Child Protection Policy

 

Effective Date of Last Update: October 31, 2023

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KYTABU CHILD SAFEGUARDING AND PROTECTION POLICY

POLICY STATEMENT

At KYTABU, we are committed to recognizing, promoting and protecting the rights of all children. KYTABU believes that the welfare of children is the highest priority and that it is the responsibility of everyone who works for and with KYTABU to ensure that children are protected from abuse and exploitation. We recognise that safeguarding considerations permeate all aspects of KYTABU’s work and we strive to prioritise safeguarding in all KYTABU’s policies, practices and activities.

In line with the United Nations Convention on the Rights of the Child (UNCRC), we recognise that all children, (meaning children under the age of 18 years), have a right to protection and freedom from abuse, including exploitation, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity in both an online and offline environment.

As a learning focused Education Technology Company, we require all KYTABU Personnel and partners to uphold and demonstrate best practice in child safeguarding and protection to ensure that children who come in contact with KYTABU Personnel and/or KYTABU software and content are protected from any form of abuse or exploitation.

DEFINITIONS
Child abuse: physical, sexual, emotional abuse and/or neglect. Abuse can take place in person and online, by other children and/or adults, including those in positions of trust.

Child safeguarding: proactive steps taken to prevent violence against children including all forms of physical or mental violence, injury and abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse.

Child protection: responding to concerns and/or disclosures that a child may be experiencing, or be at risk of physical and/or mental violence, injury and/or abuse, neglect and/or negligent treatment, maltreatment and/or exploitation, and/or sexual abuse.

SCOPE OF THIS POLICY
This policy applies to all KYTABU employees, contractors, trustees, consultants, fellows, advisors, interns and volunteers (referred to in this policy as ‘KYTABU Personnel’). This policy recognises that KYTABU Personnel may have access to sensitive, confidential information about children, access to images and may visit KYTABU programs.

Additionally, KYTABU recognises that direct services and support to children is primarily implemented through our software. Consequently, KYTABU has requirements (set-out below) for all products that are used by children on any one of our platforms.

PLATFORM AND CONTENT REQUIREMENTS.

The safeguarding and protection of children is a non-negotiable on all platforms and content created by KYTABU. Therefore it is a requirement that all products:
1. Have their own tailored Child Safeguarding and Protection Policy.
2. Have moderator specifications to Safeguarding users on the platform and respond to reports of misconduct,
3. Work immediately and collaboratively with KYTABU’s Legal Officer where there is a disclosures of child protection concerns.

This requirement also applies to all downstream personnel, partners and sub-contractors who are engaged by KYTABU to perform any part of the design, development or implementation activities when working with or in contact with children.

KYTABU is committed to working with institutions and educators to assist with drafting and implementing a Child Safeguarding and Protection Policy if they do not have one for their school. KYTABU will review the Child Safeguarding or Protection Policy of all schools using our products as part of the partnership KYC process. Once a partnership has been approved, KYTABU will adopt a collaborative approach and work with the institutions and educators to develop and/or strengthen their Child Safeguarding and Protection Policy and may provide additional support, both in terms of capacity and staff to assist with this.

Once a KYTABU deployment begins, KYTABU will have open and regular dialogue with the partners regarding Child Safeguarding and Protection. In the event that a concern or disclosure of abuse is reported to an institution, the institution will address it in accordance with its own child safeguarding or protection policy and national laws. In addition, the institution must advise KYTABU within 7 days of the knowledge of the concern or disclosure. Institutions are expected to provide regular updates to KYTABU as to the status of any investigation and the outcome of the process. At any time, KYTABU can request an independent audit of any institution, platform deployment or mobile application in relation to child safeguarding and protection.

Should any institutions or educator fail to deal with safeguarding and protection issues in line with their policy or the KYTABU Safeguarding and Protection Agreement, KYTABU will terminate our services and any future arrangements with immediate effect and, where appropriate, report the institution to appropriate safeguarding authorities.

KYTABU’S SAFEGUARDING COMMITMENT
Awareness:

At KYTABU, we commit to;

  • ensuring that KYTABU Personnel understand what safeguarding and child protection are; what the risks to children they work with are; what is expected from their behavior with children and their responsibilities to priorities the well-being of children at all times;
  • ensuring that KYTABU Personnel have read, understood and agree to uphold this policy;
  • ensuring that KYTABU Personnel know where to access this policy and that it can be easily found on the KYTABU intranet and website;
  • actively promoting safeguarding and children’s rights to be protected, and ensuring that safeguarding is discussed with all learning institutions or potential learning institutions and that they agree to take their obligations seriously;
  • sharing this policy with the broader donor community with whom KYTABU operates.

Prevention:

At KYTABU, we commit to;

  • working collaboratively with learning institutions to promote child safeguarding and protection best practices;
  • discuss child safeguarding and protection actions, challenges and concerns/disclosures with learning institutions at each reporting interval (or at least every three months);
  • have robust recruitment and selection processes to check that, to the best of our knowledge, all KYTABU Personnel are suitable to work with or have contact with children (regardless of whether or not contact with children will actually take place). This includes background checks, behavior based interviewing, specific questions on safeguarding in interviews to understand individuals’ attitudes to safeguarding, completing a self-disclosure form, and reference checks on suitability to work with children. Should there be a change of circumstance or role (for example increased travel) resulting in increased contact with children, it is the responsibility of the individual to notify KYTABU who will conduct a further security check at a higher level;
  • ensuring that all potential KYTABU Personnel sign up to and abide by this policy and the attached Code of Behavior (Annex 1) before commencing employment / contracted work/ appointment;
  • appointing a trained Legal Officer for each project where necessary who is supported by the General Counsel;
  • taking stringent measures against any KYTABU Personnel or learning institution that abuses a child, or  does not uphold this policy, including not taking action when they have reasonable grounds to suspect a child might be at risk of harm. This includes KYTABU reporting the individual/learning institutions to the relevant authorities and registers;
  • safe storage of all confidential material, including material with personal data, in line with GDPR Regulations and KYTABU policies.

Reporting:

At KYTABU, we commit to;

• KYTABU Personnel being clear what to do when child protection concerns or disclosures arise;
• KYTABU Personnel knowing who their local Legal Officer is and how to contact them;
• all concerns or disclosures being reported to the Legal Officer immediately (within working hours);
• all Personnel knowing what steps to take if the concern/disclosure is outside of working hours, they cannot contact the Legal Officer or the concern is regarding the Legal Officer

Responding:

At KYTABU, we commit to;

  • ensuring the safety of the child is always the first priority and that action is taken to support and protect children who are the subject of concerns regarding possible abuse
  • applying the principle of ‘best interests of the child’ to all child safeguarding protection concerns and disclosures;
  • taking all concerns and disclosures seriously and fully supporting any KYTABU Personnel who in good faith raises his or her concerns. No form of coercion, intimidation, reprisal or retaliation against any KYTABU representative who reports any suspected form of abuse or exploitation is tolerated. (See also KYTABU’s whistle-blower Policy in the KYTABU Staff Handbook and KYTABU’s whistle-blowing statement;)
  • handling all concerns and disclosures in a confidential manner, with information shared on a ‘need to know’ basis;
  • all incidents being dealt with promptly, and all cases relating to KYTABU Personnel being investigated and reported to the Executive Team within one month of being reported to the DSO. Where deemed necessary or appropriate (such as cases of serious harm to a child) the DSO will inform the Executive Team and Trustees of KYTABU of grantee case details.

Investigating:

KYTABU Personnel:

  • If a concern or disclosure relates to a KYTABU Personnel, KYTABU will form a Child Protection Investigation Committee consisting of an Executive Director, the HR Director, the General Counsel and an external protection expert.
  • Where an allegation is made about a KYTABU Personnel, the individual may be immediately suspended from their employment or contract without prejudice, whilst the investigation takes place. Where feasible, a decision as to whether the individual can return to work, be dismissed or further time to make a decision is required, will be made by KYTABU’s Executive Team and the General Counsel within 28 days. In some cases, particularly where local authorities are involved, more time may be required before a decision can be made.
  • Should an allegation of abuse or other breach of this Safeguarding and Child Protection Policy be substantiated, the individual will be subject to disciplinary action in accordance with KYTABU’s Disciplinary Procedures which may include dismissal or termination of contract and reporting the concern/disclosure to relevant safeguarding authorities.

KYTABU Partners:

Where a concern or disclosure relates to a grantee, KYTABU requires all Partners to inform KYTABU within three (3) days of the concern / disclosure being made. Where the grantee chooses to seek advice or support from KYTABU regarding a concern or disclosure, KYTABU will support the Partner to investigate all concerns and disclosures in line with their Child Safeguarding and Protection Policy and local legislation. KYTABU and the Partner may decide to:

  • Internally investigate the concern or disclosure
  • Report a concern or disclosure to a local children’s protection service
  • Report a concern or disclosure to the police particularly if someone is or may be in immediate danger
  • Report the outcome of the investigation to relevant external bodies such as the criminal bureau and/or Children Safety Commission or equivalent in other geographies
  • Where KYTABU has concerns that a partner organization is not following best practice, KYTABU may take independent action in line with this policy.
  • All allegations regarding KYTABU Personnel and grantees will be handled equitably and transparently (with due regard to confidentiality) irrespective of whom they are made against, and taking into account the rights of the parties involved. Whilst aiming to make fair, fact-based decisions, KYTABU will always prioritize the well-being of children in its decision-making.

Training and Education:

At KYTABU, we commit to;

  • Provide training to all new KYTABU Personnel that may come into contact with children in their role, during their induction process, and in any case, within three months of starting with KYTABU.
  • Provide annual refresher training to KYTABU Personnel that may come into contact with children in their role;
  • Ensure KYTABU Personnel who have specific responsibilities for keeping children safe (including DSOs) have access to specialist advice, support and regular opportunities to update their skills and knowledge.

Media and Communications:

We acknowledge that child abuse, including exploitation can occur through the use of information technology, such as when children are photographed or filmed in an inappropriate way. Transparency, openness and appropriate professional purpose underpin any KYTABU Personnel’s interaction with children including via electronic and digital means.

At KYTABU, we commit to;

  • obtain informed consent from the child and the parents/guardian before taking a photograph, video or audio recording and ensure that an explanation as to how, where, when and for how long the photo or film will be used is provided;
  • take care to assess local traditions or restrictions for reproducing personal image and endeavor to comply with them;
  • ensure that children are presented in a dignified and respectful manner in text, photographs and film and that images are an honest representation of the context and facts;
  • ensure that no pictures of children that can be interpreted as sexualised or degrading or shaming in any way shall be published by KYTABU or KYTABU Personnel;
  • ensure that no personal data or sensitive information about any individual child that could compromise their care or protection is disclosed in publications or other materials, including surnames or any specific location details;
  • ensure that pictures, materials and personal information regarding children are held in a secure place, whether physical or online and any lost or stolen equipment containing material should be reported immediately to the Legal Officer and to KYTABU’s IT Director
  • report and record any complaints or concerns about inappropriate or intrusive images as a safeguarding concern.

Monitoring and Review:

With Partners:

• KYTABU prioritizes the monitoring and evaluation of proactive approaches to keeping children safe and responding to child protection concerns and disclosures.
• KYTABU requires that safeguarding is evaluated on a regular basis as agreed between KYTABU and the Partner.
• KYTABU may request further information based on evaluation reports. Reasons for this may be:

  1. High numbers of child protection cases
  2. No reported child protection cases
  3. Other reasons as specified by KYTABU.

Internally, KYTABU will:

  • Monitor compliance of this policy within KYTABU platforms and evaluate the effectiveness of this policy through analytical checks, including an annual report to the Executive Team and the Board detailing the number of incidents or concerns of safeguarding reported across its platforms;
  • Commit to review this Safeguarding and Child Protection policy every two years or sooner where there are changes in legislation or within the organization that affect this policy.

This policy has been approved by the Board and is effective from 20 February 2020. The policy was updated in October 2023.

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