Safeguarding Policy

This policy should be read in conjunction with:


  • Keeping Children Safe in Education (2022): All school staff as a minimum to read Part  1 and Annex B, SLT, the Advisory Board and Directors to also read Part 2 and Annex  C.
  • Working Together to Safeguard Children (2018)
  • IT Acceptable Use Policy
  • Anti-bullying policy
  • Safer Recruitment policy
  • Complaints Procedures
  • Whistleblowing policy
  • The Staff Code of Conduct (Staff Handbook)
  • Behaviour Policy  
  • Children Missing Education policy
  • Low Level Concerns Policy

The Designated Safeguarding Lead at International School Pune is:


The Deputy Designated Safeguarding Leads at International School Pune are:

Name (Head of Boarding Female):

Name (Head of Boarding Male):

Name (Another member of staff)


The Designated Safeguarding Lead(s) will ensure that there is always cover for their role, including  for any out of hours/out of term activities. Arrangements for cover will be communicated clearly to  staff.


The International School Safeguarding Team are supported in their work by the School’s Advisory Council  and the Board of Directors. The Advisory Council Safeguarding Lead is: Adam Lubbock.

Policy Statement

1.1.1 Safeguarding and Child Protection Policy

International School is committed to safeguarding, protecting and promoting the welfare of children. The  Safeguarding and Child Protection Policy is an integral part of our overall approach to ensuring that  all students, regardless of special needs or disability, racial/cultural heritage, religious belief, sexual  orientation or age, receive an excellent standard of bespoke pastoral care.

International School aims to prepare its students to stay safe in life beyond that of the educational setting,  delivering a personal, social, health and relationships curriculum that is representative, realistic and  abreast of rapid development and is in keeping with technological advancements which is an  integral part of our modern society.  

1.1.2 This policy has been prepared in compliance with, and with regard to: • Keeping Children Safe in Education (September 2022)  


International School recognises and acts upon its legal duties as set out in the above statutes, regulations  and guidance, to protect its students and staff from harm and to work with other agencies in  carrying out these duties and responding to safeguarding concerns.  

International School’s Board of Directors and Advisory Council recognises the requirement to comply with  its duties under legislation. Thus, this policy complies with KCSIE (September 2022) and Working  Together to Safeguard Children (2018) and procedures detailed by the Suffolk Safeguarding  Partnership.

All staff are required to have read and understood this policy, Parts One and Five of KCSIE 2022 and  the related policies referenced on Page 1 of this policy. Staff will be also be required to undergo  safeguarding and child protection training, a record of which will be kept by the International School  Safeguarding Team. Training records will be reviewed and updated regularly by the Safeguarding  Team.

The Board of Directors and Advisory Council will ensure that they have read and understood Parts  One and Two of KCSIE, including Annex C.

Compliance with this policy will be monitored by the Principal, the DSL and the Advisory Council  Safeguarding Lead.


This policy is mandatory for all members of staff and volunteers at the School (temporary and  permanent). This policy is applicable at all times that staff and volunteers are working with students,  including when this involves working away from the school.



This policy is available to all parents, staff and volunteers on the School’s website. A paper copy of  this policy is also available to parents upon request to the School Office.

1.2 Creating a Culture of Safeguarding


Safeguarding and promoting the welfare of children is everyone’s responsibility. All staff and  volunteers are expected to recognise International School’s holistic approach, ensuring that students’  wellbeing and welfare is at the forefront of all practice.

The School seeks to promote and nurture the mental health and wellbeing of all students and  members of staff as reflected in procedures and practices outlined in the Staff Handbook and  through the School’s high standard of pastoral care.

At International School we are committed to safeguarding children and young people and we expect  everyone who works at International School to share this commitment. Adults at the School take all  welfare concerns seriously and encourage children and young people to talk to us about anything  that worries them. We will always act in the best interest of the child. Staff are trained to adopt an  ‘it could happen here’ approach.


International School takes a broad approach to safeguarding in order to recognise that protecting the  welfare of children includes:

  • Protecting children from maltreatment
  • Preventing the impairment of children’s health or development
  • Ensuring that children are growing up in circumstances consistent with the provision of safe  and effective care
  • Taking prompt action to enable all children to have the best outcomes
  • Ensuring that Early Help is accessed promptly where concerns are emerging

If a child is suffering significant harm, or is likely to suffer significant harm, immediate action will be  taken to protect that child and a referral will be made to social services.

If a child is not suffering significant harm, or likely to, but requires additional support in order to  thrive, action will be taken to promote the welfare and wellbeing of that child. This may include (as  an example): additional pastoral support, intervention in liaison with the SENDCO, liaison with  agencies who can offer the child support, support for the parents and peer support.  

The school uses MyConcern to ensure that timely and accurate records are kept of all safeguarding  concerns. The Safeguarding Team aims to intervene promptly to address risks and to prevent issues  from escalating.  

Every member of staff has access to MyConcern training via the DSL and the Advisory Council  Safeguarding Link. Staff are aware that all safeguarding concerns should be reported using


Records will be comprised of all relevant information, including the views of the child,  communication with external agencies and records of communication with parents and guardians.


The School will contribute to inter-agency working, in line with the statutory guidance provided in  Working Together to Safeguard Children (2018). This includes providing a co-ordinated offer of early  help when additional needs of children are identified and contributing to inter-agency plans to  provide additional support to children subject to Child Protection Plans.


The School has systems in place to:  

  • Prevent unsuitable people working with students
  • Identify students who are at risk of and/or are likely to suffer significant harm and take  appropriate action and promote the welfare of students in need of additional support • Promote safe practice and challenge poor and unsafe practice  
  • Protect students and staff from online risks, which include online safety education and  training, policies and procedures governing the use of IT, filtering and monitoring systems  and procedures to manage any incidents that occur
  • Filter and monitor online activity via applications which prevent access to blocked internet  sites and report attempts to access sites that may give rise to concern. Email messages  between staff and students are also scanned for inappropriate language and behaviour
  • Deal with issues of confidentiality, information sharing and consent in line with the GDPR  regulations
  • Ensure that staff do not, through their actions, place students at risk of harm, or themselves  at risk from an allegation of harm (by providing guidance on areas such as 1-1 tuition, sports  coaching, conveying by car, inappropriate electronic communication).  


At International School we encourage students to share their views via student voice opportunities such as  International School Student Council, via Form Tutors and with a transparent safeguarding structure,  ensuring that students have a clear understanding of who to approach with safeguarding concerns.


Where safeguarding advice is needed, a member of the Safeguarding Team may consult the Suffolk MASH PCL, the LADO (Local Area Designated Officer) or the school’s Advisory Council Safeguarding  Link. The Principal will also be notified in the following circumstances:

  • The issue involves an allegation against a member of staff or a volunteer • The issue relates to a concern about the education provided to a student • The issue involves a referral to external agencies
  • The issue could affect the school’s reputation

In the event that the issue involves an allegation against the Principal, the Chair of the Advisory  Council will be informed by the member of staff or by the DSL.


All staff are required to adhere to the ICT Acceptable Use Agreement and specifically to  ensure that any images taken of students are appropriate and stored and managed safely.

1.3 Children with Special Educational Needs and Disabilities

Children with special education needs and disabilities (SEND) can face additional  safeguarding challenges. Staff must be alert to the fact that additional barriers can exist  when recognising abuse and neglect in this group of children. These may include:  

  • Assumptions that indicators of possible abuse such as behaviour, mood and  injury relate to the child’s disability without further explanation;  
  • Being more prone to peer group isolation than other children;
  • The potential for children with SEN and disabilities to be disproportionately  impacted by things like bullying without outwardly showing any signs; and  • communication barriers and difficulties in overcoming these barriers.  

To address these additional challenges, children with SEND may require extra pastoral  support. The additional vulnerabilities of pupils with SEND and the school’s duty to make  reasonable adjustments should be particularly carefully considered in situations where the  use of reasonable force may be needed in response to risks presented by incidents involving  children with SEND or medical conditions.  

1.4 Boarding

Boarding schools are required to promote and protect students’ welfare. The School will comply  with the relevant National Minimum Standards and Regulations for boarding schools and is  particularly alert to the potential for abuse in this setting.  

As a member of the Boarding Schools’ Association, the school follows the Commitment to Care  Charter meaning that:  

  • We are committed to the highest duty of care and safeguarding  
  • Everyone working in the school will raise any concerns immediately  
  • We will follow all statutory safeguarding guidance and laws and report concerns to the  relevant authority and the BSA  
  • We will support any present students affected by abuse and those who report concerns, and  offer support to past students.


1.5 Looked After and Previously Looked After Children

The school will ensure that staff have the skills, knowledge and understanding necessary to keep  safe any children on roll who are looked after by the local authority.  

1.6 Private Fostering

Private fostering occurs where a child under the age of 16 (or 18 if disabled) is provided with care  and accommodation by someone to whom they are not related in that person’s home, for 28 days or  more, unless that person has parental responsibility for them or is a local authority or agency foster  carer. If a member of staff becomes aware that a student may be in a private fostering arrangement,  they should raise this in the first instance with the Designated Safeguarding Lead. The School will  then notify Suffolk local authority through the Private Fostering team (FCFCT) on 01473 265025 or  email [email protected] to report or for advice. At Stoke we are aware that this could occur for a  boarder who may stay with a host family or guardian for extended periods. We will ensure that we  and they have reported the arrangement to the appropriate safeguarding partnership where the  child is residing.  

A private fostering arrangement is one that is made privately (without the involvement of a local  authority) for the care of a child under the age of 16 years (under 18, if disabled) by someone other  than a parent or close relative, in their own home, with the intention that it should last for 28 days  or more. A close family relative is defined as a ‘grandparent, brother, sister, uncle or aunt’ and  includes half-siblings and step parents; it does not include great-aunts or uncles, great grandparents  or cousins.  

Parents and private foster carers both have a legal duty to inform the relevant local authority at least six weeks before the arrangement is due to start; not to do so is a criminal offence.  

Whilst most privately fostered children are appropriately supported and looked after, they are a  potentially vulnerable group who should be monitored by the local authority, particularly when the  child has come from another country.  

In some cases privately fostered children are affected by abuse and neglect, or be involved in  trafficking, child sexual exploitation or modern-day slavery.  

Schools have a mandatory duty to report to the local authority where they are aware or suspect that  a child is subject to a private fostering arrangement. Although schools have a duty to inform the  local authority, there is no duty for anyone, including the private foster carer or social workers to  inform the school. However, it should be clear to the School who has parental responsibility.  

International School staff should notify the designated safeguarding lead when they become aware of  private fostering arrangements. The designated safeguarding lead will speak to the family of the  child involved to check that they are aware of their duty to inform the LA. The school itself has a  

duty to inform the local authority of the private fostering arrangements. On admission to the school,  we will take steps to verify the relationship of the adults to the child who is being registered.

At Stoke we are mindful that private fostering could also include guardianship host family  arrangements when these occur for more that 28 days. These need to be reported by the  guardianship organisation and the International School.

2.1 Our Aims

By creating a culture of safeguarding, we aim to:

  • create an environment at International School which is safe and secure for all students  • encourage our students to establish positive and fulfilling relationships within their families,  with peers and with other adults;  
  • encourage children to develop a sense of autonomy and independence;  • work with parents to build their understanding of and commitment to the welfare of all  pupils.  

We will ensure that children and young people are taught about safeguarding, including online safety, through teaching and learning opportunities as part of a broad and balanced curriculum. This  is in order to help children stay safe, recognise when they do not feel safe and identify who they  might or can talk to. This may include covering relevant issues through personal, social, health and  economic education (PHSE) and relationships and sex education (RSE).  

Schools and Schools play a crucial role in preventative education. Preventative education is most  effective in the context of a whole-school or School approach that prepares pupils and students for  life in modern Britain and creates a culture of zero tolerance for sexism, misogyny/misandry,  homophobia, biphobic and sexual violence/harassment.

We will also ensure there is a comprehensive curriculum response to online safety issues, enabling  children and young people and their parents to learn about the risks of new technologies,  communication and social media and how to use these responsibly.  

2.1.2 The School will ensure there are appropriate filters and monitoring systems in place to  safeguard children and young people from potentially harmful and inappropriate online material.  Risks are, however, considerably greater where devices are beyond the school’s control (3G, 4G, 5G,  social media platforms etc.), so the education aspect of safeguarding in this area is particularly  important. Getting pupils into safe habits when accessing the online world via our systems should  enable them to make the right choices when using their own connections. A key part of the online  safety support we provide is education about the need for safe practices and habits (through  assemblies, PSHE, the curriculum, peer support and form time) and showing students how to apply  controls and privacy settings to their own devices and accounts. We also ensure that they  understand the need not to share their login details with others and to change their passwords  regularly.  

We believe that educating parents and guardians empowers them to support their children, or the  children and young people in their care, in making positive choices to keep safe. Our Advisory  Council Safeguarding Link delivers information, advice and guidance to parents and guardians in  liaison with the Safeguarding Team.

Guidance about online learning can be found in the Guidance for Safer Working Practices (February, 2022).

Staff training will include specific Online Safety training in order to ensure that all staff have an up to-date understanding of current risks, trends and topics so that they are well-placed to advise and  guide International School students.


2.2 In order to fulfil these aims, the Principal will take the necessary steps to ensure that: 2.2.1

All staff (including supply and temporary) and volunteers receive training in safeguarding  children and an explanation of the systems within the School which support this as part of  their induction. This includes:  

  • the School’s Safeguarding and Child Protection policy and procedures, including  whistleblowing procedures, the Staff Handbook and the Code of Conduct • Part 1 and Annex B of Keeping Children Safe in Education (September 2022)  • The Whistleblowing Policy
  • The International School behaviour policy  
  • The safeguarding response to children who go missing in education  • The identity and role of the Designated Safeguarding Lead(s) and Deputy Designated  Safeguarding Leads and how to contact them  
  • Safeguarding and child protection training and Online safety training  2.2.2

All staff, volunteers and the Principal are trained in child protection, (including Prevent Awareness,  online safety training, the local early help process and how to manage a report of child on child  sexual violence or sexual harassment) regularly, in line with advice from the Suffolk Safeguarding  Partnership, and receive safeguarding and child protection updates as required, but at least  annuallyThe Designated Safeguarding Leads receive the required updated child protection and  Prevent Training, at least annually (as set out in Annex B of Keeping Children Safe in Education  2022).

The key training elements are: Induction Training – this is mandatory and should include;  • The International School safeguarding and child protection local arrangements

  • the safeguarding and child protection policy;  
  • the code of conduct);  
  • the behaviour policy;
  • the safeguarding response to children who go missing from education; and  • the role of the designated safeguarding lead (including the identity of the designated  safeguarding lead and any deputies). (see KCSIE 2022)  
  • Online Safety Training


All Staff in our school have a responsibility to provide a safe learning environment in which our  children can learn.

International School recognises that, because of the day-to-day contact with children, school staff are well  placed to observe the outward signs of abuse. The School will therefore:

  • Create a culture of vigilance where the welfare of our pupils is promoted and where timely  and appropriate safeguarding action is taken.
  • Establish and maintain an environment in which children feel safe, secure, are encouraged to  talk and are listened to enabling children to learn
  • Ensure children know that there are adults in the school whom they can approach if worried  or are in difficulty
  • Be sensitive that children may not feel ready or know how to tell someone that they are being  abused, exploited, or neglected and they may not recognise their experiences as harmful.  (This should not prevent staff from having a professional curiosity and therefore they should  continue to speak to the DSL/DDSL if concerned about a child.)
  • Encourage all staff to exercise professional curiosity and know that spotting what to look for  is vital for the early identification of abuse and neglect so that staff are able to identify cases  of children who may be in need of help or protection.
  • Ensure pupils receive the right help at the right time to address risks and prevent issues  escalating
  • Encourage staff to act immediately if they have a concern about a child
  • Give children time if they wish to talk to a member of staff, be sensitive and supportive to  their needs, listening carefully, reflecting back, using the child’s own language • Include opportunities in the curriculum, specifically through Relationships and Sex Education  , computing and IT for children to develop the skills they need to recognise and stay safe from  abuse and to know who they should turn to for help  
  • Include in the curriculum material which will help pupils develop realistic attitudes to the  responsibilities of adult life, particularly with regard to childcare and parenting skills  • Protect children from harm and to ensure that they are taught in a way that is consistent with  the law and our values and to promote respect for all others
  • Facilitate understanding of wider issues within the context of learning about the values on  which our society is founded and our system of democratic government
  • Provide a curriculum which actively promotes the fundamental British values of democracy,  the rule of law, individual liberty and mutual respect and tolerance of those with different  faiths and beliefs
  • Promote tolerance of and respect for people of all faiths (or those of no faith), races, genders,  ages, disability and sexual orientations
  • Make parents/carers aware of the school policies and practice for safeguarding and ensure  that, wherever possible, every effort will be made to establish open and honest effective  working relationships with parents and colleagues from partner agencies
  • Regularly remind staff (training and policy) that if staff have a safeguarding concern or  allegation about another member of staff (including supply staff, volunteers or contractors)  that does not meet the harm threshold, then this should be shared in accordance with the  school or School low-level concerns policy.

‘Safeguarding’ is broader than ‘child protection’. As well as protecting pupils from harm, ‘safeguarding’  widens the responsibility to preventing harm and promoting the welfare of children. It is recognised  that safeguarding and promoting the welfare of pupils includes:

  • Protecting children from maltreatment
  • Preventing impairment of children’s mental and physical health or development • Ensuring that children are growing up in circumstances consistent with the provision of safe  and effective care
  • Taking action to enable all children to have the best outcomes

DSLs attend training every two years; and in addition to formal training, their knowledge and skills  should be refreshed at regular intervals, at least annually.

All other staff – will receive regular safeguarding and child protection updates as required, but at  least annually, to provide them with relevant skills and knowledge to safeguard children effectively.  

Safer Recruitment training is available to all relevant staff and governors who are involved in the  recruitment process and is updated every 3 years.


The School adheres to the Safer Recruitment Policy and safer recruitment procedures. Procedures  are in accordance with the Independent School Standards Regulations and include ensuring that at  least one member of any recruitment panel involved in all stages of the recruitment process has  undertaken the appropriate training in Safer Recruitment and carrying out all required checks on the  suitability of staff and volunteers to work with children and young people. Appropriate supervision  arrangements are put in place if staff start work before their DBS disclosure has been obtained and,  in all cases, a Barred List Check and Prohibition Order check (if applicable) will have been  undertaken. Relevant staff are also asked to confirm that they do not meet the criteria for  disqualification under the Childcare Act 2006 and the 2018 Regulations.  


The School carries out the mandated checks on all people who serve on the School’s Board of  Directors and Advisory Council. This process is overseen by the Advisory Council Safeguarding Lead.  The required checks on the proprietors are carried out by the DfE.


Where the School ceases to use the services of any person (whether employed, contracted, a  volunteer or student) or the person resigns or otherwise ceases to provide his or her services  because it is considered that the person may be unsuitable to work with children, a referral will be  made to the Disclosure and Barring Service (DBS) in accordance with the procedural guidance at (contact: PO Box 181, Darlington,  DL1 9FA. Tel: 01325 953795, email [email protected]). In cases involving teaching staff,  the school will also decide whether to refer the matter to Teaching Regulation Authority (TRA) to  consider prohibiting the individual from teaching.  


All School staff are alert to signs of abuse and neglect and all staff know to whom they should report  concerns or suspicions of abuse or neglect.  


All International School staff keep themselves updated on safeguarding issues and child protection  procedures by accessing advice, guidance and training as appropriate to their role. Key topics are  covered throughout the year (as detailed in the International School Safeguarding Calendar).


This Policy is compatible with, and meets all applicable requirements of, the Suffolk Safeguarding  Partnership. The School ensures that it has positive communication with the Suffolk Safeguarding  Partnership to ensure compliance with local protocol and access to relevant support. The Suffolk  Safeguarding Partnership can be contacted through the Local Social Services Department, Children’s  Services. Their contact details are:

  • Local Authority Designated Officer (LADO): 0300 123 2044
  • Customer First: 0800 800 4005
  • Suffolk Multi Agency Safeguarding Hub (MASH): 0345 606 1499
  • Suffolk Safeguarding Children Board: 01473 265359
  1. Responding to Safeguarding and Child Protection Concerns


Everyone who comes into contact with children and their families has a role to play in safeguarding  children. International School staff are particularly important as they are in a position to identify concerns  early and provide children with help, to prevent concerns from escalating. School staff have a  responsibility to identify children who may be in need of extra help or are suffering, or are likely to  suffer, significant harm. All staff have a responsibility to take appropriate action, working with other  services as needed.  


Any concern, allegation or incident of abuse must be reported to the Designated Safeguarding Lead or one of the Deputy Designated Safeguarding Leads immediately. Staff should not assume that a  colleague or another professional will take-action and share information that might be critical in  keeping children safe. They should be mindful that early information sharing is vital for effective  identification, assessment and allocation of appropriate service provision. All concerns, discussions  and decisions made and the reasons for those decisions should be recorded via MyConcern. If in  doubt about recording requirements, staff should discuss this with the Designated Safeguarding  Lead. Fears about sharing information must not be allowed to stand in the way of the need to  promote and protect the safety of children. The School’s use of MyConcern ensures that  information can be shared promptly and effectively.


If staff have concerns about a child (as opposed to a child being in immediate danger or risk of harm  – see para 3.5 below), they will need to decide what action to take. All staff should be prepared to  identify children who may benefit from early help (see the Early Help Framework), that is, support as  soon as an issue emerges. Such issues should be discussed in the first instance with the Designated  Safeguarding Lead or one of the Deputy Designated Safeguarding Leads. The Early Help process may  also involve sharing information with other professionals and contributing to an early help  assessment.  


Any child may benefit from early help, but staff should be particularly alert to the potential need for  early help for a child who:


  • is disabled and has specific additional needs
  • has special educational needs
  • is a young carer
  • is showing signs of being drawn into anti-social or criminal behaviour  
  • is frequently missing/goes missing from care or from home  
  • is misusing drugs or alcohol
  • is at risk of modern slavery, trafficking or exploitation
  • is in a family circumstance presenting challenges for the child  
  • has returned home to their family from care
  • is showing early signs of abuse and/or neglect
  • is at risk of being radicalised or exploited
  • is a privately fostered child  


If a child is in immediate danger or at risk of harm, this must be reported to the Designated  Safeguarding Lead, who will make a referral to children’s social care and/or the police immediately.  It is not the role of the School to investigate suspected or alleged abuse; this is the role of the Police  and Social Services. Staff are also trained that anyone can make a referral if they believe that a child  is in immediate danger or at immediate risk of harm.

3.6 What is Child Abuse?

Knowing what to look for is vital to the early identification of abuse and neglect. All staff are aware of  the indicators of abuse and neglect so that they are able to identify cases of children who may be in  need of help or protection. If staff are unsure they should always speak to the designated safeguarding  lead (or deputy).

All School staff know that abuse, neglect and safeguarding issues are rarely standalone events that  can be covered by one definition or label. In most cases, multiple issues will overlap with one another. All staff, but especially the designated safeguarding lead (and deputies) should consider whether  children are at risk of abuse or exploitation in situations outside their families. Extra-familial harms  take a variety of different forms and children can be vulnerable to multiple harms including (but not  limited to) sexual abuse (including harassment and exploitation), domestic abuse in their own intimate  relationships (teenage relationship abuse), criminal exploitation, serious youth violence, county lines,  and radicalisation.

Technology is a significant component in many safeguarding and wellbeing issues. Children are at risk  of abuse online as well as face to face. In many cases abuse will take place concurrently via online  channels and in daily life. Children can also abuse their peers online, this can take the form of abusive,  harassing, and misogynistic messages, the non-consensual sharing of indecent images, especially  around chat groups, and the sharing of abusive images and pornography, to those who do not want  to receive such content.

Indicators of abuse and neglect

Keeping Children Safe in Education (DfE, 2022) describes abuse in the following way:

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. Harm can include ill treatment that is not physical as well as the  impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation  to the impact on children of all forms of domestic abuse. Children may be abused in a family or in an  institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by


an adult or adults or by another child or children.If a member of staff has concerns about a pupil, they  should report their concerns to the Safeguarding Team via My Concern.  

The categories in this document are drawn from Keeping Children Safe in Education September  2022:  


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 ill-treatment of a child such as to cause severe and  persistent adverse effects on a child’s emotional development. It may involve conveying to children  that they are worthless or unloved, inadequate, or unvalued, or valued only in so far 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 looking at  or the production of sexual images, watching sexual activities, encouraging children to behave in  sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take  place online, and technology can be used to facilitate online abuse. Sexual abuse is not solely  perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The  sexual abuse of children by other children is a specific safeguarding issue in education.  


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, for example, as a result of maternal substance abuse. Once a child is born, neglect may  involve a parent or carer failing to: provide adequate food, shelter and clothing (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); ensure access to appropriate  medical care of treatment. It may also include neglect of, or unresponsiveness to, a child’s basic  emotional needs.



Child Sexual Exploitation (CSE) – CSE occurs where an individual or group takes advantage of an  imbalance of power to coerce, manipulate or deceive a child 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. CSE does not always involve physical contact; it can also occur through the use  of technology. CSE can affect any child or young person (male or female) under the age of 18 years,  including 16 and 17-year-olds who can legally consent to have sex. It can include both contact  (penetrative and non-penetrative acts) and non-contact sexual activity and may occur without the  child or young person’s immediate knowledge (e.g. through others copying videos or images they  have created and posted on social media).  

The above CCE indicators can also be indicators of CSE, as can:

  • children who have older boyfriends or girlfriends; and
  • children who suffer from sexually transmitted infections or become pregnant.  

Some of the following can be indicators of CCE (KCSIE 2021):

  • children who appear with unexplained gifts or new possessions;
  • children who associate with other young people involved in exploitation;
  • children who suffer from changes in emotional well-being;  
  • children who misuse drugs and alcohol;  
  • children who go missing for periods of time or regularly come home late; and •children who regularly miss school or education or do not take part in education.


E-Safety & Online Safety (further guidance can be found in the school’s ICT Policy) All members of staff are aware of the risks to children online and we seek to help children  keep themselves safe online in a range of ways. Staff are trained in and receive regular  updates in e-safety and recognising reporting concerns through MyConcern. Online safety will be a running and interrelated theme when devising and implementing  policies and procedures. This will include considering how online safety is reflected in all  relevant policies and whilst planning the curriculum, any teacher training, the role of the DSL  and any parental engagement.

The Whole School’s ICT e-safety policy recognises that Internet safety is a whole school  responsibility, involving staff, pupils and parents with appropriate filters and monitoring  systems in place.

It is essential that children are safeguarded from potentially harmful and inappropriate online  material. The school adopts a whole school approach to online safety to protect and educate  pupils and staff in their use of technology, and establishes mechanisms to identify, intervene  in, and escalate any concerns as appropriate.

Appropriate filters and monitoring systems are in place. However, they are careful not to ‘over  block’ as this will lead to unreasonable restrictions as to what children can be taught with  regard to on-line teaching and safeguarding.

We recognise that our children are growing up in an increasingly complex world, living their  lives on and offline. This presents many positive and exciting opportunities, but we recognise  it also presents challenges and risks. Any pupil can be vulnerable online, and their vulnerability  can fluctuate depending on their age, developmental stage and personal circumstances. We  want to equip our pupils with the knowledge needed to make the best use of the internet and  technology in a safe, considered and respectful way, so they are able to reap the benefits of  the online world.

The three main areas of online risk could be categorised as:

▪ Content: being exposed to illegal, inappropriate or harmful content, for example,  pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, or  radicalisation or extremism;

▪ Contact: being exposed to harmful online interaction with other users, for example, peer  to peer pressure, commercial advertising, and adults posing as children or young adults  with the intention to groom or exploit them for sexual, criminal, financial or other  purposes;

▪ Conduct: personal online behaviour that increases the likelihood of, or causes, harm, for  example, making, sending and receiving explicit images (e.g. consensual and non consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit  images, and online bullying); and

▪ Commerce: risks such as online gambling, inappropriate advertising, phishing and/or  financial scams. If staff feel that either they or pupils are at risk this should be reported to  the Anti-Phishing Working Group (

These issues are addressed within the curriculum, in the PSHE and ICT programme and in  assemblies. Parents will also be invited to attend talks on e-safety. The latest resources which  can be used are:

  • Education for a connected world framework  
  • The UK Safer Internet Centre (
  • CEOP’s Thinkuknow website (


Child Criminal Exploitation (CCE) – CCE is where an individual or group takes advantage of an  imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in  exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of  the perpetrator or facilitator and/or (c) through violence or the threat of violence. The victim may  have been criminally exploited even if the activity appears consensual. CCE does not always involve  physical contact; it can also occur through the use of technology.  

CCE can include children being forced to work in cannabis factories, being coerced into moving drugs  or money across the country (county lines, see page 85 for more information), forced to shoplift or  pickpocket, or to threaten other young people.

Some of the following can be indicators of CCE:

  • children who appear with unexplained gifts or new possessions;


  • children who associate with other young people involved in exploitation;
  • children who suffer from changes in emotional well-being;
  • children who misuse drugs and alcohol;
  • children who go missing for periods of time or regularly come home late; and • children who regularly miss school or education or do not take part in education.  

As outlined in KCSiE 2022:

It is important to note that the experience of girls who are criminally exploited can  be very different to that of boys. The indicators may not be the same, however  professionals should be aware that girls are at risk of criminal exploitation too. It is also  important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.


County lines – County lines is a term used to describe gangs and organised criminal networks  involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing  areas [within the UK], using dedicated mobile phone lines or other form of “deal line”.  

Exploitation is an integral part of the county lines offending model with children and vulnerable  adults exploited to move [and store] drugs and money. Offenders will often use coercion,  intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.  Children can be targeted and recruited into county lines in a number of locations including schools,  further and higher educational institutions, pupil referral units, special educational needs schools,  children’s homes and care homes. Children are often recruited to move drugs and money between  locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed  internally to avoid detection. Children can easily become trapped by this type of exploitation as  county lines gangs create drug debts and can threaten serious violence and kidnap towards victims  (and their families) if they attempt to leave the county lines network.  

One of the ways of identifying potential involvement in county lines are missing episodes (both from  home and school), when the victim may have been trafficked for the purpose of transporting drugs  and a referral to the National Referral Mechanism (NRM) should be considered. If a child is  suspected to be at risk of or involved in county lines, a safeguarding referral should be considered  alongside consideration of availability of local services/third sector organisations (TSOs) who offer  support to victims of county lines exploitation.  

Further information on the signs of a child’s involvement in county lines is available in guidance  published by the Home Office.  


Serious violence – All staff should be aware of indicators, which may signal that children are at risk  from, or are involved with serious violent crime. These may include increased absence from school, a  change in friendships or relationships with older individuals or groups, a significant decline in  performance, signs of self- harm or a significant change in wellbeing, or signs of assault or  unexplained injuries. Unexplained gifts or new possessions could also indicate that children have  been approached by, or are involved with, individuals associated with criminal networks or gangs.



