S-MB COMPANY PRIVACY POLICY
S-MB Company is committed to protecting the privacy of our students, parents/guardians and staff. This Privacy Policy explains what information S-MB Company collects, why we use it, how it is stored and shared, and the rights available to students and parents/guardians.
S-MB Company is responsible for deciding how and why personal information is collected and used in connection with the operation and administration of S-MB classes, programs, rehearsals, performances, competitions, festivals and related activities.
If you have any questions about how S-MB Company handles personal information, please contact us at:
Email: info@s-mbcompany.com
Data controller legal name and postal contact address: [Sara to confirm the legal entity/person operating S-MB Company and insert the postal address before issue]. Policy version: October 2026 revised draft.
S-MB Company will only ask for personal and medical information that is reasonably necessary for the administration and safe delivery of our activities. Depending on the student's participation, this may include:
· Student name and date of birth.
· Parent/guardian contact details.
· Student email address, where appropriate.
· Emergency contact information.
· Relevant medical, allergy, injury or other health information that may affect safe participation.
· Information relating to a student's participation in S-MB classes and programs.
· Information relating to rehearsals, performances, competitions, festivals and events.
· Photography and video consent.
· Information relating to attendance and participation.
· Other information reasonably required to administer a student's participation with S-MB Company.
Where relevant, we also hold payment/transaction records, communications, incident and safeguarding records, and approved online-session account or attendance information. The information actually collected depends on the activity. We receive information from students and families, and where necessary from authorised teachers, event organisers or safeguarding agencies.
Where appropriate, S-MB Company may use a dancer's own email address for communication relating to their participation with S-MB Company.
This may apply particularly to dancers aged 16 and over, where the dancer has requested that their own email address is used. Where a dancer's own email address is provided, it may be used for relevant S-MB communications in place of, or alongside, a parent/guardian email address, as appropriate.
Communication with under-18 dancers follows the Safeguarding Policy and approved professional channels. A dancer’s own email address does not remove appropriate parent involvement or the dancer’s privacy rights. We do not disclose recipients’ addresses unnecessarily in group emails.
Information provided to S-MB Company may be used to:
· Administer S-MB classes and programs.
· Contact parents/guardians and students regarding classes, rehearsals, performances, competitions, festivals and events.
· Respond to emergencies or medical situations where necessary.
· Maintain appropriate emergency and medical information.
· Organise participation in performances, competitions, festivals and other events.
· Communicate important information relating to S-MB activities.
· Maintain appropriate records relating to students and their participation.
· Meet our safeguarding and safety responsibilities.
· Manage photography and video consent.
· Monitor attendance and participation where necessary for the administration and safe delivery of S-MB activities.
S-MB Company will only use personal information for purposes connected with the student's participation and the operation of S-MB Company, or where otherwise permitted or required by law.
S-MB Company will only collect and use personal information where there is a lawful basis for doing so under applicable UK data protection law. Depending on the purpose, this may include:
· Contract: information necessary to enter into or perform a contract with the individual concerned, such as administering a booking made by that person. Where the parent is the contracting party, the parent’s contract does not automatically establish this basis for all processing of the child’s data.
· Where processing is necessary for S-MB Company's legitimate interests in operating and administering its activities, provided those interests do not override the individual's rights and interests.
· Where S-MB Company has a legal obligation to process information.
· Where consent has been provided, including where consent is required for optional uses such as certain photography and video activities.
· Vital interests: processing necessary to protect someone’s life or other vital interests in an emergency. This is not a general basis for all routine safety administration.
Medical and health information is special category data and requires additional protection. S-MB Company will only collect and use such information where permitted under applicable data protection law and where an appropriate special category condition and safeguards apply. Where appropriate, S-MB Company may rely on explicit consent for the use of health information.
We assess and record the basis for each purpose before processing. Routine student attendance, professional communications and safe administration may rely on legitimate interests following a balancing assessment that gives particular weight to children’s rights. Optional publicity relies on separate consent. Legal obligation is used only where an identifiable law requires processing.
Routine health information requires an Article 6 basis and an Article 9 condition; where we rely on explicit consent, we obtain a clear, specific statement from the person able to give it. Emergency health processing may rely on vital interests only where the legal criteria, including inability to consent, are met. Necessary safeguarding processing may use an applicable substantial-public-interest condition and the corresponding Data Protection Act 2018 safeguards. We document the condition and maintain an appropriate policy document where required. We do not change from consent to another basis merely to defeat withdrawal.
