Safeguarding Policy

EtonX is an online education company, delivering soft-skills courses to students aged 13 – 20 in the UK and around the world. A typical taught EtonX course lasts seven weeks and involves four different elements:

- - self study tasks;
  - group classes;
  - peer learning tasks; and
  - reflection tasks.

These elements include discussion forums and activity types where students can interact asynchronously. EtonX holds group classes in its own innovative online classroom (“Virtual Classroom”).

EtonX also has self-study versions of its courses which include self study tasks and reflection tasks but no classes or peer learning tasks.

For ease, all versions of EtonX courses will be referred to as the “Course Site”.

1. Introduction

1.1 EtonX recognises its moral and statutory responsibility to safeguard and promote the personal safety and welfare of all children and young people (“students”) who have an EtonX account or are enrolled on an EtonX course. Every employee of EtonX (“staff”), tutor or contractor of EtonX is under regulatory and legal requirement to:

- - protect students from abuse
  - be able to spot early welfare concerns among students and spot students who need additional support
  - be aware of EtonX’s Safeguarding Procedures, to know how to access them and to follow them
  - keep a record of significant conversations, events or incidents pertaining to safeguarding
  - report any concerns to the Designated Safeguarding Lead (DSL).

1.2 This document and its appendices give clear instructions on what you should do if you see or hear anything that indicates to you that a student may be at risk of harm or abuse.
1.3 EtonX staff should always maintain the idea the ‘it could happen here’ attitude where safeguarding is concerned. When dealing with the welfare of a student, all staff should always act in the best interest of the student.
1.4 This policy applies at EtonX and is designed to ensure the welfare of students on all EtonX courses. The policy is reviewed and updated annually or when required by legislative change.

2. Aims of Policy

2.1 This policy applies to EtonX and is designed to:

- - ensure the welfare of all students using the EtonX system whilst they are on the Course Site or in a Virtual Classroom and
  - provide all EtonX staff and tutors with the framework and principles that guide our approach to safeguarding and child protection online.

2.2 Safeguarding legislation and guidance

2.2.1 Our safeguarding policy has been drawn up using legal guidance and frameworks that serve to protect and safeguard children, namely:

- - The Children Acts 1989 and 2004
  - The Education Act 2002
  - Safeguarding Vulnerable Groups Act 2006
  - The Protection of Freedom Act 2012
  - Working Together to Safeguard Children 2018 (WTSC) – statutory guidance
  - What to do if you’re worried a child is being abused 2015 – non-statutory guidance
  - Keeping Children Safe in Education 2020 (KCSIE) – statutory guidance
  - UK Guidance for Child Internet Safety 2016 (UKCCIS)
  - Sexting in Schools and Colleges 2018

2.2.2 This policy also takes into account the policy and practice of The London Borough of Southwark, particularly the safeguarding procedures set up by the Local Safeguarding Children Board (LSCB).

2.2.3 This policy should be read in conjunction with the Terms of Service and Privacy Policy.

2.3 Safeguarding Principles

2.3.1 EtonX is committed to ensuring that:

1. - the safety and welfare of the student is paramount;
  - we cultivate and promote a culture of listening to all students, taking into account their wishes and feelings, both in individual decisions and the development of services;
  - we create an environment where staff and tutors feel able to raise concerns and feel supported in their safeguarding role;
  - all students, whatever their age, culture, gender, language, race, religious belief, sexual identity and ability are able to receive the benefit of learning in a safe online environment;
  - all reasonable steps are taken to protect students from harm, discrimination and abuse;
  - procedures are developed and implemented to monitor, identify and report cases, or suspected cases, of inappropriate behavior by staff and tutors;
  - all staff and tutors who work with students will be recruited with regard to their suitability for that responsibility, and will be given a mandatory induction, receive safeguarding training and guidance to ensure they work within the relevant professional code of conduct and behave in accordance with the EtonX Safeguarding Policy and Procedures;
  - students, parents, teachers, staff and tutors are familiar with what appropriate behaviour constitutes, and ensure they have someone at EtonX they can contact if they feel a tutor or a staff member has not behaved appropriately;
  - we comply with (and ensure compliance for third-party agencies working with EtonX) the necessary data protection obligations set out in the Data Protection Act 1998 and consequently with new GDPR legislation; and
  - all staff are aware of and comply with the Whistleblowing Policy and Procedures (Appendix E).

2.3.2 We acknowledge the procedures set out by the London Borough of Southwark London Safeguarding Children Board (LSCB) and take account of guidance issued by the Department of Education, UK, to:

1. - ensure we have a designated senior person for child protection;
  - ensure all EtonX staff, tutors and contractors know the name of the designated senior person responsible for child protection and their role;
  - ensure all EtonX staff, tutors and contractors are aware of the relevant EtonX Code of Conduct and Safeguarding Policy;
  - ensure that parents, teachers and tutors have an understanding that the responsibility for ensuring child protection is a joint effort and that they play a crucial supporting role in managing and monitoring student and tutor behaviour;
  - develop effective links with relevant agencies and cooperate as required with their enquiries regarding child protection matters;
  - ensure safe recruitment practices are always followed for individuals who EtonX will permit to carry out regulated activity or work regularly with children, including policies on issuing criminal record checks;
  - outline clear policies on how to deal with concerns, allegations and complaints against staff and tutors working with children;
  - use technology to prevent (as far as possible) the sharing of personal details and of inappropriate content on the EtonX platform;
  - monitor and moderate tutor and student activity through an established process; and
  - make it easy for students to report concerns about tutors or other students.

3. The EtonX Safeguarding Team

The Designated Safeguarding Lead (DSL) for EtonX is Alice Vicary-Stott. She is the first point of contact for any safeguarding matter.

Designated Safeguarding Lead	Mobile/Phone Number	Email
Alice Vicary-Stott, Director of Safeguarding and DSL at Eton College	+(44)01753 370822 +(44)01753 370188	A.Vicary-Stott@etoncollege.org.uk Safeguarding@etoncollege.org.uk Safeguarding@etonx.com
EtonX Board Member responsible for Safeguarding Oversight
Tom Arbuthnott, Deputy Head (Partnerships)	+(44)1753 370815	t.arbuthnott@etoncollege.org.uk

4. Policy Details

4.1 Types of Abuse

To protect students from harm both online and offline, we need to understand the different types of behaviour which constitute abuse and neglect and how these apply to both contexts. The definition of child abuse needs to cover any form that children may endure in their lives. Students may be abused in a family, at school, by those known to them or more rarely, by others. Abuse is also increasingly occurring online, via the internet and new technologies. Students can be abused by another student or students or by an adult or adults.

Abuse and neglect are both forms of maltreatment. Abuse can take four main forms:

- - Physical
  - Emotional
  - Sexual
  - Neglect

4.1.1 Physical abuse is a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a student. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a student.

4.1.2 Emotional abuse is the persistent emotional maltreatment of a student such as to cause severe and persistent adverse effects on a student’s emotional development. For example, it may involve telling a student that they are worthless, unloved or inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the student opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on students. These may include interactions that are beyond a student’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the student participating in normal social interaction. It may involve serious bullying (including cyberbullying), causing students frequently to feel frightened or in danger, or the exploitation or corruption of students. Some level of emotional abuse is involved in all types of maltreatment of a student, although it may occur alone.

4.1.3 Sexual abuse involves forcing or enticing a young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the student is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities (which can be performed via the internet), such as involving students in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other students.

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

4.1.4 Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of health or development. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

4.2 Procedure to follow

EtonX follows specific procedures to protect students who are suffering harm or at risk of suffering harm as a result of physical, sexual, and emotional abuse of neglect in accordance with Section 157 of the Education Act 2002.

4.3 Reporting a concern about a student

If you are concerned about a student’s welfare or safety (including, for example, mental health concerns and/or concerns they are abused) you must report this to EtonX’s DSL.

It is the responsibility of any member of staff to report their concerns. It is not their responsibility to investigate whether a student has been abused.

4.3.1 Any member of staff who is concerned about a student’s welfare or safety must:

- - take the situation seriously and act in the interests of the student;
  - make an accurate record of the concern within 24 hours using the Reporting Form, including details of:
    - - what they have observed and when;
      - times when any observations/took place; and
      - what action was or is going to be taken.
  - sign and date the form;
  - clarify the incident/disclosure if necessary;
  - submit the form following the instructions provided on the form; and
  - inform the DSL without delay.

4.3.2 Where a member of staff or a tutor has a concern about a student’s mental health, it may be appropriate for them, in consultation with EtonX’s DSL (and/or Eton College’s), to agree with the student that their parents should be informed so that they can support them.

4.3.3 Where a member of staff or a tutor in particular has a concern about the student being at risk of harm from a parent, it may be appropriate, in consultation with EtonX’s DSL to contact the student’s school to notify them of a concern. This is referred to in the Student Code of Conduct and students are aware that EtonX may contact their school if necessary.

4.3.4 In an emergency, if neither the parents nor the school is contactable, then EtonX will take advice from Eton College’s Director of Safeguarding on the best procedure to follow and may need to contact the emergency contact for the nearest British Embassy.

4.4 Reporting abuse

4.4.1 Any member of staff who is told of any incident or strong suspicion of physical, psychological or sexual student abuse or neglect including attempts (by other students or tutors) to radicalise students to hold extreme political or religious views must report this the same day to the DSL (Alice Vicary-Stott). If the allegations concern a member of EtonX staff or a tutor, the matter must be reported to the DSL immediately. Reports of allegations will be escalated to Tom Arbuthnott (Member of the EtonX Board) where necessary.

4.4.2 Abuse to be reported includes abuse of a student by a member of staff or other adult, abuse at home which a student reports or discloses to a member of staff, abuse by a stranger online, and abuse of a student by another student or a group of students.

4.4.3 Staff, must not investigate reports of abuse themselves. Alleged victims, perpetrators, those reporting abuse and others involved should not be interviewed by staff members beyond the point where it is clear that there is an allegation of abuse. Once a concern has been established, the member of staff dealing with the case shall pass the information on to the DSL who will then take necessary action.

