Version: [0.1 draft] · Effective date: [to be set] · Next review: [within 12 months of adoption]
This is a working draft prepared as a starting point. It must be reviewed and adapted by someone with safeguarding and legal expertise, and checked against the law of the countries where the platform has a significant audience, before it is adopted or published. All items in square brackets need to be completed first. It does not constitute legal advice.
This policy sets out our commitment to keeping children and adults at risk safe across everything we do, including the website, the newsletter, our social media channels, and the AI companion Sammy. It explains how concerns are recognised, how they are responded to, and who is responsible for acting on them.
We take safeguarding seriously because the work of this platform brings us into contact with people who may be vulnerable, including young people exploring their identity and people in distress. We want everyone who reaches us to be met with care, and to be guided quickly to the right help, wherever in the world they are.
This policy applies to everyone who works on or contributes to the platform, including the founder, employees, contractors, and anyone acting on its behalf. It also governs the design and operation of the automated services, in particular the AI companion Sammy.
Our audience is international. People reach us from many countries, and the right route to help, and the relevant law, depend on where each person is. This policy is written to work globally rather than for any single country.
It is important to be clear about what this platform is and is not.
Safeguarding means protecting people from abuse, harm, and neglect, and acting to promote their welfare.
A child is anyone under the age of 18.
An adult at risk is an adult who may be unable to protect themselves from harm or abuse, for example because of illness, disability, or circumstances.
Abuse can take many forms, including physical, sexual, emotional or psychological abuse, neglect, financial abuse, and online or digital abuse such as grooming, exploitation, or exposure to harmful content.
A disclosure is when someone tells us, directly or indirectly, that they or another person are being harmed or are at risk.
The DSL holds lead responsibility for safeguarding on the platform. The role is held within Helen's team. We do not publish individual names or contact details here.
Any concern spotted by Sammy, or reported to Sammy, is delivered to Helen's team through the platform's notification process and picked up by the DSL. Concerns reaching us by any other route, such as email, comments, or social media, are passed to the DSL in the same way.
The DSL is responsible for receiving safeguarding concerns, deciding what action to take, making referrals to external agencies where needed, keeping secure records, and making sure this policy is followed, understood, and reviewed.
In the DSL's absence, concerns are picked up by another senior member of the team.
Everyone who works on or contributes to the platform is expected to read this policy, to recognise when something may be a safeguarding concern, and to pass it to the DSL without delay. No one should attempt to investigate a concern themselves or promise to keep a disclosure secret.
Concerns may reach us in many ways: through a conversation with Sammy, by email, through comments or messages, or through our social media channels. A concern might be an explicit disclosure, or a quieter sign, such as a young person describing an unsafe home, secrecy being imposed on them, fear of an adult, sexualised contact, or thoughts of self-harm.
We do not need to be certain that abuse is happening before we act. A reasonable concern is enough to pass to the DSL.
Sammy is configured to follow a child safety and safeguarding protocol that sits above all of their other instructions and applies in every country. In summary, Sammy is designed to:
Sammy's limits are real and must be understood. They are automated, they cannot guarantee that they will recognise every concern, they cannot verify what they are told, and they cannot take real-world action or contact anyone on a user's behalf. They are not monitored in real time, so they are not a route to emergency help. Anyone in danger must contact their local emergency services. The protocol Sammy follows is maintained as part of their configuration and is reviewed alongside this policy.
Direct them to their local emergency number without delay. Across the European Union this is 112. In the United Kingdom it is 999, in the United States and Canada 911, and in Australia 000. If the country is not known, the instruction is simply to call the local emergency number. Then inform the DSL.
If someone discloses harm to you, the following principles apply.
Safeguarding records are factual, written promptly, stored securely, and kept confidential. They are handled in line with applicable data protection law, including the EU and UK General Data Protection Regulation and equivalent law in other relevant countries.
Information is shared only with those who need it in order to protect the person concerned. Confidentiality cannot be absolute where there is a risk of harm, and the duty to protect someone takes precedence over a wish to keep a matter private.
On receiving a concern, the DSL assesses the level of risk and decides what action is needed. Where a referral is appropriate, the DSL notifies the relevant child protection or safeguarding authority for the area where the person lives, and records the decision and the reasons for it.
This policy does not name particular agencies. The right authority depends on the person's country, and naming a single country's services would be wrong for most of the people we reach. The DSL identifies the appropriate authority for the person's location and refers to it.
We are honest about the limits of this. We operate online and across borders, and we cannot always make a direct referral into another country's child protection system, nor can we act in real time. For that reason we always direct a person at risk first to the services that can respond fastest where they are, namely their local emergency number and their national child helpline. Our own escalation supports that. It does not replace it.
Because we operate online, we cannot reliably verify a person's age, identity, or location. We therefore treat every interaction as though the person could be vulnerable, and we apply the same calm, careful response whether or not we suspect a conversation may be a test or made in bad faith. A suspected test is never treated as a reason to dismiss a concern.
We do not tolerate any sexual content involving a child. If we encounter material or behaviour that indicates a child is being abused or is at risk, we do not engage with it further, we preserve any relevant record, and we report it to the appropriate authorities for the relevant country.
The same principles apply to adults at risk. Where we are concerned that an adult may be unable to protect themselves from harm, we respond with care, avoid investigating, signpost to appropriate local support, and pass the concern to the DSL, who decides whether a referral is needed and to which authority.
Any allegation that someone working on or connected to the platform has harmed a child or adult at risk is taken seriously and reported to the DSL at once. If the allegation concerns the DSL, it is reported to another senior member of the team. The matter is referred to the appropriate authority in the relevant country.
Everyone working on the platform is given a copy of this policy and is expected to understand it. The DSL undertakes appropriate safeguarding training and keeps it up to date. Safeguarding is included in the induction of anyone new who joins the work of the platform.
This policy is reviewed at least once a year, and sooner if there is a safeguarding incident, a change in the law, or a significant change to how the platform or Sammy operates. Each version is dated and recorded.
Safeguarding concerns raised on the platform, including anything Sammy spots or is told, are delivered to Helen's team through the platform's notification process and handled by the Designated Safeguarding Lead.
If you or a child is in immediate danger, call your local emergency number now. Across the European Union, 112 reaches emergency services and 116 111 reaches a child helpline in most countries. If you do not see your country below, call your local emergency number, contact a trusted adult, or search for your national child helpline.
| Region | Emergency | Child or safeguarding helpline |
|---|---|---|
| European Union | 112 | Child helpline 116 111. Missing children 116 000. Both available in most EU countries. |
| France | 112 (police 17, fire 18, medical 15) | 119, children in danger, free, 24/7 |
| Spain | 112 | Fundación ANAR on 116 111 or 900 20 20 10, free, 24/7 |
| United Kingdom | 999 (101 non-emergency) | Childline 0800 1111. NSPCC, for adults worried about a child, 0808 800 5000 |
| United States | 911 | Childhelp National Child Abuse Hotline 1-800-422-4453 |
| Canada | 911 | Kids Help Phone 1-800-668-6868 |
| Australia | 000 | Kids Helpline 1800 55 1800 |
Add the equivalent contacts for any other countries with a significant audience, and confirm all numbers are current at each review. Numbers above were checked in June 2026.