Applies to all platform users (learners aged 14–24), staff, contractors, contributors, partner institutions, and parents/carers.
Lumina is committed to safeguarding and promoting the welfare of children and young people. We recognise our responsibility to take all reasonable steps to ensure that learners using the Lumina platform are protected from harm, abuse, neglect, and exploitation.
This policy applies to all staff, contractors, content contributors, partner institutions, and anyone involved in the creation, management, or delivery of Lumina content and services. It sets out how Lumina identifies, prevents, and responds to safeguarding concerns across its platform.
Lumina operates as an online learning platform and does not replace formal schooling or institutional pastoral care. However, Lumina takes its safeguarding obligations seriously regardless of whether learners access the platform through a partner institution or independently.
This policy should be read alongside Lumina's Online Safety Policy, Privacy Policy, and Code of Conduct.
This policy applies to:
This policy covers all activity related to the Lumina platform, including learning content, the AI Tutor, task submission, and platform administration.
This policy has been developed in line with relevant UK safeguarding legislation and statutory guidance, including:
Lumina monitors changes to legislation and statutory guidance and updates this policy accordingly.
Lumina is an online learning platform that delivers structured courses across 7 learning pillars. The platform operates a primarily pre-recorded content model with the following interactive elements:
Both access models carry safeguarding obligations. Where learners access the platform independently, Lumina holds primary responsibility for safeguarding on the platform. Where learners access through a partner institution, safeguarding responsibility is shared.
Lumina has appointed a Designated Safeguarding Lead responsible for safeguarding oversight across the organisation and platform.
The DSL is responsible for:
If the DSL is unavailable, or if a safeguarding concern involves the DSL directly, concerns should be escalated using the following route:
Lumina will ensure that at least one person with safeguarding responsibility is contactable at all times during business hours.
All staff, contractors, and contributors should be aware of the four main categories of abuse as defined in Working Together to Safeguard Children:
A form of abuse which may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child's emotional development. It may involve conveying to a child that they are worthless, unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include age or developmentally inappropriate expectations being imposed on children, or causing children to feel frightened or in danger.
Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening. This includes contact and non-contact abuse, including online abuse such as grooming, exploitation, and exposure to indecent material.
The persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy, or once a child is born, and may involve a parent or carer failing to provide adequate food, clothing, shelter, supervision, or access to medical care.
Lumina recognises the following specific safeguarding risks, which may be identified through learner behaviour, AI Tutor interactions, or task submissions:
A form of sexual abuse where a child is manipulated or coerced into sexual activity, often in exchange for something such as gifts, money, affection, or status. CSE can occur online as well as in person.
Children and young people may be exploited by criminal gangs to carry drugs, money, or weapons. This can involve coercion, intimidation, and violence, and may be indicated by changes in behaviour, unexplained absences, or new possessions.
Lumina has a duty under the Counter-Terrorism and Security Act 2015 to have due regard to the need to prevent people from being drawn into terrorism. Staff should be alert to changes in behaviour that may indicate a learner is being radicalised. Any concerns should be reported to the DSL, who will make a referral to the local authority Prevent coordinator or police if appropriate.
While Lumina's platform does not include peer-to-peer communication features, the platform recognises that peer-on-peer abuse (including bullying, harassment, and sexual violence) may occur outside the platform and may become apparent through learner behaviour or disclosures in task submissions or AI Tutor conversations.
FGM is illegal in the UK. There is a mandatory reporting duty for professionals who discover that FGM has been carried out on a girl under 18. If any Lumina staff become aware of FGM, this must be reported to the police and the DSL immediately.
Learners may disclose self-harm, suicidal thoughts, or mental health difficulties through AI Tutor conversations or task submissions. The AI Tutor is configured to handle such disclosures with care and direct learners to appropriate support. Any disclosure identified through platform monitoring should be reported to the DSL.
While Lumina's interaction with learners is primarily through an online platform rather than face-to-face, signs of abuse or concern may still be identified through:
All staff and contributors are expected to maintain a professional curiosity and report anything that causes concern, however minor, to the DSL.
Learners are expected to use the Lumina platform responsibly. This includes:
Learners who repeatedly or seriously breach these expectations may have their access restricted or removed.
Any safeguarding concern — whether identified through platform activity, a disclosure, or external information — should be reported immediately.
The AI Tutor is an interactive feature that introduces specific safeguarding considerations. The following controls are in place:
All learning materials published on the Lumina platform must meet the following standards:
Contributors are briefed on safeguarding expectations before commencing work. Content that does not meet these standards will be removed immediately and may not be republished without revision and re-approval.
Lumina maintains secure records of all safeguarding concerns, referrals, and actions taken. Records include:
Safeguarding records are stored securely, accessible only to the DSL and authorised personnel, and retained in accordance with statutory guidance and Lumina's data retention policy. Records relating to child protection are retained for the duration of the individual's involvement with Lumina and for a reasonable period thereafter, in line with legal requirements.
Lumina will share safeguarding information with external agencies where it is necessary to protect a child or young person. Information sharing decisions are made by the DSL on a case-by-case basis, guided by the following principles:
Where a referral is made to the local authority, police, or other agency, Lumina cooperates fully with any subsequent investigation or assessment.
Lumina embeds online safety into the design and operation of the platform through the following controls:
For full details of Lumina's online safety measures, refer to the Lumina Online Safety Policy.
All Lumina staff, contractors, and content contributors are required to:
Training requirements are reviewed annually and updated to reflect emerging risks and best practice. The DSL receives enhanced safeguarding training appropriate to the role.
Lumina encourages all staff, contractors, and contributors to raise concerns about the conduct of any individual — including colleagues, senior staff, or the DSL — without fear of reprisal.
Concerns may be raised:
Lumina will not tolerate retaliation against any person who raises a safeguarding concern in good faith. All whistleblowing reports are treated confidentially and investigated promptly.
Lumina handles all personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For full details of how personal data is collected, used, stored, and protected, refer to the Lumina Privacy Policy.
In the context of safeguarding, the following principles apply:
This policy should be read in conjunction with the following Lumina documents:
This Safeguarding & Child Protection Policy is reviewed annually or sooner if any of the following occur:
The next scheduled review is June 2027.
For any enquiries relating to this policy or safeguarding on the Lumina platform:
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See also our Privacy Policy, Terms of Service, and Online Safety Policy.