1. Our Commitment

Promoting Queens is deeply committed to the safety, dignity, and wellbeing of every child and young person who participates in our programs. This commitment applies across all our programs and operations — regardless of country, program type, partner organisation, or delivery method.

We believe every child has the right to be protected from harm. This is not a legal obligation we fulfil reluctantly — it is the foundation of the trust placed in us by the girls, families, schools, and communities we serve.

2. Scope — Who This Policy Covers

This policy protects all participants under the age of 18 in any Promoting Queens program, all young women and girls of any age in contexts where there is a power imbalance or vulnerability, and all online participants in digital chess sessions, scholarship programs, and master instructor sessions.

A child is defined as any person under the age of 18, consistent with the UN Convention on the Rights of the Child. Where local law defines a higher age of majority, the higher threshold applies.

Parental or guardian consent is required for all participants under 18, without exception. A participant aged 16 or 17 may not consent on their own behalf for the purposes of this policy, regardless of local legal variations.

This policy applies to:

• All Promoting Queens staff, volunteers, coaches, consultants, and contractors.
• All programs, events, outreaches, and online sessions run by or affiliated with Promoting Queens.
• All partner organisations delivering programs on our behalf.
• All countries in which Promoting Queens currently operates or will operate in future.

3. Designated Safeguarding Lead (DSL)

The Designated Safeguarding Lead is the named individual responsible for receiving safeguarding concerns, deciding on action, and liaising with relevant authorities. All concerns must be reported to the DSL immediately.

Our current DSL is Perpetual Ogbiyoyo, Founder and Executive Director. She can be reached at safeguarding@promotingqueens.org.

• Receiving and acting on all safeguarding concerns.
• Maintaining confidential records of all concerns and actions taken.
• Ensuring this policy is implemented consistently across all programs and countries.
• Liaising with local child protection authorities when required.
• Updating the Country Annexes when Promoting Queens expands to a new country.
• Ensuring all staff and volunteers have read and confirmed this policy.

The DSL is responsible for:

4. Understanding Harm

Promoting Queens recognises and is committed to preventing the following categories of harm:

• Physical abuse — any form of physical harm including hitting, shaking, or inappropriate restraint.
• Emotional abuse — persistent mistreatment, humiliation, threats, or undermining of a child’s confidence.
• Sexual abuse — any sexual activity involving a child, or exposure to sexual material or behaviour.
• Neglect — failure to meet a child’s basic physical or emotional needs.
• Online abuse — grooming, exploitation, or inappropriate contact through digital platforms.
• Bullying and harassment — persistent behaviour intended to intimidate, degrade, or exclude.
• Positions of trust abuse — any sexual relationship between a Promoting Queens representative and a participant under 18 is prohibited regardless of local age of consent laws.

5. Safe Recruitment and Vetting

• All new staff and volunteers complete an application process including reference checks.
• Interviews for roles involving direct contact with children include safeguarding-specific questions.
• All staff and volunteers receive and confirm this policy before beginning any role.
• Any individual with a known history of harm to children will not be permitted to work with Promoting Queens.
• Where background check systems are available in the country of operation, Promoting Queens will use them.
• All staff and volunteers complete safeguarding awareness training before working with participants.
• The DSL completes formal safeguarding training and refreshes this annually.
• All external contractors, freelance coaches, and master instructors are required to sign a Contractor Safeguarding Declaration before any contact with participants.

6. Code of Conduct

Everyone working with Promoting Queens will always:

• Treat all participants with dignity, respect, and fairness regardless of background.
• Work in open environments — avoid one-to-one situations with children out of sight of others unless following the approved one-to-one session structure.
• Communicate with children in age-appropriate, respectful language.
• Report any concern about a child’s welfare immediately to the DSL.
• Obtain appropriate consent before photographing or filming participants.
• Maintain professional boundaries at all times.
• Ensure all contact with participants relates only to Promoting Queens program activities.

And will never:

6b. Prohibited Conduct

• Engage in any form of physical punishment or intimidation.
• Develop personal, romantic, or sexual relationships with participants of any age.
• Use alcohol or illegal substances when responsible for participants.
• Transport a child alone in a vehicle without documented parental or guardian consent.
• Share photographs or personal information of participants without appropriate consent.
• Promise confidentiality to a child making a disclosure.

7. Social Media and Communication

All contact between staff, volunteers, coaches, and participants must relate only to Promoting Queens program activities. This applies regardless of the channel used — phone, message, email, or social media.

• Official Promoting Queens social media accounts may feature participant content only with documented consent.
• Any communication that feels inappropriate or makes a participant uncomfortable must be reported to the DSL immediately.
• Staff and volunteers must not use their personal access to participants for purposes unrelated to PQ programs.

8. Photography, Media, and Data Protection

On consent:

• Written consent is obtained from a parent or guardian for participants under 18 before any photograph or video is used publicly.
• Direct consent is obtained from adult participants.
• Consent forms explain clearly how content will be used — website, social media, donor reports, grant applications.
• Photographs of participants may include full names where parental or guardian consent has been given; consent forms must specify that names may be used publicly alongside images.
• Consent may be withdrawn at any time — content will be removed within 30 days of a written withdrawal request.
• At group events, participants and attendees are asked not to photograph or film other participants without their consent.

On storage and use: personal data is stored securely and used only for program purposes. Promoting Queens will not sell or share participant data with third parties. Data is retained only as long as necessary for program delivery and legal compliance, and safeguarding records are retained for a minimum of 7 years or until the child reaches the age of 25 — whichever is longer. Where participant data crosses international borders — for example, a participant in Nigeria or Kenya joining an online session administered from the US — Promoting Queens takes reasonable steps to ensure data is handled lawfully across all relevant jurisdictions. Country-specific data protection laws are referenced in the Country Annexes; where local law requires stricter standards than this policy, the stricter standard applies.

9. Online Safety

• All group online sessions are facilitated by a named Promoting Queens representative.
• Participants are not permitted to share personal contact details in group sessions.
• Sessions are not recorded without explicit consent from participants and guardians.
• Inappropriate behaviour results in immediate removal and review by the DSL.
• All external instructors and master coaches must sign a Contractor Safeguarding Declaration before any contact with participants.
• Minimum age for online program participation is 13 years. Participants under 13 require specific written parental consent and a parent or guardian must be present or available during the session.

One-to-one online training for talented or advanced participants is permitted only when the session is scheduled in advance and logged with the DSL, a parent or guardian is informed the session is taking place, the session is conducted on an approved platform with a record of the conversation, video is on for both parties throughout, and any discomfort or concern is reported to the DSL immediately.

10. Allegations Against Staff or Volunteers

• The individual is immediately suspended from all contact with participants pending investigation.
• If the concern involves the DSL, the most senior available board member or trusted adviser acts instead.
• The concern is referred to relevant local authorities as required by the Country Annex.
• Records of the concern and all actions taken are maintained securely.
• The individual under investigation is not informed of details that could compromise the investigation or put a child at risk.
• Promoting Queens cooperates fully with any statutory investigation.

11. Whistleblowing Protection

Anyone who raises a safeguarding concern in good faith will be fully protected. Promoting Queens will not penalise, dismiss, demote, or otherwise disadvantage any staff member, volunteer, or partner for raising a genuine concern about a child’s welfare — even if that concern turns out to be unfounded.

If anyone feels they cannot raise a concern internally — for example, because the concern involves the DSL — they should contact the relevant local child protection authority directly. Contact details are in the Country Annexes.

12. How to Report a Concern

Report immediately. You do not need to be certain that abuse has occurred. If something feels wrong, report it.

The three-step process:

• Contact the DSL. Email safeguarding@promotingqueens.org immediately. If the situation is urgent, contact local emergency services first, then notify the DSL.
• Record. Write down exactly what you observed, heard, or were told — using the child’s own words where possible. Note the date, time, and any witnesses. Do not investigate yourself or promise confidentiality.
• DSL acts. The DSL assesses the concern, consults relevant parties, and determines whether to refer to local child protection authorities. All concerns are taken seriously and documented.

Country-specific reporting authorities and contact details are in the Country Annexes below.

13. Responding to a Disclosure

• Listen carefully and stay calm.
• Take what the child says seriously.
• Do not promise to keep secrets — explain you may need to tell someone to keep them safe.
• Do not ask leading questions — let the child speak in their own words.
• Reassure the child they are not in trouble and that you are glad they told you.
• Report to the DSL immediately after the conversation.
• Record the conversation as accurately as possible using the child’s exact words.

14. Record Keeping

• Promoting Queens maintains two categories of record: a Concern Log for matters that raised worry but may not constitute abuse, and an Incident Log for matters that crossed a clear safeguarding threshold and required formal action.
• All entries are recorded in writing by the DSL within 24 hours.
• Records include: date, nature of concern or incident, action taken, outcome, and follow-up.
• Records are stored securely — accessible only to the DSL and, where required, statutory authorities.
• Safeguarding records are retained for a minimum of 7 years, or until the subject child reaches 25 — whichever is longer.
• Records are never shared with unauthorised parties.

15. Consent and Registration

Promoting Queens collects consent as part of the registration process for all programs — both online and in-person events. Registration forms include:

• Program participation consent — signed by parent or guardian for participants under 18.
• Photography and media consent — specific to public use of images and stories, including use of full names.
• Data use consent — explaining how personal information is stored and used, including cross-border transfers.

Registration and consent forms are available in English and in local languages where required. Completed forms are retained securely by the DSL for the duration of the program plus 7 years. When a participant ends their involvement, the DSL is notified and the participant is removed from active communication lists; their records are archived securely and retained for the required period, and any consent previously given for use of photographs or stories remains valid unless the participant or their guardian formally withdraws it.

16. Participant Wellbeing and Mental Health

Promoting Queens works with girls and women in underserved communities who may be experiencing poverty, family instability, trauma, or other significant challenges. Our staff and volunteers are not mental health professionals and must not attempt to provide counselling or therapy.

• If a participant appears to be in emotional distress beyond the normal scope of the program, staff and volunteers should listen with care, avoid probing questions, and report to the DSL.
• The DSL maintains a basic referral list of appropriate local support services for each program location.
• Staff and volunteers must never attempt to manage a participant mental health crisis independently — refer to the DSL and local services immediately.
• If a participant discloses thoughts of self-harm or harm to others, treat this as an urgent safeguarding concern and contact the DSL and local emergency services immediately.

17. Partner Organisations and External Venues

• Partners are informed of this policy and agree to uphold its standards before any program begins.
• Any safeguarding concern arising from a partner-delivered program is reported to the Promoting Queens DSL.
• Partners without their own safeguarding policy agree to operate under this policy.
• Promoting Queens reserves the right to suspend or terminate a partnership if safeguarding standards are not met.
• When programs are delivered at external venues — schools, community centres, partner facilities — host venues are expected to have their own safeguarding procedures. Promoting Queens policy applies to all PQ representatives regardless of venue.
• Host venues are informed of this policy before any program begins and asked to confirm their own safeguarding arrangements.

18. Governing Law

This policy is governed by the laws of the State of New York, United States of America. Where country-specific laws in the annexes impose stricter obligations than this universal policy, those stricter obligations prevail within their respective jurisdictions.

19. Training and Review

• All staff and volunteers read and confirm this policy before beginning any role.
• All staff and volunteers working directly with children complete safeguarding awareness training.
• The DSL completes formal safeguarding training and refreshes this annually.
• This policy is reviewed annually, or sooner following any significant safeguarding incident, change in legislation, or expansion to a new country.
• When Promoting Queens expands to a new country, a Country Annex is added within 30 days of program launch.

Annex A — Nigeria

Applies to all Promoting Queens programs in Nigeria — community outreach in Bayelsa, Osun, Enugu, and Jos, school programs at Elelenwo CSS and partner schools, and online sessions with Nigerian participants.

Governing legislation:

• Child Rights Act 2003 (Federal) — establishes the rights of the child and prohibits all forms of abuse and exploitation. Not all Nigerian states have domesticated the Act; Promoting Queens applies federal standards in all states regardless.
• Violence Against Persons Prohibition Act 2015 (VAPP) — criminalises sexual and physical violence.
• Nigeria Data Protection Regulation (NDPR) 2019 — governs the collection and use of personal data, administered by NITDA.

A child is any person under 18. Under the Child Rights Act, any person who has reasonable grounds to believe a child is being abused has a duty to report to relevant authorities. Promoting Queens staff and volunteers in Nigeria report to the DSL immediately, who refers to the relevant authority. Local reporting authorities: the Ministry of Women Affairs and Social Development (state-level offices in each state where we operate); NAPTIP (National Agency for the Prohibition of Trafficking in Persons, naptip.gov.ng) for trafficking and sexual exploitation cases; and the Nigeria Police Force (emergency: dial 112 or 199).

Annex B — Kenya

Applies to Promoting Queens Chess Club Mombasa (launched February 2025) and any future Kenya programs.

Governing legislation:

• Children Act 2022 — primary legislation governing the rights and protection of children in Kenya.
• Sexual Offences Act 2006 — criminalises sexual abuse and exploitation of children.
• Data Protection Act 2019 — governs collection, use, and storage of personal data, administered by the Office of the Data Protection Commissioner (ODPC).

A child is any person under 18. Under the Children Act 2022, any person who suspects a child is being abused or neglected must report to a children’s officer, police officer, or other authorised officer. Promoting Queens staff and volunteers in Kenya report to the DSL immediately, who refers to the relevant authority. Local reporting authorities: the Department of Children’s Services (children’s officers stationed at county level); Kenya Police Service (emergency: dial 999 or 112); Childline Kenya (116, free helpline for children in distress); and the Gender Violence Recovery Centre (GVRC) at Nairobi Women’s Hospital for sexual and gender-based violence.

Annex C — United States

Applies to any US-based programs, online sessions administered from the US, and all organisational operations based in New York, NY.

Governing legislation:

• New York Social Services Law Article 6, Title 6 (Sections 411–428) — mandatory reporting requirements.
• Child Abuse Prevention and Treatment Act (CAPTA) — federal framework.
• Children’s Online Privacy Protection Act (COPPA) — applies to online programs involving children under 13.

A child is any person under 18 under New York State law. Under New York Social Services Law, mandated reporters are legally required to report suspected child abuse or maltreatment. Promoting Queens treats all staff and volunteers as mandated reporters and requires immediate reporting of any concern to the DSL. Local reporting authorities: the New York State Central Register (SCR) at 1-800-342-3720, 24 hours a day, 7 days a week; and emergency services (dial 911). Promoting Queens complies with applicable US federal and New York State data protection requirements, and with COPPA for online programs involving children under 13.