Internal Policy Last Updated: October 2026

1. Purpose

NaTakallam provides online language-learning and cultural exchange services to students of different ages and backgrounds.

NaTakallam’s General Language Sessions may be provided to children from age 6, and its Integrated Curriculum may be adapted for children from age 10.

This policy establishes the minimum safeguarding standards that apply whenever NaTakallam employees, Language Partners (“LPs”), language instructors, contractors, volunteers, or other representatives interact with children or young people through NaTakallam programs.

The purpose of this policy is to:

• protect children from abuse, exploitation, grooming, harassment, and inappropriate conduct;
• establish clear professional boundaries;
• reduce safeguarding risks associated with one-on-one online learning;
• establish reporting and escalation procedures;
• clarify expectations for LPs and staff;
• protect children while preserving the educational and human exchange at the heart of NaTakallam’s model.

2. Scope

This policy applies to:

• NaTakallam employees;
• Language Partners;
• language instructors;
• contractors and consultants;
• volunteers;
• program facilitators;
• anyone acting on behalf of NaTakallam who may interact with a child through a NaTakallam program.

It applies to:

• one-on-one sessions;
• Integrated Curriculum sessions;
• school and university programs involving minors;
• organizational programs involving minors;
• email and other program-related communication;
• approved online platforms;
• any other interaction arising directly from a NaTakallam program.

3. Definitions

For this policy:

Child / minor: a person under 18.

Parent/guardian: a parent, legal guardian, or other adult legally authorized to provide consent or act on behalf of a child.

Language Partner (LP): a person providing language practice, conversation, or related educational services through NaTakallam.

Language instructor: an individual providing structured curriculum-based language instruction through NaTakallam.

Safeguarding concern: any concern, allegation, disclosure, observation, or information suggesting that a child may have experienced or may be at risk of abuse, exploitation, grooming, harassment, inappropriate conduct, or another form of harm.

4. Core Principles

NaTakallam’s approach to child safeguarding is based on the following principles:

1. The safety and well-being of the child come first.
2. Children should be treated with dignity and respect.
3. Children should be able to learn without fear of harassment, exploitation, discrimination, or inappropriate conduct.
4. Adults working with children must maintain clear professional boundaries.
5. Children should never be asked to keep inappropriate interactions secret.
6. Concerns should be reported rather than ignored.
7. Retaliation against anyone who raises a good-faith safeguarding concern is prohibited.
8. Personal information about children should be minimized and protected.
9. Safeguarding responsibilities apply equally in online environments.
10. Cultural differences must never be used as an excuse for conduct that violates NaTakallam’s safeguarding standards.

5. Parent and Guardian Participation

For child participants, NaTakallam may require a parent or legal guardian to:

• register the child;
• purchase the service;
• provide contact information;
• provide required consent;
• communicate with NaTakallam regarding administrative matters;
• receive information concerning the child’s participation where appropriate.

Parents and guardians should be treated as an important safeguarding partner.

However, a child should not be instructed that they are prohibited from speaking privately with a trusted adult about something that occurred during a NaTakallam session.

6. Minimum Ages

NaTakallam currently permits:

• General Language Sessions: age 6+
• Integrated Curriculum: age 10+

Specific programs may impose higher minimum ages where appropriate.

No LP or instructor may independently decide to provide a child under the applicable minimum age with a NaTakallam session.

7. LP and Instructor Requirements

Anyone working directly with children must:

• acknowledge and comply with this policy;
• comply with NaTakallam’s applicable Code of Conduct;
• maintain professional boundaries;
• use approved communication channels;
• report safeguarding concerns promptly;
• cooperate with reasonable safeguarding investigations;
• avoid conduct that could reasonably create a risk to a child.

Where appropriate to the role and jurisdiction, NaTakallam may conduct screening, reference checks, identity verification, background checks, or other due diligence.

The specific screening requirements may vary according to the program, country, client, school, or legal requirements.

8. Professional Boundaries

LPs and instructors must keep interactions with children professional and educational.

