Key safeguarding contacts

For Joco Prep students, the name and contact details of the Designated Safeguarding Lead at each student’s school are kept on that student’s record.

1. Our commitment

Child protection is at the very core of the values of Joco Dance and Theatre Arts LLP and of everyone who works for or with us. We are fully committed to safeguarding and promoting the welfare of every child and young person who takes part in our activities. We recognise our responsibility to take all reasonable steps to promote safe practice and to protect children from harm, abuse and exploitation.

We believe that:

• the welfare of the child is paramount and takes precedence over all other considerations, including our teaching aims;

• every child, whatever their age, disability, sex, gender identity, race, religion or belief, or sexual orientation, has an equal right to protection from harm;

• some children are more vulnerable than others (for example, children with special educational needs or disabilities, mental health needs or caring responsibilities) and we will be alert to this;

• safeguarding is everyone’s responsibility, and working in partnership with children, parents and carers, schools and other agencies is essential;

• children should feel listened to, respected and able to speak up.

We will respond promptly and appropriately to any allegation, report or suspicion of abuse. Staff and volunteers will work together to build an ethos which embraces difference and diversity and respects the rights of children, young people and adults.

2. About us and who this policy covers

Joco Dance and Theatre Arts LLP is a limited liability partnership with two partners, Mrs Josephine Clarke and Mr Peter Clarke, referred to in this policy as “the partners”. Established in Ashtead in 2014, we provide weekly dance and performing arts classes, private lessons, IDTA and LAMDA examinations, festival entries, pantomime and Joco Shows. We also run Joco Prep, a daytime performing arts programme for students aged 11 and over.

This policy applies to everyone who works on our behalf, whether paid or unpaid: the partners, teachers, assistants, guest tutors, chaperones, volunteers and students on placement (together referred to as “staff”). It applies to all our activities, whether in the studio, at a theatre or examination venue, on a trip, or online.

In this policy, a “child” or “student” means anyone under the age of 18. “Safeguarding” means protecting children from maltreatment, preventing harm to their health or development, making sure they grow up with safe and effective care, and acting so that all children have the best outcomes. “Child protection” is the part of safeguarding that focuses on children who are suffering, or are likely to suffer, significant harm.

3. Legislation and guidance

This policy is based on the law and statutory guidance that apply in England, including:

• the Children Act 1989 and the Children Act 2004;

• the Children and Young Persons Act 1963 and the Children (Performances and Activities) (England) Regulations 2014;

• the Safeguarding Vulnerable Groups Act 2006, as amended by the Protection of Freedoms Act 2012;

• the Sexual Offences Act 2003;

• the Equality Act 2010;

• the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR);

• the Children’s Wellbeing and Schools Act 2026 and the Crime and Policing Act 2026;

• Working Together to Safeguard Children (Department for Education, 2026);

• Keeping Children Safe in Education (Department for Education, 2026), which applies to the schools our Joco Prep students attend, and which we follow wherever it is relevant to our work with those schools;

• Keeping children safe during community activities, after-school clubs and tuition (Department for Education guidance for providers of out-of-school settings);

• the safeguarding procedures of the Surrey Safeguarding Children Partnership.

4. Roles and responsibilities

4.1 The partners

The partners have overall responsibility for safeguarding. They will:

• make sure this policy is put into practice, properly resourced and reviewed every year;

• make sure safer recruitment procedures are followed and that every member of staff is trained;

• make sure all staff are properly insured, including public liability and professional indemnity insurance;

• make this policy available to parents, carers and partner schools, including on our website.

4.2 The Designated Safeguarding Lead (DSL)

The Principal, Josephine Clarke, is our Designated Safeguarding Lead and Online Safety Coordinator. She is responsible for making sure this policy and its procedures are followed. Peter Clarke is the Deputy DSL and acts for the DSL whenever she is unavailable. Staff at every class and activity will know who the DSL and Deputy are and how to reach them.

