Child Protection Policy

CHILD PROTECTION SAFEGUARDING

30 December 2021
CONTENT

Preamble
PART I: INTRODUCTION
1.1 El Sistema Greece mission
PART II: SCOPE, PRINCIPLES AND DEFINITIONS
2.1 . Scope of this Policy
2.2 Principles of The Policy
2.3 . Definitions
PART III: POLICY PROCEDURES AND IMPLEMENTATION
3.1 Risk Assessment
3.2 Recruitment policy and guidelines for ESG Staff and Volunteers
3.3 Employment Agreements – Service delivery contracting and sub-contracting policy issues
3. 4 Professional boundaries and Code of Conduct
3.5 Process for the reporting of safeguarding issues and concerns
3.6 Awareness of staff members, volunteers and partners
3.7 Commitment to the policy by visitors and confirmation of awareness
3.8 Regulation of use of images and videos by visitors and external persons
PART IV: MONITORING, EVALUATION and REVIEWING
PART V: LIST OF DOCUMENTS ANNEXXED
5.1. Code of Conduct
5.2. Code of Conduct for Journalists
5.3. Guidelines for personal data protection during the remote work
5.4. Flow chart report
5.5. Incidence reporting form
5.6. Parent consent form for personal data collection and use
5.7. Parent consent form for taking pictures and use of them
5.8. Staff personal declaration (on criminal record)
5.9. Staff GDPR declaration (for freelancers)
5.10. Staff GDPR declaration (for employees)
5.11. Staff GDPR declaration (after leaving the job position)

CHILD PROTECTION POLICY

Preamble:
El Sistema Greece is a community music project inspired in the philosophy and methodology of El
Sistema in Venezuela, created in September 2016. Open to all children and youths in Greece, it promotes
the social inclusion of refugee children in the Greek and European society by means of group music
practice; it also addresses disadvantaged Greek children and youth who wouldn’t otherwise have access to
studying music. No matter their origin, nationality, or religion— the members of El Sistema Greece are
inspired to dream and strive for a more welcoming society and a better future.
The current document is issued in Athens in October 2018 and is approved by its founders and
administrators in order to be implemented in all its activities and locations. Its first review has been
approved in December 30, 2021.

PART I:

1. INTRODUCTION

1.1 El Sistema Greece’s mission
Musical education has been proven to be an incredibly effective medium for achieving long term social
inclusion, for both the children involved and their families.
The Funders of El Sistema Greece have experienced the changes inspired by the practice of ensemble music
and wish to provide a new platform for dialogue and togetherness across the diverse communities
represented within the Greek society, including refugee camps and shelters for unaccompanied minors.
Within the choir or orchestra, the students learn to consistently work to achieve their goals, in a bid to
pursue excellence. By spending time with their peers in an environment of tolerance and solidarity, the
young musicians grow in a culture of peace. By teaching them music, El Sistema Greece wishes to inspire
them to build an inclusive society for all and to strive for a better future.
El Sistema Greece provides free music education to all children who have lived the experience of leaving
their homes in search of a future and to gives them a social and educational experience which will improve
their lives not only inside refugee camps, but also in the wider frame of the Greek and European society as
a whole, regardless of nationality or religion.
El Sistema Greece is a concrete possibility to improve children’s life in the refugee camps and to prepare
them for a world they need to be included in. It operates with Greek teachers and collaborates with
international artists and pedagogues, in the belief that these children deserve the best educators.
The partners are local and international, private and public, since it is ESG’s belief that all the parts of
society have to be included in the welcoming process and in the mission of dealing with the migrations
issue and supporting those who flee from war, persecution and poverty.

