Whistleblowing Policy

Safeguarding concerns come first. Any concern about the safety or welfare of a child must be reported immediately under our Safeguarding and Child Protection Policy. If a child is in immediate danger, call 999.

1. Introduction

Luma Education Recruitment is committed to maintaining the highest standards of honesty, integrity and accountability. This policy sets out how anyone working with or for Luma can raise concerns about safeguarding, misconduct, malpractice or unethical behaviour, particularly where it may affect the welfare and safety of children, young people or vulnerable adults in education settings. It forms part of our staff handbook and is shared with every Worker at registration.

2. Purpose

• Encourage and enable staff, Workers, contractors, partners and stakeholders to report concerns without fear of victimisation.

• Ensure concerns are handled promptly, sensitively and appropriately.

• Protect the welfare of children and vulnerable individuals in line with safeguarding legislation and Keeping Children Safe in Education (KCSIE).

• Promote an open, transparent and accountable culture.

3. Scope

This policy applies to all employees, directors, agency Workers placed by Luma, volunteers, consultants and third-party partners. It covers concerns about safeguarding, misconduct, harm to pupils or service users, financial malpractice, negligence, unethical conduct, breaches of law or policy, and any activity that may place children, young people or vulnerable adults at risk. It does not replace our Complaints Policy (for complaints about our service) or our grievance procedure (for personal employment issues).

4. Safeguarding commitment

We recognise our duty under KCSIE and other statutory guidance to protect children from harm. Whistleblowing is an essential part of safeguarding, and any concern about the safety or welfare of a child must be reported immediately. A concern about the conduct of a Worker in a school is also passed to the school's own Designated Safeguarding Lead and, where the threshold is met, to the Local Authority Designated Officer (LADO).

5. What to report

Concerns may include, but are not limited to:

• any safeguarding or child protection concern;

• suspected abuse, neglect or inappropriate behaviour by staff, Workers or partners;

• unsafe recruitment, missing or falsified pre-employment checks, or failure to follow compliance procedures;

• criminal activity, fraud, bribery or financial malpractice;

• breaches of data protection, health and safety or other legal duties;

• unprofessional conduct or serious breach of policy;

• any attempt to cover up any of the above.

6. How to raise a concern

Raise a concern as soon as possible, verbally or in writing, with:

• Daniel Benson, Director and Designated Safeguarding Lead – daniel.benson@lumaedrec.com – 0204 576 4344; or

• Tom Jackson, Director and Deputy DSL – tom.jackson@lumaedrec.com – 0204 576 4102, if the concern involves the DSL or the DSL is unavailable.

Workers placed in a school should also follow the school's own whistleblowing and safeguarding procedures. Where Luma supplies under the HEART Academies / Value Match Framework, Workers may also use the confidential whistleblowing channel provided by Value Match. Anonymous reports will be considered, although we may need more information to investigate fully.

7. Confidentiality and protection

Concerns are treated confidentially wherever possible. Anyone who raises a concern in good faith and in the reasonable belief that it is in the public interest will not suffer detriment, victimisation or disciplinary action as a result. Deliberately false or malicious allegations may lead to disciplinary action.

8. How we respond

• Concerns are logged and acknowledged in writing within two working days. Safeguarding concerns are acted on the same day.

• A director not involved in the matter carries out an initial review within five working days.

• Where needed, a formal investigation takes place and external agencies are involved.

• The person raising the concern is told the outcome as far as confidentiality and the law allow.

• All concerns, actions and outcomes are recorded and kept securely in line with our Data Retention Schedule.

9. External reporting

If you feel unable to raise a concern internally, or are not satisfied with our response, you can contact:

• the Local Authority Designated Officer (LADO) for the area where the school is located;

• the police (999 in an emergency) or local children's social care;

• the NSPCC Whistleblowing Advice Line – 0800 028 0285 – help@nspcc.org.uk;

• the Department for Education, Ofsted or another relevant prescribed person (see gov.uk/whistleblowing).

Nothing in this policy prevents anyone from making a protected disclosure under the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act 1998.

10. Training and awareness

Directors and staff are briefed on this policy at induction and annually. Every Worker is told how to raise a concern when they register and before their first placement.

11. Review

This policy is reviewed annually by the policy owner, or sooner after significant changes to legislation, statutory guidance or our operations.

Version history

Approved and signed electronically on behalf of Luma Education Recruitment Ltd by Daniel Benson, Director and policy owner, on 6 November 2026.