1) Purpose
Fundación Pasos de Luz (“the Foundation”) is committed to preventing harm, abuse, neglect, and exploitation of all people we engage with, especially children, adolescents, and adults at risk, and to responding promptly and safely to any concern. This policy sets out our principles, standards, roles, and procedures to keep people safe across our programs, operations, communications, and partnerships.
2) Scope
Applies to all trustees, staff, consultants, interns, volunteers (including student volunteers), contractors, and partners working with or for the Foundation, in person or online, including fieldwork, events, and media/communications.
3) Definitions
- Safeguarding: Measures to protect people from harm, abuse, neglect, exploitation, and harassment in connection with our activities.
- Children: Anyone under 18 years.
- Adults at risk: Adults who, due to neurodevelopment conditions, may be unable to protect themselves.
4) Principles
- Do no harm; survivor-centered and trauma-informed responses.
- Zero tolerance for abuse, exploitation, bullying, harassment, discrimination, or retaliation.
- Best interests of the child and participation consistent with their evolving capacities.
- Proportionality & risk-based approach across programs and partners.
- Confidentiality & data minimization consistent with legal requirements.
5) Code of Conduct
All representatives must:
- Treat everyone with dignity and respect; uphold non-discrimination and inclusion.
- Maintain professional boundaries; never engage in sexual activity or romantic relationships with beneficiaries; never exchange money, employment, goods, or services for sex.
- Avoid being alone with a child where not visible to others; adhere to the Two-Adult Rule and approved supervision ratios.
- Prohibit corporal punishment, emotional abuse, humiliation, or degrading treatment.
- Use safe digital/online practices; never request private images, personal contact outside approved channels, or share personal social media with beneficiaries.
- Report concerns immediately via the channels below.
6) Safer Recruitment & Vetting
- Role descriptions include safeguarding responsibilities.
- Pre-employment checks: identity, qualifications, references, and criminal background checks where lawful and feasible; conflict-of-interest declaration.
- Contractors and partners must evidence equivalent safeguarding standards in contracts.
7) Training & Awareness
- Induction: Mandatory safeguarding induction for all representatives before contact with beneficiaries.
- Ongoing: Annual refreshers; role-specific modules (e.g., teachers, therapists, volunteers).
- Community awareness: Age-appropriate, culturally sensitive materials for families and youth volunteers.
8) Risk Assessment & Safe Program Design
- Conduct and document risk assessments for programs, events, outreach, transport, field visits, online activities, and partner activities; update at least annually or after any incident.
- Build in mitigation: safeguarding briefings, supervision plans, consent procedures, accessibility and inclusion adaptations, and emergency protocols.
9) Communications, Images & Storytelling
- Obtain informed consent (and parental/guardian consent for minors) for interviews, photos, audio, and video; explain purpose, channels, retention, and the right to withdraw consent.
- Protect identity when appropriate (e.g., use first name initials or aliases; avoid revealing locations/schools; no images that could be misused or sexualized; no images of partially clothed children).
- Dignified, accurate portrayal, no sensationalism or stereotypes. Maintain consent records securely.
10) Data Protection & Confidentiality
- Collect only data necessary for safeguarding and program operations; store securely with restricted access; share on a need-to-know basis for safety and legal purposes.
11) Reporting Concerns & Whistleblowing
- Report immediately any suspicion, disclosure, or allegation of abuse or policy breach—no proof required.
- Reporting channels (available 24/7):
- Safeguarding Focal Point (SFP): Send an email to pasosdeluz.fundacion@gmail.com
- Anonymous option: Fill the form here
- We will escalate to relevant authorities (e.g., child protection services, police) as required; trustees are informed per severity and law. No retaliation against good-faith reporters.
12) Responding to Safeguarding Concerns
- Immediate safety first (medical care, separation of alleged perpetrator, safe transport).
- Record on the standard Incident Reporting Form within 24 hours; preserve evidence; respect confidentiality.
- SFP initiates a proportionate review/investigation; apply sanctions as warranted; notify donors/partners when required.
- Provide survivor support/referrals (health, psychosocial, legal). Maintain a secure incident log.
13) Working With Partners, Schools, & Volunteers
- Written agreements require partner policies consistent with this policy; joint risk assessments before activities at schools or community venues; orientation for youth volunteers.
- Ensure supervision, consent, transport protocols, and clear activity boundaries; teachers or guardians present when minors volunteer.
14) Governance, Oversight, and Review
- The Board holds ultimate responsibility for safeguarding and receives quarterly reports from the SFP.
- Annual policy review (or sooner after incidents/legislative changes).
- Program audits include safeguarding spot checks and beneficiary feedback.
Approved by: Board of Trustees, Fundación Pasos de Luz
Effective date: 05/01/2024
Next review: