Safeguarding & Child Protection Policy

1. Statement of Commitment

Nova Education (operated by Nova House Publications Limited) (“Nova”, “we”, “us”)is committed, without reservation, to safeguarding and promoting the welfare of every child who participates in our tutorial programmes. We believe that the safety, wellbeing, and dignity of every child in our programme is the first responsibility of every person who works for or with us, above all other considerations.

This policy sets out the framework within which Nova fulfils that commitment: through safe recruitment to prevent unsuitable people from working with children, comprehensive training and robust safety protocols to support children and keep them safe, clear reporting procedures and a culture in which any concern about a child's welfare can be raised promptly and without hesitation. It is our willingness to work safely and challenge inappropriate behaviours, that underpins this commitment. We have a culture of vigilance and staff are instructed in the need to act without delay to protect children and report anything that might suggest a child is being abused, neglected or made to feel vulnerable.

This policy applies to all Nova tutors, all contracted staff, all volunteers, and all persons engaged in any capacity on behalf of Nova. It applies to all programme formats, one-to-one and group (Nova Shared Programme), diagnostic sessions and practice tests, and to all sessions, whether delivered in person or online. To be clear, we expect ALL persons associated with Nova to share our commitment to maintaining a safe environment and a culture of vigilance in which children can learn.

Compliance with this policy is not optional. It is a condition of engagement with Nova.

2. Scope & Legal Framework

Legislative and Guidance Framework

This policy is grounded in the following legislation and statutory guidance:

• Children Act 1989 and Children Act 2004, establishing the duty to safeguard and promote the welfare of children
• Keeping Children Safe in Education (KCSIE) 2026, adopted by Nova as the guiding framework for safeguarding practice
• Working Together to Safeguard Children 2026, multi-agency safeguarding framework
• Counter-Terrorism and Security Act 2015, the Prevent Duty (adopted as best practice)
• Female Genital Mutilation Act 2003, mandatory reporting obligations
• Children and Social Work Act 2017, including the introduction of contextual safeguarding
• Online Safety Act 2023, online safety obligations
• UK GDPR and Data Protection Act 2018, data handling in a safeguarding context
• Disclosure and Barring Service Code of Practice, DBS obligations for organisations working with children

Definition of a Child

For the purposes of this policy, a 'child' is any individual under the age of 18. All students enrolled in Nova programmes are children. This policy treats every enrolled student as a child regardless of their apparent maturity, competence, or independence.

Who This Policy Covers

This policy applies to:

• All tutors, Senior tutors and administrative staff ) engaged by Nova
• The DSL team Head of Operations
• All members of Nova's leadership team
• All members of staff
• Any volunteers, observers, or work-experience placements
• Any third-party contractors who have direct contact with students

3. Designated Safeguarding Lead (DSL)

DSL Structure

Responsibilities of the Designated Safeguarding Lead (DSL)

The Designated Safeguarding Lead is responsible for:

• Receiving and acting upon all safeguarding referrals from tutors and staff
• Maintaining a confidential record of all safeguarding concerns and actions taken
• Liaising with the Local Authority Designated Officer (LADO) and statutory agencies where required
• Ensuring all tutors and staff receive appropriate safeguarding training and induction
• Maintaining and reviewing this policy annually and following any significant event
• Keeping up to date with safeguarding guidance, legislation, and local procedures
• Overseeing the management of allegations against staff in accordance with Clause 10
• Ensuring that no child participates in a Nova programme without a DBS-checked tutor in place

DSL Unavailability

Where the DSL is unavailable, the Deputy DSL assumes full responsibility for safeguarding matters. If neither the DSL nor any Deputy DSL can be reached, the concern must be referred directly to the local authority children's services or, in an emergency, to the police. A safeguarding concern must never be left unaddressed because the DSL is unavailable.

4. Types of Abuse & Indicators of Concern

All Nova tutors are required to be familiar with the main categories of abuse and the indicators that may suggest a child is at risk. The presence of one or more indicators does not confirm that abuse is taking place, but it does mean a concern must be recorded and reported to the DSL without delay.

Contextual Safeguarding

Nova recognises that abuse can occur beyond the home environment, in schools, online, and in peer relationships. Tutors should be alert to indicators that suggest harm may be occurring in the wider context of a child's life, not only within the family, and should report any such concern to the DSL in the same way.

