Adopted by EDF executive committee March 2019
The European Disability Forum is an independent organisation of persons with disabilities that defends the interests of more than 80 million Europeans with disabilities. We are a unique platform that brings together representative organisations of persons with disabilities from across Europe. We are run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.
EDF works with a range of partners including government, civil society actors and the private sector.
Our principles and working methods are guided by the UN Convention on the Rights of Persons with Disabilities.
This Safeguarding Policy complements other EDF policies which are applicable in all our working settings, including our Harassment Policy and our Guidelines for Accessible Meetings and events.
The Executive Committee has overall responsibility for Safeguarding. The day to day management of Safeguarding is delegated to the Director, replaced by the HR manager as needed.
EDF has established this policy in view of our growing involvement in projects which include grass roots activities. We would like to thank Sightsavers, our partner in one such project which shared its policy which we have assessed, learned from and adopted to EDF reality.
What is safeguarding?
Safeguarding means promoting and protecting people’s health, wellbeing and human rights, and enabling them to live free from harm, exploitation and abuse. A safeguarding approach means identifying and minimising the risk of harm to children and adults at risk from staff, representatives and partners through EDFs activities and includes responding appropriately to any safeguarding concerns about children and women and men at risk within communities where we work. It entails a wide potential range of policies, procedures and activities seeking to address child and adult safety and wellbeing.
In EDF’s case, a safeguarding approach means minimising the risk of harm, exploitation or abuse of children and adults from staff, or programme activities. It includes reporting any safeguarding concerns about a child or adult within settings where we work to the appropriate authorities.
It is known that children and adults with disabilities may be at particular risk of harm, exploitation and abuse. This policy recognises that these specific risks are best addressed through a broader (twin-track) safeguarding approach with specific actions focused on children and adults with disabilities who are at risk where relevant.
Target groups of the policy
The Safeguarding Policy is to be applied across all EDF; all EDF staff and everyone that represents EDF, including our partners should be aware of, and adhere to, the policy.
It is recognised that, for government partners, national policy and legal frameworks take precedence.
Purpose and commitment
The purpose of this policy is to ensure that EDF activities are implemented in a safe and protective environment where rights and autonomy are promoted and harm, exploitation and abuse are effectively prevented, and responded to effectively.
The policy has three specific objectives:
- Keeping children and adults safe;
- Ensuring the highest standards of behaviour from representatives and minimising the risk of abusers entering the organisation
- Safeguarding the reputation of EDF, including guarding EDF’s representatives from false allegations or from operating within an unclear framework;
EDF is committed to taking all necessary measures to ensure the safety of all children and adults involved.
In any activities involving children, the primary consideration should be given to children’s rights, following the four key principles of the UN Convention on the Rights of the Child (CRC), namely, the “best interest” of the child, the child’s right to life and development, the child’s right to be heard/participate, and the child’s right to non-discrimination.
In all activities involving adults who are at additional risk because of disability, age , gender or other circumstances and/or status, EDF will be guided by the human rights principles of respect for dignity, autonomy, independence, choice, non-discrimination and equality.
Principles of safeguarding
EDF is committed to key principles that should underpin all safeguarding functions. These principles are relevant for both child and adult safeguarding.
- Empowerment. People being encouraged and supported to make their own decisions and give informed consent, including through supported decision-making mechanisms. An enabling approach to risk assessment is used which promotes autonomy.
- Prevention. It is better to take action before harm occurs.
- Proportionality. The least intrusive response appropriate to the risk presented.
- Partnership. Local solutions through services working with their communities. Communities have a part to play in preventing, detecting, and reporting neglect and abuse.
- Accountability. Accountability and transparency in delivering safeguarding.
Children and adults with disabilities
Recent research on child protection and disability has found that children with disabilities experience far higher levels of abuse than their peers. Girls and boys with disabilities are vulnerable to many forms of abuse but most at risk are children with intellectual disabilities and those who have difficulties to communicate. Emotional and sexual abuse are mostly reported by girls with disabilities, but boys with disabilities are also targeted.
Negative cultural norms around disability contribute to putting persons with disabilities at risk of violence and abuse, including factors such as stereotyping, prejudice, discrimination, institutionalisation, isolation, difficulty in protecting oneself or inadequately understanding and/or communicating that abuse has occurred.
EDF commits to communicating this policy throughout the organisation, to partners and, where relevant, to children themselves, their parents and others in programme activities; as part of a broader programme to challenge stereotypes and cultural norms around disability, particularly with regards to children’s potential and rights.
Measures to implement the policy
The safeguarding policy requires the following steps for its implementation.
- Prevention measures including awareness-raising, training of relevant staff and other EDF representatives, risk analysis, recruitment procedures, induction of staff in the policy, codes of conduct for EDF’s representatives, and incorporation of the policy into relevant existing systems including in project meetings with partners when projects are being initiated.
- Reporting and responding measures including steps for alerting and reporting safeguarding concerns, investigation and incident management, duties and responsibilities of assigned managers.