So-called ‘honour-based’ abuse (including Female Genital Mutilation and Forced Marriage) – So called ‘honour-based’ abuse (HBA) encompasses incidents or crimes which have been committed to  protect or defend the honour of the family and/or the community, including female genital  mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the  context of preserving “honour” often involves a wider network of family or community pressure and  can include multiple perpetrators. It is important to be aware of this dynamic and additional risk  factors when deciding what form of safeguarding action to take. All forms of HBA are abuse  (regardless of the motivation) and should be handled and escalated as such. Professionals in all  agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a  child being at risk of HBA, or already having suffered HBA.  

Honour-based Violence – Actions:

If staff have a concern regarding a child that might be at risk of HBV, or who has suffered from HBV,  they should speak to the DSL or deputy. As appropriate, they will activate local safeguarding  procedures using national and local protocols for multi-agency liaison with police and children’s  social care. Where FGM has taken place, since 31 October 2015, there has been a mandatory  reporting duty placed on teachers that requires a different approach.  


Domestic abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern  of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or  emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects  of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage  relationship abuse). All of which can have a detrimental and long term impact on their health, well being, development and ability to learn.

The Domestic Abuse Act 2021 recognises the impact of domestic abuse on children, as victims in  their own right, if they see, hear or experience the effects of abuse.  

Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or  abuse between those aged 16 or over who are, or who have been, intimate partners or family  members regardless of gender or sexuality. The abuse can encompass, but is not limited to:

  • psychological
  • physical
  • sexual;
  • financial; or
  • emotional

We work with other key partners and will share relevant information where there are concerns that  domestic abuse may be an issue for a child or family or be placing a child at risk of harm.

Additional advice on identifying children who are affected by domestic abuse and how they can be  helped is available at: 17

NSPCC– UK domestic-abuse Signs Symptoms Effects  

Refuge what is domestic violence/effects of domestic violence on children 

Safelives: young people and domestic abuse.

Domestic abuse: specialist sources of support – GOV.UK ( (includes information for adult  victims, young people facing abuse in their own relationships and parents experiencing child to parent  violence/abuse)

Home : Operation Encompass (includes information for schools on the impact of domestic abuse on  children)

Operation Encompass

Operation Encompass operates in all police forces across England. It helps police and schools work  together to provide emotional and practical help to children. The systems ensures that when police  are called to an incident of domestic abuse, where there are children in the household who have  experiences the domestic incident, the police will inform the key adult (usually the DSL) in school  before the child or children arrive at school the following day. This ensures that the school has up to  date relevant information about the child’s circumstances and can enable immediate support to be  put in place, according to the child’s needs. Operation Encompass does not replace statutory  safeguarding procedures. Where appropriate, the police and/or schools should make a referral to  children’s social care if they are concerned about a child’s welfare. More information about the  scheme and how schools can become involved in available in the Operation Encompass website.

National Domestic Abuse Helpline

Refuge runs the National Domestic Abuse Helpline, which can be called free of charge and in  confidence, 24 hours a day on 0808 2000 247. Its website provides guidance and support for  potential victims, as well as those who are worried about friends and loved ones. It also has a form  through which a safe time from the team for a call can be booked.


FGM comprises all procedures involving partial or total removal of the external female genitalia or  other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long lasting harmful consequences.  

Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime  Act 2015) places a statutory duty upon teachers along with regulated health and social care  professionals in England and Wales, to report to the police where they discover (either through  disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under  18. Those failing to report such cases will face disciplinary sanctions. It will be rare for teachers to see  visual evidence, and they should not be examining pupils, but the same definition of what is meant by  “to discover that an act of FGM has been carried out” is used for all professionals to whom this  mandatory reporting duty applies. Information on when and how to make a report can be found at  Mandatory reporting of female genital mutilation procedural information.

Forced Marriage

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered  into without the full and free consent of one or both parties and where violence, threats or any  other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or  emotional and psychological. A lack of full and free consent can be where a person does not consent


or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some  perpetrators use perceived cultural practices as a way to coerce a person into marriage. Schools and  Schools can play an important role in safeguarding children from forced marriage.  

The Forced Marriage Unit has published statutory guidance and Multi-agency guidelines, pages 35- 36 of which focus on the role of schools and Schools. School staff can contact the Forced Marriage  Unit if they need advice or information: Contact: 020 7008 0151 or email [email protected].  


As part of the Counter Terrorism and Security Act 2015, schools have a duty to ‘prevent people being  drawn into terrorism’. This has become known as the ‘Prevent Duty’. Where staff are concerned that  children and young people are developing extremist views or show signs of becoming radicalized,  they should discuss this with the Designated Safeguarding Lead. The Designated Safeguarding Lead  has received training about the Prevent Duty and tackling extremism and is able to support staff with  any concerns they may have.  

We use the curriculum to ensure that children and young people understand how people with  extreme views share these with others, especially using the internet. Staff should be alert to changes  in children’s behaviour, which could indicate that they may be in need of help or protection.  Staff should use their judgement in identifying children who might be at risk of radicalisation and act  proportionately which may include the designated safeguarding lead (or deputy) making a Prevent  referral.  

We are committed to ensuring that our pupils are offered a broad and balanced curriculum that  aims to prepare them for life in modern Britain. Teaching the International School’s core values alongside  the fundamental British Values supports quality teaching and learning, whilst making a positive  contribution to the development of a fair, just and civil society. Recognising Extremism Early  indicators of radicalisation or extremism may include:  

  • showing sympathy for extremist causes glorifying violence, especially to other faiths or cultures • making remarks or comments about being at extremist events or rallies outside school  • evidence of possessing illegal or extremist literature
  • advocating messages similar to illegal organisations or other extremist groups • out of character changes in dress, behaviour and peer relationships (but there are also very  powerful  

narratives, programmes and networks that young people can come across online so involvement  with particular groups may not be apparent.)

  • secretive behaviour
  • online searches or sharing extremist messages or social profiles
  • intolerance of difference, including faith, culture, gender, race or sexuality
  • graffiti, art work or writing that displays extremist themes
  • attempts to impose extremist views or practices on others
  • verbalising anti-Western or anti-British views
  • advocating violence towards others

Preventing radicalisation – Children are vulnerable to extremist ideology and radicalisation. Similar  to protecting children from other forms of harms and abuse, protecting children from this risk  should be a part of the Schools’ safeguarding approach.  

  • Extremism is the vocal or active opposition to our fundamental values, including democracy, the  rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs.  This also includes calling for the death of members of the armed forces.
  • Radicalisation refers to the process by which a person comes to support terrorism and extremist  ideologies associated with terrorist groups.  
  • Terrorism is an action that endangers or causes serious violence to a person/people; causes  serious damage to property; or seriously interferes or disrupts an electronic system. The use or  threat must be designed to influence the government or to intimidate the public and is made for the  purpose of advancing a political, religious or ideological cause.

KCSIE (2022) states there is no single way of identifying whether a child is likely to be susceptible to  an extremist ideology. Background factors combined with specific influences such as family and  friends may contribute to a child’s vulnerability. Similarly, radicalisation can occur through many  different methods (such as social media or the internet) and settings (such as within the home).  However, it is possible to protect vulnerable people from extremist ideology and intervene to  prevent those at risk of radicalisation being radicalised. As with other safeguarding risks, staff should  be alert to changes in children’s behaviour, which could indicate that they may be in-need of help or  protection. Staff should use their judgement in identifying children who might be at risk of  radicalisation and act proportionately which may include the designated safeguarding lead (or  deputy) making a Prevent referral.  

The school’s DSL (and DDSLs) are aware of local procedures for making a Prevent referral.  3.6.13

The cross-government definition of domestic violence and abuse is: any incident or pattern of  incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16  or over who are, or have been, intimate partners or family members regardless of gender or  sexuality. The abuse can encompass but is not limited to: psychological; physical; sexual; financial;  and emotional.  

All children can witness and be adversely affected by domestic abuse in the context of their home  life where domestic abuse occurs between family members. Exposure to domestic abuse and/or  violence can have a serious, long lasting emotional and psychological impact on children. In some  cases, a child may blame themselves for the abuse or may have had to leave the family home as a  result.  


Sharing of nude and semi-nude images (Youth produced imagery) is a child protection issue. Even if  explicit material is sent or elicited without malicious intent, the consequences are serious and put  those involved at risk of serious harm. Having or sending explicit material on digital devices is also a  criminal offence for those under 18. Pupils are taught about sexting and the sharing of nude and  semi-nude images as part of their online safety education. The School takes incidences of sexting and the sharing of nude and semi-nude images extremely seriously and deals with them in  accordance with child protection procedures, including reporting to the police.  


Upskirting The Voyeurism (Offences) Act, which is commonly known as the Upskirting Act, came into  force on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a person’s clothing (not  necessarily a skirt) without their permission and or knowledge, with the intention of viewing their  genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim

humiliation, distress or alarm. It is a criminal offence. Anyone of any gender, can be a victim. It is a  criminal offence and incident of ‘Upskirting’ must be reported to the DSL (or a DDSL) who, following  investigation, may report the incident to the police.  


All staff should have an awareness of other safeguarding issues, some of which are listed below,  with further information included in KCSiE 2022. Staff should be aware that behaviours linked to the  likes of drug taking, alcohol abuse, truanting and sexting put children in danger.  

School staff can access government guidance as required on the issues listed below via GOV.UK and  the safeguarding topics page on the SSP website. Further information is also included in Annex A.  


Who are the Abusers? Abusers can be parents or carers, siblings or members of the extended  family, neighbours, teachers, strangers or other pupils; in short, an abuser could be anyone.  

Children who are lesbian, gay, bi, or trans (LGBT)

Children who are LGBT can be targeted by other children. In some cases, a child who is perceived by  other children to be LGBT (whether they are or not) can be just as vulnerable as children who identify  as LGBT.

Staff will endeavour to support these children and will provide a safe space for them to speak out or  share their concerns.

LGBT inclusion forms part of the Statutory Relationships Education and Relationship and Sex Education  and Health Education curriculum.

