Adult Confirmed Posing
as a Child — Procedure

Section 1When This Procedure Applies

This procedure applies when any person over the age of 18 attempts to create an account on VML Kids by fraudulent means — including but not limited to the substitution of a photograph in a genuine identity document, the presentation of a tampered document, or any biometric or facial recognition failure that indicates the person is not who they claim to be.

This procedure applies the moment such evidence is identified, regardless of how far the account creation process has progressed. Under no circumstances may an account identified as potentially fraudulent be allowed to become authorised and live.

Section 2Immediate Required Actions

The following steps must be taken immediately upon identification of a confirmed or suspected fraudulent account creation attempt. They must be taken in this order without delay:

• 1
  Freeze the account immediately. The account must be placed in the pending investigation queue and must not under any circumstances be allowed to progress, be activated or become live. No notification must be sent to the applicant at this stage.
• 2
  Notify the Duty Safeguarding Director. An email log of the attempt must be sent to the Duty Safeguarding Director immediately. The log must include the account reference, the nature of the fraudulent evidence identified, the timestamp of detection and the name of the staff member who identified it.
• 3
  Contact the Police. The Police must be contacted immediately. An adult posing as a child on a child safety platform is a serious matter that warrants immediate police notification. Provide the account details and the nature of the fraud detected.
• 4
  Preserve all evidence. All verification data, biometric results, document scans and system logs connected to the account must be preserved immediately in accordance with the evidence architecture set out in Section 3. No data may be deleted or modified.
• 5
  Generate an escalation package. A formal escalation package must be generated automatically and referred to the Independent Safeguarding Panel without delay. The panel has authority to refer directly to statutory authorities without requiring management approval.

Section 3Evidence Preservation

All evidence connected to the fraudulent account creation attempt must be preserved in the same three-layer architecture used for all critical alert evidence:

All verification data is captured and secured at the point of detection. A working copy is made available to the police and, where formally requested, to the Crown Prosecution Service or its equivalent, on receipt of a formal written request and with the written authority of the Safeguarding Director. The core evidential log is sealed and may not be accessed without a Court Order. Its integrity is essential to any subsequent prosecution.

Section 4Procedure Flowchart

Section 5Version Control

Other Critical Alerts