Safeguarding Policy
1. Introduction
Zero Gravity Tech Ltd, company number 12091675 (“Zero Gravity”), takes its responsibilities and duty of care seriously to safeguard and promote the welfare of Young People and Adults At Risk. The support and protection of those we support and those involved in our activities are paramount in all we do. This Safeguarding Policy (the “Policy”) sets out that commitment.
We have embedded safeguarding features into app.zerogravity.co.uk (the ”Platform”) to ensure that safeguarding underpins all our activities.
For the purposes of this Policy, the term “Zero Gravity” refers to both Zero Gravity Tech Ltd and the Zero Gravity Fund, charity number 1188177.
This Policy should be read in conjunction with the Terms & Conditions, the Privacy Policy and the Cookie Notice.
We will review this policy annually and in line with any significant changes in legislation, statutory guidance, or learning from both external case reviews and internal management of concerns. We will post any changes on the Platform.
This Policy was last updated on 18th April 2023.
2. Definitions
For the purposes of this Policy, the following definitions will apply:
“Regulated Activity” will be used to describe:
Certain roles that involve working with Young People or Adults At Risk, such as teaching and providing care, which the Disclosure and Barring Service can bar people from doing.
“Zero Gravity Platform Features” will be used to describe:
Any features that are accessible to users within the Zero Gravity Platform.
“Zero Gravity Board” will be used to describe:
Zero Gravity board members.
“Zero Gravity Staff” will be used to describe:
Employees of Zero Gravity; and
Those people contracted as consultants by Zero Gravity who partake in Regulated Activity.
“School Student” will be used to describe:
Zero Gravity members that are currently enrolled in a secondary school, sixth form, or further education college.
“University Student” will be used to describe:
Zero Gravity members that are currently enrolled in a university institution on a undergraduate or postgraduate course.
“Partner Employees” will be used to describe:
Zero Gravity members that are employed by Zero Gravity’s employer partners.
“Safeguarding Query” will be used to describe:
A question that relates to safeguarding but is not an allegation or concern.
“Safeguarding Concern” will be used to describe:
Any concern that a Young Person or Adult At Risk may be vulnerable or at risk of harm, neglect or abuse.
“Safeguarding Allegation” will be used to describe:
- When a member of Zero Gravity Staff, University Student or Employer Member is alleged to have:
Behaved in a manner that has caused distress, negatively impacted or harmed a Young Person or Adult At Risk;
Possibly committed a criminal offence against or related to a Young Person or Adult At Risk; or
Behaved in a way (in any context) that indicates that they have poor intent or could present a risk of harm to Young People or Adults At Risk.
“Young Person/People” will be used to describe:
A person under the age of 18;
The Children Act 1989 defines a child as “anyone who has not yet reached their eighteenth birthday”;
However, for the purposes of this policy, we will use the term ‘Young People’ for those under 18 years of age as it resonates more comfortably with the way we seek to work in partnership with and to empower those Young People who Zero Gravity seeks to support;
Most, but not all, School Students will be Young People.
“Adult(s) At Risk” will be used to describe:
A person aged 18 or over 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;
Our safeguarding commitment also extends to supporting and protecting these individuals from harm and/or abuse.
3. Principles
The welfare and protection of Young People and Adults At Risk will always be our paramount consideration. Zero Gravity’s approach to safeguarding is underpinned by the following principles, which reflect those set out in statutory guidance:
Empowerment: Young People and Adults At Risk being supported and encouraged to make their own decisions and informed consent.
Prevention: it is better to take action before harm occurs.
Proportionality: the least intrusive response appropriate to the risk presented.
Protection: support and representation for those in greatest need.
Partnership: working in collaboration with Young People and Adults At Risk to ensure that their views and needs are central to assessing concerns and safeguarding risk. This will include clarifying sources of potential support and what they think might help.
Accountability: accountability and transparency in implementing our safeguarding policy and procedures.
