Child Safeguarding and Protection Policy

Our programme work is varied and works across the whole career pipeline, from primary school through to employment. We run events, competitions, mentorship networks and careers guidance, these are primarily online

The purpose of this policy statement is:

• to protect children and young people who take part in Into Games programme work.
• to provide parents, staff and volunteers with the overarching principles that guide our approach to child protection.

This policy statement applies to anyone working on behalf of Into Games, including senior managers and the board of trustees, paid staff, volunteers, sessional workers, agency staff and students.

1. Our Commitment to Safeguarding

Into Games is committed to conducting its programs and operations in a manner that is safe for the children it serves and to helping protect the children with whom Into Games is in contact. All Into Games representatives are explicitly prohibited from engaging in any activity that may result in any kind of Child Abuse. Into Games policy to create and proactively maintain an environment that aims to prevent and deter any actions and omissions, whether deliberate or inadvertent, that place children at the risk of any kind of Child Abuse.

All Into Games representatives are expected to conduct themselves in a manner consistent with this commitment and obligation. Any violations of this policy will be treated as a serious infraction and will result in disciplinary action being taken, up to and including termination and any other available legal remedy. In furtherance of this Policy, Into Games has adopted procedures, described below, to promote:

1. Prevention of Child Abuse: Striving, through awareness, good practice and training, to minimize the risks to children and take positive steps to help protect children who are the subject of any concerns.
2. Reporting of Child Abuse: Ensuring that all Representatives know the steps to take and whom to contact when concerns arise regarding the safeguarding of children.
3. Responding to Child Abuse: Engaging in action that supports and protects children when concerns arise regarding their well-being; supporting those who raise such concerns; investigating, or cooperating with any subsequent investigation; and taking appropriate corrective action to prevent the recurrence of such activity.
4. Training to Promote Awareness of Child Safeguarding Obligations: Ensuring that all Representatives are adequately trained and supported in preventing, reporting and responding to safeguarding concerns; and ensuring that all Representatives are notified of and made aware of the expectation to comply with this Policy.

Into Games will take all reasonable steps to make the organisation safe as it conducts its routine operations, program implementation, policy and campaigning efforts.

2. Representatives Code of Behavior

Into Games is committed to creating a safe environment in which young people can feel comfortable and secure while engaged in any of our programme work. Personnel should at all times show respect and understanding for individual’s rights, safety and welfare, and conduct themselves in a way that reflects the ethos and principles of Into Games.

Staff and volunteers should be committed to:

• Treating children and young people with respect and dignity.
• Always listening to what a child or young person is saying.
• Valuing each child and young person.
• Recognizing the unique contribution each individual can make.
• Encouraging and praising each child or young person.

Staff and volunteers should endeavour to:

• Provide an example, which we would wish others to follow.
• Use appropriate language with children and young people and challenge any inappropriate language used by a young person or child or an adult working with young people.
• Respect a young person’s right to privacy.

Staff and volunteers should:

• Not spend time alone with children, away from others
• In the unlikely event of having to meet with an individual child or young person make every effort to keep this meeting as open as possible and if privacy is needed, ensure that other staff are informed of the meeting and its whereabouts
• Be aware that someone might misinterpret their actions no matter how well-intentioned
• Never draw any conclusions about others without checking the facts
• Never allow ourselves to be drawn into inappropriate attention-seeking situations such as tantrums or crushes
• Never exaggerate or trivialise child abuse issues or make suggestive remarks or gestures about, or to a child or young person, even in fun

Staff and volunteers should never:

• act in ways that may be abusive or place Children at risk of abuse;
• hit, physically assault or physically abuse Children or threaten to do so;
• engage in behaviors that are physically inappropriate or sexually provocative;
• engage in sexual activity or have a sexual relationship with anyone under the age of 18 years irrespective of the age of majority/consent or local custom;
• stay alone overnight with one or more Children benefiting from Into Games programmes who are not part of their family, whether in their house, project premises or elsewhere;
• have a Child beneficiary, who is not a part of their family, stay overnight at their home; sleep in the same bed as a Child beneficiary or sleep in the same room as a Child beneficiary, who is not a part of their family;
• invite Children to stay overnight in a hotel or other accommodations, domestically or internationally, with a non-relative Into Games representative;
• exchange personal contact information or ask for Children’s personal information; develop relationships with Children which could in any way be deemed exploitative or abusive;
• use language, make suggestions or offer advice to Children which is inappropriate, offensive or abusive;
• do things for Child beneficiaries of a personal nature that they can do themselves (e.g., toileting, dressing, feeding, washing, etc.); condone or participate in behavior of Children which is unsafe or illegal;

3. Social Media and Online Child Safeguarding

The majority of Into Games programmes are conducted online. We expect our representatives and partners to use the same Code of Conduct outlined above and be mindful when using personal social media accounts.

To ensure that Children are safe and represented with dignity and care, the following guidance has been developed:.

