Legal

Child safety policy

Version 4 · Updated Wednesday, 7 October 2026

Last updated: October 2026

# 1. In short

Tumble helps families find and book children's activities provided by independent activity providers.

The provider is responsible for safeguarding children during its activities. This includes the provider's staff, volunteers, premises, supervision, staffing arrangements, safeguarding procedures and compliance with the requirements that apply to its setting.

Tumble does not run those activities and does not employ the people delivering them.

Tumble nevertheless takes child safety seriously. We build safeguarding-related information and controls into the platform, require providers to give us information about their safeguarding arrangements, and act on safeguarding concerns that are reported to us.

Tumble does not currently independently verify every safeguarding declaration, DBS check, qualification, insurance policy or registration supplied by a provider.

We say this clearly because families should not interpret a provider's presence on Tumble as meaning that Tumble has inspected or independently approved that provider.

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# 2. If a child is in immediate danger

If a child is in immediate danger, call 999.

Do not rely on Tumble to provide an emergency response.

For a concern about a child's welfare where there is no immediate emergency, contact the relevant local authority children's services or other appropriate safeguarding authority.

You can also contact the NSPCC Helpline for advice.

If the concern relates to an activity or provider listed on Tumble, you should also tell us so that we can take appropriate action within our role.

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# 3. Why we are explicit about what Tumble does and does not check

Tumble introduces families to independent activity providers.

We do not employ the people who deliver those activities and we do not operate the providers' premises.

A provider may therefore have legal or regulatory obligations that Tumble does not have.

We believe it is safer to tell families exactly what Tumble checks, records and does not check rather than create the impression that a provider has been independently approved by Tumble when that is not the case.

A provider appearing on Tumble does not mean that Tumble has independently verified every safeguarding or suitability statement made by that provider.

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# 4. What Tumble does

Tumble provides tools and processes designed to help providers manage information relevant to children's safety.

Depending on the provider and service, this includes:

Provider safeguarding information

Tumble allows providers to record information such as:

  • DBS checks;
  • safeguarding training;
  • first-aid training;
  • insurance;
  • risk assessments;
  • safeguarding policies;
  • registrations or memberships; and
  • relevant expiry or renewal dates.

Where the system supports expiry dates, Tumble can remind providers when information is approaching expiry.

Recording information in Tumble does not mean that Tumble has independently verified it.

Information about children

For a booked activity, Tumble can provide the provider with relevant information needed to help keep a child safe.

This may include:

  • child's name;
  • age or date of birth;
  • allergies;
  • relevant medical information;
  • additional needs;
  • emergency contact information;
  • authorised collection arrangements; and
  • whether the parent or carer has authorised the child to leave independently.

Tumble aims to minimise the information shown to a provider.

A provider should only receive information relevant to children attending its activities.

Collection arrangements

Tumble records whether a parent or carer has authorised a child to leave an activity without an adult.

An unanswered question is not treated as permission for a child to leave alone.

Where a provider uses Tumble's collection functionality, the provider remains responsible for checking the child's collection arrangements and applying its own safeguarding procedures.

Attendance and registers

Tumble provides providers with tools for managing:

  • session registers;
  • attendance;
  • check-in;
  • check-out;
  • collection;
  • staffing information; and
  • relevant emergency information.

Where available, Tumble's registers can be used without an internet connection so that a provider can continue to access relevant information if connectivity is unavailable.

Staffing information

Tumble may provide providers with tools that help them identify staffing or supervision issues.

For example, a provider may configure expected staffing requirements for a session and Tumble may warn the provider where the recorded staffing level appears insufficient.

The provider remains responsible for deciding the appropriate staffing arrangements and complying with any legal or regulatory ratios or supervision requirements that apply to its activity.

Tumble does not determine whether a provider's staffing arrangements are legally adequate.

Records

Where the provider uses Tumble's relevant functionality, the system may retain records of:

  • registers;
  • attendance;
  • check-in and check-out;
  • collection;
  • incidents;
  • relevant session information; and
  • who was recorded as teaching or supervising.

Tumble uses appropriate technical controls to reduce the ability for records to be changed without a trace.

Where an amendment is made to a relevant record, the system may retain an audit record of the change.

This does not mean that Tumble guarantees that every provider record is complete or accurate.

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# 5. Children's information is not public

Tumble does not publicly display children's personal information.

A child's name, age, medical information, safeguarding information or photograph is not published on public Tumble activity or provider pages.

Providers receive information about the children attending their own activities in accordance with the applicable booking and privacy arrangements.

A provider does not receive information about another provider's families merely because the same family uses both providers.

