CODECA CHILD PROTECTION POLICY
1. Engagement of CODECA with children
CODECA is a non-profit research organization with the aim to foster and promote social cohesion, development and care, Among its objectives are to maintain social cohesion by implementing actions that will help reduce social inequalities and develop conditions for equal opportunities; plan, implement and evaluate programs to Combat Economic and Social Exclusion of Vulnerable Social Groups; provide Social Care services at individual level, family, group and community; promote respect for human rights, religious freedoms and gender equality.
To this date, CODECA participating in numerous European and National Projects has undertaken research, consulting and institution-building projects and maintains an active network of collaborating institutions and highly qualified experts.
More specifically, the activities of CODECA include:
Scientific research in specific thematic fields
Institution and capacity building projects
Training and participation in research networks
In particular, to achieve the above-mentioned objectives, children might be involved in a set of activities as research subjects focusing on protection measurements and/or national policies on children’s wellbeing. These activities include:
Fieldwork research which consists of quantitative surveys, qualitative interviews, focus groups discussions and participatory observations.
Capacity building and empowerment workshops.
The policy outlines the ways in which CODECA safeguards the well-being and safety of all children with whom it comes in direct or indirect contact in the framework of its programming and operations.
The present document describes policies and relevant procedures that regulate the organizations’ operations, so that no harm is caused to children, regardless of gender, race, country of origin or religious belief.
A child is defined as anyone under the age of 18, in line with the UN Convention on the Rights of the Child and Cyprus Law.
Child safeguarding refers to all the actions an organization takes to keep all children they come into contact with safe – and includes the proactive measures put in place to ensure children do not come to harm as a result of any direct or indirect contact with the company. Child safeguarding encompasses the prevention of physical, sexual and emotional abuse, neglect and maltreatment of children by employees and other persons whom the company is responsible for, including contractors, business partners, visitors to premises and volunteers.
Child protection refers to actions taken to address a specific concern that a particular child is at risk of significant harm due to his or her contact with partners, products or services.
Direct contact refers to face-to-face contact with children. Examples include working directly with children to make films, attend events or participate in research. Indirect contact refers to contact with children online, through their data – including images of a child and text posted by a child – and contact via a third party.
Physical abuse, including an organization employee/representative hitting a child while at work as a means of control or punishment.
Sexual abuse, including sexual activity with a child below 18 years, irrespective of local country definitions of when a child reaches adulthood. This could include an employee / representative soliciting children for sex or a company employee downloading child sexual abuse images on their computer.
Emotional abuse or ill-treatment, including repeatedly conveying to a child that they are worthless or inadequate, such as an employee/ representative making hurtful or discriminatory statements to a child.
Neglect, which includes inadequate care or supervision. Sometimes an organization’s employment policies can unintentionally result in children being neglected, for example, inflexible working, conditions could mean that parents are not able to take their children to the doctor or older children must stay home from school to care for younger siblings.
Commercial exploitation, including employees engaging in commercial sexual exploitation of children, for example an employee/ representative facilitating sexual abuse by other adults. Commercial exploitation may also be indirect, for example in a situation where the organization is using children as unpaid promoters of sharable and viral commercial content.
Online abuse, including grooming or online bullying, exposure to inappropriate content or contact through for example online chatrooms or video games, or inadequate data protection.
3. Principles that Guide CODECA Activities
The CODECA Child Safeguarding Policy is based upon the following principles:
All children have equal rights to protection and to have their wellbeing and participation promoted.
Any activity that results or may result in any kind of harm and/or abuse of children is strictly prohibited.
All actions regarding child safeguarding must be taken in the best interest of children. This includes an understanding that in all our programmes and activities we must ensure that we respect children’s rights and do not cause harm.
The policy is mandatory for all those who work for or on behalf of CODECA, including staff 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.
All reports of concern regarding the safety and protection of a child will be taken seriously. Where necessary, appropriate steps will be taken to protect the child and to take action against the alleged perpetrator.
Child Safeguarding must be integrated in all aspects of organizational work, including recruitment, management and behaviour of staff.
4. Child Safety in Research and Capacity Building Activities
This section depicts the actions that need to be taken to ensure that safeguarding is included in research activities:
In case a research study will include the involvement of children, a child participation approach will govern the entire process.
Children will participate in research activities as active social agents rather than ‘objects of research’ and consequently their abilities and autonomy will be respected.
a child-centred research approach will be adopted, where children will participate to ta research process.
Heterogeneity of childhood will be systematically sought and will include the awareness of notion and understanding that children’s competence, independence and autonomy differ across cultures and are may likely influence the research approach.
Clear and unambiguous agreement of the child participation will be sought, after receiving child-friendly information about the research and ensuring that he/she has fully understood everything.
Information about the research purpose and objectives will be provided to members of the organizations, potential participants (children and parents) on its purpose and benefits, as well as on participants rights (there is the option of a self-report survey to measure parental understanding).
Information about the research purpose and objectives will be provided to institutions/ organizations who shall enable access to children or even participate (e.g. schools, leisure centres).
5. Acknowledgement of the Duty of Care and Other Legal Responsibilities
This section defines the specific obligations and responsibilities for all adults working with/for CODECA, including Board members, senior management, staff members, external experts or consultants and interns, regardless of their contractual relationship with the organization (full or part time, paid or unpaid).
5.1 Managing a Breach in Child Protection Policy
Management will investigate the breaches in a fair, unbiased and supportive manner by:
a. Discussing the breach with all the people concerned in, and will be advised of the process, case by case
b. Giving the representative the opportunity to provide their version of events
c. Documenting the details of the breach, including the versions of all parties and the outcome will be recorded
d. Ensuring the matters in relation to the breach are kept confidential
e. Approaching an appropriate outcome which will be decided based on evidence and discussion
f. Suspending the involved representative, until the investigation concludes, and findings have been made.
5.2 Outcome of a Breach in Child Protection Policy
Depending on the nature of the breach, outcomes may include:
a. Emphasizing the relevant element of the child protection policy and procedure
b. Providing closer supervision
c. Further education and training
d. Facilitating between those involved in the incident (where appropriate)
e. Disciplinary procedures if required
f. Reviewing current policies and procedures and developing new policies and procedures if necessary.
g. If the incident constitutes a criminal offence (in line with local and international laws), the regular legal procedure must be followed (see ‘Reporting an incident’ section).
6. Implementation Plan
To support the implementation of the policy, the organization appoints a Child Safeguarding Committee within the organization, comprised of the executive manager of the organization, one representative from the Management Office, one representative from the Project Manager Department and the Legal advisor.
The Safeguarding Committee is selected based on their high level of knowledge and expertise on relevant matters.
The designated Child Safeguarding committee is responsible for the issues below:
a. act as a focal point to receive information about child safeguarding concerns.
b. maintain the child safeguarding incident tracker (appendix 1).
c. provide consultation to organization’s members when they have concerns about child safeguarding or abuse.
d. provide an annual training to organization’s representatives about child safeguarding.
e. provide overall support to the wider implementation of policies and procedures to safeguard children.
f. assess child safeguarding risks within the organisation, including its programs and projects.
g. consult with local agencies whenever necessary and gather up to date information about service provision.
h. ensure that referral pathways for child safeguarding responses are updated.
6.2 Safe Recruitment
Child-safe recruitment and screening procedures have been put in place and are regularly reviewed and updated. All new staff will be made aware of the Child Protection Policy, as well as the standard Code of Ethics, and to sign it to indicate their commitment to abide by it.
1.1 Pre-selection procedure
a. Job posts are based on a detailed analysis of tasks and the level of contact with children (if relevant),
b. Job descriptions clearly detail the organization’s values and commitment to its Child Protection policy,
c. References are asked for all candidates which are kept in HR files and then destroyed in accordance with the applicable data protection rules.
d. All applications are checked to ensure that they are fully and properly completed,
e. All applications are considered with regard to any history of gaps or repeated job changes without clear reasoning.
f. A short list of candidates is prepared
1.2 Evaluation and selections procedure
a. Selection of potential partners/staff members/external experts/consultants etc. is based on an interview procedure in which among others candidates’ ability to work with children is assessed through focused questions,
b. All candidates must be made aware of and understand the principles of the organization’s values and policy,
c. All candidates are obliged to bring with them to interview their identity.
d. Upon the completion of the selection process and the commence of an offer, the detailed Child Safeguarding Policy is also attached which has to be agreed, signed and return back to the HR department.
