Safeguarding children

Safeguarding Children Handbook February 2021

This policy is for all Karo employees, contract staff and shift workers and details the policies and procedure for safeguarding Children and to ensure full compliance with the HSE.

Introduction:

Karo Karo is the online marketplace seamlessly connecting independent nurses and carers with the shifts they want.
Its client group includes older persons, people with a medical diagnosis of dementia, children and adults with complex care needs, adults who require support due to chronic illness (arthritis, multiple sclerosis, respiratory conditions, etc.) children and adults with physical, sensory and intellectual disabilities, college students that require support to attend college, and individuals requiring post-hospital support, care and rehabilitation.
Its services, which are personalised and tailored to the needs of each individual client, enable people with complex and specialist needs to continue to live at home with dignity and independence.
Karo provides direct care to customers on behalf of the HSE and other agencies in addition to providing services to customers in a private capacity. More recently it has begun to develop and expand its services to children and young people and as an approved provider of care it provides home care packages to children with a range of complex careneeds.
As an organisation that is dedicated to continuous improvement, Karo Care seeks to provide the highest possible standard of care to all its clients. In the areas in which it works with children and families, it recognises its role and responsibility to promote children’s welfare and to provide safe and effective services that safeguard them from abuse or harm.
Karo is demonstrating its commitment to safeguarding children who avail of its services by having reviewed and updated its child protection policies and procedures to ensure that they reflect best practice and are fully compliant with recent changes in legislation and national policy.
This Child Protection Policy builds on Karo’s previous Child Safeguarding Statement and is the outcome of its most recent review process. It covers the guiding principles that inform its approach to child protection; the procedures that it follows to reduce the likelihood of child abuse and a new Child Safeguarding Statement (see Appendix 1), which outlines how Karo aims to keep children and young people safe.
The Child Protection Policy and Child Safeguarding Statement are developed as a statement of intent, to assure staff, volunteers, parents, children and the wider community that Karo is committed to safeguarding children and is following best practice standards in the area of child protection.

9. Karo’s new Child Safeguarding Statement is included in Appendix 1 of this document and is intended to be photocopied and displayed in prominent places in all of Karo’s premises throughout the country and are made available to all stakeholders.

1.10.Vital to any policy initiative is implementation. Karo sees this Child Protection Policy as a living policy document that needs to be fully implemented and embedded within the organisation. To this end, Karo commits to ensuring that all staff and volunteers confirm that they have read and understood it and that copies are made available to all children, young people, parents/carers, relevant bodies and members of the general public on request.

Purpose

1. This Child Protection Policy seeks to meet the legal requirements of the Children First Act, 2015 and the obligations that are set out in the Children First National Guidance, 2017 to keep children and young people safe from abuse or harm. It serves to:

Ensure that legislative requirements are met;

● Outline roles and responsibilities of all staff and managers, including Mandated Persons Designated Liaison Persons and Deputy Designated Liaison Persons;
● Guide safe practice;
● Facilitate effective staff induction;
● Act as an educational tool in the area of child protection training;
● Act as a basis for adult and evaluation.ScopeThe Child Protection Policy and Child Safeguarding Statement apply to everybody involved in Karo, including its CEO, its directors, management teams, staff groups and volunteers. While it has particular application for personnel who work directly with children and young people in Karo, it also applies to those staff who are providing services to adults who may come into occasional contact with children or who may receive third party information about a child protection or welfare concern.The Child Protection Policy is devised specifically in the context of Karo’s responsibility to meet all its obligations in the area of child protection and welfare. It complements other Karo policies that, together, exist to ensure the delivery of safe and effective services. Other policies relate to Staff Recruitment and Selection, Health & Safety, Protected Disclosures, Complaints, Grievances, Disciplinary procedures, Dignity at Work, Data Protection (including GDPR, 2018), Incident Management, and Information Technology, Lone Workingetc.Legal & Policy ContextThe Child Protection Policy has been devised within the context of a number of key legal and policy developments that represent a sustained effort to strengthen child protection systems within the statutory, voluntary and private sectors. They are as follows:
● The setting up of Tusla, the Child & Family Agency, in 2014 as a dedicated state agency responsible for child protection and welfare in Ireland. Tusla works in partnership with the HSE and other state bodies in providing direction and guidance to all sectors and agencies, including Karo, on the delivery of safe practices in the services that they provide to children and young people
● The enactment of new Children First legislation, the Children First Act, 2015 which placed a number of new statutory obligations on specific groups of professionals, called Mandatory Persons, including the

requirement on them to report concerns above a particular threshold and to assist Tusla in its assessment of

those concerns.

● The legislation also strengthened safeguarding arrangements within specific groups of organisations, called‘relevant services’, obliging them to carry out risk assessments of their services to identify whether any risks to children exist; to develop Child Safeguarding Statements and appoint a staff member, known as a ‘relevant person’, to act as the first point of contact in respect of the organisation’s Child Safeguarding Statement. Under the Children First legislation, Karo is deemed to be a ‘relevant service’ and is therefore legally bound to adhere to the above requirements.
● The publication of revised Children First National Guidance (Department of Children & Youth Affairs) in 2017 to reflect the legal changes of the Children First Act,2015 and to offer guidance on recognising and reporting child abuse, child protection processes within state bodies and the need for oversight arrangements for child protection and welfare in differentsectors.
● The enactment of legal protections for persons reporting child abuse (Protections for Persons Reporting Child Abuse Act, 1998) if they report a concern ‘reasonably and in good faith’ to designated officers in Tusla, the HSE and An Garda Síochána.
● The enactment of legal protections for children that introduced offences and penalties for reckless endangerment (Criminal Justice Act, 2006); withholding information on offences against children and vulnerable persons (Criminal Justice Act, 2012); employment of staff to carry out relevant work with children and vulnerable adults without adhering to national vetting requirements (National Vetting Bureau Acts, 2012- 2016) and the use of technology for the purposes of grooming or sexually exploiting a child (Criminal Law Act, 2017).

Other legal and policy documents also underpin and are relevant to this child protection policy:

● UN Convention on the Rights of the Child, 1989;
● Child Care Act, 1991
● ‘Trust in Care’ – Guidelines for Health Service Employers on Preventing Patient/Client Abuse and Dealingwith allegations of abuse against employees (HSEA, 2005);
● National Standards for the Protection & Welfare of Children (HIQA, 2012);
● Investing in Families: Supporting Parents to Improve Outcomes for Children (Tusla,2013)
● ‘Meitheal’ – a National Practice Model for All Agencies Working with Children, Young People and theirFamilies. (Tusla, 2013)
● Parenting Support Strategy – 50 key Messages to Accompany Investing in Families (Tusla, 2013)
● What Works in Family Support (Tusla, 2013)
● HSE Works in Family Support (Tusla, 2013)
● 4.8.10.‘Better Outcomes, Brighter Futures’ – the National Policy Framework for Children & Young People2014-2020 (DCYA, 2014)Safeguarding PrinciplesKaro has developed a set of safeguarding principles to reassure staff, volunteers, children, families and the wider community of its commitment to keeping children safe. These principles underpin the ethos of Karo and guide the policies, practices and procedures set out in this Child Protection Policy:
● All children have rights, including the right to be protected from harm;
● The safety and well-being of a child is paramount and takes priority over all other concerns;Reports made where reasonable grounds for concern exist are made to Tusla without delay;
● Timely responses and early intervention can help to keep children safe;
● Karo works in partnership with families and parents and carers have a right to respect and to be consultedon matters that relate to their family;

● Karo will ensure that all managers, staff and volunteers are provided with the information and training that they need to safeguard children.

Definitions

● In line with Children First Act, 2015 and the Children First National Guidance, 2017, this Child Protection Policy refers to a child as meaning a person under the age of 18 years, who is not or has not been married.

Categories of Child Abuse

● Raising awareness within Karo of the possibility and the risks associated with child abuse requires everyone in the organisation to have a standardized training relevant to their role/responsibility to include an understanding of the four different categories of abuse and be familiar with the typical signs and symptoms.
● In Children First National Guidance, 2017, child abuse is classified into four separate categories – neglect, emotional abuse, physical abuse and sexual abuse. It is generally accepted, however, that children may be subjected to more than one category of abuse at any given time and that all forms of child abuse have an emotional impact on achild.
● Abuse and neglect can occur within a number of different settings, including the family, in the community or within an institution or service. The abuser may be someone known to the child or a stranger, and can be an adult, staff member or another child. In a situation where abuse is alleged to have been carried out by another child, child protection procedures initiated by Tusla are followed both for the victim and the alleged abuser.
● The definitions of neglect and abuse presented in this section are not legal definitions but are taken from Children First National Guidance 2017. They are intended to describe ways in which a child might experience abuse and how the abuse may be recognised.Neglect‘Neglect occurs when a child does not receive adequate care or supervision to the extent that the child is harmed physically or developmentally. It is generally defined in terms of an omission of care, where a child’s health, development or welfare is impaired by being deprived of food, clothing, warmth, hygiene, medical care, intellectual stimulation or supervision and safety’.

The following are features of child neglect:

● Children being left alone without adequate care and supervision
● Malnourishment, lacking food, unsuitable food or erratic feeding
● Non-organic failure to thrive, i.e. a child not gaining weight due to not only malnutrition but also emotionaldeprivation
● Failure to provide adequate care for the child’s medical and developmental needs, including intellectualstimulation
● Inadequate living conditions – unhygienic conditions, environmental issues, including lack of adequateheating and furniture
● Lack of adequate clothing
● Inattention to basic hygiene
● Lack of protection and exposure to danger, including moral danger, or lack of supervision appropriate to thechild’s age
● Persistent failure to attend school
● Abandonment or desertion

Emotional Abuse

‘Emotional abuse is the systematic emotional or psychological ill-treatment of a child as part of the overall relationship between a caregiver and a child. Once-off and occasional difficulties between a parent/carer and child are not considered emotional abuse. Abuse occurs when a child’s basic need for attention, affection, approval, consistency and security are not met, due to incapacity or indifference from their parent or caregiver. Emotional abuse can also occur when adults responsible for taking care of children are unaware of and unable (for a range of reasons) to meet their children’s emotional and developmental needs’.

Emotional Abuse may be seen in some of the following ways:

● Rejection
● Lack of comfort and love
● Lack of attachment
● Lack of proper stimulation (e.g. fun and play)
● Lack of continuity of care (e.g. frequent moves, particularly unplanned)
● Continuous lack of praise and encouragement
● Persistent criticism, sarcasm, hostility or blaming of the child
● BullyingConditional parenting in which care or affection of a child depends on his or her behaviours or actions
● Extreme overprotectiveness
● Inappropriate non-physical punishment
● Ongoing family conflicts and family violence
● Seriously inappropriate expectations of a child relative to his/her age and stage of developmentPhysical Abuse‘Physical abuse is when someone deliberately hurts a child physically or puts them at risk of being physically hurt. It may occur as a single incident or as a pattern of incidents. A reasonable concern exists where the child’s health and/or development is, may be, or has been damaged as a result of suspected physical abuse.’

Physical

abuse can include the following:

● Physical punishment
● .Beating, slapping, hitting or kicking
● Pushing, slapping, hitting or kicking
● Pushing, shaking or throwing
● Pinching, biting, choking or hair-pulling
● Use of excessive force in handling
● Deliberate poisoning
● Suffocation
● Fabricated/induced illness
● Female genital mutilation

Sexual Abuse

‘Sexual abuse occurs when a child is used by another person for his or her gratification or arousal, or for that of others. It includes the child being involved in sexual acts

(masturbation, fondling, oral or penetrative sex) or exposing the child to sexual activity directly or through pornography. It should be remembered that sexual activity involving a young person may be sexual abuse even if the young person concerned does not themselves recognise it as abusive’. Child sexual abuse can include the following:

● Any sexual act intentionally performed in the presence of a child
● An invitation to sexual touching or intentional touching or molesting of a child’s body whether by a person orobject for the purpose of sexual arousal or gratification
● Masturbation in the presence of a child or the involvement of a child in an act of masturbation
● Sexual intercourse with a child, whether oral, vaginal or anal
● Sexual exploitation of a child, which includes: Inviting, inducing or coercing a child to engage in prostitutionor the production of child pornography [for example, exhibition, modelling or posing for the purpose of sexual arousal, gratification or sexual act, including its recording (on film, videotape or other media) or the manipulation, for those purposes, of an image by computer or other means]
● Inviting, coercing or inducing a child to participate in, or to observe, any sexual, indecent or obscene act
● Showing sexually explicit material to children, which is often a feature of the ‘grooming’ process byperpetrators of abuse
● Exposing a child to inappropriate or abusive material through information and communication technology
● Consensual sexual activity involving an adult and an underage person.Vulnerable ChildrenIt is recognised that some groups of children are more vulnerable to abuse than others. These groups include children with disabilities and children who live away from home, as well as children in care, children seeking asylum and children whose parents have problems in their own lives such as addictions, substance abuse, mental health issues or domestic violence.There can be an increased vulnerability amongst children with disabilities and complex health needs. This is particularly so among those who do not understand social cues and/or have difficulty in communicating with others. Some children may lack an understanding of social situations and may therefore trust everyone implicitly. Such children are more vulnerable because they do not have the skills or capacities to recognise and defend themselves against abusive behaviour.BullyingIt is also recognised that bullying affects the lives of a significant number of children and can be the cause of genuine concerns about children’s welfare. Bullying can be defined as repeated aggression, whether it is verbal, psychological or physical, that is conducted by an individual or group against others for a variety of reasons. Karo’s Anti-Bullying Policy accepts a zero-tolerance towards all forms of bullying. Karowill seek advice from Tusla on any known cases of serious bullying causing reasonable grounds for concern of children using its services from any source, as appropriate.Roles and ResponsibilitiesAll Karo staff and personnel, irrespective of their role or the client group with whom they work, have a responsibility for implementing this Child Protection Policy to keep children using its services safe

Mandated Persons

The Children First Act, 2015 introduced new measures for key groups of professionals who, because of their qualifications, training or employment roles, were seen to be in key positions to protect children from harm. These people are known as Mandated Persons (See Appendix 2 of the Children First National Guidance for the Protection and Welfare of Children for schedule of Mandated Persons) and they are, under the legislation, legally required to report concerns above a particular threshold to Tusla and to assist Tusla, if requested, in assessing a concern that has been the subject of a mandated report.

The legal definition of the term harm and the defined threshold for making a mandatory report, taken from the Children First Act, 2015, are included in the box below

Section 2 of the Children First Act 2015 defines harm as follows:

‘harm means in relation to a child

a. b. c.

● 15.2.1.assault, ill-treatment or neglect of the child in a manner that seriously affects, or is likely to seriously affect the child's health, development or welfare, or,
● 15.2.2.sexual abuse of the child.’Section 14(1) of the Children First Act 2015 states:‘...where a mandated person knows, believes or has reasonable grounds to suspect, on the basis of information that he or she has received, acquired or becomes aware of in the course of his or her employment or profession as such a mandated person, that achildhas been harmed,
is being harmed, or
is at risk of being harmed,he or she shall, as soon as practicable, report that knowledge, belief or suspicion, as the case may be, to the Agency.’Section 14(2) of the Children First Act 2015 also places obligations on mandated persons to report any disclosures made by a child:‘Where a child believes that he or shehas been harmed,
is being harmed, or
is at risk of being harmed,and discloses this belief to a mandated person in the course of a mandated person’s employment or profession as such a person, the mandated person shall, ... as soon as practicable, report that disclosure to the Agency.’

Mandated Persons are seen to have a central role for child protection across the agencies in which they work, both in terms of making mandatory reports and assisting Tusla in assessing the risks to the child. While in some cases they may work with other client groups, such as adults with disabilities or health issues, they are, as a result of their employment or professional duties, legally mandated to report on suspected child abuse.

Under the legislation, Mandated Persons are obliged to report any knowledge, belief or reasonable suspicion that they may have that a child has been harmed, is being harmed or is at risk of being harmed. The Act defines harm as assault, ill-treatment, neglect or sexual abuse and the threshold for making a mandatory report to Tusla is reached when it is seen that the child’s health, development or welfare has been or is likely to be seriouslyaffected.

If the concern does not reach the threshold for mandatory reporting, but the person feels there are reasonable grounds for concern, they should make the report under the Children First National Guidance 2017, either single handedly or in conjunction with a Designated Liaison Person (DO). In some instances, Mandated Persons may choose to make a joint report to Tusla with a DO or other work colleague, if there are reasonable grounds for concern but the concern does not reach the threshold for a mandatory report.

The report form to be used for making both a mandatory and non-mandatory report is available on the Tusla website (www.tusla.ie).

● To be familiar with the Children First Act, 2015 and Children First National Guidance,2017 and be aware of the threshold that needs to be reached to make a mandatory report;
● To ensure that when the threshold for making a mandatory report is reached, that the report is made as soon as practicable;
● To identify on the Tusla report form whether the report being made is a mandatory report under the Act;
● To discuss any uncertainty as to whether the threshold for a mandatory report has been reached with a Tusla Social Worker prior to the report being made;
● To understand that the decision to make a mandatory report rests with themselves as Mandated Persons
● To recognise that sanctions may be imposed on them if they fail in their duty to report a concern;
● To assist and participate at any follow-up meetings in relation to the child and co-operate with Tusla’s plansto keep the child safe;
● To make sure that information shared as part of an assessment on a child is not shared with a third partywithout the written permission of Tusla;
● To contact An Garda Síochána in emergency situations or afterhours;
● To inform Tusla when urgent action to protect a child has been taken and to ensure that the report relating tothe concern is submitted within 3 days;Designated OwnerKaro has in place appointed a Designated Owner (DO) for child protection. These person is principally responsible for reporting reasonable grounds for concern to Tusla and are nominated to liaise with outside agencies and to act as staff resources in the area of child protection. Reasonable grounds for concern’ are specified in Children First National Guidance as including the following:Evidence, for example an injury or behaviour, that is consistent with abuse and is unlikely to have been caused in any other way
● Any concern about possible sexual abuse
● Consistent signs that a child is suffering from emotional or physical neglect
● A child saying or indicating by other means that he or she has been abused
● Admission or indication by an adult or a child of an alleged abuse they committee
● An account from a person who saw the child being abused.It should be noted that the threshold for establishing whether there are reasonable grounds for concern may not reach the threshold for a mandated report. This is to ensure that cases that do not reach the threshold of harm are also reported on to

Tusla if the concern is seen to be reasonable and enables services to be mobilised to support the child and family before the situation deteriorates to the point where the child is seen to suffer harm.

DOs are responsible for ensuring that internal and external reporting procedures are followed in a consistent way so that any child protection or welfare concerns are properly conveyed within the organisation and, if required, reported to Tusla or to An Garda Síochána (in the event of emergencies or outside of office hours) without undue delay. In some instances, DOs may choose to make a joint report to Tusla with a Mandated Person.

The report form to be used for making both a mandatory and non-mandatory report is available on the Tusla website (www.tusla.ie).

Responsibilities of Karo designated liaison persons to be familiar with the Children First Act, 2015 and Children First National Guidance, 2017 and to apply their knowledge within the context of Karo.

● To act as a resource person within Karo for other staff and volunteers in child protection matters and to liaise with outside agencies;
● To encourage and facilitate staff and volunteers to share any concerns that they might have about a child or young person;
● To discuss with a Tusla Social Worker whether reasonable grounds for concern exist that warrant a report being made;
● To make a report to Tusla on behalf of the organisation and to identify on the report form whether the report being made is a mandatory report under the Act or not;
● To ensure that all relevant information is appropriately shared with Tusla when a report is made;
● To participate at any follow-up meetings in relation to the child and co- operate with Tusla’s plans to keepthe child safe;
● To contact An Garda Síochána in emergency situations or afterhours;Karo ManagementOne of the main objectives of the Children First Act, 2015 is to ensure that organisations like Karo keep children availing of its services safe from harm. While it is not possible to completely eliminate all risks of harm, it is possible to put measures in place that reduce and manage risk to the greatest extent possible.Staff, Volunteers & StudentsAs Karo upholds a corporate duty of care towards children, all staff, irrespective of the area in which they work, carry a responsibility for keeping children safe. This responsibility extends to all staff who work directly with children, staff who work with adults, families and older people; staff who work in support and administrative positions; persons who may undertake work for Karo in a volunteering capacity and also to students, if attached to Karo on student placement.

● This responsibility needs to be brought to the attention of all staff through information and training events and reaffirmed through ensuring that all staff and volunteers have access to and have read this Child Protection Policy and Child Safeguarding Statement. The responsibilities of Karo staff and volunteers are as follows:

All staff should read, understand and adhere to Karo’s Child Protection Policy and Child Safeguarding Statement. If an individual staff member does not understand their responsibilities set out in the Child Protection Policy, he or she should inform their supervisor;

● Staff should remain open to the possibility of child abuse, look out for signs and symptoms and record information accurately;
● If any staff member has a concern about a child’s safety or welfare, they are required to pass their concerns on to a DO without delay;
● Staff members should discuss with their line manager or a DO any behaviour by another staff member that might transgress Karo’s Staff Code of Behaviour or which gives rise to a child protection or welfare concern;
● All staff members should attend information sessions and training events in child protection and welfare that are arranged by Karo.It should be noted that Karo has no responsibility for investigatingallegations of child abuse as this is a matter for Tusla and An Garda Síochána. In this context, the role of Karo is confined to recognising any signs or symptoms that might be indicative of abuse, to report on any concerns that it has and to co- operate with statutory authorities.Under the Children First Act, 2015 mandated persons are legally required to report the harm of children above the defined threshold and, if requested, to assist in the assessment of the concern which has been the subject of a mandated report.

Reporting Procedures

A key element of this Child Protection Policy is the reporting procedure which all managers, staff and volunteers must follow if information becomes available to them which gives rise to a concern about a child.

The Need to Report

The need to report on a child protection concern may arise for Karo staff in a number of different contexts. It may arise as the result of direct physical or indirect emotional or behavioral signs; something concerning that a child might say; something concerning someone else might say; a concern about a staff member’s behaviour; actions and reactions of parents/carers or signs of chronic or persistent neglect over a period of time.

Furthermore, the need to report may arise as a result of a retrospective disclosure made by an adult who reports that they had been abused as a child. Concern must be given to the possibility that the alleged abuser may have contemporaneous contact with other children and may be placing them at risk. For this reason, Karo staff should pass details of any retrospective disclosure to the DO to report toTusla.

The report form to be used for making a report of a retrospective disclosure is available on the Tusla website (www.tusla.ie).

Sometimes children may select a staff member as a trusted person who they wish to talk to about concerns that they might have. When this occurs, staff are advised to:

● React calmly
● Listen carefully and attentively
● Take the child seriously
● Reassure the child that they have taken the right action in talking to you
● Avoid promising to keep anything secret 20.4.6.Ask questions for clarification only 20.4.7.Avoid askingleading questions
● Check back with the child that what they have heard and understood is correct
● Avoid expressing any opinions about the alleged abuser
● Ensure that the child understands the procedures that will follow
● Make a written detailed record of the conversation as soon as possible
● Treat the information confidentially.
● such situations, while it is important that the child is reassured and supported by the staff member as muchas possible, they need to also be informed that the details of the concern may need to be reported or passed on in order to keep them safe in the future. Staff should pass details of disclosures to the DO without delay in accordance with this policy.
● Sometimes a concern of a child protection or welfare nature comes to the attention of Karo in the form of a complaint, either from a child, a family member, a staff member or from a member of the general public. Whenever this occurs, the concern raised needs to be responded to in line with this Child Protection Policy and reported to Tusla as appropriate. Complaints that are received which are not of a child protection or welfare nature will be dealt with separately within the context of Karo’s Complaints Policy.Internal Reporting ProceduresKaro has developed a standard reporting procedure for all staff and volunteers to follow in the event of them coming across a child protection or welfare concern about a child.If any member of Karo has a child protection or welfare concern, they should follow the internal reporting procedure outlined as follows:What to do in the event of a concern
● Record the details of the concern in writing and complete a Child Concern Report Form (CCRF) for the child, confining the information to facts and observations that are relevant to the concern;
● Ensure that details of the concern are passed on to the DO in Karo without undue delay;
● The DO will decide if reasonable grounds for concern exist and if this needs to be reported to Tusla and will,if necessary, seek advice from Tusla as to what actions need to be taken;
● In the event of an emergency where a child may be in immediate danger or a situation that arises after officehours which requires an immediate response, staff are advised to contact An Garda Síochána without delay.3-Step Process Outlining Reporting Procedure

