Question 1

Complaints and Compliments policy_Elevate Ed 2025

Accepted Answer

Compliments and Complaints Policy

1. Introduction and Statement of Intent

ElevatEd AP Ltd is committed to providing a high-quality educational experience and ensuring the well-being and success of all its pupils. We believe that open communication and feedback are essential for continuous improvement. This policy outlines our clear, fair, and accessible procedures for receiving, handling, and responding to compliments and complaints from all stakeholders, including pupils, parents/carers, staff, and external partners.

We welcome compliments as they help us to recognise good practice and celebrate success. We view complaints as an opportunity to learn, resolve issues, and improve our services. All complaints will be treated seriously, confidentially, and resolved as quickly and effectively as possible. No individual will be discriminated against or disadvantaged for making a complaint in good faith.

This policy will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and the specific needs of our provision.

Signed: Mark Aitken                                              Date: 01/09/25                                         Review 01/09/26

Mark Aitken

2. Guiding Principles 
Accessibility: The policy is easily accessible and understood by all stakeholders. 
Fairness: All complaints will be investigated impartially and objectively.
Confidentiality: Information relating to complaints will be handled with discretion and confidentiality, only shared on a "need to know" basis. 
Timeliness: Complaints will be addressed promptly and within defined timescales.
Resolution: Our aim is to resolve complaints at the earliest possible stage. 
Learning: All feedback, both positive and negative, will be used to improve our services and practices. 
No Detriment: Individuals making complaints in good faith will not suffer any disadvantage.
Mediation/Informal Resolution: Where appropriate, we will seek to resolve issues informally before moving to formal stages.

3. Scope of the Policy
This policy covers:
Compliments and feedback regarding the provision's performance, staff, or services.
Complaints relating to the provision's operations, staff conduct, educational provision, safeguarding arrangements, or any other aspect of the service provided by ElevatEd AP Ltd. 
This policy does not cover:
Complaints about safeguarding matters already being handled under child protection procedures: These will be managed in accordance with our Safeguarding and Child Protection Policy and statutory guidance (e.g., "Keeping Children Safe in Education"). 
Staff disciplinary matters: These are handled under the provision's Staff Disciplinary Policy.
Exclusions appeals: These are handled under the provision's Exclusions Policy and relevant statutory guidance. 
Admission decisions: These are handled under the provision's Admissions Policy.

4. Compliments Procedure
We actively encourage and welcome compliments and positive feedback. These help us to:
Recognise and celebrate the achievements of staff and pupils.
Reinforce good practice.
Understand what we are doing well and how we can build on our strengths. 
How to give a compliment:
Compliments can be given in the following ways:
Verbally: Directly to a member of staff, the Head of Provision, or any other appropriate person.
In writing: Via email to mark@elevate-ed.co.uk or letter to Head of School Mark Aitken, Unit 15A, Empress Business Centre, Chester Rd, Old Trafford, Stretford, Manchester, M16 9EA or via our website contact form.
Via feedback surveys: Periodically, we may issue surveys to gather feedback.
All compliments will be shared with the relevant staff member(s) and, where appropriate, acknowledged and used to inform our practice.

5. Complaints Procedure
We aim to resolve most concerns or complaints quickly and informally. If an issue cannot be resolved informally, it can be escalated through the formal stages outlined below.

5.1 Stage 1: Informal Resolution
Many concerns can be resolved quickly and informally by speaking directly with the relevant member of staff.
Who to contact:
For issues relating to a specific session or pupil's day-to-day experience: The Head of Provision
For pastoral concerns or general pupil well-being: The Designated Safeguarding Lead
For transport or administrative issues: The Administrative Lead.
Expected timeframe: We aim to resolve informal concerns within 5 working days.
Outcome: The staff member will discuss the concern with you and seek to find a mutually acceptable resolution. A record of the discussion and outcome may be kept informally.
If you are not satisfied with the outcome of Stage 1, or if the nature of the complaint is serious and you feel it cannot be addressed informally, you may proceed to Stage 2.

5.2 Stage 2: Formal Complaint - Investigation by the Head of Provision.
If a complaint cannot be resolved informally, or if you deem the matter to be serious, you should submit a formal complaint in writing.
How to make a formal complaint:
Complete the Formal Complaint Form: appendix 1
Send a letter or email clearly marked "Formal Complaint" to the Head of Provision
Ensure your complaint includes:
Your full name and contact details.
The nature of the complaint, providing as much detail as possible (what happened, when, where, who was involved).
Any relevant dates or times.
Attempts made to resolve the issue informally (if any).
What outcome you are seeking.

Who to send it to: The Director of School Operations Mark Aitken (address above)
Acknowledgement: You will receive a written acknowledgement of your complaint within 3 working days of receipt.
Investigation: The Head of Provision:
Undertake a thorough and impartial investigation.
Gather all relevant information, including speaking to those involved and reviewing documentation.
May arrange a meeting with you to discuss the complaint further.

Response: A written response detailing the findings of the investigation and any actions taken or proposed will be sent to you within 15 working days of the acknowledgement. If the investigation is complex and requires more time, you will be informed of the delay and given an estimated new response date.
If you are not satisfied with the outcome of Stage 2, you may proceed to Stage 3.
​
5.3 Stage 3: Formal Complaint - Review by Independent Panel
How to request a review: You must submit a written request for a Stage 3 review within 10 working days of receiving the Stage 2 response.
Who to send it to: LADO (local Authority Designated officer) Manchester City Council
Acknowledgement: You will receive a written acknowledgement of your request within 3 working days.
Review Process:
The Independent Panel to review the complaint.
The review will consider the original complaint, the investigation conducted at Stage 2, and the findings and conclusions.
A meeting may be convened, involving the complainant, the Head of Provision, and any other relevant parties.
The review body may seek further information or clarification.
Outcome: A written response, detailing the findings of the review and the final decision of the provision, will be sent to you within 20 working days of the acknowledgement of the Stage 3 request. If the review is complex and requires more time, you will be informed of the delay and given an estimated new response date.
Final Decision: The decision at Stage 3 is the final stage of the complaints procedure within ElevateEd.

5.4 Complaints against the Head of Provision 
If the complaint is against the Head of Provision, it should be submitted directly to the Commissioning school or LADO 
Then the Commissioning School/Lado will then appoint an appropriate person to investigate the complaint. The process will then follow Stage 2 and Stage 3 procedures as outlined above.

6. Vexatious Complaints
ElevatEd AP Ltd is committed to dealing with all complaints fairly and impartially. However, there may be occasions when complainants behave unacceptably. While we recognise that complainants may be frustrated, we will not tolerate behaviour that is abusive, aggressive, or causes undue distress to staff.
A complaint may be deemed 'vexatious' if it is:
Obsessive, persistent, harassing, prolific, or repetitive.
Clearly unfounded and amounts to a general nuisance.
Pursued in an aggressive or abusive manner.
A complaint for which the provision has done everything reasonably possible to resolve.
​
In such circumstances, the Proprietor reserves the right to:
Limit contact to written correspondence only.
Specify one point of contact for the complainant.
Refuse to respond to further communications on the same subject.
Refer the matter to relevant authorities where necessary. Any decision to treat a complaint as vexatious will be made by the Proprietor and communicated in writing to the complainant, with reasons for the decision.

7. Confidentiality and Data Protection
All complaints will be handled with sensitivity and in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Information will only be shared with those who need to know in order to investigate and resolve the complaint. Personal data will be stored securely and retained only for as long as necessary in accordance with the provision's Data Retention Policy.

8. Monitoring and Review of Complaints
All formal complaints, outcomes, and lessons learned will be recorded centrally by the Head of Provision
This monitoring allows us to identify trends, address systemic issues, and continuously improve our services.
The Compliments and Complaints Policy will be reviewed annually to ensure its effectiveness and compliance with current legislation and best practice.
​​
Appendix 1: Formal Complaint Form
Please complete this form in full to enable us to investigate your complaint thoroughly.

Complainant Details:
Full Name:
Relationship to Pupil (if applicable):
Pupil's Name (if applicable):
Contact Address:
Contact Telephone Number:
Email Address:
Date:

Nature of Complaint:
Please provide a clear and concise description of your complaint. Include relevant dates, times, names of individuals involved, and any specific incidents. Please attach any supporting documents. (Continue on a separate sheet if necessary)

Informal Resolution Attempts (if any):
Have you tried to resolve this complaint informally?
Yes / No 
If yes, who did you speak to? 
Date of informal discussion(s): 
What was the outcome?

Outcome Sought: 
What resolution are you seeking from this complaint?

Declaration:
I confirm that the information provided in this form is accurate to the best of my knowledge. 
Signature: 
Date: 
Please return this form to: 
The Head of Provision Mark Aitken, Unit 15A, Empress Business Centre, Chester Rd, Old Trafford, Stretford, Manchester, M16 9EA 
Or email: mark@elevate-ed.co.uk

Question 2

Data Protection and Information Management Policy

Accepted Answer

Data Protection and Information Management Policy
Date Adopted: 9th September 2025
Review Date: September 2026
Policy Lead: Data Protection Officer (DPO) – Alexandra Mcloughlin
Approved by: Mark Aitken, Head of Provision

1. Statement of Intent
ElevatEd AP Ltd is committed to protecting the personal data of all students, parents/carers, staff, volunteers, and partners. We handle data responsibly, lawfully, and transparently in line with the UK General Data Protection Regulation (GDPR), the Data Protection Act 2018, and relevant safeguarding requirements.
This policy explains how data is collected, stored, used, shared, and protected within ElevatEd, and outlines procedures for managing and responding to data breaches.

2. Guiding Principles
We follow the seven key principles of GDPR:
Lawfulness, fairness, and transparency – data is processed legally and openly.
Purpose limitation – data is collected for specific, legitimate purposes only.
Data minimisation – only data that is necessary is collected and processed.
Accuracy – data is kept up to date and accurate.
Storage limitation – data is kept only as long as necessary.
Integrity and confidentiality – data is kept secure.
Accountability – ElevatEd is responsible for demonstrating compliance.
​
3. Scope
This policy applies to:
All personal data processed by ElevatEd (including digital and paper records).

All staff, volunteers, students, and parents/carers.
All systems, software, and devices used to handle personal data.

4. Definitions
Personal Data: Any information relating to an identified or identifiable individual (e.g., name, address, student ID).
Special Category Data: Sensitive information (e.g., health, SEND, safeguarding).
Processing: Any operation performed on data (collecting, storing, sharing).
Data Subject: The individual to whom the data relates.
Data Controller: ElevatEd, responsible for deciding how and why data is processed.
Data Processor: Third parties processing data on behalf of ElevatEd.

5. Roles and Responsibilities
Data Protection Officer (DPO):
Ensures ElevatEd complies with data protection law.
Provides advice, training, and monitoring.
Acts as point of contact with the ICO (Information Commissioner’s Office).

Leadership Team:
Ensure adequate resources for compliance.
Monitor data handling practices.

Staff and Volunteers:
Handle data responsibly, following this policy.
Report any breaches or concerns immediately.

Students and Parents:
Provide accurate information.
Understand their rights under GDPR.

6. Rights of Data Subjects
Under GDPR, individuals have the right to:
Be informed about how their data is used.
Access their personal data (Subject Access Request).
Rectify inaccurate or incomplete data.
Erase data where there is no legal basis for its retention (“right to be forgotten”).
Restrict or object to processing under certain conditions.
Data portability (transfer of data where applicable).

7. Data Collection, Storage, and Use
Collection: Data collected is necessary for education, safeguarding, and operational purposes.
Storage: Data stored securely on password-protected systems and locked filing cabinets.
Use: Data used only for legitimate educational, pastoral, or administrative purposes.
Retention: Data retained in line with statutory guidance (e.g., student records until 25 years

old).

8. Data Sharing
Data will only be shared with:
Local authorities, schools, and exam boards (where lawful and necessary).
Social care, police, health services, and safeguarding partners (where required).
Approved third-party service providers (with Data Processing Agreements in place).
Data will never be sold to third parties.

9. Data Security
Secure passwords and two-factor authentication used on systems.
Regular staff training on safe data handling.
Encryption of sensitive data when transferring.
Secure disposal of old records (shredding, digital wiping).

10. Data Breaches
A data breach is any incident where personal data is:
Lost, stolen, destroyed, accessed without permission, or shared inappropriately.
All breaches must be reported immediately to the DPO.

Flowchart: Data Breach Response
Step 1: Breach Identified
⬇️
Staff/volunteer detects data loss, theft, or misuse.
⬇️
Step 2: Report Immediately
⬇️
Notify the DPO within 24 hours.
⬇️
Step 3: Contain the Breach
⬇️
DPO/IT team take urgent steps (e.g., disable accounts, recover data, secure systems).
⬇️
Step 4: Assess Risk
⬇️
DPO evaluates severity and potential harm to individuals.
⬇️
Step 5: Notify ICO (if required)
⬇️
ICO informed within 72 hours if breach poses risk to individuals.
⬇️
Step 6: Notify Data Subjects (if required)
⬇️
Affected individuals informed if there is a high risk to their rights/freedoms.
⬇️
Step 7: Record & Review
⬇️
Incident recorded in Data Breach Log.
Preventative measures put in place to reduce future risk.

11. Monitoring and Review
The DPO will conduct annual audits of data handling.
All breaches and near misses will be reviewed to identify patterns.
This policy will be reviewed annually or earlier if legislation changes.

12. Related Policies
Child Protection and Safeguarding Policy
Behaviour Policy
Staff Code of Conduct
E Safety Policy
Whistleblowing Policy

Question 3

E-safety policy_Elevate Ed - 2025

Accepted Answer

E-Safety Policy

1. Statement of Intent

ElevatEd AP Ltd is committed to providing a safe and positive learning environment for all its pupils, both offline and online. We recognise that the internet and digital technologies offer vast educational opportunities, but also present potential risks. This E-Safety Policy outlines our commitment to protecting pupils and staff from online harms, promoting responsible and safe use of technology, and educating our community about digital citizenship.

We understand that pupils attending Alternative Provisions may have particular vulnerabilities or varying levels of digital literacy, and our approach to e-safety is therefore proactive, supportive, and tailored to meet their individual needs.

This policy applies to all users of our digital systems and equipment (including pupils, staff, visitors, and contractors) on and off-site, and covers all digital devices, whether owned by the provision or personal devices used on premises. It will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and technological advancements.

Signed: Mark Aitken                                       Date: 01.09.25                                              Review 01.09.26

Mark Aitken

2. Guiding Principles

Our approach to e-safety is guided by the following principles:
Safeguarding: E-safety is an integral part of our overall safeguarding duties, protecting children from harm and promoting their welfare in the online world.
Education: Empowering pupils and staff with the knowledge and skills to use technology safely, critically, and responsibly.
Prevention: Implementing proactive measures, both technical and educational, to minimise exposure to online risks.
Protection: Providing clear procedures for reporting and responding to e-safety incidents effectively.
Responsibility: Encouraging all members of our community to take responsibility for their online actions and to report concerns.
Partnership: Working collaboratively with parents/carers, referring schools, and external agencies to ensure a consistent approach to e-safety.
Compliance: Adhering to all relevant legislation and statutory guidance, including the Online Safety Act (2023).
​
3. Roles and Responsibilities

3.1 Head of Provision:
Ensuring the provision has a comprehensive and effective E-Safety Policy. 
Holding himself and E-Safety Lead accountable for its implementation. 
Ensuring adequate resources are allocated for e-safety education, technical infrastructure, and staff training. 
Reviewing e-safety incident reports and ensuring appropriate actions are taken. 
Overall responsibility for the day-to-day implementation and consistent application of this policy. 
Appointing a designated E-Safety Lead and ensuring they have appropriate training and support. 
Ensuring all staff receive regular e-safety training. 
Promoting a culture of online safety across the provision. 
Liaising with parents/carers and external agencies regarding e-safety concerns.

3.2 Designated Safeguarding Lead (DSL): 
The DSL is the primary point of contact for all safeguarding concerns, including those related to e-safety. 
Managing and responding to e-safety incidents that involve safeguarding concerns (e.g., online sexual exploitation, radicalisation, serious cyberbullying). 
Liaising with relevant external agencies (e.g., LADO, police, social care, CEOP). 
Ensuring e-safety is fully integrated into the provision's overall safeguarding procedures.

3.3 E-Safety Lead (or designated staff member): 
Responsible for the day-to-day management of e-safety implementation.
Advising the Head of Provision and DSL on e-safety matters.
Overseeing technical e-safety measures (filtering, monitoring).
Coordinating e-safety education for pupils and staff.
Acting as a point of contact for e-safety concerns.
Keeping up-to-date with current e-safety threats and guidance.

3.4 All Staff (Teachers, Support Staff, Administration, Volunteers):
Understanding and adhering to this E-Safety Policy and the Staff Acceptable Use Policy (AUP).
Modelling safe and responsible online behaviour.
Integrating e-safety education into the curriculum and daily interactions.
Being vigilant for e-safety incidents or concerns and reporting them immediately to the E-Safety Lead or DSL.
Supervising pupils' online activities where appropriate.
Participating in e-safety training.

3.5 Pupils:
Understanding and adhering to the Pupil Acceptable Use Policy (AUP).
Using technology responsibly and respectfully.
Knowing how to report concerns about online content or contact to a trusted adult.
Protecting their personal information online.
Being critical consumers of online information.

3.6 Parents/Carers:
Supporting the provision's e-safety approach at home.
Monitoring their child's online activity outside of the provision.
Discussing online safety with their child.
Reporting any e-safety concerns to the provision.

4. E-Safety Education
We will provide e-safety education through:
Curriculum Integration: E-safety topics will be integrated into relevant subjects (e.g. IT/Computing lessons).
Dedicated Sessions: Regular e-safety lessons, workshops, and awareness campaigns for pupils.
Discussions: Regular discussions about online risks and responsible use.
Staff Training: Mandatory annual e-safety training for all staff, covering new threats, guidance, and reporting procedures.
Parental Engagement: Providing information, resources, and workshops for parents/carers on how to support e-safety at home.

5. Acceptable Use Policy (AUP)
Separate, clear, and age-appropriate Acceptable Use Policies (AUPs) will be in place for:
Pupils: Detailing expectations for online behaviour, use of provision devices, internet access, social media, and consequences for misuse.
Staff: Covering professional conduct online, use of provision and personal devices, social media guidelines, and data handling.
Visitors/Contractors: Briefing on acceptable use of provision Wi-Fi and devices, and safeguarding expectations.
All users will be required to sign and adhere to the relevant AUP.

6. Managing Online Risks
We employ a multi-layered approach to mitigate online risks:
6.1 Online Content:
Filtering: Robust internet filtering systems are in place to block access to inappropriate or harmful content. This filtering is regularly reviewed and updated.
Monitoring: Network monitoring tools are used to identify potential online safety concerns, key word searches, and suspicious activities. Alerts are directed to the E-Safety Lead/DSL.
Reporting: Clear procedures for pupils and staff to report inappropriate content encountered online.

6.2 Online Contact (Grooming and Exploitation):
Pupils are educated about the risks of communicating with strangers online and the importance of not sharing personal information.
Staff are trained to identify signs of online grooming or exploitation and to report concerns immediately to the DSL.
Where concerns arise, the DSL will follow safeguarding procedures, including referral to the Local Authority Designated Officer (LADO) and/or police (e.g., CEOP).

6.3 Cyberbullying:
Our Anti-Bullying Policy explicitly covers cyberbullying.
Pupils are educated on how to prevent, recognise, and report cyberbullying.
All incidents of cyberbullying will be investigated thoroughly, and appropriate action taken in line with our Behaviour Policy.
Support will be provided to both victims and perpetrators, using restorative practices where appropriate.

6.4 Online Radicalisation and Extremism (Prevent Duty):
Staff are trained to recognise the signs of online radicalisation and extremism, in line with the Prevent Duty.
Filtering systems are designed to block access to extremist content.
Any concerns about pupils being drawn into terrorism or radicalisation online will be reported to the DSL, who will follow local Prevent referral pathways.

6.5 Privacy and Data Protection:
Personal data is handled in accordance with our Data Protection Policy and GDPR.
Pupils are taught the importance of protecting their personal information online.
Staff are trained on secure data handling practices.

6.6 Gaming and Associated Risks:
We recognise that online gaming is a popular activity, but it can present risks including:
Inappropriate Content/Contact: Exposure to offensive language, violent content, or contact with strangers.
Addiction/Excessive Screen Time: Impact on sleep, education, and physical health.
In-game Purchases/Gambling-like Mechanics: Financial risks or normalisation of gambling behaviours.
E-safety education will address these risks, promoting healthy gaming habits and advising pupils to report any uncomfortable online interactions.
Staff will monitor gaming-related discussions or behaviours for signs of concern.

6.7 Misinformation and Disinformation:
Pupils will be educated on media literacy, critical thinking skills, and how to evaluate the reliability of online information.

7. Reporting and Responding to E-Safety Incidents
7.1 Reporting Procedures:
Pupils: Should report any e-safety concerns (e.g., inappropriate content, contact, cyberbullying) to any trusted adult (e.g., teacher, Key Worker, E-Safety Lead, DSL).
Staff: Must report all e-safety incidents, concerns, or disclosures to the E-Safety Lead or DSL immediately.
Parents/Carers: Should contact the E-Safety Lead or DSL with any concerns about their child's online safety.

7.2 Incident Response:
All reported incidents will be logged.
The E-Safety Lead/DSL will investigate the incident in line with the provision's safeguarding procedures.
Actions may include:
Providing immediate support to the pupil(s) involved.
Liaising with parents/carers and referring schools.
Disabling user accounts or device access where misuse has occurred.
Involving external agencies (e.g., police, CEOP, LADO) if the incident meets thresholds for criminal activity or safeguarding concerns.
Applying appropriate consequences in line with the Behaviour Policy.
Reviewing and updating relevant policies or procedures.

Confidentiality will be maintained as far as possible, whilst ensuring the safety and well-being of those involved.

8. Technical Measures
Network Security: Secure networks, firewalls, and antivirus software are in place.
Device Management: Regular security updates, clear rules for device use, and controlled access to software and apps.
Wireless Network: Secure Wi-Fi with appropriate access controls.
Personal Devices: Clear rules will be communicated regarding the use of personal mobile phones and other devices on provision premises (e.g., not allowed during learning time, no photography/recording without consent).

9. Staff Professional Conduct and Use of Technology
Staff will adhere strictly to the Staff AUP and relevant professional codes of conduct.
Personal devices should not be used for contact with pupils unless explicitly approved and logged for professional purposes (e.g., emergency calls, official communication platforms).
Staff will exercise extreme caution regarding their personal social media presence and online interactions to avoid any perception of impropriety or compromising their professional role.

10. Monitoring and Review
The effectiveness of this policy and our e-safety practices will be monitored through:
Analysis of reported e-safety incidents.
Regular reviews of filtering and monitoring logs.
Feedback from pupils, staff, and parents/carers.
Keeping up-to-date with new online risks and technologies.

This policy will be formally reviewed at least annually by the Head of Provision

Appendix 1: Key External Resources
NSPCC: Advice and resources on a range of child safety issues, including online safety.
Thinkuknow (CEOP Education): Online safety education resources for children, young people, parents, and teachers. Report child sexual abuse online.
Internet Watch Foundation (IWF): Reports and removes child sexual abuse content online.
UK Safer Internet Centre: Advice, resources, and report harmful content online.
Parent Zone: Provides information and support to parents on children's digital lives.
Childline: Offers support and advice for young people.

Question 4

General Data Protection Regulation (GDPR) Policy

Accepted Answer

General Data Protection Regulation (GDPR) Policy
1. Statement of Intent
ElevatEd is deeply committed to protecting the privacy and security of all personal data it processes. This policy articulates our unwavering dedication to upholding the principles and requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
We recognise our profound legal and ethical responsibility to handle all personal data with the utmost care, transparency, and respect for individual rights. For an Alternative Provision, this commitment is particularly salient given the highly sensitive and often complex nature of the data we hold concerning our pupils (including their diverse needs, safeguarding information, health records, and behavioural histories), staff, parents/carers, and other vital stakeholders.
This policy applies comprehensively to all personal data handled by ElevatEd AP Ltd, irrespective of whether it is stored electronically or in paper format. It extends to all individuals acting on behalf of the provision, including employees, temporary staff, volunteers and contractors.
This policy will be subject to rigorous review at least annually, or more frequently if necessitated by changes in legislation, guidance, or our data processing activities, ensuring its ongoing relevance and effectiveness.
Signed: Mark Aitken Date of Adoption: 7th June 2025 Date of Review: June 2026
Mark Aitken of Head of Provision
2. Scope This policy's provisions encompass:
All categories of personal data (including special category data and criminal offence data) processed by ElevatEd AP Ltd.
All personnel, including employees, temporary staff, volunteers, and contractors, who engage in data processing activities on behalf of the provision.
All information systems, applications, and networks utilised by the provision, whether accessed on-site or remotely.
3. Key GDPR Principles
Our robust data handling practices are built upon the following foundational GDPR principles:
Lawfulness, Fairness and Transparency: Personal data is processed in a manner that is lawful, fair, and transparent in its interactions with the data subject.
Purpose Limitation: Personal data is collected for specified, explicit, and legitimate purposes. It will not be further processed in a manner that is incompatible with those original purposes.
Data Minimisation: Personal data collected and processed is adequate, relevant, and strictly limited to what is necessary for the purposes for which it is processed.
Accuracy: Personal data is maintained as accurate and, where essential, kept up to date. Every reasonable step is undertaken to ensure that personal data found to be inaccurate, considering its processing purposes, is either promptly erased or rectified.
Storage Limitation: Personal data is retained in a format that permits the identification of data subjects for no longer than is absolutely necessary for the purposes for which the personal data is processed.
Integrity and Confidentiality (Security): Personal data is processed in a manner that guarantees its appropriate security, safeguarding it against unauthorised or unlawful processing, and against accidental loss, destruction, or damage, through the implementation of robust technical and organisational measures.
Accountability: As the data controller, the Governing Body/Proprietor bears the responsibility for, and must demonstrably evidence, compliance with all the aforementioned principles.
4. Definitions To ensure clarity, the following terms are defined:
Personal Data: Any information that relates to an identified or identifiable natural person ('data subject'). This encompasses, but is not limited to, names, addresses, contact details, photographs, unique pupil numbers (UPNs), and online identifiers.
Special Category Data: A subset of personal data that is particularly sensitive and requires higher levels of protection. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (used for identification purposes), data concerning health, or data concerning a person's sex life or sexual orientation. In an educational context, this specifically includes sensitive information such as safeguarding details, Special Educational Needs and Disabilities (SEND) information, and data pertaining to children looked after or those classified as children in need.
Criminal Offence Data: Personal data relating to criminal convictions and offences or associated security measures.
Processing: Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. This includes, for example, collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Data Subject: The identified or identifiable natural person to whom the personal data relates (e.g., pupils, staff, parents/carers, visitors).
Data Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. At ElevatEd AP Ltd, this responsibility rests with the Proprietor.
Data Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller (e.g., IT service providers, cloud storage providers, payroll services).
Data Protection Officer (DPO): An individual formally appointed to provide independent advice and monitor compliance with data protection law within the organisation.
5. Roles and Responsibilities
5.1 Data Controller (The Proprietor):
Possesses the ultimate responsibility for ensuring comprehensive compliance with UK GDPR and DPA 2018.
Is responsible for the approval of this GDPR Policy and all other pertinent data protection policies (e.g., Data Retention Schedule, Data Breach Response Plan).
Is responsible for the formal appointment of a qualified Data Protection Officer (DPO).
5.2 Head of Provision/Manager:
Holds the responsibility for the day-to-day operational implementation and consistent application of this GDPR Policy across the provision.
Ensures that all staff are aware of their data protection obligations and adhere to established principles.
Manages the provision's data processing activities and verifies that appropriate security measures are effectively in place.
Acts as the primary liaison with the DPO and relevant external bodies (e.g., Information Commissioner's Office (ICO), Local Authority).
5.3 Data Protection Officer (DPO):
[State the Name/Organisation of DPO, or confirm 'The DPO is [external company/individual] and their contact details are: [provide clear contact details, e.g., email address, postal address]']
Acts as an independent advisor, tasked with informing and advising the provision and its staff about their obligations under UK GDPR and DPA 2018.
Monitors the provision's compliance with data protection law and its internal data protection policies.
Provides expert advice regarding the necessity and execution of Data Protection Impact Assessments (DPIAs).
Serves as the primary contact point for the ICO and for data subjects regarding all data protection matters.
5.4 All Staff (including temporary staff, volunteers, contractors):
Are mandated to adhere strictly to this policy and all other related data protection procedures.
Are required to complete mandatory data protection training as provided by the provision.
Must handle all personal data securely and maintain strict confidentiality.
Are obliged to report any suspected data breaches or data protection concerns immediately to the Head of Provision and/or the DPO.
Are only authorised to access personal data that is strictly necessary for the fulfilment of their specific job role.
6. Types of Personal Data Held
ElevatEd AP Ltd processes various categories of personal data relating to its stakeholders, including but not limited to:
Pupils: Full names, contact details, date of birth, unique pupil numbers (UPNs), attendance records, academic assessment data, progress reports, behaviour records, comprehensive safeguarding information, Special Educational Needs and Disabilities (SEND) information, pertinent health data, photographs/videos for educational or publicity purposes, details of referrals, and funding eligibility (e.g., Free School Meals, Pupil Premium).
Staff: Full names, contact details, comprehensive employment history, professional qualifications, Disclosure and Barring Service (DBS) check results, payroll and financial information, performance management data, relevant health information, and absence records.
Parents/Carers: Full names, contact details, and information pertaining to parental responsibility.
Governors/Proprietors: Full names, contact details, declarations of interest, and DBS check results.
Visitors/Contractors: Names, contact details, and vehicle registration details (collected for security and health and safety purposes).
7. Lawful Basis for Processing
Every instance of personal data processing undertaken by the provision must be underpinned by a clear lawful basis as stipulated in Article 6 of the UK GDPR. For the processing of Special Category Data, an additional explicit condition under Article 9 is always required.
Our primary lawful bases for processing personal data are typically:
Public Task (Article 6(1)(e)): This is the most common lawful basis for educational institutions. Processing is deemed necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (e.g., providing education, implementing robust safeguarding measures for children, maintaining statutory records as required by the DfE).
Legal Obligation (Article 6(1)(c)): Processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., fulfilling statutory returns to the Department for Education, adhering to safeguarding duties outlined in "Keeping Children Safe in Education," compliance with employment law, sharing data for Children Missing Education (CME) purposes).
Legitimate Interests (Article 6(1)(f)): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject. This basis is applied carefully and proportionately, for example, for some security measures (e.g., CCTV in common areas) or for certain internal administrative processes not covered by public task, where a clear balancing test demonstrates our legitimate interest.
Consent (Article 6(1)(a)): The individual has given clear, unambiguous consent for us to process their personal data for a specific purpose (e.g., for certain types of photographs/videos used in publicity, participation in optional non-statutory activities, or for specific research projects that fall outside our public task). When relying on consent, it is always freely given, specific, informed, and unambiguous, and crucially, it can be withdrawn by the data subject at any time.
For Special Category Data, we rely on specific conditions under Article 9, such as:
Substantial Public Interest (Article 9(2)(g)): Processing is necessary for reasons of substantial public interest, as defined by UK law (e.g., robust safeguarding of children, the effective provision of education and care, preventing unlawful acts, promoting equality of opportunity).
Health or Social Care (Article 9(2)(h)): Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.
Vital Interests (Article 9(2)(c)): Processing is necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent (e.g., in a life-threatening medical emergency).
Explicit Consent (Article 9(2)(a)): This condition is only used when no other appropriate lawful basis or condition under Article 9 applies, and where explicit, unambiguous consent is obtained (e.g., for the sharing of specific health data beyond statutory duties, or participation in specific research where the public interest basis is not applicable).
9. Data Subject Rights
Individuals are afforded specific rights concerning their personal data under UK GDPR. ElevatEd AP Ltd is committed to facilitating the exercise of these rights:
The Right to be Informed: Individuals have the right to be informed about how their personal data is being collected and processed. This is fulfilled through our clear and accessible

Privacy Notices (refer to Section 13).
The Right of Access (Subject Access Requests - SARs): Individuals (or their legal representatives) have the right to request a copy of the personal data we hold about them.
SARs must be submitted in writing (via email or letter) and specifically directed to the Data Protection Officer (DPO).
We are committed to responding to SARs without undue delay and, in any event, within one calendar month of receiving the request. This timeframe may be extended by a further two months for complex or numerous requests, with the data subject being informed of any such extension.
No fee will be charged for SARs unless the request is deemed manifestly unfounded or excessive, or if further copies of previously provided information are requested.
We will rigorously verify the identity of the requester to prevent unauthorised disclosure.
We will ensure that the rights and freedoms of other individuals are not adversely affected by the disclosure of information.

The Right to Rectification: Individuals have the right to request that inaccurate or incomplete personal data held about them be corrected or updated without undue delay.
The Right to Erasure ('Right to be Forgotten'): Individuals can request the deletion of their personal data in certain specific circumstances (e.g., where the data is no longer necessary for the purpose for which it was collected, or where consent is withdrawn and no other lawful basis applies). This right is not absolute, particularly where the data is processed under a legal obligation or a public task.
The Right to Restrict Processing: Individuals can request the restriction or suppression of their personal data in certain circumstances (e.g., if the accuracy of the data is contested, or if the processing is unlawful but the data subject opposes erasure).
The Right to Data Portability: Individuals have the right to obtain and reuse their personal data for their own purposes across different services. This right primarily applies to data processed by consent or under a contract, and typically requires the data to be provided in a structured, commonly used, and machine-readable format.
The Right to Object: Individuals have the right to object to processing based on legitimate interests or performance of a public task, or for direct marketing purposes.
Rights in relation to Automated Decision Making and Profiling: Individuals have specific rights regarding decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects. ElevatEd AP Ltd does not currently use automated decision-making or profiling that would have a significant impact on individuals.
10. Data Security
ElevatEd AP Ltd implements robust technical and organisational measures to ensure the appropriate security of personal data, protecting it from unauthorised or unlawful processing and from accidental loss, destruction, or damage. These measures include:
Physical Security: Secure storage of all paper records in locked cabinets within secure rooms with restricted access.
Network Security: Deployment of robust firewalls, comprehensive antivirus and anti-malware software, secure Wi-Fi networks, and regular security updates across all systems.
Access Controls: Strict access controls based on job role and the 'need to know' principle, implementation of strong password policies, and the use of multi-factor authentication where technically feasible and appropriate.
Encryption: Utilisation of encryption for sensitive data, particularly when transmitted over networks or stored on portable devices.
Staff Training: Mandatory and regular training for all staff on secure data handling practices, security awareness, and breach procedures.
Clear Desk/Screen Policy: Enforcement of a policy to ensure that sensitive physical documents or digital information is not left visible or unsecured.
Secure Disposal: Implementation of secure procedures for the disposal of all data, both electronic (e.g., hard drive wiping, degaussing) and paper (e.g., cross-shredding, confidential waste disposal).
Processor Contracts: Ensuring that all third-party data processors (e.g., Management Information System (MIS) providers, cloud service providers, payroll services) are fully UK GDPR compliant and operate under legally binding data processing agreements outlining their responsibilities.
11. Data Retention
Personal data will not be retained for any longer than is strictly necessary for the purposes for which it was collected. ElevatEd AP Ltd maintains a comprehensive Data Retention Schedule (a separate, detailed document) which outlines the maximum retention period for different categories of personal data, in strict accordance with legal and statutory requirements (e.g., DfE guidance, Limitation Act 1980) and best practice guidelines.
12. Sharing Data
ElevatEd AP Ltd will only share personal data when there is a clear and legitimate basis to do so, adhering to the following principles:
Lawful Basis: Data will only be shared when there is a clear lawful basis (e.g., legal obligation, public task, explicit consent), and where an additional condition under Article 9 applies for special category data.
Safeguarding and Welfare: Data may be shared immediately where it is necessary for safeguarding purposes or for the vital welfare of a child (e.g., sharing with social care, police, health services under established safeguarding principles).
Data Sharing Agreements: Where appropriate and necessary (e.g., for regular, routine sharing with external bodies), a formal Data Sharing Agreement will be in place with the recipient, clearly outlining the purpose of the sharing, the types of data involved, and the security measures to be employed.
DfE Guidance: Compliance with Department for Education guidance on data sharing (e.g., pupil transfers between schools via Common Transfer Files (CTF)).
Security and Proportionality: All data sharing will be conducted securely, using appropriate transfer methods, and will be strictly proportionate to the purpose for which the data is being shared.
​
13. Privacy Notices
We are committed to transparency regarding our data processing activities. Clear, concise, and easily understandable Privacy Notices will be provided to all data subjects (pupils/parents/carers, staff, governors, visitors) at the point of data collection or as soon as practically possible thereafter. These notices explicitly explain:
What specific personal data we collect.
The precise purposes for which we collect it.
How we will use and process the data.
With whom we may share the data.
How long we will retain the data.
The individual's statutory data protection rights.
Contact details for our Data Protection Officer (DPO) and the Information Commissioner's Office (ICO).
These Privacy Notices are published on our official website and are readily available in paper format upon request.
14. Data Protection Impact Assessments (DPIAs)
A comprehensive Data Protection Impact Assessment (DPIA) will be conducted for any new project, system, or process that is likely to result in a high risk to individuals' data protection rights and freedoms. This includes, but is not limited to:
The introduction of new technologies (e.g., extensive biometric systems, new large-scale CCTV deployments).
Large-scale processing of special category data (e.g., new comprehensive health databases).
Systematic processing of data concerning vulnerable individuals (such as pupils within an Alternative Provision setting).
Transferring personal data outside the UK or the European Economic Area (EEA).
The DPIA process involves a structured approach: identifying the necessity for a DPIA, thoroughly describing the proposed processing operation, assessing its necessity and proportionality, identifying and rigorously assessing all potential risks to data subjects, and finally, identifying and documenting comprehensive measures to mitigate those identified risks. The DPO will be consulted at all stages of the DPIA process.
​
15. Data Breaches
A personal data breach is defined as a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
In the event of a suspected or actual data breach, the following immediate and systematic steps will be taken, as further detailed in our separate Data Breach Response Plan:
Containment and Recovery: Immediate action will be taken to limit the damage caused by the 
breach and to restore affected systems and data integrity.
Assessment of Risk: A rapid assessment will be conducted to determine the likelihood and severity of the resulting risk to individuals' rights and freedoms.
Notification:
If the breach is likely to result in a high risk to individuals' rights and freedoms, the Information Commissioner's Office (ICO) will be notified without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
If the breach is likely to result in a high risk to individuals' rights and freedoms, affected data subjects will also be informed directly without undue delay.
Investigation and Review: A thorough investigation of the breach will be conducted to ascertain its root causes, and robust measures will be implemented to prevent recurrence.
16. Staff Training
All staff members (including temporary staff, volunteers, and governors) will receive mandatory data protection training upon their induction and at least annually thereafter. This comprehensive training will cover:
Their specific responsibilities and obligations under this policy.
A clear understanding of data protection principles.
How to recognise, respond to, and report suspected data breaches.
Procedures for handling Subject Access Requests (SARs) and other data subject rights requests.
Specific guidance pertinent to handling the sensitive pupil data prevalent in an Alternative Provision setting.
17. Policy Review
This policy will be subject to a comprehensive review at least annually by the Head of Provision. The review process will critically consider:
Any changes in data protection legislation, statutory guidance, or ICO recommendations.
Feedback received from the DPO, staff, pupils, and parents/carers.
Outcomes of any internal or external data protection audits or incident investigations.
The introduction of any new technologies or data processing activities within the provision. people.

Question 5

ICT User Acceptance Policy

Accepted Answer

ICT User Acceptance Policy
Date Adopted: 9th September 2025
Review Date: September 2026
Policy Lead: Mark Aitken - Head of Provision

1. Statement of Intent
ElevatEd AP Ltd is committed to ensuring that all users of ICT systems — including students, staff, volunteers, and visitors — use technology safely, responsibly, and in line with our values. ICT is central to teaching, learning, communication, and safeguarding. This policy sets out clear rules to protect users, safeguard data, and promote digital wellbeing.

2. Guiding Principles
ICT is a tool to support learning, creativity, and wellbeing.
Users must act with integrity, respect, and responsibility.
ICT must be used in a way that keeps children and staff safe online and offline.
Personal data and information must always be protected.
Misuse of ICT may lead to disciplinary action, safeguarding intervention, or legal action.

3. Scope This policy applies to:
All users of ElevatEd’s ICT systems (students, staff, parents, volunteers, contractors).
All ICT devices (PCs, laptops, tablets, smartphones, printers, projectors).
All networks, internet access, and software systems.
Personal devices when connected to ElevatEd’s network or used for ElevatEd business.

4. Definitions
ICT: Information and Communication Technology, including hardware, software, and online systems.
User: Any person authorised to use ElevatEd ICT systems.
Acceptable Use: Safe, responsible, and educationally beneficial use of ICT.
Unacceptable Use: Misuse of ICT that is unsafe, illegal, harmful, or breaches this policy.

5. Roles and Responsibilities
Leadership Team: Ensure robust ICT safety policies, resources, and monitoring systems.
Data Protection Officer (DPO): Maintain systems securely, monitor usage, and respond to breaches.
Staff: Model responsible ICT use, supervise students, and report concerns promptly.
Students: Follow the rules of this policy and respect ICT equipment.
Parents/Carers: Support their child in safe, responsible ICT use at home.

6. Acceptable Use Rules
For Students:
Use ICT only for learning and creativity.
Always log in with your own username and keep passwords private.
Respect others — no cyberbullying, harassment, or inappropriate communication.
Report any harmful or unsafe content to a member of staff immediately.
Treat equipment with care.
For Staff/Adults:
Use ICT only for professional purposes in line with ElevatEd values.
Protect student data in line with the Data Protection Policy.
Do not use ICT for personal gain, inappropriate material, or illegal activity.
Maintain professional boundaries online (including social media).
Report any ICT misuse or breach immediately.

7. Unacceptable UseExamples include (but are not limited to):
Accessing, downloading, or sharing offensive, extremist, or illegal content.
Bypassing security or attempting unauthorised access (“hacking”).
Using ICT to bully, harass, or harm others.
Sharing confidential information without authorisation.
Damaging or misusing equipment, software, or systems.
Using ICT for personal commercial purposes.

8. ICT Monitoring and Filtering
ElevatEd monitors ICT use for safeguarding, security, and compliance.
Internet access is filtered to block harmful content.
Email and digital communication may be monitored where safeguarding concerns arise.
Users should have no expectation of privacy when using ElevatEd ICT systems.

9. Reporting ICT Misuse
All users must report ICT misuse immediately to a staff member
Reporting ICT Misuse
Step 1: Misuse Detected
Student, staff, or system identifies ICT misuse.
Step 2: Report Immediately
Inform E Safety Lead / DSL (if safeguarding concern).
Step 3: Initial Response
ICT access may be suspended while incident is investigated.
Step 4: Assessment
E Safety Lead and DPO investigate the nature of misuse.
DSL consulted if safeguarding issue.

Step 5: Action Taken
Minor misuse → Warning / Restorative action.
Serious misuse → Parental involvement / Disciplinary process.
Illegal misuse → Police and external agencies informed.
Step 6: Record & Review
Incident logged.
Systems/policies updated to prevent recurrence.

10. Consequences of Breach
Students: Loss of ICT privileges, parental involvement, disciplinary action, safeguarding referrals.
Staff: Disciplinary action (up to dismissal), referral to regulatory bodies if required.
All Users: Possible legal consequences for serious/illegal misuse.

11. Training and Awareness
All staff trained annually on ICT safety and GDPR.
Students receive regular online safety education.
Parents supported through discussion and resources.

12. Monitoring and Review
Policy reviewed annually or when legislation/technology changes.
E Safety Lead and DSL report to Leadership Team any ICT incidents and emerging risks.

13. Related Policies
Data Protection & Information Management Policy
Child Protection and Safeguarding Policy
Behaviour Policy
Staff Code of Conduct
E Safety Policy

Question 6

Safer Recruitment Policy

Accepted Answer

Safer Recruitment Policy

1. Statement of Intent
ElevatEd AP Ltd is committed to safeguarding and promoting the welfare of children and young people. We expect all staff and volunteers to share this commitment. This Safer Recruitment Policy outlines the robust procedures we follow to ensure that all prospective employees and volunteers are thoroughly vetted and suitable to work with children. We are committed to deterring, identifying, and rejecting applicants who are unsuitable to work with children and young people.
This policy applies to all paid employees, volunteers, agency staff, and any other individuals who will have regular contact with pupils, or access to sensitive information about pupils, in our provision. It will be reviewed annually and updated as necessary to reflect changes in legislation, guidance (especially "Keeping Children Safe in Education"), and the specific needs of our provision.

Signed: Mark Aitken                                   Date: 01.09.25   			Review: 01.09.26

2. Principles of Safer Recruitment
Our safer recruitment practices are underpinned by the following principles:
Child Protection: The welfare of children is paramount in all recruitment decisions.
Compliance: Adherence to all relevant legislation and statutory guidance, 	including "Keeping Children Safe in Education" (KCSIE), 	the Data Protection Act 2018, and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975.
Fairness and Transparency: All applicants will be treated fairly and consistently, and the 	recruitment process will be transparent.
Prevention: Proactive measures will be taken to prevent unsuitable individuals from gaining access to pupils.
Continuous Improvement: Our recruitment procedures will be regularly reviewed and improved.

3. Roles and Responsibilities
3.1 The Leadership Team:
Responsible for ensuring the provision has a comprehensive and effective Safer Recruitment Policy.
Ensuring that at least one person on any recruitment panel has completed accredited safer recruitment training.
Holding the Head of Provision accountable for the effective implementation of this policy.
3.2 The Head of Provision:
Overall responsibility for ensuring all 	recruitment procedures comply with this policy and statutory 	guidance.
Ensuring that all staff involved in recruitment have received appropriate safer recruitment training.
Making final decisions on appointments, ensuring all necessary checks have been satisfactorily completed.
Reporting to the Independent Body on recruitment practices and compliance.
3.3 Recruitment Panel Members:
All members of a recruitment panel willhave completed accredited safer recruitment training.
Will adhere strictly to the procedures 	outlined in this policy.
Will ensure objective assessment of 	candidates and thorough exploration of safeguarding suitability.
4. The Recruitment Process
The following steps outline the comprehensive safer recruitment process undertaken by ElevatEd:
4.1 Job Description and Person Specification:
All roles will have a clear, up-to-date job description outlining duties and responsibilities.
A person specification will clearly define the qualifications, experience, skills, and personal attributes 	required for the role, with a strong emphasis on suitability to work with children. This will explicitly state: "This post is exempt from the Rehabilitation of Offenders Act 1974 and subject to an enhanced Disclosure and Barring Service (DBS) check."

4.2 Advertising:
All advertisements will include a prominent statement about the provision's commitment to safeguarding and the requirement for an enhanced DBS check. For example: "ElevatEd is committed to safeguarding and promoting the welfare of children and young people 	and expects all staff and volunteers to share this commitment. This 	post is subject to an enhanced DBS check and satisfactory references."
Advertisements will clearly state that 	references will be sought prior to interview.
4.3 Application Form:
Only application forms will be accepted, not CVs, as they may contain insufficient information.
The application form will require: 
Full employment history, with explanations for any gaps in employment.
Details of qualifications.
Declaration of any spent or unspent convictions (as permitted by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975).
The names and contact details of two professional referees, one of whom must be the applicant's current or most recent employer (or educational institution if no 		employment history).

4.4 Shortlisting:
Shortlisting will be conducted by at least two individuals, both of whom will have completed safer recruitment training.
The shortlisting process will objectively assess candidates against the person specification, identifying any 	inconsistencies or gaps in employment history or other information that may need to be explored at interview.
4.5 References:
References will always be sought directly from the referees prior to interview for shortlisted candidates.
Reference requests will specifically ask about: 
The applicant's suitability to work with children.
Any disciplinary investigations or sanctions relating to children.
Any concerns about the applicant's behaviour.
References will be carefully scrutinised for any inconsistencies or areas that require further clarification. Any negative or concerning information will be thoroughly investigated.
If a reference is not received prior to 	interview, the interview will proceed but no offer of employment will be made until satisfactory references are obtained.
4.6 Interview Process:
All interviews will be conducted by a 	panel of at least two individuals, both of whom have completed safer recruitment training.
Interviews will include open, competency-based, and probing questions designed to: 
Assess the candidate's skills, experience, and suitability for the role.
Explore any anomalies or gaps identified in the application form or references.
Specifically assess the candidate's understanding of and commitment to safeguarding and child protection.
Include a question about the candidate's past conduct or behaviour, including any disciplinary action or 	sanctions related to children.

Candidates will be given the opportunity to clarify any information or concerns raised during the interview.
4.7 Pre-Appointment Checks (Essential for all successful candidates):
No offer of employment will be confirmed, and no individual will commence work (paid or unpaid) until all of the following checks have been completed and deemed satisfactory:
Enhanced Disclosure and Barring Service 	(DBS) check (including Barred List check): 	This will be obtained for all roles involving regulated activity. The check will identify any convictions, cautions, warnings, or reprimands, and whether the individual is on the children's barred list.
Identity Check: Verification of the applicant's identity (e.g., passport, driving licence, birth certificate).
Right to Work in the UK Check: Verification of eligibility to work in the UK (e.g., passport, 	visa).
Professional Qualifications Check: Verification of relevant qualifications (e.g., teaching 	qualifications, social work qualifications) with the issuing body where appropriate.
Prohibition from Teaching Check (for teaching roles): Verification with the Teaching Regulation Agency (TRA) for any prohibition orders.
Overseas Checks (where applicable): For applicants who have lived or worked outside the UK, additional checks will be conducted to ensure they are suitable to work with 	children, proportionate to the time spent overseas and the risk assessment. This may include obtaining a certificate of good conduct from the relevant embassy or police force.
Section 128 check (for management roles in independent schools/APs): 	Verification that individuals in leadership/management positions are not prohibited from being involved in the management of an independent school/AP.
Health Declaration: 	A satisfactory health declaration to ensure the individual is fit to 	undertake the role, with reasonable adjustments made where necessary under the Equality Act.
Satisfactory References: 	Confirmation that two satisfactory professional references have been received and verified (as per section 4.5).
Childcare Disqualification Check (for relevant roles): Where applicable, a check to ensure staff are not disqualified from working with children (e.g., in early years or childcare roles).
4.8 Single Central Record (SCR):
A Single Central Record will be maintained for all staff, including temporary staff, volunteers, and those 	working for external agencies.
The SCR will record that the essential pre-appointment checks have been completed, verified, and dated. It will include: 
Identity checks
Right to work checks
Enhanced DBS check (including children's 	barred list check)
Prohibition from teaching check (where applicable)
Section 128 check (where applicable)
Childcare Disqualification check (where applicable)
Qualifications check
References (confirmation of satisfactory receipt)
Any relevant overseas checks

5. Induction and Probation
All new staff will undergo a thorough 	induction process, which will include comprehensive safeguarding training and a clear understanding of the provision's safeguarding 	policies and procedures.
All new appointments will be subject to a probationary period, during which performance and conduct, including safeguarding responsibilities, will be closely monitored.
Regular supervision and support will be provided during the induction and probationary periods.
6. Recruitment of Agency Staff and Contractors
We will only use reputable employment agencies or supply companies who are able to confirm that their vetting procedures meet or exceed those required by this policy and 	statutory guidance.
Written agreements will be in place with agencies, clearly outlining their responsibilities for conducting all necessary pre-appointment checks.
For individual contractors working on site, the Head of Provision will assess the level of supervision required and ensure that appropriate DBS checks are conducted if they will be working unsupervised with pupils.

7. Volunteers
All volunteers who will have regular contact with pupils will be subject to the same pre-appointment checks as paid staff, including an enhanced DBS check.
Volunteers will receive appropriate safeguarding training and a clear induction.
Casual or one-off visitors who are supervised at all times by a member of staff may not require a DBS check. This will be determined by a risk assessment.

8. Managing Allegations Against Staff and Volunteers
Any allegations or concerns about staff or 	volunteer conduct towards a child will be dealt with immediately and in accordance with our Safeguarding and Child Protection Policy and 	statutory guidance.
The Head of Provision will immediately refer any allegations that meet the criteria for a referral to the Local Authority Designated Officer (LADO).
The Head of Provision will notify the DBS and the Teaching Regulation Agency (TRA) where appropriate.

9. Data Protection
All personal information obtained during the recruitment process will be handled in accordance with the 	General Data Protection Regulation (GDPR) and the Data Protection 	Act 2018.
Information will be stored3  securely and retained only for as long as necessary, as outlined in 	the provision's Data Retention Policy.

10. Policy Review
This policy will be reviewed annually by the Head of Provision, or sooner if there are changes in legislation, guidance, or the provision's operational practices.
Records of all reviews will be maintained.

Appendix 1: Summary of Pre-Appointment Checks (Example)
Check Type
Purpose
Timing
Recorded 	on SCR
Application Form
Information on employment history, qualifications, gaps, and declarations.
Received pre-shortlisting
N/A
References (x2)
Assessment of suitability, past conduct, disciplinary issues.
Prior to interview
Yes
Interview
Assess suitability, explore gaps, test safeguarding commitment.
Post-shortlisting
N/A
Enhanced DBS Check (with Barred List)
Identify criminal records, suitability to work with children.
Pre-employment offer
Yes
Identity Verification
Confirm applicant's identity.
Pre-employment offer
Yes
Right to Work in UK
Confirm legal right to work.
Pre-employment offer
Yes
Qualifications Verification
Confirm stated qualifications.
Pre-employment offer
Yes
Prohibition from Teaching (TRA)
Ensure not prohibited from teaching.
Pre-employment offer
Yes
Section 128 Check (management roles)
Ensure not prohibited from managing an independent school/AP.
Pre-employment offer
Yes
Overseas 	Checks (if applicable)
Assess suitability based on overseas experience.
Pre-employment offer
Yes
Health Declaration
Confirm fitness for role (with reasonable adjustments).
Pre-employment offer
N/A
Childcare 	Disqualification (if applicable)
Confirm not disqualified from childcare roles.
Pre-employment offer
Yes

Question 7

Child Protection and Safeguarding Policy

Accepted Answer

Child Protection and Safeguarding Policy
Dated: 1st September 2025
Review Date: 1st September 2026
Policy Lead: Tracie Daly, DSL 
Approved by: Mark Aitken, Head of Provision  
1. Statement of Intent
ElevatEd AP Ltd is committed to safeguarding and promoting the welfare of all children and young people. We believe that all children have the right to be safe, to feel safe, and to thrive in an environment where their welfare is paramount. This policy applies to all staff, volunteers, and any other adults working on behalf of ElevatEd, and is underpinned by the principle that safeguarding is everyone's responsibility.
2. Guiding Principles
Child-Centred Approach: 	We will always act in the best interests of the child.
Prevention: We will take proactive steps to prevent harm to children.
Protection: We will respond robustly and effectively to concerns about child abuse or neglect.
Partnership: We will work collaboratively with parents/carers, local authorities, and other agencies to safeguard children.
Confidentiality (with limits): Information will be shared on a "need to know" basis, always prioritising the child's safety.
Transparency: Our procedures will be clear and accessible.
3. Scope and Definitions
Scope: This policy applies to all children and young people attending 	ElevatEd, regardless of age, ability, gender, race, religion, sexual orientation, or background. It covers all activities undertaken by 	ElevatEd, both on and off-site.
Child Protection: Protecting children from maltreatment; preventing impairment of 	children's health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.
Safeguarding: 	Encompasses child protection alongside the broader aim of promoting 	the welfare of children. This includes protecting children from maltreatment, preventing harm to children's health or development, 	ensuring children grow up with safe and effective care, and taking action to enable all children to have the best outcomes. It also includes protecting children from radicalisation, exploitation, online abuse, and other forms of harm.
Abuse Categories: (Briefly define, referencing "Working Together to Safeguard Children"): Physical Abuse, Emotional Abuse, Sexual Abuse, Neglect.
Harmful Sexual Behaviour: Differentiate between HSB in children and adults.
Contextual Safeguarding: Understanding how extra-familial contexts (e.g., peer groups, 	schools, online environments) can contribute to harm.
Child Sexual Exploitation (CSE), Child Criminal Exploitation (CCE), Modern Slavery/Trafficking, FGM, Forced Marriage, Honour-Based Abuse, Online Safety, Radicalisation (PREVENT 	Duty).
Looked After Children (LAC) and Children with Special Educational Needs and Disabilities (SEND): Recognition of increased vulnerability and specific considerations.
4. Roles and Responsibilities
Designated Safeguarding Lead (DSL):

Name: Tracie Daly
Contact:tracie@elevate-ed.co.uk
Deputy DSLs: Mark Aitken 
Responsibilities:
Acting as the first point of contact for all staff regarding safeguarding concerns.
Liaising with the local authority 	children's social care and other agencies.
Ensuring staff are aware of their responsibilities and reporting procedures.
Maintaining confidential records of safeguarding concerns.
Providing advice and support to staff.
Attending relevant training and ensuring deputies are trained to the same level.
Keeping the leadership team/governing body updated on safeguarding matters.
Leading on the implementation and review of this policy.
Supporting referrals to the LADO (Local Authority Designated Officer) for allegations against staff.

All Staff and Volunteers:
Familiarise themselves with this policy and "Keeping Children Safe in Education" (KCSIE).
Identify and report concerns immediately using the established procedures.
Attend regular safeguarding training.
Maintain professional boundaries with children.
Understand the signs of abuse and neglect.
Contribute to a safe and positive environment for children.

Leadership Team:
Ensuring the policy is implemented effectively.
Appointing a suitably trained DSL and deputies.
Ensuring adequate resources are allocated to safeguarding.
Monitoring the effectiveness of 	safeguarding arrangements.
Holding the DSL to account for the effective implementation of the policy.
Ensuring safer recruitment practices are adhered to.

5. Reporting Procedures
How to Report a Concern:
Any member of staff or volunteer who has 	a safeguarding concern must immediately report it to the DSL (or a Deputy DSL if the DSL is unavailable).
Concerns should be reported verbally in the first instance, followed by a written record using the 	designated form (e.g., Concern Recording Form).
Do NOT investigate the concern yourself.
Do NOT promise confidentiality to a child.
Do NOT delay reporting.
DSL's Actions Upon Receiving a Concern:
Assess the nature and seriousness of the concern.
Consult with children's social care if deemed necessary.
Make a referral to children's social care if there is reasonable cause to suspect a child is suffering or likely to suffer significant harm.
Liaise with the police if a crime may have been committed.
Inform parents/carers where appropriate and safe to do so, in consultation with social care.
Maintain accurate, confidential records of all actions taken.
Monitor the welfare of the child following a referral.
Referral to Local Authority Children's Social Care: 
Provide all relevant information, including a clear chronology of events.
Follow local multi-agency referral procedures.
Confirm the referral has been received and actioned.
Allegations Against Staff and 	Volunteers: 
Any allegation or concern that a staff member or volunteer has: 
Behaved in a way that has harmed a child, or may have harmed a child.
Possibly committed a criminal offence against or related to a child.
Behaved towards a child or children in a way that indicates they are unsuitable to work with children.
MUST be reported immediately to the Head of ElevatEd (or LADO if the 		allegation is against the Head).
The Head will then contact the Local 	Authority Designated Officer (LADO) 		within one working day.
DO NOT investigate the allegation internally.
DO NOT interview the child or adult involved.
Follow LADO guidance explicitly.

Whistleblowing:
ElevatEd has a clear whistleblowing policy to enable staff to raise concerns about poor practice or potential wrongdoing, including safeguarding issues, without fear of reprisal. This should be a separate, but referenced, policy.

6. Safer Recruitment
ElevatEd is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment.
Rigorous recruitment procedures are in place to deter, identify, and reject applicants who are unsuitable to work with children. This includes:

Robust application forms that require full employment history and explanations for gaps.
At least two professional references that are sought directly from the referee.
Enhanced DBS checks (including barred list checks) for all staff and regular volunteers.
Identity verification.
Verification of qualifications and right to work.
Checks for any overseas criminal history if applicable.
Understanding and challenging interview questions about safeguarding.
A single central record (SCR) of all required checks.

7. Training and Awareness
All staff and volunteers will receive regular, up-to-date safeguarding training at least annually.
The DSL and Deputy DSLs will undertake more in-depth training every two years and refresh their knowledge annually.
Training will cover: 
Understanding different forms of abuse and neglect.
Recognising the signs of harm.
Reporting procedures.
Online safety risks.
Prevent duty awareness.
Contextual safeguarding.
Professional boundaries.
Specific vulnerabilities (e.g., LAC, SEND).
The content of KCSIE and "Working Together to Safeguard Children."

8. Online Safety and Digital Safeguarding
ElevatEd recognises the importance of online safety and the risks children face online.
Policies and procedures for: 
Safe and responsible use of technology within ElevatEd.
Filtering and monitoring systems on all school devices and networks.
Educating pupils about online risks (e.g., cyberbullying, online grooming, harmful content).
Responding to and reporting online safety 	incidents.
Guidance for staff on appropriate online conduct and professional boundaries.
Guidance for parents on supporting online safety at home.

9. Managing Behaviour and Physical Intervention
ElevatEd's behaviour policy is intrinsically linked to safeguarding. It promotes a positive, 	supportive environment where children feel safe.
Any physical intervention used will be reasonable, proportionate, and necessary to prevent harm to a child 	or others, or damage to property.
All incidents of physical intervention 	will be recorded and reviewed.
Staff are trained in de-escalation techniques.

10. Prevent Duty
ElevatEd has a duty under the Counter-Terrorism and Security Act 2015 to have due regard to the need to prevent people from being drawn into terrorism (the Prevent Duty).
Staff receive training on how to identify children who may be vulnerable to radicalisation and know how to refer concerns.
This is integrated into our safeguarding procedures.
11. Working with External Agencies and Parents
Inter-agency Working: ElevatEd is committed to working effectively with Children's Social 	Care, police, health services, and other relevant agencies to safeguard children.
Information Sharing: Information will be shared appropriately and legally, following the 	principles of "Working Together to Safeguard Children" and GDPR, always prioritising the child's safety.
Parental Engagement: ElevatEd aims to work in partnership with parents/carers. We will:

Inform parents/carers of our safeguarding policy.
Discuss concerns with parents/carers where appropriate and safe to do so.
Provide support and signposting to external agencies where needed.
Maintain confidentiality but understand that confidentiality cannot be promised if a child is at risk of harm.

12. Monitoring, Evaluation, and Review
This policy will be reviewed annually, or sooner if there are changes in legislation, statutory guidance, or internal procedures.
The DSL will provide regular reports to the leadership team/governing body on safeguarding activity, including:

Number and type of concerns raised.
Referrals made to children's social care/LADO.
Training undertaken.
Any emerging trends or risks.
Regular audits of safeguarding practices will be conducted.

13. Related Policies (to be read in conjunction with this policy):
Behaviour Policy
E Safety Policy
Whistleblowing Policy
Staff Code of Conduct
SEND Policy
Health and Safety Policy
Complaints Policy
Safer Recruitment Policy
Data Protection Policy

Question 8

Absence Management and Reporting Procedures

Accepted Answer

Absence Management and Reporting Procedures
Dated: 1st September 2025
Review Date: 1st September 2026
Policy Lead & Approved by: Mark Aitken, Head of Provision

1. Statement of Intent
Regular attendance is vital for young people to benefit fully from ElevatEd’s programmes. Absence can disrupt learning, hinder progress, and increase the risk of social exclusion.
ElevatEd is committed to:
Promoting high attendance and punctuality.
Identifying barriers to attendance early.
Working with parents, carers, schools, and agencies to overcome difficulties.
Ensuring absence is monitored, recorded, and followed up consistently.

2. Guiding Principles
Every Day Counts: Every session missed reduces learning opportunities.
Early Intervention: Attendance issues are identified and addressed quickly.
Transparency: Procedures for reporting and managing absence are clear to 	parents/carers.
Collaboration: Attendance is everyone’s responsibility – staff, students, parents, and schools.
Supportive Approach: We aim to understand and address the reasons behind absence, not 	simply record it.

3. Scope
This policy applies to all students enrolled at ElevatEd. It covers:
Daily attendance and punctuality.
Reporting of absence by 	parents/carers.
Procedures for unauthorised 	or unexplained absence.
Partnership working with 	commissioning schools and local authorities.
4. Roles and Responsibilities
Parents/Carers:
Ensure their child attends every day, on time.
Notify ElevatEd of absence by 8.30am on the first day (telephone/email).
Provide reasons for absence and supporting evidence (e.g., medical note) if required.
Students:
Attend every day unless too unwell or prevented by exceptional circumstances.
Arrive on time, ready to learn.
Take responsibility for catching up on missed work.
Staff:
Accurately record attendance each session.
Follow up unexplained absences promptly.
Provide support and 	encouragement to improve attendance.
Attendance Lead/Head of Provision:
Monitor attendance data weekly.
Lead meetings with parents/carers where concerns arise.
Liaise with commissioning schools and agencies regarding persistent absence.
Report patterns and concerns to the Head of Provision.

5. Procedures
Flowchart: Reporting and Managing Absence
Step 1: Parent/Carer Reports Absence
Call/email ElevatEd before 8.30am.
Give reason for absence (illness, appointment, etc.).
Step 2: Absence Recorded
Staff record on the attendance register.
 “Authorised” or “Unauthorised” coded in line with DfE guidance.
Step 3: No Contact from Parent/Carer
Attendance team contacts parent/carer by phone.
If no response, text/email sent.
Home visit may be arranged if absence persists or safeguarding concerns arise.
Step 4: Monitoring Patterns
Attendance Lead reviews weekly data.
Patterns of lateness/absence identified.
Step 5: Escalation for Persistent Absence
Parent/carer meeting arranged.
Support plan agreed 	(mentoring, timetable adjustment, therapeutic support).
Commissioning school informed.
Step 6: Continued Persistent Absence
Referral to external agencies (e.g., Early Help, Education Welfare).
Formal attendance panel may be convened.
In extreme cases, legal action is considered (via local authority).
6. Authorised vs Unauthorised Absence
Authorised absence: illness, medical/dental appointment (proof may be required), 	religious observance, exceptional family circumstances (agreed in advance).
Unauthorised absence: holidays during term time, lateness after registers close, absence 	with no explanation or without valid reason.
7. Persistent Absence (PA)
A student is classified as PA if attendance falls below 90%.
ElevatEd will intervene swiftly, with parental meetings and multi-agency involvement if 	needed.
8. Monitoring, Evaluation, and Review
Attendance data monitored weekly by Attendance Lead.
Termly reports shared with Trustees and commissioning schools.
Annual review of policy or earlier if statutory guidance changes.
9. Related Policies
Behaviour Policy
Child Protection and 	Safeguarding Policy
Fixed-Term and Permanent Exclusion Policy
Code of Conduct
Data Protection and 	Information Management Policy

Question 9

Anti-Bullying Policy

Accepted Answer

Anti-Bullying Policy
Dated: 1st September 2025
 Review Date: 1st September 2026
 Policy Lead: DSL and Head of Provision
 Approved by: Head of provision
1. Statement of Intent
ElevatEd AP Ltd is committed to creating an environment free from bullying, where every learner feels safe, respected, and valued.
2. Guiding Principles
Zero Tolerance: Bullying of any kind will not be tolerated.
Prevention: Promote respect, inclusion, and positive behaviour.
Support: Victims and perpetrators offered appropriate support.
3. Scope and Definitions
Bullying: Behaviour intended to hurt, intimidate, or humiliate, repeated over 	time.
Forms of Bullying: Physical, verbal, cyber, relational, discriminatory.
4. Roles and Responsibilities
DSL: Leads anti-bullying initiatives and monitors incidents.
All Staff: Recognise, intervene, and report bullying.
Learners: Encouraged to report bullying.
5. Procedures
Reporting: Bullying reported to DSL or staff.
Response: Investigate promptly, record incident, take action.
Support: Victims supported; perpetrators educated and sanctioned where 	needed.
6. Training and Awareness
Annual anti-bullying training for staff.
Awareness campaigns with learners.
7. Monitoring, Evaluation, and Review
Regular analysis of incident data.
Annual policy review.
8. Related Policies
Behaviour Policy
Safeguarding Policy
E-Safety Policy

Question 10

Health & Safety Policy

Accepted Answer

Health & Safety Policy
Date: 1st September 2025
Review Date: 1st September 2026
Approved by: Mark Aitken, Head of Provision

1. Statement of Intent
ElevatEd AP Ltd is committed to providing a safe and healthy environment for all its pupils, staff, visitors, and contractors. We recognise our legal and moral obligations to ensure the health, safety, and welfare of everyone on our premises and during off-site activities. This policy outlines our commitment to preventing accidents, injuries, and ill-health, and to fostering a positive health and safety culture.
This policy will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and the specific needs of our provision.

Signed: Mark Aitken	 Date:  01.09.25	 Review 01.09.26

Mark Aitken - Head of Provision

2. Responsibilities for Health and Safety (Mark Aitken, Head of Provision) 
The ultimate responsibility for health and safety within ElevatEd rests with Mark Aitken
They will:
Ensure adequate resources (financial, human, and time) are allocated to health and safety.
Appoint a competent person(s) to assist in meeting health and safety obligations.
Monitor the effectiveness of the health and safety policy and procedures.
Receive regular reports on health and safety performance.
Ensure compliance with all relevant legislation and guidance.
The Head of Provision is responsible for the day-to-day implementation and monitoring of this policy. They will:
Ensure that all staff are aware of their health and safety responsibilities and are provided with necessary training.
Oversee the completion of risk assessments and the implementation of control measures.
Investigate accidents and incidents and implement corrective actions.
Ensure effective communication and consultation on health and safety matters.
Liaise with external bodies such as the HSE, Local Authority, and Ofsted regarding health and safety.
2.1 Staff (All Employees)
All staff members have a legal and moral responsibility to:
Take 	reasonable care of their own health and safety and that of others who may be affected by their acts or omissions.
Co-operate with management on health and safety matters.
Report any health and safety concerns, hazards, or defects to the Head of 	Provision/Manager immediately.
Adhere to all health and safety policies, procedures, and instructions.
Use 	equipment and materials in accordance with training and instructions.
Participate in health and safety training as required.
2.2 Pupils
Pupils are expected to:
Take 	reasonable care of their own health and safety and that of others.
Follow all health and safety instructions given by staff.
Report any concerns or hazards to a member of staff.
Behave in a manner that does not endanger themselves or others.
2.3 Visitors and Contractors
Visitors and contractors are expected to:
Adhere to the health and safety rules and procedures of ElevatEd.
Report to reception upon arrival and follow signing-in procedures.
Familiarise themselves with emergency procedures.
Ensure their work practices do not create hazards for others.
Provide evidence of their own health and safety competence and risk assessments where applicable.
3. Arrangements for Health and Safety
3.1 Risk Assessment
We will conduct regular and suitable and sufficient risk assessments for all significant activities, premises, and equipment.
Risk assessments will identify hazards, assess the level of risk, and determine appropriate control measures.
Specific risk assessments will be undertaken for:
Educational activities, including practical subjects (e.g., workshops, art, science)
Off-site visits and activities
Individual 	pupils with specific needs (e.g., medical conditions, challenging 	behaviour, SEND)
New 	equipment or substances
Contractor activities
Fire 	safety
First 	aid
Manual handling
Slips, trips, and falls
Management of asbestos (if applicable)
Control of Substances Hazardous to Health (COSHH)
Work-related stress
Risk 	assessments will be reviewed annually or sooner if there are significant changes, incidents, or new information.
Staff involved in the activities being assessed will be consulted during the risk assessment process.
3.2 Fire Safety
A comprehensive fire risk assessment will be conducted and regularly reviewed by a competent person.
Firefighting equipment will be maintained and regularly inspected.
Emergency lighting and exit routes will be clearly marked and kept clear at 	all times.
Regular fire drills will be conducted, and evacuation procedures will be clearly displayed and communicated to all pupils and staff.
All staff will receive appropriate fire safety training, including the use of firefighting equipment.
Specific arrangements will be made for the evacuation of individuals with mobility issues or other special needs.
3.3 First Aid and Medical Needs
We 	will provide adequate first aid equipment and facilities, proportionate to the number of pupils and staff.
A sufficient number of trained and qualified first aiders will be available during operational hours.
An appointed person will be designated to oversee first aid arrangements when a first aider is unavailable.
Individual 	healthcare plans will be developed for pupils with specific medical conditions, detailing their needs and how they will be met.
All 	incidents requiring first aid will be recorded in a first aid log.
Parents/carers 	will be informed of any significant first aid incidents.
3.4 Accident and Incident Reporting (RIDDOR)
All 	accidents, near misses, and dangerous occurrences will be reported 	immediately to the Head of Provision.
Serious  accidents, occupational diseases, and dangerous occurrences will be 	reported to the Health and Safety Executive (HSE) under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) by the Proprietor/Head of Provision as the 	employer.
An internal accident investigation process will be implemented to identify root causes and prevent recurrence.
Records 	of all accidents and incidents will be maintained.
3.5 Safeguarding and Child Protection
This 	Health and Safety Policy works in conjunction with our comprehensive 	Safeguarding and Child Protection Policy.
All staff are trained in safeguarding procedures and understand their responsibilities to protect children from harm.
Appropriate vetting and DBS checks are carried out for all staff and volunteers 	in accordance with "Keeping Children Safe in Education" guidance.
Clear procedures are in place for reporting any concerns about a pupil's welfare.
3.6 Premises and Equipment
Regular inspections of the premises and equipment will be carried out to ensure they are safe and well-maintained.
Any 	defects or hazards identified will be promptly rectified.
All equipment will be used, maintained, and stored in accordance with manufacturer's instructions and relevant safety standards.
Portable 	Appliance Testing (PAT) will be conducted regularly on electrical 	equipment.
Adequate 	ventilation, heating, and lighting will be maintained.
Floors and walkways will be kept clear, clean, and in good condition to prevent slips, trips, and falls.
Play 	areas (if applicable) will be regularly inspected for hazards and maintained to a safe standard, with appropriate surfacing.
3.7 Control of Substances Hazardous to Health (COSHH)
A COSHH assessment will be carried out for any hazardous substances 	used or stored on the premises (e.g., cleaning materials, art 	supplies).
Control measures will be implemented to minimise exposure to hazardous substances, including proper storage, labelling, personal protective equipment (PPE), and safe disposal.
Staff will receive training on the safe handling and use of hazardous 	substances.
3.8 Educational Visits and Off-Site Activities
All educational visits and off-site activities will be thoroughly risk-assessed, considering the specific needs of the pupils 	involved.
Appropriate supervision ratios will be maintained.
Staff leading visits will be competent and suitably trained.
Emergency procedures for off-site activities will be clearly established and 	communicated.
Parents/carers will be informed and provide consent for participation in off-siteactivities.
3.9 Manual Handling
Manual handling tasks will be assessed to identify and minimise risks of injury.
Where manual handling cannot be avoided, appropriate training and equipment will be provided to staff.
3.10 Lone Working
Risks associated with lone working will be assessed, and appropriate 	control measures will be put in place to ensure staff safety (e.g., communication systems, regular check-ins).
3.11 Contractors
All contractors working on the premises will be required to demonstrate 	their competence and provide risk assessments and method statements before commencing work.
Contractors will be made aware of our health and safety procedures.
3.12 Emergency Procedures
Clear emergency procedures are in place for:
Fire evacuation
Medical emergencies
Lockdown procedures (e.g., in response to an external threat)
Bomb threats
Intruder alerts
These procedures will be communicated to all staff and pupils and practiced regularly.
4. Training and Information
All staff will receive induction training covering essential health and 	safety information, including emergency procedures and their responsibilities.
Specific health and safety training will be provided to staff based on their roles and responsibilities (e.g., first aid, fire warden, COSHH, manual handling, safeguarding).
Information on health and safety performance and relevant updates will be 	regularly communicated to staff.
5. Monitoring and Review
The effectiveness of this policy and associated procedures will be monitored through:
Regular health and safety inspections and audits of the premises and 	activities.
Review of accident and incident reports.
Feedback 	from staff and pupils.
External inspections (e.g., Ofsted, Local Authority, HSE).
This 	policy will be formally reviewed at least annually by ElevatEd’s leadership team. Any necessary amendments will be made and 	communicated.

6. Consultation
We will consult with staff on health and safety matters, fostering an open dialogue to identify and address concerns. This may be through staff meetings, dedicated health and safety representatives, or direct communication.

Appendix 1: Key Legislation and Guidance

Health and Safety at Work etc. Act 1974
Management of Health and Safety at Work Regulations 1999
Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 	(RIDDOR)
Control of Substances Hazardous to Health Regulations 2002 (COSHH)
Fire 	Safety Order 2005 (Regulatory Reform (Fire Safety) Order 2005)
Health and Safety (First Aid) Regulations 1981
Manual Handling Operations Regulations 1992
Working at Height Regulations 2005
The 	Education (Independent School Standards) Regulations 2014 (if 	registered as an independent school)
Department for Education (DfE) guidance: "Health and Safety: Responsibilities and duties for schools"
DfE 	guidance: "Keeping Children Safe in Education"
Health and Safety Executive (HSE) guidance for education settings.

Question 11

Risk Assessment Policy

Accepted Answer

Risk Assessment Policy
1. Statement of Intent
ElevatEd AP Ltd is committed to providing a safe and healthy environment for all its pupils, staff, visitors, and contractors. We recognise that effective risk management is fundamental to achieving this commitment. This policy outlines our systematic approach to identifying hazards, assessing risks, and implementing control measures to minimise the likelihood of harm or ill-health.
We believe that a proactive approach to risk assessment is essential for preventing accidents, injuries, and work-related ill-health, and for ensuring the well-being of everyone involved with our provision.
This policy will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and the specific needs and activities of our provision.
Signed: Mark Aitken                                 Date: 01.09.25  			Review: 01.09.26
Mark Aitken

2. Principles of Risk Assessment
Our risk assessment process is based on the following key principles:
Proactive 	Identification: Identifying 	potential hazards before they cause harm.
Suitability and Sufficiency: Risk assessments will be 'suitable and sufficient', meaning they are proportionate to the risk, identify who might be harmed and how, evaluate risks, and identify appropriate control measures.
Competence: Risk assessments will be conducted by competent persons with the necessary knowledge, experience, and training.
Consultation: Staff who are directly involved in the activity or area being assessed will be consulted.
Prioritisation: Higher risks will be prioritised for action.
Control Measures: Emphasis on eliminating hazards where possible, or reducing risks to the lowest reasonably practicable level.
Documentation: Significant findings of risk assessments will be recorded.
Review: Risk assessments will be regularly reviewed and updated.
3. Definitions
Hazard: Something with the potential to cause harm (e.g., electricity, chemicals, working at height, challenging behaviour).
Risk: The likelihood that harm will occur from a hazard, and the severity of that harm (e.g., low, medium, high).
Risk 	Assessment: A careful examination of what could cause harm to people in our provision, so that you can weigh up whether you have taken enough precautions or should do more to prevent harm.
Control Measure: Action taken to eliminate a hazard or reduce the risk to an acceptable level.
4. Roles and Responsibilities for Risk Assessment
4.1 Head of Provision:
Overall responsibility for ensuring that suitable and sufficient risk assessments are carried out.
Ensuring 	adequate resources are made available for risk management.
Receiving 	reports on significant risks and overall risk management performance.
Monitoring compliance with this policy.
Responsible for ensuring that risk assessments are undertaken, reviewed, and acted upon across the provision.
Identifying and appointing competent persons to undertake risk assessments.
Ensuring 	staff are aware of identified risks and control measures relevant to their roles.
Reviewing significant risk assessments and approving control measures.
Ensuring 	that identified actions from risk assessments are implemented.
Maintaining a register of risk assessments.
4.2 Staff (All Employees):
Taking reasonable care for their own health and safety and that of others.
Co-operating with risk assessment processes and adhering to control measures.
Reporting any new hazards, defects, or concerns immediately to the Head of Provision.
Participating in risk assessment training as required.
4.3 Competent Person(s) for Risk Assessment:
Individual(s) appointed by the Head of Provision who have the necessary knowledge, 	experience, and training to conduct risk assessments effectively. This may include the Head of Provision, specific departmental leads (e.g., Workshop Lead, Science Lead), or external consultants for specialist areas.
5. The Risk Assessment Process (The 5 Steps to Risk Assessment)
Risk assessments at ElevatEd will follow the Health and Safety Executive (HSE) five-step process:
Step 1: Identify the Hazards
Look for things that could cause harm.
Consider 	all areas, activities, and equipment within the provision (e.g., classrooms, workshops, outdoor areas, specific lessons, break times, off-site visits, manual handling, cleaning chemicals, challenging behaviour).
Think about non-routine activities and emergencies.
Consult accident and incident records.
Listen to staff and pupil concerns.
Step 2: Decide Who Might Be Harmed and How
Consider 	all groups of people: pupils (including those with SEND or specific vulnerabilities), staff (including new, young, or pregnant workers), visitors, contractors.
Think about how they might be harmed (e.g., falls, cuts, burns, allergic reactions, stress, injuries from challenging behaviour).
Step 3: Evaluate the Risks and Decide on Precautions
Assess the likelihood of harm occurring (e.g., unlikely, possible, likely) and the severity of the potential harm (e.g., minor injury, major injury, fatality). This helps determine the risk level (e.g., low, medium, high).
Determine if existing control measures are adequate or if more needs to be 	done.
Apply the 'Hierarchy of Control Measures' (in order of preference):

Eliminate the hazard: Can the hazard be removed entirely?
Substitute: Can a less hazardous alternative be used?
Engineering Controls: Can physical changes be made (e.g., guards on machinery, ventilation)?
Administrative 	Controls: Can safe working procedures be put in place (e.g., training, supervision, rotation of tasks, clear rules)?
Personal 	Protective Equipment (PPE): Can PPE be provided (e.g., gloves, safety glasses) as a last resort? (This should never be the sole control measure).

Step 4: Record Your Significant Findings
Forall significant hazards, record: 
The 	hazard and who might be harmed.
What you are already doing to control the risk.
What further actions are needed to control the risk.
Who is responsible for completing these actions.
The deadline for completion.
Risk 	assessments will be documented using the provision's risk assessment form
Step 5: Review the Assessment and Update if Necessary
Risk 	assessments will be reviewed: 
At least annually.
When there are significant changes to activities, equipment, or the environment.
Following 	an accident, incident, or near-miss.
If new information about a hazard becomes available.
If there are changes in legislation or guidance.
The 	review process will involve checking if the control measures are still effective and if any new hazards have emerged.
6. Types of Risk Assessments
ElevatEd will undertake risk assessments for:
General Premises Risk Assessments: Covering common areas such as classrooms, corridors, offices, welfare facilities, outdoor spaces.
Activity-Specific Risk Assessments: For all educational activities, including: 
Practical subjects (e.g., art, design technology, science, cooking).
Physical  education and sports.
Sensory rooms or specific learning environments.
Breaks and unstructured time.

Off-Site Activities and Educational Visits: Detailed risk assessments will be completed for all off-site visits, considering transport, location-specific hazards, supervision, and individual pupil needs.
Individual Pupil Risk Assessments: For pupils with specific needs that may pose a risk to themselves or others (e.g., challenging behaviour, complex medical needs, mobility issues, allergies, tendencies for self-harm or absconding). These will be developed in collaboration with parents/carers and relevant professionals, and regularly reviewed.
COSHH Assessments: For all hazardous substances used or stored on the premises (e.g., cleaning materials, art supplies, workshop materials).
Fire 	Risk Assessments: A comprehensive assessment of fire hazards and risks, required under he Regulatory Reform (Fire Safety) Order 2005.
Manual Handling Assessments: For any tasks involving lifting, carrying, pushing, or pulling that could cause injury.
Work at Height Assessments: For any work carried out at height (e.g., changing lightbulbs, working on ladders).
Specific 	Event Risk Assessments: For one-off events such as open days, performances, or special projects.
7. Training and Competence
All staff involved in conducting risk assessments will receive appropriate training to ensure they are competent in identifying hazards, assessing risks, and determining control measures.
All staff will receive induction training covering significant risks within the provision and the control measures relevant to their roles.
Specific training will be provided where required (e.g., manual handling, first aid, fire safety, management of challenging behaviour).
8. Communication of Risk Information
Significant findings from risk assessments, and the control measures required, will be communicated to all relevant staff.
This 	may be done through staff meetings, training sessions, clear signage, or direct communication.
Pupils will be made aware of risks relevant to them in an age-appropriate manner, and taught about safe practices.
Information will be shared with parents/carers where appropriate, particularly for individual pupil risk assessments or off-site visits.
9. Monitoring and Review
The 	implementation and effectiveness of risk assessments and control measures will be monitored regularly through:

Routine inspections of the premises and activities.
Review of accident, incident, and near-miss reports to identify recurring issues or new hazards.
Feedback 	from staff and pupils.
Internal and external audits.

The 	Head of Provision will maintain a register of all significant risk assessments, including their review dates.
This 	policy, and the overarching risk management framework, will be 	formally reviewed at least annually by the Head of Provision to ensure its continued suitability and effectiveness.

Appendix 1: Hierarchy of Control Measures
Eliminate: Get rid of the hazard completely (e.g., removing a dangerous piece of equipment).
Substitute: Replace the hazard with a safer alternative (e.g., using non-toxic paints instead of toxic ones).
Engineering Controls: Change the way work is done or design the workplace/equipment to reduce the risk (e.g., installing guards on machinery, improving ventilation).
Administrative 	Controls: Implement safe 	working practices, training, or supervision (e.g., clear rules, rotation of tasks, induction).
Personal 	Protective Equipment (PPE): Provide equipment for individuals to wear (e.g., safety glasses, 	gloves) – this is the last resort and should be used in conjunction with other controls, not instead of them.

Question 12

Code of Conduct

Accepted Answer

Code of Conduct
Dated: 1st September 2025
Review Date: 1st September 2026
Policy Lead and Approved by: Mark Aitken, Head of Provision
1. Statement of Intent
ElevatEd AP Ltd is committed to maintaining the highest standards of integrity, professionalism, and care in all aspects of our provision. Our Code of Conduct sets out the expected behaviours of staff, volunteers, and students to ensure a safe, respectful, and inclusive learning environment.
 This Code supports ElevatEd’s ethos of restorative practice, compassion, and accountability. Breaches of this Code will be taken seriously and dealt with fairly, consistently, and transparently.
2. Guiding Principles
Respect: Treat others with dignity, fairness, and kindness.
Professionalism: Maintain clear boundaries and act as role 	models.
Integrity: Act honestly and responsibly in all interactions.
Safeguarding: Place the safety and wellbeing of students 	first.
Accountability: Accept responsibility for actions and 	decisions.
Equity: Uphold diversity, inclusion, and equal opportunities for all.
3. Scope
This Code applies to:
 All ElevatEd staff and volunteers.
 All students enrolled at ElevatEd.
 Visitors and external partners when engaging on site or in 	ElevatEd-led activities.

4. Expectations for Staff and Volunteers
Professional Conduct:
 Adhere to ElevatEd’s values and policies.
 Maintain professional boundaries (no inappropriate relationships, favouritism, or communication outside agreed channels).
 Dress appropriately for a learning environment.
 Avoid the use of offensive or discriminatory language.
Safeguarding:
 Place the welfare of students above all else.
 Follow the Child Protection and Safeguarding Policy.
 Report any safeguarding concerns immediately to the DSL.
Confidentiality:
 Respect privacy, sharing information only on a need-to-know basis.
 Handle student data in line with Data Protection Policy.
Use of Technology:
 Use ElevatEd devices and systems responsibly.
 Do not engage in personal social media interactions with students.

5. Expectations for Students
Respect:
 Treat peers, staff, and visitors with kindness and fairness.
 Respect property, equipment, and the learning environment.
Responsibility:
 Follow the Behaviour Policy and the 3 R’s (Respect, Responsibility, Readiness).
 Arrive on time, ready to learn.
 Take ownership of actions and decisions.
Safety:
 Behave in ways that ensure safety for self and others.
 Avoid physical or verbal aggression.
 Refrain from bringing prohibited items (weapons, drugs, alcohol).

6. Breaches of the Code
Breaches may include:
 Failure to maintain professional conduct (staff/volunteers).
 Persistent disruption, bullying, or aggression (students).
 Breach of safeguarding protocols.
 Misuse of data, technology, or confidential information.

7. Procedures for Reporting and Responding
Flowchart: Reporting a Breach of the Code
Step 1: Concern Identified

Staff/student/volunteer notices a breach.

Step 2: Immediate Action (if needed)

If risk of harm → intervene to ensure safety.
 Safeguarding concerns → report to DSL immediately.

Step 3: Reporting

Concern reported to line manager/Head of Provision (staff breaches).
 Concern reported to Behaviour Lead/Head of Provision (student breaches).

Step 4: Investigation

Senior leader gathers evidence, meets with those involved.

Step 5: Outcome
Minor breach: restorative conversation, reminder of Code.
Moderate breach: formal meeting, behaviour/professional plan.
Serious breach: disciplinary process (staff) or exclusion process (students).
Step 6: Follow-Up
 Record kept on file.
 Support offered to prevent recurrence.
8. Monitoring, Evaluation, and Review
 Breaches and responses monitored by leadership team.
 Reports shared with Trustees where necessary.
 Annual review of policy and practice.
9. Related Policies
 Behaviour Policy
 Child Protection and Safeguarding Policy
 Fixed-Term and Permanent Exclusion Policy
 Data Protection and Information Management Policy
 Whistleblowing Policy sk is significant (see Exclusion Policy).

Question 13

First Aid and Medical Policy

Accepted Answer

First Aid and Medical Policy
1. Statement of Intent
ElevatEd is committed to providing a safe and healthy environment for all its pupils, staff, and visitors. This policy outlines our procedures for providing first aid in emergencies and for supporting pupils with medical conditions to ensure their full participation in the life of the provision.
We recognise that effective first aid and medical management are fundamental to our safeguarding responsibilities and to promoting the well-being and educational progress of every individual. We are acutely aware that pupils attending ElevatEd may present with a higher prevalence of complex or long-term medical conditions, and our approach is therefore proactive, individualised, and delivered with compassion and competence.
This policy applies to all activities organised by ElevatEd, whether on or off the premises. It will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and the specific needs of our provision and its pupil cohort.
Signed: Mark Aitken    		Date: 01.09.25.  		Review 01.09.26.
Mark Aitken - Head of Provision
2. Legal Framework and Guidance
This policy adheres to:
The Health and Safety (First-Aid) Regulations 1981
The Education Act 1996
The Children Act 1989 and 2004
The Equality Act 2010
The UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018
Department for Education (DfE) guidance: 	"Supporting pupils with medical conditions at school" (2015)
Department for Education (DfE) guidance: 	"Keeping Children Safe in Education" (KCSIE)
Local Authority (Manchester City Council) 	health and safety guidance.

3. Roles and Responsibilities
3.1 The Head of Provision: 
Ensuring the provision has a robust First Aid and Medical Policy.
Ensuring adequate resources (e.g., funding for training, equipment) are available.
Monitoring the effectiveness of the policy 	and ensuring compliance with regulations.
Overall responsibility for the day-to-day implementation and consistent application of this policy.
Undertaking a needs assessment to determine first aid requirements.
Appointing a competent First Aid Co-ordinator.
Ensuring an adequate number of appropriately trained first aiders are available.
Ensuring staff are aware of their responsibilities regarding first aid and supporting medical 	conditions.
Liaising with parents/carers, healthcare professionals, and referring schools regarding individual pupil medical needs.
3.3 First Aid Co-ordinator:
Lead Administrator
Maintaining first aid supplies and equipment, ensuring they are in date and fit for purpose.
Overseeing the training and re-qualification of first aiders.
Maintaining records of first aid incidents and medication administration.
Disseminating relevant medical information to staff on a 'need to know' basis.
Managing Individual Healthcare Plans (IHPs).
3.4 Qualified First Aiders:
Mark Aitken: First Aid at Work L3 - expiry July 2028 
Alexandra Mcloughlin: First Aid at Work L3 - expiry July 2028. Adult Mental Health: Workplace First Aider L3 - expiry March 2027		
Providing immediate and appropriate first 	aid care to pupils, staff, and visitors.
Summoning emergency medical help when necessary.
Accurately recording all first aid 	incidents.
Maintaining their first aid qualification through regular refresher training.

3.5 All Staff:
Understanding and adhering to this policy.
Knowing the location of first aid kits and who the qualified first aiders are.
Being aware of pupils with medical conditions and knowing where to access their IHPs.
Receiving relevant training to support pupils with specific medical conditions (e.g., administering 	auto-injectors).
Reporting any concerns about a pupil's health or well-being to the relevant staff member.
Completing basic first aid training or 	awareness where appropriate.
3.6 Parents/Carers:
Providing the provision with full and up-to-date information about their child's medical conditions, allergies, and medication.
Ensuring medication required at the 	provision is in date and supplied in its original packaging with 	clear dispensing instructions.
Collaborating with the provision and 	healthcare professionals in developing and reviewing IHPs.
Being available or arranging alternative emergency contact if required during the day.
3.7 Pupils:
Taking responsibility for their own health and informing a member of staff if they feel unwell.
Following instructions regarding their medication or medical management.
Understanding and following provision rules regarding health and safety.
4. First Aid Provision
4.1 Needs Assessment:
A comprehensive First Aid Needs Assessment will be conducted annually by the Head of Provision.
This assessment will consider: 
The number of pupils and staff.
The specific medical conditions of pupils and staff.
The nature of activities undertaken (e.g., workshops, physical education, off-site visits).
The layout of the premises and location of different areas.
The proximity to emergency medical 	services.
Any particular hazards identified in risk assessments.

4.2 Qualified First Aiders and Training:
A sufficient number of staff will be trained to at least Emergency First Aid at Work (EFAW) level.
Additional staff may hold full First Aid at Work (FAW) qualifications or specific training for individual medical conditions.
All first aid qualifications will be 	regularly refreshed as per awarding body requirements (e.g., every 3 years for FAW/EFAW/PFA, annual refreshers for specific medical conditions).
4.3 First Aid Facilities and Equipment:
Clearly identifiable and accessible first aid kits will be located throughout the provision at designated points (e.g., reception, staff room, workshops, outdoor areas).
All first aid kits will be appropriately stocked as per HSE guidance and regularly checked by the First Aid Co-ordinator.
A designated first aid room/area will be available for privacy and minor treatment, equipped with a couch, sink, and access to drinking water.
Appropriate personal protective equipment (PPE), such as disposable gloves, will be readily available in all first aid kits.
4.4 Responding to Incidents:
Minor Incidents: Staff will provide basic first aid. All incidents, no matter how minor, will be recorded in the First Aid Log.
Serious Incidents/Emergencies:

The nearest qualified first aider will be called immediately.
If a serious injury or illness is suspected, emergency services (999) will be called without delay.
The Head of Provision/First Aid 	Co-ordinator will be informed immediately.
Parents/carers will be contacted as soon as practicable.
Staff should not move a seriously injured person unless they are in immediate danger.
A senior member of staff will accompany the pupil to the hospital if parents/carers cannot attend immediately.

Recording: All first aid incidents, no matter how minor, will be recorded in the First Aid Log Book. More serious incidents will be fully documented on an accident report form and potentially reported to the HSE under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) if the criteria are met.

5. Managing Medical Conditions
5.1 Individual Healthcare Plans (IHPs):
For pupils with long-term or complex 	medical conditions (e.g., asthma, epilepsy, diabetes, severe allergies, mental health conditions), an Individual Healthcare Plan (IHP) will be 	developed in collaboration with the pupil, parents/carers, relevant healthcare professionals (e.g., GP, school nurse, consultant), and the referring school (for dual-registered pupils).
IHPs will detail: 
The medical condition and its symptoms.
Its impact on the pupil's learning and 	participation.
Triggers and warning signs.
Specific medication to be administered (dose, timing, method).
Emergency procedures and who to contact.
Roles and responsibilities of provision staff, parents, and healthcare professionals.
Storage requirements for medication.
IHPs will be reviewed at least annually, or sooner if there is a change in the pupil's condition, medication, or upon re-entry to the provision after a significant absence.
5.2 Information Sharing and Confidentiality:
Relevant medical information from IHPs will be shared with staff on a 'need to know' basis to ensure the pupil's safety and well-being.
Staff involved in providing care will be fully informed and receive appropriate training.
All medical information will be handled in accordance with the provision's GDPR Policy and data protection principles, maintaining strict confidentiality.
5.3 Administering Medication:
Prescription Medication: 	Will only be administered by designated, trained staff, as agreed in 	an IHP and with written parental consent. Medication must be in its original packaging, clearly labelled with the pupil's name, dosage, and frequency. A record of every dose administered will be kept.
Non-Prescription Medication: 	Generally, the provision will not administer non-prescription 	medication. In exceptional circumstances, parental consent and an assessment of need will be required, and the medication will be stored and administered safely with a record kept.
Self-Administration: 	Pupils may be permitted to self-administer medication (e.g., asthma 	inhalers, EpiPens) if deemed competent to do so in their IHP, but this will be monitored.
Storage of Medication: All medication (except emergency medication like inhalers or 	auto-injectors that need to be immediately accessible) will be stored securely in a locked cabinet, accessible only by authorised staff, and protected from misuse.

5.4 Emergency Procedures for Specific Conditions:
Clear emergency protocols will be in place 	for common severe conditions such as anaphylaxis, severe asthma attacks, and epileptic seizures.
Relevant staff will receive specific training (e.g., administering EpiPens, rescue medication for 	asthma).
Emergency medication will be readily available and accessible to relevant staff.
5.5 Mental Health and Well-being:
While not always requiring direct first aid, the provision recognises that mental health issues can impact a pupil's physical health and require support.
Staff will be trained to identify signs of mental health distress and know how to access appropriate support 	services (internal or external).
For pupils with diagnosed mental health conditions, these may be addressed in their IHP, outlining support strategies.
5.6 Pupils Joining from Other Settings:
For pupils transitioning from other provisions or mainstream schools, robust procedures will be in place to ensure timely and comprehensive transfer of medical information 	and IHPs.
Liaison with the referring school and 	parents/carers will occur prior to entry to ensure all medical needs 	are understood and planned for.
6. Off-Site Activities and Educational Visits
Comprehensive risk assessments for all off-site activities will include detailed first aid and medical arrangements.
An adequate number of appropriately trained first aiders will accompany all visits, and access to necessary medication (e.g., IHPs, EpiPens) will be ensured.
Emergency contact information for all pupils will be readily available to trip leaders.
For overseas visits, appropriate travel insurance and medical advice will be obtained.
7. Infectious Diseases
The provision will follow guidance from the UK Health Security Agency (UKHSA) and local public health authorities (Manchester City Council Public Health) regarding the 	management and prevention of infectious diseases.
Clear procedures for reporting infectious diseases, managing outbreaks, and advising on exclusion periods will be in place.
Emphasis will be placed on good hygiene practices (e.g., handwashing) and maintaining a clean environment.
8. Record Keeping
First Aid Log Book: All first aid incidents, no matter how minor, will be recorded. This 	includes date, time, nature of injury/illness, treatment given, name of first aider, and any follow-up actions.
Accident Report Forms: For more serious incidents, a detailed accident report form will be 	completed.
Medication Administration Records: A clear record will be kept of all medication administered, including pupil's name, medication, dose, date, time, and signature 	of administering staff.
Individual Healthcare Plans (IHPs): Securely stored and regularly updated.
All records will be maintained in 	accordance with the provision's GDPR Policy and Data Retention 	Schedule.
9. Policy Review
This policy will be reviewed annually by the Head of Provision. The review will consider:
Changes in relevant legislation, DfE guidance, or health authority advice.
Lessons learned from first aid incidents or the management of medical conditions.
Feedback from staff, pupils, parents/carers, and healthcare professionals.
The specific and evolving medical needs of the pupil cohort.

Question 14

Fixed-Term and Permanent Exclusion Policy

Accepted Answer

Fixed-Term and Permanent Exclusion Policy
Dated: 1st September 2025
Review Date: 1st September 2026
Policy Lead & Approved by: Mark Aitken, Head of Provision
1. Statement of Intent
ElevatEd AP Ltd is committed to ensuring that exclusions are only used as a last resort when all other interventions have been tried, and where allowing the student to remain would seriously harm the education, welfare, or safety of others.
We aim to:
Keep young people engaged in learning wherever possible.
Apply exclusion fairly, consistently, and lawfully.
Support reintegration and minimise long-term impact.
Work closely with parents, carers, and partner schools.
2. Guiding Principles
Proportionality: Exclusion decisions must be fair, reasonable, and proportionate.
Early Intervention: Supportive strategies will always be explored before exclusion.
Last 	Resort: 	Exclusion is not a punishment but a protective measure.
Transparency:Parents and carers will be informed promptly and fully.
Restoration: Focus on repairing harm and supporting re-engagement.
Equity: Consideration of SEND, safeguarding, and vulnerable groups is central to all decisions.
3. Scope
This policy applies to all students at ElevatEd and covers both:
Fixed-Term Exclusion (temporary removal from ElevatEd for a set number of days).
Permanent Exclusion (permanent removal from ElevatEd, usually with referral to local 	authority or commissioning school).
4. Roles and Responsibilities
Head of Provision/Policy Lead:
Holds authority to issue exclusions.
Ensures exclusions follow statutory guidance.
Reports exclusions to commissioning school and local authority (where required).
Staff:
Record and report serious incidents.
Provide evidence for consideration of exclusion.
Support reintegration following return from exclusion.
Parents/Carers:
Engage with the exclusion process and reintegration meetings.
Support the young person in reflecting on and addressing behaviour.
Students:
Take 	responsibility for their actions.
Participate in restorative and reintegration processes.
Independent Body:
Monitor exclusions for fairness, frequency, and proportionality.
Hear appeals where necessary.

5. Reasons for Exclusion
Exclusions may be considered for:
Serious physical assault.
Threatening or abusive behaviour towards staff or peers.
Possession of weapons, drugs, or illegal substances.
Persistent refusal to engage after multiple interventions.
Serious and sustained disruption to learning.
Any 	act that significantly compromises safety or welfare.

6. Exclusion Process
Flowchart: Exclusion Decision Pathway

Step 1: Serious Incident Occurs

Staff intervene to ensure immediate safety.
Incident logged and reported to leadership.

Step 2: Investigation

Head of Provision/Policy Lead gathers evidence (staff statements, student 	account, CCTV if available).
Consideration 	given to safeguarding, SEND, and personal circumstances.

Step 3: Decision

If exclusion is deemed necessary → Head of Provision authorises.
Type and length determined (Fixed-Term or Permanent).

Step 4: Parent/Carer Informed

Immediate phone call followed by written notification.
Details include reason, length, and appeal rights.

Step 5: Notification

Commissioning school and local authority informed (where required).

Step 6: Reintegration Planning

For fixed-term exclusions → reintegration meeting held on return.
Individual 	Behaviour Plan updated.
Support package agreed (therapeutic work, mentoring, restorative sessions).

Step 7: Appeal/Review
Parents/carers 	may request a review or appeal to the Independent Body.
The 	independent Body may uphold or overturn decision.
7. Reintegration after Fixed-Term Exclusion
A Reintegration Meeting 	will be held with the student, parent/carer, and staff.
Targets will be set through an updated Behaviour Plan.
A restorative conversation will address the harm caused and how to 	repair relationships.
Ongoing 	support (mentoring, therapy, family workshops) will be offered.

8. Permanent Exclusion
Permanent exclusion will only be considered when:
A serious breach of behaviour expectations occurs, AND
Remaining in provision would seriously harm others’ safety, learning, or wellbeing.
The Head of Provision will:
Provide written reasons to parents/carers.
Notify the commissioning school and local authority immediately.
Ensure safeguarding arrangements remain in place until transition.
Parents/carers will be given clear information about appeal rights.

9. Monitoring and Evaluation
All exclusions will be recorded and reviewed termly.
Data will be analysed for patterns (e.g., SEND, gender, ethnicity).
Findings will be reported to the Board of Trustees.
This 	policy will be reviewed annually.

10. Related Policies
Behaviour Policy
Child Protection and Safeguarding Policy
Anti-Bullying Policy
Attendance and Absence Management Policy
Code of Conduct needs of the pupil cohort.

Question 15

Recruitment & Selection Policy (Including Safer Recruitment and DBS Disclosure Process)

Accepted Answer

Recruitment & Selection Policy (Including Safer Recruitment and DBS Disclosure Process)
Date Adopted: 1st September 2025
 Review Date: 1st September 2026
 Policy Lead and Approved by: Mark Aitken, Head of Provision

1. Statement of Intent
ElevatEd AP Ltd is committed to recruiting and selecting staff who share our values and commitment to safeguarding children, young people, and vulnerable adults. Our recruitment and selection procedures are designed to deter, identify, and reject individuals who are unsuitable to work with children. We comply fully with statutory requirements and guidance, including Keeping Children Safe in Education (KCSIE).
2. Guiding Principles
Safeguarding First: Every stage of recruitment prioritises the welfare of children.
Transparency:Recruitment procedures are open, fair, and consistent.
Equality: All candidates are treated fairly and without discrimination.
Accountability: Clear documentation is maintained to evidence decisions.
Compliance: All safer recruitment requirements, including DBS checks, are 	rigorously applied.
3. Scope and Definitions
Scope: Applies to all permanent, temporary, supply, and volunteer roles at 	ElevatEd.
DBS 	Disclosure: A check undertaken by the Disclosure and Barring Service to identify 	criminal records and whether an individual is barred from working with children or vulnerable adults.
Safer Recruitment: A process that reduces the risk of appointing individuals who may 	harm children.

4. Roles and Responsibilities
Head of Provision: Ensures safer recruitment practices are followed and approves final 	appointments.
Designated Safeguarding Lead (DSL): Advises on safeguarding aspects of recruitment, including DBS clearance.
Interview 	Panel: At least one member must be Safer Recruitment trained.
HR/Admin Team: Maintains the Single Central Record (SCR) and verifies all checks.
5. Recruitment and Selection Procedures
Advertising and Applications:
All adverts include safeguarding commitments.
Application forms require full employment history with explanation of gaps.
CVs alone are not accepted.
Shortlisting:
Completed by at least two staff members.
Discrepancies or gaps in employment must be explored.
References:
At least two references are obtained, including the most recent 	employer.
References must be verified and checked for safeguarding concerns.
Interviews:
At least one panel member has completed Safer Recruitment training.
Questions include safeguarding scenarios.
Pre-Employment Checks:
Enhanced  DBS with barred list check.
Identity verification.
Right to work in the UK.
Qualification verification.
Overseas criminal records check (if applicable).
Medical fitness declaration.

DBS Disclosure Process:
All staff and regular volunteers must complete an Enhanced DBS.
Original certificates must be seen by HR/Admin.
Any positive disclosures are risk-assessed by the Head of Provision and DSL.
Staff cannot commence unsupervised work until clearance is obtained.
Single Central Record (SCR):
Maintained securely and regularly audited.
Records all required checks for staff, volunteers, and contractors.
6. Training and Awareness
At least one staff member involved in recruitment will have completed accredited Safer Recruitment training.
All managers involved in recruitment will refresh safer recruitment  knowledge every 3 years.
7. Monitoring, Evaluation, and Review
Policy reviewed annually in line with KCSIE updates.
Audits of recruitment files and SCR conducted termly.
Lessons learned from recruitment processes are documented and used to improve practice.
8. Related Policies
Child Protection and Safeguarding Policy
Staff Code of Conduct
Whistleblowing Policy
Grievance Policy
Inclusion and Equal Opportunities Policy

Question 16

Inclusion, Equal Opportunity, and Protected Characteristics Policy

Accepted Answer

Inclusion, Equal Opportunity, and Protected Characteristics Policy
1. Statement of Intent
ElevatEd AP Ltd is profoundly committed to fostering a vibrant, inclusive, and equitable environment where every individual feels valued, respected, and empowered to reach their full potential. We firmly believe that diversity enriches our community and strengthens our collective educational experience.
This policy reaffirms our unwavering commitment to eliminating unlawful discrimination, promoting equality of opportunity, and fostering good relations among all members of our provision community. We recognise that pupils in Alternative Provisions often have diverse backgrounds, complex needs, and may belong to one or more protected characteristics, making our commitment to inclusion even more critical. We are dedicated to proactively identifying and addressing barriers to participation and success, ensuring that all pupils and staff are treated fairly and with dignity, and that discriminatory behaviours are challenged and rectified.
This policy applies to all pupils, staff (employees, volunteers, contractors, agency staff), parents/carers, visitors, and stakeholders of ElevatEd. It governs all aspects of our provision, including admissions, curriculum, teaching and learning, behaviour management, pastoral care, extra-curricular activities, recruitment, employment practices, and engagement with the wider community.
This policy will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, and the evolving needs of our community.

Signed:Mark Aitken                   Date: 01.09.25		 Review 01.09.26
Mark Aitken

2. Legal Framework and Guidance
This policy is developed in strict accordance with, and commitment to, the following legislation and guidance:
The Equality Act 2010: This is the cornerstone of our policy, prohibiting discrimination on 	the basis of protected characteristics.
Public Sector Equality Duty (PSED): 	As an educational provider, we have a specific duty to:

Eliminate unlawful discrimination, harassment, and victimisation.
Advance equality of opportunity between people who share a protected characteristic and those who do not.
Foster good relations between people who share a protected characteristic and those who do not.

Human Rights Act 1998: Protecting fundamental rights and freedoms.
Special Educational Needs and Disability (SEND) Code of Practice 0-25 Years (2015): 	Guiding our provision for pupils with SEND.
Keeping Children Safe in Education 	(KCSIE): Recognising that 	discrimination, bullying, and a lack of inclusion can be 	safeguarding concerns.
Children Act 1989 & 2004:Upholding the welfare of children.
Education Act 1996: 	Promoting the education of all children.

3. Key Definitions
Equality: Treating people fairly, recognising that everyone has different needs and circumstances, and ensuring that outcomes are fair, not necessarily that everyone is treated the same.
Diversity: 	Recognising and valuing the differences between people, including their varied experiences, characteristics, and perspectives.
Inclusion: 	Ensuring that all individuals feel welcomed, supported, and are able 	to participate fully and without barriers.
Discrimination: Less favourable treatment due to a protected characteristic.

Direct Discrimination: Treating someone less favourably directly because of a protected 	characteristic.
Indirect Discrimination: A provision, criterion, or practice that applies to everyone but 	disadvantages people with a particular protected characteristic, 	and cannot be objectively justified.
Harassment: Unwanted conduct related to a protected characteristic that has the 		purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.
Victimisation: Treating someone less favourably because they have made or 		supported a complaint of discrimination under the Equality Act.
Discrimination arising from Disability: Treating a disabled person unfavourably because of something connected to their disability, where that treatment cannot be justified.

4. Protected Characteristics (Equality Act 2010)
The Equality Act 2010 legally protects people from discrimination based on nine 'protected characteristics':
Age: Prohibits discrimination against people of a certain age group (primarily relevant to staff employment, but also ensuring 	age-appropriate provision for pupils).
Disability: A person has a disability if they have a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. This includes physical disabilities, learning disabilities, mental health 	conditions, and long-term illnesses.
Gender Reassignment: A person is protected if they are proposing to undergo, are 	undergoing, or have undergone a process to reassign their sex.
Marriage and Civil Partnership: Prohibits discrimination against those who are married or in a civil partnership (relevant to staff employment).
Pregnancy and Maternity: Protects women during pregnancy and after childbirth.
Race: Includes colour, nationality, ethnic or national origins.
Religion or Belief: Includes any religion, philosophical belief (e.g., humanism), or 	lack of religion/belief.
Sex: 	Refers to a person being male or female.
Sexual Orientation: Refers to a person's sexual orientation towards people of the same 	sex, opposite sex, or both sexes.
5. Our Commitment
At ElevatEd we commit to:
Eliminating Discrimination: Actively working to prevent and challenge all forms of unlawful 	discrimination, harassment, and victimisation, as defined by the 	Equality Act 2010.
Advancing Equality of Opportunity: 	Taking proactive steps to remove barriers and create opportunities for all pupils and staff, particularly those with protected 	characteristics, to participate and achieve. This includes positive action where appropriate and legally permissible.
Fostering Good Relations: Promoting understanding, respect, and positive relationships between 	people from different backgrounds, including those with different protected characteristics. We will challenge prejudice and 	stereotypes.
Meeting Individual Needs: Recognising that a 'one-size-fits-all' approach is not inclusive. We 	will provide tailored support and reasonable adjustments to meet the 	diverse needs of our pupils and staff, especially those with disabilities or other vulnerabilities.
Inclusive Environment: Cultivating a welcoming, safe, and supportive atmosphere where 	everyone feels they belong and are valued for who they are.
6. Positive Action
Where proportionate, lawful, and necessary, ElevatEd may take positive action to overcome or minimise disadvantages experienced by people who share a protected characteristic, or to address under-representation in certain activities or roles. This is distinct from positive discrimination, which is generally unlawful. Examples might include targeted support programmes or mentoring schemes.

7. Promoting Equality and Inclusion: Practical Measures
Our commitment to inclusion and equal opportunity is embedded across all aspects of our provision:
7.1 Admissions and Exclusions:
Admissions procedures are fair, 	transparent, and non-discriminatory, based solely on educational need and suitability for our provision, not protected 	characteristics.
Exclusion procedures are applied fairly and consistently, ensuring that pupils with protected 	characteristics are not disproportionately excluded. Reasonable 	adjustments will be considered for disabled pupils.
7.2 Curriculum, Teaching, and Learning:
Our curriculum is broad, balanced, and inclusive, reflecting the diversity of our local community and the 	wider world.
Teaching methods are adapted to meet diverse learning styles and needs, ensuring accessibility for all pupils, including those with SEND or other disabilities.
Resources are selected to challenge 	stereotypes, promote positive images of all protected 	characteristics, and provide diverse role models.
Opportunities are provided to explore issues of equality, diversity, and human rights in an 	age-appropriate and sensitive manner.
7.3 Assessment and Achievement:
Assessment methods are fair and allow all 	pupils to demonstrate their knowledge and skills effectively, with appropriate reasonable adjustments for disabled pupils.
We monitor the attainment and progress of pupils from different protected characteristic groups to identify and address any disparities.

7.4 Behaviour Management and Anti-Bullying:
Our Behaviour Policy clearly states that discriminatory bullying, harassment, and language (e.g., racist, homophobic, transphobic, disablist) are unacceptable and will not be 	tolerated.
All incidents of discriminatory behaviour will be investigated thoroughly and dealt with firmly, in line with our Anti-Bullying Policy and Disciplinary Policy.
Support will be provided to victims of bullying and discrimination.
Pupils are educated on respectful interactions and challenging prejudice.
7.5 Staff Recruitment, Employment, and Professional Development:
Our recruitment and selection processes are fair, transparent, and based on merit, skills, and experience, ensuring equal opportunity for all applicants regardless of protected characteristics.
We provide a supportive and inclusive working environment free from harassment and discrimination.
Staff receive regular training on 	equality, diversity, inclusion, and challenging unconscious bias.
Reasonable adjustments will be made for disabled staff members.
7.6 Facilities and Environment:
We strive to ensure our premises and facilities are accessible to all pupils, staff, and visitors, making reasonable adjustments as required by the Equality Act 2010.
Our physical and emotional environment promotes a sense of belonging and safety for everyone.
7.7 Parental and Community Engagement:
We actively encourage and value the 	participation of all parents/carers, ensuring inclusive 	communication and engagement strategies that respect diverse backgrounds and needs.
We will work collaboratively with relevant external agencies and community groups in Manchester to support our inclusive practices and meet the needs of diverse individuals.
8. Dealing with Discrimination, Harassment, and Victimisation
ElevatEd will take all reports of discrimination, harassment, or victimisation seriously and deal with them promptly and effectively.
8.1 Reporting Procedures:
Pupils: Should report any incident of discrimination or harassment to any trusted adult within the provision (e.g., Head of Provision, Designated Safeguarding Lead).
Staff: Should report concerns about pupils to the Head of Provision/DSL. Concerns about colleagues or workplace discrimination should be reported to the Head of Provision.
Parents/Carers/Visitors: Should report concerns to the Head of Provision.
8.2 Investigation and Resolution:
All reported incidents will be investigated thoroughly, sensitively, and impartially.
The investigation will aim to ascertain the facts, identify those involved, and determine appropriate action.
Support will be offered to the complainant 	and any others affected.
Where appropriate, restorative justice approaches may be used to repair harm and promote understanding.
8.3 Consequences:
Any individual (pupil, staff, or visitor) 	found to have engaged in discriminatory behaviour or harassment will face appropriate consequences in line with the provision's Behaviour 	Policy (for pupils) or Disciplinary Policy (for staff).
Serious or persistent discrimination may lead to exclusion (for pupils) or dismissal (for staff).
9. Monitoring and Review
Monitoring Outcomes: We will regularly monitor and analyse data relating to pupil 	outcomes (e.g., attendance, attainment, progress, exclusions) and staff information (e.g., recruitment, promotions, grievances, 	disciplinary action) to identify any disparities related to 	protected characteristics.
Impact Assessments: We will undertake equality impact assessments for new policies, 	procedures, and significant changes to ensure they do not 	inadvertently disadvantage any group.
Reporting: We will report on our progress in meeting the Public Sector Equality Duty (if required, as part of a wider trust or local authority reporting structure).
Policy Review: This policy will be reviewed at least annually by the Head of Provision. The review will consider:

Effectiveness of current practices.
Feedback from stakeholders.
Changes in legislation or best practice.
Identified areas for improvement from data analysis.

10. Links to Other Policies
This policy works in conjunction with, and should be read alongside, the following key policies:
Safeguarding and Child Protection Policy
Anti-Bullying Policy
Behaviour Policy
Special Educational Needs and Disability 	(SEND) Policy
Admissions Policy
Staff Code of Conduct
Grievance Policy
Disciplinary Policy
Data Protection (GDPR) Policy
Accessibility Plan

Question 17

Fire Evacuation policy

Accepted Answer

11. Statement of Intent
ElevatEd is unequivocally committed to providing a safe and secure environment for all its pupils, staff, and visitors. This policy outlines our robust procedures for managing fire emergencies and responding to potential intruder situations, ensuring the swift and effective protection of all individuals on our premises.
We recognise that pupils attending ElevatEd may have diverse needs, including Special Educational Needs and Disabilities (SEND), anxiety, or trauma, which necessitate thoughtful and adaptive emergency protocols. Our procedures are designed to minimise risk, promote calm, and ensure the safety and well-being of everyone during critical incidents.
This policy applies to all individuals on the premises of ElevatEd and extends to any off-site activities where relevant. It will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, premises, and the specific needs of our pupil cohort.

Signed: Mark Aitken 		Date: 01 September 2025  		Review 01 September 2026
Mark Aitken 
Head of Provision

PART 1: FIRE EVACUATION POLICY
2. Legal Framework and Guidance
This section of the policy adheres to:
The 	Regulatory Reform (Fire Safety) Order 2005
Building Regulations 2010 (as amended)
Health and Safety at Work etc. Act 1974
Department for Education (DfE) guidance on fire safety in schools.
Local Fire and Rescue Service advice (Greater Manchester Fire and Rescue 	Service).
3. Roles and Responsibilities (Fire Safety)
3.1 Head of Provision/Fire Safety Manager:
Overall responsibility for ensuring the provision complies with all fire 	safety legislation.
Ensuring adequate resources are allocated for fire safety measures, training, and maintenance.
Reviewing fire risk assessments and ensuring remedial actions are completed.
Mark Aitken -Lead Fire warden/Tracie Daly -Deputy Fire warden
Overall day-to-day responsibility for fire safety management.
Ensuring 	a comprehensive and up-to-date Fire Risk Assessment is in place and 	regularly reviewed.
Appointing and training sufficient Fire Wardens.
Ensuring 	fire drills are conducted regularly and records are maintained.
Maintaining fire safety equipment and systems (e.g., alarms, extinguishers).
Liaising with the Fire and Rescue Service as required.
3.2 Fire Wardens:
Mark Aitken/Tracie Daly 
Assisting in fire prevention measures.
Ensuring clear escape routes are maintained.
Assisting with the safe evacuation of all occupants, particularly vulnerable 	individuals.
Checking 	designated areas during an evacuation.
Reporting to the Fire Safety Manager at the assembly point.
3.3 All Staff (including temporary staff, volunteers):
Understanding 	and adhering to this policy and all fire safety procedures.
Knowing 	the location of fire exits, assembly points, and fire-fighting 	equipment.
Participating fully in fire drills.
Taking all reasonable steps to prevent fires.
Reporting any fire hazards or defects in fire safety equipment immediately.
3.4 Pupils:
Understanding 	the importance of fire safety rules.
Knowing the sound of the fire alarm.
Knowing evacuation routes and assembly points.
Following 	staff instructions calmly and quickly during a fire drill or actual evacuation.
3.5 Visitors and Contractors:
Being made aware of the fire evacuation procedure upon arrival (e.g., 	through visitor briefing, signage).
Following 	staff instructions during an alarm.
4. Fire Risk Assessment
A comprehensive Fire Risk Assessment will be carried out by a 	competent person annually, or whenever there are significant changes to the premises, activities, or staffing.
The 	assessment will identify fire hazards, persons at risk, evaluate the risks, and recommend control measures.
Findings 	of the Fire Risk Assessment will be reviewed and acted upon by the Head of Provision.
5. Fire Prevention
Electrical 	Safety: Regular Portable 	Appliance Testing (PAT), visual checks of plugs and cables, avoiding 	overloading sockets.
Flammable Materials: Secure storage of flammable liquids and materials in designated areas.
Waste Management: Regular emptying of 	bins, secure storage of waste away from buildings.
Housekeeping: 	Maintaining clear corridors and escape routes, ensuring no obstructions.
Smoking: 	Strict no-smoking policy across the entire premises.
Kitchen/Cooking Areas: Regular cleaning of equipment, ensuring staff are trained in safe cooking practices.
6. Fire Detection and Alarms
The 	provision has a [e.g., Grade A, Category L2] automatic fire 	detection and alarm system.
The 	fire alarm system will undergo an annual service by a certified external contractor.
Fire 	alarm call points are located throughout the building, clearly marked.
7. Emergency Procedures (Fire Evacuation)
7.1 Raising the Alarm:
Anyone discovering a fire should immediately activate the nearest fire alarm call point.
If safe to do so, alert others verbally.
DO 	NOT attempt to fight the fire unless it is very small, you have been trained to use an 	extinguisher, and you are confident you can do so without putting yourself or others at risk. Prioritise evacuation.

7.2 Evacuation Procedure:
On 	hearing the fire alarm (a continuous [e.g., bell/siren] sound):

Immediate Evacuation: All individuals must evacuate the building immediately and calmly via the nearest safe exit.
Leave Belongings: Do not stop to collect personal belongings.
Close Doors and Windows (If Safe): Close doors and windows behind you to limit the spread of fire and smoke, but do not compromise your escape.
Assisting 	Vulnerable Individuals: Staff are responsible for assisting any pupils or visitors with mobility 	issues, SEND, or other vulnerabilities who may require additional support to evacuate. Specific Personal Emergency Evacuation Plans 	(PEEPs) will be in place for identified individuals.
Designated Routes: Follow designated fire 	escape routes, which are clearly displayed throughout the building.
Silence: 	Maintain silence during evacuation to allow for clear communication of instructions.
Assembly 	Point: Proceed directly to the designated fire assembly point, which is the car park at the front of the building.
Register/Roll 	Call: Class teachers/session leaders are responsible for taking their register immediately at 	the assembly point to account for all pupils. The Head of Provision/Fire Safety Manager will be responsible for confirming all staff and visitors are accounted for.
No 	Re-entry: No one is to re-enter the building until the all-clear has been given by the 		Fire and Rescue Service or the Head of Provision/Fire Safety Manager, who will confirm the building is safe.

7.3 Accounting for Everyone:
Registers 	will be taken promptly at the assembly point.
The 	Fire Safety Manager will collect all registers and visitor logs to confirm everyone is accounted for.
Any 	missing persons will be immediately reported to the Fire and Rescue 	Service upon their arrival.
7.4 Calling Emergency Services:
The 	Fire and Rescue Service (999) will be called immediately upon activation of the fire alarm. This will be the responsibility of the 	Head of Provision/Deputy Fire Warden.
Provide clear information: "Fire alarm activated at ElevatEd Fiera Studios, Unit 15A, Empress Building Centre, Chester Rd, Old Trafford, Stretford, Manchester, M16 9EA.

8. Fire Drills
Fire 	drills will be conducted at least once per term, three times per academic year to ensure all occupants are familiar with the 	evacuation procedures.
Drills will be varied to simulate different scenarios (e.g., an exit route blocked).
Each drill will be evaluated, and any issues or areas for improvement will be addressed and recorded.
Records 	of drills, including date, time, duration, and any issues, will be maintained by the Fire Safety Manager.
9. Fire Fighting Equipment
Appropriate fire extinguishers are located at strategic points throughout the building.
Staff who may be required to use fire extinguishers will receive 	appropriate training.
Fire 	extinguishers will be regularly inspected and serviced annually by a certified contractor.
10. Communication (Post-Incident)
In the event of an actual fire or significant incident, parents/carers will be informed as soon as it is safe and practical to do so, usually via [e.g., text message, email, school communication app].
Relevant authorities (e.g., DfE, Local Authority) will be informed as required.

PART 2: INTRUDER POLICY
11. Statement of Intent (Intruder)
ElevatEd recognises the critical importance of protecting pupils, staff, and visitors from potential external threats, including unauthorised individuals or intruders on the premises. This policy outlines our proactive measures to prevent such incidents and our emergency response procedures to ensure the safety and security of our community in the event of an intruder.
12. Roles and Responsibilities (Intruder Safety)
12.1 Head of Provision:
Ensuring 	robust security measures are in place.
Reviewing incident reports and acting on recommendations.
Overall responsibility for site security and intruder response.
Ensuring 	staff are trained in intruder procedures.
Liaising with emergency services (Police) during an incident.
Conducting drills and reviews.

12.2 Designated Safeguarding Lead (DSL):
Will 	be informed immediately of any intruder incident, as there is a direct safeguarding concern.
Will 	lead on welfare and support for pupils and staff following an incident.
12.3 All Staff (including temporary staff, volunteers):
Being vigilant for unauthorised persons on site.
Understanding 	and adhering to intruder response procedures.
Following 	instructions during an intruder alert.
Ensuring 	their classrooms/areas are secured during a lockdown.
12.4 Pupils:
Understanding 	the importance of following staff instructions during an intruder 	alert.
Knowing 	the "lockdown" procedure.
13. Prevention and Deterrence
Secure Entry Points: All external doors and gates are kept locked during provision hours, with 	controlled access via [e.g., buzzer system, key fob entry].
Visitor Procedures: All visitors must 	report to reception, sign in, wear a visitor badge, and be 	accompanied by a staff member or be supervised.
CCTV: Strategically placed CCTV cameras monitor external areas.
Perimeter 	Security: Outside doors and internal doors robust to secure the perimeter 
Staff Vigilance: All staff are trained to challenge any unfamiliar individuals on site and to report concerns immediately.
14. Identification of Threat
An intruder is defined as any unauthorised person on the provision premises who poses a potential threat or causes concern. Threats could include:
An aggressive or disturbed individual.
A person acting suspiciously or attempting to access restricted areas.
A known threat attempting to gain access (e.g., prohibited parent, ex-staff member).
A person carrying a weapon or exhibiting violent behaviour.
15. Emergency Procedures (Intruder / Lockdown / Invacuation)
The response to an intruder incident will depend on the nature and location of the threat. The primary objective is to protect life.
15.1 Initiating the Alert:
Any 	staff member who identifies a potential intruder threat should immediately alert Mark Aitken, Head of Provision / Security Lead.
The 	Head of Provision / Security Lead will assess the situation and initiate the LOCKDOWN/INVACUATION procedure.
15.2 Lockdown / Invacuation Procedure (on hearing the alert):
For Staff and Pupils Inside the Building:

Secure: Immediately lock all classroom/office doors. If doors do not lock, secure them with furniture if safe and possible.
Conceal: Move pupils and staff away from windows and doors, out of sight. 	Encourage them to sit on the floor under desks or in a secure corner.
Silence: Maintain absolute silence. Switch off lights. Silence mobile phones.
No Entry/Exit: Do not open doors for anyone until the official "all-clear" is given. Do not leave the secure area.
Await Instructions: Staff should 	remain in lockdown until the police or Head of Provision gives the 	official all-clear. Do not respond to fire alarms during a lockdown 	unless there is clear visual evidence of a fire in your immediate vicinity.

For Staff and Pupils Outside the Building:

Invacuate/Run/Hide: Depending on the immediate threat, staff must decide to either:

Invacuate: Quickly and calmly move pupils into the nearest secure building/room.
Run: 	Move away from the perceived threat to a safer location, if a secure building is not immediately accessible.
Hide: If running is not safe, hide in a secure location away from the immediate threat.

Once in a secure location (inside or outside), follow the "Secure, 	Conceal, Silence, No Entry/Exit, Await Instructions" protocol.

Calling Emergency Services: The Head of Provision / Security Lead (or designated alternate) will immediately call the Police (999) and provide clear, concise information about the incident.
15.3 Specific Considerations for ElevatEd Pupils during Lockdown:
Staff will be particularly mindful of pupils with SEND, anxiety, or trauma who may react differently to lockdown procedures.
Communicate calmly and clearly, using simple language.
Reassurance and support will be provided as far as possible without compromising the lockdown.
Consider 	pre-agreed adaptations for specific pupils if their IHP/SEND plan outlines particular needs during high-stress situations.
16. Training and Drills
All staff will receive initial and annual refresher training on intruder response procedures, including lockdown/invacuation.
Lockdown drills will be conducted at least once per academic year to practice the procedures.
Drills will be evaluated, and any areas for improvement will be addressed and recorded.
17. Post-Incident Management
Once the "all-clear" is given by the Police or Head of Provision, pupils and staff will be guided to a safe assembly area.
The 	DSL will coordinate immediate welfare support for pupils and staff affected by the incident.
Access to counselling or psychological support will be made available.
A debriefing session will be held for all staff to review the incident and identify lessons learned.
An official incident report will be completed.
18. Communication (Intruder Incident)
Internal: 	The distinct lockdown alert system is used for internal communication.
External (Emergency Services): Police (999) will be called immediately.
External (Parents/Carers): 	Parents/carers will be informed as soon as it is safe and appropriate to do so, typically after the immediate threat has passed and information is confirmed, via [e.g., text message, email, school communication app]. Details shared will be factual and reassuring.
External 	(Referring Schools/Local Authority): 	Relevant authorities and referring schools will 
be informed as required.

19. Policy Review
This combined policy will be reviewed annually by the Head of Provision. The review will consider:
Changes in relevant legislation or guidance.
Lessons learned from drills or actual incidents.
Feedback 	from staff, pupils, and emergency services.
Any 	changes to the premises or pupil cohort.

Appendix 1: Emergency Contact Information
Emergency Services (Police, Fire, Ambulance): 999
Head of Provision:  Mark Aitken 	07761370613
Fire 	Safety Manager: Mark Aitken 07761370613
Security Lead: Mark Aitken 07761370613
Designated Safeguarding Lead (DSL): Tracie Daly - tracie@elevate-ed.co.uk 
LADO (Manchester): Majella O’Hagan 0161 234 1214
Out 	of Hours Emergency Contact (Proprietor): 	Chandni Patel- 07875680277  Empress Business 	Centre - 0161 244 5500

. Statement of Intent
ElevatEd is unequivocally committed to providing a safe and secure environment for all its pupils, staff, and visitors. This policy outlines our robust procedures for managing fire emergencies and responding to potential intruder situations, ensuring the swift and effective protection of all individuals on our premises.
We recognise that pupils attending ElevatEd may have diverse needs, including Special Educational Needs and Disabilities (SEND), anxiety, or trauma, which necessitate thoughtful and adaptive emergency protocols. Our procedures are designed to minimise risk, promote calm, and ensure the safety and well-being of everyone during critical incidents.
This policy applies to all individuals on the premises of ElevatEd and extends to any off-site activities where relevant. It will be reviewed annually and updated as necessary to reflect changes in legislation, guidance, premises, and the specific needs of our pupil cohort.

Signed: Mark Aitken 	 Date: 01 September 2025  	 Review 01 September 2026
Mark Aitken 
Head of Provision

PART 1: FIRE EVACUATION POLICY
2. Legal Framework and Guidance
This section of the policy adheres to:
The Regulatory Reform (Fire Safety) Order 	2005
Building Regulations 2010 (as amended)
Health and Safety at Work etc. Act 1974
Department for Education (DfE) guidance on fire safety in schools.
Local Fire and Rescue Service advice 	(Greater Manchester Fire and Rescue Service).
3. Roles and Responsibilities (Fire Safety)
3.1 Head of Provision/Fire Safety Manager:
Overall responsibility for ensuring the provision complies with all fire safety legislation.
Ensuring adequate resources are allocated for fire safety measures, training, and maintenance.
Reviewing fire risk assessments and ensuring remedial actions are completed.
Mark Aitken -Lead Fire warden/Tracie Daly 	Deputy Fire warden
Overall day-to-day responsibility for fire safety management.
Ensuring a comprehensive and up-to-dateFire Risk Assessment is in place and regularly reviewed.
Appointing and training sufficient Fire Wardens.
Ensuring fire drills are conducted regularly and records are maintained.
Maintaining fire safety equipment and systems (e.g., alarms, extinguishers).
Liaising with the Fire and Rescue Service as required.
3.2 Fire Wardens:
Mark Aitken/Tracie Daly 
Assisting in fire prevention measures.
Ensuring clear escape routes are maintained.
Assisting with the safe evacuation of all occupants, particularly vulnerable individuals.
Checking designated areas during an evacuation.
Reporting to the Fire Safety Manager at the assembly point.
3.3 All Staff (including temporary staff, volunteers):
Understanding and adhering to this policy 	and all fire safety procedures.
Knowing the location of fire exits, assembly points, and fire-fighting equipment.
Participating fully in fire drills.
Taking all reasonable steps to prevent fires.
Reporting any fire hazards or defects in fire safety equipment immediately.
3.4 Pupils:
Understanding the importance of fire safety rules.
Knowing the sound of the fire alarm.
Knowing evacuation routes and assembly points.
Following staff instructions calmly and quickly during a fire drill or actual evacuation.
3.5 Visitors and Contractors:
Being made aware of the fire evacuation procedure upon arrival (e.g., through visitor briefing, signage).
Following staff instructions during an alarm.
4. Fire Risk Assessment
A comprehensive Fire Risk Assessment will be carried out by a competent person annually, or whenever there are significant changes to the premises, activities, or staffing.
The assessment will identify fire hazards,persons at risk, evaluate the risks, and recommend control measures.
Findings of the Fire Risk Assessment will be reviewed and acted upon by the Head of Provision.
5. Fire Prevention
Electrical Safety: Regular Portable Appliance Testing (PAT), visual checks of plugs and 	cables, avoiding overloading sockets.
Flammable Materials: Secure storage of flammable liquids and materials in designated areas.
Waste Management: Regular emptying of bins, secure storage of waste away from 	buildings.
Housekeeping: Maintaining clear corridors and escape routes, ensuring no 	obstructions.
Smoking: 	Strict no-smoking policy across the entire premises.
Kitchen/Cooking Areas: Regular cleaning of equipment, ensuring staff are trained in safe cooking practices.
6. Fire Detection and Alarms
The provision has a [e.g., Grade A, Category L2] automatic fire detection and alarm system.
The fire alarm system will be tested weekly every Monday at 12:30AM by a competent person. Any defects will be reported immediately for repair.
The fire alarm system will undergo an annual service by a certified external contractor.
Fire alarm call points are located throughout the building, clearly marked.
7. Emergency Procedures (Fire Evacuation)
7.1 Raising the Alarm:
Anyone discovering a fire should immediately activate the nearest fire alarm call point.
If safe to do so, alert others verbally.
DO NOT 	attempt to fight the fire unless it is very small, you have been trained to use an extinguisher, and you are confident you can do so without putting yourself or others at risk. Prioritise evacuation.

7.2 Evacuation Procedure:
On hearing the fire alarm (a continuous [e.g., bell/siren] sound):

Immediate Evacuation: All individuals must evacuate the building immediately and calmly via the nearest safe exit.
Leave Belongings: Do not stop to collect personal belongings.
Close Doors and Windows (If Safe): 	Close doors and windows behind you to limit the spread of fire and smoke, but do not compromise your escape.
Assisting Vulnerable Individuals: Staff are responsible for assisting any pupils or visitors with mobility issues, SEND, or other vulnerabilities who may require additional support to evacuate. Specific Personal Emergency Evacuation Plans (PEEPs) will be in place for identified individuals.
Designated Routes: 	Follow designated fire escape routes, which are clearly displayed 	throughout the building.
Silence: Maintain silence during evacuation to allow for clear communication of instructions.
Assembly Point: Proceed directly to the designated fire assembly point, which is 	the car park at the front of the building.
Register/Roll Call: Class teachers/session leaders are responsible for taking their register immediately at the assembly point to account for all  pupils. The Head of Provision/Fire Safety Manager will be responsible for confirming all staff and visitors are accounted for.
No Re-entry: No one is to re-enter the building until the all-clear has been given by the Fire and Rescue Service or the Head of Provision/Fire Safety Manager, who will confirm the building is safe.

7.3 Accounting for Everyone:
Registers will be taken promptly at the assembly point.
The Fire Safety Manager will collect all registers and visitor logs to confirm everyone is accounted for.
Any missing persons will be immediately reported to the Fire and Rescue Service upon their arrival.
7.4 Calling Emergency Services:
The Fire and Rescue Service (999) will be called immediately upon activation of the fire alarm. This will be the responsibility of Director of School Operations/Director of 	Programmes and Operations.
Provide clear information: "Fire alarm activated at Elevate Ed Fiera Studios, Unit 15A, Empress 	Building Centre, Chester Rd, Old Trafford, Stretford, Manchester, M16 9EA.

8. Fire Drills
Fire drills will be conducted at least once per term, three times per academic year to ensure all occupants are familiar with the evacuation procedures.
Drills will be varied to simulate different scenarios (e.g., an exit route blocked).
Each drill will be evaluated, and any issues or areas for improvement will be addressed and recorded.
Records of drills, including date, time, duration, and any issues, will be maintained by the Fire Safety Manager.
9. Fire Fighting Equipment
Appropriate fire extinguishers are located 	at strategic points throughout the building.
Staff who may be required to use fire 	extinguishers will receive appropriate training.
Fire extinguishers will be regularly inspected and serviced annually by a certified contractor.
10. Communication (Post-Incident)
In the event of an actual fire or significant incident, parents/carers will be informed as soon as it is safe and practical to do so, usually via [e.g., text message, email, school communication app].
Relevant authorities (e.g., DfE, Local Authority) will be informed as required.

PART 2: INTRUDER POLICY
11. Statement of Intent (Intruder)
ElevateEd recognises the critical importance of protecting pupils, staff, and visitors from potential external threats, including unauthorised individuals or intruders on the premises. This policy outlines our proactive measures to prevent such incidents and our emergency response procedures to ensure the safety and security of our community in the event of an intruder.
12. Roles and Responsibilities (Intruder Safety)
12.1 Head of Provision:
Ensuring robust security measures are in place.
Reviewing incident reports and acting on recommendations.
Overall responsibility for site security and intruder response.
Ensuring staff are trained in intruder 	procedures.
Liaising with emergency services (Police) during an incident.
Conducting drills and reviews.

12.2 Designated Safeguarding Lead (DSL):
Will be informed immediately of any intruder incident, as there is a direct safeguarding concern.
Will lead on welfare and support for pupils and staff following an incident.
12.3 All Staff (including temporary staff, volunteers):
Being vigilant for unauthorised persons on site.
Understanding and adhering to intruder response procedures.
Following instructions during an intruder alert.
Ensuring their classrooms/areas are secured during a lockdown.
12.4 Pupils:
Understanding the importance of following staff instructions during an intruder alert.
Knowing the "lockdown" procedure.
13. Prevention and Deterrence
Secure Entry Points: All external doors and gates are kept locked during provision hours, with controlled access via [e.g., buzzer system, key fob entry].
Visitor Procedures: 	All visitors must report to reception, sign in, wear a visitor 	badge, and be accompanied by a staff member or be supervised.
CCTV: Strategically placed CCTV cameras monitor external areas.
Perimeter Security: 	Outside doors and internal doors robust to secure the perimeter 
Staff Vigilance: All staff are trained to challenge any unfamiliar individuals on site and to report concerns immediately.
14. Identification of Threat
An intruder is defined as any unauthorised person on the provision premises who poses a potential threat or causes concern. Threats could include:
An aggressive or disturbed individual.
A person acting suspiciously or attempting to access restricted areas.
A known threat attempting to gain access 	(e.g., prohibited parent, ex-staff member).
A person carrying a weapon or exhibiting violent behaviour.
15. Emergency Procedures (Intruder / Lockdown / Invacuation)
The response to an intruder incident will depend on the nature and location of the threat. The primary objective is to protect life.
15.1 Initiating the Alert:
Any staff member who identifies a potential intruder threat should immediately alert Mark Aitken, Head of Provision / Security Lead.
The Head of Provision / Security Lead will assess the situation and initiate the LOCKDOWN/INVACUATION procedure.
15.2 Lockdown / Invacuation Procedure (on hearing the alert):
For Staff and Pupils Inside the 	Building:

Secure: Immediately lock all classroom/office doors. If doors do not lock, secure them with furniture if safe and possible.
Conceal: Move pupils and staff away from windows and doors, out of sight. 	Encourage them to sit on the floor under desks or in a secure corner.
Silence: Maintain absolute silence. Switch off lights. Silence mobile phones.
No Entry/Exit: Do not open doors for anyone until the official "all-clear" is given. Do not leave the secure area.
Await Instructions: Staff should remain in lockdown until the police or Head of Provision gives the official all-clear. Do not respond to fire alarms during a lockdown unless there is clear visual evidence of a fire in your immediate vicinity.

For Staff and Pupils Outside the Building:

Invacuate/Run/Hide: Depending on the immediate threat, staff must decide to either:

Invacuate: Quickly and calmly move pupils into the nearest secure building/room.
Run: Move away from the perceived threat to a safer location, if a secure building is not immediately accessible.
Hide: If running is not safe, hide in a secure location away from the immediate threat.

Once in a secure location (inside or outside), follow the "Secure, Conceal, Silence, No Entry/Exit, Await Instructions" protocol.

Calling Emergency Services: The Head of Provision / Security Lead (or designated alternate) will immediately call the Police (999) and provide clear, concise information about the incident.
15.3 Specific Considerations for ElevatEd Pupils during Lockdown:
Staff will be particularly mindful of pupils with SEND, anxiety, or trauma who may react differently to lockdown procedures.
Communicate calmly and clearly, using simple language.
Reassurance and support will be provided 	as far as possible without compromising the lockdown.
Consider pre-agreed adaptations for specific pupils if their IHP/SEND plan outlines particular needs during high-stress situations.
16. Training and Drills
All staff will receive initial and annual refresher training on intruder response procedures, including 	lockdown/invacuation.
Lockdown drills will be conducted at leastonce per academic year to practice the procedures.
Drills will be evaluated, and any areas 	for improvement will be addressed and recorded.
17. Post-Incident Management
Once the "all-clear" is given by the Police or Head of Provision, pupils and staff will be guided to a safe assembly area.
The DSL will coordinate immediate welfare support for pupils and staff affected by the incident.
Access to counselling or psychological support will be made available.
A debriefing session will be held for all staff to review the incident and identify lessons learned.
An official incident report will be completed.
18. Communication (Intruder Incident)
Internal: The distinct lockdown alert system is used for internal communication.
External (Emergency Services): Police (999) will be called immediately.
External (Parents/Carers): Parents/carers will be informed as soon as it is safe and appropriate to do so, typically after the immediate threat has passed and information is confirmed, via [e.g., text message, email, school communication app]. Details shared will be factual and reassuring.
External (Referring Schools/Local Authority): Relevant authorities and referring schools will 
be informed as required.

19. Policy Review
This combined policy will be reviewed annually by the Head of Provision. The review will consider:
Changes in relevant legislation or guidance.
Lessons learned from drills or actual  incidents.
Feedback from staff, pupils, and emergency services.
Any changes to the premises or pupil cohort.

Appendix 1: Emergency Contact Information
Emergency Services (Police, Fire, Ambulance): 999
Head of Provision: Mark Aitken 07761370613
Fire Safety Manager: Mark Aitken 07761370613
Security Lead: 	Mark Aitken 07761370613
Designated Safeguarding Lead (DSL): Tracie Daly - tracie@elevate-ed.co.uk 
LADO (Manchester): Majella O’Hagan 0161 234 1214
Out of Hours Emergency Contact (Proprietor): Chandni Patel- 07875680277   Empress Business Centre - 0161 244 5500

Question 18

Admission Policy

Accepted Answer

Admission Policy
Date Adopted: September 2025
 Review Date:  September 2026
 Policy Lead: Mark Aitken, Head of Provision
 Approved by:  Head of Provision
1. Statement of Intent
ElevatEd AP Ltd is committed to providing fair, transparent, and supportive admission procedures that prioritise the welfare, needs, and aspirations of each learner.
2. Guiding Principles
Child-Centred: Admission 	decisions are made in the best interests of the learner.
Inclusivity: All 	applications are treated fairly and without discrimination.
Transparency: Criteria and processes are clear and consistently applied.
Safety: Admissions consider safeguarding and risk assessments.
3. Scope and Definitions
Scope: Applies to all 	children and young people referred to ElevatEd.
Admission: The process of evaluating and approving a referral to the provision.
4. Roles and Responsibilities
Head of Provision: Approves all admissions.
Admissions Panel: Reviews referrals, considers needs, and ensures provision suitability.
DSL: Ensures safeguarding concerns are addressed before admission.
Referring Agencies: 	Provide accurate, relevant information.
5. Admission Procedures
Referral Received: From schools, local authorities, or agencies.
Initial Screening: Review documentation (EHCP, risk assessments, safeguarding history).
Admission Meeting: With learner, parents/carers, and referring agency.
Risk Assessment: Conducted prior to admission.
Decision: Head of Provision approves/rejects admission.
Transition Plan: Individual plan created for each admitted learner.
6. Training and Awareness
All staff involved in admissions trained in safeguarding, SEND awareness, and equality.
7. Monitoring, Evaluation, and Review
Admission data monitored termly to ensure fairness and effectiveness.
Policy reviewed annually.
8. Related Policies
Safeguarding Policy
Behaviour Policy
Equality and Diversity Policy
SEND Policy

Question 19

Privacy Policy

Accepted Answer

Privacy Policy
Date Adopted: 18th September 2025
Review Date: September 2026
Policy Lead: Alexandra Mcloughlin, Data Protection Lead
Approved by: Mark Aitken, Head of Provision

1. Statement of Intent
ElevatEd AP Ltd is committed to protecting the privacy and personal data of our students, parents/carers, staff, and partners. We comply fully with the UK General Data Protection Regulation (GDPR), the Data Protection Act 2018, and relevant safeguarding legislation. This policy explains how we collect, use, store, and protect personal data.

2. Guiding Principles
Lawfulness, Fairness & Transparency: Data is processed fairly, lawfully, and openly.
Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes.
Data Minimisation: Only relevant and necessary data is collected.
Accuracy: Data is kept accurate and up to date.
Storage Limitation: Data is retained only as long as necessary.
Integrity & Confidentiality: Data is kept secure through technical and 	organisational measures.
Accountability: ElevatEd AP Ltd demonstrates compliance with data protection obligations.

3. Scope and Definitions
Scope: Applies to all 	personal data processed by ElevatEd AP Ltd relating to students, 	parents/carers, staff, contractors, and partners.
Personal Data: Any information that identifies or could identify an individual.
Special Category Data: Sensitive information such as health, ethnicity, or safeguarding 	records.
Processing: Any action taken with personal data, including collection, storage, sharing, or 	deletion.

4. Roles and Responsibilities
Data Protection Lead (DPL):

Name: Alexandra Mcloughlin
Contact: alex@elevate-ed.co.uk
Responsibilities: Overseeing compliance, responding to data subject requests, reporting 	breaches.

All Staff: Responsible for handling personal data securely and in line with training.
Head of Provision: Ensures resources and systems are in place for compliance.

5. Data We Collect and Why
Students: Contact details, academic records, attendance, safeguarding information, 	SEN/EHCP records, medical needs.
Parents/Carers: Contact details, parental responsibility, emergency contacts.
Staff: Employment history, qualifications, payroll, safeguarding and vetting checks.
Other: Visitor records, CCTV (where applicable), contractor details.
Purpose of Data Collection:
To deliver education and safeguarding responsibilities.
To meet legal obligations (e.g., safeguarding, reporting to Local Authorities).
To communicate effectively with parents/carers.
To manage staff employment.
To ensure health, safety, and wellbeing of students and staff.

6. Lawful Basis for Processing
ElevatEd AP Ltd processes data under the following bases:
Legal Obligation: Safeguarding, employment law, and reporting duties.
Public Task: Delivering education services in the public interest.
Contract: Employment and service agreements.
Consent: For optional activities (e.g., photos for marketing, additional services).
Vital Interests: 	Protecting life or health in emergencies.

7. Data Sharing
We may share data with:
Local authorities, social care, and safeguarding partners.
The Department for Education (DfE) and Ofsted.
External agencies for SEN 	support, counselling, or medical needs.
Third-party service providers (IT systems, payroll, DBS checks).
We will never sell personal data.

8. Data Storage and Security
Data stored securely on password-protected systems and locked storage.
Access restricted to authorised 	staff only.
Regular security audits and staff training undertaken.
CCTV (if used) is retained for a limited period unless needed for investigations.

9. Data Retention
Personal data is retained only as long as necessary, in line with statutory guidance (e.g., pupil records retained until the child is 25 years old, safeguarding records retained in accordance with KCSIE and ICO guidance).

10. Rights of Data Subjects
Individuals have the right to:
Access their personal data.
Request correction of inaccurate data.
Request erasure (where legally appropriate).
Restrict or object to processing.
Request data portability.
Withdraw consent (where 	applicable).
Complain to the Information Commissioner’s Office (ICO).

11. Data Breach Procedures
All staff must report suspected 	breaches immediately to the DPL.
Serious breaches reported to the ICO within 72 hours.
Affected individuals will be informed where there is a high risk to their rights and freedoms.

12. Training and Awareness
All staff receive GDPR and data 	protection training on induction and refresher training annually.
Specialist training provided for staff handling sensitive data.

13. Monitoring, Evaluation, and Review
The DPL reviews data protection practices annually.
This policy is reviewed every 12 months or sooner if legislation changes.

14. Related Policies
Safeguarding Policy
Staff Code of Conduct
ICT and E-Safety Policy
Whistleblowing Policy
Recruitment & Selection Policy

Question 20

Wellbeing Policy

Accepted Answer

ElevatEd Wellbeing Policy
Policy Review and Approval
Responsible Lead: Head of Provision
Date of Policy Approval: 2.9.25
Date of Next Review: 1.9.26   	
Reviewed By: Tracie 	Daley - Holistic Education Lead
Approved By: Mark Aitken 	-

1. Purpose
ElevatEd is committed to creating a thriving, safe, and inclusive learning and working environment that prioritises the wellbeing of staff and pupils. We recognise that physical, mental, emotional, social, moral, spiritual, and cultural wellbeing are essential foundations for success, personal growth, and lifelong learning.
2. Scope
This policy applies to all members of the ElevatEd community: staff, pupils, contractors, volunteers, and partners, across all settings (school, remote, fieldwork, and extracurricular activities).
3. Definitions
Wellbeing: a holistic state of positive physical, emotional, mental, social, moral, spiritual, and cultural health.
Pupil wellbeing: supporting young people to feel safe, valued, and equipped with tools to manage their wellbeing in line with the NHS Five Ways to 	Wellbeing.
SMSC: development of pupils’ social, moral, spiritual, and cultural awareness.
4. Principles
Whole-community approach: wellbeing is embedded in everything we do, benefiting both staff and pupils.
Inclusivity and 	accessibility: wellbeing support is available to all, regardless of background or need.
Prevention and early intervention: proactive measures and timely support.
Collaboration: partnership between staff, pupils, families, and external agencies.
Confidentiality: wellbeing concerns will be handled sensitively and appropriately.
Continuous reflection: feedback and monitoring will ensure the policy evolves with 	community needs.

5. Responsibilities
Role
Key Responsibilities
Leadership / Governors
Champion wellbeing at strategic level, allocate resources, ensure compliance.
Staff & Mentors
Promote wellbeing through curriculum, pastoral care, modelling positive 				behaviours, and facilitating wellbeing initiatives.
Pupils
Engage with wellbeing activities, support peers, develop self-awareness and 				self-care practices.
Families / Carers
Partner with ElevatEd to reinforce wellbeing values at home.
Wellbeing Champions / Coordinators
Lead wellbeing strategy, monitor uptake, and provide training and guidance.
6. Wellbeing for Staff
ElevatEd provides:
Employee Assistance Programme (confidential counselling and support)
Mental health awareness training and resources
Flexible working where possible
Wellness Action Plans and 	reasonable adjustments
Access to wellbeing workshops 	and activities
Peer mentoring and reflective practice groups
Safe, inclusive working conditions

7. Wellbeing for Pupils
Pupils will access a wide range of structured and informal wellbeing opportunities, including:
Breathwork and Yoga: to 	develop self-regulation, calmness, and resilience
1:1 Mentoring: 	personalised wellbeing and pastoral support
Therapeutic Interventions: access to evidence-based therapeutic support (e.g., counselling, 	play therapy, art therapy, or other interventions as appropriate), 	provided by trained professionals or trusted external partners
Wellbeing Posters and Signposting: visible reminders of strategies and where to find 	help
NHS Five Ways to Wellbeing Framework: integrated into curriculum and daily practice 	(Connect, Be Active, Take Notice, Keep Learning, Give)
Regular Sport and Exercise: PE, team sports, active play, movement breaks during lessons
Journaling Opportunities: fostering reflection, gratitude, and emotional expression
Connecting with Nature: outdoor learning, nature walks, environmental projects
Movement and Mindfulness: regular opportunities for mindful movement to reduce stress and 	improve focus
Reflections and Setting Intentions: encouraging pupils to pause, review, and set 	positive goals for learning and wellbeing
Stretching and Meditation: structured activities to release tension, improve focus, and support emotional regulation
SMSC Development: embedding social, moral, spiritual, and cultural awareness in 	lessons, assemblies, and community activities

8. Health, Safety & Safeguarding
Risk assessments will include wellbeing and mental health considerations.
Clear safeguarding pathways exist for pupils at risk.
Anti-bullying and anti-harassment policies support a safe environment.
Pupils and staff are encouraged to report concerns without stigma.
9. Monitoring & Evaluation
Staff and pupil wellbeing surveys conducted annually.
Regular feedback loops with school council, pupil voice forums, and staff networks.
Wellbeing initiatives reviewed each year and adapted based on evidence and community need.
Data monitored includes attendance, behaviour, uptake of wellbeing services, and engagement with activities.
10. Communication & Awareness
Induction for staff and pupils includes wellbeing orientation.
Wellbeing policy and resources 	are visible on ElevatEd platforms, notice boards, and in classrooms.
Regular assemblies, workshops, and newsletters highlight wellbeing practices.
11. Legal & Ethical Compliance
Policy complies with UK Health 	and Safety law, Equality Act 2010, Keeping Children Safe in 	Education (KCSIE), and relevant safeguarding guidance.
Confidentiality and data protection standards are upheld in all wellbeing matters.

Question 21

SEND Policy

Accepted Answer

ElevatEd Special Educational Needs and Disabilities (SEND) Policy
Policy Lead: Tracie Daley
Approved by: ElevatEd Leadership Team
Date Approved: 1.09.25
Review Cycle: Annually
Next Review Date: 2.09.25
Version: 1.0

1. Purpose
ElevatEd is committed to ensuring that all learners, regardless of their individual needs or abilities, are supported to achieve their full potential. This policy outlines our approach to the identification, support, and monitoring of learners with Special Educational Needs and Disabilities (SEND), ensuring compliance with statutory requirements and the promotion of inclusive education.
2. Principles
Inclusive Practice – Every learner has the right to access high-quality, equitable education.
Early Identification – Needs are recognised and responded to at the earliest opportunity.
Collaboration – Support is strengthened through partnership with learners, families, staff, and external specialists.
High Expectations – 	SEND is never a barrier to success; aspirational goals are set for all learners.
3. Identification and Assessment
Staff are trained to recognise signs of SEND and raise concerns promptly.
ElevatEd follows a graduated approach: assess – plan – do – review.
Assessment considers academic, social, emotional, and physical factors to provide a holistic understanding of each learner’s needs.
4. Support and Provision
Individualised Support Plans are developed in consultation with learners and their families.
Differentiated teaching, reasonable adjustments, and targeted interventions are embedded in practice.
Where required, ElevatEd engages with external agencies and professionals for specialist advice and support.
5. Roles and Responsibilities
Leadership – Ensure 	compliance with SEND legislation, allocate resources, and champion inclusive practice.
Educators – Deliver inclusive teaching, implement support strategies, and monitor learner progress.
SEND Lead – Oversee SEND provision, coordinate assessments and reviews, and liaise with families and external professionals.
Learners and Families – Contribute actively to the planning, implementation, and review of support.
6. Monitoring and Evaluation
Learner progress is tracked against individual targets using qualitative and quantitative measures.
Support plans are reviewed at least once per term, with adjustments made in response to progress and feedback.
The effectiveness of this policy is evaluated annually, incorporating input from learners, families, and staff.
7. Legal and Statutory Framework
This policy is guided by and compliant with:
The SEND Code of Practice (2015)
The Equality Act (2010)
ElevatEd is committed to meeting its statutory duties, ensuring reasonable adjustments are in place, and guaranteeing fair treatment for all learners.
8. Commitment
At ElevatEd, we affirm our belief that diversity strengthens our learning community. By removing barriers, fostering inclusion, and promoting belonging, we enable every learner to thrive.

Question 22

Behaviour and Reward Policy

Accepted Answer

Behaviour & Rewards Policy
Date: 1st September 2025
Review Date: 1st September 2026
Approved and Lead by: Mark Aitken, Head of Provision
1. Statement of Intent
ElevatEd AP Ltd is committed to creating a safe, respectful, and supportive environment
where every young person can thrive. We recognise that many of our learners face
significant challenges and may display behaviours that reflect unmet needs, trauma, or
disengagement from education.
This policy sets out how we promote positive behaviour through:
● Clear expectations, consistently applied.
● Restorative practices that repair relationships.
● Therapeutic interventions that address underlying needs.
● High aspirations for all learners.
We believe behaviour is a form of communication. By responding with compassion,
structure, and consistency, we help young people develop self-regulation, resilience, and
responsibility.
2. Guiding Principles
● Respect and Dignity: Every child and adult is valued and treated fairly.
● Restorative Approach: Incidents are opportunities to repair harm and rebuild trust.
● Consistency with Flexibility: Expectations are clear, but responses are tailored to
individual needs.
● Trauma-Informed Practice: We understand behaviour in the context of life
experiences.
● Partnership: Parents, carers, and schools are engaged in supporting positive
behaviour.
● Celebration of Success: Positive behaviour and achievements are recognised and
r
3. Scope
This policy applies to all staff, students, visitors, and volunteers at ElevatEd, across:
● On-site provision.
● Off-site trips, visits, and workshops.
● Online interactions related to ElevatEd.
4. Roles and Responsibilities
Staff:
● Model respectful behaviour at all times.
● Use positive language and restorative approaches.
● Apply consistent expectations.
● Record and report behaviour incidents using agreed systems.
● Engage in professional development around behaviour management.
Students:
● Show respect to themselves, peers, staff, and the environment.
● Take responsibility for their actions.
● Engage with restorative conversations.
● Work towards their personal behaviour goals.
Parents/Carers:
● Support ElevatEd’s ethos and policies.
● Engage in dialogue with staff around behaviour.
● Encourage and reinforce positive behaviour at home.
Leadership:
● Ensure staff are trained in behaviour management and restorative practice.
● Monitor and evaluate the effectiveness of this policy.
● Provide adequate resources for interventions.
5. Expectations and Standards
Our “3 R’s” guide all behaviour at ElevatEd:
1. Respect – for self, others, and the environment.
2. Responsibility – for learning and actions.
3. Readiness – to participate and
Practical expectations include:
● Using kind and respectful language.
● Following staff instructions first time.
● Looking after equipment, resources, and property.
● Behaving safely at all times (no violence, bullying, or unsafe behaviour).
6. Behaviour Support and Interventions
We recognise that students may need tailored support to meet expectations. Interventions
include:
● Mentoring sessions (1:1 with staff).
● Therapeutic activities (breathwork, yoga, digital/art therapy, nature-based work).
● Individual Behaviour Plans (with clear, achievable targets).
● Parental involvement (workshops, meetings, family support).
● Restorative meetings following conflict or harm.
Where necessary, sanctions may be applied in a proportionate and fair way, such as loss of
privileges, limited access to activities, or supervised reflection time. Exclusion is only used
as a last resort (see Exclusion Policy).
7. Recognition and Rewards
ElevatEd places high value on celebrating progress, effort, and achievement. Recognition
may include:
● Verbal praise and encouragement.
● Certificates, awards, or tokens.
● Displaying work.
● Sharing success with parents/carers.
● Opportunities for leadership and responsibility.
8. Serious Incidents
Incidents involving violence, bullying, drug/alcohol misuse, theft, or persistent disruption will
be dealt with promptly and proportionately. In such cases:
● A senior leader will investigate.
● Parents/carers will be informed.
● Restorative processes will be prioritised.
● Risk assessments and behaviour plans may be updated.
● Where necessary, the Exclusion Poli
9. Monitoring, Evaluation and Review
● Behaviour data will be recorded and analysed regularly.
● Patterns will be identified to inform interventions.
● The policy will be reviewed annually (or sooner if needed).
● Student and parent feedback will be considered in reviews.
10. Related Policies
● Child Protection and Safeguarding Policy
● Fixed-Term/Permanent Exclusion Policy
● Anti-Bullying Policy
● Data Protection and Information Management Policy
● Code of Conduct
● Attendance and Absence Management Policy

Question 23

GDPR policy_Elevate Ed 2025

Accepted Answer

General Data Protection Regulation (GDPR) Policy

1. Statement of Intent

ElevatEd AP Ltd is deeply committed to protecting the privacy and security of all personal data it processes. This policy articulates our unwavering dedication to upholding the principles and requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

We recognise our profound legal and ethical responsibility to handle all personal data with the utmost care, transparency, and respect for individual rights. For ElevatEd, this commitment is particularly salient given the highly sensitive and often complex nature of the data we hold concerning our pupils (including their diverse needs, safeguarding information, health records, and  behavioural histories), staff, parents/carers, and other vital stakeholders.

This policy applies comprehensively to all personal data handled by ElevatEd, irrespective of whether it is stored electronically or in paper format. It extends to all individuals acting on behalf of the provision, including employees, temporary staff, volunteers and contractors.

This policy will be subject to rigorous review at least annually, or more frequently if necessitated by changes in legislation, guidance, or our data processing activities, ensuring its ongoing relevance and effectiveness.

Dated: 1st September 2025

Date of Review: 1st September 2026

Signed: Mark Aitken

Mark Aitken of Head of Provision

2. Scope

This policy's provisions encompass:

All categories of personal data (including special category data and criminal offence data) processed by ElevatEd AP Ltd.

All personnel, including employees, temporary staff, volunteers, and contractors, who engage in data processing activities on behalf of the provision.

All information systems, applications, and networks utilised by the provision, whether accessed on-site or remotely.

3. Key GDPR Principles

Our robust data handling practices are built upon the following foundational GDPR principles:

Lawfulness, Fairness and Transparency: Personal data is processed in a manner that is lawful, fair, and transparent in its interactions with the data subject.

Purpose Limitation: Personal data is collected for specified, explicit, and legitimate purposes. It will not be further processed in a manner that is incompatible with those original purposes.

Data Minimisation: Personal data collected and processed is adequate, relevant, and strictly limited to what is necessary for the purposes for which it is processed.

Accuracy: Personal data is maintained as accurate and, where essential, kept up to date. Every reasonable step is undertaken to ensure that personal data found to be inaccurate, considering its processing purposes, is either promptly erased or rectified.

Storage Limitation: Personal data is retained in a format that permits the identification of data subjects for no longer than is absolutely necessary for the purposes for which the personal data is processed.

Integrity and Confidentiality (Security): Personal data is processed in a manner that guarantees its appropriate security, safeguarding it against unauthorised or unlawful processing, and against accidental loss, destruction, or damage, through the implementation of robust technical and organisational measures.

Accountability: As the data controller, the Head of Provision bears the responsibility for, and must demonstrably evidence, compliance with all the aforementioned principles.

4. Definitions

To ensure clarity, the following terms are defined:

Personal Data: Any information that relates to an identified or identifiable natural person ('data subject'). This encompasses, but is not limited to, names, addresses, contact details, photographs, unique pupil numbers (UPNs), and online identifiers.

Special Category Data: A subset of personal data that is particularly sensitive and requires higher levels of protection. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (used for identification purposes), data concerning health, or data concerning a person's sex life or sexual orientation. In an educational context, this specifically includes sensitive information such as safeguarding details, Special Educational Needs and Disabilities (SEND) information, and data pertaining to children looked after or those classified as children in need.

Criminal Offence Data: Personal data relating to criminal convictions and offences or associated security measures.

Processing: Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. This includes, for example, collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Data Subject: The identified or identifiable natural person to whom the personal data relates (e.g., pupils, staff, parents/carers, visitors).

Data Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. At ElevatEd, this responsibility rests with the Head of Provision.

Data Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller (e.g., IT service providers, cloud storage providers, payroll services).

Data Protection Officer (DPO): An individual formally appointed to provide independent advice and monitor compliance with data protection law within the organisation.

5. Roles and Responsibilities

5.1 Data Controller (Head of Provision):

Possesses the ultimate responsibility for ensuring comprehensive compliance with UK GDPR and DPA 2018.

Is responsible for the approval of this GDPR Policy and all other pertinent data protection policies (e.g., Data Retention Schedule, Data Breach Response Plan).

Is responsible for the formal appointment of a qualified Data Protection Officer (DPO).

5.2 Head of Provision:

Holds the responsibility for the day-to-day operational implementation and consistent application of this GDPR Policy across the provision.

Ensures that all staff are aware of their data protection obligations and adhere to established principles.

Manages the provision's data processing activities and verifies that appropriate security measures are effectively in place.

Acts as the primary liaison with the DPO and relevant external bodies (e.g., Information Commissioner's Office (ICO), Local Authority).

5.3 Data Protection Officer (DPO):

Alex Mcloughlin, Lead Administrator: alex@elevate-ed.co.uk

Acts as an advisor, tasked with informing and advising the provision and its staff about their obligations under UK GDPR and DPA 2018.

Monitors the provision's compliance with data protection law and its internal data protection policies.

Provides expert advice regarding the necessity and execution of Data Protection Impact Assessments (DPIAs).

Serves as the primary contact point for the ICO and for data subjects regarding all data protection matters.

5.4 All Staff (including temporary staff, volunteers, contractors):

Are mandated to adhere strictly to this policy and all other related data protection procedures.

Are required to complete mandatory data protection training as provided by the provision.

Must handle all personal data securely and maintain strict confidentiality.

Are obliged to report any suspected data breaches or data protection concerns immediately to the Head of Provision and/or the DPO.

Are only authorised to access personal data that is strictly necessary for the fulfilment of their specific job role.

6. Types of Personal Data Held

ElevatEd AP Ltd processes various categories of personal data relating to its stakeholders, including but not limited to:

Pupils: Full names, contact details, date of birth, unique pupil numbers (UPNs), attendance records, academic assessment data, progress reports, behaviour records, comprehensive safeguarding information, Special Educational Needs and Disabilities (SEND) information, pertinent health data, photographs/videos for educational or publicity purposes, details of referrals, and funding eligibility (e.g., Free School Meals, Pupil Premium).

Staff: Full names, contact details, comprehensive employment history, professional qualifications, Disclosure and Barring Service (DBS) check results, payroll and financial information, performance management data, relevant health information, and absence records.

Parents/Carers: Full names, contact details, and information pertaining to parental responsibility.

Governors/Proprietors: Full names, contact details, declarations of interest, and DBS check results.

Visitors/Contractors: Names, contact details, and vehicle registration details (collected for security and health and safety purposes).

7. Lawful Basis for Processing

Every instance of personal data processing undertaken by the provision must be underpinned by a clear lawful basis as stipulated in Article 6 of the UK GDPR. For the processing of Special Category Data, an additional explicit condition under Article 9 is always required.

Our primary lawful bases for processing personal data are typically:

Public Task (Article 6(1)(e)): This is the most common lawful basis for educational institutions. Processing is deemed necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (e.g., providing education, implementing robust safeguarding measures for children, maintaining statutory records as required by the DfE).

Legal Obligation (Article 6(1)(c)): Processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., fulfilling statutory returns to the Department for Education, adhering to safeguarding duties outlined in "Keeping Children Safe in Education," compliance with employment law, sharing data for Children Missing Education (CME) purposes).

Legitimate Interests (Article 6(1)(f)): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject. This basis is applied carefully and proportionately, for example, for some security measures (e.g., CCTV in common areas) or for certain internal administrative processes not covered by public task, where a clear balancing test demonstrates our legitimate interest.

Consent (Article 6(1)(a)): The individual has given clear, unambiguous consent for us to process their personal data for a specific purpose (e.g., for certain types of photographs/videos used in publicity, participation in optional non-statutory activities, or for specific research projects that fall outside our public task). When relying on consent, it is always freely given, specific, informed, and unambiguous, and crucially, it can be withdrawn by the data subject at any time.

For Special Category Data, we rely on specific conditions under Article 9, such as:

Substantial Public Interest (Article 9(2)(g)): Processing is necessary for reasons of substantial public interest, as defined by UK law (e.g., robust safeguarding of children, the effective provision of education and care, preventing unlawful acts, promoting equality of opportunity).

Health or Social Care (Article 9(2)(h)): Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.

Vital Interests (Article 9(2)(c)): Processing is necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent (e.g., in a life-threatening medical emergency).

Explicit Consent (Article 9(2)(a)): This condition is only used when no other appropriate lawful basis or condition under Article 9 applies, and where explicit, unambiguous consent is obtained (e.g., for the sharing of specific health data beyond statutory duties, or participation in specific research where the public interest basis is not applicable).

9. Data Subject Rights

Individuals are afforded specific rights concerning their personal data under UK GDPR. ElevatEd is committed to facilitating the exercise of these rights:

The Right to be Informed: Individuals have the right to be informed about how their personal data is being collected and processed. This is fulfilled through our clear and accessible Privacy Notices (refer to Section 13).

The Right of Access (Subject Access Requests - SARs): Individuals (or their legal representatives) have the right to request a copy of the personal data we hold about them.

o   SARs must be submitted in writing (via email or letter) and specifically directed to the Data Protection Officer (DPO).

o   We are committed to responding to SARs without undue delay and, in any event, within one calendar month of receiving the request. This timeframe may be extended by a further two months for complex or numerous requests, with the data subject being informed of any such extension.

o   No fee will be charged for SARs unless the request is deemed manifestly unfounded or excessive, or if further copies of previously provided information are requested.

o   We will rigorously verify the identity of the requester to prevent unauthorised disclosure.

o   We will ensure that the rights and freedoms of other individuals are not adversely affected by the disclosure of information.

The Right to Rectification: Individuals have the right to request that inaccurate or incomplete personal data held about them be corrected or updated without undue delay.

The Right to Erasure ('Right to be Forgotten'): Individuals can request the deletion of their personal data in certain specific circumstances (e.g., where the data is no longer necessary for the purpose for which it was collected, or where consent is withdrawn and no other lawful basis applies). This right is not absolute, particularly where the data is processed under a legal obligation or a public task.

The Right to Restrict Processing: Individuals can request the restriction or suppression of their personal data in certain circumstances (e.g., if the accuracy of the data is contested, or if the processing is unlawful but the data subject opposes erasure).

The Right to Data Portability: Individuals have the right to obtain and reuse their personal data for their own purposes across different services. This right primarily applies to data processed by consent or under a contract, and typically requires the data to be provided in a structured, commonly used, and machine-readable format.

The Right to Object: Individuals have the right to object to processing based on legitimate interests or performance of a public task, or for direct marketing purposes.

Rights in relation to Automated Decision Making and Profiling: Individuals have specific rights regarding decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects. ElevatEd does not currently use automated decision-making or profiling that would have a significant impact on individuals.

10. Data Security

ElevatEd AP Ltd implements robust technical and organisational measures to ensure the appropriate security of personal data, protecting it from unauthorised or unlawful processing and from accidental loss, destruction, or damage. These measures include:

Physical Security: Secure storage of all paper records in locked cabinets within secure rooms with restricted access.

Network Security: Deployment of robust firewalls, comprehensive antivirus and anti-malware software, secure Wi-Fi networks, and regular security updates across all systems.

Access Controls: Strict access controls based on job role and the 'need to know' principle, implementation of strong password policies, and the use of multi-factor authentication where technically feasible and appropriate.

Encryption: Utilisation of encryption for sensitive data, particularly when transmitted over networks or stored on portable devices.

Staff Training: Mandatory and regular training for all staff on secure data handling practices, security awareness, and breach procedures.

Clear Desk/Screen Policy: Enforcement of a policy to ensure that sensitive physical documents or digital information is not left visible or unsecured.

Secure Disposal: Implementation of secure procedures for the disposal of all data, both electronic (e.g., hard drive wiping, degaussing) and paper (e.g., cross-shredding, confidential waste disposal).

Processor Contracts: Ensuring that all third-party data processors (e.g., Management Information System (MIS) providers, cloud service providers, payroll services) are fully UK GDPR compliant and operate under legally binding data processing agreements outlining their responsibilities.

11. Data Retention

Personal data will not be retained for any longer than is strictly necessary for the purposes for which it was collected. ElevatEd maintains a comprehensive Data Retention Schedule (a separate, detailed document) which outlines the maximum retention period for different categories of personal data, in strict accordance with legal and statutory requirements (e.g., DfE guidance, Limitation Act 1980) and best practice guidelines.

12. Sharing Data

ElevatEd AP Ltd will only share personal data when there is a clear and legitimate basis to do so, adhering to the following principles:

Lawful Basis: Data will only be shared when there is a clear lawful basis (e.g., legal obligation, public task, explicit consent), and where an additional condition under Article 9 applies for special category data.

Safeguarding and Welfare: Data may be shared immediately where it is necessary for safeguarding purposes or for the vital welfare of a child (e.g., sharing with social care, police, health services under established safeguarding principles).

Data Sharing Agreements: Where appropriate and necessary (e.g., for regular, routine sharing with external bodies), a formal Data Sharing Agreement will be in place with the recipient, clearly outlining the purpose of the sharing, the types of data involved, and the security measures to be employed.

DfE Guidance: Compliance with Department for Education guidance on data sharing (e.g., pupil transfers between schools via Common Transfer Files (CTF)).

Security and Proportionality: All data sharing will be conducted securely, using appropriate transfer methods, and will be strictly proportionate to the purpose for which the data is being shared.

13. Privacy Notices

We are committed to transparency regarding our data processing activities. Clear, concise, and easily understandable Privacy Notices will be provided to all data subjects (pupils/parents/carers, staff, governors, visitors) at the point of data collection or as soon as practically possible thereafter. These notices explicitly explain:

What specific personal data we collect.

The precise purposes for which we collect it.

How we will use and process the data.

With whom we may share the data.

How long we will retain the data.

The individual's statutory data protection rights.

Contact details for our Data Protection Officer (DPO) and the Information Commissioner's Office (ICO).

These Privacy Notices are published on our official website and are readily available in paper format upon request.

14. Data Protection Impact Assessments (DPIAs)

A comprehensive Data Protection Impact Assessment (DPIA) will be conducted for any new project, system, or process that is likely to result in a high risk to individuals' data protection rights and freedoms. This includes, but is not limited to:

The introduction of new technologies (e.g., extensive biometric systems, new large-scale CCTV deployments).

Large-scale processing of special category data (e.g., new comprehensive health databases).

Systematic processing of data concerning vulnerable individuals (such as pupils within an Alternative Provision setting).

Transferring personal data outside the UK or the European Economic Area (EEA).

The DPIA process involves a structured approach: identifying the necessity for a DPIA, thoroughly describing the proposed processing operation, assessing its necessity and proportionality, identifying and rigorously assessing all potential risks to data subjects, and finally, identifying and documenting comprehensive measures to mitigate those identified risks. The DPO will be consulted at all stages of the DPIA process.

15. Data Breaches

A personal data breach is defined as a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
In the event of a suspected or actual data breach, the following immediate and systematic steps will be taken, as further detailed in our separate Data Breach Response Plan:

Containment and Recovery: Immediate action will be taken to limit the damage caused by the breach and to restore affected systems and data integrity.

Assessment of Risk: A rapid assessment will be conducted to determine the likelihood and severity of the resulting risk to individuals' rights and freedoms.

Notification:

o   If the breach is likely to result in a high risk to individuals' rights and freedoms, the Information Commissioner's Office (ICO) will be notified without undue delay and, where feasible, within 72 hours of becoming aware of the breach.

o   If the breach is likely to result in a high risk to individuals' rights and freedoms, affected data subjects will also be informed directly without undue delay.

Investigation and Review: A thorough investigation of the breach will be conducted to ascertain its root causes, and robust measures will be implemented to prevent recurrence.

16. Staff Training

All staff members (including temporary staff, volunteers, and governors) will receive mandatory data protection training upon their induction and at least annually thereafter. This comprehensive training will cover:

Their specific responsibilities and obligations under this policy.

A clear understanding of data protection principles.

How to recognise, respond to, and report suspected data breaches.

Procedures for handling Subject Access Requests (SARs) and other data subject rights requests.

Specific guidance pertinent to handling the sensitive pupil data prevalent in an Alternative Provision setting.

17. Policy Review

This policy will be subject to a comprehensive review at least annually by the Head of Provision. The review process will critically consider:

Any changes in data protection legislation, statutory guidance, or ICO recommendations.

Feedback received from the DPO, staff, pupils, and parents/carers.

Outcomes of any internal or external data protection audits or incident investigations.

The introduction of any new technologies or data processing activities within the provision.