SafeToNet Policy Position on Privacy and Children’s Online Safety
1. Our HarmBlock starting position
SafeToNet’s approach to privacy is grounded in a simple principle: children should be protected from harm online without being monitored, tracked, or profiled.
We design safeguarding technology on the assumption that children have a right to privacy, dignity, and freedom from unnecessary surveillance, as well as a right to protection from harmful and illegal content.
This position aligns with the UN Convention on the Rights of the Child (UNCRC), including General Comment No. 25, which makes clear that children’s rights apply fully in the digital environment and that protection measures must be proportionate, necessary, and privacy-preserving.
2. Privacy by design, not privacy as an afterthought
SafeToNet does not believe that effective safeguarding requires the collection of personal data, browsing histories, messages, or behavioural profiles.
Our technology is deliberately engineered to minimise data processing and eliminate data flows wherever possible. Safeguarding should not depend on surveillance, nor should children’s safety be achieved at the cost of their privacy.
This approach is consistent with:
- the UNCRC principle of the child’s best interests,
- the UK Age-Appropriate Design Code’s requirement for data minimisation and privacy by default,
- and core GDPR principles, including privacy by design and purpose limitation.
3. What HarmBlock activation does and does not mean
When HarmBlock activates to block harmful or illegal sexual content, this does not indicate that a child has searched for, requested, or sought out such material.
HarmBlock does not analyse intent, interest, or behaviour. It does not track searches, monitor conversations, or infer motivation.
Activation reflects a different reality: that explicit and harmful sexual content is widespread across the internet, embedded in mainstream platforms, advertising systems, group chats, image sharing, and automated content feeds.
Children are routinely exposed to sexual material through algorithmic recommendations, unsolicited messages, shared content, and ambient digital environments, often without actively looking for it.
HarmBlock responds to what appears on the device, not to what a child is trying to do.
4. A systemic problem requires systemic safeguards
SafeToNet’s position is that online sexual harm affecting children is a systemic issue, not an individual behavioural issue.
Children cannot control what appears in feeds, messages, recommendations, or shared spaces online. Harmful content is often unavoidable, even for cautious and well-supported children.
Placing the burden on children to avoid harmful content, or on parents to monitor every interaction, is neither realistic nor fair. Equally, treating exposure as evidence of a child's curiosity or wrongdoing is both inaccurate and harmful.
Safeguards should be built into the digital environment itself, in ways that work across apps, platforms, and encrypted spaces, without requiring constant oversight or data collection.
5. Why on-device, privacy-preserving protection matters
HarmBlock is designed to operate entirely on the device, without collecting, storing, or transmitting personal data. This is a deliberate policy choice.
By processing content locally and transiently, safeguarding can occur:
- without creating user profiles,
- without logging activity,
- without sharing data with companies, platforms, or third parties,
- and without exposing children to additional privacy or security risks.
This approach supports the UNCRC requirement that children’s rights to protection and privacy must be balanced, not traded off against each other.
6. Respecting children’s dignity
SafeToNet rejects models of child safety that rely on constant surveillance, behavioural scoring, or intrusive monitoring.
Children should not grow up under the assumption that being safe means being watched.
Our policy position is that effective safeguarding should be largely invisible, proportionate, and protective, intervening only when necessary to prevent harm, and doing so without judgment, profiling, or stigma.
7. Our commitment
SafeToNet is committed to:
- designing safeguarding technology that protects children without exploiting their data,
- aligning with internationally recognised children’s rights frameworks,
- supporting parents, carers, and institutions without encouraging over-monitoring,
- and contributing to a digital environment where children are protected by design, not policed by default.
Privacy is not a barrier to child protection. When done properly, it is one of its foundations.
Software Privacy Policy
For the Privacy Policy applying to our website, please see this Privacy Policy instead.
Effective date: December 2025
Product: HarmBlock
Provider: SafeToNet Limited
Contact: privacy@safetonet.com
HarmBlock is designed in line with children’s rights and age-appropriate design principles. Its architecture reflects international and UK regulatory expectations that children should be protected proactively from harmful content, while their privacy is preserved through strict data minimisation and privacy-by-design.
This document explains what HarmBlock does, how it processes data on devices, and how it protects privacy.
It is written to reflect HarmBlock’s role as a business-to-business safeguarding technology licensed to device manufacturers and embedded at the operating system or firmware level.
1. What Is HarmBlock
HarmBlock is an on-device safeguarding technology designed to reduce the risk of children and young people viewing, creating, storing, livestreaming, or sharing harmful or illegal sexual content on their devices.
It uses artificial intelligence to analyse visual content in near real time and takes protective action where necessary. All analysis takes place locally on the device, without reliance on cloud services, remote servers, or human review.
2. How HarmBlock Operates
HarmBlock is licensed to and deployed by device manufacturers as a built-in safeguarding capability. It may be enabled as part of a manufacturer's operating system child or youth safety configuration.
When active, HarmBlock analyses visual content at the moment it appears on the device, including on-screen content, camera-captured images, videos or livestreams, and content stored locally on the device. Content is analysed transiently and is not retained.
3. Data Collection and Storage
- HarmBlock does not collect personal data.
- HarmBlock does not store personal data.
- HarmBlock does not transmit personal data.
No images, videos, metadata, identifiers, logs, or behavioural information are captured, saved, exported, or shared. SafeToNet has no access to device content, user activity, or usage information.
4. On-Device Processing Only
All processing is performed locally on the device using embedded AI models.
Visual content is assessed in near real time solely to determine whether it meets predefined safeguarding thresholds. Once a decision is made, the content is immediately discarded. Nothing leaves the device.
5. What HarmBlock Does With Content
HarmBlock uses AI solely to determine whether visual content should be permitted or blocked.
Where harmful or illegal sexual content is detected, HarmBlock can:
- prevent the content from being displayed
- block capture or recording
- prevent saving to the device
- prevent sharing or transmission
6. No Third-Party Access
HarmBlock does not share content or data with:
- SafeToNet
- Device manufacturers
- Parents or guardians
- Platforms or apps
- Law enforcement or third parties
There is no backdoor access and no remote viewing capability.
7. Automated Decision-Making
HarmBlock uses automated decision-making to act in near real time. Decisions are limited to determining whether specific images or video frames should be blocked or allowed.
These decisions do not involve human review, and HarmBlock does not possess the capability to create user profiles, assess behaviour or identify the device.
8. Intended Users
HarmBlock is designed to protect children and young people using devices configured for their use.
Deployment and activation are controlled by device manufacturers. SafeToNet does not manage end-user accounts or interact directly with children.
9. Legal and Regulatory Alignment
Because HarmBlock does not collect or retain personal data, most data subject rights do not apply in practice.
The on-device processing that occurs while HarmBlock is active supports legitimate interests in protecting children from harm and aligns with child protection obligations and regulatory expectations, including;
- The UN Convention on the Rights of the Child (General Comment No. 25),
- The UK Age-Appropriate Design Code (Children’s Code),
- Data (Use and Access) Act (DUA),
- EU GDPR principles of data minimisation and privacy by design.
10. Security and Assurance
HarmBlock is designed to minimise risk by eliminating data flows entirely.
Key safeguards include:
- local-only processing
- no logging or telemetry
- no identifiers or analytics
- regular testing for accuracy, bias, and security
11. Changes to This Document
This document may be updated to reflect changes in law, regulation, or product deployment. Updates relate only to how HarmBlock operates.
12. Contact
For questions about HarmBlock’s privacy or technical operation:
SafeToNet Limited
Quadrant House, Broad Street Mall
Reading, RG1 7QE, United Kingdom
Email: privacy@safetonet.com
Note: If you are using the HMD Fuse with HarmBlock Plus, it includes technology produced by HMD. Please see the HMD Privacy Policy here and here.