CHILD WELFARE & SAFEGUARDING POLICY
Glossary
1. Policy Statement
2. Children’s First Statutory Obligation
3. Child Welfare And Safeguarding Roles
4. Child Abuse
5. Reporting Procedures
6. Stand Down Orders (Club & FAI)
7. Disciplinary Action
8. General Guidance For Interaction Between Adults And Children
[This Policy is drawn extensively from the FAI Child Welfare & Safeguarding Policy]
Glossary
Board shall mean the Board of Management of the Club.
Child Welfare and Safeguarding Committee shall mean a Committee of the Club
Children, Child or Young Person shall mean a person under the age of 18 other than a person who is or has been married.
Children First Act (2015) shall mean the Act for the purposes of making further and better provision for the care and protection of Children and for those purposes to require that preparation, by certain providers of services to Children, of Child Safeguarding Statements; to require certain persons to make reports to the Child and Family Agency in respect of Children in certain circumstances; to require certain persons to assist the Child and Family Agency in certain circumstances.
Child Risk Assessment shall mean a Risk Assessment which is carried out to identify whether a Child could be harmed whilst using the service.
Child Safeguarding Statement shall mean a statement that outlines the policies and procedures which are in place to manage the risks that have been identified through the Risk Assessment.
Clubs Children’s Officer shall mean the person who the Child welfare day to day functions are delegated to. Their remit shall be a key component of the Safeguarding Statement and they shall be the Relevant Person for the Child Safeguarding Statement.
Designated Liaison Person shall mean the person who is responsible for ensuring that reporting procedures within the Club/League are followed so that Child welfare and protection concerns are referred promptly to Statutory Authorities and will also liaise with outside agencies. Additionally, they will be a resource person to any employee or volunteer who has Child protection concerns.
Deputy Designated Liaison Person shall mean the person who carries out the duties of the Designated Liaison Person when the Designated Liaison Person is unavailable.
Harm shall mean, as defined in the Children First Act 2015, in relation to a Child–
(a) assault, ill-treatment or neglect of the Child in a manner that seriously affects, or is likely to seriously affect the Child's health, development or welfare, or,
(b) sexual abuse of the Child. whether caused by a single act, omission or circumstance or a series or combination of acts, omissions or circumstances or otherwise.”
Mandated Persons shall mean, as set out in the Children’s First Act 2015, persons who have contact with Children and/or families and who, because of their qualifications, training and/or employment role, are in a key position to help protect Children from harm.
Participants shall mean a Player, Official, Manager, Match Official, Match Agent, Intermediary and all such persons who are from time to time participating in any activity sanctioned by the Club or by any Affiliated Member.
Relevant Person shall mean the person who is appointed as the Children’s Officer within National Bodies, Provincial Associations, Leagues, Clubs, to be the first point of contact in respect of an Organisation’s Child Safeguarding Statement.
Relevant Service shall mean Organisations that have statutory responsibilities under the Children First Act 2015, any work or activity which consists of the provision of educational, research, training, cultural, recreational, leisure, social or physical activities to Children.
Stand Down Order shall mean an order which is issued to any person who is the subject of a complaint or inquiry by a Statutory Authority in relation to any Child Welfare or Vulnerable Person concern. A Stand Down Order is issued to an individual to immediately refrain from particular activities within the FAI for a specified or indefinite period pending the outcome of an enquiry or investigation in accordance with FAI Rules.
Statutory Authorities shall mean those state bodies which promote the welfare and protection of Children and Vulnerable Persons and have a legal responsibility for the investigation and/or validation of suspected abuse, and these include but are not limited to An Garda Síochána, the Health Service Executive and the Child and Family Agency (Tusla).
The Policy shall mean this Child Welfare and Safeguarding Policy.
Vulnerable Person means a person, other than a Child, who—
(a) is suffering from a disorder of the mind, whether as a result of mental illness or dementia,
(b) has an intellectual disability,
(c) is suffering from a physical impairment, whether as a result of injury, illness or age,
(d) has a physical disability, which is of such a nature or degree: - As to restrict the capacity of the person to guard himself or herself against harm by another person, or - That results in the person requiring assistance with the activities of daily living including dressing, eating, walking, washing and bathing.
Please note- within the Policy where Child/ Children is referred to there may be occasions when it may also be applicable to Vulnerable Persons.
1. POLICY STATEMENT
1.1. Why do we need a Policy?
The Club’s Child Welfare and Safeguarding Policy (the “Policy”) aims to set out guidelines and procedures to assist those working with Children within the club and where appropriate those working with Vulnerable Persons. It is the responsibility of all adults involved in the club to actively promote best practice standards whilst being ever vigilant and aware of their responsibilities. This policy is based on the FAI’ Child Welfare and Safeguarding Policy which was formulated in line with the statutory requirements of the Children First Act 2015 other relevant statutory guidance.
1.2. Who is the Policy aimed at?
The Policy is aimed at all those working and engaged in football activities in the Club. The Club is committed to following the principles and practice guidelines contained in the Policy by: -
Obliging all persons engaging with Children and Vulnerable Persons to be Garda vetted; -
Promoting appropriate FAI training , education and guidance in the area of Child welfare and safeguarding; -
Appointing a Club Designated Liaison Person -
Appointing a Club Children’s Officer Welfare -
Adhering to the rules for the protection of Children and Vulnerable Persons within the FAI Rule Book; -
Appointing a Child Welfare and Safeguarding Committee responsible for overseeing the Club’s policy on child protection and its implementation; -
Providing a clear pathway for the investigation of complaints and appropriate disciplinary procedures -
Recognising that the safety, protection and welfare of Children and Vulnerable Persons is of paramount importance;
1.3. Who approves the Policy?
The Policy is approved by the Board of the Club. Proposals for additions and/or amendments are considered by the Child Welfare and Safeguarding Committee of the Club on an ongoing basis. Once proposed amendments are approved by the Committee they are then put forward to the Board for final approval.
1.4. What are the underlying principles of the Policy?
The Policy follows the principles outlined in relevant guidelines and legislation provided by Statutory Authorities. The Policy is established on a number of core principles: -
the needs of the Child or Vulnerable Person, integrity and respect, environment, equality, fair play, welfare and safety in football. These underlying principles underpin the Policy and outline our principles of good practice and Child protection and safeguarding policy and procedures.
Safe Environment
The safety and welfare of Children and Vulnerable Persons is of paramount importance and they must feel safe in their surroundings. Unhealthy competitive demands should not be placed too early as this could result in excessive levels of pressure and as a consequence, high levels of dropout from the sport.
Those working with Children and Vulnerable Persons should be suitable for their positions, i.e. all should be Garda vetted and should be aware of the principles of Children First Act (2015) and the requirements of the Policy. The Club should ensure proper procedures are put in place to ensure our Children and Vulnerable Persons can participate in a safe manner and that concerns regarding their welfare are correctly and speedily handled.
The Needs and the Rights of the Child and Vulnerable Person
A balanced approach to competition can make a significant contribution to the development of Children and Vulnerable Persons, while at the same time providing fun, enjoyment and satisfaction. Participants should put the welfare of the child first and competitive standards second. A Child-centred/ person-centre approach will help to ensure that competition and specialisation are kept in their appropriate place.
Integrity and Respect
Adults interacting with Children and Vulnerable persons in football should do so with integrity and respect. All adult actions in football should be guided by what is in the best interests of the Child or Vulnerable Person and in the context of quality and open working relationships. Abuse of any kind is unacceptable within football.
Equality
All Children and Vulnerable Persons should be and are entitled to be treated in an equitable and fair manner regardless of age, ability, gender, religious, social, or ethnic background or political persuasion. The provisions of equality legislation apply to all involved in football.
Fair Play
Fair Play is the guiding principle of the Code of Ethics and Good Practice for Children’s Sport. It states that “All Children’s sport should be conducted in an atmosphere of fair play. Fair play is cited as: “much more than playing within the rules. It incorporates the concepts of friendship, respect for others and always playing with the right spirit. Fair play is defined as a way of thinking, not just behaving”.
2.CHILDREN FIRST: STATUTORY OBLIGATIONS
Clubs such as ours are defined in the Children First Act 2015 as providing “Relevant Services” and as such have specific statutory obligations under the Act.
The requirements include: - Keep Children safe from Harm while they are using the service -
Carry out a Risk Assessment to identify whether a Child could be harmed whilst receiving our services -
Develop a Child Safeguarding Statement that outlines the policies and procedures which are in place to manage the risks that have been identified
-Appoint a Relevant Person to be the first point of contact in respect of the Organisation’s Child Safeguarding Statement.
2.1. Risk Assessment
A Risk Assessment is an exercise where the Club examines all aspects of the service from a safeguarding perspective to establish whether there are any practices or features of the service that have the potentials to put Children at risk, ranking them low, medium or high risk.
The Risk Assessment process is intended to enable us to; -
Identify potential risk -
Develop policies and procedures to minimise risk by responding in a timely manner to potential risks -
Review whether adequate precautions have been taken to eliminate or reduce these risks
2.2. Child Safeguarding Statement
This is a written statement that specifies the Relevant Service being provided and the principles and procedures to be observed in order to ensure, as far as practicable, that a Child availing of the service is safe from Harm.
(a) The statement must include both the written Risk Assessment and the procedures that are in place to; -
Manage any risk identified -
Investigate an allegation against any volunteer or staff member about any act, omission or circumstance in respect of a Child availing of the service -
Select and recruit volunteers and staff who are suitable to work with Children -
Provide information and training to volunteers and staff on Child protection and safeguarding issues -
Enable volunteers or staff members, whether Mandated Persons or otherwise, to make a report to Tusla in accordance with the Act or any guidelines issued by the Minister for Children and Youth Affairs -
Maintain a list of persons in the Organisation who are Mandated Persons under the Act -
Appoint a Relevant Person in the Organisation for the purposes of the Act.
(b) The purpose of the Child Safeguarding Statement is provide an overview of the measures that the Club has put in place to ensure that Children are protected from Harm
(c) It can also refer to more detailed policies which can be made available on requires
(d) The Club will circulate the Child Safeguarding Statement to all volunteers and employees.
(e) The Club will display the Child Safeguarding Statement publicly (at the Clubhouse and on the Club website) and make it available to parents and guardians, Tusla and members of the public upon request.
(f) The Child Safeguarding Statement will be reviewed every two years, or sooner if there has been a material change in any of the issues to which it refers to.
(g) The Club’s Safeguarding Statement is based on the FAI’s sample Child Safeguarding Statement.
(h) A copy of The Football Association of Ireland’s Child Safeguarding Statement can also be found on the FAI website at https://www.fai.ie/domestic/safeguarding/documents.
2.3. Appointing a Relevant Person
The Relevant Person for the Club will be under the roles and responsibilities of the Children’s Officer (See Section 3 Below) .
2.4. Register of Non- compliance
The Club notes that there is a provision in the Children First Act 2015 for Tusla – Child and Family Agency to establish and maintain a register of non-compliance for service providers who fail to provide a copy of the Child Safeguarding Statement to Tusla when requested to do so. Non-compliance could also lead to disciplinary action against a Club, League or other Affiliated Member as this would be a breach of Part B Rule 40.1 C) of the FAI Rules.
2.5. 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 (See Section 3 Below).
3. CHILD WELFARE AND SAFEGUARDING ROLES
The Club are required to have two key roles in place in order to fulfil the Child welfare and safeguarding roles and responsibilities within the Organisation. These two roles are Club/League Children’s Officer and Designated Liaison Person.
3.1. Club/League Children’s Officer:-
(a) The appointment of a Club Children’s Officer is an essential element in the creation of a quality atmosphere in the Club.
(b) They act as a resource to members with regard to Children’s issues and also ensure that Children have a voice in the running of the club and can freely talk about their experiences.
(c) The Children’s Officer should be a member of or have access to, the Club Management Committee.
