Policies

Privacy Policy

This Privacy Policy explains how Mark Trewby/BAT Education ("we," "us," or "our") collects, uses, shares, and protects personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). We are committed to safeguarding the privacy and security of personal information provided to us in the course of our tuition services.

Data Controller

• • Mark Trewby is the data controller responsible for the processing of personal data collected through our tuition services. If you have any questions or concerns regarding the processing of your personal data, please contact us using the details provided at the end of this policy.

• Legal Basis for Processing

  • We process personal data based on one or more of the following legal bases:

    • Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

    • Legitimate Interests: Processing is necessary for our legitimate interests or the legitimate interests of a third party, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

    • Compliance with Legal Obligations: Processing is necessary for compliance with a legal obligation to which we are subject.

    • Consent: Processing is based on your consent, which you may withdraw at any time.

• Information We Collect

  • We collect and process various types of information, including personal data, for the following purposes:

    • Contact information (such as name, address, email address, and telephone number) to communicate with you regarding our tuition services and to schedule sessions.

    • Student information (such as name, age, grade level, and academic performance) to tailor tuition sessions to individual student needs and monitor progress.

• Use of Information

  • We use the information we collect for the following purposes:

    • To provide tuition services and fulfil our contractual obligations towards students, parents/guardians, schools/local authorities and/or other organisations to whom we deliver tuition services.

    • To communicate with students, parents/guardians, tutors, teachers (where applicable) regarding tuition sessions, scheduling, updates and feedback (where applicable).

    • To monitor student progress and academic performance, and provide feedback and support as necessary.

    • To comply with legal and regulatory requirements, including record-keeping, reporting and safeguarding obligations.

    • To improve our tuition services, develop new programs and enhance the overall learning experience.

• Sharing of Information

  • We may share personal information with the following categories of recipients:

    • Parents/Guardians: We may share student information with parents/guardians to provide updates, feedback and progress reports.

    • Schools: We may share information relating to students with schools and their employees (e.g. teachers) either where the school is our client and has contracted for us to deliver tuition services to one or more of their students, or where a Parent/Guardian for the student has given us their consent, in writing, to share information with the student’s school.

    • Service Providers: We may engage third-party service providers to assist us in providing tuition services, such as IT service providers, payment processors, and administrative support.

    • Regulatory Authorities: We may disclose information to regulatory authorities or law enforcement agencies as required by law or to protect our legal rights.

  • We do not sell or rent personal information to third parties for marketing purposes.

• Data Retention

  • We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting requirements. The specific retention period for personal data may vary depending on the nature of the data and the purposes for which it is processed.

• Data Subject Rights

  • Under applicable data protection laws, you have certain rights regarding your personal data, including:

    • Right of Access: You have the right to request access to your personal data and information about how it is processed.

    • Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.

    • Right to Erasure: You have the right to request the deletion of your personal data under certain circumstances.

    • Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data under certain circumstances.

    • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.

    • Right to Object: You have the right to object to the processing of your personal data under certain circumstances, including processing for direct marketing purposes.

    • Right to Withdraw Consent: If processing is based on your consent, you have the right to withdraw your consent at any time.

  • To exercise any of these rights, or if you have any questions or concerns about the processing of your personal data, please contact us using the details provided at the end of this policy.

• Data Security

  • We implement appropriate technical measures and adopt relevant policies and processes, as an organisation, in order to protect the security and confidentiality of personal information. These measures include access controls (e.g. secure passwords), encryption, 2-factor authentication, and regular security assessments. However, please note that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

  • Special category data and data relating to children (under the age of 18) and vulnerable adults (“Sensitive Data”) that is collected and processed in accordance with this policy shall be stored subject to additional reviews by our internal team to ensure that we are satisfied that the storage and processing of that data is appropriate. In particular, Sensitive Data shall be subject to the following additional safeguards:

    • We shall review where Sensitive Data is stored periodically and at least every three (3) months to ensure that it is appropriately secured and protected.

    • We shall maintain robust processes that govern the access to and retrieval of Sensitive Data, which shall include:

      • Who can access Sensitive Data, and how much access they will need at any given point in time in order to discharge our duties to you or to any lawful authority;

      • What Sensitive Data is permitted to be used for (which shall be restricted only to that use which is reasonably necessary for us to discharge our contractual and/or statutory duties);

      • What processing takes place when Sensitive Data is retrieved, including guidelines about what copies might be made, what they will be used for and where they will be stored.

  • In the event that there was to be any data breach of any kind (either suspected or known), we will undertake to:

    • Immediately take action to assess and mitigate the extent of any such breach.

    • Take steps to promptly assess what data has been, or may have been, compromised.

    • Inform data subjects of the data breach, using clear and jargon-free language.

    • Take any measures that may be necessary in order to prevent compromised data being used by an unauthorised third party (e.g. recommending to data subjects that they change passwords that may have been compromised).

    • Where appropriate, we will keep data subjects informed of any change to the level of risk we assess exists as a result of any such breach.

• Changes to this Privacy Policy

  • We reserve the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the updated Privacy Policy on our website. We encourage you to review this Privacy Policy periodically for any changes.

• Contact Us

  • If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your data subject rights, please contact us:
    Mark Trewby, BAT Education, 104 Headswell Avenue, Bournemouth, Dorset, BH10 6LD
    mark@bat.education
    07971348106

Last updated: 14/11/2024

Next update: 14/11/2025

Safeguarding Policy

Person Responsible for this Policy: Mark Trewby

1.     Introduction, Government Guidance and Aims

BAT Education is committed to the wellbeing and safeguarding of all children, adults and staff who attend tuition with them. This policy’s main aim is to provide all children and adults with a comprehensive, secure and clear commitment to safeguarding and a framework to ensure all children attending BAT Education are protected from harm.

This Safeguarding and Child Protection Policy is written with consideration of the following Department for Education statutory guidance:

·      Keeping Children Safe in Education (2024)

·      Working Together to Safeguard Children (2023)

 and the following guidance from HM Government:

·      Prevent Duty Guidance (2023)

·      Information Sharing: advice for practitioners providing safeguarding services (2024)

and the following Department for Education non-statutory guidance:

·      After-school clubs, community activities and tuition: safeguarding guidance for providers (2023)

·      What to do if you’re worried a child is being abused (2015)

In addition, this setting operates in accordance with the local authority in partnership to keep children safe. Details of the local authority can be found here:

BCP Children’s First Response Hub

Office hours are Monday to Thursday 8.30 to 5.15 pm and Fridays 8.30 to 4.45 pm.
01202 123334

childrensfirstresponse@bcpcouncil.gov.uk

Out of hours service

Hours of operation are 5.00pm to 9.00am from Monday to Friday, all day Saturdays and Sundays and all bank holidays, including Christmas Day and New Year's Day.

01202 738256

childrensoohs@bcpcouncil.gov.uk 

In cases where a criminal offence has been committed or it is suspected that one has been committed, the matter must be reported immediately to the local police force using the 101 service. In an emergency this must be reported using the 999 service. Definitions of ‘significant harm’ are taken from Section 47 of The Children Act (1989). This policy is available to all parents whose children use our service and is available on our public-facing website. For the purpose of this policy, ‘children’ refers to any student under the age of 18 attending the setting.

The aims of this policy are:

·      To ensure that all understand the importance of safeguarding and that it is everyone’s responsibility

·      To support any child who makes a disclosure of abuse 

·      To ensure everyone at BAT Education knows who to inform in the event of a disclosure, concern or safeguarding issue and to ensure they are alert to the signs of possible child abuse

·      To aid everyone at BAT Education in understanding and recognising specific safeguarding concerns

·      To ensure, in accordance with The Children Act 1989, that the welfare of the child is paramount at all times

2.     Designated Safeguarding Lead

The Designated Safeguarding Lead is Mark Trewby (owner).

The role of the Designated Safeguarding Lead (DSL) is to:

·       Be a point of advice on safeguarding and pastoral issues

·       Have overall responsibility for safeguarding

·       Raise awareness of safeguarding amongst those attending the setting

·       Manage referrals from to the local authority

·        Manage the record-keeping of safeguarding concerns and ensure records are kept up to date

·       To update their own Level 3 safeguarding training at least once every two years using an external provider including Online Safety training and Prevent training

·       Make referrals to the local authority Prevent Officer under the Counter-Terrorism and Security Act 2015

3.     Safeguarding Issues

For further details and definitions of types of abuse and neglect, we can reference DfE guidance Working Together to Safeguard Children (2023) and Keeping Children Safe in Education (2024). External training will also reference these documents including definitions of abuse and neglect. 

a. Types of abuse

For the purposes of this policy, BAT Education are aware of and vigilant to the following types of abuse and safeguarding issues:

·      Physical abuse

·      Emotional abuse

·      Sexual abuse

·      Neglect

·      Child on child abuse (see below)

·      Extremism and radicalisation

·      Sexual harassment

·      Bullying

·      Substance abuse

·      Online exploitation and abuse

·      Domestic abuse

b. Contextual safeguarding

We are also aware that safeguarding incidents and behaviours can occur outside the home environment and are vigilant to reports of these. These contextual safeguarding issues form part of external training. These include:

·      Child Sexual Exploitation

·      Child Criminal Exploitation

·      Female Genital Mutilation

·      Honour Based Abuse

·      Knife Crime

·      Children Absent from Education

c. Child on child abuse

Such abuse can include:

·      abuse in intimate personal relationships between children

·      harmful sexual behaviour including but not limited to the use of inappropriate sexual language, sharing of nude of semi-nude images or videos, upskirting, sexual violence

·      bullying (including cyberbullying)

·      physical abuse such as:

o   hitting

o   kicking

o   shaking

o   biting

o   hair pulling

o   otherwise causing physical harm

d. Children with Additional Educational Needs, Disabilities and other vulnerabilities

BAT Education are aware that children with Additional Educational Needs, disabilities or health issues may face additional safeguarding issues. We are vigilant to:

·      Any indicators of possible abuse not in keeping with the child’s additional needs or history

·      Any communication challenges the child faces in disclosing the abuse (for example, if the child is non-verbal)

·      The fact that children with additional needs or other vulnerabilities are disproportionally impacted by abuse and behaviours such as bullying

·      That children who are (or are perceived to be) lesbian, gay, bisexual or trans are more likely to suffer child on child abuse and are more vulnerable to abuse

4.     Reporting Concerns about a child

BAT Education  are aware that barriers to reporting abuse exist, and that some children may not be ready or not know how to tell someone that they are being abused. We are aware that children with Additional Educational Needs or disabilities are more vulnerable to abuse. We never assume that an issue has been reported or disclosed by another person.

If a child discloses abuse:

·      We will stop and listen straight away without delay

·      We will write notes as soon as possible after the conversation

·      We must not guarantee confidentiality 

·      We use TED – Tell me, Explain to me, Describe to me. We can ask children whether they have been harmed and the nature of that harm, without asking leading questions. 

·      We  will not conduct our own investigation but will refer immediately

·      We will maintain a calm and professional attitude and prioritise the wellbeing of the child at all times. 

Reports to the local authority children's safeguarding board must be undertaken:

·      As soon as possible and within 2 hours of the concern being raised or suspected

·      For a child at risk or suspected to be at risk of significant harm, the concern must be raised immediately 

·      In person or by telephone as required by local services.      

We note that it is usually best practice to share concerns with parents/ carers. However, for children at risk of significant harm (or where there is reasonable cause to suspect this), it may not be appropriate to do so. Decisions on whether to share information must be made in conjunction with the DSL. It may be helpful to refer to the following guidance:

https://www.gov.uk/government/publications/safeguarding-practitioners-information-sharing-advice

The DSL will decide if a concern should be raised with the local authority. If a child is at risk of significant harm, in accordance with Section 47 of The Children Act (1989), statutory child protection agencies will conduct the investigation and the DSL must not investigate. At all times, decision-making in this regard must be documented, including:

·      Who raised the concern (include details of date, time, job title)

·      Who was the concern raised about (include details of child’s name, date of birth, address, school)

·      What decision was made and why – what were the reasons for making the referral

·      Who was consulted

·      What action was taken

·      Whether parents/ carers were consulted and if not, why not

5.     Useful Contact Details

DSL - Mark Trewby

Local authority contacts

LADO - Allyson Donovan, Hayley Cowmeadow and Tina Cooper

01202 817600 lado@bcpcouncil.gov.uk

Specialist helplines

Police – immediate threat - 999

Police – serious concerns – 101

Prevent (non-emergency advice) – 0800 011 3764

NSPCC helpline – 0808 800 5000

Childline – 0800 1111

Ofsted – 0300 123 4666

Mark Trewby, BAT Education

104 Headswell Avenue, Bournemouth, Dorset, BH10 6LD

mark@bat.education

07971348106

Last updated: 14/11/2024

Next update: 14/11/2025