Safeguarding & E-Safety Policy

1.    Purpose and Scope

This policy outlines the commitment of Onion Training to safeguard all participants. As a digital-only provider, we adopt the best-practice recommendations set out in the Department of Education’s September 2023 guidance: ‘After-school clubs, community activities and tuition: safeguarding guidance for providers.’

2.    Low-Contact Delivery Model

To minimise safeguarding risks, Onion Training operates a restricted interaction model:

• Asynchronous Learning: The course is self-paced. There are no live video sessions, webcams, or real-time audio interactions.
• No Peer Interaction: The platform does not host chat rooms, forums, or user profiles. Students cannot see or communicate with other students.
• Official Communication Only: All contact between students and Onion Training is restricted to our official support email and encrypted web forms. We do not use phone, personal messaging, or social media for student support.

3.    Data Minimisation & Privacy

In accordance with GDPR and safeguarding best practices, we collect only the minimum data required for course participation: Student Name and Email Address. This data is used solely for account management and progress tracking.

4.    Digital Safety & Monitoring

• Filtering & Monitoring: Our platform utilises appropriate digital filtering to ensure students are only exposed to age-appropriate, professional curriculum content.
• Position of Trust: All staff are trained to maintain professional boundaries appropriate for 16 - 17-year-olds, in compliance with the Sexual Offences Act 2003 (updated 2022).

5.    Identifying and Reporting Concerns

While interaction is limited to email, we remain vigilant for signs of distress or disclosure.

• Monitoring Support Channels: If a student discloses a safeguarding concern (e.g., a threat to their safety or wellbeing) via a support email or feedback form, the Designated Safeguarding Lead (DSL) will be notified immediately.
• Reporting to Schools: As an external provider, our protocol is to immediately contact the Safeguarding Lead at the student’s school (the DofE Licensed Organisation). They hold the primary duty of care and the necessary local authority links to support the student.
• Incident Log: A detailed record of any such disclosure and the subsequent referral will be kept in our secure, confidential Incident Log.

Complaints Procedure

1.    Our Commitment

Onion Training is committed to providing high-quality software testing education. We value feedback and take all complaints seriously, viewing them as an opportunity to improve our course and platform.

2.    How to Raise a Complaint

If you are dissatisfied with any aspect of our service, please contact us as soon as possible via our contact form.

3.    Our Three-Stage Process

• Stage 1: Informal Resolution: We aim to resolve most issues within 2 working days through direct communication with our support team.
• Stage 2: Formal Investigation: If you are not satisfied with the initial response, you can request a formal review. This will be escalated to a Founder, who will conduct a full investigation and provide a written response within 7 working days.
• Stage 3: Final Decision: If the matter remains unresolved, a final meeting (via video call) will be offered to reach a conclusion. Our decision at this stage is final.

4.    Record Keeping

All complaints are recorded in our internal Complaints Log, including the nature of the issue and the actions taken to resolve it.

Equal Opportunities & Accessibility

1.    Statement of Intent

Onion Training is committed to promoting equality of opportunity for all students, regardless of race, gender, disability, religion, or socio-economic background.

2.    Digital Accessibility

As an online-only provider, we strive to ensure our Software Testing Masterclass is accessible to all learners. This includes:

• Visual Accessibility: High-contrast text and scalable fonts.
• Cognitive Accessibility: Breaking complex technical topics into "bite-sized" modules with clear, jargon-free explanations.

3.    Fair Enrolment

We operate a non-discriminatory enrolment policy. Our pilot programme and standard pricing are designed to be transparent and accessible to schools and individual learners alike.

4.    Monitoring

We regularly review our course completion data and feedback to identify and remove any potential barriers to learning for underrepresented groups in tech.

Health & Safety Policy

1.    Statement of Intent

Onion Training recognises its responsibility to provide a safe and healthy learning environment for all participants. As our Software Testing Masterclass is delivered entirely online, this policy focuses on minimising the physical and digital risks associated with remote, screen-based learning.

2.    Learner Health & Well-being

While students engage with our platform from their own locations (home or school), we promote safe study habits by:

• Ergonomic Awareness: Encouraging students to set up a comfortable workspace and maintain proper posture during study sessions.
• Managing Screen Time: Our 200+ lessons are designed in "bite-sized" lessons to encourage regular breaks and prevent eye strain or digital fatigue.
• Mental Well-being: Providing clear, stress-free navigation and support channels to prevent frustration or anxiety related to technical barriers.

3.    Digital Safety & Environment

• Platform Stability: We maintain our digital infrastructure to prevent sudden outages that could disrupt the learning process.
• Content Safety: We ensure that all course materials are free from flashing lights or high-frequency sounds that could trigger photosensitive epilepsy or sensory sensitivities.

4.    Risk Assessment

Onion Training maintains a "Digital Risk Register" which is reviewed annually. This includes:

• Risk: Prolonged screen use. Mitigation: Modular course design in "bite-sized" lessons.
• Risk: Technical failure leading to loss of student work. Mitigation: Automatic progress saving and cloud backups.
• Risk: Online harassment. Mitigation: No public-facing student profiles or unmoderated chat functions.

5.    Responsibilities

The Founders of Onion Training hold primary responsibility for the implementation of this policy. Any health and safety concerns raised by students or schools will be reviewed immediately as part of our Incident Reporting procedure.

Emergency Procedures & Incident Reporting

1.    Definition of an Emergency

For the purposes of our digital delivery, an "Emergency" is defined as:

• Total Platform Failure: A sustained outage of the Software Testing Masterclass exceeding 24 hours.
• Data Breach: Unauthorised access to student personal data or progress records.
• Critical Safeguarding Alert: An immediate threat to a student’s life or safety disclosed via the platform.

2.    Emergency Response Procedures

Technical Failure: In the event of a critical server or platform failure, we will:

1. Immediately notify all enrolled participants via their registered contact email.
2. Implement our disaster recovery plan to restore data from the most recent secure cloud backup.
3. Provide an estimated "Return to Service" time within 4 working hours of the outage.

Data Breach (GDPR): If a breach is detected, we will:

1. Identify the scope of the breach and secure the platform.
2. Notify the Information Commissioner’s Office (ICO) within 72 hours if required.
3. Inform affected participants and schools regarding what data was accessed and the steps taken to secure it.

Safeguarding Emergency: If a student discloses immediate harm:

1. The founder will immediately call the student’s school (or local emergency services if the school is unreachable).
2. We will provide all relevant digital logs to the authorities to assist in the welfare check.

3.    Incident Reporting

An "Incident" is any non-emergency event that disrupts the standard learning experience (e.g., a minor software bug, a student complaint, or a short-term login issue).

The Incident Log: Onion Training maintains a centralised, secure Incident Log. Every entry must include:

• Date and time of the incident.
• Description of the event.
• Names of those involved (pseudonymised where appropriate for GDPR).
• Action taken to resolve the issue.
• Lessons learned to prevent recurrence.

Reporting to DofE/Schools: Significant incidents that impact a student's ability to complete their "Skills" section will be reported to the relevant DofE Leader or School Coordinator within 48 hours.

4.    Review and Training

These procedures are reviewed every six months to ensure contact details for emergency services and school leads remain accurate.