The DSL will:

• be the first point of contact for any safeguarding concern;

• decide what action to take, including referrals to Surrey C-SPA, the police or the LADO, and seek advice whenever unsure;

• keep accurate and secure safeguarding records;

• liaise with parents and carers and, for Joco Prep students, with the DSL at the student’s school;

• make sure all staff are trained, understand this policy and know how to report a concern;

• complete designated safeguarding lead training (such as the NSPCC’s Designated safeguarding officer course), refreshed at least every two years, and keep up to date with Surrey Safeguarding Children Partnership procedures. The Deputy DSL will be trained to the same level.

4.3 All staff and volunteers

Everyone who works with us will:

• understand their legal and moral responsibility to protect children from harm, abuse and exploitation;

• read this policy during their induction and whenever it is updated;

• report any concern about a child, or about the conduct of any adult towards a child, to the DSL without delay;

• follow the code of conduct in section 9 and complete the safeguarding training set out in section 8.

5. Recognising abuse and neglect

Abuse is a form of maltreatment of a child. Someone may abuse or neglect a child by causing harm, or by failing to act to prevent harm. Children may be abused by adults or by other children, in person or online. There are four main categories of abuse:

• Physical abuse: hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm, including fabricating or deliberately inducing illness in a child.

• Emotional abuse: persistent emotional maltreatment, such as making a child feel worthless, unloved or frightened, placing age-inappropriate expectations on them, serious bullying, humiliation, or seeing or hearing the ill-treatment of another person, including domestic abuse.

• Sexual abuse: forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. This includes non-contact activities, such as involving children in looking at or producing sexual images, and grooming in person or online.

• Neglect: persistent failure to meet a child’s basic physical or psychological needs, such as adequate food, clothing, shelter, supervision or medical care.

Staff should also be alert to:

• child-on-child abuse, including bullying and cyberbullying, sexual harassment, and the sharing of nude or semi-nude images;

• online harms, including grooming, sextortion and AI-generated sexual images of children;

• child sexual exploitation and child criminal exploitation, including “county lines”;

• domestic abuse and coercive control, including abuse within teenage relationships;

• radicalisation and extremism;

• female genital mutilation, forced marriage and so-called “honour”-based abuse;

• children who go missing from education or from home;

• mental health concerns, including self-harm, anxiety, and concerns about eating, weight or body image, which can be heightened in dance and the performing arts.

Possible signs include unexplained injuries; changes in behaviour, mood or appearance; withdrawal; fear of going home or of a particular person; sexual knowledge or behaviour that is not appropriate for the child’s age; poor hygiene or persistent hunger; significant weight change; frequent absence; and unexplained gifts or money. These signs do not prove that abuse is happening, but they must never be ignored. Staff should always think “it could happen here” and report what they notice. It is not a member of staff’s job to decide whether abuse has taken place; it is their job to pass on their concern.

6. What to do if you are worried about a child

6.1 If a child is in immediate danger

Call 999, then tell the DSL as soon as possible.

6.2 If a child tells you something

If a child discloses abuse, or tells you something that worries you:

• stay calm, listen carefully and let the child talk in their own words;

• reassure them that they have done the right thing in telling you, and that it is not their fault;

• do not promise to keep it a secret. Explain kindly that you will need to tell the person whose job it is to help keep them safe;

• if you need to clarify anything, ask only open questions (such as “Can you tell me more about that?”). Never ask leading questions, investigate, or approach anyone else involved;

• write down what was said as soon as possible, using the child’s own words, on the Record of Concern form. Do not photograph any injuries;

• report to the DSL immediately, and on the same day at the latest.

6.3 Reporting a concern

• All concerns, however small, must be passed to the DSL straight away. Small concerns can form part of a bigger picture. If the DSL is not available, report to the Deputy DSL.

• If neither can be reached and you believe a child may be at risk, contact Surrey C-SPA on 0300 470 9100 (or the Emergency Duty Team on 01483 517 898 out of hours) yourself. Anyone can make a referral.

• The DSL will decide on the next steps: making a referral to C-SPA, contacting the police, seeking advice from the C-SPA professionals’ advice line, or recording and monitoring the situation. Where a family would benefit from extra support, the DSL may, with the family’s agreement, signpost them to Surrey’s Family Help services.

• Parents and carers will usually be told about a referral, unless this could place the child at greater risk or interfere with a police investigation. The DSL will take advice from C-SPA or the police if in doubt.

