General Safeguarding Policy
Introduction
What is safeguarding?
Safeguarding is how the organization delivers on its duty of care to prevent and minimize the risk of harm to its service users and staff/volunteers. This includes both preventative actions to minimize 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 vulnerable adults and children especially, but also to those staff and volunteers working in the OCC community.
Purpose of this policy
OCC takes seriously it’s responsibility to protect the safety and well-being of its community, including vulnerable children and adults from the refugee community, and the volunteers working with them. We are committed as an organization to keeping the OCC community safe and protecting them from all forms of harm and abuse.
This policy aims to act as a guide to managing day-to-day activities with vulnerable adults and children, and mitigating against the risk of harm, whether physical or psychological. We recognize that there is risk of harm to members of our community, especially vulnerable people on the move, and that OCC has a duty of care. We have developed this safeguarding policy as a means of minimizing the risk of harm across all OCC operations, and ensuring that any safeguarding concerns or incidents are met with an appropriate and rigorous response. We also extend the requirements of the safeguarding policy to any partners or visitors, as well as OCC staff, via the Code Of Conduct.
Any violations of this policy will be treated as a serious issue and will result in disciplinary action being taken, including termination and any other available legal remedy. This policy also describes these actions.
While the Safeguarding Policy aims to be comprehensive, it is likely that there may be circumstances which are not covered or where there is a question about the application of the policy and procedures. In such situations, the local coordinator should be contacted or other reporting forms can be followed as described here.
Communication of the policy
All members of staff and volunteers are made aware of this policy upon joining OCC. During induction training they are required to familiarize themselves with the policy, and sign the Code Of Conduct. All OCC partners who visit or participate in OCC operations will be required to read a copy of the policy and sign the Code Of Conduct.
Principles of our Safeguarding Policy
Our Safeguarding Policy is based upon a number of principles and beliefs, including:
All members of the OCC community have a right to a safe environment, free of harm, abuse and neglect.
People on the move and children may be more vulnerable to harm by others.
Everybody has a responsibility for safeguarding. This policy is mandatory for all those who work for or on behalf of Open Cultural Center, including staff, volunteers and partners. Although training, advice and support will be provided, everyone should actively participate so that they can carry out their responsibilities towards safeguarding children.
We work in a transparent and open way where safeguarding is recognized as a priority. We understand that situations of abuse and harm are able to flourish when staff, volunteers, partners, children, families and community members do not feel able to raise their concerns.
All reports of concern regarding safety and protection will be taken seriously. Where necessary, appropriate steps will be taken to protect vulnerable individuals and to take action against the alleged perpetrator. This may include referrals to law enforcement and child protection agencies. In relation to allegations against staff, volunteers and partners, action may also include the suspension or termination of engagement or any type of cooperation.
No single organisation is able to safeguard children by working in isolation, and therefore we will work with other organisations, agencies and groups as necessary and appropriate.
We maintain confidentiality and do not disclose personal details of those involved in protection concerns, including the names of those raising concerns unless it is necessary to pass on information to ensure that a vulnerable person is protected (for example where a child may need specialist services or where a criminal offence may have been committed).
We work within the framework of international and national laws and policies regarding safeguarding.
There is no one specific way of safeguarding vulnerable people and promoting their rights. Solutions need to reflect the culture and operating environment and the nature of activities being undertaken. However, culture can never be used as an excuse for abuse.
Safeguarding roles and responsibilities
Designated Safeguarding Lead (DSL)
The Designated Safeguarding Lead is a member of the Leadership Team. The Designated Safeguarding Lead (DSL) acts as the main source of support and advice for safeguarding. The DSL is primarily responsible for:
supporting staff and volunteers with advice and guidance on safeguarding issues.
managing safeguarding concerns raised by volunteers, staff or community members.
referring concerns to external agencies including the police, NGOs and other statutory bodies.
keeping up to date with relevant safeguarding legislation and good practice
providing safeguarding training for group members
Safeguarding Committee
The Safeguarding Committee is responsible for overseeing safeguarding policy process and culture across OCC. When safeguarding decisions are escalated beyond local staff or volunteers, the Safeguarding Committee will take over decisions and responsibility for managing the situation. The Safeguarding Committee can also advise local staff and provide support with assessing risk and responses.
The Committees work includes:
writing and approving the safeguarding policy
reviewing the policy annually
ensuring this policy meets the requirements of local regulatory frameworks, as well as staff volunteers and the wider OCC community
ensuring group members are recruited safely (as outlined in the Safer Selection guidelines)
at least one member of the group acts as a DSL, with other members stepping in to deputize in their absence.
arrangements are put in place in the event of a complaint against any staff member/volunteer by the OCC community
ensuring all volunteers attend Safeguarding training and read the Handbook for Volunteers and this policy.
All staff and volunteers
All OCC staff and volunteers have a responsibility to:
Read and follow the Volunteer Handbook which includes this policy
Attend Safeguarding Training provided in your induction.
Be aware of, and alert to signs and indicators that all might not be well with colleagues and members of the community.
Treat all safeguarding concerns seriously, reporting immediately to the Designated Safeguarding Lead and taking advice when needed.
If for any reason the Designated Safeguarding Lead cannot be contacted, it is not appropriate to do so, or the need is immediate, report any Safeguarding Concerns directly to the appropriate agencies (Director of OCC Didac Guillamet, local Police, other agencies or organizations in the area).
The Handbook for Volunteers and mandatory Safeguarding Training covers the following:
Good practice guidelines, including the Code of Conduct
Volunteer Self Care
Working with refugees
Identifying and reporting safeguarding concerns
Whistleblowing and complaints
Safeguarding concerns
What is a safeguarding concern?
A safeguarding concern is any worry or concern about the safety or well-being of a person because of something seen or heard, or information which has been received. It can be a one-time occurance, or a recurring something that is happening. This includes any concerns about the behavior of community members, staff or volunteers which is harmful or puts others at risk. A concern may arise in several ways, for example:
Someone’s behavior gives cause for concern.
Someone says they are being harmed, exploited, or abused.
Someone indicates they want to harm themselves.
Signs of harm, exploitation, radicalisation, abuse or neglect are seen
Someone witnesses a person being harmed.
An adult survivor discloses their experience of harm, exploitation, radicalisation, abuse or neglect (often called ‘historical abuse’). The perpetrator may still be alive, and others may be at risk.
How do we respond to a safeguarding concern?
Concerns and reports may be received from a number of sources – including staff, volunteers, partners, children and families/community members. When a safeguarding concern is raised our group members will:
Treat all safeguarding concerns seriously.
If appropriate try to speak to the person, to explain their concerns and seek further information.
Always act in the best interests of the person, respecting and involving them, giving them a choice over decision making which impacts them, unless they lack the capacity to do so or it would put them at serious risk of harm, exploitation, radicalisation, abuse and neglect.
Provide people with safe and appropriate advice, signposting and referring them to services that meet their needs.
Work in partnership with other organisations, including statutory services like the police and social care to make sure they get the help they need.
Refer concerns where a child or adult at risk has been or is at significant risk of harm, exploitation, radicalisation, abuse and neglect to local authority social care or the police.
Protect confidential information except where the wider duty of care or the public interest might justify making it known.
In any medical emergency or when there is a risk of imminent, significant harm, we will contact the appropriate emergency services, and report directly to the Designated Safeguarding Lead immediately.
How to report a safeguarding concern?
All Representatives should know the steps to take and whom to contact when concerns arise regarding the safeguarding. Failure to report a reasonable suspicion of misconduct in accordance with this Policy will be treated as a serious issue and may result in disciplinary action. If a child or vulnerable person is in danger or in harm’s way, call the local authorities immediately. In any case you must inform your manager about the danger and contact directly the Designated Safeguarding Lead or the Safeguarding Committee.
Key takeaways about reporting:
Any manager who receives a report of any allegation of a violation of this Safeguarding Policy must forward the report as soon as practicable to the `Designated Safeguarding Lead.
All other staff/volunteers covered by this policy must report any suspicion of misconduct covered by this policy as soon as practicable to their direct supervisor. Usually this will be the local Project Coordinator, who is also the Designated Safeguarding Lead.
The main point of referral should be the Designated Safeguarding Lead. This is to ensure that reports are managed in a systematic way, and lessons are learned in terms of the implementation of the policy. The Designated Safeguarding Lead is always in direct contact with the Safeguarding Committee and is required to report any worries or doubts directly to the committee.
Decisions about child protection incidents must not be made by individual workers in isolation. However in exceptional circumstances – such as a life threatening situation – staff or volunteers 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 described in this policy document.
Local contacts with child protection agencies, social workers and law enforcement should be identified in advance to enable a referral to an outside agency if required to protect the child or adult. Contact details should be retained so a referral can be made quickly and efficiently. Table 1 provides a list of current focal points for safeguarding within the Polykastro/Axioupoli/Nea Kavala ecosystem.
Consideration on whether to refer to an outside agency for protection must always be made within the legal framework of the country and with consideration for the best interests and wishes of the person at risk.
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 vulnerable people are kept safe and appropriate assistance is given.
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 Safeguarding Committee.
Mitigating risk in our work
Background Checks
In Greece, Open Cultural Center shall require criminal background checks from all Open Cultural Center staff and volunteers, and anyone who visits Open Cultural Center’s programs (e.g., journalists, donors, celebrities) and as it deems appropriate and as permitted by law. In OCC Spain, criminal background checks will be asked if required for the specific role.
Obligations & responsibilities
Specific obligations and responsibilities for all adults (including Board Members, staff, interns, volunteers and consultants) working with/for Open Cultural Center, whether paid or unpaid or full or part time.
The Safeguarding Policy applies to all those working with or on behalf of Open Cultural Center. By agreeing to work with/for the organization, it is implied that the terms and conditions of the Safeguarding Policy have been accepted as a condition of involvement.
All staff (including consultants and standing volunteers) are required to sign and abide by the Code of Conduct as a condition of their involvement with Open Cultural Center. This sets out specific expectations of acceptable and unacceptable behavior.
All occasional volunteers and visitors are required to sign the Code of Conduct as a condition of their involvement with Open Cultural Center.
While orientation on the policy together with any necessary additional training regarding responsibilities and duty of care (particular to specific roles) will be provided, all adults have a personal responsibility to seek further clarification and advice where they are not clear about what is expected of them.
Breaching the Code of Conduct or contravening the Safeguarding Policy may lead to suspension and termination of any type of engagement. This will be determined on a case by case basis, ensuring that applicable employment conditions and legislation are observed and with regard for the privacy and confidentiality of those concerned while any internal investigation is carried out. In addition, after a thorough consideration of the facts, we will decide whether the case needs to be reported to law enforcement authorities in full conformity with the law.
The Safeguarding Policy focuses on contact with members of the OCC community taking place during work under the responsibility of the organization. Nevertheless, conduct outside the work environment of those associated with Open Cultural Center may also contravene the principles and values of the Safeguarding Policy. If such issues arise, these will be carefully considered and any decisions made will place utmost importance on the community’s best interests.
Safeguarding training
All open Cultural Center staff must undertake an initial training on safeguarding and the OCC Safeguarding Policy before starting their work for OCC. Managers at all levels are responsible for ensuring those reporting to them are made aware of and understand this Policy and are given trainings as described above. Refresher training will also be provided periodically.
Training Course | Who? | When? |
Safeguarding Basics | All staff and volunteers | Before starting work |
Refresher Training | All staff and volunteers | Every 3 months |
Monitoring and review
To establish and maintain a strong safeguarding culture, OCC will monitor data from a number of different sources. We will create spaces and channels where volunteers and community members can communicate concerns openly, and where possible, anonymously.
What are you monitoring? | Data source | Action Owner | Escalation levels | Frequency |
Policies and procedures are being communicated to relevant audience | Volunteer exit questionnaires | OCC Barcelona | OCC Director | Once a member leaves |
Safeguarding awareness as part of induction process | Signed Code of Conduct records | OCC Greece | OCC Director | Once a new member joins |
Whether we are managing risk well | Safeguarding Incident Log | Safeguarding Committee | OCC Director | Monthly |
The Safeguarding Policy will be reviewed annually by the safeguarding committee. Safeguarding incidents will be monitored in monthly meetings of the Safeguarding Committee.
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