• Discussing or sharing, via Public Communication, any sensitive, confidential or internal matters concerning Children, their data or Child Safeguarding violations is strictly prohibited.
• Use of Social Media: It is not acceptable for Representatives to accept or make friend requests from/to any beneficiary who is a Child and/or has been or continues to be a recipient of services through Into Games.
• Similarly, making contact with a Child’s caretaker or guardian for purposes of connecting with a Child for reasons unrelated to Into Games is not allowed.
• Always exercise caution and professional judgment when communicating with an unknown social media request or a person you have reason to believe is under the age of 18.

Following Children via Social Media: Where profiles are often public, you may want to follow a Child due to her/his public persona or relevancy to your work. This is acceptable as long as you have undertaken due diligence to ensure that this is appropriate and in alignment with this Policy and the Code of Conduct.

Communicating with Children: If part or all of your work includes communicating with Children, this must be done via professional channels such as your work email address or an official social media account. Personal social media should never be used to conduct work activities, especially as it relates to communications with Children. If you have had an occasion to communicate with a Child through anything other than an Into Games account, your line manager must be informed and alternative means of communication arranged.

Public Profile: If your social media are in public settings, always remember that any content you generate can be viewed by anyone, including Children.

Child Beneficiary Sends a Social Media Request: If a Child contacts you or sends a social media request to your personal account, consult with your line manager for guidance and direction on how to proceed.

Posts and Blogging: If your social media or blogs are public and accessible to Children, specifically beneficiaries through Into Games, you should be cautious with the information that you are sharing about yourself and loved ones, including images of your friends, family and Children (whether a beneficiary or not), and exercise caution and good judgment when posting pictures or videos of Children.

If your blog is public and content contained therein refers to work that is performed on behalf or because of your association with Into Games, you are responsible for adhering to this Policy. Photos, video, artwork or stories of beneficiary Children that have not been obtained with proper consent and for purposes of Into Games business cannot be used for personal accounts without permission from Media and Communications.

Online Video streaming When broadcasting over the Internet, it’s easy for young people to feel safe due to physical boundaries and this itself leads to increased vulnerability. People may attempt to trick, blackmail or coerce children during a time when their typical defences are down, and this may lead to riskier behaviour. In cases of online grooming, predators have targeted children and used trickery and grooming techniques to get them to perform acts of a sexual nature in front of the camera. This is classified as a ‘non-contact’ abuse offence but is still sexual abuse.

• Video streaming should never be 1-2-1
• Careers should be aware of stream taking place and if under 16 be supervising children whenever they are using Zoom
• All meetings must be password protected
• if you’re hosting a public meeting ensure only the host can share their screen by turning on the function when setting up the call
• ensure the waiting room feature is on at all times and only let in people you know
• do not share meeting details or passwords publicly or on social media, including in ‘closed’ groups, and only share them privately with attendees you know and trust
• familiarise yourself with the security icon in the menu bar so you know how to lock the meeting, use the waiting room and remove participants

Photos and Videos After approval, any photo, video, artwork or story referring to Children in Into Games programs must adhere to these guidelines:

If you see any inappropriate or indecent content, communication, images or video of Children online, please report this immediately to the social media’s reporting system.

If you believe that any inappropriate or indecent content is connected to or implies a connection to Into Games, you must immediately report this to your direct manager or National Director of Child Safeguarding within one (1) business day.

All Representatives are required to report any suspected or known social media violations in the same manner as any other Child Safeguarding Policy violation. You are not expected to provide evidence or proof but any that you may have should be included in your report. You are not to investigate the concern; however, you may take whatever action is necessary to ensure the safety of Children involved.

4. Data Protection

We comply with all the requirements of the GDPR, not just those specifically relating to children in the following list;

• We design our processing with children in mind from the outset and use data protection by design and by default approach.
• We make sure that our processing is fair and complies with the data protection principles.
• As a matter of good practice, we use DPIAs to help us assess and mitigate the risks to children.
• If our processing is likely to result in a high risk to the rights and freedom of children then we always do a DPIA.
• As a matter of good practice, we take children’s views into account when designing our processing.
• When relying on consent, we make sure that the child understands what they are consenting to, and we do not exploit any imbalance of power in the relationship between us.
• When relying on ‘necessary for the performance of a contract’, we consider the child’s competence to understand what they are agreeing to, and to enter into a contract.
• When relying upon ‘legitimate interests’, we take responsibility for identifying the risks and consequences of the processing and put age-appropriate safeguards in place.
• When considering targeting marketing at children we take into account their reduced ability to recognise and critically assess the purposes behind the processing and the potential consequences of providing their personal data.
• We take into account sector-specific guidance on marketing, such as that issued by the Advertising Standards Authority, to make sure that children’s personal data is not used in a way that might lead to their exploitation.
• We stop processing a child’s personal data for the purposes of direct marketing if they ask us to.
• We comply with the direct marketing requirements of the Privacy and Electronic Communications Regulations (PECR)

5. Child Participation and Inclusion

To promote the safety, inclusion and equitable participation of all children irrespective of their abilities, racial heritage, tribal affiliations, religious beliefs, languages, gender or gender association, LGBTI+ identity and/or medical/physical conditions, all programs and activities shall be assessed to ensure consideration of such factors from its inception through delivery. The aforementioned factors are not an exhaustive list. These aspects must be included in the Monitoring and Evaluation frameworks for such activities.

