Safeguarding and Contact with Minors Policy

This Safeguarding and Contact with Minors Policy explains how CleverPATHS manages interactions involving children and minors in connection with its services.

CleverPATHS is a trading name of Intelligent Monitors Pty Ltd (ABN: 69 697 100 235) ("we", "us", "our").

This policy should be read in conjunction with our other applicable policies, including our Privacy Policy and any terms governing use of the CleverTrack system.

By using our services, you acknowledge that you have read and understood this policy.

Purpose

This policy is intended to:

• ensure transparency in interactions involving minors
• define the limits of our role and responsibilities
• reinforce that safeguarding responsibility rests with the subscriber
• establish appropriate safeguards within the CleverTrack system

Scope of Services

CleverPATHS provides:

• study hour tracking through the CleverTrack dashboard
• academic mentoring support limited to study motivation and academic performance

We do not provide:

• counselling, wellbeing, or mental health services
• supervision of minors
• behavioural or safeguarding intervention

Our services are strictly limited to academic tracking and mentoring.

Relationship and Responsibility

CleverPATHS has a contractual and service relationship solely with the subscriber (the responsible adult), not with the minor.

The subscriber is solely responsible for:

• determining whether the CleverTrack system is appropriate for the minor
• supervising the minor’s use of the service
• reviewing all communications within the platform
• ensuring safeguarding, welfare, and any necessary intervention

Use of the service does not transfer any duty of care to CleverPATHS.

Data Minimisation and Anonymisation

CleverPATHS does not require identifying personal information about minors.

Subscribers are:

• strongly encouraged to avoid entering identifying data
• encouraged to use nicknames or non-identifiable labels for both themselves and the minor
• responsible for ensuring that any data entered is appropriate and proportionate

The service is designed to function effectively without personal identification and should be used accordingly.

The subscriber is solely responsible for:

• any personal data entered into the system
• any decision to share or disclose that data externally

We do not control or monitor how subscribers use or share data outside the platform.

Communication Framework

All communication occurs exclusively through the CleverTrack dashboard.

The system is designed so that:

• all communication is visible to the subscriber
• no private or hidden communication channels exist within the platform

CleverPATHS personnel must not:

• communicate with minors outside the dashboard
• initiate or accept direct contact with minors
• engage via personal email, messaging apps, phone, or social media

If communication outside the platform is required:

• it may only be initiated by the subscriber
• we will not initiate off-platform contact

Nature of Mentor Interaction

Mentor interaction is strictly limited to academic engagement.

This includes:

• study motivation
• accountability prompts
• academic encouragement and challenge

Mentors must:

• maintain professional and appropriate communication at all times
• avoid personal, emotional, or non-academic discussions
• not engage in counselling or behavioural advice

Any attempt by a minor to move outside academic discussion must be redirected or discontinued.

Child Safety Compliance

CleverPATHS requires personnel engaging in mentoring roles to hold appropriate child safety clearances under Australian law, including a valid Working with Children Check (WWCC) where required.

These checks support safe engagement standards but do not replace the subscriber’s responsibility for supervision.

Safeguarding Boundaries

CleverPATHS operates within a limited academic scope.

We:

• do not actively monitor communications for safeguarding concerns
• do not provide safeguarding oversight or intervention
• do not assume responsibility for the safety or wellbeing of minors

Where concerning content is observed, we may notify the subscriber via the platform.

We are not obligated to:

• monitor all communications
• detect or interpret safeguarding issues
• report concerns to external authorities

All safeguarding responsibility remains with the subscriber.

System and Platform Limitations

The CleverTrack platform relies on software systems and infrastructure.

You acknowledge that:

• system visibility depends on technical performance
• communications may be affected by delays, outages, or limitations
• records may not always be complete or real-time

We are not responsible for:

• missed or delayed communications
• system-related visibility issues
• reliance on the platform for supervision

Limitation of Liability

To the maximum extent permitted by law, Intelligent Monitors Pty Ltd (including its officers, employees, contractors, and agents) excludes all liability for any loss or damage arising from or in connection with:

• interactions between minors and mentors
• use of the platform for tracking or communication
• failure to identify or respond to safeguarding concerns
• reliance on the service as a supervisory or safeguarding tool
• any data entered, shared, or disclosed by the subscriber
• actions or omissions of minors or subscribers

You acknowledge that:

• CleverPATHS provides a limited academic service only
• safeguarding responsibility remains entirely with the subscriber
• no duty of care is assumed in relation to minors

Where liability cannot be excluded, it is limited to the extent permitted by law.

User Acknowledgement

By using the service, the subscriber acknowledges that:

• they have assessed the suitability of the system for the minor
• they are responsible for all supervision and safeguarding
• they control what data is entered and how it is used
• CleverPATHS has no direct relationship with the minor

Changes to this Policy

We may update this policy at any time without prior notice.

The latest version will be published on the Website. Continued use of the service constitutes acceptance of any updates.

Governing Law

This policy is governed by the laws of New South Wales, Australia.

Contact

For enquiries regarding this policy, please use the contact details provided on the Website.