| Date | 14 October 2026 |
|---|---|
| Review Date | December 2026, then annually, or sooner if practice or legislation changes |
| Owner | Designated Safeguarding Lead (NEO), with the Director, NEO & Head of School; oversight by the Nudge Education National Designated Safeguarding Lead |
| Approved by | Approved by the Director, NEO & Head of School on 14 October 2026 under authority delegated by the Proprietor (CEO of Nudge Education Ltd) on 13 October 2026; for noting at the NEO board on 3 December 2026 |
| Version | v10.26 |
A fully online alternative provision for learners aged 11–18
1. Basis
The Prevent duty (Counter-Terrorism and Security Act 2015, section 26) and the Prevent duty guidance: England and Wales (2023, in force 31 December 2023) require specified authorities, including schools and registered childcare providers, to have due regard to the need to prevent people from being drawn into terrorism, and to assess the risk of that happening in their setting. NEO is not a registered school and is not a specified authority in its own right. NEO adopts the duty in full because Keeping Children Safe in Education 2026 makes Prevent part of safeguarding, because the online education standards (4.1) expect it, and because an online provision serving young people who have been out of school is exactly the setting in which online radicalisation can go unseen. The Prevent provisions are set out in the Child Protection and Safeguarding Policy; this document is the risk assessment and action plan that policy requires.
2. Risk assessment
Scores are likelihood × impact on the 1–5 scale used in the Nudge Education Board Risk Register.
| Risk | Why it is relevant to NEO | L | I | Score | Controls in place | Action and owner |
|---|---|---|---|---|---|---|
| A learner is drawn towards extremist content online outside NEO sessions | Learners spend most of the day online; many have reduced adult oversight and limited peer contact; isolation and grievance are known susceptibility factors | 3 | 5 | 15 | Smoothwall Cloud Filter (with the Prevent / IWF categories enabled) and Monitor on every NEO-managed device; Practitioner-Mentor daily contact; WHO-5 and Cornerstones check-ins; online safety and RSHE curriculum | Confirm Prevent categories are enabled in the filter policy table before learner-device rollout — CTO, October 2026. State the own-device gap in the Remote Learning policy — Head of School |
| Extremist material or contact enters a live session (screen share, chat, link, intrusion) | Live sessions use Google Meet with learner accounts | 2 | 4 | 8 | Meet settings checklist (manual admission, host controls, no private messaging); co-host in every classroom; learner accounts cannot receive external email | Termly test of Meet settings — CTO; incident drill at INSET — DSL |
| Staff do not recognise signs of radicalisation or do not know how to refer | Small, distributed, part-time team; pool educators join through the year | 3 | 4 | 12 | Prevent awareness training on the mandatory list (one module a week to Christmas); DSL has completed Prevent referral training; Channel route known | Completion table to the 3 December board — Head of School; Prevent in every educator induction — DSL |
| NEO’s own content, speakers or AI tools expose learners to extremist views | Enrichment speakers; AI tools under the Diamond Standard | 1 | 4 | 4 | Speaker vetting under the NEO — Safer Recruitment and Use of Volunteers Policy; no learner-facing AI without review under the NEO — Artificial Intelligence Policy | Add a Prevent line to the speaker checklist — Head of School |
| A concern is raised and the response is slow or unrecorded | Online disclosures can arrive by chat or in a transcript | 2 | 5 | 10 | Transcripts reviewed for safeguarding; concern form; DSL contactable in all session hours; local authority Prevent lead and Channel contacts held by the DSL | Confirm the local Prevent lead contact for the learner’s own local authority at admission — DSL |
3. Action plan
| Action | Owner | By |
|---|---|---|
| Enable and test Prevent and extremism categories in Smoothwall Cloud Filter before any learner device is deployed | CTO | Before learner-device rollout, October 2026 |
| Prevent awareness training recorded for every member of staff and every pool educator; completion table to the board | Head of School | 3 December 2026 |
| Local authority Prevent lead and Channel contact recorded for every local authority NEO serves | DSL | 3 December 2026 |
| Prevent and online radicalisation covered in the RSHE and Cornerstones Day curriculum (Relational Intelligence, Digital Skills) | Head of English (RSHE lead) | Spring term 2027 |
| Review this risk assessment after any incident, after each KCSIE revision, and annually at the NEO board | DSL | Ongoing; October 2027 |
4. Referral route
A concern that a learner may be susceptible to radicalisation is a safeguarding concern. Staff report it to the DSL the same day using the concern form. The DSL decides, with the Head of School where appropriate, whether to refer to the local authority’s Prevent lead or make a Channel referral, and whether a referral to children’s social care or the police is also required. The learner’s commissioner is informed where the placement is commissioned. The DSL records the concern, the decision and the reasons.
5. Related documents
- Prevent duty guidance: England and Wales (Home Office, 2023); Channel duty guidance (2023)
- Keeping Children Safe in Education 2026, Part one and Annex B
- Child Protection and Safeguarding Policy with NEO Online Addendum
- NEO — Online Safety and Acceptable Use Policy
- NEO — Remote Learning Policy
- Risk Assessment Policy with NEO Online Addendum