Safeguarding & Child Protection Policy

HeyLocals is the UK-facing brand of ACL Travel S.r.l. Società Benefit (“ACL Travel”), an Italian travel organiser that designs and sells volunteer-travel packages. Our volunteers (“participants”) travel to partner organisations across 15 countries to take part in community-led projects that include contact with children and, in some cases, adults at risk.

We are committed to creating and maintaining a safe environment for every child, young person and adult at risk who comes into contact with our organisation, our staff, our participants and our partner projects overseas.

We believe that:

• Every child and young person, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, has the right to equal protection from all types of harm or abuse.
• The welfare of children is paramount.
• Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting their welfare.

This policy applies to all projects promoted, sold or coordinated by HeyLocals, including those delivered through in-country partner organisations, and governs the conduct of all staff, participants, administrators, contractors and anyone acting on our behalf.

We recognise that, while our company is Italian and our partner projects are overseas, many of our participants are UK residents, and that UK sector standards on the safeguarding of children in international-volunteering settings are among the most developed in the world. We therefore apply the higher of Italian law, UK best-practice standards, and the legal requirements of the host country across all of our operations.

As a Società Benefit under Italian Legge 208/2015, our commitment to the welfare of children and communities is not only a policy choice but a binding element of our corporate purpose.

This policy applies to:

• All ACL Travel S.r.l. employees, administrators (amministratori) and contractors, wherever based.
• All HeyLocals participants travelling on our programmes.
• All in-country coordinators, host family members, drivers and project staff operating under HeyLocals’ umbrella.
• All partner organisations hosting HeyLocals participants.
• Any third party (photographer, journalist, visitor) acting on behalf of, or visiting, a HeyLocals project.

It covers all contact with children and adults at risk in person, online, by telephone, in writing, or through any other form of communication.

We operate as an Italian commercial company. Italian law applies to the company as such (company, tax, civil liability, and consumer law for contracts governed by Italian law). UK and EU consumer-protection and data-protection law applies to our dealings with UK and EU residents. The law of each host country applies to the activity that takes place there.

Within this framework, this policy is developed with reference to:

Italian law

• Codice Civile and Codice Penale (including Art. 600-bis, 600-ter, 600-quater on offences against minors; Art. 609-bis ff. on sexual offences; Art. 572 on maltreatment);
• Legge 15 febbraio 1996 n. 66 and subsequent reforms (sexual violence);
• Legge 3 agosto 1998 n. 269 and Legge 6 febbraio 2006 n. 38 (exploitation of minors);
• D.Lgs. 39/2014, implementing Directive 2011/93/EU (requirement to verify the criminal record of persons working in professional activities involving regular contact with minors);
• D.Lgs. 196/2003 as updated, and Regulation (EU) 2016/679 (GDPR);
• Legge 208/2015, Art. 1, commi 376-384 (Società Benefit);
• Codice del Turismo (D.Lgs. 79/2011) as it applies to travel organisers.

UK law and guidance (applied voluntarily as best-practice standards)

• Children Act 1989 and 2004;
• Safeguarding Vulnerable Groups Act 2006 and Protection of Freedoms Act 2012;
• Sexual Offences Act 2003 — in particular Part 1, which applies to UK nationals abroad;
• Modern Slavery Act 2015;
• Data Protection Act 2018 and UK GDPR;
• Working Together to Safeguard Children, Keeping Children Safe in Education, and the DBS Code of Practice, referenced as sector-standard benchmarks.

International instruments

• UN Convention on the Rights of the Child (UNCRC);
• UN Convention on the Rights of Persons with Disabilities (UNCRPD);
• Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography;
• ECPAT International guidance (“The Code”).

Sector best practice

• ReThink Orphanages / Better Volunteering, Better Care principles;
• Keeping Children Safe International Child Safeguarding Standards;
• Global Federation of Animal Sanctuaries (GFAS) standards, where applicable.

Where conflict between these sources is possible, the standard that provides higher protection to the child prevails.

We are not a UK charity, a UK employer of participants, or a UK “regulated activity provider” within the meaning of the Safeguarding Vulnerable Groups Act 2006. Nothing in this policy creates such a legal status; the policy is instead our voluntary commitment to meet and, where appropriate, exceed sector-standard UK safeguarding expectations.

Child / young person: any person under the age of 18, as defined by the UNCRC. Where local law defines childhood differently, the higher protective standard applies.

Adult at risk: any person aged 18 or over who may be unable to protect themselves from harm or exploitation due to age, disability, illness, or other factors.

Safeguarding: the action we take to promote the welfare of children and adults at risk, and to protect them from harm.

Child protection: the specific activity undertaken to protect children who are suffering, or are at risk of suffering, significant harm.

Abuse: a form of maltreatment. Someone may abuse or neglect a child or adult at risk by inflicting harm, or by failing to act to prevent harm. The main recognised categories are:

• Physical abuse — hitting, shaking, throwing, poisoning, burning, drowning, suffocating or otherwise causing physical harm.
• Emotional abuse — persistent emotional maltreatment that causes severe and adverse effects on emotional development.
• Sexual abuse — forcing or enticing a child or adult at risk to take part in sexual activities, whether or not they are aware of what is happening. Includes contact and non-contact activities, grooming, and online abuse.
• Neglect — persistent failure to meet a child’s or adult at risk’s basic physical and/or psychological needs.
• Exploitation — including criminal exploitation, sexual exploitation, labour exploitation and trafficking.
• Online abuse — any abuse facilitated by technology, including grooming, sextortion, cyberbullying, and sharing of indecent images.
• Institutional abuse — harm caused by the systems, policies or culture of an organisation.

Disclosure: when a child, young person or adult at risk communicates, directly or indirectly, that they are being harmed, have been harmed, or are at risk of harm.

DSL: Designated Safeguarding Lead — the person at HeyLocals with primary responsibility for safeguarding.

Participant: a fee-paying volunteer travelling on a HeyLocals programme.

All HeyLocals activity is governed by the following principles:

1. The welfare of the child is paramount. Any action or decision taken in relation to a child will have their best interests at its core.
2. Children have the right to be heard. We take the views and wishes of children and young people seriously, appropriate to their age and understanding.
3. Zero tolerance of abuse. All forms of abuse, harassment, exploitation and discrimination against children and adults at risk are unacceptable.
4. Do no harm. We assess and minimise the risks that our activities may create for children and adults at risk in their own communities.
5. No direct donations, no gifts, no promises. Well-intentioned but uncoordinated gifts or promises can cause lasting harm. Any support to children, families or communities is channelled through vetted partner organisations.
6. Short-term volunteering does not replace professional care. Participants never act as substitute parents, primary teachers, or sole care-givers.
7. Transparency and accountability. We report concerns openly and cooperate with Italian, UK and in-country statutory agencies as applicable.
8. Confidentiality on a need-to-know basis. Information about a child is only shared with those who need it to protect the child.

6.1 The administrators (amministratori) of ACL Travel S.r.l.

As the legal representatives and governing body of the company (currently Andrea Tonetti and Giovanni Sala), the administrators hold ultimate responsibility for safeguarding. They will:

• Approve and review this policy at least annually;
• Appoint a Designated Safeguarding Lead (DSL);
• Ensure that adequate resources (time, training, budget) are allocated to safeguarding;
• Receive regular reports on safeguarding incidents, trends and action taken;
• Ensure that safeguarding is a standing agenda item at board meetings;
• Discharge the Società Benefit obligations relating to the welfare of children and communities, including the annual relazione d’impatto.

6.2 Designated Safeguarding Lead (DSL)

The DSL has operational responsibility for safeguarding across HeyLocals. The DSL will:

• Act as the first point of contact for any safeguarding concern;
• Maintain this policy and associated procedures;
• Deliver or commission safeguarding training for staff and participants;
• Keep confidential, secure records of all concerns and disclosures;
• Liaise with Italian, UK and in-country statutory agencies as appropriate;
• Ensure that partner organisations meet HeyLocals’ safeguarding standards;
• Be contactable through the escalation arrangements communicated for active placements, personally or through a named Deputy DSL.

DSL contact details: Andrea Tonetti · [email protected] · out-of-hours phone contact and applicable availability provided directly in the Pre-Departure Pack

6.3 Deputy DSL

At least one Deputy DSL will be appointed to ensure cover during absence. The Deputy DSL will have equivalent training and authority.

Deputy DSL contact details: Giovanni Sala · [email protected] · out-of-hours phone contact and applicable availability provided directly in the Pre-Departure Pack

6.4 In-country coordinators

Each destination has a named in-country coordinator. They are responsible for:

• Day-to-day welfare of participants and children on project;
• Immediate response to incidents and concerns on the ground;
• Escalation to the DSL in line with this policy;
• Liaison with local authorities and partner project leaders.

6.5 Partner organisations

HeyLocals only works with partner organisations that:

• Have their own written child-protection policy aligned with international standards;
• Have a named safeguarding focal point;
• Screen and train their own staff and volunteers;
• Accept and sign HeyLocals’ Partner Safeguarding Agreement;
• Allow monitoring visits and audits by HeyLocals.

6.6 Staff and participants

All staff and participants are responsible for:

• Reading and understanding this policy before any contact with children;
• Signing and adhering to the Code of Conduct (Appendix B);
• Reporting any safeguarding concern without delay;
• Completing required training;
• Cooperating fully with any safeguarding investigation.

Everyone has a personal duty to act if they see, hear or suspect that a child is being harmed. Safeguarding is everyone’s responsibility, not just the DSL’s.

HeyLocals applies safer-recruitment principles to all roles — paid and voluntary — that involve contact with children. Because ACL Travel is an Italian company, and because the overwhelming majority of our participants are UK or EU residents travelling to third countries, our screening model is a verification model: we require each applicant to obtain the appropriate criminal-records certificate for their country of residence, and we verify it — rather than submitting the check ourselves as a UK employer would. Full detail is set out in our separate DBS Check Policy.

In summary:

7.1 Staff and in-house volunteers (any nationality)

• Written application and full CV;
• At least two references verified before any placement;
• Values-based interview;
• Criminal-records certificate from each country of residence in the last 5 years:
  • Italy — certificato del casellario giudiziale, including certificato penale ex art. 25-bis DPR 313/2002 where D.Lgs. 39/2014 applies;
  • UK — Enhanced DBS certificate with Children’s Barred List check where obtainable;
  • Other countries — national equivalent certificate.
• Verified identity (passport, proof of address);
• Written acceptance of the Code of Conduct.

7.2 Participants on placements involving children

• Safeguarding Self-Declaration form, disclosing any relevant criminal or safeguarding history (spent or unspent, insofar as local law permits such disclosure for work with children);
• Criminal-records certificate from country of residence:
  • UK residents — Enhanced DBS with Children’s Barred List check where eligible; where not eligible, Basic DBS + International Child Protection Certificate (ICPC) from ACRO;
  • Italian residents — certificato penale ex art. 25-bis DPR 313/2002;
  • Residents of other countries — national equivalent certificate issued within the last 6 months;
• Signed Code of Conduct;
• Completion of the pre-departure safeguarding training module.

Undisclosed conviction or allegation later discovered is grounds for immediate removal from the programme.

7.3 In-country staff and partner staff

• Local criminal-records check where available;
• Two references verified by HeyLocals or the partner;
• Interview including safeguarding scenarios;
• Written Code of Conduct aligned with this policy.

7.4 Records

Recruitment records are retained securely in line with GDPR (Regulation (EU) 2016/679), the Italian Codice Privacy and — for UK residents’ data — UK GDPR.

All staff and participants must sign the HeyLocals Code of Conduct (Appendix B) before any contact with children. Key rules include:

Participants and staff MUST

• Treat every child with respect, dignity and fairness;
• Work within the plan of activities set by the partner organisation;
• Remain in visible, group settings when with children;
• Immediately report any safeguarding concern to the in-country coordinator or DSL;
• Respect local culture, customs and dress codes.

Participants and staff MUST NOT

• Be alone with an individual child in a private space (closed room, bedroom, vehicle) at any time — “two-adult rule”;
• Take a child off-site, outside of planned activities;
• Engage in any form of sexual activity, relationship, or sexually-charged communication with a child or vulnerable adult (regardless of local age-of-consent law — HeyLocals applies a blanket rule of no sexual contact with anyone under 18);
• Use physical punishment or humiliating discipline of any kind;
• Use, or be under the influence of, alcohol or illegal drugs while working with children;
• Give personal contact details (personal phone, social media, email, home address) to a child or their family, or accept theirs, without written DSL approval;
• Give gifts, money or favours to individual children;
• Promise a child anything HeyLocals cannot guarantee (visits, letters, sponsorship, adoption);
• Share, post, or private-message photos or videos of children outside the channels approved in Section 13;
• Continue contact with children after the placement ends, other than through official HeyLocals channels;
• Visit orphanages, children’s homes or similar residential-care settings outside of the official programme.

Breach of the Code of Conduct is a serious matter and may result in immediate removal from the programme, referral to statutory authorities in Italy, the UK and/or the host country, and a lifetime ban from HeyLocals and partner programmes.

9.1 Staff and in-country coordinators

• Safeguarding Children Level 2 (or equivalent) on induction;
• Annual refresher training;
• DSL and Deputy DSL complete Safeguarding Children Level 3 (or equivalent), updated every two years.

9.2 Participants

Every participant, before departure, must complete:

• The HeyLocals online pre-departure safeguarding module;
• A live or recorded briefing call with an in-country coordinator;
• A written acknowledgement of the Code of Conduct;
• An on-arrival in-country induction repeating key safeguarding messages.

9.3 Partner staff

Partners are required to train their own staff on their own child-protection policy and confirm this in writing annually.

Before accepting any project into the HeyLocals portfolio, the DSL (or delegated senior staff) will carry out partner due diligence, including:

• Review of the partner’s written child-protection policy;
• Review of its staff recruitment and screening practices;
• Registration and legal status in-country;
• Review of governance, financial transparency and safeguarding track record;
• On-site visit to observe activities with children;
• References from other international partners (where available);
• Signed Partner Safeguarding Agreement binding the partner to HeyLocals’ standards.

Partner due diligence is repeated at least every two years, or immediately if a concern is raised.

Any partner that is unable or unwilling to meet HeyLocals’ standards is removed from the portfolio.

HeyLocals recognises the international consensus — expressed by UNICEF, Lumos, ReThink Orphanages and the Better Volunteering, Better Care initiative — that short-term, rotating volunteers in residential-care settings for children can cause attachment disorder, institutional abuse, and demand-driven family separation.

HeyLocals therefore:

• Does not offer placements in residential orphanages where children reside full-time and lack family contact;
• Prioritises projects that support children in their own families, schools and communities (community-based childcare, day centres, school support);
• Will not place participants in any project where the primary contact is with children separated from their families, except where the partner is a recognised transitional or specialist-care facility with a documented child-protection framework and where HeyLocals’ role is explicitly supportive and non-caregiving;
• Continues to review its programme portfolio against these standards.

Where HeyLocals works with children with disabilities, in hospital settings, or with children from disadvantaged backgrounds, participants act only in a supporting role alongside qualified local staff, and never as substitute professionals.

12.1 One-to-one contact

Participants must not be alone with an individual child. The “two-adult rule” applies: another adult — a partner staff member, another participant, or a coordinator — must be present or have clear line-of-sight at all times.

If a one-to-one situation is unavoidable (for example, responding to a child in distress), the participant must:

• Remain in a visible, public area;
• Keep the interaction as short as possible;
• Inform the partner staff member and, where appropriate, the in-country coordinator immediately afterwards;
• Record the interaction in the daily log.

12.2 Physical contact

Physical contact with children, however well-intended, is an area of significant safeguarding risk and cultural variation. The default position is minimal and necessary physical contact only. Participants must:

• Take cues from the child and from local staff;
• Never initiate physical contact that is prolonged, private or intimate;
• Never sit a child on their lap, share a bed, share a bedroom, or engage in horseplay;
• Avoid physical contact entirely in disciplinary or care contexts (dressing, toileting, bathing) unless explicitly part of a trained role approved by the partner.

Any concern about appropriate physical contact should be raised with the in-country coordinator immediately.

Images of children are personal data and, in many jurisdictions, sensitive personal data. They also carry safeguarding risk (identification, trafficking, “poverty porn”, grooming).

13.1 Rules for participants

• Never photograph a child without the explicit, informed consent of the partner organisation and the child’s parent or legal guardian;
• Never photograph a child in a state of undress, distress, or medical vulnerability;
• Never photograph individual children in a way that allows them to be identified (full face + name + location);
• Never post an image of a child on a personal social-media account, blog, or messaging service;
• Do not share children’s images in private messaging groups (WhatsApp, Telegram, Discord);
• Do not use children’s images in crowdfunding, fundraising or personal marketing;
• Do not photograph other participants or staff without their consent.

13.2 Rules for HeyLocals communications

When HeyLocals uses images of children on heylocals.co.uk, in marketing materials, or on social media:

• Consent is obtained in writing from the parent/legal guardian and, where age-appropriate, the child;
• Children are not identified by full name;
• Locations are described at region level only;
• Images showing distress, nudity or medical treatment are not used;
• Consent can be withdrawn at any time and images will be removed;
• Records of consent are retained by the DSL.

13.3 Online and messaging conduct

Staff, participants and partners must not:

• Accept children or young people (under 18) as contacts on personal social media;
• Exchange personal phone numbers, email addresses, or messaging IDs with children;
• Engage in any private online communication with a child or their family.

All post-programme communication between participants and the communities they have visited takes place through official HeyLocals and partner channels only.

Staff and participants will be trained to recognise signs that a child may be being abused or neglected. A non-exhaustive list of indicators is provided in Appendix A. Key signs include:

• Unexplained or repeated injuries;
• Sudden changes in behaviour, withdrawal or aggression;
• Inappropriate sexualised behaviour or knowledge;
• Fear of specific adults or places;
• Poor hygiene, inappropriate clothing for weather, persistent hunger;
• Disclosure, whether direct, indirect or third-party.

Nobody is expected to diagnose abuse. The duty is to report a concern so that trained professionals can assess it.

15.1 The four Rs

RECEIVE — take any concern or disclosure seriously. Listen, stay calm, do not interrupt or ask leading questions.

REASSURE — reassure the child that they have done the right thing, but do not promise confidentiality: make clear that the information has to be shared to keep them safe.

RESPOND — do not investigate. Do not confront the alleged abuser. Do not delay.

RECORD AND REPORT — write down what was said, in the child’s own words where possible, with date, time and location. Report to the in-country coordinator and DSL within 1 hour for immediate risk, and within 24 hours for all concerns.

15.2 Reporting routes

Internal reporting routes are, in order:

1. In-country coordinator — immediate response and escalation on the ground.
2. Designated Safeguarding Lead (DSL) — overall coordination and decision-making.
3. Deputy DSL — if DSL is unavailable, or if the concern involves the DSL.
4. Administrators of ACL Travel S.r.l. — if the concern involves the DSL and Deputy DSL, or if there is a conflict of interest.

Confidential reporting channel for concerns that cannot be raised through line management:

• Email (confidential): [email protected]
• Phone and applicable availability during active placements: provided directly to every participant in their Pre-Departure Pack before travel

15.3 What happens next

• The DSL assesses the concern, usually within 24 hours.
• Immediate action is taken to safeguard the child.
• The concern is documented in the confidential safeguarding register.
• Referral to external statutory agencies is made where required (Section 17).
• The person reporting receives an acknowledgement, and, where appropriate, feedback on action taken.
• The child and their family are supported through the partner organisation.

DO:

• Stay calm and listen carefully;
• Take it seriously — even if it seems far-fetched;
• Allow the child to speak in their own words;
• Acknowledge what they have said;
• Explain what will happen next in age-appropriate language;
• Record as soon as possible, using the Concern Report Form (Appendix C).

DO NOT:

• Promise confidentiality;
• Ask leading questions (“Did X do Y to you?”);
• Investigate or interview the child;
• Confront the alleged abuser;
• Discuss the disclosure with anyone other than the DSL and, where applicable, statutory agencies.

17.1 In-country (host country) referrals

In every country in which HeyLocals operates, the in-country coordinator maintains an up-to-date local referral list, including:

• Local child-protection authority;
• Local police;
• Local child-safe helpline (where available);
• Nearest hospital;
• Embassy/consular contact for the participant.

Where a child is at immediate risk of significant harm, the first call is to the appropriate local statutory service.

17.2 Italian referrals

As ACL Travel S.r.l. is incorporated in Italy:

• Telefono Azzurro (child-abuse helpline): 19696
• Emergenza infanzia (Ministry of the Interior): 114
• Polizia di Stato — Polizia Postale (for online abuse, CSAM): commissariatodips.it · 113
• Carabinieri: 112
• Autorità garante per l’infanzia e l’adolescenza (AGIA): www.garanteinfanzia.org
• Procura della Repubblica (for reporting of offences under Art. 600-bis ff. Codice Penale);
• Garante per la protezione dei dati personali (for data-protection complaints): www.garanteprivacy.it.

17.3 UK referrals

Because HeyLocals is a UK-facing brand and many participants are UK citizens, concerns may also be reported in the UK:

• NSPCC helpline: 0808 800 5000 (or [email protected])
• Childline: 0800 1111
• UK Police: 999 (emergency) / 101 (non-emergency)
• Local Authority Children’s Services in the participant’s home area (where the concern relates to a UK child)
• LADO (Local Authority Designated Officer) — for allegations against a person in a position of trust in the UK
• Disclosure and Barring Service — to refer a person who has caused harm to children
• FCDO Consular Assistance: +44 20 7008 5000
• Information Commissioner’s Office (UK data-protection complaints): www.ico.org.uk

17.4 Offences committed abroad

Under the UK Sexual Offences Act 2003 (Part 1), UK nationals can be prosecuted in the UK for sexual offences against children committed anywhere in the world. Similarly, Art. 604 of the Italian Codice Penale provides for extraterritorial application of certain offences against minors. HeyLocals will cooperate fully with Italian, UK and in-country law-enforcement in the investigation of such offences.

17.5 For participants: reporting after you return home

If you have a concern that you did not feel able to raise during the placement, you can still report it when you return home. Contact the DSL or use the confidential email above. Concerns will be taken equally seriously whether raised during or after a placement.

Allegations are handled separately from general safeguarding concerns because of the specific risks involved (continued access to children, retaliation, reputational damage).

1. Receive the allegation using the same principles as any disclosure.
2. Refer to the DSL immediately. If the allegation is against the DSL, refer to the Deputy DSL or an administrator of ACL Travel.
3. Risk assessment within 24 hours: is the child safe? Should the subject of the allegation be removed from contact with children pending investigation?
4. External referral where the allegation crosses a threshold of possible criminal conduct, significant harm, or professional misconduct. Referrals are made to local police and child-protection authorities, and, for UK-based subjects, to the LADO and the DBS; for Italian-based subjects, to the Procura and any applicable professional body.
5. Investigation is carried out by the appropriate authority. HeyLocals does not conduct its own criminal investigation. It may conduct an internal conduct investigation after the external process concludes.
6. Interim measures (suspension, removal from project, reassignment) are protective, not disciplinary.
7. Support is provided to the child, the person reporting the allegation, and — where appropriate — the subject of the allegation.
8. Record keeping: a confidential record of the allegation, action taken, and outcome is retained by the DSL in line with data-protection rules.

Allegations made in good faith that are not substantiated will not be held against the reporter.

HeyLocals encourages all staff, participants, partners and members of the public to raise concerns about wrongdoing — including safeguarding failures — without fear of retaliation. We are subject to the Italian whistleblowing framework (D.Lgs. 24/2023, implementing EU Directive 2019/1937), which provides formal protection for reporters.

Whistleblowers can:

• Raise concerns directly with the DSL;
• Raise concerns confidentially through [email protected];
• Raise concerns with an external prescribed body (ANAC in Italy; NSPCC or police in the UK; ECPAT International).

No member of staff, participant or partner will be disadvantaged for raising a concern in good faith. Retaliation against a whistleblower is itself a disciplinary offence.

• Participants and children do not travel together, other than in group transport organised by the partner organisation with partner staff present.
• Private transport of children by participants is prohibited.
• Home-stays and host-family arrangements are assessed for safeguarding risk, including sleeping arrangements, supervision and the presence of children.
• Adult participants and child project beneficiaries never share sleeping accommodation.
• Mixed-gender dorms, shared bathrooms and cultural expectations are explained to participants before travel.

Safeguarding records are processed in accordance with Regulation (EU) 2016/679 (GDPR), the Italian Codice Privacy (D.Lgs. 196/2003 as amended) and, for data of UK residents, the Data Protection Act 2018 and UK GDPR.

• Records are held securely by the DSL in access-restricted systems.
• Access is on a need-to-know basis.
• Records are retained for a minimum of 7 years after the child reaches adulthood, or longer where required by local law or specific guidance.
• Records of referrals to statutory agencies are cross-referenced with the agency’s own record-keeping.
• Subject access requests are handled in consultation with the DSL and are not used to circumvent safeguarding confidentiality.
• Cross-border transfers of personal data are carried out under appropriate safeguards (Standard Contractual Clauses, adequacy decisions, or the lawful basis of “vital interests” under Art. 6(1)(d) GDPR, as applicable).

Our Privacy Policy sets out in full how personal data is handled. Any conflict between the Privacy Policy and this Safeguarding Policy is resolved in favour of the protection of the child.

Anyone — participant, parent, partner, child, community member, member of the public — can make a complaint about a safeguarding matter or about HeyLocals’ handling of a safeguarding matter.

How to complain:

• By email: [email protected]
• By post to our UK correspondence office: WeWork, Aviation House, 125 Kingsway, London WC2B 6NH, United Kingdom
• By post to our Italian registered office: ACL Travel S.r.l., Piazza Durante 24, 20131 Milano, Italy
• Via certified email (PEC, Italian residents): [email protected]
• Via the contact form on heylocals.co.uk

Complaints are acknowledged within 5 working days and responded to substantively within 30 calendar days.

If the complainant is not satisfied with the response, they may escalate to the administrators of ACL Travel S.r.l., and, where applicable, to external bodies (Garante Privacy, Autorità garante per l’infanzia e l’adolescenza, ICO, NSPCC, ECPAT, or the relevant in-country regulator).

• This policy is reviewed at least annually by the DSL and approved by the administrators.
• It is reviewed immediately after any significant safeguarding incident or any material change in law, partner or programme.
• The DSL reports to the administrators on safeguarding at least quarterly.
• Anonymised safeguarding data is summarised in an annual safeguarding report, made available on request and referenced in the Società Benefit relazione d’impatto annuale.

HeyLocals — internal

• Designated Safeguarding Lead: Andrea Tonetti · [email protected] · phone contact and applicable availability provided in the Pre-Departure Pack
• Deputy Designated Safeguarding Lead: Giovanni Sala · [email protected] · phone contact and applicable availability provided in the Pre-Departure Pack
• Legal representatives (legali rappresentanti): Andrea Tonetti and Giovanni Sala, ACL Travel S.r.l.
• Data Protection contact: [email protected]
• Confidential safeguarding email: [email protected]
• In-placement emergency contact and applicable availability: provided directly in the Pre-Departure Pack before travel
• PEC: [email protected]

Italy (external)

• Emergenza infanzia: 114
• Telefono Azzurro: 19696
• Carabinieri: 112
• Polizia Postale: www.commissariatodips.it
• Autorità garante per l’infanzia e l’adolescenza: www.garanteinfanzia.org
• Garante per la protezione dei dati personali: www.garanteprivacy.it

UK (external)

• NSPCC Helpline: 0808 800 5000 / [email protected]
• Childline: 0800 1111
• Emergency police: 999
• Non-emergency police: 101
• DBS: 03000 200 190
• FCDO Consular Assistance: +44 20 7008 5000
• Information Commissioner’s Office: www.ico.org.uk

International

• ECPAT International: [email protected]
• Child Helpline International: www.childhelplineinternational.org
• INHOPE (online CSAM reporting): www.inhope.org

In-country contacts for each destination are maintained by the in-country coordinator and published in the participant’s destination-specific Pre-Departure Pack.

This list is not exhaustive. The presence of one or more indicators does not in itself confirm abuse, but should prompt further attention and, where appropriate, reporting.

Physical abuse

Unexplained bruises, burns, fractures or bite marks; bruises in a pattern suggestive of an implement; injuries on parts of the body not normally injured in play; reluctance to change clothes or to be touched; fear of a specific adult; flinching at sudden movement; inconsistent explanations of injury.

Emotional abuse

Low self-esteem; extreme passivity or aggression; developmental delay; inability to form relationships; persistent anxiety; self-harm; attachment difficulties; lack of normal emotional response.

Sexual abuse

Sexualised behaviour or language inappropriate for age; knowledge of adult sexual behaviour; genital or urinary symptoms; unexplained pregnancy or STI; fear of specific adults; reluctance to undress; drawings, writings or play with sexual content.

Neglect

Persistent hunger; poor personal hygiene; inappropriate clothing for weather; untreated medical or dental conditions; frequent lateness or absence from school; being left alone or in the care of unsuitable people; tiredness.

Exploitation

Unexplained gifts, money, phones, clothes; association with older individuals or groups not known to family; frequent unexplained absences; involvement in criminal activity; signs of substance use; evidence of being moved around.

Online abuse

Secretive use of the internet; sudden receipt of gifts or money; emotional withdrawal after being online; older “friends” contacting the child online.

Institutional abuse

A setting in which children are consistently humiliated, harshly disciplined, kept in poor physical conditions, denied freedoms normal for their age, or in which staff behaviour goes unchallenged.

To be signed by every staff member, participant and partner personnel member before any contact with children.

I, [FULL NAME], acting as [ROLE: staff / participant / partner staff / visitor] with HeyLocals (ACL Travel S.r.l. Società Benefit), confirm that I have read, understood and agree to abide by:

1. The HeyLocals Safeguarding & Child Protection Policy, in particular the Code of Conduct set out in Section 8;
2. My personal duty to report any safeguarding concern without delay, through the routes set out in Section 15;
3. The “two-adult rule” and minimum-contact standards for physical contact;
4. The rules for photography, social media and online conduct set out in Section 13;
5. The rule that I will never exchange personal contact details with, or continue post-programme private contact with, any child I meet through the programme;
6. The rule that I will not visit any orphanage, children’s home or residential-care setting outside of the official programme;
7. The rule that I will not give money, gifts or favours to individual children or make promises I cannot keep;
8. The consequences of breach, including immediate removal from the programme, referral to statutory authorities, and a lifetime ban from HeyLocals and partner programmes.

I confirm that I have disclosed any relevant criminal conviction, caution or safeguarding allegation (spent or unspent) on my Safeguarding Self-Declaration form, and that I understand that failure to do so will be treated as gross misconduct / material breach of contract.

Complete as soon as possible after the event. Use the child’s own words where possible. Stick to facts, not interpretations. Hand the completed form to the DSL or in-country coordinator immediately. Keep copies confidential.

• Date and time of report:
• Reporter’s name and role:
• Date, time and location of the concern/incident:
• Name, age and gender of the child (if known):
• Parent/guardian (if known):
• Partner organisation:
• Nature of concern: [direct disclosure / observed behaviour / third-party report / allegation against staff-participant / other]
• Factual description of what was seen, heard or reported: (Attach a second sheet if needed. Distinguish clearly between what was directly observed and what was reported by someone else.)
• Child’s own words (verbatim where possible):
• Who else was present:
• Action taken so far:
• Who has been informed:
• Signature of reporter:
• Received by DSL / in-country coordinator — name, signature, date/time:
• DSL follow-up log (to be completed by DSL only):

1. Concern arises — you see, hear, or are told something that makes you concerned about a child’s welfare or about the conduct of a member of staff, participant or partner.
2. If the child is in immediate danger — call local emergency services first, then inform the in-country coordinator.
3. If not in immediate danger — inform the in-country coordinator within 1 hour and complete the Concern Report Form (Appendix C) within 24 hours.
4. The in-country coordinator notifies the DSL within 24 hours and secures the immediate welfare of the child.
5. The DSL within 24 hours of notification carries out an initial risk assessment, decides on interim protective measures, and determines whether an external referral is needed.
6. External referral is made without delay where the threshold is met — to local statutory services first and, where relevant, to Italian and UK authorities.
7. The DSL keeps all parties (child/family via partner, reporter, administrators) appropriately informed throughout, records the concern, and monitors the case to conclusion.
8. After closure, a lessons-learned review is carried out for every substantiated concern, and policy/procedure is updated where needed.