Safeguarding and Children's Data

1. Why This Page Exists

Teloframe is used by clubs, academies, and schools that work with children. This page sets out plainly what the Service does to support your safeguarding obligations, what it deliberately does not do, and how to raise a concern. It is written for welfare officers and club administrators doing due diligence, not only for lawyers.

It sits alongside our Privacy Policy, Terms of Service, and Data Processing Addendum. Where this page and those documents differ, those documents govern.

2. Who Is Responsible for What

Teloframe is a tool. Your club, academy, or school is the organization responsible for the children in its care and for the records it creates about them. In data-protection terms you are the controller and we are your processor. In safeguarding terms, you hold the duty of care, the policy, and the designated safeguarding lead.

Our job is to give you controls that make good practice practical, to keep the platform secure, and to act promptly when something is reported to us. Our job is not to make safeguarding decisions on your behalf, and we are not in a position to do so.

3. Controls We Provide

• Role-based access inside a club - Club workspaces use defined roles, currently owner, admin, coach, and staff, so a person only reaches the records their role allows. Owners and admins control who is invited and can remove access at any time.
• Scoped portal access for players and families - A linked portal account reads only the player it is linked to. It does not receive club-wide access, other players' records, or internal staff notes you have not chosen to share. Every link can be revoked, and invitations expire.
• Private storage for the most sensitive files - Player profile photos and development-plan evidence are held in private storage and served through controlled retrieval rather than open URLs.
• Consent records - You can record the consents you hold for a player, including media, data-processing, medical, and travel consent, with the date, source, and any expiry, so your position is evidenced rather than remembered.
• Per-item media removal - Any photo or video in a match gallery can be removed individually, and a published public match page can be withdrawn, so a withdrawal of consent can be actioned quickly.
• Activity records - Significant actions in a club workspace are recorded, including who created, changed, shared, published, invited, or deleted something, so a concern can be investigated rather than guessed at.
• Account security - Optional two-factor authentication, secure session handling, and transport encryption for the Service and its APIs.
• Deletion that works - Players and teams can be archived or deleted, and account holders can delete their own account, which removes the personal-scope records held under it.

4. What the Service Does Not Do

We would rather you know these limits before you rely on the Service than discover them during an incident.

• We do not verify age at invitation - When you invite a player or a parent to the portal, the Service does not check the recipient's age or confirm that a guardian has consented. That decision and that record sit with you. If your rules require guardian-first access below a certain age, you need to operate that rule yourself.
• We do not screen or scan content - Uploaded photos, video, notes, and messages are not automatically reviewed, classified, or scanned for harmful material. We act on reports rather than detecting problems proactively.
• We do not vet your people - Teloframe holds no record of background checks, qualifications, or safeguarding training for the staff you invite into your workspace.
• We are not a safeguarding case-management system - Teloframe is not designed to hold safeguarding disclosures, incident reports, or welfare case files. Use your governing body's system for those, not a player note.
• Some media is stored at public URLs by design - Match gallery media, crests, and branding images are stored at unguessable public storage URLs so they can render in shared pages, exports, and printed materials. Anyone holding the URL can open the file without signing in.

5. Age Thresholds and Portal Access

Teloframe accounts require a minimum age of 13. Your obligations may be stricter. In Kenya, where NEXTON INTERACTIVE LIMITEDis established, a person under 18 is treated as a child whose personal data generally requires parental or guardian consent. In the UK and much of the EU the threshold for a child's own consent is 13, and separate rules apply to processing a child's data at all.

Because the Service does not check age or guardian consent at the point of invitation, you should decide in advance, as a matter of club policy, which age groups may hold a portal account directly and which must be reached through a parent or guardian, and then apply that consistently when you send invitations.

6. Photos and Video of Children

Match galleries can hold photos and video clips, and media can be tagged to identify the players who appear in it. If you publish a public match page, that media becomes visible to anyone who has the link. Media files are also stored at unguessable public storage URLs so they can be rendered in exports and shared material.

Before you upload or publish, confirm you hold the media consent required for every child shown, and check whether any player has withheld it. Record that position using consent records so it is evidenced. If consent is withdrawn, remove the media item and, where relevant, withdraw the public page. Copies already downloaded or screenshotted by others cannot be recalled by us or by you, which is a good reason to be conservative about publishing.

7. Health and Welfare Records

Injury, rehabilitation, availability, and welfare notes can reveal a child's health status. Keep entries relevant and proportionate, restrict them to staff who need them, and do not use free-text notes as a substitute for your medical or safeguarding systems. Teloframe is not a medical device, a clinical records system, or an emergency service, and AI output in the Service is never medical advice.

8. Your Responsibilities

• Deciding whether you have a lawful basis and the necessary permissions before uploading any child's data.
• Deciding whether to invite a player directly to a portal account or to invite only a parent or guardian, and meeting the age and consent standard that applies to you.
• Holding the media and likeness permissions for every photo or video you upload, tag, or publish, and removing that media when consent is withdrawn.
• Limiting internal access to children's records to staff with a legitimate need, and removing access promptly when someone leaves.
• Vetting your own staff, including any criminal-record or background checks your governing body requires. Teloframe does not carry out or verify vetting.
• Running your own safeguarding policy, reporting routes, and designated safeguarding lead, and responding to concerns raised through them.
• Deciding how you distribute link-based access you create, including public match pages and family calendar links, and revoking those links when circumstances change.

9. Raising a Concern

If a child is at immediate risk of harm, contact your local police or child-protection authority first. Do not wait for a response from us.

For concerns about a child in a club's care, the right first contact is that club's designated safeguarding lead. They hold the duty of care, the context, and the authority to act. We do not hold that role and cannot investigate a club's conduct on its behalf.

Contact us at contact@teloframe.com where the concern is about the platform itself, for example content published on Teloframe that should not be there, an image of a child used without permission, access that appears to have been granted to the wrong person, or a suspected security problem. Tell us what you found, where, and your relationship to the child or the club.

On receiving a report of that kind we will acknowledge it, remove or restrict the content where that is the right immediate step, contact the customer that controls the record, and, where we are only the processor, direct the request to that customer so it can act. We may suspend an account while we look into it. Where the law requires us to notify a regulator or a customer of a personal-data breach, we will.

10. Changes to This Page

We will update this page as the Service changes. Where a change affects how children's data is handled, we will update the date above and, where appropriate, give additional notice.

11. Contact

NEXTON INTERACTIVE LIMITED, contact@teloframe.com.

P.O BOX 632, 00618 - RUARAKA, NAIROBI, KENYA