Purposes and field of application of the policy 

This Children’s Protection Policy aims at protecting and enhancing children’s rights within the institutional activities of the Scuola Superiore Sant’Anna.
The Children’s Protection Policy is mainly applied whereas children (persons aged < 18 yrs old) are involved in research activities of the Scuola Superiore Sant’Anna. However, the monitoring and report mechanisms can find application also in possible didactical activities and third missions activities engaging minors.

Policy

The Academic Senate approved the Children’s Protection Policy in Research Activities on 10.12.2020 (decision n. 267).
Here the approved text: 
/sites/default/files/childrens_protection_in_research_activities_last_version.pdf

Roles and responsibilities 

Children’s right protection and enhancement is ensured by a system of roles and responsibilities identified as follows.
The Principal Investigator / Project Coordinator of the Research where children are involved is responsible to:

• comply with the applicable legal framework;
• ensure that her/his staff will be instructed and authorized to deal with minors;
• involve the Data Protection Officer within the Impact Assessment Activities whereas personal data flows are processed in the research activities;
• promptly answer any questions / requests from the research subjects and their legal representatives;
• collaborate with other partners/research structures;
• report to the Area of Promozione, Coordinamento e Valutazione della Ricerca in their monitoring activities.

Procedures

The Scuola Sant’Anna created a child-safe environment through implementing child safeguarding procedures that are applied across the organisation.
A risk-based approach is applied as main methodology to detect and assess the impact of the research on children before starting any activity.
Considering its research mission, the Scuola Sant’Anna identified three different main scenarios, where children might be involved:

1. clinical trials: a research protocol will be developed and submitted for approval to the competent clinical ethics committee, according to sub 4, of the Policy;
2. non-clinical trials: a research protocol will be developed and submitted for approval to the competent ethics committee (e.g. the Joint Ethics Committee SSSA – SNS), according to sub 4, of the Policy;
3. indirectly engage them by processing their personal data: the Data Protection Officer will be consulted for the Impact Assessment Procedures, according to sub 4, of the Policy.

Implemented safeguards and monitoring activities

According to the principle of accountability, the organisation will map and monitor projects and research activities involving children within the annual report of each involved competent structures (eg Institutes, Area of Promozione, Coordinamento e Valutazione della Ricerca, Data Protection Officer, and Joint Ethics Committee).
Appropriate safeguards and mechanisms are set to monitor, review, and report and included in the policy. In particular,

1. Training activities and seminars are organized to share best practises on children’s protection among administrative and research staff.
2. A dedicated webpage on the intranet of the Scuola will include information, templates, materials on children’s protection within research activities.
3. Bridging activities between the data protection officer, the joint ethics committee, the administrative and research staff are established to facilitate a compliant management of child-related issues.
4. Beyond the specific channels identified in each research project and the claim reporting system, children’s rights might be in any case exercised by their legal representatives/parents/guardians/minors by addressing requests to the official email of the School protocollo@sssup.legalmailpa.it and to the Privacy Committee of the Scuola privacy@santannapisa.it.
5. These guidelines will be available on the institutional website of the Scuola.

These mechanisms are implemented through the following processes during the all life-cycle of the research:

Research Proposal:

• the involvement of children is subordinated by a self-assessment by the scientific coordinator, who can ask the competent offices for a preliminary advice.
• An internal section in the intranet (link) will include useful documents/reports/best practices on the topic.

Research Activities:

• once a project involving children is funded / granted / approved, the scientific coordinator will communicate all the information to the Area of Promozione, Coordinamento e Valutazione della Ricerca.
• The Area of Promozione, Coordinamento e Valutazione della Ricerca will include the research in the general report and address the principal investigator to the competent offices according to the policy.
• The P.I. will submit the research protocol to the competent ethics committee (where required) and / or will perform the impact assessment involving the Data Protection Officer.
• The P.I. will update the Area of Promozione, Coordinamento e Valutazione della Ricerca on the Ethics Committee approvals.

Report Activities:

• Children as Research Subjects will be identified as a specific ground of the annual reports provided by the Scuola Sant’Anna offices and institutes on research activities.
• URP and Privacy Committee will report every year on the number and object of any feedback/request concerning children.

Template for request/Report information etc 

Please feel free to ask for further information and/or report any request/violation of the Children’s Protection Policy to the Scuola Superiore Sant’Anna. For any requests and/or reports, please fill out this form and return it to: urp@santannapisa.it and privacy@santannapisa.it 

Useful links 

Monitoring of the School's research projects involving children (updated January 2022) is available, for internal users only, in the School Intranet.

You can find more information on the topic here: 
https://www.keepingchildrensafe.global/blog/2019/02/15/implementing-child-safeguarding-standards/