Safeguarding & Child Protection Policy

1. Our commitment
2. Who this policy covers, and who is responsible
3. Legal framework
4. What safeguarding means in an online gaming club
5. How Arcadia is built to reduce risk
6. Recognising a concern
7. If a child tells you something
8. Reporting: what happens, and how fast
9. External contacts
10. Allegations about Eris, or about any adult
11. Low-level concerns
12. Nudes, semi-nudes and indecent images
13. Records and confidentiality
14. Vetting and safer recruitment
15. Adult code of behaviour
16. Photographs, screenshots and recordings
17. Training
18. Review

1. Our commitment

Arcadia is an afterschool gaming and coding club for under-18s, run online. Many of our members are SEND — autistic, ADHD, dyslexic, or with other additional needs. Some members are under 13.

The welfare of the child comes before everything else: before the club's reputation, before a parent's convenience, and before any adult's discomfort at raising something awkward. We accept that children with additional needs and communication differences are at higher risk of abuse and less likely to be believed when they report it. Arcadia is built and run on that assumption.

Specifically, we commit to:

• Treat every concern seriously, including vague ones, and never leave a child to raise it twice.
• Never dismiss a disclosure because of a child's communication style, behaviour, or history of being "difficult".
• Keep the club small, closed and known — invite-only membership, no public access, no strangers.
• Act on concerns the same day, and refer on where the threshold is met, even if the family objects.
• Keep clear, dated, factual records.

2. Who this policy covers, and who is responsible

This policy applies to every child who is a member of Arcadia, and to every adult with access to them through it — currently that is one adult.

3. Legal framework and the standards we follow

Arcadia is a private provider, not a school, so it is not directly bound by Keeping Children Safe in Education. We follow it as the standard anyway, because it is the standard the schools and families we work with expect. This policy has regard to:

• Children Act 1989 and 2004 — the welfare duty and the duty to co-operate.
• Working Together to Safeguard Children (2023) — how agencies share information and refer.
• Keeping Children Safe in Education (current edition) — followed as good practice.
• Equality Act 2010 — the anticipatory duty to make reasonable adjustments for disabled children. See Accessibility & Reasonable Adjustments.
• Sexual Offences Act 2003 — including section 15A, sexual communication with a child, and the position-of-trust provisions.
• Online Safety Act 2023 — Arcadia lets members see content posted by other members, so it is a user-to-user service with UK child users. We keep an illegal-content risk assessment and a children's access assessment as internal records.
• UK GDPR and Data Protection Act 2018 — including the ICO's Age Appropriate Design Code. See the Privacy Notice.

Nothing in data protection law prevents sharing information to safeguard a child. Where the two appear to conflict, safeguarding wins and we record why.

4. What safeguarding means in an online gaming club

The four statutory categories of abuse — physical, emotional, sexual, and neglect — all reach children online. On top of those, these are the risks that are specific to what Arcadia actually is:

• Grooming and sexual communication. An adult, or an older child, building trust with a member through chat, voice or in-game play, then moving the conversation somewhere private and unmonitored.
• Moving the child off-platform. The single most common escalation: "add me on Discord / Snap / Roblox". Anything that happens there is invisible to us, which is exactly why it is asked for.
• Nudes and semi-nudes being requested, shared or used to threaten a child (sextortion).
• Cyberbullying and exclusion — pile-ons in chat, deliberate freezing-out, mocking a child's voice, reading level or gameplay.
• In-game harm that is not "just a game" — griefing a build a child has worked on for months, stealing their items, killing them repeatedly. For an autistic child whose build is a special interest, this is not trivial and we do not treat it as trivial.
• Doxxing and personal information — a child revealing their school, address, surname or a photograph, either accidentally or under pressure.
• Radicalisation and harmful ideology reaching a child through gaming communities.
• Harmful content in third-party mods — Arcadia's Minecraft worlds run community-made mods. Every mod is checked before it goes on a world; the record is kept internally.
• Screen sharing exposing something the child did not intend to show — a private message, a family member, a document.
• Account takeover — a member's login used by somebody else, including an older sibling or a friend, so that the person in the club is not the child we think it is.

5. How Arcadia is built to reduce risk

These are not aspirations. They are how the server is configured today.

6. Recognising a concern

Online, you rarely see bruises. You see changes. Things that should prompt a second look:

• A member who was chatty going quiet, or leaving the club without explanation.
• Language, knowledge or sexualised talk that does not fit the child's age.
• Being secretive about who they are talking to, or closing a window when a tutor joins.
• Asking another member to move to a different app, or being asked to.
• Mentions of an adult "friend" from online that the parent does not seem to know about.
• Distress that is out of proportion to what happened in the game — often a sign that the game is not what it is really about.
• Anything a child says about home that worries you, even in passing, even as a joke.
• Signs of neglect visible on a call — being alone late at night, hunger, an unsafe environment.

A concern does not need to be about anything that happened at Arcadia. If a child discloses something about home or school, the duty is the same.

7. If a child tells you something

Do:

• Listen. Let them finish. Take it seriously the first time.
• Say you are glad they told you, and that you will have to tell someone whose job it is to help.
• Use their words. Write down what was said as close to verbatim as you can, and do it straight away.
• Allow for how the child communicates — typing instead of talking, longer pauses, an indirect route into the subject, or telling you inside a game.

Do not:

• Promise to keep it secret. You cannot, and saying so betrays them later.
• Investigate, cross-examine, or ask leading questions. Establishing what happened is not your job and doing it badly can wreck a later inquiry.
• Confront the person the child has named.
• Delete anything.
• Wait to see if it happens again.

8. Reporting: what happens, and how fast

Referrals are made with the family's knowledge and, where possible, their consent — unless telling them would put the child at greater risk, in which case we refer without telling them and record that decision and the reason for it.

Access to Arcadia can be suspended immediately as a protective measure while a concern is looked into. That is not a punishment and is not treated as one.

9. External contacts

Any child, parent or carer can use these directly. You do not need Arcadia's permission and you do not need to tell us first.

10. Allegations about Eris, or about any adult

Eris runs Arcadia alone. A policy that routes every concern through Eris would be worthless in the one case that matters most. So:

• If a concern is about Eris's conduct, it should go directly to the Safeguarding Sponsor, Piyush Gupta — pgupta@tutordoctor.co.uk — and/or to the LADO at the local authority, or to the police. Contacts are in section 9. Do not raise it with Eris first, and you are not expected to.
• The Sponsor is independent of Cognito Coding. He can refer to the LADO himself, and will tell you that he has.
• Eris will refer any allegation about themselves to the LADO within one working day and will co-operate fully with whatever follows, including standing the club down.
• Eris will not investigate an allegation about themselves, will not contact the child or family about it, and will not access the club's records relating to it.
• Any parent or carer may ask for evidence of Eris's DBS check and safeguarding training at any time.

The same route applies to any future volunteer, helper or guest tutor.

11. Low-level concerns

A low-level concern is behaviour by an adult that does not meet the threshold for a referral but does not sit right — over-familiarity, favouritism towards one member, contacting a child privately, blurring the line between tutor and friend.

These are recorded, dated and kept, because patterns only become visible when the small things are written down. Anyone — parent, carer, child or other professional — can raise one, and can do so anonymously. They can be sent to the DSL or, if the concern is about the DSL, to the LADO.

12. Nudes, semi-nudes and indecent images

• Do not ask the child to show you the image.
• Do not delete it either — leave the device or account alone and secure it.
• Report to the police (101, or 999 if the child is at risk) and to children's social care.
• Support the child to use Report Remove to get the image taken down.
• Record the fact of the report, not the content.

Children who have shared images are treated as children who need help, not as offenders.

