Safeguarding Policy

1. Statement of Commitment

Foundry Education Group Ltd ("Foundry") is committed to safeguarding and promoting the welfare of every child and young person who engages with our services. We believe that every child has the right to learn free from harm, abuse and neglect, and that safeguarding is the responsibility of everyone who works with, or on behalf of, Foundry.

This policy applies to all directors, tutors, speakers, facilitators, employees, contractors, volunteers and anyone else acting on behalf of Foundry ("Foundry personnel"). It covers both of our services:

Foundry Tuition: one-to-one tuition for Primary, 11+, GCSE, A-Level and university entrance, delivered online nationwide and in person across Oxfordshire, including support for students with special educational needs and disabilities (SEND).

Foundry Pathways: school-based career talks, university entrance guidance and vocational sessions delivered to secondary students in partner schools.

For the purposes of this policy, a "child" is anyone under the age of 18. Foundry also recognises that some students aged 18 and over may be vulnerable, and applies the principles of this policy to them where appropriate.

2. Legal and Statutory Framework

This policy has been written with regard to the following legislation and guidance, as amended from time to time:

• Children Act 1989 and Children Act 2004
• Working Together to Safeguard Children (HM Government), current edition
• Keeping Children Safe in Education (Department for Education), current edition, as it applies to the schools we work with
• Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012
• Sexual Offences Act 2003, including the position of trust provisions
• Counter-Terrorism and Security Act 2015 and the Prevent Duty
• Data Protection Act 2018 and UK GDPR
• Equality Act 2010
• Statutory guidance and procedures published by the local safeguarding partnership for the area in which a child lives

3. Principles

• The child's welfare is paramount. It outweighs commercial, reputational and relationship considerations.
• Safeguarding is everyone's responsibility. All Foundry personnel must know how to recognise and report a concern.
• Report, do not investigate. Foundry personnel refer concerns; they do not investigate or seek to prove abuse.
• Children are listened to. Their wishes and feelings are taken seriously, and no child is promised confidentiality where their safety is at risk.
• Inclusion. Children with SEND, and those who are otherwise vulnerable, may be at greater risk and may find it harder to disclose. We take particular care with these students.
• A culture of openness. Concerns about adult conduct, including low-level concerns, are raised early and handled fairly.

4. Roles and Responsibilities

4.1 Directors

The directors hold ultimate accountability for safeguarding within Foundry. They ensure this policy is implemented, that a DSL is appointed and trained, that recruitment checks are completed, that adequate resources are available, and that the policy is reviewed at least annually.

4.2 Designated Safeguarding Lead

The DSL is the first point of contact for all safeguarding concerns across both services. The DSL will:

• receive, record and assess all concerns, and decide on referral to statutory agencies
• act as the liaison with children's social care, the Local Authority Designated Officer (LADO), the police and partner schools
• keep confidential, secure and accurate safeguarding records
• complete safeguarding training appropriate to the role, refreshed at least every two years, with regular informal updates in between
• report to the directors at least termly on safeguarding activity and trends

If the DSL cannot be reached and a child is at immediate risk, personnel must contact the police or children's social care directly (see Section 6.2).

4.3 All Foundry personnel

• read and confirm in writing that they have understood this policy and the Code of Conduct (Section 10) before commencing work
• report any concern immediately, following Section 6
• never promise a child absolute confidentiality
• cooperate fully with any safeguarding enquiry

5. Recognising Abuse and Concerns

Foundry personnel must be alert to the signs of abuse, neglect and exploitation. Signs are not proof, but they are a reason to act.

Children with SEND may show signs of distress differently, and behaviour changes should never be assumed to be "part of their condition" without consideration. They may also be more vulnerable to bullying, exploitation and communication barriers. Tutors and speakers should adapt how they listen and record, and seek advice from the DSL where unsure.

