What is this Privacy Policy for?

SK Education Ltd., trading as ‘My Language Lab®’, carries out activities which bring our employees and self-employed tutors into regular unsupervised contact with children and/or vulnerable adults. This includes providing tutoring and educational services in the students’ home via online methods. SK Education Ltd. takes its responsibilities to safeguard and protect the interests of all young children very seriously. This policy is non-contractual but indicates the way in which SK Education Ltd intends to deal with such matters.

Scope of this policy

‍This policy applies to all self-employed tutors, employees, workers or volunteers whose duties bring them into contact with children and/or vulnerable adults.

Aims of this policy

‍This policy aims to create and maintain the safest possible environment for the children and vulnerable adults with whom we deal, as well as for our self-employed tutors, employees and workers, and all reasonable steps will be taken to prevent all parties from harm.

Legal considerations

‍There is a considerable body of legislation designed to ensure that children and vulnerable adults are protected and it is important to understand that everyone is responsible for their safety. The main acts include:

• the Protection of Freedoms Act 2012
  
• Safeguarding Vulnerable Groups Act 2006 (VBS)
• Conduct of Employment Agencies and Employment Business Regulations 2003
• Protection of Children Act 1999/Criminal Justice and Court Services Act 2000
• Care Standards Act 2000
• The Police Act 1997
• The Children (Protection from Offenders) (Miscellaneous Amendments) Regulations 1997
• The United Nations Convention on the Rights of the Child
• the Rehabilitation of Offenders Act 1974
• Health and Safety at Work etc Act 1974 (HASAWA)

Definitions

‍A “child” is anyone under the age of 18.
A “vulnerable adult” is a person aged 18 years or over who is:

• in residential accommodation provided in connection with care or nursing or receiving care or nursing at home
  
• receiving health care
• in lawful custody or under the supervision of a probation officer
• receiving a welfare service of a prescribed description or direct payments from a social services authority
• receiving services, or taking part in activities, aimed at people with disabilities or special needs because of his/her age or state of health.

It may be a person who is unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation. He/she may be elderly or frail, have learning disabilities, suffer from mental illness, have a physical disability, be a substance misuser, be homeless or in an abusive relationship.

Criminal records

‍Those who are involved in work situations where they have sustained or prolonged unsupervised access to children or vulnerable adults are exempt from the Rehabilitation of Offenders legislation. This means that prospective employees, self-employed contractors and volunteers must declare all criminal convictions, however long ago; and these will be taken into account when deciding on their suitability for working with children or vulnerable adults. No-one will be permitted to undertake a role which involves regular contact with children or vulnerable adults without a satisfactory Disclosure and Barring Service (DBS) check.

Planning and supervision

‍All activities or assignments involving children or vulnerable adults should be planned in advance to ensure they take into account the age range and ability of the participants. Staff, volunteers or freelancers supervising assignments involving children/vulnerable adults should be competent to do so. Supervision should take account of the age, gender, nature of the activity and any special needs of the individuals. Where appropriate, a risk assessment will be undertaken and documented.

Communication

‍Communication with children/vulnerable adults is vital in establishing relationships built on trust. Those working with children or vulnerable adults should listen to what they are saying and respond appropriately. Children and vulnerable adults are entitled to the same respect as any self-employed tutors, employees, workers and volunteers. It should also be made clear to them what standards of behaviour and mutual respect are expected from them.Those working with children/vulnerable adults should behave appropriately, ensure that language is moderated in their presence and should refrain from adult jokes or comments which are clearly unsuitable.

Behaviour and abuse

‍We should all aim to promote an environment of trust and understanding. Those working with children/vulnerable adults should not tolerate unsociable behaviour but should try to ensure good working relationships.

All self-employed tutors, employees, workers and volunteers at SK Education Ltd. have a strict duty never to subject any child/vulnerable adult to any form of harm or abuse. This means that it is unacceptable, for example, to treat a child/vulnerable adult in any of the following ways:

• to cause distress by shouting or calling them derogatory names
  
• to allow or engage in sexually suggestive behaviour within a person’s sight or hearing, or make suggestive remarks to or within earshot
• to give or show anything which could be construed as pornographic
• to seek or agree to meet them anywhere outside of the normal workplace without the full prior knowledge and agreement of the parent, guardian or carer.
• to engage with them online in an unacceptable manner.

Suspicions of abuse

‍Any worker who witnesses or suspects abusive behaviour towards a child/vulnerable adult should record the details and report it to SK Education Ltd. It is NOT the individual’s responsibility to investigate his/her suspicions – this requires expertise he/she is not expected to have.

Any allegations of abuse made against anyone working for SK Education Ltd. will be thoroughly investigated and dealt with through our disciplinary procedure for employees. Serious breaches may lead to dismissal (for employees) or termination of any agreement (for self-employed tutors, workers or volunteers).

SK Education Ltd. will appropriately record an allegation or reported incident. He/she will be responsible for contacting the statutory child protection agency such as the Local Safeguarding Children Board or the police if necessary.

Safety

‍The safety of the people we work with is paramount and we are committed to providing a safe environment within which to work. Those working with children/vulnerable adults should ensure all appropriate risk assessments and security checks have been carried out prior to any assignment.

Confidentiality

‍All personal information regarding children/vulnerable adults is highly confidential and should only be shared with appropriate people on a need to know basis. Anyone who is likely to have access to confidential material regarding children or vulnerable adults, or any of the bodies on behalf of whom SK Education Ltd. is working, may be required to sign a non-disclosure agreement. The requirement for confidentiality is emphasised.

Contact outside of work

‍Contact should not be made with any of the children/vulnerable adults with whom we are working for any reason unrelated to the particular work. In particular, our self-employed tutors and employees are required to maintain our reputation for integrity and responsibility in dealing with such people, and should not enter into any social or other non-work related arrangements with them.

Gifts and inducements

‍On no account should anyone from SK Education Ltd. give a child/vulnerable adult a gift which could be in any way considered as a bribe or inducement to enter into a relationship with SK Education Ltd. or give rise to any false allegations of improper conduct against the individual.

Communicating this policy and concerns

‍All employees, workers and volunteers at SK Education Ltd. will be made aware of this policy and a copy will be available via the website.

Furthermore, a copy of this policy will be made available to all relevant bodies with whom we work and will be made available to parents and carers of children/vulnerable adults with whom we plan to work.

Any concerns about the assignment or people involved should be addressed with SK Education Ltd.

Breach of this policy

‍Failure to follow the guidelines in this policy is considered a serious offence and will be investigated thoroughly and dealt with through our disciplinary procedure for employees. Serious breaches may lead to dismissal (for employees) and termination of any agreement (for self-employed tutors, workers or volunteers).

Implementation, monitoring and review of this policy

‍This policy will be reviewed on a regular basis following its implementation and additionally whenever there are relevant changes in legislation or to our working practices.