CHILD PROTECTION POLICY
Safeguarding & Child Protection Policy
March 2026
1. Policy Statement
SubMotion Productions Ltd recognises that children and young people have the right to participate in film and media projects in ways that are safe, positive and respectful. We believe there are clear benefits for both young contributors and audiences when children are given
appropriate opportunities to take part in creative work.
We have a duty of care to safeguard and promote the welfare of all children and young people who participate in, contribute to, or are otherwise involved in our productions. We are equally mindful of the potential impact our content may have on child audiences and online users.
Safeguarding is central to our production planning and operational processes.
For the purpose of this policy:
• A "child" refers to anyone under the age of 18.
• The welfare of the child is paramount in all decision-making.
2. Scope
This policy applies to:
• Children and young people appearing in or contributing to our productions
• Children present on set or location
• Children engaging with interactive or digital content produced by SubMotion
• Employees, freelancers, contractors and suppliers working on behalf of SubMotion
3. Our Commitment
SubMotion Productions Ltd is committed to:
• Ensuring that the safety, dignity and emotional wellbeing of children are prioritised at all times.
• Providing safe, welcoming and age-appropriate environments for children involved in filming.
• Ensuring that children are treated with respect as individuals and offered equality of opportunity.
• Minimising the risk of physical, emotional or psychological harm during participation and following broadcast or distribution.
• Ensuring that no child is subjected to bullying, harassment, exploitation or inappropriate conduct.
• Maintaining clear communication with parents or legal guardians throughout the production process.
• Designating a named Designated Safeguarding Lead (DSL) within the production team for all safeguarding matters.
• Handling any personal data relating to children in accordance with UK GDPR and data protection legislation.
4. Designated Safeguarding Lead
SubMotion Productions Ltd will designate a named Designated Safeguarding Lead (DSL) for each production involving children. The DSL is the first point of contact for all safeguarding concerns and is responsible for ensuring this policy is implemented on set and throughout
the production.
The DSL for SubMotion Productions Ltd is:
Name: Rachel Prendergast
Role: Founding Director & Producer
Email: rachel@submotion.net
Telephone: 07738975569
Where the DSL is unavailable, senior leadership will assume responsibility and ensure a deputy is appointed for the duration of any production involving children. Contact details for the current DSL will be shared with all crew members, parents and guardians at the start of each production.
5. Licensing & Legal Compliance
SubMotion Productions Ltd will comply with all relevant legislation including:
• The Children and Young Persons Acts
• The Children (Performances and Activities) (England) Regulations 2014 (or relevant Home Nation equivalent)
• The Children Act 1989 and 2004
• The Equality Act 2010
• UK GDPR and Data Protection Act 2018
Where a child is performing, modelling, presenting or participating in regulated activity for the purposes of entertainment, a performance licence will be obtained from the relevant local authority in advance of filming, in accordance with statutory requirements.
We will comply with all conditions set by the licensing authority, including those relating to:
• Maximum working hours
• Rest breaks
• Education requirements
• Supervision arrangements
Children requiring a licence will be accompanied at all times by a parent, legal guardian, or appropriately licensed chaperone.
Children will not be required to work outside permitted hours without explicit approval from the relevant licensing authority.
6. Parental Consent
Written consent from a parent or legal guardian will be obtained before any child participates in a SubMotion production. This consent will clearly set out:
• The nature and purpose of the production
• How footage or content featuring the child will be used and distributed
• The platforms or channels on which the content may appear
• Any foreseeable long-term digital footprint implications
• The right to withdraw consent and the process for doing so
Consent forms will be retained securely and in accordance with UK GDPR. Consent will be sought separately for any use of a child’s image or contribution beyond the original agreed purpose. No child’s image, voice or personal details will be used without valid, documented
parental or guardian consent.
7. Safeguarding Training
SubMotion Productions Ltd recognises that effective safeguarding depends on informed and aware team members. Accordingly:
• The Designated Safeguarding Lead will hold an up-to-date safeguarding qualification appropriate to their role, and will refresh this training at least every two years.
• All employees and regular freelancers working directly with children will complete introductory safeguarding awareness training before or at the start of relevant productions.
• All crew members will be briefed on key safeguarding expectations, the identity of the DSL, and how to report a concern before any production involving children commences.
• Training records will be maintained and made available upon request.
SubMotion Productions Ltd will identify and access appropriate training through recognised providers, including ScreenSkills, the NSPCC, or locally accredited safeguarding training programmes.
8. Safe Production Practices
Safeguarding considerations will be integrated into pre-production risk assessments and scheduling. This includes:
• Identifying potential physical and emotional risks
• Ensuring appropriate supervision ratios
• Conducting enhanced DBS checks where legally required
• Ensuring clear behavioural expectations for cast and crew
• Preventing unsupervised contact between children and adults not known to them
All crew members are expected to behave professionally and appropriately when working with children. Any inappropriate behaviour will be addressed immediately and may result in removal from production.
9. Digital & Online Safety
Where children participate in content that is distributed online or via social platforms, consideration will be given to:
• The potential long-term digital footprint
• Online audience interaction and moderation
• Protection of personal data and identifying information
• Avoiding content that could expose children to harm or exploitation
Parents or guardians will be informed of distribution platforms and consent will be obtained
where required (see Section 6).
10. Reporting Concerns
Any safeguarding concern must be reported immediately to the Designated Safeguarding Lead (DSL). If the concern involves the DSL, it should be reported directly to senior leadership or to the relevant statutory authority.
Escalation process:
• Step 1: Report the concern immediately to the DSL. Do not investigate alone or delay reporting.
• Step 2: The DSL will assess the concern and determine the appropriate response, which may include internal action, consultation with statutory agencies, or an immediate referral.
• Step 3: Where there is reasonable concern that a child is at risk of harm, the DSL will refer the matter to the relevant Children’s Services team or contact the police without delay.
• Step 4: Where an allegation is made against a member of staff, crew or volunteer, the DSL will contact the Local Authority Designated Officer (LADO) within one working day. The LADO for Norfolk can be reached via Norfolk County Council’s LADO referral process.
• Step 5: All concerns, decisions and actions taken will be recorded in writing and retained securely.
SubMotion Productions Ltd will take all safeguarding concerns seriously, act promptly and proportionately, and maintain confidentiality where possible. No individual will suffer detriment for raising a safeguarding concern in good faith.
11. Monitoring & Review
This policy will be reviewed annually, or sooner in the event of:
• Changes in legislation
• Updated statutory guidance
• Learning arising from production experience
• Any safeguarding incident
Senior leadership retains responsibility for ensuring this policy is implemented and embedded across all productions.
Rachel Prendergast
Founding Director & Producer
March 2026
Safeguarding Action Statement
SubMotion Productions Ltd is committed to maintaining robust safeguarding practices across all productions involving children and young people. Over the next three years, we will strengthen our safeguarding processes by embedding formal safeguarding consideration into pre-production planning and risk assessments for any project involving children. This will include clearly designating a named safeguarding lead
within the production team, confirming licensing requirements at the earliest stage, and ensuring that appropriate supervision and welfare arrangements are in place before filming begins.
We will maintain awareness of current safeguarding legislation and guidance and ensure that relevant team members understand their responsibilities when working with children. All crew members working directly with children will complete safeguarding awareness training, and the DSL will hold an up-to-date recognised safeguarding qualification. Where legally required, appropriate DBS checks will be undertaken.
Parental consent will be sought and documented for all child participants, covering the nature of the production, distribution arrangements, and the long-term implications of digital content. No child’s image or contribution will be used without valid written consent.
We will also ensure that digital distribution and online engagement are assessed for safeguarding implications, particularly in relation to consent, moderation and the long-term digital footprint of participating children.
Safeguarding practice will be reviewed annually by senior leadership to ensure it remains aligned with legislation, industry best practice and the scale of our operations.
Rachel Prendergast
Founding Director & Producer
March 2026
SubMotion Productions Ltd, 15 Palace Street, Norwich, United Kingdom, NR3 1RT
Company No.: 10701573 VAT No.:267789532