Safeguarding Policy

The Hub Multisport Limited, trading as HubSport, provides online athlete development resources used by adults and by young people. Many of our users are children. This policy sets out how we protect young users, what we expect of them and of the adults responsible for them, how growth measurements should be taken, how our support channels work, and what to do if you have a concern. It applies to everyone who uses the platform and to everyone who works for or on behalf of HubSport.

HubSport is an advisory education and training platform. It provides programmes, resources and monitoring tools that help athletes and their families make informed decisions.

HubSport is not a medical or clinical service. Nothing on the platform is a diagnosis, a medical opinion, or a substitute for professional advice. Readiness scores, workload risk bands, wellbeing indices, assessment ratings and maturation outputs are informational prompts generated from what a user has entered. They are not clinical assessments and they must not be treated as such.

Any concern about health, injury, illness, growth, eating, or mental wellbeing should be taken to a GP or another suitably qualified professional. Our Strength and Conditioning, Nutrition and Mind Power 4 Success disclaimers set out the limits of each programme.

A young person under 18 can hold their own HubSport account. When they register, the platform identifies from their date of birth that they are under 18, requires the email address of a parent or guardian, and sends that adult an approval link. The account is not fully active until the parent or guardian has confirmed their consent through that link. We record when and how consent was given.

A parent or guardian can also hold profiles for children within their own account, for example to track growth in the Maturation Monitor.

In either case, an account is held by the athlete or by the parent or guardian of the athlete. Coaches, clubs, schools and other third parties cannot hold accounts containing another person's information. This means that responsibility for a young person's use of the platform always sits with an adult who has parental responsibility for them, either as the account holder or as the adult who consented to the account.

We ask parents and guardians who have consented to a young person's account to take an interest in how it is used, to keep their own email address current with us so that we can reach them, and to contact us if anything on the platform causes concern.

• The welfare of children and young people comes before every other consideration.
• We design the platform so that a young person's information is not visible to other users.
• We do not provide a young person's information to coaches, clubs or any other third party.
• Features that involve tracking or that would make a young person visible are off unless actively turned on.
• We collect the minimum information needed for each feature.
• We take any concern raised with us seriously, and we act on it.
• We follow the principles of the NSPCC Child Protection in Sport Unit and the Information Commissioner's Age Appropriate Design Code.

The Maturation Monitor requires physical measurements, including standing height, sitting height and body mass. Taking measurements of a child requires care.

Measurements of anyone under 18 must be taken by their parent or guardian, or with their parent or guardian present. They must not be taken by any other adult without a parent or guardian there.

Where a coach, practitioner or other adult is taking measurements of a young person, we expect all of the following.

• The parent or guardian is present throughout.
• Written consent has been obtained in advance from the person with legal responsibility for the young person.
• That written consent is retained by the person who obtained it. It is not uploaded to HubSport.
• The young person understands what is being measured and why, and knows they can stop at any point.
• Measurements are taken in an open setting, never behind a closed door or in a private space.
• The young person remains fully clothed. No measurement offered by HubSport requires otherwise.
• No photographs or video are taken.

The platform asks whether you are the athlete, or the parent or guardian. If you are neither, it sets out the requirements above and asks you to confirm they have been met. Those confirmations are recorded. They are a statement by you, and they do not reduce your own responsibility for how a measurement is taken.

Maturation outputs, including bio-banding classification, describe where a young person is in their growth. They are not a measure of ability, potential or worth, and they should never be used to decide whether a young person is selected, retained or released. They are estimates, with a meaningful margin of error at the individual level. Any concern arising from them should be discussed with a GP.

This is a safeguarding position and a legal one. A maturity classification is health data. Where an adult applies such a classification mechanically to decide whether a young person is selected, retained or allowed to take part, that is a decision with a similarly significant effect taken without meaningful human involvement, and UK GDPR permits decisions of that kind only in narrow circumstances. It is one of the reasons the platform does not provide these outputs to anyone other than the account holder.

A support chat button appears in the corner of every page. It is provided by a third party, Chatello. Anyone, including a young person, can type a message into it. Replies come either from an automated assistant or from a member of the HubSport support team.

This is the only channel on the platform through which a user can send a message. There is no messaging between users, no comments, and no way for one user to contact another. A young person cannot be contacted through the platform by another user or by anyone outside HubSport.

• The chat is for questions about the platform and accounts. HubSport support staff keep it to that.
• Support staff do not ask a young person for personal details beyond what is needed to resolve a platform question, do not ask about their health, body or wellbeing, and do not arrange contact with a young person outside the chat.
• If you are signed in, the chat provider receives your name, email address and user ID so that the conversation can be linked to your account. Conversations are stored by the chat provider, not by HubSport. Our Privacy Policy explains this in full.

