This Child Safety Strategy was developed with the assistance of the Lithuanian Football Federation, which reaffirms its commitment to ensuring that football is a fun and safe activity for all children who play it, regardless of their age, ability or level of involvement.
This strategy pursues five objectives in the areas of activity, which should form the basis for the work of FC Gintra in preventing any risk of injury to children in the football environment and responding appropriately to the harm caused.
While the aim is to develop a comprehensive strategy for ensuring child safety, given the diversity of football organisation and playing environments at different levels, there is a possibility that situations may arise that are not covered or questions may arise about the practical application of this strategy. In such circumstances, all actions should be guided by the spirit of the strategy, which is based on the aim of ensuring the best interests of the child.
Five goals
GOAL 1: To create the foundations for ensuring security.
GOAL 2: To ensure organizational preparedness and prevention.
GOAL 3: To raise awareness among those working in the football organization.
GOAL 4: Work with other responsible authorities and report situations of concern to them.
GOAL 5: To assess progress in ensuring security.
GOAL 1: Create a security assurance pagrindus
- Accountability
- Ensuring safety is everyone's responsibility.
- Every person working at or on behalf of FK "Gintra" at any level and in any position recognizes his/her duty to ensure the safety of children and to foster the well-being and interests of children, as well as the responsibility to take appropriate steps to implement this strategy.
- Definition of security assurance
- The Child Safety Strategy defines safety as the responsibility of the organization to ensure that football is a positive and enjoyable experience for all children and that all children are protected from injury while playing football (including violence – see the Law on Amendment of Articles 1, 2, 19, 23, 43, 46, 47, 49, 56, 58, 59 of the Law of the Republic of Lithuania on Education No. I-1489 and Supplementing the Law with Articles 23-1, 23-2).
- Ensuring the safety of children includes preventive actions to reduce the risk of harm and responsive actions to ensure that issues of concern are appropriately addressed when they arise. This approach reflects the need to promote the best interests of the child and comply with international standards and the legislation of the Republic of Lithuania, especially in cases where the issues of concern are potentially related to criminal activity.
- In this security strategy, based on the 1989 United Nations Convention on the Rights of the Child, a child is considered to be any person under the age of 18 unless, under the laws of the country in force, he or she has attained the age of majority earlier.
- What is meant by harm and violence?
- Everyone working for or on behalf of Gintra FC at any level and in any capacity should understand that violence, harm and safety issues rarely exist in isolation and cannot be attributed to a single definition – in many cases, several issues are intertwined.
- Harm can take many forms and usually refers to a risk to the safety and well-being of a child. This may occur because someone deliberately chooses to abuse the authority or trust placed in them and uses violence against a child. Or it may occur because of poor practice, possibly due to a lack of awareness and training, such as a failure to properly supervise children or take action.
- Violence is inappropriate treatment of a child that causes or is likely to cause harm to the child. A person may be violent towards a child either by harming the child themselves or by failing to prevent harm being caused by another person. Children may be violent towards people they know from their family environment or from an institution or community. On the other hand, although less frequently, children may be violent towards strangers, for example on the Internet. Children may be violent towards an adult or several adults, or another child(ren).
- Violence comes in many forms and includes all types of physical, emotional (psychological) violence and sexual abuse, neglect and negligent treatment, violence and exploitation both in person and in cyberspace.
- Although safety issues are usually thought of as arising when an adult mistreats a child, it is also possible for children to be violent towards each other. This usually happens when one child finds themselves in a position of superiority due to power or influence (for example, because they are older or have authority, such as being the team captain) – this is called bullying.
- In the case of bullying, it is very important to help both the child who was bullied and to find the best ways to help the child who was bullying, ensuring that neither child is harmed and that the well-being and interests of both children are protected.
- Football-specific security risks
- There are several very specific situations in the football environment where harm and violence can occur.
- INJURIES: Every sport carries some risk of injury, and football is no exception. The desire to succeed and win can mean that children are forced to do things that are beyond their reasonable age or ability level or are not appropriate for their age and ability level.
- PRESSURE FOR RESULTS: Winning is an important part of football. On the other hand, forcing children to perform well and putting a lot of pressure on them to succeed can be harmful to them psychologically, emotionally and physically.
- FIZINIS SAUGUMAS: persirengimo kambariai, dušai ir kitos fizinio kontakto situacijos (pavyzdžiui, fizioterapijos ir kitokio gydymo) gali sudaryti prielaidas patyčioms, fotografuoti ar filmuoti nedoriems tikslams ir seksualinei prievartai.
- TRAVELS WITH ACCOMMODATION: Overnight trips can be dangerous due to inadequate supervision, lost children, access to alcohol or inappropriate television content, problems with social media use, and the risk of abuse, especially sexual abuse.
- CLOSE RELATIONSHIPS: Football is a very important and beneficial sport for team members, with the coach and other support staff (such as physiotherapists and doctors). Many children develop close and trusting relationships with their coaches, who become important people in their lives, especially if the children do not have positive, supportive relationships with other adults. Although many coaches foster inspiring relationships with the best interests of the children entrusted to them, there is a risk that this power and trust may be abused, and children may be harmed.
- Link to national legislation or strategy
- This strategy sets out minimum requirements. All actions taken to implement the security strategy must be guided by relevant legal acts, if there are legal requirements that must be met.
- Actions outside of football environment
- This safety strategy focuses on contact with children that occurs at work and in activities for which FK "Gintra" or another entity subordinate to FK "Gintra" of any level and competence is responsible.
- On the other hand, the principles defined in this strategy may be violated and the values of football may be undermined not only in football, but also through other inappropriate individual or collective behavior, for example: posting inappropriate content on social networks or personal sexual relationships with children.
- Such cases must be carefully examined and any decision to continue working with a particular individual should be based on the principle that children involved in football activities should be kept safe and in the best interests of the child. This may require referral to a specialist child protection or law enforcement authority.
- Key principles of a child safety strategy
- Football should be a safe, positive and enjoyable experience for all children.
- All children have the same right to the protection and promotion of their well-being and opportunities to participate, regardless of age, gender, sexual orientation, ethnic or social origin, religion, and their abilities or disabilities.
- All actions taken to ensure the safety of children must be guided by the best interests of the child.
- Everyone is responsible for ensuring safety. Children can also play a role in helping to protect themselves and other children, although the ultimate responsibility for ensuring safety lies with adults.
- Safety measures should be inclusive and non-discriminatory, and should take into account that some children (for example, those with disabilities) may be at higher risk of violence.
- The values of transparency and openness are essential in safety and security. Violence and abuse can flourish if staff, volunteers, partners, children, family and community members do not feel able to voice concerns.
- All concerns raised about the safety and protection of a child should be taken seriously. Where necessary, appropriate action must be taken to ensure the child's safety, possibly including contacting law enforcement or child protection authorities.
- No organization can ensure the safety of children working alone, therefore it is necessary to cooperate with other organizations, state institutions (for example, departments and ministries protecting children's rights) and, if necessary, other groups.
- Confidentiality must be ensured by not disclosing the personal details of the individuals involved (both the person raising the concerns, the child concerned and the alleged perpetrator) unless this is necessary to enable the transmission of information and ensure the protection of the child, for example where criminal activity is suspected.
- All security actions should be carried out in accordance with relevant national and international legislation and strategies.
- Actions outside of football environment
GOAL 2: Ensure organizational preparedness and prevention
- Security strategies parengimas
- FK Gintra has prepared this strategy based on the guidelines and measures provided by the Lithuanian Football Federation to implement it.
- This strategy must be followed by every person who holds any position at any level in football or a related field, including FK "Gintra" or any entity subordinate to FK "Gintra".
- Appointment of persons responsible for ensuring security
- In order to ensure the implementation of this security strategy, FK Gintra appoints a person responsible for security from the FK Gintra administration. This person maintains contact with other persons responsible for security in other organizations.
- FK "Gintra" will appoint at least one person who would be tasked with performing the functions of the person responsible for ensuring security.
- The role of the person responsible for ensuring security is to be a contact person, to advise, support and assist the organization in implementing the security strategy and related procedures, including procedures for responding to specific incidents and situations of concern.
- It is recommended that the role of the person responsible for ensuring safety be assigned to a person with at least the minimum knowledge of child protection or safety as described in the Child Safety Toolkit. Alternatively, this role may be assigned to any other responsible person who is capable of performing the required tasks.
- Safer personnel selection
- Safer recruitment procedures will be implemented in professional football clubs and football organisations to help ensure that candidates who may pose a risk to children are identified and are not allowed to work with children.
- Safer recruitment procedures can include pre-selection, selection and post-selection activities, ensuring that as many safeguards as possible are in place.
- To prevent unsuitable individuals from working with children, no one should start working with them until all safer staff selection processes, all suitability checks and all induction or other safety training sessions have been completed.
- In certain exceptional cases, it is possible to start operations without completing the screening of safer personnel. However, in such cases, additional measures (such as additional supervision and a strict ban on working alone) must be put in place to ensure that the organisation can be confident that the potential risk to children has been reduced.
- Documents related to safer recruitment practices (e.g. recommendations) must be preserved. This information must be stored and destroyed in accordance with applicable personal data protection legislation.
- Code of ethics
- The Code of Ethics of the Lithuanian Football Federation and the Code of Ethics (hereinafter referred to as the Codes of Ethics) described in the Child Safety Assurance Kit, which sets out clear expectations for ensuring the safety of children and describes desired and prohibited behavior, apply to persons working at FK "Gintra" or acting on its behalf..
- Any participation in activities organized by FK "Gintra" is possible only when a specific person has been familiarized with the provisions of the codes of ethics and agrees to comply with them in writing, and references to this code of ethics will be provided in all employment or service contracts.
- All violations of the codes of ethics are responded to immediately, maintaining the confidentiality of information on a "need to know" basis, and in accordance with employment contract, contractual and other legal requirements.
- If a violation of the codes of ethics is suspected or reported, you can contact the Gintra FC employee group responsible for child safety so that an independent, impartial person with the necessary competence in the field of ensuring safety can investigate the case accordingly, following the official valid procedure.
- In response to such cases, FK "Gintra" will take all necessary measures against the person who has violated the rights of children or the internal rules of FK "Gintra".
- It is necessary to assess the risk to children and decide whether the offending person(s) should be temporarily suspended from work at FC "Gintra" pending the results of the relevant investigation.
- The Code of Ethics will provide for specific disciplinary measures for violations. Possible disciplinary measures range from a warning or temporary suspension from duty, possibly combined with additional training and awareness-raising measures, to dismissal.
- Codes of ethics are applied without limiting the possibility of imposing possible additional sanctions provided for in legal acts.
- Care and individual work
- Individual work should generally be avoided. At least 2 adults should work with children. It is recognised that this is not always possible, but adults should always work openly, under the observation of others, and preferably with groups of children rather than individually with a child.
- Depending on the context and the age and abilities of the particular children, there must always be a sufficient number of adults involved in the activity to ensure adequate safety for the children. Issues of supervision and individual work should always be considered in any risk assessment.
- Lithuanian Football Federation recommends the following ratio of adults to children:
1 adult for 10 children aged 13 to 18,
1 adult for 8 children aged 9 to 12,
1 adult for 6 children aged 5 to 8,
1 adult for 3 children under 4 years old.
- If a sufficient number of adults are not gathered to achieve the required level of supervision, the activity cannot take place and must be cancelled.
- When providing medical or other intimate assistance, children should be allowed to have another child or adult of their choice with them.
- There are specific requirements for the collection of anti-doping samples from minors that must be followed during the testing procedure. Minor athletes must be informed of their selection for doping control in the presence of an adult, and the athlete may choose to be accompanied by a team representative throughout the sample collection procedure. If a minor athlete declines to have a representative present during the sample collection procedure, a person must be present to observe the doping control officer during the collection of the urine sample.
- Lithuanian Football Federation The clubs participating in the competition and the members of the Lithuanian Football Federation organizing the events undertake to ensure that the “Acquaintance and Consent Form for Minors” is properly completed and signed for each participating minor. The completed forms must be kept in the clubs/organizations and submitted to Lithuanian football federations upon request.
- Children should not receive personal care services (such as being washed) if they are able to do it themselves.
- Changing rooms, showers and other facilities should be supervised, but in a way that protects children’s privacy. Only an adult responsible for supervising children should be in the changing rooms when children are changing. No other person (such as photographers) should be in the changing rooms when children are changing. They should be told when they can enter and when they should leave.
- On overnight trips (for example, when attending away matches and training camps), children should not sleep alone in the same room as the adults supervising them, unless the child is a relative of the adult or the adult has been asked by the child's parents or guardians to look after the child.
- There should be clear procedures in place for dealing with cases where a child is lost or missing, or where parents or guardians fail to collect the child.
- If children are allowed to travel to and from classes independently, written permission to do so must be given by one of the child's parents or another person with the authority to give such permission (for example, a legal guardian).
- Visitors, including media representatives, participating Lithuanian Football Federation at children's competitions and other events
- FK Gintra and each person assigned by FK Gintra to perform specific functions at FK Gintra youth competitions should ensure that all visitors for whom they are responsible (including media representatives) are made aware of and understand the principles of this FK Gintra Child Safety Strategy prior to their visit and agree to abide by the terms and conditions set out therein.
- Visitors (including media representatives) should always be accompanied, and children should only be left unaccompanied in exceptional circumstances (for example, if an investigation is underway). In such cases, additional safeguards must be taken to ensure that the visitor or observer does not pose a risk to children.
- Children’s safety and well-being should never be compromised when interacting with the media. Personal information, such as children’s home addresses, should not be provided to media representatives.
- Possession and use of personal data is possible only in strict compliance with the Law on Personal Data Protection of the Republic of Lithuania and the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, General Data Protection Regulation), after obtaining written consent from the children's parents regarding the use and processing of their children's personal data.
- Personal data of a child means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data and an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Permission for the media and others to use images and stories should be obtained from both the child and the person responsible for the child, such as a parent.
- The use or distribution of offensive or exploitative images of children, including images in which the child is partially clothed, is prohibited.
- Cybersecurity
- FK "Gintra" has conducted an assessment of the risks posed by the use of technology and media to the safety of children and has identified steps to eliminate or reduce these identified risks.
- Lithuanian Football Federation will provide guidance on the appropriate use of technology (internet, mobile phones, social networks, etc.) related to ensuring the safety of children and the implementation of a safety strategy.
- If a child has access to the Internet, filters and blocking software must be installed to help prevent access to inappropriate, including offensive, material. All devices provided by FK "Gintra" will be blocked from accessing websites that promote violence against children or contain images and information that may be harmful to children.
- Upon receipt of offensive material or unwanted messages, this must be immediately reported to the persons responsible for ensuring security, who in turn will be obliged to inform the information technology security team about the incident so that it can improve the security of internet access, as well as the relevant law enforcement authorities. It should be remembered that when reporting specific material or messages, these cannot be transmitted electronically, as such an action may be considered a criminal act under international law.
- Information that has a negative impact on minors is considered to be public information that may be harmful to the mental or physical health, physical, mental, spiritual or moral development of minors. In order to protect children from information that has a negative impact, persons working with children are familiarized with the main provisions of the Law of the Republic of Lithuania on the Protection of Minors from the Negative Impact of Public Information.
- Lithuanian Football Federation partnership
- Particular attention should be paid to child safety issues. Partnership agreements and contracts should include references to child safety measures and clearly define the actions to be taken in the event of any child safety concerns.
- If concerns about ensuring the safety of a child are related to the activities of a Gintra partner, it is appropriate to consider not only whether to report such concerns to the relevant authorities, but also whether to terminate the partnership. The procedures provided for in the contract should be followed.
- Raising a child safety issue with a Gintra partner does not automatically mean that the partnership must be terminated. Any decision on further partnership must take into account the partner's reaction and commitment to resolving the situation.
GOAL 3: Raise awareness
- Awareness raising and training
- Everyone working for or acting on behalf of FK Gintra, including associated amateur and professional clubs, as well as communities, families, children and other stakeholders, should be familiar with the child safety strategy and understand how to recognize and report violence or suspected violence.
- FK "Gintra" will develop security training modules (both e-learning and self-learning) for this purpose and help its organizational community deepen its knowledge about child protection.
- Special attention will be paid to informing children about the FC "Gintra" strategy and various possible ways of protection. For this purpose, a child-friendly version of the strategy and training modules can be developed in cooperation with children.
- Depending on the nature of the work being carried out and the specific role, education and experience of staff, volunteers, trainers, etc., specific training in child welfare, safety and security may be provided.
- FK Gintra will regularly update information on ensuring child safety through formal (for example, training or supervision) or informal means (for example, discussions at team meetings).
- Although the Lithuanian Football Federation provides guidance and training on the responsibilities and duties of specific positions under this strategy, all adults must personally request further clarification and consultation if they are unsure of what is expected of them in their position. The Child Safety Team or the Child Safety Officer at FK Gintra is the first person to whom such requests should be addressed.
- Records of all training and orientation sessions conducted, including dates of sessions and participant lists, must be maintained. These records should be stored in accordance with appropriate data management procedures.
- Risk assessments
- Risk assessments are an important element of any security process. They form the basis for preventive actions, ensuring that activities are safe and that identified risks are eliminated or reduced. They also define specific actions to be taken in the event of any security concerns.
- When organising an activity (such as a competition), a risk assessment should be carried out to identify potential sources of risk and develop a plan to reduce these risks. The responsibility for carrying out the risk assessment lies with the person with primary responsibility for the activity.
- If the assessment concludes that there are too many sources of risk that cannot be reduced to an acceptable level, the activity should no longer be organised.
- Before children participate in physical activities, emergency contact details and medical information should be collected and made available to all those responsible for the safety of children at the relevant events.
- Risk management measures are regularly reviewed both during and after the activity, allowing lessons learned to be incorporated into future activities and necessary adjustments to be made.
- A safe channel to raise concerns
- A clear procedure for reporting concerns must be in place and made known to all those working in professional football clubs and other football organisations, as well as children, their families and communities.
- The reporting flow chart will explain all the steps involved in reporting. The person responsible for ensuring child safety will be the primary point of contact..
- To ensure consistency of processes, the scheme for handling reports and related procedures will be discussed with the relevant child protection or law enforcement authorities.
- FK ,,Gintra“ will provide an opportunity to raise concerns (including the possibility of reporting anonymously). Complaints can be sent to the email address info@fkgintra.lt or concerns can be reported directly to the FK ,,Gintra“ employee responsible for ensuring child safety, tel. +37068733129.
- FK "Gintra" guarantees complete confidentiality of the documents obtained during this process and the informal investigation procedure.
- If concerns are not substantiated, no punitive action should be taken against the reporting person, unless such statements were made with malicious intent.
- The person responsible for ensuring the safety of children must keep written records of the reports received (even unclear reports) in a safe place, unknown to others.
- All concerns will be taken seriously and addressed in accordance with this Security Strategy and the procedures defined therein.
GOAL 4: Work with others and report concerns
4.1 Establishing a relationship with a child protection institutions
- In order to facilitate referral of an issue to other authorities where specialist advice and assistance is required, it is essential to establish relationships with the police and relevant child protection and law enforcement authorities. These relationships will also be necessary to allow the police and relevant authorities to formally approve the reporting of concerns.
- In order to facilitate the transmission of reports to local child protection and law enforcement authorities, contact persons within these institutions should be identified in advance. Contact details should be kept so that, if necessary, a request can be made quickly and effectively.
- It is recommended that persons responsible for ensuring the safety of children and other employees participate in training on ensuring the safety of children and protecting the rights of the child organized by other organizations.
4.2 Creating an open work environment
- Seeking help or advice regarding child safety should be taken seriously. Advice or seeking help should never be interpreted as a lack of ability or knowledge, or as spreading rumors, etc.
- If persons working for or acting on behalf of FK "Gintra" encounter child protection incidents as investigators or witnesses, they must be provided with appropriate assistance. This assistance may take the form of additional supervision or counseling.
- Incident reporting and follow-up
4.3.1. Any reporting, investigation and management of security incidents must be in accordance with national law. When considering whether to refer a child to an external agency for protection, the legal order in force in the country, as well as the best interests and wishes of the child, must always be taken into account.
4.3.2. Only those persons whose participation is necessary may participate in the consideration of issues of concern, providing medical or psychological assistance to a child. After each procedure, a document must be prepared and signed by the participants in the procedure. The document is sent to the employee of FK "Gintra" responsible for ensuring the safety of children.
4.3.3. The transmission of a report to a child protection or law enforcement authority should be in accordance with the procedure established by that authority; the authority may have established an acceptable format for the report. If the report is transmitted orally, such transmission must be confirmed in writing.
GOAL 5: Measure the success of security assurance
- The ultimate responsibility for the implementation of the child safety strategy lies with the responsible child safety officer of FK "Gintra".
- At least once a year Lithuanian Football Federation will evaluate the implemented child safety measures and the implementation of the child safety strategy.
- Based on the annual assessment, an annual action plan should be prepared to address the identified gaps in the implementation of this strategy and to reduce risks.
- At least every 3 years Lithuanian Football Federation should ask its affiliated clubs to assess the situation within their organisation. Based on this, a review of security measures across the country should be prepared.
- This Child Safety Strategy is a "living" document that will be reviewed every 3 years.
- Lithuanian Football Federation may regularly commission an external assessment of the implementation and adequacy of this security assurance strategy and related procedures.
Final provisions
This strategy was approved by FK "Gintra" on 2024-03-22 club director Mantas RadavičiusIt shall enter into force on the same day.
