Safeguarding Policy

Last updated 23 October 2026

Document details
Owner Designated Safeguarding Lead (Adrian Angol-Henry)
Who it applies to Everyone who works or volunteers with NSEMM, and pupils and families
Approved by Adrian Angol-Henry (DSL and trustee) and Socks Ansell (trustee), 23/10/2026, under the decision of the first AGM; reported to all trustees at the next trustee meeting
Version 1.0
Date 23/10/2026
Next review October 2027, or sooner if the law or guidance changes

Parts A, B and D are on this page. Part C, the leads' procedures, is on a separate restricted page for the safeguarding leads and the trustees: Safeguarding Policy: leads' procedures.


Part A. Audience: Everyone

A1. About this policy

This policy sets out how NSEMM keeps safe the children, young people and adults at risk who use our services.

Who it applies to

  • Our trustees, employees, volunteers and contractors, and anyone acting for NSEMM.
  • Partner organisations and outside professionals who use our safeguarding systems.

What we do

  • The National Society for Education, Mentoring and Media (NSEMM) is a registered charity, number 1209673.
  • We teach young people in Year 5 to Year 13 in England, one to one or in small groups, alongside school (A12).
  • Our lessons are online. Any session held in person follows B8.

Who this policy protects

  • A child is anyone under 18.
  • Students aged 18 or over are adults. We call them young adults.
  • An adult at risk is an adult who needs care and support, is being abused or neglected or is at risk of it, and can't protect themselves because of their needs.
  • Safeguarding means protecting children from maltreatment, including online, preventing harm to their health or development, making sure they grow up with safe and effective care, helping as soon as problems emerge, and enabling all children to have the best outcomes.

These meanings come from the law and guidance in D1.

Students who may be more vulnerable. Many of our students may be more vulnerable because of their age, circumstances or support needs, for example family difficulties or trauma, being socially isolated, having English as an additional language, or academic stress. A4 lists other children who may need extra care.

Other policies

A2. Who to contact

If a child is in immediate danger, call 999.

Our safeguarding team

Role Name Email
Designated Safeguarding Lead (DSL) Adrian Angol-Henry, Chief Executive Officer [email protected]
Deputy DSL Socks Ansell, Chief Operations Officer and Chief Education Officer [email protected]
Lead Trustee for Safeguarding Amelia Hutton [email protected]

If your concern is about the DSL or the Deputy, follow A6.

Other contacts

For Contact
Report a concern (anyone, 24 hours a day, you can stay anonymous) protect.nsemm.org.uk/report-concern
Allegations against staff or volunteers: Nottingham City Council LADO 0115 876 5166
Police (non-emergency) 101
NHS (non-emergency) 111
Anything else nsemm.org.uk/contact

More helplines are in D2.

Amelia Hutton is not the DSL.

A3. How we work

  • If there is a conflict between a child's safety and anything else, the child's safety always wins. That includes what a parent wants, what is easier for us, and how it looks for NSEMM.
  • If you are worried, report it. Don't assume someone else has.
  • We act on small worries early, before they become big ones.
  • We listen to what children tell us and take it into account.
  • We ask questions when something doesn't add up.
  • Every child gets the same protection, whatever their culture, language or religion.
  • We check whether race, disability, gender, religion or anything else is affecting the harm a child faces or the help they get.
  • We write down what we decide and why.

A4. Recognising abuse

Abuse can happen online or in person, by adults or by other children, and a child can be going through more than one kind at once. These are the kinds of harm to watch for. The signs are in B7.

It can happen here. The biggest risk is thinking it couldn't: that a tutor we know, a volunteer we like, or a small charity like ours is the exception. We don't rule anyone out, and a concern about someone we trust is reported like any other.

Where it happens What to watch for
In NSEMM a tutor, volunteer or member of staff harming a child, or crossing boundaries: contact outside our systems, gifts, secrets, favouritism, or meeting up
At home physical, emotional or sexual abuse; neglect; domestic abuse, including in a young person's own relationship; so-called "honour-based" abuse, female genital mutilation and forced marriage
From other children bullying, including online and prejudice-based bullying (picking on someone for their race, religion, disability, sex or sexuality); sexual harassment and sexual violence; misogyny and violence against women and girls; sharing nudes or semi-nudes, including AI-made ones; upskirting (taking a photo up someone's clothes); initiation or hazing (humiliating "joining" rituals)
Outside the home criminal and sexual exploitation, including county lines; modern slavery and trafficking; serious violence; radicalisation; an adult the child doesn't know approaching them or trying to take them away
Online online abuse and grooming; being asked for nude images; harmful content, misinformation and conspiracy theories; deepfakes (fake images or videos made with AI); sextortion (being blackmailed over sexual images, often for money); being drawn into hacking, fraud or other cybercrime
The child's own wellbeing mental health problems, self-harm and suicidal thoughts
School and going missing being missing from education, often absent, home educated or in alternative provision (taught somewhere other than a school); running away or going missing from home
Children who may need extra care children with special educational needs, disabilities or health conditions; children with a social worker; children in care, children who used to be in care, and care leavers; young carers (children who look after someone at home); children who are lesbian, gay or bisexual, or questioning their gender, who are more likely to be bullied; a family that has lost or may lose its home; a parent or other family member in prison; a child going through the courts (giving evidence, or in family proceedings); a child under 16 (under 18 if disabled) living for 28 days or more with someone who is not a parent or close relative (private fostering)

Report abuse by another child like any other concern, even when it looks like banter.

A5. How to report a concern

If you are worried about a child, report it in the time set in B1. Don't wait until you are sure, and don't investigate it yourself.

If a child is in immediate danger, call 999 first. You don't need anyone's permission. Then report it to us when it is safe.

Way to report Where Use it for
Protect form protect.nsemm.org.uk/report-concern Any concern, day or night
Report Concern button NSEMM Learn Any concern (it opens the Protect form)
Email the DSL [email protected], or the Deputy if the DSL is away Urgent or complicated concerns
Tell a member of staff In person, on a call or in a lesson Any concern (they must pass it on, B1)

The Protect form needs no account and works on a phone. You can stay anonymous. It starts with emergency numbers, has a Quick Exit button, gives you a reference number and tells the DSL straight away.

Anyone can report: pupils, parents and carers, staff, volunteers, schools, other professionals and the public. If you stay anonymous we still act, but giving your name helps us follow up.

If the Protect form isn't working, the safeguarding page shows our phone numbers and a short backup form. The DSL and the Deputy get an email and a text straight away, with no personal details in it. A concern about the DSL or the Deputy follows A6.

Nobody at NSEMM is allowed to stop, delay or put off someone who wants to report a concern. Doing so can be a crime. If it happens, report that too.

You can also go straight to children's social care or the police at any time. Please tell us if you do, so we have it on our records.

A6. Concerns about staff, volunteers, the DSL or the Deputy

If you are worried about how anyone working or volunteering for NSEMM behaves towards a child, report it the same way (A5). We refer allegations to the LADO (C2).

If the concern is about the DSL or the Deputy, don't send it to them. Tell the LADO first (Nottingham City Council, 0115 876 5166) and give them the details. Then email [email protected] to say only that you have a concern and that the LADO has it. Every trustee sees that inbox, so nothing is missed if one person is away, and Amelia Hutton, our Lead Trustee for Safeguarding, deals with it.

Protect also sends any concern that names the DSL or the Deputy away from them, so nobody handles a concern about themselves.

A7. What happens after you report

  1. The DSL is told straight away. If a child is in immediate danger, they get an urgent alert, day or night.
  2. If you gave contact details, you get a confirmation with your reference number.
  3. Protect marks how urgent the concern is, so the most urgent are dealt with first. The DSL can change this.
  4. The DSL decides what to do: open a case, add it to an existing case, ask for more information, refer it to another agency, or take no further action. The reason is always recorded.
  5. We keep you updated as far as we safely can.

The DSL checks new concerns every day, including weekends and bank holidays. Urgent concerns get a reply the same day, and others within 5 working days.

Records are kept in NSEMM Protect, a separate system that only the DSL and the Deputy have full access to. Nobody can delete or write over a record. If a record is changed, the original stays, so we can always see what was changed, by whom and when. We don't use AI on Protect records, and we only share them to safeguard and protect children (A8).

A8. Sharing information

If you need to share information to keep a child safe, share it. Data protection law does not stop you.

  • Ask the family for consent first, unless asking would put the child at more risk. Share without consent if the child is in immediate danger or at risk of significant harm, if the law requires it (for example a court order), or to prevent a crime or protect the public.
  • Share only what is needed, only with the people who need it, and make sure it is accurate, on time and sent securely.
  • Tell the family what was shared and why, unless that would put the child at risk.
  • If a council, school or the police asks us for information to keep a child safe, we give it, unless that would put the child at more risk.
  • Only the DSL or the Deputy shares safeguarding information outside NSEMM, except in an emergency (call 999) or where B1 tells you to go to the police yourself.
  • If you are not sure, ask the DSL straight away.
  • Record it in Protect: what was shared, with whom, when and why.

Our legal basis. We share safeguarding information under UK GDPR Article 6(1)(f) (legitimate interests), or Article 6(1)(c) where the law requires it, and Article 6(1)(d) in an emergency. For sensitive information we also rely on Article 9(2)(g) and the Data Protection Act 2018, Schedule 1, Part 2, paragraph 18 (safeguarding of children and of individuals at risk). This lets us share without consent when that is the right thing to do. The Children Act 2004, section 16LA, applies to our work for schools, and we follow it for all our work.

We share with families, schools, health services, children's social care, the police, the LADO, the NSPCC, other charities and the Charity Commission, following Working Together to Safeguard Children, the DfE's Information Sharing Duty guidance and the ICO's guide to sharing information to safeguard children.

A9. Online lessons

Where and how

  • Online lessons take place in NSEMM's online classroom. Tutors and pupils use only its own video, audio and chat.
  • In one-to-one lessons, the tutor and the pupil keep their cameras on. In group lessons, pupils keep their cameras off and the tutor's stays on.
  • The pupil should be in a shared part of the home, with a parent or carer aware. Bedrooms are best avoided.

Contact

  • Tutors don't swap personal contact details (phone, social media or personal email) with pupils or parents, and don't contact pupils through personal social media.
  • Any contact between lessons goes through NSEMM's own messages or the parent's email address registered with us.
  • This applies while the tutor teaches the pupil, and afterwards while the pupil is under 18.

Language

  • Lessons are taught mainly in English, so that our safeguarding team can understand and check every recorded lesson.
    • A tutor may use another language briefly to explain something if it helps the pupil learn, for example a word in a pupil's home language.
    • A lesson in a modern foreign language is taught in English and that language.
    • An interpreter, including a BSL interpreter, can join if we agree it beforehand. The lesson is still recorded.

Online safety

  • Our online classroom is set up to block harmful content, and our other systems filter content to suit pupils' ages.
  • We can't control filtering at home, so we give parents guidance on internet safety.
  • Images uploaded to our systems are checked automatically for harmful content. Messages are not.

Before the first lesson, a parent or carer accepts our tutoring agreement, gives emergency contacts, and is told in writing that lessons are recorded and how we use information (our Privacy Notice).

A10. Recording

We record every online lesson. This protects pupils and tutors, means no tutor is ever alone and unrecorded with a pupil, and helps us check the quality of teaching. We only teach recorded lessons.

  • Why we can. We record because it is in our legitimate interests and the pupil's. A recording that becomes evidence of a safeguarding concern is kept as a safeguarding record. The legal basis is in D1.
  • Who can watch. The lesson's own tutor, the pupil and their parent or carer. The pupil and parent can watch it for 7 days after the lesson.
    • Our admin, leadership and safeguarding staff (the DSL and Deputies) can also watch it, for safeguarding, training and lesson audits (C5).
    • Every time a recording is opened, it is logged.
  • How long. Each recording is deleted 90 days after the lesson, unless it is linked to a safeguarding concern. The full periods are in the Data and Privacy Policy, Annex (rows F7 and S1).
  • Your rights. Families keep their normal data rights over recordings, as our Privacy Notice explains.

A11. Missed lessons

Missing lessons can be a warning sign of harm, including sexual abuse, sexual exploitation and child criminal exploitation. Most missed lessons are about money, time or practical problems, so when a pupil misses a lesson we check in with the family to make sure they're OK.

We count a lesson as missed only when the miss was on the pupil's or family's side: a family no-show, a family cancellation with no reason, or a lesson the DSL or Deputy has flagged as unexplained. We never count a lesson the tutor missed, or one lost to a problem on the tutor's side or with our systems. The full list is in C7.