4.4.4 If a student tells you about an allegation of physical, sexual, emotional abuse or neglect you must follow the procedure below (the ‘Six R’s’). You should record in writing all concerns, discussions and decisions (together with reasons) made under these procedures. You should use our Reporting Form (Appendix B) for this purpose. This record should include the date, time and place of the conversation and detail of what was said and done by whom and in whose presence. The record should be signed by the person writing it.

4.4.5 EtonX staff will not promise confidentiality, investigate, ask leading questions or ask the student to repeat the disclosure over and over again.

4.5 What to do if a student makes a disclosure – ‘The Six Rs’

1. Ready?
Someone may want to talk to you at any point. If this involves safeguarding you must be prepared to listen immediately.

2. Receive
The student has chosen you. You are in a position of trust. Listen carefully to what they say. Do not show shock or disbelief. Take it seriously.

3. Reassure
Tell the student that they have done the right thing in talking
Do not make promises you cannot keep (eg. ‘It will be alright now’)
Do not promise confidentiality – you have a duty to refer
Reassure the student that information will only be shared with those who need to know
Alleviate guilt – the student is not to blame

4. Respond
Listen to the student to establish whether you need to refer the matter, but do not interrogate them
Do ask open questions i.e. ‘Is there anything else you want to tell me?’
Do not ask leading questions i.e. ‘Did he/she do X to you?’
Do not criticise the alleged perpetrator
Do not ask the student to repeat the matter to another member of staff
Explain that you will need to talk to the DSL

5. Record
Make brief notes at the time if you can, and write these up as soon as you can
Keep your original notes
Record the date, time, place and the actual words used by the student (if you can)
Record statements and actions rather than your own interpretations

6. Report
Immediately contact the DSL

Write up your notes using the Reporting Form found in Appendix B

The DSL may have to make your record available to Children’s Services

Do not assume another colleague will take responsibility or action. Safeguarding is everybody’s responsibility. If you have any concerns about a student or any suspicions, talk to one of EtonX’s Safeguarding Team immediately. You do not have to wait for proof of your concerns. Do not attempt to investigate the issue yourself

5. Concerns about a student

5.1 Early Help, Student in Need, Student at Risk

Concerns about a student may fall into one or more of several categories, of which the most important are listed below:

5.1.1 Early Help. Some students may benefit from early help. Early help means providing support as soon as a problem emerges at any point in a student’s life. EtonX does not have sufficient contact with students to identify and make Early Help referrals.

5.1.2 A Student in Need. Refers to a student whose circumstances may require them to have extra support in order for them to live a life which does not compromise their ability to fulfil their potential. These students will be referred to the relevant local authority Children’s Services. EtonX may also refer to external agencies for further advice and support.

5.1.3 A Student at Risk – A student who is at risk of significant harm (which may or may not be abuse). Such cases will be referred to the relevant local police authority immediately with the procedures outlined in this policy.

5.1.4 Student at risk of immediate harm – If you believe that a student is in immediate danger or at risk of harm, you should make an immediate referral to children’s social care and/or Police in the relevant local authority in the UK or country if overseas. Anyone can make a referral. Any such referral must be made immediately and in any event within 24 hours of you becoming aware of the risk. You do not need to gain parental consent for referrals to statutory agencies such as the police and children’s social care. If anyone other than the DSL makes a referral, you should inform the DSL as soon as possible that a referral has been made. You can fill in the Reporting Form in Appendix B, detailing the concerns, discussions, decisions made and reasons for those decisions.

5.1.5 EtonX’s Local Safeguarding Children Board (LSCB) is the London Borough of Southwark. A full copy of their local procedures can be found here.

5.1.6 Specific concerns about immediate harm may arise in situations where students are working closely with a tutor, such as one-to-one tutorials.

5.2 Student at risk of radicalisation

5.2.1 We are fully committed to safeguarding and promoting the welfare of all students who have an EtonX account or who are enrolled on EtonX courses. Every member of staff recognises that safeguarding against radicalisation and extremism is no different to safeguarding against any other vulnerability in today’s society.

5.2.2 Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. ‘Extremism’ is defined in the Prevent strategy as vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

5.2.3 Signs of radicalisation: There is no single way of identifying an individual who is likely to be susceptible to extremist ideology. It can happen in many different ways and settings. Background factors may contribute to vulnerability and are often combined with influences such as family, friends or online, and with particular needs for which an extremist or terrorist group may appear to provide an answer. The internet and the use of social media in particular has become a major factor in the radicalisation of young people. As with managing other safeguarding risks, you should be alert to changes in a student’s behaviour which could indicate that they may be in need of help or protection. You should use your professional judgement in identifying students who might be at risk of radicalisation and act proportionately. Such cases may involve a referral to children’s social care in the relevant country depending on the level of risk.

5.2.4 Staff training: The DSL and the Deputy DSL have undertaken Prevent awareness training and are able to provide advice and support to other members of EtonX staff on protecting students from the risk of radicalisation.

5.2.5 Technology: Tutors have the ability to hide and/or edit and delete messages that might pertain to radicalisation within the Virtual Classroom and the Course Site. Students are able to flag comments or posts containing such material. There is also a Report a Concern button in the Virtual Classroom and on the Course Site that students and tutors can use to flag any material that might put students at risk of radicalisation.

5.2.6 Procedures: If you are concerned that a student is being exposed or risks being exposed to radicalisation, the normal referral processes apply. You should discuss your concerns with the DSL who will follow the safeguarding procedures outlined in this policy.

5.3 Peer-on-peer abuse

Peer-on-peer abuse occurs frequently online. Students are reminded of EtonX’s policies on bullying and cyberbullying and sign up to adhere to these policies which govern their behaviour on the EtonX Course Site and in the Virtual Classroom. Peer-on-peer abuse can take many forms, such as inappropriate behaviour between students within their schools or in the Virtual Classroom. Abuse can be physical, emotional or sexual. Emotional and sexual abuse can take place online.

Peer-on-peer abuse can include, but is not limited to the following: bullying, cyberbullying, gender-based violence, homophobic bullying, physical abuse, sexual abuse, radicalisation, extremism, grooming, trafficking and sexual exploitation, sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiating/hazing type violence and rituals; upskirting.

5.3.1 As regular, scheduled group classes form the core of any EtonX course, there is a risk of peer-on-peer abuse. All staff and tutors must be particularly alert to safeguarding students against the risk of peer-on-peer abuse. Abuse that takes place between students can be physical, sexual or emotional in nature and can take place online and offline. EtonX staff should be particularly aware of the online elements of peer-on-peer abuse and the manifestations this can take.

5.3.2 Staff and tutors should be aware that safeguarding issues can manifest themselves via peer-on-peer abuse, especially in the Virtual Classroom or in the discussion forums and certain activity types on the Course Site.

5.3.3 EtonX operates a zero tolerance policy-on-peer abuse, and abuse will not be passed off as ‘banter’, ‘part of growing up’, ‘just a laugh’ or ‘boys being boys’. Students who abuse their peers will be dealt with according to the Student Code of Conduct which outlines acceptable and non-acceptable behaviour. Staff will follow the guidance given in the updated section on peer-on-peer abuse in KCSIE 2020.

5.3.4 In the event of peer-on-peer abuse, staff will reassure all victims that their report will be taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report.

5.3.5 As EtonX might offer courses to students from the same school, staff and tutors must be particularly alert to safeguarding students against the risk of peer-on-peer abuse (including physical) both offline and online as students will have regular contact at school and in the Virtual Classroom.

5.3.6 Sexual abuse online is increasingly common. Staff must take seriously any allegation of sexual misconduct and follow the procedure outlined in this policy if they are made aware of reports sexual violence or sexual harassment.

5.3.7 Procedures: Sharing sexual images of a person under the age of 18 or ‘sexting’ is illegal. Sharing images of child abuse is also illegal. Where there is suspicion that image(s) of child sexual abuse are being shared or viewed within the Virtual Class or the Course Site, the matter should be reported immediately to the DSL. The DSL should report the concern to the Police immediately, taking advice where appropriate. The image might also be reported to the Internet Watch Foundation (www.iwf.org) so that it can contact the relevant law enforcement agency in the relevant country.

5.4 Reporting and responding to incidents of ‘sexting’

5.4.1 All EtonX staff must be trained to spot incidents of ‘sexting’ (also known as ‘youth produced sexual imagery’) as well as know what to do in the event that a ‘sexting’ incident is reported to them by a young person or a tutor.

5.4.2 Sharing photos and videos containing sexual imagery is increasingly common amongst young people. Whilst the EtonX Virtual Classroom and Course Site disallows and prohibits the sharing of files amongst students precaution must be taken to ensure that students do not share personal information with each other in a way that would increase their exposure to ‘sexting’ or ‘youth produced sexual imagery’.

5.4.3 Making, possessing and distributing indecent sexual imagery of anyone under the age of 18 is illegal, regardless of who is disseminating it. The following instances are examples of cases covered by the non-statutory advice in ‘Sexting in Schools and Colleges’ (2018).

- - A person under the age of 18 creates and shares sexual imagery of themselves with a peer under the age of 18
  - A person under the age of 18 shares sexual imagery created by another person under the age of 18 with a peer under the age of 18 or an adult
  - A person under the age of 18 is in possession of sexual imagery created by another person under the age of 18.

5.4.4 If you are alerted to a ‘sexting’ incident, you should …

- - inform the DSL as soon as possible. The DSL will hold a meeting with the relevant people and the young person or people involved might need to be interviewed (if appropriate) and
  - explain to the young person that you need to report it and reassure them that they will receive support and help from the DSL.

5.4.5 If you are alerted to a ‘sexting’ incident, you should not …

- - view, download or share the imagery yourself, or ask a child to share or download – this is illegal. If you have already viewed the imagery by accident (e.g. if a young person has showed it to you before you could ask them not to), report this to the DSL;
  - delete the imagery or ask the young person to delete it;
  - ask the young person(s) who are involved in the incident to disclose information regarding the imagery. This is the responsibility of the DSL;
  - share information about the incident to other members of staff, the young person(s) it involves or their, or other, parents and/or carers; and
  - say or do anything to blame or shame any young people involved.

5.4.6 If it emerges at any point in the process that a young person has been harmed or is at risk of harm a referral must be made to the Police or the Children’s Services immediately.

