1. Purpose and commitment

Crowd Scout exists to widen sporting opportunity without compromising safety. We recognise that creating visibility for athletes, including children, also creates safeguarding responsibilities. Our objective is to make talent discoverable while reducing opportunities for abuse, grooming, exploitation, harassment, coercion, inappropriate contact and other harm.

Safeguarding is not treated as a feature added after product development. It is a design, governance and operational requirement. Crowd Scout will place the welfare and best interests of children at the centre of decisions that affect their safety.

This Policy explains the safeguarding standards governing Crowd Scout, the protections built around young athletes, the behaviour expected of adults using trusted roles, and how concerns are handled and escalated.

​

2. Scope

This Policy applies to the Crowd Scout mobile application, website and related services and to conduct connected with use of Crowd Scout. It applies to athletes, parents and guardians, fans, verified Scouts, clubs and organisations, staff, contractors, moderators and relevant service providers or partners.

A safeguarding concern may arise from content posted on Crowd Scout, conduct using Crowd Scout functionality, an attempt to move a child into inappropriate off-platform contact, information reported to Crowd Scout, or credible information received from another source.

​

3. Who is a child?

For this Policy, a child is anyone under the age of 18. A young person does not lose their safeguarding status because they are 16 or 17, compete at an elite level, appear mature, have public sporting profiles, earn money from sport or communicate confidently with adults.

Children may have different levels of maturity and vulnerability. Crowd Scout therefore considers age, context, power imbalance and the nature of the interaction rather than assuming that one safeguard is appropriate for every child.

​

4. Safeguarding principles

• The welfare and best interests of the child come first.

• Children have a right to be heard, taken seriously and treated with dignity.

• Sporting opportunity must never depend on secrecy, inappropriate access to a child or the removal of protective adults.

• Adults in positions of sporting trust carry greater responsibility, not greater entitlement to access.

• Safeguarding concerns should be acted upon on the basis of risk; certainty of abuse is not required before a concern can be reported or escalated.

• Information should be shared lawfully, proportionately and on a need-to-know basis where necessary to protect a child.

• Safeguarding decisions and significant actions should be capable of audit and review.

• Commercial objectives, engagement or growth must not override child safety.

​

5. Crowd Scout's safeguarding-by-design model

Crowd Scout deliberately constrains functionality that could create unnecessary access to children. The core model includes the following protections:

• under-18 athlete accounts are subject to parent/guardian approval and age-appropriate protections;

• young athletes can be identified as protected accounts within the Platform;

• Scout functionality is restricted to adults aged 18 or over who satisfy Crowd Scout's verification requirements;

• Scout access is a privileged role and may be reviewed, suspended or revoked;

• Crowd Scout does not provide a general-purpose private messaging or open direct-message system between Scouts and young athletes;

• where a verified Scout expresses legitimate interest in a minor, the safeguarded workflow routes the relevant contact through the parent or guardian where required;

• attempts to bypass the guardian pathway or obtain secret/private access to a child are prohibited;

• users can report concerning content, conduct or accounts;

• safeguarding reports and significant case actions may be recorded to create an accountable case history;

• content and account restrictions may be applied urgently where necessary to reduce risk.

 

The existence of a technical control does not replace professional judgement. Crowd Scout will review its controls as the Platform, threat environment and regulatory expectations develop.

​

6. Parent and guardian role

Parents and guardians are an important part of the protection model for young athletes. Where guardian involvement is required, Crowd Scout may use the guardian account or relationship to approve participation, receive protected Scout contact and support safeguarding action.

Parents and guardians should keep account and relationship information accurate, discuss safe online behaviour with the young athlete, review concerns raised by the child, and report suspicious approaches or attempts to circumvent Crowd Scout's controls.

Guardian involvement does not remove the child's own rights, voice or entitlement to protection. A safeguarding concern involving a parent or guardian will be assessed according to the child's welfare and may require a different protective route.

​

7. Scout verification and positions of trust

A verified Scout occupies a position of trust within Crowd Scout. Verification is intended to reduce impersonation and restrict Scout functionality to adults whose identity and relevant affiliation or authority have been assessed under Crowd Scout's verification standard.

Verification is not a guarantee of character, future conduct or suitability in every context. It is one layer of a wider safeguarding system. Crowd Scout may request further information, re-check status, restrict functionality, suspend access or revoke verification where concerns arise.

Verified Scouts must comply with the Scout Code of Conduct, maintain professional boundaries and use Crowd Scout only for legitimate talent-identification purposes.

​

8. Professional boundaries and prohibited conduct

No adult using Crowd Scout may exploit sporting ambition, perceived authority, access to opportunities or a position of trust to obtain inappropriate access to a child.

