Nousara Safeguarding and Escalation Policy

1. Purpose and scope

Nousara is a platform that records and transcribes one-to-one tutoring sessions and uses automated analysis to generate progress reports. Most students are aged 13 to 18 and are therefore children. This policy explains how safeguarding concerns relating to those children are handled in connection with the Nousara platform, and sets out the roles and responsibilities of Nousara, of the tutoring agencies and tutors who use it, and of their staff.

This policy applies to Nousara and its personnel, and to the tutors, agencies and other users who use the platform. It does not replace the safeguarding policies and statutory duties of the agencies and tutors who use Nousara; it sits alongside them.

2. Nousara's position, and what Nousara is not

It is important that everyone using the platform understands the following, so that no one relies on Nousara for protection it does not provide:

• Nousara is a technology provider. It is not a school, a tutoring provider, a regulated safeguarding body, or a substitute for the safeguarding arrangements of the agency or tutor using it.
• Nousara does not monitor session audio, transcripts or reports in real time for safeguarding concerns, and does not provide a safeguarding screening, triage or detection service.
• The automated reports are a support tool for tutors. They are AI-generated, may contain errors, and must not be treated as a safeguarding assessment or relied upon to identify risk to a child.
• Responsibility for identifying, assessing and acting on safeguarding concerns rests with the agency or tutor and their designated safeguarding personnel, in line with the law and guidance that applies to them.

3. Roles and responsibilities

4. How a safeguarding concern may arise

A concern about a child's welfare or safety may come to light through the platform in several ways, for example:

• A child says or shows something concerning during a session, which a tutor hears at the time or later sees in a transcript or report.
• A parent, tutor or agency raises a concern with Nousara through a support channel.
• Nousara personnel become aware of a concern incidentally, for example while providing technical support.

However a concern arises, the escalation steps in section 5 apply.

5. Escalation procedure

For tutors and agency users. If you become aware of a safeguarding concern through the platform:

1. If a child is in immediate danger, contact the emergency services on 999 first.
2. Report the concern to your organisation's Designated Safeguarding Lead without delay, following your own safeguarding policy.
3. Record what you saw or heard, factually and promptly, including where in the session or report it appeared.
4. Do not attempt to investigate the concern yourself, and do not alert the person the concern may be about.

For Nousara. If a safeguarding concern reaches Nousara directly:

5. If there is an imminent risk of serious harm to a child, Nousara will contact the appropriate authorities (such as the police or children's social care, or 999 in an emergency) without delay.
6. Nousara will escalate the concern to the relevant agency or tutor Designated Safeguarding Lead as soon as possible, and in any event without undue delay, so that they can act under their own safeguarding arrangements.
7. Nousara will record the concern, what was done, and when, and will share information only as necessary and lawful for the purpose of protecting the child.
8. Nousara will not delay protective action in order to seek consent where a child may be at risk.

6. Urgent risk and emergencies

Where a child is at immediate risk of harm, protecting the child takes priority over every other consideration in this policy, including normal data protection and confidentiality steps. Contact the emergency services on 999. Acting to protect a child at risk is lawful and expected.

7. Information sharing and data protection

Sharing information to protect a child is permitted by data protection law. Where it is necessary to share personal data to safeguard a child or to act in their vital interests, Nousara and users may do so without consent, relying on the appropriate lawful bases under the UK GDPR and the safeguarding provisions of the Data Protection Act 2018. Information shared for safeguarding will be limited to what is necessary, shared only with those who need it, and recorded.

8. Confidentiality

Safeguarding concerns are sensitive. They will be handled discreetly and shared only with those who need to know in order to protect the child. Confidentiality must never be a reason to withhold information where a child may be at risk.

9. Record keeping

Nousara keeps a confidential record of any safeguarding concern raised to it, the action taken, who it was escalated to, and when. These records are held securely, with access restricted to the Nousara safeguarding contact, and retained in line with safeguarding good practice.

10. Requirement for agencies and tutors

As a condition of using Nousara, an agency (and an independent tutor working with children) must confirm that it has its own safeguarding policy and a Designated Safeguarding Lead, and that its tutors know how to raise a concern. Nousara may ask for confirmation of this during onboarding.

11. Contacts

12. Review

This policy will be reviewed at least annually, and sooner if there is a material change to the platform, to safeguarding law or guidance, or following any safeguarding incident.