Youth Protection Policy

Version 4 – Last reviewed 26 March 2026

Introduction

At Huddle, we are committed to providing a safe, supportive, and nurturing environment for all with whom we come into contact as part of our mission to ensure quality education for all children and youth in South Africa. Safeguarding at Huddle Education extends to all learners and youth involved in our programmes, services, or platforms. This includes:

Children (under 18 years of age), who require age-appropriate safeguarding.
Youth (18–35 years of age), who may face distinct risks, power imbalances, and vulnerabilities, particularly in digital spaces, work-integrated learning, or mentoring settings.

Safeguarding applies equally across all engagements, whether in-person or virtual.

All children and young people have the right to have their welfare safeguarded and promoted, and they should never experience abuse, exploitation, or neglect of any kind. We believe that safeguarding is everyone’s responsibility, and it is essential that we have effective procedures and policies in place to prevent any form of harm.

While most of our staff have limited interaction with children and youth, a small number of our staff may spend extended time in classrooms with teachers or provide on-site educational sessions. This policy outlines the steps we will take to safeguard children and youth, and how we will ensure that staff, both new and existing, are trained, competent, and held accountable.

Through thorough recruitment, comprehensive training, and strict adherence to safeguarding policies, Huddle aims to protect children and youth from all forms of harm, while ensuring that staff members are responsible, qualified, and trustworthy in their interactions with them.

Youth Participation and Empowerment

Huddle is committed to meaningful youth involvement in the design, review, and improvement of our safeguarding measures.

Youth voices must be included in safeguarding discussions, policy reviews, and programme feedback loops.
Huddle will create safe channels for youth input, including anonymous reporting, and inclusive feedback mechanisms.
Where appropriate, youth will be invited to co-design improvements and changes to interventions, ensuring that safeguarding is not only done for young people, but also with them.

Applicable Legislative Framework

This policy is based on and aligned with the following key legislative frameworks and guidelines:

Children’s Act, 2005 (Act 38 of 2005) – Provides a framework for the protection and promotion of children’s rights and welfare in South Africa.
Constitution of the Republic of South Africa, 1996 – Guarantees the rights to safety, dignity, and freedom for all children and ensures that their best interests are paramount.
Criminal Procedure Act, 1977 (Act 51 of 1977) – Establishes processes for the handling of criminal offences, including those related to child protection.
Criminal Law (Sexual Offences and Related Matters) Amendment Act, 2007 (Act 32 of 2007) – Addresses sexual offences and provides specific protection for children from sexual abuse and exploitation.
Employment of Educators Act, 1998 (Act 76 of 1998) – Regulates the employment of educators, ensuring that they meet appropriate standards of competence, integrity, and professional conduct.
Nonprofit Organisations Act, 1997 (Act 71 of 1997) – Governs the operation of nonprofit organisations in South Africa and provides guidelines for their responsibilities toward beneficiaries, including children.
Protection of Personal Information Act (POPIA), 2013 – Ensures that personal information of learners is handled with respect and in compliance with privacy laws.
South African Schools Act, 1996 (Act 84 of 1996) – Provides the framework for the establishment, governance, and management of schools in South Africa, including the protection of learners.
South African Council for Educators Act, 2000 (Act 31 of 2000) – Establishes the regulatory authority for educators to ensure professionalism and accountability in the teaching profession.
Trespass Act, 1959 (Act 6 of 1959) – Governs unauthorised entry to premises and the protection of public spaces, including educational institutions.
Western Cape Provincial School Education Act, 1997 (Act 12 of 1997) – Provides additional regulations regarding the operation and management of schools in the Western Cape.

Code of Conduct

All staff members are expected to adhere to a strict code of conduct.

