Statement of intent

As a provider of online services directly involving young people, The Access Platform (TAP) acknowledges the special duty of care this places upon us to both safeguard young people themselves and to promote their welfare. In particular, The Access Platform recognises the evolving complexities of safeguarding in a digital age and the unique risks raised via interaction using online platforms. As an organisation we are committed to maintaining rigorous standards informed by the latest guidance. The safety and wellbeing of young people using our service is our number one priority and the purpose of this policy is to outline the practical steps The Access Platform takes to ensure this approach is embedded through all aspects of the organisation.

We are committed to ensuring that regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation, socioeconomic background, or any other factor, each young person accessing our services will be:

  1. protected from abuse or harm whilst using the TAP platform
  2. accessing a platform where all possible steps are taken to restrict access to age inappropriate conversations or the sharing of personal contact information
  3. have any concerns, difficulties or welfare issues responded to promptly and in a manner conforming to best safeguarding practice

 

Scope of Policy

This policy and accompanying procedures is required reading for all staff, contractors, volunteers or other adults working or acting on behalf of TAP. The contents are binding upon all employees or other representatives of the organisation and apply to any child, young person or vulnerable adult the organisation, or those working on its behalf, comes into contact with. Failure to comply with this policy and procedures will be addressed robustly and may result in disciplinary action, including in dismissal.

Review process

This policy will be reviewed every 6 months. Responsibility for review and amendment of the policy falls to the Designated Safeguarding Person (DSP). Changes to the policy will be made in consultation with senior members of TAP staff and external Safeguarding consultants.

Latest review date: April 2019

Next annual review: April 2020

Key safeguarding contacts

Designated Safeguarding Person (DSP)

Name: Nik Higgins

Position: Co-Founder and Chief Commerical Officer

Email: nik@theaccessplatform.co.uk

Tel: 07538909915

Deputy Designated Safeguarding Person (DSP)

Name: George Olesen

Position: Co-Founder and Chief Executive Officer

Email: george@theaccessplatform.co.uk

Tel: 07910255294

All Safeguarding related issues must be referred to the Designated Safeguarding Person without delay. If for any reason a response is not received within an appropriate timeframe (at the most, the same day), the Deputy Designated Safeguarding Person should be contacted. If, at any point, an individual is concerned that a young person or vulnerable adult is at immediate risk of serious harm, the Police should be contacted immediately.

1. Relevant legislation, policy guidance, and clarification of terminology 

1.1 Relevant legislation and policy guidance

The Access Platform’s Safeguarding, Child Protection, and Vulnerable Adults policy draws on a range of existing legislation, statutory guidance and sector best practice, namely:

  • Children Act 1989
  • Children Act 2004
  • Safeguarding and Vulnerable Groups Act 2006
  • Protection of Freedoms Act 2012
  • Education Act 2002
  • Education Act 2011
  • Children and Young People’s Act 2008
  • Children and Families Act 2014
  • Sexual Offences Act 2003
  • Communications Act 2003
  • Serious Crime Act 2015
  • Keeping Children Safe in Education (2016)
  • Working Together to Safeguard Children (2015)
  • The London Child Protection Procedures (2017)
  • Information Sharing (2015)
  • What to do if you’re worried a child is being abused: advice for practitioners (2015)
  • Counter Terrorism and Security Act (2015)

1.2 Clarification of terminology

Child or Young Person

A ‘child’ or ‘young person’ is someone who has not yet reached their 18th birthday (Children Act, 1989).

Vulnerable adult

‘A ‘vulnerable adult’ is any person over the age of 18, “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation because of mental or other disability, age or illness”’.

(Safeguarding adults at risk of harm, 2013)

2. What is Safeguarding and Child Protection? 

Safeguarding and the protection of children and vulnerable adults is an immensely important part of working with young people. It covers young people and vulnerable adults at risk of maltreatment, neglect, physical, emotional or sexual abuse, and radicalisation. This risk could come from parents, carers, teachers, friends, acquaintances, or people they do not know. 

TAP has a safeguarding policy and associated procedures to ensure that it creates a safe online and offline environment for students. It recognises that members of staff have an important role to play in safeguarding the welfare of young people and vulnerable adults and preventing their abuse.

