Child Safeguarding Policy
Reviewed and Updated: March 2021
A. Policy Statement
ISI Dublin welcomes both Adult (over 18) and Non-adult ( U18 ) Overseas Students throughout the year to our two Dublin Centres located at 4 Meetinghouse Lane and 39 Parnell Square. ISI Dublin also welcomes Students aged 12-17 to its Junior Summer Centre in Belvedere College from June to August. In addition to these Schools, ISI Dublin runs an external programme, called High School or HSP, placing Overseas Students into Secondary Schools and Homestays throughout Dublin and Ireland. We recognise that we have a fundamental Duty of Care for all of these Students as they are living away from home and without their normal support networks. We also recognise the additional Duty of Care for all Students who are under 18. This Safeguarding Policy represents our belief that it is always unacceptable for a Child or Young Person to experience abuse of any kind and it is the responsibility of all adults in contact with young people to safeguard their welfare. It is our intention to comply with national policy, current legislation and guidance. Our Guiding Principles to safeguard Children and Young Persons under our care will be communicated to all our Employees, Volunteers, Children, Young People and Service Providers.
We believe that:
- Our priority to ensure the Welfare and Safety of every Child and Young Person who attends our service is paramount.
- Our Guiding Principles and Procedures to safeguard Children and Young People reflect National Policy and Legislation and we will review our Guiding Principles and Child Safeguarding Procedures every two years or more often where consider3ed necessary or required by law.
- All Children and Young People have an equal right to attend a service that respects them as individuals and encourages them to reach their potential, regardless of their background.
- We are committed to upholding the rights of every Child and Young Person who attends our service, including the rights to be kept safe and protected from harm, listened to and heard.
- Our Guiding Principles apply to everyone in our Organisation.
- Workers / Volunteers must conduct themselves in a way that reflects the Principles of our Organisation.
- Safeguarding: Safeguarding is the action that is taken to promote the welfare of children and protect them from harm.
- Child Protection: Protecting children from abuse
- Abuse: all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power.
- Adults: Refers to all adults who are working with the children (including Group Leaders and Homestay Hosts).
- Named Person: Person who will be responsible for ensuring the work gets done.
- Designated Liaison Person: On-site Member of Staff responsible for day to day Child Welfare concerns and with overall responsibility for Child Protection and Safeguarding issues in ISI.
- Mandated Person: Person who has a statutory obligation to report concerns that meet or exceed a particular threshold and to cooperate with Tusla in the assessment of mandated reports, where requested to do so.
- Child / Under 18s (U18): Any individual who has not yet reached their 18th birthday, irrespective of the age of the majority in their home country.
A3) U18s’ entitlement
We recognise that :
- The welfare of the Child / Young Person is paramount;
- All children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse;
- Working in partnership with Children, Young People, their Parents / Guardians, Homestay Providers, Agencies, Leaders and Teachers are essential in promoting Young People’s welfare.
A4) Adults’ Responsibilities
This Policy & Guidelines apply to all ISI Dublin Staff including directly employed Staff, Homestay Hosts, Accommodation and Transport Providers, Volunteers, Interns and anyone working on behalf of ISI Dublin. All adults are expected to read and abide by the Policy, Guidelines and Procedures set out in this document.
A5) The purpose of the policy:
- To promote best practice in Child Protection in all ISI Centres and to set out a Procedural Framework for adherence by all Staff Members.
- To provide protection for Persons under the age of 18 (U18s) who receive ISI Dublin’s services.
- To provide Staff with guidance on the Procedures they should adopt if they suspect a Child or Young Person availing of the services of ISI Dublin may be experiencing, or be at risk of harm.
We seek to safeguard U18s by:
- Valuing them, listening to and respecting them ;
- Adopting Child Protection Guidelines through Procedures and a Code of Conduct for all Adults, Recruiting Staff and Homestay Providers safely, ensuring all necessary checks are made;
- Sharing information about Child Protection and Good Practice with U18s, their Parents / Guardians and all Adults sharing information about concerns with relevant Agencies and involving Parents and U18s appropriately;
- Providing effective management measures for all Adults through Recruitment Policies, Supervision, Support and Training.
