3. Safeguarding and Child Protection Policies and Procedures To Ensure Safe Remote Teaching

“Safeguarding” has been defined by the NSPCC (National Society for the Prevention of Cruelty to Children) as the action that is taken to promote children’s welfare and protect them from harm. Child protection is part of the safeguarding process. It focusses on protecting individual children who might be at risk of harm.

Smile 4 Kids is committed to safeguarding and protecting all children.

Some of the Safeguarding and child protection policies and procedures that we follow include:

a. Recruitment of suitable staff and volunteers: We follow safe recruitment principles which include the following:

• We short-list candidates that best match the job description published by us
• We interview only short-listed candidates, always ensuring that the candidate being interviewed continues to match our recruitment requirements
• We carry out DBS (Disclosure and Barring Service) checks at the required level
• We obtain at-least 2 (two) references in respect of a candidate that we have interviewed
• We verify a potential candidate’s right to remain and work in the United Kingdom
• We do not confirm employment until we have received a satisfactory DBS check report, and satisfactory feedback from the referees

b. Child Protection Training: We constantly emphasise on and remind our staff and volunteers about our commitment to keep children and young people safe within the online space that we provide them. We ensure that all staff and volunteers complete the child protection training as part of the induction process, which includes training on online safety as well as the procedures to be followed if a child protection concern is identified.

c. Supervision of New Staff and Volunteers: New staff are always supervised at regular intervals, by Senior staff, as well as, Safrina Saran

d. Use of suitable platforms and devices

1. We only use platforms that have been trialled by us, and that have proved to be suitable for the use by children we are teaching.
2. Smile 4 Kids teachers will never use their personal accounts to conduct any courses and/or to communicate with children, young people or their Parents. Courses will always be conducted and children, young people or their Parents will always receive all communications from an authorised Smile 4 Kids’ account, created and managed exclusively for the purposes of delivering courses and carrying out communication with the students and/or their Parents.
3. We also ensure that we turn on and regularly check the privacy settings on the account that we are using to interact with children and young people.
4. to the extent possible, we use organisational, i.e. Smile 4 Kids’ devices to communicate with children and young people. However, in a remote teaching set-up, it may not always be possible for teachers to have access to an organisational device. In such circumstances, the founder and supervisor of Smile 4 Kids, Mrs. Safrina Saran, will on a case-by case basis, authorise certain teachers and volunteers to use a personal device, and will keep a record of this authorisation.
5. teachers and volunteers who have been authorised to use a personal device for the purposes of delivering courses and communicating with children and young people must adhere to the following rules:

• We only use platforms that have been trialled by us, and that have proved to be suitable for the use by children we are teaching.
• Smile 4 Kids teachers will never use their personal accounts to conduct any courses and/or to communicate with children, young people or their Parents. Courses will always be conducted and children, young people or their Parents will always receive all communications from an authorised Smile 4 Kids’ account, created and managed exclusively for the purposes of delivering courses and carrying out communication with the students and/or their Parents.
• We also ensure that we turn on and regularly check the privacy settings on the account that we are using to interact with children and young people.
• to the extent possible, we use organisational, i.e. Smile 4 Kids’ devices to communicate with children and young people. However, in a remote teaching set-up, it may not always be possible for teachers to have access to an organisational device. In such circumstances, the founder and supervisor of Smile 4 Kids, Mrs. Safrina Saran, will on a case-by case basis, authorise certain teachers and volunteers to use a personal device, and will keep a record of this authorisation.
• teachers and volunteers who have been authorised to use a personal device for the purposes of delivering courses and communicating with children and young people must adhere to the following rules:

e. Use of cameras for live classes:

• Our teachers will have their cameras on while teaching, as our teaching methods include several activities and interactive techniques such as quizzes and games.
• While cameras are on, teachers will ensure that:
1. there is never any risk of strangers having access to the screen
2. they are dressed appropriately
3. they conduct lessons in a quiet space, ensuring that friends and family are never visible during a lesson
4. Check what is visible on screen to the student(s), so that nothing inappropriately personal is visible (such as personal items, posters, etc.)
• While we prefer students to have their cameras on during a class, we understand that some children or Parents may not be comfortable having their cameras/webcams on. If a child is shy or for any reason not comfortable turning on their webcam, or you as a Parent have concerns relating to the use of a webcam by your child please discuss the situation with us.
• Please note that a student will be asked to use their webcam only for the purposes of participating in class activities and not for any other purpose. In addition every student must be supervised by a Parent for the duration of their online class with us.
• Please note that Parents must fill out a consent form, expressly consenting to their children attending online classes delivered by us and including, without limitation the use of cameras during the online class.

f. Livestreaming and recording sessions

1. Live streaming: We do not directly and/or through third parties livestream any content
2. Recording online sessions:
• We may record online sessions, subject to written consent from the Parents and/or students (if they are 13 years of age or above), allowing us to make a recording for the purposes stated in this section of the policy.
• We will also obtain written permission from our staff and/or volunteers before we make a recording
• We will make recordings of our online classes only for the purposes of quality control so that we can further improve the delivery of our online classes
• Not all online classes will be recorded, but occasionally we may request to record a class for the above-mentioned purposes
• Before we record a class we will expressly seek the consent of the children participating in the class, and if a child or children show hesitation or are uncomfortable with us making a recording, we will not proceed to make the recording
• A child or Parent may at any time withdraw consent in relation to the recording of our online classes. If a child or parent withdraws consent after a recording has been made, we will ensure that we dispose of the recording securely.
• We understand that a recording may constitute personal data relating to children and our staff or volunteers. We take the privacy of our staff, volunteers, students and their Parents very seriously and will only record classes on receipt of prior consent from the parties involved. We will ensure that any such recordings made are stored securely on password protected systems and only authorised persons have access to such recordings. We will also ensure that should we have to dispose of a recording, we will do so in the most secure manner possible, ensuring that the recording as well as any back-up copies if any, are deleted from the system and/or any hard-drive or devices.
3. Children/Parents recording online sessions
• We understand that sometimes students or their Parents may want to record sessions for future reference.
• Please note that we cannot allow the recording of group classes

g. Staff’s digital footprint

• Please note that as a strict policy, as long as our staff and/or volunteers are working with us, they will not send nor accept any friend requests on their personal accounts from students, children, young people and their families.
• If a student, child, young person, their Parents or families find that our staff or volunteers have tried connecting with them via social media in breach of their obligations under this policy please report the concerned individual immediately to Safrina Saran.
• Parents also have a duty to ensure that their children are not misusing social media nor using social media to communicate with our staff or volunteers.
• Given that children, young people and/or their families may look up the personal social media accounts of our staff and volunteers, we constantly remind our staff and volunteers to be aware of their digital footprint, and to keep their social media accounts free of inappropriate or harmful content, and not to provide any personal information such as personal email addresses or phone numbers via their social media accounts
• Please note that a member of staff or volunteer should never request children or young people to share their pictures and/or videos. If a picture or video has to be taken for a class activity, parents will be served a written notice, requesting for express consent. If a member of staff or volunteer requests a child or young person for their pictures or videos, without having sought consent from the Parent, please report the concerned individual immediately to Safrina Saran

h. Contacting Parents /Students ( Over 18 years of age)

• Sometimes a member of staff or volunteer may have to contact a student over 18 (eighteen) years of age or a student’s Parent, in relation to their homework or to check on a student’s well-being.
• A member of staff or volunteer will contact a student or a Parent only during hours which would be considered normal school hours, via the Parent’s email address or phone number given to us as the contact details to be used for such purposes, unless this poses a safeguarding risk.
• Parents also have a duty to ensure that their children are not misusing social media nor using social media to communicate with our staff or volunteers.
• Please note that all the contact details shared with us will be used in accordance with our privacy policy
• If a student becomes ill or asks to speak to a member of staff alone, the member of staff will ensure that they adhere to safeguarding measures to protect the child or young person and that they give the chid or young person space to ask questions and talk about anything that worries them.