5. Reporting Procedures

Step-by-Step Reporting Process

1. 1
   Notice: the tutor becomes aware of a concern during or after a session. The concern may arise from something observed, something said by the child, or something disclosed directly.
2. 2
   Record: before contacting the DSL, the tutor makes a brief written record of exactly what was observed or heard. Use the child's own words where possible. Do not interpret, assess, or draw conclusions. Note the date and time.
3. 3
   Report: the tutor contacts the DSL without delay, either by phone or by secure email to the DSL's designated contact. The written record is shared at this point.
4. 4
   DSL decides next steps: the DSL will determine whether the concern requires referral to children's services, the LADO, or the police; whether further information is needed; or whether the matter can be managed internally with monitoring. Where the situation reaches the statutory reporting threshold to LADO, the DSL shall contact the LADO within 24 hours of the concern coming to light.
5. 5
   Document: the DSL records the concern, the tutor's report, and all decisions and actions taken, in Nova's confidential safeguarding log.
6. 6
   Follow up: the DSL ensures that any referral is followed up, that the tutor is informed of the outcome to the extent appropriate, and that the child continues to be supported through their sessions.

If a Child Makes a Direct Disclosure

If a child discloses information that suggests they are at risk of harm, the tutor should:

• Stay calm and listen carefully without displaying shock or disbelief
• Reassure the child that they are not in trouble and have done the right thing
• Not ask leading questions or press for more detail than the child volunteers
• Never promise confidentiality: tutors must explain that they will need to tell someone who can help
• Not contact the child's parents or carers without explicit DSL guidance
• Report to the DSL immediately after the session, or in an emergency, during it

Emergency Situations

External Referral Contacts

6. Online Safety Protocols

Nova delivers the majority of its tutorial sessions online via video call. The online environment presents specific safeguarding risks that require dedicated protocols. All online safety requirements are mandatory and non-negotiable.

Safe Session Delivery, Tutor Requirements

• Tutors must conduct online sessions from a quiet, well-lit, neutral professional space. Sessions must never be conducted from a bedroom.
• The tutor's camera must remain on throughout the entirety of every online session. There are no exceptions to this requirement.
• Before the session begins, the tutor must confirm that a parent or carer is aware the session is taking place and is present or accessible in the home.
• Students must not conduct sessions from a bedroom. Where this appears to be the case, the tutor should politely ask the student to move to another room and note it as an observation in the internal Tutor Notes section of the session record.
• Tutors must ensure their background does not contain personal information, inappropriate imagery, or anything that could cause concern.
• Tutors must test their connection, camera, and microphone before every session. Technical unpreparedness is a professional responsibility.

Recording

Digital Communication Standards

• Tutors must not contact students or families through personal social media platforms, personal messaging apps, or personal email accounts.
• All communication between tutors and families must take place through Nova-authorised channels only.
• Tutors must not share their personal mobile number, personal email address, or home address with any student or family.
• If a student contacts a tutor via a personal social media account or personal messaging platform, the tutor must not respond through that channel. The contact should be reported to the DSL.
• Digital materials shared during sessions must comply with copyright law and Nova's data protection obligations.

Online Platform Security

Nova uses Zoom Business for all online sessions. The following platform-specific requirements apply:

• Session links must be sent through Nova-authorised communication channels and not via personal accounts.
• Waiting rooms must be enabled so that the tutor admits each participant individually.
• Session links must not be shared publicly or forwarded by families to third parties.
• The session must not be screen-shared to any external platform during delivery.
• Where a tutor suspects that an unauthorised person has joined or is observing a session, they should end the session immediately and contact the DSL.

Online Safeguarding Risks, Awareness

Tutors should be alert to the following online safeguarding risks and report any concern to the DSL:

• Signs that a student is being groomed or exploited online: unusual references to unknown adults, unexpected gifts, or distress before or after device use
• Evidence that a student is being bullied online: distress, withdrawal, or references to online conflict
• Inappropriate content visible in a student's environment during a session
• Any attempt by a student to share inappropriate content during the session
• Any adult other than a parent or carer who appears unexpectedly during an online session

7. DBS Checks & Safer Recruitment

DBS Requirements

Safer Recruitment Practices

Nova applies the following safer recruitment practices to all appointments:

• All candidates complete a structured application (which includes undertaking interviews) and provide a full employment history with no unexplained gaps
• At least two professional references are obtained before appointment, including from the most recent employer or educational institution where the applicant worked with children
• Candidates are interviewed by at least one trained interviewer and assessed against Nova's safer recruitment framework
• Identity verification is conducted before the DBS application is submitted
• Qualifications are verified against original certificates
• All recruitment materials signed will include reference to our commitment to safeguarding and promoting the wellbeing of students
• The DSL reviews all safer recruitment documentation before appointment is confirmed

Single Central Record

Nova maintains a Single Central Record (SCR) of all tutors and staff, recording DBS check dates and certificate numbers, safeguarding training dates, and the date each person signed the Nova Tutor Code of Conduct. The SCR is maintained by the Head of Operations and reviewed by the DSL quarterly.

8. Safeguarding Training

Induction Training

All tutors and staff must complete Nova's safeguarding induction before their first session with any student. The induction covers this policy in full, the categories of abuse and their indicators, the reporting process, online safety requirements, and the identity and contact details of the DSL. Completion of the induction is recorded in the Single Central Record.

DSL Training

The Designated Safeguarding Lead and Deputy DSL(s) must hold safeguarding training at Level 2 or above, delivered by a recognised provider. This training must be refreshed every two years. The DSL must also attend any relevant local authority safeguarding briefings and keep abreast of updates to statutory guidance.

Refresher Training

All tutors and staff are required to complete safeguarding refresher training at least every two years. Where there is a significant update to statutory guidance, or where a safeguarding incident has occurred that requires a policy review, refresher training may be required sooner. The DSL will notify all tutors and staff when refresher training is due.

Awareness of Updates

Nova will communicate any significant updates to safeguarding guidance or this policy to all tutors and staff promptly. Tutors have a responsibility to read and acknowledge any such communications.

9. Confidentiality & Information Sharing

10. Allegations Against Staff or Tutors

Nova takes all allegations against tutors and staff with the utmost seriousness. An allegation may relate to behaviour during a session, outside sessions, or in any other context. The procedure below applies regardless of whether the allegation is made by a student, a parent, another tutor, or any other person.

Definition of an Allegation

An allegation is any concern that a tutor or staff member has:

• Behaved in a way that has harmed, or may have harmed, a child
• Possibly committed a criminal offence against or related to a child
• Behaved towards a child in a way that indicates they may pose a risk of harm to children
• Behaved in a way in their work or personal life that may indicate, or indicates, they may not be suitable to work with children
• Behaved in a manner that discriminates, or may have discriminated, against a child based on one or more of their protected characteristics (e.g., race, disability, gender)

Reporting an Allegation

Where an allegation is made against a tutor or staff member, it must be reported to the DSL immediately. Where the allegation is against the DSL themselves, it must be reported directly to the other most senior member of the leadership team, and, independently, to the LADO.

LADO Referral

Suspension

The DSL will consider whether it is necessary to suspend the tutor or staff member pending investigation. Suspension is a neutral act and does not imply guilt. The welfare of the child is the primary consideration in this decision. Suspension may be lifted if the investigation concludes that the allegation is unfounded, unsubstantiated, or malicious.

Support During Investigation

Nova will provide appropriate support to both the child and the person subject to the allegation throughout the process. The person subject to the allegation will be informed of the concern as soon as possible, subject to any advice from the LADO or police not to do so.

Outcome and Record Keeping

All allegations will be recorded in Nova's confidential safeguarding log regardless of their outcome. Where an allegation is found to be malicious, a separate record will be maintained to protect the tutor's reputation. DBS referral will be considered where the investigation concludes that a person has harmed or posed a risk of harm to a child.

11. Specific Safeguarding Issues

Female Genital Mutilation (FGM)

Prevent, Radicalisation and Extremism

Nova has adopted the Prevent Duty as best practice, in recognition of the risk that children may be vulnerable to radicalisation. Tutors should be alert to:

• A student expressing views that appear to glorify or justify terrorism or extremist ideology
• A student showing signs of sudden withdrawal, change in behaviour, or new associations
• References to online activity that suggest exposure to extremist content

Any such concern should be reported to the DSL, who will determine whether a referral to the Channel programme is appropriate.

Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)

Tutors should be alert to indicators of CSE and CCE as set out in Clause 4. These forms of exploitation are forms of abuse and must be reported to the DSL in the same way as any other safeguarding concern.

Domestic Abuse

Nova recognises that children can be affected by domestic abuse within their household, even where they are not the direct victim. Tutors who observe indicators that a child may be living in a household affected by domestic abuse, including the child's reference to conflict, fear, or injury at home, should report this to the DSL.

Mental Health

Nova is alert to the connection between a child's mental health and their safeguarding. Tutors should be aware that anxiety, low mood, withdrawal, or sudden changes in a student's engagement or presentation may indicate that a child is struggling and may need support beyond the tutorial programme. Such observations should be shared with the DSL.

12. Record Keeping

13. Whistleblowing

14. Policy Review & Governance