Safeguarding Policy

Our approach to safeguarding is guided by the following core principles:

• Best interests of the child: The welfare of the child is paramount. All decisions and actions will prioritise the safety and wellbeing of the young person above all other considerations.
• Proportionate responses: We will respond to safeguarding concerns proportionately, taking into account the nature and severity of the concern, the age and vulnerability of the child, and relevant context.
• Working with parents and guardians: We will work in partnership with parents, guardians, and carers to support the safety and wellbeing of young people, unless doing so would place the child at further risk of harm.
• Listening to children and young people: We will take the views, wishes, and feelings of young people seriously, and ensure they are listened to and involved in decisions that affect them.
• Zero tolerance of abuse: We operate a zero-tolerance approach to any form of abuse, exploitation, or harmful behaviour directed at children and young people.
• Transparency and accountability: We are open about our safeguarding practices and will hold ourselves accountable for maintaining the highest standards of child protection.

As a digital education platform serving young people, we implement robust online safety measures across every layer of the product:

5.1 AI Content Filtering

All AI-generated content on the platform is subject to automated filtering designed to detect and prevent the presentation of harmful, inappropriate, or age-inappropriate material. Our filtering systems are regularly reviewed and updated to address emerging risks.

5.2 No Direct Messaging

The English Hub does not provide any direct messaging, chat, or private communication features between users. This design decision eliminates the risk of grooming, bullying, or other harmful interactions between users on the platform.

5.3 No Sharing of Personal Information

The platform does not permit users to share personal information (such as full names, addresses, phone numbers, photographs, or social media handles) with other users. User profiles are not publicly visible.

5.4 Parental Consent for Under-16s

In compliance with the UK General Data Protection Regulation (UK GDPR) and the Age Appropriate Design Code, we require verifiable parental or guardian consent before processing the personal data of any user under the age of 16. Consent mechanisms are built into our registration process.

5.5 Age-Appropriate Design (ICO Code Compliance)

The English Hub is designed in accordance with the ICO's Age Appropriate Design Code (Children's Code). This includes:

• Privacy settings configured to the highest level by default
• Data collection minimised to only what is necessary for the educational service
• No profiling of children for marketing or commercial purposes
• No nudge techniques or design patterns that encourage users to weaken their privacy protections
• Clear, age-appropriate privacy information provided to young users
• Data Protection Impact Assessments (DPIAs) conducted for all features and services likely to be accessed by children

If you have a safeguarding concern about a child or young person using The English Hub, you should report it immediately using one of the following methods:

• Online reporting form: Submit a report - available 24/7, anonymous reporting accepted
• Email the DSL: [email protected]

When reporting a concern, please provide:

• A description of the concern, including what you have seen, heard, or been told
• The date and time of the incident (if applicable)
• Any relevant usernames or identifying information (if known)
• Your contact details (optional but helpful for follow-up)

If a child is in immediate danger, call 999 without delay. Do not wait to submit a report through the platform.

If a child discloses something to you

Act immediately. Record exactly what you saw or heard, when, and any actions you have already taken. Refer to the user by their account ID, not by name, in any email subject line.

• Do not investigate or interview the child yourself.
• Do not promise confidentiality you cannot keep.
• Do not delete any evidence — preserve the record.
• Do not discuss the concern with anyone who does not need to know.

Severity classification and response times

On receiving a concern the DSL classifies severity and acts within the following timeframes:

• Immediate risk: act now; call 999 if life is threatened.

Safeguarding data is handled with the highest level of care and in compliance with the UK GDPR and Data Protection Act 2018:

• Lawful basis: Safeguarding data is processed under Article 6(1)(d) (vital interests) and Article 6(1)(e) (public task) of the UK GDPR, and Article 9(2)(c) (vital interests) for special category data.
• Access controls: Only the DSL and authorised personnel with a legitimate need have access to safeguarding records. Access is strictly limited on a need-to-know basis.
• Secure storage: Safeguarding records are stored securely with encryption at rest and in transit. Records are kept separately from general user data.
• Retention: Safeguarding records are retained in accordance with statutory guidance and relevant retention schedules. Records relating to child protection concerns are retained until the individual's 25th birthday, or for 6 years from the date of the last entry (whichever is longer).
• Information sharing: Safeguarding information will be shared with external agencies (such as local authority children's services, the police, or the NSPCC) where necessary to protect a child. Data protection legislation is not a barrier to sharing information where failure to do so would place a child at risk.

Safeguarding records and retention

Every safeguarding concern is recorded in a secure log that captures a unique incident ID, the date and time of the report, who reported it, the nature of the concern, the user(s) involved (by account ID), the actions taken by the DSL, any external contacts made, the outcome, and review dates. In line with Keeping Children Safe in Education guidance, safeguarding records relating to a child are retained until that child reaches the age of 25. Access to the safeguarding log is restricted to the DSL; broader access requires a documented need.

All individuals working on behalf of Upskill Energy Limited who may come into contact with safeguarding matters are required to:

• Complete safeguarding awareness training upon commencement of their role
• Undertake refresher training at least annually, or more frequently where required
• Read and confirm understanding of this safeguarding policy
• Understand how to recognise signs of abuse, neglect, and exploitation
• Know how to report safeguarding concerns through the correct channels

The DSL receives enhanced safeguarding training, including inter-agency working, in line with Working Together to Safeguard Children and Keeping Children Safe in Education requirements.

Records of all safeguarding training are maintained centrally and reviewed regularly to ensure compliance.

Safer recruitment and background checks

All staff and contractors who have access to children’s data or to child-facing systems undergo:

• Identity verification and right-to-work checks
• Reference checks
• Enhanced DBS checks where required by role
• Signed confidentiality and acceptable-use agreements
• Mandatory safeguarding training before access is granted

This safeguarding policy is reviewed and updated at least annually by the Designated Safeguarding Lead, or sooner if:

• There are changes to relevant legislation or statutory guidance
• A safeguarding incident identifies areas for improvement
• New features or services are introduced that affect the safety of young users
• Feedback from users, parents, or external agencies indicates a need for change

Each review is documented, and the updated policy is published on the platform and communicated to all staff and contractors.

Any staff member, contractor, or volunteer who believes that a safeguarding concern is not being handled properly — or who is concerned that the safeguarding policy itself is being ignored or undermined — can raise the issue with any of the following, in any order:

• The DSL’s line manager (the CEO)
• The board, or the nominated board-level safeguarding governor
• The NSPCC whistleblowing helpline on 0800 028 0285
• The Information Commissioner’s Office, where the concern relates to data handling

No staff member, contractor or volunteer will suffer retaliation for raising a safeguarding concern in good faith.

This policy is written to be consistent with the following statutory guidance and legislation, to the extent that each applies to a digital publisher serving children:

• Keeping Children Safe in Education (KCSIE) — statutory guidance for organisations working with children in the English education system.
• Working Together to Safeguard Children — the inter-agency framework for safeguarding and promoting the welfare of children.
• Children Act 2004 — the underlying statutory framework for safeguarding in England and Wales.
• Online Safety Act 2023 — applied to the extent our service is in scope, with particular attention to age-appropriate design and harms to children.
• UK GDPR and the Data Protection Act 2018, alongside the ICO Age Appropriate Design Code — governing how we handle children’s personal data.

The Designated Safeguarding Lead is responsible for keeping this policy aligned with updates to any of the above, and for triggering a policy review when those updates materially affect our obligations.

If you need immediate help or wish to report a concern to an external organisation, the following services are available: