Last reviewed and updated on: 21st December 2023

Our Commitment

OpenClassrooms’ mission is to make education accessible. We have a vibrant and diverse online community of learners, apprentices, staff and visitors, and we are fully committed to providing a safe and supportive learning environment for all.

OpenClassrooms recognizes the importance of safeguarding commitments to safety and welfare and further committed to safeguarding all without discrimination of an individual's age, disability, race, religion or belief, sex, gender reassignment, pregnancy or maternity leave status, marriage or civil partnership status, or sexual orientation. 

Consequently, OpenClassrooms has implemented this safeguarding policy in order to meet its obligations as an organisation working with Learners.

This policy sets out the processes and mechanisms we have put in place to ensure the safeguarding of young people and vulnerable adults.

This policy sets out the processes and mechanisms we have put in place to ensure the safeguarding of Learners, including Learners who have Special Educational Needs and Disability (SEND). 

The purpose of this policy is to:

• Give clear guidelines about procedures in regard to identifying and reporting issues, concerns, and incidents relating to safeguarding;
• Ensure any safeguarding issue is handled in a timely manner, as well as being handled sensitively, professionally, and in a way that protects Learners;
• Ensure People involved in training and Learners are aware of our safeguarding policies and procedures;
• Commit to the development of good practice regarding all aspects of safeguarding at OpenClassrooms.

In case of a breach, OpenClassrooms has the right to impose any action to ensure that the Safeguarding policy is adhered to.

Definition

Learners

Those who follow any training with OpenClassrooms in the UK.

People involved in training

The category of people listed below:

• Any employee of OpenClassrooms who is involved in the education provisions in the UK.
• External service providers, contractors (i.e. mentors). 
• Consultants, volunteers, contractors, and programme visitors.

Safeguarding

Is the overarching term used to describe the Protection of the health, wellbeing and human rights of individuals. Many areas are considered to fall under the definition of safeguarding, including:

• Physical Abuse: Domestic abuse (often referred to as domestic violence) refers to any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence, or abuse between those aged 16 or over who are, or have been, intimate partners or family members, regardless of gender or sexuality. It can occur in intimate relationships between older children.

• Emotional Abuse: The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them, or ‘making fun’ of what they say or how they communicate. It may also feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may also involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

• Bullying (including online): Ongoing and deliberate misuse of power in relationships through repeated verbal, physical and/or social behaviour that intends to cause physical, social and/or psychological harm. It can involve an individual or a group misusing their power, or perceived power, over one or more persons who feel unable to stop it from happening. Bullying can happen in person or online, via various digital platforms and devices and it can be obvious (overt) or hidden (covert). Bullying behaviour is repeated, or has the potential to be repeated, over time (for example, through sharing of digital records).

• Discrimination: Treating someone less favourably than someone else because of a protected characteristic (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexuality).

• Forced Marriage: Forced Marriage is a human rights abuse and falls within the Crown Prosecution Service definition of domestic abuse. It is also a criminal offence to force a person to marry in England and Wales.

• Financial Abuse: Financial abuse can be concerning money, property or belongings. Financial abuse might look like:
• Borrowing money and not giving it back
• Stealing money or belongings
• Taking pension payments or other benefit away from someone
• Taking money as payment for coming to visit or spending time together
• Forcing someone to sell their home or assets without consent
• Tricking someone into bad investments
• Forcing someone to make changes in wills, property or inheritance.

• Neglect and Self-Harm: The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy - for example, as a result of maternal substance abuse.

• Sexual Harassement and Abuse: Forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening.

• Radicalisation and Extremism: Radicalisation as the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. Extremism is defined as vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

Compliance with Legislation 

This policy covers the legislative requirements and recommendations pertaining to the protection of Learners in the UK, in accordance with statutory guidance on safeguarding and promoting the welfare of Learners in education.

Therefore this policy has been created in line with:

• Working together to safeguard children 2018
• The Children Act 1989 & 2004 
• Safeguarding Vulnerable Groups Act 2006
• Protection of Freedoms Act 2012
• Equality Act 2010

1. Safeguarding Team

The Senior Director of International Customer Success is the Designated Safeguarding Lead in the UK and as such, is the lead contact for safeguarding matters. They are supported in their safeguarding duties by the Student Success team who are the first point of contact for all learner welfare and safeguarding matters.

Additionally, the International team is responsible for ensuring awareness of this policy and is promoted to all employees, mentors and any other contractors who regularly come into contact with Learners are made aware of their specific safeguarding duties and responsibilities as part of their onboarding (and included within their contracts) and notably through our internal platforms.

1.Contact Details

1.2 The Designated Safeguarding Lead

The Senior Director of International Customer Success is the Designated Safeguarding Lead in the UK and as such, is the lead contact for safeguarding matters and Learner protection (including online safety and understanding the filtering and monitoring systems and processes in place). The responsibilities of the role are included in the role holder’s job description.

1.2.1 Roles and responsibilities

The Safeguarding Lead will:

• Act as the first point of contact with regard to all Learning welfare and safeguarding matters,
• Provide support and training for all employees, external contractors, and third parties who will interact with Learners and log any attendance,
• Cooperate with mentors undertaking services,
• Support employees to make effective referrals to the appropriate Local Authority (Local Authority Designated Officer, LADO), emergency services, and any other agencies where there are concerns about the welfare of a child, Learner, or vulnerable adult,
• Liaise with mentors, managers, or Local Authority if needed,
• Keep copies of all referrals made to a Local Authority, emergency service or any other other agencies related to safeguarding, 
• Ensure that all employees and external contractors receive information on safeguarding policies and procedures from the start date of their contract,
• Manage and keep secure the OpenClassrooms’ safeguarding records,
• Ensure that all employees and external contractors understand and are aware of OpenClassrooms’ reporting and recording procedures and are clear about what to do if they have a concern about an individual,
• Ensure that the Safeguarding Policy is regularly reviewed and updated to abide with any legislative change,
• Keep up to date with changes in local policy and procedures and are aware of any guidance issued by the Department for Education concerning Safeguarding,
• Undertake all relevant training and Continuing Professional Development (CPD) to ensure that their knowledge and understanding is current and relevant on best practices and changes in policy and at least annually.

Finally, our practices in implementing this policy are reviewed regularly by the Designated Safeguarding Lead working collaboratively with the teams responsible for their implementation, updated for continuous improvement and communicated through staff briefings.

1.2.2 Emergencies or serious concerns

If someone considers there is an immediate risk of harm, if someone has concerns or other emergencies, he/she should call 999 or 111 and speak to the emergency services or refer to other relevant external agencies. Please inform the Student Success Team of your action as soon as possible.

Some external agencies to contact who can provide support:

• Samaritans: 116123 – for support with many forms of emotional distress (For non-emergencies: jo@samaritans.org).
• Papyrus: 0900 068 4141 or text 07860 039967 - Suicide Prevention advice.
• Mind: 020 8519 2122 - info@mind.org.uk - Advice and support around metal health or text 'shout' to 85258 a free, confidential, anonymous text support service. 
• NSPCC Helpline: 0808 800 5000 – help@nspcc.org.uk advice for anyone who has concerns about the welfare of a child or young person. 
• Anti-terrorist hotline: 0800 789 321 – for concerns about possible terrorist activity Report online material promoting terrorism or extremism.
• Report illegal or harmful information, pictures or videos you’ve found on the internet. You can make your report anonymously. https://www.gov.uk/report-terrorism

If you do contact any of the above external agencies, please inform the Student Success Team of your actions as soon as possible.

2. Safeguarding processes

2.1 Identifying a safeguarding risk

All People involved in training have a responsibility to be alert to spot safeguarding concerns and to know how to respond if they become aware of a risk during the course of their normal duties. Examples of the ways in which risk may be identified include: routine monitoring of Learner activity, such as frequency and level of engagement; monitoring and moderation of online Learner communications and interactions; and the Learner proactively choosing to make a disclosure.

2.2 Responding to a safeguarding risk

The Student Success team is responsible for the pastoral support of Learners and is the first point of contact for Learners to raise concerns. However, it is recognised that Learners may choose to discuss concerns with other members of OpenClassrooms or external service providers such as a mentor.