(d) To undertake the role of Children’s Officer, the individual must have completed the Safeguarding 1 and Safeguarding 2 courses.
(e) The Club Children’s Officer roles and responsibilities are;-
- To be familiar with the FAI Child Welfare and Safeguarding policy, Complaints and Disciplinary procedures, Social Media Policy and any other relevant guidelines
- Implement Child centred policies and procedures within the Club - Ensure safe recruitment procedures are in place
- Have completed the Risk Assessment and Child Safeguarding Statement
- Promotion of Child Safeguarding Statement and be the first point of call for it
- Host regular information meetings and get parental involvement
- Ensure that Club members are adequately trained and adhere to the Child Welfare and Safe-guarding Policy
- Ensure that there are accurate and up to date records of coaches and volunteers training and Garda Vetting Clearance
- Monitor movement and drop out of players and volunteers.
- Handle any complaints received regarding poor practise. - Make contact with League, Affiliate and National roles.
- In addition to the functions outlined above, they should ensure that all The Club’s Children’s Officers does not have the responsibility of investigating or validating Child protection concerns within the Club and have no counselling or therapeutic role. This responsibility lies with the Gardaí, Tusla or the HSE.
3.2. Designated Liaison Person
(a) In line with the FAI’s Child Welfare & Safeguarding Policy, the Club’s Designated Liaison Person shall be the Chairperson who will be responsible for dealing with any concerns about the protection of Children.
(b) The Designated Liaison Person is responsible for reporting allegations or suspicions of Child abuse to Tusla and/or An Garda Siochana,
(c) Support and advice is available from the Football Association of Ireland’s Child Welfare and Safeguard¬ing Manager, who is also the FAI’s Mandated Person.
(d) To undertake the role of Designated Liaison Person, the individual must have completed the Safe-guarding 1 and Safeguarding 3 course.
(e) The Club will make the name and contact details of the Designated Liaison Person available to all staff and volunteers working within the Organisation. The Club may also appoint from time to time a Deputy Liaison Person who can fulfil the role when the Designated Liaison Person is not available.
(f) The Designated Liaison Person Roles and Responsibilities are;
- Have knowledge of the Code of Ethics, and statutory requirements - Have a knowledge of categories and indicators of abuse
- Be familiar with and able to carry out reporting procedures using the correct forms, (see appendix 6 for forms).
- Communicate with parents and/or agencies as appropriate
- Assist with the ongoing development and implementation or Child protection training needs
- Liaise with the League Officers and FAI Child Welfare and Safeguarding Manager in relation to Child protection training needs.
- Be aware of local contacts and services in relation to Child protection, i.e. principal and duty social workers and their contacts.
- To inform duty social worker in Tusla – Child and Family agency and/ or An Garda Siochana of relevant concerns about individual Children, using the Reporting Form, keep a copy of this form and ensure acknowledgement of receipt of this form.
- Reporting poor practise to their relevant governing body having ensured that any concerns regarding Child protection issues have been reported to the relevant Statutory Authority.
- Advise administrators on issues of confidentiality, record keeping and data protection.
Designated Liaison Persons do not have the responsibility of investigating or validating Child pro-tection concerns within the Club/League and have no counselling or therapeutic role. This respon-sibility lies with the Gardaí, Tusla or the HSE.
4. CHILD ABUSE
4.1. Reasonable grounds for concerns Individuals should always inform Tusla when they have reasonable grounds for concern that a Child may have been, is being, or is at risk of being abused or neglected. It is not necessary for the individual to prove that abuse has occurred to report a concern to Tusla. All that is required is that the individual have reasonable grounds for concerns. It is Tusla’s role to assess concerns that are reported to it. Reasonable grounds for a Child protection or welfare concern include: - Evidence, for example of an injury or behaviour, that is consistent with abuse and is unlikely to have been caused in any other way
- Any concern about possible sexual abuse
- Consistent signs that a Child is suffering from emotional or physical neglect
- A Child saying or indicating by other means that he or she has been abused
- Admission or indication by an adult or a Child of an alleged abuse they committed
- An account from a person who saw the Child being abused
4.2. What is Child Abuse
Child Abuse can be categorised into four main types: neglect, emotional abuse, physical abuse and sexual abuse. Other forms of abuse include bullying. A Child may be subjected to one or more forms of abuse at any given time. Abuse and neglect can occur within the family, in the community or in an institutional setting. The abuser may be someone known to the Child or a stranger, and can be an adult or another Child. In a situation where abuse is alleged to have been carried out by another Child, you should consider it a Child welfare and protection issue for both Children and you should follow Child protection procedures for both the victim and the alleged abuser. The important factor in deciding whether the behaviour constitutes abuse or neglect is the impact of that behaviour on the Child rather than the intention of the parent/carer/alleged abuser. The definitions of neglect and abuse presented in this section are not legal definitions nor are they exhaustive. They are intended to describe ways in which a child might experience abuse and how this abuse may be recognised.
4.3. Neglect
(a) Neglect is generally defined in terms of an omission of care, where a Child’s health, development or welfare is impaired by being deprived of food, clothing, warmth, hygiene, medical care, intellectual stimulation, supervision and safety.
(b) The following are features of Child Neglect:
- Children being left alone without adequate care and supervision
- Malnourishment, lacking food, unsuitable food or erratic feeding
- Inadequate living conditions – unhygienic conditions, environmental issues, including lack of adequate heating and furniture
- Lack of protection and exposure to danger, including moral danger, or lack of supervision appropriate to the Child’s age
- Non-organic failure to thrive, i.e. a child not gaining weight due not only to malnutrition but also emotional deprivation
- Failure to provide adequate care for the Child’s medical and developmental needs, including intellectual stimulation
(c) A reasonable concern for the Child’s welfare would exist when neglect becomes typical of the relationship between the Child and the parent or carer. This may become apparent where you see the Child over a period of time, or the effects of neglect may be obvious based on having seen the Child once.
4.4. Emotional Abuse
(a) Emotional abuse is the systematic emotional or psychological ill-treatment of a Child as part of the overall relationship between a caregiver and a Child. Abuse occurs when a Child’s basic need for attention, affection, approval, consistency and security are not met, due to incapacity or indifference from their parent or caregiver.
(b) Emotional abuse may be seen in some of the following ways: Rejection - Lack of comfort and love
- Lack of attachment
- Lack of proper stimulation (e.g. fun and play)
- Lack of continuity of care (e.g. frequent moves, particularly unplanned)
- Persistent criticism, sarcasm, hostility or blaming of the Child
- Bullying
- Conditional parenting in which care or affection of a Child depends on his or her behaviours or actions
- Extreme overprotectiveness
- Inappropriate non-physical punishment (e.g. locking Child in bedroom) - Seriously inappropriate expectations of a Child relative to his/her age and stage of development
(c) There may be no physical signs of emotional abuse unless it occurs with another type of abuse. A Child may show signs of emotional abuse through their actions or emotions in several ways. These include insecure attachment, unhappiness, low self-esteem, educational and developmental underachievement, risk taking and aggressive behaviour.
(d) A reasonable concern for the Child’s welfare would exist when the behaviour becomes typical of the relationship between the Child and the parent or carer.
4.5. Physical Abuse
(a) Physical Abuse is when someone deliberately hurts a Child physically, or puts them at risk of being physically hurt. It may occur as a single incident or as a pattern of incidents
(b) Physical abuse can include the following: Beating, slapping, hitting or kicking
- Pushing, shaking or throwing
- Pinching, biting, choking or hair-pulling
- Use of excessive force in handling
- Suffocation
- Physical punishment
- Fabricated/induced illness
- Female genital mutilation
- Deliberate poisoning
(c) The Children First Act 2015 includes a provision that abolishes the common law defence of reasonable chastisement in court proceedings. This defence could previously be invoked by a parent or other person in authority who physically disciplined a Child. The change in the legislation now means that in prosecutions relating to assault or physical cruelty, a person who administers such punishment to a Child cannot rely on the defence of reasonable chastisement in the legal proceedings. The result of this is that the protections in law relating to assault now apply to a Child in the same way as they do to an adult. A reasonable concern exists where the Child’s health and/or development is, may be, or has been damaged as a result of suspected physical abuse.
4.6. Sexual Abuse
(a) Sexual abuse occurs when a Child is used by another person for his or her gratification or sexual arousal or for that of others. It includes the Child being involved in sexual acts (masturbation, fondling, oral or penetrative sex) or exposing the Child to sexual activity directly or through pornography
(b) Child sexual abuse may cover a wide spectrum of abusive activities. It rarely involves just a single incident and in some instances, occurs over a number of years. Child sexual abuse most commonly happens within the family, including older siblings and extended family members.
(c) It should be remembered that sexual activity involving a Young Person may be sexual abuse even if the Young Person concerned does not themselves recognise it as abusive.
(d) Examples of child sexual abuse include the following:
- Any sexual act intentionally performed in the presence of a Child
- An invitation to sexual touching or intentional touching or molesting of a Child’s body whether by a person or object for the purpose of sexual arousal or gratification
- Masturbation in the presence of a Child or the involvement of a Child in an act of masturbation
- Sexual intercourse with a Child, whether oral, vaginal or anal
- Sexual exploitation of a Child, which includes: Inviting, inducing or coercing a Child to engage in prostitution or the production of Child pornography [for example, exhibition, modelling or posing for the purpose of sexual arousal, gratification or sexual act, including its recording (on film, videotape or other media) or the manipulation, for those purposes, of an image by computer or other means]
- Inviting, coercing or inducing a Child to participate in, or to observe, any sexual, indecent or obscene act
- Showing sexually explicit material to children, which is often a feature of the ‘grooming’ process by perpetrators of abuse
- Exposing a Child to inappropriate or abusive material through information and communication technology
- Consensual sexual activity involving an adult and an underage person
(e) An Garda Síochána will deal with any criminal aspects of a sexual abuse case under the relevant criminal justice legislation. The prosecution of a sexual offence against a Child will be considered within the wider objective of Child welfare and protection. The safety of the Child is paramount and at no stage should a Child’s safety be compromised because of concern for the integrity of a criminal investigation.
(f) In relation to Child sexual abuse, it should be noted that in criminal law the age of consent to sexual intercourse is 17 years for both boys and girls. Any sexual relationship where one or both parties are under the age of 17 is illegal. However, it may not necessarily be regarded as Child sexual abuse.
4.7. Other forms of ‘Abuse’
(a) Bullying -
Bullying can be defined as repeated aggression
– whether it is verbal, psychological or physical
– that is conducted by an individual or group against others. It is behaviour that is intentionally aggravating and intimidating, and occurs mainly among Children in social environments such as schools. It includes behaviours such as physical aggression, cyberbullying, damage to property, intimidation, isolation/exclusion, name calling, malicious gossip and extortion. Bullying can also take the form of abuse based on gender identity, sexual preference, race, ethnicity and religious factors. With developments in modern technology, Children can also be the victims of non-contact bullying, via mobile phones, the internet and other personal devices.
- While bullying can happen to any Child, some may be more vulnerable. These include: Children with disabilities or special educational needs; those from ethnic minority and migrant groups; from the Traveller community; lesbian, gay, bisexual or transgender (LGBT) Children and those perceived to be LGBT; and Children of minority religious faiths.
- There can be an increased vulnerability to bullying among Children with special educational needs. This is particularly so among those who do not understand social cues and/or have difficulty communicating. Some Children with complex needs may lack understanding of social situations and therefore trust everyone implicitly. Such Children may be more vulnerable because they do not have the same social skills or capacity as others to recognise and defend themselves against bullying behaviour.
- In cases of serious instances of bullying where the behaviour is regarded as possibly abusive, you may need to make a referral to Tusla and/or An Garda Síochána.
(b) Cyber, text and social media bullying Cyber bullying can involve unwanted text messages, phone calls, video chats/ recordings or web posts being used to threaten abuse or harm someone. It is similar to physical or verbal bullying, but it uses technology instead. Cyber bullying, like all bullying, is difficult for the victim. It can be hard to prove and difficult to get the courage to report it. Text bullying or harassment can be texts that frighten, insult, threaten or make the recipient feel uncomfortable. Email, social networks like Facebook/Twitter and phone calls can be used to harass in the same way. The FAI Social Media Policy 2018 provides guidance on the appropriate use of social media.
(c) Safeguarding Vulnerable Persons All adults have the right to be safe and to live a life free from abuse. All persons are entitled to this right, regardless of their circumstances. It is the responsibility of all service providers, statutory and non-statutory, to ensure that, all adults using the services provided are treated with respect and dignity, have their welfare promoted and receive support in an environment in which every effort is made to promote welfare and to prevent abuse. Vulnerable Persons may need extra support when accessing clubs. Please see the FAI Support Guidance for Children with Additional Needs and Vulnerable Persons 2018, for help and advice.
4.8. Vulnerable Children
(a) Certain Children are more vulnerable to abuse than others. Such Children include those with disabilities, homeless Children and those who, for one reason or another, are separated from their parents or other family members and who depend on others for their care and protection. The same categories of abuse - neglect, emotional abuse, physical abuse and sexual abuse - are applicable, but may take a slightly different form. For example, abuse may take the form of deprivation of basic rights, harsh disciplinary regimes or the inappropriate use of medications or physical restraints.
(b) It is important to remember that the presence of any of these factors does not necessarily mean that a Child in those circumstances or settings is being abused.
(c) Vulnerable Children and Children with additional needs may need extra support when accessing our services within the Organisation please see the FAI Support Guidance for Children with Additional Needs and Vulnerable Persons 2018, for help and advice .
4.9. Recognising Child Abuse Child abuse can often be difficult to identify and may be present in many forms, therefore it is necessary to follow some general guidelines.
(a) There are commonly three stages in the identification of child abuse: Considering the possibility; Looking out for signs of abuse; Recording of information.
(b) Stage 1: Considering the possibility The possibility of Child abuse should be considered if a Child appears to have suffered a suspicious injury for which no reasonable explanation can be offered. It should also be considered if the Child seems distressed without obvious reason or displays persistent or new behavioural problems. The possibility of Child abuse should also be considered if the Child displays unusual or fearful responses to parents/carers.
(c) Stage 2: Looking out for signs of abuse
Signs of abuse can be physical, behavioural or developmental. They can exist in the relationships between Children and parents/carers or between Children and other family members/other persons. A cluster or pattern of signs is likely to be more indicative of abuse. Children who are being abused may hint that they are being harmed and sometimes make direct disclosures. Disclosures should be believed.
- Some signs are more indicative of abuse than others. These include: - Disclosure of abuse and neglect by a Child or Young Person;
- Age-inappropriate or abnormal sexual play, language or knowledge; - Specific injuries or patterns of injuries;
- Absconding from home or a care situation;
- Self-harm;
- Attempted suicide;
- Underage pregnancy or sexually transmitted disease;
- Signs in one or more categories at the same time may together indicate a pattern of abuse. Most signs of abuse are non-specific and must be considered in the Child's social and family context with the aid of professionals. Football clubs are often the places where appropriate trusting relation-ships with adults outside the family or formal education sector are developed. However, it can also provide opportunities for adults to target and groom a Child or Young Person through their role as a volunteer or paid employee. Grooming can be seen as the process by which an individual manipulates those around them
– particularly, but not exclusively, the Child
– to provide opportunities to abuse and reduce the likelihood of being reported or discovered.
(d) Stage 3: Recording and reporting of information
If abuse is suspected, it is important to establish the grounds for concern by obtaining as much detailed information as possible. Observations should be accurately recorded and should include dates, times, names, locations, context and any other information that may be relevant. Please refer to section 5 - reporting procedures of the Policy for more information.
(e) Points to remember
- The severity of a sign does not necessarily equate with the severity of the abuse. Severe and potentially fatal injuries are not always visible. Emotional and/or psychological abuse tends to be cumulative and effects may only be observable in the longer term.
- Neglect is as potentially fatal as physical abuse. It can cause delayed physical, psychological and emotional development, chronic ill-health and significant long-term damage. It may also precede, or co-exist with other forms of abuse and must be acted upon.
- Child abuse is not restricted to any socio-economic group, gender or culture. All signs must be considered in the wider social and family context.
- Challenging behaviour by a Child should not render them liable to abuse. Children in certain circumstances may present management problems. This should not leave them vulnerable to harsh disciplinary measures or neglect of care. Please refer to the FAI Support Guidance for Children with Additional Needs and Vulnerable persons 2018, for help and advice with how to deal with Challenging behaviour which can be found within Appendix 1.
- It is sometimes difficult to distinguish between indicators of Child abuse and other adversities suffered by Children and families. The advice of professionals should always be sought.
4.10. Distinguishing between ‘Child abuse’ and ‘Poor Practice’
(a) Concerns identified as child abuse will fall within the following categories:
- Physical Abuse
- Neglect
- Sexual Abuse
- Emotional Abuse
- Bullying
(b) Incidents of poor practice occur when the needs of Children and Vulnerable Persons are not afforded the necessary priority, so their welfare is compromised. Examples of poor practice are likely to be once off incidents and these might include but are not limited to:
Coach
- Giving preferential treatment to individuals and unfairly rejecting others (e.g. singling out and only focusing on the talented children and failing to involve the full squad).
- Giving preference to winning games over Children’s development, participation and satisfaction.
- Encouraging Children to play while injured.
- Using inappropriate language, gestures or comments to motivate Children or provoke a reaction.
- Using inappropriate language, gestures or comments with other coaches or parents
- Delivering a coaching session alone, without another responsible adult present.
- Coaching alone when their own child is part of the team.
- Entering the field of play as a coach/manager when their own child is involved in an on-field incident.
Parent/Guardian
- Placing too much pressure on their Child to perform to a high standard and win games.
- Criticising their Child’s performances instead of highlighting the positives of their game and where improvements were made.
- Failing to ensure that their Child is appropriately dressed for weather conditions.
- Making derogatory comments about their Child, or another Child during a game or training session.
- Failing to bring their Child to training on time, or collect them promptly at the end of the session.
Supporters
- Using inappropriate language towards Children, coaches, referees or other supporters.
- Making inappropriate comments about the performance of Children, coaches or referees.
- Entering the field of play during a match or training session without being asked to do so.
The Club
- Failing to implement FAI Rules on the protection and welfare of Children and Vulnerable Persons, the FAI Child Welfare and Safeguarding Policy and other supporting documents.
- Placing undue pressure on a coach or team of Children to win games or competitions.
- Allowing poor practice to go unreported (e.g. a coach who ridicules and criticises Children who make a mistake during training or a match).
- Failing to create an environment that encourages player development and enjoyment over winning games and trophies.
- Failing to provide appropriate safeguarding education for their coaches and members.
- Not having procedures in place to ensure a parent does not coach their child’s team alone and to ensure that they do not enter the field of play as the coach or manager when their own child is involved in an on-field incident.
General
- Shouting at or ridiculing Children when they make a mistake. Children should be given the opportunity to learn from their mistakes and develop.
- When insufficient care is taken to avoid injuries (e.g. by excessive training or inappropriate training for the age, maturity, experience and ability of players).
- Allowing Children to use inappropriate language unchallenged. - Placing Children, Young People or Vulnerable Persons in potentially compromising and uncomfortable situations with adults (e.g. changing in a 1:1 situation with a coach).
- Ignoring health and safety guidelines (e.g. allowing Children or Vulnerable Persons to set up goal posts unsupervised by adults).
- Failing to adhere to the Club’s codes of practice.
4.11. Points to remember -
Judgement about whether an incident is one of Child abuse or poor practice may not be possible at the point of referral, but only after the collation of relevant information.
- The majority of poor practice concerns should be dealt with directly by the Club in the first instance. Further support and guidance should be sought from the League, the National Body/Provincial Association and then the FAI where appropriate. Please following the FAI Concern/Complaint procedure which can be found in Appendix 9 of the FAI’s Child Protection & Safeguarding Policy and within the FAI Concern/Complain policy 2018 which can be found in Appendix 10 of their policy.
- Please refer to the FAI Concern Complaint Policy 2018, Section 3 for guidance on how to deal with an example of Poor Practice.
- In some cases, poor practice may amount to Child abuse, e.g. where the actions of a coach/manager put a Child at unacceptable risk of injury and accordingly must be reported to the Statutory Authorities.
- All Child abuse investigations will be dealt with by the Statutory Authorities with the support of the Club, the GFA and the FAI.
- The role of the Club is to report any allegations of abuse to the Statutory Authorities. Any action taken by the Club will not interfere with or impede any statutory investigation.
- The FAI Player Development Plan offers a workshop for Clubs and League who would like to highlight poor practices to coaches and parents. Please see the FAI website for information on the Coach/Parent Education Workshop at www.fai.ie/domestic/player-development-plan/parent-education.
5. REPORTING PROCEDURES
In line with FAI’s best practice as set out within their Child Welfare & Safeguarding Policy, the Club shall treat all concerns reported under the Policy in a serious manner and in line with the following principles. It is a fundamental principle of the Club’s approach to child welfare and safeguarding that a Child or Vulnerable Person themselves or their parent/carer have a right to communicate welfare and safeguarding concerns through their coach or other relevant persons (such as the Children’s Officer) and to be heard, considered, addressed in an appropriate and respectful manner.
5.1. Members of the Club who have reasonable grounds for concerns that a Child or Vulnerable Person may have been, is being, or is at risk or being abused or neglected are advised, to immediately inform the relevant Designated Liaison Person. If this is not possible the FAI Child Welfare and Safeguarding Manager should be informed. The priority in all cases is the safety and wellbeing of the Child. The Statutory Authorities should also be advised where appropriate and all necessary steps taken to protect the Child.
5.2. The Designated Liaison Person should record all concerns or allegations brought to his or her attention.
5.3. If, as a Designated Liaison Person, you decided not to report a concern to Tusla, the following steps should be taken;
- The reasons for not reporting should be recorded
- Any actions taken as a result of the concern should be recorded
- The employee or volunteer who raised the concern should be given a clear written explanation of the reasons why the concern is not being reported to Tusla
- The employee or volunteer should be advised that if they remain concerned about the situation, they are free to make a report to Tusla or An Garda Siochana.
5.4. If there are concerns about a Child but the Designated Liaison Person is unsure if it should be reported to Tusla, it may be useful to contact Tusla to informally discuss the concern. This provides an opportunity to discuss the query in general and to decide whether a formal report of the concern to Tusla is appropriate at this stage.
5.5. Employees or others engaged by the FAI who are advised, suspect or are concerned that a Child may be at risk of abuse are obliged to immediately inform the FAI Child Welfare and Safeguarding Manager. The priority in all cases is the safety and wellbeing of the child. The Statutory Authorities should also be advised and all necessary steps taken to protect the Child.
5.6. In the event of an emergency where a Child is believed to be in immediate danger and Tusla cannot be contacted then the Gardaí should be contacted.
5.7. In cases where there is deemed to be a serious risk to Children the Designated Liaison Person may issue a temporary Stand Down Order in line with the Policy.
5.8. Reports can be made to Tusla in person, by telephone or in writing - including by email- to the local duty service in the area where the Child lives. Detail can be found on the Tusla website (www.tusla.ie)
5.9. To help Tusla staff assess the reasonable concern, they need all relevant information. Observations should be accurately recorded and should include dates, times, names, locations, context and any other information that may be relevant. It is not the role of the Designated Liaison Person to investigate the circumstances of an allegation of abuse prior to informing the Statutory Authorities. It should be ensured that all relevant information is recorded and provided to the Statutory Authorities. The reporting form can be found in Appendix 6 of the FAI’s Child Welfare & Safeguarding Policy.
5.10. Parents/carers of a Child who is a suspected victim of abuse should be advised that a report is being made unless doing so is likely to endanger the Child.
