Safeguarding Children & Young People Policy

• Protect children and young people who engage in Penta’s work from harm.  
• Provide staff and volunteers, as well as children, young people and their families, with the overarching principles that guide our approach to child protection.  

1.2 Scope

This Policy applies to any individual working or volunteering at Penta, or acting on their behalf, who has contact with children and young people. 

It provides the framework to help all staff, contractors, collaborators and volunteers to safeguard children and young people with commitment and confidence.  

The welfare of children and young people is paramount regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse. 

Some children and young people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues. 

Penta believes that children and young people should never experience abuse of any kind, and it recognises that working in partnership with children, young people, their caregivers and other organisations is essential in the promotion of children and young people’s welfare. 

Penta promotes the welfare of all children and young people while conducting scientific research and training in the paediatric field.  

More precisely, Penta seeks to promote the welfare of children and young people involved in its activities by: 

• Valuing, listening to and respecting them. 
• Adopting child protection and safeguarding best practice through our policies and procedures. 
• Sharing information about safeguarding with children, young people and their families when they are involved in our work, including processes for reporting concerns. 
• Building a safeguarding culture where staff and volunteers, children, young people and their families, treat each other with respect and are comfortable about sharing concerns. 

All staff, contractors, collaborators and volunteers must at all times show respect and understanding for the rights of children and young people, their safety and welfare, and conduct themselves in a way that reflects this. 

• Using procedures to manage any allegations made against staff and volunteers appropriately. 
• Ensuring to provide a safe physical and digital environment for children, young people, staff and volunteers. 

3.1 Safeguarding Leadership

Penta has adopted a management process to facilitate the implementation of the children and young people safeguarding policy and procedures. 

The Network, Education and Training Team Manager is appointed as Designated Safeguarding Lead (DSL) and takes lead responsibility for managing child protection referrals, safeguarding training and raising awareness of all child protection policies and procedures. In detail, the DSL: 

• Ensures that everyone, including temporary staff, volunteers and contractors, are aware of these procedures and that they are followed at all times (see section 3.3). 
• Acts as a source of advice and support for other staff on child protection matters and ensure timely referrals to the relevant people (see section 3.6).  
• Takes lead responsibility for keeping full written chronological records of all concerns raised against any Penta personnel, including consultants or any other person that has a contractual relationship with Penta, relating to a child or young people at risk, even if there is no need to make an immediate referral. These records are kept confidentially and securely.  

3.2 Recruitment

Penta is committed to assure a safe recruitment and selection procedure for those working directly with children and young people. 

Penta staff, contractors, collaborators and volunteers should undergo through a standardized recruitment process, based on a detailed analysis of each task and the level of contact with children, in order to ensure that they are suitable to work with children and young people. 

During the recruitment and selection process some actions shall be adopted to obtain a safer procedure: 

• For any role working directly with children and young people, the job description should highlight the safeguarding responsibilities, including what skills and knowledge are needed to safely work with children and young people.  
• Advert for a role which foresees to work with children and young people should include a statement on Penta’s commitment to keep children and young people safe. 
• Ask applicants to provide the details of at least two referees. 
• Questions relating to safeguarding are included in interviews. 
• Certificate of pending charges to assess the absence of crimes against minors are referred thereto to shall be obtained. 

3.3 Awareness and Training

Penta shall provide training and support designed to ensure that staff and others required to comply with this Policy understand their safeguarding responsibilities and have the knowledge and skills necessary to fulfil their obligations. 

All staff, contractors, collaborators and volunteers working directly with children and young people, shall receive an induction training on safeguarding and requirements outlined in this policy and other procedures. 

Penta shall ensure that all staff and others working in direct contact with children and young people are aware of the definition and signs of child abuse, the risks, and proper reporting procedures (see section 3.6).

3.4 Conduct and Behaviours 

Penta shall ensure through awareness, good practice, and proper infrastructure, that staff and others minimize the risk to children while they participate in Penta’s activities. 

All individuals involved in activities with children and young people must adhere to the principles and procedures outlined in the following guidelines for conduct and behaviours: 

• Listen to children and young people and take their contributions seriously.  
• Respect a children and young people’s right to personal privacy and use caution when discussing sensitive topics. 
• Comply with all relevant laws concerning the protection of children in the country where the activity takes place. 
• Inform children and young people of their rights in a way they can understand, including by identifying the person where to seek advice/complain in case of problem. 