If a Learner makes a disclosure that suggests he/she may be at risk or when following up on a risk that has been brought to the Success team’s attention, OpenClassrooms has implemented guidelines to listen to these Learners, such as:

• Always listen carefully and quietly. Take note of the available facts.
• Remain calm and reassuring.
• Tell them what they are going to do about the concern (e.g. referring them to the Safeguarding Team) and note any views that they may have regarding how they wish the matter to be dealt with.
• Do not refute the allegation. 
• Show that you care through open and reassuring facial expressions and body language.
• Ensure you take a written verbatim account of the Learner’s disclosure.
• Record the reasons for reaching each decision.
• Attend all the necessary training about safeguarding.

OpenClassrooms will also work with external agencies if needed depending on the risk and issue flagged.

Information disclosed and stored will be processed in accordance with OpenClassrooms’ obligations under the data protection laws and in accordance with our Privacy Policy.

2.3 Recording safeguarding risks

A written record (including recording dates, times, people responsible, and actions) of all safeguarding concerns received must be made. These will be received and centrally logged by the Safeguarding Team, who will ensure they are stored securely against the Learner record and shared only on a need-know basis, e.g., with the Designated Safeguarding Lead, in line with data legislation and regulations.

If a mentor or any other employee has a Learner protection concern, they should inform the Designated Safeguarding Lead as soon as possible. These will be kept on the Children’s protection file.

Records will be reviewed regularly to identify any patterns or systematic issues within the school. 

All safeguarding risks must be logged with and investigated by the Safeguarding Team. In the event of material risk, the latter must inform the OpenClassrooms Legal Department. Where appropriate, the Safeguarding Team may refer the matter to the relevant Local Authority or external agencies e.g., emergency services, a medical professional, or the police.

Please refer to the Prevent Duty Policy in relation to any concerns identifying risk of radicalisation and extremism below. These will be dealt with in accordance with our Prevent Duty Policy.

2.4 Additional support and guidance

Where the Safeguarding Team identifies that additional support and guidance is needed either directly for the Learner or by an employee supporting a Learner, the individual will be directed to appropriate external specialist agencies. 

The Designated Safeguarding Lead will maintain a register of external specialist agencies partners.

2.5 Monitoring of IT usage

• Home Office: Report online material promoting terrorism or extremism, illegal or harmful information, or pictures and videos you’ve found on the internet. You can make your report anonymously: https://www.gov.uk/report-terrorism
• Fake News: 4 quick checks and tips on how to identify fake news saferinternet.org.uk/blog/fake-news-4-quick-checks
• UK Safer Internet Centre: Where you can find online safety tips, advice and resources to help children and young people stay safe online: saferinternet.org.uk/

CEOP (Child Exploitation and Online Protection command`: Are you worried about online sexual abuse or the way someone has been communicating with you or others online?

2.6 Additional Safeguards for Learners aged 16-17 years old

Details of what constitutes acceptable usage of OpenClassrooms online platforms, along with details of the disciplinary action taken against anyone who violates the terms of acceptable usage, are set out in our Terms of Use and Student Policy documents.

The online forums used by employees and students to interact with each other are routinely and proactively monitored by the Student Success team who will flag any safeguarding risk in accordance with this policy.

We reserve the right to monitor, intercept and review, without further notice, activities using our IT resources and communications systems, including but not limited to social media postings and activities, for legitimate business purposes which include ascertaining and demonstrating that expected standards are being met by those using the systems and for the detection and investigation of unauthorised use of the systems (including where this is necessary to prevent or detect crime).

2.7 Additional safeguards for students aged 16-17 years old

OpenClassrooms specialises in the provision of higher level education; therefore the vast majority of our Learners are aged 18 or over. In the event that we receive an application from a Learner who is aged 16-17, the following additional safeguarding arrangements will apply:

• Details of the Learner’s parent or legal guardian will be collected during the admissions process and stored appropriately. In the context of an apprenticeship programme, the apprentice’s parent or legal guardian will be a co-signatory of the relevant Commitment Statement
• The Designated Safeguarding Lead will make contact with the parent/legal guardian regarding any specific Safeguarding arrangements that may be required. These will be logged with the Safeguarding Team who will link them confidentially to the Learner record.
• Routine check-ins by the Student Success Team with the Learner will be extended to include safeguarding matters. Any concerns identified will be managed in accordance with this policy.

