Data Protection & Safeguarding

Data Protection Policy

Version 1.5 · adopted 24 August 2026 · review due 31 August 2028

1. Purpose and Scope

This policy sets out how Missing Link Martial Arts Ltd and its subsidiaries (“the Company”) collect, use, store and dispose of personal data. It applies to all directors, staff, instructors, assistant instructors, volunteers and contractors.

It replaces the website privacy notice previously generated by a third-party template tool, which did not accurately describe the Company’s processing.

This policy sits alongside the Safeguarding Children and Adults at Risk Policy. Where the two touch — on safeguarding records, medical information and images — they are intended to be read together.

1.1 Controller details

There is a single data controller. Missing Link Martial Arts Ltd is the controller for all Company activity in both England and Scotland, and for all of the websites listed above. The Manchester address is the controller’s address for all of it; the Scottish operations are not a separate controller and do not have a separate registration.

1.2 A note on scope

Teaching children is not the Company’s core activity. The Company’s purpose is researching and teaching martial arts to students of all ages. Children are among those students, and while that remains the case the Company processes children’s data and this policy applies in full to that processing. Nothing in this policy is contingent on the volume of children taught.

2. Roles and Responsibilities

The Company is not required to appoint a statutory Data Protection Officer. Responsibility is allocated as follows.

3. Data Protection Principles

The Company applies the six principles of UK GDPR Article 5. Personal data must be:

1. processed lawfully, fairly and transparently;

2. collected for specified, explicit and legitimate purposes, and not used in a way incompatible with those purposes;

3. adequate, relevant and limited to what is necessary;

4. accurate and, where necessary, kept up to date;

5. kept in a form permitting identification for no longer than necessary; and

6. processed securely.

The Company is accountable for demonstrating compliance with all six.

4. What Personal Data the Company Processes

The Company does process special category data. Health data and safeguarding records are special category data under Article 9, and vetting and allegation records are criminal offence data under Article 10. Any statement to the contrary in an earlier notice was incorrect.

5. Lawful Bases

5.1 General personal data (Article 6)

Recognised legitimate interests. The Data (Use and Access) Act 2025 inserted a new lawful basis at Article 6(1)(ea), in force since 5 February 2026. Where processing is necessary for one of the five purposes in Annex 1 to the UK GDPR — which include safeguarding vulnerable individuals, including children and adults at risk, and the prevention or detection of crime — no balancing test is required. The basis is available to private and third-sector organisations but not to public authorities. The Company relies on it for safeguarding and for vetting.

5.2 Special category data (Article 9)

5.3 Criminal offence data (Article 10)

DBS and PVG results, self-declarations, allegations and barring referrals are criminal offence data. The Company processes these under the conditions at paragraph 18 (safeguarding) and paragraph 10 (preventing or detecting unlawful acts) of Schedule 1 to the Data Protection Act 2018.

5.4 Children and consent

• Where consent is the basis and the student is under 13, consent is given by a person with parental responsibility.

• Where the student is 13 to 15, the Company seeks parental consent as a matter of policy, and explains the processing to the child in terms they can understand.

• A student aged 16 or over may give their own consent, provided they clearly understand what they are agreeing to.

• Consent is never bundled into the membership terms. It is a separate, positive opt-in, and it can be withdrawn at any time without affecting the student’s ability to train.

The Company is mindful that children may be less aware of the risks of sharing their data, and gives their interests additional weight in any balancing exercise.

5.5 Health information and the limits of consent

Consent under UK GDPR must be freely given. A consent that is a precondition of receiving the service is not freely given, and the Company does not treat it as one. Three points follow, and they are explained to members and parents before consent is sought.

• Providing health information is optional. A student or parent may decline to give health information, or give only part of it. The Company does not refuse membership on that ground alone, and consent may be withdrawn at any time.

• Safety duties are separate from data protection. The Company has independent duties under health and safety law and a general duty of care. Where it is aware of a risk it cannot manage, it may be unable to allow a student to take part in some or all activities. That restriction arises from the safety duty and would apply equally if the information had never been requested. It is not a penalty for a data protection decision, and it is explained in advance so the choice is an informed one.

• Emergencies do not depend on consent. Where there is a risk to life or serious harm, the Company acts under Article 9(2)(c), vital interests. Withdrawing consent therefore never prevents the Company from acting to protect a student.

Consent is recorded, is granular where a student has more than one condition, and is reviewed annually so that the information held stays accurate.

6. Images

Photography and filming take place during training, and are used both internally for coaching and externally for promotion.

Permission is granted as part of membership at sign-up, and covers publication. The Company does not operate a separate opt-in. Members, parents and carers are told clearly before joining that photography and video take place and how they are used.

The lawful basis is legitimate interests under Article 6(1)(f), with the right to object under Article 21 — not consent. Consent under UK GDPR requires a clear affirmative opt-in and cannot be bundled into membership terms, so it is not the basis the Company relies on. Legitimate interests requires instead that the Company has assessed the balance between its interests and the individual’s, and that objections are honoured. That assessment is recorded in a written Legitimate Interests Assessment, which gives children’s interests specific weight and is reviewed alongside this policy.

Accordingly:

• Any member, parent or carer may object at any time, without giving a reason, by telling the DSL or the Company office. The objection is recorded and honoured from that point, and existing images are removed from the Company’s own channels on request.

• Objecting has no effect on the member’s ability to train.

• The Company does not publish personally identifiable images without asking first.

• Full names are never published alongside an image of a child.

• The Company cannot recall material already shared onward by others, and says so when permission is taken.

• Internal coaching footage is not published, not shared outside the Company, stored securely, and deleted when no longer needed.

• Safeguarding Policy Section 14.3 provides a confidential route for a child who must not be photographed at all. That route exists regardless of anything in the membership terms.

7. Sharing Information

The Company shares personal data only where there is a lawful basis. Recipients may include:

• children’s social care, adult social care, the police, the LADO or a local authority child protection team, where safeguarding requires it;

• the DBS or Disclosure Scotland, where the duty to refer applies;

• the Health and Safety Executive, for RIDDOR-reportable incidents;

• emergency services and healthcare professionals, where a student needs urgent care;

• insurers, where a claim or notification arises; and

• a martial arts governing body or association, where the Company is affiliated and the rules require it.

Data protection is not a barrier to sharing information in order to keep someone safe. Where a child or adult is at risk, the Company shares what is necessary, with the right people, without delay, and records what was shared and why. Concern about data protection is never a reason to withhold or delay a safeguarding referral.

7.1 Processors

The Company uses third parties who process personal data on its behalf. Each must be covered by a written contract meeting Article 28.

The Company’s own server. The membership system and The Learning Site, the Company’s instructor training platform, are not third-party services and are not operated by a processor. They run on the Company’s own server: privately owned by Martin Miketta, Director, held locally, with encrypted off-site backup. The equipment is dedicated business equipment, bought and maintained privately and used solely for the Company’s purposes; it is not a personal device, a personal email account or a personal cloud account within the meaning of Section 9, and no personal use is made of it. Safeguarding, accident, concussion, low-level concern and vetting records are held on this server on an encrypted volume, together with membership and contact, training and employment records.

Copies of the records. There are two copies of the encrypted backup outside the server itself. The first is the off-site copy held with Google Drive, listed above. The second is the cold-storage archive described at Annex B, which is held offline and is not operated by any processor. Neither copy is readable by anyone who does not hold the encryption keys.

Microsoft OneDrive and Proton Drive are no longer used. The records formerly held there are on the Company’s own server, with encrypted off-site backup.

International transfers. The Company uses processors outside the UK only where UK adequacy regulations cover the transfer, or where an appropriate safeguard such as an International Data Transfer Agreement or the Addendum to the EU Standard Contractual Clauses is in place. Canada is covered by adequacy regulations, but only partially: adequacy applies solely where the recipient is subject to PIPEDA, which covers private-sector organisations acting in the course of commercial activities. Before relying on it, the Company checks that the specific recipient falls within PIPEDA’s scope.

Transfer safeguards. For Anthropic PBC, Google LLC and Google Drive, the Company relies on the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum, as incorporated in each provider’s standard data processing terms. Where a provider offers no transfer safeguard at all, the Company does not use that provider.

8. Retention

Personal data is kept no longer than necessary. The schedule at Annex B governs. Two points are worth stating in the body of this policy because they are frequently misunderstood.

Safeguarding records are not deleted on request, and not deleted at 25. The Crime and Policing Act 2026 removed the three-year limitation period for civil claims arising from child sexual abuse and reversed the burden of proof on whether a fair trial is possible. Claims may now be brought at any point in a person’s life. The Company must be able to evidence what it knew and what it did. Child protection records are therefore retained for 75 years from the date of the record.

The right to erasure does not override this. Where the Company processes safeguarding data under the substantial public interest condition, or to comply with a legal obligation, erasure does not apply. The Company will explain this in writing to anyone who requests deletion of a safeguarding record.

9. Security

• Safeguarding records are kept separately from general membership records, with access limited to the DSL and Deputy DSL.

• Safeguarding, accident, concussion, low-level concern and vetting records are held on an encrypted volume on the Company’s own server, described at Section 7.1.

• Those records are backed up off-site to Google Drive in encrypted form. Google Drive receives only encrypted data and cannot read its contents. The protection relied on is the encryption, not the absence of transfer.

• A copy of the encrypted backup is written to the cold-storage archive with every backup run, and at least once a month. The archive is held offline. See Annex B.

• Membership and contact, training and employment records are held on the same server and backed up in the same way. Microsoft OneDrive and Proton Drive are no longer used.

• Encryption keys and passphrases are held in Proton Pass.

• Devices used to access Company records are password-protected and encrypted.

• Paper records are kept in a locked cabinet and are not left unattended at venues.

• Member data is never stored on a personal device, personal email account or personal cloud account.

• Access follows need-to-know. Medical information is shared with the staff working directly with that student and no further.

• Access rights are reviewed when anyone joins or leaves, and shared credentials are changed on departure.

• Registers of attendance and contact details are not left visible at venues.

10. Individual Rights

Individuals have the right to be informed; of access; to rectification; to erasure; to restrict processing; to data portability; to object; and not to be subject to automated decision-making. The Company does not carry out automated decision-making or profiling.

10.1 Handling a request

7. Any request — however it arrives, including verbally — is passed to the data protection contact the same day. A request does not have to mention data protection to be valid.

8. Verify the identity of the requester. Where the request concerns a child, establish who is entitled to make it: a person with parental responsibility may request on behalf of a child who is not old enough to act for themselves, but a child who understands their rights may request in their own name, and their wishes are respected.

9. Respond within one calendar month. Following the Data (Use and Access) Act 2025, where the Company reasonably requires identity verification or clarification of a broad request, the clock pauses until that information is supplied. The pause must be genuine and promptly raised — it is not a means of extending the period. The month may also be extended by two further months for complex requests, provided the requester is told within the first month.

10. Redact third-party personal data before releasing anything.

11. Take advice before releasing any safeguarding record. Exemptions may apply where disclosure would be likely to cause serious harm, would prejudice the prevention or detection of crime, or would identify a person who reported a concern. Record the reasoning either way.

The Company keeps a log of every request and its outcome.

11. Personal Data Breaches

A personal data breach is any incident leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. A lost phone with member contacts on it is a breach. An email sent to the wrong parent is a breach.

12. Report it immediately. Anyone who becomes aware of a suspected breach tells the data protection contact at once — not at the end of the day, and not after trying to fix it first. Nobody is penalised for reporting a breach they caused.

13. Contain. Take immediate steps to limit the damage: recall the email, remotely wipe the device, revoke the access.

14. Assess. The data protection contact assesses the risk to the individuals affected, and records the assessment.

15. Report to the ICO within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to people’s rights and freedoms. The 72 hours runs from awareness, not from the end of the investigation. If in doubt, report.

16. Tell the individuals without undue delay where the breach is likely to result in a high risk to them.

17. Record. Every breach is recorded, including those not reported to the ICO, with the reasoning. The Board is informed of every breach.

12. Complaints

The Data (Use and Access) Act 2025 requires controllers to operate a procedure allowing individuals to complain about how their personal data is handled. This requirement commenced on 19 June 2026 and applies to the Company.

• A complaint may be made in any form, including verbally, to the data protection contact. It does not have to use the word “complaint” or cite any legislation to count as one.

• The Company acknowledges receipt within 30 days.

• The Company takes appropriate steps to respond — investigating the substance and informing the complainant of the outcome — without undue delay.

• Every complaint and its outcome is logged, and the log is reviewed at each annual policy review.

• A complainant may go to the Information Commissioner at any time. The Company does not require internal routes to be exhausted first, and says so when acknowledging a complaint.

13. Training and Review

• All staff and volunteers receive data protection awareness as part of induction, covering: what personal data is, the rules on devices and accounts, how to recognise and report a breach, and how to pass on a rights request.

• Completion is recorded against each person in the vetting register.

• This policy is reviewed every 12 months alongside the Safeguarding Policy, and sooner following any breach, any change in the law, or any change to the systems the Company uses.

Approved by the Board of Missing Link Martial Arts Ltd and its subsidiaries.

Signed: …………………………………………………… Date: ………………….

Annex A — Appropriate Policy Document

Required by paragraph 5 of Part 4 of Schedule 1 to the Data Protection Act 2018, where special category or criminal offence data is processed under a Schedule 1 condition. Must be retained until six months after the processing ceases, reviewed and updated as necessary, and made available to the Information Commissioner on request.

A1. Conditions relied upon

A point commonly got wrong: the recognised legitimate interests basis introduced by the Data (Use and Access) Act 2025 operates at Article 6 only. It does not alter Article 9 or the Schedule 1 conditions, and it does not remove the need for this Appropriate Policy Document. Where special category data is involved, the pre-existing protections apply in full.

The Company is satisfied that this processing is necessary for reasons of substantial public interest: it cannot protect children and adults at risk without recording and acting on concerns, and it cannot meet its legal obligations on vetting and barring without processing criminal offence data.

A2. Compliance with the principles

A3. Retention and erasure

Retention of special category and criminal offence data is set out at Annex B. The Company records the date each safeguarding record was created and the date it becomes due for destruction. Destruction is secure — shredding for paper, permanent deletion including from backups for electronic records — and is recorded.

A4. Review

This Appropriate Policy Document is reviewed at least annually, and whenever the Company’s processing changes. It is retained until six months after the relevant processing ceases.

Annex B — Retention Schedule

Long-term archive. Retention of 75 years cannot be delivered by a commercial cloud subscription alone. Platform closure, account lapse, format obsolescence and simple corporate churn all operate on a far shorter timescale, and synchronisation between cloud services provides redundancy against loss rather than longevity — a deletion or a lapsed subscription propagates to every copy.

The Company therefore maintains a cold-storage archive, held offline and independently of the Google Drive off-site copy. A copy of the encrypted backup is written to the archive with every backup run, and at least once a month. Together with the server and the off-site copy, this gives three copies of the child protection records, of which one is offline and beyond the reach of any account lapse, accidental deletion or provider decision.

The archive is verified by restoring and reading from it at least once a year. An archive that has never been read is not known to be an archive, and the verification is what makes the other two copies worth having.

Annex C — Breach Report Form

Complete as soon as a breach is suspected. Do not wait until the facts are complete — the 72-hour clock runs from awareness.

Date and time the breach was discovered

Discovered by

What happened

What personal data was involved (categories and approximate numbers)

Were children or safeguarding records involved?

Who is affected, and how many people

Containment action taken, and when

Likely consequences for the individuals affected

Risk assessment — low / high, and why

Reportable to the ICO? (Yes / No) — and reasoning either way

If reported: date, time, ICO reference

Individuals informed? Date and method

What will be changed to prevent a recurrence

Board informed — date

Completed by / date

Safeguarding Children and Adults at Risk Policy

Version 4.3 · adopted 16 October 2026 · review due 31 August 2027

1. Introduction and Scope

Missing Link Martial Arts Ltd and its subsidiaries (“the Company”) research and teach martial arts, following the concept of the Missing Link Martial Arts Community.

The Company operates from Piccadilly Business Centre, Unit C Aldow Enterprise Park, Blackett Street, Manchester M12 6AE, and delivers activities in England, Scotland and Wales. Where the law differs between jurisdictions, this policy states the requirement for each. Where the requirement is stricter in one jurisdiction, the Company applies the stricter standard across the whole organisation unless stated otherwise.

This policy applies to all directors, managers, staff, instructors, assistant instructors, volunteers, students in positions of responsibility, contractors and anyone else acting on behalf of the Company. Every such person is expected to know this policy, comply with it, and sign the Code of Conduct at Appendix C.

Activities covered: martial arts training, seminars, events, workshops, gradings, competitions, and connected activities, whether delivered at the Company’s own premises, at hired venues, in schools, or online.

2. Purpose and Principles

The Company believes no child or adult at risk should experience abuse or harm. This policy sets out how we prevent harm, how we recognise it, and what we do when we suspect it.

The Company recognises that:

• the welfare of the child is paramount;

• all children, regardless of race, gender, religious belief, disability, age, sexual orientation or identity, have an equal right to protection from harm;

• some children are more vulnerable to harm because of their circumstances, prior experiences, communication needs or level of dependency;

• working openly with children, young people, parents, carers and other agencies is essential to protecting wellbeing; and

• safeguarding is everyone’s responsibility, not only the Designated Safeguarding Lead’s.

We also recognise that it is not in children’s interests to exaggerate everyday risk. Our aim is that children train in an environment that is demanding, rewarding and safe — not one that is risk-averse to the point of being pointless.

3. Legal and Regulatory Framework

This policy has been drawn up in accordance with the legislation and guidance applicable in the jurisdictions in which the Company operates. Principally:

England

• Children Act 1989 and Children Act 2004

• Working Together to Safeguard Children 2026 (statutory guidance, published 18 March 2026, replacing the 2023 edition)

• Keeping Children Safe in Education 2026 (in force 1 September 2026) — applicable where we deliver on school premises, and used as a benchmark elsewhere

• Crime and Policing Act 2026 — mandatory reporting duty for child sexual abuse; removal of the supervision exemption from regulated activity; removal of the limitation period for child sexual abuse civil claims

• Safeguarding Vulnerable Groups Act 2006 (as amended)

• Sexual Offences Act 2003, as amended by the Police, Crime, Sentencing and Courts Act 2022 (positions of trust — sports coaches)

• Care Act 2014 (adults at risk)

• Keeping children safe during community activities, after-school clubs and tuition (DfE non-statutory guidance for out-of-school settings)

Wales

• Social Services and Well-being (Wales) Act 2014 — the foundational safeguarding law in Wales. Unlike England, a single Act covers both children and adults at risk.

• Wales Safeguarding Procedures — the national procedures. Section 5, covering allegations and concerns about practitioners and those in positions of trust, was revised in 2026.

• Working Together to Safeguard People (Welsh Government), Volumes 1–6 — in particular Volume 5, handling individual cases to protect children at risk

• Violence against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015

• Children Act 1989 (applies in England and Wales)

• Keeping Learners Safe (Welsh Government) — applicable where we deliver on school premises in Wales

Scotland

• Children (Scotland) Act 1995 and Children and Young People (Scotland) Act 2014

• National Guidance for Child Protection in Scotland 2021 (updated 2023)

• Protection of Vulnerable Groups (Scotland) Act 2007 and Disclosure (Scotland) Act 2020

• Adult Support and Protection (Scotland) Act 2007

• Children (Equal Protection from Assault) (Scotland) Act 2019

• Sexual Offences (Scotland) Act 2009

UK-wide

• UK GDPR and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025

• Equality Act 2010

• Health and Safety at Work etc. Act 1974; PUWER 1998; COSHH 2002

• Public Interest Disclosure Act 1998 (whistleblowing)

• UK Concussion Guidelines for Non-Elite (Grassroots) Sport (November 2024 update); Scottish Sports Concussion Guidance 2024

• Safeguarding Code in Martial Arts (Sport England) — adopted by the Company as its sector standard

Note on jurisdiction: Working Together to Safeguard Children 2026 and Keeping Children Safe in Education 2026 are England-only. The Care Act 2014 is England-only. The mandatory reporting duty in the Crime and Policing Act 2026 applies in England only — see Section 17.1. Enhanced DBS checks, the duty to refer to the DBS, the positions of trust provisions of the Sexual Offences Act 2003 and the removal of the limitation period for child sexual abuse claims all apply across England and Wales.

