Child Safety and Vulnerable Populations Policy
Safeguarding children, older adults, persons with disabilities, and other vulnerable populations in ASF surveys, governance, and standards content
Foreword
Healthcare settings are, by definition, places where people are at their most vulnerable. Children are brought to hospitals and clinics for procedures they cannot consent to and cannot fully understand. Older adults in residential care depend on staff for their most basic functions. Patients at the end of their lives cannot always advocate for their own dignity. Persons with dementia or severe mental illness may not be able to report mistreatment. The accreditation process — which involves external assessors entering these settings, observing care, and interviewing patients — creates its own distinct safeguarding obligations.
This policy addresses both dimensions: what ASF standards require of facilities that care for vulnerable populations, and how ASF surveyors conduct themselves when those populations are present. It does not duplicate the protections already embedded in the standards themselves — it makes ASF’s own governance obligations explicit and auditable.
The policy is grounded in the UN Convention on the Rights of the Child, the UN Principles for Older Persons, the CRPD, UNICEF’s humanitarian safeguarding standards, and JCI’s requirements for care of vulnerable patients. ASF’s geographic scope — which includes facilities serving refugee populations, conflict-affected communities, and populations with high rates of gender-based violence and harmful traditional practices — makes these protections not abstract obligations but operational necessities. They apply in every survey in every country.
1. Scope and Purpose
Several ASF standards contain criteria that directly address the care of children (Hospital Standard 4.x, Ambulatory Standard 23, Primary Health Clinic Standards 1–3, Long-Term Care Standard 1), older adults (Long-Term Care Standards 2–6), persons with dementia (Long-Term Care Standard 5), end-of-life patients (Long-Term Care Standard 6, Home Care Standard 6), and victims of gender-based violence (Hospital Standard 5.x). ASF surveyors enter facilities where these populations are present. This creates specific obligations that this policy makes explicit.
The purpose of this policy is threefold: to establish what ASF standards require facilities to do to protect vulnerable patients; to establish how surveyors conduct themselves around vulnerable populations; and to establish how ASF develops standards for care settings where vulnerability is the defining patient characteristic.
2. International Framework
This policy is grounded in:
- UN Convention on the Rights of the Child (CRC, 1989) — Articles 3 (best interests), 19 (protection from violence), 24 (health), 25 (periodic review of placement) [1]
- UN Principles for Older Persons (1991) — dignity, independence, participation, care, and self-fulfilment [2]
- UN Convention on the Rights of Persons with Disabilities (CRPD, 2006) — Article 16 (freedom from exploitation, violence and abuse), Article 25 (health) [3]
- UNICEF Core Commitments for Children and Minimum Standards in Humanitarian Action — applied to ASF’s Crisis and Transitional category facilities [4]
- WHO Guidelines on Safe Identification and Management of Child Abuse [5]
- JCI Standards for Hospitals, 8th edition — Standard COP.7 (care of vulnerable patients), Standard AOP.1.7 (children as a special population) [6]
3. Definitions
For the purposes of this policy:
- Child: Any person under 18 years of age (UN CRC definition), or under the applicable legal age of majority in the jurisdiction, whichever is higher.
- Vulnerable adult: Any adult who, by reason of age, disability, illness, or circumstance, is less able to protect themselves from harm, exploitation, or abuse — including but not limited to persons with dementia, persons with severe mental illness, persons in end-of-life care, persons under coercive control, and persons in detention.
- Safeguarding: The range of measures taken to protect children and vulnerable adults from harm, abuse, exploitation, and neglect — including the identification and reporting of harm, and the conduct standards that reduce the risk of harm occurring.
- Harmful contact: Any physical, emotional, sexual, or financial contact with a patient that is not required for the conduct of a legitimate assessment activity and that a reasonable observer would consider inappropriate.
4. Surveyor Conduct Around Vulnerable Populations
The following requirements apply to all ASF surveyors during facility visits. They are incorporated into the ASF Surveyor Training Standard (ASF-SURV-STD-v2) curriculum and are assessed in the Domain D competency assessment.
A surveyor must never be alone with a child without a member of the facility’s staff present. Patient-tracer interviews with children require the presence of a parent, guardian, or appropriate staff member. A surveyor must not photograph, record, or obtain personal information from or about a child patient beyond what is minimally necessary for the assessment. Any observation that suggests a child may be subject to abuse or neglect must be reported to the ASF Director immediately after the survey — not during the survey, to avoid alerting the facility — and is handled under the public complaints and sentinel event procedures. Exception — immediate danger: If a surveyor directly observes a child in immediate physical danger during a survey, the surveyor is not required to wait until after the survey to act. The surveyor should immediately alert the most senior clinical staff member present. If the danger is acute and staff response is inadequate, the surveyor may contact emergency services. This action does not violate the survey protocol — patient safety takes absolute precedence over assessment process.
Surveyors assess care quality for persons with dementia through staff interview and record review — not through direct assessment of a person whose cognitive state may make them unable to give informed consent to an interview. Where a resident does approach or engage with a surveyor, the surveyor responds courteously and professionally, but does not use the interaction to gather assessment evidence without staff supervision.
