Safeguarding and Child Protection Policy

1. Introduction

This Safeguarding and Child Protection Policy sets out the commitment of Summit Mentoring Hub LTD a UK-based  mentoring service, to safeguard and promote the welfare of children and young people. The Business recognises its duty of care and takes seriously its responsibility to protect children from harm.

This policy applies to:

• The business owner / mentor

• Any associates, subcontractors, or volunteers engaged by the Business

• Any other adults involved in mentoring activities delivered by the Business

A child is defined as anyone under the age of 18, in line with the Children Act 1989.

2. Legal Framework

This policy is informed by, and should be read in conjunction with, the following legislation and statutory guidance:

• Children Act 1989 and Children Act 2004

• Working Together to Safeguard Children (HM Government)

• Keeping Children Safe in Education (where relevant)

• The United Nations Convention on the Rights of the Child

• Data Protection Act 2018 and UK GDPR

3. Policy Statement

Summit Mentoring Hub LTD is committed to:

• Safeguarding and promoting the welfare of children and young people

• Providing a safe mentoring environment

• Ensuring all concerns about a child’s welfare are taken seriously and acted upon appropriately

• Working in partnership with parents/carers and relevant agencies where necessary

The Business has zero tolerance for abuse of any kind.

4. Types of Abuse

Safeguarding concerns may relate to:

• Physical abuse – deliberate physical harm

• Emotional abuse – persistent emotional maltreatment

• Sexual abuse – forcing or enticing a child to take part in sexual activities

• Neglect – persistent failure to meet a child’s basic physical or psychological needs

• Online abuse – abuse facilitated through digital platforms

5. Roles and Responsibilities

Designated Safeguarding Lead (DSL)

As a freelance mentoring business, the Designated Safeguarding Lead is:

Name: Layla Wareham-Bassett Role: Business Owner / Lead Mentor Contact: layla@summitmhltd.com

The DSL is responsible for:

• Implementing this policy

• Responding to safeguarding concerns

• Making referrals to children’s social care or the police where necessary

• Keeping safeguarding records securely

• Undertaking regular safeguarding training

6. Safer Working Practices

All mentoring activities will:

• Take place in agreed, appropriate settings (e.g. schools, community venues, online platforms with parental consent)

• Be conducted in a professional manner at all times

• Maintain appropriate boundaries between mentor and child

Mentors must not:

• Engage in physical contact unless necessary and appropriate

• Communicate with children via social media or personal messaging apps

• Communicate with the children outside of mentoring hours unless planned appropriately with parent/guardian

• Transport children without parental consent

7. Online and Remote Mentoring

Where mentoring is delivered online:

•  Parental/carer consent must be obtained

• Sessions should take place on approved platforms

• Communication should be professional and transparent

• Records of sessions should be maintained

8. Recruitment and Vetting

The Business ensures safer recruitment practices, including:

• Enhanced DBS checks (including barred list where appropriate)

• Verification of identity and qualifications

• Safeguarding training prior to working with children

DBS checks will be renewed in line with best practice.

9. Responding to Safeguarding Concerns

If a child discloses abuse or a safeguarding concern is identified:

1. Listen carefully and remain calm

2. Do not promise confidentiality

3. Reassure the child that they have done the right thing

4. Record the information accurately and promptly

5. Report the concern to the DSL immediately

If a child is at immediate risk of harm, contact emergency services (999).

Referrals may be made to:

• Local Authority Children’s Social Care

• The Police

• NSPCC (0808 800 5000)

10. Allegations Against Adults

Any allegation against the mentor or an adult associated with the Business will:

• Be taken seriously

• Be reported immediately to the Local Authority Designated Officer (LADO)

• Result in suspension of mentoring activities where appropriate

11. Confidentiality and Information Sharing

• Safeguarding information will be shared on a need-to-know basis

• Records will be stored securely in line with GDPR

• Confidentiality will not be maintained where a child is at risk of harm

12. Record Keeping

The Business will:

• Keep clear, factual safeguarding records

• Store records securely and separately from general mentoring records

• Retain records in line with legal requirements

13. Training and Review

The DSL will:

• Undertake safeguarding training at least every 2–3 years

• Keep up to date with changes in safeguarding legislation

This policy will be reviewed annually or sooner if legislation or guidance changes.

14. Policy Approval

Policy Owner: Layla Wareham-Bassett

Date Adopted: 14/01/26

Review Date: 14/01/26

15. Contact Information

For safeguarding concerns, contact:

• Designated Safeguarding Layla Wareham-Bassett

• Local Authority Children’s Services: 01189 373641

• NSPCC Helpline: 0808 800 5000

Equality, Diversity & Inclusion Policy

For Summit Mentoring Hub LTD

1. Purpose

This policy sets out the Business’s commitment to promoting equality, valuing diversity, and ensuring inclusion in all aspects of wellbeing mentoring services.

2. Scope

This policy applies to:

• Children and young people receiving mentoring

• Parents, guardians, and carers

• Schools, local authorities, and other stakeholders

• The mentor and any approved associates

3. Principles

• Every child and young person is treated with respect and dignity.

• Discrimination, harassment, or victimisation on the basis of protected characteristics (Equality Act 2010) is not tolerated.

• Services are inclusive, accessible, and tailored to individual needs.

• The mentor promotes a culture of fairness, respect, and openness.

4. Implementation

• Mentoring sessions consider individual needs, abilities, and circumstances.

• Materials, language, and communication methods are inclusive.

• Opportunities for participation are provided equitably.

• Feedback is sought and valued to improve inclusivity.

5. Responsibilities

The mentor is responsible for:

• Upholding the principles of equality, diversity, and inclusion

• Addressing any incidents of discrimination or bias immediately

• Ensuring practice reflects inclusivity and accessibility standards

Parents, carers, and stakeholders are encouraged to:

• Support inclusive practices

• Report any concerns regarding discrimination or exclusion

6. Monitoring & Review

• Policies and practices are reviewed regularly to ensure equality and inclusivity

• Adjustments are made as needed to address emerging needs or concerns

For Summit Mentoring Hub LTD

Health and Safety Policy

EHCP & Local Authority Aligned

Policy Statement

Summit Mentoring Hub committed to promoting the health, safety, and wellbeing of all children and young people accessing mentoring services. This policy aligns with expectations set by Local Authorities, EHCP provision standards, and statutory guidance including:

• Health and Safety at Work etc. Act 1974

• Management of Health and Safety at Work Regulations 1999

• Children Act 1989 & 2004

• Working Together to Safeguard Children (2023)

• Keeping Children Safe in Education (where applicable)

Health and safety practice is embedded within safeguarding procedures and is central to supporting positive outcomes for children and young people with additional needs.

1. Roles and Responsibilities

Mentor Responsibilities

The Mentor will:

• Take reasonable care of their own health and safety and that of the mentee

• Act in loco parentis during sessions

• Carry out written and dynamic risk assessments

• Ensure all activities are appropriate to the mentee’s EHCP outcomes, age, needs, and abilities

• Follow safeguarding and whistleblowing procedures

• Maintain professional boundaries at all times

• Hold appropriate insurance and qualifications

Parent / Carer Responsibilities

Parents/carers will:

• Provide accurate medical, behavioural, and emergency information

• Inform the Mentor of any changes that may impact safety

• Provide written consent for off-site activities and transport

2. Risk Assessment and Planning

• Individual risk assessments will be completed for each mentee where required by the Local Authority or EHCP.

• Risk assessments consider: 

  • The child’s SEND profile

  • Emotional regulation and SEMH needs

  • Physical and sensory needs

  • Environmental and travel risks

• Dynamic risk assessments are undertaken during sessions and activities may be adapted or stopped if risks increase.

3. Transporting Children and Young People

Where transport is agreed as part of provision:

• Written parental consent will be obtained.

• Transport supports EHCP outcomes such as independence, confidence, and community access.

• The Mentor will hold a full UK driving licence.

• The vehicle will be: 

  • Fully roadworthy

  • Insured for business use

  • Equipped with appropriate seatbelts and child safety measures

• Seatbelts must be worn at all times.

• Mobile phones will not be used while driving and only accessed via hands free if necessary.

Transport will not be provided where it presents an unmanageable risk.

4. Use of Community and Local Environments

Mentoring may take place in local environments including parks, libraries, shops, cafés, and community spaces.

The Mentor will:

• Select environments appropriate to the mentee’s needs and risk profile

• Avoid high-risk or overcrowded locations

• Consider accessibility, weather, and sensory impact

• Maintain appropriate supervision and visibility

• Ensure activities remain purposeful and outcome-focused

5. Safeguarding and Supervision

• Safeguarding underpins all health and safety practice.

• Concerns about a child’s welfare will be reported in line with Local Authority safeguarding procedures.

• Lone working risks are assessed and managed.

• The Mentor will escalate concerns immediately where there is risk of harm.

6. Medical Needs and Emergencies

• Relevant medical information must be disclosed prior to sessions.

• Emergency contact details are carried at all times.

• In the event of illness or injury: 

  • First aid will be administered where appropriate

  • Emergency services will be contacted if required

  • Parents/carers will be informed immediately

7. Accidents and Incident Reporting

• All accidents, incidents, and near misses will be recorded.

• Serious incidents will be reported to parents/carers and, where required, the Local Authority.

• Records will be stored securely in line with data protection legislation.

8. Insurance

The Mentor holds:

• Public Liability Insurance

• Professional Indemnity Insurance

• Business-use vehicle insurance (where applicable)

Evidence of insurance is available upon request.

9. Policy Review

This policy will be reviewed annually or sooner if:

• Legislation changes

• Service delivery changes

• An incident highlights the need for review

Parent-Friendly Summary

How we keep your child safe

• Your child’s safety and wellbeing come first at all times.

• Activities are carefully considered and risk assessed.

• Community visits are chosen to support confidence, independence, and EHCP outcomes.

• Vehicles are insured, safe, and seatbelts are always worn.

• We follow strict safeguarding procedures and will contact you immediately if there are concerns.

• Any accidents or incidents are recorded and shared with you.

If you ever have questions or concerns about safety, you are encouraged to speak directly to the

1. Purpose

This policy sets out expectations for behaviour and outlines positive support strategies to create a safe and supportive mentoring environment for children and young people with social, emotional, and mental health (SEMH) needs.

The aim is to promote wellbeing, respect, and constructive engagement.

2. Scope

This policy applies to:

• All children and young people receiving mentoring

• Parents and legal guardians

• All mentoring sessions delivered online or in person

3. Guiding Principles

• Positive behaviour is encouraged through respect, recognition, mutual planning and constructive feedback.

• Understanding individual SEMH needs is central to supporting positive behaviour.

• Mentoring sessions are safe, inclusive, and predictable due to them being child-led

• Behaviour concerns are addressed with empathy and proportionate responses.

4. Expectations of Behaviour

Children and young people are expected to:

• Show respect for themselves, the mentor, and others

• Communicate safely and honestly

• Follow agreed session boundaries

The mentor will:

• Model respectful and positive behaviour

• Listen actively and respond appropriately

• Maintain professional boundaries

5. Positive Support Strategies

Strategies may include:

• Clear, consistent communication of expectations

• Use of praise, celebrating small successes, reinforcement that is appropriate to the child at sessions

• Collaborative goal-setting

• Support for self-regulation and emotional awareness

• Adjusting activities to suit individual needs

6. Managing Challenging Behaviour

• Behaviour is assessed in context, considering SEMH needs.

• Minor disruptions are managed calmly, with restorative approaches where possible.

• Persistent or unsafe behaviour may result in temporary suspension of a session, with parent/guardian discussion.