Note on Prevent: the Company is not a specified authority under the Counter-Terrorism and Security Act 2015 and does not hold the statutory Prevent duty. We nevertheless expect staff to be alert to radicalisation as a safeguarding concern and to report it through the routes in Section 17.

4. Roles and Responsibilities

4.1 Named post-holders

Where a concern relates to the DSL, it is reported to the Board safeguarding contact or the Deputy DSL, either of whom may act without the DSL’s involvement or knowledge.

4.2 Post-holders who are also serving police officers

The following applies to any post-holder in the same position. - The role is held in a personal capacity. A post-holder who is a serving officer acts as a volunteer of the Company, not in a policing capacity, and does not represent Police Scotland or any other force when acting for the Company.

• Police systems are never used for Company purposes. No post-holder may access or ask a colleague to access police systems, databases or intelligence to check on any student, parent, applicant, member of staff or volunteer. Accessing police information for a non-policing purpose is a criminal offence under section 170 of the Data Protection Act 2018 as well as a serious disciplinary matter. This rule exists to protect the post-holder as much as the Company.

• Vetting goes through the proper route only. Suitability is established through PVG or DBS and the process at Section 5. It is never established through informal police enquiry.

• Reports go through public channels. Where a matter must be reported to the police, it is reported by 999, 101 or a formal referral, so that it enters the system with a reference number and a record. It is not passed informally to a colleague, however much quicker that would be. An informal report leaves the Company unable to evidence that it reported at all.

• Conflict of interest. Where a post-holder has any personal or professional involvement in a matter, or where their force is investigating it, they step back and the DSL or Board safeguarding contact takes it. The LADO or local authority process is followed exactly as it would be otherwise.

• Declaration to their force. The post-holder notifies their own force of this voluntary role in line with its business interests or secondary occupation policy, and confirms to the Board that they have done so.

4.3 Independence in a small organisation

The Company has a single director, who is the Deputy Safeguarding Lead. This is stated plainly because a policy that implies oversight the Company cannot provide is worse than one that is honest about its limits.

The Board safeguarding contact is the Chief Instructor, not a director. He provides a second internal route, and naming him is better than having none. But he is engaged by the Company and works under the Deputy DSL, so he cannot be treated as an independent check on the Deputy DSL, and the Company does not claim otherwise.

The independent route is therefore external, and it is available to everyone without permission from anyone.

• Anyone — student, parent, instructor, volunteer or member of staff — may contact the LADO, the local authority, the police or the NSPCC directly at any time. No internal report, permission or notification is required first. The contacts for all three jurisdictions are at Section 23 and are displayed at every venue.

• Where a concern relates to the DSL, the external route is the primary one, not the fallback. The Board safeguarding contact or Deputy DSL contacts the LADO or Designated Officer for Safeguarding (England and Wales) or the local authority child protection team (Scotland) directly, and does not inform the DSL first.

• The DSL himself is the least conflicted internal route. He is a volunteer rather than an employee, so he is not economically dependent on the DSL.

• No one is penalised for going outside. Raising a concern externally, in good faith, is expressly protected under Section 20 and can never be treated as disloyalty or as a disciplinary matter.

The Company keeps under review whether to appoint an additional director or an external safeguarding adviser to provide genuine independent oversight. Affiliation to a martial arts association offering safeguarding escalation support would achieve the same thing.

5. Safer Recruitment and Vetting

Criminal record checking is necessary but not sufficient. Every appointment to a role involving contact with children follows the full process below.

5.1 Recruitment process

1. Role description that states the safeguarding responsibilities of the post.

2. Written application or record of appointment, including a full history with any gaps explained.

3. Self-declaration of any criminal record, caution, investigation, disciplinary finding, or barring in any jurisdiction.

4. Verification of identity and of any martial arts or coaching qualifications claimed.

5. At least two references, one of which should be from a previous role involving children where one exists. References are taken up before the person starts.

6. Interview or structured conversation covering attitudes to child safety, boundaries and physical contact.

7. Criminal record check at the level required by Section 5.2, obtained and seen before the person starts.

8. Induction covering this policy and the Code of Conduct, and a probationary period with supervised delivery.

5.2 Criminal record checks

Company standard: every instructor, assistant instructor, volunteer and member of staff who has contact with children holds a current check at the highest level for which they are eligible, whether or not they are supervised, and a check is in place before they begin.

Scotland. Membership of the Protecting Vulnerable Groups (PVG) scheme has been a legal requirement since 1 April 2025. Since 1 July 2025 it is a criminal offence both for an individual to carry out a regulated role without PVG membership, and for an organisation to offer a regulated role to a person who is not a member. This applies to paid and unpaid roles, and to trial sessions. Coaching children in martial arts is a regulated role. No person may deliver, assist with, or trial in any Scottish session until the Company has received confirmation of their PVG scheme membership.

Disclosure levels in Scotland are now Level 1, Level 2, and Level 2 with barred list check, replacing the former basic, standard and enhanced disclosures. “Regulated work” is now “regulated roles”. PVG membership is no longer held for life.

England and Wales. Enhanced DBS check with children’s barred list check. The Disclosure and Barring Service covers both jurisdictions and the requirement is identical in each. The Crime and Policing Act 2026 removes the day-to-day supervision exemption from the definition of regulated activity, so people working closely and frequently with children on a supervised basis — including assistant instructors and regular helpers — are now eligible for the highest level of check. The Company checks them at that level.

5.3 Duty to refer

Where a person is dismissed, removed from a role, or would have been removed had they not resigned, because they have harmed a child or pose a risk of harm, the Company has a legal duty to refer them to the Disclosure and Barring Service (England and Wales) or Disclosure Scotland. Following the Crime and Policing Act 2026 this duty now also applies to people in supervised roles. The referral is made by the DSL with the Board’s knowledge, and is made in addition to any referral to the local authority or the police — not instead of it.

5.4 Supervision

New instructors and assistants deliver under the supervision of an experienced instructor throughout their probationary period. Supervision arrangements are recorded. Supervision does not reduce the level of criminal record check required.

6. Training

Safeguarding training is delivered internally by the Company. Completion is recorded against each person in the vetting register — the Company does not maintain a separate training log. The following minimum standards apply.

No person delivers or assists with a session involving children until their safeguarding induction is complete and recorded.

7. Risks to Children

It is important not to exaggerate the dangers children face in everyday life. There are, however, real situations in which children need protection, including but not limited to:

• sexual abuse, sexual exploitation and grooming (in person and online);

• physical and emotional abuse, and neglect;

• domestic abuse, including where a child sees, hears or experiences its effects;

• inappropriate supervision by staff or volunteers;

• bullying and cyberbullying; child-on-child abuse, including sexual harassment and sexual violence;

• victimisation and discrimination;

• self-harm and mental ill health;

• unsafe environments, unsafe training practice and head injury;

• criminal exploitation, including county lines;

• radicalisation; and

• online harms, including image-based abuse and AI-generated sexual imagery.

8. Supervision, Ratios and One-to-One Contact

Children under 16 are not left at Company sessions unaccompanied. A responsible adult over 18 brings the child, remains contactable, and collects the child afterwards. Young people aged 16 or 17 may attend unaccompanied where a parent or carer has provided written consent and a contactable mobile number.

For any session or event, the Company records the child’s name, age, address, the names of parents or carers, contactable numbers, and relevant medical information before the child takes part.

8.1 One-to-one contact

The Company does not operate a one-instructor-to-one-child model. Sessions are delivered to groups, with more than one adult present wherever reasonably possible.

Where individual instruction is genuinely necessary — for example correcting an individual technique, a grading, or a private lesson requested by a parent — all of the following apply:

• it takes place in an open, visible area of the training space, never behind a closed door or out of sight of others;

• another adult is present in the venue and knows it is happening;

• the parent or carer is informed in advance and may attend; and

• it is recorded in the session record.

Sufficient adults must be present at every session for one adult to deal with an emergency while another supervises the remaining children.

8.2 Changing areas, toilets and transport

• No adult supervises a child alone in a changing area or toilet. Where supervision is needed, two adults are present.

• No member of staff or volunteer transports a child alone in a vehicle, other than in an emergency. Where an emergency requires it, the DSL is informed the same day and the journey is recorded.

• Children change in areas appropriate to their age and sex. Where adults and children share a changing area, adults change at separate times.

• Photography and filming in changing areas and toilets is prohibited absolutely, including by parents and members. Mobile phones are not used in those areas.

9. Physical Contact in Martial Arts Instruction

Martial arts involve physical contact. Instruction requires demonstration, adjustment of posture, pad work, partner drills and controlled sparring. Bruises and minor injuries occur. Members and parents are told this clearly at sign-up, and it is a normal and accepted part of training.

The Company’s governing rule is that

the student or training partner defines what is acceptable for them. Every training partner and every instructor is responsible for their own actions and for being aware of the individual boundaries of the person they are training with.

This rule applies in both directions and at all levels of the organisation. In addition:

• Responsibility sits with the adult. A child may not feel able to object to an adult instructor, particularly a senior one. Where an adult is training with or instructing a child, responsibility for staying within appropriate limits rests entirely with the adult. An instructor may never rely on a child not having objected as evidence that contact was welcome.

• Explain before you touch. Contact used in instruction is explained first — what will happen, why, and where — and is the minimum necessary to teach the technique safely.

• Stop means stop. Any indication that a student wants contact to stop — verbal, a tap, or physical withdrawal — is respected immediately and without question or comment.

• Public and purposeful. Contact takes place in the open training area, in view of others, and is never prolonged beyond the instructional purpose.

• Adjust for the individual, do not expect the individual to adjust. Some students — including autistic students and students with sensory processing differences, communication needs or a history of trauma — experience touch differently, and may find it difficult to say so. Finding a way to teach the technique within that student’s limits is the instructor’s job, not the student’s. Where a student’s needs are known, the approach is agreed with them and their parent or carer in advance and shared with the instructors who teach them.

• Pairing. Instructors give attention to age, size, experience and individual needs when pairing students, and supervise mixed-age or mixed-size pairings directly.

• Injuries are recorded. An injury arising in instruction, training or sparring is recorded where it meets the threshold at Section 13.3. The same threshold applies throughout this policy. The record is made in the accident book and is available to the DSL.

If any student, parent or member of staff is uncomfortable with contact they have seen or experienced, they should raise it with the DSL. Raising such a concern is welcomed and will never be treated as disloyalty to an instructor.

10. Positions of Trust and Personal Relationships

An adult who coaches, teaches, trains, supervises or instructs a young person on a regular basis holds a position of trust over that young person.

Company rule: no instructor, assistant instructor, volunteer or member of staff aged 18 or over may enter into a sexual or romantic relationship with any student under the age of 18, anywhere in the organisation, regardless of the age of consent and regardless of jurisdiction. Breach is gross misconduct and will result in dismissal and referral to the DBS or Disclosure Scotland.

England and Wales. This is also a criminal offence. The Police, Crime, Sentencing and Courts Act 2022 amended the Sexual Offences Act 2003, which extends to England and Wales, so that a person who coaches, teaches, trains, supervises or instructs another in a sport on a regular basis, and knows that they do so, holds a position of trust. Sexual activity with a 16 or 17 year old in that position is an offence irrespective of consent.

Scotland. The positions of trust provisions in the Sexual Offences (Scotland) Act 2009 have not been extended to sports settings, so the same conduct may not attract the same criminal liability. This makes no difference to the Company rule above, which applies identically in Scotland.

Any member of staff or volunteer who is or becomes aware of a personal relationship that could give rise to a conflict of interest — including a pre-existing family relationship with a student — must declare it to the DSL.

10.1 Relationships with adult students

A relationship between an instructor and an adult student is not unlawful, and the Company does not prohibit one. It does, however, create a power imbalance and a conflict of interest, because instructors assess technique, award grades, and decide who trains with whom.

• An instructor who enters into a personal relationship with an adult student declares it to the DSL. The declaration is recorded and treated confidentially.

• The instructor takes no part in grading, assessing or making disciplinary decisions about that student. Another instructor is assigned.

• An instructor never uses their position — grading, opportunities, seniority, or access to instruction — to initiate or sustain a personal relationship with any student.

• Persistent unwanted attention towards a student of any age is misconduct and is dealt with under the disciplinary procedure.

The Company teaches martial arts. Training sessions are not a social or dating environment, and instructors are expected to conduct themselves accordingly.

11. Managing Behaviour, Discipline and Restraint

• Corporal punishment is prohibited absolutely, in any form, in any Company setting. Physical punishment of children is unlawful in Scotland under the Children (Equal Protection from Assault) (Scotland) Act 2019.

• Physical restraint may be used only where it is necessary to prevent injury to a person or serious damage to property, and only to the minimum degree and for the minimum time necessary. Martial arts techniques are never used as a means of discipline.

• Every instance of restraint is recorded and reported to the DSL the same day, and the parent or carer is informed.

• Discipline is never administered through physical exertion, exclusion from water or rest, humiliation, or public ridicule.

11.1 Sanctions

Sanctions follow a proportionate ladder: verbal reminder → time out from the activity → parent or carer informed → parent or carer asked to collect → temporary suspension from sessions → exclusion for a defined period of up to 18 months.

Unacceptable behaviour in sessions is generally managed by separating the children involved and returning them to the care of their parents or carers as soon as possible, with suitable supervision in the meantime.

11.2 Appeals

A parent or carer aggrieved by an exclusion may appeal in writing to the Company within 14 days. A hearing is held within 21 days, and the views of all relevant persons are heard.

The appeal is heard by a person who was not involved in the original decision. Because the Company has a single director, this will normally be the Board safeguarding contact or the Deputy DSL. Where the original decision was taken by the director, or where no uninvolved person is available, the Company appoints an independent person from outside the Company to hear the appeal, at the Company’s expense. The Company will not have a decision reviewed by the person who made it.

12. Bullying and Child-on-Child Abuse

The Company does not tolerate bullying of children, whether by adults or by other children. We recognise that children can and do abuse other children, that this can happen inside and outside sessions and online, and that it must never be dismissed as banter, horseplay, or part of growing up.

Child-on-child abuse includes bullying and cyberbullying, physical abuse, sexual harassment, sexual violence, sharing of nude or semi-nude images, initiation or “hazing” rituals, and abuse within young people’s intimate relationships.

Where an incident of child-on-child bullying or abuse arises:

1. Those involved are separated immediately and made safe.

2. The incident is recorded in writing and reported to the DSL the same day.

3. The DSL assesses the incident, including whether it meets the threshold for referral to children’s social care or the police, and whether the mandatory reporting duty in Section 17 is engaged.

4. The parents or carers of all children involved are informed, unless doing so would place a child at further risk.

5. Support is offered to the child who has been harmed, and a response — which may include sanctions under Section 11 — is decided for the child who caused harm.

6. The DSL reviews the incident, records the outcome, and considers whether any pattern is emerging.

The Company does not hand incidents of child-on-child abuse to parents to resolve between themselves. Parents are informed and involved, but responsibility for assessing and responding to the incident sits with the DSL.

13. Health, Safety and Medical

13.1 Risk assessment

A written risk assessment is completed for each venue and for each type of event before it runs, and reviewed annually or after any incident. Parents and children are told about any particular risk and the steps taken to reduce it.

13.2 First aid

An appointed person for first aid is identified for every session. Instructors carry first aid essentials appropriate to the activity.

13.3 Recording accidents and injuries

An accident or injury is recorded where any of the following applies:

1. the person injured is under 18 or is an adult at risk, and the injury is such that a parent, carer or next of kin would expect to be told;

2. the injury is reportable under RIDDOR;

3. the injury may give rise to a claim or is otherwise reportable to the Company’s insurers;

4. the person injured, or their parent or carer, asks for it to be recorded;

5. the injury is a head injury, or a concussion is suspected. This applies in every case, regardless of apparent severity, and the concussion procedure applies alongside this record.

Where none of these applies, a record may still be made, and the reason for making it must be stated.

This is the single recording threshold for accidents and injuries throughout this policy, and it applies wherever an injury arises — in instruction, in training, in sparring, at events, and at any Company venue.

This threshold replaces the former requirement to record every injury however minor. Recording everything made the completeness of the log unauditable: a missing entry could not be distinguished from an injury nobody thought worth writing down. Recording against a stated threshold means the absence of a record becomes evidence rather than an unanswered question.

13.4 Medical information

Parents and carers are asked for relevant medical information, including asthma, allergies, epilepsy and any condition affecting participation. This information is shared with the staff working directly with that student and is not shared more widely. Emergency medication is accessible during sessions.

13.5 Concussion and head injury

The Company follows the UK Concussion Guidelines for Non-Elite (Grassroots) Sport (November 2024 update) and, in Scotland, the Scottish Sports Concussion Guidance 2024. The guiding principle is: if in doubt, sit them out.

Immediate management of a suspected concussion:

1. Remove the student from training immediately. They do not return that day, and they are not left alone.

2. Check for red flags — including neck pain, deteriorating consciousness, repeated vomiting, seizure, double vision, weakness or tingling in the limbs, or increasing confusion. If any are present, call 999.

3. Inform the parent or carer immediately and hand over in person where possible.

4. Advise contact with NHS 111 within 24 hours of the injury.

5. Record the incident, including the mechanism of injury and the signs observed, and report to the DSL.

Return to training follows the graduated pathway at Appendix B. The key minimums are:

• no return to any sport within 24 hours of a suspected concussion;

• an initial 24 to 48 hours of relative rest, then a graduated return to school or work, which takes priority over return to sport;

• no return to training with any risk of head contact for a minimum of 14 days;

• no return to competition or full-contact sparring before 21 days from the date of injury, and only if symptom-free for the preceding period; and

• if symptoms persist beyond 28 days, the student must be assessed by a GP before returning.

A student who has sustained a second concussion within 12 months, or who has a history of repeated concussion, does not return to contact training until assessed by a healthcare professional with experience in sport-related concussion. Instructors have the authority to stand a student down and will be supported in doing so, regardless of pressure from the student, a parent, or an upcoming grading or competition.

14. Photography, Filming and Images

Photography and video are a normal part of training at the Company. They are used for coaching and technique analysis, for recording gradings, and for promoting the Company and the wider Missing Link Martial Arts Community. Members and parents are informed of this at sign-up.

The Company distinguishes between two uses.

14.1 Internal use — coaching, technique analysis and grading records

Photography and filming for coaching purposes is part of the training programme. Permission for this is granted at sign-up. Such material:

• is used only for coaching, assessment and internal records;

• is stored securely with access limited to the instructors who need it;

• is not published, shared outside the Company, or posted to any public or social channel; and

• is deleted when no longer needed for its purpose.

14.2 External use — publication, website, social media and promotion

Permission to use photographs and video, including publication, is granted as part of membership at sign-up. Members, parents and carers are told this clearly before joining. The Company does not operate a separate opt-in for publication.

Any member, parent or carer may withdraw that permission at any time by telling the Designated Safeguarding Lead or the Company office. No reason has to be given. The objection is recorded, the person does not appear in published material from that point, and existing images are removed from the Company’s own channels on request. Withdrawing permission has no effect on the member’s ability to train.

The Company does not publish personally identifiable images without asking first, and the following rules apply to everything it publishes:

• Full names are never published alongside an image of a child. First name only, or no name.

• Personal contact details are never published with an image.

• Images are not published in a way that reveals the location or timing of a specific child’s regular attendance.

• The Company cannot recall material already shared onward by third parties, and says so when permission is taken.

• Photography or filming by members, parents or spectators requires the Company’s permission.

• Anyone not known to the Company who is photographing or filming a session is challenged by an instructor, and the DSL is informed.

14.3 Children who must not be photographed

There will occasionally be a child whose image must not be captured or published at all — for example a child living in a refuge, a looked-after child, a child subject to a court order, or a child at risk from a person who must not learn their whereabouts. The Company must be able to accommodate this without excluding the child from training.

Parents and carers may notify the DSL confidentially that a child must not be photographed. Where notified:

• the DSL records the restriction and informs the instructors delivering that child’s sessions, without disclosing the reason;

• a discreet identifier agreed with the family (for example a coloured wristband) is used at events where a photographer is present; and

• the child is positioned and grouped so that they can train fully while remaining out of shot.

This route is available at all times and is signposted on the sign-up form.

15. Online Safety and Communications

• Communication with students under 18 takes place through Company-approved channels only, and copies a parent or carer or a second adult.

• No member of staff or volunteer contacts a student under 18 through a personal social media account, personal phone number, or private direct message, or accepts a friend or follow request from one.

• Online sessions are delivered from an appropriate setting, with a second adult or the parent present, and are not recorded without consent.

• Staff report to the DSL any online content or contact involving a student that causes them concern, including sexual imagery, AI-generated or manipulated images, and contact from unknown adults.

• Concerns about a nude or semi-nude image of a child being shared are reported to the DSL and, where appropriate, to the police. Staff do not view, copy, forward or store the image.

16. Adults at Risk

The Company teaches adults as well as children, and some adult students may be adults at risk. An adult at risk is a person aged 18 or over who has needs for care or support, is experiencing or at risk of abuse or neglect, and as a result of those needs is unable to protect themselves.

The same reporting route applies: concerns go to the DSL the same day, and the DSL decides on referral.

The Company recognises that an adult’s right to make their own decisions must be respected. Where an adult at risk has capacity and does not wish a referral to be made, the DSL will normally respect that, unless others are at risk, a criminal offence has been committed, or the person lacks capacity to make that decision. The reasoning is recorded either way.

The Ann Craft Trust provides specialist guidance on safeguarding adults at risk in sport, and the DSL may seek advice from them.

17. Recognising and Responding to Concerns

17.1 Mandatory reporting of child sexual abuse (England)

The Crime and Policing Act 2026 introduces a statutory duty to report child sexual abuse. It applies to anyone in regulated activity with children in England, which includes the Company’s instructors, assistants and volunteers.

The duty is engaged where a person:

• is told by a child that they are being sexually abused;

• is told by a person that they have sexually abused a child; or

• witnesses a child being sexually abused.

Where the duty is engaged, a report must be made to the police or the local authority as soon as reasonably practicable. Only one report is required per incident: a member of staff discharges the duty by reporting to the DSL, provided the DSL then makes the notification. The DSL must confirm to the reporter that the notification has been made.

Failure to comply may result in referral to the Disclosure and Barring Service and barring from working with children. It is a criminal offence, punishable by up to seven years’ imprisonment, to act with the intention of preventing a report being made under this duty.

No member of the Company — at any level, including directors — may discourage, delay or obstruct a report. Concern for the Company’s reputation is never a reason to withhold a report.

Scotland and Wales. Neither jurisdiction has an equivalent duty binding the Company. Wales has a statutory duty to report children and adults at risk under sections 128 and 130 of the Social Services and Well-being (Wales) Act 2014, but it binds “relevant partners” — local authorities, the police, health boards, probation and youth offending teams — and not private organisations such as the Company. The Company applies the same reporting standard in Scotland and Wales as a matter of policy, and every instructor is expected to follow it regardless of where they are teaching.

17.2 Receiving a disclosure

1. Receive. Listen carefully and calmly. Reassure the person that they were right to speak up. Ask the minimum number of open questions needed to understand whether there is a concern. Never ask leading questions and never investigate.

2. Do not promise secrecy. Explain, in age-appropriate terms, that you may have to tell someone in order to get them help, and that you will tell them who you are telling.

3. Record. As soon as possible and the same day: the facts, the person’s own words in quotation marks, times, dates, who was present, and anything observed such as injuries. Record what was said, not your interpretation. Sign and date the record.

4. Report. Hand the record to the DSL or Deputy DSL the same day. If neither is available and a child is at immediate risk, call 999 or the local authority yourself — do not wait.

5. Support. Check on your own wellbeing. Receiving a disclosure is difficult and support is available from the DSL.

17.3 DSL decision and referral

The DSL informs the parent or carer unless doing so may place the child at further risk, alert an alleged perpetrator, or interfere with a police investigation. The decision and the reason are recorded.

If a referral is made and nothing appears to happen, the DSL escalates — to the team manager, then to the safeguarding partnership or Child Protection Committee. The Company does not assume that silence means the concern was unfounded.

18. Allegations Against Staff and Volunteers

This section applies where it is alleged that a member of staff, instructor, volunteer or contractor has harmed a child, committed a criminal offence against a child, behaved towards a child in a way that indicates they may pose a risk, or behaved in a way that indicates they may be unsuitable to work with children.

1. The allegation is reported immediately to the DSL. Where the allegation concerns the DSL, it is reported to the Board safeguarding contact or the Deputy DSL, who contacts the LADO or local authority directly and does not inform the DSL first (Section 4.3).

2. England: the DSL contacts the Local Authority Designated Officer (LADO) within one working day, before taking any other action including speaking to the person accused. Wales: the DSL contacts the LADO or Designated Officer for Safeguarding for the relevant local authority, within one working day. In Wales this role covers allegations concerning adults at risk as well as children, so the same route is used for both. Section 5 of the Wales Safeguarding Procedures applies. Scotland: the DSL contacts the local authority child protection team.

3. The Company considers immediate suspension or redeployment where there is a continuing risk to children, a risk of interference with evidence or witnesses, or the allegation is so serious that it warrants it. Suspension is a neutral act and is not a disciplinary sanction.

4. The Company follows the LADO or local authority process and its own disciplinary procedure, and keeps a written chronology throughout.

5. The person accused is kept informed as far as is consistent with the investigation, and is told where to find support.

6. The outcome is recorded as substantiated, unsubstantiated, unfounded, or malicious.

7. Where the outcome meets the threshold, the Company makes a referral to the DBS or Disclosure Scotland under Section 5.3. This duty applies even if the person has resigned.

A record of the allegation and its outcome is retained on the person’s file in line with Section 21. Unfounded and malicious allegations are recorded as such.

19. Low-Level Concerns

A low-level concern is any behaviour by an adult that is inconsistent with the Code of Conduct at Appendix C but does not meet the threshold for an allegation. Examples include being over-familiar, using inappropriate language, or repeatedly finding reasons to be alone with a particular child.

• Low-level concerns are reported to the DSL and recorded on the low-level concerns log, with dates, and are shared with the person concerned unless doing so would compromise a wider investigation.

• The DSL reviews the log at least every 4 weeks.

• Where a pattern emerges, the DSL escalates to the LADO or Designated Officer for Safeguarding (England and Wales) or the local authority child protection team (Scotland), and considers whether a DBS or Disclosure Scotland referral is required.

• The log is retained until 7 years after the person leaves the Company. Where a concern has been escalated, it is retained in line with Section 21.

Recording a low-level concern is not an accusation. The purpose is to allow patterns to be seen that no single incident would reveal.

20. Whistleblowing

Anyone who believes that a child is at risk, or that the Company is failing to act on a safeguarding concern, is expected to say so. Concerns may be raised with the DSL, with any director, or externally.

• The Board acknowledges any whistleblowing report within 7 days and provides an outcome within 28 days.

• Victimising or penalising anyone who raises a concern in good faith is gross misconduct. Protection under the Public Interest Disclosure Act 1998 applies.

• Concerns may be raised externally at any time, including with the NSPCC whistleblowing advice line, the local authority, or the police. Nobody is required to exhaust internal routes first.

21. Records, Data Protection and Retention

21.1 Lawful basis

The Company processes personal data for safeguarding purposes on the following bases:

Relying on the paragraph 18 safeguarding condition requires the Company to keep an Appropriate Policy Document. This is maintained by the DSL, reviewed alongside this policy, and made available to the Information Commissioner on request.

The Company is registered with the Information Commissioner’s Office and maintains a separate Data Protection Policy, which includes the Appropriate Policy Document referred to above and the full retention schedule.

21.2 Storage and access

• Safeguarding records are kept separately from general membership records.

• Electronic records are encrypted and access is restricted to the DSL and Deputy DSL. Paper records are kept locked.

• Information is shared on a need-to-know basis. Data protection law is not a barrier to sharing information in order to keep a child safe, and concern about data protection is never a reason to delay a safeguarding referral.

21.3 Retention

The Crime and Policing Act 2026 removed the three-year limitation period for civil claims arising from child sexual abuse in England and Wales, and reversed the burden of proof on whether a fair trial is possible. Claims may therefore now be brought at any point in a person’s life, and the Company must be able to evidence what it knew and what it did.

Subject access requests are handled within one month. Third-party data is redacted. Where disclosing information would be likely to cause serious harm, or would prejudice the prevention or detection of crime, the relevant exemption is applied and the reasoning recorded. The DSL takes advice before releasing any safeguarding record.

22. Monitoring, Review and Assurance

• The DSL produces an annual safeguarding report for the Board each September, covering concerns raised and their outcomes, training completed, vetting status of all staff and volunteers, and any policy gaps identified.

• This policy is reviewed every 12 months, in August.

• It is also reviewed sooner following: any serious incident; any change in legislation or statutory guidance; any allegation against a member of staff; or feedback from a local authority, LADO, inspection or governing body.

• The current version is published on the Company’s websites and issued to all staff and volunteers, who confirm they have read it.

• The Company works towards and maintains the Safeguarding Code in Martial Arts.

23. Key Contacts

Verified August 2026. Re-checked at each annual review.

Emergency and immediate risk

Statutory referral — England (Manchester)

Statutory referral — Wales (Wrexham)

Unlike Manchester and South Lanarkshire, Wrexham does not operate a single 24-hour line. Evening and weekend sessions fall outside office hours, so the Emergency Duty Team number is the one instructors will most often need. Both numbers must appear on the venue notice, with the hours stated. The North Wales Safeguarding Board provides strategic oversight and does not take frontline reports — all concerns and allegations go through the council lines above.

Statutory referral — Scotland (South Lanarkshire)

Advice and support

Both council lines are 24-hour and route to the out-of-hours service automatically, so no separate emergency number is needed for either jurisdiction.

Sources of help for children and young people are displayed at every training venue and included in the membership pack.

This policy is approved and endorsed by the Board of Missing Link Martial Arts Ltd and its subsidiaries.

Signed: …………………………………………………… Date: ………………….

Heero Miketta, Director and Designated Safeguarding Lead

Appendix A — Reporting Procedure at a Glance

If in doubt, report it. It is not your job to decide whether abuse has happened. It is your job to pass on the concern.

Appendix B — Concussion: Graduated Return

Based on the UK Concussion Guidelines for Non-Elite (Grassroots) Sport (November 2024 update). Day 0 is the day of injury. Each stage lasts a minimum of 24 hours and must be completed without symptoms returning. If symptoms return, the student drops back to the previous stage.

• No return to any sport within 24 hours of a suspected concussion.

• Return to education or work takes priority over return to sport.

• No return to competition before 21 days from injury.

• Symptoms persisting beyond 28 days: GP assessment required before return.

• Second concussion within 12 months, or a history of repeated concussion: assessment by a healthcare professional experienced in sport-related concussion before any return to contact.

Red flags — call 999 immediately: neck pain or tenderness; deteriorating consciousness; increasing confusion or irritability; repeated vomiting; seizure or convulsion; weakness, tingling or burning in the arms or legs; severe or increasing headache; double vision.

Appendix C — Code of Conduct for Staff and Volunteers

Every member of staff, instructor, assistant instructor and volunteer signs this Code before working with children, and again at each annual review.

I will

• treat every child and adult at risk with respect, and provide an example I would wish others to follow;

• report every safeguarding concern to the DSL or Deputy the same day, however small it seems;

• explain physical contact before I use it in instruction, and stop immediately if asked;

• take responsibility for staying within appropriate limits when training with or instructing a child, and never treat a child’s silence as consent;

• keep contact with students under 18 to Company-approved channels, with a parent or second adult copied in;

• record any accident or injury meeting the threshold at Section 13.3, and report it, together with any use of restraint and any suspected concussion, the same day;

• challenge poor practice by colleagues, at any level of seniority, and report it if it does not stop;

• report to the DSL within 24 hours any arrest, caution, charge, conviction, civil injunction, or allegation made against me in any setting, and any change to my DBS or PVG status.

I will not

• use corporal punishment, or use martial arts techniques as a punishment;

• be alone with a single child out of sight of others, or supervise a child alone in a changing area or toilet;

• transport a child alone in a vehicle other than in an emergency;

• contact a student under 18 through a personal social media account, personal number or private message, or accept a friend or follow request from one;

• enter into a sexual or romantic relationship with any student under 18;

• photograph or film in changing areas or toilets, photograph or film without the Company’s permission, or publish an identifying image of anyone who has withdrawn permission;

• give gifts to individual children, show favouritism, or develop a relationship with a particular child that could be seen as preferential;

• consume alcohol or be under the influence of alcohol or drugs when responsible for children, or use tobacco or vapes in their presence;

• promise secrecy to a child, or investigate a concern myself;

• discourage, delay or obstruct anyone from making a safeguarding report.

I have read and understood the Safeguarding Children and Adults at Risk Policy version 4.3 and this Code of Conduct, and I agree to comply with both.

Name: …………………………………………………… Role: ………………………………..

Signed: …………………………………………………. Date: ………………………………..