5.11. Reports received anonymously should be taken seriously and relevant enquiries made to establish if there is any substance to the complaint. The welfare of the Child is a priority in all cases.
5.12. Children who are being abused may hint that they are being Harmed and sometimes make disclosures. Disclosures should always be believed and reported to the relevant Designated Liaison Person without delay.
5.13. Any request to keep information anonymous cannot be guaranteed.
5.14. Missing Children: If a Child is believed to be missing, efforts should be made to first establish the Child’s whereabouts by contacting the parents/carers. If the Child’s location cannot be established and/or the parents/carers are not available and reasonable efforts have been made to contact them the matter should be reported to the Gardaí urgently.
5.15. There are Protection from civil liability for persons reporting concerns of child abuse in good faith:
(a) Section 16 (3) of the Children First Act, 2015: If a Mandated Person furnishes any information (including a report), document or thing to the Agency pursuant to a request made under subsection (1), the furnishing of that information, document or thing shall not give rise to any civil liability in contract, tort or otherwise and nor shall the information, document or thing be admissible as evidence against that person in any civil or criminal proceedings.
(b) Section 3 Protections for Persons Reporting Child Abuse Act 1998: Legislation makes provision for the protection from civil liability of persons who have communicated Child abuse 'reasonably and in good faith' to designated officers of Tusla or to any member of An Garda Síochána. This protection applies to Organisations as well as to individuals. This means that even if a communicated suspicion of Child abuse proves unfounded, a plaintiff who took an action would have to prove that the person who communicated the concern had not acted reasonably and in good faith in making the report.
5.16. How Reports shall be managed
(a) Once a report is received it shall be reviewed by the relevant Designated Liaison Person. The Des¬ignated Liaison Person shall determine if an enquiry is required and the nature and extent of enquiries and/or reports to be made to the relevant Authorities following the above information.
(b) If the report is not reported to the relevant Authorities but the Designated Liaison Person feels a breach of this Policy has occurred then the matter may be delegated to the Club Children’s Officer in line with the FAI’s Concerns\Complaint Policy 2018.
(c) Any enquiry is not to proceed if a Statutory Investigation is under way. Once any Statutory Investi¬gation is completed then the Designated Liaison Person shall follow the above step.
(d) It is a matter for the Designated Liaison Person and Children’s Officer to determine if a report falls under the remit of the Policy.
5.17. False/Malicious Allegations False or malicious allegations are deemed to be a serious breach of the Policy and of the FAI Rules. This may result in disciplinary action been taken and may constitute an offence under relevant legislation.
6. GARDA VETTING & STAND DOWN ORDERS
6.1. - The Club’s Children’s Officer shall keep and update a list, called the Volunteers List, which shall include names and contact details of volunteers, employees, contractors who work with children or vulnerable adults. The Volunteer List shall also confirm the position regarding current Garda Vetting status and Safeguarding course undertaken (including expiry/renewal dates) and age group where the individual volunteers/works. The Volunteer List shall be confirmed by the Committee annually, prior to each season and as required thereafter, so that an appropriate record can be maintained and a pipeline of actions identified to best ensure current and future compliance with the Child Protection Policy.
6.2. The Club’s Child Welfare Sub Committee shall liaise with the Committee of the Club with regard to any necessary steps required in terms of the Volunteer List and Child Welfare shall be maintained as a running item on the Committee’s agenda for that purpose.
6.3. Where any a garda vetting disclosure is made the Children’s Officer shall, together with a number of the Child Welfare Sub Committee, shall with due regard for confidentiality, carry out a risk assessment of the information disclosed, including where relevant and appropriate consulting with the applicant/volunteer/coach and make a determination as to the applicant’s suitability to be engaged/retained. At all times, the rights and obligations owing to the Child shall be of paramount consideration in undertaking any such risk assessment. A right of appeal of the decision shall lie to the Chairman (or their nominated person) in the form of a written appeal made within 7 working days.
6.4. A Stand Down Order may be issued to an individual directly by the FAI itself or by the Club. A Stand Down Order is an order made for the immediate protection and safeguarding of Children and Vulnerable Persons and is not a determination of wrongdoing by any individual. Stand Down Orders may be issued in a number of circumstances including but not limited to the following:
(a) Any person who is the subject of a complaint or inquiry by a Statutory Authority in relation to any Child welfare or Vulnerable Person concern shall be issued with a Stand Down Order from all football activities. This order shall be issued by the Child Welfare and Safeguarding Manager of the FAI or the Designated Liaison Person of the Club, pending the outcome of any inquiry and any sub¬sequent internal disciplinary proceedings. Terms of a Stand Down Order must be complied with.
(b) The Club shall immediately notify the FAI of any Stand Down Order issued.
(c) The FAI may also issue a Stand Down Order in circumstances where concerns are raised with the FAI outside of a Statutory Authority investigation. The Club may also issue a Stand Down Order in these circumstances, however the issuance of such order must be notified to the FAI Child Welfare and Safeguarding Manager immediately.
(d) Stand Down Orders shall be issued, managed and lifted in accordance with FAI Child Welfare and Safeguarding Policy.
(e) Any person wishing to continue to engage within football who is the subject of a vetting disclosure, which in the opinion of the Child Welfare and Safeguarding Committee or the FAI Child Welfare and Safeguarding Manager deems them unsuitable to work with Children or Vulnerable Persons, shall be issued with an immediate Stand Down Order.
(f) Where it is determined that urgent action is required for any reason an immediate Stand Down Order shall be issued by the FAI Child Welfare and Safeguarding Manager or by the Club. A written explanation as to why such order was issued must be included when notifying the FAI Child Welfare and Safeguarding Manager.
6.5. Where a Stand Down Order has been issued directly by the Club, that member must immediately inform the FAI Child Welfare and Safeguarding Manager to determine if such a stand down should be applied to all FAI football related activity. The notification must include a written explanation as to why the Stand Down Order was issued.
7. Disciplinary Action
7.1. If, following an investigation, a person is found to have breached the Club or FAI Rules or committed an offence in relation to Child protection and welfare they shall be subject to disciplinary action. Such disciplinary action may be at Club level (such as in respect of a matter held to be poor practice) or at FAI level if appropriate or submitted to the FAI Disciplinary Bodies in accordance with the below procedure. Disciplinary action by the FAI may proceed notwithstanding any action by Statutory Authorities, however the FAI reserve the right to liaise with the Statutory Authorities in respect of any action and to take instruction from them in respect of same. Any delay in the initiating of disciplinary charges at the request of Statutory Authorities shall not prejudice later disciplinary action.
7.2. It should be noted that any action taken by the FAI under their policy is under football rules and policy and not indicative of any criminal or civil liability
8. GENERAL GUIDELINES FOR INTERACTION BETWEEN ADULTS AND CHILDREN
8.1. Conduct and Behaviour towards Children
(a) All adults involved in football have an important role to play in promoting good practice. Their first priority has to be the Children’s welfare, safety and enjoyment of the game.
(b) Adults should be aware of the emotional, physical and personal needs of Children and should ensure that Children are treated with integrity and respect.
(c) The trust implicit in adult Child relationships in sport places a duty of care on all adults, voluntary or professional to safeguard the health, safety and welfare of the Child while engaged in football.
(d) Adults have a crucial leadership role to play and contribute to the creation of a positive sporting environment for Children. This allows the Child to develop and express themselves in an open and secure way.
(e) The principles set out within this Policy should always be emphasised in football and Children should be given clear guidelines regarding acceptable standards of behaviour.
(f) The importance of participation for each Child, best effort and enjoyment rather than winning should be stressed. All Children should be valued and treated in an equitable and fair manner and every Child, irrespective of ability, should be involved in football in an integrated and inclusive way where possible.
(g) In particular all adult-Child relationships in football should be: - open, positive and encouraging;
- defined by a mutually agreed set of goals and commitments;
- respectful of the creativity and autonomy of Children;
- carried out in a context where Children are protected and where their rights are promoted;
- free from any abuse or any threat of such abuse;
- respectful of the needs and developmental stage of the Child;
- aimed at the promotion of enjoyment and individual progress;
- in accordance with Club and FAI policies and codes;
- respectful but not unquestioning of authority;
- aware that Children with disabilities or additional needs may be more vulnerable.
8.2. General Supervision of Children It is important to create a safe and enjoyable environment in which to play and train and to ensure any risks in relation to premises, training facilities and equipment are minimised with the implementation of appropriate safety rules. Children need to be supervised at all times as the likelihood of accidents happening increases when adequate supervision is not in place. In particular the following should be adhered to;
(a) Ensure adequate Adult: Child ratios, including one adult of each gender with mixed parties.
(c) Children should be supervised at all times.
(d) Adults should avoid being left alone with Children. Clearly state times for start and finish of training and/or competitions. If late collections occur, participants should remain in pairs until all players have left
(e) If a coach/manager needs to talk separately to a player this should be done in an open environment, in view of others.
(f) Respect the privacy of Children while changing, coaches/managers may only need to enter changing rooms where the Participants are very young or require special assistance. When necessary, Participants should supervise in pairs or seek assistance, it is the safety and welfare of the Participants that is of paramount importance.
(g) If a Child suffers an injury or accident the parents/guardians should be informed and necessary reports completed.
(h) Activities being undertaken should be suitable for the ability, age, and experience of the participants.
(i) Equipment and facilities should meet the highest possible standards and be appropriate to the maturity of the participants.
(j) All FAI Goalpost Safety Guidelines must strictly be adhered to and enforced.
(k) Where protective equipment is deemed necessary it should be used and first Aid should be available for all training sessions and matches.
8.3. Transport of Children
The Club’s Travel Policy should be adhered to at all times
8.4. Overnight and away trips
The relevant provisions of the Club’s Child Supervision Policy should be adhered to at all times.
8.5. Changing facilities
(a) Where possible Children should have sole use of changing facilities and all efforts should be made to try and secure separate facilities for Children. As many Children are self-conscious about changing in front of others it may become more suitable to ask Children to change at home before and after activities. A common-sense approach should be adopted as to what the parents/guardians may prefer.
(b) Where facilities are being used by Children proper supervision is required and careful consideration should be given to who should be supervising.
(c) Those persons should be suitable for such supervision, being vetted.
(d) Adults in such supervisory roles should balance the need of supervision with respect of the privacy of Children at all times.
(e) It is recommended that more than one adult supervise at any time and supervisors are of the same gender as the Children involved.
(f) Contact between other adults and Children should be avoided by careful timing of the changing facilities and adequate notices being put in place. Where mixed changing facilities with adults and Children are unavoidable proper adult supervision is even more important.
(g) Parents may be of valuable assistance but should also be suitable for undertaking this responsibility.
(h) Where mixed gender teams are involved arrangements should be made to allow for separate changing facilities. This can be accomplished through timing arrangements, changing at home only, allocating rooms or areas which are screened off
8.6. Accidents/Incidents
(a) Any accidents or incidents involving Children should be reported in full to the Children’s Officer by completion of the appropriate report in Appendix 8.
(b) If a Child is referred for medical treatment contact should immediately be made with the Child’s parent/guardian and the relevant consent form located for medical treatment.
(c) The Child should be accompanied by the person in charge of the Child, if for any reason enquiries should be made regarding any diagnosis or treatment.
(d) An incident report form should be completed in all cases whether medical treatment is required or not.
(e) In all cases insurers should be notified of the incident and the report form submitted for their records.
8.7. Insurance
(a) Appropriate Insurance must be in place to cover organised activities and programmes undertaken with Children or otherwise.
(b) Away trips must be included in such cover and your insurance company must be informed in advance of such trips.
(c) In relation to away trips, parents/guardians must be advised of the need for comprehensive personal insurance to cover the Child, to include but not limited to medical or health insurance.
(d) Adults transporting Children in their personal vehicles should be aware of the extent and limits of their own motor insurance cover, particularly in relation to acceptable numbers and liability.