Safeguarding Policy

Avalon Education Limited, company number 14389670, registered in England and Wales

124 City Road, London, EC1V 2NX · hello@avaloneducation.co.uk · +44 20 8156 4942

Version 1.2 · Last reviewed 26 August 2026 · Next review due 26 August 2027

Signed: Andrew Doane, Director and Designated Safeguarding Lead

1. Introduction

1.1 Avalon Education Limited provides tuition, university and college applications support, and independent school placement

advice. We contract with our clients as principal and deliver our services through tutors and consultants engaged by us as self-

employed contractors working to our direction. We do not introduce tutors to clients, and we remain responsible to the client for

the services however they are delivered.

1.2 We do not maintain educational premises and we do not hold or arrange events at which children are likely to be present. The

majority of students using our services are in full-time education, and the majority of tuition takes place online.

1.3 We are a corporate member of The Tutors

' Association and follow its Code of Practice.

2. Definitions

2.1 Child — a person who has not yet reached their 18th birthday.

2.2 Adult at risk — as defined by the Care Act 2014: an adult aged 18 or over who (a) has needs for care and support, whether or

not the authority is meeting any of them, (b) is experiencing, or is at risk of, abuse or neglect, and (c) as a result of those needs is

unable to protect themselves against the abuse or neglect or the risk of it.

3. Scope

3.1 This policy promotes the welfare of children and adults at risk. It applies to anyone working with or on behalf of Avalon,

including directors, employees, contractors, volunteers, tutors and consultants.

3.2 Everyone we engage is required to comply with this policy and to take prompt and effective action if a safeguarding concern

arises.

3.3 This policy should be read alongside our Client Agreement, General Terms and Privacy Policy.

4. Legal framework

4.1 This policy is drawn up on the basis of legislation, policy and guidance that seeks to protect children in the United Kingdom. It

applies to our employees, agents, contractors and other connected parties wherever they work in the world.

4.2 Where we operate outside the UK we undertake to:

(a) comply with local laws, regulations, instructions from law enforcement agencies and rulings by any legitimate judicial authority;

(b) refer any matters of criminal conduct, especially in relation to safeguarding, to the local authorities responsible for policing and

law enforcement;

(c) where local legislation permits, or is ambiguous or indifferent, follow this policy to the fullest extent possible in order to

safeguard children and adults at risk, applying whichever definition — local or UK — is broader.

4.3 Guidance we work to includes: After-school clubs, community activities and tuition: safeguarding guidance for providers

(England); What to do if you're worried a child is being abused (HM Government); Keeping Children Safe in Education (England);

Working Together to Safeguard Children (England); and the Care Act 2014 (England and Wales). A summary of key UK legislation

is available from the NSPCC at learning.nspcc.org.uk.

5. What we recognise

5.1 The welfare of children is paramount in all our work and decisions.

5.2 All children, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation, have an equal

right to protection from all types of harm or abuse.

5.3 Some children are additionally vulnerable because of previous experiences, level of dependency, communication needs or other

issues, and extra safeguards may be needed to keep them safe.

5.4 Adults may also be at risk, for reasons including age and disability, and deserve the same care, attention and protection.

6. How we keep children and young people safe

6.1 We value, listen to and respect them.

6.2 We appoint a Designated Safeguarding Lead, and maintain an escalation route for any concern that cannot appropriately be

raised with them.

6.3 We adopt safeguarding best practice through our policies, procedures and code of conduct.

6.4 We maintain an effective approach to online safety, set out in section 10.

6.5 We provide support and quality assurance so that everyone working with us knows and follows our policies confidently.

6.6 Everyone we engage to work with children holds a current enhanced DBS certificate with a barred list check, either issued within

the last 12 months or maintained through the DBS Update Service. For tutors outside the United Kingdom we accept the

recognised equivalent for their jurisdiction. We verify this before a tutor's first session and keep it under review for as long as they

work with us. A client may ask us to confirm a tutor's check at any time.

7. Designated Safeguarding Lead

7.1 Designated Safeguarding Lead: Andrew Doane, Director — andrew@avaloneducation.co.uk, +44 20 8156 4942.

7.2 Where a concern relates to the Designated Safeguarding Lead. We do not currently have a Deputy. Nobody is ever expected

to raise a concern with the person it is about. A concern about the Designated Safeguarding Lead should instead be taken directly to:

(a) the Local Authority Designated Officer, through the Local Children's Safeguarding Partnership for the area where the child

lives; or

(b) the NSPCC Helpline on 0808 800 5000 or help@nspcc.org.uk; or

7.3 Telling people about this route. Everyone working with us is told about this route when they start, and it is repeated in our

code of conduct. Raising a concern by any of these routes is protected and will never be treated as a disciplinary matter.

7.4 Duties of the Designated Safeguarding Lead:

(a) Take a lead role in developing, reviewing and implementing our safeguarding and child protection policies and procedures, and

in ensuring all safeguarding issues are responded to appropriately.

(b) Make sure everyone working with or for children at Avalon understands this policy and knows what to do if they have concerns.

(d) Receive and record information from anyone with concerns about a child, and ensure reports are stored securely.

(e) Take the lead on responding to information that may constitute a child protection concern, including a concern that an adult

involved with Avalon may present a risk. This means assessing and clarifying the information — not investigating — making

referrals to statutory organisations as appropriate, consulting and informing management, and following this policy.

(f) Liaise with and pass information to and from statutory child protection agencies, including the Local Children's Safeguarding

Partnership, the Local Authority Designated Officer and the police, including making formal referrals where necessary.

(g) Consult the NSPCC Helpline when support is needed.

(h) Store and retain child protection records according to legal requirements and this policy.

(i) Keep a written record of safeguarding concerns and of the action taken, and review it periodically alongside this policy.

8. Responding to concerns

8.1 Everyone working with us is required to read this policy before they begin, and to be alert to signs that the welfare of a child or

adult at risk may be at risk. Concerns should be reported directly to the Designated Safeguarding Lead, or by the route in clause 7.2

where the concern relates to them.

8.2 Perpetrators can be adults, and they can also be other children. There is no specific identity of a perpetrator.

8.3 Report concerns without delay. Delaying a report leads to forgotten or altered details.

8.4 Reports should contain only the facts of what raised the concern. Assumptions and interpretations should not be included — if

a person was crying, the report should say they were crying, not that they were sad or upset.

8.5 If a concern arises or a disclosure is made, take it seriously and listen. Do not ask leading questions. If a child says "[name] hurt

me yesterday", asking "did they hit you?" is not appropriate; repeating back "how did they hurt you?" lets them respond in their own

words.

8.6 Never promise to keep something secret. Be open: if we have concerns for someone's welfare we may have to talk to others, and

we will only do so to keep them safe and get them support.

8.7 It is rarely possible to be certain, and it is not our role to investigate. Our role is to notice signs and report them to those with the

authority and experience to act.

9. Who to report to

9.1 Working for Avalon. Concerns arising while working for Avalon should be reported to the Designated Safeguarding Lead by

email to safeguarding@avaloneducation.co.uk, or by telephone on +44 20 8156 4942 where the matter is urgent. Set out what you

saw or were told, when, and who was present, in the words used where you can.

9.2 Working in a school or other setting. Where our people are working in a school, college or other educational setting, that

setting's internal procedures should be followed and a report should also be made to us, and shared with the setting's safeguarding

lead.

9.3 Tutors reporting. Where possible, report to the Designated Safeguarding Lead first, so that we can act on the concern and keep

a record of it. Nothing in this policy prevents a tutor reporting directly to the Local Children's Safeguarding Partnership or Adult

Safeguarding Board where the person lives, or to the NSPCC Helpline, and a tutor should do so where they cannot reach us, where

the matter is urgent, or where the concern relates to the Designated Safeguarding Lead. Where the person lives abroad, contact the

local authorities where that person lives, as that is where the concern will need to be dealt with.