- Ensuring contact with Students of all ages will be appropriate and professional at all times.
- Treating all students equally.
- Treating all students with respect and dignity.
A6) Policy Review
We ensure that this Policy is communicated and understood and that there are sufficient resources available for its implementation.
Our Policy, Guidelines and Procedures are reviewed annually by the Designated Liaison Person (DLP) and reported to and signed off by the Director of Schools.
A7) Roles and Responsibilities
Responsibilities for the implementation of this Policy are as follows :
- U18s: Responsible for understanding the Policy, looking out for each other and raising any concerns with Adults if necessary.
- Adults: Responsible for understanding the Policy and pro-actively engaging with its requirements.
- Designated Liaison Person: In ISI Dublin there is are two Designated Liaison Persons whose role is to oversee the Standards and Practices across the Group. The DLP’s are also responsible for the implementation of the Policies and Procedures and the implementation of all Procedures as laid out in this document. The DLP’s will liaise with statutory agencies responsible for child protection and welfare and will be the resource person to any worker or volunteer who has child protection concerns. Contact details are made known to all Staff.
The DLP / Deputy DLP will :
- Be fully familiar with the Organisation’s Duties in relation to the safeguarding of children.
- Have a good knowledge of the Organisation’s Guiding Principles and Child Safeguarding Procedures.
- Ensure that the Organisation’s reporting Procedure is followed, so that Child Protection & welfare concerns are referred promptly to TUSLA.
- Receive child protection & welfare concerns from Workers & Volunteers and consider if reasonable grounds for reporting to TUSLA exist.
- Consult informally with a TUSLA Duty Social Worker, if necessary.
- Where appropriate, make a formal report of a child protection or welfare concern to TUSLA on behalf of the Organisation, using the Child Protection & Welfare Report Form.
- Inform the Child’s Parents / Guardians that a Report is to be submitted to TUSLA or An Garda Siochana, unless :
Informing the Parents / Guardians is likely to endanger the Child or Young Person.
Informing the Parents / Guardians may place the DLP as the reporter at risk of harm from the family.
The family’s knowledge of the Report could impair TUSLA’s ability to carry out an Assessment.
- Record all concerns or allegations of Child abuse brought to the attention of the DLP as well as any action/inaction taken in response to these concerns.
- Provide feedback to the Referrer, as appropriate.
- Ensure that a secure system is in place to manage confidential records.
- Act as Liaison with TUSLA & An Garda Siochana, as appropriate.
- Where requested, jointly report with a Mandated Person.
A Deputy DLP may be appointed by ISI Dublin to whom responsibility may be delegated in the event of the appointed DLP being unavailable for any reason.
The Mandated Person will :
- Report any concerns that meet or exceed the threshold for reporting under the legislation. If reporting independent of the Organisation’s DLP, the Mandated Person should inform the DLP that a report under the Children First Act 2015 has been made.
- The statutory obligation of a Mandated Person to report under the Children First Act 2015 MUST be discharged by the Mandated Person and cannot be discharged by the DLP on their behalf.
- The Mandated Person can make a joint report with the DLP or another person, mandated or otherwise.
- Where the Mandated Person has a concern that they believe does not reach the threshold for a mandated report, they should consider whether the concern meets reasonable grounds for concern. If the Mandated Person thinks the concern does meet reasonable grounds for concern, it should be reported to the DLP. The Mandated Person retains the right to report independently, should the DLP choose not to report the concern.
A8) Policy Availability & Formats
ISI Dublin’s Safeguarding Policy is available in all our Centres, on a shared Server Drive, and in Staff Manuals. It is provided to Staff with their Contract and included in Application Packs for Host Families, and is published on our website.
