Child protection policy

Guiding principles for Children’s Books Ireland staff, volunteers, interns and artists

By adhering to these guiding principles, staff, volunteers, interns and artists can ensure that our events will be safe and fun for young participants, while those undertaking roles within our organisation will be protected.

Children’s Books Ireland’s guiding principles involve:

• putting the child's welfare, safety and enjoyment first
• treating all young people equally, and with respect and dignity
• making our activities fun and enjoyable
• building balanced relationships based on mutual trust, which empowers children to share in the decision-making process
• giving enthusiastic and constructive feedback
• using appropriate language (physical and verbal), tempering language to the needs and sensitivity of the children present
• challenging use of inappropriate language by children
• planning and preparing appropriately so that each session suits the needs of the group (e.g. activities are age appropriate and allow each child to participate in an enjoyable way)
• always working in an open environment, avoiding private or unobserved situations and encouraging an open environment
• recognising the developmental needs and capacity of young people
• ensuring that manual or physical support is only provided when relevant and necessary, except in emergency situations. Young people should always be consulted, and their agreement gained before any physical contact takes place
• involving parents/guardians/caregivers wherever possible and keeping them informed of any issues that concern their children
• ensuring that all children are accompanied to Children’s Books Ireland events by a parent/guardian/caregiver
• maintaining accurate policies and procedures in relation to the care of young people
• keeping a written record of any injury or incident that occurs, along with the details of any treatment given including bringing forms and a copy of this policy and Children’s Books Ireland’s Safeguarding Statement to all Children’s Books Ireland events
• requesting written parent/guardian/caregiver consent if Children’s Books Ireland staff are required to transport young people in their cars and, where possible, having a second adult present

It is important that all Children’s Books Ireland staff, volunteers, interns and artists adhere to these guiding principles. By keeping young people at the forefront of our planning and practice we can be confident that participants will enjoy their experiences and that our actions will be regarded as safe.

In addition, staff, volunteers, interns and artists should never:

• Exert undue influence over a young participant in order to gain personal benefit or reward
• Spend excessive amounts of time alone with a young person
• Leave children alone or unsupervised
• Engage in rough contact, sexually provocative games, inappropriate touching of any kind, and/or make sexually suggestive comments about or to a child
• Engage in a sexual relationship with a young person. This is considered a breach of trust and a disciplinary matter. If the young person is below the age of consent it may be illegal and hence a criminal matter.
• Use any form of corporal punishment or physical force on a young person

Following any incident where a member of staff, a volunteer, an intern or an artist feels their actions could be misinterpreted, a written report should be submitted to all Children’s Books Ireland’s relevant person.

Children’s Books Ireland will recruit and select volunteers and staff in a transparent and equitable fashion.

Children’s Books Ireland recognises that anyone may have the potential to harm children in some way so we will take all reasonable steps to ensure unsuitable people are prevented from working with children.

We will ensure that staff are carefully selected, trained and supervised by observing the following actions:

• Roles and responsibilities will be clearly defined
• Posts will be advertised widely
• All candidates will submit a CV and cover letter
• Staff will be selected by a panel of at least two (or more) representatives through an interview process
• At least two confidential references which are relevant, recent and independent will be sought and verbally confirmed
• Evidence of identity (passport or driving licence with photo) will be collected from staff and volunteers
• There will be a six-month probationary period
• Any staff member whose role requires working with children or young people will be required to consent to Garda vetting and for their disclosures from the National Vetting Bureau to be held on all Children’s Books Ireland’s premises
• No person will be employed who is deemed to constitute a risk
• Grounds for exclusion include:
  • Child-related convictions
  • Refusal to comply with Garda vetting procedures
  • Insufficient documentary evidence of identification
  • Concealing information about suitability for working with children

Staff Management Policy

To protect both our staff and volunteers and all young people we undertake that

New staff and volunteers will:

• Take part in mandatory induction training session
• Be made aware of our guiding principles, Child Safeguarding Statement, Child Protection
• Policy and the identity and role of the relevant person and designated liaison person
• Undergo a probationary period of six months

All staff and volunteers will:

