Online tutoring academies teaching children need a child protection policy, a named safeguarding lead, teacher background checks, classroom safety rules and secure concern records. In England, the DfE’s non-statutory safeguarding guidance covers private tuition.
Who does safeguarding guidance cover in online and private tuition?
England’s DfE guidance covers out-of-school settings, including private tuition, and provides a useful framework for organizing safeguarding in an online academy. The guidance is non-statutory; providers still have a legal duty of care. The version summarized here was updated on 9 February 2026. This is general information, not legal or tax advice; check with an adviser in your country.
Separate the guidance’s jurisdiction from your academy’s daily practice. A teacher abroad, an academy owner elsewhere and a child in England can create questions that a classroom policy cannot settle. Ask an adviser which requirements apply rather than assuming a UK checklist settles every local obligation.
Use the policies below to assign responsibility and describe what staff actually do. A document that says children should be safe gives a teacher little help when a child makes a worrying comment during class. The teacher needs a reporting route and someone ready to respond.
Privacy questions also need their own review. Our overview of COPPA, GDPR and the UK Children’s Code addresses that separate topic. A safeguarding policy should explain how staff protect children; privacy documents should explain how the academy handles personal information.
What should your child protection policy and safeguarding lead cover?
A child protection policy should tell teachers, administrators and families how to raise a concern and who will handle the response. DfE guidance says you should appoint an adult DSL, who can be the owner, and train that person in online safety and referral processes to local authority children’s social care. Name the person rather than assigning responsibility vaguely to management.
Make the reporting route usable during a live lesson. Teachers should know where to send a concern, how to reach the DSL and what to do if the usual contact is unavailable. Arrange cover and explain the route for a concern involving the DSL or owner.
Build the policy around practical instructions:
- Explain the behavior expected from adults and how children can ask for help.
- Give staff a clear route for reporting concerns, including concerns about colleagues.
- Describe how the DSL records decisions and follows the appropriate referral process.
- Explain how families can raise a concern without going through the teacher involved.
Walk through the policy during induction. Ask a teacher to explain the reporting route back to you. That conversation can reveal an unclear contact method or an assumption that someone else will act. Keep the family version easy to read and easy to find.
How should recruitment checks, DBS checks and references work?
Safer recruitment needs checks suited to the actual teaching role, supported by references and clear conduct expectations. DfE guidance says unsupervised work with a child is likely to be regulated activity and may qualify for an enhanced DBS check with a barred list check. The NSPCC recommends that independent tutors show parents an up-to-date certificate and provide at least 2 referees’ contact details.
Avoid turning that guidance into a claim that every online role has identical DBS eligibility. Describe the role accurately and check which process applies. For teachers in other countries, get local advice; the sources above do not establish police-check procedures outside the UK.
Give recruitment a named owner. Record what was checked, who reviewed the information and any follow-up decision. A certificate should sit alongside the academy’s recruitment process, not replace the conversation about boundaries, communication and reporting concerns.
Use references to ask about suitability for work with children and conduct in teaching. Give the referee enough context to understand the role. Resolve questions before assigning teaching work, rather than leaving an administrator to discover an unfinished check after lessons begin.
Explain the academy’s classroom rules before the teacher starts. Recruitment and induction should connect: the person assessing suitability should know the behavior the academy expects during classes and communication with families.
What online-safety rules should apply during live classes?
Online-safety rules should cover what children see, who can contact them, how people behave and commercial pressures. DfE guidance calls these the 4 Cs: content, contact, conduct and commercialisation. The NSPCC also recommends another adult within earshot or parents sitting in, avoiding a bedroom where possible, blurring the background if necessary, and spending 5 minutes updating parents after each session.
Translate the 4 Cs into teacher instructions. Use suitable teaching materials, protect access to class, set communication boundaries and keep sales or unrelated promotional material away from the lesson. Explain how a teacher reports unsuitable content or contact rather than leaving the teacher to improvise.
Agree the teaching environment with staff and families. A neutral background helps keep private spaces out of view. Tell parents how they can remain within earshot or sit in, and explain what teachers should do when the agreed arrangement changes.
Keep communication on academy channels. A parent should know where class information comes from and where to raise a concern. The routine parent update can cover the learning completed and anything needed for the next session. A safeguarding concern needs the reporting process, rather than being folded into a casual progress update.
Observations can help you check whether staff follow the policy. Explain the purpose and consent arrangements before observing. Our guide to observing online classes with consent covers that process in more detail. Observation should support the policy and the DSL’s work.
How should you record concerns and share information?
Safeguarding records should preserve the concern, the response and the reason for decisions without exposing the information to unrelated staff. DfE guidance says providers should record safeguarding incidents, store records securely and limit access to the DSL or relevant senior colleagues. The guidance also says to keep records only as long as necessary. Set an academy process that follows applicable requirements.
Give teachers a clear place to report concerns. Avoid using a shared teaching chat where staff who have no safeguarding role can read sensitive details. Keep safeguarding records separate from ordinary lesson feedback so an academic update does not become an informal incident file.
A useful record distinguishes what the teacher saw or heard from the teacher’s interpretation. Include the circumstances, the action taken and who received the concern. Preserve the child’s words accurately where possible. Do not rewrite uncertainty as a confirmed allegation.
The DSL should record the response and follow the relevant referral process. Teachers need to report concerns promptly rather than investigate them alone. Explain who can authorize sharing information and how staff should seek help if they are unsure.
Write down who reviews access and decides when records should be removed. Do not invent a universal retention period. The appropriate period needs advice based on your circumstances and applicable rules; a software subscription does not decide that policy for you.
What consent do photos and lesson recordings need?
Photos and recordings need a separate policy that explains purpose, access, use and retention. DfE guidance says providers using children’s photos should get parental consent, explain where and how images will be used, and say how long images will be kept. The guidance suggests considering annual consent renewal. NSPCC advice recommends organization accounts, avoiding personal devices for images, and secure storage.
Separate teaching access from permission to publish an image. A parent agreeing to an online lesson should not have to guess whether a screenshot might later appear on the academy website. Describe the intended use clearly before seeking permission, and explain how families can raise questions.
Make the device rule concrete. Tell staff which academy account and approved storage location to use. Avoid a workflow in which a teacher takes a photo on a personal phone and promises to delete the photo later. Include screenshots in the discussion so staff understand the policy’s scope.
If your academy considers recording lessons, review consent and privacy before choosing a workflow. Our guide to recording online lessons: consent and privacy explores those questions. A recording policy also needs to explain what happens when permission is absent or changes.
Halqora does not record classes. Keep that product limit separate from the academy’s wider policy on images, screenshots and any other tools staff use.
Which policies should be on your safeguarding checklist?
| Policy area | What to put in place | Who owns it | Source |
|---|---|---|---|
| Child protection and DSL | Written reporting route, named lead and referral training | Owner and DSL | DfE provider guidance |
| Recruitment checks | Role-appropriate DBS process and at least 2 referees | Recruitment owner | DfE checks guidance, NSPCC tutor advice |
| Online-safety rules | 4 Cs, suitable background and adult within earshot or parent sitting in | DSL and teachers | DfE online safety, NSPCC tutor advice |
| Accounts and devices | Organization accounts; avoid personal devices for images | Owner and staff | NSPCC image guidance |
| Incident records | Secure storage, restricted access and retention decisions | DSL and relevant senior colleagues | DfE records guidance |
| Photos and recordings | Clear consent, purpose, access and retention policy | Owner and DSL | DfE consent guidance, NSPCC image guidance |
| Parent updates | Brief update after sessions | Teacher | NSPCC tutor advice |
The safeguarding checklist brings the policies together, but each row needs someone who can explain the actual process. The ownership column above is a suggested division of work for your academy. Confirm names, contact routes and cover arrangements. Then check that teachers and families can find the information they need without asking around for the right document.
How Halqora handles this
Halqora is management software for online academies. In its one-to-one classroom, chat stays closed until an admin opens it. Join and leave events are logged, but there is no attendance report screen. Halqora does not record classes.
Admins can observe silently. Camera and microphone access depends on consent on file; an observer can still see shared teaching materials. Consent changes apply from the next join. Explain those boundaries through your academy’s consent-based class observation policy. Software supports classroom rules; your academy still needs a written policy, a trained DSL and a way to respond to concerns.
Sources
- DfE safeguarding guidance for out-of-school settings, checked 21 October 2026
- DfE safeguarding guidance for providers, PDF, checked 21 October 2026
- NSPCC safeguarding and child protection for tutors, checked 21 October 2026
- NSPCC photographing and filming children guidance, checked 21 October 2026
