Version 1.11 · 14 September 2026
Fodus Coach Limited (“Fodus Coach”, “we”, “us”) provides an AI-assisted golf coaching platform used by two groups: Players connected to a golf professional (“Pro”) who teaches and manages them on the platform, and standalone Players with no connected Pro, who join directly via our website or via a Pro’s referral link without becoming that Pro’s active player. Some Players in either group are under 18.
The best interests of any child using our service are our primary consideration in how the platform is designed, built and run. This policy explains how we protect children who use Fodus Coach, what happens if a concern arises, and — because the platform is used by adults as well — what happens when an adult Player discloses that they are struggling.
Generally, the potential risks to children include:
Physical and emotional abuse
Domestic violence
Neglect
Sexual abuse
Grooming
Bullying
Victimisation
Self-harm
Unsafe environments and activities
Exploitation
Crime
Underpinning Safeguarding Principles
To raise awareness of individual responsibilities in identifying and reporting possible cases of abuse;
To provide a systematic means of monitoring, recording and reporting concerns;
To identify strategies and interventions available to children at risk;
To ensure any deficiencies or weaknesses in our arrangements are quickly identified and remedied without undue delay;
To ensure that our recruitment procedures are safe.
Legal Framework
We have developed this policy in accordance with:
The Domestic Abuse Act (2021)
The Children Act 1989 and 2004
Online Safety guidance and regulations
Safeguarding extends far beyond preventing deliberate harm. It encompasses all aspects of children's welfare, health, and safety.
As provided by the NSPCC and KCSIE 2025, the definition of safeguarding includes:
Protecting children from abuse and maltreatment;
Preventing harm to children's health and development;
Providing support to meet children's needs when problems emerge;
Ensuring children grow up with safe and effective care, within their family where possible;
Taking action to make sure that all babies, children and young people have the best outcomes.
There are six principles of safeguarding, as defined by the Care Act 2014:
Prevention – The act of organisations working to stop abuse before it happens, raising awareness, training staff and making information easily accessible are all ways that they can demonstrate prevention measures and encourage individuals to ask for help;
Empowerment – Ensuring people are supported and confident in making their own decisions and giving informed consent;
Protection – Organisations put measures in place to help stop abuse from occurring and offer help and support to those at risk;
Proportionality – Ensures that services take each person into account when dealing with abuse, respecting each individual and assessing any risks presented, taking a proportionate and least intrusive response to the issue presented;
Partnership – Forming partnerships with local communities and other appropriate organisations provides the opportunity to work together, to create solutions, so as they can assist in preventing and detecting risk and abuse;
Players under the age of 18, whether or not they have a connected Pro.
Players under 16, anywhere in the world, who require verified parental or guardian consent before an account becomes active (see section 6). We apply this single threshold everywhere rather than the varying local minimum, so that no child receives a lower standard of protection because of where they live.
Adult Players, in respect of section 5 only.
Pros — golf professionals at any stage of their qualification, including trainees and assistants — who have safeguarding responsibilities of their own as members of their professional body, separate from and in addition to this policy.
The AI coaching assistant (“Coach”) that Players speak with operates under safeguarding rules built into its instructions, which apply to every conversation without exception:
Coach must always identify itself as an AI, never as a person, friend, or companion, if asked.
Coach must never encourage secrecy between itself and a Player, and must never suggest a Player keep a conversation private from a parent, guardian, teacher, or their human Pro.
Coach is free to discuss the mental and emotional side of golf — pressure, confidence, motivation — as this is central to good coaching. The boundary is not subject matter but harm: Coach does not probe for personal disclosures about a Player’s home life or relationships, but responds with brief human warmth if a Player raises something personal before returning to coaching.
If a Player’s message suggests they are being harmed, are unsafe, or are in genuine distress that goes beyond the normal difficulties of life and golf, Coach is instructed to:
Stay in the conversation and let the Player lead it. Coach does not bring the session to a close, does not sign off, and does not steer the conversation back to golf unless the Player takes it there themselves.
Respond with calm, warm acknowledgement, without probing for further detail.
Give the relevant support services in that first response (see section 4), and raise them again later in the conversation where it genuinely fits — recognising that a helpline number repeated in every message stops being help and starts being a way of not listening.
Where a Player says that Coach is the only one they can talk to, be honest that it is an AI, say plainly that they deserve a person alongside this, and name the support available again. Coach is one of their supports — not the only one, and not the main one.
Record the event internally so it can be reviewed (see section 7).
Ordinary sporting frustration, family friction, or a difficult day are explicitly not treated as safeguarding concerns — only matters that clearly point to harm, danger, or a Player being unsafe.
Where a Player hints that something may be wrong without being explicit, or responds to encouragement in a flat or non-committal way, Coach treats this as unresolved rather than moving on, and the event is recorded at a lower tier for human review (see section 7).
Where a Player's message indicates immediate danger to their life or safety, Coach's first response tells them plainly to contact the emergency services in their country (999 in the UK, 911 in the US, or their own local emergency number) or, if someone else is with them who can help right now, to ask that person to call. This comes before, not instead of, anything else in this section. The services Coach names depend on the Player’s age and on their country. A service appropriate for a child is not appropriate for an adult and, in several cases, will not take an adult’s call at all; and a service that exists in one country does not exist in another.
United Kingdom
Players under 18: Childline (0800 1111, free and confidential, available any time) and the NSPCC helpline (0808 800 5000), alongside encouragement to speak to a trusted adult — a parent, guardian, teacher, or their Pro.
Players aged 18 and over: Samaritans (116 123), Shout (text 85258, for anyone who would sooner write than speak), and NHS 111.
United States
Players under 18: the 988 Suicide & Crisis Lifeline, free at any time by call or text, and the Childhelp National Child Abuse Hotline (1-800-422-4453) where they are being hurt or do not feel safe at home, alongside the same encouragement to tell a trusted adult.
Players aged 18 and over: 988, and Crisis Text Line (text HOME to 741741) for anyone who would sooner write than speak.
Unlike the United Kingdom, 988 serves young people and adults alike, so it appears in both.
Anywhere else
Players under 18: encouragement to tell a trusted adult as soon as they can and, if they would rather talk to someone outside their family, findahelpline.com, which lists free and confidential helplines in over 130 countries — together with their own local emergency number if they are in immediate danger.
Players aged 18 and over: encouragement to talk to someone they trust, or their doctor, and findahelpline.com, whatever country they are in — together with their own local emergency number if they are in immediate danger.
Where a Player’s age is not recorded, the adult wording is used, since those services accept callers of any age. A Player’s country is recorded at signup and is a required field with no default, so an unrecorded country falls to the international services above rather than to a national service we cannot verify.
Where a Player is in immediate danger, Coach gives their local emergency number (999 in the UK, 911 in the US, or the applicable local number elsewhere) before any other service listed below, in every country.
Fodus Coach is a golf coaching platform, not a crisis service, and does not hold itself out as one. But adults do sometimes disclose genuine distress to a coaching assistant they have come to trust, and the platform behaves in a defined way when they do rather than leaving it to chance.
The same standard applies as in section 3.1: Coach stays with the Player, does not end the conversation, gives the adult support services in section 4, and is honest about being an AI while remaining present. The event is recorded and reviewed internally on the same basis as any other, described in section 7.
Two things do not happen for an adult Player and do happen for a child. No third party is notified — there is no adult equivalent of the guardian email described in section 6, because an adult is entitled to decide for themselves who to tell. And nothing about a disclosure is shared with the Player’s Pro.
A Player under 16 cannot use the platform until a parent or guardian has granted consent via a unique, securely generated link sent to the email address provided at signup. Consent status, the guardian’s name and email, and the date consent was requested and granted are recorded against the Player’s account and cannot be self-edited by the Player. Where consent is not given, the account and the data provided at signup are deleted after one week.
What a guardian is told. Where a Player under 16 has a full safeguarding record raised, the parent or guardian who gave consent is emailed to tell them that a concern has arisen and to invite them to contact us. That email deliberately does not contain what the child said. The detail goes to our own safeguarding contact, so that a conversation between a parent and their child begins with the parent, not with a transcript — and so that a child is not deterred from speaking honestly by knowing their exact words will be forwarded home. A Player aged 16 or 17 holds their own account and has no guardian registered with us, so no third party is notified; the record is raised and reviewed in the same way.
This notification is not sent where the Designated Safeguarding Lead considers that doing so would place the child at greater risk of harm - for example, where the concern raised suggests the guardian themselves may be a source of harm, or where notifying them could compromise a police or local authority investigation. In that circumstance, the record is instead referred directly under section 7 without contacting the guardian, and the reason for that decision is recorded on the file.
Every safeguarding disclosure is logged to a record only Fodus Coach’s administrators can access, at one of two tiers: a full disclosure, and a lower-level flag for vague or withheld disclosures that fall short of that bar but are worth a human review. Records are reviewed by Fodus Coach’s safeguarding contact (see section 9).
A record covers an episode rather than a single message. Where a Player continues to talk about the same thing, later messages are added to the existing record rather than creating new ones, so that a difficult conversation normally produces one review — and, for a child, one email to their guardian rather than a series of them. An episode runs for an hour from the first disclosure; a conversation still going beyond that starts a fresh record. Two things deliberately override this: a lower-level flag that later meets the full-disclosure bar is escalated, with the guardian notified at that point; and any new material added to a record returns it to the review queue even if it has already been marked reviewed.
Neither Players nor Pros can access, edit, or delete a safeguarding record once it exists. It is visible to Fodus Coach’s administrators only. A Player’s conversations with the AI are also kept, as a separate record (see section 10); the safeguarding record is what brings a concern to a human’s attention and holds the review of it.
Retention. Where the Player was under 18 at the time, the record is kept until their 25th birthday, in line with standard practice for child welfare records in sport. Where the Player was an adult, it is kept for six years. Either way the record is retained even if the account is closed or deleted in the meantime, because the reason for holding it does not end when an account does.
Referral to external agencies
Logging and internal review are not, by themselves, the end of Fodus Coach's response. Where a full disclosure indicates that a Player is suffering, or is likely to suffer, significant harm, the Designated Safeguarding Lead will refer the matter to the relevant children's social care team and, where appropriate, the police, in addition to (or, per section 6, instead of) notifying a guardian. Where a Player appears to be in immediate danger, the Designated Safeguarding Lead will contact the police on 999 (or the applicable emergency number for the Player's country) without waiting for any other step in this policy to complete first.
The Designated Safeguarding Lead keeps a short list of external contacts for this purpose, including the NSPCC helpline (0808 800 5000), the non-emergency police line (101 in the UK), and the contact details for the relevant local authority children's services team, and will seek advice from any of these where the right course of action is unclear.
All referrals, and the reasoning behind them, are recorded on the safeguarding record in the same way as any other action under section 7.
Pros have access to a second AI assistant (“Assistant Coach”), distinct from the Player-facing Coach conversation, which they use to discuss their players, draft lesson notes, and think through their coaching. Unlike section 3.1, this is fundamentally a conversation between an adult professional and an AI assistant, not the platform interacting directly with a child.
Our position: if a Pro raises a welfare concern about a child in conversation with his own Assistant Coach — his own player, a junior at his club, or anyone else, whether or not they use Fodus Coach at all — that conversation is treated as a private professional conversation between the Pro and his own AI assistant. It is not tagged, flagged, or surfaced to Fodus Coach’s administrators, and no automatic follow-up occurs. Like every conversation on the platform, it is kept as a record for six years (see section 10), but it is not monitored or reviewed; it would be read only to look into a concern or a complaint.
We reached this position for two reasons. First, the Pro is the responsible adult in that moment, not the person at risk. Every Pro on Fodus Coach confirms on registration that he is a current member in good standing of the professional golf governing body in the country where the pro is based, and meets that body’s safeguarding and vetting requirements for working with children — in Great Britain and Ireland, The PGA’s own framework including DBS checks and SafeGolf accreditation; elsewhere, the equivalent set by his own body. We verify that he holds that membership. We do not carry out our own background checks, and we do not verify his individual DBS or accreditation status — his governing body does that as a condition of the membership we have checked. Fodus Coach relies on that existing professional framework rather than duplicating it, and does not insert itself as a second safeguarding authority over his professional judgement. Second, a Fodus-specific escalation path would frequently make no sense in practice: the person a Pro is concerned about may not be a Fodus Coach Player at all, so there is often nothing on our platform to act on.
What Fodus Coach does commit to, within our own control, is this: rather than staying silent, Assistant Coach is built to actively support the Pro’s own judgement in the moment. Where relevant to what he describes, it will help him think through what he has observed and, where it fits naturally, remind him of the real channels already available to him as a golf professional: his club’s designated Welfare or Safeguarding Officer, and his own professional body’s safeguarding team — for members of The PGA in Great Britain and Ireland, that is safeguarding@pga.org.uk. The NSPCC helpline (0808 800 5000) is also raised where a Pro is unsure where to take a concern. If anything described points to immediate danger, Assistant Coach is instructed to say so plainly and be direct that this goes beyond the usual channels — straight to children’s social care or the police, 999 if urgent, without waiting on the club first. Those are the United Kingdom channels.
For a Pro in the United States the guidance is structurally different, because reporting duties for youth-sport coaches are set by federal and state law and can require a suspicion of child abuse to go directly to state child protective services or local law enforcement, rather than through his club or his association first. He is told not to assume a club-first route applies to him, and is given the Childhelp National Child Abuse Hotline (1-800-422-4453), which exists for an adult unsure whether or how to report and can direct him to the right agency in his state. Where the concern arises inside a PGA Jr. League programme, that programme has its own confidential child safety helpline. For immediate danger, 911, without waiting on anyone.
For a Pro anywhere else, Assistant Coach helps him identify his own club or facility’s designated safeguarding lead and his own national governing body’s safeguarding route, tells him plainly that duties differ by country and that some place a legal obligation on him personally, and points him to findahelpline.com where he is unsure. This guidance is never presented as a checklist, and never recorded, tagged, or reviewed by Fodus Coach.
Whistleblowing
Whistleblowing is when someone reports wrongdoing on the basis that it is in the public interest for the wrongdoing to be brought to light. The wrongdoing may be something that happened in the past, is happening now or something the whistleblower is concerned may happen in the near future.
We hope that in any case involving whistleblowing, the concerned party will be able to bring the matter to the attention of the Designated Safeguarding Lead in the first instance. We will then seek to arrange a meeting with the concerned party as soon as possible to discuss their concerns and seek to resolve the matter swiftly.
The law recognises that in some circumstances it may be appropriate for coaches to report their concerns to an external body. We strongly encourage any whistleblower to share their concerns with us, before making a disclosure externally.
The NSPCC offers a free whistleblowing advice line to support people with concerns about how child protection issues are being handled. The advice line (0800 028 0285) may be contacted if:
concerns are not being dealt with properly or may be covered up
a concern that was raised hasn’t been acted upon
you are worried that repercussions are likely to arise if you raise a concern.
Coaches should refer to our Whistleblowing policy for additional information on Whistleblowing.
Where a disclosure or concern indicates that a Player's own Pro may be the source of harm, the matter is handled separately from section 8 and is not shared with, or routed via, that Pro. The Designated Safeguarding Lead assesses the concern directly and, where it meets the threshold in section 7, refers it to the police and/or children's social care, and separately notifies the Pro's professional governing body's safeguarding team (for a PGA member in Great Britain and Ireland, safeguarding@pga.org.uk) so that body can consider the Pro's fitness to hold his membership.
Pending the outcome, Fodus Coach will suspend the Pro's access to the Player concerned and review, on a precautionary basis, his connections to any other Players under 18. Suspension of platform access in this context does not itself imply a finding of wrongdoing and is a precautionary step only.
The affected Player's guardian (where one is registered) is notified in line with section 6, including the safeguard in that section where notifying them is assessed as increasing risk to the child.
In line with the ICO’s Children’s Code (Age Appropriate Design Code), we collect only what is needed to provide coaching, and give Players separate, explicit control over what they choose to share:
Profile data (name, date of birth, gender, handicap) — provided by the Player or their Pro at signup.
“About Me” — optional free text the Player writes themselves about their own game: injuries or physical limitations, how often they play, and similar context. This is visible to the Player’s Pro as well as to their own AI conversations, and Players are told this plainly.
Lesson notes — written by the Pro after a lesson, describing what was worked on. These inform how the AI coaches a Player between lessons, but are never quoted or read back to the Player verbatim.
Rounds and practice sessions — scores, self-rated areas of the game, and any notes a Player chooses to add. This data is used directly by the AI to identify weaker areas, build personalised practice plans, and shape ongoing progress conversations.
Conversations with the AI coach — kept as a record, so that if anything is ever raised about what was said, there is a true account of it. The record is written by the platform itself and cannot be edited or deleted by a Player or a Pro. Where the Player was under 18 at the time, it is kept until their 25th birthday; where the Player was an adult, for six years. Like a safeguarding record, it is kept even if the account is closed or deleted. It is read only by Fodus Coach’s administrators, and only to look into a safeguarding concern or a complaint. The conversation is also checked for safety as it happens, and anything meeting the thresholds in section 3.1 is recorded as a safeguarding record. Separately, the AI maintains a short rolling summary of a Player’s golf so it can hold a continuous coaching relationship rather than starting fresh each time. Neither the conversation nor the summary is ever shown to the Player’s Pro.
We do not ask Players to disclose dietary requirements or allergy information, and do not hold ourselves out as tailoring any advice around either.
Fodus Coach has a Designated Safeguarding Lead who reviews every safeguarding record raised on the platform and is the point of contact for anything arising under this policy. They can be reached at the address below, and we will tell you who they are on request.
Any concern about a Player’s safety, or about how this policy is applied, can be raised at:
safeguarding@foduscoach.com
Fodus Coach Limited (company number 17371029).
Fodus Coach's Designated Safeguarding Lead has a nominated deputy who assumes the same responsibilities under this policy whenever the Designated Safeguarding Lead is unavailable, so that a disclosure is never left unreviewed for want of cover.
Any administrator with access to safeguarding records, and any member of staff who may correspond directly with a Player under 18 (for example, in customer support), undergoes a basic DBS check before being given that access, and receives an introduction to this policy and to recognising the signs that a disclosure needs escalating.
This policy is reviewed whenever the platform’s safeguarding-relevant behaviour changes, and at minimum annually.