Legal

Safeguarding Policy

Last updated: 9 October 2026 · Version: 1.2.1 · Applies to: all Atlas Learning tutors and clients

Primary Safeguarding Lead (PSL): John Pistorius
PSL Email Address: john.pistorius@atlas-learning.co.uk
PSL Contact Telephone: +44 7950 673679

Secondary Safeguarding Lead (SSL): Jacob Waterhouse
SSL Email Address: jacob.waterhouse@atlas-learning.co.uk
SSL Contact Telephone: +44 7490 912621

1. Who we are

Atlas Learning (“Atlas”, “we”, “us”) is a general partnership that provides tutoring and education services, primarily through online one-to-one lessons and activities.

Registered Address: 15 Breydon Gardens, St Helens, England, WA9 5WH. Contact Email: contact@atlas-learning.co.uk

Atlas Learning operates throughout the UK. This policy is principally based on the safeguarding framework applicable in England. Where a student is located in Scotland, Wales or Northern Ireland, Atlas will follow the relevant local safeguarding procedures and authorities for that nation.

2. Purpose

Atlas Learning is committed to protecting the safety, welfare and wellbeing of every student who uses our services.

We recognise that safeguarding is everyone’s responsibility. As an organisation that provides tutoring primarily to children and young people, we have a responsibility to take reasonable and appropriate steps to prevent harm, identify safeguarding concerns, respond appropriately, and cooperate with relevant authorities where necessary.

The purpose of this policy is to:

protect students from harm, abuse, neglect and exploitation;
promote the safety and wellbeing of students;
provide clear procedures for reporting safeguarding concerns;
establish appropriate standards for online tutoring and communication;
ensure that tutors, clients, and anyone involved with a student’s tuition understand their safeguarding responsibilities;
ensure safeguarding concerns are recorded and handled appropriately; and
provide clients, students, and tutors with confidence that Atlas Learning takes safeguarding seriously.

This policy should be read alongside Atlas Learning’s Data Protection Policy, Equality and Accessibility Statement, Client Agreement, Tutor Contract, and any relevant individual tutoring arrangements.

Atlas keeps this policy under review with reference to applicable safeguarding law and guidance, including relevant government guidance for out-of-school settings and online education.

3. Scope

This policy applies to:

Atlas Learning and its representatives;
all tutors providing services through Atlas Learning;
all students receiving tutoring services from Atlas Learning;
all clients, parents, guardians, and anyone else involved with a student;
all online lessons and communications arranged through Atlas Learning; and
any safeguarding concern arising from a person’s involvement with Atlas Learning, including concerns that occur outside a lesson where the concern is relevant to the safety or wellbeing of a student.

Where appropriate, safeguarding principles in this policy may also be applied to adult learners, including where there is a concern that an adult learner may be at risk of abuse, neglect or exploitation.

4. Our Safeguarding Principles

Atlas Learning operates according to the following principles:

4.1 The student’s safety comes first

Student safety and wellbeing take priority over student learning, commercial considerations, or tutoring arrangements. This means that safeguarding concerns should be reported immediately regardless of the effects this may have on a tutoring arrangement.

4.2 Safeguarding is everyone’s responsibility

Safeguarding is not solely the responsibility of Atlas or the Safeguarding Leads. Tutors, clients, Atlas representatives, students, and anyone else involved with a student should raise concerns when they become aware of information that may indicate that a student is at risk.

4.3 Students should be treated with respect

Students should be treated fairly, respectfully and inclusively. Atlas Learning does not tolerate discrimination, bullying, harassment, intimidation, abuse or inappropriate behaviour. A student’s concerns should be taken seriously.

4.4 The child’s voice should be heard

Where appropriate, Atlas will take account of a student’s wishes, feelings and views when responding to a safeguarding concern, while recognising that protecting a student from harm may require information to be shared or action to be taken without their consent.

5. Definition of a Safeguarding Concern

For this policy:

A safeguarding concern is any information, disclosure, allegation, observation, behaviour, or circumstance that gives reason to believe a student may be at risk of harm, abuse, neglect, exploitation, or other circumstances that could adversely affect their safety or wellbeing.

A safeguarding concern does not require proof or certainty that harm has occurred.

Examples include, but are not limited to:

physical, emotional, psychological, or sexual abuse;
neglect;
bullying or serious harassment;
discrimination;
domestic abuse affecting a student;
grooming or inappropriate relationships with students;
inappropriate sexualised behaviour;
inappropriate or unauthorised communications with students;
inappropriate requests for photographs, videos or personal information;
threats, intimidation or coercion;
self-harm or a serious risk of harm to the student;
exploitation, including criminal or sexual exploitation;
radicalisation or concerns relating to extremist influence;
serious online safety concerns;
a student being exposed to inappropriate or harmful online content;
concerns about a tutor or other adult working with students; or
any other circumstance in which a student may be at risk of harm.

The list above is not exhaustive.

6. Safeguarding Leads

Atlas Learning will appoint a Primary Safeguarding Lead (PSL) who has primary responsibility for safeguarding within the organisation.

The PSL will:

act as the main point of contact for safeguarding concerns;
verify DBS checks, professional references, and other identification documents before tutors are allowed to provide tutoring services;
assess safeguarding concerns and determine the appropriate next steps;
maintain Atlas Learning’s safeguarding records;
make referrals to children’s social care, the police, the Disclosure and Barring Service, or other relevant authorities where appropriate;
maintain appropriate confidentiality and information-sharing arrangements;
ensure that tutors and clients understand their safeguarding responsibilities;
ensure that appropriate safeguarding training and guidance are provided to tutors;
review the safeguarding policy and procedures regularly; and
maintain awareness of relevant safeguarding guidance and changes to legislation.

Atlas Learning will also appoint a Secondary Safeguarding Lead (SSL). The SSL may undertake the PSL’s responsibilities where the PSL is unavailable or where it would be inappropriate for the PSL to manage a particular concern.

7. Reporting Safeguarding Concerns

Anyone can and should report safeguarding concerns, including tutors, students, clients, Atlas representatives, or anyone else involved with a student.

Safeguarding concerns should be reported immediately, regardless of the effects this may have on a tutoring arrangement. A person should not attempt to obtain additional evidence, investigate the situation, or conduct their own enquiries before reporting a safeguarding concern.

Safeguarding concerns should normally be reported to the PSL named at the beginning of this policy. If a safeguarding concern relates to the PSL, the PSL is unavailable, or it would otherwise be inappropriate for the PSL to handle it, report the concern to the SSL.

Where appropriate, safeguarding concerns should also be reported directly to the relevant safeguarding authorities.

Reports should contain factual information wherever possible, including what was seen, heard or disclosed, when it occurred, and who was involved. A person reporting a concern should clearly distinguish between facts and their own assumptions or opinions.

8. Immediate Danger or Emergencies

If a student appears to be in immediate danger or there is an immediate risk of serious harm, the priority is to obtain emergency assistance first.

In England:

999 should be contacted where there is an immediate danger or emergency;
101 may be used for non-emergency police matters; and
the relevant local authority children’s social care service should be contacted where appropriate.

For students in Scotland, Wales or Northern Ireland, the relevant local emergency, police and child protection services should be contacted in accordance with local procedures.

Do not delay a safeguarding concern because Atlas Learning has not yet been contacted.

Once the relevant emergency services or safeguarding authority has been contacted, Atlas Learning should be informed as soon as reasonably practicable, where appropriate and safe to do so.

9. Students

Students may raise a safeguarding concern with:

the PSL or SSL;
their tutor;
Atlas Learning;
a parent or guardian;
another trusted adult; or
the police or children’s social care where appropriate.

Students should be encouraged to report anything that makes them feel unsafe, uncomfortable or concerned.

