Guide
Child protection and safeguarding for NGOs
Any organisation that works with children must keep them safe, and act fast when something is wrong. Here is what the law requires, what a good policy contains and exactly what to do if you are worried about a child.
At a glance11 min read
- If a child is in immediate danger, call 112. For a child at risk, call 1098, the free national child helpline. Then tell your safeguarding lead.
- Under Section 19 of the POCSO Act, 2012, anyone who knows or suspects that a child has been, or may be, sexually abused must report it to the police or the Special Juvenile Police Unit.
- Not reporting is an offence: up to six months’ imprisonment, a fine or both, and up to a year and a fine for a person in charge of an institution who fails to report about someone under them.
- Never publish anything that could identify a child victim or a child in care. The law bars it in any media report on a child victim (POCSO, Section 23) and in reports on a JJ Act inquiry, investigation or court case (Section 74).
- A child protection policy should cover safe recruitment, a code of conduct, the two-adult rule, photos and online contact, training and a clear reporting route.
On this page
- If you are worried about a child right now
- What safeguarding means
- The law in brief
- What a child protection policy should contain
- Safe recruitment and a code of conduct
- The two-adult rule
- Responding to a disclosure
- Photos, stories and online safety
- What CSR funders and partners expect
- Common mistakes
- Questions people ask
- Sources
Safeguarding is how an organisation keeps the children and vulnerable adults it works with safe from harm, and what it does when it is worried that someone is at risk. In India part of it is also law: under the Protection of Children from Sexual Offences Act, 2012 (POCSO), anyone who knows or suspects that a child has been sexually abused must report it to the police.
This guide is for NGO leaders, staff and volunteers, and for CSR teams that fund work with children. It explains the law in plain words, but it isn’t legal advice: in a specific case, turn to the police, the child helpline, a lawyer or a child protection professional.
If you are worried about a child right now
Act calmly and quickly. You don’t need proof, or anyone’s permission, to call for help.
- If a child is in immediate danger, call 112 for the police, the fire service or an ambulance.
- For a child at risk, call 1098, the national child helpline. It is free, it runs 24 hours a day with control rooms in every state and union territory, and it is linked with 112.
- If you know or suspect sexual abuse, tell the police: the local police station or the Special Juvenile Police Unit (SJPU), the police unit for children that every district and city must have. Under Section 19 of POCSO this is your own legal duty, not only your organisation’s.
- Tell your organisation’s safeguarding lead at once, so they can make the child safe and help you report.
- Write down what you saw or heard as soon as you can: the child’s own words, the date, the time and who was there.
- Don’t investigate, and don’t confront anyone. Questioning a child again and again, or warning a suspect, can damage the case and put the child at greater risk.
What safeguarding means
Safeguarding is the broad duty: preventing harm to the people you work with, and acting when harm is suspected. Child protection is the part that deals with children who are being harmed or are at risk. In POCSO and in the Juvenile Justice (Care and Protection of Children) Act, 2015 (the JJ Act), a child is anyone under 18. A vulnerable adult is someone who, for a time or always, can’t fully protect themselves, such as some older people, patients and people with disabilities.
Harm can be abuse of any kind, neglect, exploitation such as child labour, or harm online, and it can come from anyone, including an organisation’s own habits, such as publishing a child’s photo with their name and school. Every organisation that works with children should name a designated safeguarding lead: the person who receives every concern and makes sure the right people act.
The law in brief
| Law | What it requires |
|---|---|
| POCSO Act, Section 23 | No media report may disclose a child victim’s identity (name, address, photo, family, school, neighbourhood or other details) unless the Special Court allows it |
| POCSO Rules, 2020, Rule 3 | Institutions that house children or are in regular contact with them must ensure periodic police verification and background checks of staff, and training on child safety |
| JJ Act, Sections 32 to 34 | Anyone who takes charge of a child who seems lost, abandoned or orphaned must, within 24 hours, inform the child helpline, the police, the Child Welfare Committee or the District Child Protection Unit. Not doing so: up to six months, a fine of ₹10,000, or both |
| JJ Act, Sections 41 and 42 | Every institution housing children in need of care and protection, or children in conflict with the law, must be registered, whether or not it gets government grants. Running one unregistered: up to a year, a fine of at least ₹1 lakh, or both |
| JJ Act, Section 74 | No media report about an inquiry, investigation or court case may identify a child in conflict with the law, a child in need of care and protection, or a child victim or witness, or show their picture. Penalty: up to six months, a fine of up to ₹2 lakh, or both |
Each district has at least one Child Welfare Committee, which decides on the care of children in need of care and protection, and since the 2021 amendment to the JJ Act the District Magistrate’s recommendation is considered before a children’s home is registered. From 13 May 2027, data protection law also requires a parent’s or guardian’s verifiable consent before you process a child’s personal data: see data protection for NGOs.
What a child protection policy should contain
A child protection policy is your organisation’s written promise and its rulebook. Many CSR funders ask to see one before they fund work with children.
| Part | What it covers |
|---|---|
| Scope | Who it applies to: staff, board, volunteers, interns, consultants, partners and visitors |
| Safeguarding lead | The named lead and deputy, and how to reach them at any time |
| Safe recruitment | The checks made before anyone works with children |
| Code of conduct | What adults must and must never do around children, including the two-adult rule |
| Photos, stories and data | Consent, never identifying children at risk, no private contact online, how records are kept |
| Reporting | The steps for a disclosure or concern, who reports to the police, and how fast |
| Allegations | How a staff member or volunteer is kept away from children while a concern is looked into |
| Training and review | Induction and refresher training; a yearly review, and one after any serious incident |
Safe recruitment and a code of conduct
Safe recruitment makes it harder for someone who means harm to reach children through your organisation. For any role that involves children:
- say in the role description that it involves children and that checks will be made;
- check identity and references, ask about working with children at interview, and ask candidates to declare any criminal record;
- for roles that bring the same adults back to work with children regularly, carry out police verification and background checks, and repeat them from time to time, as Rule 3 of the POCSO Rules expects;
- train people on your policy before they start, and supervise them closely while they are new.
A code of conduct turns the policy into plain rules for the day: never be alone with a child; no private contact with children by phone, WhatsApp or social media; no gifts or money to individual children; touch only when it is appropriate and the child is comfortable; never take a child anywhere; no alcohol or drugs; and never hit, shout at or punish a child. Physical punishment isn’t only a breach of the code: under Section 75 of the JJ Act, cruelty to a child by someone employed by, or managing, an organisation entrusted with the child’s care can bring up to five years’ rigorous imprisonment and a fine of up to ₹5 lakh.
The two-adult rule
The two-adult rule means that no staff member or volunteer is ever alone with a child or a vulnerable adult: at least two adults are present, in the open. It protects children, and adults too. Hold one-to-one reading or tutoring where others can see, ask a teacher or carer to take a child to the toilet, never let one adult drive a child alone, and name a safeguarding lead for every activity with children. Volunteering on SocioStory is for adults only, and every drive with children follows this rule; our safeguarding policy sets out the rest.
Responding to a disclosure
A disclosure is when someone tells you that they, or someone else, are being harmed. Listen calmly, and don’t show shock or anger. Don’t ask leading questions: “Tell me more” is enough, “Was it your uncle?” is not. Never promise to keep it secret. Reassure them that they were right to tell you, write down their words as soon as you can, and report it straight away.
A good first response might be: “Thank you for telling me. You’ve done the right thing. I can’t keep this a secret, because I need to tell people who can help keep you safe.”
Then the organisation acts. It makes the child safe first, reports to the police where the law requires it, tells only the people who need to know, and keeps records securely. If the concern is about a staff member or volunteer, keep them away from children while it is looked into: that protects everyone, and it isn’t a finding of guilt. An internal inquiry never replaces a report to the police.
Photos, stories and online safety
Photograph children only with a parent’s or guardian’s consent and the organiser’s agreement. Never publish anything that could identify a child victim or a child in care, not even in a WhatsApp forward: blurring a face doesn’t help if the caption names the school or village. Turn off location tags, because a photo’s location data can lead someone to a child’s home or a shelter. Our guide to consent, photos and dignity covers this in full.
What CSR funders and partners expect
CSR teams increasingly ask partners that work with children for a written policy, a named safeguarding lead, training records and a reporting route before they release money. Paperwork shows that a policy exists, not that it works, so good funders also ask how the last concern was handled, without asking for anyone’s identity, and write safeguarding into their CSR agreements.
If you are on a CSR team, check safeguarding when choosing an NGO partner, in proportion to the risk, and help a promising partner fix gaps rather than simply turning it down. Make sure your employee volunteers follow the partner’s rules, and never ask for photos or stories that identify children.
Common mistakes
- A policy on paper that nobody has been trained on.
- Leaving one adult alone with a child “just for five minutes”.
- Promising a child to keep a secret, or waiting for proof before reporting.
- Opening a hostel or children’s home before it is registered under the JJ Act.
The Academy’s safeguarding course teaches all of this in short, practical lessons.
Questions people ask
- Is reporting child sexual abuse mandatory in India?
Yes. Section 19 of the POCSO Act, 2012 requires any person who knows, or fears, that a sexual offence against a child has been or is likely to be committed to inform the Special Juvenile Police Unit or the local police. Under Section 21, not reporting can bring up to six months’ imprisonment, a fine or both, and up to a year and a fine for a person in charge of an institution who fails to report an offence by someone under their control.
- What is the child helpline number in India?
Call 1098, the national child helpline. It is free and runs 24 hours a day under the Ministry of Women and Child Development, with control rooms in every state and union territory, and it is linked with 112, the emergency number. If a child is in immediate danger, call 112.
- What should an NGO’s child protection policy include?
It should say who it applies to, name a safeguarding lead, and set out safe recruitment checks, a code of conduct including the two-adult rule, rules for photos, online contact and children’s data, and the steps for reporting a concern, including to the police. It should also cover allegations against staff or volunteers, training and a yearly review.
- Do NGO staff and volunteers need police verification to work with children?
Rule 3 of the POCSO Rules, 2020 requires institutions that house children or are in regular contact with them to carry out periodic police verification and background checks of their staff. Good practice applies the same to volunteers who come back regularly to work with children. One-off volunteers should work only under supervision and the two-adult rule.
- Does a children’s home or hostel run by an NGO need to be registered?
Yes. Section 41 of the Juvenile Justice Act, 2015 requires every institution that houses children in need of care and protection to be registered, whether or not it receives government grants. Running one without registration can bring up to a year in prison, a fine of at least ₹1 lakh, or both.
Sources
- Protection of Children from Sexual Offences Act, 2012 (Sections 19, 21 and 23) · India Code, Ministry of Law and Justice
- Juvenile Justice (Care and Protection of Children) Act, 2015 · National Commission for Protection of Child Rights
- Juvenile Justice (Care and Protection of Children) Amendment Act, 2021 · Central Adoption Resource Authority, Ministry of Women and Child Development
- Child Helpline 1098 · Ministry of Women and Child Development
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