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CurioCoreFlowbase and SportsFlow legal

Safeguarding and Child Protection Policy

Flowbase and SportsFlow · Version 1.0 · Effective {EFFECTIVE_DATE} · Owner: Company Safeguarding Lead · Review: annually

1. Policy Statement

CurioCore is committed to the safety and wellbeing of every athlete who uses Flowbase and SportsFlow, and especially of children and young people. Our products are built so that concerns reach a responsible adult, private information stays private, and no feature puts a young person in contact with an adult outside a legitimate coaching relationship. This policy sets out how we do that and what clubs, coaches and athletes can expect.

2. Scope

This policy applies to everyone who uses the Services, to our staff and contractors, and to clubs that sign the Club Operating Agreement. It covers messaging, media and reels, public results, coach access to athlete data, wellbeing screening, FlowCoach, and reports of abuse or misconduct. It does not replace a club's own safeguarding policy or any legal or governing-body duty, which prevail where more protective.

3. Frameworks We Align With

Region Framework
United States U.S. Center for SafeSport Code and Minor Athlete Abuse Prevention Policies (MAAPP); Safe Sport Authorization Act mandatory reporting; state child abuse reporting laws; 18 U.S.C. § 2258A reporting to NCMEC
United Kingdom Children Act 1989 and 2004; Working Together to Safeguard Children; governing body safeguarding standards; UK Online Safety Act
Canada Universal Code of Conduct to Prevent and Address Maltreatment in Sport (UCCMS); provincial child protection laws
Australia National Principles for Child Safe Organisations; Sport Integrity Australia's National Integrity Framework; state reportable conduct schemes
New Zealand Children's Act 2014; Sport Integrity Commission guidance

4. Principles

  1. The welfare of the child or athlete is paramount.
  2. Every concern is taken seriously and acted on.
  3. Adults interact with minors only in observable, accountable ways.
  4. Only the minimum information needed is shared, and the athlete is told whenever an adult is told anything about their wellbeing.
  5. No safeguarding or wellbeing information is used in selection or any decision about an athlete's standing.

5. Roles

Role Responsibilities
Company Safeguarding Lead Owns this policy; receives and triages reports; makes required reports to authorities; reviews incidents; reachable at {SAFEGUARDING_EMAIL}
Club Wellbeing Lead and Backup Lead Receive threshold notifications; offer the athlete support; keep records
Club After-Hours Contact Ensures notifications received outside club hours reach the Lead or Backup the next business day
Club Designated Safeguarding Officer Receives escalations; ensures the club's roles are filled and working
Coaches Follow this policy, the club's policy and the Code of Conduct in the Club Operating Agreement; report concerns
Clubs Name and train their people; vet coaches; keep records; meet legal duties

6. Safeguards Built into the Platforms

6.1 Accounts. Minimum age 13. Under-18 accounts need guardian approval before any information is stored, and start with the most private settings.

6.2 Messaging. Messages are between an athlete and their own coach only. There is no athlete-to-athlete messaging, no group chat and no messaging with strangers. Every message between a coach and a minor is copied to the guardian, consistent with MAAPP electronic communication standards. Coaches may not move conversations with minors to private channels.

6.3 Media and reels. Images and video of minors may be shared only for a sporting purpose. Content that is sexual, suggestive, humiliating, or that shows a minor changing, showering or in a state of undress is prohibited and removed. Reels showing a minor may be published publicly only from the minor's own account or by the club, and a guardian can remove any content showing their child.

6.4 Public results. Any athlete or guardian can shorten the displayed name to first name and last initial.

6.5 Location. We do not display any user's location to others. Precise location is off by default for minors.

6.6 Coach access. Coaches see wellbeing data only as the athlete allows, never raw questionnaire answers, and may not use it for selection.

7. Reporting a Concern

7.1 Immediate danger. Call local emergency services first (Section 13).

7.2 How to report. Use the report option on any message, profile or piece of content, or email {SAFEGUARDING_EMAIL}. Reports can be made by anyone, including athletes, parents and people without an account.

7.3 What we do.

Step Action Timeframe
1 Acknowledge the report Within 24 hours
2 Triage; restrict content or accounts where a minor may be at risk Same day for risk to a minor
3 Preserve evidence At triage
4 Report apparent child sexual abuse material to NCMEC, and other matters to police, child protection services or the U.S. Center for SafeSport as the law requires As required by law, without delay
5 Inform the relevant club's Designated Safeguarding Officer, unless doing so could put someone at risk or prejudice an investigation Within 2 business days
6 Record the outcome and tell the reporter what we can On closure

7.4 Coaches' duties. Coaches and club staff who learn of possible abuse must follow their club's procedures and their legal and governing-body reporting duties. A report to us does not replace a report the law requires.

8. Wellbeing Screening and Threshold Events

8.1 What a threshold event is. The WHO-5 and GAD-7 screening questionnaires are available only through clubs at this time. They are not offered to individual Flowbase or SportsFlow accounts or through creators. A result at or beyond the threshold in the Club Operating Agreement means the athlete has reported enough difficulty that someone should check in. It is not a diagnosis or an emergency. Neither questionnaire asks about self-harm.

8.2 Procedure.

  1. The athlete and the Wellbeing Lead are notified at the same moment.
  2. If the notification cannot be delivered to the Lead, the Backup Lead is notified.
  3. If the Lead has not acknowledged it within 24 hours, the Backup Lead is notified.
  4. If it is still unacknowledged 24 hours later, the Designated Safeguarding Officer is notified.
  5. The Lead or Backup offers the athlete a private conversation within 1 business day.

The notification contains the athlete's name, the questionnaire, the date and the fact the threshold was met. The athlete sees the same notification. Undelivered notifications are retried and logged.

8.3 The conversation. The Lead offers a private conversation, does not ask for the score, and respects the athlete's choice about what to share. The Lead may refer the athlete to the club's support contacts, a physician, or the resources in Section 13.

8.4 Athletes under 18. The Lead decides whether to involve the parent or guardian, and does so unless that would put the athlete at risk. The athlete is told before the guardian is contacted. Clubs also follow their own policy and local law on young people's consent to health care.

8.5 Activation. Screening questionnaires are available only to clubs that have signed the Club Operating Agreement, named their Lead, Backup, After-Hours Contact and Designated Safeguarding Officer, and completed the exercise in Appendix A. They are not available to individual accounts or in creator mode at this time.

8.6 Failure to respond. Repeated failure to acknowledge notifications is a breach of the Club Operating Agreement. We switch screening off for that club until it is fixed.

9. FlowCoach and Disclosures of Risk

If a user's words to FlowCoach suggest a risk of self-harm, harm to others, or abuse, FlowCoach responds with crisis resources for the user's country and encourages them to contact a trusted adult or emergency services. FlowCoach does not notify any person. It is not monitored in real time.

If an athlete discloses abuse or a risk of serious harm to a coach or club member, that adult follows Section 7.

10. Records and Confidentiality

10.1 Threshold records contain the event, time, recipients, delivery status, acknowledgment time and the Lead's notes. Never the score or answers.

10.2 Safeguarding records are stored securely, accessible only to those with a role in this policy, and kept as set out in the Data Retention Schedule. Athletes and coaches cannot delete them.

10.3 Information is shared only with those who need it to protect someone, or as the law requires. It is never shared with coaches, selectors or teammates as such.

11. Athletes' Rights

Every athlete has the right to:

  1. Know, before taking a screening questionnaire, that a threshold event is shared and with whom;
  2. Be told at the same moment as the Lead, and see what the Lead saw;
  3. Decline a conversation. This is respected for adults unless there is a risk of serious harm;
  4. Request the safeguarding record about them from the club;
  5. Stop taking screening questionnaires at any time without any effect on their place in the club;
  6. Raise a concern about how they were treated with the club's Designated Safeguarding Officer or with us.

12. Training and Review

Club safeguarding personnel complete SafeSport Trained core training or their country's equivalent and acknowledge this policy in the Services before screening is enabled, and review it each year. Our staff with access to user reports complete safeguarding training on joining and annually. This policy is reviewed annually, after any serious incident, and whenever the law or the product changes.

13. Crisis and Emergency Resources

Country Emergency Crisis support Young people
United States 911 988 Suicide & Crisis Lifeline (call or text 988) Childhelp 1-800-422-4453
Canada 911 988 (call or text) Kids Help Phone 1-800-668-6868
United Kingdom 999 Samaritans 116 123 Childline 0800 1111
Ireland 112 or 999 Samaritans 116 123 Childline 1800 66 66 66
Australia 000 Lifeline 13 11 14 Kids Helpline 1800 55 1800
New Zealand 111 Need to talk? Call or text 1737 Youthline 0800 376 633
Elsewhere in the EU 112 Local services Child helpline 116 111

Appendix A. Tabletop Exercise

Completed before screening is enabled and every year after.

Scenario Expected result Pass/Fail
Test threshold event during club hours Lead and athlete notified together
Lead's email fails Backup notified
Threshold event after hours After-Hours Contact hands off at start of next business day
Notification left unacknowledged Backup at 24 hours, Designated Safeguarding Officer at 48 hours
Athlete asks for their record Club produces it, without any score
Report of a message concern involving a minor Club officer knows how to report to us and to authorities

Record the date, participants and any failures, and keep the record with the club's safeguarding records.