Students should not be discouraged from reporting a concern because they are uncertain whether it is serious enough. Atlas will assess the concern appropriately.

10. Responding to Disclosures

Where a student discloses information that may indicate abuse or harm, the person receiving the disclosure should:

Do:

listen carefully;
remain calm;
take the student seriously;
allow the student to use their own words and take their time;
acknowledge that speaking up was appropriate;
explain that information may need to be shared to keep them safe;
record the information accurately, using the student’s own words where relevant; and
report the concern immediately.

Do not:

promise secrecy;
investigate the allegation;
ask unnecessary or leading questions;
suggest answers;
confront the alleged perpetrator;
attempt to determine whether the allegation is true;
express personal opinions about the alleged perpetrator;
make assumptions about what happened; or
delay reporting because the information appears uncertain.

The purpose of the initial response is to safeguard the student and pass accurate information to the appropriate person or authority.

11. Low-level Concerns

Atlas Learning recognises that behaviour which does not immediately meet the threshold for a formal safeguarding concern may nevertheless indicate a developing concern.

Examples may include:

inappropriate jokes or comments;
unnecessary attempts to communicate with a student outside approved channels;
excessive personal disclosure by a tutor;
inappropriate familiarity;
minor boundary concerns;
inappropriate use of social media;
behaviour that makes a student uncomfortable; or
repeated failure to follow safeguarding procedures.

Low-level concerns should still be reported to Atlas.

The PSL will determine whether further action, monitoring, advice, restrictions, training, or referral is appropriate.

A pattern of low-level concerns may become more significant when considered alongside other information.

12. Safeguarding Procedures

Atlas has procedures in place to help protect students from potential harm. Some of them are highlighted here.

12.1 Student Registration Limitations

Students can register an enquiry for tutoring on our website but do not have contact with a tutor until someone aged 18 or over agrees to be legally and financially responsible for their tuition. This may be a parent, guardian, or family member, whom we refer to as the client.

The client must formally register and sign the Client Agreement before the student can have any lessons. Clients may authorise other people of legal age to make some decisions regarding the student’s tuition. We call these trusted people authorised clients.

Students aged 18 or older are considered adult learners and can register for tutoring themselves. In this case, they also act as the client and must sign the Client Agreement.

12.2 Trial Lessons

Atlas offers free trial lessons with tutors before any formal registration.

The purpose of a trial lesson is for the student and client to:

meet the tutor;
ensure they approve of the tutor’s teaching style;
address any doubts or uncertainty; and
ask any questions.

Atlas’s safeguarding requirements apply to trial lessons. A trial lesson is not an exception to the requirement for appropriate tutor checks or professional boundaries.

13. Tutor Suitability

Atlas Learning requires tutors to provide evidence of an appropriate Enhanced DBS check before they can start tutoring. Where the role and applicable law permit or require a Children’s Barred List check, Atlas will require the appropriate level of check.

DBS certificates do not have an expiry date. Atlas may require tutors to provide updated evidence or complete further checks at intervals it considers appropriate, including where there is a change in circumstances or role.

Tutors must notify Atlas promptly of any criminal investigation, charge, conviction, caution, safeguarding concern, or other circumstance that may affect their suitability to work with children, to the extent that they are legally permitted and required to do so.

Atlas recognises that a DBS check is only one part of safer recruitment and does not, by itself, establish that an individual is suitable to work with children.

Atlas will therefore also consider:

identity;
qualifications;
relevant experience;
references;
employment or education history;
interview information;
safeguarding knowledge and training;
professional conduct; and
any other information reasonably relevant to suitability.

Atlas may refuse, suspend, restrict, or terminate a tutor’s provision of services where safeguarding information gives reasonable cause for concern, subject to applicable contractual and legal requirements.

14. Tutor Safeguarding Responsibilities

Every Atlas tutor is expected to:

prioritise the safety and wellbeing of students;
maintain appropriate professional boundaries;
communicate with students and clients professionally and respectfully;
use professional and inclusive language;
make reasonable accommodations for students’ individual needs;
complete any safeguarding training required by Atlas;
report safeguarding concerns immediately;
maintain appropriate confidentiality;
use Atlas-approved communication channels;
avoid unnecessary private communication with students;
avoid connecting with students through personal social media accounts;
never request inappropriate personal information, photographs or videos from students;
never engage in sexualised or inappropriate conversations with students;
never arrange inappropriate private meetings with students;
never offer inappropriate gifts, money or personal services to students;
never encourage students to conceal communications or interactions from their parents, guardians or Atlas;
never attempt to establish an inappropriate personal relationship with a student; and
comply with this policy and all relevant Atlas Learning policies and contractual requirements.

Tutors should also take reasonable steps to maintain a safe and professional online teaching environment, including protecting lesson links, files and shared resources from unauthorised access.

15. Client Safeguarding Responsibilities

Clients retain responsibility for taking reasonable precautions to support the student’s safety and wellbeing in the student’s home and online environment. This does not remove or reduce Atlas Learning’s own safeguarding responsibilities.

Client responsibilities include, but are not limited to:

ensuring the student is aware of Atlas’s safeguarding policy and how to raise concerns;
ensuring the student knows how to contact appropriate authorities, emergency services, or other sources of help where appropriate;
ensuring the student’s physical environment is safe and appropriate, including any technological devices, resources, or equipment that the student may use;
ensuring the student’s online environment is safe and appropriate, including the documents, images, videos, links, or other content they may see or hear; and
where appropriate, being present or available during lessons to report concerns as soon as possible and ensure lessons are progressing appropriately and effectively for the student’s learning.

Clients should report safeguarding concerns to Atlas and, where appropriate, the relevant authorities immediately.

16. Professional Boundaries and Communication

Atlas Learning’s tutoring model is primarily online and one-to-one. Maintaining clear professional boundaries is therefore particularly important.

Tutors must use the communication platforms and methods authorised by Atlas Learning.

A tutor must not communicate privately with a student outside Atlas-approved platforms unless Atlas Learning and the client have expressly authorised it in writing.

This includes, but is not limited to:

telephone numbers;
personal email addresses;
social media accounts;
messaging applications; and
other private communication services.

Any safeguarding emergency takes priority over normal communication arrangements.

Tutors must not encourage students to move conversations to private or unmonitored platforms.

Where a student attempts to establish inappropriate private communication, the tutor should end the communication appropriately and report the matter to Atlas.

17. Online Safety

Atlas Learning recognises that online tutoring presents particular safeguarding risks.

Tutors must:

conduct lessons using appropriate equipment and professional surroundings;
ensure that their behaviour and appearance remain professional;
avoid exposing students to inappropriate material;
avoid sharing inappropriate websites, images, videos or other content;
take reasonable steps to prevent unauthorised individuals from participating in lessons;
maintain professional boundaries when using screen sharing or file sharing;
report inappropriate online behaviour or content;
report attempts by students or others to obtain inappropriate personal information; and
report any suspected grooming, exploitation or inappropriate online relationship.

Students should not be encouraged to share personal information unnecessarily.

Atlas Learning will consider online safety when selecting and using digital platforms and will take reasonable steps to protect students’ personal information and access to lessons.

18. Student Wellbeing

Safeguarding includes consideration of a student’s wider wellbeing.

Tutors should remain alert to significant changes in a student’s behaviour or presentation that may indicate that the student is experiencing difficulties.

Tutors are not expected to diagnose mental health conditions or provide counselling.

If a tutor is concerned about a student’s wellbeing or believes there may be a risk of harm, they should report the concern to Atlas in accordance with this policy.

If there is an immediate risk of serious harm, follow emergency procedures.