2.8  Learners with SEND

Learners with special educational needs and disabilities (SEND) or health issues can face additional safeguarding challenges, both online and offline. 

Additional barriers can exist when recognising abuse and neglect in this group of Learners with SEND. These can include:

• Assumptions that indicators of possible abuse such as behaviour, mood, and injury relate to the Learner’s condition without further exploration. 
• The fact that these learners are more prone to peer group isolation or bullying (including prejudice based bullying) than other children. 
• The fact that these Learners are at increased risk of abuse and exploitation whether from peers, those who seek to harm children, or criminal gangs. 
• The potential for Learners with SEND or certain medical conditions to be disproportionately impacted by behaviours such as bullying, without outwardly showing any signs. 
• Communication barriers and difficulties in managing or reporting these challenges. 

OpenClassrooms, therefore, looks to address this issue by raising awareness amongst employees, offering tailored pastoral support, and ensuring communication with Learners in these groups is effective. 

It may also involve close liaison with the Designated Safeguarding Lead for reports of abuse involving Learners with SEND and referral to Child and Adolescent Mental Health Services (CAMHS) or supporting any such referral.

2.9 Learners absent from OpenClassrooms' training

All Learners, regardless of their circumstances or background, are entitled to education that is suitable to their age, ability, aptitude, and any special educational needs and disabilities.

OpenClassrooms operates a strong attendance tracking system. The tracking and use of effective attendance management strategies enables the school to ensure each day that every Learner is accounted for.

The school takes a range of actions to tackle Persistent Absentees and completes official reports on Learners who are persistently absent from their training.

OpenClassrooms will only authorise leave of absence in exceptional circumstances. The Student Success team will determine the length of time that the Learners can suspend their training.

OpenClassrooms recognises that some Learners seeking leave of absence are vulnerable to risk of abuse, neglect, exploitation or travelling to conflict zones, or at risk of FGM or Forced Marriage.

Mentors and OpenClassrooms’ employees are trained to look for these triggers and OpenClassrooms intervenes to identify any risk factors that may prevent attendance compliance. 

When a risk factor is identified, OpenClassrooms’ employees should alert the Designated Safeguarding Lead. 

AOpenClassrooms monitors:

• Learner’s attendance based on mentor sessions and GLH session attendance. 
• weekly attendance trends.

No Learner will be removed from the OpenClassrooms register until all safeguarding checks have been completed.

3. Recruitment of Employees

Openclassrooms will conduct appropriate recruitment processes when recruiting new employees.

OpenClassrooms will seek to ensure that their employees are appropriate to work in a training provider setting with Learners by complying with its legal obligations, including Enhanced DBS checks with barring. Where Openclassrooms provides training in other countries, other relevant checks are required or undertaken.

OpenClassrooms will ensure new employees take part in, understand the content of, all necessary safeguarding training before having any contact with Learners.

4. Related OpenClassrooms Policies

4.1 General policies

This policy is supported by the following other policies and procedures:

• Privacy Policy
• Learners Policy
• Code of Conduct
• Disciplinary Process
• Complaints Policy
• Terms of Use Policy

4.2 Whistleblowing policy

Prevent Duty Policy

OpenClassrooms is fully committed to providing a safe and supportive learning environment to our vibrant and diverse online community of Learners, People involved in training, and visitors alike. 

We have a range of mechanisms in place to ensure and promote the safeguarding and welfare of our Learners. These include safeguarding against radicalisation and extremism.  

This Prevent Duty policy should be read in conjunction with the above Safeguarding Policy.

1. Signs of Radicalisation

There is no single way of identifying whether a vulnerable person is likely to be susceptible to an extremist ideology. Background factors combined with specific influences such as family and friends may contribute to a Learner’s vulnerability. Similarly, radicalisation can occur through many different methods (such as social media) and settings (such as the internet).

Social media and other online interactions may be used by some people to promote terrorism and Extremism.

2. Risk Assessment

The Designated Safeguarding Lead will be responsible for ensuring that appropriate risk assessment is conducted and regularly reviewed to identify potential areas that present a risk of vulnerable Learners being drawn into terrorism or other forms of extremism. A Prevent Action plan will be maintained, as appropriate.

3. Leadership and Governance

OpenClassrooms are fully committed to providing a safe and supportive learning environment to our vibrant and diverse online community of Learners, People involved in training, and visitors alike.

OpenClassrooms has a range of mechanisms in place to ensure and promote the safeguarding and welfare of our Learners. These include our Prevent Duty, which includes Radicalisation and Extremism.

4. Employee awareness and training

As with other safeguarding issues, OpenClassrooms’ employees should use their professional judgement in identifying individuals who may be at risk. They should be alert to any content they encounter on the OC platforms used for the delivery of learning that they feel is offensive or illegal. Any such content should be reported immediately to the Designated Safeguarding Lead.

The Designated Safeguarding Lead will maintain existing partnership arrangements and keep open lines of communication with Prevent Partners, including DfE Prevent Coordinators, relevant Local Authorities and the Police.

In order to be updated regularly, OpenClassrooms has set up safeguarding awareness training for employees, including coverage of Prevent Duty. The Designated Safeguarding Lead will have undertaken to Prevent awareness training and be able to provide advice and support to other employees on protecting vulnerable individuals from the risk of radicalisation.

In addition, employee training enables staff to use opportunities in learning to educate and challenge. It will also allow leaders and mentors to exemplify British values in their management, teaching, and through general behaviours.

5. IT Screening

The online systems used by People involved in training and Learners to interact with each other are routinely and proactively monitored to identify risks.

We reserve the right to monitor, intercept and review, without further notice, activities using our IT resources and communications systems, including but not limited to social media postings and activities, for legitimate business purposes, which include ascertaining and demonstrating that expected standards are being met by those using the systems and for the detection and investigation of unauthorised use of the systems (including where this is necessary to prevent or detect crime).

OpenClassrooms has the right and the power to regulate and, if necessary, to impose conditions or restrictions upon activities that take place or are planned or proposed, or due to take place on its premises or online.

Any organisers of any activity, if there is any doubt as to whether the activity may be controversial, must consult the Designated Safeguarding Lead at the very earliest opportunity so that the correct procedure may be followed.

6. Communication

OpenClassrooms has a statutory obligation to ensure that the platform does not distribute or display any content that promotes radicalisation or extremism or may place learners at risk of being drawn into terrorism. Consequently, action will be taken to delete any material, and steps will be taken to address any publication of material in breach of this Prevent Duty Policy.

7. What to do if you suspect an individual is at risk under Prevent Duty

If there is a concern regarding Radicalisation and or Extremism, this must be reported first to the Designated Safeguarding Lead as referenced in the contacts section above, then  Director UK Accreditation and Academic Partnerships and finally Student Success Team as the first point of contact- oc.cm/contact. In the event of a serious concern, the Designated Safeguarding Lead should contact the OpenClassrooms’ Legal Department.

In addition, in some circumstances, OpenClassrooms recommends that:

• contact your local authority designated officer (LADO) through your local safeguarding partnership or local authority
• submit the details on the report extremism in education.

Finally, if you consider there is a serious risk of immediate danger or harm, you should call the police at 999. An external agency that can provide support is the Anti-terrorist hotline: 0800 789 321 – for concerns about possible terrorist activity and reporting online material promoting terrorism or extremism.

8. Visitors

Visitors to any event put on by OpenClassrooms should be made aware of our safeguarding and prevent policies on arrival and given information about what to do if they are concerned about any aspect of any Learner’s welfare. Where appropriate, relevant vetting checks are undertaken for all visitors who are invited to speak to Learners. We shall endeavour to undertake due diligence to ensure that visiting speakers are appropriate. Speakers will be supervised at all times.

9. Related Policies

This policy is non-contractual and will be reviewed and amended from time to time, as may be required. This policy is also supported by the following other policies and procedures:

• Safeguarding Policy
• Student Policy
• Code of Conduct
• Disciplinary Process
• Complaints Policy
• Terms of Use Policy

 10. General

OpenClassrooms will review and amend this policy annually and, at its own discretion and where otherwise necessary, may revise it as required in response to findings of any review or testing or when there is a change in legislation and Law. 

The next date of planned reviews is 31st October 2024.