• grooming, sexualised communication, sexual exploitation or abuse;

• requesting or sharing sexual or indecent images of a child;

• asking a child to keep contact, meetings, gifts or communications secret from a parent/guardian or safeguarding professional;

• attempting to bypass a guardian-controlled contact route;

• requesting a child's private telephone number, home address or unnecessary private contact information for an improper purpose;

• pressuring a child to move to private or disappearing-message channels to avoid safeguarding oversight;

• threats, coercion, blackmail, intimidation or manipulation;

• bullying, harassment, discriminatory abuse or humiliation;

• offering sporting opportunity, trials, selection, money, gifts or benefits in exchange for inappropriate conduct or secrecy;

• impersonating a Scout, club, agent, coach, parent or other trusted person;

• arranging an unsafe or secret meeting with a child;

• retaliating against a person for raising a safeguarding concern.

This list is not exhaustive. Conduct may breach this Policy even if it occurs away from Crowd Scout where there is a sufficient connection to use of the Platform or a risk to a Crowd Scout user.

​

9. Content safeguarding

Sporting content must be appropriate for the Platform. Crowd Scout may remove, restrict or investigate content that creates a safeguarding risk, violates the Terms or Community Guidelines, or may be unlawful.

• child sexual abuse or exploitation material and content amounting to grooming or facilitation of abuse;

• sexualised or exploitative depictions of children;

• content revealing unnecessary precise personal information that could expose a child to risk;

• credible threats, coercion, stalking, harassment or targeted abuse;

• content promoting self-harm, dangerous conduct or other harms where applicable to Crowd Scout's legal duties and risk assessment;

• material intended to identify, shame, exploit or endanger a child.

​

Crowd Scout may preserve relevant evidence where necessary for safeguarding, legal compliance or law-enforcement reporting even where content is removed from ordinary user access.

​

10. Reporting a safeguarding concern

Anyone may raise a safeguarding concern using Crowd Scout's reporting or support mechanisms. A person does not need proof that abuse has occurred before reporting a genuine concern.

Reports should include enough information to identify the relevant account, content or behaviour where possible. Users should not place themselves or a child at additional risk in order to gather evidence.

If a child is in immediate danger in the UK, call 999. Concerns about abuse may also be reported to the relevant local authority children's social care service or police. Child sexual exploitation or online sexual abuse concerns may also be reported through the appropriate national child-protection route.

​

11. Triage and immediate protective action

Safeguarding reports are assessed according to risk and urgency. Crowd Scout may take immediate protective action before an investigation is complete where delay could expose a child or another person to harm.

• restricting or removing content;

• limiting account functionality;

• suspending an account or Scout verification;

• preventing or restricting further contact pathways;

• preserving relevant records and evidence;

• escalating the matter to the designated safeguarding function or senior decision-maker;

• making an external safeguarding or law-enforcement report where required or appropriate.

 

Protective action is not a finding of criminal guilt. It is a risk-management measure designed to protect users while facts are assessed.

​

12. Safeguarding case management

Crowd Scout will maintain proportionate records of significant safeguarding concerns and actions. Records may include the report, relevant account/content references, risk assessment, decisions, actions taken, external referrals, review outcomes and significant case events.

Safeguarding records are access-controlled and handled on a need-to-know basis. They may be retained after account deletion where necessary to protect children, identify repeat risk, comply with law, preserve evidence or establish, exercise or defend legal rights.

Where appropriate, Crowd Scout will separate public-facing moderation outcomes from confidential safeguarding information so that protecting a child, reporter or investigation is not undermined.

​

13. Escalation to authorities and CSEA reporting

Crowd Scout will cooperate with competent safeguarding bodies, regulators and law-enforcement authorities where required by law or where lawful and necessary to protect a child or another person.

Where Crowd Scout is subject to the UK Online Safety Act CSEA reporting duty, detected and previously unreported child sexual exploitation and abuse content present on the service will be reported through the required National Crime Agency industry reporting process, or an applicable equivalent reporting route where the law permits. This includes content falling within the relevant statutory CSEA offences, which can include child sexual abuse material and grooming content.

Crowd Scout will maintain internal procedures for preservation, restricted handling and reporting of suspected CSEA material. Staff or contractors must not unnecessarily copy, download, circulate or view suspected illegal material outside an authorised safeguarding/legal process.

Nothing in this Policy prevents urgent contact with police or emergency services where there is an immediate threat to life or safety.

​

14. Information sharing and confidentiality

Safeguarding can require information to be shared. Crowd Scout will not promise absolute confidentiality where doing so could prevent action necessary to protect a child.

Information will be shared lawfully, proportionately and with appropriate recipients. The amount disclosed should be limited to what is reasonably necessary for the safeguarding, legal or investigative purpose.

Where it is safe and appropriate, the affected person or guardian may be informed about relevant action. Crowd Scout may withhold details where disclosure could endanger a child, prejudice an investigation, expose a reporter, facilitate retaliation or conflict with legal obligations.

​

15. Responding to a disclosure by a child

If a child tells Crowd Scout or a person acting for Crowd Scout that they have been harmed or feel unsafe, the concern must be taken seriously. The child should not be blamed, challenged or asked to prove the allegation.

The response should prioritise immediate safety, record the child's account accurately without unnecessary investigative questioning, explain that relevant information may need to be shared to keep them safe, and escalate promptly through the safeguarding process.

Crowd Scout's role is not to conduct a criminal interview. Detailed investigation of suspected crime belongs with the appropriate authorities.

​

16. Allegations involving Scouts, staff, contractors or trusted adults

Concerns about a verified Scout, member of staff, contractor, club representative or other trusted adult will be treated seriously regardless of seniority, reputation or commercial importance.

Crowd Scout may suspend access or trusted status while a concern is assessed. Where the information indicates a child may have been harmed, a criminal offence may have occurred, or an adult may pose a risk to children, Crowd Scout will consider and make the appropriate external referral or report.

No person should investigate an allegation against themselves or use their position to suppress, alter or discourage a safeguarding report.

​

17. Bullying, harassment and discrimination

Safeguarding includes protection from emotional and psychological harm. Crowd Scout does not tolerate targeted bullying, degrading commentary, discriminatory abuse, threats or harassment.

Sporting performance may be rated through Platform features, but criticism of performance does not justify personal abuse. Crowd Scout may remove content or restrict accounts where behaviour crosses the line from legitimate sporting opinion into harassment, humiliation, discrimination or targeted harm.

​

18. Missing children, trafficking, exploitation and coercion

Information suggesting trafficking, criminal exploitation, sexual exploitation, abduction, coercive control or a missing child will be treated as a serious safeguarding concern. Crowd Scout may preserve information and refer concerns to the appropriate authorities where lawful and necessary.

Sport, trials, travel, scholarships, representation and commercial opportunities must never be used as mechanisms to exploit or isolate a child.

​

19. Training, access and safeguarding competence

People performing safeguarding, moderation or relevant operational roles for Crowd Scout should receive training proportionate to their responsibilities. Training should cover recognising and responding to concerns, professional boundaries, escalation, confidentiality and information sharing, online abuse, grooming and CSEA, record keeping and the limits of the individual's role.

Access to sensitive safeguarding systems and records should be limited to people who require it for their role.

​

20. Governance and accountability

Senior leadership is accountable for ensuring that safeguarding is adequately resourced and considered in product and commercial decisions. Crowd Scout will maintain a designated safeguarding function with clear responsibility for escalation, policy ownership and liaison with relevant authorities.

• maintaining and reviewing safeguarding policies and operational procedures;

• maintaining required Online Safety Act risk assessments and records where Crowd Scout is in scope;

• reviewing safeguarding metrics, trends and significant incidents;

• ensuring serious incidents receive appropriate senior oversight;

• reviewing whether product functionality creates new or increased risk;

• maintaining appropriate training and access controls;

• documenting material safeguarding decisions and lessons learned.

​

21. Online Safety Act risk management

Crowd Scout will assess its duties under the Online Safety Act 2023 and applicable Ofcom codes and guidance. Where the Platform is a regulated user-to-user service likely to be accessed by children, Crowd Scout will maintain suitable and sufficient illegal-content and children's risk assessments and proportionate systems and processes to mitigate identified risks.

A material change to the design or operation of the service will trigger safeguarding and regulatory review before launch where required. Risk assessments will be kept up to date and reviewed when the law, Ofcom risk profiles, Platform functionality or evidence of harm materially changes.

Crowd Scout will maintain reporting and complaints mechanisms and apply its Terms, Community Guidelines and safeguarding standards consistently, subject to urgent protective action where necessary.

​

22. Product change and safeguarding review

Safeguarding review is required before introducing features that could materially change how children are discovered, contacted, ranked, located, identified or commercialised. Examples include messaging, live streaming, precise geolocation, new recommender systems, artificial-intelligence features, biometric processing, payments, digital assets/NFTs, expanded social functionality or new forms of Scout access.

The review should consider foreseeable misuse as well as intended use. A feature should not be approved merely because its intended use is benign if predictable misuse creates unacceptable child-safety risk.

​

23. Commercialisation and children

A child's sporting ambition must not be exploited. Future sponsorship, payments, digital assets, NFTs or other commercial functionality involving young athletes must be designed with age-appropriate protections, guardian involvement where appropriate, transparent terms and consideration of the child's welfare and rights.

No commercial opportunity facilitated through Crowd Scout permits an adult to bypass safeguarding controls or acquire private access to a child.

​

24. International safeguarding

Crowd Scout is operated from the United Kingdom and this Policy is principally structured around UK safeguarding and online-safety requirements. Where Crowd Scout deliberately expands into another jurisdiction, we will assess applicable child-protection, reporting, privacy, age-assurance and sports-safeguarding requirements and introduce local supplements or procedures where necessary.

Local mandatory safeguarding obligations take precedence where they impose additional requirements. Cross-border concerns may require cooperation with authorities or recognised child-protection bodies in more than one country.

​

25. Complaints and review

Users may complain about safeguarding-related moderation or account action through Crowd Scout's published support process. Crowd Scout will provide an appropriate review route where required by law and where doing so would not compromise child safety, confidentiality, evidence or an external investigation.

Safeguarding decisions may be revisited when material new information becomes available.

​

26. Policy review and learning

This Policy will be reviewed at least annually and sooner following a serious safeguarding incident, material legal or regulatory change, significant product change, emerging pattern of harm or evidence that an existing control is ineffective.

Crowd Scout will use appropriate incident learning and trend analysis to improve controls. Public transparency will be balanced against the need not to disclose detailed abuse-detection or enforcement methods that could enable circumvention.

​

Schedule 1 - Safeguarding concern categories

Immediate danger: Credible information indicating an imminent threat to life, serious injury, abduction or immediate abuse.

Child sexual abuse/exploitation: CSAM, grooming, sexualised contact, sexual coercion, exploitation or facilitation of a child sexual offence.

Inappropriate adult-child contact: Boundary violations, secret contact, guardian bypass, requests for private details or suspicious off-platform movement.

Physical/emotional harm: Threats, violence, severe bullying, harassment, humiliation, coercion or discriminatory abuse.

Exploitation: Trafficking, criminal exploitation, financial exploitation or misuse of sporting opportunity or authority.

Privacy/safety exposure: Doxxing, unnecessary disclosure of a child's precise whereabouts or information creating a credible safety risk.

Platform integrity with safeguarding impact: Scout impersonation, false guardian status, manipulated identity or other deception creating access to children.

​

Schedule 2 - Emergency and external support (UK)

If a child is in immediate danger, call 999. Non-emergency crime can be reported to police through 101 or the appropriate police reporting service. Concerns that a child is being abused or is at risk can be reported to the children's social care team at the child's local authority. Online child sexual abuse or exploitation concerns may be reported to CEOP. Adults seeking safeguarding advice can also contact the NSPCC Helpline; children and young people can contact Childline.

Crowd Scout's in-app or support reporting process does not replace emergency services or statutory child-protection agencies.

​

Schedule 3 - Principal UK framework

• Children Act 1989 and Children Act 2004, as applicable.

• Working Together to Safeguard Children 2026 and associated statutory framework, as applicable to relevant organisations and safeguarding practice.

• Online Safety Act 2023 and applicable secondary legislation.

• Ofcom Illegal Content Codes of Practice, Protection of Children Codes of Practice, risk-assessment guidance and related online-safety guidance.

• Online Safety (CSEA Content Reporting by Regulated User-to-User Service Providers) Regulations 2026 and associated NCA reporting arrangements, where applicable.

• Data Protection Act 2018, UK GDPR and the ICO Children's Code in relation to safeguarding information and children's privacy.

• Sexual Offences Act 2003, Protection of Children Act 1978 and other relevant criminal law.

• Crime and Policing Act 2026 and applicable commencement/guidance, where relevant to safeguarding and reporting obligations.

​

Schedule 4 - Related Crowd Scout documents

• Terms & Conditions

• Privacy Policy

• Community Guidelines

• Child Protection Policy

• Parent & Guardian Promise

• Scout Verification Standard

• Scout Code of Conduct

​

Legal and operational readiness note

This is Crowd Scout's final publication draft for operational review. Before public launch, Crowd Scout should ensure that the internal safeguarding procedure supporting this Policy is operational, responsible persons are formally appointed, external reporting routes are registered/configured where required, and applicable Online Safety Act risk assessments and records are completed. Specialist UK safeguarding and online-safety legal review is recommended.