Safeguarding and Child Protection Policy

If a child is in immediate danger, call 999. If you are worried about a child, tell the school's Designated Safeguarding Lead (DSL) straight away, then tell Luma's DSL the same day on 0204 576 4344 or info@lumaedrec.com.

Approved by the Directors of Luma Education Recruitment. Based on Keeping Children Safe in Education 2026 (KCSIE, September 2026); Working Together to Safeguard Children; the Conduct of Employment Agencies and Employment Businesses Regulations 2003; GCA RM6376 framework; APSCo Compliance+ Education Standards v15.

1. Policy statement

Luma Education Recruitment ("Luma") supplies teachers, support staff and other temporary workers to schools, colleges and early years settings in England. We believe every child has the right to be safe, and that safeguarding and promoting the welfare of children is everyone's responsibility. "Children" means everyone under the age of 18.

Although schools are responsible for the children in their care, Luma has its own clear duties: to make sure every worker we supply is safe and suitable to work with children; to make sure our workers know how to recognise and respond to concerns; to act quickly and fairly when concerns or allegations are raised about our workers; and to meet our legal duty to refer to the Disclosure and Barring Service (DBS). KCSIE 2026 makes clear that schools and agencies share safeguarding responsibilities for supply staff.

This policy also protects adults at risk. Where a worker is placed in a setting with adults at risk (for example, a post-16 SEND provision), the same principles apply.

Our aims

• Recruit and vet every worker to at least the standard a school must meet for a direct appointment (KCSIE Part three), and to framework and APSCo Compliance+ standards where they apply.
• Make sure every worker has read KCSIE Part one, is trained, and knows how to report concerns in each school they work in.
• Respond to every concern about a child, and every concern or allegation about a worker, promptly, fairly and in line with KCSIE Part four and local safeguarding arrangements.
• Refer to the DBS (and consider referral to the Teaching Regulation Agency) whenever the legal criteria are met, and keep a full audit trail of every referral.
• Share information safely and lawfully, and keep accurate, secure records.
• Learn from incidents and review this policy at least once a year.

2. Scope

This policy applies to everyone who works for or on behalf of Luma, whether paid or unpaid, including directors, internal recruitment and compliance staff, contractors, and all temporary workers while on assignment. It covers placements made directly with schools (DfE standard) and through public sector frameworks such as the Government Commercial Agency (GCA) RM6376 framework and the Value Match / HEART Academies Trust framework.

It should be read with the Luma Code of Conduct (September 2026), the Luma Vetting Requirements checklist, and the safeguarding policy of each school a worker is placed in. Where a school's procedures differ, workers follow the school's procedures while on site and also inform Luma as set out in this policy.

3. Legislation and guidance

This policy reflects the following (as amended):

• Keeping Children Safe in Education 2026 (statutory guidance, September 2026), which replaces KCSIE 2025.
• Working Together to Safeguard Children (statutory guidance) and "What to do if you're worried a child is being abused".
• Children Act 1989 and 2004; Education Act 2002 (section 175/157); Childcare Act 2006 and the Childcare (Disqualification) Regulations 2018.
• Safeguarding Vulnerable Groups Act 2006, including the duty to refer to the DBS, as amended by the Crime and Policing Act 2026 (which removed the "supervision exemption" from regulated activity).
• Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975; Police Act 1997.
• Conduct of Employment Agencies and Employment Businesses Regulations 2003 (including regulations 19 to 22).
• Counter-Terrorism and Security Act 2015 (Prevent duty); Female Genital Mutilation Act 2003 (mandatory reporting duty); Sexual Offences Act 2003 (including abuse of a position of trust); Modern Slavery Act 2015.
• Data Protection Act 2018, UK GDPR and the Data (Use and Access) Act 2025 ("data protection laws").
• Equality Act 2010, including the Public Sector Equality Duty where we work with public bodies; Human Rights Act 1998.
• Early Years Foundation Stage (EYFS) statutory framework, section 3.
• DfE "Restrictive interventions, including use of reasonable force in schools" guidance and DfE guidance on generative AI in education and mobile phones in schools.
• GCA RM6376 Framework Schedule 1 (Specification), paragraph 4; APSCo Compliance+ Education Standards v15 (October 2026).

4. Key contacts and DSL arrangements

DSL cover

In line with KCSIE 2026, Luma has robust cover arrangements for when the DSL is unavailable through illness, leave or other reasons. The Deputy DSL holds full DSL authority in the DSL's absence. Concerns can always be sent to the confidential safeguarding inbox, which is checked at least every working day so that concerns are received, monitored and acted on without delay. If neither the DSL nor the Deputy is available, this must never delay action: staff should take advice from the LADO, children's social care or the police, and update the DSL as soon as possible.

5. Roles and responsibilities

Directors

• Make sure this policy, the Code of Conduct and the vetting procedures are in place, resourced, followed and reviewed every year.
• Appoint a senior DSL and Deputy DSL, give them the time, training and authority to carry out the role, and receive regular safeguarding reports.
• Make sure all staff who recruit are trained in safer recruitment.

Designated Safeguarding Lead (and Deputy)

• Take lead responsibility for safeguarding and child protection at Luma, and act as the point of contact for schools, LADOs, police and children's social care.
• Receive, record and act on all concerns about children reported by workers, and all concerns and allegations about Luma workers.
• Decide (with schools and the LADO) whether to suspend bookings for a worker during an investigation, and lead any Luma disciplinary or "cease to supply" decision.
• Make referrals to the DBS and the Teaching Regulation Agency when the criteria are met, and keep the safeguarding referral log.
• Keep up to date with KCSIE and local arrangements, complete formal DSL training every two years and update knowledge at least annually.
• Make sure all workers receive this policy, the Code of Conduct and KCSIE Part one at registration, and are told about updates.
• Audit compliance files and safeguarding records regularly and report findings to the Directors.

Consultants and internal staff

• Follow Luma's vetting procedures in full. No worker may start any assignment until every required check is complete and recorded (100% clearance). If a worker is not cleared in time, the start date is moved back.
• Send the school written confirmation of checks (the vetting form) before the worker starts.
• Pass any safeguarding concern, complaint or allegation about a worker, or any concern about a child, to the DSL immediately and on the same day. Never investigate yourself or tell the worker about an allegation before the DSL has agreed how this will be handled.
• Complete safeguarding and safer recruitment training.

Temporary workers

• Read KCSIE 2026 Part one in full, this policy and the Code of Conduct, and complete the required training before the first assignment.
• Follow the safeguarding and child protection procedures of each school, and attend its safeguarding induction. Find out who the school's DSL is on the first day.
• Report concerns about a child to the school's DSL immediately, and inform Luma's DSL the same day.
• Tell Luma immediately of any arrest, caution, charge, conviction, investigation or other change that could affect suitability to work with children.

Schools (our clients)

Our terms of business ask schools to give our workers a safeguarding induction, tell us promptly about any concern or allegation involving a Luma worker, involve us in LADO and allegations management meetings, and not to stop using a Luma worker because of a safeguarding concern without establishing the facts and liaising with the LADO (KCSIE 2026, Part four).

6. Recognising abuse and safeguarding issues

All Luma staff and workers must know the signs of abuse and neglect and the specific safeguarding issues described in KCSIE 2026. Abuse can happen in the family, in an institution or in the community, wholly online, or with technology used to facilitate offline abuse. Children can be abused by adults or by other children. Safeguarding issues often overlap.

Specific safeguarding issues workers must be alert to

• Child-on-child abuse (including harassment and violence): bullying, physical abuse, sexual violence and sexual harassment, upskirting, initiation or hazing, and abuse in intimate relationships. It is a safeguarding issue for both the victim and the child who has caused harm, it is preventable, and it must never be passed off as "banter" or "part of growing up". Harmful sexual behaviour sits on a continuum that can progress to sexual violence.
• Making or sharing nudes or semi-nudes, including images digitally altered or wholly generated by AI ("deepfakes"). Every incident requires a safeguarding response, whether consensual or not.
• Child criminal exploitation (CCE) and child sexual exploitation (CSE), including county lines, financial exploitation and organised networks or gangs. Victims may identify with the group, may be criminalised for actions taken under coercion, and exploitation may amount to modern slavery.
• Serious violence, including knife crime and gang involvement; signs include unexplained injuries, gifts or money, changes in friendships and absence from education.
• Domestic abuse, including the impact on children who see, hear or experience it, abuse in teenage relationships, stalking, and child to parent or care giver abuse.
• Mental health: staff are not expected to diagnose, but should report concerns about a child's mental health that are also safeguarding concerns.
• Radicalisation and extremism (see section 16), and the influence of online misogyny and other harmful content, including violence against women and girls.
• Honour-based abuse, including female genital mutilation (FGM) and forced marriage.
• Children absent from education, particularly repeatedly or for long periods, which can be a sign of abuse, exploitation or neglect.
• Children at greater risk, including children with SEND or medical conditions, young carers, looked-after and previously looked-after children, children with a social worker, children who are LGB or gender questioning, and children in temporary accommodation.

