The following outline is a consolidated description of the functions prescribed in the global, regional and local safeguarding policies of the Prelature in Ireland for the following overlapping roles:
Regional Safeguarding Coordinator (aka Director of Safeguarding)
Designated Liaison Person (“DLP”)
Garda Vetting Officer
Data Protection Officer
Safeguarding Trainer
The office of Coordinator for the safeguarding of minors in the Prelature as a whole is established in Article 8 of the Prelature Safeguarding Policy (“PSP”). The corresponding role of Director of Safeguarding (or Safeguarding Coordinator) for each Region is specified in Article 9 of the PSP and in Articles 14 to 21 of the Regional Safeguarding Policy (“RSP”).
The person appointed as Coordinator must have been in the Prelature for at least for 10 years and be outstanding in the qualities of upright Christian living, prudence, empathy, doctrine, and have the aptitudes necessary to discharge the functions described below (cf. PSP Art. 9). It is also advisable that the Coordinator have a knowledge of psychology. The Coordinator may also be a member of the Safeguarding Committee and/or the Advisory Panel, but this is not essential.
The Regional Vicar shall also appoint a Deputy Coordinator or Coordinators, endowed with similar qualities, who will assist or deputise the Regional Safeguarding Coordinator in these tasks, whether in particular areas of the Region or generally, and "Coordinator" will be understood to include a Coordinator acting as a deputy in a particular case or area of the region.
In this policy, the functions of the Regional Safeguarding Coordinator of the Prelature (and the delegated functions of the Deputy Coordinator for Ireland) subsume those of the Designated Liaison Person (“DLP”) and of the Safeguarding Director envisaged by the NBSCCCI Policy for Ireland. The separate role of Safeguarding Trainer in the NBSCCCI guidance may be added to the role of Coordinator or fulfilled separately, as circumstances permit.
The separate roles of Garda Vetting Officer and Data Protection Officer under civil legislation in Ireland may also to be assigned to the Deputy Coordinator for Ireland or fulfilled separately, as circumstances permit.
In the Local Safeguarding Policy for Ireland (“LSP-I”), therefore, the Deputy Coordinator will in principle have the following functions:
Deputy Safeguarding Coordinator, in PSP & RSP, corresponding to:
Director of Safeguarding (from NBSCCCI policy)
Designated Liaison Person ("DLP", from NBSCCCI policy)
Member of the standing Safeguarding Committee (from NBSCCCI policy), corresponding to:
Member of Advisory Committee (optional), in PSP & RSP
Member of the Advisory Panel (from NBSCCCI policy) convoked ad casum, corresponding to:
Member of Advisory Committee (optional), in PSP & RSP.
The following additional safeguarding functions may either be assigned to the Deputy Coordinator, or fulfilled by another person or persons:
Safeguarding Trainer, from PSP & NBSCCCI
Data Protection Officer (“DPO”), from NBSCCCI & GDPR
Garda Vetting Officer (“GVO”), from NVB.
For the purposes of LSP-I (and the role of the Deputy Coordinator who will be responsible for them) these functions are described below under three main policy headings:
The Regional Coordinator and the Deputy Coordinators shall work with the Vicar on the management, coordination and auditing of compliance with the safeguarding standards and procedures established in the Local Safeguarding Policies.
In the case of the Deputy for Ireland, this includes:
Keeping up to date with relevant civil legislation and and NBSCCCI policies and practice;
Ensuring that all those responsible for child safeguarding are kept up to date with current practice, including the provision of on-line resources;
Liaising with and supporting the Local Safeguarding Committee and Local Safeguarding Representative in each relevant centre of the Prelature in Ireland to ensure implementation of local safeguarding policies and procedures and the proper management of personal records;
Liaising with (or being a member of) the Safeguarding Committee for the Region (or functional area) and assisting in their planning and oversight functions.
Reporting directly (or via the Regional Coordinator) to the Regional Vicar on all child safeguarding issues.
Before designating persons who will work with minors or vulnerable persons in apostolic initiatives which receive pastoral support from the Prelature, even for an occasional involvement, the suitability of the candidates to interact with such persons should be ascertained through appropriate inquiry and by establishing, in accordance with current legislation, the absence of a criminal record.
To facilitate the statutory police vetting process in Ireland, the Deputy Coordinator will act as the Garda Vetting Officer (“GVO”) for the Prelature, and will be registered with and trained for this role by the Dublin City Volunteer Centre. The GVO will communicate exclusively with the Liaison Officer of the Dublin City Volunteer Centre in relation to each application for a vetting disclosure.
In the candidate selection process for Ireland,
unless already well known, the candidate is interviewed about the responsibility involved and his or her previous experience in giving formation to minors;
unless already vetted for a similar role for the Prelature, the candidate is invited to complete a Garda Vetting application online, via the Dublin City Volunteer Centre (designated a ‘relevant organisation’ by the NVB);
the disclosure is communicated from the NVB via the Dublin City Volunteer Centre to the Deputy Coordinator (as the Garda Vetting Officer for the Prelature in Ireland);
the candidate is informed if there is any specified information in the disclosure;
the Deputy Coordinator communicates the outcome to the Regional Vicar, who then decides on the suitability of the candidate;
the Coordinator keeps a confidential record of the application and approval process (which the candidate has a right to inspect and correct if necessary), for as long as the information is relevant to the purposes of the application.
The Regional and Deputy Coordinators shall foster the provision of training and awareness programmes in the various parts of the Region on the safeguarding of minors and vulnerable persons in accordance with the local policies.
Candidates must be provided with adequate induction and training, using the most appropriate means, to help them to understand, identify and prevent risks of sexual exploitation and abuse.
In the case of the Deputy Coordinator for Ireland, this includes:
Preliminary induction using the Tusla on-line learning module and local instruction on the Prelature code of safeguarding practice;
Developing and implementing an in-person and on-line training schedule for those engaged in work with minors on behalf of the Prelature, including training and refresher days following the NBSCCCI programme.
To make recourse to the Regional and Deputy Coordinators easily accessible, telephone numbers and e-mail addresses where they may be contacted quickly should be clearly visible on the national websites in the Region. This same information should be available in each Centre of the Region. The Regional safeguarding website (www.nwepolicy.online) will also facilitate anyone who wishes to raise a concern or submit a report online or to update it whenever necessary.
It is the responsibility of the Regional or Deputy Coordinator (as appropriate):
to receive and acknowledge every kind of complaint or report – whether directly from the person affected or from third parties – regarding conduct to which the Policy applies;
in the case of an oral complaint, to prepare an authenticated statement, noting everything that has been affirmed and also the steps that have been taken;
to receive any such report (notitia de delicto) with respect, understanding and compassion, to be a skilled listener, receptive to the needs of those who present a report and to act with tact and sensitivity;
to inform the Regional Vicar promptly of the complaint and to include a brief report in which, in addition to his/her views on any aspects of the matter on which the Deputy may consider it appropriate to comment, he/she shall propose possible measures of accompaniment or pastoral and psychological help to the informants or complainants and other persons affected;
to provide initial assistance to victims and, where appropriate, to arrange for a Support Person to accompany the complainant during the process;
to inform the complainant or offended person about the civil and canonical procedural steps;
in particular, to explain to them in advance – where such is the case – that the civil law or the norms of the Church oblige the Coordinator to inform the civil authorities about the accusation which they wish to share with him –
In Northern Ireland the civil reporting responsibility is mandatory;
In the Republic of Ireland legislation requires “mandated persons” (including a Coordinator) to report child protection suspicions, concerns, knowledge or allegations;
Canon law and the Prelature’s safeguarding policy require the reporting of allegations to the statutory authorities (without prejudice to the sacramental seal) in compliance with the obligations of national law;
The NBSCCCI flowchart in Figure R1.A1 (Standard R1.A, p. 6) indicates the reporting responsibilities that arise in a variety of different circumstances;
In the case of a complaint concerning a cleric, the NBSCCCI should also be informed, without disclosing the identities of those involved.
In a case of emergency, where a child appears to be at immediate and serious risk, an urgent report must be made to Tusla/HSCT or an Garda Síochána/PSNI must be contacted to ensure that under no circumstances a child is left in a dangerous situation pending Tusla/Health and Social Services intervention.
In all cases, consideration should also be given as to whether an immediate referral is necessary in order to preserve and safeguard against the possibility of any loss, deterioration or destruction of forensic or other potential evidence.
without interfering with investigations which may be carried out by authorities in any civil process, to make internal inquiries to gather whatever data may be necessary for the purpose of identifying the person accused and the possible victims, as well as any subsequent data relating to the facts asserted and the persons affected;
to safeguard and communicate information concerning the case in such a way as to ensure its security, integrity and confidentiality in accordance with the prescriptions of Can. 471, 2° CIC, in order to safeguard the reputation, esteem and privacy of everyone involved so far as possible, without prejudice to the obligations laid down by civil law (including any reporting obligations and complying with legitimate requests of civil authorities).
The relevant Coordinator will have the responsibility to manage an ongoing case and the associated documents, including liaising with the victim support person, the advisor to the respondent and the Regional Vicar.
This may include arranging meetings of affected persons with the Vicar - or in the context of a canonical Preliminary Investigation, with the Investigator - in any case in which this seems appropriate, to discuss whatever pastoral or medical care the person concerned might need.
The Coordinator shall liaise with (or being a member of) the Advisory Panel appointed to advise the Regional Vicar in a particular case.
Where there are respondents to a current or previous case in the region who have not been fully vindicated, the relevant Coordinator shall be responsible for monitoring them as appropriate or, with the Regional Vicar, appointing a suitable person to carry out this role.
The Coordinator shall not retain the documents of a case, once his civil reporting, management, monitoring and other responsibilities have been discharged and his function of gathering and forwarding them to the Vicar has been fulfilled.
Without prejudice to his duty to follow the appropriate procedures, the Vicar is to archive and safeguard such documents as stipulated by the canonical norms (cf. Can. 489 to Can. 490 CIC) and in keeping with GDPR requirements.
In the Coordinator’s role as Data Protection Officer (“DPO”), he/she shall:
inform and advise the Data Controller, its employees, and any associated Data Processors about their obligations to comply with the GDPR and other relevant data protection laws;
monitor compliance with data protection laws, including managing internal data protection activities, advise on data protection impact assessments; train staff and conduct internal audits;
be the first point of contact for the Data Commission/Information Commissioner and for individuals whose data is being processed;
with the Regional Vicar, develop the necessary procedures and policies to ensure that the safe and secure processing of personal and sensitive data is in keeping with the principles of data protection;
ensure that all records associated with the local and regional safeguarding policies are reviewed on a periodic basis for the purposes of determining whether such records, in whole or in part, should be retained, having regard to an assessment of possible danger or harm to children arising out of the destruction of the relevant records.
The Deputy Coordinator for Ireland shall prepare annual reports, regarding compliance in Ireland with –
and submit them to the Regional Vicar, who will then inform the NBSCCCI that he has received these reports.
