Safeguarding Policy

1. Our Commitment

NeuroPathway Ecosystem is committed to safeguarding and promoting the welfare of all children, young people, and vulnerable adults who use our platform. We recognize that safeguarding is everyone's responsibility.

This policy applies to all staff, contractors, volunteers, and partner organizations working with NeuroPathway Ecosystem. It aligns with:

• Working Together to Safeguard Children (2023)
• Keeping Children Safe in Education (2024)
• Care Act 2014 (safeguarding adults)
• Children Act 1989 and 2004
• Mental Capacity Act 2005
• Local Safeguarding Children Partnership (LSCP) procedures

2. Definitions

2.1 Safeguarding Children

Safeguarding children means:

• Protecting children from maltreatment
• Preventing impairment of children's mental and physical health or development
• Ensuring children grow up in safe, effective care
• Taking action to enable all children to have the best outcomes

2.2 Child Protection

Child protection is part of safeguarding and refers to activities to protect specific children who are suffering, or likely to suffer, significant harm.

2.3 Types of Abuse

We recognize the following categories of abuse:

• Physical Abuse: Hitting, shaking, throwing, burning, or otherwise causing physical harm
• Emotional Abuse: Persistent emotional maltreatment causing severe adverse effects on emotional development
• Sexual Abuse: Forcing or enticing a child to take part in sexual activities
• Neglect: Persistent failure to meet a child's basic physical and/or psychological needs
• Online Abuse: Cyberbullying, grooming, exploitation, exposure to harmful content
• Self-Harm and Suicidal Ideation: Risk of harm to self

3. Recognition of Abuse

3.1 Signs and Indicators

Through platform monitoring, we watch for indicators including:

• Sudden changes in mood patterns (sustained low mood, increased anxiety)
• References to self-harm or suicidal thoughts in journal entries or AI conversations
• Disclosures of abuse or concerning situations
• Repeated access to crisis support resources
• Expressions of hopelessness, worthlessness, or despair
• Significant deterioration in emotional wellbeing over time
• References to harmful relationships or dangerous situations

3.2 AI-Assisted Detection

Our AI pattern detection system is designed to identify concerning trends while respecting privacy:

• Analyzes mood check-in data for persistent negative patterns
• Flags concerning keywords in AI assistant conversations (not private journals)
• Generates alerts for safeguarding team review (not automated reporting)
• Human safeguarding professionals make all final decisions

Important: Private journal entries are NEVER monitored by AI or staff unless the young person explicitly shares them or there's an immediate life-threatening emergency.

4. Responding to Concerns

4.1 Immediate Safety

If a young person discloses immediate danger or risk:

• Life-threatening emergency: Call 999 immediately
• Serious safeguarding concern: Contact Designated Safeguarding Lead (DSL) within 24 hours
• Mental health crisis: Direct to crisis support (NHS 111 option 2, Childline, Samaritans)
• Child in need: Refer to local authority children's services

4.2 Five Rs of Responding

When a child discloses abuse or concern:

• Receive: Listen without interrupting, stay calm
• Reassure: Tell them they did the right thing by sharing
• Respond: Explain what will happen next, don't make promises you can't keep
• Record: Document exactly what was said using the child's own words
• Report: Pass information to Designated Safeguarding Lead immediately

4.3 What NOT to Do

• Promise confidentiality (explain safeguarding may require sharing)
• Investigate or ask leading questions
• Discuss the concern with anyone other than appropriate professionals
• Contact the alleged abuser
• Delay reporting due to uncertainty

5. Roles and Responsibilities

5.1 Designated Safeguarding Lead (DSL)

Our DSL is responsible for:

• Acting as the first point of contact for safeguarding concerns
• Coordinating safeguarding actions within the organization
• Making referrals to children's social care and police as needed
• Liaising with local authority Designated Officers (LADO)
• Maintaining confidential safeguarding records
• Providing safeguarding training to staff
• Reviewing AI safeguarding alerts daily

Designated Safeguarding Lead: [Name to be added]
Contact: safeguarding@neuropathwayecosystem.co.uk
Emergency Line: [Number to be added] (24/7)

5.2 All Staff and Contractors

Everyone working with NeuroPathway Ecosystem must:

• Complete safeguarding training (Level 2 minimum, renewed every 3 years)
• Hold enhanced DBS checks (Disclosure and Barring Service)
• Report any safeguarding concerns immediately to DSL
• Maintain professional boundaries with service users
• Follow data protection and confidentiality policies
• Challenge inappropriate behavior

5.3 Partner Professionals

Healthcare and education professionals using the platform must:

• Follow their own organization's safeguarding procedures
• Report concerns through appropriate channels (their DSL/safeguarding team)
• Use platform safeguarding alerts as supplementary information
• Maintain their professional duty of care

6. Information Sharing

6.1 When to Share

We share information without consent when:

• There is risk of significant harm to a child or vulnerable adult
• Necessary to prevent crime or support prosecution
• Required by court order or statutory duty
• In the public interest (serious crime, national security)

Information sharing is governed by:

• Working Together to Safeguard Children (Information Sharing Advice)
• UK GDPR Article 6 (legal basis) and Article 9 (special category data)
• Common Law Duty of Confidentiality (exceptions for safeguarding)
• Local Multi-Agency Safeguarding Arrangements (MASA)

6.2 Seven Golden Rules for Information Sharing

1. Remember that UK GDPR and Data Protection Act 2018 are not barriers to sharing information but provide a framework
2. Be open and honest with the child/family about why and with whom information will be shared (unless unsafe)
3. Seek consent where appropriate, but recognize this is not required for safeguarding
4. Consider safety and wellbeing: base decisions on the child's best interests
5. Share information on a need-to-know basis with relevant agencies
6. Ensure information shared is accurate, up-to-date, necessary, and proportionate
7. Keep records of decisions and reasons for sharing (or not sharing)

7. Specific Safeguarding Issues

7.1 Self-Harm and Suicide

If a young person expresses suicidal thoughts or self-harm:

• AI assistant immediately provides crisis resources (Childline, Samaritans, NHS 111)
• Safeguarding alert generated for DSL review
• DSL assesses risk and contacts parents/carers or emergency services as appropriate
• If imminent risk identified, immediate action taken (may include contacting emergency services)

7.2 Online Safety

We protect young people from online risks:

• No direct messaging between users (prevents grooming)
• No public profiles or social features
• AI assistant trained to recognize and respond to inappropriate requests
• Content filtering to prevent exposure to harmful material
• Education resources about online safety within the app

7.3 Peer-on-Peer Abuse

If disclosures of bullying or peer abuse are made:

• Take all allegations seriously
• Report to DSL who will liaise with schools/youth services
• Support both victim and alleged perpetrator appropriately
• Follow up to ensure safeguarding measures are in place

7.4 Radicalisation and Extremism

Under Prevent duty, we:

• Train staff to recognize signs of radicalization
• Report concerns to DSL who contacts local Prevent coordinator
• Provide support to vulnerable individuals

7.5 Domestic Abuse

If domestic abuse is disclosed or suspected:

• Assess immediate safety of child and non-abusing parent
• Make referral to MARAC (Multi-Agency Risk Assessment Conference) if high risk
• Provide information about support services (Women's Aid, Refuge, Men's Advice Line)

7.6 Child Sexual Exploitation (CSE) and County Lines

Indicators monitored include references to:

• Inappropriate relationships with older individuals
• Going missing or unexplained absences
• Unexplained gifts or money
• Signs of gang affiliation or exploitation

Any concerns immediately reported to police and children's social care.

8. Record Keeping

All safeguarding concerns and actions are recorded:

• Factual, objective account of concerns
• Date, time, and details of disclosure or incident
• Exact words used by the child (in quotes)
• Actions taken and rationale for decisions
• Information shared and with whom
• Outcome and follow-up actions

Records are:

• Stored securely with restricted access (DSL and authorized personnel only)
• Retained until the child's 75th birthday or as required by local authority
• Transferred appropriately if the child moves services
• Subject to audit and inspection by regulatory bodies

9. Training and Support

9.1 Staff Training

• Induction: Safeguarding awareness for all new staff
• Level 2 Safeguarding: All staff working with children (refreshed every 3 years)
• DSL Training: Designated Safeguarding Leads (refreshed every 2 years)
• Prevent Training: Awareness of radicalization risks
• Specialist Training: CSE, mental health first aid, trauma-informed practice

9.2 Professional Supervision

DSL receives regular supervision from experienced safeguarding professionals to ensure quality decision-making and emotional wellbeing support.

10. Whistleblowing

All staff have a duty to report concerns about colleagues or organizational practices that may put children at risk.

If you have concerns about:

• Safeguarding practices within NeuroPathway Ecosystem
• Conduct of staff or contractors
• Failure to follow safeguarding procedures

Report to:

• Internal: DSL or Senior Leadership Team
• External: Local Authority Designated Officer (LADO)
• Anonymous: NSPCC Whistleblowing Helpline: 0800 028 0285

11. Allegations Against Staff

If an allegation is made against a staff member or volunteer:

• Report immediately to Senior Leadership (not the accused)
• Contact LADO within 24 hours
• Suspend the individual if necessary to ensure child safety
• Conduct investigation in line with disciplinary procedures
• Make referrals to DBS and professional bodies if substantiated
• Support for all parties during investigation

12. Policy Review

This Safeguarding Policy is reviewed:

• Annually or whenever there are changes in legislation or guidance
• Following any serious safeguarding incident
• In consultation with safeguarding partners and service users

Next review date: December 2025

13. Key Contacts