Safeguarding and Child Protection Policy

1. Introduction

The Independent School of Jakarta (hereafter 'the School') recognises that it has a duty to ensure that safeguarding permeates all activities and functions. The School expects all members of staff, volunteers, visitors and third parties to share its commitment to Safeguarding and promoting the welfare of pupils. The School prohibits the use of Corporal Punishment.

This policy is addressed to all members of staff, volunteers and visitors and is available to all parents on request and is available on the website. It applies to all staff, volunteers and visitors who work with pupils from the School, even where this is away from the School's premises. Safeguarding and promoting the welfare of children is everyone's responsibility and all staff, and volunteers have a responsibility to provide a safe environment in which pupils can learn. Children includes everyone under the age of 18 years. However, the School's duty is to promote the welfare and health and safety of all pupils in its care whether they are under or over the age of 18 years.

This policy should be read in conjunction with the following policies/documents at the School:

• Safer Recruitment Policy
• Lost Child Policy
• Code of Conduct
• Acceptable Use of Technology Policy
• Anti-Bullying Policy
• Behaviour Policy
• Whistleblowing Policy
• Supervision of Pupils Policy

2. Policy Aims

The School fully recognises its respective responsibilities for Safeguarding and Child Protection. All staff must be aware of the professional obligation laid upon them by the School, in line with the UK 1989 Children Act and subsequent legislation which is invoked when it is considered that a child is at risk of significant harm. However, this policy also outlines our expectations and responsibilities regarding the wider agenda of Safeguarding and Promoting the Welfare of Children in schools in response to the obligations laid out in the UK Education Act 2002 (Section 175/157). This policy is updated in line with Working Together to Safeguard Children (July 2018), The Children Act 2004, The Education Act 2011 and the latest guidance on managing allegations, preventing & tackling bullying, use of reasonable force, screening searching & confiscation and managing student behaviour (2014), and Keeping Children Safe in Education (Statutory guidance for schools and colleges September 2024). The School is also fully compliant with Indonesia's Law #23 (2002) and the subsequent amendments including Law #35 (2014). All staff are issued with the latest copy of 'Keeping children safe in education': Part 1 and Annex A at the beginning of each academic year.

Our policy applies to all staff, Board members, volunteers and visitors working in the School. There are five main elements to our policy:

• Ensuring we practise safer recruitment procedures in checking the suitability of staff, volunteers and visitors to work with pupils, including obtaining assurance that appropriate checks and procedures apply to any staff employed by another organisation, and ensuring all staff have read the policy and understood the chain of command and their responsibility
• Raising awareness of child protection and safeguarding issues and equipping pupils with the skills needed to keep themselves safe
• Developing and then implementing procedures for identifying and reporting cases, or suspected cases, of abuse
• Supporting any pupil who has been abused in accordance with his or her agreed child protection plan, where available
• Establishing a safe environment in which pupils can learn and develop

We recognise that, because of the day-to-day contact with pupils, School staff are well placed to observe the outward signs of abuse. The School will therefore:

• Establish and maintain an environment where pupils feel secure, are encouraged to talk, and are listened to
• Ensure pupils know that there are adults in the School whom they can approach if they are worried; including, but not exclusively through the system of Form Teachers
• Include opportunities in the PSHEE curriculum, Form time and assemblies for pupils to develop the skills that they need to recognise and stay safe from abuse and harm. This includes opportunities to promote online safety through computing or IT lessons or through PSHEE
• Ensure that all staff in the School receive Basic Awareness training in Safeguarding and Child Protection regularly, and at least every year, and that the Designated Safeguarding Lead for safeguarding and child protection attends more advanced child protection training every two years. All staff will receive updates on child protection and safeguarding as appropriate
• Ensure that all staff in the School are prepared and able to identify children who may benefit from early help, providing support as soon as a problem emerges in a child's life
• Ensure that all staff know what to do if they are concerned about a pupil and recognise that safeguarding is everyone's responsibility
• Ensure that staff read and understand Part 1 of KCSIE and Annex A and that they recognise that they have a responsibility to provide a safe environment in which pupils can learn. The Teachers' Standards 2012 state that teachers, including headteachers, have a duty to safeguard the well-being of children and maintain public trust in the teaching profession as part of their professional duties
• Ensure that all staff are aware of the process for making referrals and the role that they might be expected for play in such a process
• Ensure that the Board undertakes an annual review of this policy and its procedures and confirms that the related duties are being discharged fully and, if necessary, exercises its commitment to rectify any identified shortcomings without delay. The Board Member responsible for Safeguarding is Darren Brown.

3. Definitions

Safeguarding and promoting the welfare of children refers to the process of protecting children from maltreatment, preventing the impairment of health or development, ensuring that children grow up in circumstances consistent with the provision of safe and effective care and taking action to enable all children to have the best outcomes

A Child at Risk is where a child is identified as suffering, or being at risk of suffering significant harm. If the child is in immediate danger the police should be called and the Designated Safeguard Lead informed.

A Child in Need is when a child is unlikely to achieve or maintain, or to have the opportunity of achieving or maintaining, a reasonable standard of health or development without the provision of additional services by an outside authority. Equally, a child is in need if their health or development is likely to be significantly impaired or further impaired without the provision of such services, or if they are disabled.

Child Protection refers to the process undertaken to protect children who have been identified as suffering, or being at risk of suffering significant harm.

4. The Role of the Designated Safeguarding Lead

The Designated Safeguarding Lead is responsible for matters relating to Child Protection and Safeguarding. Staff should speak to the Designated Safeguarding Lead if they have a concern about a child's welfare and parents are welcome to approach the DSL if they have any concerns, whether they relate to their own child or any other. In accordance with Annex B of KCSIE, the main responsibilities of the DSL are:

Managing referrals

• To take lead responsibility for promptly referring all cases of suspected abuse of any pupil to local agencies and/or authorities where possible
• To have a working knowledge of local safeguarding procedures
• To develop effective links with relevant government and voluntary agencies
• To take lead responsibility for making referrals promptly to the police where a crime may have been committed which involves a child
• To liaise with the Academic Director in respect of police investigations
• To act as a source of support, advice and expertise to staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with relevant agencies

Raising awareness

• To ensure this Policy is reviewed annually and the procedures and implementation are updated and reviewed regularly
• To ensure this policy is publicly available
• To ensure that parents are aware that referrals about suspected abuse or neglect may be made to external agencies and the School's role in this
• To ensure staff are aware of training opportunities and the local policies on safeguarding
• To ensure that the School's Computing and PSHEE programmes teach pupils about safeguarding, including safe and appropriate use of the internet and social media
• Where children leave the School, to ensure their child protection file is transferred to any new school or college as soon as possible. This will be transferred separately from the main pupil file, ensuring secure transit, and confirmation of receipt will be obtained. Where a pupil leaves the Schools after completing their final Senior year the School will retain the Child Protection pupil record until the pupil reaches the age of 25 years.

The Designated Safeguarding Lead will:

• advise and act upon all suspicion, belief and evidence of abuse reported to them
• keep the Academic Director informed of all actions unless the Academic Director is the subject of a complaint. In this situation, the Designated Safeguarding Lead should consult with the Board without notifying the Academic Director first
• liaise with external services and other agencies on behalf of the School

Training

The Designated Safeguarding Lead for Child Protection and Safeguarding attends a training course every two years. The DSL also, as a minimum, has accessed Prevent Awareness training.

At the start of each academic year there is a Child Protection and Safeguarding briefing for all staff. New staff who join the School at other points in the year are directed to the DSL for training.

5. Child Protection Procedures

If a member of staff is concerned about a child or suspects that a pupil is the victim of abuse, whether physical, emotional, sexual or as a result of neglect, s/he should inform the DSL.

The DSL can be contacted during School hours and on their mobile. The Academic Director can also be contacted on her mobile out of hours. All members of staff in the School will be given a wallet sized card with their contact details on it.

The DSL will decide, in consultation with the Academic Director, whether to make a referral to external agencies where possible and appropriate. External agencies may include NGOs, Embassy Community Liaison Officers, the British Council in Indonesia, the International Child Protection regional office in Bangkok, Therapeutic Specialists or Psychologists.

6. Recognising Abuse

Types of abuse and neglect (Taken from 'Keeping Children Safe in Education, September 2019')

Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. They may be abused by an adult or adults or another child or children.

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child's emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or 'making fun' of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child's developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Neglect: the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child's basic emotional needs.

7. Indicators of Abuse

The identification of physical signs of abuse is complicated, as children may go to great lengths to hide injuries, often because they are ashamed or embarrassed, or their abuser has threatened further violence or trauma if they 'tell.' It is also quite difficult for anyone without medical training to categorise injuries into accidental or deliberate with any degree of certainty. For these reasons it is vital that members of staff are also aware of the range of behavioural indicators of abuse and reports any concerns to the DSL. It is the responsibility of all staff to report any and all niggling worries or concerns over safeguarding and welfare. It is not their responsibility to investigate or decide whether a child has been abused.

A child who is being abused or neglected may:

• have bruises, bleeding, burns, fractures or other injuries
• show signs of pain or discomfort
• change their eating habits
• have difficulty in making or sustaining friendships
• appear fearful
• be reckless with regard to their own safety
• self-harm
• show signs of not wanting to go home
• display a change in behaviour — from quiet to aggressive, or happy-go-lucky to withdrawn
• challenge authority
• become disinterested in their school work
• be constantly tired or preoccupied
• be wary of physical contact
• be involved in, or particularly knowledgeable about drugs or alcohol
• display sexual knowledge or behaviour that normally exceeds that expected for their age
• have 'tummy pains' with no medical reason
• be dirty, smelly, poorly clothed or appear underfed

Individuals indicators will rarely, in isolation, provide conclusive evidence of abuse. They should be viewed as part of a jig-saw, and each small piece of information will help the DSL to decide how to proceed. It is therefore essential that staff report any concerns they have.

8. Contextual Safeguarding

Safeguarding incidents and/or behaviour can be associated with factors outside of the School and can occur between children outside of the School. All staff at the School, and especially the DSL, should consider the context in which such incidents and/or behaviours occur. This is known as contextual safeguarding, which simply means assessments of children should consider whether wider environmental factors are present in a child's life that are a threat to their safety and/or welfare.

9. Child Sexual Exploitation (CSE)

UK DfE guidance on CSE (February 2017) gives this definition: 'Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 years into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.' Child Protection and safeguarding procedures will be followed if the School has concerns that a child is at risk of CSE or is already a victim of CSE.

10. Sexting

'Sexting' is an increasingly common activity among young people where they share inappropriate or explicit images online or through mobile phones. In the latest advice for schools and colleges (UKCCIS, 2016), sexting is defined as 'the production and/or sharing of sexual photos and videos of and by young people who are under the age of 18 years. It includes nude or nearly nude images and/or sexual acts. It is also referred to as 'youth produced sexual imagery'. 'Sexting' does not include the sharing of sexual photos and videos of under-18 year olds with or by adults. This is a form of child sexual abuse and must be referred to the police.

Regrettably, there is international concern related to young people (under the age of 18 years of age) engaging in sending/sharing inappropriate/indecent photographs of themselves or of other children via texts, SnapChat messages, Facebook Messenger, Instagram, WhatsApp etc.

Sexting' is often seen as flirting by children and young people who feel that it is a part of normal life and relationships. Laws were created long before the widespread use of the internet and, therefore, the School should always take a measured approach and seek to avoid criminalising children and young people where possible.

Dealing with Sexting incidents

When an incident involving youth produced sexual imagery comes to the School's attention the incident should be referred to the DSL as soon as possible. The DSL will apply their professional judgement to each sexting incident and consider the following:

• Whether there is a significant age difference between the sender/receiver involved
• Whether there is any external coercion involved or encouragement beyond the sender/receiver
• Whether the child is recognised as more vulnerable than is usual (i.e. at risk)
• Whether the image is of a severe or extreme nature
• Whether the situation is not isolated and the image has been more widely distributed
• Whether this is not the first time children have been involved in a sexting act
• Whether other knowledge of either the sender/recipient may add cause for concern (e.g. difficult home circumstances)
• That sexting among children and young people can be a common occurrence; where they often describe these incidents as 'mundane'
• Children, involved in sexting incidents, should be dealt with as victims as opposed to perpetrators (unless there are mitigating circumstances)

All incidents of sexting should be recorded, including action taken by the member of staff who found out about the incident.

Initial response

The DSL should hold an initial review meeting with appropriate pastoral staff. There should be subsequent interviews with the young people involved (if appropriate) and parents should be informed at an early stage and involved in the process unless there is good reason to believe that involving parents would put the young person at risk of harm. Immediate protective action will be taken if there is a concern a young person has been harmed or is at risk of harm and:

• The incident involves an adult
• There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs)
• The imagery suggests the content depicts sexual acts which are unusual for the young person's developmental stage, or are violent
• The imagery involves sexual acts and any pupil in the imagery is under 13 years
• There is reason to believe a pupil is at immediate risk of harm owing to the sharing of the imagery, for example, the young person is presenting as suicidal or self-harming

The DSL should always use their professional judgement in conjunction with those of their colleagues to assess incidents. Adults should not view youth produced sexual imagery unless there is good and clear reason to do so. Wherever possible responses to incidents should be based on what the DSL has been told about the content of the imagery. The decision to view imagery should be based on the professional judgement of the DSL and in line with the School Safeguarding Policy. If the DSL is satisfied that no other agency needs to be involved in dealing with the case, consideration should be given to deleting the images. The pupil should do this under supervision. Images should never be copied printed or shared with others. If any devices need to be seized and passed onto the police then the device(s) should be confiscated and the police should be called. The device should be turned off and placed in a secure locked location until the police are able to come and retrieve it.

11. Peer-on-Peer Abuse

Children can abuse other children. This is generally referred to as peer-on-peer abuse and can take many forms. There is no clear definition of what peer on peer abuse entails as it can be captured in a range of different definitions.

• Domestic abuse — young people who experience physical, emotional, sexual and/or financial abuse, and coercive control in their intimate relationships, as well as family relationship
• Harmful sexual behaviour refers to any young person, under the age of 18, who demonstrates behaviour outside of their normative parameters by another person under 18 — this includes producing youth sexual imagery
• Serious youth violence with reference to offences including those of the most serious natures such as murder, rape and GBH between young people under 18
• It can also include bullying and cyberbullying, sexting, initiation / hazing type violence and rituals, upskirting

There is a gendered nature to peer-on-peer abuse and it is more likely that girls will be victims and boys perpetrators. Nonetheless, all staff will recognise that pupils of both genders are capable of abusing their peers.

Peer on peer abuse should be treated as a Child Protection and safeguarding concern when there is reasonable cause to suspect that a child is suffering or likely to suffer significant harm. Abuse of this nature should never be tolerated or passed off as 'banter'; 'just having a laugh'; or 'part of growing up'.

Strategies to minimise the risk of peer-on-peer abuse

The School aims to prevent peer on peer abuse (which can include bullying) from becoming established. This is achieved by establishing a culture in which peer on peer abuse is not tolerated and where it is seen as the responsibility of all members of the School community to report any instances of peer-on-peer abuse. The School promotes this culture by promoting an open environment where pupils feel safe. The School operates an open-door policy where pupils are encouraged to discuss concerns and worries with any member of staff. Pupils have weekly PSHEE lessons, which give pupils a forum to talk openly about any difficulties that they may have and discuss issues which may affect them. The School operates a clear behaviour policy to support pupils, which includes rewards and sanctions.

In addition, peer-on-peer abuse is regularly discussed in staff meetings across the School. The result of these meetings is to feedback information to senior leaders about friendship patterns, particular incidents, any pupil who seems to be isolated, any growing "power base" and any known conflict between a member of staff and a pupil, or between pupils so that strategies can be developed to prevent peer-on-peer abuse.

Procedures to deal with peer-on-peer abuse

Peer-on-peer abuse may be identified in several ways:

• disclosure to a member of staff by the individual being abused
• disclosure to another pupil by the individual being abused
• witnesses to specific incidents
• suspicion of peer on peer abuse based upon the indicating factors

When a disclosure or allegation is made by a pupil against another, members of staff should treat it as a safeguarding concern. Staff should inform the DSL. The DSL will gather information from the pupil making the allegation and consider whether they are at risk of significant harm. If the allegation indicates that a potential criminal offence has taken place, the DSL will inform the police. Once advice has been taken from the police, the School will begin its investigation. The DSL or member of staff designated by the DSL will speak separately to the pupils involved to gain a statement of facts from them, using consistent language and open questions for each account. Any written evidence or images will be gathered. Parents, of both the alleged perpetrator and the alleged victim will be informed at an early stage and kept updated. If the allegation highlights a potential risk to the School and the pupil, the School will follow the School's behaviour policy and procedures and take appropriate action. The pupil will be provided with appropriate support and education whilst they are off site.

Support for the victim and perpetrator

The support the victim requires will depend on the individual, but the School can offer support to the victim in a number of ways:

• a support plan, naming someone who they can talk to and listing support strategies for managing issues
• the victim can speak to a trusted adult of their choosing in the School
• the School may consider a referral to outside agencies

It is important to find out why the perpetrator has behaved in such a way. It may be that they may have been harmed themselves in a similar way or may be experiencing their own difficulties. The School acknowledges its responsibility to offer support and will consider the following:

• a support plan, including support strategies for managing issues
• the perpetrator can speak to a trusted adult of their choosing in the School
• a referral to outside agencies
• such other action as may appear to the Senior Leadership Team and Academic Director as appropriate

12. Child on Child Sexual Violence and Harassment

Sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physically and verbally) and are never acceptable. Sexual violence and sexual harassment should never be accepted. It is never acceptable to dismiss it as "banter", "part of growing up", "just having a laugh" or "boys being boys." The School will take all allegations of sexual violence and sexual harassment seriously.

Sexual violence

Sexual violence can be defined as rape, sexual assault or assault by penetration without consent. The legal age of consent in Indonesia is 15 years.

Sexual harassment

Sexual harassment can be defined as 'unwanted conduct of a sexual nature' that can occur online and offline.' Sexual harassment is likely to violate a child's dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment.

Whilst not intended to be an exhaustive list, sexual harassment may include:

• sexual comments such as telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names
• sexual "jokes" or taunting, sexual violence and sexual harassment
• physical behaviour, such as: deliberately brushing against someone, interfering with someone's clothes; upskirting

Online sexual harassment may include:

• non-consensual sharing of sexual images and videos
• sexualised online bullying
• unwanted sexual comments and messages, including, on social media; sexual exploitation; coercion and threats

Any allegations of sexual violence or harassment that are made must be reported to the DSL immediately. The DSL will follow the procedure as outlined in the investigation, referral and reporting section of this policy. In addition, if an incident of sexual violence has been reported, the DSL will make an immediate risk and needs assessment. Where there has been a report of sexual harassment, the need for a written risk assessment should be considered on an individual basis. This will consider:

• the victim, especially their protection and support
• the alleged perpetrator; and
• all the other children (and, if appropriate, adult pupils and staff) at the School

13. Forced and Child Marriage

A forced marriage is a marriage in which one or both spouses do not consent to the marriage but are coerced into it. Duress can include physical, psychological, financial, sexual and emotional pressure. There is a clear distinction between a forced marriage and an arranged marriage. In arranged marriages, the families of both spouses take a leading role in arranging the marriage, but the choice of whether or not to accept the arrangement still remains with the prospective spouses.

Although the legal age of marriage in Indonesia is 21, or over 16 for girls and over 19 for boys with parental consent, child marriage remains prevalent in Indonesia with around 1 in 9 girls married before age 18. The Government of Indonesia is committed to achieving the elimination of child marriage in Indonesia by 2030. Girls from households with the lowest levels of expenditure are almost five times more likely to be married before age 18 than girls from households with the highest levels of expenditure.

There are specific safeguarding issues which staff should be aware of and any member of staff who has a concern about any of the issues listed below should discuss this with the DSL immediately:

• child missing from home or care
• bullying including cyberbullying
• domestic violence
• drugs
• fabricated or induced illness
• faith abuse
• gangs and youth violence
• gender-based violence/violence against women and pupils (VAWG)
• hate
• mental health
• private fostering
• relationship abuse
• sexting
• trafficking

14. Female Genital Mutilation (FGM)

Female Genital Mutilation is illegal in Indonesia. However, FGM is estimated by UNICEF to affect 52% of women and girls in Indonesia. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a pupil being at risk of FGM, or already having suffered FGM. There is a range of potential indicators that a child or young person may be at risk of FGM, which individually may not indicate risk but if there are two or more indicators present this could signal a risk to the child or young person. Victims of FGM are likely to come from a community that is known to practise FGM. Professionals should note that pupils at risk of FGM may not yet be aware of the practice or that it may be conducted on them, so sensitivity should always be shown when approaching the subject. Staff should immediately inform the DSL of any concerns relating to FGM in line with the School safeguarding procedures.

15. Prevent

The School has due regard to the need to prevent people from being drawn into terrorism. Being drawn into terrorism includes not just violent extremism but also non-violent extremism, which can create an atmosphere conducive to terrorism and can popularise views which terrorists exploit. The School provides a safe space in which children and young people can understand and discuss sensitive topics, including terrorism and the extremist ideas that are part of terrorist ideology, and learn how to challenge these ideas.

Different people display various signs of radicalisation. Some people are able to hide it so well that they are indistinguishable from anybody else, making it hard to identify them as radicalised and understand what their intentions are or could be. The following are some signs that could mean somebody could be at risk of radicalisation or is going through a radicalisation process:

Physical changes

• Sudden or gradual change in physical appearance
• Sudden or unexpectedly wearing religious attire
• Getting tattoos displaying various messages
• Possesses unexplained gifts and clothing (groomers will sometimes use gifts such as mobile phones and clothing to bribe a young person)

Social changes

• Cuts ties with their friends, family or community
• Starts to become socially withdrawn
• Becoming dependent on social media and the internet
• Begins to associate with others who hold radical views
• Bullies or demonises other people freely
• Begins to attend rallies and demonstrations for extremist causes
• Associates with known radicals
• Visits extremist websites, networks and blogs

Emotional and verbal changes

• Advocates violence or criminal behaviour
• Begins to believe in government conspiracies
• Exhibits erratic behaviour such as paranoia and delusion
• Speaks about seeking revenge
• Starts to exhibit extreme religious intolerance
• Demonstrates sympathy to radical groups
• Displays hatred or intolerance of other people or communities because they are different

Members of staff, who have concerns about a pupil, will make these concerns known to the DSL at the earliest opportunity.

16. Children who may be Particularly Vulnerable

Some pupils may be at an increased risk of abuse. It is important to understand this this increase in risk is more likely due to societal attitudes and assumptions, and failures to acknowledge pupils' diverse circumstances, rather than the individual's personality, impairment or circumstances.

Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues and reluctance on the part of some adults to accept that abuse can occur.

To ensure that pupils at the School receive equal protection, special consideration will be given to pupils who are:

• disabled or have special educational needs
• young carers at home
• living in a domestic abuse situation
• affected by parental substance misuse
• living away from home
• vulnerable to being bullied, or engaging in bullying
• living transient lives
• living in chaotic and unsupportive home situations
• vulnerable to discrimination and maltreatment on the grounds of race, ethnicity, religion, disability or sexuality
• involved directly or indirectly in sexual exploitation

This list provides examples of particularly vulnerable groups, but it is not exhaustive.

17. Children with Special Educational Needs and Disabilities

Children with special educational needs (SEN) and disabilities can face additional safeguarding challenges. Staff must be aware that additional barriers can exist when recognising abuse and neglect in this group of children. These can include:

• assumption that indicators of possible abuse such as behaviour, mood and injury relate to the child's disability without further exploration
• being more prone to peer group isolation than other children
• the potential for children with SEN and disabilities being disproportionally impacted by behaviours such as bullying, without outwardly showing any sign
• communication barriers and difficulties in overcoming these barriers

To address these challenges, the School offers additional pastoral support, including one to one sessions where appropriate, for children with SEN and disabilities.

18. Children Missing from Education

'All children, regardless of their circumstances, are entitled to a full-time education' (Keeping Children Safe in Education, September 2019). A child going missing from education, particularly repeatedly, can act as a vital warning sign of a range of safeguarding possibilities. This may include sexual abuse or exploitation and child criminal exploitation. It may indicate mental health problems, risk of substance abuse, risk or traveling conflict zones, risk of FGM or risk of forced marriage. Form Teachers are responsible for taking registers twice daily and reporting absences to the School Office. These absences are monitored and the DSL is informed if a pupil fails to attend school regularly.

19. Missing Child Procedures

All staff are informed of the separate procedure to be used for searching for and, if necessary, reporting any pupil missing from the School. The procedure includes the requirement to record any incident, the action taken and the reasons given by the pupil for being missing.

Please see the separate Missing Child Policy for further details.

If the School becomes aware of a child having run away from or having gone missing from home, this will be dealt with as a safeguarding matter and Child Protection Procedures will be followed.

20. Staff Interaction with Pupils

Full details of required behaviour from staff towards pupils are given in the Code of Conduct.

The current climate of suspicion with regard to child abuse poses a real dilemma for caring adults. In order to protect pupils from abuse, and staff from suspicion of abuse, the natural inclination to comfort and reassure pupils through physical contact has to be curbed, and impulse restrained, by a considered assessment of the situation.

This does not mean that physical contact is never permissible, but adults touching pupils must operate within understood limits, and contact without those limits must be a considered response which must be justified if necessary.

Rigid rules about what is and is not permissible/acceptable are difficult to implement. See the additional specific guidelines for peripatetic teachers (below).

The simplest advice is to try, as far as is possible, to avoid being alone with a pupil. Where one-to-one contact does happen, e.g. in music lessons, it should be arranged with others, where possible, within ear shot or vision.

Physical contact and the use of Reasonable Force

This may be for the purpose of:

• care
• instruction
• restraint

Staff should always be able to justify resorting to any physical contact. There are circumstances when it is appropriate for staff to use reasonable force to safeguard children and young people. The term 'reasonable force' covers the broad range of actions used by staff that involve a degree of contact to control or restrain children. Reasonable in these circumstances means 'using no more force than is needed.' The use of force may involve either passive physical contact, such as standing between pupils or blocking a pupil's path, or active physical contact such as leading a pupil by the arm out of the Form Room. Should physical contact appear necessary, staff should, if at all possible, summon a colleague to assist. Any incidents where reasonable force is used must be reported to the DSL immediately after the incident.

This policy should be read in conjunction with the Code of Conduct for staff and the Physical Contact and Intervention Policy.

As adults in positions of trust, and in order to minimise the risk of accusations being made against staff as a result of their daily contact with pupils, all School staff will adhere to the School's expectations regarding professional conduct and should familiarise themselves with the 2013 DfE Guidance regarding reasonable force, called 'Use of Reasonable Force'.

Remarks

Salacious or demeaning remarks should never be made to or in the presence of the pupils. Remarks about a pupil's physical characteristics or development, or suggestive or derogatory comments could fall into this category.

Attachments

Staff are strongly advised to share their concerns with the Academic Director or the DSL if:

• they suspect a pupil is becoming inappropriately attached to them or another member of staff, or
• their relationship with, or feelings towards, a child or young person is placing them at risk of unprofessional behaviour

Residential and non-residential trips

During residential and non-residential trips, staff are strongly advised to adhere to all the guidelines above and to be extra vigilant because:

• The pupils will be around people that are unknown to them and the staff
• Pupils may perceive boundaries to be blurred during residential trips

During the completion of a risk assessment for any residential trip, a discussion will take place on how these risks can be minimised. Any concerns should be discussed with the DSL.

Advice and Guidance for Peripatetic Teachers

Any peripatetic teacher, for example, instrumental and visiting sports or languages teachers, should be made fully aware of the Safeguarding and Child Protection policy and procedure by the DSL.

By the nature of their duties, instrumental teachers usually establish a personal relationship with pupils. Individual tuition could provide an opportunity for pupils to give information which teachers feel constrained to pass on. There is also the potential for unfounded accusations about the conduct of music teachers during lessons.

The following may be helpful to visiting music teachers:

• If a pupil seems unhappy you should mention this to the Head of Music or the DSL
• When teaching individuals, especially in rooms that have no direct view from the corridor, staff should continue to create an impression of easy access and openness to other pupils and colleagues
• Whilst some physical contact is an essential element in some lessons unnecessary proximity to pupils must be avoided. If there is a need to touch a pupil, it should be made obvious that this is going to happen and an explanation as to why physical contact is necessary. For example: 'I am going to move your arms into the correct position over the keyboard. Is that ok?'
• If staff have any physical contact that may in any way be considered inappropriate, this must be reported to the DSL immediately

21. Handling a Disclosure

If a pupil discloses directly, listen carefully to what is said. Ask only open questions such as:

• What was happening at the time?
• Anything else you want to tell me?

Do not ask leading questions which may be considered as suggesting what might have happened, or who has perpetrated the abuse as this can later be interpreted as putting ideas into the child's mind. Allow the child to lead the conversation and remain calm.

NEVER GIVE UNDERTAKINGS OF ABSOLUTE CONFIDENTIALITY TO A PUPIL: breaking a child's confidence could be highly damaging; it is advisable from the outset to say that you might have to tell someone.

Make notes of the details of the disclosure using the child's words where possible. Records should:

• be handwritten and if at all possible within one hour but certainly within 24 hours
• be accurate and descriptive, using the child's words/quotations as much as possible
• not make assumptions
• not include any opinions
• indicate sources of information
• be clear and concise and include date, time, place and who was present where applicable
• include what led up to the disclosure and include what you said to the child (to illustrate that you did not ask leading questions)

If the disclosure is coming from a secondary source, for example a friend is telling you something about his or her friend, then if at all possible ask him/her to give you a written account of their concern which you should then pass on to the DSL along with your own account of the conversation.

Reassure the pupil that they have done the right thing and tell them that they are not to blame. Offer ongoing support.

Talk immediately to the DSL, unless the complaint involves the DSL, in which case talk to the Academic Director. Do not discuss the matter with anyone else.

If you observe anything which involved a pupil at the School which you feel could be a Child Protection matter, you must talk to the DSL as soon as possible.

22. Investigation, Referral and Reporting

It is the responsibility of the School staff to:

• Protect children from abuse
• Be aware of the School's Child Protection procedures
• Keep a sufficient record of any significant complaint, conversation or event
• Report any matters of concern to the Designated Safeguarding Lead for Child Protection
• Undertake appropriate training, including refresher training at three yearly intervals

It is not the responsibility of the School staff to investigate suspected abuse. The School is not an investigation or intervention agency for child protection, but it has an important role to play in the protection of the children in its care and to seek advice and support from external agencies where possible.

When considered appropriate and safe to do so, the DSL will discuss the concerns with the parents/guardians and seek their agreement before making a referral to external agencies, recognising that this may strengthen the capacity of parents to respond to the needs of their children before problems develop into abuse.

If a referral is made, the DSL will keep the Academic Director informed of the case unless the complaint involves the Academic Director in which case the Chair of the Board and Member of the Board for Child Protection, Darren Brown, must be contacted.

23. Confidentiality and Information Sharing

Child Protection records will be kept securely locked and separate from the pupils' main files. The best interests of the child will always be paramount. For manual records in principle the sharing of details of individual cases will be limited to the minimum number of people whilst ensuring that the staff who will be supporting and monitoring the child are kept appropriately informed.

If there have been any concerns of a Child Protection nature relating to a child the DSL and/or the Academic Director of the School has the responsibility of passing this information on should the child transfer to a new school.

Parents will normally be kept informed as appropriate of any action to be taken under these procedures.

24. Allegations against Pupils

The School acknowledges its responsibility to protect pupils and to prevent them from possibly committing a criminal offence, in line with UK government guidance on Preventing & Tackling Bullying (under The Education Act 2014). All staff should be aware that safeguarding issues can manifest themselves via peer-on-peer abuse. This is most likely to include, but may not be limited to, bullying (including cyberbullying), gender-based violence/sexual assaults and sexting.

A pupil against whom an allegation of abuse has been made may be suspended from the School during the investigation and the School's Behaviour Policy will apply. Issues of bullying and especially cyber-bullying will be addressed through the Anti-bullying Policy and the Internet Use Agreement for Pupils.

25. Allegations against Staff

If an allegation is made against a member of staff, the Academic Director would be informed immediately.

Where an allegation or complaint is made about the DSL, the member of staff or the complainant should report directly to the Academic Director. Where an allegation or complaint is made about the Academic Director, the complainant will report to and consult with the Chair of the Board who is also the member of the Board responsible for Child Protection, Darren Brown.

Confidentiality will be maintained throughout this stage in order that any subsequent investigation is not prejudiced.

There are two possible routes for further investigation: either by the police or under the School's disciplinary and competence procedure.

For UK qualified teachers, separate consideration will be given to whether to refer the matter to the TRA (Teaching Regulation Agency) in order to consider prohibiting the individual from teaching. Reasons such an order may be considered are: "unacceptable professional conduct", "conduct that may bring the profession into disrepute" or "conviction, at any time, for a relevant offence".

Allegations against an expatriate teacher who is no longer working at the School should be referred to the appropriate authorities in their home country.

Whistleblowing

All staff have a duty to raise concerns about the attitude and actions of colleagues. For further details on this, please refer to the School's Whistleblowing Policy.

26. Appropriate and Inappropriate use of Electronic Communication

'The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation — technology often provides the platform that facilitates harm.' (Keeping Children Safe in Education, September 2019). Online safety at the School both protects and educates the whole School community in the use of technology and establishes mechanisms to identify, intervene and escalate any incident where appropriate.

Access to the School's internal network and to the internet is essential as a means of providing valuable tools to support teaching and learning. While recognising these benefits, the School is also mindful of potential risks to the well-being of young people through excessive and continual exposure to online content, some of which can be harmful.

When using School ICT facilities and wireless network, internet access is comprehensively filtered and monitored to prevent access to harmful or offensive websites. The database of blocked websites is regularly updated to capture any new and emerging online threats. At the same time as ensuring that appropriate filters and monitoring systems are in place, the School is careful that 'over-blocking' does not lead to unreasonable restrictions as to what children can be taught with regard to online teaching and safeguarding.

A comprehensive programme of online safety study is delivered across all year groups, during timetabled lessons and PSHEE sessions. Topics are appropriately differentiated dependent upon age group, with a primary focus of preventative strategies. All pupils are aware of a direct course of action that should be followed if they wish to report an incident of online misconduct. Clear guidelines when using the School computers are set out in the School's Safe and Acceptable Use of Technology policy. These guidelines make expressly clear that even while using social media, blogs and forums that pupils are constantly representing the School's community.

All staff should exercise caution in electronic communication with pupils. Staff should not give their personal mobile phone numbers or e-mail addresses to pupils, nor should they communicate with them by text message, WhatsApp or personal e-mail, unless this has been agreed with the DSL. If staff need to speak to a pupil by telephone, they should use one of the School's telephones and e-mail using the School system. The group leader on all trips and visits, including overnight stays, should ideally take a School mobile phone with him/her but may well use his or her own phone following discussions and agreement with the DSL. The group leader will delete any record of pupils' mobile phone numbers at the end of the trip or visit and should ensure that pupils delete any staff numbers that they may have acquired during the trip.

Staff should also:

• ensure that their own personal social networking sites are set as private and ensure that pupils are not approved contacts
• never use or access social networking sites of pupils
• never use internet or web-based communication channels to send personal messages to pupils
• only make contact with pupils for professional reasons
• recognise that WhatsApp / text messaging should only be used when other forms of communication are not possible

27. Acceptable use of Mobile Phones, Cameras and Recording Devices

Mobile Phones

All staff should aim to ensure that their mobile phones, personal cameras and recording devices are not in use or in evidence in front of pupils. If a member of staff is using a mobile device in front of a pupil they should be able to demonstrate that it is on School business. The PE Department may use their mobile phones when going off-site as a point of contact.

Cameras

Children should only be photographed or filmed on video for the purpose of recording their development or participation in events organised by the School. Parents indicate their consent to the above if they do not opt-out of this as designated in the School's Terms & Conditions of entry. Parents have the right of access to records holding visual images of their child.

Staff are allowed to:

• Take photos on any School device of our pupils
• Store the photos on the School network
• Use the photos for School promotions
• Take photos on a personal own device but then delete them from the device and the cloud once they have been used

If a member of staff takes a photo on a personal mobile phone or device, this must be uploaded to a School social media account and deleted from the personal mobile device as soon as possible.

Staff cannot:

• Keep photos unnecessarily on personal tablets or mobile phones
• Download photos to personal computers or devices at home
• Store any photos of pupils that have been obtained from elsewhere on personal computers, e.g. Twitter
• Name pupils by surname on any social media

By following the above procedures, staff minimise their risk of being exposed to inappropriate images as contact is kept within professional boundaries.

Images taken must be deemed suitable without putting the child in any compromising position that could cause embarrassment or distress. Staff must ensure that the pupil/s understand why the images are being taken and have agreed to the activity. Images should not be made during one-to-one situations. Staff should ensure that pupils are appropriately dressed.

Images taken on a School camera must be downloaded as soon as practicable. Images should be downloaded to an approved network folder designated by the IT Department. All images of pupils should be stored securely and only accessed by those authorised to do so. Images must never be taken secretively.

Images may only be uploaded to the School website by authorised staff and should never be uploaded to the internet for any other reason, including onto social networking sites, e.g. Facebook.

If an image is to be displayed in a place to which the public have access, it should not display the pupil's name. Similarly, where a pupil is named (in a School prospectus, for example) the name should not be accompanied by a photograph or video.

Under no circumstances must cameras of any kind be taken into bathrooms or changing areas.

It is the responsibility of all members of staff to be vigilant and report any concerns to the DSL.

Any non-compliance will be taken seriously, logged and investigated appropriately in line with our disciplinary policies.

28. Visiting Speakers and Volunteers

The School will ensure that visiting speakers, whether invited by staff or pupils, are suitable and appropriately supervised. The following outlines the procedure for visiting speakers:

• All visiting speakers will be approved by the Academic Director, or the DSL
• Appropriate checks on the suitability of the speaker should be made, which may include internet searches and/or contacting schools where the person has already spoken. Although not always possible, it is useful to invite speakers from an established company, charity or other group whose aims are well-documented
• There will be an understanding that the speaker will be expected to talk with staff about the content of the presentation before the event; speakers and staff must allow time for this discussion, whether it is on the day or beforehand
• Visiting speakers must arrive at the School Office in good time to sign the Schools' visitors' book. They must bring suitable identification to prove who they are, such as a passport or driving licence
• All visitors must be supervised at all times and not left alone with pupils
• Visiting speakers should understand that their presentation will be brought to an early end, if the content proves unsuitable
• All information about the visiting speaker and the booking process should be recorded on a Visiting Speakers' Record which will be kept in the Visiting Speakers' Register is kept in the School Office
• Where the School uses volunteers, it will adhere to the vetting requirements outlined in KCSIE 2019 and undertake risk assessments, as appropriate

29. Monitoring

The DSL will monitor the operation of this policy and procedures and liaise with the member of the Board responsible for Child Protection, Darren Brown.

Any Child Protection incidents at the School will be followed by a review of the safeguarding procedures within the School by the DSL and a prompt report to the Board. Any deficiencies or weaknesses in regard to Child Protection arrangements at any time will be remedied without delay.

The Academic Director and Senior Leadership Team (including the DSL) will monitor and evaluate, with the Board, the effectiveness of the Safeguarding and Child Protection Policy on an annual basis. The policy will be subject to review at least annually (or more frequently if changes to legislation, regulation or statutory guidance so require). The Safeguarding and Child Protection Policy will also be subject to critical review by the member of Board responsible for Safeguarding and Child Protection, Darren Brown, who has received safeguarding training, on an annual basis, the outcome of which will be reported to the Board. The Board will review this policy and the implementation of its procedures annually, including good cooperation with local agencies, and approve the amendments to the policy, which will, in turn, be signed off by the Chair of the Board. This annual review will take account of evidence such as staff training in safeguarding matters, referral data, analysis of any issues and themes which have emerged in the School and how these have been handled, initiatives to educate pupils about safeguarding, and details of any contribution the School has made to local discussions on safeguarding matters.

30. Secure School Premises

The School will take all practical steps to ensure that premises are as secure as circumstances permit.

A visitor's book is kept at reception at the School and all visitors are required to sign in on arrival and sign out on departure and will be escorted whilst on School premises by a member of staff or appropriately vetted volunteer. All visitors will be given a name badge with the title 'Visitor' which must be clearly displayed and worn at all times whilst on the premises.

The School has a crisis management procedure and drills are regularly carried out so that pupils know what to do in an emergency.

31. Safer Recruitment Practices

The School has a Safer Recruitment Policy. All relevant staff undertake Safer Recruitment training with the dual aim of safeguarding the pupils in the school and avoiding any allegation of negligence in the recruitment process.

The School will, when appointing staff, volunteers and visitors, take account of the DfE guidance on Safer Recruitment and that issued by the Education Department's Contracts and Personnel Section; observing the following safeguards:

1. That documentation sent out to potential candidates will make it clear that child safeguarding is a high priority of the school and that rigorous checks will be made of any candidate before appointments are confirmed
2. That a reference as to the suitability of a candidate to work with children will always be obtained from the last employer, and may also be sought from other previous employers
3. That at interview candidates will be asked to account for any gaps in their career/ employment history, and questions asked will include some designed to explore their attitudes towards children
4. That rigorous background checks will be carried out on any staff or volunteer in regulated activity. Evidence of relevant checks will be recorded and stored in a single, central location, easily accessible when appropriate and necessary
5. Staff, volunteers, and helpers who have worked or resided outside of the UK / Indonesia will be asked to produce a certificate of good conduct (or national equivalent) from the authorities representing the countries from which they have recently moved. If the individual will be involved in teaching, the College will undertake an additional check for information about any teacher sanction or restriction that an EEA professional regulating authority has imposed
6. That assurance is obtained that appropriate child protection checks and procedures apply to any staff employed by another organisation and working with the School's pupils on another site
7. Board members acknowledge their responsibility for any child safeguarding issues that may arise when other organisations use the facilities of the School. They exercise their responsibility by ensuring such organisations accept and meet all the requirements of the School's safeguarding policy or that the organisation's own policy is suitably in line with this
8. The School will be compliant with the expectations of the Independent School Standards Regulation
9. Induction and on-going performance management at the School will focus in significant part on safeguarding, in order to maintain the profile of the issues, but also to minimise the risk of a member of staff deliberately or inadvertently abusing their relationship with the pupils
10. The School will report to the Disclosure & Barring Service, or other appropriate overseas authority, within one month of leaving the School any person (whether employed, contracted, a volunteer or student) whose services are no longer used because s/he is considered unsuitable to work with children. In the event of such a person resigning, the investigation will continue to a conclusion. If that conclusion indicates that the person would have been suspended had s/he not resigned, a similar referral will be made immediately.

Disclosure & Barring Service
PO Box 181
Darlington DL1 9FA
Tel: 0300 123 1111