• Receive an adequate level of supervision and review of their work practices
• Read this Child Protection Policy and Children’s Books Ireland’s Child Safeguarding Statement

Procedure for provision of and access to child safeguarding training and information, including the identification of the occurrence of harm

• Children’s Books Ireland will ensure that training and provision of information on safeguarding of children and young people is provided to all staff, volunteers and interns so that they are clear on their responsibilities and understand the different forms of abuse and risks that children and young people may be exposed to in the course of our work with them.
• Children’s Books Ireland will ensure that any safeguarding training provided to staff, volunteers or interns is consistent with Children First Act 2015, Children First: National Guidance for the Protection and Welfare of Children (2017), and Tusla’s Child Safeguarding: A Guide for Policy, Procedure and Practice.
• Children’s Books Ireland will ensure that all staff, volunteers or interns have attended child safeguarding training relevant to their role in the organisation. At a minimum, all staff, volunteers or interns must have completed Tusla’s universal e-learning training programme called ‘Introduction to Children First’.
• Children’s Books Ireland will ensure that appropriate resources (financial and time) are available to the Designated Liaison Person, Deputy Designated Liaison Person and any other staff members who may require additional training.
• Children’s Books Ireland will keep training records, noting the dates that each member of staff underwent training, the name of the training programme and provider, and a note of any staff members who need to undertake training. Refresher training should be carried out every two years by core staff and annually by Children’s Books Ireland Book Doctors and Children’s Books Ireland Book Clinic administrators, whose roles involve a high level of contact with children.

We are committed to being open with parents/guardians and all primary carers.

As we are a child-centered organisation we are committed to putting the interest of the child/young person first. To that end we will:

• Contact Tusla/Gardaí if there is a child safeguarding concern 
• Expect parents/guardians/caregivers to work in partnership with us under the guidelines set out by our organisation to ensure the safety of their children 
• Appoint a relevant person and Designated Liaison Person who is available for consultations. If the DLP is not available, the Deputy DLP will be responsible for acting in their stead.

We undertake to:

• Make parents/guardians/caregivers aware of our Child Protection Policy
• Inform parents/guardians/caregivers and schools of all activities and potential activities
• Issue contact/consent forms where relevant
• Comply with health and safety practices
• Operate child-centered policies in accordance with best practice
• Adhere to our recruitment guidelines
• Ensure as far as possible that the activities are age appropriate
• Encourage and facilitate parent/guardian/caregiver involvement where appropriate

If we have concerns about the welfare of the child/young person we will:

• Respond to the needs of the child or young person
• Inform the parents/guardians/caregivers on an ongoing basis unless this action puts the child or young person at further risk
• Where there are child protection and welfare concerns, we are obliged to pass these on to Tusla and/or the Gardaí
• In the event of a complaint against a member of staff/volunteer/artist/intern we will immediately ensure the safety of the child/young person and inform parents/guardians/caregivers as appropriate

Children’s Books Ireland has appointed a relevant person. As defined in the Children First Act 2015, this ‘means a person who is appointed by a provider of a relevant service to be the first point of contact in respect of the provider’s Child Safeguarding Statement’. Children’s Books Ireland’s procedure for appointing a relevant person is to take into account which member of staff is most knowledgeable in the area of child safeguarding and is most familiar with Children’s Books Ireland’s Child Safeguarding Statement.

Children’s Books Ireland has appointed a Designated Liaison Person (DLP) in keeping with best practice in child safeguarding. This person is the resource person for any staff member or volunteer who has child protection concerns and will liaise with outside agencies. The DLP is knowledgeable about child protection and will be provided with any training considered necessary to fulfil this role.

The DLP is responsible for ensuring that reporting procedures are followed, so that child welfare and protection concerns are referred promptly to Tusla.

Children’s Books Ireland has appointed a Deputy DLP who will assume responsibility when the DLP is not available or on leave.

The relevant person is: Elaina Ryan, CEO elaina@childrensbooksireland.ie / 01 872 7475

The DLP is Elaina Ryan, CEO elaina@childrensbooksireland.ie / 01 872 7475

The Deputy DLP is Jenny Murray, Deputy CEO jenny@childrensbooksireland.ie / 01 872 7475

The DLP will be available on-call. In the absence of the DLP, due to illness or holiday, the Deputy DLP will be on-call on the same basis. In cases where it is inappropriate for the DLP to investigate issues, i.e. an allegation against the DLP, the Deputy DLP, supported by the Chairperson of Children’s Books Ireland, will take on the role of DLP.

Role of Designated Person

• Receives and considers all child protection concerns and decides whether reasonable grounds for reporting to Tusla exist
• Records all allegations of child abuse or other concerns as well as any action/inaction taken in response to same
• Liaises with appropriate authorities in Tusla and An Garda Síochána
• Ensures Children’s Books Ireland policy and procedures relating to child protection are followed
• Ensures Children’s Books Ireland’s reporting procedures are followed so that any concerns are relayed promptly to Tusla
• Consult informally with a Tusla Duty Social Worker if necessary 
• Provides information and advice on protection and welfare at Children’s Books Ireland
• Manages referrals to Tusla, with adequate confidential information
• Provides feedback to the referrer, as appropriate
• Informs the child’s parents/guardians/caregivers if a referral is to be made to Tusla, unless:
  • Informing the parents/guardians/caregivers is likely to endanger the child or young person
  • Informing the parents/guardians/caregivers is likely to place the DLP as reporter at risk of harm
  • The family’s knowledge of the report could hinder Tusla’s ability to carry out their assessment
• Consults with management and Chairperson of Children’s Books Ireland with regard to child protection
• Ensures confidentiality/safe recording of child protection issues and of individual case histories
• Provides advice on child protection training needs
• Maintains training and awareness of child protection issues to keep updated on new developments and to be fully aware of Children’s Books Ireland’s duties in relation to the safeguarding of children
• Where requested, jointly reports with a mandated person

Mandated persons

The Children First Act 2015 places a legal obligation on certain people, many of whom are professionals, to report child protection concerns at or above a defined threshold to Tusla – Child and Family Agency. These mandated persons must also assist Tusla, on request, in its assessment of child protection concerns about children who have been the subject of a mandated report. Mandated persons are people who have contact with children and/or families who, by virtue of their qualifications, training and experience, are in a key position to help protect children from harm. Mandated persons include key professionals working with children in the education, health, justice, youth and childcare sectors. Certain professionals who may not work directly with children, such as those in adult counselling or psychiatry, are also mandated persons. The list also includes registered foster carers and members of the clergy or pastoral care workers of a church or other religious community. The Children First Act 2015, Schedule 2, provides a full list of people who are classified as mandated persons. At present, Children’s Books Ireland has no mandated persons in its employ.

Children’s Books Ireland is committed to ensuring people’s rights to confidentiality and is aware of its obligations under GDPR. However, in relation to child protection and welfare we undertake that:

• Information will be forwarded to the relevant authorities on a ‘need to know’ basis in order to safeguard the young person. Information about an incident should only be divulged if it is needed to remove the child from harm. Children’s Books Ireland will not discuss this incident with anyone other than those who need to know.
• Children’s Books Ireland cannot guarantee total confidentiality where the best interests of the child are at risk.
• Primary carers and children have a right to know if personal information is being shared and/or a report is being made to Tusla or An Garda Síochána, unless doing so could put the child at further risk.
• All information relating to children protection incidents will be stored appropriately and securely in Children’s Books Ireland’s offices.

Rules to guide use of photography and video

Any recording or photography at Children’s Books Ireland events must be undertaken with the consent of both the young person and their parent/guardian/caregiver.

• For events where children are attending as part of a school or other group, signed consent forms will be sought from all participants via their group leader. For example, where a class are attending an event, consent forms will be sent in advance to the group leader for distribution to parents/guardians/caregivers.
• For events where children are attending as individuals and where places are booked in advance, parental consent forms will be distributed to all participants in advance.
• For events where children are attending as individuals but where places are not booked in advance, notices will be displayed at the event and at any information or ticketing stand, informing participants that photographs or video may be taken at the event.
• Any photographer documenting events for Children’s Books Ireland will be clearly identified to artists and event staff.
• Where a selection of participants are asked to participate in a photograph e.g. a media photocall, permission must be sought from the accompanying adult before a young person is moved to a different location. A member of the event team must accompany the young people and return them to the group as soon as photography is completed. Children and young people should not be left unaccompanied with any one adult at a time e.g. Children’s Books Ireland staff member, artist, photographer, videographer, volunteer or intern.
• To reduce the risk of inappropriate use, Children’s Books Ireland will only use images of young people in suitable dress. The content of the photograph should focus on the activity, not on a particular child.

