Legal

Safeguarding & Child Protection Policy

Mindsetters Club · Mumbai, India · For members aged 13–16
Version 1.0 · August 2026 · Next review: August 2027

1. Purpose and scope

Mindsetters Club works with young people aged 13–16 through small-group (Inner Circle) and one-to-one coaching, workshops, masterclasses and events. We are committed to safeguarding and promoting the welfare of every young person in our care, and we expect all coaches, mentors, staff, volunteers, guest experts and contractors to share this commitment. This policy applies to everyone acting on behalf of Mindsetters, in person and online.

2. Our principles

  1. The welfare of the young person is always our first priority.
  2. Every young person, whatever their background, identity or ability, has an equal right to protection from harm.
  3. We listen to young people, take what they tell us seriously, and act on concerns.
  4. We have zero tolerance towards any form of abuse, harassment or bullying.

3. Legal framework

This policy is designed to be consistent with Indian law, including:

  1. The Protection of Children from Sexual Offences (POCSO) Act, 2012 and POCSO Rules, 2020 — including the mandatory duty to report offences.
  2. The Juvenile Justice (Care and Protection of Children) Act, 2015.
  3. The Commissions for Protection of Child Rights Act, 2005 (National Commission for Protection of Child Rights (NCPCR) and the Maharashtra State Commission for Protection of Child Rights).
  4. Relevant provisions of the Bharatiya Nyaya Sanhita, 2023 / Indian Penal Code.
  5. The Digital Personal Data Protection Act, 2023, in respect of children’s personal data (see Section 10 below and our Privacy Policy).

4. Roles and responsibilities

  1. Designated Safeguarding Lead (DSL): The DSL is Mindsetters' single point of accountability for safeguarding. All concerns, disclosures and allegations under this policy are to be reported to the DSL. The DSL is responsible for: compliance with this policy; receiving and logging concerns; ensuring safety of the young person; deciding on and making external reports to Police/SJPU (as defined below)/CWC (as defined below)/Childline/NCPCR or other authority as required by law; reporting any incident to the parents/guardians immediately and liaising with them; cooperating with the police or other authorities in relation to investigation of the matter; maintaining safeguarding records and ensuring their confidentiality; and ensuring staff receive induction and refresher training.
  2. Deputy DSL: who acts in the DSL's absence.
  3. Management/Leadership: responsible for ensuring this policy is implemented, resourced, and reviewed, and bears institutional liability for non-reporting under Section 21(2) of the POCSO Act where the organisation, through a person in charge, fails to report.
  4. All coaches, mentors, staff, volunteers, guest experts and contractors: responsible for following this policy, completing training, and reporting any concern to the DSL immediately, without delay. Reporting is mandatory — see Section 8.

5. Types of abuse we guard against

Physical abuse; emotional abuse; sexual abuse and exploitation (including online); neglect; online abuse; grooming; and harm, bullying (including cyberbullying) or peer-on-peer harm. Abuse can happen in person or online, and can be caused by adults or by other young people.

6. Recognising a concern

Signs may include unexplained injuries; sudden changes in behaviour, mood or withdrawal; fear of a particular person or place; age-inappropriate knowledge or language; or a young person telling you directly or indirectly that something is wrong. You do not need to be certain — a reasonable concern is enough to report. All safeguarding concerns must be raised with the DSL using the contact details specified herein without delay, and in any event immediately where a sexual offence is known or suspected, consistent with Rule 4 of the POCSO Rules, 2020.

7. Code of conduct for adults

  1. Always maintain professional boundaries; treat every young person with respect.
  2. Avoid being alone with a young person in a private or closed setting. One-to-one sessions must take place in an open, visible or approved space, with the parent/guardian aware.
  3. For online one-to-one sessions: use Mindsetters’ approved platform, keep cameras on, use an appropriate setting, and ensure the parent/guardian is aware. All sessions will be recorded only with prior verifiable consent to record from parents/guardians (see Section 10). Recordings are stored securely with access restricted to the DSL and designated leadership, and are retained for no longer than one year, after which they are deleted, subject to applicable laws.
  4. Communicate with young people only through Mindsetters’ official channels — never through personal phone numbers, personal email or private social media, and not in secret from parents.
  5. Do not give or receive gifts, lifts, or personal contact details outside the programme.
  6. Do not behave in a discriminatory manner or give special treatment to any child.
  7. Do not use punishment, aggression, or intimidation as a means of discipline.
  8. Exercise caution and follow cyber safety norms when using technology.
  9. Physical contact should be avoided except where clearly necessary and appropriate, and never in a way that could be misinterpreted.
  10. Never use, view or share content that sexualises or endangers a child, and never seek to isolate a young person from trusted adults.
  11. Immediately report any suspicion, allegation or disclosure of any form of abuse (as set out in Section 5 above) in accordance with the procedure set out in Section 8 below.

8. How to report a concern

  1. If a young person is in immediate danger, call the Police (112/100) and Childline (1098) straight away.
  2. Report the concern to the DSL immediately.
  3. The DSL will act on it immediately, including reporting it to the parents of the young person and — where there is knowledge or suspicion of a sexual offence — making a report to the local Police or Special Juvenile Police Unit (SJPU) and/or Childline 1098, as required by law under Section 19 of the POCSO Act and Rule 4 of the POCSO Rules, 2020. Where relevant, the matter will also be referred to the Child Welfare Committee (CWC) or reported via the NCPCR POCSO e-Box.

9. If a young person discloses something to you

  1. Stay calm, listen without expressing shock, disbelief or judgment, and take them seriously.
  2. Do not promise to keep it secret — explain you may need to tell someone who can help keep them safe.
  3. Do not question, lead or investigate; use open, gentle prompts only.
  4. Record what was said in the young person’s own words as soon as possible, with date and time, and pass it to the DSL immediately.
  5. It is to be noted that, in case of emergency and where required, the individual that becomes aware of an incident of abuse must administer first aid and/or CPR to the young person immediately, and/or taken to the nearest hospital for tests/investigative procedures by the DSL. In case of an incident of sexual abuse, the young person must not be subjected to any physical examination to ascertain any physical injuries directly.

10. Data protection, consent and confidentiality

  1. Verifiable parental consent: Under Section 9 of the Digital Personal Data Protection Act, 2023, Mindsetters obtains verifiable consent from a parent/lawful guardian before processing any member's personal data, including for programme enrolment, photography/video, and recording of sessions. Consent is verified using signed physical/digital form matched against government ID / OTP-linked parent registration, and records of consent are retained as evidence of compliance.
  2. Data retention: Personal data, recordings, and photographs/videos are retained only as long as necessary for the stated purpose (see Sections 7 and 13) and are securely deleted thereafter.
  3. Confidentiality and information sharing: Safeguarding information including details of any incident reported by a young person shall be shared strictly on a need-to-know basis. The safety of the young person always overrides a duty of confidentiality: where a young person or another person may be at risk of harm, or the law requires it, we will share information with parents/guardians and/or the relevant authorities, but with no one else. This is consistent with our Privacy Policy and the DPDP Act, 2023. We will not publicize or reveal the identity of a young person who has made a report under this policy unless as required by law.

11. Safer recruitment and training

We take reasonable steps to ensure adults working with our members are suitable, including identity verification, reference checks, police verification checks, verification of qualifications, and induction on this policy. All coaches, mentors, staff and volunteers receive safeguarding guidance, sign the acknowledgement in Section 17, and are expected to complete refresher training at least annually. Concerns about any adult’s conduct are treated as safeguarding matters.

12. Allegations against an adult in our organisation/allegations against peers

  1. Any allegation or concern about an adult, coach, mentor, staff member or volunteer must be reported to the DSL immediately. The DSL will act promptly, prioritise the child's safety, and — pending the outcome of any inquiry — apply appropriate interim measures, which may include suspending the individual from unsupervised or one-to-one contact with members. The DSL will investigate any allegation or concern and make recommendations for actions to be taken in the matter and external reports will be made as required by law.
  2. Any allegation or concern about another young person must be reported to the DSL immediately. The DSL will act promptly, prioritise the child's safety, and — pending the outcome of any inquiry — apply appropriate interim measures, which may include suspending the individual from unsupervised or one-to-one contact with members. The DSL will investigate any allegation or concern and make recommendations for actions to be taken in the matter and external reports will be made as required by law. The DSL shall inform the parents of the young person against whom allegations or concerns have been raised. The DSL shall ensure that the young person is not intimidated or subjected to repeated questioning/interrogation.
  3. After the completion of the investigation into an incident, the DSL shall prepare an incident report in the form set out in Annexure A including details of the result of the investigation and the actions taken to address the incident.

13. Photography, media and online safety

Photographs or video of members are taken and used only with verifiable parental consent (Section 10), stored securely, retained only as long as necessary, and never published with identifying personal details.

14. Whistleblowing and review

Anyone can raise a safeguarding concern in good faith without fear of penalty. This policy is reviewed at least annually, and immediately following any significant incident or change in the law.

15. False complaints or allegations

  1. Mindsetters Club will not tolerate misuse or abuse of this policy in the form of false allegations or complaints by any personnel, students, parents or others, for reasons of personal anger, vendetta, etc., and any such false allegations/complaints will be dealt with strictly.
  2. Mindsetters Club may take legal action in relation to the same and/or take disciplinary action (as recommended by the DSL).

16. Key contacts

  1. Designated Safeguarding Lead: Cheryl Dutta · connect@mindsettersclub.com
  2. Deputy DSL: [name · phone · email]
  3. Childline (24/7): 1098
  4. Police emergency: 112 or 100
  5. Local police station / SJPU
  6. Child Welfare Committee (Mumbai)
  7. NCPCR POCSO e-Box: ncpcr.gov.in · Cyber Crime: cybercrime.gov.in

17. Acknowledgment

I confirm I have read, understood, and agree to comply with the Mindsetters Club Safeguarding & Child Protection Policy.

Name: ______________________   Role: ______________________
Signature: ______________________   Date: ______________________

Annexure A — Incident Report

1. Incident Details

  1. Date: [MM/DD/YYYY]
  2. Time: [HH:MM AM/PM]
  3. Location: [Specific area]
  4. Reported By: [Name & Role]

2. Individuals Involved

  1. Name(s): [List all involved]
  2. Role: [Student/Staff/Visitor]

3. Witnesses

  1. Name(s): [List all]
  2. Role: [Student/Staff/Visitor]

4. Incident Description

  1. What happened? [Brief, factual account in the young person’s words]
  2. Actions taken on-site: [First aid, security, etc.]

5. Response & Follow-Up

  1. First Aid Provided? [Yes/No – If yes, details]
  2. Emergency Services Contacted? [Yes/No – Specify if applicable]
  3. Parents/Guardians Notified? [Yes/No – By whom]
  4. Further Actions: [Counselling, disciplinary actions, safety measures]

6. Reporting Officer

  1. Name: [Full Name]
  2. Position: [Job Title]
  3. Signature: ____________
  4. Date: [MM/DD/YYYY]