Whistleblowing Policy

1. Purpose

This policy encourages anyone with serious concerns about conduct, safety, malpractice, or wrongdoing connected to SoloCogs to speak up - without fear of reprisal. It covers concerns that go beyond individual complaints (which are handled under the Complaints Policy).

Whistleblowing is about raising concerns in the public interest - particularly where children may be at risk. SoloCogs is committed to taking such concerns seriously.

2. What This Policy Covers

You should use this policy if you have concerns about:

• A safeguarding or child protection failure - including a failure to act on a concern
• Conduct by any person connected to SoloCogs that puts a child at risk
• Serious breach of legal or regulatory obligations
• Deliberate concealment of wrongdoing
• Misuse of personal data or a serious data breach that is not being addressed
• Any other serious malpractice

3. Who Can Use This Policy

This policy can be used by:

• Any parent or carer with a concern about how SoloCogs operates
• Any student (with or without a parent/carer) who has a serious concern
• Any contractor, supplier, or other person with a professional connection to SoloCogs

4. How to Raise a Concern

You have three routes. Pick whichever feels right for the concern.

Route A - internal, direct to Jazz

In the first instance, concerns can be raised with Jazz directly via the contact page. Concerns raised this way are logged, acknowledged within 3 working days, and investigated with the protections set out in section 6.

Route B - internal, but bypassing Jazz

SoloCogs is a small operator. If your concern is about Jazz specifically, or you would prefer not to raise it with the founder, you can send it in confidence to our independent intermediate contact. This is a named professional adult - unaffiliated with the day-to-day running of SoloCogs - whose only role in this policy is to receive whistleblowing concerns, log them, and either escalate to an appropriate external body or, where appropriate, feed them back into Portsdown Tuition's governance without revealing your identity.

The intermediate contact for the current policy period is to be published in the DPA information pack sent to school / MAT / LA procurement contacts on request. Individuals wanting to use Route B can email whistleblowing@solocogs.co.uk - this address is auto-forwarded to the intermediate contact only, not to Jazz, and its access is audit-logged. If you are a parent, tutor, staff member, or student and this route is not currently reachable, use Route C instead - your protection under this policy is the same.

Route C - external

You can always go straight to an external body without using Route A or Route B first. UK whistleblowing law (Public Interest Disclosure Act 1998) protects you when you disclose to a prescribed regulator in good faith. Relevant bodies:

• Safeguarding concerns about a child: Portsmouth City Council Children's Services - 023 9268 8793, or the NSPCC - 0808 800 5000. In an immediate emergency call 999.
• Concerns about a teacher's conduct: Teaching Regulation Agency (TRA) - gov.uk/TRA
• Data protection concerns: Information Commissioner's Office (ICO) - ico.org.uk or 0303 123 1113
• General whistleblowing advice + confidential advice line: Protect (formerly Public Concern at Work) - protect-advice.org.uk - 020 3117 2520

5. Confidentiality

Where possible, we will keep the identity of anyone raising a concern confidential. However, there may be circumstances - particularly where a child's safety is at risk - where it is not possible to maintain full anonymity. We will discuss this with you before proceeding wherever possible.

You may raise a concern anonymously. Anonymous concerns will still be investigated, though the ability to respond directly to you will be limited.

6. Protection from Reprisal

Anyone who raises a genuine concern in good faith under this policy will not face any negative consequences as a result. This includes:

• No adverse change to their access to the platform
• No hostile response in any communication
• No discrimination or disadvantage of any kind

Raising a concern in good faith means you honestly believe the information to be true, even if it later turns out to be mistaken. Malicious or deliberately false allegations are a separate matter and may be dealt with under the Complaints or Acceptable Use Policy.

7. Record Keeping

All whistleblowing concerns and the actions taken in response are recorded securely and retained for a minimum of 7 years.