The use of inappropriate images should be reported to the DLP

Definition and Recognition of Child Abuse (as detailed in Children First, chapter 2)

Child abuse can be categorised into four different types: neglect, emotional abuse, physical abuse and sexual abuse. A child may be subjected to one or more forms of abuse at any given time.

In the Children First: National Guidance, ‘a child’ means a person under the age of 18 years, excluding a person who is or has been married.

Definition of ‘neglect’ – Neglect can be defined in terms of an omission, where the child suffers significant harm or impairment of development by being deprived of food, clothing, warmth, hygiene, intellectual stimulation, supervision and safety, attachment to and affection from adults, and/or medical care.

Harm can be defined as the ill-treatment or the impairment of the health or development of a child. Whether it is significant is determined by the child’s health and development as compared to that which could reasonably be expected of a child of similar age.

Neglect generally becomes apparent in different ways over a period of time rather than at one specific point. For example, a child who suffers a series of minor injuries may not be having his or her needs met in terms of necessary supervision and safety. A child whose height or weight is significantly below average may be being deprived of adequate nutrition. A child who consistently misses school may be being deprived of intellectual stimulation.

The threshold of significant harm is reached when the child’s needs are neglected to the extent that his or her well-being and/or development are severely affected.

Definition of ‘emotional abuse’ – Emotional abuse is normally to be found in the relationship between a parent/guardian/caregiver and a child rather than in a specific event or pattern of events. It occurs when a child’s developmental need for affection, approval, consistency and security are not met. Unless other forms of abuse are present, it is rarely manifested in terms of physical signs or symptoms.

Examples may include:

1. the imposition of negative attributes on a child, expressed by persistent criticism, sarcasm, hostility or blaming;
2. conditional parenting in which the level of care shown to a child is made contingent on his or her behaviours or actions;
3. emotional unavailability of the child’s parent/guardian/caregiver;
4. unresponsiveness of the parent/guardian/caregiver and/or inconsistent or inappropriate expectations of the child;
5. premature imposition of responsibility on the child;
6. unrealistic or inappropriate expectations of the child’s capacity to understand something or to behave and control himself or herself in a certain way;
7. under- or over-protection of the child;
8. failure to show interest in, or provide age-appropriate opportunities for, the child’s cognitive and emotional development;
9. use of unreasonable or over-harsh disciplinary measures;
10. exposure to domestic violence;
11. exposure to inappropriate or abusive material through new technology.

Emotional abuse can be manifested in terms of the child’s behavioural, cognitive, affective or physical functioning. Examples of these include insecure attachment, unhappiness, low selfesteem, educational and developmental underachievement, and oppositional behaviour. The threshold of significant harm is reached when abusive interactions dominate and become typical of the relationship between the child and the parent/guardian/caregiver.

Definition of ‘physical abuse’ – Physical abuse of a child is that which results in actual or potential physical harm from an interaction, or lack of interaction, which is reasonably within the control of a parent or person in a position of responsibility, power or trust. There may be single or repeated incidents.

Physical abuse can involve:

1. severe physical punishment;
2. beating, slapping, hitting or kicking;
3. pushing, shaking or throwing;
4. pinching, biting, choking or hair-pulling;
5. terrorising with threats;
6. observing violence;
7. use of excessive force in handling;
8. deliberate poisoning;
9. suffocation;
10. fabricated/induced illness (see Appendix 1 for details);
11. allowing or creating a substantial risk of significant harm to a child.

Definition of ‘sexual abuse’ – Sexual abuse occurs when a child is used by another person for his or her gratification or sexual arousal, or for that of others. Examples of child sexual abuse include:

1. exposure of the sexual organs or any sexual act intentionally performed in the presence of the child;
2. intentional touching or molesting of the body of a child whether by a person or object for the purpose of sexual arousal or gratification;
3. masturbation in the presence of the child or the involvement of the child in an act of masturbation;
4. sexual intercourse with the child, whether oral, vaginal or anal;
5. sexual exploitation of a child, which includes inciting, encouraging, propositioning, requiring or permitting a child to solicit for, or to engage in, prostitution or other sexual acts. Sexual exploitation also occurs when a child is involved in the exhibition, modeling or posing for the purpose of sexual arousal, gratification or sexual act, including its recording (on film, video tape or other media) or the manipulation, for those purposes, of the image by computer or other means. It may also include showing sexually explicit material to children, which is often a feature of the ‘grooming’ process by perpetrators of abuse.
6. consensual sexual activity involving an adult and an underage person. In relation to child sexual abuse, it should be noted that, for the purposes of the criminal law, the age of consent to sexual intercourse is 17 years for both boys and girls. An Garda Síochána will deal with the criminal aspects of the case under the relevant legislation.

It should be noted that the definition of child sexual abuse presented in this section is not a legal definition and is not intended to be a description of the criminal offence of sexual assault.

Procedure for Dealing with Concerns/Suspicion of Abuse

Staff, volunteers, interns and artists working with young people must share their concerns about child protection or child welfare with the DLP or, if the concern relates to the DLP, with the Chairperson of Children’s Books Ireland.

Information that staff, volunteers, interns and artists should record in relation to children and young people:

• suspicions
• concerns
• worrying observations
• behavioural changes

Reasonable Grounds for Concern

The statutory authorities must be informed when a person has reasonable grounds for concern that a young person may have been abused, is being abused, or is at risk of abuse. The following examples constitute reasonable grounds for concern:

• Specific indication from the young person that she/he was abused
• An account by the person who saw the young person being abused
• Evidence such as injury or behaviour, which is consistent with abuse and unlikely to be caused in another way
• Consistent indication, over a period of time that a child is suffering from emotional or physical neglect. (It should be noted that Children’s Books Ireland staff, volunteers, interns and artists will rarely be in an appropriate position to make informed judgments regarding this ground for concern. Any queries or concerns in this regard should be discussed and actions authorised through the DLP.)

Procedure for Dealing with a Disclosure or Allegation

It is important that allegations are handled in a sensitive and discreet manner. Any response to a child making an allegation should take the following into consideration:

• Actively listen to the child, ensuring that they feel heard
• Inform the child of your duty to report their disclosure as early as possible in the conversation. Never agree to keep the disclosure secret.
• React calmly; overreaction may intimidate the child and increase any feelings of guilt.
• Reassure the child that it was right to tell someone what happened
• Be careful when asking questions. Conversation should be supportive and for the purpose of clarification. Never ask leading questions.
• Do not express any opinions about the alleged abuser to the child.

Procedure for the reporting of child protection or welfare concerns to Tusla

• Record the concern, including the date, time and people involved in the concern/disclosure and the facts in Children’s Books Ireland’s incident book and directly to the DLP. Information recorded should be factual. Any opinions recorded should be supported by facts.
• Inform the DLP or if unavailable the Deputy DLP.
• The most appropriate person should discuss the concern with parents/guardians/caregivers where necessary. Parents/guardians/caregivers should be told of a report to Tusla or An Garda Síochána unless it is likely to put the child/young person at further risk or put the reporter at risk from the family.
• The DLP may contact a Tusla Duty Social Worker for an informal consultation prior to making a report.
• Concerns should be reported in person, by telephone or in writing to the local social work duty service in the area where the child lives. Contact details for local social work teams are available on the Tusla website.
• Tusla has two forms for reporting child protection and welfare concerns – the Child Protection and Welfare Report Form (CPWRF) and the Retrospective Abuse Report Form (RARF). The Child Protection and Welfare Report Form is to be completed and submitted to Tusla for concerns about children under the age of 18. A web portal has been developed to allow for the secure submission of CPWRFs to Tusla. The Retrospective Abuse Report Form is to be completed and submitted to Tusla for cases of adults disclosing childhood abuse. It is not currently possible to submit RARFs using the web portal. Both the CPWRF and RARF can be downloaded here. If using a hardcopy CPWRF or RARF, the completed form should be sent to the Duty Social Work team in the area where the child resides. Both forms can be found on the Tusla website.
• Information will be shared on a strictly ‘need to know’ basis.
• Reports will be made to Tusla without delay. If the DLP/Deputy DLP is not available then staff should contact the Chairperson of Children’s Books Ireland or in exceptional circumstances, Tusla directly.
• In emergencies, which are out of Tusla hours, contact the Gardaí. There may be extreme situations, which threaten the immediate safety of a child/young person where it may be necessary to contact the Gardaí.