7. Safer recruitment and vetting

KCSIE 2026 (paragraph 364) requires schools to obtain written notification from an agency that it has carried out the same checks the school would otherwise perform. Luma therefore completes every pre-appointment check a school must do for a direct appointment, before any worker is placed. Full details, evidence standards and scoring are set out in the Luma Vetting Requirements checklist. In summary:

Framework and APSCo standards

• GCA RM6376 and Value Match placements also require: a face-to-face or video registration interview; references covering the last two years including the most recent school-based employer; a DBS checked within the last 12 months with the certificate produced; a signed Rehabilitation of Offenders Act declaration; the worker told to report any investigation or prosecution; and documents held to the framework's document standard. Compliance is reconfirmed at least once a year during an assignment. Where KCSIE sets a higher standard, KCSIE applies.
• APSCo Compliance+ is Luma's overarching standard: every document is validated, signed and dated; DBS Update Service checks are made about every 12 weeks; and a worker with a gap of 12 weeks or more since their last placement is re-checked before being placed again.

Regulated activity and early years

Following the Crime and Policing Act 2026, there is no longer a "supervision exemption" from regulated activity. All Luma workers who teach, train, instruct, care for or supervise children are treated as being in regulated activity and must have an enhanced DBS with children's barred list check. No worker may start in a setting covered by the EYFS framework until Luma has received the enhanced DBS certificate including barred list information.

Ongoing suitability

• Workers must tell Luma immediately about any arrest, caution, charge, conviction, police or regulatory investigation, or anything else that may affect their suitability. Luma will tell the school immediately if it learns anything that suggests a worker may be unsuitable.
• Registration details, DBS status, right to work and training are reviewed at least every 12 months and after any break of 12 weeks or more.

8. Information provided to schools

• Before each worker starts, Luma sends the school written confirmation (the vetting form) that all required checks have been carried out, with the dates and DBS details, so the school can complete its single central record.
• Where the enhanced DBS certificate disclosed any information, Luma provides a copy to the school before the worker starts, with the worker's knowledge.
• Luma tells schools that they should check, on arrival, that the person presenting for work is the person on whom the checks were made.
• Luma gives schools a copy of, or a link to, this policy and its allegations procedure.

9. Induction, training and support

Luma will send workers short safeguarding updates when guidance changes (for example, each new version of KCSIE), and will support any worker affected by a safeguarding incident.

10. Responding to concerns about a child

Workers should act on any concern about a child immediately and should not assume someone else will. The steps are:

1. Child in immediate danger: call 999, then tell the school's DSL and Luma's DSL.
2. Report to the school's DSL (or a deputy) immediately and follow the school's child protection procedures. The school DSL decides on next steps, which may include support within school, a Family Help assessment (targeted early help) or a referral to children's social care or the police.
3. If the school DSL is not available, the concern must not wait: speak to a member of the school's senior leadership team and/or contact local children's social care directly.
4. Inform Luma's DSL the same day, using the confidential safeguarding inbox or phone. Luma records that a concern was raised and checks it has been passed on; Luma does not investigate concerns about children itself.
5. Record it in writing as soon as possible and within 24 hours (see Appendix B).
6. Escalate if needed: if a worker believes the concern has not been acted on and the child remains at risk, they should speak to Luma's DSL, who will take it up with the school and, if necessary, refer directly to children's social care.

Specific legal duties

• FGM: a teacher who discovers that an act of FGM appears to have been carried out on a girl under 18 must personally report it to the police (101), as well as informing the DSL.
• Nudes and semi-nudes: workers must not view, copy, print, forward or delete images. Report to the school DSL, who will follow the UKCIS guidance.
• Concerns raised outside the school day (for example, a disclosure to a worker who also tutors privately for Luma) are reported directly to Luma's DSL, who will contact children's social care or the police as appropriate.

11. Concerns and allegations about Luma workers

This section applies when it is alleged that a Luma worker or member of staff has:

• behaved in a way that has harmed a child, or may have harmed a child; and/or
• possibly committed a criminal offence against or related to a child; and/or
• behaved towards a child or children in a way that indicates they may pose a risk of harm to children; and/or
• behaved, or may have behaved, in a way that indicates they may not be suitable to work with children (including behaviour outside work, or "transferable risk").

How responsibilities are shared

Under KCSIE 2026 Part four, the school and Luma share safeguarding responsibilities. The school usually takes the lead in gathering the facts and managing the safeguarding process, because Luma does not have direct access to children or school staff. Luma will usually lead on any disciplinary action. Luma will co-operate fully with the LADO, police and children's social care, and will share any previous concerns or allegations it holds about the worker so they can be considered.

