Child Safeguarding Policy · Down Syndrome Albania

Updated: June 2026

Down Syndrome Albania Foundation (DSA) is a nonprofit organization founded in September 2013 by the parents of a child with Down syndrome, who saw an urgent need to create a more supportive, inclusive and equal environment for persons with disabilities in Albania. Since its founding, DSA has worked to promote the rights of persons with disabilities, especially persons with Down syndrome and their families, contributing to a more inclusive society built on respect for human rights. The organization is guided by the principles of equality, non-discrimination, active participation and respect for the dignity of every individual.

Over the years, DSA has developed and offered a wide range of professional services for children, young people and their families, including multidisciplinary assessments, developmental therapy, psychological support, early intervention programs, parent training, and activities that promote independence and social inclusion. In 2014 the organization opened the PRO PAK Service Center, one of the first specialized centers in the country providing services for children with disabilities. Besides direct services, DSA has played an important role in advocating for more inclusive policies and practices in health, education, social protection and employment. The organization works closely with public institutions, national and international organizations, professionals from different fields and the community of families to improve the quality of life of persons with disabilities and to guarantee equal access to services and opportunities.

Vision

A healthy, independent and inclusive life for individuals with disabilities in Albania.

Mission

To support the full development of individuals with disabilities in Albania. To promote and protect their rights through the value of human rights and based on the principles of non-discrimination, individual dignity, acceptance and inclusion, by raising awareness, advocating and working transparently with high ethics and professionalism.

Document versions

Year	Prepared by	Details	Reviewed and approved by
2018	Senior management team (Mirela Juka & Flavia Shehu)	First draft developed	Executive Director
2020	Senior management team (Mirela Juka & Flavia Shehu)	Revision	Executive Director
2023	Senior management team (Mirela Juka & Flavia Shehu)	Revision	Executive Director
2026	Senior management team (Mirela Juka & Flavia Shehu)	Second draft, based on the NISMA ARSIS template	Executive Director

Approved by: Emanuela Zaimi, Executive Director; Flavia Shehu, Head of the Service Center; Mirela Juka, Program Manager.

Definitions

Child: Any person under the age of 18. If a person's age cannot be determined precisely but there is reason to believe that the person is a child, they will be considered a child for the purposes of this policy until their age is determined under the legislation in force.
Child abuse: Any act or failure to act by individuals, institutions or processes that directly or indirectly harms children or damages their prospects of a safe and healthy development into adulthood. The main categories of child abuse are physical abuse, emotional abuse, neglect/negligent treatment, sexual exploitation and abuse, and exploitation.
Physical abuse: Occurs when a person deliberately harms or threatens to harm a child. Physically abusive behaviour includes pushing, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning. Physical injury or suffering may include, but is not limited to: bruises, marks, soft tissue swelling, haematomas, fractures, sprains, dislocated joints, burns, organ damage, death, permanent disfigurement and any other injury that is not minor.
Neglect: The persistent failure, where the means exist, or the deliberate refusal to provide a child with clean water, food, shelter, sanitation, supervision or care, to the extent that the child's health and development are put at risk.
Emotional abuse: A persistent attack on a child's sense of self-worth. It may happen as an isolated event or on an ongoing basis. It includes, but is not limited to: humiliating or degrading treatment, failure to meet the child's emotional needs, rejection, ignoring, terrorizing, isolating or confining the child. Examples are name-calling, threats, ridicule, shaming, frightening or isolating the child.
Child sexual abuse: Occurs when a child is used by another child, an adolescent or an adult for their own sexual stimulation or gratification. It includes all forms of sexual violence and coercion, sexual enticement, manipulation or deception, including incest, early and forced marriage, rape, involvement in or exposure to indecent images/videos (pornography), sexual slavery/trafficking and sexual relations with minors. It may include inappropriate touching, exposure of intimate parts, the use of sexual language towards or about a child, and the process of grooming. Sexual abuse does not always involve physical contact. Sexual exploitation is any actual or attempted abuse of a position of vulnerability, power or trust for sexual purposes, including financial, social or political gain from the sexual exploitation of another person.
Grooming: The process in which an adult builds a relationship with a child or the child's carer to gain their trust with the aim of sexually abusing and/or exploiting the child. The process usually develops in stages and may happen online or face to face, by a stranger or by someone the child or carer knows. Because it is gradual, it is often difficult to identify.
Child exploitation: Involves the sexual abuse of a child by an adult and payment in cash or in kind to the child or a third party. The child is treated as a sexual object and at the same time as a commercial object. The Commercial Sexual Exploitation of Children is a form of coercion and violence against children, and is considered forced labour and a modern form of slavery.
Online child sexual exploitation: Includes all acts of a sexually exploitative nature carried out against a child that are, at some stage, connected to the online environment. This includes any use of Information and Communication Technologies (ICT) that results in the sexual exploitation of a child, or in the production, purchase, sale, possession, distribution or transmission of material documenting such exploitation.
Child labour: Often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to their physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and that interferes with children's schooling and recreational activities. In its most extreme forms, child labour involves enslavement, separation from the family and exposure to serious hazards and illness.
Child marriage: A formal marriage or informal union before the age of 18. It affects both girls and boys, although girls are affected disproportionately. Early marriage can lead to a life of disadvantage and deprivation.
Child trafficking: Includes any role in the recruitment, transport or receipt of children for the purpose of exploitation, through threats, force or other forms of coercion, including the abuse of power.
Child in need of protection: A person under the age of 18, regardless of their legal capacity under the legislation in force, who may be a victim of abuse, neglect, exploitation, discrimination, violence or criminal offences; as well as a person under the age of criminal responsibility who is suspected or accused of committing a criminal offence, and children in conflict with the law.
Child protection: Preventing and responding to violence, abuse, exploitation and neglect of children, including abduction, sexual abuse, trafficking and child labour.
Child participation: An ongoing process of actively involving the child and respecting their right to express their views and to be heard at all levels of decision-making on matters that affect them.
Child safeguarding: The set of policies, procedures and practices used to ensure that DSA is a safe organization for children. It covers collective and individual responsibility, as well as preventive action to protect children from intentional or unintentional acts that may put them at risk or cause them harm by staff, representatives and third parties who have contact with children or affect them through the organization's programs, protective interventions and operations. It also covers the management of children's personal data.
Child welfare: Consists of creating a safe community for children. It covers suspected cases of child abuse that occur outside DSA and/or that by law or local norms must be reported to the relevant authorities, including abuse in the family, the community or institutions.
Domestic violence: Includes verbal, physical, sexual or emotional violence within the family or home that the child witnesses, usually repeatedly.
Contact with children: Work or activity that involves or may involve direct contact (including online contact) or indirect contact (such as the use of children's images) with children. This contact may be part of the job description or may occur in the course of the work, for example during community activities.
Working with children: Means taking part in an activity with a child where contact with the child is reasonably expected as a normal part of the activity and is not incidental. Work also includes volunteering.

Introduction

The Child Safeguarding Policy and its procedures apply to all operations and activities carried out by or on behalf of DSA. This policy recognizes and strengthens our commitment as an organization to guarantee the safety of children and to protect them from all forms of harm and abuse. DSA offers protection to every child, young person and family in a vulnerable situation, and respecting children's rights and promoting their wellbeing are at the heart of our work.

The purpose of the Child Safeguarding Policy and Procedures is to govern how we act as an organization, so that the children we are in contact with (directly or indirectly) are protected and their wellbeing is promoted, and to ensure that our actions, while carrying out programs or institutional activities, do no harm to children.

The Child Safeguarding Policy is a statement of the professional expectations the organization has of its employees and other persons when they come into contact with children in the course of their duties. All employees and other adults who have contact with children must be aware of the requirements of this policy, bearing in mind that there is a "duty of care": employees and others must not only apply the principles of good practice when working with children, but also have a responsibility, and in many cases a legal obligation, to guarantee the protection and safety of the children in their care.

Children are exposed to the risk of harm from many sources, so employees and others are responsible for reducing these risks by challenging inappropriate practices and by identifying and managing the risks that may affect the children they work with.

Statement of commitment and guiding principles

This document has been prepared in line with national and international legislation and standards on the rights, safety and support of children and young people.

The best interests of the child will be the primary consideration in every action concerning children. Children must be protected and promoted in every situation and in every context.

In all actions concerning children, and when dealing with any concern about the safety or wellbeing of a child, the best interests of the child will be our primary consideration.

DSA believes that children have the right to be active participants in all matters that affect their lives, and that they are able to make choices and take decisions in line with their development.

Decisions about children and young people will be made, as far as possible, with their participation and in their best interests, taking full account of the impact these decisions may have on them.

There may be times when adults must make decisions on behalf of children to protect them from harm or danger, but even then the best interests of the child must remain the main consideration in the decision-making process.

If this policy is breached and harm is caused as a result, DSA undertakes to listen to the child and to act in line with the child's wishes and interests, as set out in Law no. 18/2017 "On the Rights and Protection of the Child".

Reference documents and standards

This policy is based on the following national and international documents and standards:

The Convention on the Rights of the Child (CRC), which provides the international framework for the right to protection from all forms of violence, discrimination and exploitation.
Resolution S-27/2 "A World Fit for Children" (2002) and General Comment no. 13 (2011) of the Committee on the Rights of the Child on the right of the child to freedom from all forms of violence, which set the protection of children and adolescents as an absolute priority.
The Child Safeguarding Policy Guidelines of the ChildFund Alliance.
The Minimum Standards for Child Protection in Humanitarian Action (2012), prepared by the Child Protection Working Group.

All children, without exception or distinction of any kind, have the right to be protected from all forms of violence and to have their dignity respected.

Any form of violence against children or between children is a violation of their rights.

Zero tolerance of abuse, exploitation and any form of violence against children

DSA applies a zero-tolerance approach to any form of child abuse and exploitation. This commitment is carried out through strong preventive measures and effective response mechanisms, by supporting victims and by holding accountable those responsible for harm caused or for unacceptable behaviour.

DSA will ensure that everyone involved in carrying out its activities and programs has access to the information they need on how to report concerns or allegations of exploitation, child abuse or other breaches of this policy.

The organization will take immediate action after any report or reasonable suspicion of a breach of this policy, always putting the safety, protection and best interests of the child first.

Everyone is responsible for protecting children

This policy is binding on everyone who works for or on behalf of DSA, including employees, volunteers, partners and any other collaborators.

Although the organization will provide ongoing training, advice and support, each person is responsible for actively fulfilling their obligations regarding child safeguarding and for helping to create a safe environment for children.

Every employment contract, service contract or volunteering agreement must be accompanied by the signing of the Child Safeguarding Policy, or by a statement confirming knowledge, acceptance and respect of this policy, as set out in the relevant employment or service contract.

An active network of child safeguarding and positive treatment is promoted within the organization, joining efforts to ensure that children are effectively protected

Child safeguarding is a priority for DSA, recognizing that abuse, neglect or harm can develop and remain undetected when staff, volunteers, partners, children, families and community members do not feel safe or able to raise their concerns.

For this reason, the organization promotes a culture of positive treatment, respect and child safeguarding, encouraging open communication, the reporting of concerns and cooperation among all parties involved.

Particular attention is given to creating and maintaining safe environments for children at the center, and to suggestions for the family and the community that support their healthy and positive development.

In all interventions and activities, the individual needs and specific situations of children are taken into account, especially of those facing particular circumstances or vulnerability factors within their communities, in order to guarantee their protection, inclusion and wellbeing.

All reports and concerns about the safety and protection of a child will be taken with full seriousness

Where necessary, immediate and appropriate measures will be taken to protect the child and to act against the alleged perpetrator. These measures may include referring the case to law enforcement bodies and to the structures responsible for child protection.

Where allegations or suspicions concern members of staff, volunteers, partners or collaborators of the organization, the measures taken may also include temporary suspension or termination of employment, of the volunteering engagement or of any other form of collaboration.

DSA responds to every case of violence, abuse, neglect or exploitation of children, whether suspected, attempted or committed. Each case is handled according to its nature and circumstances, with care and professionalism, guaranteeing confidentiality and the protection of information for all parties involved, especially for the child.

Confidentiality

DSA is committed to maintaining confidentiality when handling and sharing sensitive information related to child safeguarding incidents and reports.

Information that could identify individuals will be shared only when necessary and with full consideration of the safety and best interests of the child, of witnesses or of the person against whom the complaint was made, and to protect the integrity of the investigation or verification of the case.

All information will be handled with care and professionalism, and in line with the legal and ethical requirements for the protection of personal data and rights.

Commitment to good practice

We raise awareness and influence others about the importance of child safeguarding, using our policy and procedures as a means of demonstrating our commitment and explaining the values that guide our work.

We will share this policy and its procedures with interested parties and will be open to comments, suggestions and assessments of its implementation and suitability.

There is no single way to guarantee the protection of children and the promotion of their rights. Child safeguarding measures and solutions must fit the culture, the context of operation and the nature of the activities carried out.

Whenever possible, the opinions and views of children are gathered and taken into account to guide the drafting, implementation and review of this Child Safeguarding Policy.

In every case, this policy must be a known, understandable and accessible tool for children themselves, so that they are informed about their rights, the protection mechanisms and the ways to report concerns or possible cases of abuse.

The policy

DSA has adopted this policy as a statement of its commitment to the protection and wellbeing of the children it serves. The policy is intended to be used internally for communication, orientation and training, and externally for information, presentation and public distribution.

DSA's Child Safeguarding Policy aims to:

ensure that the organization fulfils its responsibilities for child safeguarding and responds appropriately to any concern or suspicion that children's safety and wellbeing are at risk;
provide guidance for employees, volunteers and other collaborators, and set clear expectations for preventing, identifying, reporting and responding to cases of abuse, neglect, exploitation or any other form of harm;
reduce the risk of harm and abuse through safe and responsible processes for recruiting, selecting and engaging employees and collaborators;
ensure that the procedures for protecting children and reporting concerns about their wellbeing are followed and applied correctly, including referring cases to the competent authorities when necessary;
reduce the risk of harm and abuse by promoting an organizational culture that is open, transparent, aware and responsible on child safeguarding issues;
promote good professional practice, ensuring the appropriate protection and safety of children while they are in the care of or in contact with DSA, and enabling staff and collaborators to respond competently, confidently and professionally to child safeguarding issues.

DSA's Child Safeguarding Policy establishes that:

DSA is committed to promoting and protecting children's rights in all its projects, programs and activities, treating the prevention of and fight against abuse, neglect, exploitation and any other form of harm as a core priority;
all employees, volunteers and other persons engaged by DSA have a clear understanding of their roles and responsibilities in preventing the abuse, neglect, exploitation and harm of children;
all employees, volunteers and collaborators of DSA are clearly informed about the procedures for receiving, handling, responding to and reporting any concern, suspicion or allegation of abuse, neglect, exploitation or threat to the safety of children.

Implementing the policy: procedures

Prevention is the foundation of child protection and safety. DSA is committed to preventing any form of harm, abuse, neglect or exploitation of children by applying appropriate measures and procedures in the following areas:

1. Risk assessment and management

DSA is committed to a systematic approach to risk assessment and management, in order to promote the wellbeing and safety of all its children, families, staff, contractors, programs, operations and visitors, by identifying and managing the main risks.

The purpose of this comprehensive risk assessment and management process is to ensure that suitable and sufficient assessments are carried out for all activities where there is a possibility of significant risk. Particular attention must be given to the main risk areas, such as the organization's programs involving children and the services provided to them.

The risk assessment will take the following elements into account:

a) Hazards – identifying any factor, situation or action that has the potential to cause harm;

b) Risk – assessing the likelihood that one or more hazards will cause harm;

c) Risk rating – assessing how serious the consequences of a given event or situation could be;

d) Control measures – identifying the physical, organizational and procedural measures that can be applied to prevent or reduce the risk.

With this in mind, the risk assessment process will consist of six main steps:

a) What could go wrong?

b) Who could be harmed?

c) How likely is it to happen?

d) How serious would the consequences be if it happened?

e) What measures will be taken to prevent it from happening?

f) How will the effectiveness of the planned measures be monitored and verified?

This process must be documented by completing and recording the risk assessment form (a template is given in Annex 1), by the employee responsible for organizing the activity.

The risk assessment form must be submitted for review and approval to the person responsible (Focal Point) for implementing this Child Safeguarding Policy.

2. Child-safe recruitment

DSA recognizes that creating safe environments for children begins with selecting and appointing qualified, professionally capable and vetted staff who have the competences, skills and integrity needed to carry out their functions effectively, efficiently and safely.

The recruitment processes applied by DSA always aim to serve the best interests of children and reflect the organization's commitment to protecting children and preventing any form of abuse, neglect or exploitation.

Staff recruitment

In addition to DSA's standard recruitment procedures, the following child safeguarding measures also apply:

Job advertisements and application documents must state that recruitment is carried out in line with the principles and practices of child-safe recruitment.
Clear job and role descriptions are drawn up for every position, with direct reference to child safeguarding responsibilities and a specification of the child safeguarding competences required.
Candidates are shortlisted through a formal application process, based on criteria set according to the requirements of the position, the qualifications needed and the principles of the Child Safeguarding Policy.
Interviews are conducted in line with equal opportunity principles, and interview questions are based on the job description and the required candidate profile.
Formal job offers are made only after the checks needed to establish the candidate's suitability have been completed, in line with this Policy and the requirements of the position. For this purpose, documents or information related to education, qualifications, health or other necessary data may be requested, only if they are strictly related to the function of the position. Their use will be limited to the purpose for which they were collected and will respect the legislation on privacy and the protection of personal data.
In particular cases, candidates may also be asked to provide the names and contact details of two referees, who will be invited to give professional references, including their assessment of the candidate's suitability to work with or be in contact with children. DSA reserves the right to also contact the candidate's previous employers.
The successful candidate will be offered the position only if the following conditions are met:
- documents proving the qualifications declared;
- successful completion of the vetting and checking procedures;
- valid identity documents confirming their identity.

Selection of consultants and contractors who work with children

All consultants, experts or other contractors identified as persons who will work with or have contact with children will be subject to the relevant vetting procedures, which may include a criminal record check, in line with local legislation.

3. Volunteers and visitors

This section deals specifically with child safeguarding in the context of occasional volunteer support for DSA's activities, and of visitors who attend the organization's programs and premises.

Official visitors may visit DSA's projects or activities only with the organization's prior authorization and approval.
All visitors must report to the person in charge on arrival and register by signing the Visitor Declaration.
The host employee is responsible for making sure that visitors and volunteers are properly informed of the organization's rules and are supervised throughout the activity or visit.
All occasional volunteers and visitors must be accompanied at all times by a member of staff or an authorized person. Under no circumstances may they be left alone or unsupervised with children.
All regular employees and volunteers will have to provide the documents and evidence required under point 2, "Child-safe recruitment". This measure aims to ensure that unsuitable persons have no opportunity to work with or be in contact with children.

Volunteer recruitment

Where a volunteer's agreed responsibilities involve direct or indirect contact with children, the recruitment and selection process will follow the same standards and procedures that apply to hiring permanent staff or engaging consultants.

If a volunteer or visitor refuses to commit in writing to respecting this Child Safeguarding Policy and the mandatory Code of Conduct, or does not respect the obligations undertaken in the signed declaration, their volunteering engagement will be ended and/or their visit will end immediately.

4. Code of conduct

All persons covered by this policy undertake to respect, promote, support and protect the rights of the child at all times, as set out in the United Nations Convention on the Rights of the Child.

The standards of behaviour set out in this code are binding on all persons covered by this policy in their relations with and behaviour towards children. Compliance with these standards will be interpreted in line with the principles and provisions of the United Nations Convention on the Rights of the Child.

Anyone found to have breached this Code of Conduct will be subject to the relevant disciplinary measures, which may go as far as ending their employment, volunteering engagement or any other form of collaboration with the organization.

Standards of behaviour

Always treat children with respect, regardless of gender, ethnic or social origin, language, religion or other beliefs, disability, sexual orientation, gender identity or any other status.
Use appropriate language and behaviour with children at all times, and avoid any communication or action that could be harassing, abusive, sexually provocative, humiliating or degrading.
Whenever possible, ensure that another adult is present when children are in private spaces not monitored by cameras, unless the necessary protective measures and safeguards have been put in place beforehand.
Inappropriate use of computers, mobile phones, photo or video cameras and any other electronic device is prohibited, including accessing, viewing, creating, downloading or distributing material that depicts the sexual abuse of children.
Any form of physical punishment, physical discipline or inappropriate use of physical force against children is prohibited.
Using children for domestic work or other forms of work is prohibited when the work:
- is not suitable for the child's age or level of development;
- prevents the child from taking part in education or recreational activities;
- exposes the child to the risk of harm, exploitation or abuse.
Report immediately any concern, suspicion, incident or allegation of actual or possible abuse of children, and any breach of this policy, in line with the relevant procedures and to the Designated Responsible Person, who is responsible for receiving and handling these reports.
A person who makes a report in good faith will not be subject to any form of retaliation, discrimination or negative consequence. Reports may also be made anonymously, although this may limit the possibility of fully investigating the allegations.
Any sexual activity or sexual relationship with children is prohibited, regardless of the legal age of consent or the age of majority set by local legislation. A claim that the child's age was mistakenly assessed is not a justification or a defence.
Sexual exploitation and abuse by the organization's employees, volunteers or representatives are considered serious disciplinary offences and are grounds for immediate termination of employment or engagement.
Exchanging money, employment, goods, services or any other benefit for sexual relations, sexual favours or humiliating, degrading or exploitative behaviour is prohibited. This includes assistance or services that beneficiaries are entitled to receive.
Any sexual relationship between persons who provide assistance or protection and persons who benefit from this assistance is prohibited where the relationship involves an improper use of position, authority or influence. Such relationships undermine the credibility and integrity of humanitarian and social work.
The organization's employees, volunteers and representatives are obliged to create and maintain an environment that prevents sexual exploitation and abuse and that promotes the application of this Code of Conduct. Directors and managers at all levels have a particular responsibility to support and develop systems and mechanisms that maintain this safe environment.
Personal conduct outside working hours or outside DSA's activities may be considered a breach of this policy when it conflicts with its principles and requirements. DSA employees must respect the principles of the Child Safeguarding Policy both on and off duty. In assessing specific cases, the principles of reasonableness and proportionality will be applied, while also respecting the individual's private life.

5. Education, training and support

Awareness and training

DSA understands that, to make sure this policy is fully understood and applied effectively, there must be a high level of awareness and knowledge of its content, and staff, volunteers and other collaborators must be clear, confident and competent in applying it in practice.

