Safeguarding Policy

Tutor Volt Ltd | Last updated: 15 February 2026

1. Policy Statement

Tutor Volt Ltd ("Tutor Volt") is committed to safeguarding and promoting the welfare of all children and young people who use our platform. We recognise that every child has a right to be safe, and we take our responsibility to protect children seriously.

This policy applies to all Tutor Volt staff, contractors, and partners, and to all users of the Platform. It is aligned with:

• Keeping Children Safe in Education (KCSIE) 2025 -- Department for Education statutory guidance
• Working Together to Safeguard Children 2023 -- HM Government inter-agency guidance
• The Children Act 1989 and 2004
• The Education Act 2002 (Section 175)
• The UK Age Appropriate Design Code (AADC)
• Online Safety Act 2023

This policy is reviewed annually and updated as necessary to reflect changes in legislation, guidance, or best practice.

2. Scope

This policy covers:

• All students aged 5 to 16 who use the Tutor Volt platform
• All interactions between students and the AI tutor (Live Wire)
• All content created, shared, or accessed through the Platform
• All staff, contractors, and third parties who have access to student data
• Marketplace tutors who provide services through the Platform

3. Designated Safeguarding Lead (DSL)

3.1 Appointment

Tutor Volt shall appoint a Designated Safeguarding Lead (DSL) who has overall responsibility for safeguarding on the Platform. The DSL holds, or is working towards, a Level 3 Designated Safeguarding Lead qualification.

3.2 DSL Responsibilities

The DSL is responsible for:

• Acting as the primary point of contact for all safeguarding concerns identified through the Platform
• Reviewing and acting upon alerts generated by the Platform's automated safeguarding monitoring system
• Liaising with schools' Designated Safeguarding Leads when concerns involve school-linked students
• Making referrals to local authority children's social care, the police, or other agencies as appropriate
• Maintaining safeguarding records securely and in accordance with retention requirements
• Ensuring all Tutor Volt staff receive appropriate safeguarding training
• Reviewing this policy annually and recommending updates
• Providing safeguarding reports to the Tutor Volt leadership team

3.3 Contact

• Email: [email protected]
• Urgent concerns: The DSL is available during business hours (Monday-Friday, 9:00-17:30 GMT). Outside these hours, critical alerts are escalated automatically (see Section 5).

4. Platform Safeguarding Measures

4.1 AI-Powered Content Monitoring

All student interactions on the Platform are monitored in real-time by an automated safeguarding detection system. This system analyses:

• All messages sent to the AI tutor (Live Wire)
• All content generated by the AI in response to student queries
• All text input across the Platform

The monitoring system uses 210+ keyword and phrase patterns across multiple categories, including:

• Self-harm and suicide
• Abuse (physical, emotional, sexual, neglect)
• Exploitation (criminal, sexual, online)
• Bullying and harassment
• Radicalisation and extremism
• Substance abuse
• Domestic violence and family concerns
• Mental health crises

4.2 Severity Tiers

Detected safeguarding concerns are classified into four severity tiers, each with a defined response:

| Tier | Severity | Response | Timeframe | |---|---|---|---| | CRITICAL | Immediate risk to life or safety (e.g. active suicidal ideation, disclosure of ongoing abuse, immediate danger) | Crisis resources displayed immediately to the student (Childline: 0800 1111, emergency services: 999). DSL notified by automated alert. Evidence preserved and protected. AI session ended with safety message. | Immediate (automated) + DSL response within 30 minutes during business hours | | HIGH | Serious concern requiring prompt action (e.g. historical abuse disclosure, concerning behaviour patterns, exploitation indicators) | Safeguarding alert created in the system. DSL notified by email and in-platform alert. School's Designated Safeguarding Lead notified where applicable. | DSL review within 4 hours during business hours | | MEDIUM | Concern requiring review (e.g. indirect references to harm, wellbeing indicators, peer conflict) | Flagged for DSL review. Logged in safeguarding records. | DSL review within 24 hours | | LOW | Minor concern for monitoring (e.g. mild language, off-topic queries, general wellbeing check) | Logged in safeguarding records. No immediate action required. Reviewed in periodic audit. | Reviewed in weekly audit |

4.3 AI Safety Controls

The AI tutor (Live Wire) incorporates the following safety controls:

• Content filtering: The AI is instructed to refuse requests for harmful, inappropriate, or dangerous content
• Age-appropriate responses: AI responses are calibrated to the student's age and year group
• Safeguarding prompts: When the AI detects potential safeguarding language, it provides supportive responses and signposts to help resources
• Session termination: In CRITICAL scenarios, the AI session is ended with a safety message directing the student to appropriate support
• Topic boundaries: The AI redirects conversations that stray significantly from educational topics

4.4 DBS Verification

All marketplace tutors who interact with students through the Platform must:

• Hold a valid Enhanced DBS (Disclosure and Barring Service) certificate
• Provide evidence of their DBS status during registration
• Undergo identity verification
• Complete Tutor Volt's safeguarding training module before being approved
• Renew their DBS verification annually

Tutor Volt reserves the right to suspend any tutor's access pending DBS verification or where a safeguarding concern is raised.

5. Reporting Procedures

5.1 Automated Reporting

The Platform's automated monitoring system handles initial detection and classification. For CRITICAL alerts:

1. Crisis resources (Childline: 0800 1111, emergency: 999) are displayed to the student immediately
2. The DSL receives an automated email alert within minutes
3. An in-platform notification is created with full context (chat transcript, user details, school affiliation)
4. Evidence is preserved and access-restricted to the DSL and authorised safeguarding personnel
5. The school's Designated Safeguarding Lead is notified (if the student is school-linked)

5.2 Manual Reporting

Any user who has a safeguarding concern may report it:

• In-platform: Using the "Report a concern" button available on all pages
• Email: [email protected]
• School DSL: Teachers and staff should also report to their school's Designated Safeguarding Lead in accordance with school policy

5.3 What to Do If a Child Is in Immediate Danger

If you believe a child is in immediate danger:

1. Call 999 and request police assistance
2. Contact the school's Designated Safeguarding Lead immediately
3. Email [email protected] with "URGENT" in the subject line
4. Do not attempt to investigate the matter yourself

5.4 External Referrals

Where the DSL determines that a referral to external agencies is necessary, they will:

• Contact the relevant local authority children's social care team
• Cooperate with police investigations where appropriate
• Make referrals to the DBS if a person in regulated activity poses a risk to children
• Report to the National Crime Agency (NCA) if child sexual exploitation material is identified
• Contact the Counter-Terrorism Police (via the Prevent duty helpline) if radicalisation is suspected

6. Staff Training

6.1 All Staff

All Tutor Volt staff members, regardless of role, must:

• Complete safeguarding awareness training within their first week of employment
• Complete annual refresher training
• Read and confirm understanding of this Safeguarding Policy

6.2 DSL and Safeguarding Team

The DSL and members of the safeguarding team must:

• Complete Level 3 Designated Safeguarding Lead training (or equivalent)
• Complete refresher training every two years
• Attend inter-agency safeguarding training as available
• Stay up to date with changes to KCSIE, Working Together, and other relevant guidance

6.3 Technical Staff

Staff with access to the safeguarding monitoring system or student data must:

• Complete enhanced safeguarding training covering data handling and confidentiality
• Be subject to DBS checks
• Sign confidentiality agreements

6.4 Marketplace Tutors

All marketplace tutors must:

• Complete Tutor Volt's online safeguarding training module before being approved to use the Platform
• Acknowledge their duty to report safeguarding concerns
• Complete annual refresher training

7. Online Safety

7.1 Age-Appropriate Design

The Platform is designed in accordance with the UK Age Appropriate Design Code (AADC):

• Default privacy settings are set to the highest level of protection
• No targeted advertising or marketing to children
• Gamification features include protections against excessive use (30-minute break reminders; no FOMO-inducing mechanics for users under 10)
• Location data is not collected
• Profiling is limited to educational personalisation with clear opt-out options

7.2 Content Moderation

All AI-generated content is subject to:

• Automated content filtering before delivery to students
• Teacher review and approval before publication of lesson materials
• Ongoing monitoring for quality and appropriateness

7.3 Communication Safety

• Students cannot communicate directly with other students through the Platform
• All student communication is with the AI tutor, which is monitored
• Teachers communicate with students only through structured Platform features (lesson publishing, feedback, announcements)

8. Record Keeping

8.1 Safeguarding Records

All safeguarding concerns, whether identified automatically or reported manually, are recorded securely in the Platform's safeguarding log. Records include:

• Date and time of the concern
• Details of the concern (including any chat transcripts)
• Severity classification
• Actions taken
• Outcome
• Name of the person who identified or reported the concern
• Name of the DSL who reviewed the concern

8.2 Retention

Safeguarding records are retained until the data subject reaches the age of 25, in accordance with KCSIE guidance. Records are stored securely with access restricted to the DSL and authorised safeguarding personnel.

8.3 Transfer

Where a student leaves a school and transfers to another school using the Platform, the DSL will ensure that any relevant safeguarding information is transferred securely to the receiving school's Designated Safeguarding Lead, with appropriate confidentiality.

9. Whistleblowing

Staff, contractors, and tutors who have concerns about the conduct of any person involved with Tutor Volt (including concerns about the organisation itself) should report those concerns to:

• The DSL: [email protected]
• Senior management: If the concern involves the DSL, report to [email protected]
• External bodies: Staff may also report concerns to the NSPCC whistleblowing helpline (0800 028 0285) or to Ofsted

Tutor Volt will not tolerate retaliation against any person who raises a safeguarding concern or whistleblowing report in good faith.

10. Review

This Safeguarding Policy is reviewed annually by the DSL and the Tutor Volt leadership team. The review considers:

• Changes to legislation and statutory guidance (particularly KCSIE)
• Incidents and near-misses from the previous year
• Feedback from schools and users
• Advances in technology and AI safety
• Recommendations from external audits or inspections

The next review is scheduled for February 2027.

11. Key Contacts

| Contact | Details | |---|---| | Tutor Volt DSL | [email protected] | | Tutor Volt DPO | [email protected] | | Childline | 0800 1111 | | NSPCC Helpline | 0808 800 5000 | | NSPCC Whistleblowing | 0800 028 0285 | | Police (non-emergency) | 101 | | Police (emergency) | 999 | | Prevent Helpline | 020 7340 7264 | | CEOP (online exploitation) | ceop.police.uk |

This Safeguarding Policy is effective from 15 February 2026. It will be reviewed annually.