• For Joco Prep students, the DSL will also share the concern with the DSL at the student’s school, unless advised otherwise by C-SPA or the police.

• If you feel a concern has not been acted on, you can and should contact C-SPA, the NSPCC Helpline or the police yourself. If the DSL is not satisfied with the response from C-SPA, she will follow the Surrey Safeguarding Children Partnership escalation procedure.

6.4 Child sexual abuse: duty to report

The Crime and Policing Act 2026 introduces a legal duty for people working in regulated activity with children to report child sexual abuse to the police or the local authority when they become aware of it, whether from the child, from the person responsible, or by witnessing it. It also makes it a criminal offence to prevent or deter someone from making such a report. We already work to this standard: any disclosure or knowledge of child sexual abuse will be referred by the DSL to Surrey C-SPA or the police without delay. Any member of staff who is not sure that a report has been made must make it themselves.

7. Concerns or allegations about staff, volunteers or the partners

Tell the DSL immediately if you are concerned that anyone who works or volunteers with us has:

• behaved in a way that has harmed, 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 may pose a risk of harm; or

• behaved in a way, in or outside work, that indicates they may not be suitable to work with children.

The DSL will contact the LADO on 0300 123 1650 within one working day, before taking any other action. We will not investigate the matter ourselves or tell the person concerned until the LADO has advised us what to do.

If the concern is about the DSL, the Deputy DSL or either partner, report it directly to the LADO. Because our two partners work closely together, this makes sure every concern is looked at independently.

Low-level concerns. Behaviour that does not meet the threshold above but is not in line with our code of conduct (for example, being over-familiar with a student, favouritism, private messaging, or taking photographs on a personal phone) must still be reported to the DSL. It will be recorded and addressed, as it may form part of a pattern.

We have a legal duty to refer to the Disclosure and Barring Service (DBS) anyone we remove from working with children, or who would have been removed had they not left, because they harmed or posed a risk of harm to a child. Where the LADO advises, we will also inform the schools of any Joco Prep students affected.

8. Safer recruitment, training and supervision

8.1 Recruitment checks

Before anyone starts teaching, supervising or chaperoning children for us, we will:

• see an enhanced DBS certificate with a check of the children’s barred list. We ask staff to join the DBS Update Service, which we check at least once a year; otherwise a new check is carried out every five years;

• check proof of identity and the right to work in the UK;

• check relevant teaching qualifications. Only suitably qualified people will be engaged to teach; anyone else assisting with teaching will work only under the supervision of a qualified member of staff;

• ask for a self-declaration of any criminal record or other information that may affect their suitability to work with children.

Volunteers and assistants. Since 1 September 2026, anyone who helps regularly with our classes or activities (more than three days in any 30-day period, or overnight) is in regulated activity with children, even when they are supervised. Volunteers and assistants aged 16 or over who help this often will have an enhanced DBS certificate with a check of the children’s barred list before they start, in the same way as staff. Young people under 16 cannot be DBS checked, so they are supervised at all times (see section 8.2).

We keep a record of all the checks carried out for each member of staff, so we can give schools written confirmation of these checks (see section 12.2).

8.2 Guest tutors, visitors and young assistants

• We will check the DBS certificate of any guest tutor or industry professional before they work with students. Any visitor who has not been checked will be supervised at all times by DBS-checked staff and will never be left alone with students.

• All visitors sign in and out, and are introduced to students by a member of staff.

• Young people under 18 who help in classes are supervised at all times, are never left in charge of children, and are not counted in staffing ratios.

8.3 Induction and training

• All staff receive a safeguarding induction covering this policy, the code of conduct and how to report a concern, before they start work.

• All teaching staff (including self-employed teachers and guest tutors) and all chaperones complete the NSPCC’s Introduction to safeguarding and child protection online course, or equivalent training agreed by the DSL, before they start working with students. They give us a copy of their certificate.

• Staff refresh this training at least every three years, for example with the NSPCC’s Safeguarding refresher course.

• Volunteers do not need to complete the NSPCC course, as they are supervised at all times by trained staff and are never left alone with students. They receive the safeguarding induction and must report any concern to the DSL in the same way as staff.

• Chaperones at shows and performances also complete the NSPCC’s Protecting children in entertainment course.

• The DSL and Deputy DSL complete the NSPCC’s Designated safeguarding officer training, or equivalent designated safeguarding lead training, and refresh it at least every two years.

• We keep a record of all training completed, with copies of certificates.

9. Code of conduct for staff

Everyone who works with us is in a position of trust and must keep clear professional boundaries. At all times, staff will endeavour to keep the highest standards of instruction and behaviour. Staff must:

• treat all students fairly and with respect, avoid favouritism, and never use humiliating language or sarcasm;

• never comment on a student’s weight, body shape or appearance;

• never have a sexual or romantic relationship with a student, or behave in any way that could be seen as grooming. This may be a criminal offence;

• avoid being alone with a student out of sight of others (see 9.3 for one-to-one lessons);

• not give personal gifts or money to individual students;

• not transport students in their own vehicles, except in an emergency or with the consent of the parent or carer and the agreement of the partners;

• not make or maintain contact with any student on personal social media or similar platforms, except in exceptional circumstances agreed by both partners and with the parent’s knowledge;

• never photograph or film students on a personal device;

• not smoke, vape, drink alcohol or be under the influence of drugs while working.

9.1 Physical contact in teaching

Teaching dance and performing arts can sometimes need physical contact, for example to correct alignment, prevent injury or support a lift. Staff will avoid any unnecessary physical contact and parents are told about this approach when their child joins us. Where contact is needed, staff will:

• consider alternatives first, such as demonstration or verbal and visual cues;

• explain what they are going to do and why, and ask the student’s permission first, respecting their right to say no;

• use the minimum contact needed, with an open hand, and avoid the chest, buttocks and groin;

• only make contact in the open, in view of others, and never in private.

If a student is distressed or upset, staff may offer proportionate physical comfort, such as a hand on the shoulder, with the student’s consent and in view of others. Physical intervention to restrain a student is only used where it is necessary to prevent injury, and will be recorded and reported to the parent and the DSL.

9.2 Changing areas and toilets

• Students change in designated changing areas, separate from adults and, where possible, separated by sex. Joco Prep students are expected to change independently.

• Staff will not enter changing areas while students are changing, except in an emergency or where a student needs help that has been agreed with their parent. Staff will knock and announce themselves, and wherever possible another adult will be present.

• Phones, cameras and other recording devices must never be used in changing areas or toilets, by anyone, at any time.

• Where a venue is shared with members of the public, we agree arrangements with the venue so that students use designated facilities and are not left unsupervised in public areas.

9.3 One-to-one lessons

One-to-one lessons (for example singing lessons, coaching or examination preparation) will:

• only take place with the parent’s knowledge and consent;

• be held in a room with a vision panel or an open door, at a time when other adults are on the premises;

• be recorded in a register. Parents are welcome to observe.

Staff must never arrange to meet a student one-to-one outside agreed lessons.

9.4 Communication with students and families

• All contact goes through official channels: the Joco work phone, team@jocodance.com and our official accounts. Staff must not use their personal phones, email or social media to contact students or their families, within or outside of work.

• Messages to students go to a group or copy in the student’s primary contact. Staff do not send private one-to-one messages to students.

• Any group chat for students (for example for Joco Prep) is set up by the partners, has a member of staff as administrator, and parents are told about it.

• All communication must be professional and sent at reasonable times.

10. Students’ wellbeing and behaviour

• All students will be treated equally and their dignity maintained. No form of unfair discrimination will be tolerated.

• No form of bullying, in person or online, will be tolerated. Child-on-child abuse will always be taken seriously and never dismissed as “banter” or “part of growing up”. Concerns will be dealt with under this policy, and those found to be bullying others will be subject to appropriate sanctions.

• The partners retain the right to ask a student to leave Joco Dance and Theatre Arts or Joco Prep if they persistently disrupt teaching or take part in or instigate anti-social behaviour. Where a student’s behaviour may be a sign that they are at risk of harm, this will be treated as a safeguarding concern first.

