Safeguarding Policy for Decimas de Leveza

Section 1: Policy Statement, Principles, and Aims
Policy Statement
At Decimas de Leveza, we are committed to safeguarding and promoting the welfare of all participants in our Erasmus+ projects (and other activities). We recognize our moral responsibility to provide a safe, inclusive, and supportive environment for all individuals.
Our safeguarding policy is designed to protect participants from harm and ensure that everyone, regardless of age, gender, cultural background, or ability, feels respected and valued. This policy applies to all staff, volunteers, and partners involved in our projects, as well as to all venues where our activities take place.

Principles
Our safeguarding principles are as follows:

• Everyone has a right to feel safe and protected, regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation.
• Safeguarding is the responsibility of all staff, volunteers, and partners.
• Individuals from marginalized groups, including those with disabilities, have a right to receive special consideration and support.
• Any disclosure of harm or abuse will be taken seriously, responded to promptly, and dealt with following this policy.
• All safeguarding concerns will be treated with confidentiality, shared only on a need-to-know basis in compliance with legal and ethical guidelines.

Aims
The aims of this policy are to:

• Provide all staff and volunteers with clear guidelines on how to safeguard participants and promote their welfare.
• Ensure consistent best practices across all projects and activities.
• Create a culture of safety, inclusion, and respect within Decimas de Leveza’s operations.
• Build effective partnerships with other organizations and agencies to enhance safeguarding efforts.

Section 2: Legal Framework
This policy is based on relevant legislation and guidance, including:

• Erasmus+ Programme Guidelines and Safeguarding Requirements.
• EU Charter of Fundamental Rights – Article 24 (The rights of the child) and Article 26 (Integration of persons with disabilities).
• GDPR Regulations for data protection and privacy.
• Relevant Portuguese legislation:
  • Lei de Protecção de Crianças e Jovens em Perigo (Lei n.º 147/99, de 01/09)
• Decimas de Leveza follows additional safeguarding practices outlined by the Safeguarding Support Hub or similar organizations to ensure compliance with international standards.

Section 3: Roles and Responsibilities

Designated Safeguarding Lead (DSL)
Joao Coimbra

• Role: President of Decimas de Leveza
• Qualifications: Professional teacher with a Master’s degree in Education
• Responsibilities:
  • Act as the primary point of contact for safeguarding concerns.
  • Ensure all safeguarding procedures are followed and concerns are addressed promptly.
  • Oversee the implementation and monitoring of the safeguarding policy.
    

Deputy Safeguarding Leads
Yulia Utenkova

• Role: Assembly President of Decimas de Leveza
• Qualifications: Education in Gestalt Therapy
• Responsibilities:
  • Support the DSL in safeguarding responsibilities.
  • Provide additional support in the absence of the DSL.
    
    

Agita Jaunzeme

• Role: General Secretary of Decimas de Leveza
• Qualifications: Board member with training in safeguarding.
• Responsibilities:
  • Assist with safeguarding training and record-keeping.
  • Act as an additional point of contact for participants or staff.

Roles and Responsibilities
Besides the Coordinators / Safeguarding leads
Group Leaders:

• Group leaders will also be trained to handle safeguarding concerns and will be the first line of support for participants in each group. The requirement is to at least familiarize themselves with this document.

Responsibilities of Sending Organizations:
Sending organizations involved in Erasmus+ projects will:

• Adhere to this safeguarding policy.
• Ensure that their group leaders are aware of safeguarding protocols before participation in the project.
• Share any safeguarding concerns with Decimas de Leveza’s designated safeguarding officers promptly.
• Collaborate with Decimas de Leveza in addressing any concerns involving participants.
  
  

Section 4: Good Practice Guidelines
To promote a safe environment for all participants:

• Staff and volunteers should build respectful, professional relationships with participants, avoiding favoritism or inappropriate boundaries.
• Communication with participants should be open, clear, and professional at all times.
• Staff and volunteers must avoid being alone with a participant unless absolutely necessary and in a visible or open setting.
• Physical contact with participants should be avoided unless required and agreed upon for safety, support, or activity purposes.

