Same Street — Adult Safeguarding Policy

Helpful organisations

• Befriending Networks UK (befriending.co.uk)
• Age UK (ageuk.org.uk)
• NHS Volunteer Responders (nhsvolunteerresponders.org.uk)

1. Our Commitment

Same Street is a free online community for people living in UK care homes. Our users are adults who may be elderly, vulnerable, navigating major life changes, or facing emotional and physical challenges.

We take our responsibility to protect our users seriously. This policy sets out how we identify, respond to, and escalate concerns about the safety and wellbeing of our community members.

2. Why Safeguarding Matters for Care Home Residents

Elderly people living in UK care homes can be particularly vulnerable online. Major life transitions, reduced social networks, and the challenges of adjusting to residential care can all affect how people assess risk and form trust. Friendship fraud, romance scams, and financial exploitation disproportionately target older adults — and the emotional harm caused can be as serious as the financial loss.

Same Street was designed from the ground up with this reality in mind. Every feature — from our matching system to our moderation approach to our crisis signposting — exists to create genuine connection while protecting the people who are most at risk. Safeguarding is not an add-on to Same Street. It is the foundation.

3. What We Are and What We Are Not

Same Street is a community platform, not a care provider, medical service, or crisis intervention service.

We are:

• A safe, moderated online space for connection and companionship
• A signposting service that directs users to appropriate support
• A platform committed to gentle moderation and user dignity

We are not:

• A replacement for professional care or medical advice
• A crisis service
• A mental health provider
• A safeguarding authority

4. Who This Policy Covers

This policy applies to all users of samestreet.co.uk, including:

• Care home residents
• Family members or carers acting on behalf of a resident
• Any adult member of our community

5. Recognising Safeguarding Concerns

We consider the following as potential safeguarding concerns:

• A user expressing suicidal thoughts or intent to self-harm
• A user describing abuse, neglect, or exploitation by another person
• A user appearing to be in a mental health crisis
• A user being contacted or pressured by another member in a harmful way
• A user sharing information suggesting they are at immediate risk
• Reports from family members or carers about a user's safety

6. Fraud and Scam Awareness

Never send money to anyone you have met on Same Street. This includes cash, bank transfers, gift cards, or any other form of payment.

Warning signs of friendship and romance fraud:

• Unsolicited affection or declarations of love after only a short time
• Making excuses to avoid video calls or in-person meetings
• Sudden requests for money, gift cards, or financial help
• Pressure to keep the relationship or financial requests secret

If you suspect you are being targeted by a scam, stop all communication and report the user to us immediately. You can also contact Action Fraud on 0300 123 2040 or visit actionfraud.police.uk.

7. Suspicious Links and Phishing

Never click links sent by people you do not know. Scammers and phishing attackers often use fake links to steal passwords, personal information, or install malicious software.

Same Street will never ask you for your password by message, email, or any other means. If someone claiming to be from Same Street asks for your password, it is a scam — please report it immediately.

8. Guidance by User Type

Care home residents

If something feels wrong while using Same Street — whether it is a message that upsets you, a request that makes you uncomfortable, or behaviour you do not understand — speak to a trusted member of staff at your care home. You are not being a nuisance; you are keeping yourself safe.

Care home staff

You have safeguarding reporting duties under the Care Act 2014. If you become aware of a concern involving a resident who uses Same Street, report it to your safeguarding lead and email us at safeguarding@samestreet.co.uk. For urgent concerns, we aim to respond within 4 hours on working days.

Family members and supporters

If you are worried about a resident's safety or wellbeing on Same Street, you can raise a concern by emailing safeguarding@samestreet.co.uk. We will review it within 24 hours on working days.

Community members and mentors

If someone you are speaking with appears to be in distress or danger, encourage them to speak to a professional or a member of their care home staff. Do not try to handle a crisis alone. Contact us at safeguarding@samestreet.co.uk so we can follow up appropriately.

9. Wisdom Bridge — Peer Mentoring Safeguards

Wisdom Bridge is a feature on Same Street that connects care home residents who wish to share their life experience and professional knowledge (mentors) with community members who want to learn from them (wisdom seekers). All Wisdom Bridge sessions are digital-only — no in-person contact takes place through this feature.