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# 6. What Tumble does not currently do

Tumble does not currently:

  • independently verify every DBS declaration;
  • inspect DBS certificates;
  • check DBS records directly with the Disclosure and Barring Service;
  • independently confirm every safeguarding qualification or training record;
  • inspect provider premises;
  • observe provider sessions;
  • independently determine whether a provider's staffing ratios comply with the law;
  • independently verify every insurance policy;
  • independently verify every risk assessment;
  • conduct Ofsted inspections; or
  • act as a substitute for the police, local authority safeguarding teams, Ofsted or another regulator.

Where a provider supplies a declaration or records information in Tumble, that information remains the provider's responsibility unless Tumble expressly says that it has independently verified it.

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# 7. What families should ask providers

Families should satisfy themselves that an activity is suitable for their child.

You may wish to ask a provider about:

  • DBS checks;
  • safeguarding arrangements;
  • staff qualifications and training;
  • first-aid cover;
  • supervision and staffing ratios;
  • insurance;
  • premises and facilities;
  • collection arrangements; and
  • what the provider does if a child becomes unwell or there is an emergency.

A provider should be able to explain the arrangements that apply to its activities.

Tumble can provide information that a provider has chosen to publish or record on the platform, but that information should not be treated as Tumble's independent certification of the provider.

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# 8. What we ask providers to do

Providers using Tumble agree to comply with the safeguarding obligations applicable to their activities and setting.

Depending on their circumstances, this includes having and maintaining:

  • appropriate safeguarding arrangements;
  • appropriate DBS checks and other suitability checks where required;
  • appropriately trained staff and volunteers;
  • appropriate first-aid arrangements;
  • appropriate insurance;
  • appropriate risk assessments;
  • appropriate staffing and supervision;
  • appropriate policies and procedures;
  • any registration, licence or approval required for their activities; and
  • appropriate procedures for dealing with safeguarding concerns and allegations.

Providers must keep the information they give Tumble accurate and up to date.

Providers must tell Tumble promptly where a serious incident, allegation, regulatory action, loss of required insurance, change in registration or other event materially affects their ability to provide activities safely.

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# 9. Tumble's response to safeguarding concerns

If Tumble receives a safeguarding concern about a provider, activity, member of staff, volunteer or other person connected with an activity, we will record the concern and assess what action is appropriate.

Depending on the circumstances, this may include:

  • contacting the person who reported the concern;
  • requesting further information;
  • contacting the provider;
  • restricting access to relevant Tumble functionality;
  • temporarily suspending or removing a provider's listing;
  • preventing new bookings;
  • preserving relevant records;
  • advising or directing the reporter to contact the police or local authority;
  • making a referral or disclosure to an appropriate authority where required or appropriate;
  • seeking professional or legal advice; and
  • cooperating with the police, local authority, regulator or other competent authority.

Tumble does not investigate safeguarding allegations as a substitute for the police or statutory safeguarding authorities.

Where an allegation may place a child at risk, Tumble may take precautionary action before the facts have been established.

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# 10. Suspension while a concern is considered

Where Tumble considers that a concern presents a potentially serious risk to children, we may temporarily:

  • suspend a provider's listing;
  • prevent new bookings;
  • restrict access to Tumble;
  • restrict particular staff or user accounts where technically and legally appropriate; or
  • take another proportionate precautionary measure.

We do not need to establish that an allegation is true before taking a precautionary platform-safety measure.

A temporary suspension is not necessarily a finding that a provider or individual has committed wrongdoing.

Where appropriate, we will tell the provider why action has been taken and give them an opportunity to provide information.

We may withhold information where doing so could:

  • put a child or another person at risk;
  • interfere with a police or safeguarding investigation;
  • compromise confidential information;
  • create a risk of evidence being destroyed; or
  • otherwise be unlawful or inappropriate.

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# 11. Reporting a concern to Tumble

You can report a safeguarding concern to:

Allyn Aaron — Designated Safeguarding Lead [email protected]

When reporting a concern, give us as much relevant information as you safely can.

This may include:

  • the provider;
  • activity;
  • date and time;
  • people involved;
  • what happened;
  • whether a child is currently at risk; and
  • whether the police or local authority has already been contacted.

Do not delay contacting the police or local authority while waiting for a response from Tumble.

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# 12. Reporting concerns to statutory authorities

Tumble is not a statutory safeguarding authority.

Where a matter requires statutory intervention, the appropriate authority may include:

  • the police;
  • the relevant local authority children's services;
  • the Local Authority Designated Officer (LADO), where applicable;
  • Ofsted, where applicable; or
  • another relevant regulator or safeguarding body.

Tumble may make a referral or cooperate with an authority where required or appropriate.

We may also advise the person reporting a concern to make a referral themselves.

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# 13. Information and confidentiality

Safeguarding concerns may contain highly sensitive information.

We will restrict access to safeguarding information to people who need it for the relevant purpose.

We may share information without the consent of the person who provided it where we consider this necessary or appropriate to protect a child, comply with the law, prevent serious harm, or cooperate with a competent authority.

We will not promise absolute confidentiality where doing so could prevent us from taking appropriate action to protect a child.

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# 14. Safeguarding information about providers

Tumble may hold information relating to a provider's:

  • safeguarding arrangements;
  • DBS checks or declarations;
  • training;
  • insurance;
  • risk assessments;
  • incidents;
  • allegations;
  • registration; and
  • compliance with Tumble's provider requirements.

Some of this information may be personal data.

We handle it in accordance with our Privacy Notice, applicable data-protection law and our contractual arrangements with providers.

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# 15. Safeguarding records

Where Tumble receives or creates a safeguarding record, we may retain it for as long as reasonably necessary for:

  • safeguarding;
  • legal or regulatory compliance;
  • responding to complaints;
  • investigating or responding to incidents;
  • preventing repeat harm;
  • defending or bringing legal claims; or
  • cooperating with statutory authorities.

Safeguarding records may therefore be retained for longer than ordinary account information.

We do not delete safeguarding records simply because a provider or family closes its Tumble account where there is a continuing lawful reason to retain them.

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# 16. What parents and carers should remember

Tumble is a platform, not the organisation delivering the activity.

Before booking, parents and carers should consider whether the activity and provider are suitable for their child.

You should:

  • keep your child's medical and safeguarding information up to date;
  • tell the provider directly about urgent or important safety information;
  • check the provider's safeguarding arrangements if you have concerns;
  • follow the provider's collection procedures; and
  • report serious concerns promptly.

Tumble's platform controls are intended to support providers' safeguarding arrangements, not replace them.

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# 17. Our limits

Tumble cannot guarantee that:

  • a provider has complied with every safeguarding obligation;
  • information supplied by a provider is complete or accurate;
  • a DBS check is current merely because a provider has recorded one;
  • a provider's staff or volunteers are suitable merely because they appear on Tumble;
  • an activity is free from risk; or
  • an incident will never occur.

Nothing in this policy excludes or limits any legal responsibility Tumble may have.

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# 18. Contact

Tumble / Rhythm Limited

Designated Safeguarding Lead: Allyn Aaron

Email: [email protected]

24 St. Stephens Gardens London W2 5QX England

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# Legal-review schedule

Before publication, Tumble's solicitor and safeguarding adviser should confirm:

1. Tumble's safeguarding legal duties: identify responsibilities arising from Tumble's own platform, contracts, representations and actual knowledge, rather than assuming Tumble is merely an introducer.

2. Provider safeguarding obligations: map the requirements for different provider types and activities, including clubs, camps, children's activities, holiday schemes and potentially regulated childcare.

3. DBS wording: confirm exactly what providers are legally required to obtain and whether Tumble's current provider declarations are appropriately worded.

4. Ofsted wording: ensure the policy does not imply that every children's activity requires Ofsted registration or that Tumble is responsible for determining registration status.

5. Staffing-ratio functionality: confirm that the product's ratio warnings are presented as provider-configured operational tools rather than Tumble certification that a session is legally staffed.

6. Safeguarding lead: confirm that Allyn Aaron is formally appointed to the role and has appropriate authority, training and availability.

7. Escalation procedure: document an internal decision tree for: - immediate danger; - allegation against a provider; - allegation against a member of staff; - allegation against a volunteer; - allegation involving another child; - historic allegations; - concerns about provider documentation; - missing/expired safeguarding information; and - complaints about Tumble itself.

8. Suspension threshold: establish when Tumble automatically suspends a listing, when it may suspend pending investigation, and when it can leave a listing live subject to restrictions.

9. Authority notification: establish when Tumble contacts the police, children's services, LADO, Ofsted or another authority, and who makes that decision.

10. Record preservation: establish a process for preserving relevant Tumble records where a safeguarding concern or legal investigation arises.

11. Confidentiality: ensure the policy aligns with the Privacy Notice, UK GDPR and safeguarding information-sharing principles.

12. Provider terms: ensure the Provider Terms contain enforceable obligations corresponding to this policy, including duties to: - maintain safeguarding arrangements; - keep declarations current; - notify Tumble of serious incidents; - cooperate with investigations; - provide accurate information; and - accept suspension/restriction where necessary for safeguarding.

13. Family terms: ensure the consumer T&Cs do not contradict this policy or accidentally suggest that Tumble has independently certified providers.

14. Children's Code / DPIA: ensure the safeguarding and child-data functionality is reflected in Tumble's Children's Code assessment and relevant DPIA.

15. Insurance: confirm Tumble's own insurance position and whether the policy's wording around provider insurance accurately reflects Tumble's contractual requirements.

16. Emergency communications: establish who receives safeguarding emails, the expected response time, backup contacts and out-of-hours arrangements.