9.4 Immediate danger. Where there is reason to believe a child or adult at risk is in immediate danger, contact the police on 999. A

report should still be made in the usual way.

9.5 If you are unsure. If it is ever unclear who to report to or how, check rather than leaving the concern unreported.

9.6 NSPCC Helpline: 0808 800 5000, 10am–4pm Monday to Friday, or help@nspcc.org.uk 24 hours a day.

10. Keeping children safe online

10.1 We only interact with children through agreed means and at agreed times, arranged through a responsible adult such as a

parent, carer or school representative. An adult may have vulnerabilities and still be able to arrange their own tuition, and this

should be considered when booking.

10.2 Nobody working with us contacts children through social media or personal profiles. The only exception is where a child

contacts an Avalon company profile to ask about our services or seek support.

10.3 Where a client has given us contact details for a child, the assigned tutor may use them by email, telephone or message for

matters relating to the tuition — arranging sessions, setting and following up work, and answering questions about it. They must

not be used for personal conversation or for anything unrelated to the tuition. A client may withdraw those details at any time.

10.4 All resources shared with or sent to children are checked to make sure they are appropriate and contain nothing that could

harm a child or expose them to harm. Where sensitive topics arise in educational content, the tutor chooses resources carefully and

raises anything they are unsure about with the Designated Safeguarding Lead before using it.

10.5 Sessions delivered through our online platform may be recorded. Recordings are stored on the platform and are available to the

client, the student and the assigned tutor. The Director has access to the platform and reviews a recording where a safeguarding

concern or a complaint is raised. A client or student may ask us not to record at any time, and recording stays off for their sessions

until they tell us otherwise. Recordings are deleted after 90 days, and any remaining recordings are deleted when the engagement

ends, except where a recording relates to a safeguarding concern or a complaint, in which case it is preserved and handled as a child

protection record under section 16. Where a client or student downloads a recording, the copy they keep is outside our control and

our deletion timescales do not apply to it.

10.6 Clients and students must not record a session, in whole or in part, other than through the platform. This protects the tutor as

well as the student.

11. Code of conduct

11.1 Everyone working with Avalon is expected to follow our general code of conduct. In relation to safeguarding, this means:

(a) Engaging with our safeguarding policies, including attending training when offered.

(b) Treating all service users with equal respect, regardless of age or any other characteristic.

(c) Not contacting children through social media or personal profiles, and not using the contact details a client has given us for

anything other than the tuition, as set out at clause 10.3.

(d) Declaring any existing personal relationship with a child or their family to the Designated Safeguarding Lead as soon as possible.

We understand that contact with existing friends or family cannot be avoided; declaring it means we know communication may

occur.

(e) Not having a sexual or romantic relationship with any child under 18, and not starting one with a service user who turns 18 after

contact began before their birthday. This could be an offence under the Sexual Offences Act 2003.

(f) Not being left completely alone with children. Where it may happen, others should be notified — the child's parents or carers, or

staff at the educational setting. Where others are in the building but not the room, the door should be left open where possible;

where that is not possible, it should remain unlocked.

(g) Where tutoring children at home, online or in person, sessions should ideally take place in a communal space such as a living

room, kitchen or office — quiet and calm, but somewhere others could look in.

(h) Where tutoring children online, arranging it through a responsible adult who has the date, time and joining link. That adult does

not need to stay for the session, but must never be prevented from accessing it if they wish to.

(i) Keeping the contents of a session confidential, except where there is a lawful reason to share — for example where the tutor

genuinely believes someone is at risk of harm.

(j) Being alone and in a secure space when delivering an online session. If anyone else will be present or joining, this must be

communicated to the client in advance.

