SAFEGUARDING POLICY.
Organisation
Jurisdiction
Version
Adopted on
International Alliance for Integration & Sustainability (IAIS)
Malta and European Union
Template v1
1 January 2024
Contents
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Governance summary
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Safeguarding Policy
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Annex A. Safeguarding reporting procedure
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Annex B. Suggested implementation checklist
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References
1. Governance summary
This policy pack is intended for IAIS as a voluntary organisation operating in Malta and delivering activities that may involve staff, board members, volunteers, contractors, participants, minors, young adults, partner organisations, funders, and members of the public. It is structured so that the organisation can use one integrated compliance framework for privacy, child protection, adult safeguarding, safer recruitment, incident handling, and accountability.
The GDPR section establishes the internal rules for the lawful, fair, transparent, secure, and accountable processing of personal data. The safeguarding section establishes the organisation’s duty of care to prevent harm, respond to concerns, and create a safe, inclusive, and respectful environment during all organisational activities, including local activities, international mobilities, training courses, youth exchanges, study visits, online delivery, and one-to-one support.
This pack assumes that IAIS acts primarily as a data controller for its own operations and projects, although it may also act as a joint controller with partners or as a processor for specific delegated tasks. It also assumes that IAIS may work with children, young people, adults at risk, and people in vulnerable situations, and therefore should operate a higher standard of care than the legal minimum where circumstances require.
2. Safeguarding Policy
3.1 Statement of commitment
IAIS is committed to creating and maintaining an environment in which all children, young people, and adults at risk are safe, respected, listened to, and protected from abuse, neglect, exploitation,
discrimination, harassment, bullying, and any other form of harm.
Safeguarding is a collective responsibility. Every board member, employee, volunteer, consultant,
trainer, host, chaperone, and partner representative working with IAIS must act in the best interests of those we work with, prevent foreseeable harm, respond to concerns promptly, and respect the dignity, privacy, and rights of all persons.
3.2 Purpose and scope
This policy applies to all organisational activities, including in-person and online activities, meetings,
workshops, youth work, adult education, mentoring, outreach, research, recruitment, events, travel,
accommodation, social activities, communications, and partner-led actions where IAIS has responsibility or influence.
It applies to conduct occurring during official activities and also to related conduct outside the formal
programme where the person’s role, access, authority, or relationship arises from IAIS’s work.
3.3 Who this policy protects
This policy protects children and young people under the age of 18, and also adults at risk or in
vulnerable situations, including but not limited to people with disabilities, migrants, survivors of violence, people with health or mental health needs, people facing exploitation, people with limited support networks, and any participant whose circumstances increase exposure to harm.
IAIS recognises that vulnerability may be situational, temporary, intersectional, and shaped by power
imbalances. A person does not need to fit a formal category to be treated as requiring safeguarding
protections.
3.4 Definitions of harm
For the purpose of this policy, harm includes physical abuse, emotional or psychological abuse, sexual abuse, neglect, coercive control, financial exploitation, trafficking-related exploitation, online abuse, bullying, discriminatory abuse, peer-on-peer abuse, abuse of power, grooming, and exposure to unsafe environments. Safeguarding concerns may arise from a single incident, a pattern of behavior, a disclosure, an observation, a digital interaction, a risk indicator, or a third-party report.
3.5 Principles
IAIS will apply the following principles: welfare and safety first; zero tolerance for abuse and exploitation; listen and take concerns seriously; respond proportionately and promptly; maintain confidentiality on a need-to-know basis; work in partnership with families, authorities, and partner organisations where appropriate; document concerns accurately; and avoid victim-blaming or retaliatory behaviour.
The organisation will also embed inclusion, anti-discrimination, trauma awareness, accessibility, cultural sensitivity, and participation rights into safeguarding practice.
3.6 Safeguarding governance and roles
The Board shall appoint a Designated Safeguarding Lead and at least one Deputy or alternate. Their
names, contact details, and escalation routes must be circulated internally and included in operational documents.
The Designated Safeguarding Lead is responsible for receiving concerns, advising staff and volunteers, assessing immediate protective action, making referrals where appropriate, maintaining the safeguarding log, preserving confidentiality, liaising with authorities and partner organisations, and briefing the Board on serious incidents.
The Board shall retain strategic oversight and shall be informed of high-risk incidents, allegations against senior personnel, systemic safeguarding failures, or matters likely to create legal, regulatory, or reputational risk.
3.7 Code of conduct
All personnel must maintain professional boundaries, treat all participants with dignity and respect, avoid favouritism, use appropriate language and behaviour, and never exploit a role of trust.
Personnel must not engage in sexual activity or inappropriate relationships with minors, must not engage in sexually exploitative or coercive behaviour with any participant, must not exchange safeguarding support for personal favours, must not shame or humiliate participants, and must not communicate privately with minors outside approved channels unless this is explicitly authorized and risk-managed.
One-to-one meetings with minors or adults at risk should be avoided where possible and, when
necessary, should take place in observable, accountable, and risk-assessed settings. Overnight
arrangements, travel, room allocations, and transport must follow safer practice rules.
3.8 Safer recruitment and vetting
IAIS shall implement safer recruitment for all roles involving direct work with children, young people, or adults at risk. This should include role descriptions, safeguarding responsibilities, identity checks,
references where appropriate, interview questions on suitability, declaration of relevant concerns, and background checks as permitted or required by law.
Where Maltese law requires checks related to the Protection of Minors regime or similar vetting
arrangements, IAIS shall ensure these are obtained before engagement or before unsupervised access is permitted. The organisation shall also assess overseas clearances where this is proportionate and feasible for international staff or volunteers.
3.9 Risk assessment and safer programme design
Each activity shall be risk assessed before delivery. Risk assessments shall cover supervision levels,
travel, accommodation, room sharing, transport, free time, medical needs, accessibility, online platforms, photography, partner roles, emergency contacts, incident reporting, and escalation pathways.
International mobility activities shall include a designated welfare contact, participant codes of conduct, emergency procedures, medication and health disclosures on a need-to-know basis, and safeguarding arrangements agreed with host partners.
3.10 Online safeguarding and communications
Digital delivery, messaging, and social media use shall be managed safely. Only approved
communication channels shall be used for programme communication. Private messaging with minors should be avoided unless operationally necessary, authorised, and transparent.
Online sessions should have appropriate moderation, access controls, waiting rooms or equivalent
features where available, and rules on recording, chat behaviour, and screen sharing. Inappropriate
content, cyberbullying, grooming indicators, or online exploitation concerns must be reported in the same way as offline concerns.
3.11 Photography, filming, and storytelling
IAIS shall use images, stories, and participant testimonials in a way that protects dignity, privacy, and
safety. Content must never expose a participant to stigma, retaliation, exploitation, or avoidable
identification risk.
Media involving children or high-risk participants requires additional scrutiny. Full names, addresses,
travel details, immigration status, trauma history, or other sensitive details should not be published
unless there is a compelling lawful reason and appropriate safeguards.
3.12 Responding to a safeguarding concern
Anyone with an immediate concern must act without delay to protect the person from imminent harm and seek emergency assistance where necessary. As soon as practicable, the concern must be reported to the Designated Safeguarding Lead or Deputy.
The person receiving a disclosure should stay calm, listen, avoid leading questions, avoid promising
absolute confidentiality, record the concern as accurately as possible, and explain that the information will only be shared with those who need to know in order to keep people safe.
IAIS shall take all concerns seriously, including concerns involving peer abuse, partner staff, volunteers, online contact, host families, transport providers, or conduct occurring abroad during project activities.
3.13 Reporting, referral, and escalation
The Designated Safeguarding Lead shall assess the concern, decide on immediate risk management,
and determine whether referral to the police, child protection authorities, emergency services, social
services, funders, insurers, venues, or partner organisations is necessary.
Where Maltese law imposes mandatory reporting or where there is reasonable concern that a child is
being abused or neglected, IAIS shall follow the applicable statutory and professional guidance. The
organisation shall also comply with any relevant funder or programme reporting duties, including
Erasmus+ or other grant conditions where applicable.
Allegations against staff, volunteers, board members, or consultants must be escalated immediately and managed with procedural fairness, confidentiality, and protective measures. No person who is the subject of an allegation should manage the case.
3.14 Confidentiality, information sharing, and records
Safeguarding information is highly sensitive. IAIS shall share safeguarding information only on a strict
need-to-know basis and only to protect a person, comply with a duty, or manage a legitimate
safeguarding process.
Safeguarding records shall be factual, dated, signed or attributable, stored securely, and kept separate from general participant records where possible. The organisation shall distinguish clearly between fact, observation, allegation, and professional opinion.
3.15 Support and non-retaliation
IAIS shall support those who raise concerns in good faith and shall not tolerate retaliation against
whistleblowers, complainants, witnesses, or affected individuals.
The organisation shall also consider support needs following an incident, including emotional support, safeguarding planning, communication with parents or carers where appropriate, changes to participation arrangements, and debriefing for staff.
3.16 Partner organisations and third parties
Where activities are delivered with partners, IAIS shall carry out proportionate due diligence and seek
assurance that appropriate safeguarding standards are in place. Agreements with partners should define roles, reporting routes, supervision arrangements, accommodation standards, and incident notification duties. If a partner’s standards fall below what is necessary to protect participants, IAIS shall escalate the issue and, if required, suspend or terminate involvement.
3.17 Training and awareness
All relevant personnel shall receive safeguarding induction before beginning their role. Those with
leadership, welfare, facilitation, mentoring, recruitment, or residential responsibilities shall receive
enhanced training.
Training should cover recognising indicators of harm, responding to disclosures, professional
boundaries, online safeguarding, record keeping, referral thresholds, cultural sensitivity, and the
interface between safeguarding and data protection.
3.18 Review and continuous improvement
This policy shall be reviewed at least annually and after any serious incident, near miss, legal change, or significant operational change.
The Board shall monitor implementation through training records, risk assessments, incident reviews,
partner due diligence, and lessons learned from activities.
3. Annex A. Safeguarding reporting procedure
1. If there is immediate danger, contact emergency services and take urgent protective action.
2. Report concerns to the Designated Safeguarding Lead or Deputy immediately.
3. Make a written record as soon as possible using the person’s own words where a disclosure was
made.
4. Do not investigate beyond what is necessary to clarify immediate safety and reporting facts.
5. Preserve evidence and relevant communications.
6. The Designated Safeguarding Lead decides next steps, referrals, notifications, and interim protective measures.
7. Keep the matter confidential and share only on a need-to-know basis.
8. Record outcomes, follow-up action, and review learning.