Child Safety & Safeguarding Policy

1.Purpose and commitment

HobbyDoor is committed to providing at-home hobby services in a manner that prioritises the safety, dignity, privacy and best interests of every child. This Policy applies to founders, directors, employees, interns, contractors, Instructors, agencies and relevant vendors whose role involves children, their homes, personal data or safeguarding information.

2.Legal framework

• Protection of Children from Sexual Offences Act, 2012 (POCSO) and applicable Rules.
• Juvenile Justice (Care and Protection of Children) Act, 2015 and applicable Rules.
• Digital Personal Data Protection Act, 2023 and applicable Rules, subject to commencement and applicability.
• Bharatiya Nyaya Sanhita, 2023 and Bharatiya Nagarik Suraksha Sanhita, 2023, where applicable.
• Commissions for Protection of Child Rights Act, 2005 and applicable guidance.
• Other applicable child-protection, safety and consumer laws.

3.Zero tolerance

• Sexual abuse, sexual harassment, grooming, exploitation, trafficking or child sexual abuse material.
• Corporal punishment, mental harassment, humiliation, intimidation or degrading treatment.
• Unwanted intimate contact or secret communications.
• Unauthorised photography, filming or recording.
• Retaliation against a child, Parent, witness or reporter.

4.Safer recruitment

• Identity/contact/address verification appropriate to the role.
• Lawful background verification and references where appropriate.
• Safeguarding induction before child-facing work.
• Acceptance of this Policy, Instructor Agreement and Code of Conduct.
• Prompt disclosure of material suitability concerns, subject to law.

5.At-home class rules

• A Parent, lawful Guardian or authorised responsible adult should remain at the premises and reasonably reachable throughout a child-facing class, unless a separately approved exception is risk-assessed and documented.
• Classes should take place in an observable and suitable area.
• No unauthorised transport or taking a child to another location.
• An Instructor is not a babysitter, guardian or general childcare provider by virtue of a booking.
• Approved attendance/check-in procedures must be followed.

6.Prohibited conduct

• Sexual conduct, grooming, solicitation, sexual comments or showing sexual content.
• Hitting, slapping, shaking, pushing as punishment, forced painful positions or other corporal punishment.
• Threats, insults, shaming, ridicule, discriminatory abuse or deliberate humiliation.
• Unnecessary intimate contact or unwanted physical contact.
• Private or secret communication with a child.
• Exchange of private contact/social-media details, gifts, money or favours outside approved processes.
• Photography, filming or audio recording except through an approved and lawful process.
• Attendance while impaired by alcohol, illegal drugs or other intoxicating substances.

7.POCSO and mandatory reporting

Where any person has knowledge of, or reasonable apprehension regarding, an offence for which POCSO imposes a reporting obligation, the statutory reporting requirements shall be followed. Reports should be made to the Special Juvenile Police Unit or local police as required by law. Internal reporting to HobbyDoor does not replace mandatory reporting.

No HobbyDoor person may instruct another person not to make a legally required report, require proof before a report that law requires to be made, or condition reporting upon Parent approval.

8.Child disclosure

Remain calm and listen without shock, anger or disbelief.

Take the child seriously and do not promise secrecy.

Use only minimal, open prompts necessary to establish immediate safety; do not conduct a private investigation.

Do not confront the alleged offender.

Record facts, exact words where possible, date/time, persons present and actions taken.

If immediate danger or urgent medical need exists, prioritise emergency services/police/medical assistance.

Make all reports required by law and notify the Safeguarding Lead promptly, unless doing so would create additional immediate risk or conflict with lawful directions.

9.Allegations against Personnel

• HobbyDoor may immediately remove a person from child-facing bookings or restrict Platform access as a neutral protective measure.
• Such action is not, by itself, a finding of guilt.
• Relevant records shall be preserved and protected from deletion, alteration or fabrication.
• HobbyDoor shall cooperate with lawful requests from police, SJPU, CWC, courts and other competent authorities.

10.Child in need of care and protection

Where circumstances indicate that a child may be in need of care and protection, HobbyDoor shall escalate to the appropriate competent mechanism, which may include the Child Welfare Committee, District Child Protection Unit, police or other competent authority, as required by the circumstances and law. Personnel must not independently remove or relocate a child except where authorised by law or necessary to address an immediate emergency.

11.Photography and digital communication

• No personal-device photography/recording for HobbyDoor purposes unless specifically authorised and lawfully consented.
• Verification photos should focus on class setup and avoid the child's face.
• Direct private messaging with a child is prohibited; communication should ordinarily be with the Parent/Guardian.
• No child image, testimonial, artwork linked to identity or identifying material may be used for marketing without required approval and consent.

12.Emergencies and injuries

• Use age- and activity-appropriate equipment and methods.
• Stop or modify unsafe activities.
• For injury/medical emergency, obtain appropriate assistance and inform the Parent immediately where safe and appropriate.
• Do not administer medication except under an approved lawful process.
• Record significant injuries, near misses and safeguarding incidents.

13.Confidentiality

Safeguarding information shall be shared on a strict need-to-know basis except where disclosure is required or permitted by law. HobbyDoor shall not promise absolute confidentiality where lawful reporting or safety disclosure is required.

14.Reporting route

15.Safeguarding Lead

16.Training and review

• Child-facing personnel shall receive safeguarding induction before or promptly after commencing child-facing work and periodic refreshers thereafter.
• HobbyDoor shall maintain appropriate records of policy acceptance, training, screening status and safeguarding incidents.
• This Policy shall be reviewed at least annually and after any serious incident, material service change or relevant legal change.

17.No retaliation

No person may retaliate against a child, Parent, Instructor, employee or witness for making a safeguarding report in good faith or participating in a lawful investigation.

18.Priority of law

If applicable law imposes a higher or more specific obligation than this Policy, the law shall prevail. Nothing in this Policy limits a statutory reporting duty or a child's right to protection.

GOVERNING LAW AND LEGAL EFFECT This Policy shall be governed by and construed in accordance with the laws of India and shall be implemented in accordance with all applicable child-protection and safeguarding laws, including the Protection of Children from Sexual Offences Act, 2012, and any applicable rules, regulations and statutory directions. Mandatory legal obligations shall prevail over any inconsistent provision of this Policy.

IN WITNESS WHEREOF, the parties/authorized representatives, as applicable, have adopted this document as part of the Company's governing contractual, policy and compliance framework.