1. Introduction

Teaching Tomorrow is committed to safeguarding and promoting the welfare of children and expects all employees, candidates, temporary workers, contractors and other individuals working on its behalf to maintain the highest standards of professional conduct. Teaching Tomorrow takes all safeguarding concerns and allegations seriously, regardless of how they arise or whether they initially appear minor. This policy sets out how Teaching Tomorrow will respond where information is received concerning the conduct or suitability of an adult working for, registered with or supplied by Teaching Tomorrow. This policy should be read alongside:

  • PP001 Safeguarding Children Policy;
  • PP011 Safer Recruitment Policy;
  • PP015 Recruitment, Selection and Vetting Policy;
  • Teaching Tomorrow’s Code of Conduct;
  • Complaints Policy;
  • Whistleblowing Policy;
  • Data Protection and Retention policies; and
  • any other relevant safeguarding or disciplinary procedures.

The policy has been developed having regard to the current version of Keeping Children Safe in Education (KCSIE), applicable safeguarding legislation and guidance, REC Audited Education requirements and, where applicable, the requirements of the RM6376 Supply Teachers and Education Recruitment Framework. KCSIE 2026 strengthens the shared safeguarding responsibilities of schools and colleges and third party organisations where concerns or allegations relate to supply staff and other contracted personnel.

2. Scope

This policy applies to:

  • Teaching Tomorrow employees and directors;
  • candidates and temporary workers registered with Teaching Tomorrow;
  • individuals supplied or introduced to clients by Teaching Tomorrow;
  • contractors;
  • work-placement individuals and volunteers; and
  • any other person undertaking work on behalf of Teaching Tomorrow where safeguarding responsibilities arise.

This policy principally relates to safeguarding concerns involving children. Where an individual is working within another regulated environment, additional sector -specific safeguarding requirements may also apply. Employment grievances, complaints about working conditions or other matters that do not involve safeguarding should normally be dealt with under the relevant grievance or complaints procedure. However, where information received through another process raises a safeguarding or suitability concern, this Allegations Policy will apply.

3. Types of Safeguarding Concern

Teaching Tomorrow distinguishes between:

  • concerns or allegations that may meet the harm threshold; and
  • concerns or allegations that do not meet the harm threshold, commonly referred to as low -level concerns.

The fact that a concern is described as “low-level” does not mean that it is insignificant. All safeguarding concerns must be taken seriously, recorded appropriately and considered in the context of any previous information held by Teaching Tomorrow.

4. Concerns That May Meet the Harm Threshold

A concern or allegation may meet the harm threshold where an adult has:

  • behaved in a way that has harmed a child or may have harmed a child;
  • possibly committed a criminal offence against or related to a child;
  • behaved towards a child or children in a way that indicates they may pose a risk of harm to children; or
  • behaved, or may have behaved, in a way that indicates they may not be suitable to work with children.

The final category may include conduct that has taken place outside the workplace where that behaviour raises questions about the individual’s suitability to work with children. This is sometimes referred to as transferable risk. Where transferable risk may exist, Teaching Tomorrow will consider whether the information has implications for the individual’s work with children and whether further safeguarding advice or action is required.

5. Low-Level Concerns

A low-level concern is any concern, no matter how small, that an adult working with or on behalf of a school, college or Teaching Tomorrow may have acted in a way that:

  • is inconsistent with expected professional conduct, including inappropriate conduct outside work; and
  • does not appear to meet the harm threshold or otherwise require immediate referral to the LADO.

Examples may include:

  • being overly familiar or overfriendly with children;
  • showing favouritism;
  • taking photographs of children contrary to a setting’s policy;
  • placing themselves in an unnecessarily secluded one-to-one situation with a child;
  • humiliating or belittling a child;
  • inappropriate communication with children;
  • behaviour that could reasonably be viewed as crossing professional boundaries; or
  • other behaviour that causes unease or concern about professional conduct.

Low-level concerns can arise from a complaint, observation, disclosure, self -referral, safeguarding report, information provided by another organisation or information identified during vetting or ongoing suitability checks. Where a school or other education setting becomes aware of a low -level concern regarding a Teaching Tomorrow candidate, Teaching Tomorrow should be informed so that the information can be considered alongside any previous or subsequent concerns involving the candidate. This is particularly important for supply staff who may work across multiple settings, as Teaching Tomorrow may be best placed to identify patterns of behaviour that would not be apparent to an individual school.

6. Reporting a Concern

Any safeguarding concern or allegation concerning a Teaching Tomorrow candidate, temporary worker, employee or other relevant individual should be reported to Teaching Tomorrow’s Designated Safeguarding Lead as soon as reasonably practicable. Where a candidate is working in a school or education setting, they must also follow that setting’s safeguarding and reporting procedures. Where a concern is raised directly with Teaching Tomorrow, the Designated Safeguarding Lead will consider:

  • the nature of the information received;
  • whether a child may be at immediate risk;
  • whether the concern appears to meet the harm threshold;
  • whether the school, client or other employer needs to be informed;
  • whether consultation or referral to the LADO is required;
  • whether police or children’s social care involvement may be necessary;
  • whether immediate action is needed in relation to current or future assignments; and
  • whether any previous information held by Teaching Tomorrow is relevant.

Where there is uncertainty as to whether the harm threshold is met, Teaching Tomorrow will seek advice from the appropriate LADO.

7. Responding to Low-Level Concerns

Where information appears to constitute a low-level concern, Teaching Tomorrow will gather sufficient information to understand the nature and context of the concern. This may include speaking with:

  • the person who raised the concern;
  • the individual concerned;
  • the school or client;
  • relevant witnesses; and
  • other appropriate persons.

This information gathering must remain proportionate and must not compromise any potential safeguarding, disciplinary or criminal investigation. Teaching Tomorrow will record:

  • the nature of the concern;
  • the circumstances and context in which it arose;
  • relevant information gathered;
  • actions taken;
  • decisions reached; and
  • the rationale for those decisions.

The record will normally identify the person who raised the concern, although requests for confidentiality or anonymity will be respected as far as reasonably possible. Low-level concerns will be reviewed collectively where appropriate so that patterns of inappropriate, problematic or concerning behaviour can be identified. Records will be kept confidential and secure. Where a pattern develops, or further information suggests the harm threshold may have been met, the matter will be escalated and the LADO consulted.

8. Allegations Concerning Candidates Working in Schools and Colleges

Teaching Tomorrow recognises that safeguarding responsibility is shared between Teaching Tomorrow and the school or education setting in which a candidate is working. Where an allegation arises while a Teaching Tomorrow candidate is working in a school or college, the school will normally be best placed to lead the initial fact-finding because it has direct access to:

  • the child or children concerned;
  • staff and other witnesses;
  • CCTV or other setting records;
  • safeguarding records; and
  • information regarding the circumstances in which the allegation arose.

Teaching Tomorrow will fully cooperate with the school and any enquiries undertaken by the LADO, police, local authority children’s social care or other relevant safeguarding body. Teaching Tomorrow should be appropriately involved in discussions and meetings concerning the candidate and should receive sufficient information to enable it to discharge its own safeguarding and personnel-supplier responsibilities. The school and Teaching Tomorrow should share relevant information, including any previous concerns or allegations known to either organisation, where lawful and appropriate. The fact that the worker is supplied by an agency does not remove the school’s safeguarding responsibilities, nor does the school’s involvement remove Teaching Tomorrow’s responsibilities as the supplying organisation.

9. Ceasing or Restricting an Assignment

A safeguarding allegation must not be dealt with simply by ending an assignment. Where a school no longer wishes a candidate to attend the setting because of a safeguarding concern, Teaching Tomorrow will seek sufficient information to understand the concern and ensure that appropriate safeguarding procedures continue. Teaching Tomorrow will not archive, close or terminate a candidate’s registration merely as an alternative to investigating or addressing a safeguarding matter. Where a safeguarding concern or allegation requires investigation, Teaching Tomorrow’s general position will be to prevent the candidate from undertaking further assignments while the matter is investigated and their suitability is assessed. This is a precautionary safeguarding measure and does not indicate that the allegation has been substantiated. There may be circumstances in which a candidate is permitted to continue working during an investigation. Any such decision will be made in accordance with section 12 of this policy. Where the candidate is supplied under RM6376, Teaching Tomorrow will comply with any additional requirements to inform the relevant Buyer where information gives reasonable grounds to believe that a temporary worker may be unsuitable for the position.

10. Initial Action Where the Harm Threshold May Be Met

Where the information may meet the harm threshold, Teaching Tomorrow must take care not to undertake an investigation that could prejudice the work of the school, LADO, police or children’s social care. Teaching Tomorrow’s initial role will normally be to obtain enough information to understand:

  • what is alleged to have happened;
  • who is involved;
  • where and when it occurred;
  • whether a child may currently be at risk;
  • whether the candidate is currently working with children elsewhere; and
  • which organisation or safeguarding authority is already involved.

Teaching Tomorrow should not conduct detailed interviews with the child, accused person or witnesses where doing so could compromise a formal investigation.

The appropriate LADO should be contacted in accordance with the local safeguarding arrangements relevant to the allegation. Teaching Tomorrow will not automatically refer every concern to the LADO without considering its nature. However, where the harm threshold may be met, or where there is uncertainty, LADO advice will be sought promptly.

11. Immediate Safeguarding Action

The welfare of children is the primary consideration. Teaching Tomorrow will consider whether immediate action is necessary to protect a child or other children from harm. This may include:

  • notifying the school or setting;
  • consulting the LADO;
  • making or supporting a referral to children’s social care;
  • contacting the police where criminal conduct or immediate danger is suspected;
  • preventing the candidate from undertaking further assignments;
  • identifying other settings at which the candidate is currently working; and
  • sharing relevant safeguarding information with appropriate organisations.

Any action taken will be proportionate to the information available and clearly recorded.

12. Working During an Investigation

Where a safeguarding concern or allegation is raised and requires investigation, Teaching Tomorrow will generally prevent the candidate from undertaking further assignments while the matter is investigated and their suitability is assessed. This is a precautionary safeguarding measure. It does not imply that the allegation has been substantiated or that any conclusion has been reached regarding the candidate. A candidate may continue to work while an investigation is ongoing where:

  • the client has been made fully aware that there is an ongoing safeguarding concern or investigation;
  • sufficient relevant information has been provided to enable the client to make an informed decision;
  • the client confirms that they are satisfied for the candidate to continue working;
  • Teaching Tomorrow has considered the nature and circumstances of the concern and does not identify an unacceptable safeguarding risk; and
  • continuing to work would not conflict with advice or restrictions imposed by the LADO, police, children’s social care or another relevant safeguarding authority.

Where appropriate, Teaching Tomorrow will record the client’s decision and confirmation that they are aware of the ongoing investigation before the candidate is permitted to continue or commence an assignment. Teaching Tomorrow reserves the right to prevent the candidate from working regardless of a client’s willingness to accept them where Teaching Tomorrow considers that the information available presents an unacceptable safeguarding or suitability risk. The position will be kept under review throughout the investigation and may change if further information becomes available. Any decision to prevent a candidate from working, or to permit them to continue working during an investigation, will be clearly documented together with the rationale for the decision and any relevant advice received.

13. Multi-Agency Working

Safeguarding allegations may involve several separate but related processes, including:

  • safeguarding enquiries;
  • LADO oversight;
  • local authority children’s social care involvement;
  • police investigation;
  • school investigation;
  • Teaching Tomorrow suitability or disciplinary procedures;
  • DBS referral consideration;
  • Teaching Regulation Agency or other professional-regulator consideration; and
  • other statutory or contractual reporting requirements.

Teaching Tomorrow will cooperate with relevant agencies and provide information lawfully and proportionately where this is necessary to safeguard children or assess an individual’s suitability.

14. Confidentiality and Information Sharing

Information relating to safeguarding allegations must be treated confidentially and shared only with those who have a legitimate need to know. However, data protection law does not prevent the sharing of information where it is necessary and proportionate for safeguarding purposes. Teaching Tomorrow will ensure that safeguarding records accurately document:

  • information received;
  • discussions held;
  • decisions made;
  • information shared;
  • referrals made or considered;
  • reasons for action or non-action; and
  • outcomes.

Teaching Tomorrow will take account of advice from the LADO, police or other investigating body before disclosing detailed allegations to the individual concerned where premature disclosure could prejudice an investigation or increase risk.

15. Support for the Individual Concerned

Teaching Tomorrow recognises that being subject to a safeguarding allegation can be stressful and potentially damaging. The individual should be treated fairly and with appropriate confidentiality while the matter is investigated. Subject to any restrictions imposed by the LADO, police, school or another investigating body, Teaching Tomorrow will:

  • explain the process being followed;
  • provide appropriate updates;
  • advise the individual that they may seek support from their trade union or professional association;
  • identify an appropriate point of contact within Teaching Tomorrow; and
  • consider any appropriate support if they subsequently return to work.

The fact that an allegation has been made must not be treated as evidence that it is true.

16. Outcomes

Where an allegation has been investigated, the following definitions may be used: Substantiated – there is sufficient evidence to prove the allegation. False – there is sufficient evidence to disprove the allegation. Malicious – there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive or cause harm to the person subject to the allegation.

Unsubstantiated – there is insufficient evidence to prove or disprove the allegation. This does not imply guilt or innocence. Unfounded – there is no evidence or proper basis to support the allegation. Teaching Tomorrow will consider the outcome alongside all other relevant information when determining the individual’s continued suitability to be supplied or employed. A decision by the police or Crown Prosecution Service to take no further action does not automatically determine the outcome of Teaching Tomorrow’s safeguarding or suitability assessment.

17. Resignation, Withdrawal or Termination of Registration

Teaching Tomorrow will seek to reach an appropriate safeguarding conclusion even where an individual:

  • resigns;
  • withdraws their registration;
  • stops accepting assignments;
  • refuses to cooperate; or
  • otherwise ceases working through Teaching Tomorrow.

An individual leaving Teaching Tomorrow does not prevent safeguarding enquiries or statutory referrals from continuing. Teaching Tomorrow will not enter into an agreement that prevents an appropriate safeguarding referral from being made.

18. Referral to the Disclosure and Barring Service

Teaching Tomorrow recognises its responsibilities as a personnel supplier to consider referral to the Disclosure and Barring Service where the statutory referral criteria are met. Where an individual is removed from regulated activity because they have harmed, or pose a risk of harm to, a child, or where Teaching Tomorrow would have removed them had they not ceased providing services, a DBS referral will be made where legally required. Resignation, withdrawal from registration or ceasing to accept assignments will not prevent a DBS referral. Teaching Tomorrow will retain a clear written record of its consideration and decision regarding whether a DBS referral was required.

19. Other Regulatory Referrals

Teaching Tomorrow will consider whether information should also be referred to another regulatory or professional body where appropriate. This may include the Teaching Regulation Agency or another relevant professional regulator. Notification to Ofsted, another regulator or statutory body will only be made where Teaching Tomorrow has an applicable legal, regulatory or contractual obligation to do so.

20. Non-Recent Allegations

Non-recent or historical allegations will be treated seriously. Where an adult reports that they were abused when they were a child, they should be supported to report the matter to the police. Where a child makes a non-recent allegation, the matter should be reported to the appropriate LADO in accordance with local procedures. Teaching Tomorrow will also consider whether the person against whom the allegation has been made is currently working with children and whether any immediate safeguarding action is required.

21. Record Keeping

Teaching Tomorrow will maintain a clear, comprehensive and confidential record of safeguarding allegations and relevant decisions. For allegations that meet the harm threshold, records will normally include:

  • a summary of the allegation;
  • information gathered;
  • referrals and consultations;
  • decisions taken and reasons;
  • the manner in which the matter was followed up;
  • the outcome; and
  • any action arising from the case.

Records relating to harm -threshold allegations will be retained at least until the individual reaches normal pension age or for 10 years from the date of the allegation, whichever is longer, in accordance with KCSIE. Records of low-level concerns will be retained in accordance with Teaching Tomorrow’s data-retention procedures and kept for sufficient time to allow potential patterns of behaviour to be identified. Safeguarding information will be stored securely and access restricted to authorised individuals.

22. References

Teaching Tomorrow will ensure that safeguarding information included in references is accurate, factual, proportionate and consistent with KCSIE. Allegations that have been found to be false, unfounded, unsubstantiated or malicious will not be included in references. Substantiated safeguarding allegations that meet the harm threshold should be included where relevant, using factual information rather than opinion. Low-level safeguarding concerns should not normally be included in a reference unless they relate to matters that would otherwise appropriately be included, such as misconduct or poor performance.

23. REC and Framework Reporting

Where an investigation into a worker supplied by Teaching Tomorrow could reasonably bring Teaching Tomorrow or REC into disrepute, Teaching Tomorrow will consider its reporting obligations to REC and notify the REC Compliance Team where required. Where the worker has been supplied under the RM6376 Framework, any additional reporting or safeguarding obligations arising under that Framework will also be followed.

24. Learning Lessons

At the conclusion of a safeguarding matter, Teaching Tomorrow will consider whether lessons can be learned regardless of whether an allegation was:

  • substantiated;
  • unsubstantiated;
  • unfounded;
  • false; or
  • malicious.

This review may consider:

  • whether Teaching Tomorrow’s processes operated effectively;
  • whether information was shared promptly enough;
  • whether previous concerns were recognised;
  • whether the candidate’s recruitment or vetting record identifies any learning;
  • whether staff training should be updated;
  • whether policies or procedures should be amended;
  • whether communication with schools or other organisations could be improved; and
  • whether any broader safeguarding or organisational issue contributed to the concern.

Any relevant learning will be incorporated into Teaching Tomorrow’s safeguarding practices, training or procedures.

25. Policy Review

This policy will be reviewed at least annually and sooner where there are changes to legislation, KCSIE, REC requirements, applicable framework requirements, safeguarding practice or Teaching Tomorrow’s internal procedures. Any significant amendments will be communicated to relevant staff.