Safeguarding
- Version
- 1.1
- Policy owner
- Designated Safeguarding Lead
- Approved
- September 2026
- Next review
- April 2027
DAIS-POL-011
Safeguarding Policy
Data and AI School of London, NCFE Approved Centre
Policy Owner: Designated Safeguarding Lead
Version: 1.1 | Date: September 2026 | Review: April 2027
NCFE Risk Level: High
Mode of Delivery: Fully Online
11.1 Purpose and Scope
The Data and AI School of London is committed to protecting all learners from harm, abuse, exploitation, and radicalisation. As the school operates entirely online, this policy addresses the specific safeguarding risks of a digital learning environment.
This policy complies with: the Children Act 1989 and 2004; Keeping Children Safe in Education (KCSIE) 2024; the Counter-Terrorism and Security Act 2015 (Prevent duty); the Online Safety Act 2023; and Working Together to Safeguard Children 2023.
11.2 Designated Safeguarding Lead (DSL)
The school's DSL is named in the staff register and registered with NCFE as a key contact. The DSL holds a Level 3 DSL qualification (or equivalent) plus current online safeguarding training and annual refresher training. In the DSL's absence, a deputy DSL covers responsibilities. The DSL's contact details are published on the VLE.
11.3 Online-Specific Safeguarding Risks
Video Session Standards
All one-to-one sessions between a tutor and a learner under 18 are logged or recorded with consent.
Tutors must not conduct private sessions without informing the DSL.
A second staff member may be invited where appropriate.
Communication Channel Rules
All staff-learner communication must take place through the school's official platform only.
Personal email, WhatsApp, or any messaging app outside the VLE are not permitted.
Staff who receive communications from learners via personal channels must report this to the DSL immediately.
Online Prevent Duty
Tutors must report to the DSL if they become aware that a learner has been exposed to radicalisation material or extremist content through any channel.
All staff complete annual online Prevent awareness training.
The DSL will refer appropriate cases to the local Prevent coordinator or Channel programme.
Online Harassment
Any report of cyberbullying or harassment between learners will be investigated by the DSL and may result in suspension of the relevant learner's platform access.
11.4 Safer Recruitment
All staff with learner contact, including remote tutors, must complete an Enhanced DBS check before beginning work, have their identity verified, provide at least one recent employment reference, and complete the online safeguarding component of induction. The school maintains a Single Central Register (SCR) of all pre-employment checks.
11.5 Reporting a Safeguarding Concern
1. Report to the DSL as soon as possible using the Safeguarding Concern Form on the staff portal (staff) or by emailing the DSL directly (learners).
2. Do not attempt to investigate the concern independently.
3. Record what was seen, heard, or reported, using the learner's own words where possible.
The DSL will assess the concern and, where appropriate, refer to local authority children's services, adult social care, or the police.
11.6 Online Learner Code of Conduct
All learners receive an Online Code of Conduct at induction covering appropriate behaviour during live sessions, respectful communication with tutors and peers, prohibited content on school platforms, and what to do if they feel unsafe.
11.7 Review and Training
This policy is reviewed annually by the DSL and Head of Centre, or sooner following any safeguarding incident. All staff complete safeguarding training at induction and annually thereafter.
Annex A: Learners under 18
This annex applies to any applicant or learner who is under 18 on the date they apply, and continues to apply until their eighteenth birthday. It does not replace anything in sections 11.1 to 11.7, which apply in full to every learner. It records what the school does differently when the learner is a child.
It was added in September 2026, when the school admitted its first applicants under 18. Twenty four of the school's thirty three qualifications carry a minimum age of 16, so this is a standing position rather than an exception.
A.1 Who contracts
A person under 18 cannot be held to a contract for a course, because a course is not a necessary. For every applicant under 18 the parent or guardian is the contracting and paying party. They give their name, relationship, email address and telephone number, confirm in terms that they are entering into the agreement and are responsible for the fee, and sign it. The application cannot be submitted without this.
The young person signs separately to confirm that the information about them is accurate. That is a statement of fact they are able to make. It is not an agreement to pay.
The parent or guardian is recorded as the contracting party in their own right. Naming them as an emergency contact is not sufficient and does not carry the same meaning.
A.2 Before an offer is issued
- The Designated Safeguarding Lead is notified that the applicant is under 18, before the offer is issued rather than after.
- The qualification is checked against its published minimum age. Nine of the school's qualifications are 18 or 19 and over and are not offered to a person under that age in any circumstances.
- The date of birth is confirmed against the identity document at the identity check. Until then it is self declared.
- Where the applicant cannot satisfy the standard identity document list, which is common for people under 18, the Head of Centre records what alternative evidence was accepted and why.
A.3 What the parent or guardian sees, and what they do not
The parent or guardian holds the contract, so they receive everything relating to it: the offer, the fee, payment, cancellation rights, withdrawal and certification.
They are not automatically entitled to everything the learner tells the school. A young person of 16 or 17 can normally expect their own confidences to be respected. The following are shared with a parent or guardian only with the learner's agreement, unless the Designated Safeguarding Lead judges that sharing is necessary to protect the learner or another person:
- a disclosed disability, health condition or learning need, which is special category data and is handled under DAIS-PRIV-001;
- the content of a safeguarding disclosure;
- the substance of pastoral or welfare conversations.
Where the Designated Safeguarding Lead decides to share without agreement, the decision, the reason and the date are recorded.
A.4 Staff who work with learners under 18
Section 11.4 already requires an Enhanced DBS check for all staff with learner contact. For a learner under 18 that check must also include the children's barred list, because teaching or supervising a child is regulated activity. The Single Central Register records which check was obtained, not only that one was.
No member of staff without that check holds a one to one session with a learner under 18.
A.5 Contact and online sessions
The rules in 11.3 apply, with two additions:
- One to one sessions with a learner under 18 are recorded, not merely logged, and the parent or guardian is told at induction that this is the standing arrangement.
- Correspondence about the contract goes to the parent or guardian. Correspondence about learning goes to the learner, with the parent or guardian copied unless the Designated Safeguarding Lead has agreed otherwise under A.3.
A.6 Data protection
DAIS-PRIV-001 governs. In summary: no personal data of a learner under 18 is used for marketing; special category data is held under its own condition and is not shared with a parent or guardian by default; and the retention period is the same as for any other learner and runs from the end of the relationship, not from the eighteenth birthday.
A.7 Review
This annex is reviewed with the policy, and immediately after the first safeguarding concern involving a learner under 18, whatever the outcome.
This policy is reviewed annually. Next review: April 2027. Approved by: Head of Centre. © Data and AI School of London, April 2026, amended September 2026. NCFE Approved Centre.
Version 1.1, 8 September 2026: adds Annex A, Learners under 18, after the school admitted its first applicants under 18. Sections 11.1 to 11.7 are unchanged.