5.5 Reporting indecent images of children/extreme pornographic images

5.5.1 Viewing or handling indecent images of children or extreme pornographic images will normally be a serious criminal offence. However, Section 46 of the Sexual Offences Act 2003 provides a limited defence for those who can prove that they needed to do so for the purposes of the prevention, detection or investigation of crime.

Where there is suspicion that image(s) of child abuse or extreme pornographic images are being shared or viewed (either in the Virtual Classroom or anywhere in the Course Site) follow the advice below.

5.6 Guidelines for handling illegal material

5.6.1 You should always:

- - restrict student access to the image (either by hiding the comment in the group chat, ending the Virtual Class if it is shared in a live class and temporarily removing student access to the course whilst the image is investigated);
  - report the matter reported immediately to the DSL. The DSL should report the concern to the Police as soon as soon as reasonably practicable, taking advice where appropriate;

If possible, report the image to the Internet Watch Foundation (www.iwf.org) so that it can contact the relevant law enforcement agency in the relevant country.

5.6.2 You should never:

- - view, download or share illegal images of a child;
  - forward illegal images of a child;
  - print out any material for evidence;
  - move any material to a difference device;
  - download or store any material on your own device; or
  - delete the image or ask any young person involved to delete the image.

5.6.3 If viewing the image is unavoidable, or you had seen it by accident, report this to the DSL as soon as possible.

5.6.4 See Appendix C for more information on the legal position and relevant criminal offences relating to online communications. For more information on the law and what constitutes a crime in respect to please click here.

5.7 Safeguarding SEND students

Children with special educational needs and disabilities (SEND) can face additional safeguarding challenges. Additional barriers can exist when recognising abuse or neglect in this group of children.

These can include:

- - assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the student’s disability without further exploration;
  - students with special educational needs and disabilities can be disproportionally impacted by things like bullying – without outwardly showing any signs; and
  - communication barriers and difficulties in overcoming these barriers. You must always be prepared to support SEND students in expressing any concerns they may have and be particularly vigilant to any signs or indicators of abuse, discussing this with the DSL as appropriate.

5.8 Pupil reporting Honour Based Violence (HBV) or Female Genital Mutilation (FGM)

5.8.1 Honour based violence is a general term which includes violence within families such as
forced marriage and female genital mutilation (FGM). If any evidence of such practices within a family comes to light you must report the matter to the DSL immediately.

5.8.2 If you learn that an act of FGM appears to have been carried out on a girl aged under 18, you
have a statutory duty to report it to the police. You should also follow the usual safeguarding
procedures set out in this policy and report the matter to the DSL who will involve the relevant local authority Children’s Services where appropriate. Any member of staff or a tutor who has a suspicion of FGM should report it to the DSL immediately. There is a range of potential indications that a girl may be at risk or has already suffered from FGM. Further information is available on p.23 of Annex A of Keeping Children Safe in Education (2020).

5.9 Dealing with allegations against a student

When an allegation is made against a student (either by a member of staff, tutor or another student), the DSL will discuss the allegation with the Designated Officer (DO) in accordance with the procedures outlined in this policy. We will take advice from the DO on the investigations of such allegations and will take appropriate action to ensure the safety and welfare of all students involved including the student/s accused of abuse. The threshold for dealing with an issue of pupil behaviour under the safeguarding policy is when there is a reasonable cause to suspect that a child is suffering, or likely to suffer, significant harm. If the matter does not reach the LSCB’s threshold for referral or if there is no intervention by the police, EtonX may nonetheless take action in relation to the allegation in accordance with its own relevant Code of Conduct.

6. Concerns about a member of staff or tutor

6.1.1 If you are concerned about the behaviour of another member of staff, you may be concerned about jeopardising their career by reporting it. You must remember, however, that the welfare of the student is paramount. You can always discuss your concerns informally with a member of the Safeguarding Team.

6.1.2 When you report a concern of this nature, you can expect:

- - The concern to be taken seriously.
  - Your identity to remain confidential (if you wish) unless it is required later for you to act as a witness in court proceedings.
  - To be protected as far as possible from victimisation or harassment.
  - For an initial inquiry to take place to identify any action necessary.
  - Children’s Services and the Police to be involved if the concern relates to abuse or neglect or the potential commission of a crime.
  - Written confirmation within the timescales given in the whistle-blowing procedures that your concern has been received and is being dealt with.
  - To be informed of the final outcome, subject to constraints of confidentiality and legal advice.

6.1.3 We have a set of procedures that we will follow if it is believed that a member of staff or tutor has:

- - behaved in a way that has harmed or may have caused harm to a student;
  - possibly committed a criminal offence against or related to a student; or
  - behaved towards a student or students in a way that indicates he or she would pose a risk of harm to students.

6.1.4 Our procedures are in line with Part Four of Keeping Children Safe in Education (2020).

6.2 How to raise a concern about a member of staff or tutor

6.2.1 If you have child protection concerns about the behaviour of a colleague or tutor, or about a company practice which is likely to put students at risk of abuse or other serious harm, you must report it immediately, using one of the steps outlined below:

6.2.2 Allegations against staff/tutors: If you are making an allegation or complaint about any member of staff or tutor, you should report it immediately to the DSL

6.2.3 Any concern about a member of staff or tutor should be raised immediately regardless of how unlikely it seems that there would be any substance to the concern. No further action may be necessary but it is important that such information is brought to EtonX’s attention as soon as possible.