They must not:

• flirt with a child;
• engage in sexual or romantic communication;
• make sexual comments or jokes;
• ask sexual or unnecessarily intimate questions;
• discuss their own sexual experiences with a child;
• request sexualized photographs or videos;
• send sexually explicit or otherwise inappropriate content;
• ask a child to keep an interaction secret;
• manipulate or pressure a child;
• threaten or intimidate a child;
• offer money or inappropriate gifts;
• ask a child for money or gifts;
• solicit personal favors;
• seek immigration, housing, financial, employment, or other personal assistance from a child;
• attempt to establish an inappropriate personal relationship with a child.

9. Communication Rules

NaTakallam sessions should take place using NaTakallam-approved communication and video-conferencing platforms.

Current approved video-conferencing platforms include:

• Zoom;
• Google Meet.

LPs must not move child communications to:

• personal email;
• personal telephone numbers;
• WhatsApp;
• Signal;
• Telegram;
• personal social-media accounts;
• private messaging platforms;
• other personal communication channels;

unless NaTakallam has expressly authorized the channel for a legitimate program purpose.

LPs must not use their personal Zoom or Google accounts to create an independent ongoing relationship with a child outside NaTakallam.

10. Social Media

LPs must not:

• add child students to personal social-media accounts;
• follow child students through personal accounts;
• communicate with child students through personal social-media accounts;
• request that children follow or contact them personally;
• move educational conversations into personal social-media channels.

If a child attempts to initiate such contact, the LP should politely redirect the child to the approved NaTakallam communication channel and notify NaTakallam if the interaction raises a safeguarding concern.

11. Personal Information

LPs should not request unnecessary personal information from child students.

In particular, LPs should not request:

• home addresses;
• personal phone numbers;
• passwords;
• financial information;
• immigration documents;
• school passwords or credentials;
• intimate photographs;

• private family information unrelated to the educational purpose.

A child may voluntarily disclose personal information during a conversation. LPs should avoid encouraging unnecessary disclosure and should not retain or share such information except where required for legitimate educational, administrative, safeguarding, or legal purposes.

12. Gifts and Money

LPs must not:

• request money from child students;
• ask children to purchase items for them;
• solicit donations;
• request financial assistance;
• request gifts;
• offer inappropriate personal gifts;
• create financial obligations or expectations.

Any concerns regarding financial requests or exchanges should be reported to NaTakallam.

13. Recording, Screenshots, and Images

LPs must not independently:

• record sessions;
• photograph children;
• screenshot children;
• save video or audio of sessions;
• distribute session recordings;
• publish images of children;

unless expressly authorized by NaTakallam and, where required, by the parent or guardian.

Third-party platform recording, transcription, or AI features must not be activated during child sessions unless expressly authorized by NaTakallam.

14. Educational Content

Language instruction should remain appropriate to the child’s age and educational context.

Some language-learning topics may naturally involve difficult subjects, including politics, conflict, religion, history, displacement, discrimination, or other sensitive issues.

LPs should exercise professional judgment and avoid content that is gratuitously graphic, sexual, abusive, or otherwise inappropriate for the child’s age.

If an LP is uncertain whether a topic or material is appropriate, they should consult NaTakallam.

15. One-on-One Sessions

One-on-one online instruction is an accepted part of NaTakallam’s educational model.

However, one-on-one instruction creates particular safeguarding responsibilities.

LPs should:

• remain focused on the educational purpose of the session;
• use approved platforms;
• maintain professional communication;
• avoid unnecessary personal disclosure;
• avoid encouraging dependency or exclusivity;
• avoid secrecy;
• report unusual or concerning interactions.

Where a school or program has additional requirements regarding adult supervision, parent presence, cameras, or recording, those requirements must also be followed.

16. Child Disclosures

A child may disclose information suggesting abuse, neglect, exploitation, bullying, self-harm, violence, or another safety concern.

If this happens, the LP should:

1. remain calm;
2. listen without interrogating the child;
3. avoid promising absolute confidentiality;
4. avoid making judgments about the alleged perpetrator;
5. avoid asking unnecessary detailed questions;
6. thank the child for telling them;
7. explain, in age-appropriate language, that they may need to tell an appropriate adult in order to help keep the child safe;
8. report the concern to NaTakallam immediately.

The LP should not attempt to conduct their own investigation.

17. Reporting a Safeguarding Concern

Any safeguarding concern should be reported as soon as reasonably possible to:

[email protected]

The subject line should be:

Child Safeguarding Concern

Reports should include, where known:

• name of child;
• name of LP or other person involved;
• date and time of incident;
• relevant program;
• description of what occurred;
• any direct statement made by the child;
• relevant evidence or communication;
• whether there is an immediate safety risk.

Only information reasonably necessary to assess and respond to the concern should be included.

18. Immediate Danger

If an LP or staff member reasonably believes that a child faces an immediate risk of serious harm, they should prioritize the child’s immediate safety.

Depending on the circumstances, this may include contacting:

• a parent or guardian;
• the relevant school or organization;
• local emergency services;
• law enforcement;
• child-protection authorities;
• another appropriate emergency or safeguarding authority.

NaTakallam should be notified as soon as reasonably possible.

19. Response to Allegations

When NaTakallam receives a safeguarding allegation or concern, it may:

• temporarily suspend an LP’s access to child programs;
• suspend or restrict a user’s account;
• preserve relevant records;
• contact the parent or guardian where appropriate;
• contact a school or partner organization where appropriate;
• seek legal or safeguarding advice;
• conduct an internal review;
• refer the matter to an appropriate external authority.

The purpose of an initial response is to protect children and preserve relevant information, not to prejudge the outcome of an allegation.

20. Confidentiality During Investigations

Safeguarding information should be shared only with people who have a legitimate need to know.

However, confidentiality is not absolute.

Information may be shared where necessary to:

• protect a child;
• investigate an allegation;
• comply with legal obligations;
• cooperate with law enforcement or child-protection authorities;
• obtain legal or safeguarding advice;
• protect another person from harm.
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21. Retaliation

NaTakallam prohibits retaliation against anyone who raises a safeguarding concern in good faith.

This includes retaliation against:

• children;
• parents or guardians;
• LPs;
• instructors;
• staff;
• partner organizations.
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22. Suspension and Removal

NaTakallam may immediately suspend or remove an LP, instructor, contractor, or user from a program where reasonably necessary to protect a child or investigate a serious safeguarding concern.

NaTakallam may also permanently prohibit an individual from participating in child programs where circumstances warrant.

23. Documentation

NaTakallam should maintain appropriate records of:

• safeguarding reports;
• actions taken;
• relevant communications;
• decisions;
• referrals;
• outcomes.

Records should be stored securely and accessed only by authorized personnel.

Safeguarding records should not be retained indefinitely. Retention should be consistent with NaTakallam’s Privacy Policy, applicable law, and the needs of the safeguarding process.

24. Training

NaTakallam should provide appropriate safeguarding guidance to LPs, instructors, staff, and others working directly with children.

At minimum, relevant personnel should understand:

• professional boundaries;
• prohibited conduct;
• approved communication channels;
• child privacy;
• reporting obligations;
• how to respond to disclosures;
• how to escalate immediate safety concerns.

Additional training may be required for particular school, university, organizational, or geographic programs.

25. Parent and Program-Specific Requirements

Schools, universities, organizations, and other partners may impose additional safeguarding requirements.

Where those requirements are consistent with applicable law and NaTakallam’s policies, they should be incorporated into the relevant program.

If a partner requirement conflicts with this policy, the matter should be escalated to NaTakallam management before the program begins.

26. Policy Review

This policy should be reviewed periodically and whenever there is a material change to:

• NaTakallam’s child programs;
• applicable law;
• technology platforms;
• safeguarding standards;
• reporting procedures;
• organizational structure.

The current policy owner is NaTakallam management.

27. Safeguarding Contact

For any child safeguarding concern:

NaTakallam LLC 54 State Street, Ste 804 #10769 Albany, New York 12207 United States

Email: [email protected]

Subject: Child Safeguarding Concern