• Respect differences and never discriminate on the grounds of gender, sexual orientation, culture, race, ethnicity, disability, and religious belief systems. 
• Use positive, non-violent methods to manage children’s behaviour. 
• Never act in a way that could be perceived as threatening, including the use of physical punishment or physical force to manage children and young people. 
• Never engage in any action that harms or exploits children or young people. 
• Never make sarcastic, insensitive, derogatory, or sexually suggestive comments or gestures to or in front of children and young people. 
• Where possible and practical, ensure that there is more than one adult present during direct interactions with children and young people. 
• Take appropriate action as required where become aware or suspect that a child has experienced or is experiencing abuse (see section 3.6). 
• Comply with the Ethic Code adopted by Penta. 

3.4.1 Participation of Children and Young People in Penta Activities

Penta is committed to ensure the children’s right to participate and to have their views considered in matters that affect them. For the purposes of this policy, participation is understood to be activities or initiatives where Penta invites children or young people to take an active role in the delivery of an initiatives or to share their views, ideas, and experiences. 

When inviting children and young people to participate in Penta activities, they shall be provided with full, accessible, diversity-sensitive and age-appropriate information about their right to express their views freely and to have their views given due weight. They should be informed on how the participation takes place, its scope, purpose and potential impact (see appendix 6.2).  

Children and young people should never be coerced into expressing views against their wishes and they should be informed that they can cease involvement at any stage. 

Children and young people should not incur costs as a result of their participation. They are reimbursed for any costs related to participation.  

Penta staff and other facilitators shall take special consideration for events where children and young people are participants to ensure that, to the best of our abilities, content does not cause unintended harm.  

Penta staff and other facilitators shall adhere and implement procedures defined to hold online and face-to-face events. Refer to SOP NET 01 “Payments to Young People and Carers”. 

3.4.2 Use of Photographs, Video and Audio Recordings

When developing and using photos or videos featuring children involved in Penta activities, the following principles should be followed: 

• A written consent from parents/guardians, carers and children/young people shall be sought before taking a photograph, video or audio recording and ensure that an explanation on the purpose is made clear to the consent giver (Please refer to Module 11A – see Penta’s Privacy Manual). 
• Personal data or sensitive information, including surnames or any specific location details, about any child will be disclosed strictly in accordance with the agreed terms. 
• Children shall be presented in a respectful manner in photographs, video and audio recordings. These shall be an honest representation of the context and facts. 
• Never directly post images or stories about children or young people who are engaged with Penta on personal social media accounts. Consent, when obtained, is given to Penta as an organisation and not to the individual for personal use. 
• Photographs, video or audio recordings taken for Penta’s use must be kept securely, in accordance with Penta policies and General Data Protection Regulation (GDPR). 
• Penta does not permit staff and volunteers to use any personal equipment to take photos and recordings of children. Only cameras or devices belonging to Penta should be used.  
  In case a photographer/ video maker is engaged for taking photos or for video / audio recording, Penta must ensure:
  • To provide the photographer with a clear brief about appropriate content and behaviour. 
  • The photographer wears identification. 
  • To inform children/young people, their parents/guardians and carers that a photographer is at the event and ensuring they give written consent to images which feature their child being taken and shared. 
  • To avoid the photographer to have unsupervised access to children/young people. 
  • To avoid the photographer to carry out sessions outside the event or at a child/young person’s home, 
  • To reporting concerns regarding inappropriate or intrusive photography.  

Additional guidance about the use of photos, video or audio recordings may be provided by Penta case-by-case, depending on the type of activities or events. 

3.5 Recognising Abuse

Abuse happens when a person harms a child or a young person. The abuse usually happens over a period of time, rather than being a single, isolated incident. Increasingly, abuse occurs online. 

Abuse is normally categorised into physical, sexual and emotional abuse, and neglect. A more comprehensive list of type of abuse is available in Appendix 6.1. Children and young people suffering abuse often experience more than one type of abuse. 

It is important to be aware of the signs which may mean the child or young people is experiencing abuse. Some examples are: 

• Unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries. 
• Any injury for which the explanation is inconsistent. 
• The child or young person describing what appears to be an abusive act. 
• Sexual awareness inappropriate for age. 
• Engaging in sexually explicit behaviour in games. 
• Becoming increasingly dirty or unkempt.  
• Unexplained changes in behaviour. 
• Talking about being sent abroad to get married. 
• Being prevented from socialising with their peers. 
• Appearing fearful of someone a young person should trust. 
• Being mistrustful of adults, particularly those with whom a close relationship would normally be expected. 
• Someone else expressing concerns about the welfare of the child or young person. 

Anyone concerned about the welfare of a​ child or​ young person must act and must not assume that someone else will.  