Stage When What happens
1 The first missed lesson The tutor records it and tries to contact the family
2 Two missed lessons in a row A member of staff contacts the parent or carer within 24 hours to understand why and offer support
3 Three or more missed lessons in 30 days The DSL reviews the pattern and completes a risk assessment, telling the school where that applies
4 When the DSL decides A referral to the local authority, only where we believe a child isn't getting a suitable education, or isn't attending because of a welfare, child protection or safeguarding concern

We also look out for lessons missed around particular topics or times, and sudden changes in a pupil who used to be reliable.

This count is about the child's welfare. If a family has a funded place, the CEF Access Policy, section 10.3a, counts missed lessons separately for the place.

A12. Children missing education

Every child of compulsory school age must get a suitable full-time education. A child is missing education if they are of compulsory school age, aren't on a school roll and aren't getting a suitable education any other way, for example at home. This puts them at risk, because the people who would notice harm may no longer see them.

Our lessons are extra help alongside school, never a replacement for it. We are not an alternative provider and we don't provide "education other than at school".

The same goes for home education. Parents who choose to home educate are responsible for their child's education. We are not a home school, and we don't provide or replace that education. Home-educated pupils can have lessons at the standard price, alongside the full-time education their parents arrange. The Fund is for extra help alongside school, so it doesn't cover lessons for home-educated pupils.

When an application says a child isn't in education or isn't attending school, the system flags it to the DSL automatically. If you work or volunteer with us and notice anything else that suggests a child may be struggling or missing school, report it through Protect in the time set in B1. Anyone else can report it in the same way (A5).

If a family tells us their child isn't in education, the application lets them know we may contact their local council's education team to help find the right support. If there is a safeguarding concern, the DSL may also contact the council's safeguarding team. We keep their application open unless there is a safeguarding reason not to, but having a tutor doesn't solve a child missing school. The DSL's steps are in C11.

A13. Safer recruitment and DBS checks

Before anyone works with pupils, we check:

  • who they are, and that they can work in the UK;
  • their qualifications and two references;
  • their DBS certificate, at the level their role needs (see the table below);
  • for tutors, that they are not banned from teaching (a Teaching Regulation Agency check);
  • if they have lived outside the UK for 6 months or more in the last 5 years, their record there (a certificate of good conduct, or as much as is available);
  • that they have done our safeguarding training.

Nobody works with children until every check is done. The system won't place anyone with a pupil until HR has verified their DBS check.

Role DBS check the role needs
Anyone, paid or volunteer, who tutors, teaches, mentors or regularly helps in lessons (supervised or not), the DSL and Deputy, the CEO and the CEdO Enhanced with the children's barred list
Trustees who do not tutor, and staff who see safeguarding information but don't work with pupils Enhanced without the barred list. The law doesn't allow a barred-list check for these roles
Roles with occasional indirect contact Standard, if the recruitment risk assessment says so
Staff with no contact with pupils Basic

Other rules

  • We recheck every 3 years, or every year through the DBS Update Service (C8).
  • Every offer depends on a satisfactory check. Only in exceptional cases, after a risk assessment, may supervised work start while a check is processed.
  • A criminal record does not automatically bar someone from working with NSEMM. The DSL and HR assess each case, and every decision is recorded.
  • Most of our tutors are university students, paid or volunteers. If NSEMM ever engages a self-employed tutor, they get their enhanced check through an umbrella body.
  • Volunteers and staff must be aged 16 or over. Some of our tutors are aged 16 or 17. They have the same checks as an adult in the same role, every one of their lessons is recorded, and a safeguarding lead reviews their lessons (B5).

A14. Records

Safeguarding records say what was seen or heard, in order, with who wrote them. They are never overwritten. How long we keep them is set only in the Data and Privacy Policy, Annex (rows S1 to S6). How the safeguarding leads look after them is in C10.

A15. Training

Training for everyone who works or volunteers with us, and for trustees, is in B6.

A16. About this document

  • This policy was adopted by the DSL and one other trustee under the decision of NSEMM's first AGM, and is reported to all trustees at the next trustee meeting. The written record of the first AGM is being written up. The DSL runs the policy day to day.
  • We check it at 6 months for changes in the law, practice or learning from cases, and review it promptly after any safeguarding incident or significant change.
  • We keep every version, with the date, the change and the reason.
  • Everyone who works or volunteers with us confirms they have read and understood it, and confirms again every year.

