Child Safety Policy

1. Our commitment

Almost everyone who uses Graspera to study is a child. That single fact shapes how the product is built, what it collects, who can see it, and what we do when something looks wrong. This policy sets out those commitments in the same place, so a parent or a school can read them without taking our word for it.

We commit to the National Principles for Child Safe Organisations: that children are safe, informed and taken seriously; that families and communities are involved; that people working with children are suitable and supported; that complaints are taken seriously; and that physical and online environments are designed to reduce harm.

We would rather over-report a concern that turns out to be nothing than sit on one that turns out to be something.

2. Where we sit legally, stated plainly

Schools ask us this, so here is the honest answer rather than a comfortable one. Graspera is software. We have no campus, no classroom and no staff who meet students. Several of the child protection obligations a school carries do not apply to us as a matter of law. We follow the substance of them anyway, and we would rather you know which is which than assume we are covered by something we are not.

If your school's procurement process needs any of this in writing on our letterhead, email admin@graspera.au and we will provide it.

3. Safety by design

The most reliable child protection control is a product that cannot be used to reach a child in the first place. Graspera has no messaging feature, and that is a deliberate design decision rather than a gap we have not got to yet.

3.1 A student cannot be contacted through Graspera

• There is no direct messaging, chat, comment thread, forum or reply box between users. There is nowhere for one user to send another user anything.
• There are no public profiles, no search for other users, no friend lists and no follower counts. A student cannot see that another student exists.
• We do not collect a student's email address, phone number or home address, so there is no channel to them even outside the product.
• We do not accept photographs or video of students, and there is no image upload in a student account. Avatars are generated cartoons, not pictures of a real child.
• A student's account is created by a parent, guardian or authorised school - never by the child, and never by a stranger who found the site.

3.2 A student cannot be identified from what leaves Australia

Schoolwork is sent to our AI provider to be marked and explained. The student's name, username, account identifier and age are not sent with it. What goes is the question and the answer. A person reading that traffic could not work out whose it is. The Privacy Policy sets this out in full at section 7.

3.3 Who can see a student's work

• The parent or guardian who holds the account.
• A teacher, only where the student's own parent or guardian created that teacher's account and named the subjects the teacher may see. It is off by default, it does not switch itself on, and no school agreement switches it on either. The parent or guardian can end it in one press, and a school's own staff accounts carry no access to a student's work.
• Our own staff, only where needed to run the Service, answer a support request or investigate a safety or security issue - and every such access is logged.

No other family, no other school, no advertiser and no data broker, ever. There is no arrangement under which a student's work could be sold, and we will not enter one.

3.4 Students are told, in words they can read

At first sign-in a student sees a short plain-English explanation of what Graspera records about their work and who can see it. A child who does not know they are being observed cannot meaningfully object to it, so we tell them.

4. Our people

Graspera is a small operation. That is an advantage for accountability - there is no ambiguity about who is responsible - and a limitation we should be honest about, which is why the design controls in section 3 carry most of the weight rather than supervision.

• Nobody working on Graspera has face to face or physical contact with a student through the Service. There is no tutoring, no video call and no live session.
• Access to student records is limited to those who need it to do their job, protected by multi-factor authentication, and recorded in an audit trail.
• Anyone with access to student data is bound by a written confidentiality obligation and must read this policy and the Acceptable Use Policy before that access is granted.
• We will obtain a Working With Children Check for any person a partner school asks us to, and we will give the school the Check number and date of birth so it can verify it directly with the Office of the Children's Guardian.
• If a concern is ever raised about a person associated with Graspera, that person's access to student data is suspended while the concern is looked into, not after it is resolved.

5. The AI, and what happens if a student writes something worrying

Students type into free-text boxes, and sometimes what a student types has nothing to do with chemistry. A study tool is not a counselling service and we will not pretend otherwise - but neither will we design one that looks away.

5.1 What the AI will not do

• It is scoped to the curriculum. It does not offer medical, psychological, legal or relationship advice, and it does not attempt to counsel a student.
• It does not generate sexual, violent or self-harm content, and it will not be talked into it by framing the request as a study question.
• It does not ask a student for personal details, and it is instructed to discourage a student who volunteers them.
• It does not pretend to be a human being, and it does not tell a student it is their friend.

5.2 If a student discloses harm

If something a student writes suggests they may be at risk - of self-harm, of abuse, or of harm from another person - the response is not to carry on marking the question. The student is shown the Kids Helpline number 1800 55 1800 and Lifeline 13 11 14, told plainly that talking to an adult they trust is a good idea, and the matter is escalated to a person on our side.

5.3 What we do with a disclosure

Where the concern is serious, we contact the student's school if they use Graspera through one, because the school knows the student and has a wellbeing team. Where it is not a school account, we contact the Account Holder - unless we have reason to believe the Account Holder is the source of the risk, in which case we do not, and we go to the NSW Child Protection Helpline instead. Where a child appears to be at risk of significant harm, we report to the Helpline on 132 111 whether or not anyone asks us to.

6. Raising a concern

You can raise a concern about a student's safety with us, with an outside body, or with both. You do not need our permission and you do not need to come to us first.

6.1 Telling us

Email support@graspera.au and put "child safety" in the subject line. Tell us what you saw, where, and when. A screenshot helps. You may do this anonymously; we would rather have the report without a name than not have it.

You will not be penalised for making a report in good faith, and neither will a student. A student who tells us something worrying will not have their account closed for it.

6.2 Outside bodies

7. What we do when we receive a concern

Reporting to an outside body is never delayed by our own process. Where a report to the Helpline or to police is warranted, it is made first and the internal work continues around it.

8. Records

Child safety records are kept separately from ordinary account data, are visible only to the person handling the matter, and are retained for 7 years from the date the matter is closed, or until the youngest student involved turns 25, whichever is later. That is longer than we keep anything else, deliberately: the Royal Commission into Institutional Responses to Child Sexual Abuse found repeatedly that destroyed records defeat later investigations.

A deletion request from an Account Holder does not erase a child safety record, and a record placed on hold is exempt from the routine deletion described at section 13 of the Privacy Policy. We will say so plainly if that applies to a request you make.

9. Keeping this current

We review this policy at least once a year, and immediately after any incident, any material change to the product, or any change in the law - including when the OAIC Children's Online Privacy Code is registered, which must happen by 10 December 2026.

Every phone number and link on this page was checked against the organisation's own website on the date shown at the top. If you find one that is wrong, please tell us at support@graspera.au - a safety document with a dead number in it is worse than useless.

Schools are welcome to send us their own child protection requirements. If your policy asks for something we do not do yet, we would rather hear it than find out during an incident.

10. Contact

David Williams trading as Graspera
ABN 50639154277
297 Miller Road, Bass Hill, NSW 2197

• A concern about a student's safety: support@graspera.au
• School due diligence, agreements and documentation: admin@graspera.au
• Privacy questions about a student's records: admin@graspera.au