1. Purpose

ShamBits Academy connects children with independent contractor Teachers for one-to-one online tutoring. This policy sets out how we approach the safety and wellbeing of children using our service — the principles we follow, the checks and controls we have in place, and how we respond if something goes wrong.

2. Scope

This policy applies to every child ("Student") who receives lessons through ShamBits Academy, every Teacher who delivers lessons, every ShamBits employee or contractor with access to the platform, and every parent or guardian ("Account Owner") managing a child's Student profile. It is incorporated by reference into our Student & Parent Terms and Conditions and our Independent Contractor Teacher Agreement.

3. Our safeguarding principles

• The welfare of the child is our primary consideration in how we design and operate the service.
• Every child using ShamBits Academy has the right to be safe, and to be listened to if something feels wrong.
• Safeguarding is everyone's responsibility — ours, our Teachers', and parents'/guardians' together.
• We aim to prevent harm through the design of the service itself (for example, lesson recording and admin-only playback access — see clause 8), not only by reacting after the fact.

4. Why one-to-one online tutoring needs particular care

A live, one-to-one video lesson between a child and an adult who is not their parent is, by its nature, a situation that calls for real safeguarding attention — regardless of how well-intentioned everyone involved is. We've built controls specifically around this: lessons are recorded, Teachers are reviewed before they can teach, and communication is expected to happen only through channels we can see (clause 7).

5. Teacher selection and verification

Before a Teacher is approved to teach any student, we require them to complete an application setting out their qualifications and experience, and to provide a passport or national identity document so we can verify their identity. We may also conduct an interview and, in some cases, a short assessed mock lesson. A Teacher only becomes able to teach real students once their application is approved.

5A. Certificate of Good Conduct / criminal-record check

Every Teacher must also provide an official Certificate of Good Conduct, police clearance certificate, or the appropriate equivalent government-issued criminal-record document for their country of residence, as part of our approval process — for example, applicants based in Jordan are asked for the official Jordanian Certificate of Good Conduct. This has been adopted as ShamBits business policy because our Teachers deliver one-to-one lessons involving children.

The certificate must have been issued within the 3 months before a Teacher's final approval. Once approved, we ask a Teacher to provide a current certificate again at least every 12 months, and sooner if we have a genuine safeguarding or security reason to ask for re-verification.

Current state, stated honestly: this requirement has been adopted as policy, but is not necessarily active in production for every applicant yet — we only begin actually collecting this document once the data-handling safeguards appropriate to this more sensitive category of information are genuinely in place. We do not claim below, or anywhere else, that this check has already taken place for any Teacher unless it genuinely has.

We do not use the term "DBS checked." A UK Disclosure and Barring Service (DBS) check is a specific, UK-only process. We will only ever describe a Teacher as "DBS checked" where a genuine UK DBS check has actually been carried out for that individual — for a Teacher based outside the UK, we instead refer to the appropriate country-specific document (such as a Certificate of Good Conduct), and we do not use "DBS checked" as a generic stand-in for it.

What we do not do: beyond the checks described in clauses 5 and 5A, we do not verify Teachers against any professional regulator or safeguarding register. This reflects our settled vetting scope for this stage of the service, not an unresolved gap — see clause 16.

5B. Our target teacher vetting model

Taken together, our intended approach to vetting a Teacher before they can teach real students is: identity verification (clause 5); qualification and certificate verification; an interview; a teaching assessment or mock lesson; professional or employment references, where required; an official Certificate of Good Conduct or the appropriate country equivalent (clause 5A); and agreement to our safeguarding obligations and training. We describe this as our target model — see clause 5A above for what is and isn't yet actually in effect for the criminal-record-check element specifically.

6. Professional boundaries

Teachers are expected to maintain clear, professional boundaries with students at all times: treating every student with respect, keeping the relationship strictly a teaching one, and never asking a student to do anything that makes them uncomfortable.

7. Communication rules

All communication between a Teacher and a Student, or between a Teacher and an Account Owner, in connection with lessons must take place through ShamBits' own channels (in-lesson chat, lesson reports, and our support channels) — never through a Teacher's personal email, phone number, or social media, and never through arrangements made outside the platform.

8. Lesson recording

Lessons are configured to be recorded as a standard part of the service, specifically to support safeguarding as well as quality and dispute review. Recordings that are successfully created can only be accessed by authorised ShamBits administrators, never by the Teacher or the Student/Account Owner themselves, and only for a legitimate reason connected with the purposes above.

Occasionally, a technical failure may mean a particular lesson is not successfully recorded, or that recording stops partway through. This does not stop or cancel the lesson — the lesson continues as normal, our other safeguarding controls remain fully in place, and any such failure is logged and reviewed by our operations team so that repeated or systemic problems are identified and addressed.

9. Recording retention — up to 30 days

Recordings that are successfully created are retained for up to 30 days and are physically deleted no later than the applicable retention deadline — not simply hidden or marked as expired. We do not promise every lesson will result in a recording, and we do not promise a recording necessarily remains available for the complete 30 days; it is never kept for longer than that maximum.

10. Responding to concerns

If a concern is raised — by a parent, a Student (through their parent), a Teacher, or a member of our own team — we take it seriously, look into it promptly, and take appropriate action, which may include reviewing the relevant lesson recording where one exists, pausing or suspending the Teacher involved while we investigate, and, where appropriate, involving external authorities (clause 15).

11. Parent and guardian responsibilities

We ask parents and guardians to: give us accurate information when setting up a child's profile; talk to their child about how to raise anything that feels wrong; and tell us promptly if they have any safeguarding concern, however small it may seem.

12. Teacher responsibilities

Teachers must: comply with this policy and with the professional-boundary and communication rules above; report any safeguarding concern to ShamBits promptly, even if it doesn't clearly fall within their own lesson; and cooperate fully with any investigation ShamBits carries out.

13. Prohibited behaviour

The following are never acceptable, by a Teacher or anyone else connected with the service, and will be treated as a serious safeguarding matter: any inappropriate, threatening, or exploitative behaviour towards a child; attempting to contact or meet a student outside the platform; asking a student to conceal something from their parent; and any request or behaviour that a reasonable person would consider intended to build an inappropriate level of trust or secrecy with a child ("grooming behaviour").

14. Reporting a concern to ShamBits

If you have a safeguarding concern, contact us as soon as possible at hello@shambits.com, with as much detail as you're able to provide. You do not need to be certain something is wrong to raise it — we would rather hear about a concern that turns out to be nothing than not hear about one that matters.

15. Immediate danger and escalation

If a child is in immediate danger, contact the emergency services first (in the UK, 999; if you're elsewhere, your local equivalent), and then let us know. Where a safeguarding concern is serious, we may suspend the Teacher involved immediately while we investigate, and, where appropriate and legally required or permitted, share information with the relevant child-protection or law-enforcement authority.

16. Vetting — decision made on requirement; production rollout still being prepared

We have decided that Teachers must provide an official Certificate of Good Conduct or equivalent country-specific criminal-record document (clause 5A) — this part of the question is resolved. What we are still actively preparing is the safe production rollout of collecting and handling this document, given criminal-offence data requires stricter handling than an ordinary identity document. We do not check Teachers against any additional professional or safeguarding register beyond the checks in clause 5B — this is not a gap awaiting a decision, but our settled MVP scope; we may add a country-specific register check in future where a credible one exists for a particular country, but this is not a requirement today. This policy will be updated once the Certificate of Good Conduct requirement is genuinely live in production.

17. Confidentiality and safeguarding disclosures

Information shared with us in connection with a safeguarding concern is treated as confidential and shared only with the people who need to know it in order to respond appropriately — except where we are legally required or permitted to disclose it, for example to protect a child from harm or in response to a lawful request from an authority.

18. Record keeping

We keep a record of safeguarding concerns raised and how they were handled, for as long as necessary for safeguarding, accountability, and legal purposes, as set out in our internal data retention schedule.

19. Reviewing this policy

We review this policy regularly, and whenever there is a material change to how the service works that could affect safeguarding (for example, a change to recording or Teacher-verification processes), to make sure it stays accurate and effective.

20. Contact

Shambits LTD, 86-90 Paul Street, London, England, EC2A 4NE, United Kingdom. Email: hello@shambits.com.