Child and Adult Safeguarding Policy

Organisation: Indigital XYZ Limited, trading as Favoured

Company number: 10869455

Registered office: 446 Uxbridge Road, London, W12 0NS

Version: 1.0

Date of adoption: 30 September 2026

Review date: 30 September 2027

Approved by: Andrew Willers, Co-founder and Commercial Director

Responsible officer: Danielle Huddlestan, Head of Operations

Statement of intent

Favoured is committed to protecting children and adults at risk from harm in the course of its work. We accept that safeguarding is everybody’s responsibility, that a concern raised in good faith must never disadvantage the person raising it, and that the welfare of a child or an adult at risk comes before the delivery of a brief, a shoot schedule or a client relationship.

This policy applies to every employee and director, and to every freelancer, contractor and subcontractor engaged on our behalf. Engagement on a Favoured production is conditional on working within it.

Scope, stated honestly

Favoured is a fully remote marketing agency. We do not provide services to children or to adults at risk, we operate no premises to which the public has access, and we hold no care, education or custodial responsibility for anyone. We are not a regulated activity provider within the meaning of the Safeguarding Vulnerable Groups Act 2006.

We set that out plainly because the honest assessment of where our risk actually sits determines what this policy needs to control. There are three such places.

Location filming and photography. A minority of our work involves filming and stills photography on premises controlled by a client or a third party. A production may involve children as contributors or performers, or adults who are at risk by reason of disability, illness, age or circumstance. This is the setting in which our people have direct contact with children and adults at risk, and it is where this policy does most of its work.

Contributor and user-generated content. We commission, source and licence content in which children and adults at risk appear, including creator and influencer material we did not produce ourselves. Risk here is a matter of consent, permitted use and the accuracy of what we are told about the people depicted.

Community management and inbound contact. Where we manage a client’s social channels or inbound enquiries, a child or an adult at risk may disclose something that indicates harm, or may be exposed to harm by another user. That contact is unplanned, which is precisely why the route for handling it has to be decided in advance.

Responsibilities

The Board is accountable for safeguarding. Andrew Willers, Co-founder and Commercial Director, holds that accountability and approves this policy.

The Designated Safeguarding Lead is the named point of contact for any safeguarding concern, is responsible for deciding what a concern requires and for making any referral to a statutory agency, and maintains the record of concerns. Pending confirmation of the appointment, the Head of Operations discharges this role and any concern is escalated to a director the same working day.

Producers and shoot leads are responsible, for every production within scope, for confirming before the shoot which safeguarding arrangements apply, who is responsible for supervision, and what consents are held. A production does not proceed without that confirmation.

Every employee, freelancer and subcontractor is responsible for raising a concern. Nobody is asked to decide whether a concern is well founded, to investigate it, or to satisfy themselves that it is serious enough. The duty is to report it.

Arrangements

Productions involving children or adults at risk

Where a production involves a child or an adult at risk, we establish before the shoot, and record:

• Who holds the statutory and supervisory responsibility. On a client’s premises, in a school, in

a care setting or at a public event, that responsibility ordinarily rests with the organisation controlling the premises or with a parent, guardian or carer. We confirm in writing who it is.

• That a parent, guardian or carer is present or has given written consent and knows what the

child is being asked to do, where the material will appear, and for how long.

• **That no member of our team is alone and unobserved with a child or an adult at risk at any

point.** This is an absolute requirement and it is a matter of scheduling and crewing, not of individual judgement.

• Whether a licence or chaperone is required. Where a child performs in a production to which

the Children (Performances and Activities) Regulations apply, a licence from the child’s local authority and an approved chaperone may be required. Determining this is the producer’s responsibility before the shoot, and the client is told where the duty falls.

• The working-hours, break, supervision and welfare arrangements appropriate to the age of the

contributors, and the identity of the person responsible for them on the day.

Recruitment and vetting, proportionate to the work

We do not carry out regulated activity, so most of our roles carry no entitlement to a criminal record check, and we do not request checks we are not entitled to. Where a specific engagement does amount to regulated activity, or where a client’s own policy properly requires it, we obtain the appropriate Disclosure and Barring Service check, or the Northern Ireland or Scottish equivalent, before the engagement begins, and we will not place a person in that engagement until it is in place.

Freelancers and subcontractors engaged on productions within scope are told of this policy and of the reporting route before they start.

Consent, image use and data

Images and recordings of children and adults at risk are personal data, and consent to be filmed is not consent to unlimited use. We record what was consented to, including the channels and the duration, and we use the material only within it. A request to withdraw is acted on, and where material is already published we remove it from the channels we control and tell the client what we cannot reach. Material is stored under the access controls set out in our data protection documentation and is not retained beyond the consented period.

Where content is licensed from a creator or a third party, we require confirmation that the necessary consents and, for a child, parental consent were obtained, and we do not treat an assurance that material is “cleared” as evidence of it.

Concerns arising in community management

Anyone managing a client channel or inbox who encounters a disclosure or an indication of harm does not attempt to counsel, investigate or resolve it. They preserve the message, report it to the Designated Safeguarding Lead the same day, and follow the client’s own safeguarding route where the client has one. Where there is an immediate risk to life or of serious harm, the emergency services are called first and the report follows.

Reporting a concern

A concern is raised with the Designated Safeguarding Lead, in person, by telephone or in writing, and on the same day it arises. It is recorded with the date, what was observed or disclosed, in whose words, and the action taken.

The Designated Safeguarding Lead decides whether the concern requires referral to the local authority’s children’s or adult social care service, to the police, or to the client’s own designated lead, and makes that referral without delay. A concern is never held back pending a client’s agreement.

Where a concern is about a person engaged by Favoured, that person is removed from any contact with children or adults at risk while it is dealt with. Where the concern meets the harm test, a referral is made to the Disclosure and Barring Service.

Nothing in this policy prevents any person from reporting a concern directly to a statutory agency at any time, and no one will be penalised for doing so.

Consultation, monitoring and review

This policy is issued to all employees and to freelancers and subcontractors engaged on productions within scope. Safeguarding concerns and the action taken on them are reported to the Board.

The policy is reviewed annually, and additionally following any safeguarding concern, any material change in the nature of our work, and any relevant change in law or statutory guidance.

Signed on behalf of Indigital XYZ Limited, trading as Favoured: