Safeguarding & School Policies Handbook

Version 1.3 · Approved: September 2026 · Next review: September 2027 · The Sprout School Ltd (company no. 17162414), 11 Portland Road, Edgbaston, Birmingham, B16 9HN · info@thesproutschool.com 

How we keep students safe and how our online school runs day to day. 

Contents 

References in this document to another named policy (for example "our Privacy Policy" or "Safeguarding Policy") mean the relevant Part of our five policy documents: Terms & Conditions; Fees, Refunds & Sales Policy; Privacy Policy; Cookie Policy; and Safeguarding & School Policies Handbook. 

Part 1: Safeguarding & Child Protection Policy 

1.1 Statement 

Safeguarding and promoting the welfare of every child is everyone's responsibility. Although we are not a registered school, we voluntarily follow Keeping Children Safe in Education (KCSIE), Working Together to Safeguard Children, and the NSPCC's guidance for online providers. For international students, we also follow local procedures where known. 

1.2 Key contacts 

1.3 Scope 

Applies to all staff, tutors, contractors and volunteers, in all live lessons, recorded content, chats, clubs, 1:1 sessions and communications. 

1.4 Types of abuse 

Staff are trained to recognise physical, emotional and sexual abuse, neglect, child-on-child abuse (including online sexual harassment and sharing nudes/semi-nudes), exploitation (CSE/CCE), radicalisation, domestic abuse, FGM, forced marriage, self-harm, mental health concerns, and children missing education. 

1.5 What to do if you have a concern 

1.6 Role of a Safeguarding Specialist 

A Safeguarding Specialist decides next steps: monitoring, early help, contacting parents (unless this would put the child at risk), and referral to the local authority children's social care where the child lives, or police. For students abroad, a Safeguarding Specialist refers to the relevant local authority or agency and, where needed, the UK authority for British nationals. Decisions and reasons are recorded. 

1.7 Online-specific safeguards 

1.8 Adult learners 

1.9 Safer recruitment and allegations 

All staff are recruited under our Safer Recruitment Policy. Allegations against staff are handled under our Managing Allegations Against Staff Policy and referred to the LADO where appropriate. 

1.10 Training 

Safeguarding Specialists complete accredited designated safeguarding lead (DSL-level) training every 2 years with annual updates. All staff complete safeguarding induction and annual training, and read KCSIE Part 1 (or Annex A). 

1.11 Records and information sharing 

Safeguarding records are confidential, stored securely and separately, and shared on a need-to-know basis. Data protection law does not prevent sharing information to keep a child safe. 

1.12 Review 

Reviewed annually by the Safeguarding Specialists and the Director. Next review: September 2027. 

Part 2: Managing Allegations Against Staff Policy 

2.1 Scope 

This policy covers allegations that an employee, tutor, contractor or volunteer has: harmed or may have harmed a child; committed a criminal offence against or related to a child; behaved in a way that indicates they may pose a risk to children; or behaved in a way that indicates they may be unsuitable to work with children. It also covers low-level concerns. 

2.2 Reporting 

Allegations are reported immediately to the Director (or to a Safeguarding Specialist if the allegation is about the Director). Staff must not investigate themselves or alert the person concerned. 

2.3 Response 

2.4 Outcomes and referrals 

Outcomes are recorded as substantiated, unsubstantiated, unfounded, false or malicious. We will refer to the Disclosure and Barring Service (DBS) where we remove someone from regulated activity because they harmed or posed a risk of harm to a child, as required by law, and to the Teaching Regulation Agency where relevant. 

2.5 Low-level concerns 

Behaviour that does not meet the harm threshold but is inconsistent with our Code of Conduct (e.g. over-familiarity, using personal messaging) must be reported to a Safeguarding Specialist, recorded and reviewed for patterns. 

2.6 Records 

Records of allegations are kept confidentially until the person reaches normal retirement age or for 10 years, whichever is longer. Unfounded or malicious allegations are not referred to in references. 

Part 3: Safer Recruitment Policy 

3.1 Commitment 

We are committed to recruiting only people who are suitable to work with children, following the safer recruitment principles in KCSIE Part 3. 

3.2 Checks for every teacher, tutor and staff member 

3.3 Contractors and self-employed tutors 

The same checks apply. A written agreement requires compliance with our safeguarding and code of conduct policies. 

3.4 Single central record 

We keep a single central record of checks for all staff and tutors, reviewed termly by the Director. 

3.5 Induction 

New staff complete safeguarding, online safety, data protection and code of conduct induction before teaching. 