B) Code of Conduct
ISI Dublin recognises the importance of creating a Safe School Culture where trust is built between Staff and U18s and both are protected from any behaviour which runs contrary to this Culture. We achieve this through adherence to the policies laid out in this Document and a genuine environment of care fostered by robust Procedures, Recruitment and Training activities.
All Staff at ISI Dublin will:
- Act in a professional manner at all times.
- Act as a role model for all Students.
- Prioritise the safety & welfare of the Students at all times.
- Strive to ensure that the Students experience is a happy one.
B2) Setting standards
The key elements of our code of conduct are Interaction; Appearance; Intoxicants ( Drink & Drugs ); IT and Social Networks; Accommodation and Transport. We expect all adults working on behalf of ISI Dublin to provide an excellent role model for all students in their care and to cultivate a respectful, safe and secure environment for Staff and Students.
B3) Interaction, Accommodation & Transport
- Maintain professional physical and relationship boundaries and act in a way appropriate to your Duty of Care.
- Do not make suggestive or inappropriate remarks to or about any adult or U18. Inappropriate remarks include innuendo, swearing and discussing their or your own intimate relationships.
- Do not engage in behaviour that may be construed as ‘grooming’ a U18 for example giving money, presents or favours or talking or behaving in an inappropriate or unprofessional manner.
- Insofar as is possible, avoid situations where you are alone with a U18. If you are required to be in a one-to-one setting with a U18, consider how this can be managed effectively i.e. leaving a door open, using a room that has a glass wall, positioning yourself within sight of the door and considering if the one-to-one setting is really necessary.
- In the case of Drivers, U18s should be seated in the rear of the car, and there should be no detours or unnecessary stops on the journey.
- All Drivers should adhere to the Code of Conduct as ISI Dublin Staff Members.
- All Transport Vehicles used by ISI Dublin will provide confirmation that the vehicles are safe to use as per RSA & HSA Checklist.
- Conduct all interactions in a calm manner and avoid shouting at U18s wherever this is possible unless there is a Health and Safety risk.
- Ensure physical contact is within clear boundaries to avoid any allegations of inappropriate touching.
- Do not socialise with U18 Students outside of School organised events.
- Those providing Accommodation should also note the following :
Abide by the Accommodation Rules and Guidelines as provided in Accommodation Guidelines. Do not enter the Student’s bedroom or bathroom when the Student is present, without first gaining the Student’s permission, i.e. knock on the door. If there is a need to search the Student’s bedroom or property this must be carried out with the Student present and with their permission.
B4) Alcohol, Drugs and Smoking
- Do not consume, or allow U18s to consume any alcohol, drugs, cigarettes or intoxicating substances on School premises. Any violation will lead to disciplinary procedures and may result in the termination of employment with ISI Dublin.
- Do not provide alcohol, drugs, cigarettes or intoxicating substances to U18s.
- Do not work under the influence of alcohol or any intoxicants or drugs.
B5) IT and Social Networks
- Do not share your personal social media details with any U18s.
- Do not produce or share any images or videos of U18s on your personal recording equipment.
- Ensure correct Parental / Guardian permission has been obtained, if producing any images or videos of U18s on school recording equipment, which is to be used for marketing or educational purposes.
C) Child Protection
We meet our child protection responsibilities by:
- Creating policies and procedures to comply with all regulatory requirements and Guidelines;
- Reviewing these policies and procedures annually;
- Training all Staff to an appropriate level of awareness and procedural competence with periodic review;
- Communicating of Child Protection Guidelines with all our contracted Partners (Host Families & Drivers);
- Ensuring that all our Staff, Host Families and Drivers are Garda vetted.
C2) Nominated / Designated Person
ISI Dublin’s Designated Liaison Person (DLP) is Sarah Robinson (email@example.com), and in her absence, the Deputy Designated Liaison Person is Karen Finn (firstname.lastname@example.org).
