Safeguarding Policy

1. Policy Statement

MediBrain UK Ltd ("MediBrain UK", "we", "us", "our") is a UK-registered education and coaching company that primarily works with Year 12 and Year 13 students (aged 16–18) and young adults applying to study Medicine and Dentistry at UK universities. Given the nature of our work, we have a clear duty of care to protect the young people in our programmes.

We are committed to:

• Protecting the health, wellbeing and human rights of all young people and vulnerable individuals in our care.
• Creating and maintaining an environment where young people feel safe, respected and heard.
• Taking all reasonable steps to prevent harm, abuse, exploitation or neglect.
• Responding promptly and appropriately to any safeguarding concern or disclosure.
• Working in partnership with parents, carers and statutory agencies where appropriate.
• Ensuring all staff, coaches and tutors understand their safeguarding responsibilities.

This policy applies alongside — and does not replace — any statutory duties under the Children Act 1989, the Children Act 2004, the Safeguarding Vulnerable Groups Act 2006, and Working Together to Safeguard Children (2023 edition).

2. Scope

This policy applies to:

• All MediBrain UK directors, employees, self-employed tutors, coaches and clinical mentors.
• Any volunteers, guest speakers or third parties acting on behalf of MediBrain UK.
• All services delivered by MediBrain UK including online group coaching sessions, 1:1 tutoring, webinars, written resources, WhatsApp support groups and any in-person events.

This policy covers all individuals under 18 years of age, and adults who may be at risk of harm due to mental health difficulties, disability, or other vulnerability, who interact with MediBrain UK.

3. Definitions

Safeguarding

Safeguarding means protecting children and vulnerable adults from abuse and maltreatment, preventing harm to their health or development, ensuring they grow up with the provision of safe and effective care, and taking action to enable all children and young people to have the best outcomes.

Child / Young Person

For the purposes of this policy, a "child" or "young person" is any individual under the age of 18. MediBrain UK's typical student cohort includes 16–18 year olds in Years 12 and 13 of secondary education.

Vulnerable Adult

An adult (aged 18 or over) who may be at risk due to mental health difficulties, physical disability, learning disability, age-related frailty, or other personal circumstance that reduces their ability to protect themselves from harm or exploitation.

Abuse

Abuse is a form of maltreatment. It may involve inflicting harm or failing to act to prevent harm. The four main categories of abuse are:

• Physical abuse — causing physical harm to a child or young person.
• Emotional abuse — persistent emotional maltreatment that affects a child's emotional development.
• Sexual abuse — forcing or enticing a child to take part in sexual activities.
• Neglect — persistent failure to meet a child's basic physical and/or psychological needs.

Additional concerns relevant to online education environments include online grooming, cyberbullying, exploitation and exposure to radicalisation (as defined under the Prevent Duty).

4. Designated Safeguarding Lead (DSL)

MediBrain UK has appointed a Designated Safeguarding Lead (DSL) who is the first point of contact for all safeguarding concerns within the organisation.

The DSL is responsible for:

• Being the central point of contact for all safeguarding concerns raised by staff, coaches, students or parents.
• Making referrals to statutory agencies (local authority children's services, police) where appropriate.
• Maintaining secure records of all safeguarding concerns and actions taken.
• Ensuring all staff and coaches receive appropriate safeguarding training.
• Keeping this policy up to date and reviewing it annually.
• Liaising with the NSPCC, Local Authority Designated Officer (LADO) and other statutory bodies as required.

In the absence of the DSL, any safeguarding concern should be reported directly to the relevant statutory authority (see Section 6).

5. Recognising Signs of Concern

All MediBrain UK staff and coaches have a responsibility to be alert to possible signs that a young person may be experiencing harm or abuse. Within an online coaching environment, indicators may include:

Behavioural Indicators

• Sudden or unexplained changes in behaviour, attitude or engagement.
• Signs of anxiety, distress, withdrawal or fearfulness during sessions.
• Disclosures (direct or indirect) of abuse, neglect or harm at home or elsewhere.
• References to self-harm, suicidal thoughts or extreme hopelessness.
• Sudden disengagement from the programme without explanation.
• Inappropriate or sexually explicit language or behaviour during online sessions.

Online Indicators

• Evidence of contact with unknown adults via MediBrain UK platforms.
• Sharing of personal information in group chats that could make a student vulnerable.
• Exposure to or sharing of inappropriate content during sessions.
• Requests from third parties for student contact details.

6. Reporting Procedures

Step 1 — Listen and Reassure

If a student makes a disclosure, remain calm and listen carefully. Do not promise confidentiality. Reassure the student that they have done the right thing by speaking out. Use open questions and avoid leading questions. Do not press for more detail than the student offers voluntarily.

Step 2 — Record

As soon as possible after a disclosure or concern, write a factual record of what was observed, said or disclosed. Use the student's exact words where possible. Record the date, time and names of all parties involved. Do not add opinions or interpretations.

Step 3 — Report to the DSL

Report the concern to the Designated Safeguarding Lead (Faizan Sharief) by email at info@medibrainuk.co.uk or by phone on +44 7346 147072 as soon as possible and no later than the same working day.