i. Child protection concerns

• We take the wellbeing of children and young people enrolled onto our courses seriously and therefore if a member of our staff sees or hears something worrying during an online lesson, or if a child discloses abuse during a phone call or via email, we may if necessary contact the NSPCC (National Society for the Prevention of Cruelty to Children) who will take the necessary action to protect the child or young person
• We constantly remind our staff and volunteers to be more vigilant if a child or young person has Special Educational Needs and Disabilities (SEND), as such children are often more vulnerable. Our child protection lead and Designated Safeguarding Person is Safrina Saran.
• We also have a Safeguarding Children policy which we encourage all Parents to read, and to contact us (Safrina Saran) if they have any concerns about the safety of their child.

j. Data Protection

• At Smile 4 Kids, we take the privacy of our students, who may be children or young people and their Parents very seriously.
• We collect and process personal data strictly in accordance with our privacy policy which can be accessed at https://smile4kids.co.uk/Privacy-policy
• Categories of Personal Data we collect- The categories of Personal Data we collect include without limitation:
1. Names of students
2. Contact details
3. Emergency contact’s details
4. Any Special Education Needs or Disabilities and/or any other medical conditions of students, so that we may be able to make certain adjustments to our classes for such students
5. Any pictures taken or video recordings made of classes for the purposes of internal staff training
• How we use the Personal Data- We may gather and use a child’s or their Parent’s personal data for the following purposes, including but not limited to.
1. Providing teaching services and supporting student learning
2. Monitoring student progress
3. Internal staff training
4. Providing students and their Parents updates about upcoming courses, events and activities
5. If a Parent has opted to receive newsletters and other marketing related communication from us, to send such communication (We will retain their personal data for these purposes until they opt-out of receiving our newsletters and/or other forms of marketing related communication)
6. Compliance and due diligence
7. Inviting students and Parents to organised events, seminars and webinars. (We will retain and use this information until such time they expressly opt-out of being contacted for receiving invitations and updates about organised events).
8. Social media- We may gather certain personal data in relation to persons who follow us on social media platforms such as LinkedIn, Instagram, Facebook, Twitter and other similar platforms. Our staff will not connect with students and/or Parents on social media, via their personal accounts. The only way we may connect with Parents is through our organisational account. Parents may at any given point in time discontinue their connection with us on social media platforms.
• Who do we share Personal Data with?

Personal data relating to students and/or their Parents may be received by:

Smile 4 Kids and its staff who need to receive such personal data in order to provide services to students or to carry out the administration of business
1. Smile 4 Kids and its staff who need to receive such personal data in order to provide services to students or to carry out the administration of business
2. Any local authorities or government bodies to whom the information may need to be submitted
3. Any regulatory authorities regulating us
4. Any external agencies that support children learning, especially for children with Special Education Needs. (Parents and where possible children and young people will however be informed and unless the law requires us to do so we will not share such personal information without the prior written consent of Parents and where possible of students)
5. Certain personal information collected for the use of marketing purposes may be shared on our website and social media platforms. (This will however be strictly subject to the prior written consent of Parents and where possible of students)
6. Any other party a Parent may instruct us to share their child’s or their own personal data with
7. Any other organisation who may take over the business of Smile 4 Kids either by purchasing it or by way of a merger or in the event of any catastrophic circumstances by reason of which new management has to continue Smile 4 Kids’ business.

We do not share our students’ personal data with anyone without express, prior written consent from the Parent unless the law and our policies allow us to do so.

• Lawful basis for processing Personal Data

The following is the lawful basis for processing a student’s or their Parent’s personal data:

1. Consent- In order that we can provide our courses and teaching services to students, you as a Parent consent to us obtaining and processing your/your child’s personal data. By enrolling into or by enrolling your child into our courses you consent to your/your child’s personal data being collected, used and processed by us.
2. Contractual necessity- One of the grounds for obtaining and processing your/your child’s personal data is so that we can perform the services you have signed up for. However, we will always obtain your consent before we (i) take any photographs/videos of you/your child, (ii) use any personal data for promotional activities and/or (iii) add you to our newsletter.
3. Compliance with legal obligations- We may have to collect personal data in order to comply with certain legislative and regulatory requirements.
4. Legitimate interests- We may process your/your child’s personal data to promote the legitimate interests our business as well to promote and pursue the legitimate interests of our students such as their safety and well-being.
• Data Protection Impact Assessment- Where we feel that processing the data of children and young persons is likely to result in a high risk to such individuals, we will carry out a Data Protection Impact Assessment (DPIA) in accordance with the ICO’s guidelines, to help us identify and minimise the data protection risks involved.

