Statement of Policy

EtonX recognises its moral and statutory responsibility to safeguard and promote the personal safety and welfare of all children and young people[1] (“CYP”) who have an EtonX account or are enrolled on an EtonX course. This policy applies to all staff, including senior managers, contractors, tutors or anyone working on behalf of EtonX.  It is a regulatory requirement that all EtonX staff and contractors should have access to and read this policy.

The aim of this policy is to:

  • safeguard all CYP and other persons using whilst they are on the Course Site or in a Virtual Classroom.
  • provide all EtonX staff and tutors with the framework and principles that guide our approach to safeguarding and child protection online.

EtonX is committed to ensuring the highest possible standard of safeguarding. The personal safety and welfare of each young person and tutor using EtonX is of the greatest importance

This policy should be read in conjunction with the EtonX Terms of Service and the Safeguarding Procedures.

Statutory and Regulatory Framework

This policy has been drawn up using legal guidance and frameworks that serve to protect and safeguard children, namely:

  • Section 11 of the Children Act (2004)
  • The Protection of Freedom Act (2012)
  • Working Together to Safeguard Children (2015)
  • Keeping Children Safe in Education (2018)


EtonX is committed to ensuring that:

  • the safety and welfare of the young person is paramount;
  • we cultivate a culture of listening to all young people, taking into account their feedback in the development of the Service;
  • we create an environment where all staff feel able to raise concerns and feel supported in their safeguarding role;
  • all young people, whatever their age, culture, gender, language, race, religious belief, sexual identity, ability are able to receive the benefit of learning in a safe online environment;
  • all reasonable steps are taken to protect children from harm, discrimination, abuse;
  • procedures are developed and implemented to monitor, identify and report cases, or suspected cases, of inappropriate behavior by tutors;
  • all staff who work with young people will be recruited with regard to their suitability for that responsibility, and will a mandatory induction, receive safeguarding training and guidance to ensure they work within a professional code of conduct and behave in accordance with the EtonX Safeguarding Policy and Procedures;
  • students, parents, teachers and staff are familiar with what appropriate behaviour constitutes, and ensure they have someone at EtonX they can contact if they feel a tutor has not behaved appropriately;
  • we comply with the necessary data protection obligations set out in the Data Protection Act 1998 and consequently with new GDPR legislation; and
  • all staff are aware of and comply with the whistle-blowing Policy and Procedures.

We acknowledge the procedures set out by the London Safeguarding Children Board (LSCB) and take account of guidance issued by the Department of Education, UK, to:

  • ensure we have a designated senior person for child protection;
  • ensure every member of staff knows the name of the designated senior person responsible for child protection and their role;
  • ensure all EtonX staff, tutors and contractors are aware of the EtonX Staff Code of Conduct and Safeguarding Policy;
  • ensure that parents, teachers and tutors have an understanding that the responsibility for ensuring child protection is a joint effort and that they play a crucial supporting role in managing and monitoring student and tutor behaviour;
  • develop effective links with relevant agencies and cooperate as required with their enquiries regarding child protection matters;
  • ensure safe recruitment practices are always followed for individuals who EtonX will permit to carry out regulated activity or work regularly with children, including policies on issuing criminal record checks; and
  • outline clear policies on how to deal with concerns, allegations and complaints against staff working with children.

Management of Safeguarding

EtonX has an appointed Senior Board Level member of staff at Eton College who reports to the Board of Trustees at Eton College, providing an oversight of EtonX’s activities in regards to Safeguarding.

The Designated Safeguarding Lead

EtonX has appointed a senior member of staff with the necessary status and authority (Designated Safeguarding Lead) to be responsible for matters relating to child protection and safety. The Designated Safeguarding Lead (“DSL”) for EtonX is Catherine Whitaker, who may be reached by email at or by phone at +(44)2038618528.

The main responsibilities of the DSL are set out in Appendix 1.

If the Designated Safeguarding Lead is unavailable, the Deputy Safeguarding Lead will carry out their duties. The Deputy Safeguarding Lead for EtonX is Rahim Hirji, who may be reached by email at or by phone at +(44)2038618529.

Recruitment Policies

EtonX employs a safer recruitment policy for all EtonX Staff as well as a safer Tutor Recruitment Policy.

Recording of live group classes, chat and file upload history

All live group classes will be recorded and stored on the EtonX server six months after the end date of the course in which the student is enrolled. A live group class may contain break out rooms where students are split into groups and allowed to collaborate within their group. These sessions are not currently recorded but may be observed by a member of EtonX staff during the live group class.

Similarly, all instant messages, files, links and uploads that are shared by the tutor using the group or private chat function will also be stored and made available for review by EtonX.

EtonX may review any sessions where a report has been made by a student or tutor and may periodically review sessions for quality control and safeguarding.

All recordings remain the property of EtonX.


All persons using EtonX services have a responsibility and duty to familiarise themselves with the EtonX Safeguarding Policy and Procedures.

Any student or tutor found to be in breach of the Safeguarding Policy, Code of Conduct or Terms of Service will be removed from any enrolled courses, have their account deactivated and be suspended from the site until the incident has been investigated by the appropriate authority.

The final decision of breaches of the above policies is at EtonX’s discretion.

Any user reported for causing harm to a student will be banned from the Service immediately.


The Safeguarding Policy and Procedure will be reviewed regularly by EtonX to make sure that it remains in keeping with current legislation and safeguarding standards.

Last revised:  21 September 2018


Appendix 1 – Role of the Designated Safeguarding Lead

  1. The main responsibilities of the DSL are:
    • to be the first point of contact for all members of EtonX staff, contractors, students, tutors, teachers, parents in all matters of child protection;
    • facilitating inter-company co-operation dealing with a child protection matter with the DSL taking the lead in the event of an incident;
    • to ensure that all members of EtonX staff understand and have familiarised themselves with the internal and external guidance on child protection and safer recruitment policy and procedures and to offer support, advice and expertise for staff as required ;
    • to ensure the appropriate training of all EtonX staff on the contents of this policy and on the procedures that staff should follow. This includes the training of all new staff as part of their induction and updating all staff annually.
    • Providing all members of staff with Welfare guidance (electronic form or hard copy) which contains:
  • A copy of Part 1 of Keeping Children Safe in Education
  • This Policy
  • The EtonX Code of Conduct for Staff
    • To advise and act on all reported incidents and where necessary refer or escalate incidents to the local authorities as required;
    • To liaise with Eton College’s Designated Safeguarding Lead to provide an oversight of EtonX’s activities in regards to safeguarding policies and procedures for contribution to the annual written safeguarding report which is submitted to the Standing Committee and one full meeting of the Provost and Fellows annually;
    • Ensuring that the EtonX Safeguarding Procedures for Staff are followed within the company and monitoring compliance with regulations;
    • To keep detailed and accurate written records of safeguarding concerns or incidents;
    • To monitor the storing, security and confidentiality of data and records relating to child protection in keeping with GDPR legislation; and
    • Monitoring the DBS checking process for all who come into contact at the company.


[1] As per the Children’s Act 1989 and 2004, a child/young person is defined as a person under the age of 18.