Safeguarding Policy (v1.0)

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1. Purpose

This policy sets out SWTrains Limited’s approach to safeguarding all individuals who engage with our services, especially children and vulnerable persons involved in voluntary testing or community participation. It is designed to protect against harm, exploitation, and unlawful data handling while aligning with UK safeguarding law, data protection regulations (UK GDPR, Data Protection Act 2018), and our published Privacy Policy and Terms and Conditions.

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2. Policy Statement

SWTrains Limited is committed to ensuring that all individuals, particularly those under the age of 18 or vulnerable adults, are protected from abuse, harm, or exploitation when engaging with our digital content, testing activities, or communications.

We promote a culture of accountability, respect, and responsible engagement across all platforms, including our website, email correspondence, content testing programmes, and affiliated social communities (e.g. Discord, WIX, Google).

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3. Scope

This policy applies to:

• All SWTrains Limited activities and platforms, including our website (www.swtrains.uk), content testing systems, and digital communication channels

• All testers, staff, volunteers, collaborators, and users

• All individuals under 18 who engage with our products or services, with consent and supervision by a parent or legal guardian

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4. Key Safeguarding Measures

SWTrains Limited undertakes the following safeguarding practices:

• Age Verification: Any individual under 18 seeking to volunteer must provide parental or guardian consent, verified through official documentation where required

• Consent Forms: Both a Volunteer Tester Agreement and a Non-Disclosure Agreement (NDA) must be signed by the parent or legal guardian of any minor participant before engagement begins

• Secure Data Handling: Any identification or consent documentation is stored securely in line with our Privacy Policy using encrypted email (Gmail/Google) and encrypted hard drives. Data is deleted once its purpose is fulfilled unless retention is required by law

• Safe Environments: We require that all under-18 participants are supervised and supported by a parent or guardian during any remote or in-person activities

• Zero-Tolerance for Abuse: We do not tolerate bullying, harassment, discrimination, or inappropriate behaviour. Any reports of misconduct will be investigated and appropriate action taken, including immediate removal from testing programmes and, where necessary, referral to external safeguarding authorities

• Safeguarding Breach Protocols: If safeguarding concerns are raised, we may:

  • Suspend the individual’s access

  • Notify parents or guardians

  • Report the matter to appropriate safeguarding or legal authorities

  • Retain relevant evidence in accordance with UK GDPR and safeguarding obligations

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5. Responsibilities

SWTrains Limited is responsible for:

• Enforcing this policy across all testing and volunteer programmes

• Training and guiding any team members involved in handling safeguarding cases

• Acting promptly on any concerns or complaints

Volunteers and Guardians are responsible for:

• Ensuring minors understand and comply with the Volunteer Tester Agreement and NDA

• Supervising minor participants during any activities

• Reporting safeguarding concerns directly to customer.relations@swtrains.uk

 

6. Legal Compliance​

This policy is designed to comply with:

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• Children Act 1989 and 2004

• Digital Economy Act 2017 (age-verification obligations)

• Company safeguarding obligations under digital content law

It is also fully aligned with our published Privacy Policy and Terms and Conditions, which govern data processing, content distribution, and acceptable use of our services.

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7. Review and Amendments

This policy is reviewed annually and updated where necessary to reflect changes in law, technology, or SWTrains Limited procedures. The current version is always available on our website or by written request.

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8. Reporting Concerns

To report a safeguarding concern or request further clarification on this policy, please contact:

SWTrains Limited
Email: customer.relations@swtrains.uk
Website: www.swtrains.uk

We treat all safeguarding concerns with the utmost seriousness, confidentiality, and urgency.

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Effective Date: 23 July 2025