All Huddle Education staff and partners working with children and youth MUST:

Treat all children and youth, irrespective of race, sex, language, sexuality, disability, religion, political or other opinions, national, social or indigenous origin, property, birth or other status, with dignity, fairness, and respect, and create a supportive, inclusive, and non-discriminatory environment at all times.
Maintain professional boundaries with children and youth; avoid favouritism, over-familiarity, or any behaviour that may be misinterpreted as inappropriate.
Never meet privately or in isolated settings with a child or youth unless absolutely necessary for your role. Any one-on-one interactions should be in plain sight, such as open spaces, rooms with large windows, or in the presence of others.
Respect children and youth privacy and handle any personal, academic, or medical information with confidentiality and care, sharing only on a strict need-to-know basis in accordance with Huddle’s data protection policies.
Follow a zero-tolerance policy for physical, verbal, emotional, or discriminatory abuse, including harassment or degrading behaviour of any kind.
Dress professionally and appropriately for an educational environment, modelling neatness and suitability in appearance.
Never use or be under the influence of drugs, alcohol, or illegal substances while on duty or around children or youth.
Promote open communication, where learners feel safe and supported to express concerns, ask questions, or raise safeguarding issues.
Educate children and youth on their rights, the organisation’s safeguarding policies, and who they can speak to if something makes them uncomfortable.
Uphold fairness and impartiality, avoiding favouritism or unequal treatment between learners.
Report any concerns or suspicions of abuse or misconduct immediately, whether observed or disclosed, using the appropriate internal channels or whistleblowing system.
Encourage transparency and ensure all concerns are handled without fear of retaliation or negative consequences for the individual raising them.
Support a culture of accountability, where the safety and well-being of children and youth is everyone’s responsibility.

Huddle staff and partners MUST NEVER:

Abuse, exploit, or place a child or youth at risk of harm in any way.
Exchange gifts, services, or favours for affection or attention from a child or youth.
Have a learner or youth stay overnight at their home, or sleep in the same room or bed.
Perform personal care tasks for children or youth that they can do for themselves.
Use offensive, humiliating, or degrading language or behaviour toward any child or youth.
Use physical punishment or emotional intimidation as a form of discipline.
Engage in prolonged or unnecessary physical contact, including hugging, tickling, carrying, or lap-sitting.
Touch a child or youth inappropriately, particularly in areas covered by a bathing suit.
Be alone with a child or youth in a private or enclosed space unless absolutely necessary and approved.
Provide or distribute medication to any child or youth.

This is not an exhaustive list. Any actions that compromise the rights, dignity, or protection of children or youth will be treated seriously and in accordance with Huddle’s disciplinary and safeguarding policies, and applicable laws.

Cyber Safety and Online Conduct

In today’s digital learning environment, online safety is as critical as physical safety. All learners, youth, staff, and partners must adhere to the following principles for online engagement:

Respectful communication: No harassment, bullying, or inappropriate language will be tolerated on digital platforms.
No private digital communication, such as DMs or private calls, between staff and learners or youth unless formally required via our support channels or approved and logged.
All official communication channels used for teaching and learning may be reviewed to ensure safety and professionalism.
Learner photos, videos, or other media may only be shared with explicit consent, and all storage of such media must be secure and policy-compliant.

Huddle maintains a zero-tolerance policy for cyberbullying and digital abuse. This includes:

Bullying, harassment, or humiliation of any learner or youth in online classrooms, chat platforms, emails, or social media.
Sharing of offensive, harmful, or discriminatory content.
Spreading of false information or engaging in targeted online exclusion.

Any incidents will be investigated immediately and may result in disciplinary action, removal from programmes, or referral to appropriate authorities.

Recruitment

Job Advertising and Position Descriptions

All roles that involve direct interaction with learners will include the requirement for background checks, including criminal and previous employment reference checks. Position descriptions will clearly state the following:

Criminal record checks are mandatory.
Applicants must provide consent for these checks as part of the application process.
Staff promoted into roles involving direct interaction with learners will undergo the necessary background checks before assuming their new responsibilities.

Background Checks

Huddle is committed to ensuring that only suitable individuals are employed in roles that involve direct interaction with children and youth. In accordance with South African law and best practices, all applicants for positions at Huddle that require regular contact with children and youth, such as on-site teachers, training leads, or facilitators, will undergo comprehensive background checks.

These checks include:

Criminal Background Check – To ensure that the individual has no history of convictions related to child abuse, violence, or other serious offences.
Qualifications – Ensure the candidate holds relevant and valid teaching credentials, where applicable to the role.
Employment History – Conduct thorough reference checks from previous employers, with at least one reference coming from an institution where the applicant worked directly with minors.

Process for Conducting Background Checks

The candidate is required to submit their application along with consent for background checks.
The candidate will complete the necessary steps to obtain a criminal background check from our nominated accredited agency, PostNet or Jetline.
The candidate will submit the results via email to Huddle.
The hiring manager will review the report and scan the QR code to ensure it is valid and unaltered. Any discrepancies should be flagged and addressed.
Where the report comes back as unclear, a further investigation will be initiated, and a detailed SAP69 AFISwitch Report will be automatically requested by the nominated agency to verify the nature of the conviction. If it involves any offence which is related to sexual assault or abuse, or alternatively moral corruptness, the candidate will be automatically disqualified.
The senior management team will review the findings and make a final hiring decision based on the context of the conviction.

Rechecks: All employees who work with children will undergo rechecks of their background every two years, or as otherwise determined by Huddle, to ensure continued suitability for their role. A record will be kept of all checks that are done as well as when the checks are due to be completed again.

Additionally, all staff in identified roles will be required to sign an acknowledgement form confirming that they agree to comply with the policy on the Protection of Children and that they understand that disciplinary action will be taken against anyone found guilty of abuse of a child or youth.

Training and Awareness

At Huddle, ensuring the safety and well-being of all children and youth is a top priority. To achieve this, we provide comprehensive Child Protection and Safeguarding Training to all new employees as part of their induction. This training is designed to equip staff with the knowledge and skills necessary to effectively protect children and youth from harm, create a safe learning environment, and respond appropriately to safeguarding concerns.

Recognising Signs of Abuse

Understanding the Types of Abuse: Staff will receive in-depth training on the various forms of abuse that children or youth may experience, and will be equipped to recognise and respond to gender-based risks such as bullying, exclusion, or gender-based violence, including:
- Physical Abuse: Recognising signs of physical harm or injury, such as unexplained bruises, cuts, burns, or fractures.
- Emotional Abuse: Identifying emotional harm, including behaviours like excessive fear, anxiety, depression, withdrawal, or an inability to express emotions.
- Sexual Abuse: Recognising physical and behavioural indicators of sexual abuse, such as inappropriate knowledge of sexual matters or reluctance to participate in certain activities.
- Neglect: Understanding the signs of neglect, such as poor hygiene, malnutrition, unkempt appearance, lack of supervision, or frequent absences from school.
Spotting the Subtle Signs: Training will focus on identifying not just the visible and obvious signs of abuse, but also more subtle signs, such as changes in a child or youth’s behaviour, emotional well-being, or academic performance that may suggest they are at risk.

Reporting Procedures

Clear Reporting Channels: Staff will be educated on the steps to take if they suspect or become aware of any form of abuse or neglect. This includes:
- Reporting concerns internally to a designated safeguarding officer, senior staff member, or line manager.
- Understanding the external reporting mechanisms available, such as reporting to law enforcement, social services, or relevant child protection authorities.
Timeliness and Confidentiality: The importance of reporting concerns promptly will be emphasised. Staff will be taught that delays in reporting can have serious consequences for the child or youth. Confidentiality will be a key aspect of the reporting process to ensure that the identity of the person raising the concern remains protected.
Anonymity and Whistleblowing: Staff will be provided with information on how to report concerns anonymously, should they feel uncomfortable speaking up directly, through Huddle’s whistleblowing channels.

Boundaries and Relationships

Maintaining Professional Boundaries: Staff will be trained on the significance of professional boundaries in their relationships with children or youth. This includes understanding that all staff-student interactions should always prioritise the child or youth’s safety, dignity, and respect.
- Appropriate Conduct: Maintaining a professional distance, refraining from personal friendships or relationships with children and youth, and understanding the risks involved in crossing professional boundaries.
- Power Dynamics: Understanding the inherent power imbalance between staff and children or youth, and the importance of ensuring that this dynamic is not exploited in any way, whether consciously or unconsciously.
- Building Trust: Building positive, supportive, and respectful relationships with children or youth, creating an environment of trust and safety without crossing personal boundaries.

Legal Responsibilities

Understanding Legal Obligations: Staff will be made aware of their legal responsibilities under South African law, particularly in relation to the safety and welfare of children. This includes:
- The Children’s Act, 2005, which outlines the rights of children and the duty of care required to protect them from harm.
- The Criminal Law (Sexual Offences and Related Matters) Amendment Act, 2007, and obligations regarding the reporting of sexual offences.
- The Protection of Personal Information Act (POPIA), including how to handle learner data responsibly and ensure compliance with data protection laws.
Duty of Care: Training will emphasise the concept of duty of care, which requires all staff to act in the best interests of children and youth at all times, ensuring their safety and well-being in all interactions.

Ongoing Training

Annual Refresher Courses: To ensure that safeguarding practices remain up-to-date, Huddle will provide all staff with annual refresher courses. These courses will cover updates on legislation or child protection laws, and best practices in safeguarding and handling safeguarding issues as they evolve.
Feedback Mechanisms: Staff will have opportunities to provide feedback on the training sessions, allowing Huddle to continuously improve the safeguarding training programme and address emerging concerns or challenges.

Reporting Concerns and Whistleblowing

Huddle recognises that safeguarding is a shared responsibility. If a staff member suspects or becomes aware of any form of abuse or inappropriate behaviour toward a child or youth, they are expected to act immediately by:

Reporting to Senior Management: Staff members must report concerns directly to a senior staff member or the designated safeguarding lead, the Head of Implementation.
Anonymous Whistleblowing: If staff feel uncomfortable reporting to senior management directly, they may use Huddle’s confidential whistleblowing form to report concerns anonymously.
External Reporting: Non-staff members who suspect abuse or inappropriate behaviour involving learners can complete the external whistleblowing form, providing contact details for further follow-up should they feel comfortable to do so.

Staff members will not be penalised or discriminated against for reporting concerns made in good faith.

Immediate Response

In cases of immediate risk to a child or youth, staff should contact the South African Police Services immediately by dialling 10111 or visiting the nearest police station. If the child has already been harmed and needs medical assistance, NETCARE (082 911) should be contacted. Netcare has social workers available at the hospital to further assist the child or youth.

Once the immediate risk is resolved, staff should alert a senior staff member to what has occurred.

Support for Learners: Huddle is committed to supporting any affected children or youth and staff by supporting them with accessing resources such as trauma counselling and other support services as deemed appropriate.

Responding to Concerns and Allegations

Huddle Education is committed to responding swiftly, sensitively, and lawfully to any concerns or allegations of abuse or exploitation involving children and youth.

All actions taken will prioritise the safety, dignity, and best interests of the learner, and will comply with South African law and Huddle’s safeguarding policies.
The rights of the child or youth will be respected at every stage, and efforts will be made to avoid any further harm as a result of the response process.
Collaborative approaches will be pursued where appropriate, including working with parents, caregivers, social workers, legal authorities, and external specialists, always with the consent of the learner when applicable.
Interventions will not be one-size-fits-all but rather acknowledge different lived experiences such as gender and identity.
A clear process for internal reflection and organisational learning will follow any reported incident. This includes evaluation of the response, identification of gaps, and updates to training or procedures where necessary.

Record-Keeping and Reporting

Huddle will maintain confidential, written records of all reported concerns, including:
- Date of the report and date of the alleged incident.
- Names and contact information of the learner and their parent(s) or guardian(s), where appropriate.
- The name of the staff member making the report.
- Details of the report submitted to child protection authorities.
- A clear summary of the concern and related facts.
Records will be handled in line with Huddle’s privacy and data protection policies and stored securely within organisational files.
Huddle will inform its insurance provider and relevant stakeholders, including any partner organisations or funders, as required by contractual or legal obligations.

Senior staff members will escalate the concern to the appropriate parties based on the nature of the incident within 72 hours of receipt of the information.

Parties include but are not limited to:

The CEO of Huddle.
Senior Management Team.
The Partner School Principal.
The Police.
Medical Services.
Social Services.
Parents or legal guardians of minor children.
The Mastercard Foundation representative using the relevant reporting form.

Protection of Children or Youth Data and Media

At Huddle, we are committed to protecting the privacy and security of data in line with the Protection of Personal Information Act (POPIA). This policy ensures that all personal details, learning assessments, and media, such as photos or videos, are handled responsibly and securely.

Compliance with POPIA: All learner, child or youth data must be collected and processed according to POPIA guidelines. Before collecting or using any personal data or media, we must obtain clear consent from parents, guardians, or authorised school representatives.
Access to Data: Only authorised staff members will have access to learner, child or youth data. We will put in place appropriate safeguards to prevent unauthorised access, use, or sharing of personal information.
Data Retention: This data and media should only be kept as long as necessary for the purpose they were collected. Once they are no longer needed, the data must be securely deleted.
Recording and Sharing Media: Before capturing or recording any media, such as photos, videos, or audio recordings, of children or youth, we will always seek explicit written consent from parents or guardians. This consent will clearly state the purpose for which the media will be used and how it may be shared.
Storage and Security: Any media collected will be stored securely and shared only with the appropriate parties, and only for educational purposes. Media will not be shared or used without proper consent.
Data Minimisation: We will only collect learner, child or youth data and media that is necessary for specific educational purposes. This includes data that directly supports learning activities, teacher support, and technology implementation.
Purpose Limitation: Any data or media collected will be used only for the purpose it was originally gathered. It will not be shared or used for any other purposes without the proper consent of parents or guardians.

By following these guidelines, we ensure that data of children and youth is treated with the utmost care and confidentiality, and that we comply with all relevant laws and regulations regarding data privacy and protection.

Ongoing Monitoring and Review

The Safeguarding Policy will be reviewed annually by the Head of Operations or senior management to ensure it remains relevant and in compliance with current legal requirements. Any changes to laws, operational practices, or safeguarding standards will be incorporated into the policy.

This review process ensures that the policy continues to effectively protect children and youth and upholds the highest standards of child safety.

Cadence of Mitigation Measures

Mitigation Measure	Cadence	Owner
Police clearance (SAPS) and vetting for appropriate staff	At time of onboarding and then audit once per year	Head of Operations
Acknowledgement form signed	At time of onboarding and then audit once per year	Head of Operations
Youth Feedback and Policy Review	Annually	Head of Implementation
Code of Conduct Training and Review	Annually	Head of Implementation
Staff training on child and youth protection	Annually	Head of Implementation
Partner training on child protection	At time of onboarding and then annually	Head of Implementation
Spot checks for adherence on site	Quarterly	Head of Implementation
LMS Security Review	Annually	Product Operations Manager
Cyberpolicy/Acceptable use Policy Review	Annually	Head of Operations
Annual audit of data access and storage procedures	Annually	Data Scientist
POPIA forms	New learner onboarding; audit once per year	Head of Implementation
Partner MOU signed	At time of onboarding and reviewed annually	Head of Operations
Partner Audit	Annually	Head of Operations
Disciplinary Code Review	Annually	Head of Operations
Reinforce supervision policies with schools	Annually	Head of Implementation
Child Protection Policy Review	Annually	Head of Operations
Risk Assessment Review	Annually	Head of Operations
Report Response Review	At time of each report	Head of Operations