Safeguarding & Child Protection Policy.

July 2022, V1.0


What is child safeguarding?
Child safeguarding is the responsibility that organisations have to make sure their employees, operations, and processes do no harm to children, that is that they do not expose children to the risk of harm and abuse, and that any concerns the organisation has about children’s safety within the communities in which they work, are reported to the appropriate authorities.

What is a Safeguarding and Child Protection Policy (SCPP) and why does VerifyMy need it?
An SCPP describes what safeguarding measures are in place to protect children, rules on how to behave when working directly or indirectly with children, how to prevent them from abuse and harm, whom to report if any of this happens and how to respond to the situation in an appropriate manner.

This SCPP provides information for children, young people, parents and other stakeholders on what to expect from VerifyMy; it guides employees in their daily work, and gives the organisation accountability.

This SCPP is also in place to protect employees, including those working for clients. It will be publicly available, is written in a simple language, and must be endorsed by all employees and management.

What is the scope of this policy?
VerifyMy is a company which designs, develops and operates a range of products that help keep children safe online. This policy is designed to apply to all existing and future projects and products.

Is there a child-friendly version of this policy?
A child-friendly version of this policy will be developed when it is likely that children will be accessing our products and may wish to refer to this policy.

1. VerifyMy SCPP

This is the VerifyMy SCPP, and this document includes key procedures which apply to all operations and activities conducted by, or on behalf of, VerifyMy, and its clients when making use of its products. This policy reaffirms and strengthens VerifyMy’s commitment as an organisation towards keeping children safe and protecting them from all forms of harm and abuse. This is an issue of critical importance for VerifyMy and the company sees the protection of children, the promotion of their wellbeing and upholding children’s rights as a foundation of its work. 

1.1. Purpose of the policy
The aim of the policy is to regulate how VerifyMy works as an organisation so that the children with which it comes into contact with (either directly or indirectly) are safeguarded and have their wellbeing promoted, and that the company’s actions do not cause any harm to children. While the SCPP aims to be comprehensive, given the diverse range of settings and operations carried out by VerifyMy, it is likely that there may be circumstances which are not covered or where there is a question about the application of the policy. In such situations, VerifyMy should be contacted for further advice.

1.2. Definition of Safeguarding
“Child safeguarding is the responsibility that organisations have to make sure their employees, operations, and processes do no harm to children, that is that they do not expose children to the risk of harm and abuse, and that any concerns the organisation has about children’s safety within the communities in which they work, are reported to the appropriate authorities''. (Keeping Children Safe Coalition).  This includes both preventative actions to minimise the chances of harm occurring, and responsive actions to ensure that incidents which may happen are appropriately handled.  Safeguarding implies a wider duty of care towards children rather than just upholding their right to protection (as defined in the UN Convention on the Rights of the Child, 1989) – but it is primarily concerned with harm and wellbeing, rather than with the promotion and protection of child rights generally. 

1.3. Principles
VerifyMy’s SCPP is based upon a number of principles, including: 
  • All children have equal rights to protection and to have their wellbeing and participation promoted. 
  • All actions regarding child safeguarding must be taken with the best interests of children in mind. This includes an understanding that VerifyMy must ensure that it respects children’s rights and does not cause harm. 
  • Everybody has a responsibility for safeguarding. This policy is mandatory for all those who work for or on behalf of VerifyMy, including employees and contractors. Although training, advice and support will be provided, everyone should actively participate so that they can carry out their responsibilities towards safeguarding children. 
  • VerifyMy work in a transparent and open way where child safeguarding is made a priority, recognising that situations of abuse and harm are able to flourish if employees, contractors or other stakeholders do not feel able to raise their concerns. 
  • All reports of concern regarding the safety and protection of a child will be taken seriously. Where necessary, appropriate steps will be taken to protect the child and to take action against the alleged perpetrator. This may include referrals to law enforcement and child protection agencies. In relation to allegations against employees, action may also include the suspension or termination of engagement or any type of cooperation. 
  • No single organisation is able to safeguard children by working in isolation, and therefore VerifyMy will work with other organisations, agencies and groups as necessary and appropriate.
  • VerifyMy maintain confidentiality and do not disclose personal details of those involved in child protection concerns, including the names of those raising concerns unless it is necessary to pass on information to ensure that a child is protected (for example where a child may need specialist services or where a criminal offence may have been committed). 
  • VerifyMy will raise awareness and influence others on the importance of safeguarding children, using this policy as a way of both highlighting its commitment and also of explaining its values. VerifyMy will share this policy with others, and be open to feedback regarding its application. 
  • VerifyMy work within the framework of international and national laws regarding safeguarding. 
  • There is no one specific way to safeguard children and promote their rights. Solutions to protect children need to reflect the culture, operating environment and the nature of any activities being undertaken. While individual processes can propose amendments and modifications to the policy, this must be done within the framework of requirements set down within this policy. It is not acceptable for a reduced level of safeguarding to be offered.

2. Definitions

For the purposes of this policy the following working definitions are used:

Abuse: used in its widest sense and includes physical, emotional/psychological and sexual abuse, neglect and negligent treatment, violence and exploitation in all forms.
Emotional Abuse: the persistent emotional ill-treatment of a child such as to cause severe and long-lasting effects on their emotional development. It may involve conveying to children that they are worthless and unloved, inadequate, or valued only so far as they meet the needs of another person. It can also involve age or developmentally inappropriate expectations being imposed, or causing children frequently to feel frightened or in danger. Some level of emotional abuse is involved in all types of ill-treatment of a child, though it may occur alone.
Neglect: the persistent failure to meet the child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s physical or cognitive development.
Physical Abuse: this may involve hitting, shaking, throwing, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child who they are looking after.
Sexual Abuse: involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening or gives consent. The activities may involve physical contact, including penetrative (e.g. rape) or non-penetrative acts. They may also include non-contact activities, such as involving children in looking at, or in the production of, pornographic materials or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Child/Children: refers to anyone under the age of 18, irrespective of the age of majority in their own country, or where they are located or living.
Child Protection Incident: refers to when an allegation is made, even if it is unsubstantiated, that a child is being abused or is likely to be abused.
Clients: VerifyMy interacts with a range of stakeholders, where the relationship can be contracted or less formal and built upon mutual work and interests. In these cases, VerifyMy may be able to positively influence the practice of the client, even if it cannot insist upon observing safeguarding practice as a condition of engagement
Employees: anyone who works for or on behalf of VerifyMy on a full time or part time basis.

3. Preventative action: Putting the policy into practice

This section of the policy identifies specific steps and concepts which translate the vision of safeguarding children into action.

Child safeguarding runs across the whole organisation and is not just associated with research activities or the work of the VerifyMy development team. The concept of thinking about safeguarding and reducing risk should be embedded in everything that the company does.

Throughout the policy, a number of situations have been highlighted which specifically call for a risk assessment, such as when conducting an activity or when concerns are raised about an employee’s reference or police check. However, this does not mean that risk should only be considered at those times. Safeguarding risks must be regularly reviewed at all levels.

It should be remembered that although VerifyMy normally thinks of safeguarding issues when an adult is mistreating a child, children can also be the perpetrators of abuse. This normally occurs where one child is in a position of power or influence. In such cases, while action is necessary to support the child being bullied, it is critical to remember that the perpetrator is also a child, and therefore interventions should be in the best interests of both children in terms of how to support the abused child and what response is required for the abusive child.

3.1. Human Resources
This section sets out the specific obligations and responsibilities for all adults working with/for VerifyMy, whether centrally or for a project, full or part time. 
  • The SCPP applies to all those working with or on behalf of VerifyMy. By agreeing to work with/or for the organisation, it is implied that the terms of the SCPP have been accepted as a condition of involvement.
  • Those in a governing capacity as Members of the Board (or equivalent) are expected to set the highest standards of behaviour for VerifyMy.
  • While orientation on the policy together with any necessary additional training regarding responsibilities and duty of care (particular to specific roles) will be provided, all adults have a personal responsibility to seek further clarification and advice where they are not clear about what is expected of them. 
  • Breaching the SCPP may lead to suspension and termination of any type of engagement. This will be determined on a case-by-case basis, ensuring that applicable employment conditions and legislation are observed and with regard for the privacy and confidentiality of those concerned while any internal investigation is carried out. In addition, after a thorough consideration of the facts, VerifyMy will decide whether the case needs to be reported to law enforcement authorities in full conformity with the law.
  • The SCPP focuses on conduct taking place during work under the responsibility of the organisation. Nevertheless, conduct outside the work environment of those associated with VerifyMy may also contravene the values of the SCPP. If such issues arise, these will be carefully considered, and any decisions made will place utmost importance on the child’s best interests.  

