1. Purpose and Scope
This Online Session Protocol sets the safety requirements for every session NSEMM delivers online. It applies to tutoring, mentoring, and any other online interaction with a child or young person. Operational procedures are set out in the Online Safety SOP.
2. Mandatory Recording
All sessions are recorded as a mandatory safeguarding control.
Lawful basis: UK GDPR Article 9(2)(g) and Data Protection Act 2018 Schedule 1 Part 2 paragraph 18 (safeguarding of children and individuals at risk).
Recording is NOT consent-based; participants are notified at onboarding via the Article 13 transparency notice. Recordings are retained in line with the Data Retention Policy and are erasure-exempt under UK GDPR Article 17(3)(e) and Data Protection Act 2018 Schedule 2 paragraph 5.
3. Platform Environment
All sessions take place through the Lessonspace classroom within the NSEMM Learn portal. Tutors and students must use the platform’s video, audio, and chat features only.
No off-platform communication is permitted during or after a session, including direct messaging, personal email, social media, or third-party video tools.
4. Camera and Environment Rules
Both tutor and student must have cameras on for the duration of the session.
The tutor must be in a quiet, professional environment with no other adults visible. The student should be in a household area with parental awareness; bedrooms are discouraged. Backgrounds should be neutral and not display personal information.
5. No Private Channels
Tutors must NOT exchange personal contact details with students or parents (phone numbers, social media handles, email addresses outside the NSEMM platform).
Any communication between sessions must be through NSEMM Learn or the parent’s NSEMM-registered email. This applies during the relationship and indefinitely afterwards while the student is under 18.
6. Inbound Student Direct Messages
If a tutor receives an inbound direct message from a current or former student outside the NSEMM platform (for example, on social media or personal email), they must:
- (a) NOT respond;
- (b) preserve the message as evidence;
- (c) immediately notify the Designated Safeguarding Lead (DSL) via NSEMM Protect with a description of the message and the platform it came on.
The DSL will assess and respond as appropriate, which may include contacting the student’s parent or carer and any platform involved.
7. Filtering and Monitoring
NSEMM Learn and Lessonspace are configured to prevent access to harmful content during sessions. Session recordings are retained and subject to random quality-assurance review by the DSL team, providing continuous monitoring of the online environment. NSEMM applies age-appropriate technical filtering across its platforms.
8. AI-Enabled Risks
NSEMM recognises that artificial intelligence creates new vectors for online harm including:
- AI-enabled grooming, where a perpetrator uses AI to generate personalised manipulation content;
- deepfakes and synthetic abusive material;
- AI tools that facilitate child sexual exploitation.
Staff training covers these risks. Where AI-generated abuse material is identified or suspected, the Internet Watch Foundation (IWF) and Child Exploitation and Online Protection Command (CEOP) reporting protocol in section 9 below applies.
9. Child Sexual Abuse Material and Illegal Content
If a tutor or any NSEMM staff member encounters child sexual abuse material (CSAM) during a session or in any NSEMM context:
- do NOT delete the material;
- do NOT screenshot or share it;
- do NOT investigate.
Stop the session safely, preserve evidence by leaving the material in place, and immediately report to:
- The Internet Watch Foundation at https://report.iwf.org.uk
- The Child Exploitation and Online Protection Command (CEOP) at https://www.ceop.police.uk
- The DSL through NSEMM Protect
If a child is in immediate danger, call 999 first.
10. Cyberbullying
Cyberbullying through NSEMM platforms is treated as a safeguarding concern. NSEMM’s response includes immediate intervention, support for the affected child, appropriate consequences for the perpetrator, and ongoing monitoring.
11. Regulated Activity Anchor
Online 1:1 tutoring constitutes regulated activity under the Safeguarding Vulnerable Groups Act 2006 (SVGA 2006) Schedule 4 (any form of teaching, training, or instruction of children, frequency met at more than three days in 30 or weekly). All NSEMM tutors are subject to an Enhanced DBS check including the Children’s Barred List, under Police Act 1997 s.113BA and the SVGA 2006, in accordance with this status.
12. Framework Anchors
This protocol reflects the DfE’s “Keeping children safe during community activities, after-school clubs and tuition” guidance (updated 9 February 2026), which NSEMM follows as if it were statutory, and Working Together to Safeguard Children 2026 (18 March 2026).
13. Cross-references
- Safeguarding Policy
- Data Protection Policy
- Data Retention Policy
- Code of Conduct
- Online Safety SOP (page 127 — operational step-by-step procedures)
This document is maintained by NSEMM’s Designated Safeguarding Lead and reviewed annually or following significant regulatory change. For queries, contact the DSL via protect.nsemm.org.uk.