Out-of-hours Emergencies

Any out-of-hours emergencies should be reported immediately to the DLP, or the Deputy DLP who will then decide whether to contact An Garda Síochána or Tusla where appropriate.

Concerns not requiring Tusla referral

The DLP will decide whether or not to refer matters to Tusla, recording their decision.

Any matters not referred to Tusla should be noted in Children’s Books Ireland’s incident book, along with any decisions made, and should be signed by the DLP and the Chairperson of Children’s Books Ireland.

The DLP will inform the staff member, volunteer, intern or artist in writing of any decision not to refer to Tusla.

If any staff member, volunteer, intern or artist feels uncomfortable with a decision made in this context, they have the right and responsibility to file a report of their own.

In the event of an allegation against an employee/volunteer/intern/artist:

There are two separate procedures to be followed:

1. The reporting procedure in respect of the child/young person
2. The procedure for dealing with the worker

The DLP will deal with issues related to the child/young person in accordance with Children’s Books Ireland’s reporting procedure and legal obligations under the Children First Act. The Chairperson of Children’s Books Ireland will deal with issues related to the worker in accordance with Children’s Books Ireland’s reporting procedure and legal obligations under the Children First Act as well as employment law.

• The first priority is to ensure that no child or young person is exposed to unnecessary risk; in the case of an allegation, Children’s Books Ireland will take protective measures in the interests of the child. Protective measures do not presume guilt but will be put in place as a matter of urgency to put the child’s welfare first.
• If allegations are made against the DLP, the disclosure should be made to the Deputy DLP, who should immediately contact the Chairperson of Children’s Books Ireland for support. The Deputy DLP will be responsible for referring the allegation to Tusla, while the Chairperson will be responsible for dealing with the DLP.
• Parents/guardians/caregivers and children (if of an appropriate age) should be informed of actions planned and taken.
• The employee/volunteer/intern/artist will be informed privately as soon as possible
  • that an allegation has been made against him/her
  • the nature of the allegation
• The employee/volunteer/intern/artist should be given the opportunity to respond.
• Any action following an allegation of abuse against an employee should be taken in consultation with Tusla and/or An Garda Síochána. Tusla will not advise on employment matters but an advise in relation to child welfare and risk management.
• Any action taken should not undermine the ability of Tusla and/or An Garda Síochána to investigate the allegation.

In the event of a complaint or comment from a participating child, young person or their parent/guardian/caregiver

• Complaints and comments will be logged in the incident book, which is stored at the desk of the DLP
• Reports of complaints should include contact details of the person making the complaint, an outline of the complaint as well as details of the response of staff members present
• Complaints will be responded to within three days
• All staff members have responsibility for directing complaints/comments to the DLP
• Verbal complaints will be responded to at the time of complaint and all details will be logged in the incident book
• Anyone who makes a verbal complaint should be encouraged to submit details of their complaint in writing also

• Any accidents which take place must be logged in Children’s Books Ireland’s incident book, including a full report of the circumstances
• Children’s Books Ireland’s first aid boxes are available in the Children’s Books Ireland store cupboard, and are regularly restocked
• The incident book is stored at the DLP’s desk
• Staff should ensure that children and young people are aware of risks of dangerous material in relation to workshops and other appropriate events
• Details of Children’s Books Ireland’s public liability insurance will be made available to venues for Children’s Books Ireland’s events