Part B. Audience: Everyone who works or volunteers with us (published for anyone to read)

B1. Your duty to report

If a child is in immediate danger, call 999 first (A5).

When to report. Report a concern as soon as you can, within the hour if you are able to, and in any case the same day. This applies to everyone, and the rest of this policy and our other policies point here.

Report everything. If you work or volunteer with us, or you are a trustee, and you become aware of a safeguarding concern, report it through NSEMM Protect or straight to the DSL. Don't filter concerns before you report them. The DSL decides what happens next.

Not reporting is gross misconduct and can lead to dismissal or removal from your role (People Policy, section B5.12). It also breaks the Code of Conduct and the Volunteer Agreement.

A concern can be something a child says, something you see, or a change in how they behave. You do not need proof.

If a child tells you something

  • Listen calmly and take the child seriously.
  • Don't promise to keep it secret.
  • Don't ask leading questions.
  • Write down what was said as soon as you can, in the child's own words. Keep the facts separate from your own view.
  • Report it through NSEMM Protect, in the time set above.
  • Don't investigate or confront anyone.

Three things you also report outside NSEMM yourself. For each one, also report it in NSEMM Protect at the same time, and add the reference number you were given.

  • FGM you discover on a girl under 18: call the police on 101.
    • "Discover" means the girl told you, or you saw physical signs. If someone else tells you, make an urgent report in Protect. The legal duty starts only when the girl tells you or you see signs.
    • Don't contact the family.
  • A child telling you directly about sexual abuse, or abuse you witness: call the police on 101.
  • Child sexual abuse material, including AI-made material: stop the session and leave the material where it is. Don't delete, screenshot or share it, and don't investigate. Report it to the Internet Watch Foundation and CEOP (D2).

Why we ask you to report these yourself. For these three, the law can put the duty to report on you personally, so telling the DSL isn't always enough on its own. To keep it simple and make sure nothing is missed, we ask everyone to report these themselves, including tutors aged 16 and 17, and to tell the DSL too.

B2. Low-level concerns

A low-level concern is behaviour by someone who works or volunteers with us that isn't serious enough for an allegation but still makes you uneasy. For example:

  • being too personal with pupils
  • crossing boundaries in online messages
  • not following the safeguarding, recording or reporting rules
  • sharing personal information that isn't appropriate

Report it through NSEMM Protect like any other concern, including a mistake of your own. We handle these with support, and we want to hear about them. How the DSL responds is in C10.

B3. In your lessons

  • Your setting. Be in a quiet, professional setting with no other adults visible. Use a neutral background that shows no personal information, and dress appropriately. Keep clear sight lines.

  • Public spaces. No tutoring from public spaces without the DSL's agreement.

  • Platform. Use only NSEMM's online classroom. Do not use personal video tools, direct messages, personal email or social media, during or after a session.

  • Group lessons. Before the lesson starts, ask pupils to keep their cameras off, and use the leader controls to switch off any pupil camera that is on. Do not begin with a pupil's camera on.

  • Messages outside NSEMM. If a current or former student contacts you outside NSEMM (for example on social media or personal email):

    • do NOT respond;
    • keep the message as evidence;
    • tell the DSL through NSEMM Protect (B1), saying where it came from.

    The DSL may contact the parent and the platform.

  • Language. Teach mainly in English (A9). If you need another language for more than a word or a quick explanation, agree it with a safeguarding lead first.

  • Mentoring. Before mentoring starts, the mentor, the student and their parent sign an agreement about confidentiality. At the first session, explain that you can't keep something confidential if it is a safeguarding concern. After each session, write short factual notes and store them securely.

  • Cyberbullying on NSEMM's platforms is a safeguarding concern, so report it. We step in straight away, support the child being bullied, deal with the child responsible and keep an eye on it afterwards.

  • If a child is in immediate danger in a lesson, call 999, keep them safe and don't leave them alone if they are at risk. Then report it through Protect and contact the DSL.

  • If it is urgent but not an emergency, report it through Protect marked as immediate danger, which sends urgent alerts, and contact the DSL or the Deputy directly.

  • Medical incidents. Record every one in Protect, however small. For urgent medical advice call 111, or 999 in an emergency, and contact the parent or carer straight away. You don't need a parent's consent for emergency treatment that is in the child's best interests, but always try to reach them and record that you did.

Your position of trust with pupils is covered in the People Policy, section B5.9.

B4. A pupil's chosen name or pronouns

If a student asks you to use a different name or pronouns, use them. It is a matter of respect, and on its own it isn't a safeguarding concern.

When a student asks, a member of staff has a short, supportive check-in with them, and the DSL updates their record. There is no waiting period, and the student can change their mind at any time. Any request has to come from the student themselves.

We don't tell parents or carers without the student's agreement, unless the DSL has a specific safeguarding concern, the law requires it, or not telling them would put the student at risk. This is the same test we use for any decision about sharing with parents. If the student wants to tell their parents, a member of staff can help.

We don't suggest or encourage social transition, so don't raise the subject unless the student does. We don't give medical advice. If a student is struggling, we offer pastoral support and point them to their GP or NHS services.

In our records we use the student's chosen name day to day, and keep their legal name in legal and safeguarding records. We record biological sex only where the law or safeguarding needs it. We will review this section if the DfE updates its guidance on gender-questioning children.

B5. If you are aged 16 or 17

At 16 or 17 you are still a child in law, so the rules that protect pupils protect you too.

Before you start

  • A parent or guardian with parental responsibility gives their consent.
  • You have the same checks as an adult in the same role: identity, two references and safeguarding training.
  • If you tutor, you also need an enhanced DBS check with the children's barred list. It is free for volunteers.
  • HR gives you an adult mentor, a member of staff aged 18 or over. You can talk to them about any worry, including how a pupil, family or colleague treats you.

If you tutor one to one

  • You only tutor pupils in Years 7 to 10 who are at least 2 years younger than you.
  • Every lesson is recorded. A safeguarding lead watches your first 3 lessons in full, then at least one lesson a fortnight.
  • On school nights (Sunday to Thursday), lessons finish by 8pm. No lesson takes place between 10pm and 6am.
  • All contact with pupils and families goes through NSEMM's platform. No personal phone numbers, emails or social media, and no meeting pupils outside lessons.

Looking after you

  • Your work fits around your own education.
  • If we are worried about your welfare, we deal with it under this policy, as we would for any young person.
  • Every half term, the DSL or a Deputy and your mentor check in with you about how things are going.
  • When you turn 18, these extra rules end. Your checks stay in force.

B6. Training you must complete

Before you start any work with children

  • this policy and our procedures
  • recognising abuse and neglect
  • how to report a concern through NSEMM Protect
  • online safety
  • the Code of Conduct and professional boundaries
  • Keeping Children Safe in Education Part 1, or a briefing on it

Every year you complete an update. It may be a bulletin, briefing, meeting or e-learning, and it covers:

  • changes in law and guidance
  • learning from cases and near misses
  • new risks, including AI-enabled grooming, deepfakes and AI-made abuse images
  • changes to our procedures

Extra training by role

  • Tutors: managing online sessions, recording and monitoring, academic pressure and mental health, and safe use of AI tools.
  • Mentors: the limits of confidentiality, emotional support within professional limits, signs of crisis and building trust safely.
  • Tutors who teach school groups: Level 2 safeguarding training within 3 months.
  • Trustees: training for their governance role.
  • The DSL and the Deputy: Level 3 training, renewed every 2 years (C1).

Training is recorded in the HR app, with the course, date and expiry date.

B7. Signs to look for

Concern Signs or examples
Physical abuse: hitting, shaking, burning, poisoning, or a carer making up or causing illness Unexplained injuries or marks in unusual places, explanations that don't fit, not wanting to show skin, flinching, fear of going home
Emotional abuse: persistent treatment that makes a child feel worthless, frightened or unloved Withdrawal or aggression, low self-esteem, difficulty with relationships, behaviour that doesn't fit their age, self-harm, a constant need for approval
Sexual abuse: forcing or enticing a child into sexual activity, with or without contact, including images Sexual knowledge or behaviour that doesn't fit their age, physical symptoms, withdrawal, not wanting to undress, sexualised language
Neglect: persistent failure to meet basic needs, including during pregnancy through substance misuse Poor hygiene, hunger, unsuitable clothing, untreated illness, often absent or late, being left unsupervised
Domestic abuse: physical, emotional, sexual, financial or technological. A child is a victim in their own right Injuries, fear of going home, regression, poor sleep, withdrawal, falling work, sexual knowledge, adult caring roles
Child-on-child abuse: physical or sexual violence, sexual harassment, initiation or hazing Any sign in this table, where another child is causing it
Bullying, including online and prejudice-based bullying Not wanting to come to lessons, lost or damaged things, unexplained marks, upset after being online, going quiet in group lessons
Sharing nudes or semi-nudes (including AI-made ones), and upskirting Secrecy about a phone, distress after being online, worry that an image will be shared
Sexual exploitation, including for money, and sextortion (threats to share real or AI-made images) Unexplained money or gifts, requests for images, secrecy online, distress after using a device, panic about something being "found out"
Criminal exploitation and county lines Unexplained money or possessions, behaviour change, going missing, signs of assault
Cybercrime: a child drawn into hacking, fraud or other online crime Unexplained money or gaming items, talk of "easy money" online, new older contacts online
Serious violence Unexplained injuries, carrying weapons, new friendship groups, falling attendance
Online abuse Grooming, harassment, harmful content, misinformation and conspiracy theories, deepfakes, radicalising content. The risks come from content, contact, conduct, commerce and AI-enabled harm
Misogyny and violence against women and girls, from other children or adults Misogynistic language, online harassment, coercive control, exploitation in sexual or romantic relationships
Radicalisation Report any worry, even without clear signs
"Honour-based" abuse, including FGM, forced marriage and breast ironing Report any worry, even without clear signs
Modern slavery and trafficking, which can happen within the UK Report any worry, even without clear signs
Homelessness, or a family at risk of losing its home Frequent moves, tiredness, hunger, talk of eviction or staying with friends, nowhere quiet to work
A family member in prison A parent suddenly absent, money worries, secrecy or shame, changes in behaviour
Self-harm and suicidal thoughts Report any worry, even without clear signs
Mental health Changes in mood or behaviour, withdrawal, hopelessness, anxiety, falling engagement, self-harm

What to do differently

  • Nudes, semi-nudes and abuse images: don't look at, copy or forward the image (B1).
  • Sextortion: treat it as urgent.
  • Child-on-child abuse: treat it as abuse. The child causing harm may also be a victim.
  • Radicalisation: report it as normal. The DSL decides whether to make a Channel referral.
  • "Honour-based" abuse: speak to the DSL before doing anything that might alert the family.
  • Domestic abuse:
    • check the immediate safety of the child and of family members who are not abusive;
    • don't alert the abuser;
    • don't promise secrecy, but say you will only tell people who need to know;
    • the DSL decides on a referral (social care, the police or specialist domestic abuse services), and we keep supporting the child in lessons.
  • Self-harm and suicidal thoughts: report through Protect. The DSL assesses the risk and may refer to mental health services.
  • Mental health: report it. We point families to help and don't treat (C10).

Look at the whole picture. Harm can come from home (domestic abuse, substance misuse, hardship), the community (gangs, exploitation), other children and online spaces, and children may suffer several harms at once. This is called contextual safeguarding. Upskirting is a crime.

B8. In-person sessions

Most of our lessons are online. If a session is held in person, it is either:

  • in a public place, such as a library or a community space open to the public; or
  • on premises closed to the public, such as a partner's building.

In-person sessions are not recorded, so these rules apply instead.

Staff and venue

  • NSEMM staff are present and can be identified throughout. There are at least two staff on every session, and minimum staffing ratios are kept.
  • Tutors work in rotating pairs, so no tutor has sustained one-to-one contact with the same child.
  • A written agreement with the venue sets out who is responsible for what in safeguarding. In a public place, the session stays in view of the venue's staff.
  • Safety checks are done before each session, emergency procedures match the venue's, and every session is logged in NSEMM Protect.

First aid

  • A trained first aider is present.
  • Medical and other healthcare students count as first aiders only if they have completed basic life support and are competent in the first aid needed, or hold a recognised first aid qualification.

Urgent medical need (same-day assessment, not life-threatening)

  • Call 111, or 999, for advice.
  • If you are advised to go to urgent care or hospital, contact the parent straight away and ask them to take the child themselves where possible.
  • Staff must not take children in their own vehicles.
  • Record the hospital or urgent treatment centre.
  • If 999 advises making your own way, accept it, get a reference number if you can, and contact the parent first.

