Safeguarding and Safer Recruitment Policy

Purpose and scope

No one at Habbly teaches pupils or works with them in person as part of the homework service. Habbly Ltd (company number 16242486) provides language homework: teachers set it, secondary-school pupils complete it in the Habbly app or in a web browser, and their answers are marked automatically.

Our safeguarding responsibility is therefore about what pupils see in the app, what they can do in it, and what happens to what they write. This policy applies to everyone who works on Habbly, including contractors.

Designated Safeguarding Lead

Anyone at Habbly, or at a school using Habbly, who has a safeguarding concern connected with the service emails the DSL with "Safeguarding" in the subject line. The DSL replies within one working day.

The pupil’s school stays responsible for the pupil. Our job is to pass on quickly anything we see.

How the app keeps pupils safe

The Habbly app does not allow person-to-person messaging. The app is built that way:

• No messaging. There is no chat or messaging of any kind for pupils in the app. They cannot message each other, their teacher or anyone at Habbly through the app, and no adult can message them through it.
• No personal details. Pupils do not create an account or enter personal details. They sign in with a class code and a 4-digit PIN from their teacher.
• Names chosen by the teacher. Each pupil’s display name is set by their teacher: a first name, initials or a username.
• Microphone only when speaking. The microphone is used only during speaking exercises, never in the background. We keep the text of what was said, not the audio.

What pupils see: content and AI feedback

Everything a pupil sees is written or checked by Habbly. Homework questions and audio are written and reviewed by our team before they are published.

Some answers are marked by an AI model (from OpenAI), which writes short feedback for the pupil. We keep that feedback appropriate in three ways:

• Fixed instructions. The AI works from marking instructions written and reviewed by Habbly. They limit it to marking the pupil’s answer to the question and commenting on their French or Spanish.
• Regular checks. We review those instructions and regularly check samples of the real feedback pupils received.
• A report button on every question. A pupil can flag any question or its feedback in one tap. Flags come to the Habbly team and are reviewed.

If a pupil’s words raise a concern

We pass any concern to the pupil’s school on the same day. Habbly staff can see pupils’ typed answers and flag comments when they review marking or reports. If anything a pupil writes suggests they may be at risk of harm, abuse, self-harm or a crime:

1. 1The person who sees it tells the DSL the same day.
2. 2The DSL passes it to the school’s Designated Safeguarding Lead the same day, through the teacher who set the homework if the school’s DSL is not known. They send the pupil’s display name, class, the date and exactly what was written.
3. 3We do not contact the pupil or their family, and we do not investigate.
4. 4If a child appears to be in immediate danger, we call the police (999 in the UK, or the local emergency number).
5. 5The DSL records the concern, what was done and when, and keeps that record securely.

Access to pupil data and contact with pupils

Our routine emails and support go to teachers and schools. We may invite pupils to share feedback through school-coordinated activities, with appropriate permissions and safeguarding arrangements.

Access to pupil data is restricted to the people who build and run Habbly, and is used only to provide and support the service. Requests to see, correct or delete a pupil’s data come through the pupil’s teacher, and we delete a class’s data within 30 days of a request.

Safer recruitment

Everyone Habbly Ltd hires to work on Habbly is checked before they get access to pupil data. This covers employees, contractors and interns. Providing the homework service does not involve direct contact with pupils; any pupil feedback activities follow the school-coordinated arrangements described above. The checks are about trust with pupils’ names and answers.

No one Habbly hires is given access to pupil data until two checks are done:

• Identity: we see photo ID and confirm the person is who they say they are.
• Criminal record check: a basic DBS check, or, for someone who lives outside the UK, the equivalent police certificate from their country.

The DSL keeps a record of each check and the date it was done. Each person gets only the access their work needs, and their access is removed on their last day.

Review

The DSL reviews this policy at least once a year, and whenever Habbly adds a feature that changes what pupils can do or see in the app.