Code of Conduct:

• Treat all participants with respect and dignity.
• Avoid any actions or language that could be perceived as discriminatory, offensive, or abusive.
• Be vigilant in identifying signs of harm, neglect, or abuse.
  
  

Section 5: Abuse of Trust
All involved with organization and coordination/leadership must recognize the inherent power imbalance in relationships with participants and avoid any form of abuse of trust. Romantic or sexual relationships between coordinators/leaders and participants are strictly prohibited.

Section 6: Support for Those Involved in Safeguarding Issues
Safeguarding concerns can be deeply distressing for all involved, including participants, coordinators, and group leaders. Decimas de Leveza is committed to providing support for everyone affected by safeguarding issues by:

Taking All Concerns Seriously: We treat all suspicions, disclosures, and concerns as legitimate and act promptly in line with our safeguarding procedures.

Dedicated Points of Contact:

The Designated Safeguarding Lead (DSL) (João Coimbra) will act as the primary contact to keep all involved parties informed and supported.

In cases where a staff member is involved in an allegation, separate contacts will be designated for the staff member and the affected participant to prevent conflicts of interest.

• Sympathetic Responses: We respond compassionately to requests from participants or staff for time and space to process distress or anxiety.
• Maintaining Confidentiality: Information will only be shared on a strict need-to-know basis with relevant parties, including appropriate external agencies.
• Secure Record Keeping: All safeguarding-related documentation will be securely stored and managed.
• Providing External Resources: We offer access to helplines, counseling, and other external support services for those in need.
• Clear Procedures: Concerns will be addressed in line with our whistleblowing, complaints, and disciplinary policies.
• Collaboration with Statutory Agencies: We will fully cooperate with local and international safeguarding authorities, such as the Comissão de Proteção de Crianças e Jovens or other relevant organizations, to ensure the best outcomes.

Section 7: Complaints Procedure
Decimas de Leveza encourages open communication and the resolution of complaints about safeguarding concerns through transparent, structured processes:

• Raising Concerns About Poor Practice:
  Participants or staff may raise concerns about poor safeguarding practices that do not meet the threshold for formal action. These complaints will be handled by the DSL, or, where necessary, the assembly president or general secretary.
• Whistleblowing Policy:
  If any participant, coordinator, or group leader has concerns about a colleague's conduct, they may refer to the whistleblowing policy, which ensures confidentiality and protects whistleblowers.
• Reporting Misconduct:
  Coordinators or group leaders must report any concerns about inappropriate behavior to the DSL (João Coimbra).
• Escalation Procedures:
  If the concern involves the DSL, the report should be made to the assembly president, Yulia Utenkova.
  
  

Handling Allegations Against Coordinators or Group Leaders
When an allegation of misconduct is made against Coordinators or Group Leaders, strict procedures will be followed:

• Acting Promptly: All allegations will be treated as serious and acted upon immediately.
• Avoiding Preemptive Investigation: No independent investigations will be carried out without prior consultation with the Comissão de Proteção de Crianças e Jovens or, in the most serious cases, the police.
• Reporting: All allegations must be reported to the DSL or, if the allegation concerns the DSL, to the assembly president.
• Support for Coordinator or Group Leader:
  Individuals accused of misconduct will:

• Be informed about the process and updated on progress.
• Have a designated representative to provide ongoing support.
• Be given access to counseling or other resources if needed.

Investigation Process

• Allegations meeting reporting criteria will be referred to the Comissão de Proteção de Crianças e Jovens within one working day.
• Discussions with statutory agencies will guide the next steps, including whether police involvement or a strategy meeting is necessary.
• The accused individual will be informed as soon as permissible, unless directed otherwise by statutory authorities.

Suspension and Alternative Arrangements

If warranted by the investigation, the coordinator or group leader may be suspended temporarily. Alternative arrangements, such as non-participation in ongoing activities, will be made for safeguarding purposes.

8. Low-Level Concerns
Low-level concerns are behaviors by coordinators, group leaders, or volunteers that do not meet the threshold of harm but still warrant attention to maintain a safe and professional environment. Examples of low-level concerns include:

• Using inappropriate language with participants.
• Being overly friendly or showing favoritism.
• Acting in ways that could be misinterpreted as unprofessional.

Reporting Low-Level Concerns
All low-level concerns should be reported to the Designated Safeguarding Lead (DSL) (João Coimbra) or, if necessary, the assembly president (Yulia Utenkova).
Staff are encouraged to self-refer if they find themselves in situations that could be misinterpreted or misconstrued.
Handling of reports will be sensitive and proportionate, with the aim of improving practices and addressing behavior at an early stage.
All concerns will be recorded, evaluated, and addressed to support a transparent and open safeguarding culture.

9. Online Safety
Recognizing the potential risks of digital technologies, Decimas de Leveza promotes safe online behavior.  To ensure a safe and respectful digital space for all participants of the online space with us: 

Respect & Inclusion

• Encourage open discussions but avoid offensive or harmful content.
• Treat all members with kindness and respect—no hate speech, discrimination, or harassment.

Privacy & Data Protection

• Do not share personal information (yours or others’) without consent.
• Respect confidentiality—private group discussions stay within the group.

Safe & Responsible Posting

• Only post appropriate and relevant content related to the project.
• Always credit sources when sharing media or information.
• Do not share misleading or false information.
  
  

Reporting & Moderation

• If you witness or experience any form of online abuse, report it to the project coordinators.
• The admins reserve the right to remove harmful content and, if necessary, restrict access to the group.
  
  

Cyberbullying Action Plan for Coordinators:

1. Monitor and assess reports and evidence. 
2. Act immediately by removing harmful content, warning offenders, and restricting access if needed.
3. Support victims by checking in privately and offering guidance.
4. Investigate further if bullying continues and escalate to the project team or authorities if necessary.
5. Prevent future incidents by reinforcing online safety rules and promoting respect.
6. Serious cases should be escalated as needed to ensure a safe environment.
   
   10. Recognizing Abuse
   It is critical for all coordinators and group leaders to understand the various types of abuse to protect individuals effectively. These include:

   Physical Abuse:
   Examples: Hitting, shaking, or otherwise inflicting physical harm.

   Emotional Abuse:
   Examples: Persistent emotional maltreatment, bullying, or causing feelings of worthlessness or fear.

   Sexual Abuse:
   Examples: Forcing or enticing a person to engage in sexual activities, whether physical or online, or grooming behaviors.

   Neglect:
   Examples: Failure to meet basic needs, such as food, shelter, or medical care.

   Coordinators and group leaders must remain vigilant for behavioral or physical indicators of abuse. Possible signs may include sudden behavioral changes, reluctance to engage with others, unexplained injuries, or withdrawal. All concerns must be reported immediately to the DSL through the designated reporting platform.
   
   
   

   11. Reporting and Accountability
   It is the responsibility of all coordinators, group leaders, and relevant partners to report safeguarding concerns promptly. This includes:

• Utilizing the organization's reporting system to log concerns or incidents.
• Maintaining confidentiality and only discussing concerns with the appropriate safeguarding team or external agencies.
• Understanding that it is not their role to investigate incidents but to report them to the DSL for further action.

12. Organizational Culture and Transparency
The organization is committed to fostering an open and transparent culture where safeguarding concerns can be raised without fear of reprisal. Coordinators, group leaders, and all relevant partners are encouraged to self-report if they find themselves in situations that may be misinterpreted. Senior leadership will handle all concerns proportionately and with sensitivity, ensuring continuous improvement in safeguarding practices.
This policy will be reviewed annually to ensure its effectiveness and alignment with legal and regulatory standards.

13. Taking Action
Key Points for Coordinators and Group Leaders to Remember When Taking Action:

1. In an emergency, take immediate action to help the individual, such as calling emergency services (112).
2. Report any concerns to the Designated Safeguarding Lead (DSL) as soon as possible, and certainly by the end of the day.
3. Avoid conducting your own investigation. Let the proper authorities handle any inquiries or investigations.
4. Share information only on a need-to-know basis. Do not discuss concerns with colleagues, friends, or family members.
5. Record your concern by creating an incident report, by filling the incident form.
6. Seek support for yourself if you feel distressed or need help processing the situation.