• Serious safeguarding concerns are acted on immediately in line with the Confidentiality & Safeguarding policies.

7. Online Behaviour Expectations

• Children should participate in a safe and appropriate environment

• Respectful communication is expected at all times

• Rules for online etiquette are shared in advance and reinforced during sessions

8. Recording Behavioural Observations

• Observations are recorded objectively, factually, and respectfully.

• Notes are stored securely in line with the Data Protection Policy.

9. Collaboration with Parents / Guardians

• Parents/guardians are informed of significant concerns or patterns in behaviour.

• Positive developments and progress are communicated as appropriate.

Confidentiality & Information Sharing Policy

For Summit Mentoring Hub LTD

1. Purpose

This policy explains how confidentiality is maintained and how information is shared appropriately when providing wellbeing mentoring to children and young people under the age of 18.

The Business recognises the importance of trust while also meeting legal and safeguarding responsibilities.

2. Scope

This policy applies to:

• All children and young people receiving mentoring

• Parents and legal guardians

• All mentoring sessions delivered online or in person

• All records, communications, and session notes

3. Principles of Confidentiality

• Information shared during mentoring sessions is treated with respect and care.

• Confidentiality helps build trust and emotional safety for young people.

• Confidentiality is not absolute and must be balanced with safeguarding duties.

4. What Information Is Kept Confidential

The following is normally treated as confidential:

• Session discussions and reflections

• Wellbeing goals and progress

• Personal thoughts, feelings, and experiences shared by the child

Information is recorded factually and proportionately.

5. Limits to Confidentiality

Confidentiality may be broken, without consent, where:

• There is a concern that a child or young person is at risk of harm

• There is a disclosure of abuse or neglect

• There is a risk of serious harm to the child or others

• Information is required by law or a statutory authority

In such cases, information will be shared on a need-to-know basis only.

6. Information Sharing with Parents / Guardians

• Parents and guardians are provided with appropriate information about attendance, engagement, and general progress.

• Detailed session content is not routinely shared to protect the child’s privacy.

• Where safeguarding concerns arise, parents will be informed unless doing so would place the child at additional risk.

7. Information Sharing with Other Professionals

Information may be shared with:

• Safeguarding services

• Schools or local authorities

• Health or support professionals

Information sharing follows statutory guidance and is:

• Necessary

• Proportionate

• Relevant

• Timely

8. Recording and Storage of Information

• Records are kept securely and accessed only by the sole trader.

• Information is recorded objectively and respectfully.

• Data storage complies with the Business’s Data Protection & GDPR Policy.

9. Explaining Confidentiality to Children

• Confidentiality and its limits are explained to children in an age-appropriate way.

• Children are encouraged to ask questions and seek clarification.

10. Breaches of Confidentiality

• Any breach of confidentiality is taken seriously.

• Breaches are recorded and reviewed.

• Where required, appropriate authorities and individuals are informed.

Item descriptionProfessional Boundaries & Code of Conduct

For Summit Mentoring Hub LTD

1. Purpose

This policy sets out the professional standards, ethical expectations, and boundaries for the mentor to ensure safe, respectful, and effective mentoring relationships with children and young people.

2. Scope

Applies to:

• All mentoring sessions delivered online and in person

• Interactions with children, young people, parents/guardians, schools, and other professionals

• The sole trader mentor and any approved associates

3. Core Principles

• Integrity, honesty, and transparency

• Respect and inclusivity

• Confidentiality balanced with safeguarding duties

• Professionalism in all communication and conduct

• Duty of care towards children and young people

4. Professional Boundaries

• The mentoring relationship is strictly professional.

• Physical contact is avoided unless safe, appropriate, and consented (e.g., supportive guidance in activities).

• Communication is through agreed professional channels; social media contact is not used.

• Relationships with parents, schools, and other professionals are collaborative, respectful, and professional.

5. Conflicts of Interest

• Any personal, financial, or other conflicts of interest must be declared immediately.

• Services are delivered without exploiting the mentoring relationship for personal gain.

6. Safeguarding and Child Protection

• The mentor adheres to safeguarding policies and procedures.

• Concerns, disclosures, or risks of harm are acted upon promptly and reported to appropriate authorities.

7. Online Conduct

• Online sessions use secure platforms with privacy settings.

• All digital communication is professional, recorded where necessary, and in accordance with confidentiality and data protection policies.

8. In-Person Conduct

• Sessions take place in safe, agreed locations.

• Appropriate supervision and risk assessment are in place.

• Behaviour management follows positive support and SEMH-informed approaches.

9. Breaches of the Code

• Breaches are taken seriously and may result in termination of services.

• Serious breaches may be reported to safeguarding authorities or other relevant bodies.

Complaints Policy

For Summit Mentoring Hub LTD

1. Purpose

This policy outlines the procedure for raising, handling, and resolving complaints regarding the wellbeing mentoring services provided by the Business. It ensures transparency, fairness, and accountability.

2. Scope

This policy applies to:

• Children and young people receiving mentoring

• Parents and legal guardians

• Schools, local authorities, or other relevant stakeholders

3. Principles

• Complaints are taken seriously and handled promptly.

• All parties are treated respectfully and fairly.

• Confidentiality is maintained, except where safeguarding or legal obligations require disclosure.

• The process is clear, transparent, and accessible.

4. How to Raise a Complaint

• Complaints should be submitted in writing (email or letter) to the mentor or Business owner.

• Include: 

  • Your name and relationship to the child

  • Date and details of the incident or issue

  • Any supporting information or documentation

5. Acknowledgment

• Complaints will be acknowledged within 5 working days of receipt.

• The acknowledgment will include the expected timescale for a full response.

6. Investigation

• The mentor will review all relevant information.

• Additional parties (parents, schools, or staff) may be consulted as appropriate.

• The investigation will be conducted fairly and objectively.

7. Resolution

• A written response will be provided detailing findings, conclusions, and any actions taken.

• Where appropriate, steps will be taken to prevent recurrence.

• Outcomes are communicated to all relevant parties.

8. Escalation

• If the complainant is dissatisfied with the outcome, they may request a further review.

• Independent mediation or external advice may be sought in exceptional circumstances.

9. Record Keeping

• All complaints and outcomes are recorded securely in line with Data Protection & GDPR Policy.

• Records are retained for a minimum of six years.

10. Policy Review

This policy is reviewed annually or following significant complaints to ensure continued effectiveness

Business Code of Conduct and Data Protection Policy

For Summit Mentoring Hub LTD (Primarily Under 18s)

Part A: Business Code of Conduct

1. Purpose

This Code of Conduct sets out the ethical standards, professional expectations, and behaviours of the sole trader wellbeing mentoring service ("the Business"). It applies to all mentoring activities delivered online and in person, primarily to children and young people.

2. Core Values

The Business is committed to:

• Safeguarding and promoting the welfare of children and young people

• Integrity, honesty, and transparency

• Respect, diversity, and inclusion

• Professional competence and accountability

• Confidentiality balanced with safeguarding responsibilities

• Compliance with UK law and recognised best practice

3. Professional Standards

• Mentoring services are delivered with appropriate skill, care, and diligence.

• The mentor acts in the best interests of the young person at all times.

• The Business is clear about the scope and limits of wellbeing mentoring.

• Mentoring does not replace therapy, counselling, medical, or mental health treatment.

• No guarantees of outcomes are made.

4. Safeguarding and Child Protection

• The Business places safeguarding at the centre of all practice.

• The mentor holds an appropriate DBS check (Enhanced where required).

• Safeguarding concerns, disclosures, or risks of harm will be acted upon immediately and in line with statutory guidance (e.g. Keeping Children Safe in Education and local safeguarding procedures).

• Confidentiality may be broken where there is a concern about a child’s safety or wellbeing.

• Parents or legal guardians will be informed of safeguarding concerns unless doing so would place the child at additional risk.

5. Consent and Parental Involvement

• Written consent from a parent or legal guardian is required before mentoring begins.

• Clear agreements are established regarding communication, session format, and boundaries.

• Parents/guardians will be provided with appropriate updates while respecting the young person’s privacy.

6. Respect, Equality, and Inclusion

• The Business does not tolerate discrimination, harassment, or abuse.

• All young people are treated with dignity and respect regardless of background or protected characteristics under the Equality Act 2010.

• Practice is inclusive, trauma-aware, and developmentally appropriate.

7. Professional Boundaries

• Clear boundaries are maintained at all times.

• No inappropriate physical contact, communication, or relationships are permitted.

• Communication outside sessions is limited to agreed professional channels.

• One-to-one sessions are conducted transparently, with appropriate safeguarding measures in place.

8. Online and In-Person Delivery

• Online sessions are conducted via secure, reputable platforms with privacy settings enabled.

• In-person sessions take place in safe, appropriate, and agreed locations.

• The mentor ensures environments are suitable, supervised where required, and risk assessed.

9. Confidentiality

• Information shared in sessions is treated as confidential, subject to safeguarding obligations.

• Records are kept factually, respectfully, and securely.

10. Complaints and Concerns

• Parents, guardians, and young people can raise concerns or complaints.

• Complaints are handled promptly, fairly, and confidentially.

11. Breaches of the Code

• Any breach of this Code may result in termination of services and, where appropriate, referral to safeguarding authorities.

Part B: Data Protection Policy (UK GDPR)

1. Purpose

This policy explains how the Business processes personal data relating to children, young people, and parents/guardians, in accordance with the UK GDPR and Data Protection Act 2018.

2. Data Controller

The Business operates as a sole trader and is the Data Controller for all personal data processed.

3. Personal Data Collected

The Business may collect:

• Child’s name, age, and relevant background information

• Parent/guardian contact details

• Consent forms and agreements

• Session notes and wellbeing goals

• Communications relating to sessions

• Payment and invoicing records

Special category data (including health or wellbeing information) is processed only where necessary and with explicit parental consent.

4. Lawful Basis for Processing

Personal data is processed under the following lawful bases:

• Consent (particularly for children’s data and special category data)

• Contract (to deliver agreed services)

• Legal obligation (safeguarding, tax, and record-keeping)

• Vital interests (where there is a serious risk of harm)

5. Children’s Data

• Children’s data is treated with the highest level of care.

• Only data that is necessary for the mentoring service is collected.

• Information is explained in an age-appropriate way where relevant.

6. How Data Is Used

Data is used to:

• Deliver wellbeing mentoring services

• Communicate with parents/guardians and young people

• Maintain safeguarding and session records

• Manage bookings, payments, and administration

• Comply with legal obligations

7. Data Storage and Security

• Data is stored securely using password-protected devices and reputable encrypted systems.

• Paper records are stored in locked storage.

• Access to data is restricted to the sole trader only.

8. Data Retention

• Safeguarding and client records are typically retained until the child reaches 25 years of age, in line with safeguarding best practice.

• Financial records are retained for at least six years in line with HMRC requirements.

• Data is securely deleted when no longer required.

9. Data Sharing

• Data is not sold or shared for marketing.

• Information may be shared with safeguarding agencies where required.

• Trusted service providers (e.g. payment processors) may process data under appropriate agreements.

10. International Transfers

• Where data is processed outside the UK, appropriate UK GDPR safeguards are in place.

11. Data Subject Rights

Parents/guardians and young people (where appropriate) have the right to:

• Access personal data

• Request correction or erasure (where applicable)

• Restrict or object to processing

• Withdraw consent at any time

Requests are responded to within one month.

12. Data Breaches

• Any data breach will be assessed promptly.

• Reportable breaches will be notified to the ICO within 72 hours.

• Affected individuals will be informed where required.