Our Commitment to Student Safety

1. Introduction and Commitment

At UpGrades, operated by Rogue Digital Ltd (registered at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, VAT: GB458050200), safeguarding the welfare of children and young people is our highest priority.

We are committed to providing a safe online learning environment for all students using our platform. This policy sets out our approach to safeguarding and outlines the measures we have in place to protect students from harm.

Our commitment includes:

• Ensuring the safety and wellbeing of all students using our platform
• Preventing harm and reducing risk to students
• Responding appropriately to safeguarding concerns
• Working with parents, schools, and relevant authorities to protect children
• Maintaining a culture of vigilance and continuous improvement

2. Scope

This Safeguarding Policy applies to:

• All students aged 14 and over who use the UpGrades platform
• All UpGrades employees and contractors
• All third-party providers who have access to student data or interact with students
• The UpGrades platform and all related services

While our platform is designed for students aged 14 and over, we recognise that many of our users are children under 18 and are therefore entitled to enhanced protection under UK law.

3. Key Principles

Our safeguarding approach is based on the following principles:

• Child welfare is paramount: The safety and wellbeing of students comes before all other considerations
• All concerns are taken seriously: We listen to and act upon any safeguarding concerns, however minor they may seem
• Prevention is better than cure: We design our platform and policies to prevent harm before it occurs
• Partnership approach: We work collaboratively with parents, schools, and authorities
• Transparency and accountability: We are open about our practices and take responsibility for student safety
• Continuous improvement: We regularly review and enhance our safeguarding measures

4. Platform Safety Measures

We have implemented comprehensive technical and operational measures to ensure student safety on our platform:

Content Moderation

• All educational content is reviewed before publication
• Content is age-appropriate and aligned with the UK National Curriculum
• Regular audits ensure content remains suitable and accurate
• Inappropriate or harmful content is removed immediately upon identification

No Direct Messaging

• Students cannot message each other directly through the platform
• Students cannot message teachers or staff directly
• All communication is structured through supervised channels (e.g., class discussions moderated by teachers)
• This prevents grooming, bullying, and inappropriate contact

Parental Oversight

• Parents can create linked accounts to monitor their child's progress
• Parents receive regular reports on their child's activity and performance
• Parents can set usage limits and restrictions
• Parental consent is required for students under 16 in accordance with UK GDPR

Data Minimisation

• We collect only the minimum data necessary to provide our service
• Students are not required to share personal information publicly
• Profile information is limited and privacy-focused
• Data is encrypted in transit and at rest
• Access to student data is strictly controlled and logged

Technical Safeguards

• Secure authentication and access controls
• Regular security audits and penetration testing
• Automated monitoring for suspicious activity
• Content filtering to block inappropriate material
• Age verification processes where required

5. Reporting Concerns

We encourage students, parents, teachers, and staff to report any safeguarding concerns immediately. Concerns may include:

• Inappropriate content or behaviour on the platform
• Signs that a student may be at risk of harm
• Suspected abuse or neglect
• Bullying or harassment
• Grooming or inappropriate contact
• Mental health concerns
• Any other welfare concerns

How to Report

You can report safeguarding concerns in the following ways:

• Email: safeguarding@upgrades.app (monitored 24/7)
• Emergency: If a child is in immediate danger, contact the police on 999
• Through the platform: Use the "Report Concern" button available throughout the application

All reports are treated confidentially and investigated promptly by our designated safeguarding team.

What Happens Next

When we receive a safeguarding concern:

1. Immediate assessment: We assess the urgency and nature of the concern within 1 hour
2. Investigation: We gather relevant information and evidence
3. Action: We take appropriate action, which may include:
   • Contacting parents or guardians
   • Reporting to local authorities or police
   • Suspending accounts
   • Removing content
   • Providing support resources
4. Follow-up: We follow up to ensure the concern has been resolved and the student is safe
5. Record-keeping: All concerns and actions are documented in accordance with data protection law

6. Staff and Contractor Requirements

All UpGrades staff and contractors who have access to student data or may interact with students are subject to rigorous safeguarding requirements:

Pre-Employment Checks

• DBS checks: Enhanced Disclosure and Barring Service checks for all relevant staff
• Reference checks: Verification of employment history and professional references
• Identity verification: Confirmation of identity through official documents
• Right to work: Verification of eligibility to work in the UK

Safeguarding Training

All staff receive mandatory safeguarding training covering:

• Recognition of signs of abuse and neglect
• Understanding of online safety risks
• Knowledge of reporting procedures
• Awareness of legal responsibilities
• Best practices for working with children online

Training is refreshed annually and updated whenever there are changes to legislation or guidance.

Code of Conduct

All staff and contractors must adhere to our Code of Conduct, which includes:

• Maintaining professional boundaries with students
• Reporting all safeguarding concerns immediately
• Protecting student data and privacy
• Never meeting students in person without appropriate safeguards
• Acting as role models in all interactions

Violations of the Code of Conduct may result in disciplinary action up to and including termination of employment and reporting to relevant authorities.

7. Alignment with Keeping Children Safe in Education

Our safeguarding practices are aligned with the statutory guidance "Keeping Children Safe in Education" (KCSIE) issued by the Department for Education. While KCSIE primarily applies to schools, we adopt its principles as best practice for our online platform.

We are committed to:

• Understanding the four categories of abuse: physical, emotional, sexual, and neglect
• Recognising specific safeguarding issues including online safety, sexual exploitation, and radicalisation
• Maintaining clear escalation procedures for safeguarding concerns
• Working in partnership with schools and local safeguarding partners
• Supporting students who have been harmed or are at risk

We review our policies annually to ensure continued alignment with the latest version of KCSIE and other relevant guidance.

8. Support Resources

If you or someone you know needs support with safeguarding issues, the following organisations can help:

• Childline: Free, confidential support for young people - 0800 1111 or childline.org.uk
• NSPCC: Advice and support for anyone concerned about a child - 0808 800 5000 or nspcc.org.uk
• CEOP (Child Exploitation and Online Protection): Report online abuse at ceop.police.uk
• UK Safer Internet Centre: Advice on online safety at saferinternet.org.uk
• Young Minds: Mental health support for young people at youngminds.org.uk

9. Review and Updates

This Safeguarding Policy is reviewed annually and updated whenever:

• There are changes to legislation or statutory guidance
• Significant safeguarding incidents occur
• New risks or vulnerabilities are identified
• Our services or platform significantly change

The next scheduled review is February 2027. The latest version of this policy is always available on our website.

We welcome feedback on our safeguarding practices. If you have suggestions for improvements, please contact our designated safeguarding lead at safeguarding@upgrades.app.

10. Contact

For all safeguarding matters, please contact:

• Designated Safeguarding Lead: safeguarding@upgrades.app
• General enquiries: hello@upgrades.app
• Address: Rogue Digital Ltd (trading as UpGrades), 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom
• VAT Number: GB458050200

Our safeguarding email is monitored 24 hours a day, 7 days a week. If you have an urgent concern outside normal business hours, you will receive an automated response with emergency contact information.

Remember: If a child is in immediate danger, contact the police on 999.