Parents/guardians are asked to provide S-MB Company with relevant medical information, injuries, allergies or other information that may affect a student's ability to participate safely. Parents/guardians should notify S-MB Company as soon as possible if this information changes.
Medical and emergency information will be treated as confidential and will only be accessed or shared where necessary for the student's welfare, safety, safeguarding or the administration of S-MB activities.
S-MB Company takes reasonable steps to ensure that personal information is stored securely and is only accessible to authorised people who require the information for their role.
Information provided through S-MB application and registration processes will be securely stored and reviewed regularly. S-MB Company will take appropriate measures to protect personal information against loss, misuse, unauthorised access, alteration or disclosure.
Access is limited by role. Safeguarding records are separated from routine class records, and medical details are shared only with those needing them for safe participation. Use approved accounts, secure transfer methods and protected devices; paper records must be secured. Staff must report suspected loss or unauthorised disclosure promptly so S-MB can assess containment and any required notification.
S-MB Company will retain personal information only for as long as reasonably necessary for the purpose for which it was collected. Different types of information may be retained for different periods depending on the nature of the information and any legal, safeguarding, financial, administrative or record-keeping requirements.
When a student leaves S-MB Company, information will be reviewed and securely deleted or disposed of when it is no longer reasonably required. Safeguarding, legal, financial or other records may need to be retained for longer where there is a legitimate reason or legal requirement to do so.
Our retention criteria are: class and contact records while participation and necessary administration continue; current medical details while needed for safe participation, subject to review when circumstances change; financial records for applicable tax/accounting requirements; images and teaching recordings only while needed for the stated authorised purpose; and incident/safeguarding records for the justified period determined by legal, safeguarding and insurance requirements. Records under investigation or a legal hold are preserved. Consent records are retained where needed to demonstrate lawful use.
Before issue, Sara must confirm the operational retention schedule, including the actual periods or deletion triggers for teaching recordings, publicity images, student records, financial records and safeguarding records, and ensure staff follow it. These periods must not be inferred from a student leaving or applied indiscriminately to every record.
S-MB Company will not routinely share personal information with unrelated third parties. Information may, however, need to be shared where this is necessary for a student's participation in an S-MB activity, performance, competition, festival or event.
For example, information may be provided to relevant competition or festival organisers, such as YAGP, where this is necessary to register or facilitate a student's participation.
S-MB Company may also use service providers to support the administration and delivery of its activities. Where another organisation processes personal information on behalf of S-MB Company, S-MB Company will take appropriate steps to ensure the information is handled in accordance with applicable data protection requirements.
Only information reasonably required for the relevant purpose will be shared. Information may also be shared where necessary to protect a student's safety or welfare, respond to an emergency, meet a safeguarding responsibility, or where S-MB Company is required or permitted to do so by law.
Recipients may include authorised S-MB staff, emergency services, social work or police, insurers and professional advisers, relevant event organisers and contracted administration/online-platform providers, where needed for the stated purpose. Some event organisers act as independent controllers and provide their own privacy notices. We do not sell personal information.
Where a provider or event organiser receives data outside the UK, we assess the transfer and use the applicable UK adequacy arrangements or appropriate safeguards and required assessment; exceptions are used only where their conditions are met. Before issue, Sara must verify the actual providers, countries, recipient roles and transfer mechanisms and supply relevant details to affected families. Provider-specific information and copies of relevant safeguards can be requested through our contact address.
S-MB Company may photograph and/or record students during classes, rehearsals, performances, competitions, festivals, workshops and other S-MB activities.
Photography and video may be used for:
· The S-MB Company website.
· Facebook.
· Instagram.
· TikTok.
· YouTube.
· General marketing and promotional material.
· Printed promotional material.
· Competition, performance, festival and event publicity.
· Internal teaching and training purposes.
· Sharing with parents/guardians.
· Sharing with relevant external organisations, including competition and festival organisers such as YAGP.
Photographs and videos will only be used in accordance with the consent provided by the student's parent/guardian or, where appropriate, the student.
We normally use a first name only when identifying a student alongside an image, where that identification has been specifically agreed. Social-media tagging or publication of a full name requires a separate, informed choice and safeguarding review; neither is a default. We avoid live locations, schedules or other details that could place a child at risk.
No images are taken in toilets, changing rooms or during personal care. Staff use authorised equipment and storage; any exceptional personal-device use must follow the documented safeguarding procedure. Students who must not be identifiable are protected discreetly. Permission to capture an image is distinct from permission to publish it.
Where consent is the basis, we obtain freely given, specific, informed permission from the student where they have sufficient understanding, or from a person with parental responsibility where appropriate. We respect the student’s objection to photography even where a parent has agreed. In Scotland, children aged 12 or over are presumed sufficiently mature to exercise data-protection rights unless there is evidence otherwise; this is not a blanket rule that parents decide all uses until age 16 or 18.
Record separate choices for internal teaching/feedback, sharing with families or event organisers, and public website/social-media/printed publicity, with additional agreement for identifying tags where proposed. Optional publicity is not a condition of attending ordinary classes. Keep the consent record, explain the duration and review preferences when purposes or circumstances change. Fresh consent is required for materially different uses; participation consent is not blanket media consent.
Parents/guardians and students have the right to withdraw or change consent at any time where processing is based on consent.
Requests may be made by email to the address below or through another clear communication to S-MB. We will record and action withdrawal; a specific form or written request is not compulsory.
S-MB Company
Email: info@s-mbcompany.com
Withdrawal does not affect the lawfulness of earlier consent-based processing. We will stop future uses covered by the withdrawn consent and remove consent-based material from channels we control where required, unless another lawful ground justifies retention. We will assess deletion requests and explain any limits, including already-distributed print material, independent third-party copies and records required for legal reasons; we cannot guarantee recall of every public copy.
Where S-MB Company provides virtual classes, students and parents/guardians must follow the S-MB Online & Virtual Class Safety Agreement and complete any required virtual consent form before participating.
Students and parents/guardians must not record, save, photograph or capture screen images containing S-MB teachers or other dancers during virtual classes. Students may record or photograph themselves for their own purposes, provided that no other student or teacher is captured.
Online classes are not routinely recorded through Zoom. Any teacher screen capture, recording, transcription or similar feature requires specific authorisation, advance notice, an identified lawful basis and appropriate permissions for everyone identifiable. Explain its purpose, access and deletion arrangements and avoid unnecessary household details. Optional recording consent is separate from class participation, with a practicable non-recorded alternative where possible. Follow the Online & Virtual Class Safety Agreement and Safeguarding Policy.
Subject to applicable legal conditions and exemptions, students and parents/guardians may have rights in relation to the personal information S-MB Company holds about them/their child. These may include:
· The right to request access to personal information held by S-MB Company.
· The right to request correction of inaccurate or incomplete information.
· The right to request deletion of information where there is no lawful reason for S-MB Company to continue holding it.
· The right to request restriction of processing in certain circumstances.
· The right to object to certain processing, where applicable.
· The right to withdraw consent where processing is based on consent.
· The right to data portability in circumstances where this right applies.
These rights are not absolute and may depend on the lawful basis for processing and other legal requirements.
Students have rights over their own personal information. Parents/guardians may make requests about their own information or act for a child where appropriately authorised or where the child cannot exercise the right themselves. Parenthood alone does not give unrestricted access to a child’s records; we consider capacity, authority, the child’s wishes, welfare and applicable exemptions.
You can make a request verbally or in writing. Email is a convenient route, but you do not need a specific form or legal wording:
S-MB Company
Email: info@s-mbcompany.com
We normally respond without undue delay and within one month, subject to lawful rules on necessary identity/authority checks or clarification. For complex or multiple requests, an extension of up to two further months may apply; we explain an extension within the applicable deadline. Requests are normally free. We will explain any lawful restriction or refusal and the right to complain.
Parents/guardians and students are responsible for informing S-MB Company of changes to relevant student, parent/guardian or dancer information.
· Contact details.
· Email addresses.
· Emergency contacts.
· Medical information.
· Allergies.
· Injuries or other circumstances that may affect participation.
Where a dancer has requested that their own email address is used for S-MB communications, they should also inform S-MB Company of any changes to that email address. Keeping information up to date helps S-MB Company maintain accurate records and support the safety and welfare of students.
S-MB Company takes the safety and welfare of its students seriously. Information relating to safeguarding concerns will be handled securely and only shared as far as reasonably necessary to manage the concern and protect the relevant student.
S-MB Company's Safeguarding Policy should be read alongside this Privacy Policy. Safeguarding responsibilities may require information to be shared without consent where this is necessary and lawful to protect a child or another person.
