Safeguarding and Child Protection Policy

1. Purpose and scope

CognateHelix is a fifteen-month life sciences enrichment programme for Year 12 students, delivered by Excellence First Enterprise Consultancy Limited, trading as CognateUK. Almost all students are 16 or 17 when they enrol and many turn 18 during the programme. In law they are children until their eighteenth birthday, and we treat them as such throughout, whatever their age on a given day.

This Policy sets out how we keep students safe, how we expect the adults who work with them to behave, and what we will do if we are worried about a student. It covers live online sessions, the digital learning platform and ProfBot, coaching, written feedback, the February study weekend, the partner-school AIML day, the Summer Intensive, the Signature Project Showcase, and any other contact between programme staff and students.

We are an external education provider. We are not a school and the students remain on the roll of their own schools and colleges throughout. Our arrangements are designed for that role: we keep our own safeguarding lead, our own procedures and our own records, and we work with each student's school and, where necessary, with the local authority for the area in which the student lives.

2. Our commitments

We will treat the welfare of every student as paramount, ahead of the interests of the programme, its staff or its partners.

We will listen to students, take what they tell us seriously, and act on it.

We will recruit safely, check every adult who works with students to the level the law requires for the contact they have, and expect the highest standards of conduct from them.

We will design our online and in-person delivery so that opportunities for harm are reduced by structure, not left to individual judgement.

We will share information about a student when it is necessary to keep that student or another person safe, and we will be clear with students about the limits of confidentiality.

We will make sure that every student and every parent or carer knows who to contact, and how, if they are worried about anything.

3. Framework

This Policy is written with regard to the Children Act 1989 and 2004, Working Together to Safeguard Children (2023), Keeping Children Safe in Education 2026 (KCSIE), the Department for Education's Keeping Children Safe in Out-of-School Settings code of practice, the Safeguarding Vulnerable Groups Act 2006, the Prevent duty guidance, and the UK GDPR and Data Protection Act 2018.

KCSIE applies to schools and colleges rather than to us directly. We apply its standards, in particular Part 1 and Part 5, as the benchmark for our own practice, because the students we work with are the same students it is written to protect and because our partner schools are entitled to expect nothing less.

4. Roles and contacts

The DSL has lead responsibility for safeguarding across the programme: receiving and recording concerns, deciding what action to take, liaising with schools, local authorities and the police, keeping this Policy and the associated procedures current, and making sure all staff are trained. The Deputy acts in the DSL's absence and whenever the DSL is the subject of a concern or is delivering the session in which a concern arises. The Chief Executive holds the DSL to account for the operation of this Policy and receives an annual report on it.

The safeguarding mailbox, safeguarding@cognateuk.com, is monitored by the DSL and the Deputy on every working day.

The DSL and Deputy each hold safeguarding lead training appropriate to the role, refreshed at least every two years, and keep up to date with statutory guidance.

5. Safer recruitment and checks

Every adult who works with students on the programme is recruited through a process that includes verification of identity, an application or professional profile, at least one reference where practicable, a self-declaration covering criminal record and any previous safeguarding concern, and an interview or professional conversation in which safeguarding is discussed.

Every adult in regulated activity with children holds an enhanced Disclosure and Barring Service check including the children's barred list. Regulated activity includes teaching, coaching or supervising students regularly, and any overnight supervision. In practice this means every tutor, coach and module lead, every adult who stays overnight at an event that includes an overnight stay, and the DSL and Deputy. Checks are verified as current before each in-person event; they are not assumed to persist from the start of the programme. Where an adult is registered with the DBS Update Service, a status check is made and recorded.

Guest speakers, university hosts, venue staff and other adults whose contact with students is occasional and supervised are not required to hold a check but are never left alone with students and do not count towards any supervision ratio.

We keep a single central record of the checks held by every adult on the programme, with dates, and the DSL reviews it before the programme begins and before each in-person event.

6. Code of conduct for staff, tutors and contributors

All adults working on the programme are given this Policy at induction, confirm in writing that they have read it, and are expected to observe the following.

Contact with students takes place only through the programme's own channels: the digital learning platform, the scheduled online sessions, and CognateUK email. Adults do not connect with students on personal social media, do not give students personal phone numbers or personal email addresses, and do not communicate with students by text or messaging apps. A student who makes contact through a personal channel is redirected to the platform and the DSL is told.

Online teaching sessions are group sessions. Coaching is delivered in small groups of up to four students. An individual online session takes place only by exception, with the DSL's prior agreement, on the platform, recorded, and with the student's parent or carer aware that it is happening.

Adults join sessions from a professional setting with the camera on, dressed as they would be in a classroom, and with nothing visible or audible that would be inappropriate in a classroom.

Language is professional at all times. Adults do not discuss their own personal relationships, health or private life with students beyond what is ordinarily appropriate in a teaching setting, do not make comments about a student's appearance, and do not use sarcasm, humiliation or favouritism.

Adults do not give gifts to individual students or accept gifts of more than token value from them, and do not offer or accept invitations to meet outside programme activities.

At in-person events adults do not transport students in private vehicles, do not enter a student's sleeping accommodation alone, and do not consume alcohol at any point during an event that includes an overnight stay. Physical contact is limited to what is necessary for safety or first aid, and is explained to the student at the time.

Any adult who is concerned about the behaviour of another adult towards a student, however senior, reports it to the DSL, or to the Chief Executive if the concern is about the DSL, and is protected from any detriment for doing so.

A breach of this code is a disciplinary or contractual matter and, where it may amount to harm to a child, is reported under section 11.

7. Online safety

Most of the programme is delivered online, and students use the platform and ProfBot between sessions without an adult present. Our arrangements reflect that.

Accounts are personal to each student. Students may not share credentials and are told how to report a suspected compromise. Access to the platform is restricted to enrolled students, programme staff and platform administrators.

Live sessions are hosted by the tutor, who controls admission, can remove a participant, and is responsible for the conduct of the session. Students attend with cameras on, as set out in the Engagement Charter, and from a suitable setting. Sessions may be recorded for teaching, catch-up and quality purposes. Recordings are held on the platform, are available only to programme staff and, for catch-up, to enrolled students, and are deleted at the end of the retention period stated in our Privacy Policy.

ProfBot is an AI-supported learning assistant. It is configured for the programme's educational content, and every message passes through a safeguarding detector. Students are told not to enter sensitive personal information about themselves or others. If a student discloses through ProfBot, or in any written work, anything that suggests they or another person may be at risk, the tutor or platform administrator who sees it treats it as a disclosure and reports it to the DSL the same day, in the same way as a disclosure made in person.

Students are expected to behave towards one another online as they would in a classroom. Bullying, harassment, sexual comments, discriminatory language and the sharing of images or content about another student are dealt with under section 9 as child-on-child abuse, not merely as misconduct.

The DSL reviews platform moderation arrangements with the platform developer before the programme begins and at least annually.

8. In-person events

The February study weekend, the partner-school AIML day, the Summer Intensive and the Signature Project Showcase are governed in detail by the Residential Supervision and Safeguarding Policy. Its principal standards are summarised here so that families can see them in one place.

Where an event includes an overnight stay, supervision is one checked adult per ten students, rounded up, plus one further adult for contingency, with a minimum of three adults, applied overnight as well as by day. Mixed cohorts have at least one adult of each gender staying overnight. Only checked adults on duty count towards the ratio. The same standard, applied by day, governs events without an overnight stay.

Our responsibility for a student at an in-person event begins at the stated arrival time and place and ends at the stated departure time and place. Families arrange travel to and from the venue. Arrival and departure arrangements, a consent form, and a request for medical, dietary and emergency contact information are sent to families before each event, and a student does not attend without them.

A base contact, not part of the event team, is reachable throughout each in-person event and holds the full participant list, consent forms and emergency contacts. The base contact is named, with their contact details, in the information sent to families before the event.

Any accident, illness, safeguarding concern or serious behavioural incident at an in-person event is reported to the event lead immediately, to the parent or carer the same day, and recorded.

9. Recognising concerns

Staff are trained to recognise the signs of physical, emotional and sexual abuse, neglect and exploitation, and to understand that abuse can take place online as readily as in person. For the age group we work with, the following are particularly relevant.

Mental health, self-harm and eating disorders. A student who is withdrawn, exhausted, or whose engagement changes sharply may be struggling. Staff are not expected to diagnose, only to notice and report.

Child-on-child abuse, including bullying, sexual harassment and the sharing of nude or semi-nude images. We assume it could happen here, and we treat a report as a safeguarding matter rather than a conduct matter.

Online harm, including grooming, coercion and exposure to harmful content.

Criminal and sexual exploitation, including county lines.

Radicalisation. We follow the Prevent duty guidance and the DSL makes any referral to the local authority Prevent lead or Channel panel.

Substance misuse, and pressure at home or in the student's wider circumstances.

Students with special educational needs or disabilities, and students who are young carers, can face additional barriers to being heard, and staff are alert to that.

A concern does not have to be certain to be reported. Staff report what they have seen or heard and leave the assessment to the DSL.

10. Responding to a concern or disclosure

If a student tells a member of staff something that suggests they or another person may be at risk, the member of staff listens, lets the student use their own words, does not press for detail or ask leading questions, does not promise to keep it secret, tells the student what will happen next, and records what was said as soon as possible using the concern record form. The record goes to the DSL the same day, and immediately if the student may be in danger.

If a student is in immediate danger, anyone may call 999 first and tell the DSL afterwards.

Students can raise a concern about themselves or anyone else by telling any tutor, by emailing safeguarding@cognateuk.com, or by speaking to the designated safeguarding lead at their own school. Parents and carers can contact the DSL by the same routes. Every route reaches the DSL the same working day.

On receiving a concern the DSL will:

• consider the information, consult the Deputy or the Chief Executive if useful, and decide the response within one working day;
• contact the student's parent or carer, unless doing so would increase the risk to the student, in which case the reason for not doing so is recorded;
• contact the designated safeguarding lead at the student's school or college, who holds the fuller picture of the student's circumstances and any existing support;
• where the threshold is met, refer the matter to children's social care for the local authority in which the student lives, using that authority's published contact route, and to the police where a crime may have been committed;
• record the concern, the decision and the reasons, and any action taken, in the safeguarding record; and
• follow up to make sure that action has been taken and that the student is supported to continue on the programme where that is right for them.

Where a student is 18 or over and the concern relates to them, the DSL applies the same process, contacts adult social care rather than children's social care where a referral is needed, and involves the student in decisions about their own information.

11. Allegations against staff and contributors

An allegation that an adult working on the programme has behaved in a way that has harmed a child, may have harmed a child, may have committed a criminal offence against a child, or has behaved in a way that indicates they may pose a risk to children, is reported to the DSL immediately, or to the Chief Executive if the allegation concerns the DSL.

The DSL, or the Chief Executive, consults the Local Authority Designated Officer (LADO) within one working day and before any internal investigation is undertaken. The adult may be asked to step back from contact with students while the matter is considered; this is a neutral act and not a finding.

The LADO consulted is the one for the local authority in which the concern arises. As an organisation based in Essex working with students across several authorities, we consult Essex County Council's LADO service in the first instance and refer on as they direct.

Low-level concerns about an adult's behaviour that do not meet the allegation threshold are also recorded and reviewed by the DSL, so that patterns are seen.

Any adult on the programme may raise a concern about safeguarding practice, including about senior staff, without fear of detriment. The Public Interest Disclosure Act 1998 applies, and the NSPCC whistleblowing helpline is available to anyone who feels unable to raise a concern internally.

12. Records, confidentiality and information sharing

Safeguarding records are kept securely, separately from other programme records, and are accessible only to the DSL, the Deputy and the Chief Executive. Records of concerns, incidents and allegations are retained until the individual reaches the age of 25. General safeguarding documentation, including DBS records and policy acknowledgements, is retained for six years from the end of the student's programme. Both periods are as set out in our Privacy Policy.

We tell students that what they tell us will be shared with the people who need to know in order to keep them safe, and with nobody else. We do not promise absolute confidentiality. We share information with parents, schools, local authorities and the police in accordance with Working Together to Safeguard Children and the Data Protection Act 2018, which permit sharing without consent where necessary to protect a child. Where we share, we record what was shared, with whom and why.

Our Privacy Policy explains how personal information is used across the programme, including for recordings and for the use of ProfBot.

13. Training

Every adult on the programme completes safeguarding induction before their first contact with students, covering this Policy, how to recognise and report a concern, the code of conduct, and online safety. Training is refreshed at least annually and whenever this Policy changes materially. Records of training are kept with the central record of checks.

14. Students, parents and carers

A one-page summary of this Policy, written for students, is included in the Student Induction Pack and is available on the platform. It tells students who the DSL is, how to make contact, what will happen if they do, and that they will be listened to.

Parents and carers receive this Policy with the enrolment information and are asked to confirm they have seen it. Event-specific consent and safeguarding information is issued before each in-person event.

15. Monitoring and review

The DSL reports to the Chief Executive at the end of each programme year on the operation of this Policy, the number and type of concerns handled (without identifying students), training completed, and any lessons learned. This Policy is reviewed annually, after any serious incident, and whenever statutory guidance changes. The Chief Executive approves each version.

Appendix A: Concern record

A concern record contains: the student's name and school; the date, time and place of the concern or disclosure; who raised it; what was seen, heard or said, in the student's own words where possible, kept separate from any interpretation; any immediate action taken; the name and signature of the person recording; and the date and time it was passed to the DSL. The DSL adds the decision, the reasons, and every subsequent action, dated.

Appendix B: External contacts