Safeguarding Policy

1. Policy Statement and Purpose

The Driving Training Centre (“The DTC”, “we”, “us”, “our”) is committed to promoting the welfare, health, and safety of all learners and to taking reasonable steps to protect children, young people, and vulnerable adults from abuse, neglect, exploitation, and harm.

We recognise that driving instruction often involves one-to-one contact, practical lessons in vehicles, direct phone and message communication, and support during mock tests and driving tests. These operating conditions require clear safeguarding standards, appropriate professional boundaries, and prompt action when concerns arise.

This policy provides a formal framework for identifying concerns, responding to disclosures, escalating risk, managing allegations, and ensuring safeguarding responsibilities are understood across the organisation.

2. Legal and Regulatory Framework

This policy is informed by, and should be read alongside, relevant UK legislation and guidance, including:

• Children Act 1989
• Children Act 2004
• Working Together to Safeguard Children (latest version)
• Keeping Children Safe in Education (KCSIE), where relevant to referrals involving schools or education settings
• Care Act 2014, including duties relating to adults at risk
• Data Protection Act 2018 and UK GDPR
• Any relevant local safeguarding children partnership and adult protection procedures

Where there is any conflict between business convenience and safeguarding practice, safeguarding takes priority.

3. Scope

This policy applies to:

• All employed and self-employed driving instructors working on behalf of The DTC
• Office staff, operations staff, managers, and directors
• Temporary staff, contractors, consultants, and agency workers
• Any third party handling learner communications, bookings, records, or welfare concerns for The DTC

This policy applies wherever our services are delivered, including:

• Driving lessons in tuition vehicles
• Mock tests and pre-test warm-up sessions
• Pick-up and drop-off arrangements
• Telephone calls, SMS, email, WhatsApp, and CRM-based communication
• Administrative contact relating to bookings, payments, lesson progress, and complaints

Learners, parents, carers, and other representatives should also be made aware that The DTC operates under this safeguarding policy.

4. Definitions

Child: anyone under the age of 18.

Young person: for the purposes of our services, typically a learner aged 16 to 17 who may lawfully receive driving tuition but is still legally a child for safeguarding purposes.

Vulnerable adult / adult at risk: an adult aged 18 or over who has needs for care and support, is experiencing or is at risk of abuse or neglect, and may be unable to protect themselves because of those needs.

Safeguarding: the action taken to protect the health, wellbeing, and human rights of children and adults at risk, enabling them to live free from abuse, harm, and neglect.

Abuse: a form of maltreatment of a child or adult at risk. Abuse may be a single act or repeated acts. It may be deliberate, neglectful, or caused by omission. It may occur in person, in a vehicle, at home, online, by phone, or through digital communications.

5. Roles and Responsibilities

5.1 Directors and Senior Management

• Approve, resource, and review this policy
• Ensure safeguarding concerns can be reported quickly and without obstruction
• Support the Designated Safeguarding Lead in carrying out their duties
• Ensure recruitment, training, supervision, and record-keeping processes are appropriate

5.2 Designated Safeguarding Lead (DSL)

The DTC will appoint a Designated Safeguarding Lead responsible for coordinating safeguarding practice.

Designated Safeguarding Lead: [Insert full name]
Role: [Insert role title]
Email: [Insert safeguarding email address]
Phone: [Insert direct safeguarding contact number]

The DSL is responsible for:

• Receiving and assessing safeguarding concerns
• Maintaining secure safeguarding records
• Making referrals to police, local authority children’s services, or adult safeguarding teams where required
• Advising staff on immediate protective action
• Monitoring patterns of concern and ensuring follow-up actions are completed
• Ensuring staff receive safeguarding guidance and refresher training

5.3 Instructors, Staff, and Contractors

• Read, understand, and comply with this policy
• Maintain professional boundaries at all times
• Recognise and report concerns without delay
• Record concerns factually and promptly
• Cooperate with safeguarding enquiries and internal reviews
• Never assume that somebody else has reported a concern

6. Types of Abuse

Safeguarding concerns may involve one or more of the following:

• Physical abuse: hitting, assault, inappropriate restraint, or physical harm
• Emotional or psychological abuse: intimidation, humiliation, threats, coercion, bullying, controlling behaviour
• Sexual abuse: sexual assault, grooming, sexualised comments, non-consensual contact, exploitation, indecent images, coercion into sexual acts
• Neglect: failing to meet basic physical or emotional needs, abandonment, inadequate supervision, failure to protect from harm
• Financial or material abuse: theft, fraud, pressure over money, misuse of funds, coercion linked to bookings or payments
• Domestic abuse: controlling, coercive, threatening, violent, or abusive behaviour in intimate or family relationships
• Discriminatory abuse: abuse linked to disability, race, religion, gender, sexuality, or other protected characteristics
• Online or digital abuse: harassment, sexual messaging, coercion, stalking, sharing images, threats, or grooming through digital channels
• Criminal or sexual exploitation: coercion into illegal or exploitative activity
• Modern slavery or trafficking: exploitation involving control, coercion, transport, or forced labour

7. Recognising Signs of Abuse

Indicators may include, but are not limited to:

• Unexplained injuries or repeated injuries
• Fearful, withdrawn, anxious, or unusually distressed behaviour
• Sudden changes in confidence, mood, attendance, or communication style
• Reluctance to go home, or visible fear of a parent, partner, carer, or other adult
• Sexualised language or behaviour that is inappropriate to age or context
• Signs of neglect, poor hygiene, hunger, exhaustion, or lack of supervision
• References to controlling behaviour, pressure, threats, or being watched
• Repeated missed lessons linked to fear, control, or unexplained access restrictions
• Disturbing messages, calls, or social media contact observed during instruction
• Disclosures by the learner, parent, carer, or another third party

A single sign may not prove abuse. However, staff should not ignore patterns, gut concerns, or disclosures that indicate possible harm.

8. Reporting Procedures

All safeguarding concerns must be treated seriously. The following escalation process applies:

Step 1: Respond to immediate safety risk

• If someone is in immediate danger, call 999 without delay
• If a learner is at immediate risk during a lesson, stop the lesson safely as soon as practical and move to an appropriate, safer location if required
• Do not place yourself or the learner at additional risk by attempting to confront a dangerous person directly unless absolutely necessary to prevent immediate harm

Step 2: Inform the DSL immediately

• Report the concern to the DSL as soon as possible, ideally on the same day and immediately for urgent matters
• If the DSL is unavailable and the concern is urgent, escalate to the deputy safeguarding contact or directly to police / local authority safeguarding services

Step 3: Record the concern factually

• Make a clear written record as soon as possible, preferably immediately after the concern arises
• Record dates, times, locations, who was present, what was seen or heard, and the exact words used where possible
• Separate fact from opinion and avoid speculation
• Upload or submit the record through the approved safeguarding reporting route or secure CRM process

Step 4: DSL review and referral

• The DSL will review the concern promptly
• The DSL will decide whether to monitor internally, seek advice, or make an external referral
• Where threshold is met, the DSL will contact the relevant local authority children’s services, adult safeguarding team, or police

Step 5: Follow-up and ongoing protection

• Any agreed protective action must be implemented quickly, such as changing instructor allocation, restricting contact routes, or adjusting pick-up / drop-off arrangements
• The DSL will maintain oversight until the matter is resolved or handed to the appropriate agency

Local authority safeguarding contacts:
Children’s Services: [Insert local authority children’s safeguarding duty team contact details]
Adult Safeguarding Team: [Insert local authority adult safeguarding contact details]
Police (non-emergency): 101
Emergency: 999

9. Dealing with Disclosures

If a learner or adult at risk discloses abuse or harm, staff must:

• Stay calm, listen carefully, and take the person seriously
• Reassure them that they were right to tell someone
• Explain that the information cannot be kept secret if someone is at risk of harm
• Ask only open, minimal questions necessary to clarify immediate safety, for example: “Can you tell me what happened?”
• Record the disclosure using the person’s own words wherever possible
• Report the disclosure immediately through the safeguarding procedure

Staff must not:

• Promise confidentiality
• Conduct their own investigation
• Ask leading or suggestive questions
• Express shock, disbelief, blame, or anger
• Contact the alleged perpetrator
• Delay reporting while waiting for more evidence

10. Confidentiality and Data Protection

Safeguarding information is sensitive and must be handled on a need-to-know basis only. Information should be shared internally only with those who need it to protect the individual or discharge legal responsibilities.

• Safeguarding records must be stored securely and separately from general learner notes where appropriate
• CRM entries containing safeguarding information must be access-controlled and limited to authorised personnel
• Personal data must be processed in line with UK GDPR and the Data Protection Act 2018
• Where there is a safeguarding risk, relevant information may be shared lawfully with statutory agencies without consent if necessary to protect the child or adult at risk
• Retention and deletion of safeguarding records must follow legal and operational requirements

Company registered / operational address: [Insert company address]

11. Safer Recruitment and DBS Checks

The DTC will take proportionate steps to recruit safely and reduce the risk of unsuitable individuals working with learners.

• Identity, right-to-work, and relevant qualification checks will be completed where applicable
• References may be requested and checked for instructors and relevant staff
• Role suitability will be assessed before engagement
• DBS checks will be sought where appropriate to the nature of the role and contact with children or adults at risk
• Any safeguarding concerns arising during recruitment must be risk-assessed before appointment

Self-employed status does not remove safeguarding responsibilities. Contractors working under The DTC brand or systems must comply with our safeguarding requirements.

12. Staff Training and Awareness

• All staff and instructors must receive safeguarding policy induction
• All staff must know how to recognise concerns and how to escalate them
• The DSL should receive enhanced safeguarding training appropriate to the role
• Refresher training and policy reminders should be delivered periodically
• Training should include child safeguarding, adult safeguarding, professional boundaries, lone working, and digital communication risks

13. Online and Digital Safeguarding

The DTC uses digital systems for bookings, operational messaging, learner records, and support communication. Digital safeguarding controls are therefore essential.

• Staff should use approved business channels wherever possible, such as company phone systems, official email, and approved CRM messaging tools
• Messages should remain professional, relevant, and proportionate to the service being delivered
• Late-night, excessive, personal, flirtatious, or secretive messaging is not permitted
• Where WhatsApp, SMS, or phone calls are used operationally, content must remain professional and any safeguarding-relevant communication should be recorded in the CRM or other approved record system
• Staff must not request or share inappropriate images, personal social media content, or private information unrelated to instruction
• Access to CRM accounts and learner records must be password-protected and limited to authorised users
• Any concerning digital contact, harassment, stalking, sexual messaging, or coercion must be reported under this policy

14. Lone Working

Driving instructors frequently work alone with learners in vehicles. This creates additional safeguarding and personal safety responsibilities.

• Lesson schedules, pick-up points, and learner details should be recorded in the company’s approved system where possible
• Instructors must maintain professional boundaries during one-to-one lessons at all times
• Pick-up and drop-off locations should be appropriate, safe, and agreed in advance
• Unplanned changes to lesson routes or destinations should be avoided unless operationally necessary
• Where a learner is under 18 or otherwise vulnerable, any unusual welfare concern during a lesson must be recorded and escalated
• Instructors should avoid situations that could create unnecessary ambiguity, such as entering a learner’s home unless there is a clear operational reason and appropriate safeguards
• Where available, instructors should follow any internal check-in, schedule visibility, or lone-worker safety procedures adopted by The DTC

15. Code of Conduct for Instructors

Instructors must:

• Act professionally, respectfully, and lawfully at all times
• Maintain clear physical and emotional boundaries
• Avoid favouritism, dependency, or overly personal relationships with learners
• Use appropriate language and behaviour in vehicles, at test centres, and in all communications
• Keep lesson-related communication focused on instruction, scheduling, payments, or welfare support relevant to the service
• Report safeguarding concerns promptly, even where evidence is incomplete

Instructors must not:

• Engage in sexualised, flirtatious, or inappropriate conversation or contact
• Request secrecy from learners
• Exchange inappropriate gifts, money, or personal favours
• Use their role to begin or pursue an improper relationship
• Share offensive, discriminatory, or explicit material
• Communicate with learners through hidden, disappearing, or unapproved channels in a way that bypasses professional oversight

16. Safeguarding in Lessons, Mock Tests, and Test-Day Support

• One-to-one lessons must be conducted in a professional manner, with clear lesson purpose and appropriate route planning
• Mock tests should be run in a structured and respectful way, without humiliation, intimidation, or unnecessary emotional pressure
• Test-day support must remain professional and should not create dependency or coercion
• If a learner presents as distressed, unsafe, or under external pressure on test day, the instructor must consider whether to pause and escalate concerns
• Where parents, carers, or third parties are involved in arrangements for younger learners, staff should maintain appropriate information sharing while respecting legal confidentiality requirements

17. Whistleblowing Procedure

Any staff member, instructor, or contractor who is concerned about unsafe practice, misconduct, policy breach, or safeguarding failure within The DTC must report it.

• Concerns should normally be raised with the DSL or a senior manager
• If the concern relates to the DSL or senior management, it must be escalated to a director or external authority as appropriate
• No one will be subject to detriment for raising a genuine safeguarding concern in good faith
• Whistleblowing concerns must be documented and reviewed promptly

18. Managing Allegations Against Staff

Allegations or concerns about the behaviour of an instructor, staff member, or contractor must be handled promptly, fairly, and in a way that protects the person at risk.

• Any allegation must be reported immediately to the DSL and senior management, unless the allegation concerns them
• Where the allegation may amount to a criminal offence or risk of significant harm, police and/or local authority safeguarding services must be contacted without delay
• The individual concerned may be removed from duties, suspended, or restricted pending investigation where appropriate
• Internal fact-finding must not interfere with statutory investigation
• Records of the allegation, action taken, and outcome must be securely retained

19. Review and Monitoring

• This policy will be reviewed at least annually, and sooner if legislation, guidance, or operational risk changes
• Safeguarding incidents, near misses, complaints, and lessons learned may trigger an earlier review
• Training completion, DBS status where relevant, and safeguarding reporting arrangements should be monitored periodically
• Any policy updates must be communicated to instructors, staff, and relevant contractors

Policy owner: [Insert name / role]
Policy approved by: [Insert approving authority]
Review date: [Insert review date]
Version: [Insert version number]