Mtoto Newz International
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Main office: Ngumo Highview Phase One House No.02
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Child Protection Policy


Mtoto News is a digital platform for news, information and resources on children; Child Participation; Data informed solutions. We are leveraging on technology to achieve the goal by making relevant, accurate and timely information on children accessible.

Our Goal
Our aim is to make significant positive difference in the lives of children by increasing their visibility in political, social, development and corporate discourse.

Our Objectives

  1. To report in the Best Interest of the Child.
  2. To provide a platform for child participation.
  3. To provide a platform where child sector practitioners can engage and collaborate.

Our Values

  1. Child participation
  2. Best Interest of the child
  3. Transparency
  4. Quality
  5. Objectivity
  6. Evidence bases
  7. Do no harm

As an online child focused platform, Mtoto News recognises that we have a responsibility to the children to tell their stories in a responsible and ethical manner. The child’s best interest should always be our primary consideration to ensure that the children taking part in its activities either online or offline are kept safe. This policy specifies how we will provide a safe environment and protect children who come into contact with Mtoto Newz International
directly or indirectly. This policy applies to all individuals linked to Mtoto News, staff, volunteers, interns, contributors and suppliers. This policy is based on the United Nations Convention on the Rights of the Child (1989), that says that every child has:

  • The right to a childhood including protection from all forms of violence (Article 6, 19, 34, 36) The right to have their best interests at the heart of all we do (Article 3)
  • The right to be educated (Article 28, 29, 32) The right to be healthy (Article 6, 31) The right to be treated fairly (Article 4)
  • The right to privacy (Article 16)
  • The right to be heard including considering children's views (Article 12, 13, 14, 15, 23)
  • Access to information from the media in a form they can understand (Article 13, 17)

Definition of terms
Child– any individual under age 18, regardless of whether the national age of majority is younger

Child abuse– includes 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.

Child safeguarding– actions taken by the company to prevent physical, sexual and emotional abuse and maltreatment perpetrated by employees or other persons whom the company is responsible for, including contractors, business partners, visitors to premises and volunteers. Safeguarding includes proactive measures to keep all children who come into contact with a company employee or representative safe from harm as a result of that contact.

Child protection– actions taken to address a specific concern that a particular child is at risk of significant harm due to his or her contact with corporate actors, business partners, products or services. 

Physical abuse,including a company employee hitting a child while at work as a means of control or punishment. This could include any employee in direct contact with a child such as security personnel or a restaurant or amusement park employee. 

Sexual abuse, including sexual activity with a child below 18 years, irrespective of local country definitions of when a child reaches adulthood. This could include an employee soliciting children for sex or a company employee downloading child sexual abuse images on their computer. 

Commercial exploitation, including employees engaging in commercial sexual exploitation of children, for example a hotel employee facilitating sexual abuse by hotel guests. Commercial exploitation may also be indirect, for example in a situation where a company is using children as unpaid promoters of sharable and viral commercial content. 

Online abuse,including grooming or online bullying, exposure to inappropriate content or contact through for example online chatrooms or video games, or inadequate data protection.

Emotional abuse or ill-treatment, including repeatedly conveying to a child that he or she is worthless or inadequate, such as an employee making hurtful or discriminatory statements to a child. Neglect, which includes inadequate care or supervision, such as an airline steward disregarding his or her duties to care for children travelling alone, or not giving access to appropriate medical care or treatment to a child when it is needed.


Policy Statement
It is our duty to take care of children in our online and offline spaces , we must ensure that there is no risk of harm to children either participating in activities or as the subject of activities online or offline.

Code of Behaviour
Following this code of conduct will allow staff ,volunteers, interns and contributors working with children to avoid most situations in which they may be compromised. You should:

  • Treat all children and young people equally.
  • Listen to and respect children.
  • Respect the child’s privacy.
  • Involve children and young people in decision making (as appropriate).
  • Provide encouragement, support and praise (regardless of ability).
  • Use appropriate language.
  • Have fun and encourage a positive atmosphere.
  • Offer constructive criticism when needed.
  • Treat all children and young people as individuals.
  • Respect a child’s or young person’s personal space.
  • Discuss boundaries on behaviour and related sanctions, as appropriate, with children and young people and their primary carers.
  • Encourage feedback from group.
  • Use age appropriate teaching aids and materials.
  • Lead by example.
  • Be cognisant of a child’s or young person’s limitations, due to a medical condition for example,Create an atmosphere of trust, Respect differences of ability, culture, religion, race and sexual orientation.

Good Practice

  • Be inclusive of children and young children with special needs.
  • Plan and be sufficiently prepared both mentally and physically.
  • Report any concerns to the Designated Person.
  • Observe appropriate dress and behaviour.
  • Report any incidents and accidents.
  • Update and review policies and procedures on a regular basis.
  • Ensure proper supervision based on adequate ratios according to age, abilities and activities involved.
  • Don’t be passive in relation to concerns i.e. don’t ‘do’ nothing.
  • Don’t let a problem get out of control.
  • Avoid being alone with children e.g. taking them to the toilet.
  • Avoid taking a session on your own. If this is not possible then it should be in an open environment with the full knowledge and consent of primary carers.
  • Maintain awareness around language and comments made. If you think that something you said may have caused offence or upset, then try to address it in a sensitive manner.
  • Set your privacy settings for any social networking site to ensure only the people you want have sight/ access to the contents. Keep these updated. The default settings for most social networking sites are set to open access where anyone can see everything.
  • Ensure your mobile phone (any technological equipment) is password/ PIN protected. This will ensure that other people can’t use your equipment and get you into trouble.
  • Consider having separate personal and professional online identities/ accounts if you wish to have online contact with service users i.e. children and young people, their families and other professionals. Ensure that your manager is aware of your professional online persona.
  • Make sure that all information about you that is publicly available is accurate and appropriate – think particularly about whether photographs/ stories that you may have posted in your personal life are appropriate for a person with a professional life and a reputation to lose. If you don’t want it to be public, don’t put it online.
  • Remember that online conversations may be referred to as ‘chat’ but they are written documents and should always be treated as such. Be mindful about how you present yourself when you are publishing information about yourself or having ‘conversations’ on-line.
  • Always be aware that technology is constantly upgrading and improving. You may have access to websites via a work-provided smartphone that are blocked by your computer. Mobile phones come with locator software. Cameras can be a feature of games consoles. When you receive any new equipment (personal or private) make sure that you know what features it has as standard and take appropriate action to disable/ protect

Inappropriate Behaviour

  • Do not allow or engage in inappropriate touching of any form.
  • Do not use actions or language that may cause a child, young person or vulnerable adult to lose self-esteem or confidence.
  • Avoid spending excessive amounts of time alone with children.
  • Do not hit or physically chastise children.
  • Do not socialise inappropriately with children.
  • Do not use your personal social network profile to communicate with or share images or take images of children/ young people and their parents/ carers Either using your personal or organisational equipment
  • Do not accept children and young people/ parents and carers as friends on your personal page.
  • Do not use your personal email account to communicate with children/ young people, their parents/ carers and adults who may be at risk, Either via mobile phones or web based software.
  • Do not use your personal web-cam to communicate with children/ young people, their parents/ carers or to make a record of activity without permission

Risk Assessment
When planning to work with children, a risk assessment must be carried out which consider all aspects of how a child may suffer harm, including physical or emotional or sexual abuse, neglect, and online grooming. How the child will be safeguarded such as, child protection training for production and Talent, obtaining appropriate consent, child performance licences, tutoring and working hours, chaperones, a safe environment and transport, use of social media for the child, production and Talent and protection from inappropriate content (this list is not exhaustive).

Health and Safety

  • Don’t leave children unattended or unsupervised.
  • Manage any dangerous materials.
  • Provide a safe environment.

Informed consent from the child, parent, legal guardian or organisation with parental responsibility for the child must always be obtained in advance of working with children in any capacity and documented evidence of consent must always be kept. Children aged 16 and 17 year olds can sign their own consent form if the project is not contentious.

Online and Social Media
When engaging with children, it is particularly important to consider the role of social media and the internet. The use of social media and the internet is an important part of life for many children and you must make sure that children understand the impact of appearing on Mtoto Newz Social media platforms, and what the implications can be for anyone active on social media. Children under 13 years of age are not permitted to have an account by many social media services, but research suggests that this is not strictly adhered to and some 10-12 year olds will have their own account. Therefore productions should make sure that
the children (and their parents) know how to keep themselves safe while online. Mtoto News has zero tolerance to any form of abuse of children including the inappropriate use of any computers, mobile phones, video/digital cameras or other electronic devices to commit online grooming, possess, distribute or create child abuse images. Disciplinary action 
which is proportionate and justifiable will be taken if anyone is found to be in breach of the above.

Data Protection
Refer to the Our Data Protection Policy


Guidelines for interviewing children

  1. Do no harm to any child. Avoid questions, attitudes or comments that are judgmental or insensitive to cultural values, that place a child in danger or expose a child to humiliation, or that reactivate a child’s pain and grief from traumatic events.
  2. Ensure that the child and guardian know they are talking with a reporter. Explain the purpose of the interview and its intended use.
  3. Assess any potential risks to the child or children, including: Reprisals, Stigmatization, rejection or attacks by family or communities, Legal prosecution, Misguided or malicious attempts by outsiders to “rescue” the child from a difficult situation.
  4. No staging: Do not ask children to tell a story or take an action that is not part of their own history. Do not ask children to promote products contributed by corporate supporters.
  5. Obtain permission from the child and her or his guardian for all interviews, videotaping and, when possible, documentary photographs. When possible and appropriate, this permission should be in writing. Permission must be obtained in circumstances that ensure the child and guardian are not coerced in any way and understand they are part of a story that might be disseminated locally and globally. This is usually ensured only if the

Guidelines for reporting on children

  1. Do not further stigmatize any child. Avoid categorizations or descriptions that expose children to negative reprisals – including additional physical or psychological harm, or to lifelong abuse, discrimination or rejection by their local communities.
  2. Always provide an accurate context for the child’s story or image.
  3. Do not give any information that could lead to a child being identified or traced. For example, if the child is from a small village, it might be easy for the child to be identified by another villager. Provide the region or district where the child lives, rather than naming the village. Do not name the school the child attends. Use first names only.
  4. Always change the name and obscure the visual identity of any child who is identified as:  A victim of sexual abuse or exploitation, A perpetrator of physical or sexual abuse, Charged or convicted of a crime, A current or former child combatant, HIV positive, living with AIDS or has died from AIDS, unless the child, a parent or a guardian gives fully informed consent, Or any child who does not wish to be named and identifiable, or whose parent/guardian does not wish the child to be named and identified.
  5. Always change the name and consider obscuring the visual identity of a child identified as: abandoned or separated from parents/guardians. In the case of orphans, please be sure to mention when they are in the care of relatives or guardians.
  6. Do not change a child’s identity when it is important to the child and the story. In certain cases, using a child's identity – name and/or recognizable image – is in the child’s best interests. However, when a child's identity is used, he/she must still be protected against harm and supported through any stigmatization or reprisals. Some examples of these special cases are: a) When a child initiates contact with the reporter, wanting to exercise their right to freedom of expression and to have their opinion heard b) When a child is part of a sustained program of activism or social mobilization and wants to be so identified. c) When a child is engaged in a psychosocial program and is claiming their name and identity as a part of their healthy development.​ d) In the case of a child’s demise and the parent/guardian wants the child’s name to be used in order to raise awareness of a problem or change policy.
  7. When changing a child’s name to protect their identity, ask them at the time of the interview what name they would prefer to be known as. If the child does not state a preference for a certain name, work with someone from the community to select a name that is culturally appropriate given the child’s gender, ethnicity, religious background, etc. Whenever possible, choose a name that is short and easily pronounced/understood by an audience that may be unfamiliar with the child’s culture.
  8. Confirm the accuracy of what the child has to say, either with other children or an adult, preferably with both.
  9. When in doubt about whether a child is at risk, report on the general situation for children rather than on an individual child, no matter how newsworthy the story.
  10. Do not invent a tragic future the child may face “if we don’t help”. If the child’s image or story are to be used in this way, the child and parent or guardian must see the creative treatment and give additional consent.

Guidelines for use of videos and photos including children
Quality Indicator Definitions

  1. Clarity – Please take clear photos and videos, test sound quality and write conversationally while remaining grammatically correct.
  2. Composition – Videos, stories and images should convey a story with a clear beginning, middle and end or imagery that conveys emotion or action.
  3. Context – Include setting or background for the story or reference that references Mtoto Newz International’s work. Describe the problem we are trying to solve or the solution to a problem. For example, feeding a hungry child or distributing books at a library.
  4. Compelling – Take pictures and videos that would make you want to stop what you are doing and take action. Compliance Indicators Protection:

Coverage (No private parts, ever. Very strict discretion around shirtless children to ensure asset does not serve as fodder for pedophiles.)
Dignity (Is the subject portrayed as a helpless victim, or as a brave survivor who is contributing to his/her own success?)
Care (Children in grave health or dangerous situations are not to be depicted without care – e.g. a baby alone and crying; under attack, severe acute malnutrition, fresh wounds or extreme physical trauma)
Released (Releases are required, some verbal in case of emergencies. Releases include informing the subject of the intended use of the photo and protecting the identity of high-risk children such as those in conflict settings, exploited workers, former slaves and those affected by deadly infectious diseases including HIV/ AIDS and Ebola.)

Reporting Procedures
The Child Protection Officer has been designated as the person to contact if there is an issue or concern about any aspect of a child’s or young person’s safety and welfare. It is the responsibility of this person to support and advice about policy and procedures in relation to child protection and to ensure procedures are followed.

Reasonable Grounds for Concern

  • Specific Indication from the child or young person that s/he has been abused
  • An account by a person who saw the child/young person being abused
  • Evidence, such as an injury or behaviour, which is consistent with abuse and unlikely to be caused another way.
  • An injury or behaviour which is consistent both with abuse and with an innocent explanation but where there are corroborative indicators supporting the concern that it may be a case of abuse
  • Consistent indication, over a period of time, that a child is suffering from emotional or physical neglect.
  • If you have a child protection concern online or offline, whether you have been told something by a child or by another person, whether you have seen or heard something that has made you uncomfortable, or whether you have become aware of a breach of policy you must share it. It doesn’t matter how you’ve become aware or how a child has come into contact with the Mtoto Newz International.
  • If you have concerns about the behaviour of an adult towards a child, be they a manager, colleague, friend, chaperone etc., you must speak to your Working with the Child Protection and Safeguarding officer, or you can email your concern to the Childm Protection Inbox
  • If you have any online safeguarding concerns, whether related to online grooming or child abuse images these must be referred to the Head of Safeguarding & Child Protection (Childrens) immediately

Procedure for dealing with a disclosure

  • Stay calm and listen to the child/young person, allow him/her enough time to say what s/he needs to say.
  • Don’t use leading questions or prompt details
  • Reassure the child but do not promise to keep anything secret.
  • Don’t make the child repeat the details unnecessarily.
  • Explain to the child what will happen next

Reporting Procedures

  • Actions and outcomes should be noted
  • Record all details, including the date, time and people involved in the concern or disclosure and the facts in the incident book. Information recorded should be factual. Any opinions should be supported by facts.
  • Inform the designated person or his/her deputy, if unavailable.
  • The most appropriate person should discuss the concern or consult with primary carers. Parents, carers or responsible adults should be made aware of a report to DCS unless it is likely to put the child at further risk.
  • The Designated Person may contact the Department of Children Services for an informal consultation prior to making a report.
  • Information will be shared on a strictly 'need to know' basis.

Confidentiality Statement
We are committed to ensuring people's’ rights to confidentiality. However, in relation to child protection and welfare we undertake that

  • Information will only be forwarded on a ‘need to know’ basis in order to safeguard the child/young person
  • Giving such information to others for the protection of a child or young person is not a breach of confidentiality.
  • We cannot guarantee total confidentiality where the best interests of the child are at risk.
  • Primary carers, children and young person have a right to know if personal information is being shared and/or a report is being made to the authorities, unless doing so could put the child at further risk.
  • Images of a child will not be used for any reason without the consent of the parent/carer ( however, we cannot guarantee that cameras/videos will not be used at public performances)
  • Procedures will be put in place in relation to the use of images of children.
  • Procedures will also be put in place for the recording and storing of information in line with our confidentiality policy.

Accidents Procedure

  • Children must be advised of risks of dangerous materials.
  • The location of incident/accident books must be made known to staff.
  • Committee members trained in First Aid:

Disciplinary Action
A report should be made immediately, within 24 hours, to allow for early intervention and a prompt investigation. This verbal report should be followed with a written statement within a further 48 hour. Mtoto News will begin an internal investigation which will be within 48 hours of the reporting and where appropriate file a complaint with the relevant Police. The rights and welfare of the child is of prime importance to Mtoto News and, therefore any investigation will aim to respect the privacy and safety of the child and to make the investigation as child friendly as possible and to the best interest of the child.
Response to Internal Investigation Findings
1. At the conclusion of the investigation, the associate, the child and/or his or her family as appropriate should be informed of concerns or allegation, the results of the investigation and what corrective action, if any, will be taken.
2. In the event an allegation is proven to be untrue, or even fabricated, appropriate steps will be taken for follow up with the person who has been accused, the child, and the person who reported the incident. Efforts will be made to provide assistance to an associate accused of abuse with children, including counseling or other appropriate forms of support.
3. If abuse is proven by the investigation, every effort will be made to assist the child in coping with any physical or emotional trauma he or she may be experiencing. This may include medical treatment, psychological counseling or any other form of assistance deemed necessary and appropriate.
4. If the investigation concludes that child abuse has occurred which is not subject to criminal prosecution, staff will be subject to disciplinary action within Mtoto News prosecution according to national laws, all findings will be reported to the relevant national police authorities and full cooperation afforded them during an external investigation.
5. In the event an associate is discharged for proven child abuse, Mtoto News will disclose such information as requested by police, a prospective employer, etc. Such disclosures will be made in accordance with applicable law.