Children with Different Abilities or Disabilities

Children with different abilities or disabilities are at an increased risk of abuse. Where children with special needs benefit from our programs, we must make all necessary accommodations to ensure their inclusion and safety. To promote the best delivery of services to children with different abilities or disabilities, please: Consult with the child to better understand his/her needs. Consult with parents/caretakers to better understand the needs of the child, as well as any limitations to activities offered. Be aware of attitudes that the child, his/her family, the community and other children in the program/activity may have towards the child with special needs and encourage inclusion and participation to the full extent possible. Programs and activities shall be designed to be inclusive and mindful of children with unique or special needs. For children whose different abilities or disabilities may not be visible or patent, staff shall make reasonable efforts to adjust program activities to promote inclusion and offer alternative activities in which all children can join. The validity of a special need must never be questioned or dismissed.

6. Partnerships

All agreements with Partners must include the requirements of this Policy, including a provision in which the Partner agrees to comply with this Policy (subject to the Exception Approval Procedure contained herein).

All partner agreements must include language about the proper vetting of employees, including criminal background checks and sexual offender registry search, and ensure that any processes for “clearing” a discrepancy does not place any Child or vulnerable adult at risk of harm or injury. All Partners are responsible for reporting any suspected or known violations of this Policy as outlined above. All Partners will conduct a Risk Assessment to ensure programming is safe for children. Partners will ensure its staff members have been vetted via safe recruiting practices. Partners receiving funds from donors with relevant requirements must comply with those child safeguarding requirements.

7. Responding to Child Safeguarding

Into Games has an appointed Senior Lead for Safeguarding and Child Protection. Their responsibilities include:

• Being the first point of contact for Child Safeguarding concerns raised by members of staff and other Into Games representatives;
• Liaise with the team on employee-related Child Safeguarding issues prior to initiation of any action or inquiry into the incident at the local level;
• Support staff during the investigation process;
• Provide basic advice & guidance on Child Safeguarding concerns;
• Conduct and/or facilitate staff training on Child Safeguarding
• Provide consultation on child welfare issues by helping members of staff to identify issues of abuse and neglect and how to report to the local authorities; and
• Ensure that suspected or known Child Safeguarding violations are reported

Contact details

Senior lead for safeguarding and child protection

Name: Declan Cassidy

Role: CEO

Email: declan@intogames.org

8. Investigation of incidents

Into Games takes every allegation of a violation of our Child Safeguarding Policy seriously. The Senior lead for safeguarding and Child protection is responsible to ensure all credible allegations are investigated, logged and tracked in the reporting database.

In addition, they, with the board of trustees are accountable for conducting investigations, interviewing all involved Into Games personnel and making recommendations that will inform the necessary corrective actions and/or remedial measures.

During the investigation process, reasonable efforts should be made to contact the caretaker of the Child(ren) identified in the report or known to be put at risk of or actually harmed within our programs. Whenever possible, the Child(ren) should be interviewed and such interviews conducted by a skilled and trained child interviewer.

Representatives covered by this policy must cooperate fully with any investigation or inquiry by Into Games and preserve all records relating to any alleged violation of this Child Safeguarding Policy. Although we cannot guarantee confidentiality, the reported concerns will remain confidential to the extent possible.

1. Initial Assessment: Upon receipt of a report, an initial screening will be conducted by the National Director of Child Safeguarding. A full account of the matter, any immediate personnel action and all documentation will be recorded in EthicsPoint/NavEx.
2. The designated personnel with investigative capacity will develop a Terms of Reference for the internal investigation and conduct it in accordance with the Investigation Workflow Process.
3. Reporting to Applicable Authorities: referrals must be made to regional Child Protective Services or the police as soon as possible, but no later than 24 hours of the incident. In addition, the relevant authorities in that location must be informed so that the appropriate response can be launched in accordance with local procedures. Irrespective of the local outcome or response, Into Games staff must report (verbally and in writing) to a senior staff member at the organization/project where they are working or via the established reporting system.

9. Documentation

All individuals with documents pertaining to an investigation will ensure that such documents are preserved and have been provided to the Senior Lead for Safeguarding and Child Protection.

Representatives must not forward any sensitive information to personal email accounts or add non-Into Games email accounts to emails containing information about possible Child Safeguarding violations, Child Data or personnel information.

Any documents shared with external parties or stakeholders must be approved by the General Counsel via the National Director of Child Safeguarding. All conversations pertaining to the investigation will be properly documented and provided to the lead internal investigator or National Director of Child Safeguarding.

A final report will be completed for all incidents that have been investigated. Reports shall include the findings and Child Safeguarding recommendations (e.g., processes, procedures and/or personnel actions) for Human Resources review and determine corrective or personnel actions.