13. Records and confidentiality

• Safeguarding records are written the same day, factual, dated, signed and in the child's own words where possible. Opinion is labelled as opinion.
• They are stored off the Arcadia server, encrypted, accessible only to the DSL. They are deliberately not held on the club's own systems.
• They are shared strictly on a need-to-know basis — with children's social care, the police, or a school's DSL — and each disclosure is logged.
• Safeguarding records are retained until the child's 25th birthday, then destroyed securely.
• If a member moves on and a school or new provider asks, we will pass on relevant safeguarding information.

Confidentiality is never promised to a child, and never used as a reason not to report.

14. Vetting and safer recruitment

Teaching and supervising children is regulated activity. Arcadia's position:

• Eris holds an enhanced DBS certificate with a children's barred list check. Certificate reference and issue date are held on the club's internal vetting record and can be shown to any parent, carer or school on request. [to confirm: certificate number and issue date, and whether it is on the DBS Update Service]
• No adult will have unsupervised access to Arcadia members until an enhanced DBS check with barred list, two references and identity verification are complete.
• A written record of those checks is kept for every adult with access — the club's equivalent of a single central record.
• Members' older siblings, parents and friends are not given accounts or access.

15. Adult code of behaviour

This is the Code Club mentor code of behaviour, adopted in full and written for how Arcadia actually runs — online, in text and voice, in Minecraft and in the labs. It binds Eris and every future volunteer, helper or guest tutor. Breaking it is a low-level concern at least (section 11), and may be a disciplinary or safeguarding matter.

Do:

• Provide a safe, secure environment, and treat every child equally and with respect whatever their gender, age, religion, ethnicity, creed or additional needs.
• Keep at least one adult per ten children in any session.
• Keep contact in the club's own channels, where it is logged: Arcadia Chat, the labs and the worlds.
• Copy a parent or carer in on every email to a member under 18.
• Offer constructive, age-appropriate encouragement, praise and critique, and involve members in decisions about their own work.
• Use resources appropriate to the age and wishes of the group, and vet every mod, tool and world before children meet it.
• Encourage members to experiment, to get things wrong, and to learn from it.
• Know what to do if you witness or are told about anything that worries you — sections 6 to 8.

Do not:

• Spend time alone with an individual child. A one-to-one tutoring session is arranged with the parent's knowledge, in a club channel, and the parent may join it at any time without notice.
• Communicate one-to-one with a member outside the club's own channels — no private social media, no personal phone number, no personal email, no private DMs on another platform, no friending on a game service.
• Use offensive or sexually suggestive language, or let a member's use of it go unchallenged.
• Single out any child for favouritism, unfair criticism, ridicule, or unwelcome attention.
• Socialise with members outside structured club activities, or meet them in person alone.
• Photograph, screenshot or record a member or a session, except as section 16 allows.
• Promise a child that a disclosure will be kept secret.

16. Photographs, screenshots and recordings

• Sessions are not recorded. Voice is not recorded. Webcams are not used or required.
• Screenshots of a member's work — a Minecraft build, a Scratch game, a Python drawing — are only used publicly with written parental consent, given on the consent form and withdrawable at any time.
• Where a child's work is shown, it is credited by first name only, or by nothing at all if the parent prefers.
• No photograph of a child's face is ever published.
• Members are asked not to screenshot or record each other, and not to post anything from Arcadia elsewhere.

17. Training

• Eris completes recognised child protection training and refreshes it at least every two years, plus annual reading of updated guidance. [to confirm: training provider, level and date completed]
• Training includes online safety, harmful sexual behaviour, and safeguarding children with SEND.
• Certificates are kept on the internal vetting and training record, and are shown to the Safeguarding Sponsor at each annual review.

18. Review

This policy is reviewed annually by the DSL with the Safeguarding Sponsor, and immediately after any safeguarding incident, any change in the law, or any significant change to what Arcadia offers — including new features, new tools, or a change in the age range of members. The Sponsor also sees the concern log and the low-level concern record at each review, so that a pattern cannot sit unnoticed in a one-adult club.

Related documents: Online Safety & Acceptable Use · Behaviour, Bullying & Sanctions · Privacy Notice · Accessibility & Reasonable Adjustments · Complaints