Privacy Policy
SpacECE India Foundation is committed to protecting the privacy of all individuals whose data we collect, process, and store. This Privacy Policy explains how we handle personal information across our programmes, platforms, and services.
1. Who We Are
SpacECE India Foundation is a non-profit organisation focused on Education & Child Development. Our FLN Monitoring System supports schools, teachers, and clusters across India.
2. Data We Collect
We may collect the following categories of personal data:
- Student attendance and performance data
- Teacher and staff personal details (name, contact, employment records)
- Donor and partner information
- Volunteer and intern records
- School and cluster operational data
- Communication records (emails, forms, reports)
3. How We Use Your Data
Personal data is used solely for the following official purposes:
- Programme monitoring and evaluation
- Academic and administrative reporting
- HR operations and payroll
- Donor reporting and fundraising compliance
- Legal and regulatory compliance
4. Data Sharing
We do not sell or rent personal data. Data may be shared only with:
- Authorised staff on a need-to-know basis
- Government authorities as required by law
- Funding partners strictly under data-sharing agreements
5. Data Security
- All digital data stored on secure, password-protected systems
- Access restricted to authorised personnel only
- Antivirus and firewall protections maintained
- Data breaches must be reported and investigated within 24 hours
6. Retention & Deletion
Data is retained only as long as operationally or legally necessary. Financial and travel records are kept for a minimum of 5 years for audit purposes. Data no longer required will be securely deleted.
7. Your Rights
- Right to access your personal data held by us
- Right to request correction of inaccurate data
- Right to request deletion (subject to legal obligations)
- Right to raise a grievance with our Data Protection Officer
8. Contact & Grievances
For privacy-related queries or to exercise your rights, please contact the HR/Compliance team of SpacECE India Foundation. Complaints will be acknowledged and resolved confidentially.
9. Policy Review
This Privacy Policy is reviewed annually and updated in response to legal changes or operational requirements. All policies listed in this hub are available in their complete form below.
Child Protection & Safeguarding Policy
SpacECE India Foundation is committed to providing a safe, respectful, and protective environment for all children. The organisation follows a zero-tolerance approach toward child abuse, neglect, exploitation, or any form of harm.
1. Purpose
This policy establishes clear rules, responsibilities, and procedures to safeguard children at all times.
2. Scope
This policy applies to:
- Employees
- Teachers and trainers
- Interns and volunteers
- Consultants
- Vendors and partners
- Visitors interacting with children
It covers both offline and online interactions.
3. Definitions
| Child | Any person below 18 years of age. |
| Safeguarding | Actions taken to protect children from harm, abuse, or neglect. |
| Abuse may include | Physical, Emotional, Sexual, Neglect, Exploitation |
4. Legal Framework
This policy aligns with:
- Protection of Children from Sexual Offences (POCSO) Act, 2012
- Juvenile Justice (Care and Protection of Children) Act, 2015
- Information Technology Act, 2000 (online safety)
- Relevant IPC provisions
5. Governance and Responsibilities
Governing Body / Management
- Ensure policy implementation
- Allocate safeguarding resources
- Review safeguarding reports annually
Designated Safeguarding Officer (DSO)
- Receive complaints
- Lead investigations
- Coordinate with authorities
- Maintain records
Child Safeguarding Committee
- DSO (Chair)
- 2–3 senior members
- External expert (child protection/legal advisor)
All Staff
- Follow policy
- Maintain safe behaviour
- Report concerns immediately
6. Staff Code of Conduct
Staff MUST
- Treat children with dignity and respect
- Maintain professional boundaries
- Ensure supervision at all times
- Use safe and open environments
- Report concerns immediately
Staff MUST NOT
- Hit or punish children
- Use abusive language
- Be alone with children in private areas
- Engage in inappropriate touching
- Share personal contacts/social media with children
- Take photos/videos without explicit parental or legal guardian permission
- Hide or ignore abuse
7. Digital and Online Safeguarding
Employees must:
- Use official communication platforms only
- Avoid one-to-one personal chats with children
- Not connect with children on personal social media
- Obtain verifiable written consent from parents or legal guardians for photos/videos
- Protect student data at all times
Unauthorized sharing of child information is strictly prohibited.
8. Safe Recruitment
All child-facing roles require:
- Identity verification
- Background/reference checks
- Police verification (where applicable)
- Signed self-declaration
Employment is subject to satisfactory screening.
9. Training and Awareness
SpacECE will ensure:
- Mandatory induction training
- Annual refresher sessions
- Awareness on recognizing abuse
- Legal obligations under POCSO/JJ Act
- Signed policy acknowledgment by all staff
10. Reporting Procedure
| What to report | Suspicious behaviour, injuries, child disclosure, policy violations, any safety risk |
| Timeline | Immediate reporting; within 24 hours maximum |
| Report to | Designated Safeguarding Officer, Child Safeguarding Committee, HR/Management, National Child Helpline Number (1098) |
Anonymous reporting is allowed.
11. Response and Investigation Procedure
Upon receiving a complaint:
- Immediate safety measures for the child
- Temporary separation if required
- Confidential investigation by Committee within structured timelines
- Proper documentation maintained throughout
- Fair hearing for all parties
- Decision and corrective action communicated
12. Mandatory Legal Reporting
Cases involving sexual abuse or serious harm must be reported to:
- Local Police
- Child Welfare Committee (CWC)
13. Support and Confidentiality
- Child's safety and well-being is the priority at all times
- Counseling or support services may be provided
- Information handled confidentially
- Shared only with authorised persons
14. Disciplinary Action
Violation may result in:
- Warning
- Suspension
- Termination
- Legal action
Serious offences will be reported to authorities.
15. Review
This policy will be reviewed annually, or immediately upon legal changes.
Code of Conduct & Workplace Ethics Policy
To promote ethical behavior, respect, and a safe workplace free from harassment and misconduct. Applicable to all staff, interns, vendors, and partners.
Expected Behaviour
- Professionalism – Maintain high standards in all interactions
- Respect – Treat all individuals with dignity
- Integrity – Act honestly and transparently
- Confidentiality – Protect sensitive information
Prohibited Behaviour
- Harassment of any kind
- Discrimination based on any protected characteristic
- Fraud or misrepresentation
- Misuse of organisational funds or assets
- Data breaches or unauthorised disclosure
Zero Tolerance
Sexual harassment is strictly prohibited. SpacECE India Foundation upholds a zero-tolerance stance in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
Internal Committee
- Presiding Officer (female)
- Members (minimum 2 employees)
- External expert (NGO/legal background)
Complaint Process
- Written complaint submitted to Internal Committee
- Confidential inquiry conducted within prescribed timelines
- Action taken as per applicable law
Reporting
Employees may report fraud, corruption, or misconduct to HR/management. Anonymous reporting is permitted.
Protection
No retaliation will be taken against whistleblowers. Any retaliatory action is itself a disciplinary offence.
Disciplinary Action
Consequences for violations include:
- Written warning
- Suspension
- Termination of employment/engagement
- Legal action where applicable
Review
This policy is subject to annual review by HR and Management.
Ethics, Compliance & Information Security Policy
This policy defines ethical standards, regulatory compliance, and information security practices to protect the organisation, its employees, children, donors, and stakeholders from legal, financial, and reputational risks.
Scope
Applies to: Employees, Interns, Volunteers, Consultants, Vendors, and Partners.
Objectives
- Promote ethical behavior
- Ensure transparency in all operations
- Safeguard confidential information
- Prevent fraud and financial misappropriation
- Comply with all applicable laws
Core Ethical Principles
All personnel must act with:
- Honesty
- Integrity
- Accountability
- Professionalism
- Respect
Code of Business Conduct
Employees must:
- Follow all organisational policies
- Avoid misconduct in any form
- Protect the organisation's reputation
- Use resources responsibly and for official purposes only
Anti-Corruption & Anti-Bribery
Strict prohibition on:
- Bribes of any kind
- Kickbacks
- Fraud
- Financial misappropriation
Conflict of Interest
Employees must disclose any situation where personal benefit may conflict with organisational interest. Such disclosures must be made to HR in writing at the earliest opportunity.
Confidential Information
Confidential information includes:
- Employee records
- Child data and programme records
- Donor details and financial data
- Internal documents and strategic plans
Confidential information must not be shared without authorisation.
Data Protection & Privacy
Data must be:
- Collected legally and with consent
- Used only for official purposes
- Stored securely with access controls
- Deleted when no longer required
Access must be limited to authorised personnel only.
Information Security Controls
- Use strong passwords; change regularly
- Do not share login credentials
- Secure devices when unattended
- Maintain antivirus and firewall protections
- Restrict unauthorised software downloads
Data Breach Management
All data breaches must be reported within 24 hours. IT/HR will investigate and take steps to mitigate impact and prevent recurrence.
Social Media Conduct
Employees must:
- Maintain professionalism on all social media platforms
- Avoid posting sensitive or confidential information
- Protect the organisation's image and reputation
Reporting & Whistleblowing
Employees may report misconduct confidentially. Anonymous reporting is permitted. Retaliation against reporters is strictly prohibited and will itself be treated as a disciplinary matter.
Investigation Process
All complaints will be:
- Documented formally
- Investigated fairly and impartially
- Resolved confidentially
- Acted upon promptly with appropriate outcomes
Monitoring & Audit
Periodic checks may be conducted by HR/IT to ensure ongoing compliance with this policy.
Disciplinary Action
Violations may lead to warning, suspension, termination, or legal action depending on severity.
Responsibilities
| Employees | Follow all policy provisions |
| Managers | Enforce ethical standards within their teams |
| HR / IT | Monitor compliance and maintain records |
Record Retention
Security and compliance records will be maintained as required by law and organisational standards.
Review
This policy is reviewed annually.
Leave and Time Off Policy
This policy provides a structured leave framework to support employee health, family responsibilities, and work-life balance while ensuring smooth organisational operations.
1. Scope
This policy applies to all permanent and fixed-term employees of SpacECE India Foundation. Interns may be governed separately as per internship guidelines.
2. Legal Framework
This policy is aligned with:
- Maternity Benefit (Amendment) Act, 2017
- Applicable State Shops & Establishments Act
- Code on Wages, 2019
Where statutory provisions provide higher benefits, those shall prevail.
3. Leave Entitlements
Special / Leave Without Pay (LWOP)
If leave balance is exhausted, unpaid leave may be granted subject to management approval. Maximum duration may be restricted based on operational needs.
4. Public Holidays & Weekly Offs
Employees are entitled to weekly offs and declared public holidays as per the organisational calendar. Work on holidays may be compensated through compensatory off.
5. Leave Application Procedure
Employees must apply through HRMS following these notice timelines:
| Leave Type | Notice Required |
|---|---|
| Privilege / Earned Leave (PL) | 7 days prior |
| Casual Leave (CL) | 1–2 days prior |
| Sick Leave (SL) | Same day intimation |
Managers must respond to leave applications within 48 hours.
6. Roles & Responsibilities
| Employees | Plan leave responsibly and follow the application process |
| Managers | Approve leave fairly and ensure work continuity |
| HR | Maintain records and ensure compliance with applicable law |
7. Non-Compliance
Unauthorized absence will be treated as Leave Without Pay (LWOP). Salary deductions will be made strictly in accordance with applicable wage laws. Habitual misuse may result in disciplinary action.
8. Review
This policy will be reviewed annually and updated as required.
Work Attendance & Remote Work Policy
This policy defines working hours, attendance standards, and internship work arrangements to ensure discipline, accountability, productivity, and legal compliance. SpacECE follows a structured on-site work model for employees while allowing limited WFH flexibility only for interns.
Standard Work Week
- 5 working days per week (Monday–Friday)
- Weekly working hours shall not exceed 48 hours
- Weekly off provided as per organisational calendar
Daily Working Hours
General office timing: 9:30 AM – 6:00 PM (includes 1-hour lunch/rest break). Employees are entitled to reasonable rest intervals during the day.
Teaching Staff Schedule
Teaching and classroom roles require mandatory physical presence.
| Role | Hours | Shift Examples |
|---|---|---|
| Full-time Teaching Staff | 8 hours/day | 9:30–5:30 |
| Part-time Teaching Staff | 4 hours/day | 9:30–2:00 or 3:00–7:00 |
Work from home is not permitted for teaching staff.
Attendance Recording
Attendance shall be recorded through HRMS or a digital attendance system. GPS/location tracking will not be used.
Attendance Expectations
Employees must:
- Mark attendance daily
- Be present during assigned hours
- Inform manager in case of delay or absence
- Follow leave procedures as per policy
Unauthorized absence may result in leave or salary deduction as per policy.
Employees
All employees, including teaching and administrative staff, are required to work on-site. Hybrid or remote work arrangements are not applicable to employees.
Interns
Work from home is permitted only for interns based on project requirements and with manager approval.
Internship Model
SpacECE offers internships primarily for learning, training, and skill development. Internships may be:
- Unpaid – training/learning phase
- Paid/Stipend-based – after successful evaluation
The internship type, duration, and stipend (if applicable) will be communicated at onboarding. Stipend-based internships do not constitute full-time employment.
Internship Working Hours
- Flexible or assignment-based
- Up to 6 hours per day
- Up to 30 hours per week
Performance will be evaluated based on deliverables, quality of work, and deadlines.