Surveyors do not conduct patient tracers in end-of-life care rooms or palliative bays without explicit, advance agreement from the facility clinical lead. Where a tracer is conducted, the surveyor proceeds with minimum disruption and exits immediately if the patient or their family indicates discomfort. Comfort and dignity of the patient and family take absolute precedence over assessment completeness.
The ASF Telemedicine Standard means children may receive clinical care through remote platforms. Online environments carry distinct safeguarding risks: the absence of physical presence makes it harder to observe child welfare indicators; session recordings may be retained on insecure platforms; and the child’s environment at the time of the consultation (home, school) may not be private or safe. The Telemedicine Standard’s criterion on technology platform security (Standard 1) and data privacy (Standard 6) apply to sessions involving children, and the next revision of the Telemedicine Standard will add an explicit criterion on child-appropriate communication protocols and the conditions under which a clinician must require parental or guardian presence during a remote consultation with a minor.
Female genital mutilation/cutting (FGM/C) is classified by WHO as a harmful traditional practice constituting a violation of the human rights of girls and women, with severe and lifelong health consequences. It is specifically relevant to ASF’s Health and Migration endorsement, given the populations ASF-accredited facilities in certain geographic contexts serve. ASF standards’ patient rights criteria (Standard 1 in all organisational standards) require facilities to operate non-discriminatory, rights-respecting intake and care processes. The Hospital Standard’s safeguarding criteria require staff to be trained in recognising the health indicators of FGM/C and to follow national mandatory reporting obligations where they exist. This policy commits ASF to maintaining these requirements and to strengthening them in the next revision cycle to align with WHO’s 2023 updated clinical guidelines on FGM/C.
Psychiatric inpatient settings and mental health facilities require specific surveyor conduct adaptations. Surveyors must complete a pre-survey briefing with the clinical lead on any specific patient safety considerations before entering wards. Patient tracers in locked or acute psychiatric settings require a staff escort at all times. Surveyors may not photograph or record in psychiatric wards without the explicit written consent of the clinical lead. Interview-based assessment of care quality in psychiatric settings is conducted primarily through staff interviews and record review rather than direct patient contact, unless the patient has been specifically assessed by the clinical lead as having capacity to consent to a voluntary interview. Any distress observed in a patient during a survey interaction — including distress that appears connected to the surveyor’s presence — is grounds to immediately disengage from that area of the ward.
Surveyors are trained, as part of Module 5 (Ethics and Conduct), to recognise indicators of intimate partner violence, child abuse, elder abuse, and human trafficking in a healthcare setting. This training covers ASF’s reporting obligation — which is to the ASF Director, not directly to authorities, since ASF’s role is quality assessment, not law enforcement — and the boundary between the surveyor’s assessment role and the clinician’s mandatory reporting role under national law.
5. Standards Content — Safeguarding Criteria
The equity review checklist (ASF-EDI-001-v1, Section 8) specifically includes an age criterion. In addition, the following commitment applies to all ASF standards that cover care settings where children or vulnerable adults are patients:
Every such standard must contain, or explicitly incorporate by reference, criteria addressing: (a) staff screening and background checks for roles involving direct unsupervised contact with children or vulnerable adults; (b) a documented safeguarding or child protection policy at the facility level; (c) staff training in recognising and responding to indicators of abuse and neglect; and (d) a reporting mechanism for suspected abuse that connects to the appropriate national mandatory reporting system.
These criteria are present in the current Hospital Standard (patient rights, safeguarding and special populations sections) and the Long-Term Care Standard (resident rights, cognitive care, and end-of-life sections). Criterion references use the domain/section structure of each standard rather than simple numbers. The next revision of the Ambulatory and Primary Health Clinic standards will explicitly incorporate safeguarding criteria for paediatric and family practice settings.
6. Governance — Safeguarding in Standard Development
Where ASF develops or revises a standard for a care setting that predominantly or significantly serves children or vulnerable adults, the Revision Panel must include, or formally consult, a practitioner with specific expertise in safeguarding in that care context. The consultation is documented in the revision file.
Public consultations on standards for paediatric, geriatric, mental health, and disability care settings specifically solicit submissions from organisations representing the interests of the relevant vulnerable populations — not only from healthcare providers.
References
- United Nations. Convention on the Rights of the Child. New York: UN; 1989.
- United Nations. Principles for Older Persons. New York: UN General Assembly Resolution 46/91; 1991.
- United Nations. Convention on the Rights of Persons with Disabilities. New York: UN; 2006.
- UNICEF. Core Commitments for Children in Humanitarian Action. New York: UNICEF; 2020.
- World Health Organization. INSPIRE: Seven Strategies for Ending Violence Against Children. Geneva: WHO; 2016.
- Joint Commission International. Joint Commission International Accreditation Standards for Hospitals, 8th edition. Oakbrook Terrace (IL): JCI; 2024. Standards COP.7, AOP.1.7.
