Shaqodoon Child and Adult Safeguarding Policy

Safeguarding principle 

Shaqodoon safeguarding principle is based on the international best practice and local culture that meet the following principle:

  1. Shaqodoon’s primary consideration is the best interests of child in all interventions, activities or interactions concerning children. Shaqodoon will ensure the decisions, interventions and interactions with children will not harm them or affect them in a negative way, even in situations where adults must make decision for children to protect them from harm.

  2. Shaqodoon will ensure the protection of the adults’ beneficiaries, its staff and people associated with the delivery of its interventions from abuse, exploitation, violence and the power misuse of its management, staff and external people involved with the service delivery to inflict harm upon adult beneficiaries and children.

  3. Shaqodoon has a zero-tolerance approach to child and adult abuse and exploitation. This is enacted via robust prevention and response work, offering support to survivors, and holding those responsible for harm and intolerable behaviour to account.

  4. Shaqodoon will ensure full accountability and transparency through rigorous reporting and complaints mechanisms for any misconducts or violations that occur under the banner of our organisation, including by any people associated with our interventions (in line with privacy regulations and within legal framework).

  5. It will ensure all relevant people have access to information about procedures and steps concerning how to report the allegations of child and adults’ exploitation, abuse, or other breaches of this policy.

  6. Shaqodoon designate specific child safeguarding roles and responsibilities to effectively embed a child and adult safe organisational practice across all programs, operations and activities.

  7. Shaqodoon will ensure child safeguarding risks are identified, monitored, and mitigated when planning of a new intervention or during the implementation of the intervention to prevent the risk of children and adults being abused, exploited, or harmed.

  8. Shaqodoon is committed to confidentiality in sharing sensitive information in relation to incidents reported to us. Information that identifies individuals will only be shared with due consideration to the safety of the child, adult, witnesses, or subject of complaint, or to protect the integrity of an investigation.

  9. Failure to follow Shaqodoon Safeguarding behaviour Protocols, failure to follow any other part of the Shaqodoon Safeguarding Policy, other inappropriate behaviour toward children or adult beneficiaries, or failing to report a known or suspected safeguarding incident committed by a Shaqodoon employee or affiliate, is grounds for discipline, up to and including termination of the employment or other affiliation with Shaqodoon.

  10. Shaqodoon will ensure the victims both children and adult who have suffered harm abuse or exploitation, regardless of whether a formal internal response is carried out (such as an internal investigation).

Minimum standard for Safeguarding policy

This minimum standard for child and adult safeguarding is applicable on Shaqodoon’s Personnel, external people associated directly or indirectly with its intervention (community committees, social media ambassadors, diaspora, host companies, contractors, and other peer organizations) will:

The Shaqodoon’s Safeguarding policy pertains to any interactions with children or with adult beneficiaries including personal data about such persons, will comply with the policy.

  1. Any incidents of harm or risk of harm to children or to adult beneficiaries will be reported immediately to Shaqodoon by following the reporting procedure

  2. Any individuals with access to children or adult beneficiaries, or to personal data about such persons, will provide, to the extent permitted by law, evidence for a current clean criminal for offences against children or abuse of adults, (where it is possible upon Shaqodoon` request)

  3. The safeguarding principles and procedures will be clearly communicated to, and acknowledged by, all employees who may have access to children or to adult beneficiaries including personal data about such persons.

  4. The safeguarding principles will be extended in identical form to associated people (if any are authorized) who engaged or interact with children and adult under the banner of Shaqodoon. Agreements with other parties (communities, community organizations, individuals or peer organizations, hosting organization for internship, social media ambassadors) referred to as hereafter other parties, When engaging with other parties, the agreement (whether referred to as an ‘agreement’ ‘Memorandum Of Understanding’, or any other term), specifies, prior of the operation, the provision of safeguarding policy and procedures to Shaqodoon and approved by Shaqodoon as appropriate for the intervention at issue.

  5. Alternatively, the other party can agree to follow Shaqodoon’s Safeguarding Policy in carrying out the activities. The agreement must ensure that any of the other party’s personnel working with the Shaqodoon’s intervention will not/ have not been involved with any criminal offences against children and abuse of adults (where it is possible, Shaqodoon may require, to the extent permitted by law, the provision of evidence for a current clean criminal for offences against children or abuse of adults.

  6. All Shaqodoon employees, interns and other people associated with the interventions sign an acknowledgement that they know, understand, and will follow this Safeguarding Management Policy. Signed agreements are kept on file by the Shaqodoon head office.

  7. Orientation: All Shaqodoon employees, and interns.as well as contractors’ employees or other parties engaging directly or indirectly with a Shaqodoon’s intervention, receive safeguarding orientation at the start of employment or engagement. Shaqodoon employees and interns receive periodic refresher or other safeguarding orientation at least once every two years thereafter.

  8. Contractors engaged in situations where they—or their employees or subcontractors—may have access to children or adult beneficiaries in Shaqodoon programs or may have access to personal data about such children or adult beneficiaries, a copy of the Safeguarding Behaviour Protocols must be attached to the contract. These requirements apply whether the Contractor is being paid for the services or is providing them for free (‘pro bono’) and is irrespective of the duration of the contract. ‘In the course of performing this contract, Contractor and Contractor’s employees will ensure that: the contractor will apply the principles and the minimum standard for child and adult Safeguarding.

  9. Shaqodoon addresses safeguarding in job advertisements (when feasible), applications, interviews, and references.

  10. when feasible Safeguarding screening measures are applied to all candidates for employment, volunteers, interns and individual contractors who will have access to children or adult beneficiaries or to their personal data.

  11. Relevant grant terms and regulations should be checked and (where it is possible) followed for specific screening requirement by the major grant donor for the work they fund.

Minimum Acceptable Behaviours 

Minimum Safeguarding Behaviour Protocols that apply to Shaqodoon’s employees, interns, people associated with the delivery of its interventions and contracts to behave in ways that promote the best interest of the children and protect the adults including its staff and adult beneficiaries from any kind of violations. Any Shaqodoon staff and other relevant people associated with its delivery are required to sign the minimum acknowledge in writing the receipt and understanding of these Safeguarding behaviour Protocols. Rules for acceptable behaviour are based on international best practice and local culture which meets or exceeds the following minimum protocols:

Shaqodoon must create and maintain an environment which promotes the implementation of the acceptable Behaviour Protocols; and which prevents any kind of violations and abuse against children and adult beneficiaries of Shaqodoon’s intervention.

  1. the employees of Shaqodoon and other relevant people must be careful about perception and appearance in their language, actions and relationships with children and vulnerable beneficiaries. Their Behaviour — including in person and on digital platforms, both online and offline— demonstrates a respect for children and adult beneficiaries and their rights.

  2. the Shaqodoon’s employees and other relevant people must ensure that all physical and online contact with children and beneficiaries is appropriate in the local culture.

  3. The Shaqodoon’s employees and other relevant people must use positive, non-violent methods to manage children’s behaviour.

  4. The Shaqodoon’s employees and other relevant people must accept responsibility for personal behaviour and actions as a representative of the organization.

  5. The Shaqodoon’s employees and other relevant people are always accountable for their response to a child’s behaviour, even if a child behaves in a sexually inappropriate manner; adults avoid being placed in a compromising or vulnerable position with children.

  6. where possible and practical, follow the ‘two-adult’ rule while conducting Shaqodoon work, wherein two or more adults supervise all activities that involve children, and are visible and present at all times.

  7. The Shaqodoon’s employees and other relevant people must comply with safeguarding related investigations (internal and external) and make available any documentary or other information necessary for the completion of the investigation.

  8. The Shaqodoon’s employees and other relevant people must comply with applicable data privacy laws and with relevant Shaqodoon data privacy and information security policies, including Shaqodoon digital child safeguarding protocols, when handling any personal data about individual children or adult beneficiaries, noting in general that collecting or using such data must be limited to the minimum necessary, and that such data must be maintained and transferred in a secure, confidential manner.

  9. immediately report through established reporting mechanisms any known or suspected safeguarding incident or breach of this Policy by a Shaqodoon employee or affiliate, or an employee from any other agency (See Section 6.5.1 on how to report).

Minimum Unacceptable Behaviour

The following minimum standards are the unacceptable Behaviour that Shaqodoon employees and other relevant people must not do:

Behave in an inappropriate physical manner or develop a sexual relationship with a child (under 18 years old), regardless of the local specific legal age of consent or age of majority. This also includes consenting or condoning the above behaviour (including fostering or condoning child marriage (under 18 years old)

  1. Develop or seek a sexual relationship with any beneficiary of any age; such relationships are not acceptable and will not be tolerated since they are based on inherently unequal power dynamics. Such relationships undermine the credibility and integrity of Shaqodoon's work.

  2. Sexually exploit or abuse any beneficiaries (adult or child); such behaviour constitutes an act of gross misconduct.

  3. Exchange money, employment, goods, or services for sex (including sexual favours, other forms of humiliating, degrading, or exploitative behaviour, or hiring sex workers) or other exploitative demands is strictly prohibited. This includes exchange of assistance that is already due to beneficiaries.

  4. Fondle, hold, kiss, hug or touch children or adult beneficiaries in an inappropriate or culturally insensitive way.

  5. Use language, make suggestions or offer advice to a child or adult beneficiary which is inappropriate or abusive, including language that causes shame or humiliation, or is belittling or degrading; g) Spend excessive or unnecessary time alone with a child or adult beneficiary, away from others or behind closed doors or in a secluded area.

  6. Condone or participate in behaviour with children or adult beneficiaries which is illegal, unsafe or abusive, including harmful traditional practices, spiritual or ritualistic abuse.

  7. Hire children in any form of child labour (including as “house help”) unless it is within the best interest of the child and in alignment with local law and international standards (‘Child labour’ is work that is mentally, physically, socially or morally dangerous and harmful to children, or that interferes with their schooling. ‘Child work’ in contrast may be beneficial if permitted by International Labour Organization (ILO) Conventions and puts the child’s interests ahead of any benefits gained by adults.);

  8. Hit or use other corporal punishment against a child while the child is in Shaqodoon care or the Shaqodoon employee or affiliate is conducting Shaqodoon work;

  9. Take a child alone in a vehicle for Shaqodoon work, unless it is absolutely necessary, and with parental/guardian and managerial consent.

  10. Misuse or be careless with personal data about individual children or adult beneficiaries.

  11. Communicate with a child in Shaqodoon's program areas via digital platforms (e.g. Facebook, Twitter), via mobile technology (e.g. texting, Whatsapp, Skype), or online without consent and knowledge of his/her parents. Further, Shaqodoon employees or affiliates never communicate on mobile, digital or online platforms with children or adult beneficiaries in ways that are inappropriate or sexual.

  12. Stay silent, cover up, or enable any known or suspected safeguarding incident or breach of Safeguarding Policy by a Shaqodoon employee or affiliate.

Minimum requirement for visiting the field

People going to a Shaqodoon field program or meeting with a Shaqodoon beneficiary children and adult must meet the minimum requirement for the safeguarding which are based on the best practices of international NGOs and these include:

Unannounced visits to sponsored children or Shaqodoon project communities are not permitted.

  1. visits by all private donors (diaspora, businessmen/women) and social media and goodwill ambassadors are pre-approved by the Shaqodoon, where it is feasible, will be required to bring evidence for current clean criminal offence for child and adult (where permitted by law).

  2. The hosting office of Shaqodoon provides a brief orientation to any distinctive Safeguarding behaviour Protocols that apply in that context, as well as local customs regarding adult interaction with children.

  3. Non-employee visitors are accompanied by a Shaqodoon employee when visiting projects.

  4. Shaqodoon will ensure prior to the visit that all visitors who are external to Shaqodoon’s staff are briefed on minimum standards of Safeguarding policy and are fully aware of Safeguarding Behaviour Protocols and the signed acknowledgement is kept on file by the Shaqodoon. This will not be required if a Shaqodoon is accompany the visitors.

Minimum standards for Communications, social media and Digital Technology

Shaqodoon’s practice regarding the use of personal data are based on both the international best practice and local traditions that allow or restrict the use or reuse of personal data including but not limited to personal images, photographic or filming a subject. The minimum requirement for communication for the digital and traditional technology must be followed include: 

Collected data shall be adequate, relevant and not excessive in relation to the purposes for which they are obtained and their further processing.

  1. Individual data can be collected upon voluntary consent of the person concerned.

  2. Personal data can be processed only for the purpose that was defined before the data was collected. Personal data shall be obtained for specified, explicit and legitimate purposes, and shall not subsequently be processed in a manner that is incompatible.

  3. When processing personal data, the individual rights of the data subjects must be protected. Personal data must be processed in a legal and fair manner.

  4. Shaqodoon ensures data processed represent are real context and facts.

  5. In all forms of communication, children and adult beneficiaries are treated and portrayed with dignity and not as helpless victims or in sexually suggestive poses.

  6. children or adult beneficiaries must provide informed consent for primary subjects of text, photo and/or video resource that will be gathered or used by Shaqodoon in a way or another. If the primary subject is a child, written consent is also collected from the parent, guardian, or other legally required entity or individual. In the following situations, written consent is collected from the child (as appropriate for age) or adult beneficiary:

  7. the subject (person) must be informed about his/her data is being handled and the purpose of collecting and processing data and categories of third parties to whom the data might be transmitted.

  8. has to a general understanding of the purpose for collecting data, photographs, and videos etc.

  9. Personal child and adult beneficiary information that is captured, stored or sent through electronic, on-line or mobile devices is protected.

  10. In the following situations, the identity of the subject must be concealed:

  • the consequence is harmful when a child/adult beneficiary is personally identified.

  • the photo tagging with the adult and child’s full name must not result identification of precise locations of the subject.

  • the sensitive nature of their personal disclosure or situation could possibly cause damage to their privacy, dignity, safety or reputation, or

  • where otherwise required by applicable law.

Minimum standards for data protection

Personal data on file must be correct, complete, and – if necessary – kept up to date. Suitable steps must be taken to ensure that inaccurate or incomplete data are deleted, corrected, supplemented, or updated.

  1. Shaqodoon should ensure the integrity and security of its data and take active steps to ensure that valuable digital equipment and more importantly, online information (such as personal data and records) are being adequately protected.

  2. Shaqodoon must take additional measures to prevent the use of the personal data for non-agreed purpose including copying of photographs without Shaqodoon permission.

Recognizing the special vulnerability of adults and children, material posted on social media or digital technology does not contain a child’s family name, sponsorship ID number, or child or adult’s personal location/address.

  1. Personal data is handled in accordance with Shaqodoon’s current information security standards for personal data (may include encryption and other requirements), international best practice and local regulations.

  2. Shaqodoon protects personal data on its websites, domains and social media platform profile pages.

  3. Personal data shall be retained in a form that allows the identification of the data subjects for a period no longer than is necessary for the purposes for which they are obtained and processed.

  4. The personal data of backer lists or contributors of fundraising should be protected in a way they are unidentifiable on the public interface.

  5. Only authorized staff should only have access to the personal data of the backer lists or contributors.

  6. The financial statements for the community bank accounts should be accessible only to authorized staff of Shaqodoon, for external use shall be approved by Shaqodoon Senior management.

  7. Shaqodoon may use beneficiary data for research purposes without the identification of personal data of individuals.

Incidents management 

International good practice, local laws and culture will guide the procedure for managing the violations inflicted upon the Shaqodoon staff, interns, the interns placed in other host companies, other people associated with the delivery of the Shaqodoon’s intervention, and the incidents inflicted upon the children and adult beneficiaries in Shaqodoon programs in ways that are prohibited by this policy, international good practice, or the local culture. The following incidents can frequently happen:

  1. Safeguarding Teams will offer support to adults and children who have suffered harm abuse or exploitation, regardless of whether a formal internal response is carried out (such as an internal investigation).

  2. Adults and children can choose if and when they would like to take up the support options available to them. Shaqodoon will connect them with the right service provider that supports and ensure the support is not sensitive to the child’s needs.

Reporting mechanism: Externally Facing Reporting Information

All Shaqodoon employees and beneficiaries are responsible and obligated to report any suspicions of child or adult beneficiary abuse (or other safeguarding concerns, including any violations of this Policy) that is connected to Shaqodoon or its programs.

any credible concern or suspicion of sexual abuse or exploitation by NGOs worker outside of Shaqodoon is immediately reported to the focal point.

  1. Shaqodoon is required to investigate and respond to reports of child or adult beneficiary abuse in Shaqodoon programs in ways which are consistent with local law.

  2. On all Shaqodoon website, social media pages, training centres, project locations and offices information should be provided for the general public, communities, and partners on how to raise a concern or complaint. Relevant email and phone contact details should also be provided.

  3. Complaint’s mechanisms should also be accessible to all individuals and structures that need to report an incident.

  4. Shaqodoon safeguarding is reported within 24 hours of the first notice incidents which puts children or adult beneficiaries in direct risk of potential harm, but where no actual harm is believed to have occurred.

  5. Response is implemented by the Head Quarters in Hargeisa with oversight by and accountability to the Shaqodoon Safeguarding Focal Point and support from the senior management.

  6. Shaqodoon safeguarding is reported actual or alleged Incidents within 24 hours of first notice.

  7. Response is implemented by the HR with oversight by and accountability to the Shaqodoon Safeguarding Focal Point. Where mandated by applicable law, relevant department managers are informed immediately in coordination with Shaqodoon Management. Executive Director will be informed and approves all actions.

Reports can be made by Shaqodoon employees or affiliates in the following ways: 

  1. Use Shaqodoon dedicated beneficiary feedback mechanism that was developed for any safeguarding incidents using short code 777 (Telesom and Golis) and 7788 (Somtel and Hormuud).

  2. Reach Shaqodoon Safeguarding focal point face to face at Shaqodoon HQ or via e-mail (to be provided in all training centres and workshops where visible).

  3. If confidentiality required/preferred or issue is the executive director of the organization, or if the above options are not available for whatever reason, contact Shaqodoon Board of Directors on bod@shaqodoon.org