3.6.18 Child on Child Abuse

All staff should recognise that children can abuse other children (formerly referred to as ‘peer-on peer abuse’). This is most likely to include, but is not limited to:

Whilst not intending to be an exhaustive list, sexual harassment can include;

  • bullying (including cyberbullying, prejudice-based and discriminatory bullying) • abuse in intimate personal relationships between children (sometimes known as  ‘teenage relationship abuse’)
  • physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise  causing physical harm (this may include an online element which facilitates, threatens  and/or encourages physical abuse)
  • sexual violence, such as rape, assault by penetration and sexual assault; (this may  include an online element which facilitates, threatens and/or encourages sexual  violence)
  • sexual harassment, such as sexual comments, remarks, jokes and online sexual  harassment, which may be standalone or part of a broader pattern of abuse • causing someone to engage in sexual activity without consent, such as forcing  someone to strip, touch themselves sexually, or to engage in sexual activity with a  third party
  • consensual and non-consensual sharing of nude and semi-nude images and/or videos  (also known as sexting or youth produced sexual imagery)
  • upskirting, which typically involves taking a picture under a person’s clothing without  their permission, with the intention of viewing their genitals or buttocks to obtain  sexual gratification, or cause the victim humiliation, distress, or alarm, and
  • initiation/hazing type violence and rituals (this could include activities involving  harassment, abuse or humiliation used as a way of initiating a person into a group and  may also include an online element).

Staff should

  • Challenge inappropriate behaviours;
  • Make clear that sexual violence and harassment is not acceptable, will never be  tolerated and is not an inevitable part of growing up
  • Have a zero-tolerance approach to abuse, and it should never be passed off as  “banter”, “just having a laugh”, “part of growing up” or “boys being boys” as this can  lead to a culture of unacceptable behaviours and an unsafe environment for children  Challenge behaviours (potentially criminal in nature), such as grabbing bottoms,  breasts and genitalia, flicking bras and lifting up skirts. Dismissing or tolerating such  behaviours risks normalising them.

The initial response to a report from a child is important. It is essential that all victims are  reassured that they are being taken seriously and that they will be supported and kept safe.  A victim should never be given the impression that they are creating a problem by reporting  sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for  making a report. Further information can be found when making a report in Appendix x.

Sexual Violence and Sexual Harassment:

As outlined in KCSiE (September 2022), it is essential that all victims of sexual violence and sexual  harassment are reassured that they are being taken seriously, regardless of how long it has taken  them to come forward and that they will be supported and kept safe. Abuse that occurs online or  outside of the school should not be downplayed and should be treated equally seriously. A victim  should never be given the impression that they are creating a problem by reporting sexual violence  

or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report or their  experience minimised.

The wishes of the victim in terms of how they want to proceed will be taken into consideration by  the International School Safeguarding Team. Victims will be given as much control as is reasonably possible  regarding how any investigation will be progressed and any support that they will be offered. This  will be balanced with the school’s duty and responsibilities to protect other children.

The Safeguarding Team will ensure that all staff have a clear understanding of their role in  responding to any suspected or disclosed incidences of sexual violence and sexual harassment,  including the need to be vigilant in reacting to overheard conversations or reports by third parties.


All staff will be asked to adopt an ‘it could happen here’ approach.

Should a disclosure of sexual violence or sexual harassment be made, consideration will be given to  carefully manage the proximity of the alleged perpetrator to the victim (whilst acting in the best  interests of all children involved). This should include all times of the school day, including school  transport, social times and shared classes. Where an allegation of rape, assault by penetration or  sexual assault has been made, the alleged perpetrator will be removed from all classes shared with  the victim.

The School will consider every report on a case-by-case basis, guided by KCSiE, Part 5 (2022).

Following a report of sexual violence or sexual harassment the Safeguarding Team will ensure that  appropriate support remains in place for the victim. Support will also be put into place for the  alleged perpetrator (see KCSiE, Part 5, paragraph 463).

Students at International School are able to report concerns via the following methods:

  • Speaking directly to their Form Tutor or any other member of staff to whom they feel  comfortable making a disclosure (all staff are trained in the steps to follow if a child makes a  disclosure).
  • Using the email address: [email protected]
  • Speaking directly to a member of the Safeguarding Team

In the event that a child makes a disclosure of child on child abuse and/or sexual harassment and  sexual violence, the Safeguarding Team will adhere to the following procedures:

  1. Two members of the Safeguarding Team will speak to the child to gather information. One  will keep notes. The Safeguarding Team will not investigate but will follow all steps outlined  in KCSIE, Part 5.
  2. Where the report includes an online element, ‘searching, screening and confiscation’ advice  for schools (KCSIE, Part 5 and UKCIS) will be followed. Staff will not view or forward illegal  images of a child.
  3. A member of the Safeguarding Team will contact the Suffolk MASH PCL and the school’s  Advisory Council Safeguarding link to seek advice as to the next steps necessary for the  specific case.  
  4. The Principal will be informed (the Principal will notify the Chair of the Advisory Council). 5. The Safeguarding Team will create a Risk and Needs Assessment (KCSIE, Part 5). 6. The LADO/the police and any other relevant authorities will be involved promptly and will be  assisted fully by the Safeguarding Team
  5. The Safeguarding Team will ensure that the details of the case are recorded accurately using  My Concern (to include details of case reference numbers, the names of those from other  agencies who become involved in the case, any related documents and to ensure that the  chronology of the case is accurate).
  6. Parents/guardians will be informed at the earliest possible opportunity (unless the Suffolk  MASH PCL, the LADO, social services or the police specifically instruct the Safeguarding Team  that parents should not be advised).
  7. A Support Plan will be created by the Safeguarding Team and the Pastoral Team. The  student and their parents will be directed to any relevant agencies who may be able to  provide further support outside of the educational setting. Early Help will always be the aim  of any Support Plan.

3.6.19 Contextual Safeguarding

Children and young people attending schools and Schools cannot be seen as islands, they are part of  a much wider network of peers, neighbourhoods and other influences. It is important that when we  consider some of the issues affecting our children and young people that we understand these  influences. We also need to consider not only the physical, real world, influences, but the wider  groupings found within social media and the important messages that they impart.

Therefore it is important that we understand that safeguarding incidents and/or behaviours can be  associated with factors outside the School and can occur between children outside the School. All  staff should consider the context within which such incidents and/or behaviour occur. It is important  to provide as much information as possible as part of the referral process. This will allow any  assessment to consider all the available evidence and the full context of any abuse.

At International School we assess the risks and issues in the wider community when we consider the well being and safety of our pupils. We work together as a safeguarding team and engage the support  and advice from outside agencies and our Advisory Council Safeguarding Lead.

3.6.20 Signs of Abuse – is this duplicated above

All School staff members should be aware of the signs of abuse, neglect and radicalisation so that  they are able to identify cases of children who may be in-need of help or protection.  

The following may help staff to be aware of possible signs of abuse. There are further sources of  information such as KCSIE 2022 , What to do if you’re worried a child is being abused and the NSPCC  website as well as the link to the SSP website in 3.6.7 above. Such lists, however, are not exhaustive – if staff members are unsure they should always seek advice and report concerns even when signs or  indicators are not present. Staff should also be alert to behaviours or circumstances that put  children in danger, such as drug taking, alcohol abuse, self-harm, truanting, cyber bullying and  sexting.  

(There may be other indicators of abuse specific to female genital mutilation and to radicalisation of  young people.)  


Physical Abuse  

  • Unexplained injuries/ burns  
  • Untreated injuries  
  • Bruises/ abrasion around the face  
  • Bi-lateral injuries e.g. two bruised eyes  
  • Bite marks  
  • Bruising abrasions to lips, cheeks, outer ear  

3.6.22 Emotional Abuse  

  • Excessive overreaction to mistakes  
  • Continual self-deprecation  
  • Excessive rocking, thumb sucking, hair twisting  
  • Extreme compliance/aggression
  • Drug, alcohol and substance misuse  
  • Significant peer relationship difficulties  

3.6.23 Sexual Abuse  

  • Sexual awareness inappropriate to child’s age, including provocative sexual  behaviour  
  • Self-harm  
  • Pregnancy  
  • Sexually transmitted diseases  
  • Sudden changes in behaviour or school performance  
  • Fear of undressing for gym  
  • Depression/withdrawal  
  • Drug, alcohol, substance abuse  

3.6.24 Neglect

  • Constant hunger, tiredness and/or poor personal hygiene  
  • Untreated medical problems  
  • Destructive tendencies  
  • Social isolation  
  • Poor self-esteem and/or relationship with peers  
  • Excessive rocking, hair twisting, thumb sucking  

3.6.25 Missing Children

A child going missing from an education setting is a potential indicator of abuse and neglect. Staff  should treat prolonged or repeated absence, with no satisfactory explanation, as a potential  safeguarding issue and take-action accordingly. International School is committed to identifying quickly  children missing from education.  

A child or young person is missing from education if they are of compulsory school age and they do  not have a school place and no alternative education arrangements have been made for them.  

Children missing from education are at much greater risk of:  

  • physical harm  
  • becoming involved in crime  
  • demonstrating anti-social behaviour  
  • abusing drugs and alcohol  
  • sexual exploitation  
  • being illegally employed  
  • forced marriages  

It is, therefore, vital that the local authority, schools and other agencies work closely together to  help safeguard children.  

Children go missing from education for a variety of reasons, which include:  • failing to start appropriate provision and hence never entering the system

  • moving out of the independent sector  
  • ceasing to attend, due to exclusion or parental withdrawal  
  • failing to complete a transition between providers or phases  
  • are part of a transient or mobile population  

Staff must, therefore, treat prolonged or repeated absence, or particular patterns of absence, with  no satisfactory explanation, as a potential safeguarding issue and take-action accordingly.  Procedures are detailed in the School’s Children Missing Education Policy. Suffolk has a Children  Missing in Education department: [email protected] (0345 606 6067) to whom a referral must be  made.  

  1. The Designated Safeguarding Lead (DSL)

4.1 For a full breakdown see Appendix 1

The School has appointed a Designated Safeguarding Lead and deputies (DDSLs) to contact in their  absence. The Designated Safeguarding Lead is a member of the School’s Senior Leadership Team,  with the necessary status and authority to take responsibility for child protection matters. This  responsibility cannot be delegated. The School will ensure that the Designated Safeguarding Lead is  given the time/cover, funding, training, resources and support to fulfil their role.  

The Designated Safeguarding Lead, Deputy Designated Safeguarding Leads, and their contact details,  are listed at the head of this policy. The DSL will ensure there is always cover for the role (including  out of hours/out of term activities).

The Designated Safeguarding Lead is responsible for safeguarding and child protection at Stoke  School.  

The key role of the Designated Safeguarding Lead is to:  

  • manage referrals from School staff or any others from outside the School;  • work with external agencies and professionals on matter of safety and safeguarding;  • undertake training;  
  • raise awareness of safeguarding and child protection amongst the staff and parents; and ensure that child protection information is transferred to the pupil’s new school  • be aware of pupils who have a social worker  
  • help promote educational outcomes by sharing the information about the welfare, safeguarding  and child protection issues with teachers and the School leadership staff.
  1. Responding to Disclosures of Abuse – see Appendix 2

5.1 Children are more likely to be abused by someone they know and trust than by a stranger. Staff  members are advised to maintain an attitude of “it could happen here” where safeguarding is  concerned. When concerned about the welfare of a child, staff members should always act in the  best interests of the child.  

