Trauma-Informed Practice Policy

Operated by: Nudge Education Ltd · Version: Dec 2025 · Owner: Director of Operations

TRAUMA-INFORMED PRACTICE POLICY DEC 2025

Review date: DEC 2026

NUDGE EDUCATION 2025 1 CONTENTS

1. Introduction

2. Purpose and Aims

3. Principles of Trauma-Informed Practice

4. Understanding Behaviour

5. Creating Safe and Supportive Interventions

6. Personalised Planning

7. De-Escalation and Crisis Response

8. Physical Intervention (Only as Last Resort)

9. Roles and Responsibilities

10.Training and Professional Development

11. Safeguarding and Information-Sharing

12.Equality, Diversity and Inclusion

13. Monitoring, Evaluation and Improvement

14.Staff Wellbeing and Trauma-Informed Leadership 15.Policy Review

The responsible people for the implementation of this policy are the Chief Executive Officer (CEO), Director of Operations, Director of Partnerships and the Service Manager.

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1. Introduction

Most guidance and regulations written for maintained, independent schools and academies state that it is a legal requirement to have a written policy to promote positive behaviour within an educational setting.

Although Nudge Education is an interim provider of bespoke academic and therapeutic interventions (which makes a ‘whole school’ policy unsuitable), we believe that trauma-informed practice should also be applied to our interventions. We aim to ensure that regulated behaviours are recognised and any periods of dysregulation are addressed with understanding, consistency, and care.

This policy draws on inclusive and evidence-informed practice from settings that specialise in supporting young people with SEND, SEMH, and unmet needs. We recognise that many of the young people we support experience a range of barriers beyond academic learning. Our approach therefore, prioritises equity, ensuring that every young person, regardless of background, identity, or need, is met with understanding, fairness, and opportunities that enable them to thrive.

2. Purpose and Aims

The purpose of a trauma-informed policy is to create safe, consistent, and emotionally supportive environments where young people feel valued, understood, and able to thrive. It ensures that staff interpret all behaviour as communication, respond with compassion and curiosity, and tailor support to each young person’s individual history, needs, and strengths. Through predictable routines, restorative approaches, emotional-regulation support, and collaborative work with families and professionals, the policy promotes belonging, builds trust, and develops the skills young people need to confidently navigate social situations, improve wellbeing, and progress towards independence.

This policy aims to:

• Promote holistic development: spiritual, moral, cultural, social, mental, and physical, and prepare young people for their next setting or destination (school, college, apprenticeship, employment, or wider community integration).

• Embed a trauma-informed approach that is adaptive to individual needs and grounded in safety, dignity, and emotional regulation.

• Ensure physical intervention is an absolute last resort; used only when all de-escalation strategies have been exhausted, and only to maintain the safety

NUDGE EDUCATION 2025 3 of the young person, practitioner and others. Any physical intervention must be reasonable, proportionate, time-limited, and carried out with care and respect. Further guidance can be found in the Physical Intervention Policy.

• Train practitioners in effective de-escalation strategies and safe physical intervention practices, equipping them with the skills required to keep young people, staff, and others safe.

• Create positive, consistent environments where challenges are met with calm, clear communication and opportunities for young people to learn constructive responses.

• Support young people to improve mental health and wellbeing, develop personal regulation strategies, build resilience, and move towards greater independence.

• Interpret behaviour as communication, approaching each young person with curiosity, empathy, and without judgment.

• Respond compassionately to distress rather than labelling behaviour, recognising vulnerability, avoiding blame, and understanding that many responses are driven by underlying emotions and experiences.

• Develop personalised support strategies that meet individual needs, promoting safety, and strengthening emotional security.

• Maintain clear, consistent boundaries and predictable routines to build trust, provide stability, and support co-regulation and self-regulation.

3. Principles of Trauma-Informed Practice

At Nudge Education, we recognise that every young person’s behaviour is a form of communication and often a reflection of their lived experiences. Trauma-informed practice is not a set of strategies, but a way of being, one that places empathy, curiosity, and safety at the heart of every interaction.

Some young people experience challenges with emotional regulation, relationships, or mental wellbeing. These difficulties often relate to trauma, loss, chronic stress, or unmet needs and may present through behaviours that can be misunderstood without a trauma-informed lens.

