Our Safeguarding Policy
Things to know
Keeping everyone in our community safe is a top priority at Zero Gravity. We have a Safeguarding Policy that sets out the specific steps we take to do that.
You can take a read of the policy below. It's meaty, but important.
1. Introduction
Zero Gravity takes its responsibilities and duty of care seriously to safeguard and promote the welfare of Young People and Adults At Risk. The welfare and protection of those we support and those involved in our activities is 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 of our activities.
For the purposes of this Policy, the term “Zero Gravity” refers to both Zero Gravity Tech Ltd (company number: 12091675), and 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.
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.
”Position of Trust” will be used to describe:
Certain roles where an adult is regularly involved in caring for, training, supervising or being in sole charge of Young People, and the Young People in their care have some dependency on them and there is an element of vulnerability involved.
“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 Tech Ltd’s Board of Directors.
“Zero Gravity Staff” will be used to describe:
Employees of Zero Gravity.
Those people contracted as consultants by Zero Gravity who partake in Regulated Activity.
“Zero Gravity Safeguarding Team” will be used to describe:
Zero Gravity Staff who are responsible for the management and oversight of this policy.
“Zero Gravity Members” will be used to describe:
Any persons that are signed up to the Zero Gravity platform and have had their membership approved.
“Zero Gravity Partners” will be used as a collective term to describe:
Organisations that have formally partnered with Zero Gravity, including Schools, Universities and Employers.
“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 an undergraduate or postgraduate course.
“Professional” will be used to describe:
Zero Gravity Members that are currently employed in a full-time job role.
“School Partner” will be used to describe:
Schools and colleges who are formally partnered with Zero Gravity and engage with the Zero Gravity Platform.
“University Partner” will be used to describe:
Universities who are formally partnered with Zero Gravity and engage with the Zero Gravity Platform.
“Employer Partner” will be used to describe:
Corporates who are formally partnered with Zero Gravity and engage with the Zero Gravity Platform.
“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 Professional 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.
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, as 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.
No University Students, Professionals, or Zero Gravity Staff will be Young People.
“Adult(s) At Risk” will be used to describe:
- The Care Act 2014 defines an Adult At Risk as someone aged 18 or over who:
has care and support needs
is experiencing, or is at risk of, abuse or neglect
as a result of their care and support needs is unable to protect himself or herself against the abuse or neglect or the risk of it
Our safeguarding commitment also extends to supporting and protecting these individuals from harm and/or abuse.
Some School Students, University Students and Professionals will be Adults at Risk.
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: encouraging Young People and Adults At Risk to make their own decisions with 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.
Accountability: implementing policies and procedures that create clear accountability for safeguarding.
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.
As per the Equalities Act 2010, all Young People and Adults At Risk have equal rights to protection, regardless of ability, sex, age, gender assignment, marriage status, pregnancy and maternity status, sexuality, religion or belief, and race (including colour, nationality, and ethnicity). Through our commitment to embedding safeguarding into our culture, we endeavour to promote an environment and services within which everyone engaged in our activities feels respected and valued.
We will seek to ensure that Zero Gravity Staff are alert to factors which potentially increase vulnerability and risk of harm and/or abuse, including indicators of concern. We are also committed to ensuring that all Zero Gravity Staff 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 comply with this Policy at all times.
This policy applies to all persons who are carrying out paid or unpaid/voluntary work on behalf of Zero Gravity.
Zero Gravity cannot guarantee that it will follow the safeguarding policies of organisations that it is not formally partnered with. However, School Students, University Students and Professionals themselves will likely be covered by the safeguarding policies of their relevant education provider or employer. Both policies will likely apply to the Zero Gravity Member, and Zero Gravity will always seek to work in partnership with the relevant organisation’s Designated Safeguarding Lead to ensure all Safeguarding Concerns are taken seriously, responded to appropriately and without delay.
Where a Safeguarding Concern does not relate to a Zero Gravity activity, Zero Gravity’s Safeguarding Team will seek assurances that the relevant educational or employer organisation is following the specific policy or process which applies to that setting to escalate the matter.
Zero Gravity will seek to follow the safeguarding policies of Zero Gravity Partners if:
The Zero Gravity Partner understands that Zero Gravity will also escalate any disclosures made to Zero Gravity under its own Safeguarding Policy.
- The Zero Gravity Partner’s safeguarding policy has been reviewed by Zero Gravity’s Safeguarding Team and includes:
Acceptable statements on safe recruitment for employees and volunteers.
A clear process for vetting employees and volunteers that are deployed in Regulated Activities.
A clear procedure for dealing with disclosures and allegations, including guidance on how to respond to a Young Person or Adult At Risk who is making a disclosure, a clear escalation pathway and relevant contact details (Designated Safeguarding Leads and local statutory agencies).
Provisions for regular review of the policy.
Board level oversight and ownership of the policy.
Clear guidance on acceptable behaviour when interacting with Young People and Adults At Risk.
5. Positions of Trust
The abuse of power is a central concern in safeguarding. Our work aims to address inequalities in opportunity by empowering Zero Gravity Members, some of whom will be Young People and Adults At Risk. This requires those who work with us and for us to be conscious at all times of the potential power imbalances which necessarily exist within our context. Ensuring that individuals are protected and supported effectively if they are vulnerable or at risk is 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. This scope therefore includes Zero Gravity Staff, University Students, and Professionals who are offering 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, will be investigated thoroughly and statutory agency advice may 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
Sexual Offences Act 2003
Criminal Justice Bill 2023
The Prevent Duty (Home Office 2015 – updated April 2022)
Working Together to Safeguard Children 2023 (DfE)
Keeping Children Safe in Education 2023 (DfE)
Care and Support Statutory Guidance (updated October 2023)
Clarity about designated roles and responsibilities, and clear lines of accountability within Zero Gravity.
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 Professionals of safeguarding issues.
Procedures for identifying, responding to and reporting safeguarding concerns or suspected cases of abuse are understood and implemented by all Zero Gravity Staff, Zero Gravity Members and Zero Gravity Partners.
7. Registration of School Students, University Students, and Professionals.
The Platform has been designed such that:
Only users who currently study at a UK-registered school, university, or employer can sign up and register on the Platform. University Student and Professionals 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 and Professionals must complete an onboarding process on the Platform, which includes compulsory video resources 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 and Professionals.
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 Zero Gravity Safeguarding Team where 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.
Zero Gravity Partners whose University Students and Professionals are deployed to support the work of Zero Gravity, are required to demonstrate that appropriate safeguarding checks are undertaken to assess the individuals’ suitability and appropriateness to work with vulnerable groups.
All user interactions with Zero Gravity Platform Features are trackable and accessible to review by Zero Gravity Staff in line with this policy.
Any School Student, University Student or Professional 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 Zero Gravity Safeguarding Team 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).
8. Platform communication and privacy
The interactions and behaviours of School Students, University Students and Professionals 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 Zero Gravity Staff.
The delivery of Zero Gravity services does not require or support physical meetings nor any communication between School Student and University Student or Professionals outside of the Platform.
The content of all communication between Professionals, 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 all Zero Gravity Members will remain private and confidential and will not be available to each other on the Platform.
Personal identities of University Students, Professionals and School Students are semi-anonymised on the Zero Gravity platform, with no identifiable details or data shared, preventing contact occurring outside the platform.
Mentoring session video recordings and message interactions between Professionals, University Students, and School Students on the Platform are available to Zero Gravity Staff.
Zero Gravity’s AI Coach has been trained to detect negative sentiment, self harm or wellbeing concerns in members’ interactions with the Platform, triggering auto alerts to the Safeguarding Team.
9. Recording and storage of platform communications
The Platform has been designed such that:
All messages are stored indefinitely.
- 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, Zero Gravity Safeguarding Team 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.
Be provided to the relevant authorities if legally obligated to do so.
10. Key Responsibilities - Zero Gravity Board
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.
Oversee the performance and conduct of the DSL (defined below), ensuring that they have access to appropriate resources, training and specialist safeguarding support.
Include Safeguarding as a standing agenda item for each Board meeting to ensure the Zero Gravity Board is appropriately informed, safeguarding is prioritised and learning from the management of concerns is embedded.
Review the DSL’s Safeguarding reports in advance of each Board meeting.
Ensure the Board Safeguarding Representative is notified of any Safeguarding Allegations within 24 hours of any initial notification to the DSL.
Provide ongoing guidance and support to the DSL in the management of any Safeguarding Allegations until the resolution of such issues.
The Board will also be alerted to both potential risks and any significant developments between annual formal reviews of the Policy.
Ensure that each member of the Zero Gravity Board holds an enhanced DBS certificate when their roles and responsibilities necessitate such clearance.
11. Key Responsibilities - Zero Gravity Staff
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.
Prior to joining Zero Gravity, be required to complete an Enhanced DBS check as part of a safer recruitment process that assesses their suitability and appropriateness for their role.
Complete a ‘Child Protection for Tutors’ training course accredited by NSPCC.
Never agree to meet with any Young person or Adult At Risk on a one-to-one basis in person.
Comply with the terms set out in Zero Gravity’s Privacy Policy.
12. Key Responsibilities - School Students
All School Students:
Must, on registration, confirm by ticking the appropriate electronic box that they have read, understood and will comply with 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.
Shall restrict their interactions with Zero Gravity University Students and Professionals 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.
13. Key Responsibilities - University Students
All University Students:
Have a duty to safeguard and promote the welfare of Young People and Adults At Risk.
Must, on registration, confirm by ticking the appropriate electronic box that they have read, understood and will comply with 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.
Must, on registration, confirm that they have never been the subject of any concerns which might indicate that they are unsuitable to work with vulnerable groups or barred from doing so.
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.
Must report any Safeguarding Concerns, no matter how severe, without delay via the ‘Report Concern’ feature on the Platform.
14. Key Responsibilities - Professionals
All Professionals:
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 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 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.
Report any Safeguarding concerns via the ‘Report Concern’ feature on the Platform.
15. 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 in doing so, submit the form to the DSL or Zero Gravity Safeguarding Team, who will raise a Safeguarding Record which will collate all information linked to any particular individual or case.
- The DSL or Zero Gravity Safeguarding Team will clarify concerns (in partnership with the Independent Safeguarding Advisor where appropriate) and assess appropriate responses, support needs and safeguarding risk, including:
Contacting 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.
Liaising with and referring to relevant agencies or services, including the Designated Safeguarding Lead of any relevant organisations, the Local Authority Designated Officer (LADO), Police and Social Services as appropriate.
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 or Zero Gravity Safeguarding Team using the contact details below.
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 complete the Incident Reporting Form without delay and in the process of doing so, submit the form to the DSL or Zero Gravity Safeguarding Team.
The Safeguarding Team will assess the risk (in partnership with Zero Gravity’s Independent Safeguarding Advisor as necessary). A member of the Safeguarding Team will contact the Young Person or Adult At Risk wherever appropriate or possible to clarify concerns and ensure that their voice and views are central to any safeguarding assessment and decision-making. The DSL will ensure that Zero Gravity liaises with and shares information appropriately with/refer to the 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 Zero Gravity Member account on the Platform. Safeguarding reports submitted from email addresses not associated with a user account on the Platform will be triaged by the Safeguarding Team. Information will be gathered and clarified in order to assess potential risks and to identify appropriate routes for referral to statutory agencies if sufficient information is shared. Wherever possible Zero Gravity will seek to verify membership details before taking action.
All safeguarding reports will be acknowledged within one working day by the DSL or Zero Gravity Safeguarding Team.
If any of the above activities relate to the DSL or Zero Gravity Safeguarding Team, the Incident Reporting Form should be sent to the Zero Gravity Board of Directors: board@zerogravity.co.uk
16. Zero Gravity Safeguarding Team Contact Details
Designated Safeguarding Lead
Name: Charlotte Rowell
Email: safeguarding@zerogravity.co.uk
Zero Gravity Safeguarding Team
Name: Alex O’Connor
Email: safeguarding@zerogravity.co.uk
Name: Elliot Little
Email: safeguarding@zerogravity.co.uk
Name: Lucy Davies-Kumadiro
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
17. External Contacts
Zero Gravity’s Safeguarding Team is committed to working in partnership with the Designated Safeguarding Leads of Zero Gravity Partners and other relevant organisations. We will liaise closely with statutory agencies (including the Designated Officers within Local Authorities, the Police and Adult and Children’s Social Care) where concerns meet appropriate thresholds or when advice and support is required.
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)
Where safeguarding concerns arise which relate to Zero Gravity Staff, Zero Gravity will seek the support and advice of the Designated Officer within the City of London’s Local Authority:
Multi-Agency Safeguarding Hub:
Tel: 07795 090649
Email: LADO@cityoflondon.gov.uk