Child Protection Policy
THAT GOVERN OTI & OTI GROUP's PROJECTS AND INITIATIVES
This document describes the Policy applied by the Organisations to explain the measures such as screening and selecting employees and volunteers who work with children, reporting and responding to suspected cases of child abuse or neglect, maintaining a code of conduct for working with children, providing regular training and education on child protection issues, and creating a safe environment for children.
The need for a child protection policy
‘All organisations and professionals working or in contact with children are obliged to ensure their operations are ‘child safe’ and therefore need to have a Child Protection Policy’.
OTI Group needs a child protection policy because:
Organisation staff are protected: All children have a right to freedom from all forms of violence, abuse and exploitation, based on the UNCRC. It is, therefore, the responsibility of OTI Group to ensure that all its activities, policies, projects and programmes are ‘child safe’. This means that staff do not represent a risk to children and that programmes, policies and practices can be designed and developed in ways that promote the protection of children.
Children are protected: Some children are in particular vulnerable to abuse, exploitation, and ill-treatment at the hands of carers, project workers, and those with access to their personal information. Many children growing up in vulnerable circumstances have already experienced ruptured relationships of trust or abuse of an adult-child relationship in the form of physical, psychological or sexual abuse.
The organisation and its reputation are protected: Organisations working with vulnerable children have been, are and will continue to be vulnerable to abuse until the issues are brought into the open. Organisations without protection policies, guidelines and systems are more vulnerable to false or malicious accusations of abuse.
Without a proper child protection policy and child protection standards in place, allegations of abuse, whether founded or unfounded, can destroy an organisation’s reputation. This will have serious implications for fundraising as well as damaging the reputation of the children’s rights NGO sector as a whole.
This Policy is developed to ensure the highest standards of professional behaviour and personal practice to ensure no harm occurs in any situation to children during their involvement in any OTI Group activities or projects.
A child is defined as anyone under the age of 18, in line with the UN Convention on the Rights of the Child (1989).
Child protection is a broad term to describe philosophies, standards, guidelines and procedures to protect children from both intentional and unintentional harm. In the current context, it applies to OTI Group’s duty to make sure that its staff, operations and programmes do no harm to children, that is that they do not expose children to the risk of harm and abuse and that any concerns the organisation has about children’s safety within the activities and programmes in which they work are reported to the appropriate authorities.
Direct contact with children
Being in the physical presence of a child/children in the context of OTI Group’s work, whether contact is occasional or regular, short or long-term. This could involve attending meetings and conferences at which children are present or working with child volunteers in the OTI Group office (N.B. these are examples).
Indirect contact with children
1) Having access to information on children in the context of OTI Group’s work, such as children’s names, locations (addresses of individuals or projects), photographs and case studies.
2) Providing funding for organisations that work ‘directly’ with children. Although indirectly, this nonetheless has an impact on children and therefore confers upon the donor organisation's responsibility of child protection issues. (N.B. this list of examples is not exhaustive).
For the purpose of this policy, a member is a full or associate member organisation or an individual member of OTI Group.
‘A statement of intent that demonstrates a commitment to safeguard children from harm and makes clear to all what is required in relation to the protection of children. It helps to create a safe and positive environment for children and to show that the organisation is taking its duty and responsibility of care seriously.
According to the World Health Organisation, “child abuse” or “maltreatment” constitutes ‘all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power’.
Our understanding of child abuse and exploitation includes, but is not limited to:
Physical Abuse may involve hitting, shaking, throwing, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer feigns the symptoms of or deliberately causes ill health to a child who they are looking after. This is commonly described using terms such as 'fictitious illness by proxy 'or 'Munchausen’s syndrome by proxy'.
Emotional Abuse is defined as the persistent emotional ill-treatment of a child such as causes severe and persistent effects on the child’s emotional development. It may involve conveying to children that they are worthless and unloved, inadequate, or valued only so far as they meet the needs of another person. It may involve age or developmentally inappropriate expectations being imposed on children. It may involve causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of ill-treatment of a child, though it may occur alone.
Sexual Abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g., rape) or non-penetrative acts. They may include non-contact activities, such as involving children in looking at, or in the production of, pornographic materials or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Neglect is defined as the persistent failure to meet the child’s basic physical and/ or psychological needs, likely to result in the serious impairment of the child’s physical or cognitive development.
Bullying may be defined as deliberately hurtful behaviour, usually repeated over a period of time, where it is difficult for those bullied to defend themselves. It can take many forms, but the three main types are physical (e.g. hitting, kicking, theft), verbal (e.g. racist or homophobic remarks, threats, name calling) and emotional (e.g. isolating an individual from the activities and social acceptance of their peer group).
Sexual abuse of children can also be defined as contacts or interactions between a child and an older or more knowledgeable child or adult (a stranger, sibling or person in a position of authority, such as a parent or caretaker) when the child is being used as an object of gratification for an older child’s or adult’s sexual needs. These contacts or interactions are carried out against the child using force, trickery, bribes, threats or pressure. Sexual abuse can be physical, verbal or emotional.
Commercial Sexual Exploitation of Children comprises sexual abuse by the adult and remuneration in cash or kind to the child or a third person or persons. The child is treated as a sexual object and as a commercial object. The commercial sexual exploitation of children constitutes a form of coercion and violence against children, and amounts to forced labour and a contemporary form of slavery.
Child Pornography means any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes. This can include photographs, negatives, slides, magazines, books, drawings, movies, videotapes and computer disks or files. Generally speaking, there are two categories of pornography: soft-core which is not sexually explicit but involves naked and seductive images of children and hardcore which relates to images of children engaged in sexual activity and the use of children in the production of pornography is sexual exploitation.
Violence was defined by the UN Secretary General’s Study on Violence as ‘physical, psychological (psychosocial), and sexual violence to children through abuse, neglect or exploitation, as acts of commission or omission in direct or indirect forms, that endanger or harm the child’s dignity, physical, psychological, or social status, or development.
Commercial Exploitation means exploiting a child in work or other activities for the benefit of others and to the detriment of the child’s physical or mental health, education, moral or social-emotional development. It includes but is not limited to, child labour.
A child who is being abused may experience more than one type of cruelty. Discrimination, harassment, and bullying are also abusive and can harm a child, physically and emotionally.
As a condition for working with OTI Group, all staff; Management Board members; interns and volunteers and all those acting on behalf of OTI Group, such as members, consultants or trainers are required to undergo the following:
1. Both acceptance and commitment to our Child Protection Policy and Code of Conduct for working with children by signing a commitment to adhere to the Child Protection Policy principles and procedures.
This includes the recruitment and appointment process:
- Staff, volunteers, interns and consultants are recruited to clear job or role descriptions that include a statement on the position or role’s responsibilities to meet the requirements of OTI Group’s child protection policy.
- All recruitment interviews should include a discussion on child safeguarding and protection, the candidate’s understanding of this and OTI Group’s commitment.
- Adherence to OTI Group’s Child Protection Policy is part of OTI Group employment contracts and service agreements.
2. Signing a personal declaration stating any criminal convictions, including spent convictions. OTI Group job application forms include a question asking for consent to gain information on a person’s past convictions/pending disciplinary proceedings.
For those working directly with children, are added:
3. Satisfactory clearance through a police check conducted by the responsible authorities of the country of origin/birth. For OTI Group staff in Cyprus an extract from the criminal record listing your convictions should be requested from the municipality or the local police of the municipality where they are registered. Model 2 is specifically designed for staff working with children and young people. The extract needs to provide clearance for having no convictions for working with children.
4. Provide the name and contact information of two character references they have known for no less than two years, excluding family members, who have knowledge of the candidate’s experience and suitability to work with children. The identity of the referees will be verified.
5. OTI Group staff is empowered to call out behaviours of members, which are not in compliance with OTI Group’s child protection policy.
Education and training are essential to implement the Child Protection Policy. This includes:
1. At the beginning of the induction period (within 3 weeks of taking up the position) staff/volunteers/interns/MB members they will receive an introduction to OTI Group’s Child Protection Policy and procedures from the Child Protection Focal person. This will include training on behavior guidelines for those in direct contact with children, and guidance on the acceptable and unacceptable sharing of information on children. Training will also allow staff to be able to identify sources of support for children and their families.
2. Child Safeguarding Training will be given to all staff, volunteers and interns, appropriate to their roles and responsibilities.
Any staff, employee, volunteer, intern, management board member, consultant or adviser who has direct contact with children in his/her work will be fully informed of OTI Group’s Code of Conduct.
A Child Protection Focal person (CPF) will be appointed who will be responsible for:
- Promoting awareness and implementation of the Child Protection Policy throughout the organisation.
- Monitoring implementation of the Policy and reporting on developments at Team meetings and for the Management Board.
- The development of child protection training resources is required.
- Maintaining knowledge of best practices and statutory requirements.
- Acting as a source of support and information for staff on safeguarding issues.
The name and contact details of the CPF will clearly be displayed in the OTI Group office and new staff will be made aware of the role.
The disclosure of personal information about children, including legal cases, will be limited to those employees, interns, volunteers, and MB members who need to know. The Management Board will have the overall responsibility to oversee and ensure the Policy’s implementation.
Specific procedures and checklists are part of the Child Protection Policy which are dealing with the implementation strategy for the Child Protection Policy, including reporting procedures and monitoring and evaluation processes. Safeguarding will be included in the development of projects by OTI Group.
All staff, volunteers and interns should be alert to signs that may suggest a child is in need of help.
Deciding whether to report can be a very difficult responsibility. The reporting procedure is made widely available to ensure that everyone is clear on what steps to take regarding the safety of children and other witnesses. All witnessed, suspected or alleged violations of OTI Group’s Child Protection Policy will be immediately reported to the Child Protection Focal Person (CPF) – using the safeguarding reporting form.
The guiding principle here is that the safety of the child is always the most important consideration. These records will be stored securely with access limited to the CPF or the Secretary-General; a report must be made to the nominated Management Board member.
At meetings and activities where children are directly involved, children will be informed about OTI Group’s safeguarding policy, code of conduct, the existence of the child protection focal person and complaints mechanism in a child-friendly manner. The first stage is to decide whether the concerns are internal to the organisation or relate to an external situation. When a child protection/safeguarding concern is brought to your attention – ACT Act on your concerns.
If in doubt, speak out. Child-centred. The protection of children is the most important consideration. Time counts. Ensure timely, effective, confidential and appropriate responses to child safeguarding issues.
OTI Group will immediately suspend any employee, volunteer, intern, board member, consultant, adviser who is alleged to have violated the Child Protection Policy, pending the outcome of the investigation. OTI Group reserves the right to take any disciplinary action against any of the above who have been proven guilty in an investigation, which may include reporting the incident to the police.
The investigation completed by the President will be submitted to the Nominated Management Board member who will come to a decision about action to be taken. Decisions from any investigation will be confirmed in writing to the individual concerned.
Acts of a criminal nature will be referred to the police and/or Children’s Welfare Services in Cyprus and may result in a criminal investigation and conviction.
When investigating concerns or complaints, the process should always be fair and, where complaints are upheld, the individual will have the right to appeal the decision. In such instances, the individual must write to the President of OTI Group within one week of receiving written confirmation of the complaint outcome, explaining the grounds for appeal. The President of OTI Group will consider the appeal, which will include re-examining the evidence and reports and may include talking directly to staff and others involved. OTI Group’s President will come to a final decision, which will be confirmed in writing. The decision from the appeals process is final.
In cases where staff from OTI Group members or accompanying adults with children are alleged to have violated OTI Group’s Child Protection Policy in meetings and activities organised by OTI Group, this needs to be reported to the OTI Group CPF. The OTI Group CPF will investigate the complaint(s) or concerns confidentially and discreetly and report this to the President. Where possible OTI Group’s CPF together with OTI Group’s Secretary General will discuss the concerns with the responsible person and/or his/her organisation in order to change the behaviour or acts of the concerned person/organisation. In case the person or organisation is not able or willing to change its behaviour according to the standards of OTI Group’s Child Protection Policy, the President will report this to the MB, which may decide to suspend further cooperation with this member organisation when directly involving children or suspend membership. The member organisation has the right to appeal the MB’s decision. In such instances, the organisation must write to the President of OTI Group within a week of receiving the written confirmation of the complaint outcome, explaining the grounds of appeal. The President of OTI Group will consider the appeal, which will include re-examining the evidence and reports and may include talking directly to staff and others involved. OTI Group’s President will come to a final decision, which will be confirmed in writing. The decision from the appeals process is final.
In cases of acts of a criminal nature committed by OTI Group member organisations in relation to activities organised by OTI Group, this will be referred to the police.
Informed consent must always be sought before taking any photos, videos, or requesting personal information about children’s lives that may then be used in OTI Group materials. Informed consent means that children are told how OTI Group may use the information or image/film and that they are under no obligation to agree to its use. They should also be re-assured that locations and other identifying information that might to the location of residence of children will be changed. They will need to be asked whether they give consent that their first name is shared with the information or image/film.
Consent must be obtained by completing and signing the media consent form (included in the consent forms in annex 3). Consent is also required from the child’s parent/carer or guardian, who must countersign the form or, where this is not possible, from the organisation working with them. The organisations working with the children should lead on asking for consent of children and families, as they may feel more comfortable to refuse consent when asked by someone they already know and trust.
The media consent forms and other consent forms will be kept on the child’s file by OTI Group.
Obtaining prior written consent, does not mean that there is no requirement to obtain verbal consent at the time of taking photographs/video/interviews.