Safeguarding Policy

Designated Safeguarding Lead: Gautam Sureshkumar — safety@cotraofficial.co.uk Deputy Designated Safeguarding Lead: Pratyush Ramesh — safety@cotraofficial.co.uk

If a child is in immediate danger, call 999. Do not report it through the app first. Cotra is not an emergency service and does not provide a 24-hour response.

1. Purpose and scope

Cotra is a coach-management app for UK grassroots sport, beginning with cricket. Coaches on Cotra work with children. This policy sets out how Cotra Limited handles safeguarding concerns arising through the platform, who is responsible, and what happens when a concern is raised.

It applies to everyone using Cotra — coaches, parents and guardians — and to Cotra's own directors and staff.

It does not replace the safeguarding policy of a coach's club, county board or national governing body. Where a coach is bound by the ECB's safeguarding requirements, or by a club or venue policy, those continue to apply in full. This policy sits alongside them and covers the part Cotra is responsible for: the platform.

2. Our position on children

Children do not have Cotra accounts. Cotra onboards adults — coaches, and parents or guardians. A child cannot sign up, cannot sign in, and is not a user. All bookings and all messages are made and managed by an adult.

Every user must confirm at onboarding that they are 18 or over and understand this. The confirmation is recorded with a timestamp.

What this does and does not mean. Cotra holds no child accounts and collects no child contact details, date of birth, photograph or medical record. But when a guardian books a session, they can type free text saying who the session is for, and in practice they will often enter a child's first name. So Cotra may hold a child's first name in connection with a booking. We state this plainly rather than claiming no child is ever named.

3. Who is responsible

Both the DSL and the Deputy are contactable at safety@cotraofficial.co.uk.

Cotra does not employ coaches and does not deliver coaching. Responsibility for the safe conduct of a session sits with the coach, and with the club or venue where it takes place. Cotra's responsibility is for the platform: providing a way to raise concerns, acting on what is raised, and referring onward when the threshold is met.

4. What we require of coaches

Every coach must, when Cotra sets up their coach account, confirm that:

1. They are aged 18 or over and legally permitted to provide coaching services in the UK.
2. They hold any DBS check, safeguarding training and governing-body clearance required for the coaching they carry out — by law, by their national governing body, by their club, or by the venue.
3. They are not subject to any current safeguarding investigation, and are not barred from working with children.
4. They will tell Cotra immediately if any of the above changes.

This confirmation is recorded with a timestamp. Coaches do not self-register on Cotra — every coach is onboarded personally — so the declaration is made to us directly during that onboarding.

Cotra does not currently collect, hold or verify DBS certificates. We record the coach's declaration; we do not check the underlying document. This is stated plainly here, in the Coach Agreement, and to guardians, so that nobody mistakes a Cotra account for a vetting badge.

Why attestation rather than verification, for now. Verifying certificates would mean Cotra handling criminal-offence data under Article 10 of the UK GDPR, which requires an Appropriate Policy Document, restricted access and a defined retention period — and the product has no document storage of any kind. At current scale, with a small number of personally onboarded coaches, a recorded declaration plus the ability to suspend is proportionate. This is a decision to revisit, not a permanent position: see §14.

A coach who makes a false declaration is in breach of the Coach Agreement and will be removed.

5. What Cotra can and cannot see

Being honest about this matters, because a policy that implies more oversight than exists is worse than one that admits its limits.

Cotra can see: messages sent between a coach and a guardian through the app, bookings, and anything reported to us. Message content is stored in the UK and is readable by Cotra only through direct database access, which is restricted.

Cotra cannot see: anything that happens at a session. Cotra is not present, does not observe coaching, and has no way of knowing what occurs in person. Nor can Cotra see conversations that move to WhatsApp, text or phone.

Cotra does not monitor messages proactively. There is no automated scanning of chat. We act on what is reported to us.

6. Raising a concern

If a child is in immediate danger, call 999.

Otherwise, there are three routes, and they are deliberately separate:

• In the app — the shield icon in any chat reports a message or a person. This is the fastest route and captures the message as evidence automatically.
• By email — safety@cotraofficial.co.uk, monitored by the DSL and Deputy. Use this for anything that isn't about a specific message, and for anything you would rather not report from inside the app.
• Directly to the authorities — you never need Cotra's permission or involvement to contact the police, children's social care or the NSPCC. See §9.

Concerns about a coach do not go through that coach. A coach owns their space in the app, but safety@cotraofficial.co.uk reaches Cotra directly and the coach is not told a report exists, is not shown its contents, and cannot access or delete it. If your concern is about the coach themselves, use that address.

You can report anonymously by email. It may limit what we can do, but we would rather know.

7. What happens after you report

Every report is logged and reviewed by the DSL. Our target response times:

These are the same figures shown in the app when you submit a report. They are a target for first review, not a guarantee of resolution, and they are not an emergency service.