5.2 Staff and volunteers should make themselves available to listen and demonstrate to the pupil  that what they are saying is being taken seriously and without criticism. No person making a  disclosure should feel that they are creating a problem by making a disclosure. Staff and volunteers  should respond in a supportive, calm manner, avoiding asking detailed questions. The role of the  staff or volunteer is to listen, record and report; not to investigate. Staff and volunteers should take

care to ensure their behaviour and actions do not place students or themselves at risk of harm. Staff  should recognise that a child may not be ready to disclose (see KCSIE 2022, Part 1).

5.3 If a student reports abuse from another pupil or pupils, staff should follow the procedures in this  section. All children involved whether perpetrator or victim will be treated as being ‘at risk’. The  Designated Safeguarding Lead will liaise with local agencies in relation to handling any such cases  which arise. A bullying incident will be regarded as a child protection concern where there is  reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm. See the  Anti-Bullying Policy.  


5.11 Recording Information

Staff/volunteers should:  

5.11.1 make brief notes immediately afterwards, which record the date, time, place and context of  the disclosure or concern, and what has actually been said (wherever possible using the child’s exact  words, even if they seem childish, rude or inappropriate), not assumption or interpretation. Notes  must be signed and dated;  

5.11.2 clearly distinguish between fact, observation, allegation and opinion;  5.11.3 record observed injuries and bruises on a body map;  

5.11.4 note the non-verbal behaviour and the key words in the language used by the pupil (do not  translate into “proper terms”);  

5.11.5 use MyConcern (online safeguarding reporting and monitoring system) to inform the relevant  staff about a safeguarding concern. If they cannot access the system, they should complete a  Safeguarding Concern Form (hard copies in the Staff Rooms on the Safeguarding Noticeboard),  attach the original notes and pass them to the DSL or a DDSL as a matter of urgency.

5.11.6 appreciate that their records may be used in criminal proceedings or disciplinary  investigations.  

5.12 Reporting Concerns

5.12.1 Any concerns about pupils must be discussed with the DSL (or a DDSL) as soon as possible  and, at the latest, by the end of the school day.  

5.12.2 Where the disclosure identifies a safeguarding issue, the Designated Safeguarding Lead/s will  report to the local Social Services department within 24 hours and will inform the Principal. In most  serious cases, and if there is suspicion that a crime has been committed, the Designated  Safeguarding Lead will contact the police.  

5.12.3 The School’s procedures differentiate between safeguarding children who have suffered  significant harm and those who are in-need of support from one or more agencies. In cases where a  child is not suffering or at risk of suffering serious harm but rather in need of additional support, an  inter-agency assessment will be undertaken to determine the most appropriate action. The DSL will  discuss with the MASH team whether an early help assessment is needed.

5.12.4 Whilst the DSL will usually decide whether to make a referral, in exceptional circumstances,  such as in an emergency or a genuine concern that appropriate action has not been taken, anyone  can refer their concerns to children’s social care directly (see section 9 below). If a member of staff  

makes a referral independently, they must inform the Designated Safeguarding Lead as soon as  possible thereafter.  

5.12.5 If, at any point, there is a risk of immediate serious harm to a child, a referral should be  made immediately. If the child’s situation does not appear to be improving, the staff member with  concerns should press for reconsideration. Concerns should always lead to help for the child at  some point.  

  1. Allegations against Staff

At International School, we recognise the possibility that adults working in the school may harm children,  including the Advisory Council, volunteers, supply teachers and agency staff.

6.1 Schools must follow the procedures for handling allegations made against staff and/or  volunteers set out in Part 4 of Keeping Children Safe in Education (September 2022). The aim is to  deal with any allegation quickly and in a fair and consistent way which provides effective protection  for the child and at the same time provides appropriate support for the person who is the subject of  the allegation.  

6.2 Where a safeguarding-related allegation or cause for concern is made against any member of  staff or volunteer (including the Designated Safeguarding Lead), the matter should be reported  immediately to the Principal (unless the allegation relates to the Principal). The Principal should not  speak to the member of staff who is the subject of the allegation at this point. In the absence of the  Principal, the allegation should be reported to the Chair of the Advisory Council). In all cases,  immediate contact should be made with the LADO to discuss the allegation.  

6.3 Where a safeguarding related allegation or cause for concern is made against the Principal, the  matter should be reported immediately to the Chair of the Advisory Council, without informing the  Principal.  

6.4 In all cases, immediate contact should be made with the LADO to discuss the allegation. A  decision as to how to proceed and eventually whether or not to suspend a member of staff or  volunteer will be taken by the Principal following consultation with the LADO (and, in most serious  cases, the police). In borderline cases, discussions with the LADO can be held informally and without  naming the school or individual. Discussions should be recorded in writing and any communication  with both the individual and the parents of the child/children agreed. Suspension is not an  automatic response and the decision will be taken according to the circumstances of each particular  case, giving due weight to the views of the LADO, guidance in Keeping Children Safe in Education  (September 2022) and Working Together to Safeguard Children (2018).  

6.5 In considering the available options, including redeployment of the member of staff or volunteer,  the LADO and the Principal will ensure that their primary concerns are the safety and wellbeing of  the pupils, together with the need for a full and fair investigation which will be led by the LADO or  the police.  

6.6 Where we cease to use the services of any person (whether employed, contracted, a volunteer  or student), or the person resigns or otherwise ceases to provide his or her services because it is  considered that the person may be unsuitable to work with children, a referral will be made to DBS.


In cases involving teaching staff, the school will also decide whether to refer the matter to the  Teaching Regulation Agency (TRA) to consider prohibiting the individual from teaching.  

6.7 Where required to do so, we will provide information requested by the DBS or TRA in respect of  a member of staff or volunteer in accordance with our legal duty.  

6.8 Communications with the School community about safeguarding related allegations shall only  be made following consultation with the LADO and any investigating authorities. There are  restrictions on the reporting or publishing of allegations against teachers (which apply to a point  where the accused person is charged with an offence, or the DfE/TRA publish information about an  investigation or decision in a disciplinary case). Every effort will be made to maintain confidentiality  and guard against unwanted publicity. The Advisory Council and the School’s solicitor will advise on  the statutory reporting restrictions on publications of details of allegations.

6.9 If there has been a substantial allegation against a member of staff, the School will work with  the LADO to determine whether there are improvements to be made to the School’s procedures or  practice to help prevent similar events in the future.

Local Designated Officer (LADO):

[email protected] 0300 123 2044

6.10 Low Level Concerns International School follows the Suffolk Safeguarding Partnership’s Low Level  Concerns procedure (please see the International School Low Level Concerns Policy) to ensure that staff  have a full understanding of the procedure for raising a Low Level Concern to the Principal. Low level  concerns regarding the Principal will be referred to the Chair of the Advisory Board. Staff are  encouraged to report Low Level Concerns promptly.

  1. Referring Concerns to Social Services


The decision to make a referral which could activate a child protection investigation, and the issue of  gaining parental consent, are serious matters and require careful judgement. These decisions must  only be taken by the Principal or by the DSL, who will liaise with the Principal as appropriate,  following consultation with Social Services. In cases of serious harm, or if a crime may have been  committed, the police will be informed from the outset. However, anyone can refer their concerns  to Children’s Social Care directly (see section 8 below).  


Advice to determine the nature of any discussions to have with parents should be sought from Social  Services in advance of making a referral.


Parental consent is not a requirement for referrals to statutory agencies. Subject to 7.1 above and  the advice of the Local Education Authority, schools should, however, aim to gain consent of  individuals or their parents, depending upon age and the circumstances, to share information about  them with Social Services and other agencies. Schools should be mindful of situations where to do so  would place a child at increased risk of harm. Schools may share information without consent: if it is  not possible to gain consent, it cannot be reasonably expected that a school will gain consent, or if  to gain consent would place a child at risk.  


In the case of concerns about a pupil being at risk of radicalisation, School staff should follow the  safeguarding guidelines by reporting to the DSL. This may lead to a referral through the Channel  programme.  


Where the disclosure relates to actual abuse or the suspicion of abuse, the DSL will report the  disclosure to Social Services within 24 hours.  


In the event of the School making a referral to Social Services, they should agree with the recipient  of the referral what exactly the child and parents will be told, by whom and when. The DSL should  ask to be kept informed of the timing of the strategy discussion between Social Services and the  police, which will decide whether and how to investigate. The DSL should be prepared to contribute  to the strategy discussion.


The local authority should make a decision, within one working day of a referral being made, about  the type of response that is required and should let the referrer know the outcome. The referrer  should follow up if this information is not forthcoming. A record of each contact with Social Services,  including the name of the officer with whom the member of School staff has spoken, and the date  and time of the call, should be kept. If, after a referral, a child’s situation does not appear to be  improving, the referrer should consider following local escalation procedures via the SSP Escalation  Policy.

  1. Duty to Report Concerns about the Management of Safeguarding


The School recognises that children cannot be expected to raise concerns in an environment where  staff fail to do so. Staff and volunteers should feel able to raise concerns about poor or unsafe  practice and potential failures in the School’s safeguarding regime and feel confident that such  concerns will be taken seriously by the Senior Leadership Team. The duty to report concerns about  the management of safeguarding, and the Whistleblowing Policy, is included in the Staff Handbook.  It will also be reflected in staff training.  


Where staff or volunteers reasonably believe that safeguarding concerns exist, or where they have  concerns regarding the management of safeguarding issues, it is their duty to raise concerns.  


The member of staff or volunteer should bring their concerns to the attention of the Designated  Safeguarding Lead, or in a case where the concerns relate to the actions or inaction of the  Designated Safeguarding Lead, to the Principal.  


However, where someone reasonably believes these reporting routes to be inappropriate or has  reported concerns and no action has been taken, they should refer their concerns to children’s  social care directly or use the NSPCC Whistleblowing Helpline (0800 028 0285).

  1. Monitoring and Review


This policy will be monitored and updated by the DSL in liaison with the Safeguarding Team, the  Advisory Council Safeguarding Link and the Principal.  


The DSL and Safeguarding Team will amend the policy to reflect any significant changes that occur  before the next review (due in July 2023).  

  1. International School Covid Response International School has an Outbreak Plan as per current DfE guidance.

Safeguarding Flowchart:



UKCIS Guidance (overview) on the sharing of nude and semi-nude images: What do we mean by sharing nudes and semi- nudes?

