Phlo Safeguarding and Child Protection Policy

1. Our commitment

Phlo believes every child and young person has the right to learn in a safe environment and to be protected from harm. We are committed to safeguarding and promoting the welfare of all children and young people we work with, and we expect everyone who tutors for Phlo to share this commitment. We give equal priority to keeping all children safe regardless of age, disability, gender, race, religion, sex, or sexual orientation, and we recognise that some children are more vulnerable than others.

2. Who this policy applies to and scope

This policy applies to Olivia Koleczek and to any tutor or other person who works for or on behalf of Phlo and has contact with children. It covers our online one-to-one tutoring. This policy is specifically about safeguarding people under 18 and is separate from any policy concerning adults.

3. Designated Safeguarding Lead

The Designated Safeguarding Lead for Phlo is Olivia Koleczek. The DSL takes lead responsibility for safeguarding, including responding to concerns, keeping records, and contacting external agencies where needed. Any safeguarding concern must be raised with the DSL without delay via hello@phlobio.ai. If a child is in immediate danger, call 999 first, then notify the DSL. A deputy DSL will be appointed as Phlo grows and takes on tutors.

4. Legislation and guidance

This policy is informed by UK child protection legislation and guidance, including Working Together to Safeguard Children and the principle that everyone who works with children has a responsibility to keep them safe. A summary of the relevant legislation and guidance is available from the NSPCC (learning.nspcc.org.uk/child-protection-system) and the Merton Safeguarding Children Partnership (mertonscp.org.uk).

5. Safer recruitment

We make sure everyone tutoring for Phlo is safe to work with children. This means:

• All tutors (including the founder) hold a current enhanced DBS check, including the children's barred list check, before working with any child.
• We obtain and check references before a tutor begins.
• We confirm identity and relevant qualifications.
• We ensure every tutor reads, understands, and agrees to this policy and the code of conduct before working with children.

6. Code of conduct for tutors

Everyone tutoring for Phlo must:

• maintain professional boundaries at all times and never form an inappropriate relationship with a child;
• communicate with students only through Phlo's approved channels, never through personal social media, personal phone numbers, or private messaging;
• never arrange to contact or meet a student outside agreed tutoring;
• keep communication appropriate, respectful, and focused on learning;
• never share personal contact details with a student or ask a student to keep anything secret;
• dress and behave professionally during sessions;
• report any concern about a child, or about another adult's behaviour, to the DSL immediately.

7. Keeping online sessions safe

Because our tutoring is delivered online and one-to-one, we take specific steps:

• We agree expectations with the parent or carer before tutoring begins, including any additional needs the child has (for example SEND), and how sessions will run.
• A parent or carer must be present in the home and within earshot for the whole session, so the tutor is never completely alone and unobserved with a child. This is a condition of booking, and parents confirm it when they book.
• Sessions take place on Phlo's agreed platform, not on personal accounts.
• We do not record tutoring sessions. The requirement for a parent or carer to be within earshot provides our safeguarding oversight instead.
• Tutors ensure their own environment is appropriate and free from anything unsuitable for a child to see.

8. Recognising abuse

Abuse and neglect can take many forms, including physical, emotional, and sexual abuse, neglect, and online harms such as grooming or bullying. Tutors do not need to be experts, but must stay alert to signs that a child may be at risk and take any concern seriously.

9. Responding to a concern or a disclosure

If a child tells a tutor about abuse, or a tutor becomes worried about a child's safety:

• Stay calm, listen, and reassure the child that they were right to speak up and that it is not their fault.
• Never promise to keep it secret. Explain that you need to tell someone who can help.
• Do not investigate or question the child beyond letting them speak.
• Record what was said as soon as possible, in the child's own words where you can, with the date, time, and facts, kept objective.
• Report it to the DSL immediately.

10. Reporting routes

• If a child is in immediate danger, call 999.
• For a non-emergency concern, the DSL will contact Merton's Children and Families Hub (the borough's single point of contact for safeguarding concerns) on 020 8545 4226 or 020 8545 4227 (Monday to Friday, 9am to 5pm), out of hours 020 8770 5000, or email candfhub@merton.gov.uk.
• For advice at any time, the NSPCC Helpline is available on 0808 800 5000 or help@nspcc.org.uk.
• Children can contact Childline free on 0800 1111.

11. Communication with parents and carers

We make sure parents, carers, and students know about this policy and how to raise a concern. We discuss safeguarding with parents before tutoring begins, and a plain-language summary is available on request. Any safeguarding concern raised by a parent will be taken seriously and acted on by the DSL.

12. Records and confidentiality

Safeguarding records are kept securely, shared only with those who need to know, and stored in line with data protection law and our privacy policy. Concerns are not discussed with anyone other than the DSL and the relevant authorities.

13. Allegations against a tutor or the founder

Any allegation or concern about the conduct of a tutor (or the founder) towards a child will be taken seriously and referred without delay to Merton's Local Authority Designated Officer (LADO) on 020 8545 3179 or LADO@merton.gov.uk, within one working day. If a child is at immediate risk, the police will be contacted on 999. A referral to the LADO must be made for any allegation that a person who works with children has behaved in a way that has harmed, or may have harmed, a child.

14. Making this policy known and reviewing it

This policy is available on our website and shared with parents and students. It is reviewed at least every 12 months, or sooner if our practice, the law, or guidance changes.