Child Protection Policy

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Purpose

  1. This policy states the principles that govern how Sparrows cares for a child and keeps a child safe. It states each principle in full.
  2. Regulation 87(3) of the General Regulations Regarding Children, 2010 says the management board is responsible for the approval of policy. The Board therefore approves this policy, and every policy that applies it, itself. Approval is not an administrative sign-off presented to the Board as a formality.

The Best Interests of the Child

  1. The best interests of the child are of paramount importance in every matter concerning a child in Sparrows' care (Children's Act, 2005, section 9). Where any Sparrows policy, or any decision taken under it, appears to conflict with a child's best interests in a particular case, the best interests of that child prevail.

No Exclusion, No Punishment

  1. Sparrows never excludes, punishes, or expels a child from its care. This is Sparrows' single most important child protection principle, and no exception to it exists anywhere in Sparrows' policies or practice. Any misbehaviour by a child in Sparrows' care is addressed through disciplinary action and rehabilitative support, never through exclusion.
  2. No other policy, now or in future, may create an exception to this principle without first amending this policy.
  3. Sparrows keeps a Discipline Register, recording every instance of a child's misbehaviour and the corrective measure used in response — never a punishment, consistent with §3.1. A Child and Youth Care Worker makes the entry at the time, and the Senior Child and Youth Care Worker holds the Register. An entry records the child, the behaviour, and the corrective measure applied.
  4. Sparrows' approach to a child's behaviour is restorative and needs-based: addressing what the child actually needs, not only correcting what they did, consistent with the principle at §3.1.
  5. Sparrows does not use physical restraint on a child. A staff member may use a brief, light touch to stop immediate physical harm — stepping between two children, guiding a child away from danger, catching a child who is falling — but does not hold a child down, restrain a child who is trying to get away, or use any method meant to control a child's body against their ongoing resistance. This is a deliberate position, not an unaddressed gap, and it applies without exception.
  6. Sparrows does not isolate a child from other children or from staff, except for medical reasons (General Regulations Regarding Children, 2010, regulation 76(2)(h)). Inviting a child to join an adult in another activity, so that the group can carry on, is not isolation if the adult stays with the child throughout, the child is not locked in or shut away, and it is never a punishment. The activity is an invitation and not a chore (regulation 76(2)(j)). It ends when the child is ready to return, and in any case within two hours. A use of isolation for any other reason is a reportable incident under the Emergency and Crisis Management Policy §4.2.

Zero Tolerance of Abuse, and Mandatory Reporting

  1. Sparrows has a zero-tolerance position on abuse of a child in its care, by anyone — staff, volunteer, visitor, or another child.
  2. Every person working with children at Sparrows is a mandatory reporter, and a concern that a child has been abused or neglected is reported as follows.
    1. Every employee and every volunteer, whatever their job title or role, must report under section 110(1) of the Children's Act, 2005 when they conclude, on reasonable grounds, that a child has been abused in a manner causing physical injury, sexually abused, or deliberately neglected. The duty does not require proof or certainty.
    2. The report is made in the prescribed form to a police official, the provincial Department of Social Development or a designated child protection organisation, and the person must substantiate their conclusion to the body they report to (section 110(3)(a)). A report to a colleague or supervisor at Sparrows does not discharge the duty. A person who reports in good faith is not liable to a civil action on the basis of the report (section 110(3)(b)).
    3. Any person, including a Board member, contractor, tutor or visitor, who has knowledge, reasonable belief or suspicion that a sexual offence has been committed against a child must report it immediately to a police official (Criminal Law (Sexual Offences and Related Matters) Amendment Act, 2007, section 54(1)). Failing to report is an offence (section 54(2)(a)). This duty is separate from, and in addition to, §4.2.1 and §4.2.2.
    4. A person makes every report under this clause immediately.
    5. Alongside the external report, the person reports the matter inside Sparrows as the Emergency and Crisis Management Policy §4.2 and §4.3 require. An internal report does not replace an external one.
    6. Where the person suspected is an employee, the Disciplinary Code and Procedure runs separately and neither delays nor replaces these duties (§1.3 and §6.2 of that Code).

Safe Recruitment and Vetting

  1. Nobody starts work in a position that involves contact with a child in Sparrows' care until they meet the checks in the Safe Recruitment Policy and, where the role needs registration, the Fit and Proper Person Standard. This covers an employee, a volunteer, a Board member, and a contractor or tutor who works with children on an ongoing basis. Anyone else who comes onto the property is covered by §7. Safe recruitment is a child protection control, not merely a human resources formality.

A Child's Right to Be Heard

  1. A child in Sparrows' care has the right to be heard on matters affecting them (Children's Act, 2005, section 10), and the right to complain about their own care, treatment, or a member of staff, without fear of consequence for having complained. This right is given practical effect through the Children's Forum and the Children's Complaints Procedure, which is a child's own route to complain, distinct from the staff Grievance Policy.

Visitors and Other Third Parties

  1. A staff member keeps a visitor in sight for the whole of a visit. The staff member does not need to stand right beside the visitor, but the visitor is never out of view. This protects both the child and the visitor, applies to every visitor covered by the Perimeter Security Policy §1.2, and applies in addition to, not instead of, that policy's sign-in requirement. It does not apply to an official of the Department of Social Development carrying out monitoring or an inspection (Perimeter Security Policy §3.2.6).
  2. A visitor does not enter a child's bedroom or other private living space, unless on a guided tour of the facility. This is a safeguarding boundary, not a perimeter-security or access-control matter, which is why it is stated here rather than in the Perimeter Security Policy.

Relationship to Sparrows' Other Children's Services Policies

  1. This policy states principle. The other policies that govern a child's care state how those principles apply at each stage of a child's time at Sparrows, from admission through daily life to discharge and aftercare, and to specific subjects (nutrition, education and the use of a child's image) that this policy does not detail. Where another policy conflicts with this policy, this policy's principles govern, and the Board amends the other policy to match.

Review

  1. This policy is reviewed annually by the Board.