Safeguarding & Child Protection Policy

Princeps Education — Online Tutoring

Policy owner: Joshua Bray, Designated Safeguarding Lead (DSL)  |  Date of issue: July 2025  |  Version: 1.2

Applies to: All Princeps Education staff, tutors, Lead Educators and contractors. Reviewed annually, or immediately following any significant incident or change in legislation.

1. Policy Statement

Princeps Education is a premium online tutoring company providing one-to-one tuition to students aged 8–18, primarily in Maths and Science across the British curriculum. Although we are not an in-person institution such as a school, we take our duty of care to every student just as seriously. The welfare and safety of the children we teach is our first priority, and every member of our organisation shares responsibility for it.

Working online does not reduce our safeguarding obligations — it changes their shape. Risks such as grooming, online exploitation, inappropriate contact and exposure to harm can arise in digital environments, and our policies, technology and procedures are designed specifically to prevent, detect and respond to them.

This policy sets out how we keep students safe, how concerns are reported and escalated, and the responsibilities of everyone who works with us. It is informed by NSPCC guidance on safeguarding and child protection for tutors, UK safeguarding standards (including the principles of Keeping Children Safe in Education), and UAE child protection law, including Federal Law No. 3 of 2016 (Wadeema’s Law) on child rights.

2. Scope

This policy applies to all Princeps Education employees, tutors, Lead Educators, and any contractor or third party who interacts with our students or their data. It covers all tutoring sessions, communications and platforms operated by Princeps Education, and applies to students in the UAE and any other jurisdiction in which we operate.

3. Designated Safeguarding Lead (DSL)

Our Designated Safeguarding Lead is Joshua Bray.

Joshua is a qualified teacher with a professional teaching background and has completed the NSPCC Child Protection for Tutors training, covering the recognition of abuse and neglect, safe tutoring practice (including online tuition), responding to disclosures, and reporting procedures. His training is refreshed in line with NSPCC recommendations.

The DSL is responsible for:

• Receiving, recording and acting on all safeguarding concerns and disclosures
• Maintaining each student’s confidential safeguarding file and the incident proforma record
• Reviewing lesson recordings where a concern has been raised
• Liaising with parents, schools, police and child protection authorities as appropriate
• Overseeing safeguarding training and ensuring this policy is followed and kept up to date

Any member of staff, any tutor, any parent or any student can contact the DSL directly at any time with a safeguarding concern. A DSL is available on demand to deal with concerns as they arise.

4. Safer Recruitment & Tutor Training

Every Princeps tutor is a degree-qualified, British-trained teacher with a minimum of five years’ experience, and is rigorously vetted before working with any student. Our checks include:

• Enhanced DBS (Disclosure and Barring Service) check, or equivalent police clearance for overseas tutors
• Identity verification and qualification checks
• Reference checks

Safeguarding training is a mandatory part of every tutor’s onboarding with the company — no tutor teaches a Princeps student before completing it. This training covers recognising the signs of abuse and neglect, professional boundaries and safe online tutoring practice, how to respond to a disclosure, and our internal reporting procedure. Safeguarding awareness is refreshed through ongoing professional development.

5. Safe Online Tutoring Environment

All tuition takes place through our approved online platforms. Tutors follow a professional code of conduct at all times, including:

• No private or off-platform contact with students (including social media, personal messaging or email)
• Professional conduct, language and environment in every session
• All scheduling and communication with families handled through Princeps channels
• Any accidental breach of these boundaries must be reported to the DSL immediately

5.1 Lesson Recordings

Every lesson is recorded and stored securely for up to 60 days. We retain recordings for the following reasons:

• Safeguarding — recordings provide an objective record of every session, deter misconduct, and allow the DSL to review a specific lesson if a concern is raised
• Incident evidence — where a concern or allegation arises, the recording preserves evidence that can be shared with parents, police or child protection authorities as appropriate
• Quality assurance — our Lead Educators review lessons to maintain teaching standards
• Learning support — students may rewatch lessons for revision during the retention period

Recordings are stored securely with restricted access and are deleted after 60 days, unless required for an active safeguarding matter, in which case they are preserved for as long as necessary.

6. Recognising Concerns

All staff and tutors are trained to remain alert to indicators of harm, including: disclosures by the student; unexplained injuries; significant changes in behaviour, mood or engagement; signs of neglect; indications of grooming or inappropriate online contact; and anything seen or heard during a session that causes concern. Tutors are never expected to investigate — their responsibility is to notice, record and report.

7. Responding to an Incident: Our Reporting Procedure

The following procedure is followed whenever a tutor or member of staff has a safeguarding concern.

7.1 Step 1 — Immediate Danger Check

If the tutor believes a child is in immediate danger — for example a predator meeting, coercion, trafficking, threats, exploitation, or a crime happening right now — a member of the safeguarding team contacts Dubai Police on 999 without delay. The DSL is informed immediately afterwards.

7.2 Step 2 — Report to the DSL

If there is no immediate danger, the tutor reports the concern to the DSL, recording:

• The cause for concern
• The student’s name
• The date of the session
• The specific time within the lesson (so the moment can be located in the recording)

The DSL then:

1. Confirms receipt of the report
2. Opens the student’s safeguarding file
3. Reviews the lesson recording
4. Completes a proforma incident report

7.3 Step 3 — Classify and Escalate

The DSL classifies the concern and contacts the appropriate authority:

If the child may face danger from within their own family, the DSL contacts the Dubai Foundation for Women and Children (DFWAC) on 800 111, who can intervene safely without putting the child at further risk.

7.4 Step 4 — Informing Parents

Before contacting parents, the DSL considers whether parents are safe to contact. If the answer is no, or we are unsure, the DSL contacts the MOI Child Protection Centre (116 111) for guidance instead. If parents are safe to contact, the DSL:

1. Shares the concern with the parents and provides the proforma report
2. Contacts the UAE Child Protection Centre (116 111) where appropriate
3. Informs the student’s school
4. Updates the proforma to reflect that the report has been dealt with

7.5 Responding to a Disclosure

If a student discloses abuse during a session, the tutor listens calmly, takes the student seriously and reassures them — without interrupting, investigating or asking leading questions. Tutors never promise to keep a disclosure secret: they explain that they must share it with someone who can help. The disclosure is reported to the DSL immediately using the procedure above.

8. Record Keeping & Confidentiality

The DSL maintains a confidential safeguarding file for any student about whom a concern is raised, together with proforma incident reports recording what was reported, what action was taken and the outcome. Records are stored securely, shared strictly on a need-to-know basis, and retained in line with our data protection obligations. Where a child is at risk of significant harm, information may be shared with the appropriate authorities without consent.

9. Allegations Against Tutors or Staff

Any allegation against a Princeps tutor or member of staff is taken seriously and handled promptly by the DSL. The tutor concerned is suspended from teaching while the matter is reviewed, relevant lesson recordings are preserved, and the concern is referred to the appropriate authorities where required. Parents are always told who they can contact if they have concerns about a tutor’s conduct.

10. Key Contacts

11. Policy Review

This policy is reviewed annually by the Designated Safeguarding Lead, and immediately following any safeguarding incident, change in relevant legislation, or change to our operating model. All tutors and staff are notified of updates, and continued compliance with this policy is a condition of working with Princeps Education.