Child Protection Policy

Asociación Gitanas Feministas por la Diversidad 

Children Europe’s Child Protection Policy 

May 2024 

​​Contenido 

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Introduction 

Gitanas Feministas is an entity with more than 11 years of experience that has developed a multitude of projects and actions that has provided them with the necessary experience in the fundamental areas of the project. 

From the entity we work to remove the Roma question from social services, charity and the paternalism of a thinking that assumes that there are people to “save or rescue” from that cultural “poverty” that defines them homogeneously, to fight and combat the structural violence faced by Roma women. That is why they try to give protagonism to lead our own processes in spite of the obstacles to which we are subjected. 

The entity continuously carries out awareness-raising and intervention for roma women.  

Our child Protection Values  

A child rights and participatory approach 

Gitanas Feministas work is underpinned by the United Nations Convention on the Rights of the Child (UNCRC). We share the philosophy adopted by the UNCRC and recognise children as individuals who have the right and the ability to express themselves and to take part in matters and decisions that affect them, including their own protection. In the UNCRC, child participation is one of three core themes covered, together with protection and provision. These three themes are interrelated as one cannot be successfully implemented without the other – “protection requires participation, participation requires provision, and provision enables protection.”1 Therefore, we encourage you to consider this Child Protection Policy together with our Child Participation Guidelines, and to carry out any work with children and young people by consulting both documents. 

Embedded in our culture 

We believe that protecting children from harm should be part of the organisation’s culture, this means it guides our partnerships with external stakeholders, funders, and programmes. 

A duty that applies to all 

We believe that protecting children from harm is a responsibility that applies to everybody. It is a duty that all members of staff – working directly and indirectly with children – as well as other adults involved in Gitanas Feministas activities are expected to uphold and act upon, when necessary.  

Guiding Policy Principles 

Principle 1: Zero tolerance of violence, abuse, exploitation, and neglect of children.  Gitanas Feministas has a zero-tolerance approach to violence, abuse, exploitation and neglect against children. Harming children through violence, abuse, exploitation, or neglect will result in criminal, civil and/or disciplinary sanctions. 

Gitanas Feministas will not knowingly engage—directly or indirectly—anyone who poses a risk to children. Gitanas Feministas strives to minimise the risks of violence, abuse, exploitation, and neglect associated with its programmes, and to ensure its personnel, partners, contractors, and suppliers understand their responsibilities and obligations under this Policy. 

Principle 2: Recognition of the best interests of the child. Gitanas Feministas is committed to upholding the rights of the child. In all actions concerning children, the best interests of the child shall be a primary consideration. 

Principle 3: Decisions affecting children need to involve children. Gitanas Feministas will aim to involve children in all decisions that affect them in our programming. This includes engaging with children through consultations, providing feedback mechanisms, and supporting their leadership to help design or deliver programming, where possible and appropriate. 

Other principles that guide our work include: 

• A child’s welfare is and will always be a priority. 
• Every child is treated with dignity and as a unique subject. 
• The right to be protected from harm belongs to every child, irrespective of sex, race, ethnicity, gender, socio-economic background, religion, disability and more. 
• Any suspicions, concerns or allegations of harm will be taken seriously and responded to in a timely manner. 
• Safeguarding is the responsibility of everybody involved and establishing a partnership approach is key to effective safeguarding. 
• Recognizes the role of families as primary caregivers. 
• Children should have the opportunity to participate in their own protection. 

Definitions 

Child: A child is any individual below the age of 18 years (UN Convention on the Rights of the Child, 1989) 

Vulnerable Adult: A vulnerable adult is an individual who is 18 years or older and requires or may require assistance and support to live within the community. Such individuals may lack the ability to adequately care for themselves and/or safeguard themselves against potential harm or exploitation perpetrated by others. 

Child protection: Child protection refers to preventing and responding to (intentional and unintentional) violence, exploitation and abuse against children – including commercial sexual exploitation, trafficking, child labour and harmful traditional practices. 

Child Safeguarding: refers to pre-emptive actions aimed at mitigating potential harm to children resulting from the activities conducted by Gitanas Feministas, including its personnel, interns, consultants, and volunteers, both directly and indirectly. These risks may include physical violence, sexual violence, exploitation or abuse, emotional and verbal abuse, economic exploitation, failure to provide for physical, emotional or psychological needs, harmful cultural practices and privacy violations. 

