhanced DBS with barred list.
    • Supervised volunteers → typically enhanced DBS (no barred list); always risk-assess.

    12. Online/Media Checks

    • Proportionate online checks may be carried out on shortlisted candidates (publicly available information only). Findings recorded and discussed where relevant.

    13. Single Central Record (SCR-Equivalent)

    • Secure personnel & vetting record logging: identity, right to work, DBS level/number/date/Update Service, barred list check result, prohibition/Section 128 (if applicable), qualifications, references, dates, verifier, and decision.
    • Robert Williams’ enhanced DBS (child workforce) and Update Service status are recorded and kept in date.

    14. Induction, Training & Supervision

    All new starters (including contractors/volunteers) receive and sign for:
    • Safeguarding/Child Protection policy; KCSIE Part 1 (or Annex A where appropriate); Code of Conduct; Whistleblowing; Low-level concerns; Managing Allegations; Online Safety; Prevent; Health & Safety; Risk Assessment; Lone Working.
    • Role guidance on boundaries, recording/reporting, information sharing, emergencies.
    • Mandatory training: Safeguarding (level appropriate), Prevent, de-escalation/EBSA, reporting pathways, information security.
    • Early supervision/check-ins (e.g., weeks 2, 6, 12) to review conduct and safeguarding practice.

    15. Managing Positive Disclosures

    • Documented risk assessment considers: nature/seriousness, relevance to role, age at time, pattern, time elapsed, rehabilitation evidence, possible controls/supervision.
    • Possible outcomes: decline, defer pending advice, proceed with controls where safe and justified.
    • Consult the LADO where thresholds are met. Record decisions and rationale.

    16. Allegations, LADO & DBS Referrals

    • Allegation/concern that an adult has harmed a child, committed a relevant offence, or may pose a risk → report to LADO within 1 working day.
    • Follow statutory processes; cooperate fully with investigations.
    • DBS referral: if removed from regulated activity (or resigns) for posing a risk of harm, we must refer to the DBS.
    • See Managing Allegations Policy for full procedure.

    17. Data Protection & Record Retention

    • Recruitment data processed under UK GDPR/DPA 2018 (legal obligation/legitimate interests).
    • Retention: unsuccessful candidates ~6 months; successful hires per statutory requirements and best practice.
    • Files stored securely with restricted access.

    18. Equality, Diversity & Inclusion

    • Fair recruitment without discrimination (Equality Act 2010).
    • Reasonable adjustments for disability.
    • Consideration of spent convictions handled lawfully under Exceptions Order while meeting safeguarding duties.

    19. Low-Level Concerns, Whistleblowing & Culture

    • “Tell-us-early” culture for low-level concerns; whistleblowing routes (internal/LA/Police).
    • Concerns recorded, reviewed, and patterns monitored.

    20. Monitoring & Review

    • Annual review (earlier if statutory updates/learning).
    • Spot checks of references, SCR entries, induction sign-offs, training currency.
    • Next scheduled review: November 2026 (or earlier on change).

    Appendix A — Pre-Engagement Checklist (Summary)

    □ Application form (no unexplained gaps)
    □ Two verified references (incl. most recent employer)
    □ Identity & Right to Work verified
    □ Enhanced DBS (+ barred list if regulated activity) / Update Service check
    □ Overseas checks (as required)
    □ Qualifications verified (originals)
    □ Prohibition/Section 128 (if applicable)
    □ Health declaration received
    □ Online checks (proportionate) completed
    □ Risk assessment (if disclosures/anomalies)
    □ Conditional offer issued; start only when safe
    □ Induction completed; policies signed; training logged
    □ SCR/personnel record updated

  • 1. Purpose & Scope

    This policy sets out how Summit Education responds to allegations or concerns about adults who work with or on behalf of children, including the proprietor, contractors, agency staff, volunteers, partner staff and third parties. It aligns with Keeping Children Safe in Education (current version), Working Together to Safeguard Children, local LADO procedures and the DfE Voluntary National Standards for Non‑School Alternative Provision.

    2. Principles

    • The welfare of the child is paramount; safeguarding is everyone’s responsibility.

    • We act immediately, fairly and proportionately; we do not investigate before consulting the LADO where the threshold is met.

    • Confidentiality is respected and information shared on a need‑to‑know basis only.

    • We support the child(ren), their family, and the adult subject to the allegation.

    • We work openly with commissioners, the LADO, Police and Children’s Social Care.

    • We record decisions, actions and outcomes contemporaneously.

    3. What is an Allegation? (LADO Threshold)

    An allegation meets the LADO threshold where it is alleged that an adult who works with children has: (a) behaved in a way that has harmed a child, or may have harmed a child; (b) possibly committed a criminal offence against or related to a child; or (c) behaved towards a child or children in a way that indicates they may pose a risk of harm to children; or (d) behaved in a way that indicates they may not be suitable to work with children (including behaviour outside work or online).

    4. Low‑Level Concerns

    A low‑level concern is any concern about an adult’s behaviour towards a child that does not meet the LADO threshold but is inconsistent with the Staff Code of Conduct, professional boundaries or safer working practice. We record and address low‑level concerns promptly to enable early intervention and to identify patterns.

    5. Roles & Responsibilities

    • Proprietor/DSL (Robert Williams): receives and records concerns, makes immediate safeguarding decisions, consults the LADO within 1 working day if threshold is met, and informs commissioners. Acts as case manager unless this presents a conflict.

    • Commissioners/placing schools: retain safeguarding oversight; must be informed promptly of allegations/concerns relating to their pupil placements.

    • If the allegation concerns the proprietor: the matter is reported directly to the LADO and the commissioner; an independent case manager is agreed with the LADO/commissioner.

    6. Immediate Actions on Receipt of an Allegation

    • Ensure the child is safe; provide medical attention or call 999 if required; take immediate safeguarding steps.

    • Do not investigate or interview the child/adult; secure initial account only as necessary to decide next steps.

    • Record verbatim comments, time/date, and any witnesses; sign and date notes.

    • Contact the LADO within one working day (sooner if immediate risk) to consult on management of the allegation.

    • Inform the commissioner/school DSL promptly (unless advised otherwise by LADO/Police).

    7. Strategy, Investigation & Multi‑Agency Interface

    • Follow LADO direction on next steps: no further action; internal management; Children’s Social Care strategy meeting; and/or Police investigation.

    • Attend and contribute to LADO/strategy meetings; share relevant information and risk assessments.

    • Agree interim safeguards (e.g., supervision changes, redeployment, suspension) based on risk—not as an automatic response.

    8. Consideration of Suspension

    Suspension is not automatic. A risk assessment will consider: the nature and seriousness of the allegation, potential risk to children, the need to preserve evidence, and whether suitable alternatives to suspension (e.g., additional supervision, adjusted duties, temporary removal from regulated activity) can manage risk. Decisions are recorded and kept under review.

    9. Communication, Confidentiality & Support

    • Information shared on a strictly need‑to‑know basis, in line with UK GDPR and statutory guidance.

    • The adult is informed of the allegation and process as soon as agreed with the LADO/Police; provided with a named contact and access to support (e.g., occupational health/GP, union/independent advice).

    • The child and family are offered appropriate support and kept updated as appropriate via the commissioner/school DSL.

    • Media enquiries handled by the commissioner/LA as appropriate; no public comment is made by Summit Education.

    10. Record‑Keeping & Data Protection

    • Maintain a confidential allegations file with chronology, decisions, risk assessments, actions and outcomes.

    • Retain records in accordance with statutory guidance and limitation periods (normally until the person reaches normal retirement age or for 10 years—whichever is longer—or as required by commissioners).

    • Provide accurate references reflecting substantiated safeguarding findings; do not enter into agreements to withhold relevant safeguarding information (‘non‑disclosure’ clauses are not used to avoid sharing safeguarding outcomes).

    11. Outcomes Definitions

    • Substantiated: sufficient evidence to prove the allegation.

    • Malicious: sufficient evidence to disprove the allegation and a deliberate act to deceive.

    • False: sufficient evidence to disprove; no deliberate intent.

    • Unsubstantiated: insufficient evidence to prove or disprove.

    • Unfounded: no evidence or proper basis that an incident occurred.

    12. Post‑Case Actions & Learning Lessons

    • Update risk assessments, policies, and staff training in light of lessons learned.

    • Where appropriate, support managed return to work or confirm dismissal/cessation of engagement.

    • Consider staff welfare and reintegration support following unfounded/false allegations.

    13. DBS and Other Regulatory Referrals

    If Summit Education removes an individual from regulated activity (or would have removed them had they not resigned) because they have harmed a child or pose a risk of harm, a referral to the Disclosure and Barring Service (DBS) is legally required. Where relevant, referrals may also be made to professional regulators. The LADO will advise on sequencing alongside any Police/CSC action.

    14. Low‑Level Concerns Procedure (Summary)

    • Report promptly to the DSL using the low‑level concerns form; record facts, dates, witnesses and context.

    • DSL reviews, logs, and decides proportionate action (e.g., advice, training, supervision, HR/contract steps).

    • Patterns/trends monitored; escalate to LADO if threshold is met or emerging risk identified.

    • Records kept confidentially and retained in line with data protection principles.

    15. Training & Awareness

    • DSL trained to Level 3 (refreshed at least every 2 years) and conversant with local LADO procedures.

    • All adults working with Summit Education receive induction on Code of Conduct, safer working practice, low‑level concerns and this policy; annual refreshers provided.

    16. Monitoring & Review

    • Policy reviewed at least annually or after any case/learning, and updated to reflect statutory changes.

    • Next scheduled review: November 2026 (or sooner if guidance changes).

    BCP Council LADO Contact

    Phone: 01202 817600

    Email: LADO@bcpcouncil.gov.uk

    In an emergency or if a child is at immediate risk of harm, call 999.

  • 1. Purpose & Scope

    Summit Education is committed to the highest standards of openness, integrity and accountability. This policy enables any adult working with or for Summit Education (including the proprietor, contractors, volunteers, agency/partner staff) to raise concerns about wrongdoing in the public interest (‘protected disclosures’) without fear of victimisation or detriment. It complements, but does not replace, safeguarding, complaints and grievance procedures.

    2. What is Whistleblowing?

    Whistleblowing is the disclosure of information where a worker reasonably believes it is in the public interest and shows one or more of the following: a criminal offence; breach of a legal obligation; miscarriage of justice; danger to health and safety; damage to the environment; or deliberate concealment of any of these. Safeguarding concerns about children should normally be reported via the Safeguarding Policy routes immediately; where those routes are compromised or create a conflict, this policy applies.

    3. Principles

    • Protect children first: immediate risks → call 999 and inform the DSL/commissioner.

    • Concerns will be taken seriously, investigated promptly and fairly, with confidentiality maintained as far as possible.

    • No victimisation or detriment for raising a concern in good faith; retaliation is misconduct and may lead to action.

    • Anonymous disclosures are accepted; however, they may be harder to investigate.

    • Malicious or knowingly false allegations may result in appropriate action.

    4. Who Can Raise a Concern?

    Any person working with or for Summit Education (including the proprietor, sessional tutors, volunteers, contractors, agency staff, and partner personnel) may raise concerns under this policy.

    5. Examples of Concerns

    • Child safeguarding risks or failure to follow KCSIE/Working Together where normal routes are compromised.

    • Financial irregularity, fraud, bribery or corruption.

    • Serious health and safety risks; unlawful discrimination; gross negligence.

    • Deliberate breaches of data protection/confidentiality; misuse of IT or personal data.

    • Deliberate non-compliance with statutory duties or regulatory requirements.

    • Attempts to conceal wrongdoing.

