Safeguarding & Child Protection Policy

1. Policy Statement

SoloCogs (operated by Portsdown Tuition (sole trader) under the SoloCogs brand, Portsmouth) is committed to safeguarding and promoting the welfare of all children and young people who use this platform. We believe every child has the right to learn in a safe environment, free from harm, abuse, or exploitation.

This policy applies to all interactions conducted through the SoloCogs platform, including resource access, assessment tools, wellbeing check-ins, and any written content students submit through the platform.

SoloCogs will always act in accordance with the statutory guidance Keeping Children Safe in Education (KCSIE), Working Together to Safeguard Children, and the Children Act 1989 and 2004.

2. Scope

This policy applies to:

• All students registered on the SoloCogs platform
• All parents and carers who hold accounts
• Jazz, as sole operator and Designated Safeguarding Lead (DSL)
• Any future employees, contractors, or volunteers engaged by SoloCogs

Safer Recruitment

Any future staff or contractors engaged by SoloCogs will undergo rigorous pre-employment checks, including enhanced DBS disclosures and barred list checks, in line with Keeping Children Safe in Education Part 3. No individual will begin work with children before these checks are satisfactorily completed.

3. Designated Safeguarding Lead

SoloCogs is used by two categories of tenant: schools (who already have a statutory DSL under KCSIE 2024) and direct family / home-education tenants (who do not). The DSL of record depends on which category applies.

3a. School-tier tenants

Where a school subscribes to SoloCogs, the school's own DSL owns any safeguarding concern raised by their pupils. SoloCogs is a tool that supports the school's statutory duty, not a substitute for it. At onboarding, the school names their DSL and provides a contact email; matched safeguarding content routes to the school's staff-dashboard queue, where the DSL reviews and decides on escalation using the school's local safeguarding partnership procedures.

SoloCogs, acting through Jazz as operator, will not intervene in a school-tenant disclosure except in these circumstances:

• Content indicating immediate risk to life triggers a human escalation by the SoloCogs DSL: the SoloCogs DSL contacts statutory services (Portsmouth MASH, or the child's local A&E, or 999 where an active in-progress emergency is disclosed) and notifies the school's DSL concurrently. The platform itself does not auto-call emergency services - a trained human always makes that call.
• Where a school's DSL contact fails to respond within the triage SLA (section 5) and content is high-severity, SoloCogs will escalate directly to MASH / statutory services and notify the school's headteacher.

3b. Direct family / home-education tenants

DSL: Jazz McCullough - qualified teacher (QTS), DSL trained, current DBS, NSPCC Level 3 refresh 2026, and Safeguarding Officer for Fort Purbrook Company of Bowman.

Deputy DSL: SoloCogs is a sole-operator business at launch, so there is no permanently-appointed Deputy DSL working alongside Jazz today. During any planned absence of more than 5 working days, the DSL role is temporarily covered by a named, DBS-checked, DSL-trained safeguarding partner - published to procurement contacts on request in advance of the cover period. For absences shorter than 5 working days, high-severity concerns are triaged within the SLA in section 5 by the on-cover partner or, if unreachable, escalated directly to Portsmouth MASH and (where applicable) the school's own DSL. A permanent Deputy DSL will be named publicly in this section within 3 months of launch (target: 3 November 2026).

The DSL is responsible for:

• Managing all safeguarding concerns raised by direct-tenant pupils through the platform
• Maintaining accurate records of concerns and actions taken
• Making referrals to statutory agencies where appropriate
• Keeping safeguarding training up to date
• Reviewing and updating this policy annually

4. Types of Abuse and Statutory Duties

Staff are trained to recognise indicators of the following categories of abuse as defined in Working Together to Safeguard Children 2023:

• Physical abuse - including hitting, shaking, burning, or causing physical harm
• Emotional abuse - persistent emotional maltreatment causing severe, persistent effects on development
• Sexual abuse - involving a child in sexual activity they do not understand, cannot consent to, or are pressured into
• Neglect - persistent failure to meet a child's basic physical and psychological needs
• Child Criminal Exploitation (CCE) and Child Sexual Exploitation (CSE)
• Online abuse - including grooming, cyberbullying, sharing of inappropriate content, and the exchange of self-generated indecent images
• Domestic abuse - including where a child witnesses abuse within the home

PREVENT duty (Counter-Terrorism and Security Act 2015)

The DSL is trained under the PREVENT duty and its 2023 statutory guidance to recognise signs that a child may be at risk of being drawn into terrorism, including online radicalisation. Where such indicators arise:

• The DSL will assess the level of concern using the Channel programme thresholds.
• Low-concern indicators will be discussed with the parent / carer and, for school-tenant pupils, the school's DSL.
• A concern that meets the Channel threshold will be referred to the Channel panel via Hampshire & IOW Police (or the child's local force for out-of-area students), and the school's DSL will be informed.
• An immediate risk to life triggers a 999 call.

PREVENT training is refreshed at least every two years, or sooner where statutory guidance is updated. SoloCogs does not host user-to-user content or open chat, so the surface area for online radicalisation via the platform is limited to the same free-text fields the DSL already monitors.

5. Safer Online Practice

SoloCogs operates as an asynchronous online learning platform. The following safer practice principles apply to all interactions:

• All platform activity is conducted through secure, logged, platform-based interactions only
• No personal contact details (phone numbers, personal email addresses, social media) are shared between SoloCogs staff and students outside the platform's official safeguarding channels
• Student data is never shared with third parties except where required by law or safeguarding obligations
• Platform access requires authenticated login and is age-appropriate
• Student wellbeing is monitored at every login through the Zones of Regulation check-in system

Professional Boundaries

SoloCogs operates with the following professional boundaries in place:

• Parents and carers can review their child's account activity and wellbeing summary through the parent dashboard at any time
• All communication between SoloCogs and a student remains within the platform - no contact takes place via personal email, phone, or social media
• Where the DSL contacts a parent or guardian regarding a safeguarding concern, that communication is logged on the platform and follows the formal procedures set out in this policy

Filtering and Monitoring

In line with Keeping Children Safe in Education 2024, SoloCogs maintains active filtering and monitoring across the platform - not only within the Zones of Regulation wellbeing check-in, but throughout all resource and assessment tools. This includes:

• Automated literal keyword detection across all student-submitted free-text responses, including vocabulary tests, self-evaluation answers, and ZoR wellbeing notes. Matching is word-boundary and case-insensitive; the trigger list is deliberately curated by the DSL to include euphemisms and misspellings (e.g. "unalive", "shrooms", "kms") in the list itself, rather than relying on fuzzy or ML-based matching which would create too many false positives. Full technical detail lives in the Safeguarding Flow reference.
• All flagged content is reviewed by the DSL within the tiered SLA below: high-severity within 4 working hours (or by end of next working day at weekends / holidays), medium within 2 working days, low within 5 working days. No automated safeguarding action is taken without human review.
• Monitoring is proportionate and privacy-respecting - only content submitted to the platform is processed, and filtering is applied solely for safeguarding purposes.

6. Wellbeing Monitoring

Every student completes a brief Zones of Regulation emotional check-in at each login. Students may also leave a private written note for the DSL. This system:

• Provides a consistent picture of each student's emotional wellbeing over time
• Automatically flags entries containing safeguarding-related keywords for DSL review
• Alerts the DSL when a student shows a persistent pattern of reported distress (e.g. consistently reporting low mood across multiple sessions)
• Treats all zones equally - a student in any emotional state may require support

All flagged entries are reviewed promptly by the DSL. No automated action is taken without human review.

7. Recognising and Responding to Concerns

Where a safeguarding concern arises - whether through a student's written disclosure, observed behaviour, or a third-party report - the DSL of record (school's DSL for school-tier; Jazz or Deputy DSL for direct-family tenants) will:

1. Record the concern accurately and promptly, including date, time, and the student's own words where applicable
2. Assess the level of risk and determine whether a referral to statutory services is required
3. Contact the relevant authority if there is risk of immediate harm: Police 999 for immediate danger, Portsmouth MASH (Multi-Agency Safeguarding Hub) for a pupil disclosure of concern, and NSPCC helpline for advice. Note: LADO is used only for allegations against adults working with children, not for pupil disclosures.
4. Inform parents or carers, unless doing so would place the child at greater risk
5. Follow up on all concerns regardless of how minor they initially appear

The DSL will never promise confidentiality to a child who discloses abuse or risk of harm. Students are told clearly and kindly that information shared in their notes may be acted upon if it suggests they are at risk.

Low-Level Concerns

SoloCogs maintains a Low-Level Concerns log to record minor incidents or observations that do not meet the threshold for a statutory referral but may indicate a need for early intervention or support. This includes patterns of behaviour, repeated emotional distress flagged via the Zones of Regulation check-in, or any interaction that feels uncomfortable without constituting a clear disclosure.

Low-level concerns are reviewed alongside the student's wider pattern of engagement. Where concerns accumulate or escalate, they will be treated as a formal safeguarding concern and handled accordingly.

8. Record Keeping

All safeguarding records are:

• Stored securely within the SoloCogs platform database (Supabase), access-controlled and encrypted at rest and in transit
• Processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 - see the Privacy Policy and Data Protection Policy for full detail
• Retained for a minimum of 7 years from the date of the record, or until the student reaches age 25, whichever is later
• Not shared with any third party except statutory agencies with a lawful basis to receive them

9. Referral Contacts

• Emergency: 999
• NSPCC Helpline: 0808 800 5000
• Childline (for students): 0800 1111
• Portsmouth Children's Services (MASH): 023 9268 8793
• Portsmouth MASH secure email: MASH@portsmouthcc.gov.uk - for submission of the Inter-Agency Referral Form (IARF)
• LADO (Local Authority Designated Officer): 023 9284 1905 - for allegations against adults working with children
• CEOP (Child Exploitation and Online Protection): ceop.police.uk - for online child sexual exploitation concerns

10. Training

The DSL maintains current DSL-level safeguarding training and refreshes this at least every two years, or sooner where statutory guidance is updated significantly. Awareness of online safety risks, including new and emerging threats, is maintained on an ongoing basis.

11. Policy Review

This policy is reviewed annually and updated whenever there are changes to statutory guidance, platform functionality, or following any safeguarding incident. The current version and review date are displayed at the top of this document.