Footnote Education Logo; navy blue letters against a white background

Online Safety Policy

Policy Owner: Joshua Lynbeck

Approved By: Charlotte Lynbeck

Effective Date: 01/05/2026

Review Date: 01/05/2027

Applies To: All staff, tutors, contractors, volunteers, students, parents/carers, and third-party providers.

1. Policy Statement

Footnote Education is committed to safeguarding and promoting the welfare of children and young people during all online tuition activities. The company recognises that online learning environments present specific safeguarding and online safety risks, including cyberbullying, inappropriate contact, grooming, data breaches, harmful content exposure, and misuse of digital technology.

This policy establishes the company’s approach to online safety, digital safeguarding, acceptable use of technology, and protection of students participating in online one-to-one Humanities tuition.

The company adopts a proactive safeguarding culture in which online safety is considered an integral part of child protection and safer working practice.

2. Scope

This policy applies to:

  • All online tuition sessions; 

  • All digital communication between tutors and students; 

  • All company-owned and approved digital platforms; 

  • Tutors, staff, contractors, volunteers, and agency workers; 

  • Students under the age of 18; 

  • Parents/carers where relevant. 

This policy should be read alongside:

  • Safeguarding and Child Protection Policy; 

  • Staff Code of Conduct; 

  • Data Protection and Privacy Policy; 

  • Acceptable Use Policy; 

  • Complaints Policy. 

3. Legislative and Regulatory Framework

This policy is informed by and operates in accordance with relevant UK legislation and statutory guidance, including:

  • The Children Act 1989 and 2004; 

  • Working Together to Safeguard Children (HM Government); 

  • Keeping Children Safe in Education (KCSIE); 

  • The Education Act 2002; 

  • The UK General Data Protection Regulation (UK GDPR); 

  • The Data Protection Act 2018; 

  • The Computer Misuse Act 1990; 

  • The Protection of Children Act 1978; 

  • The Sexual Offences Act 2003; 

  • The Malicious Communications Act 1988; 

  • The Communications Act 2003; 

  • The Equality Act 2010; 

  • The Prevent Duty under the Counter-Terrorism and Security Act 2015; 

  • The Online Safety Act 2023. 

The company also follows relevant guidance from:

  • The Department for Education (DfE); 

  • Ofcom; 

  • The NSPCC; 

  • UK Safer Internet Centre; 

  • Child Exploitation and Online Protection Command (CEOP). 

Government guidance states that safeguarding principles applicable in face-to-face education also apply to remote and online education. 

4. Definitions

Online Safety

Online safety refers to the safe, responsible, and appropriate use of digital technologies and online communication platforms.

Safeguarding

Safeguarding means protecting children from maltreatment, preventing impairment of mental and physical health or development, and ensuring children grow up in safe and effective care environments.

Harmful Online Behaviour

This includes, but is not limited to:

  • Cyberbullying; 

  • Grooming; 

  • Harassment; 

  • Sexting or sharing indecent images; 

  • Radicalisation; 

  • Exposure to harmful or extremist content; 

  • Identity theft; 

  • Online exploitation; 

  • Coercive or controlling behaviour; 

  • Inappropriate online contact. 

5. Roles and Responsibilities

5.1 Directors and Senior Management

Senior management are responsible for:

  • Ensuring appropriate safeguarding arrangements are in place; 

  • Monitoring compliance with this policy; 

  • Providing safe digital systems and approved platforms; 

  • Ensuring staff receive online safety training; 

  • Appointing a Designated Safeguarding Lead (DSL). 

5.2 Designated Safeguarding Lead (DSL)

The DSL is responsible for:

  • Managing safeguarding concerns arising online; 

  • Responding to allegations or incidents; 

  • Maintaining safeguarding records; 

  • Liaising with external agencies where necessary; 

  • Monitoring online safeguarding risks; 

  • Supporting tutors regarding online safety concerns. 

5.3 Tutors and Staff

Tutors must:

  • Maintain professional boundaries at all times; 

  • Use only approved company communication channels; 

  • Report safeguarding concerns immediately; 

  • Deliver sessions in line with safer working practices; 

  • Avoid private or secretive communication with students; 

  • Complete mandatory safeguarding and online safety training. 

5.4 Parents and Carers

Parents/carers are encouraged to:

  • Support safe online learning at home; 

  • Supervise students appropriately; 

  • Ensure students access tuition from suitable locations; 

  • Report concerns promptly. 

5.5 Students

Students are expected to:

  • Behave respectfully online; 

  • Use company systems appropriately; 

  • Report anything that makes them feel unsafe; 

  • Avoid sharing personal information unnecessarily. 

6. Safer Online Tuition Practices

To reduce safeguarding risks, the company adopts the following measures:

6.1 Approved Platforms

All tuition must take place using company-approved platforms with suitable security controls, such as:

  • Waiting rooms; 

  • Password-protected sessions; 

  • Secure login requirements; 

  • Moderation features; 

  • Recording capability where appropriate. 

Tutors must not use personal social media accounts or unauthorised messaging platforms to communicate with students.

6.2 Professional Conduct

Tutors must:

  • Use professional language and behaviour; 

  • Conduct sessions from appropriate environments; 

  • Dress appropriately; 

  • Avoid one-to-one communication outside agreed channels; 

  • Never exchange personal contact details with students. 

6.3 Session Recording

Where appropriate and lawful, sessions may be recorded for safeguarding, quality assurance, or training purposes.

Students and parents/carers will be informed where recordings occur.

Recordings shall be:

  • Securely stored; 

  • Access-controlled; 

  • Retained in accordance with the company retention schedule; 

  • Deleted when no longer required. 

6.4 Appropriate Learning Environment

Students should participate in tuition:

  • In a communal or appropriate home environment where possible; 

  • Using suitable devices; 

  • Free from inappropriate background content. 

Tutors should minimise risks associated with students learning in isolation.

7. Communication Rules

Permitted communication methods include:

  • Company email systems; 

  • Approved learning platforms; 

  • Company-monitored messaging systems. 

The following are prohibited unless expressly authorised:

  • Personal mobile phone communication; 

  • Personal email accounts; 

  • Social media contact; 

  • Encrypted disappearing-message applications. 

Communication must occur during reasonable hours unless exceptional circumstances apply.

8. Online Safety Risks

The company recognises the following risks associated with online tuition:

  • Exposure to inappropriate or harmful content; 

  • Online grooming; 

  • Cyberbullying; 

  • Radicalisation and extremist material; 

  • Misuse of webcams or recordings; 

  • Unauthorised sharing of content; 

  • Data breaches; 

  • Impersonation and fake identities; 

  • Inappropriate tutor-student relationships; 

  • Technology-enabled abuse. 

Under the Online Safety Act 2023, organisations operating online services must assess and mitigate risks to children where children are likely users of the service. 

9. Safeguarding Procedures

Any safeguarding concern arising online must be treated seriously and reported immediately.

Examples include:

  • Disclosure of abuse; 

  • Concerning online behaviour; 

  • Inappropriate communications; 

  • Exposure to harmful material; 

  • Suspected grooming; 

  • Signs of neglect or exploitation observed during sessions. 

Staff must:

  1. Record concerns accurately; 

  2. Report concerns immediately to the DSL; 

  3. Avoid investigating independently; 

  4. Preserve evidence where appropriate. 

The DSL will determine whether referral to external agencies is necessary, including:

  • Local Authority Children’s Services; 

  • Police; 

  • CEOP; 

  • Prevent teams. 

10. Cyberbullying

Cyberbullying will not be tolerated.

Examples include:

  • Abusive messages; 

  • Exclusion; 

  • Harassment; 

  • Sharing humiliating material; 

  • Threatening behaviour. 

Incidents will be investigated promptly and may result in:

  • Suspension from tuition; 

  • Parent/carer involvement; 

  • Referral to external agencies; 

  • Termination of services. 

11. Filtering and Monitoring

The company will implement proportionate filtering and monitoring measures to reduce exposure to harmful content and inappropriate activity.

Measures may include:

  • Secure platforms; 

  • Restricted file-sharing permissions; 

  • Monitoring of communication systems; 

  • Access controls; 

  • Antivirus and cybersecurity protections. 

Government guidance recommends the use of filtering systems and safeguarding controls in remote education environments. 

12. Data Protection and Privacy

The company processes personal data in accordance with UK GDPR and the Data Protection Act 2018.

Personal information shall be:

  • Collected lawfully and transparently; 

  • Used only for legitimate purposes; 

  • Kept secure; 

  • Retained only as long as necessary. 

Tutors must:

  • Use secure passwords; 

  • Protect devices; 

  • Avoid downloading confidential data onto personal devices where possible; 

  • Report data breaches immediately. 

Students’ personal information must not be shared without lawful justification.

13. Use of Artificial Intelligence (AI)

Where AI-assisted tools are used:

  • Human oversight must remain in place; 

  • AI tools must not replace safeguarding judgement; 

  • Sensitive personal data must not be input into unsecured AI systems; 

  • Outputs must be reviewed for accuracy and appropriateness. 

The company will assess emerging technologies for safeguarding implications before adoption.

14. Staff Recruitment and Training

All tutors and relevant staff will receive:

  • Safeguarding training; 

  • Online safety training; 

  • Prevent awareness training; 

  • Data protection training. 

Appropriate safer recruitment checks will be completed, including:

  • Enhanced DBS checks where applicable; 

  • Identity verification; 

  • Reference checks; 

  • Right-to-work checks. 

15. Allegations Against Staff

Any allegation involving inappropriate online conduct by a tutor or staff member will be managed in accordance with safeguarding procedures and statutory guidance.

This may include:

  • Immediate risk assessment; 

  • Suspension of online access; 

  • Referral to the Local Authority Designated Officer (LADO); 

  • Referral to the Disclosure and Barring Service (DBS); 

  • Police involvement where appropriate. 

16. Incident Management

Online safety incidents will be:

  • Logged; 

  • Investigated proportionately; 

  • Reviewed for lessons learned; 

  • Used to improve safeguarding systems. 

Serious incidents may require:

  • Notification to regulators; 

  • Data breach reporting; 

  • Referral to safeguarding authorities. 

17. Monitoring and Review

This policy will be reviewed:

  • Annually; 

  • Following legislative changes; 

  • After serious incidents; 

  • Following updates to statutory guidance. 

The company will continually review risks associated with evolving technology and online learning environments.

18. Key Contacts

Designated Safeguarding Lead (DSL):Joshua Lynbeck

Deputy DSL:Charlotte Lynbeck

Emergency Contacts:

19. Related Guidance and Resources

Policy Approval

Name: Charlotte Lynbeck

Role: Co-Founder & Business Manager

Signature: CED Lynbeck

Date: 01/05/2026