    6. How to Raise a Concern (Stages)

    Choose the route that is safest and most appropriate. You can bypass any stage if you believe the matter will not be properly addressed or there is a conflict of interest.

    • Stage 1 – Internal: Raise with the DSL/Proprietor (Robert Williams) at robertwilliams@summitprovision.com / 07488 593576. Provide facts, dates, names, and any evidence; mark as ‘Confidential – Whistleblowing’.

    • Stage 2 – Commissioner/Placing School: If Stage 1 is not appropriate/effective, report to the commissioning school/LA contact named in the placement agreement.

    • Stage 3 – LADO (Safeguarding Allegations): If the concern involves an adult working with children and meets the threshold, contact the LADO within one working day: BCP Council LADO — Phone: 01202 817 600 • Email: LADO@bcpcouncil.gov.uk.

    • Stage 4 – External Prescribed Bodies: Where internal routes are inappropriate or not effective, raise with a prescribed body (e.g., the Police for criminal matters; the Information Commissioner’s Office for data protection; the Health and Safety Executive for H&S). For safeguarding, you may also contact Children’s Social Care directly or the Police.

    7. Handling, Investigation & Outcomes

    • Acknowledgement within 5 working days where contact details are provided.

    • Initial triage and risk assessment; immediate protective steps taken where necessary.

    • Independent investigation where appropriate; opportunity to provide further information.

    • Outcome reported to the whistleblower as far as legally possible, with actions and learning captured.

    • Records kept securely and retained per data protection and legal requirements.

    8. Confidentiality & Data Protection

    • Identity kept confidential as far as possible; may need to be disclosed to progress an investigation (e.g., to Police/LADO).

    • Information handled under UK GDPR/Data Protection Act 2018; only shared on a need‑to‑know basis.

    • Secure storage of all whistleblowing records; separate from personnel files.

    9. Protection from Detriment

    Victimisation or retaliation against a whistleblower (or anyone cooperating with an investigation) is strictly prohibited and will be treated as misconduct. Workers making protected disclosures under the Public Interest Disclosure Act 1998 are legally protected from detrimental treatment and dismissal.

    10. False or Malicious Allegations

    If an allegation is found to be knowingly false or malicious, this may be addressed through supervision, contractual action or other appropriate measures. This does not include disclosures made in good faith that are later unsubstantiated.

    11. External Advice & Support

    12. Monitoring & Review

    • This policy is reviewed at least annually or following any case/learning or legal change.

    • Next scheduled review: 12 months from approval

  • 1. Policy Statement & Purpose

    Summit Education is committed to providing a safe and healthy environment for all children, visitors and adults. We deliver 1:1 or 1:2 tutoring and re‑engagement sessions—often in community and outdoor settings—so we plan proactively, assess risks dynamically and put robust controls in place. We comply with UK health and safety law and relevant education guidance.

    2. Scope

    • Applies to the proprietor and to any future staff, contractors, volunteers and partner personnel working for or on behalf of Summit Education.

    • Applies to all locations: homes, libraries, community venues, parks, trails, sports facilities and travel between them.

    • Covers learners aged 5–18 and any accompanying adults where relevant.

    3. Legal & Guidance Framework

    • Health and Safety at Work etc. Act 1974 and associated regulations.

    • Management of Health and Safety at Work Regulations 1999 (risk assessment duties).

    • Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

    • First Aid at Work Regulations; Manual Handling Operations Regulations; Control of Substances Hazardous to Health (COSHH) where applicable.

    • Fire safety legislation; local authority/commissioner policies; DfE guidance relevant to alternative provision.

    4. Roles & Responsibilities

    Proprietor/Responsible Person: Robert Williams. Accountable for health and safety, risk assessment approval, provision of training/equipment, incident management and policy review. Commissioners/venues retain responsibilities for their premises; Summit coordinates controls and supervision for our activities.

    • All adults working with Summit must follow this policy, risk assessments and safe systems of work; report hazards, near‑misses and incidents immediately; and take reasonable care of themselves and others.

    5. General Arrangements

    • Plan–Do–Check–Act approach for all activities.

    • Dynamic risk assessment on the day for weather, site condition, crowd density and learner presentation (EBSA, SEND, medical).

    • Supervision ratios normally 1:1 or 1:2 as commissioned; consider increased supervision for higher‑risk activities.

    6. Risk Assessment

    • Written activity/venue risk assessments covering: environment/route; traffic and access; water; heights/edges; tools/equipment; dogs/animals; members of the public; weather/heat/cold; medical needs; behaviour; lone working; emergency access.

    • Child‑specific adjustments (SEND/SEMH/medical/behaviour plans).

    • Review: before first use; after incidents/near‑misses; and at least annually.

    7. Safeguarding Interface

    • Safety planning aligns with the Safeguarding & Child Protection Policy (e.g., visibility during sessions, boundaries, photography, transport).

    • Report safeguarding concerns immediately via the DSL route; call 999 if there is an immediate risk of harm.

    8. First Aid & Medical Needs

    • Carry an appropriate first aid kit for the environment; check contents regularly.

    • Ensure at least one adult present is first aid trained appropriate to activity/setting; know local AED locations where possible.

    • Obtain medical information and consent from commissioner/parents; follow individual healthcare plans.

    • Administration of medicines only with written consent and according to plan; record any administration.

    9. Accidents, Incidents & RIDDOR

    • Record all accidents, incidents and near‑misses promptly using the incident form; notify the commissioner/parent on the same day where appropriate.

    • RIDDOR: report specified injuries, hospital treatment, dangerous occurrences and incidents arising from work activity in line with legal requirements.

    • Review risk assessments and controls following any incident; implement learning.

    10. Lone Working & Personal Safety

    • Follow the Lone Working Policy: itinerary shared; check‑in/out; escalation if overdue; avoid isolated areas where possible; maintain phone charged.

    • Pre‑visit intelligence via commissioner/venue; avoid entering a property or area if you feel unsafe; withdraw and report.

