Safeguarding Policy

1. PURPOSE AND COMMITMENT

TRUE operates a reward-based insight panel that involves people aged 16–18 completing retail tasks (mystery shops, product trials, insight pulses, unboxing). Because our activities are directed at and carried out by minors, safeguarding is a core operating condition of the business, not an add-on.

TRUE is committed to:

Protecting the welfare of every panellist aged under 18.

Putting the safety of the young person ahead of commercial convenience in every decision.

Meeting our legal and ethical duties toward minors, including under UK GDPR / the Data (Use and Access) Act 2025, and safeguarding best practice.

This policy applies to all directors, staff, contractors, and anyone acting on behalf of TRUE.

2. SCOPE

This policy covers all panellists aged 16 and 17 (and, where relevant, any panellist who is 18 but was recruited or onboarded while under 18). It governs recruitment, onboarding, task design, task allocation, in-task conduct, content capture (photo/video), communication, and incident handling.

3. KEY ROLES AND RESPONSIBILITIES

DESIGNATED SAFEGUARDING LEAD (DSL): [Victoria Phillips]

Single point of accountability for safeguarding.

Receives and acts on all concerns; decides on referrals to external agencies.

Maintains the safeguarding record and reviews this policy annually.

Contact: [victoria@true-agency.co.uk / [07534991915].

ALL STAFF/CONTRACTORS must: complete safeguarding induction before contact with panellists; follow this policy; report any concern to the DSL without delay; never attempt to resolve a serious concern alone.

4. DEFINITIONS

Safeguarding: protecting minors from harm, abuse, neglect and exploitation, and promoting their welfare.

Panellist (minor): a registered participant aged 16 or 17.

Task: any activity TRUE asks a panellist to complete.

Age-restricted product/environment: anything a person under 18 cannot lawfully buy, use, or (where relevant) enter.

5. RECRUITMENT AND ONBOARDING SAFEGUARDS

5.1 Age verification. No one under 16 may join. Age is verified at sign-up by [chosen method — e.g. self-declared DOB PLUS a documented verification step]. Under-16 sign-ups are rejected and their data deleted.

5.2 Parental/guardian consent. No panellist under 18 is activated until verifiable parental/guardian consent is recorded (see the separate TRUE Parental Consent Process). Consent must be in place BEFORE any task is offered.

5.3 Staff vetting. Any TRUE staff member or contractor whose role involves [direct/regular contact with, or oversight of, minors] is subject to [appropriate DBS check level — to be confirmed with a safeguarding professional; the correct level depends on the exact nature of contact]. Vetting records are held securely.

5.4 Clear terms for the young person. Panellists receive a plain-English explanation of what they will and won't be asked to do, that participation is voluntary, and that they can stop at any time without penalty.

6. TASK DESIGN — HARD EXCLUSIONS

Panellists under 18 must NEVER be asked to buy, handle, trial, film, or seek out any of the following. These are absolute exclusions with no exceptions:

Alcohol.

Tobacco, cigarettes, vapes / e-cigarettes and related products.

Gambling, lottery, scratchcards, betting.

Knives, blades, or other bladed/offensive articles.

Fireworks, lighters, aerosols/solvents and other age-restricted items.

Pharmacy-only or age-restricted medicines.

Adult (18+) rated content, products or venues.

Any product, service or venue that a person under 18 cannot lawfully purchase or enter.

Every task template must pass an age-appropriateness check by [the DSL or a delegate] before it is issued. If in doubt, the task is not issued.

7. IN-TASK SAFETY

7.1 No isolation, no unsupervised adult contact. TRUE never directs a panellist into a one-to-one situation with an adult connected to TRUE or a client, into a private/back-of-house area, or anywhere they would be isolated. Tasks take place in normal, public, open retail spaces during standard trading hours.

7.2 Location and lone-working. [State the position: e.g. tasks are limited to public retail premises; panellists choose stores they can safely reach; a panellist is never required to travel to an unfamiliar or unsafe location to earn a reward.] REVIEWER: a lone-working / journey risk assessment for minors is required here.

7.3 Right to stop. A panellist may abandon any task at any point if they feel unsafe or uncomfortable, and still be treated fairly. No reward is ever conditional on a young person staying in a situation they want to leave.

7.4 No pressure mechanics. Reward and gamification must not pressure minors into more, riskier, or faster activity. Streaks, urgency and similar mechanics are reviewed against the DUAA "children's higher protection matters" and the ICO Children's Code.

8. COMMUNICATION AND CONDUCT

All communication with panellists happens through TRUE's official channels and is capable of being monitored/retained. No private/personal DMs from staff to a minor.

Staff maintain professional boundaries at all times; no personal relationships, no requests to meet, no contact outside approved channels.

Content and messaging aimed at under-18s uses age-appropriate language and never encourages secrecy from parents/guardians.

Any social recruitment content (Snapchat/TikTok/etc.) must pass a safeguarding review before publication.

9. CONTENT CAPTURE (PHOTO / VIDEO — e.g. UNBOXING)

Any capture of a minor's image, voice or video requires specific, informed consent from both the panellist and their parent/guardian (covered in the consent process).

Panellists are never asked to film themselves in a state, place, or manner that is unsafe or inappropriate.

Captured content is stored, used and retained only as described in the privacy information, and deleted on request/withdrawal where required.

10. RECOGNISING AND REPORTING CONCERNS

10.1 Everyone acting for TRUE has a duty to report. If you become aware of, or suspect, that a young person is at risk of harm — through a task, a communication, disclosed information, or any other route — you must tell the DSL immediately.

10.2 Do not investigate alone. Do not promise secrecy. Record what you saw/heard in the young person's own words as soon as possible.

10.3 Escalation. The DSL assesses each concern and decides on next steps, which may include contacting the parent/guardian, the police (999 in an emergency; 101 otherwise), or the relevant local authority children's services. Where there is an immediate risk to life, call 999 first.

10.4 Records. All concerns and actions are logged confidentially and securely, separately from routine panel data, and retained per the retention schedule.

11. DATA PROTECTION LINK

Handling minors' personal data is itself a safeguarding matter. TRUE processes panellist data in line with UK GDPR (as amended by the DUAA 2025), the ICO Children's Code, and the TRUE DPIA. A Data Protection Impact Assessment must be completed and kept current for all processing of minors' data.

13. TRAINING AND REVIEW

All staff/contractors complete safeguarding induction before contact with panellists, refreshed [annually].

This policy is reviewed at least [every 12 months], and immediately after any incident or relevant change in law.

Approved by: [Victoria Phillips] — Date: [28/08/2026].

TRUE — Where honesty sells.

Safeguarding comes first. Always.