Managing PSEA and handling sensitive cases

1A PSEA system that works

A solid system rests on four pillars: prevention (code of conduct, reference checks, training, risk analysis of activities), reporting (multiple, safe channels accessible to children and people with disabilities), response (victim assistance, investigation, sanctions) and accountability (informing communities, reporting to donors, taking part in the country PSEA network).

The PSEA focal point receives reports and passes them on; they do not investigate alone. The IASC commitments and the CHS (commitment 5 on complaints) set the expectations.

2The survivor-centred approach

Four principles guide case handling: safety, confidentiality, respect for the person's choices, non-discrimination. The survivor decides which services she wants; for a child, action is taken in their best interests, involving them according to their age.

Never ask for the facts to be told several times (risk of re-traumatisation), never confront the alleged perpetrator, and refer to specialised services (health within 72 hours for post-exposure prophylaxis, psychosocial support, legal aid) identified by the GBV sub-cluster.

3Protection, strategy and advocacy

Protection mainstreaming (safety and dignity, meaningful access, accountability, participation and empowerment) applies to every sector. At strategic level, the organisation analyses protection risks in its programmes, budgets the measures (lighting, accompaniment, interpreters) and trains its partners.

Advocacy on violations relies on aggregated, safe data, in consultation with the Protection cluster, always weighing the risk for people and for access.

4Governance of a PSEA system: roles, budget and management indicators

The four pillars covered in the module (prevention, reporting, response, accountability) only work if responsibilities are clearly assigned, funded and monitored. The IASC Minimum Operating Standards (MOS-PSEA) and donor assessments all start from the same observation: failures rarely stem from the absence of a policy, but from the absence of oversight and management.

Who does what

Budgeting for PSEA

Budget lines to plan for a medium-sized country office (150 to 300 staff, several bases): dedicated time for focal points (often 10 to 20% of their time, more for a full-time PSEA coordinator in large programmes); annual training and briefings for daily workers; toll-free line and communication materials in local languages; a victim assistance fund to cover transport, temporary accommodation or costs not covered by services; investigation costs (travel, external investigators, interpreters); support to partners. A dedicated budget line is now accepted by most donors, who prefer to see it explicitly rather than diluted in running costs.

Management indicators

Management relies on aggregated, anonymised data. No coordination meeting, not even a senior management meeting, is the place to discuss a named case.

5Handling an allegation from start to finish: receipt, investigation, decision, closure

Managing an allegation follows two parallel tracks that must never be confused: the assistance track for the victim, guided by her needs and choices, and the administrative and disciplinary track, which establishes the facts and decides on measures against the alleged perpetrator. The CHS Alliance investigation guidelines and the IASC guide on complaint mechanisms describe the following steps.

The steps and their timeframes

Quality requirements for an investigation

• Competence: investigators trained in interviewing survivors and in the rules of evidence; for a child, an interview by a specially trained person, or reliance solely on other evidence.
• Independence: no reporting line or personal link with the alleged perpetrator or the victim; use of an external investigator or the headquarters investigation unit if the alleged perpetrator is a senior manager.
• Working in pairs: two investigators, including at least one woman when the victim is a woman; a trained interpreter bound by a confidentiality undertaking.
• Consent: the victim chooses whether or not to take part; the investigation can proceed without her on the basis of other evidence.
• Fairness: the alleged perpetrator is informed of the allegations, heard, and may present evidence; presumption of innocence.
• Data security: encrypted files, named access, retention in line with the policy, never on personal devices.

Relationship with criminal justice

The internal investigation is administrative: it does not replace criminal proceedings. Referral to the judicial authorities depends on local law, the wishes of the adult victim, the best interests of the child and the risk assessment (reliability of the justice system, risk of reprisals, possibility of forced marriage imposed on the victim, criminalisation of certain relationships). The decision is documented and taken with legal advice.

A badly conducted investigation is worse than no investigation: it exposes the victim, alerts the alleged perpetrator, destroys evidence and makes a lawful sanction impossible. Staff without a mandate ask no investigative questions.

6Supporting the survivor: assistance, safety plan, children's consent

The United Nations Protocol on the Provision of Assistance to Victims of Sexual Exploitation and Abuse (2019) sets a simple rule: assistance is provided unconditionally, whatever the outcome of the investigation and whether or not the victim takes part in the process. Children born as a result of sexual exploitation and abuse are also covered. Within the UN system, the Victims' Rights Advocate and PSEA coordination bodies oversee the application of this principle.

The assistance package

Building a safety plan

Developed by a trained case worker together with the survivor, it answers practical questions: does the alleged perpetrator know where she lives or where she receives aid? Who around her is informed and protective? Which routes should she avoid? How can she receive aid without running into the alleged perpetrator (change of distribution point, home delivery)? What number should she call if threatened? The plan is reviewed after each stage of the process, particularly when the alleged perpetrator is informed of the allegations, a moment of increased risk of reprisals.

Children's consent and assent

The IRC and UNICEF guidance on caring for child survivors proposes an age-based framework, to be adapted to national law and to each child's maturity:

In all cases, the final decision is based on the best interests of the child; when the parent is the alleged perpetrator or is not protective, the case worker or the child protection authority takes over, in line with the Inter-Agency Guidelines for Case Management and Child Protection (2014).

What the survivor needs to know

• That she does not have to tell her story to several people and that she may refuse an investigation interview.
• That her humanitarian assistance will be neither suspended nor reduced.
• Who her single point of contact is and how to reach that person.
• What the organisation can and cannot tell her about the outcome of the investigation.

One point of contact, one account, unconditional assistance: these are the three concrete guarantees of the survivor-centred approach. Any procedure that requires the victim to repeat the facts to several people must be reviewed.

7Full example: handling an allegation against a driver in Moranga

This fictional case extends the module's case study. The international NGO Lumen Aid runs a health and nutrition programme in the fictional province of Moranga (210 employees, 3 bases). One donor requires notification within 48 hours; a UN agency co-funds the programme. A 15-year-old girl, a beneficiary of a nutrition centre, is reported to have been sexually abused by a driver employed for eight years.

Timeline of the response

Direct costs of the response

These costs were covered by the PSEA line in the country budget, which avoided any debate in the middle of the emergency.

Key takeaways from this case: refusing the "discreet check", the immediate precautionary measure, a single account taken by a professional, objective evidence (logbooks) that made it unnecessary to interview the child, a decision separate from the investigation, and a systemic fix at the end.

8The inter-agency PSEA network, protection strategy and advocacy

No organisation can address PSEA alone: communities do not always distinguish between organisations, alleged perpetrators move from one to another, and service providers are shared. Since the IASC adopted its Plan for Accelerating PSEA in Humanitarian Response in 2018, every Humanitarian Country Team must have a collective system in place.

Typical in-country architecture

• The Humanitarian Coordinator is responsible for the collective PSEA strategy and is accountable to the Humanitarian Country Team.
• A full-time PSEA coordinator, often based in the office of the Resident or Humanitarian Coordinator, leads the network.
• The PSEA network brings together focal points from UN agencies and international and national NGOs; it adopts an annual action plan, inter-agency standard operating procedures for referring allegations, and common messages.
• Inter-agency community-based complaint mechanisms allow a person to report an allegation against any organisation through a common channel; the allegation is referred to the organisation concerned according to agreed rules.
• Links with the GBV sub-cluster and the Child Protection Area of Responsibility guarantee assistance to victims.

What an organisation contributes to the network

Integrating PSEA and protection into the organisation's strategy

• PSEA and safeguarding included in the country strategic plan, with objectives, a budget and a lead on the senior management team.
• SEA risks taken into account when choosing modalities (in-kind, cash, through service providers) and partners.
• Consistency with the Humanitarian Country Team protection strategy and with the priorities of the centrality of protection.
• Annual review by senior management: allegations, timeframes, investigations, corrective measures, awareness of channels, improvement plan.

Advocacy: rules of caution

Advocacy on sexual exploitation and abuse aims at systemic change: funding for GBV services, presence of female staff, working conditions of daily workers, rules applicable to security forces and to the authorities that manage sites. It relies on aggregated data and trends, never on recognisable individual cases. Before speaking out, three risks are assessed: to survivors and witnesses, to humanitarian access, and to staff. Public advocacy is generally carried collectively, by the PSEA network, the Protection Cluster or the Humanitarian Coordinator, rather than by a single organisation.

An organisation that refuses to share aggregated data with the network out of concern for its reputation weakens the collective system and takes a greater risk: being found out later, through an audit or by the press.

9Mistakes, the auditor's perspective, contextual variations and interview questions

Common mistakes in handling sensitive cases

What auditors and evaluators look at

• The allegations register: dates of receipt, referral, notification and closure; consistency with the timeframes in the policy and agreements.
• Investigation terms of reference and reports (on a sample basis, respecting confidentiality): independence, competence, fairness, standard of proof.
• Evidence of assistance offered to victims, regardless of the outcome.
• Systemic measures taken after each case: closing control gaps, training, changes to procedures.
• Active participation in the in-country PSEA network and sharing of aggregated data.
• The annual report to the governing body.

Variations by context

• Sudden-onset emergency: influx of staff and daily workers, PSEA network sometimes non-existent; from the very first days, activate a focal point per base, a simple reporting channel and a minimum agreement with the GBV actors present; plan for reinforcement from the headquarters investigation unit.
• Protracted crisis: older cases that emerge late; procedures allowing historical allegations to be handled and victims whose children were born as a result of SEA to be assisted.
• Remote management: investigations difficult to conduct on site; use of trained, independent national investigators, remote interviews only if safety and confidentiality are guaranteed.
• Insecurity: the alleged perpetrator may be linked to an armed group or an authority; the safety of the victim and staff comes first; the case is often handled at headquarters and network level.
• Allegation against a local partner: the partner investigates under its own policy with support from the organisation or the funding agency; if its capacity is insufficient or there is a conflict of interest, the investigation is entrusted to a third party, as provided for in the 2018 UN Protocol.
• Allegation against a senior manager or an expatriate: the investigation must be entrusted to headquarters or an external provider; direct reporting to the governing body is possible.

Interview questions

Key references

• IASC, Minimum Operating Standards on PSEA (2012) and Plan for Accelerating PSEA in Humanitarian Response (2018).
• United Nations, Protocol on the Provision of Assistance to Victims of Sexual Exploitation and Abuse (2019) and Protocol on Allegations of Sexual Exploitation and Abuse Involving Implementing Partners (2018).
• CHS Alliance, Guidelines for Investigations and PSEA Implementation Quick Reference Handbook (2017).
• IASC, Best Practice Guide: Inter-Agency Community-Based Complaint Mechanisms (2016).
• WHO, UNHCR and UNFPA, Clinical Management of Rape and Intimate Partner Violence Survivors (2020).
• IRC and UNICEF, Caring for Child Survivors of Sexual Abuse (2012); Child Protection Case Management Task Force, Inter-Agency Guidelines for Case Management and Child Protection (2014).
• GBV AoR, Inter-Agency Minimum Standards for Gender-Based Violence in Emergencies Programming (2019).
• Steering Committee for Humanitarian Response, Misconduct Disclosure Scheme (2019).
• IASC, Policy on Protection in Humanitarian Action (2016).