Direct contact: Interacting and working with children, both alone or in a group. This involved being in the physical presence of children as well as interacting with them online. For instance, through a meeting on Zoom. 

Indirect contact: Having access to children’s information, or working on activities and projects that 

could directly impact children. 

Abuse: Appendix n. 1 at the end of this policy defines the different categories of abuse and provides both behavioural and physical signs of abuse that can be used as indicators of child protection concerns. 

Scope and need 

Gitanas Feministas has developed a child protection policy to ensure that all staff (interns, volunteers, and other adults) working with children and vulnerable adults offer child-safe operations and activities. In doing so, we mitigates the risk that its staff and programmes pose a risk to children and/or vulnerable adults. In addition, our child protection policy recognizes that some children are more vulnerable to abuse and therefore outlines measures to take to address increased vulnerabilities and protect them from harm. For the purpose of this policy whenever it is referred to a child the same also applies to a vulnerable adult. 

Our policy applies to:  

• All board members, staff, interns, and volunteers working directly and indirectly with children. 
• All adults involved in our activities such as consultants, partners, stakeholders, and trainers. 
• All those participating in Gitanas Feministas activities under different capacities, such as journalists, service providers, sponsors, and donors. 

This list is not exhaustive. 

For purpose of this policy whenever it is referred to a staff this would also apply to any of the categories above.  

Gitanas Feministas Child Protection Policy 

1. Staff and personnel 

Staff, board members and volunteers working with Gitanas Feministas are bound by the principles outlined in the membership handbook and must adhere to the principles and values of Gitanas Feministas. 

1. Recruitment 

• Prior to commencing work for Gitanas Feministas, all adults (members of the Board, staff, and volunteers) must undergo a criminal clearance and submit documentation to confirm their identity. This criminal clearance cannot be older than 6 months. 
• At least two verbal or written references will be required before signing a contract with a new employee. Within these reference checks specific child safeguarding questions will be asked. Records of these reference checks will be kept in the staff files. 
• New employees and volunteers must sign a statement of commitment to Gitanas Feministas 

Europe’s policy and a code of conduct. 

• All job applicants or volunteers who fail to disclose convictions that are subsequently identified by the criminal clearance check will be disqualified from working for the organisation. 

1. Training 

• All new employees will be required to read this Child Protection Policy as part of their induction, and become familiar with safeguarding processes within the organization. 
• Staff will be required to attend an internal Child Safeguarding training within their first year of joining the organization. This training will be repeated every 2 years. 

1. Code of Conduct 

The code of conduct ensures that the highest standards of behaviour are adopted by all staff and any external members or professionals involved in Gitanas Feministas activities. Any staff member whether they have direct or indirect contact with children in relation to their role have a duty to safeguard and promote the welfare of children. 

To this end all staff must: 

• Listen to and respect all children and young people. 
• Treat all children and young people equally and with dignity. The best interests of the child or adult of concern are paramount in all considerations about their welfare and protection. 
• All children have an equal right to protection from harm and this is best achieved by safeguarding practice that is actively anti-oppressive, anti-discriminatory and anti-racist. 
• All children must be valued, empowered, and supported to inform and shape our activities, including decision-making, risk-identification and review of our safeguarding practices. 
• All children should feel that our physical and online environments should be safe and secure and promote enjoyable and positive experiences. 
• Involve children and young people in decision-making, as appropriate. 
• Always provide encouragement and support. 
• Use appropriate language and communication (verbal and non-verbal). 
• Have fun and encourage a positive environment. 
• Offer constructive criticism when appropriate. 
• Treat all children and young people as individuals. 
• Always respect a child’s or young person’s personal space. 
• Discuss boundaries on behavior and related sanctions, as appropriate, with children and young people and primary carers. 
• Agree group ‘contract’ before beginning any activity. 
• Encourage feedback from group. 

• Use age-appropriate teaching resources and materials. 
• Lead by example. 
• Create an atmosphere of trust. 
• Respect differences of culture, religion, and background. 
• Make primary carers, children, young people, adults, visitors, and facilitators adhere to and sign the Child Protection Policy and procedures. 
• Have emergency procedures in place and make all staff aware of these procedures. 
• Be inclusive of children and young people with a disability. 
• Plan and be sufficiently prepared, both mentally and physically. 
• Report any concerns to the Designated Safeguarding Contact and follow reporting procedures, including completing the Safeguarding Incident Reporting Form. 
• Organizations should have an anti-bullying policy. Encourage children and young people to report any bullying and to be aware of anti-bullying policy. 
• Observe appropriate dress code and behavior. 
• Evaluate work practices on a regular basis.  

Provide appropriate training for all staff and volunteers. 

• Report and record any incidents and accidents. 
• Update and review policies and procedures regularly. 
• Keep primary carers informed of any issues that concern their children. 
• Ensure proper supervision based on adequate ratios according to age, abilities and activities involved; observe appropriate gender balance for residentials. 
• Ensure clear communication between artist and organizations; have guidelines and a prompt sheet for artists. Encourage artists to refer to the Arts Council website for direction. 
• Have a written agreement with any external organization that an artist/facilitator is working with. 
• Don’t be passive in relation to concerns, i.e., don’t ‘do nothing’. 

• Avoid taking a session/event/activity on your own. If this is not possible then it should be in an open environment with the full knowledge and consent of primary carers. 
• Avoid if possible, giving a lift to a child/young person and if you do then make sure that primary carers are informed. 
• Maintain awareness around language and comments made. If you think that something you said may have caused offence or upset, then try to address it in a sensitive manner. 
• Children should not be touched in a way that is against the Convention on the Rights of the Child or expose them to inappropriate materials such as pornographic videos and literature. 
• No physical harm should be exhorted towards children or adults. 
• In case of a breach of code of conduct, procedures identified in clauses 3.4 and 3.5 will apply. 

1. Management and Safeguarding focal points 

A designated Safeguarding Officer is appointed within the organization. The name of the focal point will be made aware to all staff and adults, as well as to children and their primary carers. The focal point will be responsible for regularly reviewing the policy, for delivering internal safeguarding training, and acting as a source of support and information towards staff on issues related to child safeguarding and participation. Ultimately, the Secretariat and the Board will have the overall responsibility to ensure the policy’s implementation. 

If the designated Safeguarding Officer is accused of abusing a child, they must step down from this role and the Secretariat and the Board must immediately appoint a new officer who meets the requirements to fulfil this role. 

1. Media 

2.1 Use of social media, photography and videos 

Before using any images or videos of children, written informed consent must be obtained in writing from children and their primary carers. Consent must be informed, meaning that children and legal guardians understand how the media will be used, for how long, and their rights to refuse consent. It must be made clear that they have a right to withdraw consent at any time, however Gitanas Feministas should clarify that it may not be possible to delete images or videos already posted. 

All adults and professionals, internally and externally, who take part in Gitanas Feministas activities must ensure that the following principles are adhered to: 

• The child’s dignity must always be preserved in any image or video. 
• All children featured in the organization’s publications are appropriately presented. 
• Language and description used with images and videos will not shame, victimize, discriminate or stereotype children. 
• Photographers, where applicable, will have a certificate of good conduct completed. 
• Identification of the organization should be present in shared images or videos. 
• No personal information of the child or of their families is present in the image or video. 
• Instances of inappropriate images or videos will be reported to the Safeguarding Officer. 
• Images and videos of children shall not be used without context to portray or sensationalize a false representation or message. 
• All media files of children will be stored securely in accordance with data protection laws. 
• Members of staff, interns and volunteers must not use images or videos of children for personal use, or share with third parties. 

1. Application of the policy for external partners, photographers, journalists and others 

We believe that in order for its work to be effective, it should be based on transparency and mutual trust, where all partners involved know what to expect from each other, allowing them each to excel in their own specific role in protecting children from any situation of conflict, abuse or neglect. 

External organizations working with children on behalf of Gitanas Feministas or in partnership with Gitanas Feministas will be expected to have an up-to-date child protection policy (see also Paragraph 1.6) and, where necessary, sign a statement of commitment to Gitanas Feministas policy. 

Where necessary, partners and members from different countries are expected to be aware of local child protection regulations, requirements and procedures to follow in case of a safeguarding incident. 

In the event of external professionals working or coming into contact with children on behalf of Gitanas Feministas, the following actions must be taken: 

• A statement of commitment to Gitanas Feministas policy must be signed. 
• A criminal clearance check should be obtained, where necessary. 
• No external professional must be left alone with a child in any given situation, or exchange personal information without consent from the child’s primary carer. 

In the event of an allegation or serious concern within a partner organization, Gitanas Feministas reserves the right to review the terms of their collaboration. 

1. Implementing child safeguarding in the organization. 

1. Reporting 

Raising a safeguarding concern may be a difficult decision. It is important that all staff are able to identify a child in distress and that they feel comfortable raising their concerns to the designated Safeguarding Officer. In the case where a child makes an allegation, staff should be familiar with the safeguarding procedures to follow. 

All concerns and allegations regarding conduct that is prohibited under this policy should be reported to the Safeguarding Officer. All reports should be made in good faith and as thorough and specific as possible. The safety and best interests of the child should always be the guiding principle. The Safeguarding Officer will then immediately report to the Secretary General who will alert the acting Board Members. A decision will be made about whether it is necessary to contact the Local Authorities. In such cases, follow-up should be taken on actions from the authorities. If this is not necessary, then the internal safeguarding procedures should be followed. 

If the concern or allegation is towards the Safeguarding Officer or any other concerns arise that would prohibit reporting to the Safeguarding Officer, it can be reported to the Deputy Safeguarding Contact directly. 

If a child or young person is in immediate danger or injured, emergency services, such as the ambulance and the police, should be contacted immediately. 

All concerns and allegations will be initiated in a timely manner based on their seriousness and urgency. 

1. Internal safeguarding procedures 

When implementing internal safeguarding procedures, every effort should be made to ensure confidentiality of the situation. Information should be shared on a need-to-know basis, where possible. There are circumstances where sharing information is considered to be in the best interest of the child, for instance in cases of alleged abuse or immediate harm. In these given situations, information must be passed on without delay to the appropriate person or entity such as law enforcement. 

1. Reporting a concern or allegation 

If you are concerned about a child or a child has made a disclosure, the procedure below has been designed to broadly outline the steps to follow: 

Create a safe space and non-judgmental space 

1. Actively listening to the child without interrupting and allowing them to remain in silence should they so wish so. be silent if they wish to. 

1. Avoid leading questions and statements that could make the child feel ashamed, threatened, unsafe, uncomfortable or insecure. 

1. Reassure the child that they have done the right thing by speaking up. 

1. Do not make false promises of assurances or of confidentiality. 

Share information 

1. Report the incident immediately to the Safeguarding Officer. If they are not available, report to the Deputy Safeguarding Officer. 

1. Only share the information disclosed by the child on a need-to-know basis and inform the child prior to sharing the information (when appropriately possible). 

1. Consult with the Safeguarding Officer on the best way to inform the child. Together with the Secretary General, a decision will be made about who will inform the child and his/her carers. This decision will be made based on the best interest of the child and his/her relationship with the adults involved. 

In case of emergencies outside of normal working hours and in situations that threaten the immediate safety of a child, it may be necessary to contact the police. 

Record everything 

• Thoroughly record all information and any actions taken by you. 
• Complete the Safeguarding Incident Form (Appendix 2). 
• If you feel you need additional support, talk to your line manager about how this can be sought. 
• Keep in mind that these records may be used as evidence in criminal proceedings. In case the child has supplied documents such as notes, drawings or pictures during its disclosure process these should be collected upon consent for future reference if needed. 

1. Internal investigation of a concern 

The Secretary General and the President, with support from the Safeguarding Officer, are responsible for investigating any concerns or allegations. Any investigation should be fair and done discreetly. As part of the investigation, interviews will be completed with all those involved. If this includes children, a trusted adult should always be present during the interview. Documentation and information available relevant to the situation may also be examined. Those responsible for making a decision will convene after all steps have been taken. 

Once a final decision has been made, the individual involve may appeal by making a written statement to the Secretary General within a week since the decision was communicated to them. The President of Gitanas Feministas will re-evaluate the appeal by re-analysing the evidence available, before making a final decision which will be confirmed in writing. 

1. Allegations towards a member of staff 

If an allegation or a concern is raised towards a member of staff, they will be suspended for the length of the investigation and until a decision is made by the Secretary General, and the Board Members. Gitanas Feministas reserves the right to take any disciplinary action during and after an investigation. If a criminal offence has been committed or a serious concern is raised, Gitanas Feministas reserves the right to contact relevant authorities to determine if any abuse has taken place. 

Investigations of allegations of staff will be robust and timely and will not cease if the staff resigns. The procedure that will be followed is broadly outlined below: 

In case of potentially harmful behavior or language towards a child, the President or Vice President, together with the Secretary General and Designated Safeguarding Contact will formally address the matter through a discussion with the person concerned, and additional measures deemed appropriate, including i.e., exclusion from certain activities of the organization or ending of the contract or cooperation. The person against whom the complaint has been issued will have an opportunity to appeal any decision in writing and ask for a discussion with the President or Vice President, Secretary General and Designated Safeguarding Contact. 

Any action following an allegation of abuse against an employee should be taken in consultation with workplace health protection services and police. After consultation, the President/Vice-President should advise the member of staff involved and agreed procedures will be followed. 

1. Anonymous reporting of incidents 

To ensure that all incidents are reported, anonymous reports will be accepted using the Reporting Form found at the end of this policy. 

1. Complaints 

In the event of complaints or comments: 

• Complaints or comments will be responded to within two weeks. 
• Verbal complaints will be logged and responded to. 

1. Safeguarding practices 

The following practices must be followed when working with children 

1. Informed Consent 

Prior to a child participating in Gitanas Feministas activities, projects or programs, informed consent or assent must be sought from the child and from their primary caregiver. Informed consent means that the child and their primary caregiver is told what the expectations of participating are, how their information will be used, how media may be used, and to remind them that they are under no obligation to participate. 

Informed consent must be obtained in writing, and verbal consent is recommended at the time of taking images/videos or at the start of any activity. 

The professional asking for consent should be an adult whom the child has already met and shares a degree of trust with; this is important to ensure that the child feels comfortable asking questions and does not feel obliged to give consent. 

Allow enough time between the point of distribution of the consent form Allow a minimum of 48 hours to pass from the point of distribution to ensure that the child and their primary caregiver have had enough time to talk about the information provided and to ask for any clarifications they may have. 

In any instance the child will be informed on the child safeguarding code of conduct and on how to disclose any concerns they may have before, during or after their participation. 

1. Risk Assessments 

Before working with children, a risk assessment should be completed to identify and minimize potential risks. The assessment should consider a child’s individual vulnerabilities and circumstances, and should look at: 

• the socio-political context, geographic, sociocultural and religious scope and setting of the programme. 
• the organisation’s potential impact on or contact with children. 
• the potential risks of that impact or contact. 
• the risks in terms of likelihood they could occur and the seriousness of the 
• impact on children. 
• which strategies (including organizational culture, roles and responsibilities, policies and procedures, systems and processes, capacity building) will be used to minimise and prevent risk will be implemented 
• when risks and preventative measures will be reviewed and revised 
• how these will be communicated and consulted. 

Additionally, a careful weighing of benefits vs. Risks of child participation will be assessed in advance of every programme/activity. 

First-aid boxes should be available in the office and regularly re-stocked and the location of the first- aid box(es) must be made known to staff. Availability of first-aid should be in accordance with the organization’s Health and Safety guidelines. The location of accident/incident books must be made known to staff. External organizations with whom your organisation has dealings with must provide proof that they have public liability insurance. 

1. Confidentiality and recording/storing information 

Any information collected about the child and their family should be stored confidentially and in accordance with data protection laws. When possible, information will be stored electronically, with restricted access and only shared on a need-to-know basis. In cases where information collected is in paper format, it should be stored in a safe location within Gitanas Feministas premises. 

Information on children will be kept in accordance with legal retention periods and disposed of safely and in a way that secures their confidentiality. 

Children and their families must be informed of what information is stored and that they have a right to access their information at any given time. 

Gitanas Feminsitas has a duty to ensure that the IT infrastructure is secure and is not open to misuse or malicious attacks. 

