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:

• Guardian consent for every child. A learner under 18 either has no sign-in at all, because a guardian keeps their record on the guardian's own account, or signs in to their own learner account. For their own account, a parent or guardian must approve by email before it can be used, and the guardian has the final say over the learner's data, including deletion. A learner aged 18 or over decides for themselves.
• One person per sign-in. Every learner who uses the app signs in to their own account, with their own password or with Google. No one signs in on another person's account, and there are no shared sign-ins or PINs.
• A learner sees only their own information. Their subjects, terms, categories and weightings, report marks, assessments, calendar and events, and their own reminder and slip-alert settings. They can see the email addresses of the guardians linked to them, and nothing of any other child or any guardian's account. These limits are enforced on our servers for every request, not only in the app.
• 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, and a learner cannot reach a sibling's information.

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.

A guardian may invite a learner they have added to sign in with their own learner account, so the learner can add and edit their own information. A learner with their own account can also link a guardian to manage them. Either can end that link at any time.

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.
• Our Information Officer 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