Policy Owner/Designated Safeguarding Officer: Arnika Singh

Next Scheduled Review: May 2028

Applies to: All staff, consultants, volunteers, interns, and partner-institution personnel engaging with programme participants

• Child/Minor: any person under the age of 18 years, in line with the Indian Constitution, the Juvenile Justice (Care and Protection of Children) Act, 2015, and the POCSO Act, 2012.
• Safeguarding: proactive steps taken to protect children and young people from harm and to respond appropriately when harm occurs or is suspected.
• Abuse: physical, sexual, emotional, or online abuse, neglect, exploitation, or bullying/harassment – whether by an adult or by a peer.
• Online Harm: exposure to inappropriate content, grooming, cyberbullying, or misuse of a child's personal data or images, including during digital literacy or online-safety sessions themselves.

• The best interests and welfare of the child are paramount in every decision S&MM makes.
• Every child has an equal right to protection from harm, regardless of gender, caste, religion, disability, or background.
• S&MM operates a zero-tolerance approach to abuse, exploitation, and harassment of minors by anyone associated with its programmes.
• All concerns are treated seriously, recorded, and acted upon promptly, proportionately, and confidentially.
• Safeguarding is everyone's responsibility – not only that of the Designated Safeguarding Officer (DSO).

All personnel engaging with programme participants must:

• Never be alone, unsupervised, with a single child in a closed or private space; sessions and interactions must be conducted in open, visible, group settings.
• Never contact a participant through personal social media, phone, or messaging accounts; all communication must go through official, logged, S&MM/school channels, copied to a supervisor where practical.
• Never use physical punishment, threatening language, or emotionally coercive behaviour.
• Treat all participants with respect and dignity, and be attentive to signs of distress, harm, or disclosure.
• Immediately report any concern, disclosure, or breach of this Code including by colleagues through the reporting procedure in Section 7.

Breach of this Code of Conduct may result in disciplinary action, up to and including termination of engagement and referral to appropriate authorities.

S&MM applies the following safeguards when engaging anyone staff, consultant, volunteer, or corporate employee volunteer who will have direct contact with programme participants:

• Police Verification Certificate / background check prior to confirmation of role.
• Minimum two professional references, checked prior to engagement.
• Mandatory safeguarding orientation completed before any unsupervised or direct contact with participants.
• Signed acknowledgement of this Policy and the Code of Conduct (Section 4) as a condition of engagement.
• Corporate employee volunteers (e.g., for mentoring circles, career talks) undergo the same orientation and sign the same Code of Conduct before any participant contact, and only engage in supervised, group-based formats, never one-on-one unsupervised interaction.

Designated Safeguarding Officer (DSO)

S&MM designates a named Safeguarding Officer responsible for:

• Acting as the first point of contact for all safeguarding concerns and disclosures.
• Maintaining a confidential log of concerns, actions taken, and outcomes.
• Escalating cases to statutory authorities (Childline 1098, local Child Welfare Committee, or police) where required by law.
• Ensuring staff, volunteer, and partner-institution safeguarding training is delivered and refreshed periodically.
• Reporting safeguarding trends and incidents (in anonymised form) to S&MM's leadership/Board and, where relevant, to programme donors.

All Staff, Facilitators & Volunteers

Any person staff, volunteer, participant, parent/guardian, or partner-institution representative who has a concern about the safety or welfare of a child, or who receives a disclosure, must follow this procedure:

• Do not investigate the matter yourself. Listen carefully, do not promise confidentiality to the child, and reassure them they were right to speak up.
• Record what was said/observed as soon as possible, using the child's own words where possible, without leading questions.
• Report immediately (same day) to the Designated Safeguarding Officer through the confidential reporting channel: arnika@socialmediamatters.in
• The DSO will assess the concern, decide on next steps within 24–48 hours, and, where the concern meets the threshold under the POCSO Act, 2012 or Juvenile Justice Act, 2015, ensure mandatory reporting to the appropriate authority (police / Child Welfare Committee / Childline 1098).
• All records are stored securely, accessible only to the DSO and, where necessary, S&MM's leadership, in compliance with Section 9 (Data Protection) below.
• S&MM will not permit any person against whom a credible concern has been raised to continue unsupervised contact with participants while the matter is reviewed.
  

S&MM prohibits retaliation of any kind against a person who raises a safeguarding concern in good faith, even if the concern is later not substantiated.

Given that S&MM's programmes are themselves delivered in digital/online literacy settings, this Policy specifically requires:

• Use of monitored, controlled devices and age-appropriate platforms during hands-on digital sessions.
• No collection of participants' personal social media handles, phone numbers, or personal accounts by staff or volunteers for programme purposes.
• Age-appropriate delivery of online-safety content itself, vetted by BAIF's technical partner prior to roll-out, avoiding graphic or distressing examples.
• Clear, age-appropriate guidance to participants on how to report anything that makes them uncomfortable during a session, including anonymised or peer-reporting routes.

• Informed, documented consent is obtained from parents/guardians (and age-appropriate assent from the adolescent) prior to baseline data collection, photography, or any recording.
• Participant data (assessment records, attendance, images) is stored securely with access restricted to authorised staff, and is not shared externally beyond BAIF reporting requirements without further consent.
• Data is retained only as long as necessary for programme monitoring and reporting, per S&MM's data retention schedule.

(For completion by the Designated Safeguarding Officer or the staff member receiving a report, as soon as possible after the concern is raised.)

Date & time of report:
Name & role of person reporting:
Name of child/young person involved (if known):
Location/programme site:
Description of concern (facts, in the reporter's own words):
Immediate action taken:
Reported to (DSO name):
Escalated to external authority? (Y/N, details):
Follow-up/outcome: