Rubicon Tutors, operated by UK Study Today Ltd (company number 07192908) and accessible at RubiconTutors.com, is committed to ensuring the safety and welfare of all individuals who use its services, particularly children and vulnerable adults.
This policy outlines our measures to ensure a safe and supportive learning environment for all online tutoring sessions delivered through the Rubicon Tutors platform.
This policy sets out the commitment of Rubicon Tutors to safeguarding and promoting the welfare of children and vulnerable adults who access tutoring services through our platform.
It provides clear guidance to all staff, tutors, learners, parents, and guardians on recognising, reporting, and responding to safeguarding concerns.
This policy is underpinned by and should be read in conjunction with the following legislation and statutory guidance:
Children Act 1989 and Children Act 2004
Care Act 2014 (Safeguarding Adults)
Safeguarding Vulnerable Groups Act 2006
Keeping Children Safe in Education (KCSIE) (current version, updated annually). This policy will be reviewed and updated to reflect each annual KCSIE update within 30 days of its publication.
Working Together to Safeguard Children (2023)
The Children and Social Work Act 2017
The Education Act 2002 (Section 175)
Counter-Terrorism and Security Act 2015 (Prevent Duty)
Female Genital Mutilation Act 2003 (as amended by the Serious Crime Act 2015)
Sexual Offences Act 2003
Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR)
The Public Interest Disclosure Act 1998 (PIDA)
This policy applies to:
All tutors providing services through the Rubicon Tutors platform as independent self-employed professionals. For the purposes of this Safeguarding Policy, all persons in a tutoring role on the platform are treated as being in regulated activity regardless of their contractual engagement structure, in accordance with the Safeguarding Vulnerable Groups Act 2006.
All learners (both minors under 18 and adults at risk of harm).
All parents and guardians of minor learners.
All internal staff, directors, and officers of Rubicon Tutors.
Any third parties or contractors who have access to learners or their personal data through the platform.
This policy covers all activities conducted through the Rubicon Tutors platform, including online tutoring sessions, messaging, and any associated communications.
Where in-person sessions are arranged through the platform, this policy also applies. In addition, the following safeguards apply specifically to face-to-face tutoring sessions:
In-person sessions involving a learner under 18 must take place in an appropriate setting, such as the learner's home with a parent or guardian present, a public library, or another suitable venue agreed in advance with the parent or guardian. Tutors must not invite learners to their own home.
Tutors conducting in-person sessions must carry out a basic risk assessment of the session venue, considering factors such as visibility, access, and the presence of other adults. Any concerns about the suitability of a venue must be reported to the Designated Safeguarding Lead (DSL) before the session takes place.
Tutors must not transport learners in their own vehicles unless expressly authorised in writing by the learner's parent or guardian and the Designated Safeguarding Lead (DSL).
A lone working protocol applies to all in-person sessions: tutors must notify the platform of the date, time, location, and expected duration of each in-person session in advance, and must confirm completion of the session promptly afterwards. Where a session overruns or a tutor fails to confirm completion, the Designated Safeguarding Lead (DSL) will follow up to ensure the safety of the learner and tutor.
The Platform (Rubico Tutors)
Rubicon Tutors is responsible for:
Ensuring that all tutors undergo Enhanced DBS checks with a Children's Barred List check before being permitted to deliver sessions on the platform.
Verifying the identity, qualifications, and professional references of all tutors prior to onboarding.
Providing mandatory safeguarding training to all tutors and staff and maintaining records of training completion and renewal.
Acting promptly and appropriately on all reported safeguarding concerns.
Appointing a Designated Safeguarding Lead (DSL) and a Deputy DSL.
Maintaining a culture in which safeguarding is everyone's responsibility.
Designated Safeguarding Lead (DSL)
The DSL for Rubicon Tutors is Saeid, who can be contacted at safeguarding@rubicontutors.com.
The DSL is responsible for:
Acting as the first point of contact for all safeguarding concerns.
Making referrals to local authority children's social care, the police, and other agencies as appropriate.
Maintaining comprehensive and confidential safeguarding records.
Ensuring that all staff and tutors receive appropriate safeguarding training.
Liaising with the Local Authority Designated Officer (LADO) where allegations are made against staff or tutors.
Providing an annual safeguarding report to the directors of Rubicon Tutors.
Where the DSL has a personal connection to, or conflict of interest in relation to, any safeguarding concern, the matter must be escalated immediately to a director of Rubicon Tutors, who will assume the DSL's responsibilities for that particular case.
Deputy Designated Safeguarding Lead
If the Designated Safeguarding Lead (DSL) is unavailable, please contact the Deputy Designated Safeguarding Lead at safeguarding@rubicontutors.com..
The Deputy DSL assumes all responsibilities of the DSL in their absence and supports the DSL in fulfilling their duties.
Tutors
All tutors using the Rubicon Tutors platform must:
Maintain professional conduct at all times during and outside of tutoring sessions.
Report any safeguarding concern to the DSL within one hour of becoming aware of it.
Use only the Rubicon Tutors platform for all communications with learners and their parents or guardians.
Tutors are strictly prohibited from sharing or requesting personal contact details, including social media accounts, personal email addresses, or telephone numbers.
Complete mandatory safeguarding training before delivering their first session and undertake refresher training annually thereafter.
Comply with this policy and the Rubicon Tutors Code of Conduct for Tutors (Section 15).
Parents and Guardians
Parents and guardians are responsible for:
Providing informed written consent before their child accesses the Rubicon Tutors platform, in accordance with the parental consent procedures set out in Section 14.
Monitoring their child's use of the platform, including attendance at sessions.
Reporting any concerns regarding a tutor's conduct or any safeguarding matter to the DSL without delay.
Providing accurate and up-to-date information about any special educational needs, medical conditions, or other relevant circumstances.
Nothing in this Safeguarding Policy creates or implies any liability on the part of Rubicon Tutors for the educational quality or outcomes of Tutor-provided sessions, which remain governed by the direct Tutor-Student contract facilitated by the Platform.
Enhanced DBS and Identity Verification
All tutors must hold a valid Enhanced DBS certificate with a Children's Barred List check before they are permitted to deliver sessions on the platform. Rubicon Tutors also performs mandatory identity verification checks, including verification of photographic identification and proof of address, to ensure that all documentation is authentic and current.
References and Qualifications Verification
In addition to DBS and identity checks, Rubicon Tutors undertakes the following vetting procedures for all tutors:
Verification of academic and professional qualifications against original certificates or directly with issuing institutions.
A minimum of two professional references, at least one of which must relate to work with children or young people where available.
A review of the tutor's employment history, with satisfactory explanations for any gaps.
Verification that the tutor is not subject to a prohibition order issued by the Secretary of State.
Where the tutor has lived or worked overseas, additional checks including overseas criminal record certificates or certificates of good conduct as appropriate.
Ongoing Monitoring
Rubicon Tutors reserves the right to require updated DBS checks at intervals of no more than three years, or more frequently where concerns arise. Tutors must notify the DSL immediately if they are arrested, charged with, or convicted of any criminal offence, or if they become subject to any investigation by a regulatory body.
Platform Security
All tutoring sessions delivered through the Rubicon Tutors platform use encrypted video connections. The platform is designed with the following safeguards:
All sessions are logged, including date, time, duration, and participants.
Screen recording by tutors or learners is prohibited unless expressly authorised in writing by the DSL and the learner's parent or guardian (where the learner is a minor).
Screen sharing is permitted only for educational content directly relevant to the tutoring session. Tutors must not share personal screens or any content unrelated to the lesson.
File transfers through the platform are restricted to educational materials. Tutors must not send or receive files of a personal nature.
All messaging through the platform is monitored and logged. Private or disappearing messages are not supported.
Use of Artificial Intelligence Tools
Tutors must not input any learner personal data, session content involving personal disclosures, or any safeguarding-related information into third-party artificial intelligence tools or platforms (including but not limited to AI chatbots, content generators, or automated assessment tools). Where AI tools are used to support lesson preparation or educational content delivery, tutors must ensure that no personally identifiable information about any learner is shared with any external AI service. Any breach of this provision will be treated as a breach of the Code of Conduct and may constitute a data protection violation.
Online Grooming and Abuse Prevention
Rubicon Tutors takes the following measures to prevent online grooming and abuse:
All communications between tutors and learners must take place exclusively through the Rubicon Tutors platform, which is subject to monitoring and audit.
Tutors are strictly prohibited from requesting or sharing personal contact details, social media accounts, personal email addresses, or telephone numbers with learners or their parents or guardians outside the platform.
Any attempt by a tutor to move communication off the platform, or to establish contact with a learner outside the tutoring context, will be treated as a serious safeguarding concern and reported to the LADO and, where appropriate, the police.
Platform algorithms and manual review processes are used to detect unusual patterns of behaviour, including excessive session frequency, sessions outside normal hours, or prolonged one-to-one messaging.
Photography and Image Policy
The taking, storing, or sharing of photographs or screenshots during tutoring sessions is prohibited unless expressly authorised by the DSL and (where the learner is a minor) the learner's parent or guardian. This includes:
Screenshots of video sessions.
Recording of sessions by any means.
The storage or sharing of any images of learners.
Any person who discovers or suspects that indecent images of a child are being created, stored, or distributed must report this immediately to the DSL and the police (999 or 101). The DSL will also refer the matter to the National Crime Agency's CEOP Command (www.ceop.police.uk).
Mandatory Safeguarding Training
All tutors and staff must complete the following training before being permitted to interact with learners:
Level 1 Safeguarding Awareness Training (or equivalent), covering the recognition of abuse, reporting procedures, and the role of the DSL.
E-safety and online safeguarding training specific to the online tutoring environment.
Prevent Duty awareness training in accordance with the Counter-Terrorism and Security Act 2015.
Refresher Training
All tutors and staff must undertake refresher safeguarding training at least annually. The DSL and Deputy DSL must undertake advanced multi-agency safeguarding training every two years in line with KCSIE (current version) requirements.
7.1 Types of Abuse
All staff and tutors must be able to recognise the signs and indicators of the following forms of abuse and neglect:
Physical Abuse: Any form of non-accidental physical harm, including hitting, shaking, burning, or poisoning. Signs may include unexplained injuries, bruising, or reluctance to participate in physical activities.
Emotional Abuse: Persistent emotional maltreatment causing severe and persistent adverse effects on a child's emotional development. This includes bullying, intimidation, constant criticism, threats, or the imposition of inappropriate expectations.
Sexual Abuse: Forcing or enticing a child or young person to take part in sexual activities, whether or not the child is aware of what is happening. This includes physical contact and non-contact activities such as grooming, exploitation, or exposure to sexual content.
Neglect: The persistent failure to meet a child's basic physical or psychological needs, likely to result in serious impairment of health or development.
Financial or Coercive Exploitation: Exploitation of a child or vulnerable person for financial gain, including through coercion, fraud, or undue influence.
Modern Abuse Typologies
In addition to the categories above, all staff and tutors must be aware of the following specific forms of abuse and exploitation:
Child Sexual Exploitation (CSE): A form of sexual abuse in which a child is manipulated or coerced into sexual activity in exchange for something (such as gifts, money, affection, or status). CSE can occur online or in person and affects both boys and girls.
Child Criminal Exploitation (CCE) and County Lines: The exploitation of children and young people to transport, store, or sell illegal drugs on behalf of criminal gangs. Indicators include unexplained absences, changes in behaviour, possession of unexplained money or goods, or association with older individuals.
Radicalisation and the Prevent Duty: Under the Counter-Terrorism and Security Act 2015, Rubicon Tutors has a duty to have due regard to the need to prevent people from being drawn into terrorism. All staff and tutors must be alert to changes in behaviour that may indicate radicalisation and report any concerns to the DSL, who will make a referral to the local Prevent team or the police anti-terrorism hotline (0800 789 321) as appropriate.
Female Genital Mutilation (FGM): FGM is illegal in the United Kingdom under the Female Genital Mutilation Act 2003. There is a mandatory duty on all professionals (including teachers and tutors) to report known cases of FGM in girls under 18 to the police. Any tutor who discovers that FGM has been carried out on a girl under 18 must report this directly to the police (101) as well as to the DSL.
