Person Responsible for this Policy: Serena Cumming
Policy last updated: 2nd June, 2025
Next update: 2nd June, 2026
1. Introduction, Government Guidance and Aims
Serena’s Tuition is committed to the wellbeing and safeguarding of all children, adults and staff who attend tuition with them. This policy’s main aim is to provide all children and adults with a comprehensive, secure and clear commitment to safeguarding and a framework to ensure all children attending Serena’s Tuition are protected from harm.
Under no circumstances must tutors or teaching assistants at Serena’s Tuition use physical force as a punishment.
This Safeguarding and Child Protection Policy is written with consideration of the following Department for Education statutory guidance:
Keeping Children Safe in Education (2024)
Working Together to Safeguard Children (2023)
and the following guidance from HM Government:
o Prevent Duty Guidance (2023)
o Information Sharing: advice for practitioners providing safeguarding services (2024)
and the following Department for Education non-statutory guidance:
After-school clubs, community activities and tuition: safeguarding guidance for providers (2023)
What to do if you’re worried a child is being abused (2015)
In addition, this setting operates in accordance with the local authority in partnership to keep children safe. Details of the local authority can be found here:
Kent County Council’s Social Services – For Child’s Safeguarding Concerns:
Phone: 03000 41 11 11
Text Relay: 18001 03000 41 11 11
Email: social.services@kent.gov.uk
Kent County Council’s Social Services – For Adult’s Safeguarding Concerns:
Phone: 03000 41 61 61
Text Relay: 18001 03000 41 61 61
Email: social.services@kent.gov.uk
In cases where a criminal offence has been committed or it is suspected that one has been committed, the matter must be reported immediately to the local police force using the 101 service. In an emergency this must be reported using the 999 service.
Definitions of ‘significant harm’ are taken from Section 47 of The Children Act (1989)
This policy must be read in conjunction with the Serena’s Tuition policies below:
TTA Code of Practice
Privacy Policy/GDPR
Safeguarding Policy
Parental Consent Form
Health and Safety Policy
It is available to all parents whose children use our settings upon request, and is available on our public-facing website (www.serenastuition.co.uk). In addition, posters and booklets at the setting display safeguarding information for parents and children.
For the purpose of this policy, ‘children’ refers to any student under the age of 18 attending the setting. ‘Adults’ refers to parents or other responsible adults who drop off or collect their child at or from the setting.
The aims of this policy are:
To ensure that all coming into contact with Serena’s Tuition understand the importance of safeguarding and that it is everyone’s responsibility
To support any child who makes a disclosure of abuse
To ensure everyone at Serena’s Tuition knows who to inform in the event of a disclosure, concern or safeguarding issue and to ensure they are alert to the signs of possible child abuse
To aid everyone at Serena’s Tuition in understanding and recognising specific safeguarding concerns
To ensure, in accordance with The Children Act 1989, that the welfare of the child is paramount at all times
2. Designated Safeguarding
The Designated Safeguarding Lead is
· Name: Serena Cumming
· Job Title : Owner
· Contact Details:
Tel: 07738 335178
Email: office@serenastuition.co.uk
The role of the Designated Safeguarding Lead (DSL) is to:
Be a point of advice on safeguarding and pastoral issues
Have overall responsibility for safeguarding (this cannot be delegated)
Raise awareness of safeguarding amongst those attending the setting
Manage referrals from to the local authority
Manage the record-keeping of safeguarding concerns and ensure records are kept up to date
To update their own Level 3 safeguarding training at least once every two years using an external provider including Online Safety training and Prevent training
Make referrals to the local authority Prevent Officer under the Counter-Terrorism and Security Act 2015
3. Safeguarding Issues
For further details and definitions of types of abuse and neglect, we can reference DfE guidance Working Together to Safeguard Children (2023) and Keeping Children Safe in Education(2024). External training will also reference these documents including definitions of abuse and neglect.
a. Types of abuse
For the purposes of this policy, Serena’s Tuition is aware of and vigilant to the following types of abuse and safeguarding issues:
Physical abuse
Emotional abuse
Sexual abuse
Neglect
Child on child abuse (see below)
Extremism and radicalisation
Sexual harassment
Bullying
Substance abuse
Online exploitation and abuse
Domestic abuse
b. Contextual safeguarding
We are also aware that safeguarding incidents and behaviours can occur outside the home environment and are vigilant to reports of these. These contextual safeguarding issues form part of external training. These include:
Child Sexual Exploitation
Child Criminal Exploitation
Female Genital Mutilation
Honour Based Abuse
Knife Crime
Children Absent from Education
c. Child on child abuse
We are vigilant to the possibility of child-on-child abuse at the setting. Close supervision of children attending the setting is designed to mitigate this risk, however we maintain the attitude of ‘it could happen here’.
Such abuse can include:
abuse in intimate personal relationships between children
harmful sexual behaviour including but not limited to the use of inappropriate sexual language, sharing of nude of semi-nude images or videos, upskirting, sexual violence
bullying (including cyberbullying)
physical abuse such as:
hitting
kicking
shaking
biting
hair pulling
otherwise causing physical harm
In the event of suspected child-on-child abuse involving one or more children who attend the setting against another child who attends the setting and where there is reasonable cause to suspect significant harm the case must be referred to the local authority.
d. Children with Additional Educational Needs, Disabilities and other vulnerabilities
Serena’s Tuition are aware that children with Additional Educational Needs, disabilities or health issues may face additional safeguarding issues. We are vigilant to:
Any indicators of possible abuse not in keeping with the child’s additional needs or history
Any communication challenges the child faces in disclosing the abuse (for example, if the child is non-verbal)
The fact that children with additional needs or other vulnerabilities are disproportionally impacted by abuse and behaviours such as bullying
That children who are (or are perceived to be) lesbian, gay, bisexual or trans are more likely to suffer child on child abuse and are more vulnerable to abuse
4. Reporting Concerns about a child
Serena’s Tuition are aware that barriers to reporting abuse exist, and that some children may not be ready or not know how to tell someone that they are being abused. We are aware that children with Additional Educational Needs or disabilities are more vulnerable to abuse. We never assume that an issue has been reported or disclosed by another person.
If a child discloses abuse:
We will stop and listen straight away without delay
We will write notes as soon as possible after the conversation
We must not guarantee confidentiality
We use TED – Tell me, Explain to me, Describe to me. We can ask children whether they have been harmed and the nature of that harm, without asking leading questions.
We will not conduct our own investigation but will refer immediately
We will maintain a calm and professional attitude and prioritise the wellbeing of the child at all times.
Reports to the local authority children's safeguarding board must be undertaken:
As soon as possible and within 2 hours of the concern being raised or suspected
For a child at risk or suspected to be at risk of significant harm, the concern must be raised immediately
In person or by telephone as required by local services.
We note that it is usually best practice to share concerns with parents/ carers. However, for children at risk of significant harm (or where there is reasonable cause to suspect this), it may not be appropriate to do so. Decisions on whether to share information must be made in conjunction with the DSL. It may be helpful to refer to the following guidance: https://www.gov.uk/government/publications/safeguarding-practitioners-information-sharing-advice
The DSL will decide if a concern should be raised with the local authority. If a child is at risk of significant harm, in accordance with Section 47 of The Children Act (1989), statutory child protection agencies will conduct the investigation and the DSL must not investigate. At all times, decision-making in this regard must be documented, including:
Who raised the concern (include details of date, time, job title)
Who was the concern raised about (include details of child’s name, date of birth, address, school)
What decision was made and why – what were the reasons for making the referral
Who was consulted
What action was taken
Whether parents/ carers were consulted and if not, why not
5. Useful Contact Details
Contacts
DSL
Serena Cumming
Tel: 07738 335178
Email: office@serenastuition.co.uk
Local authority contacts
Kent County Council Safeguarding Team
Child Services Tel: 03000 41 11 11
Adults’ Services: 03000 41 61 61
Email: social.services@kent.gov.uk
Out of Hours: 03000 41 91 91
LADO (Local Authority Designated Officers)
Email: lesasenquiries@kent.gov.uk
Specialist helplines
Police – immediate threat - 999
Police – serious concerns – 101
Prevent (non-emergency advice) – 0800 011 3764
NSPCC helpline – 0808 800 5000
Childline – 0800 1111
Ofsted – 0300 123 4666
When your child registers with Serena's Tuition and Serena's Tuition Rochester Ltd, one of the forms that you fill in relates – in part – to GDPR, and specifically what we do with any photographs/videos taken of your child during their time here. This is a contract with you, with your consent, and/or for compliance with our legal obligations, and is part of Serena’s Tuition’s broader GDPR policy. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
· To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Bond 11+, Google, TutorCruncher, QuickBooks or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
· To post testimonials. We post testimonials on our services that may contain personal information. Prior to posting a testimonial, we will remove names and contact details. If you wish to update, or delete your testimonial, please contact us at office@serenastuition.co.uk or enquiry@serenasrochester.com
· Request feedback. We may use your information to request feedback and to contact you about your use of our Service.
· To send administrative information to you. We will use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
· To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
· To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
· To respond to legal requests and prevent harm. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.
· Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
· Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
· To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
· To respond to user enquiries/offer support to users. We will use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
· To send you marketing and promotional communications. We and/or our third-party marketing partners will use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time by emailing office@serenastuition.co.uk or enquiry@serenasrochester.com and the Subject: unsubscribe from marketing emails.
· Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
· For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.
We may process or share your data that we hold based on the following legal basis:
· Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
· Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. For example, an email directly to your child’s tutor relating to their learning, attainment, attendance etc.
· Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
· Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
· Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities.
More specifically, we may need to process your data or share your personal information in the following situations:
· Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 5 years.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
6. WHAT ARE YOUR PRIVACY RIGHTS?
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
7. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
8. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you can email office@serenastuition.co.uk or enquiry@serenasrochester.com or by post to:
Serena's Tuition, 15 Portland Road, GRAVESEND, Kent DA12 1DL
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us.