Concern identified by staff member and written record kept
Concern reported by staff member to the DO, using Karo’s Child Concern Report Form (CCRF)
The DO consult with or report concern to TUSLA or in the event of emergency, contact An Garda Síochána

Reasonable Grounds for Concern

If a DO within Karo receives information that gives rise to a concern about a child, they should consider whether there are reasonable grounds for making a report to Tusla. They can seek advice on this by consulting directly with a Tusla Duty Social Worker.

The following examples constitute reasonable grounds for concern that warrant a report to Tusla being made: Evidence, for example an injury or behaviour, that is consistent with abuse and is unlikely to have been caused in any other way

Any concern about possible sexual abuse
Consistent signs that a child is suffering from emotional or physical neglect

A child saying or indicating by other means that he or she has been abused 22.2.4.Admission or indication by an adult or a child of an alleged abuse they committed 22.2.5.An account from a person who saw the child being abused.

If reasonable grounds for concern are seen to exist, the DO should report the concern to Tusla, by contacting the Duty Social Worker in the area in which the child normally resides, either by telephone, in person, in writing or by completing the standard reporting form used by Tusla to receive reports.

The report form to be used for making both a mandatory and non-mandatory report is available on the Tusla website and contact details of local Social Work Duty Teams are also available on the Tusla website (www.tusla.ie).

When a report is made to Tusla, Tusla Social Workers will help to facilitate this process by clarifying information with persons making a report. The type of information that will be sought include the following:

Child’s name, address and age

Names and addresses of parents or guardians

Names, if known, of who is allegedly harming the child or not caring for them appropriately

A detailed account of the grounds for concern (e.g. details of the allegation, dates of incidents and descriptions of any injuries)

.Names of other children in the household

Name of the school that the child attends

Name of person making the report, safeguarding role and relationship to the child.

The ability of a Tusla Social Worker to respond will depend on the quality and extent of the information reported and any new information that is considered relevant to the report should also subsequently be passed on to Tusla. All information relating to the report should be retained by Karo and should be dated, signed, held securely and treated as confidential.

If a DO is in doubt as to whether reasonable grounds for concern exist, they can consult with the Tusla Social Worker, giving an outline of the concern without providing any identifying details, in order to seek information and advice as to whether the concern warrants a formal report. Tusla Social Workers will explore the nature and extent of the concern with the DO and will advise them accordingly.

A suspicion that is not supported by any objective indicator of abuse is not generally considered to be reasonable grounds for concern and would not normally be reported to Tusla. However, such concerns should still be recorded by Karo staff and noted internally by a DO as future concerns may lead to a decision being made to report in thefuture.

If a DO receives information about a child from a staff member but subsequently decides that reasonable grounds for reporting the concern do not exist, the staff member should be informed of the reasons for why the organisation is not taking action inwriting.

The staff member should also be advised that if they remain sufficiently concerned about the situation, they are free to consult with or report directly to Tusla or An Garda Síochána themselves and that they are legally protected from penalisation or civil liability under the Protections for Persons Reporting Child Abuse Act, 1998 as long as the report is made ‘reasonably and in good faith’.

In line with good practice, Karo is committed to supporting any staff member who chooses to make a report reasonably and in good faith directly to the relevant authorities, even if the DO’s view may have been at variance with the view of the staff member and the concern turns out to be unfounded following an investigation.

Responding to Allegations Against Employees

Karo is committed to developing an open environment in which staff members feel supported and safe to share any concerns that they may have about a child. If a staff member has a concern about the behaviour of a colleague, they should bring their concern to the attention of their line manager, a DO, a Mandated Person or to another senior colleague.

Staff and volunteers should also be made aware of the fact that they can report their concern directly to Tusla if they feel inhibited for any reason about reporting their concern about a colleague to Karo management or where they are dissatisfied with the internal response.

Procedures

If an allegation or concern regarding a child protection issue is made against an employee of Karo, two separate sets of procedures apply. These procedures are designed to ensure that due regard is given to the rights of the child on the one hand and those of the employee against whom the allegation is made on the other hand. In accordance with the HSEA’s national good practice guidelines ‘Trust in Care’ (2005), Karo seeks to balance its dual responsibility in respect of both the child and the employee. The safety and wellbeing of the child is paramount.

The two separate procedures are overseen by the CEO in Karo. On receiving notice of the allegation or concern, Director will appoint two managers to manage the two separate processes and will seek legal advice as required.

The first procedure relates to the child and is followed for the purpose of ensuring that the child in question or any other child is kept safe from harm and that a report of the allegation is made to Tusla without undue delay. The first procedure is managed by the DO or Deputy DO for Karo.

The second procedure relates to the employee and is for the purpose for

ensuring that the employee is dealt with in a fair and even-handed way in accordance with natural justice and that they are facilitated to avail of assistance from a professional association or trade union if required. This procedure is managed by a manager of equal rank or grade to the DO or by another senior colleague in Karo.

The DO overseeing the first procedure will decide upon what protective measures may need to be taken in order to ensure that no child is exposed to harm or danger and will make arrangements for a report of the allegation or concern to be made to Tusla without undue delay.

While protective measures may involve the reassignment of tasks, chaperoning or the temporary suspension of the staff member for the duration of the investigation on paid leave, these measures should be proportionate to the perceived level of risk and should not unreasonably discriminate against the staff member in question, financially or otherwise.

It is important to note that these actions do not imply guilt or predict the outcome of any subsequent investigation but rather represent a best practice approach to child protection while matters are being properly investigated.

The manager overseeing the second procedure will ensure that the staff member is treated in accordance with the principles of natural justice. The manager will, at the earliest opportunity, inform the person in question of the fact that an allegation has been made against them, the nature of the allegation and afford them an opportunity to formally respond to it. In situations where the allegation is denied, there is a presumption of innocence unless it is proved to the contrary.

The manager will also advise the employee that they can seek information and support from their professional association or trade union in relation to the matter and inform them of the procedures that will be followed to ensure that the allegation is thoroughly investigated and to maintain due diligence.

Once Tusla has completed its assessment, it will provide written feedback to Karo on the outcome of its assessment and its conclusion. Tusla will follow its own internal procedures and notify An Garda Síochána if the allegation or concern is upheld or if abuse is suspected.

It will be for Karo to decide upon what subsequent actions it will take in response to the outcome of the assessment carried out by Tusla. The safety and welfare of the child remains the paramount consideration throughout the entire investigation process.

If the outcome of the Tusla assessment concludes that the allegation is substantiated and the staff member in question has a case to answer, Karo will decide upon what sanctions or disciplinary procedures will be initiated, up to and including, dismissal.

If, on the other hand, the outcome of the assessment concludes that the allegation or concern is unfounded, this will be communicated to the staff member who will be fully exonerated and cleared of any wrong doing. The outcome of the investigation will be recorded on the staff member’s HR file and the person in question will be offered counselling support, if required.

Support and counselling will also be offered to other staff members affected by the allegation or by the subsequent investigation.

Karo recognises that staff working with children may sometimes feel vulnerable to accusations of child abuse. There are occasions when a false allegation is made against a staff member either because of a misunderstanding or a genuine mistake.

It is for these reasons that Karo will treat any allegation against a staff member openly and without judgement. It is important for all involved that the matters relating to any allegation are treated fairly and expeditiously and that strict confidentiality is observed by all those involved.

The procedures for Karo to follow in the event of an allegation or concern being made against an employee or volunteer are summarised below.

The Director should be notified of the allegation or concern as soon as possible;
Two separate managers should be appointed to manage the two separate processes described above;

The manager dealing with the employee should inform the staff member of the allegation and afford them an opportunity to respond to the allegation;

The manager dealing with the reporting procedure should report the details of the allegation or concern to Tusla and in consultation with Tusla decide upon how the parents of the child should be informed;

Proportionate protective measures will be put in place, as necessary, to ensure that no child is exposed to harm or danger;

Tusla will conduct an investigation into the allegation and provide Karo with notification of the outcome of its assessment. On this basis of this information, the Director will decide upon what further actions should be taken and whether disciplinary action against the employee is required;

If the allegation relates to any person responsible for discharging management duties in relation to this procedure, alternative arrangements will be made by Karo to re- assign key staff to ensure that procedures are followed rigorously and objectively;

A written record of all meetings and communications should be maintained safely and securely by the managers assigned to each procedure within the process.

Sometimes allegations about employees come to the attention of Tusla or An Garda Síochána without the prior knowledge of the employing agency. If the statutory body in receipt of this information considers that the seriousness of the allegation is likely to place any child or group of children at immediate risk, it will make arrangements to notify the institution or employer of the allegation.

In situations where the statutory body receives an allegation about an employee but it considers that the allegation is not so serious as to place children at immediate risk, it will seek to inform the person in question of the allegation that has been made against them and of its intention to subsequently notify the institution or employer of the allegation.

Recruitment, Induction & Probation

● All organisations working with children are required to develop safe care practices in the recruitment and appointment of staff, including Garda vetting, the checking of references, face to face interviewing, induction training and the establishment of a probationary period for newly appointed staff.
● All organisations working with children are required to develop safe care practices in the recruitment and appointment of staff, including Garda vetting, the checking of references, face to face interviewing, induction training and the establishment of a probationary period for newly appointed staff.
● Karo is committed to vetting all potential employees who have applied to work with children and vulnerable adults with the National Vetting Bureau prior to appointment and commencement of work and will store and retain records in line with data protection legislation and GDPR.
● Applicants and volunteers are automatically excluded from working in Karo if they fail to disclose any criminal convictions or cases pending against them or if they have committed an offence that is deemed to make them unsuitable to work with children or vulnerable adults. These include all sexual offences, offences against a person, firearm offences, robbery, or serious motoring offences. While some limited discretion may be used in the recruitment and appointment of staff and volunteers, the paramount consideration is the safety and welfare of all of Karo’s clients, children and adults.
● Karo will make provision for the re-vetting of incumbent staff and volunteers every five years, following standard procedures, in line with expediency and current best practice.

When recruiting new staff, Karo has established a pre-selection process specifically with child protection in mind, which includes the following:

An application form that seeks a systematic record of applicants’ past experience and history of working with children and young people;

● A declaration form that allows an applicant to self-declare any relevant information, including convictions, cautions or cases pending against them, that may have a bearing on their suitability to work with children and young people;
● The obtaining of three references, one professional from their last employer and two- character references in writing sought for selected applicants provided by two non- family member referees, to testify as to the applicant’s suitability to work with children and followed up and confirmed by telephone or inperson;
● Verification of relevant qualifications with qualifying bodies;
● Proof of identity (birth certificate, passport or driving licence with photograph);
● Written consent obtained from selected applicants for Karo to undertake Garda vetting in Ireland and Policeclearance in other jurisdictions;
● Confirmation of the outcome of the Garda vetting / Police clearance processes;
● Setting of a probation period following which employee’s suitability and progress is reviewed;
● Ensuring that all appointments are formally signed off by a Director.InductionAn induction programme for newly appointed staff is an important process for introducing new staff to an organisation and helping them to integrate and become familiar with the working environment. It also provides an opportunity for them to learn the importance of child safeguarding, Karo’s staff code of behaviour and their role within the organisation to keep children safe.Managers should ensure that during this induction period all new staff know how they can access a copy of this Child Protection Policy and Child Safeguarding Statement stored on the BRAT system. Subsequent meetings between

managers and staff members can provide opportunities to reaffirm the importance of safeguarding and ensure that staff know how to pass on any concerns that they might have.

Probation

The introduction of probationary periods for new staff can also help to create a structure for staff performance appraisal. This enables a formal review of roles, responsibilities, conduct, competencies, standards and agency expectations within a given period of time. For further details on Karo’s probationary processes see Karo’s HR Policy.

Following appointment and during the probationary period, staff will be supported by the organisation to fulfil their duties to the best of their ability and receive feedback from management on their performance and practice in order to ensure that appropriate standards of care are achieved. This will include particular attention being paid to the Child Protection Policy and Child Safeguarding Statement and the importance of Karo’s safe management and staff code of behaviour.

Karo has committed to ensure that all its staff, irrespective of the roles that they have within the organisation, complete the HSE e-learning module ‘Introduction to Children First’, which is available on www.hseland.ie. This will act as a Standard and benchmark for newly appointed staff and act as a refresher for staff who had attended the last training schedule.

Child protection training is seen to be particularly relevant for staff who supervise other staff or who provide direct services to children and families and also for staff, like DOs and Mandated Persons who carry a particular responsibility for receiving and reporting any concerns and working closely with relevant authorities. However, given the fact that within Karo child protection is seen to be everyone’s business, basic level training is needed by all other staff, including staff who work with adults and administrative and ancillary staff.

Karo will audit take-up levels and retain records of staff who have completed the HSE e-learning module and those staff who have still to complete the module. Staff themselves will be furnished with certificates of completion which they will be advised to retain as proof of attendance.

Compulsory attendance is seen by Karo as the most effective way of ensuring that staff have received up to date child protection training that will outline what they must do if they come across a child protection or welfare concern. It is expected that staff will complete this training in the course of their induction process and will receive refresher training in child protection every three years.

It is envisaged that managers, DOs and Mandated Persons within Karo will also access more advanced-level training in child protection and will maintain their knowledge and commitment by keeping informed of child safeguarding developments and linking with other professionals working in the area.

Supervision

Within Karo, Supervision is seen as a formal process where line managers and staff meet at regular intervals to enable the manager to evaluate the staff member’s performance, support and development needs.

Staff supervision provides an ideal forum for managers and staff to explore child protection and welfare issues. It provides an opportunity for both parties to reflect on issues relating to child protection and for the manager to reinforce the importance of the staff member being familiar with the policies and procedures covered by this Child Protection Policy and Child Safeguarding Statement.

Supervision is viewed as a shared responsibility between the supervisor and supervisee and should be scheduled in advance and with the time ring-fenced without interruption. The roles and responsibilities of supervisor and

supervisee should be clearly documented, and a written record of all supervision sessions should be maintained, signed and dated by both parties involved. The supervision record should be stored in a safe and confidential place in adherence with Data Protection requirements.

Dealing with child protection issues can be emotive for individual staff members and supervision sessions can provide opportunities for managers to debrief staff after a child protection incident or review critical incidents with staff and explore how the staff member responded to a particular situation and how to maximise their learning from it.

Staff supervision also provides opportunities for managers to assess staff members’ learning and development needs in the area of child protection and explore with them opportunities for ongoing information, training andsupport.

Safe Management

Karo, like other agencies that provide direct services and activities for children, can safeguard children by adhering to Health & Safety legislation and by implementing a code of staff behaviour for working with children. Such actions help to create a safe, child-centered environment for children and young people and contribute to keeping children safe.

Karo has clear guidelines for its staff regarding how activities are organised and run. This is to minimise opportunities for accidents and incidents that may result in a child being hurt or harmed in any way.

.Karo maintains a register of all children and young people using its services which includes the child’s and family’s details, medical details, care plans and family contact details as well as attendance, consent forms, accidents, incidents, complaints and grievances. It also displays work schedules in its premises to ensure that everyone knows which staff members are on duty at any given time.

Consideration is also given to the physical state and safety standards of any premises or vehicles used by Karo to ensure that they comply with legislation requirements and meet all health and safety standards. Equally, a comprehensive risk assessment is carried out in advance of all outside facilities and trips away that involve children using Karo services.

Karo staff will only undertake one-to-one working with children when consent has been granted by the parents and child and after a risk assessment has been carried out to identify and minimize any potential risks to the child or misunderstandings about staff behaviour. Practical measures such as informing another member of staff of the start and finish times of the session and leaving a door open to enable easy access and visibility can help to provide safeguards and help reduce risks.

Code of Behaviour

Karo, has established a Staff Code of Behaviour to guide staff practice when working directly with children in different settings. The code of behaviour is a central element of its risk management strategy and provides clarity in terms of maintaining appropriate boundaries of behaviour and acceptable physical contact between staff and children. Furthermore, the code of behaviour reflects Karo’s staff code of conduct which is applied uniformly across the organisation with all its clients and is reinforced in staff induction, training and supervision.

Karo’s code of behaviour is aimed at all staff in Karo, including managers, staff and volunteers and represents a list of key action principles for working with children and young people irrespective of the setting in which they are applied. The code of behaviour incorporates the following principle.

Karo’s code of behaviour for working with children & young people:
● Treat all children and young people equally and with respect and dignity;

1. Put the welfare of each child first;

1. Seek to build balanced relationships with children, based upon mutual trust and respect;

1. Listen to children and facilitate them to be involved indecision-making;

1. Find opportunities to encourage and praise every child;

1. Make activities fun, enjoyable and promote fair play;

1. Work in an open environment with clear and honest communication and no secrets;

1. Maintain safe and appropriate boundaries with children at all times; 30.2.1.9.Respect children’s personal space, safety and privacy at all times;

1. Ensure that children are adequately supervised at all times and that consideration is given to the need for mixed gender staff-child ratios;

1. Develop a policy of openness and partnership with parents that promotes consultation, information-sharing and active participation;

Secure written parental consent in situations when Karo acts ‘in loco parentis’ and in
The administration of emergency first aid and other medical treatments;

1. Ensure that robust and efficient procedures are in place for responding to accidents, incidents and complaints;

1. Maintain written records of all significant events and ensuring that parents are informed of events at the earliest opportunity;

1. Ensure that nappy changing, toilet training and any form of personal care is provided by agreement and with the prior consent of children and their parents/carers;

1. Ensure that all staff know who to contact in the event of them becoming concerned about the safety or welfare of a particular child or the attitude or behaviour of a work colleague.

1. Practices that are regarded as unsafe or inappropriate are outlined below: 1. Being overly involved or showing favoritism towards any one child;

1. Spending time alone with a child;

1. Undertaking one-to-one work with a child without gaining the consent of parents;

1. Giving lifts to children in cars without the consent of parents;

1. Transporting children in staff members own cars without appropriate risk controls as identified in the Karo Policy;

1. Making contact with children and young people outside of the context of the service or on social media;

1. Taking photos of children with or without consent at any stage;
30.2.2.8.Leaving a child unsupervised or unattended, even for short periods of time;

1. Engaging in rough physical games;

1. Making sexually suggestive comments to a child;

1. Physically punish or verbally chastise a child;

1. Failing to act upon any concerns expressed or allegations made about a child;

1. Doing things of a personal nature for children that they can do for themselves.

1. Consistent implementation of the code of behaviour requires all staff to have read the code, integrated it into their work practices and to know that there is a duty on them to report any breaches of the code to their line manager, DO or other senior colleague.

1. Issues of concern relating to staff conduct will be dealt with by line managers through supervision and performance management structures and staff should be aware that if reasonable grounds for concern exist this may result in the matter being reported to Tusla or An Garda Síochána and subsequent disciplinary action being taken against the staff member by Karo.

1. Behaviour Management of Children

Sometimes children can display behaviours that challenge. This can place their own safety and the safety of other children and staff at risk. Staff members need to be equipped with the skills to prevent, contain and de-escalate such situations and respond to such behaviours in ways that do not leave children open to inappropriate responses or neglect.

● Parents should be informed of times when their children behaved in challenging or risky ways, as soon after the incident as possible.
● When the situation is resolved, staff will ensure that the incident is recorded on a Karo Accident & Incident Form and forwarded to Karo management, in accordance with Karo’s policy on dealing with accidents and incidents.Confidentiality
● 32.1.Effective child safeguarding is dependent on the sharing and exchange of relevant information. For thisreason, it is vital that Karo staff have a clear understanding of what confidentiality means in the context of child protection and the importance of passing on information when there is a concern about a child.
● In line with Children’s First National Guidance 2017, Karo’s policy on information sharing is as follows
● Information of a child protection nature is shared only on a ‘need to know’ basis in the best interests of thechild;
● 32.2.2.No undertakings regarding secrecy can be given and those working with children and families shouldmake this clear to all parties involved.
● No unofficial or ‘off the record’ discussions about child protection issues should take place with children,parents or other professionals;
● The sharing of information to statutory agencies for the protection of a child does not constitute a breach ofconfidentiality or dataprotection;
● Information that is gathered for one purpose cannot be used for another;
● 32.2.6.Mandated Persons should not disclose any information shared by Tusla in the course of carrying out an assessment to a third party without the written permission of Tusla;
● 32.2.7.It is good practice to inform parents that a report is being made and the reasons for it, unless it places the child at further risk, impairs Tusla’s ability to carry out a risk assessment or places the person making the report at risk of harm from the family.
● 32.3.Every effort is made within Karo to ensure that confidentiality is maintained, and that information is handled sensitively and shared only with persons who have a bona fide reason for needing to know the information in order to keep the childsafe.Record Keeping
● Karo has developed appropriate record keeping systems that are compliant with data protection legislation and GDPR. This ensures that all personal data is held fairly and lawfully, is obtained for specific purposes, isadequate, relevant and not excessive, is accurate and up to date, is not kept for longer than is necessary, isonly made available to those who need to know it and is only used for specific purposes.
● If a staff member comes across a situation which gives rise to a child protection or welfare concern, theyshould keep a written record outlining the details of their concern. Relevant observations relating to the concern should be recorded accurately and should include dates, times, names, locations and other relevant information. This record provides the basis of information needed when the concern is reported to a DO on Karo’s Child Concern Report Form (CCRF) and will assist the DO if the concern is subsequently reported on to Tusla.
● All records created as a result of this Child Protection Policy that include personal data should be signed, dated and treated as confidential. Where reports are recorded on computer, such files are password protected and accessible by authorised persons only. Karo is committed that all client records that relate to child protection and welfare are retained and stored in a safe and secure place
● For further details on Record Keeping see Karo’s record keeping and file retention policy.Oversight & Governance
● This Child Protection Policy and Child Safeguarding Statement require official and formal approval by the CEO of Karo Corporate and a written record kept of the date on which approval was granted.
● A communications strategy will be developed by Karo to ensure that all staff, volunteers, children, young people and families using the service are aware of the Child Protection Policy and Child Safeguarding Statement and that it is embedded into the culture of the organisation.
● An information sheet for parents and guardians that outlines the purpose of this document is included in Appendix 4.
● Review mechanisms will be put in place to evaluate the implementation of the Child Protection Policy and Child Safeguarding Statement and to monitor their levels of use, compliance and effectiveness. Practical indicators that are being considered as ways of assessing their impact include:
● Measuring the extent to which personnel understand child safeguarding and know what child protection procedures to follow
● Measuring the extent to which personnel understand the role of DOs and Mandated Persons;
● Measuring the number of personnel attending the HSE’s Children First e- learning module and other childprotection training courses;
● Measuring the extent to which personnel know Karo’s Code of
● Behaviour for working with children;
● Recording the number of concerns of a child protection nature that are conveyed to DOs by Karo personnelover a given period;
● Evaluating the experience of individual staff members when they pass on a concern about a child to a DOand tracking the outcome of the concern;
● Recording the number of reports and consultations made by DOs and Mandated Persons to Tusla over a given period;
● Recording the number of allegations against employees that are investigated over a given period.
● A template for capturing information on all reports, both internal and external, called the Child SafeguardingLog is included in Appendix 5.
● The Child Protection Policy and Child Safeguarding Statement should be formally reviewed within 24months of the date of its original approval by Karo, or earlier if there have been any material changes to any matter relating to this document or the policy or practices therein.