    3.1.1.  Education, Advice & Support 
    This section sets out the efforts undertaken to support the implementation of the SCPP.
    • Within their probationary period all employees will be given guidance as to the SCPP, and their responsibilities towards safeguarding children. 
    • Employees must be given the opportunity for regular updates on safeguarding children either formally through training, or more informally, for example through discussion at team meetings. 
    • Depending upon the nature of the work being undertaken, the role of the employees and their experience, additional specialist training regarding child wellbeing should be provided. 
    • While all adults have a responsibility for safeguarding children, no one should have to do this alone and unsupported. 
    • Where support or advice is sought regarding child safeguarding this must be taken seriously. At no time must seeking advice or support be considered indicative of someone lacking capacity or knowledge.
    • Where those working with/for VerifyMy are involved in child protection incidents, either as the subject of an investigation or as a witness, appropriate support must be provided. This may include additional supervision or counselling.  

    3.1.2.  Awareness Raising 
    This section sets out how awareness will be raised regarding the SCPP.
    • Employees and other stakeholders should be made aware of the SCPP, and how to report a concern. This should be done in ways that are appropriate and accessible given the context. 
    • A copy of the SCPP, including local adaptations, should be translated and made available in local languages. Depending on the context, this should be provided in a variety of suitable formats.
    • Special consideration must be given on how to raise awareness with children about the policy and ways in which they can help keep themselves safer. This could include developing with children a child friendly version of the policy.

    3.1.3.  Safer Recruitment  This section focuses on how those working with/for VerifyMy are selected. 
    • Individuals who are intent on abusing children often target organisations where they can gain access to children. While no recruitment process can ever be 100% safe, by having stringent processes in place, the likelihood of engaging someone not suitable can be dramatically reduced.
    • Safer recruitment procedures act as a safety net that in combination provide a level of assurance that proper attempts have been made to ensure that they identify those who may pose a risk.
    • All recruitment procedures must be based on a detailed analysis of each role and the level of contact with children. Safer recruitment procedures include pre-selection, selection and post-selection actions to ensure that there are as many safeguards as possible in place. 
    • Work should not commence until all safer recruitment processes have been followed and background checks and guidance on the SCPP have been completed. However, it is recognised that in some exceptional circumstances there may be a long delay, or for operational reasons it may be necessary to start work at short notice. In such situations, additional measures must be put in place so that VerifyMy can be confident that the risks for children are minimised. For example, providing additional supervision and ensuring the employee in question does not work alone.
    • Records of safer recruitment practice, such as references etc., must be kept on record. This information must be kept and destroyed in accordance with applicable data protection rules. 

    3.1.4.  Child Protection Champion
    This section sets out the obligation of VerifyMy to nominate someone to act as Child Protection Champion (CPC).
    • The role of this person is to provide a point of contact and to advise, support and assist teams in the implementation of the SCPP.
    • Ideally the role of the CPC will be assigned to someone with child safeguarding knowledge. However, the role can be given to anyone who is committed and has the respect of the team.  
    • It should be understood that the CPC is not solely responsible for child safeguarding, this responsibility rests with everyone. 

    3.1.5.  Clients
    This section considers how to work with clients in order to promote the implementation of the SCPP. 
    • In selecting clients consideration should be made with respect to their suitability and track record for working with children, including if they have their own child safeguarding policy. 
    • In all Client relations, strong attention must be given to issues related to child safeguarding. As good practice, specific reference to child safeguarding measures should be included in contracts.
    • Working with clients is an opportunity to raise awareness on the need for institutional policies on child safeguarding. 
    • In any partnership established by VerifyMy, where VerifyMy is the lead partner (i.e. can exert more control over the terms of the contract) then reference in the contract must be made to the commitment to keeping children safe and VerifyMy’s SCPP. Where not the lead partner, then attempts should be made to include safeguarding within the agreement. In either case, partners should be given access to the SCPP and guidance provided on the contents. 
    • Where concerns about child safeguarding arise in relation to a partner, in addition to considering whether a report of the concerns needs to be made to appropriate authorities, consideration must also be given regarding whether to suspend the clients and/or withdraw funding and support.
    • A child safeguarding concern raised in relation to a partner does not mean that the relationship must be terminated automatically. The decision to continue with the client must take into account the reaction of the partner and their commitment to addressing the situation such as prioritising the best interests of the child, responding to advice on managing the situation and agreeing to seek support through training. 

    3.2. Media & Communication
    This section considers the actions that need to be taken to ensure that safeguarding is included in media activities involving children and vulnerable adults.
    The Ethical Rules regarding the use of images by VerifyMy must be observed, namely:  
    1. Respect the SCPP. 
    2. Make sure that the safety of the child will not be compromised if one disseminates images of his or her home, community or environment. 
    3. Be accompanied by an employee of VerifyMy while doing a report (video, photo, etc.). 
    4. Obtain permission from the child and the person who is responsible for looking after him or her. 
    5. Ensure that the child does not pose in an inappropriate manner (sexual connotations etc.). 
    6. Do not take or publish photos of children who are completely naked or dressed inappropriately. Images of children which are exploitative or offensive must not be used. 
    7. Always respect the children’s dignity. Do not represent the children as victims (weak, desperate etc.). Images should present children in a ‘positive way’.  
    8. Taking pictures or videos is reserved for strictly professional use. Employees are encouraged to 'like' and 'share' photographs published on official VerifyMy websites and social media sites. In this way, officially approved photographs may be distributed more broadly on personal social media sites. Unofficial photographs must not be posted or uploaded on personal pages. 
    9. Never indicate in the files any information that could endanger the child victim of abuse (title, metadata, captions etc.). When publishing/distributing photos, images, stories etc., personal information must be removed to ensure privacy. 
    10. Only use photos available for public use (verified and validated by an official client or VerifyMy representative and the person in charge of visual communication). 

    3.2.1.  Online Protection and Safety  
    The CPC should ensure that sufficient guidance is provided to employees about the appropriate use of technology, including internet, mobile phones and social media.
    Filters and blocking software should be installed to ensure that unsuitable/offensive sites cannot be accessed. In general, sites which promote the abuse of children or contain images and information which are harmful to children should be blocked unless access is required for legitimate business purposes. Such access should always be pre-authorised by a line manager so there can be no doubt that access was legitimately required. 
    In the event that offensive material or unsolicited messages/chats are received, these must be passed on to the CPC who must report to an agency working to improve internet safety. 
    Employees must also report to their line manager if any offensive material is received or accidentally downloaded.
    (In the event that offensive material, such as child pornography, is received or accidentally downloaded and a report is made to law enforcement, the materials must not be sent with the referral. The transmission of images is considered a crime under international law. Guidance should be sought from the law enforcement agency as to how to arrange for images to be transferred appropriately).

    3.2.2.  Information, Communication & Technology (IT)  
    VerifyMy clients must have their own IT rules on the use of computers and other technology. 
    IT equipment is provided for business purposes, and its use is subject to this SCPP.
    The use of computer and technology resources for private purposes is allowed provided that this does not prevent employees from exercising their professional activities, and that it is not prejudicial to the reputation of VerifyMy.
    While the privacy of employees is respected, this is not guaranteed. This may be, for example, if there was a suspicion that IT equipment had been used to access child pornography online.  
    Any voluntary non-professional access to websites detrimental to the reputation of VerifyMy (and in violation of this SCPP) is strictly forbidden and can justify a dismissal with immediate effect or the termination of business contracts.
    Any unintended access to harmful data should be immediately reported to line managers to avoid any misunderstanding. 

    3.3. Programme Design & Implementation
    Programmes and all types of actions across all aspects of VerifyMy, not just child protection programmes, should ‘think safeguarding’ at all times and across all activities, and not consider safeguarding as a separate activity, but rather a theme that runs through all work. 
    Safeguarding must be considered at every stage, from project/programme design and must be reviewed regularly as part of the monitoring of a project’s implementation.
    In addition to programme design, when conducting specific activities such as consultations with children, a risk assessment must be undertaken to identify any potential dangers and a plan put in place to minimise these risks. If the assessment concludes that there are too many risks that cannot be reduced to an acceptable level, then the activity should not proceed.
    If necessary, additional guidance must be given to employees and clients in order to ensure that the spirit of the SCPP is met for specific activities or programmes, for example, to highlight particular dangers or concerns.
    Before activities are conducted which involve children, the written permission of both parents and children must be obtained. 
    Employees and consultants who work with children must be supervised on a regular basis and given the opportunity to participate in discussions about safeguarding issues, for example, in meetings, informal discussions or through considering case studies. 
    There are two distinct ways in which child protection incidents may arise: 
    1. Where the concern relates to potential, actual or suspected abuse of a child by the family/community - such incidents can be managed at a high level and handled by the CPC, in conformity also with national and international law. These cases are not managed under this policy. 
    2. Where the concern involves an employee or client/partner of VerifyMy, or a representative of a significant stakeholder such as a Board member, it must be referred to the CPC who will determine the appropriate action necessary. This is not to avoid taking action, but to ensure that the action taken does not jeopardise organisational or individual reputation, and to ensure that appropriate support is given to the delegation as such incidents can be particularly difficult to manage.

4. Reporting Concerns & Child Protection Incidents

This section covers the case where a concern is reported that the SCPP is not being implemented or a child protection incident is reported (i.e. where a child may be or is at risk of abuse and actions may be necessary to ensure that the child is protected).

Concerns and reports may be received from a number of sources including employees and other stakeholders. All concerns and reports must be taken seriously.

Such reports should be passed in the first instance to the CPC.

Clients should develop a reporting framework which identifies how concerns and reports should be managed. The main point of referral should be the CPC. This is to ensure that reports are managed in a systematic way, and lessons are learned in terms of the implementation of the policy. This does not mean that the CPC is responsible for action, but he or she should be involved in decision making.

Decisions about child protection incidents must not be made by individual employees in isolation. However, in exceptional circumstances, such as a life-threatening situation, employees may take whatever action they deem necessary to protect a child at immediate risk, but this must be reported as soon as possible in accordance with the reporting framework (i.e. in the first instance to the CPC). Local contacts with child protection agencies and law enforcement should be identified in advance to enable a referral to an outside agency if required to protect the child. Contact details should be retained so a referral can be made quickly.

Consideration on whether to refer a child to an outside agency for protection must always be made within the legal framework and with consideration for the best interests and wishes of the child.

When concerns are raised or reports made, importance must be placed on confidentiality, both of the referrer and also the child(ren)/adults involved. Information must be shared strictly on a need-to-know basis as necessary to ensure the child is kept safe and appropriate assistance is given.

Where concerns are raised by employees about other workers and clients, even if these are not substantiated, providing there was no malicious intent, no punitive action will be taken against the person raising the concern or making the report.

Referrals to local child protection agencies/police should be done in the prescribed manner (for example, there may be a particular format for reporting). Where the referral is made verbally it must also be confirmed in writing.

Written records of all reports received (even if the report is vague) must be kept and maintained in a secure and confidential location by the CPC.

5. Accountability, Monitoring & Review

This section details how the implementation of the SCPP will be monitored, and how it will be reviewed.

The CSC has overall responsibility for the SCPP. Directors are also responsible for determining policy and good practice and for implementation of the policy in all activities related to their areas of organisational responsibility.

Annually, the VerifyMy team shall conduct a self-assessment of safeguarding and the implementation of the SCPP. Based on the self-assessment, an annual plan of action will be developed to address any gaps in policy implementation and to mitigate any risks identified.

Both the self-assessments and the development of action plans will be coordinated by the CSC so that information from all projects can be assessed to measure safeguarding across the organisation.

This policy will be reviewed on a regular basis, but not more than every five years. Such reviews will also include feedback from employees, and where possible, the views of children and other stakeholders.

6. VerifyMy Child Protection Code of Conduct

This Code of Conduct must be adhered to and acknowledged by all employees and contractors. VerifyMy considers all forms of abuse towards children as unacceptable and recognises a duty to safeguard children, that is to keep them safe, promote their wellbeing and protect them from abuse and harm.

Neglect, physical, psychological/emotional and sexual violence are the main forms of abuse. This SCPP sets out the measures VerifyMy will take to safeguard children. This includes proactive actions to prevent situations of abuse and harm occurring and reactive actions to respond to situations where a child is, or may be, suffering abuse.

A child is any human under the age of 18 as stipulated by the UN Convention on the Rights of the Child, 1989.

As part of our SCPP, it is a requirement that all employees (including consultants), whether full or part time, agree to abide by the SCPP and specifically to agree to work in accordance with this Code of Conduct which sets out responsibilities for safeguarding children and expected behaviour of staff. This is a mandatory requirement.

Any form of unacceptable behaviour which breaches this Code of Conduct must be reported. In the case of situations which are not covered by the Code of Conduct, VerifyMy expects its representatives to apply common sense whilst focusing on the ‘child’s best interests’.

VerifyMy respects the Convention on the Rights of the Child and the following five principles:

  1. All VerifyMy employees must respect and promote children’s rights. Above all, they must protect the right of each child to live in safety, without risk of abuse or exploitation and must act, at all times, in the child’s best interests.
  2. Zero tolerance: VerifyMy will not tolerate any form of abuse and will take all necessary measures to implement the SCPP.
  3. Risk management: VerifyMy ensures that risks are identified and minimised from the planning stage through to the implementation stage of activities.
  4. Everyone’s responsibility: the successful implementation of the SCPP is based on the individual and shared responsibility of all VerifyMy stakeholders including employees. VerifyMy will seek to ensure that partners' programmes also comply with international safeguarding standards.
  5. The duty of notification: any suspected violation or any actual violation of the current Code of Conduct must be reported immediately to the supervisor or the MerifyMy CPC. Confidentiality will be maintained throughout the entire procedure.
VerifyMy employees and stakeholders will:
  • Treat children with respect and equally regardless of age, sex, language, religion, opinion or nationality, ethnic or social origin, status, class, caste, sexual orientation, or any other personal characteristics.
  • Help children to take part in decisions which concern them according to their age and their level of maturity.
  • Maintain a culture of communication and create trust with children, employees and representatives of partner organisations so that concerns may be shared and discussed.
  • Use non-violent and positive behaviour methods when supervising children.
  • Encourage children and communities to speak openly about their interactions with adults and with each other.
  • Inform children and communities of their right to report any worrying situations and how they can raise a concern.
  • Empower children so that they are in a position to better protect themselves.
  • Make sure that another adult is present or try to be visible when in contact with a child.
  • Plan activities and organise the workplace in such a way so as to minimise the risk of harm taking into account the age and development of children.
  • Ensure that information concerning children remains confidential.
  • Behave in a way that sets a good example.
  • Obtain permission from the child and their parents before taking a photograph, recording or using the child’s image, what they have said or their history. This includes explaining to children and their parents how the photos or messages will be used.
  • Ensure that the child does not pose in a degrading manner or in a way that may be interpreted by others as having sexual connotations.
  • Raise any concerns and queries concerning the SCPP with a manager or the CPC.
  • Immediately report any suspicions or allegations to the CPC of behaviour which goes against the principles of the SCPP and Code of Conduct including any form of child abuse, even if the information or allegation is vague.
VerifyMy employees and stakeholders will never:
  • Engage in any form of sexual relations with anyone under 18 years old, regardless of the legal age of sexual consent, the law and local customs. Mistaking a child’s age is not a defence.
  • Exchange money, job, goods or services or humanitarian aid for sexual favours or subject a child to any other kind of humiliating, degrading or abusive behaviour.
  • Touch children or use language or make suggestions in an inappropriate manner to provoke, harass or degrade the child or show disrespect for cultural practices. This includes acting in a manner which is likely to have a negative impact on the child’s confidence and feelings of self-worth.
  • Exploit a child for labour.
  • Discriminate against, treat children unequally or unfairly for example by favouritism or excluding others.
  • Invite a child or their relatives to their home or develop a relationship with a child and/or their family which may be considered outside normal professional boundaries.
  • Work with or transport a child alone without the prior authorisation of their manager, unless absolutely necessary for the safety of the child.
  • Be under the influence of drugs or alcohol while working with children.
  • Take photos or videos of beneficiaries for use that is not strictly professional unless the CPC gives permission.
  • Watch, publish, produce, or share pornography showing children, and/or show pornographic material to children.
  • Show the faces of children who are exploited sexually, victims of trafficking, abuse, in conflict with the law, linked to armed groups or who can easily be located even if their identity has been modified.
  • Represent children as victims (weak, powerless, unassisted, desperate, etc.).
  • Publish a story or image which may endanger a child, their family or community.
  • Use photos which have not been checked and approved by a manager, or post unofficial pictures or information about children on personal websites or social networks.
  • Maintain contact with children and/or their families via social networks, unless a specific VerifyMy project requires them to do so and they have been given express permission.
  • Close their eyes to, ignore or fail to report any concern, suspected violation or violation of the SCPP and the Code of Conduct to the CPC.
VerifyMy employees and stakeholders understand that, in the event of suspicions or allegations of their violation of the Code of Conduct: VerifyMy will take any action deemed necessary, which may include, but is not limited to:
  • Providing assistance for the victim and taking immediate steps to protect and support the child.
  • Attempting to establish the facts in the most objective manner possible (the presumption of innocence prevails) while protecting the reputation and confidentiality of the adults involved.
  • Undertaking disciplinary actions, which may result in my suspension or termination of contract.
  • Initiating judicial proceedings and/or reporting to the competent authorities any violation of the Code of Conduct which may breach national legislation.
  • Taking appropriate measures in order to ensure that such incidents do not occur again, for example, informing other organisations which may apply for professional references regarding the termination of contract due to violation of the principles of the protection of children (within the legislative framework applicable to the protection of information).

7. Roles and Responsibilities of the Child Protection Champion

To support operations with the day-to-day implementation of the SCPP:
  • To act as the main point of contact within the delegation for child safeguarding.
  • To ensure that employees and clients are aware of the SCPP and their responsibilities under it (for example by providing training and guidance).
  • To advise and support employees and clients with the implementation of the SCPP, including risk assessments.
  • Establish links with local specialist child welfare, health and law enforcement contacts in order to have information available if an incident occurs and/or external advice is needed.
  • Ensure that the SCPP and our commitment to children’s rights is made known to children and other stakeholders who work with VerifyMy, and that the policy is accessible.
  • Ensure that the name and contact details of the CPC are made available so that people know how to raise a concern/where to seek advice.
  • To act as the first point of contact for concerns regarding child protection incidents and to escalate those concerns as appropriate.
  • Keep an accurate record of any incidents.
Skills and Characteristics:
  • Have knowledge and experience about child safeguarding and child protection.
  • Have respect and authority within the business so that their opinions are valued.
  • Be approachable, with good communication skills with adults and children.
  • Be able to keep calm when a concern is raised, especially if a child needs assistance.
  • Be able to work with others to ensure that the policy is implemented, and respond where a child protection incident occurs.
  • Commitment to safeguarding children and upholding their rights, together with the ability to advocate for and defend safeguarding.
  • Training and presentation skills.
  • Be able to keep information confidential.

Proud to be funded by

Google for Startups
We are ISO 27001 Certified

KYC AVC UK Ltd has been certified
by A-LIGNto ISO 27001 under
certificate number ISMS-KY-11920.

PAS 1296:2018

KYC AVC UK Ltd is certified under
PAS1296:2018 - the code of practice
for online age verification.

Proud member of UKIE

Trade association for the UK's
games and interactive
entertainment industry.

High-end cryptography

All data is encrypted at rest and
in-transit using a combination of 256-bit
encryption and hashing algorithms.

KJM approved

Age verification system approved
by the German regulator for the
protection of minors on online media.

Proud member of the IWF

Working to stop child sexual abuse