Policy for the protection of children, women and people in situation of vulnerability (2024)

Applicable to: All Actividades Alternativas’ Staff, Experts, Research Associates and Volunteers.

Reviewed: Annually


Child: Any person under 18 years of age.

Person in a Situation of Vulnerability: Any person in a situation of social inequality, whether for reasons of gender, sex, religion, beliefs, economy… or any other circumstance that causes a situation of social disadvantage or opportunity, in relation to the development of their basic rights.

Women: All women, including transgender women.

Child protection: A range of efforts to prevent and respond to violence, exploitation and abuse against children, including sexual exploitation, trafficking, child labour and harmful traditional practices such as female genital mutilation and child marriage.

CWoVI: Child, woman or vulnerable individual.

Commitments of the association with each group

Children and young people.

Kean ‘Alternative Activities’ guarantees the safety and support of children at all times.

We therefore state the following in accordance with the Convention on the Rights of the Child, which became law in 1990, after being signed and accepted by 20 countries, including Spain.

1) Non-discrimination: all children have the same rights.

2) The best interests of the child: any decision, law, or policy that may affect children must take into account what is in the best interest of the child.

3) The right to life, survival and development: all children have the right to live and develop properly.

4) Participation: children have the right to be consulted on situations that affect them and to have their views taken into account. 

Vulnerable adults

From a generic perspective, a «vulnerable adult person» can be defined as any person who is at least 18 years of age or older, who for reasons of disability, age, illness, the context in which they find themselves or as a consequence of social inequity, is or may be unable to protect themselves from potential harm or exploitation.

As a concretisation of the above, we are aware that each person in a situation of vulnerability has unique characteristics, so we individualise the intervention and adapt to all cases and their realities.


This refers to women in vulnerable situations such as: economic and social distress, abuse, trafficking, forced marriage or any kind of situation that violates human rights, but also extends to women who suffer sexual harassment, harassment at work, wage imbalances or verbal sexual harassment in their daily lives.

Thereby, all women should be free of any type of discrimination, harassment and should be able to participate equally in society as well as to have the same rights as men.



Laws to which this policy of protection for children, women and people in vulnerable situations adheres:


  1. Convention on the Rights of the Child (approved by the General Assembly of the United Nations on 20 November 1989 and entered into force on 2 September 1990).
  2. General Comment No. 5 (2003) of the Committee on the Rights of the Child, General measures of implementation of the Convention on the Rights of the Child (CRC/GC/2003/5).
  3. General Comment No. 8 (2006) of the Committee on the Rights of the Child, The right of the child to protection from corporal punishment and other cruel or degrading forms of punishment (CRC/C/GC/8).
  4. General Comment No. 13 of the Committee on the Rights of the Child (2011): The right of the child to be free from all forms of violence (CRC/C/GC/13).
  5. The most comprehensive convention on women’s rights is the Convention on the Elimination of Discrimination Against Women (CEDAW), which is a United Nations (UN) initiative. It stresses the significance of ensuring that men and women have equal access to political, economic, social, cultural, and civic rights and denounces all forms of discrimination against women. Refer to the Convention on the Elimination of All Forms of Discrimination Against Women (1249 UNTS 13), which was adopted on December 18, 1979, and went into effect on September 3, 1981. Out of the 193 UN Member States, 188 were parties to CEDAW as of May 2014.


  1. Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse (2007)10.


  1. Royal Decree-Law 33/1978 of 16 November 1978 on the age of majority.
  2. Organic Law 8/2015, of 22 July, on the modification of the system for the protection of children and adolescents11.
  3. Law 26/2015, of 28 July, on the modification of the child and adolescent protection system12.
  4. Organic Law 5/2000, of 12 January, regulating the criminal responsibility of minors13.
  5. Law 4/2015, of 27 April, on the Statute of the Victims of Crime14. 11.
  6. Royal Decree 1109/2015, of 11 December, which develops Law 4/2015, of 27 April, on the Statute of the Victim of Crime, and regulates the Offices for Assistance to Victims of Crime15. Institutional initiatives in Spain:
  7. Report on the conclusions of the Subcommission for the study of violence against children in Spain of the Congress of Deputies (2015).

Article 19 of the Convention on the Rights of the Child

  1. States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child.
  2. Such protective measures should include, as appropriate, effective procedures for the establishment of social programmes to provide necessary assistance to the child and those who have the care of the child, as well as for other forms of prevention and for identification, reporting, referral, investigation, treatment and follow-up of instances of child maltreatment described above, and, as appropriate, for judicial involvement.

At Actividades Alternativas we…

  • Provide a Protective environment: A protective environment is a safe space for children’s participation, expression and development. All necessary conditions must be created to make the places where children live and develop safe places where those responsible for their well-being bring together all their capacities to promote, demand and defend their rights. Built on the principle of co-responsibility enshrined in law, everyone in the protective environment must be ready to prevent, detect and report any threat or violation that puts a child’s life, integrity or development at risk. Protecting these children is a task that involves families and educators, but also communities and other actors and institutions. Creating a protective environment for children that helps prevent and respond to violence, abuse and exploitation includes eight essential elements:
  1. strengthening government commitment and capacity to fulfil children’s right to protection.
  2. promoting the sanctioning and enforcement of violence against children.
  3. Counteract harmful attitudes, customs and practices;
  4. Promote frank and open debate on these issues, including the media and civil society partners.
  5. Develop the life skills, knowledge and participation of boys and girls;
  6. Build the capacity of families and communities;
  7. Provide essential prevention, recovery and reintegration services, including basic health, education and protection;
  8. and establish and implement consistent and effective monitoring, reporting and oversight measures.

2 – Fight against all types of violence such as:

Child maltreatment: Although there are various definitions, the most widely agreed definition is that developed by the Childhood Observatory in 2008, which refers to «an action, omission or negligent treatment, not accidental, that deprives a child of his or her rights and well-being, that threatens or interferes with his or her orderly physical, psychological or social development and whose perpetrators may be individuals, institutions or society itself». Child abuse can be exercised either by action or by omission. According to these parameters, four basic modalities of maltreatment are defined:

  • Physical maltreatment (we refer to any non-accidental act that causes physical injury to the child, illness or risk of illness).
  • Neglect (failure to attend to the needs of the child, as well as non-compliance with the duties of guardianship, care and protection, for example: not attending to the child’s state of health, hygiene or nutrition).
  • Abuse and/or emotional neglect (all those actions, generally verbal or attitudinal, which cause or may cause psychological damage to the child, for example: rejection, ignoring, terrorising, domestic violence, not attending to their affective and affectionate needs, socialisation needs, development of positive self-esteem, stimulation…).
  • Sexual abuse, which includes both physical and non-physical behaviour. Among the former, and as an example of conduct of Sexual Abuse with physical contact without penetration, it is worth highlighting the touching of genitals (one of the most frequent behaviours), together with rape, incest or prostitution of children and adolescents. With regard to conduct without physical contact, examples include child pornography or exhibitionism in front of children. In relation to Sexual Abuse, it is also considered within the spectrum of maltreatment not to attend adequately to the child in the process of disclosure of the abuse (showing disbelief, not protecting the child from the aggressor, ignoring the situation, not attending to the child’s demand for help or not providing the necessary support).

All these aspects are extensive to the rest of the modalities of maltreatment.

On the other hand, it must be taken into account that maltreatment can take place both in the prenatal phase, causing harm to the foetus (through, for example, toxic habits of the parents, alcoholism, drug addiction, lack of medical follow-up and even physical aggression to the foetus or the pregnant mother), and postnatal, within which the modalities described above are included.

Reference should also be made to the modalities of maltreatment depending on the perpetrators, in such a way that we can speak of Family maltreatment (when it is exercised by a member of the same family), Extrafamilial (exercised by someone outside the family) Institutional (when the institutions do not guarantee an adequate attention to the child) Social (when a set of factors of a social / contextual nature come together which prevent guaranteeing the protection and care of the child).

In any case, maltreatment directly and negatively influences the correct and full development of children and causes immediate, medium and long term consequences.

What is meant by «mild or moderate child maltreatment»? The situation is not urgent as there are physical, psychological and/or social indicators of maltreatment that can be addressed educationally in the child’s socio-familial environment. In this way, the child remains in the family and an educational intervention is carried out by the municipal social services.

What do we mean when we talk about «serious maltreatment«?

The situation is urgent:

Existence of physical, psychological and/or social indicators of maltreatment that endanger the integrity and well-being of the minor. The criteria that define the seriousness of the maltreatment are: Frequency and intensity of the indicators and degree of vulnerability of the child.

To assess the vulnerability of the child, the following factors must be evaluated:

  1. chronicity and frequency of the abuse
  2. access of the perpetrator to the child, characteristics and conditions in which the child is.
  3. The relationship between the aggressor and the child.
  4. Whether the child has any type of disability.
  5. The characteristics of the parents or main caregivers and the characteristics of the child’s family environment.
  6. whether help was ever sought, who it was from, when and how it was resolved.

In addition, two parameters must be taken into account to discriminate the urgency of the intervention:

  1. Determine the severity, taking into account the type of injury and the child’s level of vulnerability.
  2. Determine the likelihood that the maltreatment will occur in the future. Determine the likelihood of recurrence of the maltreatment taking into account the chronicity and frequency, the accessibility of the perpetrator to the child, the behavioural characteristics of the child, the type of relationship of the primary caregiver with the child, the characteristics of the parents and the family environment.

Violence against women: Which is defined by the United Nations, in the Declaration of violence against women as “any act of gender-based violence that results in, or is likely to result in, physical, sexual, or mental harm or suffering to women, including threats of such acts, coercion or arbitrary deprivation of liberty, whether occurring in public or in private life”.



Peer violence / bullying / bullying / cyber-bullying

Bullying is a form of peer violence that consists of behaviour carried out by an individual, or a group, that is repeated over time to hurt, harass, threaten, scare, frighten or pick on another person with the intention of causing harm. It is different from other aggressive behaviour because it involves an imbalance of power that leaves the victim unable to defend themselves.   Cyberbullying is a form of bullying that involves the use of mobile phones (texts, calls, video clips), the internet (email, social networks, instant messaging, chat, websites) or other information and communication technologies to deliberately harass, harass, abuse, insult, threaten or intimidate someone. The peculiarity of cyberbullying is that a single aggression that is recorded and uploaded to the internet is considered cyberbullying because of the possibility of innumerable reproduction and its potentially global audience.

Harmful cultural practices: These are forms of violence against children and women that are common in some societies or cultures or traditions and are contrary to respect for children’s rights, such as female genital mutilation, violent initiation rites or forced marriage.



This classification and the consequences determine two clearly differentiated circuits in terms of the institutional pathway for their care and social intervention, which are explained in detail below:

  1. Ordinary pathway or procedure, in situations of mild or moderate risk of maltreatment: Notification is oriented towards the municipal social services, where each case is assessed and the appropriate measures are taken to support the child and the family


  1. Urgent procedure, where specialised attention is required, which must be provided by the Public Entity for the Protection of minors of the Autonomous Community, the lack of protection is assessed and the protection measures foreseen by Law 1/96 are taken.

These two procedures are present in all the Autonomous Communities.



This Policy and its instruments and tools affect all the people who collaborate with the organisation, regardless of their employment relationship, and whether their activity is directly linked to the care of the child or adolescent or not.

All persons (regardless of the nature of their relationship with the organisation) who have direct or indirect, frequent or occasional contact with the CWoVI must be aware of:

  1. The potential situations of vulnerability of the rights and integrity of the CWoVI.
  2. Of the potential harm to these individuals, acquiring the necessary degree of awareness of the problem.
  3. Of their individual obligations and responsibilities both in relation to the CWoVI’s rights and integrity.
  4. Of the potential for harm to the CWoVI. Of their individual obligations and responsibilities both in relation to the prevention of harm and to act accordingly.
  5. Of the need to acquire, develop and strengthen the attitudes, knowledge and competences necessary for all of these. Awareness of harm and risk → Awareness of the issues Awareness of the obligation to: Prevent. Act. → Awareness of the need to develop, acquire and strengthen: Attitudes.  Knowledge.  Competences.
  6. For this purpose, the following networks formed by all key actors are defined:

Internal network

Board of Directors.

Project coordinators.

Workers and professionals.

Administration and services staff.

Technical staff. 



Members of the organisation.

Participants:  Children and Adolescents.

People in vulnerable situations.


External network

Collaborators (continuous and occasional).


Contractors / subcontractors.


Research staff.

Donors and companies.

Financial partners.

Technical partners.

Other NGOs and Third Sector entities.

Community of reference of the CWoVI


  1. The Policy is applicable to all staff and collaborators at all times, giving rise to a personal commitment both inside and outside the work or performance context, in such a way that – with regard to CWoVI protection – both the members of the Internal Network and the External Network act as extensions of the Policy of the entity for whose purposes they collaborate.
  2. Accordingly, the Policy also applies to all functional areas of the organisation, so that all of them should be aware of the risks associated with their work and their obligations to protect, detect and report as appropriate.



Approval 1. The validity of this document is subject to its approval by the Board of Directors of Kean Alternative Activities and its ratification by the Ordinary General Assembly. Details of its approval (the body by which it was approved, the date and the planned review date) can be found in the Document Sheet on the first page, and this criterion applies to all documents of the Internal Protection System.

Policy Coordination:

The Child Protection Officer (Internal Referent).


  1. Ensure that protection measures are integrated throughout the entity.
  2. To be an informed agent with whom any member of the Internal and External network can share or comment on issues, doubts or advice needs related to child protection.
  3. To act as an internal coordination point.
  4. To act as an immediate reference point for the Coordination Points for the prevention, detection and notification of violence against minors.


  1. Directly answerable to the Board of Directors of the Association, to whom it will report periodically.
  2. It will have sufficient autonomy, decision-making capacity, support and resources to carry out its function.
  3. The figure of the Deputy Protection Officer shall be designated to guarantee:
  4. Alternative channels of information.
  5. The continuous availability (physical and/or telephonic) of the Security Officer (during shifts, holidays, leave and other contingencies).
  6. Continuous availability of a Security Officer during the working day. To this end, this issue is taken into account in the design of shifts, timetables and work schedules.
  7. The titular and substitute Referent are appointed by the Board of Directors of the Association.



Governing and executive bodies.

Delegate for the Protection of Minors of the Governing Body Designation: The Board of Directors of Kean Alternative Activities will designate this Delegate from among its members, becoming known as the «Delegate for the Protection of minors and people in vulnerable situations», without prejudice to other names and/or functions that his or her position may hold depending on the distribution of responsibilities of the entity.


  1. To be actively involved in all activities related to the protection of minors and people in vulnerable situations in the entity, especially in the Protection Committee.
  2. To attend to the requests made to him/her by the Board of Directors, the Protection Officer and the Protection Committee within the established deadlines.
  3. In the event that, for various reasons, these deadlines cannot be met or the required availability is not available, the Board of Directors shall appoint a temporary substitute or replace him/her.
  4. To liaise with the Board of Directors.
  5. Act as the institutional representative of the institution in the Protection Committee.
  6. To place at the disposal of the Protection Committee its knowledge, experience and network of contacts in accordance with the objectives of the Committee.
  7. Their functions and responsibilities shall include, by default, those of the Directors and Managers listed in the following section.

Executives and Managers / Project Coordinators


  1. To ensure that codes of conduct and protection policy are fulfilled
  2. To ensure that all staff members, whether contracted or volunteers:
  3. Understand the scope and personally sign the security policy and code of conduct and file it in their personnel file.
  4. Receive security training according to their activities and responsibilities within the organisation, both at the start of their work with the organisation and on a regular basis.
  5. Ensure that all members of the External Network:
  6. Are informed of, understand the scope of, and adhere to the Security Policy and Code of Conduct.
  7. In particular, visitors and collaborators (sporadic or not) must be informed, understand the scope and subscribe to the Protection Policy and the Code of Conduct.
  8. In the case of sporadic visitors, their commitment can be managed through the provision of an information document while they are accompanied during their visit.
  9. Ensure that all actions carried out by the organisation:
  10. Are carried out in accordance with the Protection Policy and the Code of Conduct.
  11. Are adapted to the local reality.
  12. Comply with the local regulatory framework.
  13. Ensure respect of the Protection Policy and the Code of Conduct where relevant:
  14. Their translation into the native languages of the beneficiaries and their families.
  15. Its adaptation to the different profiles of beneficiaries and their families.
  16. Its understanding by the different profiles of beneficiaries and their families.
  17. Guarantee with regard to actual and/or potential situations of violence against children and/or people in vulnerable situations:
  18. That both people who make enquiries, notify, who are victims or aggressors receive adequate information, advice, care and support.
  19. That all of them receive the necessary protection, including their anonymity in the case of people who need advice, whether they are notifiers or victims.
  20. The identity of potential perpetrators will be handled as discreetly as possible until proven responsible.

All of the above, without prejudice to the entity taking any action it deems appropriate (such as temporary suspension or change of job, among others).


This policy is the responsibility of the Board of Actividades Alternativas, who also oversees its execution.

In addition to being in charge of communicating with CWoVI, caregivers, and their legal representatives, the Social Services Manager is also in charge of carrying out CPP.

The social service manager is in charge of giving directions and contacts if the person reporting requests information for additional support and consultation.

The mandatory tracking of the Child Protection Policy Implementation Standards and the Actividades Alternativas’ Code of Conduct by all parts of Actividades Alternativas is used to ensure that this policy is being followed.

Sanctions may be imposed for violations of this policy and disregard for these obligations.

  • For Actividades Alternativas’ Staff: disciplinary action that could result in dismissal.
  • Up to and including the termination of all relationships, including contractual and partnership agreements with Actividades Alternativas, for Actividades Alternativas Experts and Research Associates, Volunteers, and External Staff.
  • Where applicable, take the proper legal or other appropriate action.

If there are concerns about the behavior of Actividades Alternativas’ Staff, Experts and Research Associates, volunteers, and External Staff in relation to child protection, or if there has been a violation of the Child Protection Policy, this will be investigated in accordance with this policy by taking into consideration referral to statutory authorities for criminal investigation under the law of the country in which they work; and/or by Actividades Alternativas in accordance with disciplinary procedures. The staff may face disciplinary action as a result of this.