Who we are

Empathia is a product of Elygra Ltd, a company registered in England and Wales.

Company registration number: 04640811 Registered address: Elygra Marketing Services Units 11-13 The Quad, Sovereign Way, Sealand Rd, Chester CH1 4QP. Contact: [email protected]

Our commitment

Elygra Ltd is committed to the safety and wellbeing of every child and young person who may encounter Empathia content. We recognise that the platform is used in school settings, with children and families, and that this creates responsibilities that go beyond standard data protection or content compliance.

This policy sets out how we embed safeguarding at every level of the Empathia platform — from how content is created and reviewed, to how we respond if a concern is raised.

Regulatory framework

This policy has been developed in accordance with:

Keeping Children Safe in Education (KCSIE) 2024

Working Together to Safeguard Children 2023

The Online Safety Act 2023

The ICO Age-Appropriate Design Code (Children's Code)

The Equality Act 2010

The SEND Code of Practice 2015

UK GDPR and the Data Protection Act 2018

We review this policy annually and following any significant change to relevant legislation or statutory guidance.

Content safeguarding

All Empathia content is developed with child safety as a primary consideration. Specifically:

Content review process Every script is reviewed before production against our editorial standards, which include explicit safeguarding criteria. These criteria address: age-appropriate language and concepts, avoidance of shame-based or punitive framing, accuracy of any mental health or SEND-related content, and appropriateness for the identified audience.

Co-creation with practitioners Content is developed in collaboration with practising SENCOs and school staff. This ensures that content reflects the realities of school safeguarding practice and is consistent with the approaches schools are required to take under KCSIE.

Content for children experiencing EBSNA or SEMH difficulties Scripts designed for children experiencing emotionally based school non-attendance (EBSNA) or social, emotional and mental health (SEMH) difficulties carry specific production notes recommending that they are used as part of a wider, agreed support plan — not in isolation. These notes are included in the platform guidance for each relevant resource.

Children's data Children do not create accounts on the Empathia platform. Content intended for children is accessed and shared by adults — teachers, SENCOs, parents, and carers. Where content is personalised for an individual child (for example, a personalised social story), that personalisation takes place locally within the school and no personally identifying information about the child is transmitted to or stored by Elygra Ltd.

Platform safeguarding

Age-Appropriate Design The platform has been designed in accordance with the ICO's Age-Appropriate Design Code. Children do not have accounts, do not submit data, and are not exposed to features designed for adult users.

Ethics Advisory Board An Ethics Advisory Board is being established to provide independent oversight of Empathia's content, platform development, and safeguarding practice. The Board will include practitioners with expertise in SEND, child safeguarding, and digital ethics. [Further details to be published in September 2026.]

Responding to safeguarding concerns

Empathia is a content platform — we do not provide direct services to children, and our staff do not have direct contact with children through the platform. However, we recognise that concerns may occasionally arise in connection with platform use.

If you have a concern about a child Empathia content is used in school settings where trained safeguarding professionals are responsible for child protection. If you have a concern about a child's safety or wellbeing, your first point of contact should be the Designated Safeguarding Lead at the relevant school.

If the concern relates to something within Empathia's content or platform that you believe may pose a risk to children, please contact us immediately at [email protected] We will acknowledge your contact within one working day and respond fully within five working days.

If you believe a child is at immediate risk Contact the police on 999 or your local authority's children's social care emergency duty team.

Reporting concerns about our content or platform We take all concerns about the safety, appropriateness, or impact of our content seriously. To report a concern:

Staff and contractor safeguarding

All Elygra Ltd staff and contractors who work on Empathia content or platform development are subject to:

Enhanced DBS checks where required

Safeguarding awareness training

Adherence to this policy as a condition of engagement

Compliance and audit

This policy is reviewed annually by the DSL and approved by [ROLE/BOARD].

A record of all safeguarding concerns received and our responses to them is maintained securely by the DSL.

Our compliance framework — covering UK GDPR, the Online Safety Act, KCSIE, the Age-Appropriate Design Code, the Equality Act, the SEND Code of Practice, and applicable AI regulatory frameworks — is available in full on request.

A Data Protection Impact Assessment (DPIA) for the Empathia platform is currently in progress. Voluntary consultation with the ICO is planned prior to commercial launch.