6. Responding to a Concern or Disclosure

6.1 If a child tells you something

• Stay calm and listen. Allow the child to speak at their own pace.
• Reassure them that they were right to tell you and that it is not their fault.
• Do not ask leading questions, press for detail, or ask the child to repeat themselves. Use open prompts such as "Can you tell me more?"
• Do not promise to keep it secret. Explain that you must tell someone whose job it is to keep children safe.
• Do not confront or contact the alleged abuser, and do not discuss the matter with the family unless the DSL has advised it is safe to do so.
• Record the concern on the same day, using the child's own words where possible.
• Report to the DSL immediately, and in any event before the end of the working day.

6.2 Escalation pathway

Concern → DSL → Children’s Social Care (MASH) → Police (999) if a child is in immediate danger

Concerns are reported to the DSL as soon as possible. Nothing in this pathway should delay action where a child is at immediate risk: in that case, call 999 first and then inform the DSL.

Foundry Tuition: report any concern about a tutored child to the Foundry DSL immediately. Do not delay to inform the parent or carer first.

Foundry Pathways: report any concern arising in a school immediately to the school's DSL, in line with the school's own procedure, then inform the Foundry DSL the same day. The school's safeguarding policy takes precedence while on school premises.

Concern about a member of Foundry personnel: report to the DSL, or to a director if the concern involves the DSL. See Section 11.

Direct referral by any member of Foundry personnel

Safeguarding responsibility does not rest with the DSL alone. Any member of Foundry personnel may make a referral directly to the children's social care team of the relevant local authority (contacts are in Appendix A) if they believe a child is suffering, or is at risk of suffering, harm. This applies in particular where:

• the DSL is unavailable
• there is an immediate concern for a child's safety
• they disagree with a decision by the DSL not to make a referral

Personnel who make a direct referral should inform the DSL as soon as practicable. No one will suffer any detriment for making a referral in good faith.

6.3 Action by the DSL

On receiving a concern, the DSL will consider the child's immediate safety, gather relevant facts without investigating, and decide whether to (a) refer to the children's social care team of the relevant local authority (the authority in which the child lives or, where different, is present) and/or the police, (b) share the concern with the child's school, (c) agree a plan with the parent or carer where this does not place the child at further risk, or (d) record the concern and monitor. Where the threshold for a referral is met, the DSL will make it without delay, and confirm any telephone referral in writing within 24 hours. Consent is not required to share information where necessary to safeguard a child.

Parents and carers will normally be informed of a concern, unless doing so would place the child at greater risk or compromise an investigation. This decision rests with the DSL, ideally following advice from children’s social care or the police.

Contact details for each local authority in which Foundry works are held in Appendix A (Local Authority Safeguarding Directory). Where a child lives or is present in an area not yet listed, the DSL will identify the correct contacts before making the referral and add them to the Appendix afterwards. The absence of a listed contact must never delay a referral.

7. Safer Recruitment

Foundry applies safer recruitment practice to everyone who works with children on its behalf, including tutors, speakers and facilitators. No individual has contact with a child until every check below is complete and the DSL has confirmed in writing that the individual is suitable to start.

Identity verification. Original identity documents are checked in person (or by secure live video where an in-person check is not practicable) to confirm that they are authentic and that the photograph matches the individual. The person carrying out the check records, signs and dates that it has been completed.

Right to work. The individual's right to work in the UK is confirmed in line with Home Office requirements.

Employment history. A full employment and education history is obtained, and any gaps are explained in writing and followed up.

References. A minimum of two satisfactory references are obtained, including one from the most recent relevant employer where appropriate. References are reviewed before the individual starts, and any discrepancy is followed up.

Interview. Every candidate is interviewed, and the interview includes specific safeguarding and suitability questions.

Qualifications. Relevant qualifications are verified.

Enhanced DBS check. A current enhanced DBS certificate is obtained and seen in original form, including a check of the Children's Barred List where the role constitutes regulated activity.

Overseas checks. Where the individual has lived or worked outside the UK, overseas criminal record checks are obtained where appropriate.

Teaching prohibition check. A Teaching Regulation Agency prohibition check is carried out where it is legally relevant to the role.

Declaration. The individual signs a declaration covering relevant convictions, cautions and safeguarding investigations or allegations.

Documented decision. Where information is disclosed during vetting (for example a conviction, a caution, a safeguarding investigation or an unexplained gap), the DSL completes and records a risk assessment and a documented recruitment decision before any engagement is confirmed.

Ongoing suitability. Foundry monitors suitability once an individual is working for it. DBS status is rechecked periodically, and in any event at least every three years or annually where the individual is subscribed to the DBS Update Service. Personnel confirm in writing each year that their circumstances are unchanged, and must notify the DSL immediately of any caution, conviction, arrest or investigation that could affect their suitability to work with children.

Foundry keeps a central record of all vetting checks, showing who carried out each check and when. Foundry will refer an individual to the Disclosure and Barring Service where they are dismissed, or would have been dismissed, for harming a child or posing a risk of harm.

8. Foundry Tuition: Working One-to-One

Because Foundry Tuition is delivered one-to-one, additional protections apply.

8.1 Online sessions

• Online sessions are delivered through Google Meet. All messages between tutors, students and families pass through the Foundry system, which is monitored. No messages are sent outside it, and personnel must not use personal messaging apps, email, social media or any other channel to contact students
• Tutors must join from a Foundry-approved account and dress professionally
• Parents or carers are asked to ensure the student joins from a shared or family area of the home, and that a responsible adult is at home and reachable during the session
• Parents or carers are entitled to observe or join a session on request
• Tutors must not take screenshots, photographs or recordings of students
• Tutors must end a session and report to the DSL if a child appears distressed or unsafe, or if another adult behaves inappropriately

8.2 In-person sessions

• In-person sessions take place in the student's home or another agreed setting, and only with a parent or carer's prior written agreement to the location and time
• A parent, carer or other responsible adult must be present on the premises for the duration of the session. Tutors must not meet a child in a location with no other adult present
• Sessions take place in an open, visible space where possible, with doors left open or the room otherwise visible
• Tutors must not transport students in their own vehicle, or enter private areas of a home such as bedrooms, unless explicitly agreed in advance with the parent or carer and the DSL
• Tutors must let the Foundry DSL or a director know the time and location of every in-person session

8.3 Students with SEND

• Consultations capture additional needs, communication preferences and any known risks so that tutors can be matched appropriately
• Tutors supporting students with SEND are briefed on the student's needs, and are supported by Foundry's SEN specialist where required
• Tutors do not provide intimate care. Any need for personal care must be agreed in advance with the parent or carer and the DSL, and a parent or carer must be present
• Restrictive physical intervention is not used by Foundry personnel. Physical contact is only ever brief, appropriate and in response to an immediate risk of injury

9. Foundry Pathways: Working in Schools

• Foundry speakers and facilitators follow the host school's safeguarding policy, visitor procedures and signing-in arrangements at all times, and are given the name of the school's DSL before arrival
• Speakers wear visible identification, report to reception, and are never left alone with individual students. Sessions are delivered to groups, with a member of school staff present in the room
• Speakers do not seek or accept private contact with students, and do not exchange personal contact details or connect on social media. Follow-up must go through the school
• Speakers must not photograph or record students. Any photography is carried out by the school in line with its policy
• Content is age-appropriate and respectful, and is reviewed with the school where a topic is sensitive. Speakers must be prepared to handle disclosures prompted by a session, and report to the school’s DSL following Section 6
• Where schools request confirmation of vetting, Foundry will provide evidence of DBS status on request

10. Code of Conduct

All Foundry personnel must:

• treat every child with dignity and respect, and model professional and appropriate behaviour at all times
• maintain clear professional boundaries. Relationships must never be secretive, and must never become friendships or romantic or sexual relationships
• communicate only through approved Foundry channels and in a manner that could be shared with a parent or the DSL
• avoid favouritism, and not give gifts to, or accept gifts of significant value from, students or families without disclosure to the DSL
• avoid being alone with a child in circumstances where they cannot be seen or heard by another adult
• never use language, humour or imagery that is sexualised, discriminatory, demeaning or intimidating
• never hit, shout at or humiliate a child
• never work while under the influence of alcohol or non-prescribed drugs
• disclose any pre-existing personal relationship with a student or family to the DSL before commencing work

Breach of this Code of Conduct may lead to termination of engagement, referral to statutory agencies and referral to the DBS.

11. Allegations and Concerns about Adults

Any allegation or concern that a member of Foundry personnel has behaved in a way that harmed, or may have harmed, a child, committed a criminal offence against or related to a child, or behaved in a way that indicates they may pose a risk to children, must be reported to the DSL immediately. If the concern is about the DSL, it must be reported to a director.

The DSL will report the matter to the Local Authority Designated Officer (LADO) of the relevant local authority (see Appendix A) within one working day, and follow the LADO’s advice. Foundry will not investigate the allegation itself before speaking with the LADO.

Foundry will suspend or remove the individual from contact with children pending the outcome where necessary. Suspension is a neutral act and not a disciplinary finding.

Where an allegation concerns conduct within a school, Foundry will inform the school's DSL and cooperate with the school's procedures.

Where personnel are dismissed or removed because of safeguarding concerns, Foundry will consider a referral to the DBS and, where relevant, the Teaching Regulation Agency.

Low-level concerns

Foundry encourages the reporting of behaviour that does not meet the threshold of an allegation but is inconsistent with the Code of Conduct, such as excessive one-to-one attention, boundary-blurring, or use of personal contact channels. Low-level concerns are recorded by the DSL, reviewed for patterns, and addressed through coaching or further action as appropriate. Reporting a concern in good faith will never result in detriment to the person who raised it.

12. Online Safety

As a significant proportion of Foundry's work takes place online, Foundry treats online safety as a core safeguarding matter. In addition to Section 8.1, Foundry will:

• use only platforms which have been assessed for security, privacy and child-safety features
• restrict access to sessions to invited participants, and use unique, non-reusable links or logins where available
• ensure that student data held on any workbook, progress-tracking or portal system is secured, access-controlled and used only for the purpose of delivering the service
• promptly address any incident of inappropriate contact, harassment or misuse of technology and report it to the DSL
• provide age-appropriate guidance to students and families on staying safe during online sessions

13. Prevent Duty

Foundry recognises its role in protecting children from being drawn into terrorism. Personnel who have a concern that a child may be at risk of radicalisation must report it to the DSL as they would any other safeguarding concern. The DSL will consider a referral to the Channel programme via the Local Authority or police, and inform the child’s school where appropriate.

14. Record Keeping, Confidentiality and Data Protection

• All concerns, disclosures and actions are recorded factually, signed and dated, and stored securely by the DSL, separate from tutoring records
• Safeguarding information is shared on a need-to-know basis only with those who must know in order to protect the child. Data protection law is not a barrier to sharing information for the purpose of safeguarding a child
• Safeguarding records are retained in line with Foundry's data retention schedule and applicable guidance, and are securely destroyed at the end of the retention period. [Retention period to be confirmed]
• Foundry's use of personal data is described in its Privacy Policy. Foundry is registered with the Information Commissioner's Office [ICO registration number]

15. Complaints

Complaints about safeguarding practice can be made in writing to the DSL or to a director. Complaints about the conduct of Foundry personnel will be handled under Section 11 where they relate to a child’s safety, and otherwise under Foundry’s Complaints Procedure. Where a person remains dissatisfied, they may contact the relevant local authority or, in the case of a school-based session, the school’s governing body.

Appendix A: Local Authority Safeguarding Directory

Foundry works with children across many local authorities. A referral is made to the children's social care team of the local authority in which the child lives or, where different, is present. Concerns about an adult are reported to the LADO of the local authority in which the concern arose. The DSL adds a table to this Appendix as Foundry begins working in each new area, so that the main policy does not need to change.

A.1. National contacts (apply in every area)

[Add national-level contacts here, e.g. NSPCC Helpline 0808 800 5000, Childline 0800 1111, and Police 999 for emergencies.]

A.2. Oxfordshire

[Add Oxfordshire contacts here: Children’s Social Care / MASH, Emergency Duty Team, LADO, Prevent / Channel.]

A.3. Further local authorities

[Add a table in the same format for each further local authority as Foundry begins working in that area: Children's Social Care / MASH, Emergency Duty Team, LADO, Prevent / Channel and any other relevant local safeguarding contacts.]