In the latest advice for schools and Schools (UKCIS, 2020), this is defined as the sending or  posting of nude or semi-nude images, videos or live streams online by young people under  the age of 18. This could be via social media, gaming platforms, chat apps or forums. It could  also involve sharing between devices via services like Apple’s AirDrop which works offline.  Alternative terms used by children and young people may include ‘dick pics’ or ‘pics’.

The motivations for taking and sharing nude and semi-nude images, videos and live streams  are not always sexually or criminally motivated.

This advice does not apply to adults sharing nudes or semi-nudes of under 18-year olds. This  is a form of child sexual abuse and must be referred to the police as a matter of urgency.

What to do if an incident comes to your attention

Report it to your Designated Safeguarding Lead (DSL) or equivalent immediately. Your  setting’s child protection policy should outline codes of practice to be followed.

Never view, copy, print, share, store or save the imagery yourself, or ask a child to share or  download – this is illegal.

If you have already viewed the imagery by accident (e.g. if a young person has showed it to  you before you could ask them not to), report this to the DSL (or equivalent) and seek  support.

Do not delete the imagery or ask the young person to delete it.

Do not ask the child/children or young person(s) who are involved in the incident to disclose  information regarding the imagery. This is the responsibility of the DSL (or equivalent).

Do not share information about the incident with other members of staff, the young  person(s) it involves or their, or other, parents and/or carers.

Do not say or do anything to blame or shame any young people involved.

Do explain to them that you need to report it and reassure them that they will receive  support and help from the DSL (or equivalent).

Appendix 1 – Role of the Designated Safeguarding Lead. ANNEX C: KCSIE

KCSiE requires staff to have knowledge of the Role of The Designated Safeguarding Lead.  The Designated Safeguarding Lead should take lead responsibility for safeguarding and child  protection.

The ultimate lead responsibility for child protection remains with the Designated Safeguarding Lead;  this lead responsibility should not be delegated.

Please note: on-line safety in school is the responsibility of the Designated Safeguarding Lead.


During term time the Designated Safeguarding Lead (or deputy) should always be  available (during school hours) for staff in the school to discuss any safeguarding concerns.  Whilst generally speaking the Designated Safeguarding Lead (or deputy) would be  expected to be available in person, it is a matter for individual schools, working the  Designated Safeguarding Lead, to define what ‘available’ means and whether in  exceptional circumstances availability via phone or Skype or other such mediums is  acceptable.

It is a matter for individual schools and the Designated Safeguarding Lead to arrange  adequate and appropriate cover arrangements for any out of hours/out of term activities.

Manage referrals

  • Refer all cases of suspected abuse to the local authority children’s social care  as required;
  • Support staff who make referrals to local authority children’s social care; • Refer cases to the Channel programme where there is a radicalisation concern as  required;
  • Support staff who make referrals to the Channel programme;
  • Refer cases where a person is dismissed or left due to risk/harm to a child to the Disclosure  and Barring Service as required; and
  • Refer cases where a crime may have been committed to the Police as required.

Working with others

  • Act as a source of support, advice and expertise for all staff;
  • Act as a point of contact with the three safeguarding partners;
  • Liaise with the Principal to inform her of issues especially ongoing enquiries under section  47 of the Children Act 1989 and police investigations; This should include being aware of  the requirement for children to have an Appropriate Adult. Further information can be  found in the Statutory guidance – PACE Code C 2019.
  • As required, liaise with the ‘case manager’ (as per part four) and the designated officer(s)  at the local authority for child protection concerns (all cases which concern a staff  member);  
  • Liaise with staff (especially pastoral support staff, IT technicians and SENCOs and Senior  Mental Health Leads) on matters of safety and safeguarding (including online and digital  safety) and when deciding whether to make a referral by liaising with relevant agencies  so that children’s needs are considered holistically;
  • Liaise with the senior mental health lead and, where available, the Mental Health Support  Team, where safeguarding concerns are linked to mental health
  • Promote supportive engagement with parents/ and/or carers in safeguarding and  promoting the welfare of children, including where families may be facing challenging  circumstances;
  • Work with the Principal and relevant strategic leads, taking responsibility for promoting  educational outcomes by knowing the welfare, safeguarding and child protection issues  that children in need are experiencing, or have experienced, and identifying the impact  that these issues might be having on children’s attendance, engagement and achievement  at school. This includes:
  • Ensure that the school knows who its cohort of children who have or have had a social  worker are, understanding their academic progress and attainment, and maintaining a  culture of high aspirations for this cohort; and,
  • Support teaching staff to provide additional academic support or reasonable adjustments  to help children who have or have had a social worker reach their potential, recognising  that even when statutory social care intervention has ended, there is still a lasting impact  on children’s educational outcomes.


Information sharing and managing the child protection file

The designated safeguarding lead is responsible for ensuring that child protection files are kept up to  date.

Information should be kept confidential and stored securely. It is good practice to keep concerns and  referrals in a separate child protection file for each child.

Records should include:

  • A clear and comprehensive summary of the concern;
  • Details of how the concern was followed up and resolved;
  • A note of any action taken, decisions reached and the outcome.
  • Where children leave the school (including for in-year transfers) the designated  safeguarding lead should ensure their child protection file is transferred to the new school  or School as soon as possible, and within 5 days for an in-year transfer or within the first  5 days of the start of a new term. This should be transferred separately from the main  pupil file, ensuring secure transit and confirmation of receipt should be obtained.  Receiving schools and Schools should ensure key staff such as designated safeguarding  leads and SENCOs or the named person with oversight for SEN, are aware as required.
  • Lack of information about their circumstances can impact on the child’s safety, welfare  and educational outcomes. In addition to the child protection file, the designated  safeguarding lead should also consider if it would be appropriate to share any information  with the new school or School in advance of a child leaving. For example, information that  would allow the new school or School to continue to support victims of abuse and have  that support in place for when the child arrives.

Raising Awareness

  • The Designated Safeguarding Lead should ensure each member of staff has access to, and  understands, the school’s child protection policy and procedures, especially new and part time staff;  
  • Ensure the school’s child protection policy is reviewed annually (as a minimum) and the  procedures and implementation are updated and reviewed regularly; and work with  governing bodies regarding this;
  • Ensure the child protection policy is available publicly and parents are aware of the fact  that referrals about suspected abuse or neglect may be made and the role of the school  in this.
  • Link with the safeguarding partner arrangements to make sure staff are aware of any  training opportunities and the latest policies on local safeguarding arrangements; and Help promote educational outcomes by sharing the information about the welfare, safeguarding and  child protection issues that children, including children with a social worker, are experiencing, or have  experienced, with teachers and school leadership staff.  


The Designated Safeguarding Lead (and deputies) should undergo training to provide them with  the knowledge and skills required to carry out the role. This training should be updated at least  every two years.

The Designated Safeguarding Lead should undertake Prevent awareness training.

Training should provide designated safeguarding leads with a good understanding of their own  role, and the processes, procedures and responsibilities of other agencies, particularly children’s  social care, so they:

  • Understand the assessment process for providing early help and statutory intervention,  including local criteria for action and local authority children’s social care referral  arrangements  
  • Have a working knowledge of how local authorities conduct a child protection case  conference and a child protection review conference and be able to attend and contribute  to these effectively when required to do so;
  • Understand the importance of the role the designated safeguarding lead has in providing  information and support to children social care in order to safeguard and promote the  welfare of children
  • Understand the lasting impact that adversity and trauma can have, including on children’s  behaviour, mental health and wellbeing, and what is needed in responding to this in  promoting educational outcomes;
  • Are alert to the specific needs of children in need, those with special educational needs  and disabilities (SEND), those with relevant health conditions and young carers;
  • Understand the importance of information sharing, both within the school and with the  three safeguarding partners, other agencies, organisations and practitioners;
  • Understand and support the school with regards to the requirements of the Prevent duty  and are able to provide advice and support to staff on protecting children from risk of  radicalisation;
  • Are able to understand the unique risks associated with online safety and be confident  that they have the relevant knowledge and up to date capability required to keep children  safe whilst they are online at school;
  • Can recognise the additional risks that children with SEN and disabilities (SEND) face  online, for example, from online bullying, grooming and Radicalisation and are confident  they have the capability so support SEND children to stay safe online;
  • Obtain access to resources and attend any relevant or refresher training courses; and  
  • Encourage a culture of listening to children and taking account of their wishes and  feelings, among all staff, in any measures the school may put in place to protect them.

In addition to the formal training set out above, their knowledge and skills should be refreshed  (this might be via e-bulletins, meeting other Designated Safeguarding Leads, or simply taking

time to read and digest safeguarding developments) at regular intervals, as required, but at  least annually, to allow them to understand and keep up with any developments relevant to  their role.

Providing support to staff

Training should support the designated safeguarding lead in developing expertise, so they can support  and advise staff and help them feel confident on welfare, safeguarding and child protection matters.  This includes specifically to:

  • Ensure that staff are supported during the referrals processes; and • Support staff to consider how safeguarding, welfare and educational outcomes are  linked, including to inform the provision of academic and pastoral support.

Understanding the views of children

It is important that children feel heard and understood. Therefore, designated safeguarding leads  should be supported in developing knowledge and skills to:

  • Encourage a culture of listening to children and taking account of their wishes and  feelings, among all staff, and in any measures the school may put in place to  protect them; and
  • Understand the difficulties that children may have in approaching staff about their  circumstances and consider how to build trusted relationships which facilitate  communication.

Holding and sharing information

The critical importance of recording, holding, using and sharing information effectively is set out in  Parts one, two and five of KCSIE, Sept 2021, and therefore the designated safeguarding lead should  be equipped to:

  • Understand the importance of information sharing, both within the school, and with  other schools and Schools on transfer including in-year and between primary and  secondary education, and with the safeguarding partners, other agencies,  organisations and practitioners;
  • Understand relevant data protection legislation and regulations, especially the Data  Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR); and • Be able to keep detailed, accurate, secure written records of concerns and referrals  and understand the purpose of the record-keeping.

Appendix 2 -Managing a Disclosure

All victims should be reassured that they are being taken seriously and that they will  be supported and kept safe. A victim should never be given the impression that they  are creating a problem by reporting abuse, sexual violence or sexual harassment. A victim should never be made to feel ashamed for making a report. It is important that  staff (trusted adult) explains to the child that the law is in place to protect children and  young people rather than criminalise them. This should be shared with the child in a  way that avoids alarming or distressing them ie age appropriate.

Teachers and other staff in schools are in a unique position to observe children’s  behaviour over time and often develop close and trusting relationships with pupils. If  a child discloses directly to a member of staff, the following advice to staff will be  followed:

  • Listen carefully to what is said. Allow the pace of the conversation to be  dictated by the pupil
  • Ask only open questions such as:

“Could you please tell me what happened?”

“Please explain what you mean when you say…?”

“Can you describe the person? Or can you describe the place?” • Accept what the pupil says and do not ask questions which may be considered  to suggest what might have happened, or who has perpetrated the abuse, eg  “Did your dad hit you?”

  • Do not force the child to repeat what he/she said in front of another person • Do not promise confidentiality
  • Do not begin an investigation – for example by asking the child to record what  happened in writing or taking a photograph of any injuries. Note carefully any  visible signs of injury or neglect
  • Reassure the pupil that they have done the right thing, that it is not their fault,  and explain that you will need to tell the Designated Safeguarding Lead and  why
  • Report immediately to a Designated Safeguarding Lead and complete a  hand-written record as soon after the disclosure as possible and in any case  within 24 hours, using the child’s words as far as possible. Use body maps to  record any observed injuries. Note staff must only view parts of a child’s body  which are normally visible
  • Where a child discloses safeguarding allegations against another pupil in the  same setting, the Designated Safeguarding Lead should refer to the local  procedure on the ECSB website and seek advice before commencing its own  investigation or contacting parent

Appendix 3 Managing reports of child on child sexual violence and sexual harassment All victims should be reassured that they are being taken seriously and that they will be supported and  kept safe. A victim should never be given the impression that they are creating a problem by reporting  abuse, sexual violence or sexual harassment. A victim should never be made to feel ashamed for  making a report. It is important that staff (trusted adult) explains to the child that the law is in place  to protect children and young people rather than criminalise them. This should be shared with the  child in a way that avoids alarming or distressing them ie age appropriate.

What is sexual violence and sexual harassment?

Sexual violence

It is important that staff at International School are aware of sexual violence and the fact children can, and  sometimes do, abuse their peers in this way and that it can happen both inside and outside of school.  When referring to sexual violence we are referring to sexual offences and the Sexual Offences Act  2003 as described below:

Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or  mouth of another person (B) with his penis, B does not consent to the penetration and A does not  reasonably believe that B consents.

Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina  or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual,  B does not consent to the penetration and A does not reasonably believe that B consents.

Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another  person (B), the touching is sexual, B does not consent to the touching and A does not reasonably  believe that B consents. (Schools should be aware that sexual assault covers a very wide range of  behaviour so a single act of kissing someone without consent or touching someone’s  bottom/breasts/genitalia without consent can still constitute sexual assault.)

Causing someone to engage in sexual activity without consent: A person (A) commits an offence of:  s/he intentionally causes another person (B) to engage in an Activity, the activity is sexual, B does not  consent to engaging in the activity, and A does not reasonably believe that B consents. (This could  include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third  party.)

What is consent? Consent is about having the freedom and capacity to choose. Consent to sexual  activity may be given to one sort of sexual activity but not another, e.g. to vaginal but not anal sex or  penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during  sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration  only if s/he agrees by choice to that penetration and has the freedom and capacity to make that  choice. Further information about consent can be found here: Rape Crisis England & Wales – Sexual  consent.

▪ A child under the age of 13 can never consent to any sexual activity;

▪ The age of consent is 16:

▪ Sexual intercourse without consent is rape.

Sexual harassment

When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur

online and offline and both inside and outside of school. When we reference sexual harassment, we  do so in the context of child on child sexual harassment. 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 can 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

▪ physical behaviour, such as: deliberately brushing against someone, interfering with someone’s  clothes (schools and Schools should be considering when any of this crosses a line into sexual  violence – it is important to talk to and consider the experience of the victim) and displaying  pictures, photos or drawings of a sexual nature; and

▪ online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment  and/or sexual violence.1It may include

▪ consensual and non-consensual sharing of nudes and semi-nudes images and/or videos. As set  out in UKCIS Sharing nudes and semi-nudes: advice for education settings working with children  and young people (which provides detailed advice for schools and Schools) taking and sharing  nude photographs of U18s is a criminal offence

▪ sharing of unwanted explicit content;

▪ upskirting (is a criminal offence)

▪ sexualised online bullying;

▪ unwanted sexual comments and messages, including, on social media; and ▪ sexual exploitation; coercion and threats;  


The Voyeurism (Offences) Act 2019, which is commonly known as the Upskirting Act, came into force  on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a persons clothing (not  necessarily a skirt) without their permission and/or knowledge, with the intention of viewing their  genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim  humiliation, distress or alarm. It is a criminal offence. Anyone of any sex can be a victim.

The response to a report of sexual violence or sexual harassment

The initial response to a report from a child is incredibly important. How the school responds to a  report can encourage or undermine the confidence of future victims of sexual violence and sexual  harassment to report or come forward. Schools not recognising, acknowledging or understanding the  scale of harassment and abuse and/or downplaying of some behaviours can actually lad to a culture  of unacceptable behaviour. It is essential that all victims are reassured that they are being taken  seriously and that they will be supported and kept safe. A victim should never be given the impression  that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a  victim ever be made to feel ashamed for making a report.

If staff have a concern about a child or a child makes a report to them, they should follow the referral  process as set out from in Part 1 of KCSiE. As is always the case, if staff are in any doubt as to what to  do they should speak to the designated safeguarding lead (or a deputy).

A child is likely to disclose to someone they trust: this could be anyone on the school staff. It is  important that the person to whom the child discloses recognises that the child has placed them in a  position of trust. They should be supportive and respectful of the child.

  • If possible, manage the report with two members of staff present, (preferably one of  the them being the designated safeguarding lead or deputy)
  • Do not promise confidentiality at this initial stage as it is very likely a concern will have  to be shared further (eg with Designated Safeguarding Lead or children’s social care)  to discuss next steps. Staff should only share the report with those people who are  necessary in order to progress it. It is important that the victim understands what the  next steps will be and who the report will be passed to
  • Listen carefully to the child, being non-judgemental, being clear about the boundaries  and how the report will be progressed, not asking leading questions and only  prompting the child where necessary with open questions – where, when, what, etc
  • Consider the best way to make a record of the report. Best practice is to wait until the  end of the disclosure and immediately write up a thorough summary. This allows the  staff member to devote their full attention to the child and to listen to what they are  saying. It may be appropriate to make notes during the report (especially if a second  member of staff is present). However, if making notes, staff should be conscious of  the need to remain engaged with the child and not appear distracted by the note  taking. Either way, it is essential a written record is made
  • Only recording the facts as the child presents them. The notes should not reflect the  personal opinion of the note taker. Schools should be aware that notes of such reports  could become part of a statutory assessment by children’s social care and/or part of a  criminal investigation
  • Where the report includes an online element, being aware of searching screening and  confiscation advice and UKCCIS sexting advice. The key consideration is for staff not  to view or forward illegal images of a child.  
  • Inform the designated safeguarding lead (or deputy), as soon as possible, if the  designated safeguarding lead (or deputy) is not involved in the initial report.

Risk Assessment

Following a report of sexual violence, the designated safeguarding lead will make an immediate risk  and needs assessment. Where there has been a report of sexual harassment, the need for a risk  assessment should be considered on a case-by-case basis. The risk and needs assessment will consider:

  • The victim, especially their protection and support
  • Whether there may have been other victims
  • The alleged perpetrator
  • All the other children (and, if appropriate, adult students and staff) at the school,  especially any actions that are appropriate to protect them
  • The time and location of the incident, and any action required to make the location  safer

The risk assessments will be recorded (written or electronic) and will be kept under review. At all  times, school will actively consider the risks posed to all their pupils and put adequate measures in  place to protect them and keep them safe.

The designated safeguarding lead (or deputy) will ensure that they are engaging with children’s social  care and specialist services as required.

Please note: The wishes of the victim of how they wish to proceed will be considered. Victims will be

given as much control as is reasonably possible over decisions regarding how any Ainvestigation will be  progressed and any support they will be offered.

Action following a report of sexual violence and/or sexual harassment

The designated safeguarding lead (or deputy) will then lead on the actions which need to be  considered

  • How the victim wishes to proceed. Victims should be given as much control as is reasonably  possible over decisions regarding how any investigation will be progressed and any support  that they will be offered. This will be balanced with the school’s duty and responsibilities to  protect other children.
  • The nature of the alleged incident(s), including whether a crime may have been committed  and/or whether HSB has been displayed
  • The ages of the children involved
  • The developmental stages of the children involved
  • Any power imbalance between the children. For example, is/are the alleged perpetrator(s)  significantly older, more mature, confident and well-known social standing? Does the victim  have a disability or learning difficulty?
  • If the alleged incident is a one-off or a sustained pattern of abuse (sexual abuse can be  accompanied by other forms of abuse and a sustained pattern may not just be of a sexual  nature)
  • That sexual violence and sexual harassment can take place within intimate personal  relationships between children
  • Importance of understanding intra familial harms and any necessary support for siblings  following incidents
  • Are there ongoing risks to the victim, other children, adult students or school staff, and • Other related issues and wider context, including any links to child sexual exploitation and  child criminal exploitation

In all cases of concern over a child, all staff should act in the best interests of the child. Immediate  consideration will be given as to how best to support and protect the victim and the alleged  perpetrator(s) (and any other children involved/impacted).

All allegations involving staff or volunteers will be discussed immediately with the Local Authority  Designated Officer (LADO) before any investigation takes place. These discussions can take place  with Customer First, who can advise, as can the LADO team at Suffolk County Council. In borderline  cases, these discussions can be held informally without naming the individual child.  

In any case of immediate risk or serious harm to children, the police shall be informed at the  outset.  


▪ Childnet – STAR SEND Toolkit equips, enables and empowers educators with the knowledge they  need to support young people with special educational needs and disabilities.

▪ Childnet – Just a joke? provides lesson plans, activities, a quiz and teaching guide designed to  explore problematic online sexual behaviour with 9-12 year olds.  

▪ Childnet – Step Up, Speak Up a practical campaign toolkit that addresses the issue of online sexual  harassment amongst young people aged 13-17 years old.

▪ Preventing Harmful Sexual Behaviour toolkit by the Lucy Faithfull Foundation, the toolkit contains  links to useful information, resources and support, including practical tips to prevent HSB.  

▪ NSPCC – Harmful sexual behaviour framework An evidence-informed framework for children and  young people displaying HSB. Contextual Safeguarding Network – Beyond Referrals – Schools  levers for addressing HSB in schools.