Honour-Based Abuse (HBA): Abuse committed to protect or defend the perceived honour of a family or community, including forced marriage, FGM, and other forms of violence or coercion. HBA may involve multiple perpetrators and must be reported to the DSL and the police.
Online Grooming: The use of online communication to build a relationship with a child with the intention of sexual abuse or exploitation. Warning signs include a tutor or adult seeking to isolate a child, encouraging secrecy, sending or requesting inappropriate images, or attempting to move communication to private channels.
Peer-on-Peer Abuse (Child-on-Child Abuse): Abuse perpetrated by children against other children, including bullying, sexual violence, sexual harassment, upskirting, initiation-type violence, and the sharing of indecent images (including sexting and non-consensual sharing of nude or semi-nude images). Although the Rubicon Tutors platform primarily facilitates one-to-one tutor-learner sessions, peer-on-peer abuse may still occur through the platform's messaging features or where learners interact in any group context. All incidents of peer-on-peer abuse must be reported to the DSL immediately. The DSL will assess each case on its own merits, ensuring that the victim is supported and protected, that the alleged perpetrator is managed appropriately (which may include suspension from the platform and referral to external agencies), and that any bystanders or witnesses are also offered support. No incident of peer-on-peer abuse will be dismissed as "banter" or minimised.
Contextual Safeguarding: Safeguarding assessments should consider the wider context in which abuse or harm may occur, beyond the child's home environment. This includes risks arising from online peer networks, social media, community settings, and relationships with other young people. All staff and tutors should be aware that children may disclose concerns during tutoring sessions that relate to harm occurring in these broader contexts. Such disclosures must be reported to the DSL, who will consider the full context when determining the appropriate response and any referrals to external agencies.
Mental Health, Self-Harm, and Suicidal Ideation: Changes in a learner's mental health may be an indicator that they are experiencing or are at risk of abuse, neglect, or exploitation. All staff and tutors should be alert to signs of deteriorating mental health, including withdrawal, changes in mood or behaviour, expressions of hopelessness, visible signs of self-harm, or direct disclosures of suicidal thoughts. Any such concerns must be reported to the DSL immediately. The DSL will assess whether a referral to external agencies, including children's social care, CAMHS (Child and Adolescent Mental Health Services), or the emergency services, is appropriate.
Domestic Abuse: Under the Domestic Abuse Act 2021, children who see, hear, or experience the effects of domestic abuse are recognised as victims of domestic abuse in their own right. Tutors should be alert to indicators that a learner may be living in a household affected by domestic abuse, including anxiety, aggression, withdrawal, difficulty concentrating, or direct disclosures. Any concerns must be reported to the DSL, who will consider referral to local authority children's social care or the National Domestic Abuse Helpline (0808 2000 247).
Child Trafficking and Modern Slavery: Under the Modern Slavery Act 2015, all organisations working with children must be alert to the indicators of trafficking and modern slavery. These may include signs that a child is being controlled by others, is not free to leave a situation, has been moved to a new area, has no access to their own identity documents, or shows signs of physical abuse or neglect. Any concerns must be reported to the DSL, who will consider referral to the National Referral Mechanism (NRM), the police, or local authority children's social care.
8.1 General Principles
All staff, tutors, parents, and guardians have a duty to report any safeguarding concern without delay. It is not the responsibility of the person reporting to determine whether abuse has occurred; that is the role of trained professionals and statutory agencies. Concerns should be reported even where there is uncertainty. All reports will be treated in confidence, shared only with those who need to know, and handled in accordance with this policy and applicable data protection legislation.
Receiving a Disclosure
When a child or vulnerable adult makes a disclosure of abuse or harm, the person receiving the disclosure must:
Listen carefully and take what the child says seriously. Allow the child to speak in their own words and at their own pace. Do not interrupt or ask leading questions.
Reassure the child that they have done the right thing in telling someone, and that the concern will be taken seriously.
Not promise confidentiality. Explain that the information may need to be shared with people who can help.