• We promote healthy, positive attitudes to the body. We do not weigh students or comment on their weight or shape. Costumes, choreography, music, lyrics and themes will always be appropriate to the age of the students.

• Staff will watch for signs of over-training, injury, exhaustion, anxiety about performance, or concerns about eating, and report them to the DSL.

• Students can share their ideas, views and concerns with any member of staff. They will know who the DSL is, and will be told about Childline. Our Complaints Procedure is available to students and families.

• We ask parents to tell us about any special educational needs, disability or medical condition, so that we can make reasonable adjustments and keep their child safe.

11. Safe practice in classes

• The wellbeing and safety of students takes precedence over all other aims of our teaching.

• No energetic instruction will be given without students first completing a warm-up, and every energetic session will end with a cool-down.

• All instruction will be suited to each student’s previous experience and ability, and no student will be required to perform movements beyond their capabilities.

• Class sizes are kept at a safe level for the space and activity. Joco Prep classes have a maximum of 12 students.

• We plan staffing so that an adult is always available to deal with an emergency, or with a student who needs help, without leaving a class unsupervised. Wherever possible two adults will be on site; where a teacher works alone, a partner or other named adult will be contactable and able to attend quickly.

12. Registers, attendance and collection

12.1 All classes

• We hold details of a primary contact for each student, usually a parent, guardian or carer. We discuss the student only with the primary contact, unless the primary contact confirms in writing that we may also discuss them with someone else. The exception is where we need to share information to keep a child safe (see section 17).

• Every student attending a class is recorded on a register, which stays on the premises throughout the class. Students are counted in at the start and counted out at the end, so that every student is accounted for while they are with us.

• Emergency contact and medical details for every student are available to staff at all times.

• No student may leave until collected by a parent, guardian or another adult they have authorised. A student may only leave on their own with the written consent of their primary contact. A member of staff will remain until all students have left.

• Late collection: staff will try the primary and emergency contacts and keep the student supervised in a safe, visible place. Staff will never take a student home themselves. If no one can be reached within 30 minutes of the end of the session, the DSL will seek advice from Surrey C-SPA (or the Emergency Duty Team out of hours) or the police.

• Missing student: if a student cannot be found, staff will supervise the other students, search the premises immediately and inform the DSL and the parent. If the student is not found within 10 minutes, we will call 999.

12.2 Joco Prep: working with schools

Joco Prep takes place during the school day, and most students remain on their own school’s roll. We therefore work closely with each student’s school.

• Before a student starts, we obtain the parent’s written consent, the name and contact details of the school and its DSL, and the parent’s agreement that we will share attendance, wellbeing and safeguarding information with the school.

• We provide each school with written confirmation of our safeguarding arrangements and the checks carried out on our staff, and we tell schools about any relevant changes, such as new staff.

• We take a register at the start of each session and after lunch, and send attendance to each school on the same day.

• If a student does not arrive and we have not been told why, we will contact the primary contact within 30 minutes of the start of the session and inform the school the same morning.

• Students are supervised at all times, including at breaks and lunch, and may not leave the premises during the day without the written permission of their primary contact.

• Safeguarding concerns are shared between our DSL and the school’s DSL. We ask schools to share any information we need to keep the student safe.

• If a student stops attending without explanation, we will inform their school and, if we are worried, Surrey C-SPA.

• Home-educated students: if a student is educated at home rather than on a school roll, we agree the arrangements above with their parent instead, and we will cooperate with any request for information from the local authority about their education.

13. Performances, examinations and trips

• We obtain a performance licence or a Body of Persons Approval from the local authority whenever the Children (Performances and Activities) (England) Regulations 2014 require one.

• Where the law requires it, children are supervised by chaperones approved by the local authority, with no more than 12 children per chaperone (or fewer if the licence says so). All chaperones have an enhanced DBS check.

• Children have dressing rooms separate from adults, with separate rooms for boys and girls.

• Every show, examination and trip is risk assessed. We obtain written consent and up-to-date medical and emergency contact details for every student taking part.

• For examinations, we follow the safeguarding requirements of the examination board.

• On any activity away from our usual premises, staff will regard themselves as being in loco parentis and will apply this policy as far as it is applicable and within their control.

14. Photographs and filming

• Students are photographed and filmed only for the purposes set out in our GDPR Privacy Notice. Before any image of a student is used on our website, on social media, in printed materials or in other marketing, we ask for the written consent of their primary contact. Consent is asked for at enrolment and can be withdrawn at any time.

• Taking part in a Joco show includes being filmed and photographed for the official show recording and photos, which are for the families of the students taking part. Photos needed for child performance licences are sent to Surrey County Council as the law requires. Parents with concerns can talk to us and have the right to object; we will try to accommodate them, for example through positioning or editing, although we cannot always remove a child from a group recording. Where a producer films or photographs a production, such as the panto, the producer is responsible for those images.

• Images are used only for these purposes. We never attach students’ names to their images, and we never use images that show a student in an inappropriate or undignified way.

• Recording in class is a useful teaching tool. Staff only take images on Joco devices. Class footage is stored securely, used only for teaching, and deleted when no longer needed; it is only shared to celebrate students’ achievements, for example on our website or social media, where the primary contact has consented.

• At shows, parents and audiences must follow the photography and filming rules announced for that event, and are asked not to post images of other people’s children online.

• Photography and filming are never allowed in changing areas or toilets.

15. Mobile phones and devices

Mobile phones are useful communication tools and can support safeguarding, but their cameras and internet access can also be misused, including for taking and sharing indecent images, exploitation and bullying. Misuse can affect anyone’s dignity, privacy and right to confidentiality, and phones can also be a distraction in class. This section applies to everyone with a phone or device at our classes, Joco Prep sessions or productions, including staff, volunteers, students, parents, carers and visitors.

We make sure all staff and volunteers:

• understand what counts as misuse and how to minimise risk;

• understand the need for professional boundaries and know what is acceptable use;

• take responsibility for their own behaviour; and

• report any concerns promptly.

Staff may carry their phones, but phones must be on silent and personal calls and messages limited to break times, other than in agreed exceptional circumstances. Staff must never use a personal phone to photograph students or to contact students or their families.

Students must not keep their phones on them during classes. Phones must be switched off or on silent and left in bags in the changing area, or with parents, and collected at the end of the session. Joco Prep students may use their phones at break times with staff permission, but never in changing areas or toilets.

Parents and visitors are asked not to use their phones in any area where children are present, unless there are exceptional circumstances.

16. Online safety

Safe use of the internet is essential to safeguarding everyone involved with Joco Dance and Theatre Arts. Josephine Clarke, Principal, is our Online Safety Coordinator. We will:

• give staff and volunteers clear direction on how to behave online in relation to our activities;

• support and encourage students to use the internet, social media and mobile phones in a way that keeps them safe and shows respect for others;

• support parents and carers to help keep their children safe online in relation to our activities;

• respond appropriately to any incident of inappropriate online behaviour, whether by an adult or a young person, in line with this policy;

• review the security of our information systems regularly, and make sure usernames, logins, email accounts and passwords are used securely;

• risk assess any social media platform or new technology before we use it.

Online lessons. Any lesson taught online uses an official Joco account. Parents are told when lessons take place and a parent or carer should be at home. Students should join from a shared space rather than a bedroom where possible, and both staff and students should be appropriately dressed, with a neutral background. Lessons are not recorded without the parent’s consent.

Nude or semi-nude images. If staff become aware that a nude or semi-nude image of a child (including an AI-generated or edited image) has been shared, they must not view, copy, forward or delete it, and must not ask the student to show it to them. They should report it to the DSL straight away.

17. Records, confidentiality and information sharing

• Safeguarding records are factual, dated, timed and signed, and record the child’s own words. They are kept securely and separately from general student records, and only the DSL and Deputy DSL can access them.

• Information is shared only with those who need to know it. Data protection law does not prevent us from sharing information to keep a child safe, and we may share information without consent where this is needed to protect a child.

• Personal information about the adults and children involved with us is held securely and shared only as appropriate.

• Child protection records are kept until the child’s 25th birthday, or longer if we are advised to. Records of allegations about staff are kept until the person reaches normal pension age or for 10 years, whichever is longer.