4. Scope
This Policy aims to ensure that all persons, in particular Young People and Adults At Risk, working with Zero Gravity and using our services can do so safely, free from abuse and discrimination on any grounds.
All Young People and Adults At Risk have equal rights to protection, regardless of ability or age, gender reassignment, being married or in a civil partnership, being pregnant or on maternity leave, disability, race including colour, nationality, ethnic or national origin, religion or belief or, sex. Through our commitment to embedding safeguarding into our culture, we endeavour to promote an environment and services within which everyone engaged in our activities and programmes feels respected and valued.
We will seek to ensure that Zero Gravity Staff are alert to factors which potentially increase vulnerability and risk and to indicators of concern, harm and/or abuse. We are also committed to ensuring that all Zero Gravity Staff will have the confidence to implement this policy and procedures to ensure that welfare and safeguarding concerns are responded to positively, consistently and appropriately (including reporting and recording concerns without delay).
All Zero Gravity Staff will be required to confirm that they have read, understood and will abide by this Policy at all times.
5. Positions of Trust
The abuse of power is a central concern in safeguarding. Our work aims to address inequalities in opportunity to empower Young People and create a fairer society. Ensuring that individuals are protected and supported effectively if they are vulnerable or at risk is therefore critically important in the context of Zero Gravity’s work.
The Sexual Offences Act (2003) established legislation relating to those in Positions of Trust, including teachers and other adults who are ‘regularly involved in caring for, training, supervising or being in sole charge of’ Young People, whether voluntary or paid. This legislation is designed to protect 16 and 17-year-olds who are over the age of consent for sexual activity but are considered to be vulnerable to sexual abuse and exploitation in circumstances where an adult is in a position of trust. This also extends to evidence of grooming and/or developing inappropriate relationships with any participant under 18 with intent to pursue a future sexual relationship.
An adult is considered to be in a position of trust where a Young Person in their care has some dependency on them and there is an element of vulnerability involved, which would include Zero Gravity Staff, and University Students and Partner Employees who are offering mentoring support to School Students through the Platform. In accordance with the expectations set out within this policy and our Terms and Conditions, any breach of trust or concerns relating to the sharing of personal contact details, personal identifying information or contact with a School Student outside of the platform will be taken very seriously and statutory agency advice will be sought through the Local Authority Designated Officer and/or the Police and Children’s Social Care.
6. Purpose
The purpose of this Policy is to ensure:
- Compliance with UK legislation and statutory guidance, including but not limited to:
Children Act 1989
Children Act 2004
Care Act 2014
The Prevent Duty (Home Office 2015 – updated April 2022)
Working Together to Safeguard Children (Home Office 2015 - updated July 2022)
Keeping Children Safe in Education (DfE Sept 2022)
Care and Support Statutory Guidance (updated June 2022)
The protection and welfare of Young People and Adults At Risk using the Platform;
Accessible support and protection for Young People and Adults At Risk who reach out to Zero Gravity in relation to safeguarding and welfare issues;
Awareness is raised among Zero Gravity Staff, University Students, and Partner Employees of safeguarding issues; and
Procedures for identifying, responding to and reporting safeguarding concerns or suspected cases of abuse are understood and implemented by Zero Gravity Staff, University Students and Partner Employees.
7. Registration of School Students, University Students, and Partner Employees.
The Platform has been designed such that:
Only users who currently study at a UK-registered school, university, or who are employed by a Zero Gravity employer partner can sign up and register on the Platform. University Student and Partner Employees email accounts are verified by their institution, and without this verification, they cannot register on the Platform;
Before being matched with a School Student for one-to-one mentoring, University Students must complete an onboarding process on the Platform, which includes training resources and video content on safeguarding responsibilities and reporting procedures;
There is a feedback system that encourages School Students to provide regular feedback about the quality of their mentoring relationships with University Students;
Sensitive and confidential information relating to School Students is held and stored securely by Zero Gravity with restricted access. This enables an informed and prompt safeguarding response by the Designated Safeguarding Lead or Deputy Designated Safeguarding Lead in case safeguarding/welfare concerns arise. This includes the School Students’ name, date of birth, contact details, address, and educational establishment.