Not investigate the matter themselves or confront the alleged abuser.
Not ask the child to repeat their account to multiple people.
Record the disclosure as soon as possible using the child's own words, noting the date, time, and context, and report it to the DSL immediately and in any event within one hour.
Reporting Procedure
Step 1 - Immediate Danger: If a child or vulnerable adult is in immediate danger, call 999 for emergency services without delay.
Step 2 - Internal Referral: Report all safeguarding concerns to the DSL at safeguarding@rubicontutors.com. In the absence of the DSL, contact the Deputy DSL. All reports will be acknowledged within 24 hours. When making a referral, provide the following information where available: the name and age of the child or vulnerable adult; the nature of the concern; any relevant dates, times, and details of what was observed or disclosed; any action already taken; and your own contact details.
Step 3 - External Referrals: The DSL will determine whether a referral to external agencies is required. This may include:
Local authority early help services (where a child's needs do not meet the threshold for statutory intervention but would benefit from coordinated early support).
Local authority children's social care (for the area in which the child resides).
The police (where a criminal offence may have been committed).
The NSPCC Helpline: 0808 800 5000 (for advice on child protection concerns).
Childline: 0800 1111 (for children and young people seeking support).
The LADO (Local Authority Designated Officer) for allegations against staff or tutors.
Step 4 - Record Keeping: All concerns, disclosures, referrals, and actions taken must be recorded in writing by the DSL using the safeguarding concern log. Records must be factual, contemporaneous, and stored securely in accordance with Section 12 (Data Protection and Record-Keeping).
LADO Contact Details
For allegations against staff or tutors, the relevant LADO should be contacted. For Rubicon Tutors, the primary LADO contact is: London Borough of Islington LADO: Telephone: 020 7527 8102 . Email: LADO@islington.gov.uk. Alternatively, contact the Islington Children's Services on 020 7527 7400. Where a learner resides in a different local authority area, the LADO for that area should be contacted. LADO contact details for all local authorities are available on the relevant council website.
Whistleblowing Policy
Rubicon Tutors is committed to maintaining an open and transparent culture in which all individuals feel able to raise concerns about safeguarding practices, misconduct, or failures in child protection without fear of retaliation. Any person who has concerns about the conduct of a member of staff, a tutor, or the management of Rubicon Tutors in relation to safeguarding may raise those concerns:
Internally, by contacting the DSL at safeguarding@rubicontutors.com.
Where the concern relates to the DSL or to senior management, by contacting a director of Rubicon Tutors at info@rubicontutors.com.
Externally, by contacting Protect (formerly Public Concern at Work), the independent whistleblowing charity, on 020 3117 2520 or at whistle@protect-advice.org.uk.
By contacting the NSPCC Whistleblowing Helpline on 0800 028 0285 (for concerns about how an organisation is handling child protection).
By contacting Ofsted on 0300 123 3155 (for concerns about the welfare of children in educational settings).
Legal Protection for Whistleblowers
Individuals who raise genuine concerns about safeguarding in good faith are protected from detriment and dismissal under the Public Interest Disclosure Act 1998 (PIDA). Rubicon Tutors will not tolerate any form of retaliation against a person who raises a safeguarding concern, and any such retaliation will be treated as a serious disciplinary matter.
10.1 Procedure for Managing Allegations
In accordance with KCSIE (current version) (Part 4), any allegation that a member of staff or a tutor has:
Behaved in a way that has harmed a child, or may have harmed a child.
Possibly committed a criminal offence against or related to a child.
Behaved towards a child in a way that indicates they may pose a risk of harm to children.
Behaved or may have behaved in a way that indicates they may not be suitable to work with children.
Any such allegation must be reported immediately to the DSL.
10.2 Investigation and Referral
Upon receiving an allegation, the DSL will:
Carry out an initial assessment of the concern within one working day.
Contact the LADO for the relevant local authority to discuss the allegation and agree the appropriate course of action.
In consultation with the LADO, determine whether a referral to the police, children's social care, or the DBS is required.
Suspension of the tutor or staff member from the platform is not automatic but will be considered where there is cause to suspect a child is at risk of harm, or where the allegation is so serious that it warrants immediate removal. The decision to suspend will be reviewed regularly and will not be treated as a presumption of guilt. Any individual who is the subject of an allegation will be informed of the nature of the concern as soon as possible, subject to restrictions imposed by the LADO or the police in the interests of the investigation. Where an allegation is substantiated, Rubicon Tutors will refer the matter to the DBS for consideration of barring and will cooperate fully with any external investigation. Where an allegation is found to be unsubstantiated, malicious, or false, Rubicon Tutors will support the individual concerned and take appropriate action against the person who made the allegation where it was made maliciously.
10.3 Low-Level Concerns
In accordance with KCSIE (current version), Rubicon Tutors maintains a system for recording and responding to low-level concerns about staff or tutors. A low-level concern is any concern that an adult working with children has acted in a way that is inconsistent with this policy or the Code of Conduct, but which does not meet the threshold for referral to the LADO. Examples may include being overly friendly with a learner, making inappropriate comments, or breaching professional boundaries in a minor way. All low-level concerns should be reported to the DSL, who will record the concern and monitor for any pattern of behaviour that may, over time, meet the threshold for formal action or LADO referral. Low-level concern records will be retained in accordance with the retention periods set out in Section 12.
10.4 Historical Allegations
Where an allegation relates to conduct that occurred before the tutor or staff member joined the platform, or where the individual has since left the platform, the allegation must still be reported to the DSL. The DSL will refer the matter to the LADO and, where appropriate, the police, regardless of the individual's current status with the platform. Rubicon Tutors will cooperate fully with any resulting investigation.
10.5 Duty to Refer to the DBS
Rubicon Tutors has a legal duty under the Safeguarding Vulnerable Groups Act 2006 to refer any tutor or staff member to the DBS where they have been removed from regulated activity (or would have been removed had they not left) because they posed a risk of harm to a child or vulnerable adult. Failure to make such a referral is a criminal offence. The DSL is responsible for ensuring that all required DBS referrals are made without delay.
Commitment
Rubicon Tutors is committed to providing a learning environment free from bullying, harassment, and intimidation. Bullying in any form, whether physical, verbal, emotional, or online (cyberbullying), is unacceptable and will not be tolerated.
This includes discriminatory bullying based on race, religion, culture, gender, sexual orientation, disability, special educational needs, or any other protected characteristic. Prejudice-based incidents will be taken seriously, recorded, and reported to the DSL.
Scope
This section applies to all interactions between learners, between tutors and learners, and between any other individuals using the Rubicon Tutors platform.
Reporting and Response
Any learner, parent, guardian, tutor, or staff member who witnesses or experiences bullying should report the matter to the DSL in accordance with the reporting procedure set out in Section 8. The DSL will investigate all reports of bullying promptly and will take appropriate action, which may include issuing warnings, suspending or removing individuals from the platform, and, where the bullying constitutes a safeguarding concern, making a referral to external agencies.
12.1 Data Protection
All safeguarding data is processed in accordance with the Data Protection Act 2018 and the UK GDPR. The lawful bases for processing safeguarding data are:
Article 6(1)(c) UK GDPR: Legal obligation (compliance with statutory safeguarding duties).
Article 6(1)(d) UK GDPR: Vital interests (to protect the life of the data subject or another person).
Article 6(1)(e) UK GDPR: Public task (the exercise of a task carried out in the public interest).
For special category data (such as health information or information about criminal allegations), processing is carried out under Article 9(2)(g) UK GDPR (substantial public interest) and Schedule 1 of the Data Protection Act 2018. Rubicon Tutors has regard to the ICO's Age Appropriate Design Code (Children's Code) in the design and operation of the Rubicon Tutors platform, given that the platform is likely to be accessed by children. In particular:
The best interests of the child are a primary consideration in the processing of children's personal data.
Default privacy settings are set to the highest level of protection for child users.
Data collection from children is minimised to that which is strictly necessary for the provision of the tutoring service.
Record-Keeping
The DSL is responsible for maintaining comprehensive and confidential safeguarding records. The following records must be kept:
A chronological safeguarding concern log, recording all concerns raised, the actions taken, the decisions made, and the rationale for those decisions.
Records of all referrals to external agencies, including the LADO, local authority children's social care, the police, and the DBS.
Records of all safeguarding training completed by staff and tutors.
Records of all DBS checks and vetting documentation for tutors.
Retention Periods
Safeguarding records relating to children must be retained until the child's 25th birthday (or for 7 years after the last entry, whichever is longer) in accordance with the Independent Inquiry into Child Sexual Abuse (IICSA) recommendations and statutory guidance. Records relating to allegations against staff or tutors must be retained for the duration of the individual's engagement with the platform and for a minimum of 10 years following the end of that engagement, or until the individual reaches normal pension age (whichever is longer), in accordance with KCSIE (current version). All safeguarding records must be stored securely with access restricted to the DSL, the Deputy DSL, and any other person authorised by the DSL. Records must not be stored on personal devices or in unsecured locations.
Right to Erasure and Safeguarding Records
Where a learner, parent, or guardian exercises the right to erasure (the "right to be forgotten") under Article 17 of the UK GDPR, Rubicon Tutors will comply with the request except where the retention of the data is necessary for compliance with a legal obligation, for the establishment, exercise, or defence of legal claims, or for reasons of substantial public interest (including safeguarding). Safeguarding records that are required to be retained under this policy or under statutory guidance will not be deleted in response to an erasure request, and the data subject will be informed of the legal basis for the continued retention.
Principles
Rubicon Tutors recognises that effective safeguarding requires timely and appropriate information sharing between agencies and professionals. Information will be shared in accordance with the following principles, drawn from Working Together to Safeguard Children (2023) and the Data Protection Act 2018:
Information will be shared on a need-to-know basis only.
The safety and welfare of the child is the paramount consideration and overrides considerations of confidentiality where there is a risk of significant harm.
Consent to share information will be sought where appropriate, but the absence of consent does not prevent sharing where there is a safeguarding concern.
Decisions to share or withhold information will be recorded, including the rationale for the decision.
Multi-Agency Working
The DSL will cooperate fully with multi-agency safeguarding arrangements, including local safeguarding children partnerships, and will share information with statutory agencies as required by law or in the interests of child protection.
Cooperation with Statutory Enquiries and Reviews
Rubicon Tutors will cooperate fully with any Section 47 enquiry conducted by a local authority under the Children Act 1989, including by sharing relevant information held by the platform where requested by children's social care or the police. All staff and tutors must comply with any reasonable request for information or assistance in connection with such enquiries.
Rubicon Tutors will also cooperate with any Child Safeguarding Practice Review (CSPR) conducted by the relevant local safeguarding children partnership under Working Together to Safeguard Children (2023). The DSL will ensure that lessons learned from any CSPR (whether or not directly involving the platform) are disseminated to staff and tutors and, where appropriate, incorporated into this policy and the platform's safeguarding procedures.
Parental Consent for Minors
Before a learner under the age of 18 is permitted to access the Rubicon Tutors platform, the following consent procedures must be completed:
A parent or guardian must create or approve the learner's account on the platform.
The parent or guardian must provide written consent (which may be provided electronically through the platform) confirming that they have read and understood this safeguarding policy and the platform's terms of use.
The parent or guardian must provide consent for the processing of the child's personal data in accordance with the platform's privacy notice and this policy.
Age Verification
Rubicon Tutors takes reasonable steps to verify the age of learners registering on the platform. These measures include:
Requiring the date of birth of the learner at registration.
Requiring parental or guardian confirmation of the learner's age for all accounts registered as under-18.
Where there is reason to doubt the accuracy of the age provided, Rubicon Tutors reserves the right to request additional evidence of age before permitting access to the platform.
Learners Aged 16 and 17
Learners aged 16 and 17 may have greater autonomy in certain respects under UK GDPR regarding consent for the processing of their personal data. However, for the purposes of safeguarding and child protection, all learners under 18 are treated as children under this policy, and parental or guardian consent remains required for access to the platform. Where a learner turns 18 during their engagement with the platform, parental consent will no longer be required and the learner will be treated as an adult user, although any existing safeguarding records will be retained in accordance with Section 12.
Withdrawal of Consent
Where a parent or guardian withdraws consent for their child to use the platform, the learner's access will be suspended immediately and all scheduled sessions will be cancelled. Any personal data held by the platform will be handled in accordance with the platform's privacy notice and Section 12 of this policy. The withdrawal of parental consent does not affect the retention of safeguarding records where retention is required by law or statutory guidance.
Professional Standards
All tutors providing services through the Rubicon Tutors platform must adhere to the following standards of conduct:
Act in the best interests of learners at all times.
Maintain appropriate professional boundaries with all learners and their families.
Never be alone with a learner in an unsupervised setting (all online sessions are logged and subject to audit through the platform).
Never use language or behaviour that is discriminatory, threatening, intimidating, or sexually suggestive.
Never share personal information, including home address, personal telephone number, or social media accounts, with learners or their families.
Never attempt to connect with, follow, or interact with learners or their families on any social media platform, whether during or after the tutoring engagement. Tutors should also be aware that their public social media activity may have safeguarding implications and should ensure that their online presence does not compromise their professional role or the safety of learners.
Never accept gifts from, or give gifts to, learners or their families, other than token items of negligible value in the context of normal social interaction.
Report any safeguarding concern, disclosure, or allegation to the DSL immediately and in any event within one hour.
Breach of Code of Conduct
Any breach of this Code of Conduct will be investigated by the DSL and may result in:
A formal warning.
Suspension from the platform pending investigation.
Permanent removal from the platform.
Referral to the LADO, the police, or the DBS as appropriate.
Making a Complaint
Any person who is dissatisfied with the way in which a safeguarding concern has been handled, or who wishes to raise a complaint about any aspect of the safeguarding arrangements of Rubicon Tutors, may do so by:
Step 1: Contacting the DSL in writing at safeguarding@rubicontutors.com, setting out the nature of the complaint and the outcome sought. The DSL will acknowledge the complaint within 2 working days and will investigate and respond within 10 working days.
Step 2: If the complainant is not satisfied with the response, or if the complaint relates to the DSL, the complaint may be escalated to a director of UK Study Today Ltd at info@rubicontutors.com. The director will respond within 15 working days.
Step 3: If the complainant remains dissatisfied, the matter may be referred to the relevant external body, which may include:
Ofsted: 0300 123 3155.
The Local Government and Social Care Ombudsman (for complaints about social care).
The Information Commissioner's Office (for complaints about data handling): 0303 123 1113.
Record of Complaints
All complaints relating to safeguarding will be recorded, including the nature of the complaint, the investigation undertaken, the outcome, and any action taken. These records will be retained in accordance with Section 12.3 (Retention Periods).
Review Schedule
This policy will be reviewed:
At least annually, with the next review due no later than 01/04/2027.
Following any safeguarding incident or concern that identifies a need to update the policy.
Following any change in relevant legislation, statutory guidance, or regulatory requirements.
Following any recommendation arising from an internal or external audit or inspection.
Responsibility for Review
The DSL is responsible for initiating the policy review process. Any proposed amendments must be approved by a director of UK Study Today Ltd before the updated policy is published.
Version Control
All previous versions of this policy must be retained for a minimum of 7 years. The current version must be published on the Rubicon Tutors website and be readily accessible to all staff, tutors, learners, parents, and guardians.
Rubicon Tutors (operated by UK Study Today Ltd)
Company Number: 07192908
Registered Address: 124 City Road, London, England, EC1V 2NX
General Enquiries: info@rubicontutors.com
Safeguarding Email: safeguarding@rubicontutors.com
Key External Contacts:
Emergency Services: 999
Police (non-emergency): 101
NSPCC Helpline: 0808 800 5000
Childline: 0800 1111
London Borough of Islington LADO: LADO@islington.gov.uk
Ofsted: 0300 123 3155
CEOP (Child Exploitation and Online Protection): www.ceop.police.uk
Prevent (anti-terrorism hotline): 0800 789 321
Protect (whistleblowing charity): 020 3117 2520
ICO (data protection): 0303 123 1113