The All Footballers Experience (AFE) is committed to creating safe, inclusive, and positive environments for all children and young people who engage with our content, both offline and online.
We prioritise the emotional wellbeing, physical safety, and privacy of every participant, and we design our products and services in line with UK Safeguarding Standards, EU GDPR, UK Data Protection Act, COPPA (US), and applicable international regulations.
This safeguarding policy applies to:
AFE Books – Printed and digital editions, including associated educational content.
AFE App – All digital features, including book-linked activities.
Interactive “Talk to Your Hero” Feature – Real-time speech interaction between children and club players’ digital personas.
We commit to:
Child-Centred Design – Features are age-appropriate, accessible, and never expose children to harmful content.
PCG Consent – Parent/Carer/Guardian (PCG) consent is required before any child accesses interactive features, including demos.
Transparency – Clear, plain-language explanations of how features work, how data is handled, and how safeguarding is embedded.
Zero-Tolerance for Harm – Any content that could cause emotional, physical, or reputational harm is strictly prohibited.
The “Talk to Your Hero” feature is designed with safeguarding at its core:
No Open-Ended AI Advice – AI is never permitted to generate unapproved advice, diagnoses, or instructions.
Pre-Approved Script Bank – All possible responses are written, reviewed, and signed off by both AFE safeguarding leads and the club’s safeguarding team before release.
Intent Detection Only – AI is used solely to classify the child’s question and select the appropriate pre-approved response.
Moderation Layer – All responses pass through automated safety filters before delivery.
Signposting Protocol – If certain keywords (e.g., distress, self-harm) are detected, the system automatically provides approved empathy statements and directs the child to age-appropriate helplines or safeguarding contacts.
No Raw Audio Storage – Children’s voices are not stored in any identifiable form.
Anonymised Transcripts – With explicit PCG consent, anonymised transcripts may be kept for quality review and safeguarding audits.
Data Minimisation – Only the minimal necessary information is processed to deliver the feature.
Compliance – All data handling complies with GDPR, UK Data Protection Act, COPPA, and relevant local laws.
Before using the interactive feature:
PCG must provide explicit consent through a verified digital or written process.
Consent records are stored securely in compliance with applicable regulations.
Children are given a clear, age-appropriate safeguarding statement before use.
Club Safeguarding Approval – No feature goes live without sign-off from the club’s safeguarding team.
Ongoing Review – Script bank and safety protocols are reviewed at least quarterly.
Incident Response – Any safeguarding concern reported is logged, investigated, and acted upon in partnership with the relevant safeguarding authority.
If a safeguarding concern arises:
Immediate referral to designated safeguarding leads (AFE + club).
Notification to relevant PCG where appropriate.
Escalation to statutory agencies if risk of significant harm is identified.
All AFE staff, contractors, and delivery partners involved in the development or deployment of the feature:
Receive safeguarding and child protection training.
Are briefed on the safeguarding statement, procedures, and escalation routes.
For safeguarding concerns or questions:
Designated Safeguarding Lead (AFE): Danny Matharu - support (at) withinu (dot) net
Club Safeguarding Lead: On a club-to-club basis
AFE Privacy Officer: Danny Matharu - support (at) withinu (dot) net