Safeguarding & Child Protection Policy.

Introduction

What is child safeguarding?
Child safeguarding is the responsibility that organisations have to make sure their employees, operations, and processes 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 communities in which they work, are reported to the appropriate authorities.

What is a Safeguarding and Child Protection Policy (SCPP) and why does VerifyMy need it?
An SCPP describes what safeguarding measures are in place to protect children, rules on how to behave when working directly or indirectly with children, how to prevent them from abuse and harm, whom to report if any of this happens and how to respond to the situation in an appropriate manner.

This SCPP provides information for children, young people, parents and other stakeholders on what to expect from VerifyMy; it guides employees in their daily work, and gives the organisation accountability.

This SCPP is also in place to protect employees, including those working for clients. It will be publicly available, is written in a simple language, and must be endorsed by all employees and management.

What is the scope of this policy?
VerifyMy is a company which designs, develops and operates a range of products that help keep children safe online. This policy is designed to apply to all existing and future projects and products.

Is there a child-friendly version of this policy?
A child-friendly version of this policy will be developed when it is likely that children will be accessing our products and may wish to refer to this policy.

1. VerifyMy SCPP

This is the VerifyMy SCPP, and this document includes key procedures which apply to all operations and activities conducted by, or on behalf of, VerifyMy, and its clients when making use of its products. This policy reaffirms and strengthens VerifyMy’s commitment as an organisation towards keeping children safe and protecting them from all forms of harm and abuse. This is an issue of critical importance for VerifyMy and the company sees the protection of children, the promotion of their wellbeing and upholding children’s rights as a foundation of its work. 

1.1. Purpose of the policy
The aim of the policy is to regulate how VerifyMy works as an organisation so that the children with which it comes into contact with (either directly or indirectly) are safeguarded and have their wellbeing promoted, and that the company’s actions do not cause any harm to children. While the SCPP aims to be comprehensive, given the diverse range of settings and operations carried out by VerifyMy, it is likely that there may be circumstances which are not covered or where there is a question about the application of the policy. In such situations, VerifyMy should be contacted for further advice.

1.2. Definition of Safeguarding
“Child safeguarding is the responsibility that organisations have to make sure their employees, operations, and processes 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 communities in which they work, are reported to the appropriate authorities''. (Keeping Children Safe Coalition).  This includes both preventative actions to minimise the chances of harm occurring, and responsive actions to ensure that incidents which may happen are appropriately handled.  Safeguarding implies a wider duty of care towards children rather than just upholding their right to protection (as defined in the UN Convention on the Rights of the Child, 1989) – but it is primarily concerned with harm and wellbeing, rather than with the promotion and protection of child rights generally. 

2. Definitions

For the purposes of this policy the following working definitions are used:

Abuse: used in its widest sense and includes physical, emotional/psychological and sexual abuse, neglect and negligent treatment, violence and exploitation in all forms.
Emotional Abuse: the persistent emotional ill-treatment of a child such as to cause severe and long-lasting effects on their 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 can also involve age or developmentally inappropriate expectations being imposed, or causing children frequently to feel frightened or in danger. Some level of emotional abuse is involved in all types of ill-treatment of a child, though it may occur alone.
Neglect: 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.
Physical Abuse: this 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.
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 or gives consent. The activities may involve physical contact, including penetrative (e.g. rape) or non-penetrative acts. They may also 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.
Child/Children: refers to anyone under the age of 18, irrespective of the age of majority in their own country, or where they are located or living.
Child Protection Incident: refers to when an allegation is made, even if it is unsubstantiated, that a child is being abused or is likely to be abused.
Clients: VerifyMy interacts with a range of stakeholders, where the relationship can be contracted or less formal and built upon mutual work and interests. In these cases, VerifyMy may be able to positively influence the practice of the client, even if it cannot insist upon observing safeguarding practice as a condition of engagement
Employees: anyone who works for or on behalf of VerifyMy on a full time or part time basis.

3. Preventative action: Putting the policy into practice

This section of the policy identifies specific steps and concepts which translate the vision of safeguarding children into action.

Child safeguarding runs across the whole organisation and is not just associated with research activities or the work of the VerifyMy development team. The concept of thinking about safeguarding and reducing risk should be embedded in everything that the company does.

Throughout the policy, a number of situations have been highlighted which specifically call for a risk assessment, such as when conducting an activity or when concerns are raised about an employee’s reference or police check. However, this does not mean that risk should only be considered at those times. Safeguarding risks must be regularly reviewed at all levels.

It should be remembered that although VerifyMy normally thinks of safeguarding issues when an adult is mistreating a child, children can also be the perpetrators of abuse. This normally occurs where one child is in a position of power or influence. In such cases, while action is necessary to support the child being bullied, it is critical to remember that the perpetrator is also a child, and therefore interventions should be in the best interests of both children in terms of how to support the abused child and what response is required for the abusive child.

4. Reporting Concerns & Child Protection Incidents

This section covers the case where a concern is reported that the SCPP is not being implemented or a child protection incident is reported (i.e. where a child may be or is at risk of abuse and actions may be necessary to ensure that the child is protected).

Concerns and reports may be received from a number of sources including employees and other stakeholders. All concerns and reports must be taken seriously.

Such reports should be passed in the first instance to the CPC.

Clients should develop a reporting framework which identifies how concerns and reports should be managed. The main point of referral should be the CPC. This is to ensure that reports are managed in a systematic way, and lessons are learned in terms of the implementation of the policy. This does not mean that the CPC is responsible for action, but he or she should be involved in decision making.

Decisions about child protection incidents must not be made by individual employees in isolation. However, in exceptional circumstances, such as a life-threatening situation, employees may take whatever action they deem necessary to protect a child at immediate risk, but this must be reported as soon as possible in accordance with the reporting framework (i.e. in the first instance to the CPC). Local contacts with child protection agencies and law enforcement should be identified in advance to enable a referral to an outside agency if required to protect the child. Contact details should be retained so a referral can be made quickly.

Consideration on whether to refer a child to an outside agency for protection must always be made within the legal framework and with consideration for the best interests and wishes of the child.

When concerns are raised or reports made, importance must be placed on confidentiality, both of the referrer and also the child(ren)/adults involved. Information must be shared strictly on a need-to-know basis as necessary to ensure the child is kept safe and appropriate assistance is given.

Where concerns are raised by employees about other workers and clients, even if these are not substantiated, providing there was no malicious intent, no punitive action will be taken against the person raising the concern or making the report.

Referrals to local child protection agencies/police should be done in the prescribed manner (for example, there may be a particular format for reporting). Where the referral is made verbally it must also be confirmed in writing.

Written records of all reports received (even if the report is vague) must be kept and maintained in a secure and confidential location by the CPC.

5. Accountability, Monitoring & Review

This section details how the implementation of the SCPP will be monitored, and how it will be reviewed.

The CSC has overall responsibility for the SCPP. Directors are also responsible for determining policy and good practice and for implementation of the policy in all activities related to their areas of organisational responsibility.

Annually, the VerifyMy team shall conduct a self-assessment of safeguarding and the implementation of the SCPP. Based on the self-assessment, an annual plan of action will be developed to address any gaps in policy implementation and to mitigate any risks identified.

Both the self-assessments and the development of action plans will be coordinated by the CSC so that information from all projects can be assessed to measure safeguarding across the organisation.

This policy will be reviewed on a regular basis, but not more than every five years. Such reviews will also include feedback from employees, and where possible, the views of children and other stakeholders.

6. VerifyMy Child Protection Code of Conduct

This Code of Conduct must be adhered to and acknowledged by all employees and contractors. VerifyMy considers all forms of abuse towards children as unacceptable and recognises a duty to safeguard children, that is to keep them safe, promote their wellbeing and protect them from abuse and harm.

Neglect, physical, psychological/emotional and sexual violence are the main forms of abuse. This SCPP sets out the measures VerifyMy will take to safeguard children. This includes proactive actions to prevent situations of abuse and harm occurring and reactive actions to respond to situations where a child is, or may be, suffering abuse.

A child is any human under the age of 18 as stipulated by the UN Convention on the Rights of the Child, 1989.

As part of our SCPP, it is a requirement that all employees (including consultants), whether full or part time, agree to abide by the SCPP and specifically to agree to work in accordance with this Code of Conduct which sets out responsibilities for safeguarding children and expected behaviour of staff. This is a mandatory requirement.

Any form of unacceptable behaviour which breaches this Code of Conduct must be reported. In the case of situations which are not covered by the Code of Conduct, VerifyMy expects its representatives to apply common sense whilst focusing on the ‘child’s best interests’.

VerifyMy respects the Convention on the Rights of the Child and the following five principles:

7. Roles and Responsibilities of the Child Protection Champion