Step 4 — DSL Action

The DSL will assess the concern and decide on next steps, which may include:

• Contacting the student's parent or guardian (unless doing so would put the student at greater risk).
• Making a referral to the local authority children's services (via the relevant MASH — Multi-Agency Safeguarding Hub).
• Contacting the police if there is an immediate risk of harm.
• Seeking advice from the NSPCC Helpline: 0808 800 5000.

External Reporting Contacts

• Emergency services: 999
• NSPCC Helpline: 0808 800 5000 (free, 24/7)
• Childline (for young people): 0800 1111
• Bolton MASH (Local Authority): 01204 331500
• LADO (Local Authority Designated Officer): Contact via Bolton Council if a concern involves a member of staff or coach.

7. Online Safety

The majority of MediBrain UK's delivery takes place online via Microsoft Teams, WhatsApp and email. We have adopted the following online safety measures:

Session Conduct

• All live coaching sessions are conducted via Microsoft Teams. Sessions may be recorded for the purpose of sharing resources with participants. Students are informed of recording at the start of each session.
• One-to-one sessions between a coach and a student under 18 are only conducted with parental consent and with the session logged by the DSL.
• Coaches must not communicate with students under 18 via personal social media accounts, personal WhatsApp numbers or any platform not approved by MediBrain UK.
• All communications with students must be professional, appropriate and proportionate.

WhatsApp Groups

• Student cohort WhatsApp groups are moderated by a designated MediBrain UK team member at all times.
• Students under 18 are added to group chats only with parental consent obtained during enrolment.
• No student's personal contact details are shared with other students without their explicit consent.
• Inappropriate content posted in group chats will result in immediate removal and a safeguarding review.

Cameras and Privacy

• Students are encouraged to keep their camera on during sessions but this is not mandatory.
• Coaches must never request or pressure a student to share their camera if they are unwilling to do so.
• Screenshots or recordings of sessions must not be made by coaches or students without explicit permission from MediBrain UK.

8. Confidentiality

MediBrain UK respects the privacy of all students and their families. Information shared within our programmes is treated as confidential. However, confidentiality cannot be guaranteed where there is a risk of harm to a young person or others.

If a safeguarding concern arises, only those who need to know will be informed. Information will be shared with statutory agencies on a need-to-know basis in line with UK data protection law (UK GDPR and the Data Protection Act 2018).

Staff and coaches must never promise a student that they will keep a disclosure secret. If a student asks for confidentiality before making a disclosure, the staff member should explain that they may need to share information to keep the student safe.

9. Safer Recruitment

MediBrain UK is committed to recruiting coaches, tutors and staff who are suitable to work with young people. Our safer recruitment process includes:

• DBS Checks: All coaches, tutors and staff who have regular contact with students under 18 are required to hold an Enhanced DBS (Disclosure and Barring Service) check before commencing work with MediBrain UK.
• References: A minimum of two professional references are obtained and verified for all new coaches and tutors prior to engagement.
• Identity Verification: Identity documents are checked and recorded for all coaches and tutors.
• Safeguarding Training: All new coaches and tutors receive safeguarding induction training prior to their first session with students.
• Right to Work: Right to work in the UK is verified for all paid staff and contractors.

MediBrain UK will not knowingly engage anyone who is barred from working with children or young people. Engagement of any individual on the DBS barred list is a criminal offence.

10. Training

MediBrain UK ensures that all staff, coaches and tutors receive appropriate safeguarding training:

• All new coaches and tutors complete safeguarding awareness training as part of their induction before working with students.
• The Designated Safeguarding Lead (Faizan Sharief) completes DSL-level safeguarding training and refreshes this training every two years.
• All team members are provided with a copy of this policy and are required to confirm they have read and understood it before commencing work.
• Safeguarding is included as a standing agenda item in team briefings and any significant updates to legislation or guidance are communicated to all staff promptly.

11. Record Keeping

MediBrain UK maintains secure records of all safeguarding concerns, disclosures and actions taken. Records are:

• Stored securely and separately from general student records, accessible only to the DSL and relevant directors.
• Factual, dated and signed by the person making the record.
• Retained for a minimum of six years following the end of the student's engagement with MediBrain UK (or until the individual turns 25 if they were under 18 at the time of the concern, whichever is longer).
• Processed in accordance with UK GDPR and the Data Protection Act 2018 — see our Privacy Policy for full details.

12. Related Policies

This Safeguarding Policy should be read alongside the following MediBrain UK policies:

• Privacy Policy
• Terms and Conditions
• Cookie Policy

Where any conflict arises between this policy and any other MediBrain UK document, the provisions of this Safeguarding Policy shall take precedence in matters relating to the welfare of young people and vulnerable individuals.

13. Policy Review

This policy will be reviewed annually by the Designated Safeguarding Lead and the MediBrain UK directorship, or sooner in response to:

• A safeguarding incident or concern within MediBrain UK.
• Changes to relevant UK legislation or statutory guidance (including updates to Working Together to Safeguard Children).
• Significant changes to MediBrain UK's services, delivery model or staffing.

MediBrain UK Ltd · Company No. 16970579 · Registered in England and Wales
Last updated: 23 May 2026 · Next review due: May 2027