Safeguarding & Filming Standards (UK) — Internal Policy

Owner: Head of Production & Safeguarding
Version: 1.1
Effective date: 11th January 2026
Review date: September 2027 (or earlier if law/platform rules change)
Applies to: All staff, freelancers, contractors, casting, editors, and third-party suppliers engaged by the Company in the UK.

1) Purpose

To prevent harm, abuse, exploitation, and sexualisation of children and young people, and to ensure all Company content complies with UK law, regulator codes, and platform standards.

This policy sets non-negotiable safeguards for any filming involving children, young people, sensitive themes, wardrobe, or physical closeness, and prohibits any portrayal that could sexualise individuals who are, or appear to be, under 18.

All Company content is created for general audiences and may be distributed online (including user-generated-content platforms). Content must therefore be suitable for all ages at the point of capture, edit, marketing, and distribution, whether filmed at public or private events.

2) Key principles

Zero tolerance: No creation, possession, distribution, or facilitation of illegal or harmful content.
Child-first approach: The safety, dignity, and best interests of under-18s override editorial, commercial, or creative considerations.
Clear age threshold:
- No nudity or sexualised content involving anyone under 18.
- No suggestive portrayal of adults who appear under 18.
Informed, ongoing consent: Adults give explicit, revocable consent for any sensitive material.
Controlled environments: Sensitive filming occurs only in controlled spaces with essential personnel and documented welfare controls.
Documented compliance: Age verification, licensing, safeguarding checks, risk assessments, and secure records are mandatory.
Immediate escalation: Any concern is reported without delay to the Head of Production & Safeguarding.

3) Scope

This policy applies to all stages of production: pre-production, casting, auditions, rehearsals, filming (public or private), post-production, marketing, distribution, and archiving.

It covers:

All Company-controlled productions
Co-productions filmed in the UK
UK-based filming intended for global online distribution

4) Definitions (plain English)

Child / under-18: Anyone under the age of 18.
Young person: Aged 16–17 (still a child under UK law).
Sexualised content: Any content likely to arouse sexual interest in the subject (including through wardrobe, framing, editing, implication, or context).
Sensitive scene: Any scene involving physical closeness, vulnerability, partial exposure, or power imbalance requiring enhanced safeguards.
Head of Production & Safeguarding: The Company’s designated safeguarding lead with authority to stop production.

5) Legal & regulatory framework (summary)

We comply with all applicable UK law and regulator guidance, including but not limited to:

Child performance and employment licensing
Child protection and safeguarding legislation
Criminal law relating to indecent images and exploitation
Data protection (UK GDPR)
Broadcasting and online safety standards
Platform terms and community guidelines where content is distributed

Internal standard:
Although the age of consent is 16, 18 is treated as the minimum age for any sensitive or potentially suggestive content, without exception.

6) Absolute prohibitions

The following are strictly forbidden and will trigger immediate suspension and investigation:

Any sexualised depiction of a child (under 18), in any form.
Any nudity or simulated nudity of a child.
Casting adults who look under 18 in suggestive roles, styling, or storylines implying youth (e.g. school settings or uniforms).
Covert or deceptive filming (e.g. voyeuristic angles, up-skirting).
Recording or distributing sensitive material without valid consent.
Possession or distribution of obscene or illegal content.
Grooming behaviour or boundary-blurring contact with under-18s.
Retaliation against anyone who raises a safeguarding concern.

7) Working with under-18s at events

Under-18s may participate only in non-sexual, non-nudity content, and only where all safeguards below are met.

7.1 Licensing & chaperones

Obtain child performance licences where required.
Approved chaperone or parent present at all times.
Attendance logs and licence copies retained securely.

7.2 Safeguarding checks & supervision

DBS checks where roles meet regulated-activity thresholds.
Mandatory safeguarding briefing for all crew.
Age-appropriate supervision ratios.
Separate changing and toilet facilities; no shared changing with adults.

7.3 Content & wardrobe

Clothing must be age-appropriate and non-sexualised.
No suggestive choreography, dialogue, framing, or edits.
No adult sensitive scenes filmed in the same space or timeframe.

7.4 Hours, education & welfare

Legal limits on hours, rest, travel, and education are mandatory.
Safeguarding and H&S risk assessments completed in advance.
A named child-welfare lead monitors wellbeing throughout.

8) Adults in sensitive scenes (18+ only)

8.1 Preconditions

Age and identity verified before rehearsal or filming.
Sensitive Content Rider signed, detailing exactly what is permitted.
Intimacy Coordinator required for physical intimacy unless formally waived by the Head of Production & Safeguarding.
Controlled access and privacy measures in place.
No alcohol or drugs on filming days.

8.2 During filming

Consent check-ins before and after filming.
Transparent shot lists; no surprise blocking or coverage.
No personal devices in controlled spaces.
Aftercare and support available on request.

8.3 Post-production

Editors restricted to agreed material only.
Watermarked dailies and controlled access.
Secure deletion of unused sensitive footage.

9) Themes and treatments to avoid

Sexualisation of youth or youth-coded aesthetics.
School or training settings used suggestively.
Romanticising power imbalances.
Intrusive or voyeuristic camera language.
Humiliation, degradation, or coercive framing.

10) Age verification & records (adults)

Two forms of government photo ID plus a live selfie.
Performer declaration confirming age (18+), identity, and consent scope.
Appearance assessment confirming the performer does not appear under 18.
Records stored securely with restricted access.
Re-verification required if doubt arises.

11) Data protection & children’s information

Data minimisation and high-privacy defaults.
No profiling or behavioural targeting of children.
Child records retained only as long as legally required, then destroyed.
Subject-access and erasure requests handled via Legal and Safeguarding.

12) Risk assessments

Separate H&S and safeguarding risk assessments for each event.
Specific controls for under-18s documented.
Dynamic review during production; stop work if risks escalate.

13) Marketing, distribution & archive

No thumbnails, titles, or copy implying youth sexualisation.
Platform compliance checks before release.
Only approved final cuts archived.
Immediate takedown for any breach.

14) Training (mandatory)

Annual safeguarding and consent training for all staff.
Role-specific modules for casting, editors, marketers, and chaperones.
Policy acknowledgement at induction.

15) Reporting & escalation

Immediate reporting to the Head of Production & Safeguarding.
If illegal material is suspected: do not view or share; isolate and escalate.
All incidents logged; serious matters escalated to the Board and authorities where required.

Safeguarding contact:
safeguarding@pgn.com (or successor address published on the intranet)

16) Enforcement

Immediate removal from site or production.
Contract termination and disciplinary action.
Supplier termination and referral to authorities where appropriate.

17) Governance

Board approval and annual review.
Supporting SOPs and templates maintained by Safeguarding.
Department heads accountable for compliance.

Appendix A — Required documents

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Appendix B — Wardrobe guardrails

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