    11. Off‑Site/Outdoor Activities

    • Route planning with safe entry/exit points and contingency routes; consider daylight hours and phone signal coverage.

    • Weather checks (heat/cold/thunder/wind); apply controls (hydration, shade, clothing, sunscreen, cold‑weather layers); postpone if conditions unsafe.

    • Water margins: maintain safe distances; no water entry unless specifically risk‑assessed, competent and consented.

    12. Transport & Travel

    • Prefer public transport or walking where safe and appropriate.

    • Private vehicle use only if authorised, business‑insured, roadworthy, with parental/carer consent and commissioner approval; no transporting without prior written agreement.

    • Seatbelts worn at all times; safe pick‑up/drop‑off points; never leave a child alone at the end of a session—follow no‑show/collection procedures.

    13. Fire Safety

    • At indoor/community venues: follow the host venue’s fire procedures; identify exits/assembly points on arrival.

    • Outdoors: identify safe assembly location; brief learners on what to do if evacuation is required (e.g., wildfire risk).

    • No open flames unless specifically risk‑assessed and permitted.

    14. Equipment, Clothing & PPE

    • Use equipment suitable for the activity and learner; check condition before use; follow manufacturer guidance.

    • Carry or require appropriate clothing/footwear for terrain and weather; provide hi‑vis where needed for roadside routes.

    • No high‑risk tools/equipment without specific competence, risk assessment and consent.

    15. Manual Handling & Loads

    • Avoid unnecessary lifting/carrying; use trolleys/backpacks; keep loads light and close to the body; bend knees and avoid twisting.

    • Do not ask learners to carry heavy loads.

    16. Infection Prevention & Control

    • Carry basic hygiene supplies; use hand hygiene before eating and after first aid or contact with bodily fluids.

    • Follow current public health advice for communicable diseases; clean/dispose of first aid waste safely.

    17. Hazardous Substances (COSHH)

    • Minimise use of hazardous substances; store securely; carry only small quantities as needed (e.g., alcohol hand gel).

    • Keep safety data (or product labels) available; avoid learner exposure and follow first aid guidance in case of contact.

    18. Severe Weather & Environmental Risks

    • Heat: avoid peak sun; schedule shade breaks; hydration plan.

    • Cold: additional layers; limit exposure; monitor for hypothermia signs.

    • Lightning/high winds: stop activity; avoid trees/exposed ridges; seek shelter.

    • Air quality/pollen alerts: adapt route or postpone for vulnerable learners.

    19. Emergencies & Business Continuity

    • Emergency actions: preserve life (DRABC), call 999, manage scene, contact commissioner/parents; record facts.

    • Carry key contacts, ICE details and grid reference/postcode for locations.

    • If a critical incident disrupts operations (e.g., severe weather, illness), activate the Contingency/Disaster Recovery arrangements to maintain essential communication and safe service delivery.

    20. Information Security & Data Protection

    • Keep personal data to the minimum needed on site; use initials where possible; store devices securely and enable encryption/passcodes.

    • Dispose of paperwork securely; follow Data Protection Policy and commissioner requirements.

    21. Training, Communication & Supervision

    • Maintain training matrix: first aid, safeguarding, lone working, risk assessment, manual handling, activity‑specific competence.

    • Brief learners on rules and safety at the start of each session; reinforce during activities.

    • Regular supervision and debriefs to review controls and learner needs.

    22. Monitoring, Audit & Review

    • Spot checks of risk assessments, equipment and incident logs.

    • Annual policy review or earlier following incidents, changes in law or operations.

    • Next scheduled review: 12 months from approval

  • 1. Purpose & Scope

    This policy explains how pupils, parents/carers, commissioners, partners and members of the public can raise concerns or complaints about Summit Education, and how we will respond in a timely, fair and transparent manner.

    2. Principles

    • We welcome feedback to improve our service; most concerns can be resolved quickly and informally.

    • Complaints are handled impartially, proportionately and without discrimination.

    • Complaints involving safeguarding or allegations against adults are managed under the Safeguarding and Managing Allegations policies and may be referred to the LADO/Police.

    • Confidentiality is respected; information is shared on a need‑to‑know basis in line with UK GDPR.

    • We keep clear records of complaints, actions and outcomes.

    3. Who can complain?

    Any person affected by our provision (including pupils through their parent/carer where appropriate), commissioners/placing schools, community partners or members of the public.

    4. Accessibility & Reasonable Adjustments

    • Complaints can be made verbally, by phone, in writing or by email. We will support access needs (e.g., translation, large print, meeting notes).

    • We can accept a representative (e.g., parent/carer or advocate) to act on a complainant’s behalf with consent.

    5. What is not covered by this policy?

    • Safeguarding/child protection concerns (use Safeguarding Policy routes; if immediate risk call 999).

    • Allegations against adults working with children (see Managing Allegations Policy; LADO involvement as required).

    • Requests for information (handled under Data Protection Policy/UK GDPR).

    6. Stages of the Procedure & Timescales

    We aim to resolve concerns at the earliest possible stage. Timescales exclude school holidays unless urgency applies.

    Stage 1 – Informal Resolution (aim: within 10 working days)

    • Raise the concern with Robert Williams (Proprietor) by phone 07488 593576 or email robertwilliams@summitprovision.com.

    • We will listen, clarify the issues, and seek a swift solution; a brief note of the outcome will be kept.

    Stage 2 – Formal Complaint (acknowledge within 3 working days; response within 15 working days)

    • Submit a written complaint marked ‘Formal Complaint’ with facts, dates, people involved and desired outcome.

    • We will investigate proportionately (may include speaking to those involved and reviewing records) and provide a written response with findings and actions.

    Stage 3 – Review/Appeal (request within 10 working days of Stage 2 response; outcome within 20 working days)

    • If dissatisfied with Stage 2, request a review stating reasons. Where appropriate, we may invite a commissioning school/LA representative to review the handling and outcome.

    • The review considers whether the process was fair and the decision reasonable, and may uphold, vary, or overturn the Stage 2 decision and specify further actions.