We ask young people not to type health information, measurements or anything private into the chat, and we ask parents and guardians to make their child aware of this.

Most users interact with HubSport only through the platform. In some cases a user may meet a member of the HubSport team in person or by video call.

Where the user is under 18, a parent or guardian must be present for the whole of any face-to-face meeting or video call. We do not hold one-to-one sessions with a young person without a parent or guardian there.

Video calls are arranged through the parent or guardian's email address. We do not arrange contact with a young person through the support chat, through push notifications, or through social media.

HubSport is an online platform. Our staff do not have unsupervised contact with children, and any face-to-face or video contact takes place with a parent or guardian present, as set out in section 7. Support staff interact with young people only through the support chat, in the way set out in section 6. On that basis we do not currently require Disclosure and Barring Service checks for staff.

We keep this position under review. If the way we work changes, and in particular if any activity would involve unsupervised contact with a young person, we will introduce vetting appropriate to that activity before it begins.

The platform does not review what users enter and cannot detect that someone is unwell, injured or struggling. It will not raise an alert. If you are worried about an athlete's health, injury, growth, eating or mental wellbeing, whether prompted by something on the platform or not, please speak to a GP or another suitably qualified professional. Where the athlete is a young person, the parent or guardian should lead that conversation.

If you are concerned about your own or another person's immediate safety, contact the emergency services on 999. If you need to talk to someone, Samaritans can be reached free on 116 123 at any time, and Childline is available for anyone under 19 on 0800 1111.

A safeguarding concern is different from a health concern. It is any worry that a child or vulnerable person is being harmed, is at risk of harm, or has been treated in a way that is not acceptable. This includes anything arising from an adult connected to the platform, from something said in the support chat, or from something seen or experienced on HubSport.

Email info@hubsportonline.co.uk, marked for the attention of the safeguarding contact. Tell us what has happened, who is involved and when, as far as you know it. You do not need to be certain, and you do not need to investigate first. This inbox is monitored by The Hub Multisport Limited.

If a child is at immediate risk, do not wait for us. Contact the police on 999 or your local authority children's social care team.

• We acknowledge your message within five working days.
• The concern is reviewed by a member of the HubSport team.
• Where the concern relates to a young person's safety, we advise and support the parent or guardian in referring it to the appropriate authority, which will normally be the local authority children's social care team or the police.
• Where a child is at immediate risk, we will contact the police or children's social care ourselves without waiting.
• Where the concern relates to conduct on the platform, we may suspend or remove an account while we look into it.
• We keep a written record of the concern, what was decided and why, and what action was taken.

We are not a referral or investigative body. Our role is to respond promptly, to support the adult responsible for the young person, and to escalate to the proper authority where that is needed.

A young person's information is visible within their own account, to a parent or guardian on request, and to HubSport staff where they need it to run the platform, which includes viewing Athlete Assessment results through the administration portal and seeing support chat conversations. It is not visible to other users, and it is not provided to coaches, clubs, schools, academies or any other third party. Where an organisation has purchased a group subscription, it is told only how many of its seats have been taken up.

Access to the databases holding user information is limited to HubSport staff. Our Privacy Policy sets this out in full.

There are no social features. Users cannot see one another, message one another, or comment. There is no leaderboard. The platform holds no photographs of users, and there is no facility to upload an image, so no image of a child can be placed on the platform by anyone.

Push notifications, where a user has allowed them, contain only fixed reminder text and never any personal or health information. Marketing cookies are off unless accepted.

We ask parents and guardians to keep account credentials secure, to supervise a young person's use of the platform in a way appropriate to their age, and to talk to us if anything on the platform causes concern.

Records relating to a safeguarding concern are held securely by The Hub Multisport Limited outside the platform, separately from ordinary account information, with access limited to those who need it. Where the concern relates to a child, the record is retained until that individual's 25th birthday. This is longer than we keep anything else, and it is deliberate: a young person may need the record long after they have stopped using the platform. Retention periods for all other information are set out in our Privacy Policy.

This policy is reviewed on a rolling basis and updated whenever the platform changes in a way that affects young users, whenever a concern shows it needs to be clearer, and whenever relevant guidance or law changes. Material changes are published with a new effective date, and users are asked to accept them at their next sign-in.

HubSport: info@hubsportonline.co.uk

• NSPCC Helpline: 0808 800 5000
• Childline: 0800 1111
• NSPCC Child Protection in Sport Unit: thecpsu.org.uk
• In an emergency, call 999