Part 4: Online Safety & Acceptable Use Policy 

4.1 Purpose 

To keep students, staff and families safe online and set clear rules for using our platform and communications. 

4.2 Students must 

4.3 Staff and tutors must 

4.4 Parents should 

Supervise general internet use, use parental controls, be nearby during lessons (especially 1:1), and ensure devices are updated and secure. 

4.5 Monitoring and filtering 

We monitor activity on our platform (e.g. chat logs and lesson recordings) to keep students safe. We cannot filter home internet connections; parents are responsible for home filtering. 

4.6 Breaches 

Breaches are dealt with under our Behaviour Policy or staff disciplinary procedures, and safeguarding concerns are passed to a Safeguarding Specialist. 

Part 5: Behaviour & Code of Conduct Policy 

5.1 Principles 

We expect courtesy, respect, honesty and effort from everyone. Good behaviour is recognised and praised; poor behaviour is addressed fairly and consistently. 

5.2 Student code of conduct 

5.3 Staff and tutor code of conduct 

5.4 Adult Learner Code of Conduct 

Adult learners (18+) are taught separately from under-18s. They must follow the student code above and must also: never seek to contact any under-18 student of The Sprout School; keep all communication within their class; and report any concern about a young person to a Safeguarding Specialist. Breaches may lead to immediate removal from group lessons. 

5.5 Parent conduct 

Parents are asked to communicate respectfully with staff. Abusive or threatening behaviour towards staff may lead to restricted communication or, in serious cases, termination of the contract. 

5.6 Rewards 

Praise, merits, certificates, positive notes home and recognition in assemblies. 

5.7 Sanctions (graduated) 

Sanctions are reasonable and proportionate, and take account of SEND and other needs. Before any suspension or termination of a student with SEND or a disability, we consider and record whether the behaviour is linked to their need and what reasonable adjustments have been or could be made. 

5.8 Serious incidents 

Serious incidents (e.g. sharing indecent images, threats, hate incidents) are also safeguarding matters and are referred to a Safeguarding Specialist. Parents may appeal decisions under the Complaints Policy. 

Part 6: Anti-Bullying Policy 

6.1 Definition 

Bullying is behaviour, usually repeated, that intentionally hurts another person physically or emotionally, often where there is an imbalance of power. It includes cyberbullying, prejudice-based bullying (e.g. race, religion, sex, sexual orientation, gender identity, disability) and exclusion from group activities. 

6.2 Prevention 

We promote respect through lessons, assemblies, clear online rules, moderated chat, and teacher supervision of all group spaces. Private student-to-student chat on our platform is disabled. 

8.2 Identifying needs 

Parents should share existing diagnoses, EHCPs or reports at application. Teachers raise concerns with our Safeguarding Specialists, who also act as SEND and pastoral leads. 

8.3 Support we can offer online 

Recorded lessons, captions, adapted resources, extra time on internal assessments, flexible camera use, breaks, seating in smaller groups where available, and a student support plan reviewed termly. 

8.4 Limits 

We are not able to deliver statutory EHCP provision or specialist therapy. Where needs cannot be met reasonably online, we will discuss alternatives honestly with families. 

8.5 Exam access arrangements 

Access arrangements for public exams (e.g. extra time, reader, scribe) are decided by the exam centre and awarding body under JCQ rules, not by us. We can provide evidence of normal way of working to support the centre's application, with your consent, but cannot guarantee any arrangement. 

8.6 Accessibility 

We aim for our website and platform to meet WCAG 2.2 AA. Please tell us about any barriers. 

Part 9: Equality, Diversity & Inclusion Policy 

9.1 Statement 

We are committed to equality of opportunity for students, families, staff and applicants, and we do not discriminate on grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex or sexual orientation (Equality Act 2010). 

9.2 In practice 

9.3 Responsibilities 

The Director leads on EDI. All staff must challenge and report discrimination. Breaches are dealt with under the Behaviour Policy or staff disciplinary procedures. 

Part 10: Complaints Policy & Procedure 

10.1 Aim 

We want to resolve concerns quickly and fairly. This procedure is available to parents and students (and to others for website/service issues). Safeguarding concerns are dealt with under the Safeguarding Policy and allegations against staff under the Managing Allegations Policy. 

10.2 Stage 1 — Informal 

Raise the concern with the teacher or email info@thesproutschool.com. We aim to resolve within 5 working days. 

10.3 Stage 2 — Formal 

If unresolved, write to the Director at info@thesproutschool.com (subject: Formal Complaint). We aim to acknowledge within 3 working days, investigate, and send a written response within 15 working days (or explain any delay). 

10.4 Stage 3 — Review 

If still dissatisfied, request a review within 10 working days. The complaint is reviewed by [a Director not previously involved / independent person], who may meet you online. We aim to give a final written decision within 15 working days. 

10.5 Principles 

Complaints are handled confidentially, without prejudice to the student, and records are kept for 3 years. We will not investigate anonymous complaints unless serious, or complaints raised more than 3 months after the event without good reason. 

10.6 Beyond our procedure 

As we are not a registered school, Ofsted and the DfE do not handle complaints about us. Consumers may seek independent advice from Citizens Advice, use an alternative dispute resolution service (we have not currently appointed an ADR provider), or take legal action. Data protection complaints can go to the ICO. 

Part 11: Whistleblowing Policy 

11.1 Purpose 

To encourage staff, tutors, contractors and volunteers to raise concerns about wrongdoing without fear of reprisal, in line with the Public Interest Disclosure Act 1998. 

11.2 What to report 

Risks to children's safety, failure to follow safeguarding procedures, criminal offences, fraud or financial misconduct, breaches of legal obligations (including data protection), dangers to health and safety, and any attempt to cover these up. 

11.3 How to raise a concern 

11.4 Protection 

Genuine concerns raised in good faith will not lead to any detriment, even if mistaken. Victimising a whistleblower is a disciplinary offence. Deliberately false and malicious reports may be treated as misconduct. 

11.5 Confidentiality and response 

We will protect your identity as far as possible, aim to acknowledge the concern within 5 working days, investigate, and tell you the outcome where appropriate. 

11.6 Personal grievances 

Complaints about your own employment terms are not whistleblowing and should use the grievance procedure. 

Part 12: Academic Integrity & AI Use Policy 

12.1 Principle 

Work submitted must be the student's own. Honesty protects the value of students' learning and their future exam entries. 

12.2 Malpractice includes 

Plagiarism, copying, collusion, submitting work written by others, sharing assessment answers, and misuse of AI tools. 

12.3 AI tools 

Students may use AI tools only when a teacher says so and in the way specified (e.g. for brainstorming or feedback). AI-generated content must never be submitted as the student's own work and must be acknowledged if used. For any coursework or non-exam assessment, the awarding body and exam centre's JCQ rules apply and AI misuse can lead to disqualification. 

12.4 Fair process 

Before any finding of malpractice we: gather the evidence (AI-detection tools alone are never treated as proof); give the student, and a parent for under-18s, the chance to explain, for example by talking through their work; and have a second member of staff review the case. Only after this are outcomes decided, and only then is any matter reported to an exam centre. 

12.5 Consequences 

Work may be re-done or not accepted, parents informed, and serious or repeated cases dealt with under the Behaviour Policy. We will report suspected malpractice to an exam centre where the work forms part of a public assessment. 

Part 13: Prevent & Anti-Radicalisation Policy 

13.1 Status 

The statutory Prevent duty does not apply to us as a non-registered provider, but we follow the Prevent duty guidance voluntarily as part of our safeguarding approach. 

13.2 Our approach 

13.3 Concerns 

Concerns that a student may be vulnerable to radicalisation are reported to a Safeguarding Specialist, who may contact the police Prevent team, the local authority or, in the UK, call 101 (or 999 in an emergency). Non-emergency advice: DfE counter-extremism helpline 020 7340 7264. 

Part 14: Supporting Students with Medical Conditions & Wellbeing Policy 

14.1 Medical information 

Parents (or adult learners) must tell us about any medical condition that may affect learning or could cause an emergency during a lesson (e.g. epilepsy, diabetes, anaphylaxis). We create a simple support plan with the family. 

14.2 Emergencies during lessons 

We cannot provide physical first aid. If a student appears unwell or in distress, the teacher will contact the parent/emergency contact immediately and, if needed, contact the emergency services for the student's location using the local emergency number on the student's record. UK emergency services (999) cannot respond outside the UK. At enrolment families must provide the student's full address, country, local emergency number, time zone and two emergency contacts, and keep these up to date. 

14.3 Mental health and wellbeing 

Pastoral staff offer check-ins and signposting (e.g. Childline, Young Minds, Kooth, or local services abroad). Concerns about self-harm or suicide are always passed to a Safeguarding Specialist the same day. 

14.4 Medication 

Parents are responsible for all medication; staff do not supervise medication.