Key safeguarding contacts 

Every member of staff, intern and volunteer is expected to be familiar with who the key contacts are for safeguarding concerns. Gitanas Feministas has identified the following people as its key contacts:  

Designated Safeguarding Contact 

María José Jiménez Cortiñas 

gitanasfeministasporladiversidad@hotmail.com 

Revision of Child Protection Policy 

This policy will be reviewed every 2 years by the Board of Gitanas Feministas alongside an overview and evaluation of progress performance and lessons learnt. 

Date of recent Review: June 2024  

Appendix 1: Categories of abuse 

The following table is indicative, and each child may display different signs of actual or likely abuse. If you spot any of the following signs, please raise your concerns with a manager or a designated safeguarding contact. 

Appendix 2: Safeguarding Incident Reporting Form 

If you are reporting a concern or an incident involving more than one child, please fill out individual reporting forms for each child. 

*Non mandatory: Should you wish to stay anonymous because you fear consequences from reporting, we prefer an anonymous report to no report. In this case, please record why you felt compelled to report anonymously. 

**Nonmandatory: we record these for statistical purposes, to identify any concerns with regard to equality and inclusion within the organisation 

Are you reporting a concern/incident raised by: (please circle one of the following) 

You A child A third person 

If someone other than you, please provide the following information about them where applicable: 

Name, date of birth, organization and role, relationship to child involved 

* Non mandatory: In case you wish to stay anonymous, please record why you felt compelled to report anonymously 

Appendix 3: Code of conduct 

Staff Code of Conduct 

All staff members and Consultants of Gitanas Feministas are required to follow this Code of Conduct. Concerns regarding compliance will be addressed directly and quickly between the line manager and the staff member and the Secretary General and Board of Directors will be kept informed. 

Personal conduct 

Staff members will conduct themselves professionally at all times during their work for Gitanas Feministas. 

Specifically, this includes to: 

• Be courteous and respectful to co-workers, clients, collaborators and children; 
• Act with honesty and integrity; 
• Refrain from violence in any form; 
• Be sensitive to the cultural and social contexts in which work takes place, and reasonably comply with local norms; 
• Comply with Belgian law, and the laws of other States in which their work for Gitanas Feministas may takes place; 
• Immediately report criminal charges against themselves that are relevant to any area covered by the Code of Conduct; 
• Speak up when concerning behaviours from coworkers, clients or collaborators is observed; 
• Not be affected by alcohol or other substances while working. 

Child safeguarding 

Gitanas Femisnitas works predominantly in the area of child protection and takes the safeguarding of children within all work activities very seriously. Specifically, staff members must: 

• Not engage in activity of a sexual nature with a person below the age of 18 at any time, including outside their work with Gitanas Femisnitas, regardless of local laws regarding sexual consent; 
• Not contact a child in any way which could be reasonably viewed as intending to engage them in sexual activity (i.e. grooming), at any time, including outside their work with Gitanas Feministas; 
• Not view, possess, produce or distribute child sexual abuse materials or live-streaming of child abuse; 
• Not engage in violence against children, including using physical discipline, at any time, including outside their work with Gitanas Feministas; 
• Actively oppose all exploitation and abuse of children; 
• Treat all children with respect and dignity, and not discriminate on the basis of any status such as ethnicity, gender, sexuality, or disability; 
• Ensure a second adult is involved during any work activities that involve direct contact with children, including via technology; 
• Be accountable for their behaviours and not place themselves in circumstances where a risk of child abuse or exploitation allegations may be made; 
• Discuss any concerns with their manager or the Secretary General about the behaviour of coworkers or clients they come into contact with during their work with Gitanas Feministas; 
• Discuss any concerns with their line manager or the Secretary General about the behaviour of children that may indicate abuse or exploitation. 

This Code of Conduct details a number of non-negotiable requirements; however, staff of Gitanas Feministas are encouraged to always consider how their actions affect others, and the work of Gitanas Feministas. Staff are encouraged to openly discuss concerns and these discussions will always be held in good faith and in confidence. Retaliation or reprisal for raising concerns will not be tolerated. However, maliciously raising false concerns is regarded as a serious violation. 

I, have read and understood the Gitanas Feministas Code of Conduct and agree to act in compliance with it. I understand that serious violations of the Code of Conduct may represent cause for termination, and that such decisions are at the discretion of the Secretary General and Board. 

Signed: Date: