STRICTLY CONFIDENTIAL — INTERNAL DOCUMENT — Not for external distribution
Safeguarding Library — Internal Document
Strictly Confidential

Staff Declaration &
Operational Safeguarding Framework

Part of the VML Digital Safety Ecosystem

ReferenceVML-KIDS-SDF-006
Version1.0 — Initial Issue
Date of IssueApril 2026
Next Mandatory ReviewApril 2027
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This document constitutes both a formal declaration of standards and an operational framework. Every person who works for, with, or on behalf of VML Kids and who comes into contact with personal data, safeguarding information, or platform systems is required to read this document in full, understand its obligations, and sign the declaration.

Signing this document is not a formality. It is a commitment. The obligations set out here are binding, enforceable, and in several respects carry legal weight independent of this document by virtue of UK law. Ignorance of an obligation is not a defence against breach of it.

This framework will be reviewed on a mandatory annual cycle and immediately upon any relevant change in legislation, statutory guidance or judicial interpretation. Staff will be required to re-sign on each review.

Section 1The Governing Principle

The protection of children is the absolute and non-negotiable priority of this platform. Every decision made by every member of staff — in every role, at every level — must be made with the best interests of the child as the primary consideration.

This principle is not aspirational. It is operational. Where any other consideration — commercial, reputational, procedural, personal or managerial — conflicts with the protection of a child, the protection of the child takes precedence. Without exception.

This principle derives from Article 3 of the United Nations Convention on the Rights of the Child (UNCRC), incorporated into this platform's Statement of Intent (VML-KIDS-SOI-001).

Section 2Scope — Who This Document Applies To

This document applies to all of the following, without exception:

If you are in any doubt as to whether this document applies to you — it applies to you.

Section 3Core Obligations — All Roles

The following obligations apply to every person within the scope of this document, regardless of role.

3.1  Child Safety — Absolute Priority

3.2  Confidentiality

3.3  Data Protection and GDPR

3.4  Mandatory Reporting

3.5  Conduct and Professional Standards

Section 4Immediate Escalation — Critical Alerts

The following categories of concern require immediate escalation without waiting for internal review, panel assessment or management approval. These are not judgment calls. Where evidence of any of the following is identified, the response is immediate.

⚠ CRITICAL ALERT — IMMEDIATE ESCALATION REQUIRED  —  Click each alert for the full procedure

Missing or Kidnapped Child with Active Account

Where a child has been reported missing, abducted or kidnapped and their VML Kids account shows activity — immediate escalation to Duty Safeguarding Director, immediate contact with police, immediate capture and preservation of all account logs, device data, location data and communications. Account must be monitored in real time. This constitutes live intelligence in an active police investigation.

Adult Confirmed Posing as a Child

Where biometric verification, facial recognition or document integrity checks produce evidence that an adult has attempted to register as a child — immediate account freeze, automatic escalation package generated, immediate referral to Independent Safeguarding Panel and Duty Safeguarding Director. Police referral without delay.

Document Fraud — Faked or Tampered Identity Document

Where a government-issued identity document shows evidence of tampering, photograph substitution or data manipulation — same response as above. Two simultaneous failure signals (document integrity and biometric mismatch) constitute essentially no innocent explanation.

Child Removed from Resident Parent in Breach of Court Order

Where platform data indicates that a child is in the presence of a person prohibited from contact by a court order, or has been removed from a resident parent without lawful authority — immediate escalation to Duty Safeguarding Director who must call a Safeguarding meeting and liaise with the resident parent's local Police force..

In all Critical Alert situations — without exception:

  • Do not wait for authorisation before escalating — escalate and notify simultaneously
  • Do not contact the account holder, the parent or any third party — preserve the integrity of the situation
  • Capture and preserve all relevant logs, data and communications immediately
  • Document every action taken with timestamp from the moment the alert is identified
  • Do not delete, modify or allow access to any data connected to the concern without an explicit written instruction from the Duty Safeguarding Director.

Section 5Role-Specific Obligations

The following obligations apply in addition to the core obligations in Section 3. Every member of staff must read the obligations for their own role. Management must read all role obligations.

Moderators

  • Monitor public communications on the platform in accordance with documented monitoring procedures and risk thresholds.
  • Flag any content or behaviour that meets or approaches the risk threshold into the human review queue without delay.
  • Do not make safeguarding decisions. Your role is to flag, not to adjudicate. When in doubt, flag.
  • Do not engage with, respond to or warn any account holder about a flag you have raised.
  • Document all flags with sufficient detail to enable the human review queue to assess the concern without requiring follow-up.
  • Report any pattern of concern — including concerns that individually fall below threshold but collectively give rise to concern — to your line manager and into the safeguarding review queue.
  • Escalate immediately to the safeguarding review queue supervisor if you identify content that may constitute a Critical Alert as defined in Section 4.

