Child safety standards

GradeLens exists to hold information about children. That places a duty on us that goes beyond ordinary data protection, and these are the standards we hold ourselves to. They are published rather than kept internal, because a standard nobody can read is not a standard.

Our absolute prohibition

Child sexual abuse and exploitation ("CSAE") is absolutely prohibited in connection with GradeLens and every other service we operate. This includes child sexual abuse material, grooming, sextortion, trafficking, and any other sexual exploitation or abuse of a child. There is no context, no exception and no tolerance.

Any account involved in such conduct is terminated immediately and permanently, and the matter is reported to the South African Police Service and to any other competent authority. We will preserve and hand over evidence as the law requires. This prohibition is also written into our Terms of Use.

How GradeLens is designed to limit risk

The strongest child safety measure available to an app is not to build the risky thing in the first place. GradeLens deliberately has none of the features that make other apps dangerous for children:

• No child accounts. Children do not sign up, sign in, or use the app. Only an adult guardian holds an account.
• No messaging. There is no chat, no comments, no direct messages and no way for one user to contact another.
• No social features. No profiles visible to others, no friends, no followers, no discovery, no sharing between accounts.
• No user-generated content shown to anyone else. What you enter is visible only to you.
• No photos or media uploads. There is no image upload anywhere in the app.
• No location data. We never collect or store where anyone is.
• No advertising and no third-party tracking. No ad networks and no analytics SDKs receive anything about a child.
• Data isolation. Every API request is checked to confirm the account making it owns the data it asks for. One guardian cannot reach another's learners.

The practical effect is that GradeLens gives no stranger any route to a child. There is no surface to exploit because there is no contact surface at all.

Who may enter a child's information

Only a person entitled to consent on the child's behalf. Under POPIA that is a competent person — the child's parent, legal guardian, or someone else legally authorised. Every guardian confirms this when adding a learner, and it is a term of the agreement they accept.

We know a confirmation is not proof. So if anyone tells us a child's information has been entered without the right to do so, we investigate, and where the claim holds up we delete the information. We do not require a court order to act on a credible report from a parent or guardian.

Handling a report

1. Acknowledged within one business day. A CSAE report is acknowledged and triaged ahead of all other correspondence.
2. Assessed immediately. Where a child appears to be at risk, we act before completing any investigation rather than after.
3. Account action. We suspend or terminate the account involved as the circumstances require.
4. Reported to authorities. Suspected CSAE is reported to the South African Police Service and any other competent authority, with evidence preserved.
5. You are told the outcome, as far as the law and the privacy of others allow.

Reports in the app: GradeLens includes an in-app route to contact us so a concern can be raised without leaving the app. You can always email admin@ellermon.com instead.

Our internal commitments

• Access to production data holding children's information is restricted to those who need it, and is logged.
• We collect the minimum about each child that the app's purpose requires, and school is optional.
• Children's information is never used for advertising, profiling, marketing, or training machine learning models.
• Children's information is never sold, and never shared for anyone else's purposes.
• A named person — our Information Officer, Michael Ian Rolle — is accountable for child safety and privacy decisions.
• We review these standards at least annually and whenever the app gains a feature that touches children's information.

Where to get help in South Africa

Emergency

South African Police Service — 10111

Childline South Africa

0800 055 555 (free, 24 hours)

Gender-Based Violence Command Centre

0800 428 428

Report to us

admin@ellermon.com