Safeguarding considerations apply whenever a lesson is scheduled, including when a student fails to attend.

Tutors should report unusual or concerning circumstances surrounding attendance where they believe these may indicate a safeguarding issue.

For example, a tutor should consider reporting circumstances where:

a student unexpectedly reports being alone when they would normally have adult supervision;
another person appears to be controlling or monitoring the lesson in a concerning manner;
a student appears distressed or frightened;
a student repeatedly attempts to communicate something concerning immediately before or after lessons; or
a pattern of attendance or cancellation creates a reasonable safeguarding concern.

Normal attendance issues do not automatically constitute safeguarding concerns.

19. Equality, Inclusion, and Additional Needs

Atlas Learning is committed to providing an inclusive tutoring environment.

Students should be treated fairly and with respect regardless of disability, race, ethnicity, nationality, religion or belief, sex, sexual orientation, gender reassignment, age or any other protected characteristic.

Tutors should make reasonable accommodations for students’ individual needs where appropriate and should raise concerns with Atlas where they believe a student’s needs cannot safely or appropriately be met through the existing tutoring arrangement.

Safeguarding concerns relating to discrimination, bullying, harassment or abuse should be reported in accordance with this policy.

20. Lesson Recording

Clients may request to record lessons for safeguarding purposes. This request must be made in writing and state the recording method: video, audio, or both.

Both the client and the tutor must give express written consent before lessons are recorded by the client using any method. The student should also be informed in an age-appropriate manner where appropriate.

If the tutor consents to lessons being recorded, the client may record future lessons using the agreed method, subject to any conditions agreed by Atlas, the client and the tutor.

Clients are responsible for the recording files they create and should handle them lawfully and securely, including in accordance with applicable data protection law where it applies. Clients must not share recording files with any unauthorised person.

If any recording files are shared, lost, disclosed, or accessed by an unauthorised person, Atlas Learning should be notified as soon as the client becomes aware of it.

If the tutor does not consent to lessons being recorded, the client may request a different tutor. The client may not record lessons unless the tutor has given the required consent.

Atlas Learning may impose additional restrictions on recording where necessary to protect students, tutors, or personal data.

21. Data Protection

Atlas Learning recognises that safeguarding information may contain sensitive personal information and, in some circumstances, special category personal data.

Personal information relating to students must be:

collected only where reasonably necessary;
stored securely;
accessed only by authorised individuals;
shared only where there is an appropriate lawful basis;
handled in accordance with applicable data protection law; and
securely deleted in accordance with Atlas Learning’s retention procedures.

Atlas will apply data protection principles including data minimisation, purpose limitation, security, accuracy and appropriate retention.

Safeguarding concerns may involve sensitive or confidential information. Confidentiality does not prevent sharing information where necessary to protect a child or where disclosure is otherwise required or permitted by law.

Where a safeguarding concern requires sharing information with children’s social care, the police, the Disclosure and Barring Service, or another appropriate authority, Atlas Learning will share only information that is reasonably necessary and appropriate for the safeguarding purpose.

Atlas will consider the best interests and safety of children when making decisions about the use and sharing of their personal information.

Please see Atlas Learning’s Privacy Policy and Data Protection Policy for further information.

Atlas Learning recognises that effective safeguarding may require sharing information with other organisations.

Information may be shared with, where appropriate:

clients;
parents or guardians;
children’s social care;
the police;
the Disclosure and Barring Service;
schools or colleges where appropriate and lawful;
healthcare professionals; or
other relevant organisations or authorities.

Atlas Learning will consider the student’s safety, wellbeing and best interests when making information-sharing decisions.

Where there is a lawful safeguarding basis to share information, Atlas Learning will not delay necessary safeguarding action solely because consent has not been obtained.

Where possible and appropriate, Atlas Learning will inform the relevant parent or guardian that information is being shared. However, this may not be appropriate where doing so could increase the risk to the student, compromise an investigation, or otherwise be contrary to safeguarding advice.

Information will be shared securely and only with the people or organisations who need it for the relevant safeguarding purpose.

23. Safeguarding Records

Atlas Learning will maintain appropriate records of safeguarding concerns.

Records should include, where relevant:

the date and time of the concern;
the name of the student;
the name of the person raising the concern;
the name of the person receiving the concern;
the nature of the concern;
the exact words used by the student where relevant;
factual observations;
actions taken;
people or organisations contacted;
the date and time of referrals;
decisions made;
the reasons for significant decisions; and
the outcome where known.

Safeguarding records will be stored securely and access will be restricted to authorised individuals. Records will be retained and securely deleted in accordance with Atlas Learning’s data retention requirements and applicable law.

24. Allegations or Concerns About Tutors and Other Adults

Atlas Learning will take concerns or allegations about tutors, Atlas representatives, or other adults involved in providing services seriously.

Where a concern indicates that an adult may have:

harmed a child;
behaved in a way that may have harmed a child;
possibly committed a criminal offence against or related to a child; or
behaved towards a child in a way that indicates they may pose a risk of harm,

Atlas may take immediate protective measures, which may include suspending or restricting the individual’s tutoring activity while the concern is assessed.

Atlas will make referrals to the police, children’s social care, the relevant local safeguarding authority, the Disclosure and Barring Service, or another appropriate body where required or appropriate.

Where applicable, Atlas will seek advice from the relevant Local Authority Designated Officer (LADO) or equivalent safeguarding authority regarding allegations concerning adults who work with children.

Atlas will not investigate in a way that could interfere with a police or safeguarding investigation. Any internal review will be carried out proportionately and in accordance with relevant contractual, employment and data protection requirements.

25. DBS Referrals

Where Atlas Learning removes a person from regulated activity with children because the person has harmed a child or poses a risk of harm, Atlas Learning will consider whether it has a legal duty to make a referral to the Disclosure and Barring Service.

Where the statutory conditions for a DBS referral are met, Atlas Learning will make the referral in accordance with the applicable requirements.

Atlas will retain appropriate records of the decision and action taken.

26. External Safeguarding Contacts

Emergency:

Police, fire and ambulance: 999
Police non-emergency: 101

For a child in England:

Contact the children’s social care service of the local authority where the child lives.
If you do not know the correct local authority, use the GOV.UK “Find your local council” service.

For children in Scotland, Wales or Northern Ireland:

Contact the relevant local child protection or social services authority for the area in which the child lives.
Use the relevant national government guidance and local safeguarding arrangements.

Other support:

Childline: 0800 1111
NSPCC Helpline: 0808 800 5000
CEOP: use the National Crime Agency CEOP Safety Centre to report concerns about online child sexual abuse or exploitation.

These contacts do not replace emergency services. Where there is an immediate risk of serious harm, call 999 first.

27. Policy Review

This policy will be reviewed at least annually and sooner where necessary.

A review will be undertaken following:

significant safeguarding incidents;
changes to safeguarding legislation or government guidance;
changes to Atlas Learning’s tutoring model;
changes to the technology or platforms used by Atlas Learning;
changes to the types of students receiving services;
significant changes to the organisation; or
lessons identified from safeguarding incidents or concerns.

The PSL is responsible for ensuring that this policy remains appropriate for Atlas Learning’s services.

28. Statement of Commitment

At Atlas Learning, we believe that students learn best when they feel safe, respected, valued and supported.

Safeguarding is therefore central to the way we operate. We are committed to maintaining clear professional boundaries, recruiting and working with suitable tutors, providing appropriate safeguarding training, responding promptly to concerns, protecting personal information, and cooperating with parents, guardians and relevant authorities where necessary.

We will take every concern seriously, and the safety and wellbeing of students will remain at the centre of our safeguarding decisions.

Atlas Learning is committed to creating a tutoring environment in which every student can learn safely and with confidence.