APPENDIX D1 – SAFEGUARDING INCIDENT PROTOCOL (OPERATIONAL SOP)

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APPENDIX D1 – SAFEGUARDING INCIDENT PROTOCOL (OPERATIONAL SOP)

Linked to: Chapter 13 (Workplace Conduct, Equality and Safeguarding), Chapter 9 (Compliance & Risk), Chapter 29 (Data Protection), Chapter 30 (Institutional Peace Indicators).

Goal: Make sure every concern about a child or vulnerable adult is handled consistently, safely and lawfully.

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1. Scope and Definitions

D1.1 Scope
This Protocol applies whenever any staff member, volunteer, monastic in an HGT role, contractor or partner:

• observes a situation that might put a child or vulnerable adult at risk,

• receives a disclosure (someone tells them about harm or risk), or

• has a reasonable suspicion of harm, neglect or exploitation linked to HGT activities, people or premises.

D1.2 Child and Vulnerable Adult

• Child: any person under 18 years of age.

• Vulnerable adult: an adult who may be more at risk of harm due to age, disability, illness, dependency, social isolation or other factors.

D1.3 Safeguarding Concern / Incident
Any situation where a child or vulnerable adult may be suffering, has suffered, or may be at risk of suffering harm, including but not limited to:

• physical, emotional or sexual abuse,

• exploitation or trafficking,

• harmful neglect or severe lack of care,

• exposure to serious violence or hate,

• serious bullying (including online),

• behaviour by HGT staff, volunteers, monastics or others that clearly violates safeguarding rules.

Note: We do not need proof. A reasonable concern is enough to trigger this Protocol.

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2. Roles and Responsibilities

D1.4 All Staff / Volunteers / Monastics in HGT Roles
Must:

• stay alert to possible signs of harm or distress,

• take any disclosure or concern seriously,

• follow this Protocol immediately,

• never promise secrecy (say: “I may need to share this with someone who can help”),

• treat all persons with respect and avoid blame or shaming.

D1.5 Safeguarding Focal Person (SFP)
Each site/major programme must have a named Safeguarding Focal Person responsible for:

• receiving and documenting safeguarding concerns,

• making initial risk assessments,

• deciding on immediate protection steps,

• consulting with the HGT Designated Safeguarding Lead (DSL),

• liaising with authorities where required.

D1.6 Designated Safeguarding Lead (DSL)
At organisational level, the DSL (or Safeguarding Officer):

• oversees all safeguarding cases,

• ensures consistent decisions and records,

• advises the Executive Director and Board/Ethics & Peace Committee,

• coordinates external reporting to authorities or partner agencies,

• ensures follow-up support and learning.

D1.7 Executive Director (ED)

• Ensures HGT as an institution complies with safeguarding law and policy.

• Supports DSL in high-risk or high-profile cases.

• Notifies the Board/Ethics & Peace Committee where appropriate.

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3. Immediate Response to a Concern or Disclosure

D1.8 If a child/vulnerable adult is in immediate danger

1. Ensure safety first, without putting yourself at serious risk.

2. Call emergency services if needed (medical, police, fire).

3. Inform the SFP or DSL as soon as it is safe to do so.

4. Complete the Safeguarding Incident Form (Appendix C3) as soon as possible.

D1.9 If there is no immediate physical danger

When a person discloses or you witness something worrying:

1. Listen calmly, do not interrupt or pressure.

2. Believe and validate: avoid questioning their truthfulness; thank them for telling you.

3. Do not promise to keep it secret – explain you may need to share with someone who can help.

4. Ask only open, simple questions if needed to clarify basic facts (who, what, when, where). Do not investigate.

5. Record as soon as possible (on Safeguarding Incident Form):

   • exact words used,

   • date, time, place,

   • who was present.

6. Report to the SFP or DSL immediately – do not wait until “later”.

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4. Recording the Incident

D1.10 Using the Safeguarding Incident Form

• Use Appendix C3 – Safeguarding Incident Form.

• Fill it in as soon as possible on the same day, while details are fresh.

• Use clear, factual language. State what you saw or heard, without speculation or diagnosis.

• Include any immediate actions you took (e.g. moved the child to a safer area, called security, informed a supervisor).

D1.11 Data Protection and Confidentiality

• Submit the completed form directly to the SFP or DSL, not via open email or public channels.

• Keep a personal copy only if required and store it securely; otherwise, hand everything to the SFP/DSL.

• Do not discuss the case with colleagues who are not involved in safeguarding decision-making.

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5. Initial Assessment and Decision-Making (SFP/DSL)

D1.12 Initial Screening by SFP/DSL

The SFP/DSL shall:

1. Log the incident (create a case reference in safeguarding register).

2. Review the form and, if needed, speak briefly with the reporter to clarify facts.

3. Assess immediate risk level:

   • High: credible risk of serious harm or ongoing abuse.

   • Medium: concern that may require further investigation or monitoring.

   • Low: unclear or minor concern; needs monitoring, advice, perhaps low-level support.

D1.13 Possible Immediate Decisions

The SFP/DSL may decide to:

• Take protective steps within HGT (e.g. remove a staff member from contact roles on a temporary basis, change supervision arrangements).

• Inform parents/guardians where appropriate and safe to do so.

• Seek internal consultation (with DSL, ED, Safeguarding Committee if any).

• Refer the case to external authorities or services (e.g. welfare services, police) when required by law or when risk is high.

D1.14 Considering Conflicts of Interest

• If the SFP is personally involved in the allegation or too close to the people involved, the case should go directly to the DSL or another designated safeguarding officer.

• If the DSL is implicated, the case goes to the ED and, where appropriate, to the Board Chair or Ethics & Peace Committee.

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6. External Reporting and Cooperation

D1.15 When to Report to Authorities

HGT will report to appropriate authorities if:

• law requires mandatory reporting (for certain types of child abuse or criminal conduct),

• there is a serious risk of ongoing harm,

• a serious criminal offence may have occurred,

• HGT cannot keep the person safe with internal measures alone.

D1.16 How to Report

• The DSL (or delegated SFP) will prepare a brief, factual statement, based on the Incident Form and any additional information.

• Only necessary information is shared, respecting privacy as far as possible.

• Records of:

  • date/time of report,

  • who was contacted,

  • summary of what was reported
    shall be kept in the safeguarding case file.

D1.17 Cooperation with Investigations

• HGT will cooperate lawfully and respectfully with official investigations.

• Staff shall follow instructions from the DSL regarding interviews or information requests.

• HGT will also ensure that the rights and wellbeing of the child/vulnerable adult remain central during these processes.

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7. Managing Cases Where the Alleged Harm-Doer is Inside HGT

D1.18 Allegations Against Staff / Volunteers / Monastics in HGT Roles

If a safeguarding concern involves a staff member, volunteer or monastic in an HGT role:

1. The SFP/DSL must be informed immediately.

2. The person may be:

   • temporarily removed from contact with children/vulnerable persons,

   • suspended from certain duties, pending clarification.

3. Any internal HR or disciplinary process must be coordinated with safeguarding and any external investigations.

4. The presumption of fair process applies; the person is not automatically “guilty” but HGT’s priority is safety.

D1.19 Allegations Against External Partners

• If the alleged harm-doer is employed by a partner organisation (e.g. school, NGO, tour operator), the DSL:

  • informs the partner organisation’s safeguarding lead where safe and appropriate,

  • may continue or suspend cooperation depending on risk,

  • assesses whether authorities also need to be informed.

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8. Supporting Those Affected

D1.20 Support to Child / Vulnerable Adult

HGT shall:

• treat the person with respect and compassion,

• ensure they are not blamed or punished for speaking up,

• facilitate access to appropriate support services (counselling, medical care, legal advice) where possible,

• avoid forcing them to repeatedly recount the incident unnecessarily.

D1.21 Support to Others

• Witnesses, staff, volunteers involved in handling the incident may also need debriefing or support.

• HGT shall consider pastoral, psychological or spiritual support for those affected, ensuring this does not interfere with investigations.

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9. Documentation, Confidentiality and Data Protection

D1.22 Safeguarding Case File

For each case, the DSL shall maintain a file including:

• the original Incident Form,

• notes of decisions and meetings,

• copies of any reports to authorities,

• correspondence with parents/guardians or partners,

• summary of follow-up actions and outcomes.

D1.23 Data Protection

• Safeguarding records are classified as Highly Sensitive Personal Data (see Chapter 29).

• Access is limited to DSL, SFPs and specific authorised leaders on a need-to-know basis.

• Files are kept securely and retained for the period specified in the retention schedule, considering law and best practice.

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10. Review, Learning and Closure

D1.24 Case Closure

A safeguarding case may be formally “closed” when:

• all planned actions have been taken,

• relevant authorities (if involved) have concluded their processes,

• ongoing risk is controlled or significantly reduced.

The DSL records closure and final outcome.

D1.25 After-Action Review

For serious or complex cases, HGT should conduct a short learning review (see Chapter 31):

• What worked well?

• What did not work well or was slow?

• What changes are needed (policies, training, structures)?

D1.26 Integration into Policy and Training

Lessons learned are:

• fed into annual safeguarding training,

• used to update SOPs, signage, volunteer briefings, and where necessary, the Policy Manual.

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APPENDIX D2 – MEDIA CONSENT PACK

(Photos / Video / Audio / Online Content)

Linked to: Chapter 24 (Educational & Programmatic Activities), Chapter 23 (Display & Ritual Use), Chapter 29 (Data Protection & Privacy).

Goal: Use images and recordings in a way that respects privacy, dignity and law, and supports HGT’s mission without exploitation.

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1. Overview and Principles

D2.1 Purpose

The Media Consent Pack:

• explains when consent is required for photos, video and audio;

• provides standard forms and processes;

• helps staff and volunteers avoid misuse of images, especially of children and vulnerable persons.

D2.2 Principles

• Respect and dignity: People have a right not to be exposed or embarrassed.

• Transparency: People should know how their image will be used.

• Data protection: Media that identifies individuals is personal data (Chapter 29).

• Special care for children / vulnerable persons.

• No exploitation: Images should not be used in ways that shame, sensationalise or exploit suffering or faith.

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2. Staff Instructions: When Consent is Needed

D2.3 General Rule

• If an individual is identifiable and the image/recording will be used beyond purely internal “evidence” of attendance (for example, on website, social media, brochures, public video), then consent is normally required.

D2.4 Public Events vs. Focused Images

• For large public events in open spaces (e.g. big festivals), general wide shots may be taken if:

  • people are informed by signs or announcements, and

  • no one is singled out in a way that might embarrass or endanger them.

• For close-up or focused shots of individuals or small groups, explicit consent is required.

D2.5 Children and Young People

• Always obtain written consent from a parent/guardian before using identifiable images or recordings of children in any public way.

• For older children, obtain their assent as well where appropriate.

• Never post children’s images with full name and location together without a strong reason and additional safeguards.

D2.6 Sensitive Contexts

Extra caution for:

• people receiving counselling or other sensitive support,

• persons in distress, illness or poverty,

• survivors of abuse or conflict,

• people who may face stigma or persecution if identified.

In such cases, usually avoid identifiable media; if absolutely necessary, anonymise (faces blurred, names removed) and seek specific advice from the DSL/Data Protection Officer.

D2.7 Staff Private Phones and Social Media

• Staff and volunteers must not take photos/videos for personal use and share them on personal social media without following HGT’s consent and data rules.

• When in doubt: ask a supervisor first, or do not take/post the image.

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3. Process: How to Get and Record Consent

D2.8 Before the Event or Activity

• For programmes where media is planned (training, retreat, workshop):

  • include a Media Consent clause in registration forms, or

  • provide separate Media Consent Forms at the start (see templates below).

• Explain clearly: what will be recorded, why, where it might be shown, and that refusal will not affect their access to the programme.

D2.9 At the Event

• Display a short notice at entrances for events where general photos/video may be taken, e.g.:

  “Photos and video may be taken during this event for HGT documentation and communication. If you do not wish to be photographed, please inform a staff member.”

• For children, visible signs are not enough – parental/guardian consent is still required.

D2.10 Recording Consent

• Use Appendix C5 forms (now part of this Pack) for:

  • Adult media consent

  • Child/parent media consent

• Keep signed forms safely with event records, in line with retention rules.

D2.11 Withdrawal of Consent

• Inform people they can contact HGT to request no further use of their image.

• Maintain a simple log of withdrawal requests and ensure:

  • future use is stopped,

  • images are taken down from HGT-controlled channels where feasible (e.g. website, official social media),

  • already printed or widely distributed materials may not be fully retractable; explain this honestly.

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4. Media Consent Forms (Expanded)

D2.4.1 Adult Media Consent (Expanded Version)

HGT – ADULT MEDIA CONSENT FORM

Name: _________________________________
Address / Contact: _________________________________
Programme / Event: _________________________________
Date(s): ____ / ____ / ______

1. What I am consenting to
   I understand that HGT may:

• take photographs and/or video and/or audio recordings of me during the above event or activity;

• store these recordings securely;

• use them for the purposes I agree to below.

2. Purposes I agree to (tick all that you allow)

☐ Internal reports and presentations (not public)
☐ Training of HGT staff/volunteers (internal only)
☐ HGT printed materials (e.g. brochures, posters, reports)
☐ HGT website and official social media channels
☐ Media/press materials (with prior notice where possible)
☐ Other (specify): ______________________________________

3. Conditions

• HGT will use my image/voice in a respectful way consistent with its mission.

• My image will not be used to endorse political parties or commercial products.

• I understand that I may contact HGT to withdraw my consent for future uses. Previously printed or widely distributed materials may not be fully recallable.

4. Signature

Signature: __________________________
Name (print): ______________________
Date: ____ / ____ / ______

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D2.4.2 Child / Young Person Media Consent (Expanded)

HGT – CHILD/YOUNG PERSON MEDIA CONSENT FORM

Child’s name: ______________________________
Age: ______ Gender: _____________________
Parent/Guardian name: _______________________
Relationship to child: ________________________
Contact details: _____________________________
Programme / Event: __________________________
Date(s): ____ / ____ / ______

1. What I am consenting to
   I am the parent/legal guardian of the above-named child. I understand that HGT may:

• take photographs and/or video and/or audio recordings of my child during the named event or activity;

• store these recordings securely;

• use them for the purposes I agree to below.

2. Purposes I agree to (tick all that you allow)

☐ Internal reports and presentations (not public)
☐ Training of HGT staff/volunteers (internal only)
☐ HGT printed materials (e.g. brochures, posters, reports)
☐ HGT website and official social media channels
☐ HGT sharing images with trusted partners for joint project reports (anonymised where possible)
☐ Other: ____________________________________________

3. Privacy and Safety

• HGT will not publish my child’s full name together with their image without asking for extra permission, unless there is a clear need and safety is considered.

• HGT will use images of my child respectfully and will not intentionally expose them to shame or danger.

4. Withdrawal of Consent

• I understand that I can contact HGT to withdraw consent for future uses.

• HGT will remove my child’s image from its website or official social media where reasonably possible, but cannot guarantee withdrawal from already printed or externally reshared materials.

5. Signatures

Parent/Guardian Signature: __________________________
Name (print): _____________________________________
Date: ____ / ____ / ______

(For older children, optional)

Child’s Signature (optional): __________________________
Date: ____ / ____ / ______

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D2.4.3 Media Consent – Research-Specific (Short)

(Use alongside the research consent form if you want to use images in publications.)

HGT – MEDIA CONSENT FOR RESEARCH PUBLICATION

Project title: _________________________________

I consent to the use of my:

☐ Photo ☐ Video ☐ Audio

in connection with the above project for:

☐ Academic publications (may be online or printed)
☐ Conference presentations
☐ HGT public reports about the research

I understand my image may appear in academic or professional materials and may be seen by a wide audience. I can ask HGT not to use my image in future materials, but some existing materials may remain in circulation.

Name: ________________________
Signature: ____________________
Date: ____ / ____ / ______

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5. Storage, Security and Retention of Media

D2.12 Secure Storage

• Digital media should be stored on approved HGT systems, not private USBs or personal phones (unless specifically authorised and time-limited).

• Access to folders holding identifiable images and recordings should be restricted to those who need it for work.

D2.13 Naming and Metadata

• File names should avoid including full names of children or sensitive information.

• If used in a database, link to consent forms via internal IDs rather than writing full details in file names.

D2.14 Retention Periods

• Media kept only for short-term documentation may be deleted after the event/report cycle, as per retention schedule.

• Media kept for historical or archival purposes (e.g. key events) should be reviewed periodically to ensure continued appropriateness and legal compliance.

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6. FAQ for Staff and Volunteers

Q1: If someone says “don’t take my photo”, what should I do?
A: Respect their wish. Do not take or keep their image. If already taken, delete it if possible and record that consent was not granted.

Q2: Can I post nice photos from HGT events on my personal social media?
A: Only if:

• the event manager has confirmed consent processes are in place, and

• there is no risk to children or vulnerable persons,

• and you do not share sensitive details.
  When in doubt, don’t post or ask your supervisor.

Q3: What if I accidentally capture a child whose parent did not consent?
A: Avoid using that image publicly. If you realise later, remove the image from platforms you control and inform your supervisor.

Q4: What about group photos?
A: For adult groups, general consent via event forms and clear notices may be enough, but you should still respect individual objections. For children, parental consent is still needed even in group photos.

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