Child Protection Policy

1. Purpose and commitment

1.1 The Saath Foundation ("Saath Foundation") supports children through registered partner shelter homes (Child Care Institutions, "CCIs") and through families. Saath Foundation does not run a children's home.

1.2 This policy sets out how Saath Foundation keeps children safe in everything it does: sponsorship (Hold a Hand), online teaching (Teach a Child), Meet Your Saathi visits and Saath Milan days, book and clothes drives, stories, photos and data.

1.3 Saath Foundation has zero tolerance for abuse, exploitation or neglect of any child, and for any attempt to hide it.

1.4 This policy follows, and does not replace, the law, including:

• the Protection of Children from Sexual Offences Act, 2012 ("POCSO Act") and the POCSO Rules, 2020;
• the Juvenile Justice (Care and Protection of Children) Act, 2015 ("JJ Act") and its rules;
• the Digital Personal Data Protection Act, 2023 and Rules, 2025;
• the Bharatiya Nyaya Sanhita, 2023, and the Information Technology Act, 2000.

1.5 Where this policy and the law differ, the stricter rule applies.

2. Who this policy applies to

Everyone who acts for Saath Foundation or meets children through Saath Foundation: trustees, staff (paid, contract or part-time), volunteers, interns, consultants, vendors on site, donors and visitors, CSR and corporate representatives, and partner-home staff while taking part in a Saath Foundation activity.

3. Definitions

• Child: anyone under 18.
• Abuse: physical, sexual or emotional abuse, neglect, exploitation (including commercial or online exploitation), and bullying. Sexual abuse includes every offence under the POCSO Act.
• Concern: anything that makes a person worried a child is being, or may be, harmed. It need not be proven.
• Safeguarding Officer: the person named in section 5.

4. Principles

• (a) The child's best interest is the first consideration.
• (b) Every child has an equal right to protection, whatever their gender, caste, religion, disability or background.
• (c) Children are listened to and believed. A child is never blamed.
• (d) Children are shown with dignity: capable and hopeful, never as objects of pity.
• (e) Information about a child is shared only on a need-to-know basis.
• (f) Saath Foundation does not investigate crimes. It reports them and cooperates with the authorities.

5. Roles

5.1 Safeguarding Officer: Akansha Guptaa, safeguarding@thesaathfoundation.com, +91 96258 68882 (9 am to 7 pm). Deputy: Apishek Pandey, who acts whenever the Safeguarding Officer is unavailable or is the subject of a concern.

The Safeguarding Officer:

• receives and records every concern;
• makes reports to the police, Special Juvenile Police Unit ("SJPU"), Child Welfare Committee ("CWC") or cyber-crime portal;
• decides on suspension of any person while a concern is looked into;
• keeps the incident log and safeguarding files;
• approves visit bookings and reviews every visit report;
• runs training and keeps this policy up to date.

5.2 Safeguarding Committee: the Safeguarding Officer, one trustee and Sudesh Kumari (ideally someone independent of Saath Foundation's operations). It is told of every concern the same day, in anonymised form where possible, and never when a member is implicated; that member steps aside. It meets at least every 2 months to review the log.

5.3 Trustees are responsible for making sure this policy is followed and resourced. Anil Kumar Agrawal is the named safeguarding trustee. For the POCSO Act, the Managing Trustee, Pravesh Rana, is the person in charge of Saath Foundation. The Managing Trustee and the Safeguarding Officer each make sure that any offence alleged against Saath Foundation staff or volunteers is reported to the police. A trustee who learns of a concern has the same personal duty to report as everyone else (section 6.1).

5.4 Everyone covered by section 2 must follow this policy and report concerns.

6. Reporting: the law and our process

6.1 What the law requires

• POCSO Act s.19(1). Any person who fears that a sexual offence against a child is likely to be committed, or knows that one has been committed, must inform the SJPU or the local police.
• POCSO Act s.20. Staff of media, studios and photographic facilities who come across sexually exploitative material involving a child must report it to the SJPU or local police.
• POCSO Act s.21. Failing to report under s.19 or s.20 is punishable with up to 6 months' imprisonment or a fine, or both. A person in charge of a company or institution who fails to report an offence committed by a subordinate under their control is punishable with up to 1 year's imprisonment and a fine.
• POCSO Rules, 2020, rule 11. Anyone who receives child sexual abuse material, or information that such material is being stored, shared or transmitted, must report it to the SJPU, the local police or the cyber-crime portal (cybercrime.gov.in).
• POCSO Act s.23 and JJ Act s.74. The identity of a child victim, or a child in need of care and protection, must not be disclosed (see section 10).

The duty in s.19 is personal. Telling Saath Foundation does not remove anyone's own legal duty to tell the police. Saath Foundation's process exists so that the report is made quickly and correctly, and so no one has to do it alone.

6.2 What to do if you have a concern

1. If a child is in immediate danger, call 112. 2. Listen, don't investigate. If a child tells you something, stay calm, listen, and reassure them that telling was right. Do not ask leading questions, promise secrecy, confront anyone, or examine the child. 3. Write it down as soon as you can, in the child's own words: what was said or seen, when, where, who was present. Sign and date it. 4. Tell the Safeguarding Officer at once, and always the same day, through Report a Concern (/en/report-a-concern), by phone or in person. If the concern is about the Safeguarding Officer, tell the Deputy or the safeguarding trustee. For a possible sexual offence, if neither the Safeguarding Officer nor the Deputy can be reached within 2 hours, go to the police or call 112 yourself, and tell the Safeguarding Officer afterwards. 5. Do not tell the person the concern is about, and do not discuss it with anyone else.

6.3 What Saath Foundation does

6.4 Other concerns (physical abuse, neglect, emotional harm, a child at risk at home) are also recorded and escalated the same day. The Safeguarding Officer must report to the CWC or the police, within 24 hours, any child found separated from their family, for example orphaned, abandoned or surrendered (JJ Act s.32), and must report to the police any cognisable offence, for example cruelty to a child (JJ Act s.75), trafficking, child marriage or child labour. For any other concern, the Safeguarding Officer decides whether to report to the police, the CWC or the Child Helpline (1098, or 112), and records the reason for the decision.

6.5 No retaliation. No one who reports a concern in good faith will face any disadvantage. Retaliation is itself a breach of this policy.

6.6 Records. Safeguarding records are kept separately, encrypted, and seen only by the Safeguarding Officer, the Deputy and the Committee. They are kept at least until 7 years after the child concerned turns 18, and never deleted while a concern, legal duty or case is open.

7. Safe recruitment and police verification

7.1 The rule. The POCSO Rules, 2020, rule 3(4), require any institution coming into regular contact with children to ensure police verification and a background check, on a periodic basis, of every staff member, teaching or non-teaching, regular or contractual.

7.2 Volunteers are treated as staff. Saath Foundation applies rule 3(4) to every volunteer who teaches, supervises or otherwise has contact with children, online or in person, whether or not the law strictly requires it.

7.3 Before any contact with a child, every staff member and volunteer must complete:

• (a) a written application and ID check;
• (b) an interview (a video interview for online volunteers);
• (c) two references, at least one from someone who has seen them work (paid or unpaid);
• (d) police verification: a police character or verification certificate from the state police of the place they live, issued within the last 12 months. For people who have lived abroad in the last 5 years, also a police clearance from that country;
• (e) a signed self-declaration that they have never been convicted of, and are not named as an accused in any FIR, charge sheet or pending case for, any offence against a child or a vulnerable adult, or any sexual offence, in India or elsewhere, and have never been dismissed or asked to leave a role with children over a safeguarding concern;
• (f) safeguarding training (section 12) and a pass on the short quiz;
• (g) signing this policy and the relevant code of conduct.

The platform blocks access to children, class links and child data until every step is recorded and approved.

7.4 Renewal. Police verification and the self-declaration are renewed every 12 months. Access lapses automatically if renewal is missed.

7.5 Donors and visitors are screened under the Visit Policy.

8. Code of conduct for staff (and volunteers)

Volunteers also sign the Volunteer Code of Conduct, which adds rules for online teaching.

You must: 1. Treat every child with respect and dignity. Use kind, age-appropriate language. 2. Follow the two-adult rule: never be alone with a child, in person or online, out of sight and hearing of another authorised adult. Keep doors open and rooms visible. 3. Contact children only through Saath Foundation channels and Saath Foundation-issued accounts, and only for Saath Foundation work. 4. Let the child set physical boundaries. Physical contact is limited to what is appropriate, public and started by the child (a handshake, a high-five). 5. Report every concern the same day (section 6). 6. Tell the Safeguarding Officer if a child becomes attached to you in a way that worries you, or if anyone asks you to break these rules. 7. Keep children's information confidential and use it only for Saath Foundation work.

You must not: 1. Hit, shame, threaten or humiliate a child, or use any form of corporal punishment. 2. Do anything of a sexual nature with or in front of a child, including sexual jokes, comments or material. 3. Give children your phone number, email, social-media handle or address, or ask for theirs or their family's. Connect with a child or their family on social media. 4. Take photos or video of a child on a personal device, or share any image of a child outside Saath Foundation's approved process (section 9). 5. Give personal gifts, money or favours to a child or family, or accept them (other than small tokens such as a drawing, which you tell staff about). 6. Take a child anywhere, transport a child, or invite a child to your home. 7. Help a child with toileting, dressing or personal care (other than as trained staff where the role requires it, with a second adult present). 8. Favour one child in ways that could isolate them or create secrecy. Never ask a child to keep a secret. 9. Promote religious or political views to children. 10. Work with children under the influence of alcohol or drugs, or smoke near them. 11. Make children perform, give speeches or be "presented" to donors or visitors.

9. Photos, video, stories and consent

9.1 Consent first. No photo, video, audio or story of a child is taken or used without the documented, verifiable consent of the parent or lawful guardian for that specific use, and the child's own agreement, asked in an age-appropriate way. A child's "no" is respected even if the guardian said yes. For a child in a CCI, Saath Foundation also needs the written consent of the home's person in charge before any public profile, photo, story or visit. Where a parent is known and no order restricts contact with them, the parent's consent is also recorded.

9.2 Only Saath Foundation staff take photos, on Saath Foundation-owned devices, including the one Saath Milan group photo. Staff and volunteers must not photograph children on personal devices. Visitors and donors must not photograph children at all.

9.3 What images may show. Children as capable: learning, making, playing, laughing. Never: children crying, in distress, in poor clothing or undress, or in any pose that could be sexualised. Never: school names, uniforms or badges, house numbers, street or shop signs, landmarks, vehicle plates, or anything that reveals where a child lives or studies.

9.4 Metadata. Every file is stripped of EXIF and location data on upload. Files are stored encrypted and shared only through Saath Foundation's platform.

9.5 Public use. Public profiles use a first name or chosen name, age band and district only. For a child who lives with family, the guardian chooses a real, blurred or illustrated image. For a child in a partner home, the public image is always an illustration. AI-generated images are always labelled as illustrations and never presented as a real child.

9.6 Withdrawal. A guardian or child can withdraw consent at any time. We take the image down within 24 hours from everything Saath Foundation controls.

9.7 Online classes are not recorded unless the guardian has given separate consent. Recordings are never downloadable.

10. Identity protection (JJ Act s.74 and POCSO Act s.23)

10.1 The JJ Act s.74(1) says that no report in any newspaper, magazine, news-sheet, audio-visual media or other form of communication regarding any inquiry, investigation or judicial procedure may disclose the name, address, school or any other particular that may lead to the identification of a child in conflict with law, a child in need of care and protection, or a child victim or witness of a crime, and that no picture of such a child may be published. The Board or the CWC may permit disclosure only for reasons recorded in writing, in the child's best interest. The penalty is up to 6 months' imprisonment, a fine of up to ₹2 lakh, or both. The POCSO Act s.23 similarly protects child victims, and for them only the Special Court can permit disclosure. Saath Foundation applies this standard to every child in a partner home as a matter of policy, whether or not a proceeding is open.

10.2 Saath Foundation treats every child in a partner home as a child in need of care and protection for this purpose. For these children, and for any child known to be involved in a JJ Act or POCSO matter, Saath Foundation:

• (a) publishes no picture from which the child could be recognised. For a child who is, or may be, a victim or witness of a POCSO offence, Saath Foundation never publishes any picture or detail, whatever permission is offered;
• (b) never publishes the child's name beyond an approved first or chosen name, or the child's address, school, partner home or any other identifying detail;
• (c) flags the child's record as "legal-proceedings child" where relevant, which blocks any public profile, story or photo entirely.

10.3 Rupee Trail. Saath Foundation never shows a school's name for a child who lives in a partner home, and never to a Saathi who has met the child at a visit or a Saath Milan. This holds whatever the setting saath.trail.showSchoolName says. The setting is on. A school is named only for a child who lives with their family, only with the guardian's consent, and only to that child's ID-verified Saathis who have accepted the donor terms (Privacy Policy 4.8). Otherwise the Rupee Trail shows "a school in {district}". No school name is ever shown for a child flagged under 10.2(c).

11. Contact between donors and children

11.1 There is no unmediated contact between donors and children.

11.2 Messages from donors to children go through a moderated channel. Staff read each one before it reaches the child.

11.3 In-person meetings happen only under the Visit Policy, only at a venue Saath Foundation hires for that event, with Saath Foundation staff present throughout, and the child's guardian or partner-home caseworker accompanying the child.

11.4 Donors must not approach or contact the child's school, the partner home, the child or the family outside Saath Foundation. A breach leads to suspension and a safeguarding report.

12. Training

12.1 Everyone in section 2 who has contact with children completes Saath Foundation's safeguarding training before first contact, and a refresher every 12 months (POCSO Rules r.3(6)).

12.2 Training covers: this policy; recognising signs of abuse; how to respond to a disclosure; the legal duty to report; online safety; photos and consent; and scenarios.

12.3 Visitors complete the orientation in the Visitor Code of Conduct.

13. Online safety

13.1 Online sessions happen only on the Saath Foundation platform or a Saath Foundation-approved tool, using Saath Foundation-issued accounts, with unique, non-public links and a waiting room.

13.2 A second authorised adult is present in every session, group or not: a Saath Foundation moderator or a partner-home staff member. A parent may be the second adult only in a session for their own child alone. Private messages are disabled. Saath Foundation does not keep class chat; any chat is held by the meeting provider under its settings.

13.3 No analytics, tracking, attention-monitoring or advertising runs on any child-facing page.

13.4 Every session and child-facing page has a one-click Report a Concern button.

14. Partner homes

Saath Foundation works only with Children's Homes, Open Shelters and Fit Facilities, registered or recognised under the JJ Act, that house children in need of care and protection. It never works with Specialised Adoption Agencies, Observation Homes, Special Homes or Places of Safety. Saath Foundation checks each home before and during the partnership (see the Partner Home Due-Diligence Checklist). Saath Foundation expects each home to have its own child protection policy. A concern about a home is reported directly to the police and the CWC, not only to the home.

15. Breaches of this policy

15.1 A breach by staff may lead to disciplinary action up to dismissal. A breach by a volunteer, donor or visitor may lead to suspension or permanent removal.

15.2 Where the law requires, or a child may be at risk, Saath Foundation reports the breach to the police, SJPU or CWC.

15.3 Saath Foundation will not give a misleading reference. Where a concern was substantiated, Saath Foundation may, in good faith, tell an organisation working with children the facts on record.

16. Review

This policy is reviewed every 12 months, after any serious incident, and when the law changes. An independent safeguarding review of Meet Your Saathi and Teach a Child takes place every year.

17. Useful contacts