Work From Home Infrastructure Requirements (Interns)
Interns working remotely must ensure:
- Stable high-speed internet connection
- Reliable Wi-Fi/broadband access
- Suitable laptop/desktop system
- Quiet and distraction-free workspace
- Proper audio/video setup for meetings
- Availability during assigned work hours
Internship Conduct
Interns must follow all organisational policies, maintain professional behaviour, protect confidential information, and adhere to safeguarding and ethics guidelines.
Overtime
Work beyond regular hours must be pre-approved by the Reporting Manager and officially recorded.
Compensatory Off
If employees work on a weekly off or perform extra duty, compensatory leave may be granted. It must be used within 30 days and is not encashable.
Responsibilities
| Employees | Follow working hours, maintain attendance, comply with this policy |
| Managers | Monitor attendance, approve overtime, ensure productivity, supervise internship deliverables |
| HR | Maintain attendance records, implement HRMS, ensure compliance with labour regulations, address concerns |
Non-Compliance
Violation of this policy may result in written warning, leave/salary deduction, or disciplinary action as appropriate.
Review
This policy will be reviewed annually or as required by changes in law or operations.
Travel, Relocation & Reimbursement Policy
This policy establishes comprehensive guidelines governing official travel, relocation support, and expense reimbursement. As a non-profit organisation, SpacECE is committed to responsible stewardship of resources. All travel-related expenses must be reasonable, necessary, and directly related to organisational objectives.
1. Scope
This policy applies to: Employees, Consultants, Interns (if travel is officially assigned), and Authorised representatives. It covers domestic travel, local travel, relocation, and expense reimbursement. Personal or unofficial travel is excluded.
2. Definitions
| Official Travel | Travel undertaken for approved organisational work |
| Per Diem | Fixed daily allowance for meals and incidental expenses |
| Relocation | Transfer of employee to a different city/location for official work |
| Reimbursable Expense | Expense incurred wholly for official purpose |
3. Guiding Principles
All travel must follow the principles of: necessity, economy, safety, transparency, and accountability.
4. Travel Planning & Authorisation
Before travel, employees must:
- Obtain written approval
- Submit a Travel Authorisation Form
- Provide an estimated budget
- Share the full itinerary
Approval hierarchy:
5. Mode of Travel
Employees must select the most economical and efficient option.
| Staff Level | Eligible Mode |
|---|---|
| Junior Staff | Sleeper class / Bus / Public transport |
| Senior Staff | 3AC or Economy air |
Air travel requires management approval. Premium/luxury travel is not permitted.
6. Accommodation
Employees must choose safe, hygienic, and reasonably priced hotels. Luxury hotels, suites, or premium services will not be reimbursed.
7. Meals & Daily Allowance
Reimbursement may be through actual bills OR an approved per-diem rate. Alcoholic beverages and entertainment expenses are not allowed.
8. Local Conveyance
Taxi, auto, or public transport is allowed with receipts. Employees must prefer economical options.
9. Travel Advance
Advance of up to 80% of estimated cost may be provided. The employee must settle the advance within 7 days of return and return any excess amount.
10. Relocation Assistance
Applicable only for official transfers. Covers: travel of employee, shifting of household goods, and temporary stay.
| Staff Level | Relocation Limit |
|---|---|
| Junior Staff | ₹5,000 |
| Senior Staff | ₹10,000 |
Personal relocation is not eligible for assistance.
11. Expense Claims Process
Employees must:
- Submit claims within 15 days of travel completion
- Attach all original bills and receipts
- Fill in the designated claim form
- Obtain manager approvals
Finance will verify and process payment after approval.
12. Non-Reimbursable Items
- Alcoholic beverages
- Personal shopping
- Traffic fines or penalties
- Entertainment expenses
- Family member expenses
- Luxury services and upgrades
13. Internal Controls
Finance may audit claims, verify bills, and request clarification at any time. Fraudulent claims are subject to strict disciplinary action.
14. Roles & Responsibilities
| Employees | Claim responsibly and within policy limits |
| Managers | Approve only necessary and compliant claims |
| Finance | Verify compliance and process payments |
| HR | Maintain records and coordinate policy updates |
15. Disciplinary Action
Misuse of travel reimbursements may lead to claim rejection, recovery of funds, written warning, or termination.
16. Record Keeping
Travel records will be maintained for audit purposes for a minimum of 5 years.
17. Review
This policy is subject to annual review.