If the parent can't be reached and urgent assessment is needed

  • Two NSEMM adults go with the child, in a trackable registered taxi, never a personal vehicle.
  • Record the times of leaving and arriving, and log where you went.

Our library sessions (the Learning Outreach Network) are paused at the moment.


Part D. Audience: Everyone (reference)

D1. Law and guidance

Law

  • Children Act 1989 (a child is anyone under 18)
  • Children Act 2004. The section 11 duty binds public bodies, not NSEMM, and we follow its standards anyway. The section 16LA information sharing duty applies to our work for schools, and we follow it for all our work (A8)
  • Care Act 2014 (section 42, adults at risk)
  • Human Rights Act 1998
  • Data Protection Act 2018 and UK GDPR, as amended by the Data (Use and Access) Act 2025
  • Equality Act 2010
  • Counter-Terrorism and Security Act 2015 (the Prevent duty)
  • Domestic Abuse Act 2021 (section 3, children as victims in their own right)
  • Female Genital Mutilation Act 2003
  • Voyeurism (Offences) Act 2019 (upskirting)
  • Public Interest Disclosure Act 1998 and Employment Rights Act 1996, including disclosures about sexual harassment under the Employment Rights Act 2025, and section 43J (gagging clauses are void)
  • Police Act 1997 sections 113A to 113BA
  • Safeguarding Vulnerable Groups Act 2006 (section 35, the duty to refer to the DBS)
  • Protection of Freedoms Act 2012
  • Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
  • Limitation Act 1980 sections 11 and 28
  • Education Act 1996 section 436A (councils' duty to identify children missing education)
  • Crime and Policing Act 2026
  • Children's Wellbeing and Schools Act 2026

Data protection grounds we use

  • Recording lessons: UK GDPR Article 6(1)(f), legitimate interests (A10).
  • Sharing information: as set out in A8.
  • Safeguarding records: Article 9(2)(g) with the Data Protection Act 2018, Schedule 1, Part 2, paragraph 18, where consent can't be given or asking would harm the child's protection. Other personal data uses Article 6(1)(d) (vital interests) or 6(1)(f) (legitimate interests), whichever fits.
  • Keeping safeguarding records against an erasure request (C10): Article 17(3)(e) for legal claims; Article 17(3)(b) read with the Data Protection Act 2018, Schedule 1, paragraph 18, to protect a child; and the Data Protection Act 2018, Schedule 2, paragraph 5.

Statutory guidance

  • Working Together to Safeguard Children 2026
  • Keeping Children Safe in Education, current edition (statutory for schools; we follow it as best practice)
  • Working together to improve school attendance (DfE, 2026)
  • Children missing education: statutory guidance for local authorities and schools (DfE, September 2025)
  • Information Sharing Duty: statutory guidance for safeguarding organisations and their practitioners (DfE, September 2026)

Other guidance

  • DfE "Out-of-school settings: safeguarding guidance for providers" (2020, last updated 9 February 2026), which we follow
  • Charity Commission safeguarding guidance
  • The ICO's guide to sharing information to safeguard children
  • DfE Generative AI product safety expectations
  • NCVO safeguarding resources
  • We watch DfE guidance for schools for good practice we can borrow.

Changes we are working through

  • The Children's Wellbeing and Schools Act 2026: multi-agency child protection teams, a consistent child identifier, a stronger duty to share, education in safeguarding partnerships, and council registers of children not in school, with council notices to out-of-school providers. None of this is in force for us yet.
  • The Crime and Policing Act 2026: a duty to report child sexual abuse, a child criminal exploitation offence, and offences for AI-made abuse images.

D2. Helplines

Service Contact
Childline 0800 1111, childline.org.uk
NSPCC Helpline (adults worried about a child; professional advice) 0808 800 5000
NSPCC Whistleblowing 0800 028 0285
Samaritans 116 123
Beat (eating disorders) 0808 801 0677, beateatingdisorders.org.uk
Shore Space (Lucy Faithfull Foundation), for young people worried about their own sexual thoughts shorespace.org.uk
Internet Watch Foundation, to report child sexual abuse images online report.iwf.org.uk
CEOP, to report online sexual abuse or grooming to the police ceop.police.uk

Whistleblowing at NSEMM. How to raise a concern about wrongdoing, and how you are protected, is in our Whistleblowing Policy. A safeguarding concern about the DSL follows A6.