Many of the young people we support have overlapping or complex needs, including mental health difficulties, neurodivergence, past or current social care involvement, or disrupted attachment. Emotional dysregulation is therefore understood not as defiance, but as a sign of distress. Our interventions are tailored to each young person’s strengths, story, and circumstances, ensuring support that is relational, predictable, and responsive.

NUDGE EDUCATION 2025 4 Our approach promotes emotional literacy, resilience, and the development of positive coping strategies. It helps young people to understand their emotions, recognise triggers, and express themselves safely and constructively, supported by a trusted practitioner.

4. Understanding Behaviour

At Nudge Education, we understand that all behaviour is communication. Our practitioners respond with empathy, curiosity, and patience, seeking to understand what a young person is expressing through their actions. Safety, trust, and a sense of belonging are the foundations upon which learning, engagement, and emotional growth are built.

Many of the young people we support experience trauma, anxiety, disrupted attachment, neurodivergence, or social care involvement. Emotional dysregulation is therefore understood as distress, not defiance. We ask, “What is this behaviour telling us?” rather than “What is wrong with this young person?”

A young person’s behaviour may be shaped by:

• past or ongoing trauma
• mental health needs
• communication or sensory differences
• neurodivergence
• instability or change in their environment

5. Creating Safe and Supportive Interventions

Safe, supportive interventions are central to Nudge Education’s trauma-informed ethos. We recognise that young people feel most able to learn, regulate, and take positive risks when they experience safety, predictability, and trusted relationships. Our approach ensures that every interaction is grounded in care, curiosity, and professionalism.

Understanding the factors that can influence behaviour, such as trauma, anxiety, neurodivergence, sensory needs, and past experiences, enables practitioners to respond safely and compassionately. Interventions are designed to reduce stress, avoid triggers, and create spaces where young people feel respected and in control.

5.1 Our Approach in Practice

Practitioners use consistent relational and de-escalation approaches to create emotional and physical safety:

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• Remaining calm, curious, and non-judgemental. Practitioners model regulation and respond to distress with empathy rather than escalation.

• Using de-escalation strategies aligned with CPI Safety Intervention™(CPI Safety Intervention. These techniques prioritise safety, reduce risk, and prevent the need for physical intervention.

• Offering predictability, clear boundaries, and supportive choices. Structure and gentle guidance help young people feel safe, informed, and empowered.

• Focusing on connection before correction; building trust and rapport forms the foundation for positive behaviour and engagement.

We aim to support behaviour rather than manage it, ensuring young people feel understood, valued, and safe during every session. Interventions are paced sensitively, adapted to individual needs, and delivered with warmth and professionalism.

Practitioner-to-Young Person ratios are determined through referral information, initial assessments, and risk considerations. These ratios are reviewed regularly and adjusted if circumstances change.

6. Personalised Planning

Every Nudge intervention is individually designed to meet the unique needs, strengths, and circumstances of each young person. Personalised planning ensures their experiences are safe, predictable, and attuned to what supports their wellbeing, engagement, and emotional regulation.

Risk assessments are completed at the Initial Assessment phase, and are revisited throughout the course of the intervention. They consider:

• precipitating factors

• known stressors or fears

• communication needs

• sensory sensitivities

• medical or physical considerations

• social care involvement or contextual risks

NUDGE EDUCATION 2025 6 Risk assessments guide practitioners in preventing avoidable distress and in maintaining safe, responsive practice. Where possible, interventions are planned to minimise exposure to known precipitating factors. This may include:

• choosing low-stimulation environments

• adjusting pace, location, or activity

• preparing young people in advance for transitions or changes

• avoiding language, topics, or expectations identified as distressing

• building in breaks, movement, or sensory regulation strategies

• offering choices to increase predictability and autonomy

Planning ahead reduces anxiety and supports the young person to remain regulated and engaged. Personalised plans are dynamic. Practitioners adapt their approach based on:

• daily presentation

• feedback from parents/carers and professionals

• reflective practice

• observations of what supports or unsettles the young person

This ensures interventions remain safe, flexible, and aligned with the young person’s evolving needs.

7. De-Escalation and Crisis Response

Nudge Education uses early, relational and trauma-informed approaches to reduce distress and prevent crises. De-escalation is always our primary response in line with CPI Safety Intervention™ guidance.