3.6 Raise Concerns 

Any concerns about minors raised against any Penta personnel during the course of the Foundation’s activities or reported to Penta personnel will be taken very seriously. Penta supports anyone (children, young people, staff, consultants and collaborators, volunteers, parents, key workers) who raises any concerns regarding the welfare or protection of children and young people.  

In order to protect children and young people from harm, it is important to get an immediate and appropriate action. The need for a reporting process for child protection violations or concerns arises in the following instances: 

• an abuse is observed or suspected, 
• an allegation of abuse is made, 
• a child discloses abuse, 
• a breach of the requirements of this policy is reported or observed. 

The guiding principle is that the safety of the child is always the most important consideration.  

Any allegation or concern regarding the abuse of a child must be treated seriously. For this reason, it is vital that anyone raising a concern should strictly follow reporting procedures. 

Child safeguarding concerns may arise in different ways. Anyone becoming aware of potential, actual or suspected abuse of a child is required to take the following action to report and share information: 

(1) Where the concern relates to abuse of a child by the family, community, or any situation external to Penta’s activities: these concerns must be reported to the DSL and, if a child is in immediate danger, to the relevant national authorities, such as local police and/or social services departments. However, particular attention should be given to the local context to decide how it is possible to report concerns, considering domestic legislation in relation to child abuse, support systems that exist (for example, medical, social and legal services) and actual engagement of authorities. 

(2) Where the concern relates to Penta’s activities: these concerns must be reported, by any means (orally or in writing), to the DSL. Penta sets up reporting channels to ensure that whistleblower’s identity is kept confidential. When the matter falls under the crimes referred to in the D.Lgs. 231/2001 whistleblowing reports must be sent to using the following methods: 

• by e-mail to odvfpenta@gmail.com; 
• by ordinary post to the following address:  
  via Orazio Marinali n. 22, 35061 Bassano del Grappa (VI), Italy. 

The DSL will promptly inform then the Senior Leadership Team that, by turn, will inform the Board of Directors. All the reporting line within Penta will be documented in writing, ensuring confidentiality of the information contained therein.  

3.7 Handling Concerns 

The identity of a person reporting information or cooperating shall not be disclosed, unless expressly authorised by him or her, or where the conduct of a fair procedure so requires. 

Details of concerns are treated with the highest degree of confidentiality and only shared with the minimum number of people necessary to ensure the safety of the child and consistent with legal obligations. 

Any allegation against a Penta staff member shall be reported and managed according to applicable laws and, where the case may be, to the whistleblowing procedure outlined in the Penta Organization, Management and Control Model (“231 Model”), including steps for eligibility analysis, assessment and investigation. 

Depending on the intensity of the misconduct, Penta takes actions accordingly: 

• If an allegation of a violation of this policy is made by a named individual from a verifiable source against any staff member, intern or volunteer, that person may be suspended from all activity or association with Penta, pending the outcome of an independent investigation. 
• Depending on the outcome of the independent investigation, immediate disciplinary action and any other action that may be appropriate will be taken. This may mean, for example, dismissal (for staff members), withdrawal of support or funding (in case of a partner) or termination of the contract (for contractors). 
• Depending on the nature, circumstances and location of the case, involving authorities such as the police will also be considered to ensure the protection of children and criminal prosecution where this is appropriate. 

All data and records taken on the child or young person (e.g. written records of concerns) should be taken and stored in compliance with Regulation (EU) 2016/679 General Data Protection Regulation (GDPR). The DSL and Supervisory Body are responsible for ensuring the appropriate level of security and confidentiality. 

4.1 Compliance, Monitoring & Reporting 

It is the responsibility of all Penta Managers to adhere to this Policy within his or her area of functional responsibility, to lead by example, and to provide guidance to those Penta staff members reporting to him or her.

All Penta staff members are responsible for adhering to the principles and rules set out in this Policy. 

Quality Assurance Manager must ensure that compliance with this Policy is regularly monitored following established audit procedures. 

Any Penta staff member, who learns of a potential deviation from this Policy, is required to report his or her suspicion promptly to the Designated Safeguarding Lead.  

5. References

• Penta Organization, Management and Control Model (“231 Model”)
• Penta Privacy Manual

6. Appendices

6.1 Types of Abuse 

6.2 Consent Form Example  

This is an example of one of the documents needed to ensure safeguarding and child protection is at the heart of Penta’s activities. Use this example to write a document that reflects the safeguarding and child protection needs of the children/young people Penta works with. A GDPR compliant privacy notice should also be included to ensure young people understand how and why we collect their data (refer to module 10A of Penta’s Privacy Manual). 

Download Consent Form Example

6.3 Incident Reporting Form

Download Incident Reporting Form

Last updated: May 2022