Policy Number: AUS-090301.001.001
Sponsor: Office of the Executive Vice President
Effective Date: September 3, 2021
I. POLICY RATIONALE
The American University of Science (AUS) recognizes the duty to create a community of care for all AUS community members and to promote and safeguard the welfare of its students, faculty, and staff, and third parties involved in AUS activities. AUS commits to taking appropriate measures and action to prevent the risk of suffering significant harm for any AUS community member and to comply with the duty to protect minors, that is, the applicable legislation as in effect from time to time. In doing so, discrimination against individuals or groups based on sex, gender and/or gender identity or expression, sexual orientation, disability, age, race, ethnicity, color and membership of a national minority, nationality or national origin, creed, religion or belief, social origin, birth and property, language, political or other opinion, pregnancy, genetic information, marital status, citizenship status, veteran or military status, or on any other legally prohibited basis is unlawful and will not be tolerated. AUS acknowledges that, particularly in multicultural communities, discrimination on any of the aforementioned bases may result in the vulnerability of individuals and groups and is committed to assessing and taking steps to ensure the appropriate campus climate at AUS. Safeguarding concerns about the safety and well-being of minors or vulnerable adults who are members of the AUS community or associated with students, faculty, and staff may arise, and this policy defines how these are to be addressed and decided upon.
II. POLICY APPLICABILITY
1. The policy applies to:
1.1. All current and prospective students under 18 years old. The fact that a minor is living independently or is in higher education does not change their status for this policy.
1.2. Vulnerable adults registered as students or prospective students. Vulnerable adults are persons aged 18 or over who are, or maybe, in need of services because of mental or other disability, age, or illness and who are, or maybe, unable to take care of themselves or protect themselves against significant harm, abuse, or exploitation.
1.3. Employees (faculty and staff) in their duties.
2. The Policy does not apply to:
2.1. Students or any AUS community member experiencing mental health difficulties who may pose a risk of harm to themselves or others but are not vulnerable. Provision for addressing such incidents is made in the AUS First Aid Protocols and the AUS SEPP.
III. POLICY PURPOSE
1. AUS is committed to safeguarding students, faculty, and staff, as well as third parties involved in its activities, to maintaining a campus ethos of mutual respect, care, and responsible action, and to providing a safe learning environment where all students can learn and develop.
2. The policy particularly applies to current and prospective students under 18 years old and vulnerable adults registered as students or prospective students as well as children/vulnerable adults connected to AUS directly or indirectly.
3. This policy aims to ensure that students and all AUS community members are equipped with information and an understanding of AUS’s responsibilities for safeguarding, safeguarding, radicalization, extremism and an awareness of keeping safe; to maintain clear procedures to identify students who are at risk of harm to self or others, are suffering or likely to suffer, and to report suspected cases of abuse; to establish clear referral protocols for students, especially minors, that go missing to help identify the risk of abuse or neglect and prevent the risk of repeated occurrences; to ensure that designated AUS employees are appointed to promote the welfare of students; to support appropriately students who have suffered significant harm and to employees involved in safeguarding; create a culture of safer employee recruitment by adopting recruitment procedures that help deter, reject or identify people who might abuse others; establish procedures for reporting abuse against faculty or staff, and dealing with such allegations; care for students who have been abused; ensure all members of the AUS community, in particular faculty and staff, receive safeguarding training appropriate to their roles; monitor and review this policy and safeguarding practices and activities.
4. This policy is part of a suite of documents and policies that outline AUS's safeguarding responsibilities. Its purpose is to ensure clarity and consistency in carrying out these responsibilities.
IV. POLICY STATEMENT
A. Definition of Safeguarding
1. The term “safeguarding” describes the broader preventative and precautionary approach to planning and procedures that are necessary to be in place to protect employees/volunteers/students from any potential harm or damage.
2. Safeguarding means:
Protection from abuse and neglect
Promotion of health and development
Ensuring safety and care
3. In order to retain necessary flexibility in the implementation of policies and procedures, AUS reserves the right to change, revise, or withdraw any of the policies and/or benefits described here. The only recognized deviations from the stated policies are those authorized and signed by AUS’s Executive Vice President.
B. Definition of Vulnerable Groups
1. Employee: The term “employee” describes an individual at the age of 18 years or over who works part-time or full-time under a contract of employment with AUS and has recognized rights and duties.
2. Volunteer: The term “volunteer” describes an individual under or over the age of 18 years who actively takes on a task, responsibility, or project of AUS under supervision and is not paid for the work that he/she provides. Volunteers may be Anatolia students or individuals who participate in internships, financial aid or fellowship programs.
3. Student: The term “student” is defined as any person, male, female or of other gender identities under or over the age of 18 years who attends any of AUS’s academic or non-academic programs.
C. Categories of Abuse
1. Financial or material abuse - including theft, fraud, internet scamming, coercion concerning an adult's financial affairs or arrangements, including in connection with wills, property, inheritance, or financial transactions, or the misuse or misappropriation of property, possessions, or benefits.
2. Physical abuse - including assault, hitting, slapping, pushing, misuse of medication, restraint, or inappropriate physical sanctions.
3. Neglect and acts of omission - including ignoring medical, emotional, or physical care needs, failure to provide access to appropriate health, care, and support or educational services, and withholding the necessities of life, such as medication, adequate nutrition, and heating.
4. Sexual abuse - including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure, and sexual assault, or sexual acts to which the adult has not consented or was pressured into consenting.
5. Psychological abuse - including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyberbullying, isolation, or unreasonable and unjustified withdrawal of services or supportive networks
6. Organizational abuse – such as through neglect or poor professional practice due to the structure, policies, processes, and practices.
7. Discriminatory abuse - including forms of harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation or religion.
8. Self-neglect - covering a wide range of behaviors such as neglecting to care for personal hygiene, health, or surroundings and includes behavior such as hoarding.
9. Domestic abuse - including psychological, physical, sexual, financial, emotional, or so-called “honor”-based violence.
10. Modern slavery - encompasses slavery, human trafficking, forced labor, and domestic servitude. Trafficking and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude, and inhumane treatment
11. All employees/volunteers/students at AUS have to care for and report when identifying any other employees/volunteers/students that may be experiencing or at risk of experiencing abuse or harm at AUS or elsewhere and take the relevant action to ensure their safety. This includes all staff reporting allegations of abuse against another member of staff as set out in the procedures.
12. AUS acknowledges that information concerning abuse provided to staff is a sensitive and crucial issue so as to identify welfare concerns and indicators of possible abuse at an early stage. It is not the responsibility of any member of staff at the AUS to investigate suspected cases of abuse; rather, all cases that take place within the AUS must be referred to the Director of Human Capital in case of an employee or volunteer and to the Dean/Director/Leader of the Program in case of a student. The Director of Human Capital or the Dean/Director/Leader of the Program will decide if external referrals are required and inform the next higher management level of the area. In case of the absence of the Director of Human Capital, the deputy safeguarding lead is the Head of Internal Affairs. In case of the absence of the Dean/Director/Leader of the Program, the deputy safeguarding lead is the deputy Dean/Director/Leader of the Program or appropriate personnel.
13. AUS wants all students to feel confident that their concerns will be taken seriously and that disclosures to any member of staff will be treated in a sensitive manner.
D. Responsibility
1. Individuals who have been designated as safeguarding officers include the Director of Human Capital, the Dean/Director/Leader of the Program, Executive Vice President, and other personnel who have been appropriately appointed to this role. Designated safeguarding officers to whom these incidents are reported are expected to:
1.1. Refer cases of suspected abuse or radicalization to the local authorities as required.
1.2. Refer cases where a crime may have been committed to the police as required.
1.3 Liaise with employees on matters of safety and safeguarding and act as a source of support, advice, and expertise for the AUS community.
2. Responsible employees are required to report incidents involving AUS students or any other community member or third party without delay, are:
2.1. ALL faculty.
2.2. ALL administrators/staff in supervisory positions, including supervisors of student employees (student assistants and on-campus interns).
2.3. ALL administrators/staff who have specific responsibility for the welfare of students or employees, such as campus security and senior staff.
2.4. Instructors, teaching assistants, coaches, advisors, and program counselors who teach, advise, coach, or mentor students.
3. Confidential resources at AUS are:
3.1. For Students: The General Counseling provides confidential short-term emotional support, and ongoing individual counseling, and helps students access further off-campus resources and support teams, including hotlines and psychological support/psychiatric care.
3.2. For Faculty and Staff: The leader of General Counseling, providing professional confidential short-term emotional support to faculty/staff, and helping faculty/staff access further off-campus resources and support teams, including hotlines and psychological support/psychiatric care.
4. AUS ensures that the staff is checked for criminal convictions before hiring. Staff undertakes training on an annual basis to ensure that they are kept up-to-date with all of AUS's policies and procedures. Furthermore, AUS circulates the existing and new policies from time to time, including the safeguarding policy, to remind the staff about the existing policies and inform them about the new ones. All AUS staff are responsible for providing a safe environment where individuals can learn and develop themselves. Staff are particularly well placed to observe outward signs of abuse, changes in behavior, and failure to develop because they have daily contact with children.
5. The Executive Vice President and the Dean of the Program take lead responsibility for safeguarding and the protection of minors at AUS, including online safety, and act as designated safeguarding officers for AUS. The designated safeguarding officers are responsible for ensuring safeguarding concerns reported to them are processed and referred to as appropriate. designated safeguarding officers are not responsible for making judgments about safeguarding concerns. Information and data received as part of reports of safeguarding concerns are handled in confidence, on a need-to-know basis, and per the provisions of the applicable legislation on personal data as in effect from time to time. The consent of a subject of a safeguarding concern is sought when possible or appropriate before sharing information with an external agency, such as social services or the local authorities.
6. Temporary staff and volunteers will be made aware of the safeguarding policies by the Office of Human Capital and the relevant Director. Staff should consider how students may be taught about safeguarding, including online and through teaching and learning opportunities, as part of providing a broad and balanced curriculum. Staff are advised to maintain an attitude of “it could happen here” where safeguarding is concerned. When concerned about the welfare of a student, staff members should always act in that student's interests.
7. When an employee/volunteer has disclosed abuse or a staff member has concerns about abuse, no contact should be made with any other member without consultation with the Director of Human Capital.
8. Where a student has disclosed abuse or a staff member has concerns about abuse, no contact should be made with any other member without consultation with the Dean/Director/Leader of the Program.
9. Third parties to whom the Policy applies may report incidents to campus security.
10. Anonymous reporting occurs when the complainant does not disclose their name or identity or that of other parties involved nor requests any action by AUS. Action by AUS shall depend on the nature of the information shared. The privacy of individuals shall be protected to the extent permitted by law and this policy. Individuals who are survivors/victims of abuse have the right to request protection and confidentiality regarding their name or identity. Information conveyed through anonymous reporting assists AUS and the police in tracking patterns of prohibited conduct and crime and may assist other similar investigations.
11. In case of a simple issue, a support plan will be made and monitored by the Director of Human Capital or the Dean/Director/Leader of the Program. Simple issues include information, guidance, and support without immediate risk of significant harm. In any other case where there is an immediate risk of significant harm, the general administration of AUS should be informed by the Director of Human Capital or the Dean/Director/Leader of the Program to proceed to immediate action to protect the individual. If this is the case, support of legal advising and/or medical assistance is involved.
12. Allegations against faculty or staff Allegations of abuse involving a member of the faculty or staff will be taken seriously by AUS.
E. PROCEDURES
1. Actions to be taken in case of a safeguarding concern about a student, especially a minor
1.1 Suppose AUS faculty or staff have any concerns about a student’s welfare. In that case, they should follow this policy and contact the designated safeguarding officers immediately and complete an Incident Report Form, including ‘Safeguarding Alert’ in the description of the incident and provide as much detail as possible.
1.2 Early information sharing is vital for effectively addressing a safeguarding concern.
1.3 Whether the incident or conduct triggering concern is disclosed in a conversation, written assignment, or posting on a forum, an AUS community member is expected to:
Listen calmly.
Respect the right to privacy but do not promise confidentiality.
Reassure the person that they have done the right thing to share this information.
Note down, as soon as possible, the exact words used to describe the incident that triggered the safeguarding concern.
Contact campus security if a minor/young person/vulnerable adult is in possible immediate danger.
2. Actions to be taken in case of immediate danger or is at risk of harm to a minor
If a student is in immediate danger or is at risk of harm a referral should be made to the student’s declared emergency contact person and/or the police immediately. University Policies prescribe the appropriate communication channels for such referrals by the Dean of the Program.
3. Actions to be taken in case of suspicion that an employee/volunteer/student is being abused or harmed
3.1. You may have concerns that an employee/volunteer/student is experiencing abuse because of their behavior or changes in their presentation or that they are missing from AUS.
3.2. If you suspect that an employee/volunteer is being abused or harmed:
3.2.1. Discuss the issue with the Director of Human Capital privately. If the Director of Human Capital considers it a safeguarding issue, he/she shares a concern with the Executive Vice President.
3.2.2. Staff receiving safeguarding concerns should not investigate or attempt to resolve the concern. The Director of Human Capital should make all external referrals. The Director of Human Capital will inform the employee/volunteer of the safeguarding outcome.
3.3. If you suspect that a student is being abused or harmed:
3.3.1. Discuss the issue with the Dean/Director of the Program in a private area. Suppose the Dean/Director of the Program considers it a safeguarding issue. In that case, he/she shares the concern with the Executive Vice President of a certain area and, if necessary, with a counselor or doctor.
3.3.2. Staff receiving safeguarding concerns about students should not investigate or attempt to resolve the concern. The Dean/Director should make all external referrals of the Program. The Dean/Director of the Program will keep the student informed of the safeguarding outcome.
3.4. If you are an employee/volunteer being abused or harmed:
3.4.1. Discuss the issue with the Director of Human Capital privately. If the Director of Human Capital considers it a safeguarding issue, he/she shares concerns with the Executive Vice President.
3.4.2. Staff receiving safeguarding concerns should not investigate or attempt to resolve the concern. The Director of Human Capital should make all external referrals. The Director of Human Capital will inform the employee/volunteer of the safeguarding outcome.
3.5. If you are a student being abused or harmed:
3.5.1. Discuss the issue with a counselor or doctor privately. If the counselor or doctor considers it a safeguarding issue, then he/she shares a concern with the Dean/Director/Leader of the Program.
3.5.2. A support plan will be made and monitored by the Dean/Director/Leader of the Program in case of a simple issue. Simple issues include information, guidance, and support on concerns without immediate risk of significant harm.
3.5.3. The Dean/Director/Leader/Leader should make all external referrals and communications of the Program. The General Counseling will keep the student informed of the safeguarding outcome.
4. Actions to be taken in case an employee/ volunteer informs another employee that he/she experiences/experienced harm/abuse
If an employee/volunteer shares with you that he/she had/has an experience of harm/abuse:
4.1. Respond calmly and listen carefully to what he/she is telling you. Try not to appear shocked or show disapproval. It can be very difficult for someone to talk about their abuse.
4.2. Explain that you cannot keep total confidentiality on such matters and may need to speak to the Director of Human Capital.
4.3. Do not discuss the disclosure with anyone other than the Director of Human Capital, only if the employee/volunteer allows you to.
4.4. find a quiet area to speak where you will not be interrupted. Do not put him/her off talking by asking him/her to meet later.
4.5. Encourage the employee/volunteer to discuss the incident with the Director of Human Capital.
4.6. An employee/volunteer may disclose information that leads to concerns that another person is experiencing abuse. You must inform the employee/volunteer that you must tell the Director of Human Capital and encourage him/her to do the same.
4.7. You may be contacted by the Director of Human Capital requesting information about an employee/volunteer who has discussed an incident of abuse/harm with you.
4.8. If you continue to be concerned about the employee/volunteer after informing the Director of Human Capital, contact the Office of Human Capital again to let them know.
5. Actions to be taken in case a student informs an employee that he/she experiences/experienced harm/abuse by an employee
If a student shares with you that he/she had/has an experience of harm/abuse:
5.1. Respond calmly and listen carefully to what he/she is telling you. Try not to appear shocked or show disapproval. It can be very difficult for someone to talk about their abuse.
5.2. Explain that you cannot keep total confidentiality and may need to speak to the counselor/doctor.
5.3. Do not discuss the disclosure with anyone other than a counselor or doctor, only if the student allows you to.
5.4. find a quiet area to speak where you will not be interrupted. Do not put him/her off talking by asking him/her to meet later.
5.5. Encourage the student to talk to a counselor or doctor about the incident since it is the only way to solve it.
5.6. A student may disclose information that leads to concerns that another student is experiencing abuse. You must inform the student that you must tell the counselor and encourage him/her to do the same.
5.7. You may be contacted by a counselor or doctor requesting information from you about the student who has discussed an incident of abuse/harm with you.
5.8. If you continue to be concerned about the student after you have informed a counselor or doctor, contact a counselor or doctor again to let them know.
In reporting, the individual should fill in the Safeguarding Reporting Form (Appendix 1).
This policy includes an easy-to-follow flowchart for staff and students (Appendix 2).
6. Record Keeping
Safeguarding concerns and decisions made, and the reasons for those decisions, should be recorded in writing. The Office of the Executive Vice President, the Dean of the Program and the Office of Academic Affairs are responsible for guiding AUS community members through the incident reporting process and keeping records on AUS’s record-keeping platform. Incidents reported to campus security shall be forwarded to the Office of the Executive Vice President. When it comes to students who are still minors at the time of admission, AUS will aim to collect more than one emergency contact numbers so as to ensure that contacting a responsible adult will be possible in case of safety/safeguarding concerns.
7. Confidentiality
7.1 Records kept will be stored confidentially in AUS’s record keeping platform (servers are within AUS). The storage of personal data records by AUS is a classified activity and, as such, is conducted by specifically authorized employees and executives of AUS. The appropriate technical and security measures have been taken to ensure that non-authorized persons do not have access to the stored records, such as password protected computers with block entry to anyone who does not have a password.
7.2 AUS employees (faculty and staff) must not, under any circumstances, discuss or disclose information to any person other than those immediately involved in any safeguarding issue. All AUS employees are bound to absolute secrecy regarding personal data and are fully cognizant of all the stipulations of the law and all the procedures, terms and conditions pertaining to compliance with any applicable data protection legislation, including with respect to the legal storage and processing of personal data.
8. Information Sharing
Information sharing between AUS and local authorities is important when addressing safety/safeguarding concerns. Such communication, when necessary, with local authorities is undertaken solely by the Executive Vice President, the Dean of the Program, and campus security. Faculty and staff are expected to be proactive in sharing information as early as possible with the responsible officers to help identify, assess and respond to risks or concerns about the safety and welfare of students or AUS community members. Information sharing involves the release only of information vital to the safeguarding and in accordance with the provisions of any applicable data protection legislation.
8. Online Safety
8.1. Information security and online safety at AUS is integral to all aspects of its operation and extra effort is made for the protection of information from unauthorized access, disclosure, disruption, modification or destruction. Measures and policies are in place to ensure the preservation of confidentiality, integrity and availability of AUS data.
8.2. More specifically, the following measures are in place:
Regularly undertakes risk assessments in order to create a risk register, evaluate the design and effectiveness of controls and plan for possible improvements.
Established additional procedures and controls in order to provide a higher level of security in the ways departments and offices handle data.
Conducts Business Impact Analysis exercises, to help AUS identify critical activities and operations of AUS Divisions / Departments and the requirements in relation to the availability of AUS IT services, resources and infrastructure in case of negative incidents.
Continuous update of the official security policies that are part of AUS information security framework. Systems protection is provided at multiple levels using the following technical measures:
All Servers, PC's and Clients have Antivirus Clients that protect against the latest in (Virus, Malware, Cryptolocker software etc.). Clients have Trend Micro Antivirus installed and Servers have Cisco Antivirus installed.
The school uses a AUS wide password policy that affects students, faculty, staff and contractors. All passwords must be strong and must change every 180 days.
Access to systems is controlled and authorized by the respective data owner.
At the central firewall level with two enterprise firewalls installed in failover mode and the required plugins for antivirus, content filtering, antimalware and application control (centrally control which Internet based applications are permitted to run).
Protection from outside attacks to AUS systems is provided at different level through:
8.3. Taking into account todays continuous increase in IT threats, risks and vulnerabilities, no protection solution can be considered 100% secure and AUS is continuously seeking and investing on the latest protection technologies.
8.4. The protection of critical information (although it plays an important role) is not the sole responsibility of the IT department, and is essentially an interdisciplinary team approach where a large number of non-IT related people must act in an appropriate way. Since the use of information technology is an essential requirement for all businesses today, appropriate awareness efforts have been designed in such a way to support the needs of the AUS community who are interested in learning how to protect their personal and corporate information resources.
8.5. Educational institutions find themselves stuck in a maze as they attempt to modify their security posture and deploy new tools for mitigating the latest hacks. At the same time, adversaries are coming up with ways around the security defences. Hence, security defences can only protect data to a certain extent. No matter how robust a higher education institute’s cybersecurity software may be, its end users would lead the line of defence during an attack.
8.6. The protection of confidential information is vital for every organization and even more vital for academic institutions –like AUS– that shape student personalities and prepare people for the workforce. For that reason, appropriate security awareness training campaigns, complemented by online courses have been established. Their purpose is to develop competence and school culture that saves money and creates a human firewall guarding against an ever increasing threat of reputational and actual damage and data loss.
8.7. The campaigns are targeted towards the following broad categories complemented by appropriate short training:
Security essentials
Email
Internet and safe browsing
Working at the online office
Working out of the office - Mobile threats
Social awareness
Guarding personal information
9. Staff Training
9.1. AUS is committed to ongoing training, prevention and awareness-raising to disseminate the Policy to students (orientations, study abroad pre-departure orientation sessions, co-curricular programming, online materials, newsletters, on-campus campaigning incl. information posters, graphics, stickers and Facebook ads), faculty and staff. Trainings to proactively address safety and safeguarding concerns take lace at least twice yearly.
9.2. Indicative training and awareness-raising topics for AUS Employees include: response to radicalization and crime; response to an incident of active shooting; strategies/role plays to respond to individuals – especially minors – in crisis; working with survivors from marginalized and/or multicultural populations; self-care for notification personnel; collaboration between AUS and Prosecutor on cold cases; victim advocacy and support services; victim notification procedures; explaining forensic science in layman’s terms; intersection of the policy with other AUS policies; special emergency response training for AUS healthcare practitioners.