    7. Escalation Beyond Summit Education

    • Commissioning school/local authority: where the pupil is on roll at a school or the LA is the commissioner, you may share the complaint and outcome for further consideration.

    • Regulatory/oversight bodies: data protection matters → ICO; health and safety → HSE; criminal matters → Police.

    • For safeguarding allegations meeting the threshold, contact the BCP Council LADO — 01202 817 600 • LADO@bcpcouncil.gov.uk.

    8. Unreasonable or Vexatious Behaviour

    • We differentiate persistent pursuit of a just cause from unreasonable conduct (e.g., aggressive language, repeated new issues before previous are resolved, excessive communications).

    • We may set communication boundaries (e.g., single point of contact, scheduled updates) and, in extreme cases, decline further correspondence except to confirm the position.

    9. Mediation & Early Resolution

    • With consent, we may propose mediation or a problem‑solving meeting with the commissioner/parent to reach an agreed plan.

    10. Recording, Confidentiality & Data Retention

    • A complaint log is maintained with chronology, investigations, findings and outcomes; retained in line with our retention schedule.

    • Personal data is handled lawfully and securely; information is shared on a need‑to‑know basis only.

    11. Equality, Diversity & Inclusion

    • Complaints are accepted and investigated without discrimination; we provide reasonable adjustments and accessible formats on request.

    12. Learning & Continuous Improvement

    • We review patterns of complaints, identify learning and update policies, risk assessments and training as needed.

    13. Monitoring & Review

    • This policy is reviewed at least annually or sooner following significant changes in law or our service.

    • Next scheduled review: 12 months from approval

  • 1. Purpose & Scope

    This policy sets out Summit Education’s approach to identifying, assessing and controlling risks so that children and adults are kept safe and learning can continue in a proportionate, enabling way. It applies to all activities, including tutoring and re‑engagement sessions (typically 120–180 minutes; 1:1 or 1:2) delivered in homes, community venues and outdoor environments.

    2. Legal & Guidance Framework

    • Health and Safety at Work etc. Act 1974; Management of Health & Safety at Work Regulations 1999.

    • Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

    • First Aid at Work Regulations; Manual Handling Operations Regulations; Fire Safety Order.

    • DfE guidance for Alternative Provision and Non‑School AP Voluntary Standards (risk assessment expectations).

    • Keeping Children Safe in Education (KCSIE) and Working Together to Safeguard Children (interface with safeguarding risk).

    3. Roles & Responsibilities

    Proprietor/Responsible Person: Robert Williams. Accountable for risk management, approving templates and significant assessments, providing training/resources, reviewing incidents and updating controls. All adults working with Summit must follow this policy, complete dynamic/written assessments, implement controls, and report hazards, near misses and incidents immediately.

    4. Risk Management Approach

    • Plan–Do–Check–Act cycle underpinning all work.

    • Suitable and sufficient written risk assessments for recurrent activities/venues; dynamic assessments at point of delivery.

    • Proportionate controls that enable participation while keeping risk as low as reasonably practicable (ALARP).

    • Child‑centred adjustments (SEND/SEMH/medical) integrated into each assessment and plan.

    5. When a Written Risk Assessment is Required

    • Any new venue or route (parks, trails, sports facilities, community rooms).

    • Activities with identifiable hazards (roadside walking, water margins, ball games, public interactions, lone working).

    • Individual learners with specific risks (EBSA, behaviour plans, medical needs, mobility or sensory needs).

    • Transport in private vehicle (only if authorised and consented), hot/cold weather plans, and remote alternatives.

    6. Risk Assessment Template & Matrix

    Summit Education uses a standard template with: activity/venue; date/time; participants; hazards; existing controls; initial risk rating; additional controls; residual risk rating; responsible person; review date. The 5x5 matrix (Likelihood x Severity) guides prioritisation and selection of controls. Residual ratings should be Low/Medium before proceeding unless commissioner agrees exceptional controls.

    7. Typical Hazards & Control Measures

    • Environment & terrain: route recce; avoid steep/unstable areas; choose accessible paths; hi‑vis where needed; pace breaks/seating points.

    • Traffic & crossings: planned safe crossings; group positioning; avoid narrow verges; reflective wear in low light.

    • Water margins: safe distances; defined no‑go zones; constant supervision; no entry to water unless specifically authorised and competent.

    • Weather (heat/cold/wind/lightning): hydration/shade; sunscreen; layers; wind and storm thresholds; postpone if unsafe.

    • Public & lone working: visible locations; check‑in/out; share itinerary; avoid isolated areas; escalate concerns promptly.

    • Sports/activities: warm‑up; space management; equipment checks; rules briefed; non‑contact adaptations for behaviour needs.

    • Medical needs: IHPs/consent; medications available; known triggers/adjustments; emergency access planned.

    • Infection control: hand hygiene; first‑aid waste; follow public health guidance.

    • Data/IT (online elements): device security; screen privacy; minimal personal data on site; offline fall‑backs.

    8. Individual Learner Risk Planning

    • Review referral information with commissioners/parents to identify risks and reasonable adjustments.

    • Agree goals, boundaries and behaviour cues; use visual schedules or social stories where helpful.

    • Record triggers and de‑escalation strategies; plan safe exits and collection arrangements.

    9. Approval, Communication & Briefing

    • Significant assessments approved by the Proprietor; routine updates approved via procedure and logged.

    • Share key controls with commissioners/parents as appropriate; record consent where required (e.g., transport, images).

    • Brief learners at session start (rules, routes, stop points, emergency actions).

    10. Monitoring, Supervision & Dynamic Review

    • Continuously scan for change (weather, crowding, learner presentation); pause/stop if controls are no longer effective.

    • Maintain supervision ratios (normally 1:1 or 1:2); increase supervision where risk increases.

    • Document significant dynamic changes and any alterations to the plan.

    11. Incidents, Near Misses & RIDDOR

    • Record all incidents/near misses the same day where possible; notify commissioners/parents as appropriate.

    • Use the incident form and update risk assessments/controls after review.

    • Report under RIDDOR where legally required; keep records securely.

    12. Records, Retention & Data Protection

    • Store assessments, briefings and incident logs securely for the retention period; share on a need‑to‑know basis.

    • Use initials on working copies in the field; upload final versions to secure storage.

    13. Training & Competence

    • Induction covers risk assessment, lone working, first aid awareness, safeguarding and incident reporting.

    • Maintain CPD for activity‑specific competence (e.g., sports supervision); first aid training appropriate to setting.

    • Periodic table‑top exercises to rehearse emergency scenarios.

    14. Review Schedule

    • Review written assessments: after first use; after incidents/near misses; at least annually.

    • Policy review: at least annually or after significant change in law/operations. Next scheduled review: 12 months from approval

  • 1. Purpose & Scope

    This policy sets out how Summit Education manages risks where work is undertaken by a single adult without close or direct supervision. It applies to the proprietor and any future staff/contractors/volunteers when delivering 1:1 or 1:2 tutoring and re‑engagement sessions in homes, community venues and outdoor environments.

    2. Legal & Guidance Framework

    • Health and Safety at Work etc. Act 1974; Management of Health & Safety at Work Regulations 1999 (risk assessment).

    • DfE Alternative Provision guidance and Non‑School AP Voluntary Standards (supervision, safeguarding, lone working).

    • Keeping Children Safe in Education; Working Together to Safeguard Children.

    3. Principles

    • Avoid lone working where risk cannot be controlled; otherwise plan, assess and implement proportionate controls.

    • Safeguarding first: maintain appropriate professional boundaries and visibility; report concerns immediately via DSL routes.

    • Stop activity and withdraw if you feel unsafe; inform the commissioner as soon as practicable.

    4. Lone Working Risk Assessment

    • Complete a written risk assessment for lone working contexts (home visits, outdoor/community routes, transport).

    • Dynamic review on the day for learner presentation, behaviour cues, location factors, weather and public activity.

    • Record specific controls for communication, supervision, meeting points, emergency access and endings.

    5. Planning & Pre‑Session Checks

    • Agree the session plan, location, timings and collection/return arrangements with the commissioner/parent in advance.

    • Share itinerary (locations/postcodes or map links), expected timings and contact numbers with a designated check‑in contact.

    • Carry a charged mobile phone/power bank; enable emergency SOS; pre‑load key numbers (999, commissioner, parent/carer).

    • Consider daylight hours, phone signal, toilets, shelter, seating and safe exit routes.

    6. Check‑In / Check‑Out Procedure

    • Pre‑session: send planned start/end time and meeting point to your designated contact.

    • Start: brief text/call to confirm session has begun.

    • Mid‑session: optional welfare ping for higher‑risk sessions (e.g., remote areas, late finishes).

    • End: text/call to confirm safe session end and onward travel; if no check‑out received within 20 minutes, the contact escalates per Section 13.

    7. Meeting Arrangements & Visibility

    • Favour public, staffed or well‑used places for meeting/handovers (e.g., school reception, library entrance).

    • Avoid entering private homes unless specifically approved by the commissioner and risk assessed; keep sessions in communal areas and maintain open doors/line of sight where possible.

    • Outdoors, choose visible routes with by‑passers; avoid isolated wooded areas or narrow towpaths where escape routes are limited.

    8. Boundaries & Professional Conduct

    • Maintain professional boundaries at all times; do not exchange personal social media; use work contact details only.

    • Physical contact is avoided except for first aid or to prevent immediate harm, and should be proportionate and recorded.

    • Do not accept gifts of significant value; record any gifts offered/received as per policy.

    9. Behaviour & De‑escalation

    • Agree ground rules collaboratively at the outset; use relational, trauma‑informed approaches; avoid triggers where known.

    • If behaviour escalates, move to a public space, reduce demands, offer choices and pause the session if needed.

    • Terminate the session if safety is compromised; arrange collection/return and report to the commissioner.

    10. Personal Safety & Security

    • Wear appropriate clothing/footwear; carry minimal valuables; keep phone and keys accessible.

    • Position yourself with a clear exit route; avoid being cornered in rooms or enclosed spaces.

    • If threatened, leave immediately to a safe place and contact 999; then inform the commissioner/parent.

    11. Travel & Transport

    • Prefer walking or public transport where safe; avoid isolated car parks and poorly lit routes.

    • Private vehicle use (if ever required) must be pre‑approved and business‑insured; no transporting children without prior written consent from the commissioner/parent.

    • Plan safe pick‑up/drop‑off points; never leave a child unattended at the end of a session—follow no‑show/collection procedures.

    12. Equipment & Information Carried

    • Carry only necessary information (use initials on paper); store devices with passcodes and encryption; avoid displaying personal data in public.

    • Take a small first aid kit, hi‑vis where appropriate and emergency contacts card; bring weather‑appropriate kit (water, layers, sunscreen).

    13. Escalation Flow (If Overdue or No Contact)

    • Designated contact calls/texts the worker; if no response within 10 minutes, attempt again and call the parent/carer and commissioner.

    • If still no contact within 20 minutes, escalate to 999 with last known location/itinerary and vehicle details if relevant.

    • Record escalation actions and outcomes; review and amend lone working controls for future sessions.

    14. Managing Sensitive Locations & Times

    • Avoid late finishes where possible; schedule sessions in daylight for outdoor routes.

    • Avoid locations with known community tensions, anti‑social behaviour or limited exits; consult local intelligence and commissioners.

    • Consider buddying with school staff for first sessions with high‑risk learners.

    15. Digital Safety & Remote Elements

    • Use approved platforms/accounts; never conduct unsupervised video calls without prior parental/commissioner consent and clear boundaries.

    • No recording of sessions unless explicitly agreed and compliant with data protection and safeguarding policies.

    16. Incidents, Near Misses & Reporting

    • Report any incident, near‑miss, threatening behaviour or safeguarding concern the same day where possible.

    • Record facts objectively; update risk assessments and controls and inform the commissioner of actions taken.

    17. Wellbeing & Supervision

    • Lone work can be demanding; build in debriefs, reflective supervision and access to support (e.g., EAP if available/commissioner provision).

    • Adjust caseloads/routes to reduce fatigue; take regular hydration and rest breaks.

    18. Monitoring & Review

    • Spot checks of adherence to check‑in/out and escalation procedures.

    • Annual review or sooner following incidents/changes; next scheduled review: 12 months from approval

  • 1. Purpose & Scope

    This policy sets out how Summit Education fulfils its Prevent duty to safeguard children from the risk of radicalisation, extremism and terrorism. It applies to all activities (typically 1:1 or 1:2 sessions, 120–180 minutes) delivered in homes, community venues and outdoor environments, and to all adults working for or on behalf of Summit Education.

    2. Legal & Guidance Framework

    • Counter-Terrorism and Security Act 2015 (Section 26) — duty to have due regard to the need to prevent people from being drawn into terrorism.

    • Prevent Duty Guidance (for specified authorities) and Channel Duty Guidance.

    • Keeping Children Safe in Education (KCSIE) and Working Together to Safeguard Children.

    • DfE Alternative Provision guidance and Non‑School AP Voluntary Standards (safeguarding expectations).

    3. Definitions

    • Radicalisation: the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.

    • Extremism: vocal or active opposition to fundamental British values; also includes calls for the death of members of the UK armed forces.

    • Terrorism: action or threat designed to influence the government or intimidate the public for a political, religious, racial or ideological cause.

    4. Roles & Responsibilities

    • Prevent Lead/DSL: Robert Williams — oversees risk assessment, training, case management and referrals; liaises with Channel/Police/LA; maintains records.

    • All adults working with Summit: remain alert to indicators of radicalisation; record and report concerns immediately to the DSL; complete required training; model and promote the values of democracy, rule of law, individual liberty, and mutual respect/tolerance.

    5. Risk Assessment & Proportionate Response

    • Include Prevent factors in organisational and individual risk assessments (online/offline influences, isolation, grievances, association, vulnerability indicators).

    • Consider local context (venues/routes, community tensions, events) and plan controls (visibility, meeting points, session content, de‑escalation).

    • Dynamic assessment during sessions; pause/stop and seek advice where risk escalates.

    6. Staff Training & Awareness

    • Mandatory Prevent awareness training on induction and refreshed at least every 2 years (e.g., Home Office Prevent e‑learning/WRAP equivalent).

    • DSL/Prevent Lead to complete advanced training appropriate to role and keep abreast of updates.

    • Training records maintained; learning from incidents is fed back into practice.

    7. Curriculum, Teaching & Learner Voice (Tutoring Context)

    • Embed and model British values through everyday routines: respectful dialogue, critical thinking, evidence‑based discussion and safe challenge.

    • Use age‑appropriate resources; avoid platforming extremist content; signpost to credible sources.

    • Support EBSA/SEMH needs with relational practice to reduce vulnerability (belonging, self‑efficacy, pro‑social networks).

    8. ICT, Devices & Online Safety

    • Use work devices/accounts for any online elements; enable filtering/monitoring where feasible; avoid exposure to harmful content.

    • Do not show or share extremist material; if encountered inadvertently, exit, record context and report to the DSL.

    • Promote safe search habits and media literacy; agree ground rules for any device use in sessions.

    9. Visitors, Partners & Venues

    • Any partner or visiting contributor is vetted proportionately; purpose and content are agreed in advance; sessions are supervised and values‑aligned.

    • Community and outdoor venues are selected with safety/visibility in mind; avoid locations with known risk where feasible.

    10. Referral Pathway & Escalation

    • Record factual concerns (what was seen/heard, context, language used, online/offline factors) and report to the DSL immediately.

    • DSL assesses with reference to thresholds; where appropriate, consults with the commissioning school/LA and considers a Channel referral.

    • Immediate risk of harm or a crime in progress: call 999.

    • Confidential Anti‑Terrorism Hotline (for non‑urgent concerns): 0800 789 321.

    • Where allegations involve an adult working with children, contact the BCP Council LADO within 1 working day: 01202 817 600 • LADO@bcpcouncil.gov.uk.

    11. Information Sharing & Record Keeping

    • Share information on a ‘necessary and proportionate’ basis in line with KCSIE and UK GDPR to safeguard children.

    • Keep a clear chronology of concerns, discussions, decisions and rationales; store securely with restricted access.

    • Retain referral and outcome records in accordance with the retention schedule.

    12. Managing Expressions, Debate & Free Speech

    • Facilitate respectful discussion; challenge extremist narratives with facts and critical inquiry; signpost to trusted sources.

    • End or relocate a session if conversation becomes unsafe or risks normalising extremist content; record and escalate.

    13. Whistleblowing & Allegations

    • Staff can raise Prevent‑related concerns via Whistleblowing Policy without fear of detriment.

    • Allegations about adults are managed under Managing Allegations Policy and may involve the LADO and/or Police.

    14. Monitoring, Review & Governance

    • Prevent risk assessment and this policy are reviewed at least annually or sooner after incidents/learning or changes in national/local risk.

    • Next scheduled review: 12 months from approval

  • 1. Purpose & Scope

    This policy sets out how Summit Education will prepare for, respond to, and recover from disruption to ensure the safety of children and continuity of essential education services. It applies to all activities including 1:1 or 1:2 sessions delivered in homes, community venues and outdoor environments.

    2. Objectives

    • Protect life, wellbeing and safeguarding of children and adults.

    • Maintain critical operations and communication with commissioners and families.

    • Restore normal service as quickly and safely as possible.

    • Capture learning and strengthen resilience for the future.