- Implementing and maintaining the policy, including training and capacity building of staff and partners, monitoring, reporting and review of the policy.
All recruitment of staff will include an induction including the safeguarding policy and code of conduct, including procedures to follow should any safeguarding concern arise.
When recruiting staff, EDF will make sure that questions regarding safeguarding are included in any relevant job interviews. Where possible, references should be sought from previous employers to get more information of the suitability of candidates.
All EDF representatives will be required to acknowledge receipt of and compliance to the Safeguarding Policy prior to their employment.
EDF will designate staff with the responsibility of building internal awareness and supporting relevant capacity development of the organisation in safeguarding. All EDF representatives and partner organisations will be duly notified of the Safeguarding Policy and be made aware of how they will be expected to comply with it. It will be the responsibility of all EDF staff to share the policy and approach as relevant to external stakeholders, in particular, project partners.
EDF will ensure all supporters, donors, sponsors, and media representatives involved with EDF’s work have access to the Safeguarding Policy through its website and will take appropriate steps to communicate that availability.
When working with partners, EDF will endeavour to ensure that the programmes it supports are safe for the adults and children they serve. To ensure that the appropriate safeguarding measures have been put in place, EDF will work with the partner, either during the project development process, or the inception phase, to carry out a safeguarding risk analysis which specifically includes any safeguarding issues and propose actions to mitigate these risks, prior to the activities taking place.
Such risk analysis will be an integral part of project proposals, programme planning guidelines, and partnership assessment tools.
Code of Conduct
All EDF representatives are required to understand their responsibility to keep adults and children safe and to sign and abide by the EDF Code of Conduct (Annex 1), which lists acceptable and unacceptable behaviour, primarily designed to safeguard others. It also serves to guard the name and reputation of EDF and its representatives from false accusations. All staff are responsible for encouraging and promoting the implementation of the Code of Conduct.
The adherence to this code is mandatory for all EDF representatives. Any violation of the Code of Conduct will result in disciplinary procedures in addition to any relevant legal action. To give maximum protection to beneficiaries, the organisation and staff, the Code of Conduct is to be applied both within and outside of working hours.
Reporting and responding to incidents
EDF will ensure that reporting and incident management procedures to handle safeguarding concerns are in place and effectively used to enable an appropriate and swift investigation of any given case. EDF representatives should be properly informed of the reporting and incident management procedures. Any EDF representative who has a concern or suspicion regarding harm, exploitation, or abuse by someone representing another agency must report such concerns to the Manager.
All reports and the information herein will be handled with the strictest confidentiality to protect the identity of the individuals concerned, the informer and the suspect, both appropriately and in accordance with relevant national legislation.
Procedures to be followed in the case of an incident
Agreed procedures to be followed are included in Annex 2.
Consequences of harm, exploitation, or abuse
Any behaviour towards children or adults, which results in harm, exploitation or abuse, or the failure to follow the general requirements and specific code of conduct of this policy, is grounds for the following measures:
- If an employee has been under investigation by EDF or by official law enforcement authorities for any area of harm, exploitation or abuse as defined under this policy, they will be subject to employee disciplinary procedures. Under these procedures, they may be temporarily suspended during the investigation. If an employee is dismissed for proven harm, exploitation or abuse, EDF will inform the relevant authorities, disclose this to prospective future employers and/or refuse a reference, depending on details.
- Appropriate action will be taken up to and including immediate termination of a partnership or service agreement. In this case, the short or long-term impact on beneficiaries of the termination of a partnership will be considered.
EDF is committed to adhering to ethical guiding principles on communications to minimise the risks of people misusing photographs and related information beyond the agreed purpose and consent. The best interests of the featured adult or child are to be safeguarded as a primary consideration. To this effect, EDF representatives and partners will abide by the following guidelines.
- Ensure all interviews and images of adults and children are undertaken with sensitivity to safeguard the individual’s rights to dignity, identity, confidentiality, and privacy. Where possible, individuals should be prepared for interviews prior to being interviewed. In the case of children, a parent or guardian should be present during interviews, where appropriate, or their permission sought beforehand for a professional adult with agreed responsibility (such as medical or educational professionals) to be present on their behalf.
- Pictures of adults and children should be decent and respectful and should not stigmatise the community, family or the individual. All children, both girls, and boys, should wear decent clothing appropriate to the local custom.
- Prior consent to use information collected in interviews and/or images of adults and children should be obtained from the individual themselves (if they possess the maturity to do so), and in the case of children, consent must also be obtained from their parents and/or guardians (permission form in annex 5). To help keep adults and children safe, consideration should be given to how much information is published.
- EDF and its partners are committed to guarding carefully any information about adults and children who feature in their publications, ensuring that their personal data are used appropriately.
- Pictures, materials and personal information regarding individuals will be held in a secure database and according to the appropriate EDF data security protocols. The misuse of images accessed will be treated in the same way as other breaches of this policy. Applicable data protection laws for all stored images will be followed.