Procedure

1. Receive: any Luma staff member who receives an allegation (from a school, parent, child, colleague or the worker) passes it to the DSL immediately and on the same day. They record what they were told, word for word where possible, and do not investigate or contact the worker.
2. Record: the DSL opens a confidential allegation record, logged in the safeguarding referral log.
3. Inform and liaise: the DSL confirms that the school's headteacher (or the chair of governors/proprietor if the allegation concerns the headteacher) knows, and that the LADO has been, or will be, informed (within one working day). If the school is not acting, or the allegation was made directly to Luma, the DSL contacts the LADO directly. If a child is at immediate risk or a crime may have been committed, the police are informed.
4. Strategy and meetings: Luma attends allegations management or strategy meetings when invited, and asks to be invited where it is not. Luma will not tell the worker about the allegation until the LADO (and police, if involved) agree what can be shared.
5. Protective action: suspension is not automatic. The DSL, with the school and the LADO, considers whether to suspend all Luma bookings for the worker, redeploy them, or put a risk assessment in place, especially where the worker is placed across several schools. Bookings at other schools are reviewed and those schools informed where the LADO advises.
6. Support: the worker is told who their point of contact at Luma is, kept informed of progress as far as possible, and advised they may contact a trade union representative or colleague for support. The child and family are supported by the school.
7. Investigation and outcome: Luma considers the outcome of any police, social care or school investigation and, where needed, carries out its own fair investigation. Outcomes are recorded as substantiated, malicious, false, unsubstantiated or unfounded. Cases should be reviewed regularly, ideally every two weeks and no longer than monthly.
8. Action: following a substantiated allegation, Luma will normally stop supplying the worker and make referrals as set out in section 13. Where an allegation is found to be malicious or false, the LADO and school are told and appropriate action considered against the person who made it.
9. Learning: at the end of every case, the DSL considers with the school whether there are lessons for Luma's vetting, induction or procedures.

If a worker resigns, stops working with Luma or refuses to co-operate, the process continues to a conclusion wherever possible. "Settlement" or compromise agreements will never be used to avoid a referral or to prevent information being shared.

12. Low-level concerns

A low-level concern is any concern, no matter how small and even if no more than a sense of unease or a "nagging doubt", that a worker may have acted in a way that is inconsistent with the Luma Code of Conduct (including inappropriate conduct outside work) but does not meet the harm threshold above. Examples include being over-friendly with children, having favourites, taking photographs of children on a mobile phone contrary to school policy, being alone with a child in a secluded area or behind a closed door, or humiliating children.

• Schools are asked to share low-level concerns about Luma workers with Luma's DSL; consultants pass on any they hear about. Workers are encouraged to self-report situations that could be misinterpreted.
• The DSL records each low-level concern confidentially (details, context, action taken, name of the person raising it unless they ask for anonymity) and reviews records so that patterns can be identified.
• The DSL decides on the response, which may include a supportive conversation, further training, or more supervision. If a concern, or a pattern of concerns, meets the harm threshold, it is dealt with under section 11.
• Low-level concerns are not included in references unless they relate to issues that would normally be included (for example, misconduct or poor performance). Records are kept at least until the worker leaves Luma.

13. Duty to refer: DBS and Teaching Regulation Agency

This is a legal duty. As a personnel supplier, Luma must refer a person to the DBS where it removes them from regulated activity (or would have done had they not left or resigned) and believes they have engaged in relevant conduct, satisfied the harm test, or received a caution or conviction for a relevant offence. Failing to refer when the criteria are met is a criminal offence.

• "Removal" includes suspension of all bookings, redeployment to work that is not regulated activity, ceasing to supply the worker, or the worker leaving or resigning before Luma could act.
• The DSL makes the referral as soon as possible using the DBS referral form and guidance, with as much relevant information as possible (investigation findings, statements, outcome). The duty applies equally to paid workers and volunteers.
• Where Luma ceases to use a teacher because of serious misconduct (or might have done so had they not left first), the DSL must consider a referral to the Secretary of State via the Teaching Regulation Agency.
• Luma also informs any framework customer (for example under GCA RM6376) immediately if it becomes aware of anything suggesting a worker is unsuitable.

Audit trail

Every safeguarding concern, allegation and referral is recorded in the Luma Safeguarding Referral Log (Appendix C), including: date received; who raised it; summary; school and LADO involved; decisions and reasons; protective action; outcome; whether DBS/TRA referral criteria were met; date and reference of any referral; and the date the case closed. Every decision not to refer is also recorded with the reasons. The log is reviewed by the DSL monthly and by the Directors at least every quarter.

14. Concerns raised by workers and whistleblowing

Luma wants workers and staff to feel able to raise concerns about poor or unsafe practice, including at a school or at Luma, and to know they will be taken seriously.

• Concerns about safeguarding practice at a school should be raised with the school's senior leadership team and with Luma's DSL, who will follow them up with the school and, where necessary, the local authority.
• Allegations by workers about client staff are handled under the school's allegations procedure, with Luma's support; Luma will make sure the worker is told the outcome as far as it can be shared.
• Concerns about Luma itself should be raised with the DSL or another Director.
• Anyone who does not feel able to raise a concern internally, or feels it is not being addressed, can contact the NSPCC Whistleblowing Advice Line on 0800 028 0285 (help@nspcc.org.uk).
• No one will suffer any detriment for raising a genuine concern in good faith.

See also our Whistleblowing Policy.

15. Online safety, generative AI and mobile devices

KCSIE 2026 groups online risks into four areas: content (illegal, inappropriate or harmful material, such as pornography, racism, misogyny, self-harm, extremism and misinformation); contact (harmful interaction with other users, or with generative AI applications that simulate this, including grooming); conduct (online behaviour that causes harm, such as making or sending explicit images, including AI-generated images, and online bullying); and commerce (gambling, inappropriate advertising, phishing and scams).

• Workers must follow each school's online safety, acceptable use and filtering and monitoring arrangements, and report any filtering failure or harmful content seen to the school's DSL.
• Schools are expected to be mobile phone-free by default. Workers must follow the school's mobile phone policy and must never use personal devices to photograph or record children.
• Workers may only use generative AI tools approved by the school, in the way the school has approved, and must never enter children's personal data into them.
• Luma staff must never contact children through personal accounts and must keep all communication with workers and schools on Luma systems.

16. Prevent duty

Schools have a duty to have due regard to the need to prevent people from being drawn into terrorism. Luma supports this by requiring all workers to complete Prevent awareness training before their first assignment. Any worker with a concern that a child may be at risk of radicalisation must report it to the school's DSL, who may make a referral to Channel, and inform Luma's DSL. If there is an immediate risk, call 999. Luma staff can also use the DfE counter-extremism helpline for advice.

17. Early years settings

• Workers placed in nurseries, Reception classes or wraparound care must follow the EYFS statutory framework (section 3) and the setting's safeguarding, supervision, ratio, mobile phone and camera policies.
• No worker can start in an EYFS setting until Luma has received their enhanced DBS certificate including barred list information.
• Workers in these settings must complete a childcare disqualification declaration and must tell Luma immediately of any change that could lead to disqualification.
• Paediatric first aid certificates are provided where the setting requires them.

18. Information sharing, records and data protection

• The data protection laws (Data Protection Act 2018, UK GDPR and the Data (Use and Access) Act 2025) do not prevent the sharing of information for the purposes of keeping children safe. Fears about sharing information must not stand in the way of protecting a child.
• Information is shared on a need-to-know basis, recording what was shared, with whom, when and why. Safeguarding records are kept separately from general candidate files, with restricted access.
• DBS certificate information is handled in line with the DBS Code of Practice and Luma's Recruitment of Ex-Offenders and DBS Policy, used only for the purpose for which it was obtained, and stored securely.
• Records of allegations are kept at least until the worker reaches normal pension age or for 10 years from the date of the allegation, whichever is longer. Records of allegations found to be malicious or false are removed from personnel files unless the worker consents to their retention. Low-level concern records are kept at least until the worker leaves Luma.
• Workers are told how their data is used in Luma's Privacy Notice for Temporary Workers, and records are kept in line with our Data Retention Schedule.

19. Monitoring, audit and review

• The DSL audits a sample of worker compliance files each month against the Luma Vetting Requirements, and reports to the Directors.
• The safeguarding referral log and low-level concerns records are reviewed monthly by the DSL and quarterly by the Directors.
• This policy is reviewed at least every year (next review September 2027), and sooner if legislation or statutory guidance changes, after a serious incident, or following an audit. Changes are version-controlled and communicated to all staff and workers.
• The policy is available to workers at registration and to schools and other clients on request or on the Luma website.

Appendix A: Quick reference for workers

Appendix B: Record of concern (what to include)

Appendix C: Safeguarding referral log (fields)