Safeguarding Policy

1. Overview

Red Robin Learning Ltd ("we", "our", "us") is committed to protecting the welfare of all children and vulnerable users who engage with our online tutoring Services. The safety of our students is our paramount concern.

This policy applies to everyone who uses the Platform — Students, Parents, Tutors, employees and contractors. We review it when the law changes, when how we work changes, and after any significant incident.

2. Legal Framework

We follow duties imposed on us by law and adopt other guidance as best practice, drawing from:

• the Children Act 1989 and 2004. (The Working Together to Safeguard Children statutory guidance is directed at safeguarding partners and named agencies; like KCSIE it does not bind a private tutoring provider, and we draw on it as best practice only);
• guidance derived from Keeping Children Safe in Education (KCSIE) 2025, applied as best practice in our non-school setting (KCSIE itself binds schools and colleges, not private tutoring providers);
• the Online Safety Act 2023 — including the Protection of Children Codes that came into force on 25 July 2025;
• the UK GDPR and the Data Protection Act 2018 (notably Schedule 1, Part 2 paragraph 18 — safeguarding of children and individuals at risk);
• the Disclosure and Barring Service (DBS) regulations for enhanced criminal-record checks; and
• the Prevent Duty (Counter-Terrorism and Security Act 2015) binds the authorities specified in its Schedule 6 and does not apply to us. We none the less report genuine concerns about radicalisation through the routes below.

3. Designated Safeguarding Lead

Our Designated Safeguarding Lead (DSL) is responsible for handling safeguarding concerns, training Tutors, and liaising with statutory authorities (such as the Local Authority Designated Officer — LADO — and the police) where appropriate.

• Contact: safeguarding@redrobinlearning.com
• Response time: within 1 Working Day for non-urgent matters; same day for urgent concerns.
• We maintain an internal record of all safeguarding reports, decisions taken, and onward referrals.

4. Tutor Recruitment and Vetting

• All Tutors who deliver Lessons to under-18s must hold a valid enhanced DBS certificate with the Children's Barred List check (or the equivalent overseas check where the Tutor has lived abroad). We ask Tutors to register the certificate on the DBS Update Service so its status can be re-checked with their consent.
• We verify identity and right-to-work in the UK before a Tutor delivers their first Lesson. Tutors recruited through our current application process also provide two referees, whose responses are reviewed before they are approved.
• Tutors recruited through our current application process complete safeguarding training, and are assessed on it, before going live.
• Any later disclosure (criminal conviction, change of status) must be reported to us immediately.

5. Online Lesson Conduct

• Lessons take place through the Platform's approved video tools (Google Meet) and must not move to private channels (personal email, social media, WhatsApp, off-platform calls).
• Tutors must dress appropriately, deliver Lessons from a neutral background, and be alone in the room with no other adults visible.
• Parents are responsible for ensuring an adult is at home and within earshot for Students under 13, and at home for Students aged 13 to 15.
• Tutors must end a Lesson and notify us if a Student appears unsafe, unwell or distressed.
• Tutors must never share personal contact details with Students or arrange to meet them in person.

6. Lesson Recording

Lessons are recorded for safeguarding purposes. Recordings are stored securely in our Google Workspace and are accessible only to the DSL and authorised admins. See the Privacy Policy for the full lawful basis and retention details.

7. Recognising and Reporting Concerns

Possible signs of abuse or harm include unexplained injuries, sudden behavioural change, fear of a particular adult, indicators of online grooming or radicalisation, disclosures of self-harm, and allegations made directly by a Student. The list is not exhaustive — if in doubt, report.

How to report:

• Immediate danger: dial 999.
• Concern about an RRL Tutor or User: email safeguarding@redrobinlearning.com with as much detail as you can.
• Concern about a child outside RRL: NSPCC helpline 0808 800 5000, Childline 0800 1111, or your Local Authority Designated Officer (LADO).
• Online harms (CSAM, grooming): CEOP Safety Centre at ceop.police.uk.

We will not retaliate against anyone who raises a safeguarding concern in good faith.

8. Our Response to a Disclosure

• Concerns are logged and reviewed by the DSL as quickly as we can, and ordinarily by the next Working Day. If a child is in immediate danger, call 999 first — do not wait for us.
• Where there is a credible safeguarding risk, the relevant Tutor or User account is suspended pending investigation.
• Where a child is at risk, we refer to the appropriate statutory authority (police, LADO, or local children's social care) without delay.
• We support the person who made the report and keep them informed within the limits of confidentiality.

9. Online Safety Act — Children's Risk Assessment

Parts of the Platform allow messages to be exchanged between users who are likely to include UK children, so we keep our obligations under the Protection of Children Codes made under the Online Safety Act 2023 under review. The controls we rely on are set out above: Tutors have no direct messaging access to Students, messages are visible to the parent and to our administrators, and any concern can be reported through the routes in section 7.

If you would like to know more about how we assess these risks, write to safeguarding@redrobinlearning.com.

10. Parent and Student Responsibilities

• Parents and legal guardians are responsible for the welfare of the Student during Lessons, including ensuring a quiet, safe environment.
• Parents must keep contact details up to date so we can reach them quickly if a concern arises.
• Students and Parents must not share personal contact information with Tutors or attempt to communicate off-Platform.
• Students should never share their account password.

11. Tutor Responsibilities

• Tutors are self-employed contractors, but they accept these safeguarding standards as a condition of using the Platform.
• Tutors must report any safeguarding concern to the DSL promptly, even if they are unsure whether it is significant.
• Tutors must respect every Student regardless of age, background, ability, gender, language, racial origin, religious belief or sexual identity.
• Tutors must not share personal contact details, accept gifts of value, or develop a personal relationship with a Student or Parent.

12. Breaches and Whistleblowing

• Confirmed breaches of this policy may result in immediate suspension and permanent removal of access to the Platform.
• Suspected illegal activity will be reported to the appropriate authority.
• Anyone — Tutor, Parent, Student or member of the public — may raise a concern in confidence with our DSL. We will not penalise good-faith reporting.