k. Parental Consent and duties of parents

• Please note that when a parent, child or young person applies to enrol onto our online courses, we seek prior written consent from:
1. The parent
2. Students over 18 years
• Prior written consent is obtained by way of an application form which is filled out by Parents or students over 18 years , in advance of their acceptance in our online courses.
• We will always obtain parental consent for children or young people below the age of 18 (eighteen).
• In addition to parental consent, for children above the age of 12 (twelve), we will seek their express consent in order to confirm that they are comfortable participating in the activities and for us to make recordings of the classes and/or to take photographs during the classes/activities.
• If a child is keen on participating in an activity but as a Parent, you are not willing to give consent we encourage you to talk to our supervisor and Designated Safeguarding Person, Safrina Saran, so that we may be able to discuss whether there is anything that we can do to make the activity more suitable for your child, or alternatively suggest other activities that your child could participate in, which as a Parent you may be more comfortable with.
• We will always obtain parental consent for children or young people below the age of 18 (eighteen).
• Parents must:
1. Ensure that their children are in a comfortable environment during an online lesson. It is paramount that the children’s place of study is well lit, ventilated and with an appropriate temperature
2. Check that their children are in a secure environment during an online lesson. In particular, no loose electrical wires or sharp objects should be around, while carpets and flooring should be laid out smooth so that the children are not at a risk of tripping
3. Ensure that their children are aware of emergency exits and fire escapes
4. Ensure that the children do not sit in one position for too long, maintain the right posture and have access to equipment and seating that is preferably ergonomic
5. Ensure that children have easy access to first aid equipment if required
6. Ensure that children who need inhalers or any other medication find these within easy reach
7. Inform our staff if their child is supported by an inhaler, hearing aid or spectacles so that before the start of a class our staff can make sure that these are always available to the child
8. Ensure that their children are hydrated and have used the toilet before the start of a class
9. Be aware that any hot food or beverages should be consumed by their children during breaks only and not during a class, in order to avoid distractions or food/beverage accidents
10. Comprehend the significance of remaining in control of electronic devices at home and remain in earshot when children are in contact with our staff
11. Ensure that their children can be immediately attended to if needed
12. Be alert as regards who their children are going to be interacting with online
13. Be aware of what their children are being asked to do during an online course
14. Always check the sites that children are going to access
15. Immediately report concerns to our staff
16. Ensure that privacy settings have been turned on

PARENTS are responsible for complying with this Policy at all times during the conduct of online courses, reporting any health and safety incidents to the Manager and asking for guidance as appropriate.

IN PARTICULAR: “As parents and guardians you warrant that your child is accessing our online courses from a comfortable and secure environment and that your child is at all times during the length of a class under parental/guardian supervision. By signing this Policy, you agree to the above and agree not to hold Smile 4 Kids responsible for not being able to supervise your child individually.”

l. Duties of Staff

• Behave appropriately during an online course
• Follow instructions issued by our staff
• Inform both our staff and their Parents of any situation which may affect their health and safety, including if a parent or person with parental responsibility is not present at home to supervise the child during their class
• Ensure that they drink enough water and use the toilet before the start of each class

STUDENTS are responsible for complying with this Policy at all times during the conduct of online courses.

n. Who to Contact?

The Health and Safety key person/ Designated Safety Person is: Mrs. Safrina Saran (“DSP”)

The DSP is responsible for ensuring that staff, Parents and students adhere to this Policy at all times, as well as for reviewing the effectiveness of this Policy on an annual basis and communicating any changes to staff, Parents, and students.

Please also note that:

1. Smile 4 Kids is an equal opportunities employer and recruits staff exclusively on the basis of the individual’s credentials
2. We provide services to and support all our students and their Parents in a non-discriminatory manner
3. We maintain relevant insurance covers