    3. Risk Assessment & Typical Scenarios

    • Loss of staff capacity (illness/injury), including sole-worker unavailability.

    • Loss of access to usual venues/routes (closure, incident, environmental hazard).

    • Severe weather or environmental alerts (heat/cold, storms, flooding, air quality).

    • Transport disruption or breakdown; road closures.

    • IT/device loss or failure; cyber incident; data breach.

    • Safeguarding critical incident; allegation involving an adult.

    • Public health incident (communicable disease).

    • Supply chain issues (equipment/first aid supplies).

    4. Business Impact & Priorities

    • Priority 1: Safeguarding & safety; emergency response; statutory/contractual notifications.

    • Priority 2: Communication to commissioners/parents; attendance reporting; daily session decisions.

    • Priority 3: Data protection and record integrity (session notes, safeguarding files).

    • Priority 4: Re‑scheduling and recovery of missed learning; stakeholder updates.

    5. Roles & Responsibilities

    • Proprietor/Incident Lead: Robert Williams – incident assessment, activation of this plan, liaison with emergency services/commissioners/LADO/insurer, decisions on suspension or adaptation of service.

    • Nominated Back‑up (commissioner‑agreed) – if proprietor unavailable, a named school/LA contact is requested to act as liaison pending proprietor’s return.

    • All partners/venues – implement their own emergency procedures and share timely information.

    6. Activation Triggers & Levels

    • Trigger: Any event that threatens safety, legal compliance, or the ability to deliver sessions as planned.

    • Level 1 (Minor): Short disruption (<1 day), managed by rescheduling/alternative route or venue.

    • Level 2 (Significant): Multi‑day disruption or multiple learners affected; partial service suspension; remote alternatives used.

    • Level 3 (Critical): Serious incident (e.g., safeguarding allegation, major injury, cyberattack) – service suspension as needed; multi‑agency coordination.

    7. Communication Tree

    • Emergency services: 999 (life‑threatening incidents).

    • Commissioners/placing schools: notify named contact within 2 working hours of significant disruption; sooner for safeguarding/critical incidents.

    • Parents/carers: update promptly on session status, safe collection/return, and any changes.

    • LADO (allegations): BCP Council LADO — Phone: 01202 817 600 • Email: LADO@bcpcouncil.gov.uk (within 1 working day where threshold met).

    • Insurer: notify per policy terms following incidents that may give rise to a claim (policy details held securely).

    8. Continuity Strategies by Scenario

    a) Loss of staff capacity (sole worker)

    • Inform commissioners immediately; cancel or reschedule sessions; offer remote tutoring/check‑ins where appropriate.

    • Provide brief continuity notes/resources so learners can continue independent work.

    • For extended absence, agree interim provision with commissioners.

    b) Loss of venue/route access

    • Switch to pre‑scouted alternative venues/routes; update risk assessments dynamically.

    • Use indoor community spaces (libraries, council venues) where available and approved.

    • If no safe alternative, postpone and reschedule.

    c) Severe weather/environmental alerts

    • Apply heat/cold/lightning/wind controls; modify duration/route; move to indoor venue or switch to remote.

    • Stop activity if risks cannot be controlled; communicate promptly.

    d) Transport disruption

    • Allow extra travel time; change meeting points; revert to walking/public transport where safe.

    • If stranded, move to a safe public place and contact commissioners/parents for arrangements.

    e) IT failure/cyber incident/data breach

    • Isolate affected device/accounts; change passwords; enable MFA; inform commissioners if data may be affected.

    • Follow Data Breach Procedure: assess risk, contain, record, and where required, notify ICO/partners in line with UK GDPR.

    • Use paper templates as fall‑back; upload to secure system once restored.

    f) Safeguarding critical incident/allegation

    • Prioritise safety; call 999 as needed; follow Safeguarding and Managing Allegations policies.

    • Contact LADO within 1 working day where threshold is met; coordinate with commissioners; suspend relevant activities if required.

    g) Public health incident

    • Follow current public health guidance; implement hygiene measures; postpone or move to remote delivery as required.

    • Inform commissioners/parents of any exposure risks per guidance.

    9. Data, Records & IT Disaster Recovery

    • Maintain secure, minimally necessary records; daily backup of digital files to encrypted storage; versioned copies retained.

    • Enable device encryption, strong passwords and multi‑factor authentication; report lost/stolen devices immediately.

    • Paper fall‑back: blank session/incident forms carried; scan and securely store when systems restored.

    10. Safeguarding Continuity

    • Safeguarding contacts and escalation routes available offline (printed card) during all sessions.

    • Maintain safeguarding chronology; if systems down, use paper/logbook and transcribe securely post‑incident.

    • Do not delay referrals because of IT failure—use phone and document later.

    11. Health & Safety in Emergencies

    • Apply dynamic risk assessment; cease activity if control measures fail.

    • Carry first aid kit and charged phone; know local emergency access points and postcodes/grid references.

    • Record incidents and near‑misses the same day where possible; review controls afterwards.

    12. Insurance & Finance

    • Maintain appropriate business insurance (public liability, professional indemnity, and any required extensions).

    • Notify insurer following incidents in line with policy conditions; retain receipts and evidence for claims.

    • Keep essential financial operations (invoicing, payroll, supplier payments) functioning using offline templates if necessary.

    13. Training, Exercising & Equipment Readiness

    • Annual tabletop exercise of at least one scenario (e.g., cyber incident or severe weather).

    • Maintain ‘go‑kit’: first aid, hi‑vis, backup power bank, paper forms, key contacts, basic PPE, emergency snacks/water.

    • Record exercises and improvements in the action log.

    14. Post‑Incident Review & Lessons Learned

    • Within 10 working days of a Level 2/3 incident, complete a debrief with commissioners as appropriate.

    • Update risk assessments, policies and this plan; share learning with partners where beneficial.

    15. Monitoring & Review

    • Policy reviewed at least annually or following significant incidents/changes in operations or law.

    • Next scheduled review: 12 months from approval