If You Suspect a Participant is at Risk of Harm:
There may be occasions when staff or group leaders suspect that a participant is at risk of harm, but there isn’t clear evidence. For example, changes in behavior, unusual statements or expressions in discussions, or inconclusive physical signs might raise concerns. In these cases, staff should:

1. Provide the participant with a safe space to talk.
2. Keep in mind that these signs could be linked to various factors (e.g., personal issues or recent changes in their life).
3. Offer the opportunity for the individual to discuss their feelings without pressuring them.
4. Record early concerns by filling an incident form. If the participant reveals they are at risk, follow the guidance below.

If a Participant Discloses They Are at Risk:
It takes significant courage for anyone, especially a young adult, to disclose that they are experiencing harm. Participants may feel ashamed, fearful of repercussions, or believe that they are at fault. If a participant shares that they are at risk, coordinator or group leader should:

1. Make it clear that they cannot promise confidentiality and must share the information with relevant safeguarding personnel. Staff should disclose this early on in the conversation.
2. Approach the situation with sensitivity and understanding, creating an environment that feels safe and supportive.
3. Avoid asking detailed or investigative questions such as "How many times has this happened?" or "Who else is involved?"
4. Offer reassurance, stating that they are not at fault and that sharing is the right thing to do.
5. Encourage the participant to talk to the DSL or safeguarding lead. If the participant declines, it is the staff member’s responsibility to inform the DSL.
6. Immediately report the conversation and document the disclosure on the record of concern form.

During their conversations with the participant, coordinator or group leader will:

1. Allow them to speak freely.
2. Remain calm and collected – the participant may stop talking if they feel they are upsetting their listener.
3. Give reassuring nods or words of comfort – ‘I’m so sorry this has happened’, ‘I want to help’, ‘This isn’t your fault’, ‘You are doing the right thing in talking to me’.
4. Not be afraid of silences – staff must remember how hard this must be for the participant.
5. Under no circumstances ask investigative questions.
6. Tell the participant that to help them, the member of staff must pass the information on.
7. Not automatically offer any physical touch as comfort. It may be anything but comforting to a person who has been abused.
8. Avoid admonishing the participant for not disclosing earlier. Saying things such as ‘I do wish you had told me about this when it started’ or ‘I can’t believe what I’m hearing’ may be interpreted by the participant to mean that they have done something wrong.
9. Tell the participant what will happen next. The participant may agree to go to see the designated senior person. Otherwise, it is the duty of the member of staff to inform the DSL of what has been discussed.
10. Report verbally to the DSL even if the participant has promised to do it by themselves.
11. Write up their conversation as soon as possible on the record of concern form and hand it to the designated person.
12. Seek support if they feel distressed.

Notifying Parents/Guardians:
While it is generally important to keep parents or guardians informed of any concerns, this may not always be appropriate, depending on the situation. If the concern involves significant risk, the DSL will contact the relevant parties (parent or guardian), but this will be done sensitively and in accordance with the individual’s safety needs.

Referral to Authorities:
If there is a concern that a participant is at risk of significant harm, the DSL will refer the case to the relevant authorities, such as the Comissão de Proteção de Crianças e Jovens (CPCJ) or police. The participant will be informed of the referral (if it does not increase the risk to them) and be supported in understanding the process.

Direct Reporting to Child Protection Agencies:
If the situation is an emergency and the designated safeguarding personnel are unavailable, coordinators or group leaders may report directly to CPCJ or the police. Coordinators or group leaders should follow the reporting procedures outlined, but in exceptional cases, they are permitted to contact child protection agencies directly if they are convinced it is the best course of action to ensure the individual’s safety.

Support for Those Involved:
Support for the participant experiencing harm may include:

• Access to counseling, peer support, or professional mental health services.
• Assistance with restoring relationships with peers or improving social connections.

For participants who may have caused harm, coordinators or group leaders will seek to understand the underlying causes of their behavior and consider appropriate support and behavioral interventions. Consequences will follow once the individual’s needs are addressed.

14. Confidentiality and Sharing Information

Data Handling and Rights
All safeguarding information must adhere to the principles outlined by data protection regulations:

• Processed for limited purposes: Safeguarding information should be collected and shared only for the purpose of ensuring the safety and well-being of the participant.
• Adequate, relevant, and not excessive: Only the necessary information required for the safeguarding concern should be documented and shared.
• Accurate: Information should be kept up to date and corrected if necessary.
• Kept no longer than necessary: Safeguarding records should be reviewed regularly and stored for no longer than is required to address the concern.
• Processed in accordance with the data subject’s rights: Any data shared with participants, partners, or third parties must comply with the individual’s rights under the data protection law (including the right to access their data).
• Secure: Safeguarding records must be protected from unauthorized access or disclosure.

15. Confidentiality and Sharing Information

Confidentiality and Data Protection
In Erasmus+ projects, all coordinators and group leaders will be fully aware that safeguarding concerns require a high level of confidentiality. This confidentiality is crucial not only to respect the privacy of the participants and coordinators involved but also to ensure that information remains protected and does not compromise any potential investigations or legal proceedings.
Coordinators and group leaders should share concerns only with the Designated Safeguarding Lead (DSL) or relevant project safeguarding personnel. In an international context, this might also include key partners in the Erasmus+ programme, such as other coordinators or safeguarding representatives from partner organizations. The DSL, or equivalent, will decide who needs to be informed on a need-to-know basis and ensure that the information is shared appropriately.

16. Information Security
To protect sensitive information:

• Written records (including record of concern forms) and all confidential information related to safeguarding will be stored securely, either in a locked physical facility or in an encrypted, password-protected digital format.
• Electronic records will only be accessible to coordinators and group leaders with appropriate safeguarding responsibilities, and all safeguarding data will be restricted to the designated Safeguarding Team in any digital platform (e.g., incident form, internal databases).

17. Sharing Information with Relevant Agencies
While confidentiality is important, there are situations where sharing safeguarding information is necessary to protect the participant's welfare. The Data Protection Act (or equivalent regulations in the country hosting the project) allows staff to share safeguarding information with relevant authorities, including:

• National child and youth protection agencies (e.g., Comissão de Proteção de Crianças e Jovens)
• Local police or law enforcement agencies
• Medical services (in case of health-related concerns)

Sharing of information with these agencies is permissible when it is essential to protect the individual from harm. Erasmus+ staff and partners should ensure that they adhere to local data protection and child safeguarding laws when making referrals.

18. Transferring Safeguarding Information Across Borders
If safeguarding concerns arise during the project, it may be necessary to transfer the relevant information back to their home country for continued support or intervention after they return.
The safeguarding lead in the hosting organization should ensure that, if needed, the safeguarding records and any related concerns are transferred securely and promptly to the appropriate authorities in the participant's home country. This transfer should take place as soon as possible, ideally within 5 days of the concern being identified, to ensure that the participant receives continuous support upon returning home.
The home country’s youth protection agencies or other relevant authorities will be responsible for managing the case upon the participant's return. The hosting organization must ensure that all information shared is in compliance with both local and international data protection regulations, and that the privacy and safety of the participant are prioritized.

19. International Safeguarding Considerations
Erasmus+ projects often involve participants from different countries, making it essential for all partner organizations to understand their responsibilities in safeguarding and data protection. Each partner must comply with their own national laws, as well as the Erasmus+ guidelines, to ensure consistency in safeguarding practices across borders.
Coordinators and group leaders should be trained in how to handle cross-border referrals and share relevant safeguarding information with the appropriate authorities in the participant’s home country. This ensures that all participant rights are respected, and that confidentiality is maintained while safeguarding concerns are addressed in line with both the local and international legal frameworks.

Policy Review

This policy will be reviewed annually by the safeguarding team to ensure it remains current and effective. Updates will be approved by the Decimas de Leveza leadership Contact Information for Safeguarding Concerns

Primary Contact:

• Joao Coimbra (President, DSL)
  Email: jbpcoimbra@msn.com
  Phone: +351 914 261 629

Deputy Contacts:

• Yulia Utenkova (Assembly President)
  Email: utenkovayulia@gmail.com
  Phone: +351 915 099 782
• Agita Jaunzeme (General Secretary)
  Email: agita.jaunzeme@gmail.com
  Phone: +351 913 06 16 06

By adhering to this safeguarding policy, Decimas de Leveza ensures the safety, dignity, and wellbeing of all participants in our projects.