18. Venues, health and safety and first aid

• We liaise with the venues we use to make sure they are free of hazards and fit for the purposes of our classes, and we carry out risk assessments for each venue.

• Staff know the fire and evacuation procedures for every venue they work in.

• A fully equipped first aid kit is available at every class, and a trained first aider is present at every class and activity.

• All accidents and injuries are recorded and parents informed. Medical needs, allergies and medication are recorded and known to the staff working with the student.

19. Working with parents and carers

• We make this policy available to parents and carers on our website and on request, and we encourage them to be involved in our work.

• We ask parents to tell us anything that helps us keep their child safe, such as medical needs, special educational needs, court orders, or changes to who may collect their child.

• Parents and carers can raise any concern with the DSL. Our Complaints Procedure is available on request.

20. Whistleblowing

Anyone who has concerns about poor or unsafe practice, or about the way safeguarding is handled at Joco Dance and Theatre Arts, should raise them with the partners. If you do not feel able to do this, or you feel your concern has not been dealt with, contact the LADO (0300 123 1650), Surrey C-SPA (0300 470 9100) or the NSPCC Whistleblowing Advice Line (0800 028 0285). Anyone who raises a concern in good faith will be supported and will not be treated unfairly as a result.

21. Monitoring and review

The partners will review this policy every year, and sooner if the law or guidance changes or after any serious safeguarding incident. All staff will be told about any changes and will confirm by email or text message that they have read the updated policy.

This policy has been approved by the partners, Josephine Clarke and Peter Clarke, in November 2026.

Appendix: What to do if you are worried about a child

What we collect and why

We collect personal data to keep everyone safe, run classes and Joco Prep, enter students for exams and stage performances such as the yearly show and panto.

We never use personal data for research, sell it, or use it for automated decision-making or profiling.

Our legitimate interests are running a safe, well-organised dance and theatre school: keeping registers, communicating with families, organising classes, exams and shows, and keeping accurate records. These are uses families would expect, and we make sure they do not override your rights.

DBS checks involve criminal offence data. We use this only to meet our safeguarding obligations, under the conditions set out in Schedule 1 of the Data Protection Act 2018, and we keep an appropriate policy document explaining how we do this.

Where we get information from. Most information comes directly from parents/carers, students and staff. We also receive exam results from IDTA and LAMDA, DBS check results from the Disclosure and Barring Service (or the organisation that processes our checks), and, for Joco Prep, information from students’ schools needed to agree attendance and to keep the student safe.

Do you have to give us this information? We need student and parent contact details and emergency contacts to enrol a student; without them we cannot offer a place. We ask parents and carers for their child’s medical and allergy details, and we expect them to provide them: we need them to keep your child safe in class and at shows, exams and trips, and to keep them up to date. Giving us SEN information is your choice, but we strongly encourage it, so that we can support your child properly in class. Staff must provide DBS information before working with us. Consent to photos on our website and social media, and to marketing, is always optional.

Who we share it with

We only share personal data where it is needed, and everyone we share with knows their responsibilities for it.

• Chaperones, helpers and teaching staff – the information they need to look after students during classes, rehearsals and shows, including relevant medical needs and emergency contact details, marked restricted, so they are available in case of an emergency.

• IDTA and LAMDA – student details needed to enter exams.

• Surrey County Council – student details needed for child performance licences, which are a legal requirement, and chaperone details needed for chaperone approval.

• Pantomime and show producers – details of students taking part, only after parents/carers have accepted the opportunity.

• Performing arts agents – only with the parent/carer’s agreement.

• Schools of Joco Prep students – attendance, sent on the same day, so the school can record Joco Prep days correctly, and wellbeing information, which parents agree to before their child starts. Our Designated Safeguarding Lead also shares any safeguarding concern with the school’s Designated Safeguarding Lead.

• Police, Children’s Social Care or other safeguarding bodies – where there is a safeguarding concern or a “vital interest”, in line with data protection law.

• Service providers – the companies whose software we use to run Joco (see below).

Once these organisations hold the information, it is also protected by their own data protection policies.

Software and service providers

We use a small number of trusted providers to run Joco. They act as our “processors”: they may only use personal data on our instructions, under a written contract, and must keep it secure. They include our website host (34SP.com), Google Analytics for our website, Microsoft (including Microsoft Forms), and our email and secure storage providers.

Enrolment forms. Families enrol through a Microsoft Form linked from our website. This collects student and parent details, emergency contacts, and any medical, allergy and SEN information you choose to give. Responses are sent directly to Joco’s Microsoft 365 business account, where Microsoft acts as our processor. They are encrypted in transit and when stored, and can only be seen by the partners. The partners share the relevant medical needs and emergency contact details, marked restricted, with the staff working with each student, so that they are available in class in case of an emergency.

Google Analytics data may be processed in the United States under the UK’s data bridge with the US, which the UK government recognises as giving adequate protection. Microsoft may also process data outside the UK, including in the United States; these transfers are protected by the UK–US data bridge or by contract terms approved by the ICO.

Storage, security and retention

Paper records are kept in a locked place and digital records on password-protected devices and accounts, accessed only by people who need them and understand their duty to keep them secure. Information is shared only with those who need to know.

We keep personal data only as long as we need it:

• Student and parent records – while the student attends Joco, then for 1 year after they leave, so we can deal with any fees or queries.

• Medical and SEN information – checked and updated each year, and deleted when the student leaves.

• Accident and injury records for students – until the student turns 21, as claims can be made up to 3 years after turning 18.

• Safeguarding records – for as long as safeguarding guidance requires; kept securely and reviewed regularly.

• Staff records – 6 years after the person leaves. We keep a note of each DBS check’s number and date, but not a copy of the certificate. Records of any allegation about a member of staff are kept until the person reaches normal pension age or for 10 years, whichever is longer.

• Financial records – 6 years, as HMRC requires.

• Photos and video – until consent is withdrawn or they are no longer needed.

• Claude conversations – deleted once the task is finished (see above).

• Records in our management app – kept for the same time as the matching records above (for example, a student’s details and date of birth for 1 year after they leave, and fee records for 6 years), then deleted.

Photos, video and social media

Shows. Taking part in a Joco show includes being filmed and photographed for the official show recording and photos, which are for the families of students taking part. We do this on the basis of our legitimate interests, as families expect a show to be recorded, and we never attach students’ names. If you have concerns, please talk to us: you have the right to object, and we will try to accommodate you, for example through positioning or editing, although we cannot always remove a child from a group recording. Where a producer films or photographs a production, such as the panto, the producer is responsible for those images.

Licences and teaching. Photos needed for child performance licences are sent to Surrey County Council as the law requires. Footage taken in class to help with teaching is stored securely and used only for teaching.

Website and social media. Images are shared on our website or social media only if you have opted in, and we never attach students’ names. We cannot stop others from identifying a child, for example by naming them in a comment congratulating them on a trophy, so please only opt in if you accept this risk. We monitor our social media pages and remove inappropriate comments, but we are not responsible for third-party posts.

You can withdraw your consent at any time by contacting us.

Your rights

Under UK GDPR you have eight rights over your personal data and your child’s. We will respond to any request without undue delay and within one month. For complex or numerous requests we may extend this by up to two further months, and we will tell you if we need to.

Students who are old enough to understand their rights can also make requests about their own data.

1. To be informed – this notice explains how we use your data.

2. Of access – to ask for a copy of the data we hold about you or your child.

3. To rectification – to have inaccurate or incomplete data corrected.

4. To erasure – to ask us to delete data where there is no compelling reason to keep it. Some records, such as injury or safeguarding records, may need to be kept.

5. To restrict processing – to ask us to store your data but not use it.

6. To data portability – to receive your data in a format that can easily be passed to someone else.

7. To object – to object to us using your data, including for marketing. Our marketing is only ever about Joco’s own classes and opportunities.

8. Relating to automated decision-making and profiling – we do not make decisions about anyone by automated means, including through Claude.

Where we rely on your consent, you can withdraw it at any time. If we refuse a request, we will explain why.

If you are unhappy with how we have handled your data, please contact us first at team@jocodance.com or on 07425 162277. We will acknowledge your complaint within 30 days and respond without undue delay. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

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