Safeguarding Policy

1. Policy statement and scope

Sophwick puts the welfare of every child first. Every child we teach has the right to learn safely, and everyone who works with Sophwick shares responsibility for keeping them safe.

This policy applies to Sophwick, a trading name of Veritas Gaming Ltd, and to everyone who works with us: the owner, any staff, and all tutors, who are independent, self-employed tutors providing tuition to families through the Sophwick platform. Because Sophwick vets, recommends and supervises every tutor on its platform, this policy applies to all of them in full. It covers online lessons, messages and files in the Sophwick portal, and any other contact with children or families arising from our work.

This policy follows:

• Keeping children safe in out-of-school settings (Department for Education code of practice), which applies to tuition providers.
• Working Together to Safeguard Children 2023 (statutory guidance on multi-agency working).
• Keeping Children Safe in Education as a reference for good practice.
• The Children Act 1989 and 2004, the Safeguarding Vulnerable Groups Act 2006, UK GDPR and the Data Protection Act 2018.

2. Roles and key contacts

The owner is the Designated Safeguarding Lead (DSL) and has overall responsibility for safeguarding at Sophwick.

The DSL will:

1. Receive and act on all safeguarding concerns, and keep secure records of them.
2. Refer concerns to children's services, the police or the LADO when needed, without delay.
3. Make sure every tutor is vetted, has read this policy and knows how to raise a concern.
4. Keep up to date with safeguarding training (at least every 2 years) and guidance.
5. Review this policy at least once a year, and after any serious incident.

Interim arrangement (30 October 2026). No deputy DSL has been appointed yet. Yoosuf Nadat is the sole Designated Safeguarding Lead and checks the portal and hello@sophwick.com at least once a day. If the DSL cannot be reached and a child is in immediate danger, call 999. Otherwise anyone, a tutor or a family, may refer a concern directly to the child's local authority children's services, or a concern about an adult working with children to the local authority designated officer (LADO), without waiting for Sophwick, and should tell Sophwick afterwards. A deputy DSL will be appointed before Sophwick opens beyond the pilot.

3. Safer recruitment and vetting of tutors

No tutor can see or contact any family until every check below is complete and recorded, and the DSL has approved them.

We keep a copy of a DBS certificate for no longer than 6 months after the decision, in line with the DBS code of practice. We keep the record of the check for as long as the tutor works with us, and for 6 years after.

If an applicant has anything on their certificate, the DSL will assess its relevance to work with children before deciding, and record the reasoning.

4. Tutor code of conduct

Every tutor must follow this code. Breaking it may lead to suspension, removal from Sophwick and, where required, referral to the LADO or DBS.

Lessons

1. Teach only through the lesson links agreed in the portal, at the booked times.
2. Join from a quiet, private, appropriate place, with a neutral background, dressed appropriately.
3. Never record a lesson, take screenshots of the student, or allow anyone else to watch without the parent's agreement.
4. If a student joins from a bedroom, ask (where possible) that the door is open or a parent is nearby, and keep the camera on the learning.
5. End the lesson if anything makes you uncomfortable, and report it to the DSL straight away.

Contact

1. Communicate with the family only through the Sophwick portal and in lessons. Never use personal phone numbers, email, social media, messaging apps or gaming platforms to contact a student or family.
2. Messages are with the parent, never privately with the child.
3. Use Microsoft Teams only for the lesson itself, through the link added in the portal. Admit the student from the lobby, do not add them as a Teams contact, and do not use Teams chat to contact them outside the lesson.
4. Never meet a student in person, give gifts, or arrange tuition directly with a Sophwick family.
5. Keep messages professional and about learning. No personal relationships, favouritism, or comments about appearance.

Information

1. Keep everything you learn about a student confidential, except where safeguarding requires sharing it with the DSL.
2. Never promise a child that you will keep a secret.
3. Do not store student information outside the portal.

5. Recognising abuse and online risks

Tutors are not expected to investigate, but they must notice and report. A tutor may be the only adult a child talks to one-to-one each week.

The four main categories of abuse are physical abuse, emotional abuse, sexual abuse (including online) and neglect. Children may also be at risk from exploitation, radicalisation, domestic abuse at home, bullying (including online), self-harm, and harm from other children.