All Zero Gravity Staff undertaking Regulated Activity will be subject to enhanced level criminal record checks through the Disclosure and Barring Services as part of our commitment to ensuring that individuals are suitable and appropriate to undertake this work with Young People and Adults At Risk;
All user interactions with Zero Gravity Platform Features are trackable and accessible to review by the Zero Gravity team in line with this policy
8. Platform communication and privacy
The interactions and behaviours of School Students, University Students and Partner Employees are restricted and monitored through the Platform’s safeguarding functions. All concerns arising through any of the visible, accessible and actively promoted reporting mechanisms will be assessed and responded to promptly by our Designated Safeguarding Lead. This is why Zero Gravity is clear about maintaining all contact within the Platform, which has been built to reduce potential safeguarding risks for all stakeholders.
The Platform has been designed such that:
All interactions with Zero Gravity Platform Features are tracked and accessible to review by the Zero Gravity team.
The delivery of Zero Gravity services (including but not limited to mentoring services) does not require or support physical meetings nor any communication between School Student and University Student or Partner Employees outside of the Platform;
The content of all communication between Partner Employees, University Students and School Students is sent via the Platform;
Attempts to share contact details that would enable users to communicate outside of the Platform are automatically detected and blocked by the Platform.
The contact details of School Students will remain private and confidential and will not be available to University Students and Partner Employees;
The contact details of University Students and Partner Employees will remain private and confidential and will not be available to School Students;
Personal identities of University Students, Partner Employees and School Students are semi-anonymised on the Zero Gravity platform, with no identifiable details or data shared, preventing contact occurring outside the platform; and
Mentoring session video recordings and message interactions between Partner Employees, University Students, and School Students on the Platform are available to Zero Gravity Staff.
9. Recording and storage of platform communications
The Platform has been designed such that:
All messages are stored indefinitely; and
- Video recordings of all mentoring sessions are automatically recorded and stored securely online for safeguarding purposes only. These recordings are automatically stored for 30 days and may:
Be reviewed as part of an investigation into any safeguarding report made to the Designated Safeguarding Lead, Deputy Designated Safeguarding Lead or other Zero Gravity Staff by a person using Zero Gravity services;
Any available video recordings may be stored indefinitely whilst a safeguarding investigation is ongoing; and/or
Be provided to the relevant authorities if legally obligated to do so.
10. Key Responsibilities - Zero Gravity Board only
The Zero Gravity Board shall:
Ensure that this Policy and the safeguarding features on the Platform are reviewed on an annual basis and will, if required, approve and sign off any updates to both;
Appoint one member of the Zero Gravity Board as the Board Safeguarding Representative who shall be responsible for ensuring that the Zero Gravity Board complies with its key safeguarding responsibilities;
Appoint one Zero Gravity Staff member to be designated as the Designated Safeguarding Lead (“DSL”) who shall be responsible for coordinating Zero Gravity’s safeguarding provision, adherence to the policy, overseeing the management of concerns, including those arising through safer recruitment processes and DBS checks, reporting to relevant authorities, and maintaining records of all safeguarding reports and incidents.
Appoint one Zero Gravity Staff member to be designated as Deputy Designated Safeguarding Lead (“DDSL”) who shall assist in the management of all safeguarding queries and concerns, including the management of concerns in line with this policy, maintaining records of all safeguarding reports and incidents and reporting to the DSL.
Oversee the performance and conduct of the DSL (defined below), ensuring that they have access to appropriate resources, training and specialist safeguarding support.
Review the DSL’s annual review findings and recommendations in readiness for consideration at the Zero Gravity Board's first meeting each calendar year.
Include safeguarding as a standing agenda item for each Board meeting to ensure the Zero Gravity Board is appropriately informed and learning from the management of concerns and alerted to both potential risks and developments between annual formal reviews of the Policy;
Ensure that each member of the Zero Gravity Board holds an enhanced DBS certificate when his/her role(s) and responsibilities necessitate such clearance.
11. Key Responsibilities - Zero Gravity Staff only
Zero Gravity Staff shall:
Have a mandatory duty to safeguard and promote the welfare of Young People and Adults At Risk;
Sign a copy of this Policy confirming they have read, understood and will comply with it;
Hold a current enhanced DBS certificate;
Complete a ‘Child Protection for Tutors’ training course accredited by NSPCC;
Never agree to meet with any School Student on a one-to-one basis in person; and
Comply with the terms set out in the Privacy Policy.
12. Key Responsibilities - Zero Gravity School Students only
All Zero Gravity School Students:
Shall abide by Zero Gravity’s Membership Agreement at all times;
Shall restrict their interactions with Zero Gravity University Students and Partner Employees to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life; and
Shall restrict their interactions with Zero Gravity Platform Features to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life.
13. Key Responsibilities - Zero Gravity University Student and Partner Employees only
All Zero Gravity University Students:
Have a duty to safeguard and promote the welfare of Young People and Adults At Risk;
Shall abide by Zero Gravity’s Membership Agreement at all times;
Must, on registration, confirm by ticking the appropriate electronic box that they have read, understood and will comply with this Policy;
Must ensure all contact with School Students only occurs on the Platform;
Shall restrict their guidance to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life;
Shall not share any contact details or other information which may undermine the anonymity of the University Student to the School Student;
Shall not solicit any contact details or other information which may undermine the anonymity of the School Student to the University Student;
Should never agree to meet with a School Student in person prior to or during their engagement with Zero Gravity;
Shall ensure all video mentoring sessions on the Platform take place in an appropriate environment that does not display any inappropriate images or activity;
Shall not engage in, incite or condone inappropriate behaviour or illegal activity on the Platform or otherwise;
Shall ensure that all language used and comments made (verbally or in text format) when carrying out Zero Gravity mentoring duties is non-discriminatory, inclusive and respectful;
Shall not bring Zero Gravity into disrepute through their behaviours, attitudes or language;
Shall restrict their interactions with Zero Gravity Platform Features to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life;
Shall restrict their interactions with Zero Gravity Platform Features to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life; and
Report any Safeguarding Concerns via the ‘Report Concern’ option on the Platform.
All Zero Gravity Partner Employees:
Have a duty to safeguard and promote the welfare of Young People and Adults At Risk;
Shall abide by Zero Gravity’s Terms of Service at all times;
Must, on registration, confirm by ticking the appropriate electronic box that they have read, understood and will comply with this Policy;
Shall restrict their guidance to the following areas: maximising academic attainment, applying for apprenticeships, internships/graduate jobs, commercial awareness, career sector insights, and working life;
Shall ensure all video mentoring sessions on the Platform take place in an appropriate environment that does not display any inappropriate images or activity;
Shall not engage in, incite or condone inappropriate behaviour or illegal activity on the Platform or otherwise;
Shall ensure that all language used and comments made (verbally or in text format) when carrying out Zero Gravity mentoring duties is non-discriminatory, inclusive and respectful;
Shall not bring Zero Gravity into disrepute through their behaviours, attitudes or language;
Shall restrict their interactions with Zero Gravity Platform Features to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life;
Shall restrict their interactions with Zero Gravity Platform Features to the following areas: maximising academic attainment, applying to university, university life, applying for internships/graduate jobs, commercial awareness, career sector insights, and working life; and
Report any Safeguarding concerns via the ‘Report Concern’ option on the Platform.
Any School Student, University Student or Partner Employee who does not comply with the Terms & Conditions, which shall incorporate this Policy, will be suspended from using the Platform pending an investigation by the Designated Safeguarding Lead with support from the Deputy Designated Safeguarding Lead and Independent Safeguarding Advisor as appropriate. Zero Gravity is committed to working in partnership with statutory agencies where concerns arise that meet appropriate thresholds for referral (including the Police, Local Authority Adult and Children’s Services, Designated Safeguarding Leads in Education and the DBS).
14. Communication and Concern reporting
If an individual or organisation has a Safeguarding Query, then the DSL will ensure that:
If a Safeguarding Query has been submitted via email to safeguarding@zerogravity.co.uk, the Safeguarding Query will receive a complete response within five working days.
If a member of Zero Gravity Staff has a Safeguarding Concern, then they must ensure:
They inform the DSL using the contact details below;
They immediately complete the Incident Reporting Form and send it to the DSL who will raise a Safeguarding Record which will collate all information linked to any particular individual or case.
The DSL will clarify concerns (in partnership with the DDSL and/or Independent Safeguarding Advisor where appropriate) and assess appropriate responses, support needs and safeguarding risk;
Contact the individual who is the subject of the concern wherever appropriate or possible to ensure that their voice and views are central to any safeguarding assessment and decision-making;
Liaise with and refer to relevant agencies or services, including the Young Person’s school DSL, the Local Authority Designated Officer (LADO), Police and Social Services as appropriate;
The DSL will access all available mentoring session recordings and message interactions between the mentoring pair and these recordings and messages will be stored until the safeguarding investigation is complete; and
If the Young Person or Adult At Risk is felt to be in immediate danger or it is indicated that a crime may have been committed, they will dial 999.
If a Young Person or Adult At Risk discloses a Safeguarding Concern or Allegation to a member of Zero Gravity Staff, then the respective member of Zero Gravity Staff must ensure:
They inform the DSL using the contact details below or via the Report Concern button on the Platform;
They advise the Young Person or adult a risk that they will offer them support but that they will have to share the concerns and information with the DSL to seek advice and support;
They listen carefully to the Young Person or Adult At Risk without interrupting them and seek clarification with open and non-leading questions;
They reassure the Young Person or Adult At Risk that sharing their concern/allegation was the right thing to do;
They immediately complete the Incident Reporting Form and send it to the DSL.
The DSL will assess the risk and contact the Young Person or Adult At Risk wherever appropriate or possible to clarify concerns and ensure that their voices and views are central to any safeguarding assessment and decision-making. The DSL will liaise with and share information appropriately with/refer to relevant agencies or services, including the Local Authority Designated Officer (LADO), police and social services as appropriate. The DSL will also ensure that any support needs for the Young Person or Adult At Risk are considered and responded to without delay.
All Safeguarding Concerns and Allegations must be sent from an email address associated with a user account on the Platform. Safeguarding reports submitted from email addresses not associated with a user account on the Platform will only be acted upon once verifiable Zero Gravity membership details have been provided.
All safeguarding reports will be acknowledged within one working day by the DSL or DDSL.
If any of the above activities relate to the DSL or DDSL, the Incident Reporting Form should be sent to the Zero Gravity Board of Directors: board@zerogravity.co.uk
15. Internal Contact Details
Designated Safeguarding Lead
Name: Tom Haywood-Pope
Email: safeguarding@zerogravity.co.uk
Deputy Designated Safeguarding Lead
Name: Alex O’Connor
Email: safeguarding@zerogravity.co.uk
Board Safeguarding Representative
Name: Michael Lonergan
Email: board@zerogravity.co.uk
Independent Safeguarding Advisor
Name: Gill Camina
Email: gill.camina@universal-safeguarding-solutions.co.uk
16. External Contacts
In the event of Safeguarding Concerns arising, it is never an option to do nothing. If, for any reason, an individual feels unable to report concerns directly through the process identified above (e.g. to the DSL or Zero Gravity Staff), they are encouraged to contact the following external sources of support and advice:
NSPCC 24-hour Helpline
Tel: 0808 800 5000
Email: help@nspcc.org.uk
Ann Craft Trust: Safeguarding Adults advice helpline
Tel: 0115 951 5400
Email: ann-craft-trust@nottingham.ac.uk
Police
Tel: 101 (or 999 in an emergency)