The Ambassador Platform Safeguarding Policy

1. Executive Summary

This policy document outlines the approach to Safeguarding taken by The Ambassador Platform (TAP). It is split into two broad sections: Context and Approach, and Processes. It should be read, and understood, in conjunction with the more operationally-focussed articles in the Safeguarding subsection of our Knowledge Base.

2. Statement of Intent

As a provider of online services directly involving young people, The Ambassador Platform acknowledges the special, and unique, duty of  care this places upon us to contribute to the safeguarding and welfare of young people and vulnerable adults who use our technology. In particular, The Ambassador 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 a key priority and the purpose of this policy is to outline the practical steps The Ambassador Platform takes to ensure this approach is embedded through all aspects of the organisation. As a technology service provider we are committed, to the fullest extent of our abilities and within the practical limitations of our remit, 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 Ambassador Platform where all possible steps are taken to restrict access to age inappropriate conversations or the sharing of personal contact information;
  2. Have the ability to raise any concerns, difficulties or welfare issues and have these responded to promptly and in a manner conforming to best safeguarding practice.

3. 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 The Ambassador Platform. The contents are binding upon all employees or other representatives of the organisation and apply to any child, young person, or vulnerable adult that the organisation, or those working on its behalf, serves via its technology or comes into direct contact with. Failure to comply with this policy and procedures will be addressed robustly and may result in disciplinary action, including in dismissal.

4. Review process

This policy will be reviewed every 12 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 The Ambassador Platform’s staff and external Safeguarding consultants.

Latest review date: May 2022

Next annual review: May 2023

5. Key safeguarding contacts:

Designated Safeguarding Person (DSP)

Name: Nik Higgins

Position: Co-Founder and Chief Strategy Officer

Email: nik@theaccessplatform.com

Tel: +447538909915

Deputy Designated Safeguarding Person (DDSP)

Name: George Olesen

Position: Co-Founder and Chief Executive Officer

Email: george@theaccessplatform.com

Tel: +44 (0) 20 3026 4663 

All Safeguarding related issues must be referred to the Designated Safeguarding Person (DPS) without delay. If for any reason a response is not received within an appropriate time frame (at the most, the same day), the Deputy Designated Safeguarding Person (DDPS) 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 then the police, or relevant local authority, should be contacted immediately.


i. Context and Approach

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

Relevant legislation and policy guidance

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

United Kingdom

  • 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)

The Ambassador Platform’s policy also takes broad instruction from overseas legislation, namely:

Australia

  • Children and Young People Act 2008 (ACT)
  • Children and Young Persons (Care and Protection) Act 1998 (NSW)
  • Care and Protection of Children Act 2007 (NT)
  • Child Protection Act 1999 (QLD)
  • Children's Protection Act 1993 (SA)
  • Children, Young Persons and their Families Act 1997 (TAS)
  • Children, Youth and Families Act 2005 (VIC)
  • Children and Community Services Act 2004 (WA)

New Zealand

  • Children’s Action Plan and Vulnerable Children Act (2014)

United States of America

  • Child Abuse Prevention and Treatment Act (2011)

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, United Kingdom).

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, United Kingdom)

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.

THE AMBASSADOR PLATFORM 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.

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 circumstances 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.

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.

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.

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 and messages.
  • Constantly posting derogatory or defamatory statements or images.
  • Tracking using spyware.
  • Sending viruses.
  • Sexting.
  • Revenge porn.
  • Online grooming (See CSE).

Profile Owners and staff of the end customer

A ‘Profile Owner’ is defined as anyone who the End Customer chooses to represent them on their TAP Feed. Responsibility for the safer recruitment of Profile Owners on The Ambassador Platform (usually university student ambassadors holding profiles on the platform) and staff of the end customer (usually university student recruitment, marketing, widening participation, or academic professional) remains with the end customer. The Ambassador Platform strongly advocates safer recruitment practices as best practice to its end customers, but takes no responsibility for their implementation, monitoring, or review.

3. Staff Safeguarding training

All Customer Success staff working for The Ambassador Platform will undertake an annual, mandatory Safeguarding refresher. All new members of staff will be briefed on the company’s approach to safeguarding as part of their staff induction. Safeguarding refreshers and 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, and refresher courses, as appropriate.

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

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

Allegations/concerns against The Ambassador Platform staff

Any allegations/concern against 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 The Ambassador Platform, 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 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. The report will 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. Should an allegation be made against the CEO the DSP will follow the procedure outlined above, but the responsibilities of the CEO will be transferred to the company Chairman.

Allegations/concerns relating to staff who are not from The Ambassador Platform

Should The Ambassador Platform 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:

6. 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
7. Request the person raising the concern provide a written account of the concern, if possible within 24 hours.
8. Notify the CEO that a concern has been received, and is being investigated.
9. 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. 

2. Steps to be taken in response to safeguarding/welfare concerns raised regarding young people or vulnerable adults

The Ambassador Platform staff do not actively monitor interactions or content (images and FAQ answers) generated on our platform. Therefore, all responsibility for oversight, review, and monitoring of interactions and content generated lies, solely, with the End Customer.

However, on an incidental basis, following best practice, The Ambassador Platform staff may become aware of a potential safeguarding concern as part of their day-to-day work. Should a potential concern regarding a young person’s welfare come to the attention of any The Ambassador Platform 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 The Ambassador Platform DSP and then deleted by the original staff member. If the staff member becomes aware of a concern but is not in direct contact with the young person then full details (such as screenshots, hyperlinks, and a written overview) should be immediately forwarded to the The Ambassador Platform’s DSP.
  2. The concern should be immediately reported to the DSP. Responsibility at this point passes from the original staff member to the The Ambassador Platform’s DSP.
  3. The Ambassador Platform’s DSP 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 The Ambassador Platform’s practice would ordinarily be to pass safeguarding concerns relating to young people’s welfare to the End User DSP, The Ambassador Platform 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 The Ambassador Platform, the welfare/safeguarding information will then be passed to the End User DSP the same day by the The Ambassador Platform’s 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 The Ambassador Platform’s 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 The Ambassador Platform’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.

3. Demarcation of responsibility between The Ambassador Platform’s DSP and End Customer DSP

The Ambassador Platform takes no responsibility for the training, quality assurance, or professional actions of the End Customer DSP. The Ambassador Platform, and the The Ambassador Platform’s DSP, also take no responsibility for the investigation, recording, taking of further action, or resolution of safeguarding incidents. The role of the The Ambassador Platform’s DSP is limited to: 1. Maintaining The Ambassador Platform’s Safeguarding Policy and associated practices; 2. ensuring that The Ambassador Platform’s technology operates effectively and in accordance with the particulars of this policy; 3. liaising with the End Customer DP in the event of further necessary action arising from a safeguarding incident.

In the event that a safeguarding incident is reported to the End Customer, or End Customer DSP, or the End Customer, or End Customer DSP, becomes aware of a safeguarding incident via automated platform notifications then the responsibility is incumbent on them, solely, to deal with the incident and, if appropriate, to communicate relevant details to The Ambassador Platform’s DSP.


Processes

Safeguarding risk mitigation measures built into the platform

The Ambassador Platform is architected around a number of ‘preventative’ and ‘reactive’ 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. The preventative measures relate to anonymity, information sharing, and manual approvals of Content and FAQ posts, and the reactive measures to automatic keyword detection within chat conversations.

Preventative Measures

8.1 Anonymity and name display on the platform

Only first names of Users and Profile Owners to either party. This greatly limits the possibility of Users and Profile Owners engaging in off-site interactions, particularly interactions through social media channels and messaging applications.

8.2 Managing Information Sharing

The Ambassador Platform manages all communication between Users and Profile Owners. No contact information about individual Users is shared with Profile Owners.

8.3 Manual approval of content and FAQ posts

All Content (images and videos) and FAQ posts created by Profile Owners on The Ambassador Platform is immediately visible to the End User Admin within the Admin Dashboard. No Content or FAQ posts are made available to users of the TAP Feed without first being approved and published by the End User Admin.

All Content can be reviewed, prior to publishing to the TAP Feed or Social Media platforms, by the End User Admin within individual ‘Content Groups’ as well as within the Content ‘Gallery’.

Fig 1. A view of the Content Gallery

All FAQs can be reviewed, prior to publishing to the TAP Feed, by the End User Admin within the ‘Library’ tab of the FAQ area.

Fig 2. A view of the Content Gallery

Reactive measures

All reactive Safeguarding measures can be controlled by the End User Admin in the Safeguarding Tab of the Admin Dashboard.

8.4 Automatic keyword detection and blocking

For Profile Owners and prospective students, detected keywords (detailed in Appendix B) will, by default, be blocked out with *** until approved by the End User Admin:

Fig 3. A example conversation with blocked keywords indicated by the presence of *** within a chat bubble.

The End User Admin will then receive an email notification when a keyword is flagged:

Fig 4. An example ‘Keyword Detected’ End User Admin email notification

When reviewed, the conversation will still show the keywords in context, however, these remain blocked for both Profile Owners and prospective students. End User Admins have the ability to reveal the keywords, if they are happy with the content and context.

Keyword blocking can be disabled. This allows all keywords to be sent between ambassadors and students. End User Admins will still receive an email notification that a keyword has been detected in a conversation, even if this feature is disabled.

Keywords can also be added and removed from our default list.

Finally, you can whitelabel phone numbers and email addresses that you’d like to pass through without triggering as a key word.

Fig 5. An screenshot of the Safeguarding Tab within the Admin Dashboard

9. Extended services and practices

The Ambassador Platform 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 DP is responsible for ensuring that The Ambassador Platform’s 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

Appendix B: How to Manage Safeguarding on The Ambassador Platform

The Ambassador Platform believes that when online interactions are well-designed and efficiently managed, they are far safer than real world interactions that might occur at Open Days, for example. The below explains the key processes that The Ambassador Platform has in place to protect users of its service and what your responsibilities are as an Admin.

The Ambassador Platform operates a shared responsibility model for Safeguarding.It is our Customers' responsibility to make themselves aware of our Safeguarding processes and use them to manage the platform and interactions that happen through it in a way that they deem appropriate.

What processes do The Ambassador Platform follow?

1. Know who your representatives are.

The Ambassador Platform gives each Customer a unique code that Ambassadors must have in order to create an account. After they have created an account, every Ambassador is 'deactivated' by default. Admins must review and approve profiles before they can be active on the service. Admins should share the code confidentially with Ambassadors and only 'activate' profiles of known Ambassadors.

2. Keep engagements within the platform where they are safe.

The Ambassador Platform only displays the first names of all users on the platform so it is harder for interactions to move onto social media where they are not visible to Admins.

3. Contact information is never shared by The Ambassador Platform.

Whilst we collect contact information, all engagements happen through the platform, so we never share a user's contact information with the other participants of any interactions.

4. Provide training and messaging around not sharing personal or contact information.

As far as is reasonably possible, we try to remind and encourage users of the service that it is against our terms and conditions to share contact information through our service. Examples of where we do this include having a 'Resources' section in the app with a Safeguarding 101 video, which talks about this any many other elements of Safeguarding on The Ambassador Platform.

5. Direct Messages are saved and accessible to all Admins User.

For future reviews, direct message conversations will be available for the period set in the ‘Auto-Deletion’ section in Settings.

6. Keyword detection on all conversations.

To save the Admin time and make the platform safer, we run keyword detection software across all of our conversations. We look for words that indicate participants are trying to communicate off-platform or meet up and words that indicate a danger. A full list of our keywords are included in our Safeguarding Policy. You can read more about how our keyword detection process works in this article.

7. Human reporting of conversations Any participant of a conversation can 'flag' a conversation which sends an alert to our Admins to review the conversation.

What processes do Customers need to follow?

7. Ensure all of your Ambassadors are appropriately trained. Ensuring your Ambassadors are appropriately trained is the single most important way to be safe on The Ambassador Platform. We have a Safeguarding 101 video in the resources section of our App to help with this, but additional training is advisable. Only 'activate' Ambassadors who you feel would represent your institution appropriately and effectively to your target audience.

8. Ensure Keyword lists are optimised and inline with any wider policies you may have in place.

9. Ensure Keyword and Flagged Conversation notifications are checked. Please note that keyword detection has limits and we cannot guarantee that all 'at risk' conversations will be flagged.

10. Identify a Designated Safeguarding Point of Contact for the Platform.