Targeted Provision - Online Safety Policy

Josh Nieboer By Josh Nieboer

Policy owner

Head of Education

Last updated

30 July 2026

Next update due

1 September 2026

1. Contacts

2. Review

The policy will be reviewed every six months. It will also be revised following any concerns and/or updates to national and local guidance or procedure.

3. Introduction

This policy sets out how Tutors interact online responsibly, lawfully, and ethically when working with or on behalf of the Company. The expectations in this document apply to all individuals who deliver services involving children and young people through Targeted Provision, regardless of employment status. They arise from Targeted Provision's statutory and contractual obligations under safeguarding legislation, data protection law (UK GDPR), Keeping Children Safe in Education, 2026 and the terms of our contracts with commissioning Local Authorities - not from any exercise of management direction or control over how individuals carry out their work. Compliance with these expectations is a condition of working with Targeted Provision in any capacity and reflects the minimum standards required by law and by the nature of the work, rather than employer-imposed rules of conduct.

Where it is deemed appropriate by the referring body that our provisions are delivered online, the following considerations should be taken into account:

  • A switch from face to face to online tuition should only be done with agreement from all parties involved, including parents/carers and the referring school or local authority.

  • We need to be mindful of the ICT that young people can access from their home, considering different internet speeds, hardware access and the presence of a responsible adult. Being mindful of those with limited access, our online provision is designed to be accessible to the majority of YP.

  • The minimum technology required will be an internet connection and a camera (accessed through a tablet, laptop or PC). We have ensured our tutors have access to the relevant technology.

4. Understanding online risk, the four areas of risk

Targeted Provision follows the four areas of online risk set out in Keeping Children Safe in Education. Tutors, mentors and staff should be alert to all four when working with children online:

  • Content - being exposed to illegal, inappropriate or harmful material, for example pornography, self-harm and suicide content, radicalisation and extremism, misogyny, and misinformation or disinformation.

  • Contact - harmful interaction with other users, or with generative AI applications that simulate another person, for example peer pressure, commercial pressure, and adults posing as children in order to groom or exploit a child for sexual, criminal or financial purposes.

  • Conduct - online behaviour that increases the likelihood of, or causes, harm, for example the making, sending or receiving of explicit images (including images generated using AI) and online bullying.

  • Commerce - commercial risks such as online gambling, inappropriate advertising, phishing and financial scams.

Any concern falling within these areas should be reported to the DSL or a deputy via the red button in the usual way. These categories inform how Targeted Provision designs its online delivery, its device controls, and the guidance in this policy.

5. Online delivery - Zoom

Tutors providing online tutoring with Targeted Provision are required to use our company Zoom Education account, which allows tutors and young people to see and hear each other in High Definition, interact via Zoom’s whiteboard technology, and do so safely.

We require all tutors to name the topic of each Zoom meeting/ session using the format first name of the YP + surname initial E.g. Josh N

To fulfil our legal safeguarding obligation and legitimate interest to safeguard children, young people and adults, we record all online lessons. We also record lessons to assess the quality of the teaching and learning. It is a legitimate interest of ours to ensure that all lessons meet our high standards.  Please note that you have the right to object to our viewing the recordings. If you would like to object, please put your concerns in writing and send them to tutors@targetedprovision.com

Recordings are encrypted in transit and at rest, stored securely and are only accessible for safeguarding purposes by our safeguarding team and/or Designated Safeguarding Leads

Stakeholders can ask to “opt out” of lessons being recorded, which we will always consider, but not necessarily comply with if we believe it compromises the safeguarding of children, young people and adults involved

6. Safeguarding Checklist for Tutors - Zoom

The following checklist exists to protect the safety of young people. We will not compromise on the Health & Safety/Safeguarding Procedures that surround young people.

  • Tutors are required to use the Company’s Zoom Education to deliver all online sessions for safeguarding purposes, in line with our safeguarding policy. You must not use the Company’s Zoom Education to deliver sessions to other students referred to you outside of Targeted Provision.

  • Keep your video on at all times for safeguarding purposes.

  • Only send documents via Zoom, not via email to students. You must not engage with students via the student's own email addresses or phone. All communication outside of the lesson must be done through the parent or carer's email address.

  • The parent or carer will act as an additional appropriate adult throughout the session for safeguarding purposes. If you find that there is no additional adult at home during a session, you must end the session and report this as a safeguarding concern; we do not support lone working.

  • Tutors must switch geolocation options off by default when at the young person’s home so that the child’s location is not visible to others. We recommend that tutors turn on Airplane mode during the session.

7. The loaning of laptops - security controls

In certain circumstances, we may loan a laptop device to a young person. The adult responsible for the young person must sign an Equipment Loan Agreement, where they agree to the following safety measures:

  • that they are present available at the other end during online sessions

  • online lessons with the tutor do not take place in the student’s bedroom

  • they organise times of sessions with the tutor

  • the young person does not contact the tutor outside of the lesson time

  • the young person does not contact the tutor via any social media account

Security and privacy settings are installed on these devices to ensure their safe use by the young person, including:

  • Only targetedprovision.education domains can sign into the laptop

  • All TP loaned equipment is subject to our extensive filtering and monitoring processes and software, 24 hours a day.

  • SafeSearch for Google Search queries is turned on

  • Restricted Mode on YouTube is enforced

  • Safe Browsing is always enabled

  • Safe Browsing checks are completed on all downloadable files

  • Users are not able to bypass Safe Browsing warnings or our filtering and monitoring software.

  • Sites are filtered for adult content

  • Devices are forced to automatically re-enroll after wiping. Even if someone wipes a chromebook, the device remains managed.

  • If the device is lost or stolen, devices can be disabled remotely and the laptop will displace return instructions.

  • Guest access is blocked so that only the student can sign into the device and all the above settings will apply.

8. Responsibility for, and review of filtering and monitoring

The filtering and monitoring controls described above are owned by the Online Safety Officer, working with our Group Technology Director and with the support of the DSL. Targeted Provision reviews the effectiveness of these controls at least once every academic year, and sooner if a concern, an incident, or a change in guidance makes it necessary. The review checks that filtering and monitoring are working as intended on all loaned devices, considers the ages and particular vulnerabilities of the children using them, and weighs the safeguarding benefit against any impact on learning. A record of each review and of the checks carried out is kept by the Online Safety Officer.

Targeted Provision has regard to the Department for Education’s filtering and monitoring standards when setting and reviewing these controls, and to the Department’s Generative AI: product safety expectations where any generative AI tool is made available to children on a loaned device.

9. Information security and cyber security

Protecting children’s personal information is part of keeping them safe. Targeted Provision maintains appropriate cyber security measures to protect the personal data it holds including recorded lessons, which are held securely with access limited to the DSL and Group Technology Director to reduce the risk of data breaches and of disruption to delivery. 

In doing so we have regard to the Cyber Security Standards for Schools and Colleges and to guidance from the National Cyber Security Centre, applied proportionately to our size and to the way we work. Any suspected data breach or cyber security incident affecting children’s information must be reported to the DSL and the Head of Education without delay so that it can be assessed and, where required, reported to the Information Commissioner’s Office.

10. Safeguarding checklist - General

If using screen sharing, please ensure nothing else is minimised on your computer that is personal.

Do not hold the tuition sessions in your bedroom and don’t allow the student to be in their bedroom either.

Ask anyone else in your house to be mindful that you are holding a session and to keep noise levels down.

Be in a well-lit environment with no personal photos or information visible.

No contact should be made directly with the student via any form of social media account.

No contact should be made directly with the student via their mobile, email or by any other method. All contact should be via the parent or carer’s email address and phone number. Contact should relate only to accessing session links. Any further requests from parents should be shared with Targeted Provision.

If a parent/carer requests that the tutor contact the young person directly, Targeted Provision needs written consent from the parent, and the tutor must cc the parent/carer and Targeted Provision in all email communications.

Be mindful that sessions might not last the usual length; due to unforeseen circumstances we need to be flexible with young people.

Ensure another responsible adult is in the vicinity. Please notify us on your reporting form if another responsible adult is not present at the location you are tutoring.

If a student attempts to contact you directly, outside of the agreed tutoring timetable, uses inappropriate language or sends inappropriate images, report this as a safeguarding concern without hesitation and block their number immediately.

11. Nudes and semi-nudes, including where generated by AI

Targeted Provision uses the term “nudes and semi-nudes” to describe the creation, sending or posting of nude or semi-nude images by a person under the age of 18. This includes all visual content, photographs, videos and livestreams, whether taken by the child themselves, taken or created by someone else, digitally altered, or wholly generated using artificial intelligence, including so-called “deepfakes” or “deep nudes.”

Tutors and mentors should treat any concern about the making or sharing of nudes and semi-nudes as a safeguarding concern, whether or not the sharing is consensual and whether or not the image is AI-generated or altered. If a child shares such an image during or around an online session, or discloses that one has been made or shared, do not view, save, copy, forward or delete the image; report it to the DSL or a deputy via the red button immediately. Non-consensual sharing, including of AI-generated or digitally altered images, is both illegal and abusive and should be treated as a safeguarding emergency where there is an immediate risk to a child.

This applies equally to sessions delivered through Targeted Provision’s Zoom Education platform. It complements, and does not replace, the existing instruction to report a student who sends inappropriate images and to raise it as a safeguarding concern without hesitation.

12. Use of generative AI

Generative AI tools (for example AI chatbots and image generators) can support learning but also carry risks, including inaccurate or inappropriate content, exposure to tools that simulate contact with another person, and the misuse of AI to create explicit or altered images. Tutors and mentors must not direct a child to a generative AI tool during a session unless it has been agreed as appropriate for that child, and must never input a child’s personal information, images or identifying details into a generative AI tool. Where a child appears to be using generative AI in a way that raises a safeguarding concern, for example to access harmful content, or to create or share nude, semi-nude or altered images, this must be reported to the DSL or a deputy via the red button. Targeted Provision has regard to the Department for Education’s guidance Generative artificial intelligence in education when deciding how such tools may be used.

13. Guidance and Support

Where online provisions become essential, guidance and support is readily available via specialists within Targeted Provision. Contact your support contact at TP for further information.

14. Useful Links for Tutors

15. National Links and Resources for Parents/Carers