How mentors are verified

Before any mentor is approved to participate in Wisdom Bridge, Same Street carries out the following steps:

• Identity verification — government-issued photo ID reviewed by Same Street admin
• Career background review — supporting documents reviewed (such as a pension statement, P60, professional registration certificate, or institutional letter) confirming the claimed career history
• Structured written interview — sector-specific questions assessed against a documented scoring framework by Same Street admin, with AI-assisted screening for inconsistencies
• Public register check — where the claimed profession has a publicly searchable register (such as the NMC for nurses, the Teaching Regulation Agency for teachers, or Social Work England for social workers), the mentor's registration is checked and the date verified
• Admin approval — a human reviewer at Same Street makes the final decision before any mentor profile is approved. No mentor is approved solely by automated means

Approved mentors are assigned a verification badge that reflects what was actually verified: Register Confirmed, Document Reviewed, or Identity Checked. Same Street does not claim more certainty than the verification process supports.

DBS checks for Wisdom Bridge mentors

Wisdom Bridge mentoring is digital-only, rate-limited, and conducted under care home staff oversight at the resident end and platform moderation throughout. Under the Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012, a mandatory enhanced DBS check is required for regulated activity — defined as in-person, unsupervised, repeated contact with vulnerable adults. Wisdom Bridge as currently configured does not meet this threshold.

Accordingly, enhanced DBS checks are not currently required for Wisdom Bridge mentors. Same Street is transparent about this position. In-person volunteers are subject to enhanced DBS checks as a condition of participation. Enhanced DBS verification for Wisdom Bridge mentors will be introduced as the platform develops and as funding allows.

Care home staff oversight

Care home staff play the primary safeguarding role in all Wisdom Bridge pairings involving their residents. Staff can view all active pairings on the care home dashboard, pause or terminate any pairing at any time, and receive monthly check-in prompts about each active pairing. Any pairing can be suspended immediately by staff without requiring the resident's agreement if there is a welfare concern. All staff decisions are logged with a timestamp on the dashboard.

Session safeguards

All Wisdom Bridge sessions are subject to the following platform controls:

• Messages are rate-limited to prevent intensive or pressured contact
• All messages pass through Same Street's moderation system before delivery
• Keyword detection flags concerning content for immediate admin review
• Either party can end a pairing at any time without explanation
• Care home staff receive a monthly check-in prompt and can terminate any pairing from the dashboard

Mentor conduct rules

All Wisdom Bridge mentors agree to the following conduct requirements as a condition of participation:

• Never request money, gifts, or financial assistance from a wisdom seeker or resident under any circumstances
• Never attempt to move communication off the Same Street platform to personal email, phone, WhatsApp, or any other channel
• Never request or share personal contact details (home address, personal phone number, personal email address)
• Never ask a resident about their financial situation, assets, estate, or will
• Never share content that is sexual, violent, discriminatory, or otherwise harmful
• Report any concern about a resident's wellbeing to Same Street immediately at safeguarding@samestreet.co.uk

Breach of any of the above conduct rules will result in immediate suspension of the mentor's account pending investigation.

10. Resident Capacity and Consent

Same Street recognises that some care home residents may have reduced or fluctuating mental capacity as a result of dementia, Alzheimer's disease, or other conditions. Approximately 70% of care home residents in the UK are estimated to have some form of dementia or severe memory problems (Alzheimer's Society, 2025).

Same Street operates in accordance with the Mental Capacity Act 2005 (MCA 2005). We assume capacity unless there is evidence to the contrary, and we design our platform features to support residents in making their own decisions wherever possible.

For Wisdom Bridge mentoring specifically:

• A resident must give informed consent before opting in as a Wisdom Bridge mentor. The consent screen is written in plain, accessible language
• Care home staff are the primary gate for mentor eligibility. When a resident opts in as a mentor, staff are notified and asked to confirm that the resident has capacity to make this decision and that participation is appropriate for their current wellbeing
• Staff record one of three capacity statuses against each resident's Wisdom Bridge eligibility: Eligible, Eligible with review (capacity fluctuates — pairing reviewed every 14 days), or Not currently eligible (lacks capacity for this decision)
• A resident who lacks capacity to consent to mentoring cannot participate as a Wisdom Bridge mentor. This is not a Same Street policy preference — it is a legal requirement under MCA 2005
• Residents with reduced or fluctuating capacity continue to have full access to all other Same Street features — mood check-ins, volunteer visits, family connections, support groups, and activities — which do not require the same level of informed consent as a mentoring relationship
• Care home staff can pause or terminate a Wisdom Bridge pairing at any time if a resident's capacity declines, without requiring the resident's agreement to do so

Same Street never makes capacity determinations itself. That judgment rests with care home staff, who know the resident and carry the professional and legal responsibility for that assessment.

11. How We Respond to Safeguarding Concerns

Step 1 — Immediate Signposting

When a user expresses distress, our first response is to acknowledge them with warmth and direct them to appropriate support:

• Samaritans: 116 123 (free, 24/7)
• Shout: text 85258 (free, 24/7)
• Mind: mind.org.uk or 0300 123 3393
• Age UK helpline: 0800 055 6112
• NHS urgent mental health support: 111 (option 2)
• Emergency services: 999

Step 2 — Platform Response

We will:

• Respond to the user with care and without judgment
• Remind them they are not alone and that help is available
• Not engage in clinical assessment or crisis counselling ourselves
• Document the concern internally with a timestamp

Step 3 — Escalation

In cases where we believe a user may be in immediate danger, we will:

• Contact emergency services (999) if we have sufficient identifying information
• Contact the care home where the user resides if known
• Cooperate fully with any safeguarding authority investigation

12. Reporting a Concern

Any member of the Same Street community can report a concern about another user by emailing safeguarding@samestreet.co.uk.

• Urgent safeguarding concerns (immediate risk to a person's safety) — we aim to respond within 4 hours on working days
• Non-urgent concerns and general reports — reviewed within 24 hours on working days
• For emergencies outside working hours, contact emergency services on 999 or your local authority adult social services

13. Content Moderation

Same Street actively moderates content to protect our users. We will remove content that:

• Encourages self-harm or suicide
• Exploits or demeans vulnerable people
• Facilitates scamming, grooming, or financial exploitation
• Harasses or bullies other members
• Attempts to move relationships off the platform or solicits personal contact details

Accounts engaging in the above behaviour will be suspended immediately.

14. Data and Confidentiality

Safeguarding concerns are handled with sensitivity. Information shared in confidence will only be disclosed:

• To emergency services where there is immediate risk to life
• To relevant authorities where required by law
• With the user's consent in all other cases

15. Working with Care Homes

Where Same Street partners with care homes, we expect care home staff to:

• Support residents in using the platform safely
• Report any safeguarding concerns to us and to their own safeguarding lead
• Comply with their own organisation's adult safeguarding procedures
• Review and action Wisdom Bridge pairing notifications on the care home dashboard promptly
• Use the capacity eligibility field on each resident's profile to record their Wisdom Bridge eligibility status and keep it up to date as circumstances change

16. Age Verification

Same Street is an adult-only platform intended for people aged 18 and over.

At the point of registration, all users are required to confirm via a mandatory tick-box that they are aged 18 or over. Same Street relies on this self-declaration in line with ICO guidance for platforms not directed at children.

If Same Street becomes aware or reasonably suspects that a user is under the age of 18, we will:

• Suspend the account immediately pending investigation
• Permanently delete the account and all associated data if the suspicion is confirmed
• Document the incident in our internal safeguarding log

Suspected underage accounts can be reported to safeguarding@samestreet.co.uk. Reports will be reviewed within 24 hours on working days.

17. Review

This policy will be reviewed annually or following any safeguarding incident.

Safeguarding contact: safeguarding@samestreet.co.uk

General contact: hello@samestreet.co.uk

Address: Monomark House, 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom

18. Local Authority Safeguarding Escalation

If you have a serious concern about the safety or wellbeing of a vulnerable adult on this platform, Same Street will, where necessary, refer concerns to the relevant local authority safeguarding team under Section 42 of the Care Act 2014. We will always inform the individual unless doing so would place them at further risk. For immediate emergencies, please call 999. For non-emergency safeguarding concerns in your area, contact your local authority adult social services.

Report abuse or neglect of an older person (gov.uk)

19. Online Safety Act 2023 Risk Assessment

Same Street is a user-to-user service under the Online Safety Act 2023. We publish an illegal content risk assessment covering grooming, financial abuse, exploitation and harassment along with the mitigations in place, a children’s access assessment confirming that Same Street is strictly 18+, the senior person accountable for online safety, and our commitment to review the assessment before every material feature change.

Read our Online Safety Act Risk Assessment

20. Our Safeguarding Culture

Safeguarding at Same Street is not a policy document — it is a culture. Every design decision, every feature, and every moderation response is shaped by one question: does this protect the people who are most at risk?

We are committed to the following principles as an organisation:

• Residents first. When there is a tension between what is convenient for the platform and what is safest for a resident, resident safety wins without exception.
• Transparency about limitations. We do not claim more safety assurance than our verification processes support. Where we have gaps, we name them and say what we are doing about them.
• No blame culture for reporting. Anyone — resident, family member, staff, or community member — who raises a safeguarding concern will be treated with respect. We never penalise people for reporting in good faith.
• Continuous improvement. We review our safeguarding approach after every incident, every significant platform change, and at least annually. We do not wait for something to go wrong before asking whether we could do better.
• Partnership with care homes. We recognise that care home staff are the people who know residents best. Our role is to support their safeguarding work, not to replace it.

If you have a suggestion for how Same Street could do better on safeguarding, we genuinely want to hear it. Email us at safeguarding@samestreet.co.uk.

21. DBS checks and compensating controls — pre-revenue phase

Same Street requires Basic DBS checks for Wisdom Bridge mentors, volunteers, and Digital Neighbours as a platform policy. Basic DBS for these roles is a platform policy decision — not a statutory legal requirement under the Safeguarding Vulnerable Groups Act 2006.

During our pre-revenue launch phase, Basic DBS checks are not yet enforced. The following compensating controls are in place across all features:

Wisdom Bridge (mentors and mentees)

• Two-selfie identity verification for all participants ✅
• 30-day account standing with no safeguarding flags ✅
• AI scoring and admin review for mentor applications ✅
• UK register check for professional credentials ✅
• AI content monitoring of all conversations ✅
• 90-day pairing check-ins — both sides confirm still happy ✅
• Care home staff oversight for resident participants ✅
• Full audit trail of all interactions ✅

Volunteering

• Two-selfie identity verification ✅
• 30-day account standing with no safeguarding flags ✅
• Care home staff approval required before first placement ✅
• All in-person visits supervised by care home staff ✅
• Resident consent required ✅
• Full audit trail ✅

Digital Neighbour

• Two-selfie identity verification ✅
• 30-day account standing with no safeguarding flags ✅
• Flag-on-demand message visibility for care home staff ✅
• AI content monitoring ✅
• Care home staff notified when resident is matched ✅
• Full audit trail ✅

DBS implementation roadmap

Basic DBS checks will be introduced as mandatory platform policy once care home subscription revenue is established. Costs will be covered as follows:

• Volunteer and Digital Neighbour DBS — covered by care home subscription
• Mentor DBS — covered by Same Street from subscription revenue
• Residents, family members, and mentees — never charged for DBS checks

Target implementation: first care home pilot go-live. This phased approach is reviewed quarterly and documented here for ICO audit purposes.

Enhanced DBS — legal position

Enhanced DBS checks are legally required only for the six categories of Regulated Activity under the Safeguarding Vulnerable Groups Act 2006 as amended by the Protection of Freedoms Act 2012. Requesting Enhanced DBS for online mentoring, video calls, or supervised in-person tech education sessions is a criminal offence under the Police Act 1997. Same Street currently has one Enhanced DBS role only: in-person volunteering involving personal care or healthcare assistance.

22. Message monitoring — necessity and proportionality

Same Street monitors private messages between Wisdom Bridge mentors and mentees for safeguarding purposes. This monitoring is justified on the following grounds:

Necessity

Same Street connects potentially vulnerable adults — including care home residents, people with cognitive difficulties, and people experiencing loneliness and isolation — with strangers in one-to-one mentoring relationships. Without message monitoring, the platform would be unable to detect grooming, exploitation, financial abuse, or psychological harm occurring within these relationships. The Care Act 2014 places a duty on organisations facilitating contact with vulnerable adults to take reasonable steps to prevent abuse.

Proportionality

Monitoring is carried out by an automated AI system in the first instance — no human reads messages unless a concern is flagged. Human review is limited to the specific flagged messages only — not full conversation histories. Care home staff have no routine access to resident messages — they are notified only when a specific concern involves their resident. Users with no vulnerability indicators and no care home connection receive AI-only monitoring with no routine human review.

Legal basis

UK GDPR Article 6(1)(f) legitimate interests, Article 9(2)(b) processing necessary for safeguarding obligations, Care Act 2014 duty of care, and Article 8(2) ECHR permitting interference with private communications where necessary for the protection of health or the rights of others.

This framework is reviewed annually and documented here for ICO audit purposes.