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SAFEGUARDING & SENSITIVE CONTENT POLICY

Last updated: February 2026

1.    PURPOSE AND SCOPE

Newbold Connect is a digital learning initiative of Newbold College of Higher Education (the “College”). It offers faith-informed, cinematic practice-first Classes and resources that help integrate Christian faith with work, home, church, community, relationships, and personal rhythms (practice-first Christian learning for real life).

Because our content and community spaces often touch on deeply personal areas of life, safeguarding and the responsible handling of sensitive topics are non-negotiable.

This Policy sets out how Newbold Connect:

  • Protects learners, instructors, staff, and guests from harm, abuse, and avoidable distress.
  • Manages content that addresses sensitive or potentially triggering topics.
  • Responds to concerns, disclosures, and indicators of risk in an online environment.

This Policy applies to:

  • All Newbold Connect learners and users
  • All instructors, guests, moderators, and production partners
  • All staff and contractors working on the Newbold Connect platform

It should be read alongside the College’s Safeguarding & Prevent Duty Policy, the Newbold Connect Terms of Use, Privacy Policy, and Community Guidelines.

Where there is any inconsistency, the College’s main Safeguarding Policy and applicable UK legislation take precedence.

The College’s Safeguarding & Prevent Duty Policy is available on the Newbold College website (newbold.ac.uk). Instructors, moderators, and staff may request a copy from the Newbold Connect Project Lead or directly from the College at [email protected].

2.   LEGAL AND REGULATORY CONTEXT

This Policy is informed by:

  • UK safeguarding law and guidance, including the Care Act 2014 (adult safeguarding), associated statutory guidance, and relevant guidance from the Charity Commission and NSPCC on safeguarding and duty of care.
  • The Counter-Terrorism & Security Act 2015 and the statutory Prevent Duty guidance, as reflected in the College’s Safeguarding & Prevent Duty Policy.
  • The Education Act 2002 (Section 175) where relevant and other higher education safeguarding frameworks relevant to the College’s operations.
  • The Charity Commission’s expectation that safeguarding is a governance priority for all charities, not only those working with children or adults at risk.
  • UK data protection law (UK GDPR and Data Protection Act 2018), particularly as it relates to special category data such as health and religious beliefs.
  • The College’s internal safeguarding, PREVENT, data protection, and HR policies.

Newbold Connect is an online platform for adults aged 18 and over only. Users under 18 are not permitted to create accounts or access the Platform. Adults using the platform may nonetheless be at risk themselves or disclose concerns about others, and safeguarding principles therefore apply in full. If we become aware that a user is under 18, we will close their account promptly and refer to the College’s Safeguarding Lead as appropriate.

3.   DEFINITIONS

For the purposes of this Policy:

  • Safeguarding

Protecting a person’s right to live in safety, free from abuse, neglect, and avoidable harm; promoting their wellbeing; and taking action to prevent and respond to concerns.

  • Child / Young person

Anyone under the age of 18.

  • Adult at risk

An adult who has care and support needs, is experiencing or at risk of abuse or neglect, and as a result is unable to protect themselves from that abuse or neglect (sometimes referred to in the College’s Safeguarding & Prevent Duty Policy as a “vulnerable adult”).

  • Sensitive content

Content dealing with subjects that may be emotionally heavy, triggering, or potentially harmful if handled carelessly – for example:

  • Mental health, burnout, depression, anxiety
  • Trauma, abuse, violence, exploitation
  • Bereavement, grief, loss
  • Sexual ethics and relationships
  • Addiction and destructive behaviours
  • Spiritual abuse, church conflict, or leadership misconduct

 

  • Disclosure

Any communication (written, spoken, or implied) that indicates a person has experienced, is experiencing, or is at risk of abuse, neglect, significant self-harm, or serious harm to others.

  • Safeguarding Lead (Newbold Connect)

The person designated by the College to coordinate safeguarding for Newbold Connect, liaise with the College’s Designated Safeguarding Lead (DSL) and join the College’s Safeguarding Team.

4.  PRINCIPLES

Safeguarding for Newbold Connect is driven by the following principles:

  1.  Safety before convenience

If we have to choose between user convenience and safety, we prioritise safety—even if that means limiting comments, closing threads, or declining particular content.

  1.  Whole-person care

Content and community interaction must recognise the spiritual, emotional, social, and physical dimensions of life, not treating anyone in isolation.

  1.  Proportionate response

We differentiate between:

  • Normal levels of discomfort that come with honest discipleship work; and
  • Genuine risk or harm that requires intervention.
  1.  Trauma-aware, not trauma-exploitative

We do not “mine” people’s pain for cinematic impact. Stories of suffering are handled with consent, sensitivity, and restraint.

  1.  Shared responsibility

Safeguarding is not “the safeguarding officer’s job”; it is a core responsibility of trustees, senior leadership, instructors, staff, moderators, and users.

5.   ROLES AND RESPONSIBILITIES

5.1.     Board of Governors and Senior Leadership

  • Ensure the College’s safeguarding framework covers Newbold Connect explicitly.
  • Approve this Policy and receive regular assurance that it is implemented.
  • Ensure sufficient resources (training, staffing, tools) are in place to discharge safeguarding duties.

5.2.    Newbold Connect Project Lead / Coordinator

  • Own day-to-day implementation of this Policy for the platform.
  • Ensure sensitive Classes are flagged, reviewed, and labelled appropriately through the CCP and QA gates before publication.
  • Ensure all instructors, moderators, and relevant contractors complete the required established safeguarding training (see item 10).
  • Maintain a basic Safeguarding & Sensitive Content Risk Register for the platform and feed material risks into the College’s central risk register and Quarterly Review Committee.

5.3.    Newbold Connect Safeguarding Lead

  • Act as the first point of contact for safeguarding concerns arising from Newbold Connect.
  • The person designated by the College to coordinate safeguarding for Newbold Connect and liaise with the College’s Designated Safeguarding Lead (DSL) and Safeguarding/Prevent Duty team. This role operates within the same safeguarding and Prevent Duty structures described in the College’s Safeguarding & Prevent Duty Policy.
  • Oversee the logging, escalation, and closure of safeguarding incidents relating to the platform.
  • Provide advice to instructors and moderators on borderline cases.

5.4.   Instructors and content contributors

Instructors must:

  • Design and deliver content in line with this Policy, the Instructor Handbook, and the Class Design Guide.
  • Flag to the Newbold Connect team any modules or episodes that cover sensitive topics.
  • Use disclaimers and signposting as agreed (e.g., “This session discusses burnout and depression”).
  • Avoid offering professional clinical, legal, or financial advice unless professionally qualified and explicitly engaged for that purpose—and even then, within agreed boundaries.
  • Escalate any disclosures or concerning messages they become aware of, rather than trying to handle them alone.

5.5.    Moderators, support staff, and production partners

  • Monitor community spaces in line with the Community Guidelines.
  • Triage and escalate safeguarding concerns quickly.
  • Maintain confidentiality, sharing information only on a need-to-know basis.
  • Follow agreed workflows for pausing or removing harmful content.

5.6.   Users (learners)

  • Engage with content and community spaces in line with the Terms of Use and Community Guidelines.
  • Avoid sharing highly sensitive personal information in open forums.
  • Report concerns about their own safety or the safety of others via the channels provided.

6.  CONTENT CLASSIFICATION AND BOUNDARIES

6.1.    Content categories

For internal planning and QA, all classes should be tagged as one of:

  1. General content – normal discipleship, vocation, theology, leadership, skills, etc., with no heightened risk.
  2. Sensitive content – includes thematic treatment of mental health, trauma, abuse, conflict, sexuality, etc., but with low risk of immediate triggering if handled well.
  3. High-risk content – includes direct discussion of self-harm, suicide, abuse situations, or detailed traumatic experiences; or is aimed at known high-risk cohorts.

QA alignment:

  • General content typically maps to QA Level 1
  • Sensitive content typically maps to QA Level 2
  • High-risk content typically maps to QA Level 3 (high-stakes/safeguarding-sensitive)

High-risk content must be the exception, not the norm, and must be justified by clear formation value and strong safeguards.

6.2.   Prohibited content

Newbold Connect will not publish content that:

  • Normalises, glorifies, or encourages self-harm, suicide, violence, or abuse.
  • Includes graphic descriptions of sexual or physical violence.
  • Trains users in harmful or illegal practices.
  • Promotes or supports terrorism, violent extremism, or ideologies that conflict with the College’s Prevent Duty responsibilities (for example, advocacy of violence, hate, or opposition to fundamental human rights and the rule of law).
  • Presents extreme or coercive theology that undermines basic human dignity or encourages spiritual abuse.

Where potentially controversial theological or ethical issues are addressed, they must be framed with pastoral care and intellectual honesty, not sensation or ideological warfare.

7.   DESIGNING AND PRESENTING SENSITIVE CONTENT

For classes flagged as Sensitive or High-risk:

7.1.     Planning and review

  • The instructor must flag sensitivity at proposal/outline stage.
  • The Project Lead ensures an appropriate pastoral/theological reviewer and, where needed, the Safeguarding Lead, review the outline and sample scripts.
  • Content that touches on trauma, abuse, or mental health must:
    • Avoid unnecessary detail that may re-traumatise.
    • Distinguish clearly between lived testimony and ‘how-to’ instruction.
    • Include clear boundaries on what the instructor can/cannot offer (e.g., “I am not your therapist; here’s when to seek professional help”).

7.2.    On-screen and platform warnings

  • Clear content warnings must appear at the start of relevant episodes and in class descriptions (e.g. “This session includes discussion of burnout and depression”).
  • Classes should highlight where topics may be particularly difficult for survivors of abuse, bereavement, etc.
  • Where appropriate, short pastoral notes should signpost to:
    • Local church leaders or trusted community.
    • Professional support (GP, counsellor, therapist).
    • Crisis helplines for users in immediate danger or distress (country-specific where practical).

7.3.    Calls to action

  • Application activities must be safe and realistic. For example:
    • Journalling, prayer, talking with a trusted friend or pastor;
    • Seeking professional help where issues are serious or longstanding.
  • Users should not be encouraged to confront abusers directly, make abrupt life changes without support, or discontinue medication / professional treatment.

8.   HANDLING DISCLOSURES AND CONCERNING BEHAVIOUR

8.1.     What counts as a concern?

Examples include:

  • A user indicates intent or plans to self-harm or attempt suicide.
  • A user discloses current abuse, neglect, or exploitation (towards themselves or another person).
  • A user expresses credible intent to harm someone else.
  • A user appears to be under coercive control or in a situation of domestic or spiritual abuse.
  • A user reveals that a child or adult at risk is being harmed or neglected.
  • A user expresses or shares material suggesting possible radicalisation or violent extremism, in ways that may fall within the College’s Prevent Duty responsibilities.

Anyone engaging with the platform in a professional capacity (staff, instructors, moderators, production partners) must treat these as safeguarding concerns and follow the steps below.

8.2.    Immediate steps for staff, instructors, and moderators

If you see or receive a concerning message:

  • Preserve the content
    • Take screenshots or secure links (without sharing them beyond the safeguarding chain).
  • Acknowledge briefly (if appropriate)
    • Respond with empathy and a clear statement that Newbold Connect cannot provide emergency support through the Platform or any Interaction Spaces, encouraging the person to contact local services immediately if they are at risk.
  • Escalate
    • Notify the Newbold Connect Safeguarding Lead without delay by:
      • Emailing [email protected] with “SAFEGUARDING – [brief summary]” in the subject line
      • Completing the Newbold Connect Safeguarding Concern Form (available on the internal Teams/SharePoint site) as soon as possible and always within 24 hours.
    • If you reasonably believe someone is at imminent risk of serious harm to themselves or others, you must treat this as an emergency:
      • Contact the relevant local emergency service (e.g. 999/112 in the UK) without delay.
      • Inform the Newbold Connect Safeguarding Lead as soon as possible afterwards so that the concern can be integrated into the College’s safeguarding/Prevent process.

 Do not

    • Promise absolute confidentiality.
    • Attempt to provide therapy, legal advice, or crisis counselling beyond your competence.
    • Share the disclosure with others “for interest” or discussion.

8.3.    Safeguarding Lead response and escalation to the College

The Newbold Connect Safeguarding Lead will:

  • Review and log
    • Review the Safeguarding Concern Form and any supporting evidence promptly (same working day for moderate or high-risk concerns).
    • Assign an initial risk rating (low, moderate, high, critical) and create or update a secure record.
  • Consult and refer within the College framework
    • Consult the College’s Designated Safeguarding Lead (DSL) and/or Prevent Duty Lead Person/Team where there is any uncertainty about the level of risk or appropriate next steps.
    • Refer concerns into the College safeguarding/Prevent system the same day where any of the following thresholds are met:
      • A child or young person (under 18) is involved.
      • An adult at risk (vulnerable adult) is involved.
      • There is actual or suspected abuse or neglect.
      • There is a credible risk of self-harm or serious harm to others.
      • There is a potential radicalisation or extremism
      • The conduct of a College staff member, instructor, or leader is in question.
    • Where such a threshold is met, forward the Safeguarding Concern Form (or equivalent written record) and a brief summary of actions taken to the DSL/Prevent Duty Lead, using the contact routes set out in the College Safeguarding & Prevent Duty Policy.
  • Take appropriate action
    Depending on the case, the next steps may include:
    • Contacting the individual with supportive signposting (e.g. to local services, pastoral support, GP, counsellor).
    • Requesting limited further information where needed to clarify risk (without undertaking an investigation).
    • Coordinating with the College DSL/Prevent team on any referral to statutory services.
    • Contacting statutory services directly (police, social services, emergency healthcare) where necessary to protect life or prevent serious harm, particularly in out-of-hours or high-risk situations.
  • Balance duties
    • Decisions will balance pastoral care, user privacy, and legal duties to protect people from harm, always operating within the College’s safeguarding, Prevent, and data protection frameworks.

8.4.   Records and data protection

  • Safeguarding records will be stored securely, with access limited to the Newbold Connect Safeguarding Lead, the College DSL/Prevent team, and a small number of authorised staff.
  • Records will:
    • Use factual, proportionate language and, where relevant, the individual’s own words.
    • Be kept only for as long as is necessary and in line with the College’s Safeguarding & Prevent Duty Policy, Data Protection Policy, and UK GDPR requirements for special category data (strict necessity, minimal detail, clear purpose).
  • Users have rights under data protection law; however, in some safeguarding and Prevent cases, full access to records may be restricted where disclosure could place someone at further risk or prejudice an investigation.

9.  COMMUNITY SPACES AND MODERATION

The Community Guidelines set baseline behavioural expectations. This Policy adds that:

  • Moderators must be particularly alert to:
    • Patterns of hopelessness, self-disgust, or extreme distress.
    • Users being targeted or harassed around vulnerable disclosures.
  • Where sensitive discussion is needed, moderators may:
    • Close public threads and invite users to continue reflection privately (journalling, local support).
    • Remove comments that disclose heavy details in ways that may distress others, while still following up pastorally with the original poster.
  • Instructors must inform moderators in advance if a live session will invite potentially sensitive sharing so moderation can be resourced appropriately.

10.       TRAINING AND COMPETENCE

The platform will not rely solely on good intentions. As a minimum:

  • The Newbold Connect Project Lead, Safeguarding Lead, and relevant staff must complete formal safeguarding and Prevent Duty training that meets the standards set out in the College’s Safeguarding & Prevent Duty Policy (e.g., adult safeguarding, online safety, basic child protection awareness, Prevent awareness).
  • All instructors and moderators must complete:
    • An induction briefing on this Policy, the College Safeguarding Policy and Prevent Duty expectations, the Community Guidelines, and escalation procedures.
    • Refresher training at least every three years (or more frequently if national guidance or College policy changes).
  • Training records must be maintained and available for audit (e.g., Quarterly Review Committee, Board scrutiny, College safeguarding reviews).

11. RELATIONSHIP WITH CPD AND EXTERNAL PARTNERS

Phase 2 of the digital initiative includes CPD/CE for pastors and administrators, potentially including safeguarding and GDPR training themselves.

To avoid hypocrisy and risk:

  • Any CPD content on safeguarding must be developed in consultation with appropriately qualified practitioners and aligned with this Policy and the College’s Safeguarding Policy.
  • Where external partners (e.g. Unions, Conferences) purchase group access or CPD seats, responsibilities for safeguarding in relation to their staff (e.g. pastoral follow-up, HR processes) must be clearly delineated in partnership agreements.

12.        COMPLAINTS AND WHISTLEBLOWING

If any user, instructor, or staff member believes that:

  • Safeguarding concerns are not being taken seriously;
  • This Policy is being ignored or undermined; or
  • The behaviour of a member of staff, instructor, or leader is itself abusive or unsafe,

they should report this via:

  • [email protected]; or
  • The College’s safeguarding and whistleblowing channels as set out in the College’s Safeguarding & Prevent Duty Policy and related procedures.

Concerns about the conduct of the Safeguarding Lead or Project Lead should be directed to the College’s Designated Safeguarding Lead or a member of Senior Leadership Team.

13.        MONITORING, REVIEW, AND GOVERNANCE

Safeguarding and sensitive content are part of the Compliance and Legal Risks identified in the Newbold College Digital Learning Initiative’s risk management plan.

To keep this Policy live and meaningful:

  • The Newbold Connect Safeguarding Lead will maintain a short annual summary of safeguarding incidents and learning points from the platform.
  • The Project Lead will report key safeguarding and online safety issues to the Quarterly Review Committee, alongside financial and operational KPIs.
  • This Policy will be reviewed at least annually, and sooner if:
    • UK safeguarding or online safety law changes;
    • The College’s Safeguarding Policy is updated; or
    • There is a significant safeguarding incident involving the platform.

Revisions will be approved through the College’s normal governance routes and, where material, changes will be signposted to users on the platform.