United Darfur Committees (UDC)
Safeguarding
Dealing with Safeguarding Reports
Purpose and scope
The purpose of this document is to provide
procedures for dealing with reports of breach of [UDC] Safeguarding Policy,
where the safeguarding violation is:
·
Against staff or members of the public,
Procedures
1. Report is received
1.1 Reports can reach the organization through
various routes. This may be in a structured format such as a letter, e-mail,
text or message on social media. It may
also be in the form of informal discussion or rumor. If a staff member hears something in an
informal discussion or chat that they think is a safeguarding concern, they
should report this to the appropriate staff member in their organization.
1.2 If a safeguarding concern is disclosed
directly to a member of staff, the person receiving the report should bear the
following in mind:
·
Listen
·
Empathies with the person
·
Ask who, when, where, what but not why
·
Repeat/ check your understanding of the situation
·
Report to the appropriate staff member (see below)
1.3 The person receiving the report should
then document the following information, using an Incident Report Form if there
is one:
·
Name of person making report
·
Name(s) of alleged survivor(s) of safeguarding incident(s) if different
from above
·
Name(s) of alleged perpetrator(s)
·
Description of incident(s)
·
Dates(s), times(s) and location(s) of incident
1.4 The person receiving the report should
then forward this information to the Safeguarding Focal Point or appropriate
staff member within 24 hours.
1.5 Due to the sensitive nature of
safeguarding concerns, confidentiality must be maintained during all stages of
the reporting process, and information shared on a limited ‘need to know’ basis
only. This includes senior management
who might otherwise be appraised of a serious incident.
1.6 If the reporting staff member is not
satisfied that the organisation is appropriately addressing the report, they
have a right to escalate the report, either up the management line, to the
Board (or other governance structure), or to an external statutory body. The staff member will be protected against
any negative repercussions as a result of this report. See [UDC] Complaints Policy and Disclosure of
Malpractice in the Workplace Policy.
2. Assess how to proceed with the
report
2.1 Appoint a Decision Maker for handling this
report
2.2 Determine whether it is possible to take
this report forward
·
Does the reported incident(s) represent a breach of safeguarding policy?
·
Is there sufficient information to follow up this report?
2.3 If the reported incident does not
represent a breach of [UDC] Safeguarding Policy, but represents a safeguarding
risk to others (such as a child safeguarding incident), the report should be
referred through the appropriate channels (eg. local authorities) if it is safe
to do so.
2.4 If there is insufficient information to
follow up the report, and no way to ascertain this information (for example if
the person making the report did not leave contact details), the report should
be filed in case it can be of use in the future, and look at any wider lesson
learning we can take forward.
2.5 If the report raises any concerns relating
to children under the age of 18, seek expert advice immediately. If at any point in the process of responding
to the report (for example during an investigation) it becomes apparent that
anyone involved is a child under the age of 18, the Decision Maker should be
immediately informed and should seek expert advice before proceeding.
2.6 If the decision is made to take the report
forward, ensure that you have the relevant expertise and capacity to manage a
safeguarding case. If you do not have
this expertise in-house, seek immediate assistance, through external
capacity if necessary.
2.7 Clarify what, how and with whom
information will be shared relating to this case. Confidentiality should be maintained at all
times, and information shared on a need-to-know basis only. Decide which information needs to be shared
with which stakeholder – information needs may be different.
2.8 You may have separate policies depending
on the type of concern the report relates to.
For example workplace sexual harassment is dealt with through the [UDC]’s
Anti Bullying and Harassment policy.
If there isn’t a policy for the type of report
that has been made, follow these procedures.
2.9 Check your obligations on informing
relevant bodies when you receive a safeguarding report. These include (but are not limited to):
·
Funding organizations
·
Umbrella bodies/networks
·
Statutory bodies (such as the Charity Commission in Sudan UK , USAID,UN agencies, CHF ,SHF and
other foreign Countries )
Some of these may require you to inform them
when you receive a report, others may require information on completion of the
case, or annual top-line information on cases.
When submitting information to any of these bodies, think through the
confidentiality implications very carefully.
3. Appoint roles and
responsibilities for case management
3.1 If not already done so (see above), appoint
a Decision Maker for the case. The
Decision Maker should be a senior staff member, not implicated or involved in
the case in any way.
3.2 If the report alleges a serious
safeguarding violation, you may wish to hold a case conference. This should include:
·
Decision Maker
·
Person who received the report (such as the focal point, or manager)
·
HR manager
·
Safeguarding adviser (or equivalent) if there is one
The case conference should decide the next
steps to take, including any protection concerns and support needs for the
survivor and other stakeholders (see below).
4. Provide support to survivor
where needed/requested
4.1 Provide appropriate support to survivor(s)
of safeguarding incidents. Nb. this
should be provided as a duty of care even if the report has not yet been
investigated. Support could include (but
its not limited to)
·
Psychosocial care or counseling
·
Medical assistance
·
Protection or security assistance (for example being moved to a safe
location)
4.2 All decision making on support should be
led by the survivor.
5. Assess any protection or
security risks to stakeholders
5.1 For reports relating to serious incidents:
undertake an immediate risk assessment to determine whether there are any
current or potential risks to any stakeholders involved in the case, and
develop a mitigation plan if required.
5.2 Continue to update the risk assessment and
plan on a regular basis throughout and after the case as required.
6. Decide on next steps
6.1 The Decision Maker decides the next
steps. These could be (but are not
limited to)
·
No further action (for example if there is insufficient information to
follow up, or the report refers to incidents outside the organization’s remit)
·
Investigation is required to gather further information
·
Immediate disciplinary action if no further information needed
·
Referral to relevant authorities
6.2 If the report concerns associated
personnel (for example contractors, consultants or suppliers), the decision
making process will be different. Although associated personnel are not staff members, we have a duty
of care to protect anyone who comes into contact with any aspect of our
programme from harm. We cannot follow
disciplinary processes with individuals outside our organisation, however
decisions may be made for example to terminate a contract with a supplier based
on the actions of their staff.
6.3 If an investigation is required and the organization
does not have internal capacity, identify resources to conduct the
investigation. Determine which budget
this will be covered by.
7. Manage investigation if
required
7.1 Refer to the organization’s procedures for
investigating breaches of policy. If
these do not cover safeguarding investigations, use external guidelines for
investigating safeguarding reports, such as the CHS
Alliance Guidelines for Investigations.
8. Make decision on outcome of
investigation report
8.1 The Decision Maker makes a decision based
on the information provided in the investigation report. Decisions relating to the Subject of Concern
should be made in accordance with existing policies and procedures for staff
misconduct.
8.2 If at this or any stage in the process
criminal activity is suspected, the case should be referred to the relevant
authorities unless this may pose a risk
to anyone involved in the case. In
this case, the Decision Maker together with other senior staff will need to
decide to decide how to proceed. This
decision should be made bearing in mind a risk assessment of potential
protection risks to all concerned, including the survivor and the Subject of
Concern.
9. Conclude the case
9.1 Document all decisions made resulting from
the case clearly and confidentially.
9.2 Store all information relating to the case
confidentially, and in accordance with [UDC] policy and local data protection
law.
9.3 Record anonymised data relating to the
case to feed into organizational reporting requirements (eg. serious incident
reporting to Board, safeguarding reporting to donors), and to feed into
learning for dealing with future cases.
1.
[1] Associated
personnel includes (but is not limited to) consultants, volunteers,
contractors, program visitors including
journalists celebrities and politicians
Safeguarding Reports
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Oleh
United Darfur Committees