2.1 Safeguarding

The Government has defined the term ‘safeguarding children’ as:

  • Protecting children from maltreatment.
  • Preventing impairment of children’s health.
  • Ensuring that children are growing up in circumstance consistent with the provision of safe and effective care.
  • Undertaking that role so as to enable those children to have optimum life chances and to enter adulthood successfully.

2.2 Child protection

The process of protecting individual children identified as either suffering, or at risk of suffering significant harm as a result of abuse or neglect.

2.3  Wider welfare issues

Students may have other welfare issues that are acting as a barrier to learning, though are not serious enough to fall into the legal categories above.

2.4 Different forms of abuse

These guidelines provide some indicators for identifying and reporting cases or suspected cases of child neglect or abuse. 

PHYSICAL ABUSE

SIGNS/INDICATORS

Physical abuse may involve hitting, shaking, throwing, poisoning, burning and scalding, drowning, suffocating or otherwise causing physical harm to a child.

 

 

 

• Bruising

• Bite Marks

• Burns and Scalds

• Fractures

• Scars

• Self-harm, self-mutilation and

suicide attempts

 

EMOTIONAL ABUSE

SIGNS/INDICATORS

The persistent emotional maltreatment of a child such as to cause severe and persistent effects on the child’s emotional development.

This type of abuse is difficult to recognise as the signs are usually behavioural rather than physical. Indicators are often associated with other forms of abuse.

NEGLECT

SIGNS/INDICATORS

Where a person suffers because their health or psychological, emotional, physical needs are being neglected

  • Young person is unresponsive.
  • Young person thrives away from home.
  • Inadequate or inappropriate clothing.
  • Seem hungry.
  • Have untreated injuries, medical and dental issues.
  • Have skin sores, flea bites, scabies or ringworm.
  • Tiredness.
  • Faltering weight or growth.
  • Smelly and dirty appearance.
  • Young person left unsupervised without adequate provision.
  • Live in an unsuitable home environment.
  • Taking on the role of carer for other family members.

SEXUAL ABUSE

SIGNS/INDICATORS

Forcing someone to have sex, unwanted kissing or touching, being made to watch pornography against will, pressure not to use contraception

  • Bruising to anal or genital areas.
  • Bleeding or discharge of anal genital areas.
  • Sexual transmitted diseases.
  • Pregnancy in a child.
  • Young people who are sexually abused may avoid being alone with people, or seem frightened or unwilling to socialise with someone.
  • Young people may show sexual behaviour that is inappropriate, particularly with regard to their age.

Child sexual exploitation

SIGNS/INDICATORS

Child sexual exploitation (CSE) is a type of sexual abuse. Children in exploitative situations and relationships receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual activities on them. Children or young people may be tricked into believing they're in a loving, consensual relationship. They might be invited to parties and given drugs and alcohol. They may also be groomed and exploited online

  • Changes in behaviour, including use of sexualised terms or language and changes in style of dress. 
  • Sudden possession to unexplained sources of money, new clothes, underwear, or other expensive items. 
  • Secretive use of phone or internet, changes in behaviour in regard to this. 
  • Mentioning of new friends with no obvious connection to young person and resistance to parents discussing/meeting them.

RADICALISATION

SIGNS/INDICATORS

The process by which individuals come to support terrorism or violent extremism.

  • Use of inappropriate language.
  • Possession of violent extremist literature.
  • Behavioural changes.
  • The expression of extremist views.
  • Advocating violent actions and means.
  • Association with known extremists.
  • Seeking to recruit others to an extremist ideology.

 

FORCED MARRIAGE

SIGNS/INDICATORS

A marriage without the consent of one or both parties where duress is a factor

  • Absence and persistent absence.
  • Request for extended leave.
  • Surveillance by siblings or cousins.
  • Poor exam results.
  • Being withdrawn from school.

 

CHILD TRAFFICKING

SIGNS/INDICATORS

A marriage without the consent of one or both parties where duress is a factor

  • Spends a lot of time doing household chores
  • Rarely leaves the house, has no freedom of movement
  • Might not be registered with a GP
  • Has no documents, or falsified documents
  • Has no access to their parents or guardians

 

E-ABUSE

SIGNS/INDICATORS

Mobile phone, e-mail, social networking sites and forums are all used to threaten and intimate people

  • Cyber stalking.
  • Repeated unwanted text & messages.
  • Constantly posting derogatory or defamatory statements or images.
  • Tracking using spyware.
  • Sending viruses.
  • Sexting.
  • Revenge porn.
  • Online grooming (See CSE).

 

3. Safer Recruitment processes

3.1 TAP staff

TAP is only directly responsible for the safer recruitment of its own employees. TAP members of staff (whether full-time or part-time) who may come into contact with children or vulnerable adults as part of their role are required to hold an enhanced Disclosure and Barring Service (DBS) with barred lists check. This will be obtained via TAP prior to the commencement of employment and will be renewed by TAP at least every three years. Details of each disclosure certificate are recorded on a single central register (SCR) in a secure cloud location.

Employees (including senior staff) must also present details of two references and proof of qualifications to the DSP. The DSP will store this information, along with DBS information, in a secure cloud location.

As part of the selection process, all potential staff members are subject to interview by a panel which will include two senior TAP managers, at least one of whom will hold recent training in Safeguarding and Safer Recruitment practices. The interview will explore safeguarding related issues and potential employee’s competence in this area.

3.2 Profile Owners and staff of the end customer

Responsibility for the safer recruitment of Profile Ownerson the TAP Chat platform (usually university student ambassadors holding profiles on the platform) and staff of the end customer (usually university student recruitment, marketing, or widening participation professional) remains with the end customer. This responsibility is explicitly stated in TAP’s customer agreement. TAP strongly advocates safer recruitment practices as best practice to its end customers, but takes no responsibility for their implementation, monitoring, or review.

4. Staff Safeguarding training

All staff working for The Access Platform will undertake mandatory safeguarding and Prevent training annually. All new members of staff will undertake safeguarding training as part of their staff induction. Safeguarding training sessions for staff will, in the first instance, be delivered by the DSP. 

The DSP and DDSP will also undertake Child Protection Level 3 / Local Authority Designated Person training annually.

All staff will be expected to read each version of the Safeguarding Policy and sign a declaration to confirm understanding and compliance.

5. Steps to be taken in response to allegations/concerns relating to staff

5.1 Allegations/concerns against TAP staff

Any allegations/concern against TAP staff will be dealt with in the first instance by the DSP. If any staff member, or other party, holds a concern regarding any employee or representative of TAP, this concern should be reported to the DSP the same working day.

On receipt of any such potential concern, the DSP will:

  1. Determine whether any immediate emergency action is required to protect a child or vulnerable person, and take such action as appropriate in response to any emergency being identified
  2. Request the person raising the concern provide a written account of the concern, if possible within 24 hours.
  3. Notify the CEO that a concern has been received, and is being investigated.
  4. Investigate the allegation, maintaining a log of the allegation and subsequent investigation in a secure cloud location, and will liaise with other agencies and professionals as necessary. The member of staff under investigation will be immediately suspended from work pending the outcome of the investigation. 
  5. On conclusion of the investigation, produce a report dealing with the allegations raised, risks identified and actions recommended. Such report to be made available to the CEO within a time period of two weeks from the initial concern being raised, unless this period is extended on the basis of clear reasons and agreed in writing by the CEO. Any subsequent internal action will be taken at the discretion of the CEO following review of the allegation report and advice from the DSP.

Should an allegation  be made against the DSP the incident will be dealt with by the DDSP, following the procedures outlined above. The DSP will have all access to safeguarding information removed for the duration of the investigation against them.

5.2 Allegations/concerns relating to non-TAP staff

Should TAP staff, or others working on its behalf, become concerned regarding the conduct of any adult working with young people/vulnerable adults, or of any young person in relation to another young person, they will raise this concern with the DSP the same working day. On receipt of any such potential concern, the DSP will:

  1. Determine whether any immediate emergency action is required to protect a child or vulnerable person, and take such action as appropriate in response to any emergency being identified
  2. Request the person raising the concern provide a written account of the concern, if possible within 24 hours.
  3. Notify the CEO that a concern has been received, and is being investigated.
  4. Liaise with the Designated Safeguarding Lead for the organisation employing the adult who is subject to concern, ensuring such contact is made the same working day. The DSP will exchange information both in written form, for clarity, and verbally, to ensure written information has been received and understood by the other agency.

 

6. Steps to be taken in response to safeguarding/welfare concerns raised regarding young people

Should a potential concern regarding a young person’s welfare come to the attention of any TAP member of staff, regardless of the channel via which this concern arises, the following steps are to be taken:

  1. If the staff member is for any reason in direct, telephone or electronic contact with the young person, their role is to listen empathetically to the young person. The staff member should not ask leading questions, should not see to ‘investigate or probe and should never promise to keep information secret. The staff member should make contemporaneous notes of any concern which, should be passed to the TAP DP and then deleted by the original staff member.
  2. The concern should be immediately reported to the DSP. Responsibility at this point passes from the original staff member to the TAP DSP.
  3. The TAP DP will determine whether any immediate emergency action is required to protect a child or vulnerable person, and take such action as appropriate in response to any emergency being identified. Whilst TAP’s practice would ordinarily be to pass safeguarding concerns relating to young people’s welfare to the End User DSP, TAP will always take any immediate emergency action, for example calling the Police, should information arise indicating a young person appear to be in immediate danger of significant harm.
  4. Whether or not interim emergency action has been taken by TAP, the welfare/safeguarding information will then be passed to the End User DSP the same day by the TAP DSP. This may initially be in verbal form for speed, but will always be followed up in writing within 24 hours.
  5. Following provision of the written account, the TAP DSP will re-contact the End User DSP to ensure this has been received and that the End User DSP is taking forward any further safeguarding measures. At this point TAP’s active safeguarding role will cease, although all requests for further information from the End User DSP or other relevant safeguarding agencies will be complied with.

7. Demarcation of responsibility between TAP DSP and End Customer DSP 

The Access Platform’s Customer Agreement clarifies the agreement between TAP and the End Customer relating to the comparative roles of their DSPs. The Customer Agreement also makes it explicit that every End Customer must have a DSP, and that the contact details for their DSP must be shared with TAP, with TAP being updated regarding any change of contact details. TAP will hold a secure record of these contact details. TAP takes no responsibility for the training, quality assurance, or professional actions of the End Customer DSP. TAP, and the TAP DSP, also take no responsibility for the investigation, recording, taking of further action, or resolution of safeguarding incidents. The role of the TAP DSP is limited to ensuring that TAP’s technology operates successfully in terms of alerting the End Customer DSP, and to liaising with the End Customer DP in the event of further necessary action. In the event that a safeguarding incident is reported directly to the End Customer DSP the responsibility is incumbent on them, solely, to deal with the incident and to communicate relevant details to the TAP DSP.

8. Safeguarding risk mitigation measures built into the platform 

TAP is architected around a number of preventative safeguarding measures. These are intended to create a safe and secure online environment and to lessen the likelihood of a safeguarding incident occurring on the platform. In addition to preventative measures, TAP also employs a number of reactive safeguarding processes. These are designed to allow automatic identification of safeguarding incidents and concerns.

8.1 Profiles deactivated by default

When an ambassador profile is created, it is deactived by default meaning that ambassadors can only represent you and interact with the service, once an admin has reviewed their profile and activated them on to the service.

8.2 Anonymity and name display on the platform

Only first names are displayed on the platform. All surnames are redacted to only display the first letter of the surname and are not searchable by Users or Profile Owners. This greatly limits the possibility of Users and Profile Owners engaging in off-site interactions, particularly interactions through social media channels.

8.3 Managing Information Sharing

The Access Platform manages all communication between Users and Profile Owners. No contact information about individual Users is shared with Profile owners or staff of the end customer by The Access Platform. 

8.4 Restrictions on sharing personal and contact information - Profile Owners mandatory terms and conditions

As part of our profile creation process Profile Owners (usually university student ambassadors or staff) are explicitly required to agree to a number of terms and conditions. In the full terms and conditions for both Profile Owners TAP states that the sharing of personal or contact information or any other inappropriate content could result in their removal from the service. 

Profile Owners check tickboxes during the profile creation process to agree to specific safeguarding items. These are:

  • I will not share any personal or contact information through this service and agree that all communications I have through this service will be appropriate and can be recorded for safeguarding and quality assurance purposes.
  • I agree to actively share any welfare concerns that arise and not to promise a young person to keep any information secret if it pertains to a welfare concern.

8.5 Call recording and storage

All calls are recorded to allow review for safeguarding and quality assurance purposes. Call recordings are stored in an identifiable, encrypted format in a secure cloud location for 12 months. After this time period calls are anonymised and contact information is abstracted from the call metadata. 

8.6 Information sharing message before calls

At the beginning of a call facilitated by the platform a recorded message is relayed to participants:

‘This call is recorded for quality assurance and safeguarding purposes. Please do not share any personal or contact information, or give any factual answers that you are unsure about. Enjoy your conversation.’

The recorded message reinforces the prohibition of sharing personal or contact information, and reminds Users and Profile Owners that the conversation is recorded and may be reviewed

8.7 Automatic keyword detection on direct message and calls

As detailed above, the TAP chat platform automatically detects certain keywords (listed in appendix of this document) that may be indicative of a safeguarding concern or incident. The process for detection and follow-up is detailed below:

  • If a keyword is detected in a call or direct message then an automatic email notification is sent to the named End Customer Page Admin.
  • This email notification is seen by our customer service team and, depending on the severity of the content, may be shared by the TAP DP. This is done on an ad-hoc basis and, as outlined above, does not affect the demarcation of responsibility between the End Customer DP and the TAP DP.
  • The email notification contains: an alert relating to the content; a link to review the whole conversation (transcript or recording) in the admin area.
  • Admins can review the content of the conversation and ‘check off’ the safeguarding ‘alert’ if the conversation is not of concern.
  • If the conversation is of concern they can escalate this internally via their own SG policies, and should notify the TAP DP.

TAP cannot guarantee the accuracy of the automatic keyword detection, but can clarify that the platform provides a higher degree of accuracy on detection relating to direct messages (as text based exchanges) as opposed to phone calls (audio based exchanges).

The End Customer DP or Page Admin can, at any point, manually review transcriptions or recordings of all interactions in the platform’s admin area.

8.8 Direct Message Participant Reporting 

Either participant in a Direct Message conversation can ‘flag’ a conversation for review by the page admin. When submitting a ‘flag’ the participant is asked for giving a reason for why they have flagged the conversation. This information is then made available to the admin in the dashboard, and a notification is sent to the admin to make them aware of the flagged content. The admin can then review the conversation, context, and reason why it was flagged. Once the issue is resolved, the admin can then dismiss the flagged content in the dashboard. 

8.9 Safeguarding responsibility for content held within the ‘Answers’ section

All submitted questions and answers are visible to the university admin. The decision to respond to a question or to publish an answer therefore remains with the End Customer  admin. The expectation is that any content which prompts a concern should be dealt with directly by the End Customer DP. The TAP DP will manually flag any content which is of potential concern, but this will only be on an ad hoc basis and is not intended to replace oversight by the End Customer admin or End Customer DP.

9. Extended services and practices

TAP also recognises that its commercial activities extend beyond the administration of an online platform, and will often involve face-to-face interactions with young people and visits to educational institutions. In these situations the TAP DP is responsible for ensuring that TAP staff behave in accordance with a given institution’s safeguarding policy and procedures, and understand that professional boundaries relating to the appropriateness of contact, interaction, and relationship with young people are rigorously maintained.

Appendix A: List of keywords scanned by software

Keywords

  • phone-number-like structures, e.g. sequence of 6 to 15 digits without respect to delimiters between those digits
  • email address structures (e.g. structures such as xxx@xxx.xxx)
  • gmail
  • hotmail
  • yahoo
  • zoho
  • outlook
  • icloud
  • facebook
  • instagram
  • twitter
  • snapchat
  • tinder
  • bumble
  • grindr
  • grinder
  • meet up
  • secret
  • depressed
  • self-harm
  • suicide
  • death
  • die
  • overdose
  • psycho
  • starve
  • bulimia
  • anorexia
  • schizophrenia
  • schizo
  • anxiety
  • bipolar
  • insomnia
  • nightmares
  • rape
  • paedo
  • paedophile
  • jihad
  • islamic state
  • isis
  • radicalised
  • bomb
  • al-qaeda
  • martyr
  • kill
  • nonce
  • skype
  • whatsapp
  • facetime
  • imessage
  • mobile 
  • Abuse
  • abused
  • abusive
  • abusing
  • bully
  • bullied
  • ibuprofen 
  • aspirin
  • paracetamol
  • #KMS
  • fb
  • insta
  • gram
  • snap
  • text
  • whatsapping
  • wechat
  • cunt
  • fuck
  • shit
  • openchat

Due to the technical reasons which would cause an adverse impact on the service, strings of numbers are only detected in Direct Message conversations.

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