1.3 Induction and training
All new staff will be made aware of the Child Protection Policy, as well as the standard Code of Ethics, and to sign it to indicate their commitment to abide by it. Introductory training session will be provided to depict CODECA policies and procedures including the Child Safeguarding policy.
The Child Safeguarding Committee ensures that all employees are being notified and receive a copy of the Child Protection Policy and that employees have a clear record from the registry of convicted sexual offenders against children (issued by the Cyprus Police, Crime Combating Department- Criminal Record Office (C.R.O) – 2009, as per the Cyprus Law against Child Sexual Exploitation and Sexual Abuse (Law No. 91(I)/2014), Article 22(6)).
6.3 Planning and Advertising
Expectations for the organizations’ commitment to child safeguarding are communicated through the job description advertisement. A link to the organization’s child safeguarding policy is included in every job advertisement.
If the job specifically involves working with children, the interview questions would be adapted and expanded to determine the candidate’s specific suitability. Along with asking about gaps in employment history, a series of relevant questions could be used to determine a candidate’s attitudes towards child safeguarding.
6.5 References and Background Checks
The background check aims to assess that the applicant has no previous record of offences against children and have not, in the past, been excluded from working with children (clear criminal record certificate[i], and clear Child sexual Abuse or pornography History Certification[ii]). It is recommended that the organization should repeat the background checks for all its representatives, at least once a year.
In addition to background checks, references can be a tool to get insight on the candidates’ former job performance regarding child safeguarding. Requiring at least two references from former employers is recommended.
7. Safe Activity Design
7.1 Parental Consent
Where children, are the target group and will be part of a program implementation phase, interviewers should obtain written consent from parents/guardian and/or relevant school/childcare authorities before beginning the implementation of the program. Guardians should be well-informed of what the implementation of the program will involve before being asked to sign this form and their consent should be given voluntarily.
7.2 Unaccompanied persons under the age of 18
Several under-age individuals who are neither accompanied by their parents nor by their legal guardian arrive every year in Cyprus. Unaccompanied individuals may apply for political asylum. Where an unaccompanied person, will be part of a program implementation phase should collaborate with social welfare services. According to the Refugees Law[iii] (2000 with its amendments until 2021), the Director of the Social Welfare Services must act as the guardian of the under-age unaccompanied person who seeks asylum in Cyprus and acts on his/her behalf.
7.3 Child information and consent
Depending on the age and competence of the children, each program implementation phase should be fully explained to them before the implementation commences. This should be explained in simple language which is appropriate to the child’s age and level of competences. A child’s right to refuse to take part in the implementation should be respected; even in the case where the parent or guardian has given their consent for the child to participate. CODECA representatives should review the Child safeguard Guidelines (appendix 5) and ensure the following measures have been put in place to ensure that the health and well-being of children, and organization members is safeguarded throughout the implementation phase.
Programs designed for children should be evidence-based and meet particularly high quality and safety requirements. Safety concerns must also be addressed for products or services that are not designed for children’s use but nonetheless present hazards to children.
7.4 Open Education Resources
Child online safety is important to the organization to prevent, respond to and resolve any potential risks to children’s safety when using the organization’s digital services, strengthening governance and accountability. CODECA ensures that online environments conform to national and international standards on child health, environmental health and safety standards[iv] by engaging in the following actions (where appropriate and needed):
a. Labelling or gating content that is not appropriate for children.
b. Putting parental controls in place and offering contextual guidance to parents and other on how to use such tools respectfully and responsibly while not inflicting a child’s right to access to information or participation.
c. Providing guidance on how to deal with abuse or misuse, such as reporting tools, ‘house rules’, the go-to employees who are trained to intervene and can provide links to external agencies (e.g., child helplines) as appropriate.
d. Guidance on dealing with child sexual abuse content or illegal content, including notice and takedown processes.
f. Offering online safety awareness guidance to parents and children.
A research activity involving a group of children requires clear scientific justification and full disclosure of the benefits and risks to children, their parents and/or guardians. The organization should ensure low risks to the child and high importance of the knowledge to be gained. Free and informed consent is required by both the legal guardian and the child if the age and maturity of the child is such that he or she can give free and informed consent.
8. Reporting an Incident
Most children who experience abuse do not ask for help, so a disclosure from a child must be approached with a heightened awareness and responsiveness. In accordance with the organization’s zero-tolerance policy and national laws (e.g., article 35A in The Violence in the Family (Prevention and Protection of Victims) Law- 212(I)/2004[v]) all organization members should be guided to report all abuse-related situations that are witnessed or suspected, including bullying, verbal abuse or insults. Any concerns that arise should always be reported, without placing the organization member in a position of deciding whether an abuse has taken place. CODECA representatives should review the General principles for reporting an incident.
9. Reporting Procedure and Complaint Mechanism
This section applies when a concern is reported that the child safeguarding policy 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 staff, partners, children and families/community members. All concerns and reports must be taken seriously. If any of them have concerns that a staff member or other associate partner has been or is at risk of being abused, exploited or harmed in any way, they must report it.
All potential, actual or suspected concerns must be reported within 24 hours. In cases of imminent danger for the safety of the child, the report must be submitted immediately.
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.
Concerns may be raised in written at the email address email@example.com to the attention of Stefanos Spaneas, Executive Director.
Reporting procedures as obliged by the relevant Cypriot Law (2014 (91(Ι)/2014) will be followed.
If someone discloses that they are being abused, then upon receiving the information he/she should,
a. React calmly.
b. Reassure that the child is not to blame and take what the claims seriously.
c. Be careful not to coerce the child and distort the claims.
d. Ask simple questions
e. Do not promise confidentiality as it involves a minor who is at a possible imminent danger.
f. Inform the child/young person about the steps that will be followed.
g. Make a full and written record of what has been said and do not procrastinate in passing on the information to the relevant authorities.
10. Communication through Media
The organization aims to take adequate security measures to protect children in all Internet-marketing venues, including social media, chat sites, blogs and web pages (e.g., do not promote harmful and unhealthy behaviors or violence). CODECA ensures that communication policy conforms to national and international standards on child health, environmental health and safety standards[vi]:
a. Children should be protected from being used and exploited as a ‘marketing technique’ to promote products of any type at schools or elsewhere.
b. Obtain written consent from parents (appendix 8) for getting pictures for work related purposes.
11. Agreements with Partners
The organization has a wide range of partners, including local NGOs, government, local authorities, and contractors. Before collaboration, the organization must make sure that there is a sound assessment of the partner’s contact with, and impact on children during the partnership and what this means for child safeguarding agreements.
12. Data Protection
The information that is collected during the above mentioned activities will only be used for research purposes. All interview data is stored in a code-protected file accessible only to persons (administrators, researchers) responsible for project management, research and quality control of findings / procedures. Pseudo-anonymization techniques will be used to save the files. Contact details will only be used for managing the research procedures. They will be stored separately they will not be transmitted to any other organisation and will be destroyed after data collection and quality control has been completed.
The Data Protection Officer (DPO) of CODECA is Mr. Agamemnon Zachariades. Any concerns may be raised in written at the email address firstname.lastname@example.org.
13. Policy Review
This Policy shall be subject to review by a multi-disciplinary group of experts (e.g., social workers, psychologists, qualified therapists, family support and lawyers) biannually in order to ensure that it is up to date with all relevant legislations.
14. Contact Details
Senior lead for safeguarding and child protection
Name: Dr. Stefanos Spaneas,
Executive Director of CODECA
We are committed to reviewing our policy and good practice annually. This policy was last reviewed on the 30th of March 2022.
Name: Dr. Stefanos Spaneas