For this reason, DSA undertakes to:

Distribute and promote the Child Safeguarding Policy through different forms of communication, such as the official website, printed copies of the document, information materials and verbal communication. Copies of the policy will be available and accessible to all interested parties, in both printed and electronic form.
Organize regular information sessions as part of implementing the policy. These sessions, or parts of them, will also be included in the standard induction process for all new employees.
Ensure that the information session on the Child Safeguarding Policy is mandatory and is held at least once a year.
Guarantee that newly recruited employees receive induction sessions on the policy after they start work. The Program Manager will set the deadline for attending the session, depending on the employee's role and responsibilities within the organization. In any case, the session must take place within three (3) months of the start of employment or before the end of the probation period.
Offer periodic update and refresher sessions, so that the policy remains an integral part of the organizational culture and staff are kept informed of changes, developments and improvements to its content and implementation.
Provide additional, more specialized sessions for persons with particular responsibilities under this policy. These include, among others, persons who work directly with children and the Designated Responsible Person for child safeguarding.
Guarantee that the sessions offered to managers and to persons in charge of receiving, handling and responding to child safeguarding complaints or incidents give them the knowledge and skills they need to respond effectively, professionally and appropriately to the cases reported.
Give employees, volunteers and collaborators access to materials, guides and support resources that help them understand, apply and respect the Child Safeguarding Policy.

6. Child-safe communication

The public use of children's images and stories can pose risks to their protection. It is therefore essential that, when using children's images and stories, we are always guided by the best interests of the child.

This means respecting their dignity and rights, including the right to privacy and the right to be heard. Consent must always be obtained before photographing, filming or using images of children.

DSA staff must ensure that:

any photograph, video or image taken by staff is taken only after the written or verbal consent of the parent, legal guardian or person responsible for the child's care has been obtained;
published images, stories or materials do not reveal the child's identity or location;
particular care is taken to preserve the anonymity and identity of children in vulnerable situations or with special protection needs;
photographs or images of children taken during field visits, activities or programs of the organization are not published or shared on DSA employees' personal social media accounts.

In every case, photographs, videos, personal stories and any other material concerning children must be used ethically, with dignity and safely, avoiding any form of stigmatization, discrimination, unnecessary exposure or violation of their rights.

Risks of images

The public use of children's images and stories carries potential safeguarding risks:

Images containing personal information can be used to identify children, to contact them remotely or to trace them to where they live.
Images can be altered or adapted for inappropriate use.
Showing and using inappropriate images or stories, or ones for which consent has not been obtained, is unethical and may create risks for the organization, such as damage to its reputation.

Rules on personal information

Personal information about a child (such as their full name and date of birth, or the full names of family members) and information that could be used to identify their location (such as the name of their town/village, community, school, etc.) must not be used, especially when accompanied by images.

The most information allowed about a child is their first name and the name of the area/region where they live.

1. Children in sensitive situations

Children who have experienced violence, exploitation or abuse, or who are at particular risk, must not be presented in a way that could lead to their identification.

Real names must be changed, and the change must be noted.
Other identifying details must also be changed.

2. Dignity and privacy

Images of children in a state of undress must not be shown, nor poses that could be interpreted as sexually suggestive or that undermine their dignity and privacy.

3. Data storage

All images and stories, together with the related data, must be used and stored in line with data protection and privacy laws.

It is recommended that:

images are stored securely (e.g. in a safe/locked cabinet, password-protected electronic folders, restricted access, etc.);
images are destroyed two years after the date of consent, unless new consent is obtained.

4. Consent

The informed, verbal consent of the child and the parent/guardian must always be obtained before a photograph is taken and used.

The intended use of the images and the possible risks must be clearly explained, especially when they are published online.
Child-friendly forms must be used.
Where possible, the child and the family should see the image before it is published.

5. Group photographs

As with individual photographs, the use of the photos must be explained and the consent of each individual in the group must be obtained.

People who do not wish to be included must be given the chance to opt out.

6. General photographs

When images are taken of crowds or public events where it is difficult to obtain individual consent, the following should be considered:

Do the children expect to be photographed at this event?
Do they consider themselves to be in a public place with no expectation of privacy?
Is it impossible for someone to object to the photo being taken?

When photographs are taken at planned events, participants must be informed in advance and given the option of not being included in the photographs.

7. Designing and running therapy programs

Programs and all types of intervention, in every sector of work and not only those directly related to child protection, must integrate child safeguarding principles at every stage of their planning and implementation. Child safeguarding should not be considered a separate activity, but a cross-cutting principle that runs through all of the organization's work.

Child safeguarding must be considered at every stage of designing projects and programs, and reviewed regularly while monitoring and evaluating their implementation.
Besides building child safeguarding into the design, a risk assessment must be carried out when organizing specific residential or non-residential activities, such as consultations with children, summer camps, recreational activities or similar initiatives, to identify possible risks and set the measures needed to minimize them.
Where necessary, staff, volunteers, partners, children and communities should receive additional guidance to make sure that the principles and objectives of the Child Safeguarding Policy are fully applied within specific activities or programs. This guidance may focus on identifying particular risks or on the protective measures that must be respected.
Before activities take place, written consent must be obtained from parents or legal guardians, and from the individual themselves according to their age and level of understanding. The Parental Consent Form is used for this purpose (see Annex 3). Where parents or children cannot read or write, the form may be signed in their presence by an authorized employee or volunteer, after its content has been explained and discussed with them in an understandable way.
Employees and volunteers who work with children must be supervised regularly and have the opportunity to take part in professional discussion and reflection on child safeguarding issues, through meetings, informal discussions, analysis of practical cases or other forms of professional exchange.
Child safeguarding issues must be reviewed regularly during and at the end of activities, in order to identify lessons learned, improve practice and make the necessary adjustments while programs are running. For example, during a program of summer activities, it would be useful to hold a discussion on child safeguarding at the end of each day, during the activity's reflection and evaluation meetings.

8. Reporting and responding to child safeguarding concerns

DSA is committed to responding to all reports or signals, including rumours, suggesting that a child may have been harmed or is at risk of harm. The safety of children must always be the main and unchanging concern.

The Child Safeguarding Focal Point is responsible for making sure that the reporting procedures described below are followed correctly, so that suspected cases of abuse and/or breaches of the Child Safeguarding Policy by DSA staff are handled appropriately and referred immediately to the relevant authorities when necessary.

The Child Safeguarding Focal Point

The Child Safeguarding Focal Point is the central point for reporting and referring concerns about child safeguarding issues, and for coordinating interventions and following up cases.

For the purposes of these procedures, the functions of the Focal Point (PO) will be carried out by their manager. However, where the PO is unable to respond within the set deadlines, action must be taken by the person temporarily appointed to this role. Any temporary appointment is made by the Executive Director and communicated to all staff. The PO role is delegated only to an employee who has the knowledge, skills and training needed to carry out this function. Their formal appointment is also confirmed by the Executive Director.

Responsibilities of the Focal Point (PO)

The PO is responsible for:

Making sure there is a written record of every formal referral and sending it to the Executive Director within 24 hours. A clear reporting line between the PO and the Executive Director ensures that all decisions are taken in consultation with, and with the knowledge of, those responsible for the organization.
The first step in every reported incident is to guarantee the safety of the child or children involved.
All reports and concerns must be documented using the relevant form (Annex 4).
Making sure that all notes and records of concerns about children are kept, even when no immediate referral is required.
Making sure that these records are kept confidentially and securely, separate from case files, with a cover page listing dates and brief notes to give a clear chronology of events.
Making sure that the relevant case files note the existence of child safeguarding records.
Applying disciplinary measures arising from breaches of this policy proportionately and justifiably, depending on the nature of the breach. Each case will be assessed individually before measures are decided.
Making sure that the reporting mechanisms and referral pathways are widely known and easily accessible.
Acting as a contact point for staff to discuss concerns and to cooperate with other agencies and professionals.
Taking part in child protection conferences, or delegating this task to another suitably informed and trained member of staff.
Continually updating their knowledge to fulfil the role, including by attending relevant training.
Offering advice and guidance to colleagues, taking part in inter-agency meetings (or supporting other staff in these meetings) and contributing to professional case assessments.

Reporting and referral procedures

What to do if you have concerns about a child's safety:

A child comes to you and tells you that they are being, or have been, harmed, abused or neglected;
You are told about such a disclosure by a member of staff, a volunteer or other persons;
You are concerned that a child is, or may be, exposed to abuse or injury.
Make a written note of the information/observation, including a record of the time, the date and the persons present, as follows:
General enquiry (how to protect children) – response within 24 hours;
Non-specific/unclear allegations (no names / identifying characteristics) – response within 72 hours
Specific – e.g. names / places are mentioned, and reporting – initial decision on action within 48 hours;
Sensitive – involving DSA staff, volunteers, the Board and other "sensitive" staff – initial decision on action within 24 hours.

Make a written note of the information/observation, including a record of the time, the date and the persons present.

Inform your line manager within the time frame mentioned above.

The line manager will assess the incident and/or make a referral to the Protection Officer.
Where it is impossible for the PO to respond within the set deadlines, action must be taken by the person temporarily appointed to carry out this role.

If your line manager is not available, contact the Protection Officer.

Does the child need urgent medical or police assistance?

Yes – Contact the emergency services immediately. Stay with the child until the emergency services take over, contact the PO and complete the form.

No – Contact the PO (Protection Officer).

What to do in the case of allegations against an employee or other persons:

You are concerned that the behaviour of a member of staff or another person is threatening, or potentially threatening, to a child's wellbeing.

Report your concerns to the Protection Officer immediately.
Where appropriate, mitigating measures may be taken and/or a referral made to an external agency.

In all situations, you must give a written summary of your concerns. If the matter is referred to external agencies or the police, you may be asked to give a formal statement of your concerns for later external investigations.

In the absence of the person with the authority to take decisions, if a child is in a life-threatening situation, the most senior member of staff available has the authority to take any decision needed to protect the child from immediate danger. Every decision taken and action carried out must be reported to the PO and the Executive Director.

Please note: If you have immediate concerns that a child is at risk of significant harm, contact the Protection Officer / Executive Director. If you believe a criminal offence has been committed, contact the police.

Managing the policy

1. Roles and responsibilities

All staff (including permanent staff, contractors, partners and volunteers) are required to apply the principles and guidance set out in this policy and the related policies. Specifically, within their role/job description, staff are expected:

to use the required procedures;
to promote good practice and contribute to discussions on child safeguarding;
to make sure that the voice of beneficiaries, the children whose protection is the purpose of this policy, is heard and taken into account;
to respect professional boundaries and the professional code of conduct referred to in this document.

DSA's Board members, the PO and the Management Team are also bound by this policy and have additional responsibilities:

to apply this policy properly and make sure it is accessible to anyone interested;
to monitor and review the policy;
to make sure that all staff have access to the right training/information;
to make sure that sufficient resources (time and money) are allocated to guarantee the effective implementation of the policy;
to receive the safeguarding concerns of staff and beneficiaries and respond to them seriously, promptly and appropriately;
to keep up to date with local arrangements, and to develop and maintain effective links with the relevant agencies;
to hold final responsibility for implementing, monitoring and reviewing this policy.

Staff are responsible for being vigilant, for knowing and being aware of the indicators of possible or actual harm, neglect and abuse, and for reporting immediately any concern, suspicion or allegation of abuse, making sure that the concern is taken seriously and reported.

2. Monitoring the policy

recruitment and selection procedures will be continually updated/improved;
formal briefings and awareness raising will be addressed to all employees and others;
all positions will be risk-assessed according to their level of contact with children;
the PO will be responsible for implementing the policy;
reporting concerns about child abuse will be mandatory for all employees and others;
local procedures will be developed for raising and reporting concerns about child abuse.

3. Communicating and committing to the policy

DSA will make beneficiaries aware of the Safeguarding Policy, using suitable tools that match the age and specific profile of each beneficiary, so that the principles and procedures of this policy are properly understood. As an indication, these tools may be:

easy-to-access and inclusive information packs on safeguarding measures, e.g. through leaflets, documents, information published on the web, etc.;
discussion and agreement with each beneficiary on safeguarding measures and the procedures for concerns/complaints.

Any person, such as sponsors, volunteers, contractors, suppliers, donors, journalists, consultants and supporters (occasional visitors), who visits DSA's facilities or offices and may have contact and/or interaction with children:

is given a copy of this policy and told that they must act in line with it while visiting DSA's premises;
declares in writing their commitment to respect and apply the principles of the safeguarding policy;
is properly informed about the reporting process and reports any concern about a child's wellbeing to the PO.

Prevention

by raising awareness of child abuse and the risks to children through implementing this policy;
safeguarding;
minimizing risks to children through risk assessments for all positions with contact with children, and by promoting awareness of abuse;
applying "best practice" in recruitment and selection;
protecting and supporting children, employees and others when there are suspicions, allegations, disclosures or witnessing of child abuse.

Rehabilitation and integration

raising concerns and reporting suspicions, allegations, disclosures and witnessing of child abuse within DSA and, where appropriate, to the relevant competent authorities;
knowing in advance the steps to follow and the persons to contact in case of child safeguarding concerns;
protecting and supporting children, employees and others who experience abuse through psychological, medical and legal support when needed.

4. Reviewing the safeguarding policy

The policy will be reviewed every year or in the following circumstances:

changes in legislation and/or government guidance;
as a result of any significant change or event.

Every year, DSA will carry out a self-assessment of safeguarding and of the implementation of the Child Safeguarding Policy. The assessment will be carried out using a set format.

Based on the self-assessment, an annual action plan will be developed to address any gaps in implementing the policy and to mitigate any risks identified.

Annexes

Annex 1: Risk assessment template

What is the risk?	Who could be harmed?	What are you already doing?	Do you need to take any further action to manage this risk?	Who will take the action?	When must the action be taken?	Arrangements agreed for monitoring by senior staff

Annex 2: Visitor declaration

I, ______________________________________, as a visitor to the center / office / community (e.g. donor, interpreter, journalist or any other visiting role), declare that I am aware of the importance of keeping confidential the information I receive during my visit to the organization's premises.

I undertake to fully respect the principles of confidentiality and of the protection of the personal data of beneficiaries, staff and the services provided by DSA, guaranteeing that no information received during the visit is shared or used for unauthorized purposes.

Specifically, I declare that:

I will not share any personal information about service beneficiaries with third parties, including but not limited to the media, family members, and public or private institutions.
I will not publish, share or comment on information about the beneficiaries, staff, activities or running of the center without prior written authorization from the parents/legal guardians or from the organization's management.
I will keep full confidentiality even after my visit to the organization has ended.
Any request for information or clarification about the organization's beneficiaries, staff or activities will be addressed only to the management or to persons authorized by DSA.

I understand that breaching this declaration may have consequences under the organization's internal regulations and the legislation in force on the protection of personal data.

Signature: _______________________
Date: _______________________
Place: _______________________

Annex 3: Parental consent form

Approval form for photos/videos/stories

This form is the declaration and the giving of informed, free and express consent by the participants in the activity, or by their parents/legal guardians, for the recording, processing, use and publication of photographs, videos, audio recordings and/or personal stories, in line with the legislation in force on the protection of personal data and image rights.

Subject of consent: The project and/or campaign ______________________, carried out by Down Syndrome Albania.

I, ______________________________________, as the participant/parent/legal guardian of the child ______________________________________, declare that I have been fully, clearly and understandably informed of the purpose, nature and manner of use of the audio-visual materials, and I give my free and express consent, without any form of coercion, for:

The recording of photographs, videos, audio material and/or the collection of personal stories during the activity: ____________________________________________;
The processing, storage, use, reproduction, publication and distribution of these materials by Down Syndrome Albania, for information, educational, promotional, awareness-raising, documentation and reporting purposes.

This consent covers, without territorial or time limitation, the use of the materials in print and electronic media, including television, radio, social media, online platforms, official websites, institutional publications, promotional materials and any other form of public communication, within and outside the territory of the Republic of Albania.

I expressly declare and accept that:

I have been informed of my rights regarding the protection of personal data, including the right of access, rectification and, where applicable, withdrawal of consent, in line with the legislation in force;
I will not request any financial compensation or any other form of reward for the use of the above materials;
I accept that the materials created may be kept and archived by Down Syndrome Albania for an indefinite period, for the purposes above;
Down Syndrome Albania has the right to use these materials in line with Albanian law on the protection of personal data and image rights, and with the relevant international standards on privacy and ethics.

By signing this form, I declare that I have read, understood and accepted its content, and I give my consent fully, freely and on an informed basis.

Full name: _________________________

Signature: _________________________ Date: _________

Annex 4: Child safeguarding reporting and recording form

1. Details of the child/children

Full name: ____________________________________
Age: ____________
Date of birth: ____________
Gender: ☐ Male ☐ Female
Address: ____________________________________
Languages spoken: ____________________________________

Additional factors that may increase the risk:

Other relevant information:

Details of the parent/legal guardian

Full name: ____________________________________
Age: ____________
Address: ____________________________________
Date of birth: ____________
Languages spoken: ____________________________________
Disability (if any): ____________________________________
Contact number: ____________________________________

Referral details

Date: ____________ Time: ____________
Place: ____________________________________
Contact person: ____________________________________
Profession: ____________________________________
Relationship to the child: ____________________________________

2. Details of the alleged person / subject of the concern

Full name: ____________________________________
Nationality: ____________________________________
Address: ____________________________________
Age: ____________
Gender: ☐ Male ☐ Female
Languages spoken: ____________________________________
Relationship to the child: ____________________________________

3. Description of the incident

Describe the incident as precisely as possible, based on what was seen or reported (include the time, location and persons involved, and the child's own words where possible):

Current safety of the child (including location):

Has urgent medical help been requested? ☐ Yes ☐ No
If yes, please specify: ____________________________________

Reported by: ____________________________________

Additional relevant information:

Persons/institutions aware of the case (with contact details where possible):

Agencies: ____________________________________
Family members / other persons: ____________________________________

4. Actions taken to date

(Include referrals and interventions made, e.g. police, social services, medical services, specifying the relevant dates, times and contacts)

5. Lessons learned, recommendations, actions taken and attachments

Lessons learned:
(Include an assessment of strengths and weaknesses in implementing the policy, case management, staff recruitment, supervision and internal procedures)

Recommendations:
(Give concrete recommendations for preventing similar cases and for improving the process of identification, reporting and investigation in the future)

Attachments / supporting documents:
(E.g. interview reports, file notes, official correspondence, other relevant documents)

Referral received by (the Designated Child Safeguarding Officer, where applicable):

Full name: ____________________________________
Position and location: ____________________________________
Date: ____________
Signature (printed copy): ____________________________

Annex 5: Code of conduct

Professional boundaries are set to protect professional integrity, appropriate distance and the proper relationship between the support worker and the beneficiary, and are based on a mandatory code of conduct.

The following boundaries and rules apply to, and are binding on, all directors, managers, consultants, assigned staff (permanent staff, contractors, external partners) and volunteers, and set out their obligation not to ignore or fail to report any concern, suspected breach or breach of the principles and measures of this safeguarding policy:

Treat every child equally and with respect, without any form of discrimination, racist or xenophobic behaviour, and with a positive, friendly and non-violent approach, respecting their personal and cultural identity in line with the principles of this policy.
Respect children's right to be heard and to take part in the procedures and decisions that concern them, by informing, encouraging and empowering them to exercise their rights.
Respect the principles of trust, confidentiality and the protection of personal data. In line with these principles, a secure process must be followed for sharing information between professionals and the competent parties involved. Any information, data or photograph relating to the beneficiary and their story is published only with their express permission, and only if it does not expose them to the risk of stigmatization. Particular care must be taken in the case of children.

It is prohibited:

To develop personal relationships between a member of staff (paid or volunteer) and a current beneficiary, or to enter into personal relationships (including on social media) with a person who has been a beneficiary in the last 12 months.
To share beneficiaries' personal contact details.
To take responsibility for valuables on behalf of a beneficiary.
To use abusive language, to respond to inappropriate behaviour/language with punishment, or any form of abuse.
To behave inappropriately (e.g. using inappropriate language), or to work under the influence of drugs or alcohol. Dignity must be maintained, and staff must serve as a role model for children.
Viewing, publishing, producing or distributing pornography involving children, and showing pornographic material to children, is prohibited at all times, both at work and outside it.

For children in particular, it must be ensured that:

A member of staff or a volunteer is never left alone with a child for any reason.
A child is never used as an interpreter in processes or responsibilities (e.g. interviews, social history, etc.).
Children are never touched, hugged or handled inappropriately, taking into account the child's perception and their cultural, ethnic and religious background and gender.
There is no cooperation with any private actor who acts against the best interests of the child.
There is no form of sexual relationship with persons under 18, and no inappropriate, harassing or degrading language or behaviour towards children.
There is no behaviour that negatively affects the child's self-confidence and self-esteem.
The child is not exploited for work (e.g. housework).
Children's faces are not published in presentations or publications, and no stories or images are published that could endanger or stigmatize the child, the family or the community.
Money is not given to children directly, nor is giving it encouraged, especially in vulnerable situations such as victims of exploitation, unaccompanied minors, victims of trafficking and street children.
No information or image of children is used without the written permission of the parents/guardians and without taking the child's opinion into account, and without forcing the child into public exposure. No information or photo may endanger the child or expose them to stigmatization.
DSA does not allow staff (paid or volunteer) to give or receive gifts/money from beneficiaries. However, gifts may be offered by the organization as part of a planned activity.
In case of a conflict of interest, the person concerned must discuss it with the designated manager/director and DSA's Board.

Breaching professional boundaries or policies may lead to disciplinary measures or to procedures for managing allegations. The employee must sign a declaration confirming that they have read, understood and accepted the policy and the code of conduct and committing to apply them, accepting that any breach may lead to the end of their engagement or to other disciplinary or legal proceedings.

Annex 6: Declaration for DSA staff and consultants

(to be attached to the employment or consultancy contract)

I have read and understood DSA's Child Safeguarding Policy and the accompanying Procedures and Guidelines.
I agree to apply DSA's Child Safeguarding Policy and Procedures.
I also declare that I have disclosed to DSA any matter that could raise child safeguarding concerns — real or perceived — about my suitability for employment or consultancy. I confirm that I have no criminal proceedings pending, and that I have not previously been convicted of any offence related to inappropriate behaviour towards children.

Name and signature: ……………………………………………………………
Date: ……………………………………………………………