Safeguarding & Child Protection Policy

Protecting children and young people across our programmes, platforms, and partner institutions

Document title	Safeguarding and Child Protection Policy
Organisation	Squid Academy Ltd (registered in the United Kingdom)
Version	2.0
Designated Safeguarding Lead (DSL)	Anusuya Mukherjee | [e-mail] | [phone]
Deputy Safeguarding Lead	Jeffrey Cray | [e-mail] | [phone]
Approved by	Steyn Van Hövell, CEO
Date of approval/commencement	21.6.2026
Next review date	21.6.2027
Review frequency	Annually, or sooner if circumstances require

1. Purpose and Aim

Squid Academy Ltd (“Squid Academy”, “we”, “us”) is committed to safeguarding and promoting the welfare, safety, and wellbeing of all children and young people who engage with our educational programmes, esports activities, online learning platforms, workshops, coaching sessions, assessments, and community events. As an organisation registered with the AQA Unit Award Scheme, we recognise that the recognition of learning we provide carries with it a duty of care towards every learner who works towards it.

We believe that:

• Every child has the right to learn and take part in a safe environment.
• Safeguarding is everyone’s responsibility.
• The welfare of the child is paramount.
• All concerns about the welfare of a child must be taken seriously and acted upon.
• Appropriate action must be taken whenever a child may be at risk of harm.

This policy sets out the principles, responsibilities, and procedures through which Squid Academy meets its safeguarding commitment and the steps that all individuals acting for or on behalf of Squid Academy must take to keep children safe.

2. Scope

This policy applies to all individuals who act for or on behalf of Squid Academy, including:

• Employees and directors
• Contractors and associates
• Coaches, tutors, and mentors
• Volunteers and guest speakers
• Any external partner delivering services on behalf of Squid Academy

It applies across all of the learning environments we provide or operate, including virtual classrooms, live online coaching, esports competitions and tournaments, educational workshops, community events, our learning management system, and any Discord or community platforms operated by Squid Academy.

Squid Academy delivers the majority of its programmes through partner institutions, including schools, colleges, universities, and esports centres, which retain their own statutory and local safeguarding duties. This policy governs the conduct of Squid Academy and its personnel and operates alongside the safeguarding policy and designated leads of each partner institution. Where a concern arises about a learner, Squid Academy will work with, and refer to, the partner institution’s designated safeguarding lead and the relevant local authorities.

3. Our Commitment

Squid Academy is committed to creating and maintaining an environment in which children and young people are safe, respected, listened to, and able to flourish. We will put the welfare of children first, respond promptly to concerns, work with parents, schools, and authorities where appropriate, and maintain confidentiality while protecting children’s welfare.

Equality. We give equal priority to keeping all children and young people safe regardless of age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, nationality, or socioeconomic background.

Additional vulnerability. We recognise that some children are additionally vulnerable because of the impact of discrimination, previous experiences, disability, communication needs, special educational needs, or their level of dependency, and that online environments can introduce specific risks. We take additional care to ensure these children are heard and protected.

4. Legal and Regulatory Framework

As a company registered in the United Kingdom that operates internationally, Squid Academy has regard to recognised safeguarding standards across every jurisdiction in which it works. In particular:

• United Kingdom guidance. We have regard to the principles of “Keeping Children Safe in Education”, “Working Together to Safeguard Children”, and the Department for Education code of practice “Keeping children safe in out-of-school settings”.
• Local law in countries of operation. We comply with the child protection and safeguarding laws and expectations of each country in which we deliver, currently including Malaysia, Thailand, India, and the United States, and any further territories we enter.
• International standards. We uphold Article 19 of the United Nations Convention on the Rights of the Child, which requires that all appropriate measures be taken to protect children from violence, abuse, neglect, and exploitation.
• Partner frameworks. Where we deliver through a partner institution, that institution’s local statutory framework and designated leads operate alongside this policy, and we refer and escalate accordingly.

5. Definitions

Child. A person under the age of 18.

Safeguarding. Protecting children from abuse, neglect, exploitation, and harm, while promoting their welfare and development.

Child protection. The actions taken when there is a reasonable concern that a child may be suffering, or may be at risk of suffering, significant harm.

6. Recognising Abuse

All personnel must be aware of the main categories of abuse and the signs that may indicate a child is at risk. The examples below are indicators, not an exhaustive list.

Physical abuse: deliberate physical harm or injury, for example, hitting, shaking, burning, or assault.

Emotional abuse: persistent emotional mistreatment, for example, humiliation, intimidation, bullying, or threats.

Sexual abuse: any sexual activity involving a child, including grooming, exploitation, sexual communication, and the sharing of inappropriate content.

Neglect: a failure to meet a child’s basic physical or emotional needs, for example, a lack of supervision, care, or safe conditions.

Online abuse: abuse facilitated through technology, including cyberbullying, grooming, exploitation, harassment, and the sharing of harmful content.

7. Roles and Responsibilities

Senior Management Team

Responsible for policy oversight, allocating resources for safeguarding, and monitoring compliance across the organisation.

Designated Safeguarding Lead (DSL)

The DSL is the first point of contact for any safeguarding concern. The DSL receives concerns, decides on and makes referrals, liaises with authorities and partner institutions, maintains records, and provides guidance to staff.

DSL: Anusuya Mukherjee Email: [e-mail] Phone: [phone]

Deputy Safeguarding Lead

Acts with the full authority of the DSL in the DSL’s absence, or where a concern relates to the DSL.

Deputy: Jeffrey Cray Email: [e-mail] Phone: [phone]

Staff, Associates, and Volunteers

Responsible for following this policy, maintaining professional conduct, and reporting any concern without delay.

Partner Institutions

Retain their own statutory safeguarding duties and designated leads. Squid Academy works with partner leads and shares relevant concerns so that they can be acted upon locally and promptly.

8. Safer Recruitment and Locally Appropriate Checks

Squid Academy applies safer recruitment principles to all personnel who may have contact with children, and carries out checks that are appropriate to the role and lawful in the jurisdiction in which the individual is engaged. These may include:

• Verifying identity
• Obtaining and following up references
• Verifying relevant qualifications
• Confirming the right to work
• Criminal background checks, such as a DBS check in the United Kingdom or the local equivalent, where legally permitted and required for the role
• Prohibition or barred-list checks where these exist in the relevant jurisdiction

No individual may work unsupervised with children until the checks appropriate to their role and location have been completed and recorded. Where Squid Academy delivers through a partner institution that employs the supervising staff, Squid Academy will seek assurance that the partner has completed locally appropriate checks on those staff. Records of checks are retained securely.

9. Code of Conduct

All staff, associates, and volunteers must:

• Treat learners with respect and maintain professional boundaries at all times
• Use only approved communication channels
• Promote a safe and inclusive environment
• Report any safeguarding concern immediately

They must not:

• Engage in inappropriate conversations or use inappropriate language
• Share personal contact information with learners
• Communicate privately with learners through personal social media or personal accounts
• Request personal photographs from learners
• Arrange unsupervised meetings with learners
• Form relationships with learners outside the professional educational setting

10. Online Safety and Digital Safeguarding

As a provider whose programmes are delivered substantially online, Squid Academy places particular importance on digital safeguarding. We will:

• Use moderated learning platforms and apply age-appropriate controls
• Monitor community spaces, including any Discord or community platforms we operate, where appropriate
• Restrict and remove inappropriate content
• Provide clear reporting mechanisms for learners
• Promote safe online behaviour and educate learners in digital citizenship

Learners are expected to treat others respectfully, report inappropriate behaviour, avoid sharing personal information publicly, and follow platform rules and community guidelines.

11. One-to-One Communication with Learners

To reduce safeguarding risk:

• One-to-one communication with a child should be avoided wherever possible
• Communication should take place through approved platforms only
• Parents, carers, or the partner institution may be copied into communications where appropriate
• Sessions should be recorded where permitted and practical
• Professional language must be maintained at all times

12. Recognising and Reporting Concerns

Any individual who observes concerning behaviour, receives a disclosure, suspects abuse, becomes aware of online exploitation or grooming, or is otherwise worried about a child’s wellbeing, must report the concern to the Designated Safeguarding Lead or Deputy without delay.

A report should include:

• The date and time
• The individuals involved
• The facts observed
• The exact words used, where possible
• Any immediate risk identified

Those raising a concern must not promise confidentiality, attempt to investigate the matter themselves, confront an alleged perpetrator, or delay reporting. Concerns are raised using 

Reporting route: [e-mail] → [e-mail] → [e-mail]

13. Responding to a Disclosure

If a child discloses abuse, staff should stay calm, listen carefully, take the child seriously, reassure them that they have done the right thing by speaking up, record the information accurately, and report it immediately.

Staff should not ask leading questions, make promises, express shock or disbelief, or conduct their own investigation.

14. Managing Allegations Against Staff, Associates, or Volunteers

Squid Academy takes seriously any concern or allegation that a member of staff, an associate, a volunteer, or any adult acting on its behalf may have:

• Behaved in a way that has harmed, or may have harmed, a child
• Possibly committed a criminal offence against, or related to, a child
• Behaved towards a child in a way that indicates they may pose a risk of harm
• Behaved, or may have behaved, in a way that indicates they may not be suitable to work with children, including conduct in their personal life that may present a transferable risk

Where such a concern arises, the following process applies:

• Report immediately to the DSL. If the concern is about the DSL, it must instead be reported to Jeffrey Cray | [e-mail] | [phone]
• The DSL, or the alternative lead where the concern relates to the DSL, takes charge, ensures the child’s immediate safety, and does not attempt an informal investigation or alert the subject in a way that could prejudice an inquiry.
• Squid Academy refers the matter to the relevant statutory or local authority, for example local children’s services or the police, and in England the Local Authority Designated Officer or equivalent, in line with the law of the jurisdiction concerned, and cooperates fully.
• Where the individual is supervised by, or engaged through, a partner institution, Squid Academy informs and works with that institution’s designated safeguarding lead.
• Appropriate employment or contractual action, including precautionary suspension or removal of access to learners and platforms, is considered to protect children while any inquiry proceeds.
• Confidential records of the allegation, decisions, and actions are kept securely.
• Allegations found to be malicious or unfounded are handled fairly, and support is offered to those affected.

15. Concerns About Another Child or Young Person

Concerns about the behaviour of one child towards another, including bullying and peer-on-peer abuse, are taken seriously, reported to the DSL, recorded, and escalated where necessary. Support is offered to all children involved, and the matter is shared with the relevant partner institution and authorities where appropriate.

16. Escalation and Risk Levels

Low-level concern (for example inappropriate language or minor bullying): record the incident, monitor behaviour, and inform the relevant supervisor.

Safeguarding concern (for example grooming indicators, self-harm concerns, or significant emotional distress): escalate immediately, notify the DSL, and consider notifying the parent, carer, or partner institution.

Immediate risk (for example a threat of serious harm, sexual exploitation, or expressed intent to take one’s own life): contact local emergency services or the relevant authorities immediately, notify the DSL, and preserve any evidence.

17. Confidentiality and Information Sharing

Information is shared only when necessary to protect a child, with relevant authorities, and with schools, partner institutions, parents, or carers where appropriate, and always in accordance with applicable data protection law. The welfare of the child is paramount and takes precedence over confidentiality. A concern about a child must always be shared with the DSL, even if the child asks that it not be.

18. Record Keeping and Data Protection

Safeguarding records are stored securely, access-controlled, available only to authorised personnel, and retained in accordance with Squid Academy’s data retention schedule and applicable data protection law, including the UK General Data Protection Regulation where relevant.

19. Training and Awareness

All personnel who work with learners receive safeguarding awareness training covering child protection principles, online safety, recognising abuse, reporting procedures, and professional boundaries. The Designated Safeguarding Lead and Deputy receive enhanced training appropriate to their role. Training is refreshed at least every two years, and completion of this policy forms part of induction.

20. Whistleblowing and Complaints

Any individual who believes a safeguarding concern has not been handled appropriately, or that a child is being placed at risk by the conduct of others or by organisational failure, can and must raise it. Concerns may be raised with the DSL, the Senior Management Team, or, where internal routes are exhausted or inappropriate, with the relevant external authority. No one who raises a genuine concern in good faith will suffer any detriment for doing so.

21. Monitoring and Review

This policy is reviewed by the Designated Safeguarding Lead and the Senior Management Team at least annually, or sooner if legislation changes, new safeguarding risks emerge, a significant incident occurs, or regulatory guidance is updated.

22. Contact Details

Designated Safeguarding Lead: Anusuya Mukherjee | [e-mail] | [phone]

Deputy Safeguarding Lead: Jeffrey Cray | [e-mail] | [phone]

Internal reporting channel: [e-mail] → [e-mail] → [e-mail]

In an emergency, staff must contact the local emergency services number for the country in which the learner is located. Widely used examples include 999 in the United Kingdom and 911 in the United States. The relevant local emergency and child protection contacts for each country of delivery are maintained by the partner institution.

Additional support and reporting:

• NSPCC Helpline (adults concerned about a child): 0808 800 5000
• Childline (for children and young people): 0800 1111
• AQA safeguarding team (for concerns relating to AQA UAS): [e-mail]

Appendix A: AQA UAS Safeguarding Assurance Mapping

AQA UAS asks that a registering organisation’s safeguarding policy addresses five points. The table below shows where each is met in this policy.

AQA UAS assurance point	How this policy provides assurance	Where
1. Clear contact details of the designated person for safeguarding matters	Named Designated Safeguarding Lead and Deputy, with direct email and phone contact	Sections 7 and 22
2. A process to respond to any safeguarding concern raised	Defined procedures for recognising, reporting, responding to disclosures, and escalating concerns	Sections 12, 13 and 16
3. A process in line with local legislation or guidance	Legal and regulatory framework covering UK statutory guidance, the law of each country of operation, and the UN Convention on the Rights of the Child	Section 4
4. Locally appropriate checks on staff employed	Safer recruitment standards with vetting appropriate to the role and lawful in each jurisdiction	Section 8
5. A process to respond to concerns raised about staff members	Dedicated procedure for managing allegations against staff, associates, and volunteers, including referral to the relevant authority	Section 14

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Appendix B: Safeguarding Reporting Flow

A quick reference for any member of staff, associate, or volunteer with a concern about a child.

1. Ensure the child is safe. If a child is in immediate danger, contact local emergency services first.
2. Record what you have seen or been told, using the child’s own words where possible. Do not investigate or confront anyone.
3. Report to the Designated Safeguarding Lead, or the Deputy, without delay. Do not promise confidentiality.
4. The DSL assesses the concern, decides on referral, and contacts the relevant authorities and, where applicable, the partner institution’s safeguarding lead and the child’s parents or carers.
5. All actions, decisions, and information shared are recorded securely.