Safeguarding children, young people and vulnerable adults:
Sisters of St. Charles Borromeo Nebbi will work with children, parents and the community to ensure the rights and safety of children, young people and vulnerable adults are protected based on the three key commitments:
a) Protection of children and other vulnerable Persons
All children are equal and must receive equal treatment for Education, Protection against hurtful treatment and abuse as requirement for safeguarding children Policy. We are committed to building a 'culture of safety' in which children, young people and vulnerable adults are protected from abuse and harm in all areas of our service delivery because we are Human Rights Defenders.
b) Working Together to Safeguard Children
Sisters of St. Charles Borromeo Nebbi will work in Dialogue, Consultation and Collaboration with the rural Parents, Families, Community people to care, ensure the safety and promote the welfare of the rural children living with disabilities, Albinism elderly and other very vulnerable youths and seniors.
Parents, close relatives, caretakers, law enforcements-police are normally the first point of contact in the case of concerns, unless it is felt that this may put the child at risk, or interfere with the course of a police investigation then advice will be sought from social care if necessary.
If a suspicion of abuse warrants referral to social care, parents are informed at the same time that the referral will be made, except where the guidance of the Local Safeguarding Children Board does not allow this, for example, where it is believed that the child may be placed at risk.
c) Support to families
We believe in building trusting and supportive relationships with families, staff and volunteers.
We make clear to parents our role and responsibilities in relation to child protection, such as for the reporting of concerns, information sharing, monitoring of the child, and liaising at all times with the local children’s social care team.
We will continue to welcome the child and the family whilst investigations are being made in relation to any alleged abuse.
d) Respect for Cultural, Traditional, Religious and Social Backgrounds
We introduce key elements of keeping children safe into our programme to promote the personal, social and emotional development of all children, so that they may grow to be strong, resilient and listened to and so that they develop an understanding of why and how to keep safe.
We create a culture of value and respect for individuals, having positive regard for children's heritage arising from their social backgrounds, cultural, traditional or religious ethnicity, languages spoken at home. We ensure that this is carried out in a way that is developmentally appropriate for the children.
e) Disciplinary Actions
Where a member of staff or volunteer engages in activities that cause concern for the safeguarding of children or vulnerable adults, he may be dismissed with mandate of the organization and the Board of Directors will be notified with relevant information, so that individuals who pose a threat to children and vulnerable groups can be identified and barred from working with these groups.
We are committed to promoting awareness of child abuse issues throughout our training and learning programmes for adults. We are also committed to empowering children through our early childhood curriculum, promoting their right to be strong, resilient and listened to.
Training opportunities are sought for all rural adults involved especially those who Never went to school or dropped out of school in the early stages of education. This is to ensure that they are able to recognize the signs and signals of possible physical abuse, emotional abuse, sexual abuse (including child sexual exploitation) and neglect and that they are aware of the local authority guidelines for making referrals.
They will also receive appropriate training for Life Skills and Vocational Training to improve their livelihoods. We ensure that we have qualified and compassionate staff to handle children and young people in Training. We ensure that all staff receive updates on safeguarding discussion at staff meetings regularly.
We will make ourselves aware that some children and young people are affected by gang activities, by complex, multiple or organised abuse. They may be affected through forced marriage or honour based violence or may be victims of child trafficking. While this may be less likely to affect little children in our care, we may become aware of any of these factors affecting older children and young people who we may come into contact with by virtue of Life Skills Develment and Vocational EducationTraining.
Where we believe that a child in our care or that is known to us may be affected by any of these factors above, we follow the procedures for reporting child protection concerns to Law Enforcements and Child /Juvenile Protection Centres so that where such evidence is apparent, the child's key person makes a dated record of the details of the concern and we will discuss what to do and the information is stored on the child's personal file.
Safeguarding in dividuals’ Personal information .
Sisters of St. Charles Borromeo Nebbi may collect and use information about people with whom we work, as well as people who have expressed an interest in the work we do.
Our core values are Honesty, Accountability and Integrity. We regard the lawful and correct
treatment of personal information as crucial to upholding our values and to maintaining confidence between us and those with whom we carry out our work. We ensure that we treat personal information lawfully and correctly.
Our Data Security Policy outlines our undertakings with regard to compliance with data protection law and is designed to support:
• Compliance with data protection law and good practice.
• Protection of privacy rights of supporters, beneficiaries, partners and staff with
Openness about how we handle confidential and personal data.
• Management of risk and Standards of good practice in accordance with our publicly stated principles, Honesty with the information we receive so as to protect our charitable purposes.
• Protect the rights of individuals by ensuring that all personal data held by us is used appropriately and lawfully
• Ensure that all collection, processing, storage and sharing of personal data complies with data protection principles and legal requirement
• Ensure that our organization meets the requirements of the General Data Protection
• Inform and enable employees, job applicants, suppliers and contractors.
These Privacy policies will apply to our Donors, Partner Organizations or Representatives who are privy to information held by Sisters of St. Charles Borromeo Nebbi and protected under the GDPR. The policy applies to the personal data of people with whom we work, job applicants, existing and former employees, interns, trustees, and self-employed contractors, and supporters.
Data and Security
Sisters of St. Charles Borromeo Nebbi retains three broad categories of data which enable us to operate:
• Fundraising data
• Grant Implementation, Project and Organizational Financial Data
• Prospective, Current and Past Employee data
We hold information as follows:
Fundraising data: a) Name, postal addresses, phone number; b) email addresses; c) job title and organization; d) details of donations made by the data subject.
Grant implementation and organizational financial data: In addition to personal information as above, during the creation and implementation of grants and operations the following financial data is important to us a) tax codes and bank account details; b) insurance details and details of other Directors
Recruitment process and employee data: We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We hold this data within our enterprise information systems and personnel files relating to each employee
within our computer systems. Specifically, we hold the following types of data for employees:
1. personal details such as name, address, phone numbers, passport details;
2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc;
3. details relating to pay administration such as National Insurance numbers, bank account details and tax codes;
4. pension and insurance details (eg: next of kin);
5. medical or health information;
6. information relating to your employment with us, including: job title and job descriptions, salary, terms and conditions of employment, formal and informal proceedings such as letters of concern, disciplinary and grievance proceedings, annual leave records, appraisal and performance information, internal and external training modules undertaken; expenses paid during travel or other circumstances; benefits claimed including gym membership and dental insurance.
How we maintain data security
Sisters of St. Charles Borromeo Nebbi operates with a high degree of awareness of risks associated with data privacy and security. As such we maintain a number of secure enterprise systems that support the work of finance, human resources, project management and communications and fundraising teams.
Personal information and relevant data are retained within the systems.
A. Collecting Data
1. Individuals are asked for their consent before Sisters of St. Charles Borromeo Nebbi collects or stores their data.
2. Individuals are made clearly aware of the purpose for which their data has been collected, will be used, disclosed, retained and disposed of.
3. Individuals are given an option to ‘opt in’ to receive follow up and marketing information and the “opt-in” must follow best practice guidelines. Consent will not be inferred if an individual does not respond to a consent request.
4. Sisters of St. Charles Borromeo Nebbi employees, will only use data for the purposes for which permission have been given.
5. We ensure that consent is appropriate for the age and capacity of the individual and to the particular circumstance. (Specific rules apply for individuals who may be children or vulnerable adults.)
6. If there is a need to collect children’s data Sisters of St. Charles Borromeo Nebbi will verify peoples ages and gather parental or guardian consent for anyone under 18 years of age.
B. Storing Data
1. Data collected by Sisters of St. Charles Borromeo Nebbi is stored securely in our enterprise information systems.
2. No data is stored on platforms such as Google Docs
3. Under no circumstances is personal data retained on spreadsheets once the purpose of doing so has been completed.
4. Personal data stored on hard drives on various document formats (MS Office suite;
Apple formats; Adobe PDFs etc) should be deleted and shredded, once the purpose has been fulfilled.
C. Sharing Data
1. In all cases, individuals will be asked for consent to share information across Sisters of St. Charles Borromeo Nebbi entities, and where necessary, third parties.
2. Individuals will always be given an option to ‘opt in’ for use of their data for other means
3. Before sharing any data externally, approval is obtained from a member of the Senior Management Team. Data that is shared after approval is encrypted.
4. Before approving the sharing of data, a third party data sharing agreement has to be in place within the organization.
5. Data that is confidential, sensitive, or poses an explicit security risk is never shared by anyone other than a senior manager and only with the approval of the Executive Director.
6. A record of all instances where data has been shared with third parties is maintained. The list identifies the purposes for which it is shared, the security measures undertaken and the nature of the consent by the individual.
7. Sensitive data might include:
• Passport information shared with transport agencies and hotels
• Budgetary information (including employees’ salaries)
• Personal contact details (email addresses, phone numbers)
• Personal information about an individual who we are working with
• Confidential details about a project
D. Removing Data
1. When removing data stored on electronic files, the information will be permanently removed from the device.
2. Paper documentation with sensitive information, such as recruitment documentation will be destroyed using a cross-cut shredder or a service that guarantees safe
removal and disposal for any paper files that no longer is need.
3. Staff does not under any circumstances leave personal data attributable to individuals, on their desk.