Human Review Queue Staff

  • Review all flagged content referred to the queue promptly and in accordance with documented review procedures.
  • Your standard response is to assess the concern and escalate to the Independent Safeguarding Panel where the higher threshold is met.
  • You have authority to take immediate action — without waiting for panel review — in any situation that constitutes a Critical Alert as defined in Section 4. In those situations, escalate to the Duty Safeguarding Director immediately and simultaneously escalate to the Police where sufficient threat exists.
  • Document every review decision with your assessment, the evidence considered, and the action taken or rationale for no action.
  • A decision not to escalate must be as well-reasoned and documented as a decision to escalate.
  • You must not contact any account holder, parent, school or third party in connection with a concern under review without explicit authorisation.
  • Report any pressure — from any source — to assess a concern differently than your professional judgement indicates to the Duty Safeguarding Director immediately.
  • If you are concerned about the behaviour of colleagues or that reasonable concerns raised are not being acted upon, you must raise these concerns to the Independent Safeguarding Panel, not the Duty Safeguard Director, or via the Whistleblower reporting system at your first opportunity.

Safeguarding Reviewers — Independent Panel Members

  • You are independent of platform management. Your safeguarding decisions are not subject to direction, approval or override by platform management.
  • Assess all concerns referred to the panel in accordance with established safeguarding standards, UK child protection law and the principles set out in this framework.
  • Where the threshold for escalation to statutory authorities is met, you have authority to refer directly to the appropriate child protection authority — police, social services, CEOP or other relevant body — without requiring management approval.
  • Generate formal escalation reports in the standardised format, containing all relevant platform data, for use by statutory authorities.
  • Where you identify management pressure, obstruction or interference in a safeguarding decision, you are required to document it and report it directly to statutory authorities where necessary.
  • Your independent status does not exempt you from the confidentiality, GDPR and conduct obligations in Section 3 of this framework.

Technical Staff

  • You may have access to platform infrastructure, databases and personal data that exceeds what most staff encounter. This access carries heightened responsibility.
  • Access only the data and systems necessary for the performance of your specific technical role. Any access beyond operational necessity is a breach of UK GDPR and this framework.
  • You must never modify, delete or allow access to data connected to a safeguarding concern or investigation without explicit written instruction from the Safeguarding Director.
  • Where you encounter personal data, content or system logs that give rise to a safeguarding concern, you are required to report it immediately — regardless of whether you were looking for it.
  • You must report any actual or suspected data breach, system compromise or unauthorised access attempt immediately to your line manager and the Data Protection Officer.
  • Technical development and changes to platform systems that affect safeguarding functionality require sign-off from the Safeguarding Director before implementation.

Management

  • Ultimate responsibility for the delivery of this framework rests with senior management. That responsibility cannot be delegated away.
  • You must ensure all staff within your area of responsibility have read, understood and signed this framework and receive appropriate training to fulfil their obligations.
  • You must create and maintain an environment in which safeguarding concerns can be raised without fear of negative consequence. Any culture of silence or suppression around safeguarding is a management failure.
  • You must never direct, pressure or incentivise any member of staff to assess a safeguarding concern differently than their professional judgement indicates.
  • You must never obstruct, delay or interfere with an escalation to the Independent Safeguarding Panel or to statutory authorities.
  • You are required to report any management conduct that breaches this framework to the Safeguarding Director and, where necessary, directly to statutory authorities.

Section 6Escalation Pathway

The standard escalation pathway for safeguarding concerns is as follows:

Critical Alert bypass: For Critical Alerts as defined in Section 4, steps 2 and 3 are bypassed. The response is: immediate escalation to the Duty Safeguarding Director → immediate referral to statutory authorities → simultaneous notification to panel.
No member of management has authority to halt, delay or redirect this escalation pathway. The pathway operates independently of management approval.

Section 7Data Retention and Log Preservation

Section 8Whistleblowing

Any member of staff who becomes aware of conduct that breaches this framework — including conduct by colleagues, line managers, senior management or panel members — is required to report it.

Reports may be made to the Duty Safeguarding Director, the Data Protection Officer, The Independent Safeguarding Panel, the Senior Management Team, or directly to statutory authorities where the concern is serious enough to warrant it.

No member of staff will be subject to any detriment, disciplinary action or negative consequence for raising a genuine concern in good faith. Any attempt to penalise a whistleblower is itself a breach of this framework and of the Public Interest Disclosure Act 1998. Any person taking action against any good faith whistleblower will be subject to disciplinary action.

Section 9Breach of This Framework

Breach of any obligation set out in this framework will be treated seriously and may result in immediate suspension, disciplinary action up to and including summary dismissal, referral to relevant professional regulatory bodies, or referral to the police where the breach constitutes or contributes to a criminal offence.

The following breaches will always result in immediate suspension and referral to the police:

Section 10Version Control and Review

Document ReferenceVML-KIDS-SDF-006
Version1.0 — Initial Issue
Date of IssueApril 2026
Mandatory Review DateApril 2027
Triggered ReviewImmediate, on any relevant legislative or statutory guidance change
OwnerTeravoxus Holdings Limited — Senior Leadership

Section 11Declaration

I confirm that I have read this document in full. I understand the obligations it places upon me. I understand that these obligations are binding, that several carry independent legal weight, and that breach of them may result in disciplinary action, termination of my engagement, regulatory referral or criminal prosecution.

I confirm that I will act at all times in accordance with this framework. I understand that I am required to re-sign this declaration on each annual review and at any point when a new version is issued.

Staff Member Declaration

Line Manager Countersignature