6.2.4 If you feel that EtonX is not dealing with a matter in accordance with their procedures, you should follow the Whistleblowing Procedure (Appendix E).

6.3 What happens when an allegation has been made?

6.3.1 We will deal with any allegation of inappropriate behaviour that harms, or may cause harm to a student, as an immediate priority.

6.3.2 Once an allegation has been made, the DSL will immediately contact the Local Authority Designated Officer (LADO) for Southwark, Eva Simcock, to discuss the situation before any action is taken. All discussions with the LADO will be recorded in writing. We will follow advice from the LADO as to what we may communicate to a) the person about whom the allegation has been made, b) the person who has raised the allegation and (if this is a student) their parents or school.

6.3.3 Records of any allegations of abuse relating to a tutor or a member of staff should be retained until the person has reached normal pension age or for a period of ten years from the date of the allegation if that is longer.

6.4 How an individual will be treated if an allegation is raised against them.

EtonX’s disciplinary procedure may apply in the event of an allegation being made. For more information on disciplinary procedures, please see the EtonX Staff Handbook.

6.5 Whistleblowing Procedure

6.5.1 All staff should feel able to raise any concerns they may have about poor or unsafe practices and potential failures in the safeguarding regime. If you have concerns that the safeguarding team are not dealing with a child protection matter in accordance with the stated procedures and policy, you should raise it under EtonX’s Whistleblowing Policy.

6.5.2 Alternatively, if you feel that your genuine concerns are not being addressed, you may contact the NSPCC whistleblowing advice line (0800 028 0285) or contact the LADO when appropriate to do so in accordance with Keeping Children Safe in Education 2020.

6.5.3 There will be no retribution or disciplinary action taken against you for making such a report provided that it is done in good faith. Malicious allegations may be considered as a disciplinary offence.

6.5.4 For more advice on whistleblowing, please click here.

7. Online Safety

7.1.1 Many of the concerns listed above are increasingly occurring online. As a company operating in the online space and bringing students together using the Internet, EtonX has a specific responsibility to ensure and promote the welfare of all students using its services online. Students are required to have read and agreed to the Terms of Service which outlines how they should use the Course Site and the Virtual Classroom.

7.1.2 Any evidence that a pupil may be at risk online or indeed being harmed online should be brought to the immediate attention of the DSL (staff should, however, not view or forward illegal images of a child). It will then be dealt with as a child protection matter.

7.1.3 There are three categories of risk within online safety that EtonX needs to monitor. These are:

- - content: being exposed to illegal, inappropriate or harmful material;
  - contact: being subjected to harmful online interaction with other users; and
  - conduct: personal online behaviour that increases the likelihood of, or causes, harm.

7.1.4 EtonX has measures in place to ensure that all content students see is regularly monitored and moderated and that students and tutors are guided in the acceptable use of the Course Site and the Virtual Classroom. Students are required to sign up and adhere to Code of Conduct at the beginning of each course which is designed to help raise awareness of safety and proper conduct online.

7.1.5 EtonX has specific measures in place when considering the privacy and safety of its students. All student data is protected and students are not able to find out personal information about each other on the Course Site. We do not share information such as address, location, or date of birth which reduces the risk of students being targeted through interactive situations.

7.1.6 EtonX has specific Codes of Conducts in place for students, tutors and staff. These outline rules and community standards that prohibit behaviour such as threats or harassment of others, etc., whilst promoting the behaviour that we expect from all users of the service when participating in interactive situations. These could be asynchronous (discussion forums, peer learning activities) or synchronous (live chat messaging or talking to peers in the Virtual Classroom).

7.1.7 Any evidence that a student may be at risk online or being harmed online should be bought to the immediate attention of the DSL.

7.2 Mitigating Risk Online

7.2.1 EtonX implements monitoring policies to monitor the three categories of risk referred to above.

7.2.2 The risk mitigation table below lays out the technological and procedural safeguards that EtonX employs to mitigate the potential risk that could occur within the three categories.

Category	Identified Risk	Mitigation Strategy
Content	Offensive language/swearing	– Offensive language and swear words will be blocked from the Virtual Classroom/Course Site. – Ad hoc monitoring of Virtual Classes and Course Site by EtonX staff and tutors.
Content	Illegal image(s) of child abuse/pornography being shared in the Virtual Classroom or on the Course Site	-Procedure in place for both students and tutors to immediately shut down the Virtual Classroom if such an image is shared within the EtonX platform. -There are guidelines in place to ensure that all user-generated content complies with the terms laid out in the Terms of Service and the Code of Conduct.
Content	Students sharing personal contact details	– Blocking strings of numbers in the Virtual Classroom/Course Site – Blocking ‘@hotmail.com’ ‘@gmail.com’ etc. in the Virtual Classroom/Course Site.
Conduct	Peer on peer abuse within the Virtual Classroom and Course Site	– Requiring students to sign up to and follow a Student Code of Conduct that expressly disallows any behaviour that might cause harm to a student or another user.

7.3 Monitoring Policy

7.3.1 EtonX staff and tutors will monitor and moderate courses, discussion forums, user-generated content and live Virtual Classes (all instant messages, shared links and files will also be made available for review) on an ad-hoc basis for the purpose of protecting children as well as ensuring student welfare and progress. If a recording has been made, EtonX will review any sessions where a report has been made by a student or tutor.

7.3.2 All staff and tutors who participate in this activity will have an enhanced DBS check with barred list or equivalent from a different country and will be trained in safeguarding procedures, including spotting grooming and offender behaviours online.

7.4 Monitoring Content

To guarantee an effective and wide-ranging monitoring strategy, EtonX’s monitoring policy covers content that promotes or displays:

- - illegal material (e.g. child abuse images);
  - unjust or discriminatory treatment of students on the grounds of age, culture, gender, language, race, religious belief, sexual identity and ability;
  - cyberbullying;
  - grooming and sexual abuse;
  - terrorism, extremist ideologies, violence or intolerance;
  - deliberate self-harm; and
  - the use of violence or threats intended to hurt or kill.

7.5 Monitoring Procedure

7.5.1 EtonX implements an ‘Active-technology model’ of monitoring for its services. This is a specialist service that actively monitor student and tutor use of the platform through keywords and other indicators.

7.5.2 To mitigate risk, EtonX have procedures in place, which include:

- - human moderation and monitoring of the live Virtual Classes and Course Site, which happens frequently;
  - monitoring at least one live Virtual Class per cohort (a class of students who are doing a course at any one time), a third of discussion forum posts, any peer-learning activities where user-generated content is required and review at least one recording (if available)including the export log containing file uploads and chat for every cohort;
  - a ‘report a concern’ button in the Virtual Classroom and on the Course Site which (based on the severity of the concern will contact the reporter directly to the DSL) allows tutors and students to highlight concerns to EtonX;
  - clear rules around the appropriate use of discussion forums, peer learning activities, and chat box within the Virtual Classroom; and
  - adopting a more robust monitoring process in the event of one-to-one tutorials, for instance, a member of EtonX staff may be required to watch a selection of recorded one-to-one sessions or attend these sessions for the first three months and then reduce this as necessary.

7.6 Retention of Records

7.6.1 To comply with changing data protection laws and GDPR, EtonX will not keep personal sensitive data longer than necessary in order to carry out its monitoring and safeguarding duties. Please refer to the EtonX Privacy Policy for more details.

7.6.2 EtonX keeps recordings of the live group classes six months after the completion of any course. Where a safeguarding incident or concern has been reported, relevant recordings will be retained until after the inquiry has completed. Where an external agency has been involved in investigating the concern, EtonX will ask the agency whether they would like EtonX to retain a copy of the recording and, if so, until when. All recordings remain the property of EtonX.

7.6.3 Child protection concerns about students are retained in EtonX’s retention schedule.

7.6.4 All information relating to students or prospective students (except for information about child protection concerns or information that may be necessary to retain indefinitely – for example, name of child, course dates and certificates) will be retained for a period of one year post the student’s last communication with EtonX. In the case where students have not completed a course with EtonX but have created an account with us or registered their interest, we will keep their information for one year from the last point of contact with EtonX.

8. Management of Safeguarding

EtonX follows rigorous procedures to ensure that the safety and welfare of students is paramount.

8.1 Safer Recruitment

We take our responsibility to recruit staff and tutors who are suitable to work with our students. The first step to safeguarding all students is to appoint staff who share our commitment to the welfare of students.

8.1.2 We undertake a rigorous recruitment and screening process, in line with the procedures laid out in Keeping Children Safe in Education. All members of staff and tutors who manage the recruitment staff are trained in these procedures.

8.1.3 We will take all reasonable measures to:

- - ensure that we practise safer recruitment in checking the suitability of all staff to work with students in accordance with the guidance outlined in Keeping Children Safe in Education. Procedures are outlined in EtonX’s Recruitment Policy.
  - ensure where EtonX ceases to use the services of any person (whether employed or contracted) because that person was considered unsuitable to work with children, a detailed report is made to the Disclosure and Barring Service (DBS) as soon as possible as the person has ceased to provide services to EtonX and in any event of the person leaving the company. Failure to make a report when required constitutes an offence.

8.1.4 The DSL is responsible for ensuring that all members of staff are recruited following the procedures defined in Part 3 of KCSIE (2020). This is done in compliance with EtonX’s Recruitment Policy. The DSL will ensure that the recruitment checks of all employees are retained.

8.1.5 The DSL will ensure that individuals who are engaged in regulated activity with students undergo the appropriate recruitment and criminal record checks as well as other applicable checks, such as prohibition from teaching checks.

8.2 Staff Training

8.2.1 All London-based staff will receive safeguarding training as part of their induction.

- - EtonX staff will be introduced to the Designated Safeguarding Lead (Alice Vicary-Stott) and her Deputy DSL, Kirsty Knell and learn about their roles. Their photographs and contact details will be displayed prominently in the office and on centrally-available staff electronic folders.
  - Staff will also be trained on the EtonX Safeguarding (Child Protection) Policy and procedures; including KCSIE Part One and Annex A (2020) in the form of a training workshop and an interactive quiz.
  - They will be informed about the company Whistleblowing Policy and required to sign the Staff Code of Conduct. They will also be informed about additional policies relating to safeguarding, including the Student Code of Conduct to ensure that they are aware and confident in the use of all procedures relating to safeguarding. Copies/access to all relevant documents will be provided during the induction training.

8.2.2 The DSL will provide an annual update to all London-based staff at the beginning of each academic year; any other necessary updates for staff will take place during the course of the year as required. Staff will understand that full refresher training will take place on a three-yearly basis or more frequently if required by the LSCB. The DSL and Deputy DSL will attend suitable training in child protection every year.

8.2.3 All staff should be particularly careful and vigilant in situations where they are alone with students, especially in the Virtual Classroom.

8.3 Tutor Training

8.3.1 All EtonX tutors will receive safeguarding training as part of a training webinar. This training will include information about how to identify and respond to child protection concerns, information on the Tutor Code of Conduct, EtonX Safeguarding (Child Protection) Policy and procedures and a subsequent test of their knowledge on the training.

8.4 Staff Code of Conduct

8.4.1 The EtonX Staff Code of Conduct sets out the behaviour that we expect from all members of staff. The EtonX Tutor Code of Conduct sets out the behaviour we expect from all external freelance tutors and contractors who undertake ‘regulated activity’ in relation to children.

8.5 Responsibilities of staff members.

You must maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a student, you should always act in the best interests of the student. We all have responsibility for ensuring the welfare of the student, and you must always appropriately share any concerns that you may have about a student.

8.6 Responsibilities of the DSL

The DSL, Alice Vicary-Stott is the designated senior member of staff who takes specific responsibility for student welfare and protection matters for the company.

The main responsibilities of the DSL are:

- - to be the first point of contact for all members of EtonX staff, contractors, students, tutors, teachers, parents in all matters of child protection;
  - facilitating intra-company co-operation dealing with a child protection matter with the DSL taking the lead in the event of an incident;
  - to ensure that all members of EtonX staff understand and have familiarised themselves with the internal and external guidance on child protection and safer recruitment policy and procedures and to offer support, advice and expertise for staff as required;
  - to ensure the appropriate training of all EtonX staff on the contents of this policy and on the procedures that staff should follow. This includes the training of all new staff as part of their induction and updating all staff annually;
  - to ensure that all members of staff have read and understood Part 1 and Annex A of Keeping Children Safe in Education (2020);
  - to advise and act on all reported incidents and where necessary refer or escalate incidents to the local authorities as required;
  - to liaise with the Designated Officer (DO) where appropriate and to maintain a close working relationship with the London Borough of Southwark Local Safeguarding Children Board;
  - to provide an oversight of EtonX’s activities in regards to safeguarding policies and procedures for contribution to each board meeting and to the annual review by the Provost of Eton’s Safeguarding subcommittee;
  - to ensure that EtonX’s Safeguarding Procedures for Staff are followed within the company and monitoring compliance with regulations;
  - to keep detailed and accurate written records of safeguarding concerns or incidents;
  - to monitor the storing, security and confidentiality of data and records relating to child protection in keeping with GDPR legislation; and
  - to monitor the DBS checking process for all staff who come into contact with students.

9. Governance Arrangements for Safeguarding

9.1 EtonX’s Board of Directors is under a series of general duties such as to govern EtonX with reasonable care, skill and diligence, to promote the success of the company and to protect the health and safety or employees or members of the public who may be affected by EtonX’s activities.

9.2 In keeping with the guidance outlined in Chapter 2 of Working Together to Safeguard Children (2015), EtonX has an appointed Tom Arbuthnott, a Board Director, to oversee EtonX’s Safeguarding arrangements and to provide an oversight (annually) of EtonX’s activities in regards to Safeguarding to the P&F at Eton College.

9.3 As a wholly owned subsidiary of Eton College, a charity, the Charity Commission will expect the Board of Trustees of Eton College also to take steps to satisfy itself of this. EtonX’s Board of Directors will report to the Board of Trustees at least annually in relation to safeguarding.

9.4 Serious incidents within EtonX will be reported to Eton College immediately so that a decision can be taken as to whether the College needs to make a Serious Incident Report to the Charity Commission.

9.5 The Safeguarding Policy and Procedure will be reviewed regularly by EtonX to make sure that it remains compliant with current legislation and safeguarding standards.

[1] As per the Children’s Act (1989, 2004), a child/young person is defined as a person under the age of 18.

[2] See ‘Sexting in Schools and Colleges’ (2018) for more information on the new definitions and parameters of ‘sexting’ as well as the ‘Overview of Sexting Guidance’ (2018).

Appendices

Appendix D

Keeping Children Safe in Education (2021).

It is a condition of employment that you read and understand Part 1 and Annex A of the government document Keeping Children Safe in Education (2021). The document may be accessed here.

Appendix E

Whistleblowing Policy and Procedure