Incusim Safeguarding Policy

Last updated: October 2026

1. Introduction

At Incusim (a More Techies company), we are committed to providing a safe and secure environment for all young people who take part in our programmes. This safeguarding policy explains how we protect the welfare of students aged 14–18 who participate in our virtual learning sessions.

Our duty of care is guided by:

• The Child Rights Act (CRA) 2003 (including relevant state-level domesticated Child Rights Laws)
• The National School Health Policy framework
• The Nigeria Data Protection Act (NDPA) 2023
• The Violence Against Persons (Prohibition) Act (VAPP) 2015

2. Purpose of This Policy

This policy ensures that:

• The welfare of children and young people is always the top priority
• All staff, mentors, and contractors understand their safeguarding responsibilities
• Concerns about a child's welfare are reported and acted on quickly

3. Scope

This policy applies to:

• All Incusim staff and contractors
• Mentors, guest speakers, and volunteers
• Any third-party providers delivering sessions to our students

4. Our Safeguarding Principles

We are committed to:

• Protecting children from harm, including physical, emotional, and sexual abuse, neglect, and online risks
• Promoting a safe learning environment, whether online or in-person
• Acting quickly and appropriately when concerns arise
• Respecting privacy, sharing information only when necessary for safeguarding purposes

5. Online Safety Measures

(for Virtual Classes)

We ensure that:

• All online sessions are conducted via secure, password-protected platforms
• Students are advised to join sessions from a shared family space (not bedrooms) where possible
• Cameras are used for engagement, but can be turned off at a student's or parent's request
• All chat functions are monitored by session leaders
• Recording of sessions by students is prohibited unless authorised by Incusim
• Only approved staff and mentors can share screens or control meeting tools

6. Safer Recruitment

• All staff, mentors, and contractors working directly with students are subject to mandatory Nigeria Police Clearance Certificates (PCC) vetting and verification
• References are taken and verified before engagement
• Safeguarding training is provided to all relevant team members

7. Recognising Signs of Abuse or Risk

Staff are trained to look out for indicators of:

• Physical injury
• Emotional distress
• Signs of neglect
• Concerning changes in behaviour
• Inappropriate online contact or grooming

8. Reporting Concerns

If a safeguarding concern is identified:

• It must be reported immediately to the Designated Safeguarding Lead (DSL)
• The DSL will assess the concern, take appropriate action, and, if necessary, contact the relevant local safeguarding authority or the police

9. Confidentiality & Data Protection

• All safeguarding records are stored securely and only accessible to authorised staff
• Only Incusim staff can award Incusim Points, and every award is recorded with the evidence held and the name of the person who verified it. Students cannot award or change points
• Students and their families control who sees a verified record: shared links can be switched off at any time, and a shared page never shows evidence files or a student's private passport writing
• A student's Incusim record is kept for up to five years after their last programme or award and is then reviewed for deletion, or deleted earlier on request (see our Privacy Policy)
• Personal data is handled in accordance with our Privacy Policy and UK GDPR regulations

10. Whistleblowing

Any staff member who has concerns about another member of staff's behaviour towards a student must report it immediately to the DSL or Managing Director. Reports will be taken seriously and handled with confidentiality.

11. Policy Review

This policy will be reviewed annually or sooner if there are significant changes in safeguarding legislation or in our operations.

12. Contact for External Help

(for Students & Parents)

If you are concerned about a child's safety, you can also contact:

• Cece Yara Child Helpline – 0800 800 8001 (Free, confidential, and available 24/7 via phone or WhatsApp)
• Lagos State Domestic and Sexual Violence Agency (DSVA) – 0800 033 3333 (Toll-free 24-hour helpline) or dial the USSD Short Code: *6820# on any mobile phone to report abuse instantly without internet or airtime.
• National Human Rights Commission (NHRC) – 6472 (Toll-Free Short Code) or 0800 647 2428
• Mirabel Centre (Sexual Assault Referral Centre) – 0815 577 0000 or 0818 724 3468
• NAPTIP (National Agency for the Prohibition of Trafficking in Persons) – 627 (Short Code) or 0703 000 0203

Incusim is committed to safeguarding and promoting the welfare of children and young people, and expects all staff, volunteers, and partners to share this commitment.