Possible signs include, but are not limited to:

• changes in mood, behaviour, appearance or engagement that are out of character;
• unexplained injuries, or explanations that do not fit;
• tiredness, hunger or poor hygiene that persists;
• signs of fear of someone in the household, or a reluctance to go home;
• worrying comments, drawings or written work;
• a child telling you something directly (a disclosure).

Online-specific risks a tutor may notice include a child mentioning secret online friendships with adults, unexplained gifts, or pressure to share images. Any of these must be reported to the DSL.

A single sign does not prove abuse. If something worries you, report it. It is the DSL's job to decide what happens next.

6. Responding to a concern or disclosure

If a child is in immediate danger, call 999 first, then tell the DSL.

If a child tells you something

1. Stay calm, listen, and let them speak in their own words.
2. Do not ask leading questions or investigate. Only ask open questions if you need to understand whether they are safe right now ("Can you tell me more?").
3. Reassure them they were right to tell you. Do not promise to keep it secret; explain you will need to tell someone who can help.
4. Do not contact or confront anyone the child has named.
5. Write down what was said, in the child's words, with the date and time, as soon as possible after the lesson.
6. Report it to the DSL the same day, by phone and by email to safeguarding@sophwick.com (read only by the DSL), or through "Report this message" on any message in the portal. In an emergency, call 999.

Who does what

The DSL decides whether to inform the parent. Parents are usually told, unless doing so could put the child at greater risk; in that case the DSL takes advice from children's services first.

7. Allegations against a tutor or staff member

Any allegation that a tutor or staff member has harmed a child, may have committed an offence against a child, or behaved in a way that suggests they may pose a risk to children, is reported to the LADO for the area where the child lives within one working day.

1. The DSL records the allegation and does not investigate it alone or tell the tutor before taking advice from the LADO.
2. While the matter is considered, the tutor is suspended. The portal then stops all new bookings with them, hides children's learning notes from them, and lists their booked lessons for the DSL to cancel. Families are told only that the tutor is not taking bookings, never why. Suspension is a neutral act, not a finding.
3. The DSL follows the LADO's advice and cooperates fully with any police or children's services enquiry.
4. Records of the allegation, the actions taken and the outcome are kept securely, in line with section 9.
5. DBS referral: where Sophwick removes a tutor from work with children, or would have done had they not left, because they harmed or posed a risk of harm to a child, Sophwick will refer them to the DBS as the law requires.
6. Low-level concerns about behaviour (for example, a message that is over-familiar) are recorded, raised with the tutor, and monitored. A pattern of low-level concerns is treated seriously.

Anyone can also raise a concern about how Sophwick has handled safeguarding directly with the LADO, the NSPCC whistleblowing helpline (0800 028 0285) or the police.

8. Online safety in the Sophwick platform

The portal is designed so that safe practice is the default, not something tutors have to remember.

When built-in video replaces Microsoft Teams, this policy will be updated to cover it.

9. Records, information sharing, training and review

Records

1. The DSL keeps a secure safeguarding record for each concern: what was reported, by whom, when, what was decided, and why.
2. Safeguarding records are kept separately from ordinary student records, with access limited to the DSL and deputy.
3. Safeguarding records are kept by the DSL outside the portal, for the periods in the Retention Schedule: a concern about a child, and what was done, until the child's 25th birthday, estimated from their year group; an allegation against an adult working with children through Sophwick (a tutor, a member of staff or a deputy DSL), including unfounded ones, until that person's normal retirement age, or 10 years from the allegation, whichever is longer. Allegations found to be malicious are removed.
4. Notes Sophwick writes in the portal about a tutor or family (for example why a tutor's lessons were cancelled) are visible only to Sophwick, never to the other side. They are not a substitute for the safeguarding record.

Information sharing

Data protection law does not stop us sharing information to keep a child safe. Where there is a risk of harm, the DSL will share relevant information with children's services, the police or the LADO, and record what was shared, with whom and why.

Training

1. The DSL completes Designated Safeguarding Lead training and refreshes it at least every 2 years.
2. Every tutor completes recognised safeguarding training (at least Level 1 or equivalent) before their first lesson, and every 3 years, and reads this policy and confirms it on joining and after each update.

Review

The DSL reviews this policy at least once a year, after any serious incident, and when the law or guidance changes. Next review: 01/01/2028.

Related documents

Platform Terms for families, Tutor Agreement, Privacy Notice, Family and Student Privacy Notice, Tutor Privacy Notice, Data Protection Impact Assessment.