C3) How to respond to concerns
Scenarios that may cause an Adult to have safeguarding concerns about an U18 are as follows :
- An U18 tells an Adult they are worried about the safety of another U18.
- An U18 tells an Adult about a safety issue that concerns themselves.
- A Third Party reports a safety issue to ISI Dublin, concerning a U18 in ISI’s care.
- An Adult witnesses behaviours of another Adult which cause concern.
- An Adult witnesses U18 non-verbal indications of safeguarding concerns.
In the event of any one of the above Adults should :
- Report immediately to the DLP;
- Explain their concerns and the reasons behind them;
- The DLP will advise on the next step.
C4) Recognising Symptoms of Abuse
Child abuse is any form of physical, emotional or sexual mistreatment or lack of care that leads to injury or harm. It commonly occurs within a relationship of trust or responsibility and is an abuse of power or a breach of trust. Abuse can happen to a child regardless of their age, gender, race or ability. Abusers can be adults (male or female) and other young people and are usually known to and trusted by the child and family. It must be stressed that none of these Indicators either singly or in any combination proves conclusively that a Child has been abused. Detection of Abuse is seldom straightforward and clear cut. It is important therefore to share concerns with the DLP.
There are four main types/indicators of child abuse: Physical Abuse, Sexual Abuse, Emotional Abuse, Neglect and Bullying.
The Abuser may be a stranger, a family member, a friend, a neighbour or they may be someone the child encounters through their programme with ISI, for example :
- At the Homestay.
- At the Secondary School.
- At ISI English classes.
- At an ISI leisure activity.
An individual may abuse or neglect a child directly or may be responsible for abuse because they fail to prevent another person from harming that child.
There is no textbook list of signs and signals. Being alert to abuse means:
- Thinking about what you are seeing and asking if it is acceptable practice;
- Taking seriously what you are told;
- Responding to the stresses behind requests for help or other presenting problems;
- Being alert to signals or non-verbal communication or challenging behaviour, and aware that this could indicate unacceptable practice is being deliberately hidden or denied; and,
- Reporting any doubts to the DLP.
Some Signs & Symptoms of Abuse :
a. Physical Abuse
- Unexplained bruising, marks or injuries on any part of the body
- Multiple bruises – in clusters, often on the upper arm, outside of the thigh
- Cigarette burns
- Human bite marks
- Broken bones
- Scalds, with upward splash marks
- Multiple burns with a clearly demarcated edge
- Aggressive behaviour or severe temper outbursts
- Flinching when approached or touched
- Reluctance to get changed, for example in hot weather
- Withdrawn behaviour
b. Sexual Abuse.
- Pain or itching in the genital area
- Bruising or bleeding near the genital area
- Sexually transmitted disease
- Vaginal discharge or infection
- Stomach pains
- Discomfort when walking or sitting down
- Sudden or unexplained changes in behaviour e.g. becoming aggressive or withdrawn
- Fear of being left with a specific person or group of people
- Having nightmares
- Sexual knowledge which is beyond their age, or developmental level
- Sexual drawings or language
- Eating problems such as overeating or anorexia
- Self-harm or mutilation, sometimes leading to suicide attempts
- Saying they have secrets they cannot tell anyone about
- Substance or drug abuse
- Acting in a sexually explicit way towards adults
c. Emotional Abuse.
- Neurotic behaviour e.g. sucking, hair twisting, rocking
- Being unable to play
- Fear of making mistakes
- Sudden speech disorders
- Fear of parent being approached regarding their behaviour
- Developmental delay in terms of emotional progress
- Constant hunger, sometimes stealing food from other children
- Constantly dirty or “smelly”
- Loss of weight, or being constantly underweight
- Inappropriate clothing for the conditions
- Complaining of being tired all the time
- Not requesting medical assistance
- Having a few friends
- Mentioning being left alone or unsupervised
Bullying is not always easy to recognise as it can take a number of forms. A child may encounter bullying attacks that are:
- Physical: pushing, kicking, hitting, pinching and other forms of violence or threats
- Verbal: name-calling, sarcasm, spreading rumours, persistent teasing
- Emotional: excluding, tormenting, ridiculing, humiliating.
Persistent bullying can result in:
- Low self-esteem
- Poor academic achievement
- Threatened or attempted suicide
Signs that a child may be being bullied can be:
- Torn clothes
- Asking for stolen possessions to be replaced
- Falling out with previously good friends
- Being moody and bad-tempered
- Sleep problems
- Becoming quiet and withdrawn
5) How to respond to a child or young adult telling you about abuse
- When someone talks to you about alleged abuse remember you are not investigating the situation, you are just listening.
- If a child discloses abuse, remember that this may be the beginning of a legal process, as well as of a process of recovery for the child. Legal action against a perpetrator can be seriously damaged by any suggestion that the child’s words have been influenced in any way by the person they told.
- The following guidance should be followed as far as possible:
- Rather than directly questioning the child, just listen and be supportive.
- Never stop a child who is freely recalling significant events, but don’t push the child to tell you more than they wish.
- Do not promise to keep the information a secret. Rather you must inform the child that you will have to share this with the person responsible for their safety.
- Write an account of the conversation immediately afterwards, as close to verbatim as possible. Make a note of what they actually said, using his or her own words and phrases.
- Describe the circumstance in which the disclosure came about.
- Where physical harm is being reported use a body map to indicate the location of cuts, bruises and abrasions, noting the colour of any bruising.
- Hand your record to the DLP, who will contact the local children’s social care office where appropriate.
C6) Keeping Records
- All serious concerns communicated to the DLP will be responded to on the same day.
- All information regarding allegations of abuse or safeguarding concerns is recorded in writing first, where possible, by the Adult who has received the information and then by the DLP.
- Details of allegations that are found to have been malicious should be removed from personnel records.
C7) If an U18 student or Adult Student is accused
The DLP will work with the Appropriate Social Work Department for advice on appropriate actions to take to ensure the safety of the Child.
D1) Responsibility for Training, and
D2) How Training is delivered
The DLP has overall responsibility for ensuring all Adults have appropriate training and that this is updated annually.
ISI Dublin conducts Children First, Child Protection Training through Barnardo’s.
Additional sessions will be organised where deemed necessary.
E) Safer Recruitment
Every Adult who is recruited by the School (including Homestay Hosts and Drivers) undergoes a process of suitability checking for work with U18s as appropriate to their role and status both through Documentation Check and the Interview and Selection Process.
E2) Recruitment stages for all
In all Recruitment Interviews for roles with substantial access to U18s there are questions exploring the Applicant’s awareness of safeguarding. For example: ‘Safeguarding is key to everything we do. What do you understand by this term, and can you give examples of how your role can contribute?’
References are always followed up for new Staff Members.
All ISI Staff must have up to date Garda Clearance.
E3) Recruitment of Homestays and Transport Providers
Homestay Hosts will agree to ISI Dublin’s Policies and Procedures. The main Host, who will always be present overnight when hosting under 18s, will complete the Garda Vetting Process for everyone in the home aged 16 and over. Parental consent is given for members of the household aged between 16 and 18 to be Garda Vetted
F) Welfare / Implementing Safeguarding
F1) Welfare provision
We provide general care for our U18s through the following means:
- 24-hour Emergency Phone Number is given to all Students, Parents and Agents
- Safeguarding Policy read and understood by all Staff and contracted Partners (Host Families and Drivers). Receiving Persons should sign to indicate having read and understood the Policy.
- Constant Safeguarding Review and Training Updates
F2) U18 Behaviour and discipline
ISI Dublin insists on appropriate behaviours in all its activities. Students are all sent a Code of Conduct in advance of travel, which must be signed by Parents / Guardians of U18 Students.