Practitioners focus on supportive, low-arousal responses that help young people remain regulated. This includes:

• staying calm, curious, and non-judgemental

• using quiet, simple communication

• reducing demands and sensory load

• offering choices and space

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• prioritising connection before correction

These approaches reduce stress and help young people return to emotional safety. When signs of increasing distress appear, practitioners:

• lower stimulation and environmental pressure

• use clear, achievable instructions

• avoid confrontation and power struggles

• work together to maintain safety

The emphasis is always on preventing further escalation.

7.1 Crisis Response (Non-Physical)

If a young person becomes highly dysregulated, practitioners first use non-physical strategies to maintain safety, such as creating space, removing potential hazards, and offering a calm, reassuring presence.

Once calm is restored, practitioners:

• provide space and time to recover

• offer supportive reflection when the young person is ready

• update plans or risk assessments if needed

• take part in staff debrief as appropriate

For all incidents requiring physical intervention, practitioners must follow the recording, reporting, and review processes outlined in the Nudge Physical Intervention Policy.

8. Physical Intervention (Only as Last Resort)

Nudge Education is committed to maintaining the safety, dignity, and wellbeing of every young person. Physical intervention is never a behaviour-management tool and is used only as a last resort, in line with CPI Safety Intervention™ guidance and the Nudge Physical Intervention Policy.

Physical intervention may be used only when a young person is at immediate risk of:

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• harming themselves,

• harming others, or

• causing serious damage that places someone in danger.

Any physical intervention must be:

• the least restrictive option available,

• used for the shortest possible time,

• reasonable, proportionate, and necessary in the circumstances, and

• carried out by practitioners trained in CPI Safety Intervention™ where possible.

This policy section provides a brief overview. Practitioners must follow the detailed procedures set out in the Nudge Physical Intervention Policy, including specific holds, reporting requirements, and CPI Safety Intervention™ protocols.

9. Roles and Responsibilities

Clear responsibilities ensure safe, consistent, trauma-informed practice across all Nudge interventions.

9.1 Senior Leadership Team

• Ensures this policy and the Nudge Physical Intervention Policy are implemented.

• Oversees training, quality assurance, and incident monitoring.

• Promotes a trauma-informed culture and provides organisational oversight.

9.2 Safety Intervention Team

• Provides advice and monitoring of all safeguarding aspects.

• Creates and sources training for practitioners.

• Deliver training.

• Monitors reports to work proactively with practitioners and the core team to promote and ensure a trauma informed approach is embedded in everything

NUDGE EDUCATION 2025 9 we do.

9.3 Regional Leads & Assistant Regional Leads

• Support practitioners to follow this policy in daily practice.

• Quality Assure risk assessments, intervention planning, and staffing ratios.

• Review incidents and provide supervision and wellbeing support.

9.4 Education Intervention Coordinators

• Maintain accurate risk information and ensure personalised plans are in place.

• Communicate with commissioners, families, and multi-agency partners.

• Update practitioners on any changes in need or risk.

9.5 Practitioners

• Deliver safe, trauma-informed interventions.

• Use de-escalation as the primary response and follow CPI Safety Intervention™ if required.

• Record, report, and reflect on incidents as required by policy.

• Seek supervision and ongoing training.

9.6 Parents, Carers and Partners

• Share relevant information to support planning and safety.

• Work collaboratively to ensure consistent support for the young person.

10. Training and Professional Development

Nudge Education is committed to ensuring all practitioners have the knowledge, skills, and confidence to deliver safe, trauma-informed interventions. Prior to starting any intervention, all practitioners must complete:

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• Safeguarding & Child Protection training, First Aid Training and Prevent Training

Where the intervention deems necessary, then practitioners complete:

• Trauma-informed practice training

• CPI Safety Intervention™ training

• Complex needs training specific to the needs of the young person

Practitioners are supported through ongoing professional development through refreshers and updates, and access to the Nudge CPD Calendar.

11. Safeguarding and Information-Sharing

Safeguarding is central to all Nudge Education interventions. Every practitioner has a responsibility to promote the safety, rights, and wellbeing of young people and to act immediately when concerns arise.

All practitioners must follow the Nudge Safeguarding and Child Protection Policy, including reporting concerns without delay to the Education Intervention Coordinator (EIC), and the Regional Designated Safeguarding Lead (RDSL).

Safeguarding concerns take priority over all other aspects of intervention.

To keep young people safe, practitioners must share relevant information with authorised professionals when it:

• protects a young person from harm,

• supports an appropriate safeguarding response, or

• is required by law

Information is shared on a need-to-know basis only, using secure systems and in line with Data Protection and GDPR requirements.

Information is handled with sensitivity, accuracy, and respect. Practitioners consider how information is communicated to avoid causing additional distress and ensure young people feel safe and understood.

This section provides a summary. Full processes, definitions, and escalation routes are outlined in the Nudge Safeguarding and Child Protection Policy.

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12. Equality, Diversity and Inclusion

Nudge Education is committed to providing safe, inclusive and equitable interventions for every young person. We recognise that identity, background, and lived experience shape how young people understand the world and how they respond to stress, relationships, and learning. Our practice reflects national expectations, including Keeping Children Safe in Education (2025) and the SEND Code of Practice (Updated 2024), which require education providers to offer individualised support that enables all young people, especially those with additional needs, to thrive.

Interventions are planned with a clear understanding of each young person’s needs, preferences and circumstances. Practitioners consider:

• Information from EHCPs, Pen Portraits and assessments including medical, sensory, communication, cultural or trauma-related factors that may influence how a young person engages or feels safe.

• Adjustments that promote equity and accessibility such as adapting environments, communication methods, pace, sensory input or expectations to ensure the young person is able to participate fully.

• The influence of identity and lived experience acknowledging how racism, discrimination, cultural background, disability, neurodiversity, gender identity or past marginalisation may shape responses, trust and emotional safety.

Practitioners ensure that every young person is treated with dignity, compassion and respect. This includes:

• using strengths-based language

• avoiding assumptions about identity or ability

• promoting autonomy and choice wherever possible

• protecting privacy and emotional wellbeing

• honouring each young person’s voice and preferences

We actively challenge bias, discrimination and stigma, and seek to create environments where every young person feels they belong.

13. Monitoring, Evaluation and Improvement

NUDGE EDUCATION 2025 12 Nudge Education is committed to continually improving practice to ensure interventions remain safe, trauma-informed and responsive to the needs of young people.

• Incident reports, risk assessments, and intervention data are reviewed regularly by Regional Leads, the Service Manager and Senior Leaders to identify patterns, emerging needs, or areas for improvement.

• Feedback from practitioners, young people, parents/carers, and multi-agency partners informs adjustments to practice and planning.

• Themes arising from debriefs, practitioner 1:1s , reflective practice, and quality assurance processes help evaluate the consistency and effectiveness of trauma-informed approaches across interventions.

• Data relating to de-escalation, physical intervention, attendance, and engagement is analysed to support continual learning.

14. Staff Wellbeing and Trauma-Informed Leadership

Nudge Education recognises that the wellbeing of our practitioners is essential to delivering safe, compassionate and effective interventions. Trauma-informed practice applies not only to young people, but also to the adults supporting them.

• Practitioners have access to regular support from leaders, reflective spaces and wellbeing support to help them process experiences and maintain emotional regulation.

• Leaders encourage open communication, recognise the emotional impact of the work and ensure staff feel heard, valued and supported.

• Workload, safety and support needs are monitored to prevent burnout and promote sustained, high-quality practice.

• Leaders model calmness, empathy and curiosity, the same qualities expected in practice with young people.

• Decision-making considers the emotional impact on staff as well as on young people.

• Leaders promote a culture of psychological safety where staff can seek help, discuss challenges and reflect without fear of blame.

• Professional development, recognition and supportive feedback are used to build confidence, skill and resilience among practitioners.

NUDGE EDUCATION 2025 13 By supporting the wellbeing of our workforce, Nudge ensures practitioners are equipped to provide consistent, trauma-informed interventions that uphold the dignity and safety of every young person.

15. Policy Review

Nudge Education remains committed to an evolving, evidence-informed approach that prioritises emotional safety, relational practice, and positive outcomes for every young person.

This policy is reviewed annually, or sooner if legislation or statutory guidance changes, stakeholder feedback indicates a need for revision, or learning from incidents or audits identifies areas for improvement.

This policy has been written with understanding and reference to:

• Behaviour in Schools - DfE February 2024

• Special Educational Needs and Disabilities Code of Practice (Updated 2024)

• Keeping Children Safe in Education (2025)

This policy should be read in conjunction with the following policies:

• Nudge Education Child Protection and Safeguarding Policy

• Equality, Diversity, and Inclusion Policy

• Information Security & Data Protection Policy

• Nudge Education Physical Intervention Policy

• Nudge Education Practitioner Code of Conduct

• Special Educational Needs and Disabilities Policy

All Policies can be found here.

Review

This policy has been signed off by the Nudge Education Directorate. Charlotte Noutch Director of Partnerships & Services 5 Dec 2025

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NEO Online Addendum — DRAFT

Status: This NEO online addendum is newly drafted and pending review by the Designated Safeguarding Lead before it goes live. The canonical Nudge Education Trauma-Informed Practice Policy above continues to apply.

Scope of this addendum

This addendum applies the canonical Nudge Education trauma-informed practice approach to the online provision context of Nudge Education Online (NEO). The same six Cornerstones (Connection, Movement, Creativity, Reflection, Rest, Nutrition) underpin practice; the operational application differs because the relationship is mediated through screens.

Pacing and session design

• Session length — NEO sessions are designed with shorter active blocks and more frequent micro-breaks than equivalent face-to-face sessions, recognising that screen-based interaction is more cognitively demanding and harder to regulate within.
• Predictable structure — every session follows a consistent, predictable shape (welcome, learning, break, learning, close) so learners do not have to expend regulation capacity on figuring out what comes next.
• Visible time cues — qualified teachers and practitioners signal session structure visually (timers, agenda on screen, break countdowns) to support learners who struggle with implicit time management.

Camera-off as a regulation tool

Cameras-off is recognised as a legitimate regulation strategy. A learner who turns their camera off during a session is not assumed to be disengaged or absent. Practitioners and qualified teachers respond to camera-off by:

• Continuing the lesson without comment if the learner is still participating in chat, audio, or task work.
• Offering a quiet check-in via private chat or audio if a sudden camera-off pattern suggests overwhelm.
• Recording in the session log: “camera off, [evidence of engagement / regulation strategy / agreed adjustment]” — never simply “camera off, disengaged”.

Screen fatigue, regulation, and breaks

NEO recognises that sustained screen exposure can compound dysregulation, particularly for learners with sensory processing differences, anxiety, or trauma histories. Sessions therefore build in:

• Mandatory off-screen movement breaks after each active block.
• Permission to step away mid-session when the learner needs to, communicated through any agreed channel (a hand signal, a chat note, or simply leaving and returning).
• Reduced bright-content/high-contrast visuals in materials where possible.
• Audio-only options for pastoral conversations where camera-on increases distress.

Trauma-aware safeguarding in online contexts

• Online disclosures, where they happen, are responded to in real time using the same safeguarding thresholds as face-to-face — the practitioner or qualified teacher notes, ends the session if appropriate, contacts the DSL, and follows the canonical Child Protection and Safeguarding Policy.
• Practitioners are alert to digital signals of dysregulation: prolonged silence, sudden disconnection, repeated brief reconnections, change in chat tone, change in posture or background. These are noted as potential indicators, not diagnoses.
• Recording of sessions is disabled by default for pastoral and 1:1 sessions, in recognition that recording can itself be retraumatising. Recording requires explicit, informed consent recorded in the learner’s support plan.

Practitioner self-regulation and supervision

The practitioner role is the relational anchor for the learner. NEO supports practitioner regulation through:

• Reflective supervision arrangements that recognise vicarious trauma in remote relational work.
• Caseload caps that protect quality of relationship.
• Peer support networks among practitioners for processing difficult sessions.

Related NEO policies and resources

• Child Protection and Safeguarding Policy
• NEO Behaviour and Regulation Policy
• SEND Policy
• Online Safety and Acceptable Use Policy

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Document control

Field	Value
Version	Dec 2025
Owner	Director of Operations
Status	live
Source file	3. Service Delivery/Trauma-Informed Practice Policy - Dec 2025.pdf