Depending on what we find, we may:

• Remove the offending message. Removal overwrites the message content — it is not merely hidden.
• Remove a guardian from a coach's space, or support either party in blocking the other.
• Suspend a coach's account while a concern is looked at.
• Ban an account outright, preventing sign-in.
• Refer the concern to an external authority — see §9.

We will tell the person who reported that we have acted, but we will not share details of any action taken against another person.

A safeguarding referral does not wait for the reporter's agreement. If the DSL believes a child may be at risk of harm, the referral is made regardless of whether the reporter wants it to be. We will normally tell you if we are going to do this, unless telling you would increase the risk to the child.

8. Cotra does not investigate

If a concern suggests a child has been harmed or is at risk of harm, Cotra's job is to record it accurately and pass it to the people whose job it is — not to establish what happened.

We will not question a child. We will not confront the person a concern is about before referring. We will not ask a guardian to gather evidence. Attempting our own investigation risks contaminating a real one.

What we will do is preserve what we hold — the report, the message evidence, the account records — and make it available to the authority handling the case.

9. External referral

The DSL will refer a concern onward where a child may have been harmed or may be at risk of harm, where an adult's behaviour towards a child gives cause for concern, or where a criminal offence may have occurred.

If in doubt, the DSL contacts the NSPCC Helpline or the local authority for advice. Uncertainty about whether the threshold is met is a reason to seek advice, never a reason to do nothing.

Referral does not depend on the concern being proven, and it does not depend on the incident having happened on Cotra. If it comes to us, we act on it.

10. Allegations about a coach using Cotra

Where a concern is about a coach on the platform:

1. The DSL will consider suspending the coach's account immediately, before any assessment of the merits. Suspension is a neutral protective step, not a finding.
2. The concern is referred to the LADO for the relevant local authority, and to the police where a criminal offence may have occurred.
3. The coach's club, county board or governing body is informed where they have their own safeguarding process.
4. Cotra will not tell the coach the identity of the person who raised the concern.
5. Guardians in that coach's space will be told that the space is suspended. They will not be told why.

Where an allegation is upheld, or where a coach is barred from working with children, the account is permanently banned and the relevant governing body is informed.

11. Records and retention

Safeguarding records are kept in Cotra's UK database (London region), readable only through restricted database access — not through the app, and not by any other user.

Two deliberate rules sit behind this. An unresolved report is never deleted, however old — a report nobody has acted on is a backlog problem, not a retention one. And a safeguarding record survives account deletion: if the person a report is about deletes their account, the report remains, with the personal identifiers severed. A moderation record its own subject can erase on demand is not a record.

Where a concern has been referred externally, the authority handling it may need the material months or years later, and destroying it on a two-year timer would be indefensible. Referred cases are marked as such in the database and are permanently excluded from the routine deletion process.

12. How the product is designed to reduce risk

These are deliberate decisions, recorded so that the reasoning survives:

• Invite-only, with no discovery. There is no public directory, no search, and no way for one user to find another. A guardian reaches a coach only by redeeming that coach's invite. Strangers cannot contact each other on Cotra.
• No group chat. All messaging is one-to-one between a coach and a single guardian. Even a coach's "message everyone" sends into each guardian's private thread. A group thread would let a guardian broadcast a child's health or personal information to people they don't know.
• No uploads. There is no photo, video or file sharing anywhere in the product. No image of a child can be posted, because no image can be posted.
• Database-enforced access control. Every table denies access by default; a guardian can see a coach's sessions and messages only while they are a member of that space. This is enforced in the database, not in the app.
• Reports capture their own evidence. When a message is reported, a copy is taken at that moment, so the evidence survives even if the message is later removed.
• No behavioural tracking. No analytics, no advertising SDK, no profiling of any user.

13. Training

Before Cotra operates beyond its initial pilot, the DSL and Deputy DSL will complete a recognised child-safeguarding course for sport — the ECB's or the NSPCC's — and will refresh it at least every three years. Completion is recorded and this section updated when it is done.

14. Review

This policy is reviewed annually, and immediately on any of the following:

• The first safeguarding concern of any kind, whether or not it is referred.
• Any expansion beyond invited guardians — a public directory, open sign-up, or coach discovery. The controls in §12 depend on the invite-only model and stop holding without it.
• Any change that lets children hold accounts.
• Any change that introduces uploads, group messaging or in-person events run by Cotra.
• Growth beyond a small number of personally onboarded coaches — at which point the attestation decision in §4 should be reconsidered in favour of verification.
• A change in the ECB's or the DBS service's requirements for self-employed coaches.

15. Contact

Safeguarding concerns: safety@cotraofficial.co.uk Designated Safeguarding Lead: Gautam Sureshkumar Deputy Designated Safeguarding Lead: Pratyush Ramesh

Cotra Limited, Company No. 17285541 65 Burgoyne Road, Sunbury-On-Thames, England, TW16 7PS

In an emergency, call 999. Do not wait for us.