PART II:

2. SCOPE, PRINCIPLES AND DEFINITIONS

2.1 Scope of this Policy
The overall purpose of this document is to ensure the prevention and avoid the risk of occurrence of
situations in which children’s rights are infringed during the activities organized, hosted or participated by
El Sistema Greece and to set out the corresponding procedures.
This document’s goals are to:
• frame the principles and procedures for the support of the staff, partners and volunteers in their
practices
• make sure that procedures to protect children and report any concerns about their welfare to
appropriate authorities shall be followed.
These procedures cover actions of anybody who represents El Sistema Greece and not only internal staff,
but also associates.
Staff includes:
• all staff, national and international
• all volunteers and interns
Associates includes:
• all contractors, e.g., consultants
• all board members
• all partners including local community based partners
• guests and visitors

2.2 Principles of The Policy
This policy is written in accordance with the Greek national and international legislation and norms
concerning children and youth rights, including but not limited to:
• The UN Convention on the Rights of the Child (ratified by Greek Law Nr. 2101/1992), including the
Optional Protocol to the Convention on the Rights of the Child on the involvement of children in
armed conflict (ratified by Greek Law Nr. 3080/2002) and the Optional Protocol to the Convention
on the Rights of the Child on the sale of children, child prostitution and child pornography (ratified
by Greek Law Nr. 3625/2007).
• The European Convention on the Exercise of Children’s Rights (ratified by Greek Law Nr.
2502/1997).
• The Directive 2011/93/EU of the European Parliament and of the Council of 13 December 2011 on
combating the sexual abuse and sexual exploitation of children and child pornography, and

replacing Council Framework Decision 2004/68/JHA (transposed into the Greek legislation by
means of Law Nr. 4267/2014).
• The International Labour Organization Convention (n° 182) on the prohibition of the worst forms
of child labor and the immediate action to eliminate them, 1999 (ratified by Greek Law Nr.
2918/2001).
• The Greek Presidential Decree Nr. 36/1994 on measures for the protection of children.
• The Greek Law Nr. 1837/1989 for the protection of child labor.
Furthermore, ESG is committed to the following fundamental principles:
• the welfare of a child or young person will always be paramount
• the welfare of families and refugee communities will be promoted
• the rights, wishes and feelings of children, young people, their families and communities will be respected
and listened to
• those people in positions of responsibility within our organization will work in accordance with the
interests of children and young people and will follow the policy outlined below
• those people in positions of responsibility within our organization will ensure that the same opportunities
are available to everyone and that all differences between individuals will be treated with respect.
2.3 Definitions
• A child is under the age of 18 (as defined in the United Nations convention on the Rights of a Child).
• Youth are those belonging to the age group 15 to 25 years (in line with main provisions of Greek
legislation)
• Abuse is perceived according to the meaning of the term “abuse” as it is outlined in the Greek legal
framework and jurisprudence as well as in the relevant international norms. It may take various forms,
including the following: Physical abuse, Emotional abuse, Sexual abuse, Bullying, Neglect.
Abuse or neglect of a child or young person is caused by inflicting harm or by failing to act to prevent them.
Children may be abused in family or in an institutional or community setting by those known to them or by
a stranger.
Physical abuse
Physical abuse may involve hitting, shaking, throwing, poisoning, 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 whom they are looking after.
Emotional abuse
Emotional abuse is the persistent emotional ill treatment of a child, such as to cause severe and persistent
adverse effects on the child’s emotional development. It may involve conveying to children that they are
worthless or unloved, inadequate, or valued only in so far as they meet the needs of another person. It
may feature age or developmentally inappropriate expectations being imposed on children. It may involve
causing children to frequently feel frightened or in danger, or the exploitation or corruption of children.
Some level of emotional abuse is involved in all types of ill treatment of a child, though it may occur alone.
Sexual abuse

Sexual abuse involves forcing or enticing a young person to take part in sexual activities, whether or not the
child is aware of what is happening. The activities may involve physical contact, including penetrative or
non-penetrative acts. This may include non-contact activities, such as involving children in looking at, or in
the production of, pornographic material, or watching sexual activities, or encouraging children to behave
in sexually inappropriate ways.
Bullying
Bullying is aggressive behaviour that is intentional and that involves an imbalance of power or strength. It
occurs when a child or person is subjected to negative behaviour, repeated over a period of time.
Neglect
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result
in the serious impairment of the child’s health or development. It may involve a parent or carer failing to
provide adequate food, shelter and clothing, failing to protect a child from physical harm or danger, or the
failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or
unresponsiveness to, a child’s basic emotional needs.

PART III:

3. POLICY PROCEDURES AND IMPLEMENTATION

It is the policy of ESG to safeguard the welfare of all children and young people by protecting them from all
forms of abuse, including physical, emotional and sexual harm.
This organization is committed to creating a safe environment in which young people can feel comfortable
and secure whilst engaged in any of ESG’s activities, residential courses or workshops. Staff and volunteers
should, at all times, show respect and understanding for individuals’ rights, safety and welfare, and conduct
themselves in a way that reflects the ethos and principles of ESG.
The procedure is approved by the founding members and the management staff of the organization and
revised on a yearly basis by a specific internal committee, in charge of supervising on the protection of the
child’ rights in the organization’s activities.
El Sistema Greece will endeavour to safeguard children and young people by:
• Adopting child protection guidelines through a code of behaviour for staff and volunteers
• Sharing information about child protection and good practice with children, parents, staff and
volunteers
• Sharing information about concerns with agencies who need to know, and involving parents and
children appropriately
• Following carefully the procedures for the recruitment and selection of staff and volunteers
El Sistema Greece will act in order to prevent and combat risks of Child Rights’ Infringement as follows:

3.1 Conducting Risk assessment on all operations of ESG;
3.2 Establishing a safe recruitment policy, including guidelines for ESG Staff and Volunteers
3.3 Establishing service delivery contracting and sub-contracting policies;
3.4 Establishing professional boundaries that safeguard professional integrity for the staff and that
assure correctness of the relationship between staff members and the beneficiaries, by means of a
mandatory CODE OF CONDUCT;
3.5 Establishing a clear process for the reporting of safeguarding issues and concerns;
3.6 Communicating its policy clearly and effectively towards the staff and organizing specific trainings
for them;
3.7 Requesting commitment to this policy by visitors and confirmation of awareness;
3.8 Regulating the use of images and videos by visitors and external persons;

3.1 Risk Assessment
Risk Assessment is regularly done on all operations of ESG; specifically, when planning performances or
trips/activities out of main locations, a risk analysis is always undertaken by the safeguarding officer and
the staff. Risk mitigation strategies, which minimise the risks to children, are developed and incorporated
into the design, delivery and evaluation of all operations.
After the COVID-19 outbursts of Spring 2020 and the lockdown period, at the retake of activities in
presence ESG has taken all the measures recommended by the Greek authorities to avoid risks of
contagion, including: temperature measurement for all persons entering the spaces/joining the activities of
ESG; distancing; sanification; wearing masks; control of number of people/room.
Plans for activities in remote are ALWAYS ready, in case new outbursts and/or quarantine periods for
teachers and students were to happen. Administration staff practices smart working as necessary, in order
to reduce the numbers of persons in the rooms; protection is guaranteed to pregnant staff, who works in
remote as soon as the pregnancy is ascertained.

3.2 Recruitment Policy and Guidelines for ESG Staff and Volunteers

3.2.1 Recruitment process
El Sistema Greece ensures safe recruitment through the following processes:
• recruitment adverts or application details shall state that the recruitment is done in line with safe
recruitment practices
• definition of jobs and roles descriptions with clear reference to safeguarding responsibilities
• interviews are conducted according to equal opportunity principles and interview questions are
based on the relevant job description and person specification

• a personal declaration on the criminal record shall be provided by the staff candidates, declaring
that they have no criminal records regarding an offence towards a child and do not know of any reason
why anyone would deem them unsuitable to work with children
• formal job offers are made after checks for suitability in line with this policy and in conjunction with
job’s specifications. Therefore, any document concerning health, education and generally any necessary
information are requested, provided that it is absolutely necessary for the certain purpose, its use will be
strictly limited within this purpose and it is in line with the privacy and data protection legislative principles.
3.2.2 Guidelines for ESG Staff and Volunteers
Attitudes: ESG staff and volunteers should be committed to:
• treating children and young people with respect and dignity
• always listening to what a child or young person is saying
• valuing each child and young person
• recognising the unique contribution each individual can make
• encouraging and praising each child or young person
Leading by example: ESG staff and volunteers should endeavour to:
• provide an example, which we would wish others to follow
• use appropriate language with children and young people and challenge any inappropriate
language used by a child or young person or an adult working with young people
• respect a child and young person’s right to privacy
One to one contact: ESG staff and volunteers should:
• not spend excessive amounts of time alone with children away from others
• in the unlikely event of having to meet with an individual child or young person, make every effort
to keep this meeting as open as possible
• if privacy is needed, ensure that the responsible staff person is informed of the meeting and its
whereabouts

Physical contact: ESG staff and volunteers should never:
• engage in sexually provocative or rough physical games
• allow, or engage in, inappropriate touching of any kind
General: ESG staff and volunteers should:
• be aware that someone might misinterpret our actions no matter how well intentioned
• never draw any conclusions about others without checking the facts
• never allow themselves to be drawn into inappropriate attention-seeking situations such as
tantrums or crushes
• never exaggerate or trivialise child abuse issues or make suggestive remarks or gestures about or
to a child or young person.

3.3 Employment Agreements – Service delivery contracting and sub-contracting policy issues
El Sistema Greece guarantees that all persons employed and providing services to it shall be contractually
bound by any and all policies and codes of conduct of El Sistema Greece, including the present one, by
means of a specific written reference in their contract. Failure to comply with these policies shall give
grounds for immediate termination of the contractual relationship.
Furthermore, El Sistema Greece ensures that partnerships with individuals or other institutions (contracting
and sub-contracting) shall not be in contrast with the scope and principles of this policy and that there will
be a systematic checking towards this. Contracts and memorandums of agreement for partnership delivery
work will include reference to this policy and a sentence of commitment to respect its basic principles and
standards, for the whole duration of the partnership.

3.4 Professional boundaries and Code of Conduct
Professional boundaries are established to safeguard the professional integrity, the correct detachment
and the proper relationship between a staff or volunteer member of El Sistema Greece and a beneficiary,
and they are based on a mandatory code of conduct – see Annex n. 1 to this policy.

3.5 Process for the reporting of safeguarding issues and concerns
3.5.1 Please, see Annex 5.4 for an example of the reporting process in case of issues.
El Sistema Greece nominates two persons as main officers for safeguarding issues – they are:
1. Angeliki Georgokosta
Designated Child Protection Person, [email protected]
2. Sevasti Matsakidou
Designated Child Protection Person, [email protected]
Also, ESG nominated Panayiotis Tsirides ([email protected]) as an internal advisor whenever a child
protection issue occurs.
3.5.2 If staff members or volunteers are concerned about a child, they must share their concerns
to these persons ONLY following a safe information sharing process. The purpose of this consultation is to
discuss concerns and decide what action is necessary. (It is good practice to ask a child why they are upset
or how a cut or bruise was caused, or respond to a child wanting to talk. This practice can help clarify vague
concerns and result in appropriate action). Also, children themselves should be aware that they can count
on those two competent persons if they feel they are somehow being threatened or if they feel
uncomfortable in any relationship with adults. Signs with information are hanging from the classrooms’
walls in different levels.
3.5.3 Making a referral (see Annex 5.5 for a template)
A referral involves giving Social Services or the Police information about concerns relating to an individual
or family in order that enquiries can be undertaken by the appropriate agency, followed by any necessary
action.
Any referral procedure of El Sistema Greece should be put in practice by both Designated Child Protection
Persons.
Parents/caregivers should be informed if a referral is being made, except in the circumstances outlined in
the paragraph “Awareness and response”. ESG’s internal advisor is to be consulted on whether any of

these circumstances apply to a specific case and prior to communicating with the parents/caregivers. The
inability to inform parents, however, should not prevent a referral being made. It would then become a
joint decision with the public social services (EKKA) about how and when the parents should be approached
and by whom.

Information required for a referral: as much of the following information as possible should be given.
• the name, telephone number and position of the staff member of volunteer making the referral
• full name, residence address and the age of the child or young person if applicable.
• names, address of parents/caregivers and their telephone numbers if applicable.
• details of the child’s gender, ethnicity, first language, and any special needs or abilities if
applicable.
• the names of professionals known to be involved with the child and/or family e.g.: Music teachers,
ESG Staff, NGOs volunteers, camps’ staff etc.
• the nature of the concerns and foundation for them (including dates and times of any specific
incidents)
• whether the child or young person has been spoken to and if so, what was said
• an opinion on whether the child may need urgent action to keep them safe
• a view on what appears to be the needs of the child or of the family
• whether the consent of a parent/caregiver has been given to the referral being made
• whether this information has been passed on to anyone, and if anyone else has been consulted.
The unavailability of some information should NOT prevent a referral being made.
Following a referral, ESG staff members and volunteers must ensure that an accurate record of the
concern(s) made at the time is kept within El Sistema Greece. The organisation should ensure that any
records made in relation to a referral should be kept confidential and in a secure place.

In Greece, the public service offers the following helplines (available 24-hours per 7-days) to make a
referral:
– 1107: SOS national line for the protection of the minors. National Centre for Social Solidarity (Greek
acronym EKKA), public agency
– 197: SOS national line for the adults. National Centre for Social Solidarity (EKKA), public agency.
– Public prosecutor for the protection of minors, public authority. For Athens, please use the enclose
contacts http://www.eispa.gr/opencms/opencms/epa_site/epa/deps/tmima_anilikon.html
– 100: SOS Hellenic Police emergency line., public authority
– 112: SOS European emergency line, European authority
Finally, private agencies operate the following helplines (available 24-hours per 7-days):
– 1109: SOS national line for the protection of the victims of trafficking in persons. “The A21
Campaign”, NGO, private agency
– 1056: SOS national line for the protection of minors, “Smile of the Child”, NGO, private agency
3.5.4 Internal Procedures – Legal measures
In case ESG becomes aware of a potential incident of misconduct, as per the above, it will immediately take
measures such as temporarily suspending any person(s) involved in the case, investigate and if it deems it
necessary, proceed with the termination of such person(s) contracts pursuant to the applicable legal

provisions of the Greek legislation. In close and constant cooperation with ESG’s legal department, all
necessary legal requirements shall be followed, based on the individual characteristics of every case.

3.6. Communicating the policy to the staff, volunteers and partners. Specific Training.
Special focus on communication, training and support for staff, partners, volunteers shall be given by El
Sistema Greece. This will include:
• discussion about the safeguarding policy and confirmation of reading and understanding it
• clear information and guidance of all staff, partners and volunteers, so as to ensure familiarity with
reporting processes
• initial training on safe working practices, on child and youth protection with a special focus on those
belonging in vulnerable groups
3.6.1 Awareness and response
ESG staff and volunteers need to be alert to the potential abuse of children, both within their families and
also in other surroundings, including abuse by other ESG staff members and volunteers.
The organization members should know how to recognize and act upon indicators of abuse, or potential
abuse, involving children. All members of the organization should be alert and ready to respond to any
suspected or actual abuse of a child, in accordance with these procedures.
It is good practice to be as open and honest as possible with parents/caregivers about any concerns.
However, staff members and volunteers must not discuss their concerns with parents/caregivers in the
following circumstances:
• where sexual abuse is suspected
• where organized or multiple abuse is suspected
• where fictitious illness by proxy (also known as Munchausen Syndrome by proxy) is suspected
• where contacting parents/carers would place a child, staff members or volunteers, or any others at
immediate risk.

3.6.2 Case Management: what to do if children talk to ESG staff and volunteers about abuse or neglect
It is recognized that a child may seek staff members and volunteers out to share information about abuse
or neglect, or talk spontaneously individually or in groups when they are present. In these situations, staff
and volunteers must:
• listen carefully to the child. DO NOT directly question the child
• give the child time and attention
• allow the child to give a spontaneous account; do not stop a child who is freely recalling significant
events
• make an accurate record of the information: timing, setting and people present; the child’s
presentation as well as what was said. Do not throw this away as it may later be needed as evidence
(see Annex 5.5 a template form for internal reporting)

• use the child’s own words where possible
• reassure the child:
– that you are glad he or she has told you
– that he or she has not done anything wrong
– by telling him/her what you are going to do next explain that you will need help to keep the child
safe
• do NOT ask the child to repeat his or her account of events to anyone.
Immediate action may be necessary at any stage in involvement with children, families and communities.
In all cases, it is vital to take whatever action is needed to safeguard the child or young person.
• if emergency medical attention is required, this can be secured by calling an ambulance (dial 166)
or taking a child to the nearest Accident and Emergency Department. NB: 1. If parents are not
involved their notification is necessary. 2. Never move a child to the hospital with private car. 3.
The child is always escorted by at least two adults persons.
• if a child is in immediate danger, the police should be contacted (dial 100 or 112) as they only have
the power to remove a child immediately if protection is necessary, via the Public Prosecutor
Order.
If the responsible persons (inside ESG) are implicated in the concerns, then these concerns should be
discussed directly with the National Centre for Social Solidarity (EKKA) at 1107.
ESG staff members and volunteers should consult externally with the National Centre for Social Solidarity
(EKKA) at 1107 in the following circumstances:
• when there is an inability to consult promptly or at all with a Designated Child Protection Person
• when there is uncertainty after internal consultation as to whether child protection concerns exist
• when there is disagreement as to whether child protection concerns exist
• when the concerns relate to any member of the organising committee; consultation is not the
same as making a referral but should enable a decision to be made as to whether a referral to the
National Centre for Social Solidarity (EKKA) or the Police should progress.
3.6.3 Confidentiality
Respect of the principles of trust, confidentiality and personal data protection is required. A safe
information sharing process among the competent involved professionals/ stakeholders shall be followed.
Data protection and confidentiality duty is expanded throughout the involvement in ESG works and tasks
and even after that. The current legislation regarding the protection of privacy and personal data shall be
respected.
3.6.4 Ensuring beneficiaries’ awareness
Children and young people have a right to information, especially any information that could increase their
safety.
ESG will make beneficiaries aware of the Safeguarding Policy, using appropriate means that are in line with
the age and the specific profile of each beneficiary, so as to ensure that the principles and procedure of this
policy are adequately understood.
Indicatively, these means may be:
– Easily accessible and comprehensive information pack on safeguarding arrangements, ie through
brochures, documents, web displayed information etc

– Discussion and agreement with each beneficiary about safeguarding arrangements and
concern/complain procedures
When sharing information, ESG staff members and volunteers should be sensitive to the level of
understanding and maturity, as well as to the level of responsibility of the child or young person with
whom they are sharing.

3.7 Commitment to the policy by visitors and confirmation of awareness
Any person such as sponsors, volunteers, contractors, suppliers, donors, journalists, consultants, occasional
visitors who visit El Sistema Greece’s infrastructures or offices and may come into contact and/or interact
with children and young adults who benefit from ESG activities:
• are given a copy of this policy and are made aware that they must act in accordance and comply
with it whilst visiting ESG infrastructures or offices.
• declare their written commitment to respect and comply with the safeguarding policy principles, as
well as with the principles and rules provided in the code of conduct.

3.8 Regulation of use of images and videos by visitors and external persons
Photographs, videos and other images are forbidden to be taken and/or published or publicly displayed
except in cases where an appropriate consent (Annex 5.7) is given, provided that:
• these pictures are respectful
• they do not expose beneficiaries to any danger or risk
• they do not infringe personal data protection provisions
• they could not be interpreted as sexually suggestive.
The pictures of children cannot be used in order to gain money in any way, nor for journalistic purposes,
without written permission from El Sistema Greece.

PART IV

4. Monitoring, Evaluation and Reviewing
In order to ensure the protection of children’s rights and to prevent situations that might affect the rights
thereof, El Sistema Greece will follow a standard procedure that is subject to biannual review or whenever
deemed necessary (e.g. through the emergence of unforeseen situations that could jeopardise the rights of
the child, and due to the need to streamline the process of preventing and protecting children’s rights,
amending or supplementing related legislation, or in order to tailor to donors’ requirements, etc.).
Monitoring and Evaluation are done in collaboration with an external consultant, specialised in the subject