Your privacy and security are our priority, and we strive to incorporate the best security practices in our operations.

If you are a subscriber, when you make an online payment on the MAP Platform, we may collect Personal Data such as your name, billing address, Permanent Account Number, telephone number, email address and any other information provided by you. The Personal Data that you are asked to provide, and the reasons for asking the same, shall be made clear to you when you are requested to provide your Personal Data. We only collect information that we believe to be relevant and for the purpose of acknowledging receipt of the subscription.

If you contact us directly, we may ask you to provide additional information about you such as your name, email address, phone number, and the contents of the message and/or attachments you may send us, and any other information you choose to provide.

Additionally, when you register for an event on the MAP website, or its’ services, we may ask for your contact information, including, but not limited to — name, occupation, gender, date of birth, address, email address, medical history and phone number.

MAP PLUS will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data shall take place to any other person or organisation. Your Personal Data will not be shared with or sold to any third-party companies or organisations.

We gather statistical and other analytical information collected on an aggregate basis of all visitors on MAP PLUS. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, clipped or anonymised user IP addresses, browser types and other anonymous statistical data involving the use of the MAP Platform to understand geography of our visitors and help us better organise the website.

We will process any Personal Data you provide to us for the following purposes:

(1) Provide, operate, and maintain our website
(2) Improve, personalise, and expand our website
(3) Understand and analyse how you use our website
(4) Develop new products, services, features, and functionality
(5) Communicate with you, either directly or through one of our partners, to provide you with updates and other information relating to the website, or for marketing and promotional purposes
(6) Send you emails
(7) Find and prevent fraud
(8) To respond to any customer service related queries
(9) Creating profiles for subscribers

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please get in touch with us here.

When you visit the MAP PLUS, we send one or more cookies (a small file containing a string of characters) to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service, including for storing user preferences, improving search results and ad selection, and tracking user trends.

MAP PLUS also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web. We may set one or more cookies in your browser when you visit a website. Cookies can make the site more useful by storing information about your preferences on particular site(s), thus, enabling website owners to provide more useful features for their users.

The information collected by “cookies” is anonymous aggregated research data and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or inform you when they are set. However, by disabling them, you may not be able to take full advantage of our website.

This Privacy Policy does not cover cookies as used by the web advertising partners. You are always free to decline such cookies, if your browser permits, or to ask your browser to indicate when a cookie is being sent.

We shall not disclose your Personal Data to third parties unless you have consented to this disclosure.

We shall disclose your Personal Data if we believe in good faith that we are required to disclose it in order to:

(1) Comply with any applicable law, a summons, a search warrant, a court or regulatory order or other statutory or legal requirement.

(2) Enforce the MAP Terms of Usage or to protect our rights.

(3) Protect the safety of users of the MAP Platform.

We will share limited Personal Data of the users as required with our agents, representatives, service providers and contractors in order to offer you services in connection with our website, communicate news and information about MAP, provide customer service, enhance and improve user experiences, and complete financial transactions. These service providers are authorised to use your information only to the extent necessary to serve these purposes, or as otherwise authorised by this policy.

We may also share your Personal Data when you make a payment or when you donate. In the event wherein MAP promotes/recommends a particular cause or social event, we may share your name and contact information and the amount of your payment with the said relevant non-profit organisation, to which the said donation has been made by you.

If MAP merges with, or becomes an affiliate of another organisation, we will ensure the confidentiality of any Personal Data involved in such transactions, and provide notice before Personal Data is transferred and becomes subject to a different privacy policy.

We will retain your information for as long as needed to provide our services. We may also retain and use your Personal Data in order to comply with our contractual or legal obligations, audit requirements, resolution of disputes, preventing abuse and other statutory/legal purposes. For example, tax laws in India may require us to keep contact information and contribution level of subscribers on a file.

The information we collect is only for the improvement of our services. We may retain your information to provide certain services to users, to recognise them the next time they use MAP PLUS or to send promotional emails and text messages.

If we decide to change our privacy policy, we will post those changes to this privacy statement so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the Privacy Policy under which the information was collected. We encourage you to periodically review this policy for the latest information on our privacy practices.

You have certain rights with respect to the Personal Data we collect about you. Upon request, we tell you what information we hold about you, we rectify any incomplete or inaccurate information and also restrict the use of your information. We will make reasonable efforts to delete your information if you ask us to do so, unless we are otherwise required to keep it.

MAP PLUS may contain links to other websites including our partners. MAP is not responsible for the privacy policy or practices on such linked sites. This Privacy Policy governs only information collected on this website. When linking to another website (s), you should read the privacy policy stated on that website. Please be aware that the terms of our Privacy Policy do not apply to these outside websites.

Our site contains links to other sites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any third-party website accessed via a link from MAP PLUS, or any contract entered into or through a third-party website. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.

All content on MAP PLUS including graphics, text, icons, interfaces, audio clips, logos, images and software is the property of MAP and/or its content suppliers and is protected by Indian and international copyright laws. The arrangement and compilation (meaning the collection, arrangement, and assembly) of all content on MAP PLUS is the exclusive property of MAP and protected by Indian and international copyright laws.

Permission is given to use the resources of this MAP Platform only for the purposes of browsing, learning, or making enquiries. Any other use, including the reproduction, modification, distribution, transmission, republication, display or performance of the content on this MAP Platform can only be made with the express permission of MAP. All other trademarks, brands and copyrights other than those belonging to MAP belong to their respective owners and are their property.

We understand the importance of keeping your information secure and confidential. To safeguard your information, we have implemented effective policies for this purpose.

When you make a payment for subscription/purchase, information about your payment card is transmitted securely through a Payment Gateway. Payment Gateways allow you to make a payment electronically using your credit card, debit card, net banking or other payment methods.

The payment gateways collect data that may include your contact details, your card details, and the transaction details which facilitates your online payment. We do not collect or store any of these personal details and we do not have any control over them. This data is completely managed by the Payment Gateway tools, in accordance to their own privacy policies.

We have taken and will continue to take reasonable efforts to protect Personal Data in our possession, or control, by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

While we strive to protect your Personal Data, we cannot ensure the security of any Personal Data which you may have transmitted to us, via the Internet, and we urge you to take every precaution to protect your Personal Data and use a secure browser.

By using our website (https://map-india.org), you hereby consent to our Privacy Policy and agree to its terms.

If you have any comments or questions about the collection, use or disclosure of your Personal Data or this Privacy Policy Statement, please contact us in writing at the address below referencing ‘Privacy Policy Statement’:

Data Protection Officer
Name: Mr. Ashwath Patil
Address: The Museum of Art & Photography
Sua House, 26/1 Kasturba Cross Road, Bengaluru 560001
Email

1. Definitions
2. Core Safeguarding Principles and Values
3. The Need for a Policy
4. Conditions of Service
5. Safeguarding Management, Roles & Responsibilities
6. Recognising & Reporting Incidents
7. Recording & Ramifications of Safeguarding Allegations
8. Online Safety Safety in the Museum space
9. Annexure 1: Children & Adults with Disabilities
10. Annexure 2: Code of Conduct
11. Annexure 3: Safeguarding Incident Report Form
12. Annexure 4: Photography & Film Making: Consent & Data Protection

1.1 Child – For the purposes of this policy, a “child” is defined as anyone under the age of 18, in line with the UN Convention on the Rights of the Child (CRC), including children with disabilities as per paragraph 2 and Article 23 of the CRC.

1.2 Child abuse – According to the World Health Organisation, “Child abuse” or “maltreatment” constitutes ‘all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power.’1

1.3 Child protection – ‘Child protection’ is a broad term to describe philosophies, policies, standards, guidelines and procedures to protect children from both intentional and unintentional harm. In the current context, it applies particularly to the duty of MAP – and individuals associated with MAP – towards children.

1.4 Safeguarding – Safeguarding within the scope of this policy, is defined as the responsibilities, measures, and activities that MAP plans to undertake to safeguard children and vulnerable adults and from both intentional and unintentional harm. In the current context this applies to the set of policies, procedures and practices that we drive to ensure MAP is a safe organisation, including our direct programme implementation, work through partners and management of personal data.

1.5 Vulnerable Adult – Adults-at-risk or vulnerable adults are persons aged 18 years or over who are or may be in need of community care services by reason of intellectual or other disability, age or illness and who are or may be unable to take care of themselves or unable to protect themselves against significant harm or exploitation; are experiencing, or at risk of, abuse or neglect; and as a result of their care and support needs are unable to protect themselves from either the risk of, or the experience of abuse or neglect.

1.6 Direct contact with children or vulnerable adults – Being in the physical or virtual presence of children or vulnerable adults in the context of MAP’s work, whether contact is occasional or regular, short or long term. Worldwide, this could involve the delivery of workshops, talks or walkthroughs to schools or groups comprising children or vulnerable adults, working with youth groups as well as children’s homes/institutions visits and attending conferences at which children or at-risk adults are also present. [N.B. this list of examples is not exhaustive].

1.7 Indirect contact with children or vulnerable adults – Access to, managing and use of the personal data of children and vulnerable adults in the context of MAP’s work, such as names, addresses and photographs or any other personal information.

1.8 Partner – For the purposes of this policy:

1. Local or international organisations that provide funding for MAP, whether funding is occasional or regular, short or long term, for a specific project or towards core costs and regardless of the amount of money involved.
2. Local or international organisations that actively participate in / collaborate with MAP, whether the project relationship is short or long term, a one-off or regular/ongoing arrangement, and regardless of whether or not any funding is involved.

1.9 Policy – A statement of intent that demonstrates a commitment to safeguard all visitors, especially children and vulnerable adults as the most vulnerable individuals/groups, from harm and makes clear to all what is required in relation to their protection and welfare. It helps to create a safe and positive environment for all and to show that the organisation is taking its duty and responsibility of care seriously.

1.10. Online Safety – The process of limiting the risks to children and young people when using any internet, digital and mobile technology.

1.11 Staff & Volunteers – For the purposes of this policy, and for ease and simplicity this term will collectively refer to all of MAP’s employees and staff (freelance, contracted or permanent) and volunteers (whether interns, researchers or others). And include trustees, advisors and board members in its spirit.