Necessary and proportionate safeguarding information may be shared without consent where a lawful basis applies. Decisions and referrals are recorded securely. We may withhold notification or access where disclosure could endanger a child, reveal protected third-party information or compromise an investigation, applying the relevant legal tests. Safeguarding records are not automatically disclosed to a parent.
If you have any questions or concerns about how S-MB Company collects, stores or uses personal information, or if you wish to request information we hold or change your consent, please contact:
S-MB Company
Email: info@s-mbcompany.com
If you remain dissatisfied with how S-MB Company has handled your personal information, you have the right to raise a concern with the Information Commissioner's Office (ICO).
You can contact the ICO at ico.org.uk/make-a-complaint or on 0303 123 1113. You may complain directly to the ICO; contacting S-MB first does not remove that right.
This Privacy Policy will be reviewed periodically and may be updated where there are changes to legislation, guidance, S-MB Company activities, technology or the way personal information is collected or used.
SAFEGUARDING POLICY
Policy Version: October 2026
Designated Safeguarding Lead (DSL): Sara-Maria G Barton
Depute Safeguarding Lead (DepSL): Daniella Brown
Safeguarding contact: info@s-mbcompany.com
Review cycle: Annually, or sooner where legislation, guidance, S-MB activities or identified risks change.
S-MB Company is committed to protecting children and young people from harm and promoting their safety, welfare and wellbeing. We recognise our responsibility to take safeguarding concerns seriously, respond appropriately and maintain a safe and supportive environment for all students involved in S-MB activities.
S-MB Company is committed to safeguarding students without discrimination on the grounds of age, disability, race, religion or belief, sex, gender reassignment, pregnancy or maternity, marriage or civil partnership, or sexual orientation.
This policy should be read alongside the S-MB Privacy Policy, Online & Virtual Class Safety Agreement, and other relevant health, safety and conduct procedures.
S-MB Company operates in Scotland and this policy is intended to reflect the Scottish child protection framework, including the National Guidance for Child Protection in Scotland 2021 – updated 2023, together with applicable Scottish legislation, guidance and Disclosure Scotland requirements.
The National Guidance provides a national framework describing responsibilities and expectations for those involved in protecting children in Scotland. S-MB Company will keep its safeguarding arrangements under review and update this policy where relevant legislation, guidance or practice changes.
Where this policy conflicts with applicable law or current statutory guidance, S-MB Company will follow the applicable legal and statutory requirements.
This policy applies to:
· All students participating in S-MB Company activities.
· All S-MB teachers, staff, volunteers, contractors and other individuals working for or on behalf of S-MB Company.
· S-MB classes, programs, rehearsals, performances, competitions, festivals, workshops, trips and other activities organised or facilitated by S-MB Company.
· Online and virtual activities delivered by S-MB Company.
· Activities taking place at S-MB venues and at external venues used by S-MB Company.
For safeguarding purposes, S-MB Company treats anyone under the age of 18 as a child or young person. Safeguarding responsibilities therefore continue to apply to students aged 16 and 17.
Safeguarding means taking reasonable and appropriate steps to protect children and young people from harm, abuse, neglect and exploitation and to promote their safety and wellbeing.
Safeguarding concerns may include, but are not limited to:
· Physical abuse.
· Emotional or psychological abuse.
· Sexual abuse or sexual exploitation.
· Neglect.
· Bullying, including cyberbullying.
· Exploitation, trafficking or other forms of harm.
· Domestic abuse or concerns arising within a child's home or wider circumstances.
· Online harm or inappropriate online contact.
· Concerns about the behaviour of an adult towards a student.
· Any situation in which a child or young person may be at risk of significant harm.
· Abuse between children, including sexual harassment, harmful sexual behaviour, coercion and unwanted sexual contact.
· Humiliating or coercive teaching, body shaming, unsafe weight-control advice, excessive training or pressure to dance through injury.
· Take safeguarding concerns seriously and respond promptly and appropriately.
· Provide a safe and supportive environment for students.
· Ensure staff understand their safeguarding responsibilities and know how to report concerns.
· Ensure relevant staff receive safeguarding training appropriate to their role.
· Use appropriate recruitment and pre-employment checks, including Disclosure Scotland checks where required.
· Maintain appropriate first-aid and emergency arrangements for S-MB activities.
· Carry out appropriate risk assessments for activities and venues.
· Handle safeguarding information securely and share it only where necessary and lawful.
· Review safeguarding arrangements regularly and update them where required.
· Work with parents/guardians and relevant external organisations where appropriate to support student safety and welfare.
All staff and volunteers have a responsibility to promote the safety and wellbeing of S-MB students. They must follow this policy and any related safeguarding procedures that apply to their role.
· Remain alert to possible signs of abuse, neglect, exploitation or other safeguarding concerns.
· Listen appropriately if a student raises a concern or makes a disclosure.
· Take concerns seriously and avoid dismissing, investigating or attempting to prove an allegation themselves.
· Report safeguarding concerns promptly through the S-MB reporting route.
· Maintain appropriate professional boundaries with students.
· Never engage in sexual activity or inappropriate conduct with a child or young person.
· Never deliberately place a student at unnecessary risk of harm.
· Maintain appropriate confidentiality while understanding that safeguarding information may need to be shared to protect a child or another person.
· Complete safeguarding training and raise any questions about safeguarding responsibilities with the DSL.
Sara-Maria G Barton is S-MB Company's Designated Safeguarding Lead (DSL) and has responsibility for overseeing S-MB's safeguarding arrangements.
· Acting as the main safeguarding point of contact for S-MB staff and students.
· Receiving and responding to safeguarding concerns.
· Ensuring safeguarding concerns are appropriately recorded and handled.
· Ensuring staff receive appropriate safeguarding training.
· Reviewing this policy and related safeguarding procedures.
· Considering whether information should be shared with parents/guardians or relevant external agencies, subject to safeguarding and legal requirements.
Safeguarding contact: info@s-mbcompany.com
A safeguarding concern may arise because a student makes a disclosure, a staff member observes something concerning, information is received from a parent/guardian or another person, or circumstances give rise to a reasonable concern about a student's safety or welfare.
Staff should listen calmly, take the concern seriously and avoid asking leading questions or carrying out their own investigation. The concern should be reported to the DSL as soon as reasonably possible.
Where a child is in immediate danger or there is an immediate risk of serious harm, emergency services should be contacted by calling 999. The DSL should then be informed as soon as reasonably practicable.
Reassure the student that they have done the right thing by speaking. Listen without judgement, do not promise secrecy, and explain that information will be shared only with people who need to help keep them safe. Ask only minimal, open questions needed to understand immediate safety; do not seek a detailed account or ask the child to repeat their disclosure unnecessarily.
The normal S-MB reporting route is:
· Report concerns to the DSL, Sara-Maria G Barton, without delay and on the same day. If the DSL is unavailable, contact the Depute Safeguarding Lead, Daniella Brown. Immediate protection or external referral must not wait for an internal response.
· Provide factual information about what was seen, heard or disclosed, including relevant dates, times and people involved.
· Do not investigate the concern yourself or promise a student that information will remain completely confidential.
· Keep any safeguarding records secure and only share them with those who need the information to manage the concern.
If the concern relates to the DSL, or if a staff member feels unable to report the concern to the DSL for another appropriate reason, the concern should be reported through an alternative appropriate route. Depending on the nature and urgency of the concern, this may include contacting Police Scotland or the relevant local authority child protection service. In an emergency, call 999.
If neither safeguarding lead is available, the concern involves a lead, or a concern remains unresolved and a child may be at risk, staff must contact the relevant local authority child-protection service or Police Scotland directly. In immediate danger call 999; suspected crimes can be reported to Police Scotland on 101. Record the referral, advice received and action taken. Use the service for the area where the child is located and seek advice if responsibility is unclear.
Record the concern promptly using a safeguarding concern record: student details; date, time and location; the child’s exact words where possible; factual observations; people present; immediate safety measures; who was contacted and when; advice received; and follow-up responsibility. Separate fact from opinion, date and identify the author, and preserve the original record. A written record must not delay urgent reporting.
S-MB Company will take any allegation or concern that a staff member, volunteer, contractor or other adult working with S-MB students may have harmed, abused or placed a student at risk seriously.
Such concerns must be reported without delay to the DSL. Where the concern involves the DSL, report to the Depute Safeguarding Lead and, where child-protection concerns arise, directly to the relevant local authority service or Police Scotland. Where both leads are implicated or there is a conflict of interest, use the external route directly. S-MB will act in accordance with safeguarding requirements, employment procedures and applicable law.
S-MB Company will not assume that an allegation is true or false. Concerns will be handled fairly, sensitively and with appropriate regard to the safety of the child and the rights of those involved.
The safeguarding lead handling the concern must assess immediate safety, obtain appropriate external advice and consider temporary restrictions on duties or contact with students. Suspension is not automatic and protective action is not a finding of guilt. Staff must not confront the person concerned, conduct a child-protection investigation or take steps that could compromise police or social-work enquiries.
Preserve relevant messages, records and other evidence securely; request preservation of relevant venue CCTV promptly through the authorised operator. Do not copy or forward suspected illegal images of children; seek police advice. Where the statutory referral criteria are met, S-MB must make a referral to Disclosure Scotland within the required timescale, including where the person resigns or leaves before action is completed.
Concerns about conduct below the apparent child-protection threshold, including boundary breaches or inappropriate communications, must also be recorded and reviewed for patterns. Staff may raise concerns about unsafe practice or failure to act through the deputy or relevant external safeguarding agency without having to obtain the DSL’s permission. Good-faith reporting must not result in retaliation.
Safeguarding information will be treated sensitively and securely. Information will only be shared as far as is necessary and lawful to manage the concern and protect the relevant child or another person.
Staff should not promise a student absolute confidentiality if information may need to be shared to protect them or someone else. Where information is shared, S-MB Company will seek to ensure that only information necessary for the relevant safeguarding purpose is disclosed.
Safeguarding information will be handled in accordance with applicable data protection law and the S-MB Privacy Policy.
Necessary and proportionate information may be shared without consent where there is a lawful basis to protect a child. Record the basis, purpose, recipient and reasons for sharing or withholding information. Consult social work or police before notifying parents where notification could increase danger, alert a suspected perpetrator or prejudice an investigation. Explain information sharing to the child and family where safe and appropriate.
S-MB must assess whether each role is a regulated role and ensure legally required PVG membership and appropriate disclosure checks are completed before the person carries out that role. This includes employees, volunteers and contracted or visiting teachers where their duties meet the criteria. Membership alone is not evidence of suitability or a substitute for safer recruitment.
PVG membership became mandatory for regulated roles from 1 April 2025. The five-year membership model began on 1 April 2026; existing members move to that model in phases or through a subsequent PVG application. S-MB will record the relevant membership status, disclosures reviewed, check dates and expiry/renewal dates where applicable, maintain its organisational interest and notify Disclosure Scotland when a person stops carrying out a regulated role for S-MB. Staff must report relevant changes affecting suitability promptly.
Recruitment must include identity verification, appropriate references, review of relevant qualifications and employment gaps, and a suitability decision recorded by the responsible manager. Staff must complete safeguarding induction before unsupervised duties, know venue emergency procedures and receive role-appropriate refresher training. The DSL and deputy must have training suitable for handling concerns and referrals.
Relevant staff will receive safeguarding and child-protection training appropriate to their role. Training should help staff understand safeguarding responsibilities, recognise possible concerns, respond appropriately to disclosures and know how to report concerns.
S-MB Company will maintain appropriate records of relevant checks and training.
Staff and volunteers are expected to maintain appropriate professional boundaries with students at all times.
· Communication with students should be appropriate to the student's age and the staff member's role.
· Staff should avoid situations or behaviour that could reasonably be misunderstood or place either the student or staff member at risk.
· Before physical corrections or spotting, explain the purpose and intended contact, seek the student’s agreement and respect refusal. Use verbal guidance or demonstration where possible. Contact must be necessary, proportionate and professional; never use intimate or humiliating contact. General parent permission does not override a student’s refusal. Where immediate injury prevention or emergency first aid requires contact, act proportionately, explain where possible and record significant incidents.
· Staff should not engage in inappropriate private or secretive communications with students.
· Concerns about professional boundaries should be raised with the DSL.
· One-to-one teaching must be planned, appropriately authorised and observable or interruptible, with another responsible adult aware of the session. Avoid isolated spaces and unnecessary closed-door contact. Record exceptional arrangements and review individual needs.
· Use S-MB-approved communication accounts and channels. Involve parents/guardians where appropriate to age and circumstances; communications must remain professional and accessible for safeguarding review. Do not use disappearing messages, secret communications or personal social-media friendships with under-18 students. Report unsolicited inappropriate contact rather than continuing it privately.
· Staff must not arrange informal private transport for students. Any S-MB transport requires prior authorisation, recorded parent/guardian arrangements where appropriate and a risk assessment. In an emergency prioritise safety, notify the safeguarding lead and record the circumstances.
· Protect privacy in toilets and changing rooms. Staff entry or assistance must be necessary, explained and appropriate to age and individual needs, with another adult informed where practicable. Do not unnecessarily observe students changing or use photography or recording devices in these areas.
S-MB Company recognises that safeguarding responsibilities also apply to online and virtual activities.
· Students must follow S-MB's Online & Virtual Class Safety Agreement when participating in online classes.
· Students must not record, photograph or capture screen images containing teachers or other students unless specifically authorised.
· Staff should maintain appropriate professional boundaries when communicating with students online.
· Concerns about online harm, inappropriate contact, bullying or other safeguarding issues should be reported through the normal safeguarding route.
The S-MB Privacy Policy explains how personal information, medical information, photographs and video are collected and used.
Parents/guardians are expected to:
· Provide accurate and up-to-date emergency and medical information.
· Inform S-MB Company promptly of changes that may affect a student's safety or participation.
· Ensure students are dropped off and collected in accordance with S-MB and venue arrangements.
· Raise safeguarding concerns promptly with S-MB Company.
· Support students in following S-MB's behaviour, online safety and other relevant policies.
Students are encouraged to speak to a trusted adult, teacher or the DSL if they are worried about their own safety or the safety of another student.
Parents/guardians are responsible before the agreed handover to S-MB. Once S-MB accepts a student into its care, responsibility continues until safe handover to an authorised collector or departure under a recorded, agreed independent-departure arrangement. The end of a class does not by itself end S-MB’s responsibility for a child awaiting collection. No child will be left alone or sent away because a collector is late.
Each venue must have written arrival, collection and sign-out arrangements, including authorised collectors, verification of changes, late collection and missing-student procedures. Independent movement and travel permissions must be based on age, maturity and individual needs; the label “senior” does not itself establish suitability. Keep emergency contacts accessible to authorised staff.
Supervision during breaks, waiting periods and between classes must be agreed in advance and clearly communicated to families. Where S-MB retains care, identify the supervising adult and the permitted areas. Self-practice requires explicit authorisation, an appropriate activity risk assessment, staff awareness, check-in arrangements and an accessible means of obtaining help. Plan staff absence and emergency cover so other students remain supervised.
S-MB's Online & Virtual Class Safety Agreement sets out additional responsibilities for students and parents/guardians when participating remotely.
Parents/guardians should inform S-MB Company of relevant medical conditions, allergies, injuries or other circumstances that may affect a student's ability to participate safely.
Students should not attend when illness may put themselves or others at risk. Where a student becomes unwell or injured, stop or adapt participation, obtain appropriate first aid or emergency assistance and contact their parent/guardian where appropriate. Under-18 students must remain supervised until safe collection or an agreed departure; they must not simply be sent away. In an emergency call 999 without waiting for parental permission.
Maintain documented first-aid needs assessments and verify suitable cover for all sessions, including when venue reception is absent. Record relevant qualifications and expiry dates; lapsed certificates must not be counted as current qualified workplace first-aid cover. Agree individual medical and medication arrangements, reasonable adjustments and assisted evacuation where needed. Record accidents and review controls after incidents.
Teaching must support physical and emotional wellbeing. Staff must not shame bodies, prescribe unsafe dieting or pressure students to continue through pain or injury. Concerns about eating, overtraining, self-harm or distress must be handled sensitively through the safeguarding route and appropriate professional support, without staff attempting diagnosis.
S-MB Company does not tolerate bullying, harassment, abusive or discriminatory behaviour. Students are encouraged to tell a teacher or another trusted adult if they experience or witness bullying or other behaviour that causes concern.
Concerns about behaviour will be dealt with fairly and proportionately, taking into account the safety and wellbeing of those involved.
Child-on-child abuse and sexual harassment must not be dismissed as banter or ordinary conflict. Protect and support affected students, assess ongoing contact and supervision, and refer child-protection concerns through the safeguarding route. Respond proportionately to the needs of all children involved without assuming that young age makes harmful behaviour harmless.
S-MB recognises that susceptibility to radicalisation may raise safeguarding concerns and will respond through its safeguarding, student-support and referral arrangements. The statutory Prevent duty applies to specified authorities; S-MB will confirm whether its legal status or activities bring it within that scope and comply where applicable. This policy does not assume that being a private dance provider alone makes S-MB a specified authority.
SMB’s approach to Prevent is safeguarding-led, proportionate and focused on early intervention. A person should not be referred simply because of their religion, ethnicity, political opinion, lawful beliefs, appearance, social background or participation in lawful debate. Concerns should be based on relevant behaviour, circumstances, vulnerability or evidence that indicates a potential risk.
Staff should report evidence-based concerns to the DSL or deputy without delay and seek advice through the appropriate Scottish safeguarding or Police Scotland route. Immediate danger must be reported to 999. Staff must not investigate suspected terrorism or make referrals solely on the basis of lawful beliefs or protected characteristics.
Photography and video are managed in accordance with the S-MB Privacy Policy and the relevant consent provided by parents/guardians or, where appropriate, students.
Safeguarding concerns relating to photographs, video, social media or online activity will be handled under this Safeguarding Policy and may also involve the S-MB Privacy Policy and Online & Virtual Class Safety Agreement.
No photography, filming or livestreaming is permitted in toilets, changing rooms or during personal care. Staff must use authorised equipment and accounts; personal devices must not be used to capture students unless explicitly authorised under a documented procedure controlling secure transfer, access and deletion.
Obtain and record the relevant permissions and lawful basis for the intended use, explain publication clearly and respect the student’s wishes. Identify students who must not be photographed or publicly identifiable and apply that restriction discreetly. Avoid publishing identifying details, live locations or schedules that could create a safeguarding risk. Provide a clear route to withdraw consent for future use and seek removal of published material where practicable.
S-MB Company will maintain appropriate safeguarding records and will handle them securely. Records should be factual, objective and limited to information necessary for the safeguarding purpose.
This policy will be reviewed annually, or sooner where there are changes to legislation, national guidance, S-MB activities, significant incidents or identified safeguarding risks.
Safeguarding records must be held separately from routine class records with access restricted to authorised people who need the information. Store paper records securely and electronic records with appropriate access controls. Preserve an audit trail of referrals, decisions, follow-up and case closure; transfer information securely when necessary.
The DSL must maintain a documented retention schedule appropriate to safeguarding records, applicable law, relevant guidance and insurance requirements, with periodic review and secure disposal. Do not delete records subject to an investigation, preservation request or legal hold. Data-protection requests involving safeguarding material must be assessed before disclosure.
· S-MB Company Privacy Policy.
· S-MB Company Online & Virtual Class Safety Agreement.
· S-MB Company student and parent/guardian policies and terms.
· Relevant venue health and safety and emergency procedures.
· Relevant recruitment, Disclosure Scotland/PVG and staff training procedures.
· Venue-specific arrival, collection, late-collection and missing-student procedures; dance activity and independent-practice risk assessments.
Designated Safeguarding Lead: Sara-Maria G Barton
Depute Safeguarding Lead: Daniella Brown
Email: info@s-mbcompany.com
DSL direct telephone: [Sara to insert and verify]. Deputy direct telephone: [Sara to insert and verify].
Emergency services: 999
Police Scotland non-emergency: 101
Where a safeguarding concern requires referral to a local authority or other external safeguarding service, S-MB Company will use the appropriate current local route for the area in which the concern arises.
Edinburgh child-protection/social-work daytime contact and out-of-hours service: [Sara to insert verified telephone numbers and current referral details].
Glasgow child-protection/social-work daytime contact and out-of-hours service: [Sara to insert verified telephone numbers and current referral details].
Implementation action: the DSL must complete and verify these contacts before this revised policy is issued, make them accessible to all staff and check them at each policy review. Email must not be the sole route for urgent concerns. Use 999 for immediate danger and 101 for suspected crimes when an emergency response is not required.
National Guidance for Child Protection in Scotland 2021 – updated 2023. This national guidance describes the responsibilities and expectations of those involved in protecting children in Scotland and provides the national framework for child protection practice.
Disclosure Scotland regulated-role, PVG membership and referral guidance; current Scottish Prevent guidance where applicable; and HSE first-aid needs-assessment and training guidance.
Implementation note: This policy should be implemented alongside S-MB's actual safeguarding procedures, staff training, recruitment arrangements and venue-specific emergency procedures. It should be reviewed if S-MB's activities or responsibilities change.
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