(k) Speaking to the Designated Safeguarding Lead whenever anything about conduct is unclear. It is better to ask beforehand.

11.2 Tutors deliver tuition using their own devices. Where an independent authority such as the police makes a lawful request in

connection with a safeguarding investigation, tutors are expected to cooperate with it.

12. Preventing and responding to bullying

12.1 Bullying takes many forms. Anyone can engage in bullying behaviour and anyone can be bullied.

12.2 We treat everyone equally and without judgement, and teach that this is how everyone should be treated.

12.3 Bullying that is seen or disclosed is reported as a safeguarding concern to the relevant person — our Designated Safeguarding

Lead, or the safeguarding lead at the educational setting concerned.

13. Allegations against staff, tutors or volunteers

13.1 Reporting an allegation. Allegations are taken seriously and passed to independent authorities to investigate, for example the

Local Authority Designated Officer via the Local Children's Safeguarding Partnership. The person concerned may be suspended

from their duties while the authorities investigate, on advice from the LCSP or other authorities.

13.2 Confidentiality during an investigation. While an investigation is taking place, others are not told why the person is not

working, to maintain confidentiality and allow the proper investigation. Where the authorities need to speak to others, that should

be kept confidential.

13.3 If an allegation is upheld. Allegations proven to be true will lead to disciplinary action or dismissal, depending on the nature

of the allegation and any history, on advice from the relevant authorities.

13.4 Referral to the Disclosure and Barring Service. Where we remove a tutor or member of our team from work with children

because they have harmed a child or pose a risk of harm — or where we would have removed them had they not resigned or withdrawn first — we have a legal duty under the Safeguarding Vulnerable Groups Act 2006 to refer them to the Disclosure and

Barring Service, and we will do so. That referral is separate from, and in addition to, any report to the Local Authority Designated

Officer, the Local Children's Safeguarding Partnership or the police.

13.5 If an allegation is not upheld. Allegations proven to be false remain on record, together with the outcome of the

investigation.

14. Allegations against other children

14.1 An allegation made against a child is reported as a safeguarding concern to the relevant person — our Designated Safeguarding

Lead, or the safeguarding lead at the educational setting. In some cases it will be necessary to refer the matter to external authorities

such as social workers, the police, or international authorities.

14.2 This guidance follows Keeping Children Safe in Education.

15. Whistleblowing

15.1 Reports should be made through the procedure in section 9, to the Designated Safeguarding Lead, or by the route in clause 7.2

where the concern relates to them.

15.2 Anyone who has reported a concern may ask the Designated Safeguarding Lead for an update. We are not obliged to share

specific details but can say whether the report has been acted on or referred externally.

15.3 If a report has not been acted on and the person who raised it believes it should have been, they can raise it again. We may hold

information the reporter does not.

15.4 If the person still has concerns, they should report to the Local Children's Safeguarding Partnership where the child lives, or the

relevant board for an adult at risk, and may tell them that a report was made to Avalon which they feel has not been passed on

appropriately.

15.5 It is not appropriate to go to the media or post on social media. Doing so is treated under our general whistleblowing policy and

may result in disciplinary action or dismissal.

16. Storing child protection records

16.1 Data protection law does not change how child protection records should be stored. We follow NSPCC guidance.

16.2 We collect and store data about the people we work with, including children and adults at risk and their carers, in order to

provide our services. Some data is collected specifically for child protection purposes.

16.3 Data collected for child protection purposes may be shared with appropriate agencies or authorities such as the Local

Children's Safeguarding Partnership or the police. It will only ever be shared for the purpose of safeguarding.

16.4 Personally identifiable data is kept for as long as necessary and appropriate. Data relating to child protection may be kept longer

— educational settings generally keep records until the person turns 25, and we follow that approach.

16.5 Physical records are locked in a secure space only the Designated Safeguarding Lead can access. Digital records are held in

password-protected folders on protected devices.