_______________________________________________________

1 The WHO definition of Child Abuse as defined by the Report of the Consultation on Child Abuse Prevention WHO – 1999

2.1 The legal basis – MAP’s Safeguarding Policy is firmly based on the principles of the UN Convention on the Rights of the Child (UNCRC). Taken holistically, the CRC provides a comprehensive framework for the protection, provision and participation of all children without discrimination to ensure their survival and development to the maximum extent possible. On the understanding that the CRC must be read as a whole, the following articles nevertheless form the specific basis of child protection: 1 (definition of ‘child’), 2 (non-discrimination), 3.1 (the best interests of the child), 3.2 (duty of care and protection), 3.3 (standards of care), 6 (survival and development), 12 (participation), 13 (freedom of expression), 19 (protection from violence), 25 (periodic review of placements), 32, 33, 34, 36, 37(a) (protection from economic exploitation, substance abuse, sexual abuse and exploitation, ‘all other forms of exploitation’; torture, cruel, inhuman or degrading treatment or punishment), 39 (physical and psychological recovery and social reintegration).

Further, to ensure delivery of the Constitutional safeguards and the commitment to the UNCRC, the Government of India has enacted several legislative measures for protection of children. While all of them encompass provisions for protection or safeguards from some form of violence or abuse, the key child legislations in the context of protection of children include:

• POCSO Act, 2012
• The Juvenile Justice Act, 2015
• The Commission for Protection of Child Rights Act, 2005
• The Prohibition of Child Marriage Act (2006)
• The Protection of Children from Sexual Offences Act (2012)
• The Child Labour (Prohibition and regulation) Act (1986, amended in 2016)
• The Right of Children to Free and Compulsory Education Act, 2009
• The Criminal Law Amendment Act 2013, 2018

2.2 The moral basis – MAP believes that organisations working in the space of education have a duty to protect children from abuse, mistreatment, and exploitation from within organisations intended for their benefit. This duty is imperative and non-negotiable. Child protection is integrally linked to every other right of the child. Failure to ensure children’s right to protection adversely affects all other rights of the child. Without adequate standards and mechanisms of protection in place, an organisation may also be negligently or recklessly fostering an environment of abuse.

2.3 An end to silence – Silence breeds abuse and exploitation of children and vulnerable adults. Organisations with weak communication structures, where secrecy and shame prevail are particularly vulnerable environments within which abuse may thrive. Furthermore, without proper policies and explicit procedures in place, organisations are extremely vulnerable to false allegations of child abuse. MAP therefore believes in:

• promoting open lines of communication both internally and externally within and between organisations to improve awareness and implementation of child and vulnerable adult protection policies and practices;
• creating a framework to deal openly, consistently and fairly with allegations concerning both direct and indirect abuse.

2.4 Taking it further – The protection of children and vulnerable adults is not just about reading and signing a piece of paper: the policy sets out guidelines and standards that must be put into practice. These include, amongst other measures: recruitment procedures, review of management structures, staff training, and development of transparent protocols.

2.5 Challenging complacency – Resistance to addressing safeguarding issues may come from lack of understanding of the nature of abuse, lack of commitment to the organisation/programme, and a sense that abuse happens elsewhere. This policy and the guidelines set herein, also serve to proactively work towards ensuring that MAP supports a safe environment at all times.

These principles underpin all of the following standards set out in this document.

• Children and vulnerable adults are especially vulnerable to abuse, exploitation, and ill-treatment at the hands of carers, other project workers, and those with access to their personal information.
• Organisations working with children and vulnerable adults have been, are and will continue to be vulnerable to harbouring abuse until the issues are brought into the open.
• Organisations without protection policies, guidelines and systems are more vulnerable to false or malicious accusations of abuse.
• Without proper policies, guidelines and procedures in place, allegations of abuse, whether founded or unfounded, can destroy an organisation’s reputation.

As a condition of working/providing service to the museum, all MAP staff and volunteers are required to undergo the following, if their roles should involve direct or indirect contact with children and vulnerable adults.

4.1 Recruitment Processes:

• During the interview process, relevant questions will be asked to assess the candidates’ attitude and sensibilities regarding the protection of children and vulnerable adults. The assessment may be based on a checklist of parameters that would enable assessment of suitability.
• Explanations for matters that include gaps between duration of employment, frequent change of jobs, or sudden resignation will be sought.
• Candidates will be required to provide the name and contact information of at least two character references whom they have known for no less than two years, and excluding family members, with whom a thorough reference check will be carried out.

4.2 Employment Process:

• MAP’s HR representative will ensure that all new staff and volunteers sign and submit the Safeguarding Policy and are inducted to the policy and Code of Conduct (See Annexure 2) upon the commencement of employment.
• Candidates will also have to sign a personal declaration stating any criminal convictions, including spent convictions. MAP reserves the right to rescind an offer of employment or terminate the employment of an individual, should any criminal background or dealings come to light at this or any other time that presents a threat to its audiences or reputation.
• MAP will continue to monitor and ascertain the individual’s present aptitude, interest and sensitivity in working with children and/or vulnerable adults. And expect all staff to attend any trainings related to safeguarding that may be identified based on need.

All Map staff and volunteers have a moral and legal duty to do their utmost to ensure that children and vulnerable adults are protected from harm whilst engaging with MAP onsite and online. Through the implementation of this policy and effective monitoring of processes and procedures, MAP will strive to build and ensure a safe space for everyone. Towards this:

• All MAP staff and volunteers have a responsibility to maintain appropriate standards of behaviour and to report poor practice.
• MAP will seek to create an open culture, where transparent discussions of any issues or concerns may be raised.
• All staff and volunteers must be aware of situations which may present risks and remain alert to recognising safeguarding concerns regarding children, and vulnerable adults, and to report any concerns and all incidents according to MAP procedures.
• MAP will appoint a Designated Safeguarding Representative (DSR) to oversee and manage the day-to-day implementation, supervision and monitoring of the Safeguarding Policy in MAP. Even while the Board of Trustees will have the overall responsibility to oversee and ensure the policy’s implementation.
• MAP will ensure the training and supervising of staff and volunteers so that safeguarding issues are understood, awareness of the policy exists and reporting mechanisms are in place.
• MAP will ensure that incidents involving children and adults at risk are recorded and investigated appropriately.
• All Staff and volunteers of MAP keep in mind and assess the risk factors with suitable mitigation suggestions while designing and conducting workshops, events and programmes for children and vulnerable adults and ensuring a safe environment for all.
• An annual audit exercise is conducted to identify the level of responsibility for and contact with children and vulnerable adults; evaluate the risk of harm or abuse from incidents, if any; and to create appropriate strategies to manage any identified risks.

5.1 The Designated Safeguarding Representative:

The DSR will be responsible for drawing up MAP’s Safeguarding Policies and Guidelines, and ensure they are enforced, regularly reviewed and kept up-to-date. Additionally, they will:

• Promote the importance of safeguarding across the organisation and establish mechanisms to communicate and raise awareness about safeguarding issues.
• Act as first point of contact for all MAP staff and volunteers for advice if they are concerned about the safety and welfare of a child or adult.
• Manage any allegations or concerns about abuse raised; as well as ensure incidents are dealt with and reported appropriately.
• Support staff and volunteers after they have shared concerns about a child.
• Ensure records of any concerns reported are maintained and stored securely.
• Keep the executive committee and trustees up to date on safeguarding issues, providing reports and monitoring information on a regular basis.
• Ensure that all MAP staff and volunteers, especially those working with public engagement, receive appropriate training and have an overview of basic safeguarding training for the organisation.
• Contact statutory services if and when appropriate. The DSR may refer to the following external redressal mechanisms:

1. Child Welfare Committee (CWC) of Juvenile Justice Board
2. Child Helpline
3. The Department of Women and Child Development

MAP’s Designated Safeguarding Representative is Shilpa Vijayakrishnan, Head of Education and Outreach. (Contact: shilpa.vijayakrishnan@map-india.org)

5.2 Line Managers Responsibilities:

All of MAP’s line managers will:

• Be familiar with MAP’s safeguarding policy and procedures and be able to guide any of their team members who are concerned about the safety and welfare of a child or adult, and connect them with the DSR.
• Ensure all staff and volunteers are informed about the person to contact if they have a concern about the safety and welfare of a child or adult.
• Ensure that all staff and volunteers know where they can find the safeguarding policy and procedures and communicate to them any changes in policy and procedures.

5.3 Transparency & Access:

• All photography and record-keeping of information pertaining to children and vulnerable adults will follow a transparent system, and include the seeking of permission from suitable guardians, institutions or the children themselves. (See Annexure 4 for more on Photography & Film Making: Consent & Data Protection)
• The disclosure of any personal information about children and vulnerable adults will be communicated to relevant employees, consultants, contractors, trustees, officers, interns and volunteers only, on a strictly need-to-know basis.
• We recognise that MAP’s audiences, whether teachers, parents, carers or members of the general public, also have a part to play in helping us create and maintain a safe environment for everyone. MAP’s Safeguarding Policy will therefore be available on our public website, so that visitors have access to it.

5.4 Training and Education:

• Training and education are essential to implementing the Safeguarding Policy. The DSR supported by Inclusion and HR representatives will ensure that training is provided to all MAP staff and volunteers to orient them with safeguarding policy and procedures, including training on behaviour guidelines for those in direct contact with children and/or vulnerable adults, and guidance on the acceptable and unacceptable sharing of information of children/vulnerable adults.
• Opportunities for staff to learn about, recognise and respond to child abuse will also be available to all staff and representatives.
• As and when required, depending on any amendments made to the Safeguarding Policy, the DSR will ensure that further training is given to all consultants, staff and personnel.
• Periodic refresher courses for staff, volunteers and board members will be organised.

5.5 Behaviour Protocols:

• Any of MAP’s staff and volunteers will be fully informed of MAP’s Code of Conduct. This provides guidance on appropriate behaviour and working safely with children and adults. (See Annexure 2)
• This guidance will not only help to protect children and adults, but will also help MAP’s staff and volunteers to identify any practices which could be mistakenly interpreted and perhaps lead to false allegations of abuse being made. Safer working practices will help reduce the possibility of anyone using their role within the organisation to gain access to those who are the most vulnerable in order to abuse them, since staff and volunteers will be expected to report any breaches of this code by any others working for or on behalf of MAP.
• If in doubt, please consider how an action may be perceived rather than how it may be intended.
• MAP recognises the opportunities and challenges technology brings to those working with children and adults. We advocate applying the same principles, expectations and standards for interacting and communicating with children and adults online as in other areas of practice.

5.6 Communications with and about Children:

MAP believes that all children have the right to speak and be heard. Any of MAP’s staff and volunteers who have direct contact with children or vulnerable adults will refrain from acting in any way that intends to embarrass, shame, humiliate or degrade a child. This includes using abusive language, corporal punishments, or threatening. [N.B. this list of examples is not exhaustive]

Further, they will refrain from discrimination on the basis of race, culture, age, gender, disability, religion, sexuality, or any other markers, and ensure that at-risk children receive equal opportunities for participation.

All publications and content on the MAP website that includes images and text related to children and vulnerable adults will not contain the following:

• Manipulated or sensationalised text and/or images
• Discriminatory and degrading language
• Images in which children are inappropriately clothed
• Personal information about children

In addition, all information relating to children is limited to those members of staff who need to know and will be treated as confidential.

6.1 Recognising Concerns:

MAP staff and volunteers may, at times, have to respond to concerns about the welfare and safety of children and adults. This could include actual or alleged harm. Alternatively, a child or adult may inform a member of staff of their abuse directly.

MAP staff and volunteers are expected to remain alert to signs of abuse and neglect. A concern about the safety of a child or vulnerable adult may arise because:

• A child or adult tells you.
• A child’s or adult’s appearance displays signs of abuse or neglect, including injuries.
• Their behaviour is inappropriate and gives cause for concern.
• You witness someone being harmed by an adult or another child.
• Someone reports their suspicions about a child or adult being abused.

6.2 Raising Concerns:

Allegations may concern one or more children or adults. It can be about any child or adult, including visitors, MAP’s volunteers, staff, donors, patrons, interns, researchers, freelance contractors and trustees.

A safeguarding allegation towards MAP staff, volunteers or freelancers/contractors may be made where they have:

• Behaved in a way that has harmed, may have harmed or might lead to harm of a child, young person or vulnerable adult.
• Possibly committed or are planning to commit a criminal offence against a child, young person or vulnerable adult.
• Behaved towards a child, young person or vulnerable adult in a way that indicates they are or would be unsuitable to work with children, young people or vulnerable adults.

6.3 Reporting Concerns:

Evidence indicates that abuse which takes place within an organisation is rarely a one-off event. It is crucial those involved in MAP are aware of this possibility and that all allegations are taken seriously, and appropriate action taken.

6.3.1. All witnessed, suspected or alleged violations of the Safeguarding Policy must be immediately reported to the Designated Safeguarding Representative, who will record and act on these in a confidential manner in accordance with the standardised process developed by MAP and the best interests of the child or vulnerable adult in question. All reports of child abuse will be treated as serious, whether they are made by an adult or a child.

6.3.2. The DSR should be informed of situations even if it is unclear if the allegation constitutes abuse or not, and the action to be taken is not obvious. The DSR will consider who else needs to be informed bearing in mind the need to maintain confidentiality.

6.3.3. If the concern is about the behaviour of the DSR it can be reported to a member of the Executive Committee directly.

The Executive Committee at MAP is composed currently of:

Abhishek Poddar, Founder (apoddarmap@gmail.com)

Kamini Sawhney, Director (kamini.sawhney@map-india.org)

Nathaniel Gaskell, Director of MAP Academy (nathaniel.gaskell@map-india.org)

6.4 Reporting Process:

6.4.1. The DSR will require a written account from staff, volunteer or line manager and a summary of any available additional information including the names and addresses of any potential witnesses using the Safeguarding Incident Report Form (see Annexure 3). The physical document should be signed and dated, and any concern raised online should include a line of acknowledgement in lieu of a signature from the sender as follows: “I (inert name), certify that the above facts are true to the best of my knowledge and belief. (Insert date)”

6.4.2. If a child or adult is at immediate risk of harm, intervene or act immediately. Else, notify the DSR within one working day. If the DSR is unavailable for any reason, contact someone from the Executive Committee.

6.4.3 It is acknowledged that feelings generated by the discovery that a member of staff or volunteer is, or may be abusing a child or vulnerable adult, will raise concerns among other staff or volunteers, including the difficulties inherent in reporting such matters. However, it is important that any concerns for the welfare of a child or vulnerable adult should be reported and acted upon immediately.

6.4.4. MAP will fully support and protect any member of staff or volunteer who, in good faith, reports their concern that a colleague is, or may be abusing a child or vulnerable adult. No penalisation will be incurred for the raising of a complaint.

MAP, in accordance with the law of the land, will take appropriate action to protect any at-risk children/adults in question from further harm and others in the organisation during and following an incident or allegation. The relevant contact details for child protection services, local social services department, police, emergency medical help and help lines will also be readily available and easily accessible.

7.1. Recording of Safeguarding allegations:

Any allegations should be recorded on the Safeguarding Reporting Form (See Annexure 3). The form can be completed by the person reporting the concern, the line manager or the designated person. However, it is the DSR’s responsibility to ensure it has been completed and the DSR will make any required referrals and consultations post assessment, keeping confidentiality in mind.

• To be as helpful as possible the information should include:
• The nature of the allegation or concern
• A description of any injuries
• The individual’s account, if they can provide one, of what has happened and how any injuries occurred
• Any times, dates, or other relevant information (However, do not delay reporting the matter by trying to obtain more information)
• A clear distinction between what is fact, opinion, or hearsay

Access to all safeguarding concern records (physical and electronic) will be strictly controlled and limited to people in named roles who either need to know about the information in those records and/or who manage the records/files. Physical records will be maintained for a maximum of 10 years. Electronic records will be maintained for a maximum of 25 years.

7.2. Ramifications of Misconduct

MAP has a zero-tolerance policy of child abuse. We will immediately suspend the services of any consultant, employee, adviser, trustee, board member, intern or volunteer in situations where there are concerns about their behaviour towards children and vulnerable adults, pending the outcome of an investigation. MAP reserves the right to take any disciplinary action against any of the above who have been proven guilty in an investigation, which may include reporting the incident to the police.

7.2.1. The fact that a member of staff tenders their resignation or ceases to provide their services will not prevent an allegation/concern from being followed up in accordance with these procedures and a conclusion reached.

7.2.2. There may be circumstances where allegations are about poor practice rather than child abuse but, where there is any doubt, the DSR will seek advice from the Trustees on the need for a disciplinary enquiry.

7.2.3. Investigations will be dealt with quickly, fairly and impartially. The concerned individual should be informed about the allegation or concern as soon as possible.

7.2.4. Every effort will be made to ensure that confidentiality is maintained for all concerned and to protect the integrity of the investigation process.

MAP recognises the opportunities and challenges technology brings to those working with children and adults. We advocate applying the same principles, expectations and standards for interacting and communicating with children and adults online as in other areas of practice, maintaining personal and professional boundaries in their communications and contacts with children, their families and adults.

8.1. MAP expects all staff to adhere to the following at all times:

• When communicating with children and vulnerable adults online, observe the same rules of behaviour as if speaking with them in person; that is by being polite, respectful, not swearing or saying anything (using the written word, images or icons) that could be regarded as sexual innuendo, bullying or discrimination.
• Always maintain professionalism in your communications online and on mobile devices.
• MAP equipment (including computers, laptops, mobile phones, tablets, notebooks, etc) must not be used to view, download, create or share (with colleagues or children) illegal content including abusive images of children.
• Contact with children online should only be with the knowledge and approval of your line manager and strictly for MAP work purposes only. The DSR should additionally be made aware of any role or project that includes contact with children via MAP online channels.
• Refrain from communicating with children via any personal social networking sites (such as Facebook, Instagram and Twitter), ask to become an online friend/contact of a child or add/allow a child to join their contacts/friends list on personal social networking profiles.
• Never seek to befriend a child, a vulnerable adult or their family online whom you have met through work for any purpose whatsoever including for the purpose of developing a personal and/or sexual relationship.
• Never encourage or initiate personal communications with children including phone calls, texts, emails or social media exchanges, unless this is part of official MAP business. In such instances, where these communications form part of a role or a project, line managers must be marked on all written communications and kept informed of any additional conversations via email for record.

8.2. If staff identify online concerns – be they about illegal online content or suspicious behaviour by another adult online – then they must follow MAP’s procedures for reporting those concerns. (See sections 6 & 7)

8.3. Care must also be taken to ensure that both adults and children’s confidentiality and privacy is maintained, and that any data collected online is handled and disseminated on a need to know basis only. Individuals must be confident that information held about them by MAP will only be disclosed to others either with their consent or when there is an imperative safeguarding concern or legal duty to do so.

8. 4. The collection and storage of information by MAP online will be in line with GDPR regulations (European General Data Protection Regulation 2018) and MAP’s Privacy Policy.

MAP is committed to facilitating a safe and enjoyable experience for all those who visit the physical museum space, in particular children and vulnerable adults.

9.1 Unaccompanied child: When MAP staff or volunteers identify an unaccompanied child in the gallery space, or at large in the museum, it becomes their responsibility to ask and act accordingly to provide for the safety of the child. This must be reported to the DSR.

9.2 Educational Group Visits: For groups from schools or other organisations visiting for learning/access programmes, MAP staff who are coordinating with the groups will provide prior guidelines to the accompanying teacher/person-in-charge. If the MAP staff identify any concern about a visiting child or vulnerable adult, this must be brought to notice of both DSR of MAP and the person-in-charge at the concerned school/organisation.

9.3 Programmes/Events:

• All programmes and events that may potentially include children or vulnerable adults amongst its audiences, will take their protection into account when being conceptualised.
• When programmes/events are being specially devised for children or vulnerable adults, MAP’s staff will carry out a risk-assessment that includes a review of content, process, requirement of adult supervision, photography, etc.
• In all cases where a safeguarding concern is raised in the risk assessment it should be discussed and managed with the DSR.

9.4 Lost Children/Vulnerable Adults:

The purpose of this procedure is to ensure lost children or vulnerable adults in the museum space are safely reunited with the responsible adult that they were visiting with. For the safety of the child/vulnerable adult, it becomes the staff’s responsibility to ensure that the child/vulnerable adult is reunited with the appropriate adult. Staff should also be sure to document the details of the lost individual and their guardian in the space for records, should they in any way be later needed.

When a lost child/vulnerable adult is found:

• staff must stay with them.
• seek the help of a colleague immediately so that they are not alone with them.
• take down the information of the responsible adult they are visiting with – name, description, as much information as possible. (This can include age, physical description and relationship to the adult in question)
• inform security, the Reception Desk and take them to a meeting room at the offices or the research centre, based on availability.
• inform the DSR; and if for some reason they cannot be reached inform either a line manager or the director.
• if a name is provided, the adult’s name may be announced upon the PA system with a request to approach the Reception Desk. The child/vulnerable adult’s name must not be announced.
• if a vulnerable adult appears confused and do not know who and/or where they are staff can ask the person if they can check their bag/coat pockets for identification as long as two members of staff are present at all times.
• security staff will conduct a physical search and use the CCTV system to find the accompanying adult, going by the description provided.
• If no responsible adult comes forward or there are doubts regarding the identity of the adult claiming the child or at-risk adult, the same must be communicated to the DSR.

When an adult reports a lost child/vulnerable adult, MAP staff will:

• take the full name and description of the missing child/vulnerable adult, as well as details as to when they were last seen.
• inform the security supervisor who ensures that security at the gate and CCTV stations are immediately alerted.
• direct the adult to wait at the Reception Desk.
• take the help of the security team to physically search the premises while a CCTV survey is simultaneously undertaken.
• if the child or vulnerable adult is not found with 30 minutes, the incident must be immediately reported to the DSR. And if for some reason they cannot be reached, either a line manager or the director without fail.

As part of MAP’s vision towards building a 360° inclusive space for art, dialogue and conversation, MAP’s programming will also include proactive outreach towards young and adult audiences with disabilities. An emphasis on ensuring their rights are equally protected, forms part of MAP’s Safeguarding Policy.

Need for a special annexure:

Disabled children and adults are particularly vulnerable to abuse.

• They are dependent on other people for their care.
• They sometimes don’t understand that they are being abused.
• They may not have the opportunity to tell people what is happening.
• Those facing difficulties with communication may be unable to share what is happening to them.

Special measures:

In light of the particular contexts of vulnerable children and adults, and the greater risk of abuse, concerns need to be taken seriously and organisations need to be proactive to prevent abuse from taking place. Practical steps include:

1. Emphasising non-discrimination
2. Actively listening to the views of vulnerable children and adults
3. Providing reasonable accommodations for access and engagement wherever and whenever possible
4. Including disability issues in different programmes and within the broader context of the museum environment Annexure 2

MAP upholds the principle that the welfare of our visitors is paramount and that all individuals whatever their age, disability, race, ethnicity, religion or belief, sex, gender identity or gender expression, sexual orientation, marriage or civil partnership, or any other equality characteristic have the right to protection from abuse.

This document outlines the behaviour expected of all MAP employees in any capacity, its trustees, board, patrons, volunteers, researchers, interns, and freelancers/contractors in respect of their work and contact with children and adults.

This guidance will not only help to protect children and adults, but will also help all MAP staff and volunteers to identify any practices which could be mistakenly interpreted and perhaps lead to false allegations of abuse being made.

Remember that safeguarding is about keeping staff safe as well as children and other adults. Never act in a way that could be misconstrued or put yourself in a potentially vulnerable position. If in doubt, always consider how an action or activity may be perceived as opposed to how it is intended.

You should:

• Respect the rights, dignity and worth of each and every person and treat each equally within the context of the museum.
• Place the well-being and safety of each visitor above all other considerations.
• Work with children and vulnerable adults in an open and transparent manner.
• Develop an appropriate working relationship with each visitor based on mutual trust and respect. Ensure that the activities you direct or advocate are appropriate for the age, maturity, experience and ability of the child or vulnerable adult.
• Watch your own language and tone of voice. Ensure all communications with and about children and vulnerable visitors are appropriate in their tone. Attitudes and language all require care and thought. The use of swear words in the presence of children, even if not directed at them, is never appropriate.
• Approach any visitor apparently in distress and ask if you can help.
• Communicate the details of any lost children or vulnerable adults to the appropriate central point. Keep any lost children in a public area where they can clearly be seen.
• Ensure that whenever possible there is more than one adult present during activities with children, young people and vulnerable adults. The adult present may be a colleague, a teacher, parent or caregiver. Avoid unobserved situations of one to one contact with a child or vulnerable adults, or at least try to restrict it for short periods of time and then only when absolutely necessary, e.g. if a teacher takes another child to the toilet.
• If known in advance, seek a parent’s permission if a child or young person is to be seen on their own. Another adult must be nearby and the child must know this.
• Respond warmly to a child who needs comforting but make sure there are other adults around.
• Administer any necessary First Aid with more than one adult present except in the rare situation of serious injury where any delay in providing urgent first-aid pending the arrival of medical aid would be harmful to the child or vulnerable adult.
• Support colleagues in times of need, and be prepared to call out any suspicious activity by other unknown persons.
• Ensure that the focus of your relationship with a child you have met through work is always on work. The aim should never be, or become, to develop the relationship into a long-term friendship.
• Ensure that dangerous and unacceptable behaviour by a child or adult is handled appropriately.
• Ensure that children and young people know who they can talk to if they need to speak to someone. Display the Child Line telephone number in a prominent place where children & young people can see it. Child Line Number: 1098
• Be mindful of keeping yourself safe. Never act in a way where your behaviour can be misconstrued or misinterpreted to put you in a vulnerable spot yourself.

You should not:

• Use physical punishment to discipline children.
• Invade a child or vulnerable adult’s privacy whilst washing or toileting.
• Be sexually suggestive about or to a child or vulnerable adult, even in jest.
• Scapegoat, ridicule or reject any child, young person or group.
• Show favouritism to any one child, young person or group.
• Use words that discriminate the children based on caste, community, gender, social and economic backgrounds.
• Allow a child or young person to involve you in excessive attention seeking that is overtly physical or sexual in nature.
• Allow or engage in inappropriate touching of any kind.
• Permit abusive peer activities e.g. initiation ceremonies, ridiculing or bullying.
• Allow unknown adults access to children. Any young audiences or vulnerable adults attending a scheduled programme should be released only into the care of proper guardians/carers.
• Restrain a child, young person or vulnerable adult physically except in exceptional circumstances (e.g. to prevent injury, damage to property or the collections or to prevent theft). Even then, be careful to use only the minimum restraint necessary. All such incidents should be recorded.
• Use foul or abusive language with any visitor nor engage in physical abuse or assault of any visitor. Never act in a way which may be perceived as threatening or intrusive; ask before you act.
• Do things of a personal nature for children or vulnerable adults that they can do for themselves or that a parent/guardian/caretaker can do for them
• Accompany a child or vulnerable adult to the toilet, or be involved in any required dressing or undressing (should that be part of any engagements).
• Give out or solicit personal information including email, social network account details and mobile phone numbers to/from any child or young person outside of existing MAP protocols or a work context, as part of personal requests or to develop personal relationships. When personal information is shared within a work context, please ensure that your line manager is made aware of the same.
• Give out information regarding children and at-risk adults.
• Send out any illegal/inappropriate content in any form of words, images or video to children via written, mobile phone or email.

All members of MAP staff and its volunteers will be expected to report any breaches of this code by any others working for or on behalf of MAP by following the Safeguarding procedures outline in Section 6 & 7 of the MAP’s Safeguarding Policy.

Photography & Film Making: Consent & Data Protection

MAP is committed to ensuring a transparent system of data collection and use, including any media related content.Consent must be obtained for all photographs, images, recordings or filming of children and vulnerable adults. The first principle is that anyone should be able to say no to having their photograph taken or to being filmed.

• Consent must be obtained for all photographs, images, recordings or filming of children and vulnerable adults. The first principle is that anyone should be able to say no to having their photograph taken or to being filmed.
• Consent can be obtained through the use of signage, the clear provision of information in marketing materials stating that filming, recording or photography will be taking place, or written forms.

1.  Written consent is preferred – ensuring that consent is knowingly and freely given and the uses that MAP will make of the images must also be made clear to the individual.
2. However, where it is not possible to obtain consent – perhaps due to the numbers of people involved – legitimate interests may provide an alternative lawful basis for taking photographs or filming an event. The individuals must be properly informed of the activity by having clear signage in place, explaining that photography and/or filming will be taking place. This could be backed up by clear information on an event invitation, or information on the web page relating to that event.

• Written consent must be obtained for the use of images of children under 16 or vulnerable people.

1. Where a child is under 16 consent can only be given by the child’s parent or an acceptable stand-in guardian (such as accompanying carer, teacher, head of the school, etc). If a young person is 16 or 17 and deemed able to understand the concept of consent they can give consent themselves.
2. For vulnerable groups, do not presume that the person lacks the capacity to give consent. It is good practice to obtain the person’s consent and ask the person’s carer or legal guardian to countersign the consent form.

• When using photographs and/or film, a child or vulnerable person’s last name should not be used, and any identifiable private details must not be shared.
• Wherever possible, it is ideal for MAP’s digital team to carry out the photography, using MAP resources and devices. However, there might be situations where this might not be possible, exceptions might include:

1. programmes in partner or participating institutions
2. external partners/contractors who might wish to take photographs or film engagements
3. lack of availability from someone from the MAP digital team, leading to facilitators (staff or volunteers) taking photographs or filming using personal devices

In such situations, any external contractors/freelancers/facilitators must be made aware of MAP’s Safeguarding policy and be willing to share the material for MAP’s records and review. Any internal MAP staff and volunteers will transfer all data to MAP storage and delete the same from their personal devices. MAP staff and volunteers will also comply with any additional safeguarding procedures of the institution or schools they might be conducting programmes at, including the wearing of tags, providing ID, or refraining from taking images/film without prior intimation.

• MAP staff or volunteers will not share images of children and vulnerable adults (when their faces are visible or identifiable) outside of a work context, on their personal social media accounts or within personal networks.
• Data storage: Images or video recordings of children and vulnerable adults must be kept securely, with restricted access to people based on need.