Part 1: The Policy Statement.

Principles 

The welfare of each student is paramount. The School will always strive to keep its students safe from any form of harm or abuse.

Any reference to ‘Student’ or ‘student’ in this policy includes any student aged 18 years or over.

At Wycombe Abbey Hong Kong, all members of the school community remain vigilant. We are never complacent about the safety and well-being of our students.

It is a student’s right to feel secure. It is the school’s responsibility to provide such an environment. No student can flourish in any area of their development unless they feel safe.

All members of staff at, Wycombe Abbey School Hong Kong, regardless of job description or status are equally responsible for the care of our students. All members of staff are responsible for acting immediately should they become concerned about any aspect of a student’s safety or well-being. As such, it is the responsibility of all members of staff to keep themselves fully informed of the policy procedures to follow should such concerns arise.

We engage in partnerships with all other relevant agencies in Hong Kong that support the care and welfare of students. By engaging efficiently with all such other agencies, we further our commitment to ensuring effective and useful partnerships designed to protect and safeguard students.

Whilst the school consistently aims to work in open and full communication with our parents, we reserve the right to contact the police or other authorized student-protection agencies without first notifying parents, where it is believed that this course of action is in the student’s best interests.

All references to student protection, well-being and safety include on-line safety for students.

Aims of the Policy

The aims of the policy are by necessity brief and direct. For further details you are guided to the ‘Procedures’ section that follows. 

The aims of the School’s Safeguarding policy are to demonstrate the school’s commitment to safeguarding our students, our colleagues, parents and the wider community. 

To safeguard any students who may be of concern through early identification of their level of need:  

those who are already identified as in need of any additional support.

those who have suffered or are likely to suffer significant harm.

those alleging abuse.

To raise and maintain the level of awareness of all members of Wycombe Abbey School Hong Kong staff members, regardless of job-description or rank of how to safeguard our students by identifying and reporting possible abuse through the correct procedural channels. 

To maintain an easily accessible communication procedure that all members of the school community can follow to report any concerns of harm or abuse of students. 

To ensure that all members of staff and members of the wider adult school community, who have immediate or substantial access to our students have been checked as to their suitability, including verification of their previous records, identity and qualifications, including any previous training and experience of student protection.  

Part 2: The Policy Procedure.

Glossary of Terms

Abuse is defined as a form of maltreatment of a child. Abuse may take the form of physical, emotional, or sexual abuse and includes neglect. This may involve inflicting harm or failing to act to prevent harm. Students may be abused by an adult or another student/student.

Student Protection refers to the processes undertaken to protect students who have been identified as suffering or being at risk of suffering significant harm or abuse.

DSL: Designated Safeguarding Lead.

DDSL: Deputy Designated Safeguarding Lead.

KCSIE: ‘Keeping Children Safe in Education.’ (A core U.K. guidance document on Safeguarding and Student Protection management).

Staff Covers all staff on site, including ancillary supply and self-employed staff, contractors, Head Office and Board colleagues, and volunteers who work with our students. For the benefit of any doubt this group also includes part-time staff, temporary and supply staff, and visiting staff, such as musicians and sports coaches, whether employed directly by the School or by other allied service-providing agencies.

WTSC: ‘Working Together to Safeguard Children.’ (A core U.K. guidance document on Safeguarding and Child Protection management).

The Difference between Safeguarding and Child Protection

Safeguarding is a broader term than child protection. It encompasses all the elements set out within this document and is what a School should do for all students; Child Protection is part of this definition and refers to activities undertaken to protect students who have been harmed/abused or at significant risk of being harmed/abused.

Safeguarding and promoting the welfare of children is defined as protecting children from maltreatment; preventing impairment of a child’s mental and physical health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes. (gov.uk/KCSIE/WTSC)

The following section of the policy document is designed to supply more specific details on how the aims of the policy are put into practice. 

Method

All aspects of this document are advised and made with reference to UK Gov, DfE, ‘Keeping Children Safe in Education’, (KCSIE) 2025, Keeping children safe in education – GOV.UK (www.gov.uk), and from ‘Working Together to Safeguard Children’, 2023, Working together to safeguard Children 2023: statutory guidance (publishing.service.gov.uk). Also from advice made available by the Hong Kong EDB and from all relevant information and advice made available by other allied agencies in Hong Kong.

All members of staff are required to read KCSIE, Part 1 annually as part of their annual Child Protection and Safeguarding training.

This policy is always easily accessible to all members of staff via the school electronic administration system.

All members of the school staff will have satisfied local government requirements in terms of police/EDB checks against any prior convictions or concerns that may exist in Hong Kong or abroad, regarding each person’s suitability to work with students. To this end the school maintains centralized records of all members of staff, this comprehensive document collection is maintained electronically by the school’s HR Manager and records all such checks and any updates.

In the event of any concern arising over data protection during a student protection concern, the school, giving due consideration to the laws of its host nation, will take the line that child protection outranks data protection and will proceed accordingly.

All members of staff are trained and receive regular refresher courses on on-line safety for children.

All members of staff and adults who are associated with the school, who have direct contact with students, are regularly trained and updated in Child Protection.

The school has appointed Julie Richardson as the Designated Senior Lead (Student Protection Officer). This colleague is responsible for administering and ensuring the safeguarding of all students in the school’s care.

Any external letting arrangements of the school’s facilities will include assessing the suitability of adults working with students on the school site.

The school will take all reasonable precautions to ensure that any contractors or visitors to the school are assessed or that their contact with students is risk assessed and that they are accompanied whilst on our site.

Roles and Responsibilities 

The Executive Headteacher 

The Executive Headteacher will ensure: 

That a rigorous and correct safeguarding policy is maintained and administered, in that the policy is adhered to by all members of staff and any other adults who may come into contact with the students at the school.

That all adult members of the school community are aware of how to access the Safeguarding Policy at any time and that colleagues are consistently aware of the core aspects of the policy, as incidents of concern over a student can arise quickly and unexpectedly.

That the school communicates and cooperates with all student protection inter-agency activities across Hong Kong and internationally, (where applicable), to ensure the safety of our students.

That a suitably qualified DSL is permanently in the post and that the post-holder is sufficiently trained and supported in practical terms in order to offer the fullest level of care and protection to our students. Such provision will include a clear job description, consideration of confidentiality issues, administrative support, training, time and staffing support. The full details of the DSL’s job-description are given below under the heading ‘Designated Senior Lead”.

Lead and model a culture of safeguarding awareness across the school community.

Together with the DSL ensure that where there is a safeguarding concern, the student’s wishes and feelings are considered when determining the next steps and future actions.

Together with the DSL ensure that all safeguarding procedures are effectively communicated across the school community.

That all members of staff are fully aware of their responsibilities regarding raising concerns about students, colleagues or unsafe practices (whistleblowing).

That via the curriculum, all students are made aware of how to keep themselves safe, including being safe online.

Ensure that all allegations or concerns raised about any member of staff are dealt with according to the school’s Safeguarding Policy and the local Hong Kong legal requirements in such cases.

The Designated Senior Lead (Student Protection Officer) 

The DSL at Wycombe Abbey School Hong Kong is:  

Julie Richardson

The Deputy DSLs are: 

Rob Fox – Head of School

Feifei Yang – Deputy Head of School

Leezel Granado – School Nurse

Veronica Tan – Head of KS1

Claudia Wong – Head of KS2

Nicola Rae – Head of KS3

Lynn Mitchell – Teacher

Jocelyn Dong – Teacher

Holds responsibility for safeguarding and Student protection, including online safety across the school. A specific letter of appointment for this role, separate from any other letter of appointment is to be signed by the DSL on appointment. The designated responsibility of the DSL may not be delegated.

Will liaise with local Student safeguarding agencies and authorities in order to support the best practice of safeguarding at the school.

In keeping with the laws and police procedures of Hong Kong, ensure that members of staff are aware of and alert to identifying possible indications of radicalisation of students at school.

Will understand and support the School’s delivery with regards to radicalization and PREVENT training within the local national context.

Will remain fully informed of the developing risks associated with on-line safety for students both at home and at school.

Maintains a school-wide culture of awareness that student abuse can happen anywhere – including at our school.

Will liaise with external case managers and any designated authorities in any safeguarding matter which may include concerns over a member staff at the school. The DSL will also be responsible for any cases of staff or volunteer dismissal stemming from a concern of risk or harm to a student.

Will be the lead authority at the school on any matter relating to peer-on-peer abuse at the school.

Be available during term time, school hours for staff to discuss any safeguarding concerns or issues with. Together with the Headteacher, will arrange and communicate contact cover arrangements for out-of-hours times.

Will act as the initial source of support and expertise in all safeguarding matters for all members of the school.

Will encourage and support a school-wide culture of paying due deference and respect to the student’s point of view, of listening to students and being alert to their feelings and sensitivities in such difficult situations.

Will be the lead practitioner in all student protection and safeguarding matters. Accordingly, the DSL will be responsible for ensuring their own training remains current as befits a lead practitioner. Equally the DSL will be responsible for maintaining the high profile of safeguarding training for all other members of staff and volunteers. The DSL will be responsible for maintaining all records pertaining to staff and volunteer safeguarding training and ensuring that all colleagues remain within agreed timeframes of such training.

Together with the SENCO, the DSL will be attuned to the needs of students with any Special Educational Needs and/or Disabilities (SEND).

Will maintain a register of all/any students who have been identified as being at risk/of concern. The Register of Concerns will be supported by full records of all concerns, incidents, actions and outcomes. Such records to be kept securely by the DSL in hard-copy format and secure electronic records. These records will include all concerns about a student even if there is no need to make an immediate referral, as well as the rationale for decisions made and action taken.

Will access training and support to ensure they have the knowledge and skills required to carry out the role. DSL training should be updated at least every two years and their knowledge and skills refreshed at regular intervals but at least annually.

Will liaise with school staff (especially pastoral support, behaviour leads, school health colleagues and the SENCO) on matters of safety and safeguarding.

Will be alert to the specific needs of students in need, those with SEND and young carers.

Will understand the risks associated with online activity and be confident that they have the up-to-date knowledge and capability to keep students safe whilst they are online at school and understand the additional risks that students with SEND face online and the associated and appropriate support they require.

Will ensure that when a student transfers school, their student protection file is passed to the new school as soon as possible, and within any statutory timescales (separately from the main student file and ensuring secure transit) and that confirmation of receipt is received. In addition the DSL will consider whether it is appropriate to share any information with the student’s new setting in advance of that student leaving the School.

Will ensure that where a student transfers school and is on a student protection plan or is a child looked after, their information is passed to the new school immediately.

Will ensure a decision in the case of a transfer whether a copy of the Student Protection file is retained or destroyed in line with best practice.

Will report to the Headteacher any significant issues in terms of student protection practice.

Will ensure that all staff sign to say they have read, understood and agree to work within the School’s Safeguarding Policy, the Online Safety Policy, the Staff Code of Conduct and the Behaviour Policy (students).

Will organize Student Protection and Safeguarding induction, regularly updated training and a minimum of annual updates (including online safety) for all school staff, keep a record of attendance and address any absences.

Ensure that in collaboration with the school leadership, the Safeguarding Policy is reviewed annually and that the procedures and implementation are updated and reviewed regularly.

Ensure that the Safeguarding Policy is available publicly and that parents are aware that referrals about suspected harm and abuse will be made where applicable and the role of the School in this.

Will ensure that the name of the designated members of staff for Student Protection, the Designated Safeguarding Lead and deputies are clearly advertised in the School, with a statement explaining the School’s role in referring and monitoring cases of suspected abuse.

Definition of Child Abuse  

Abuse and neglect are forms of maltreatment of a student. Somebody may abuse or neglect a student by inflicting harm, or by failing to act to prevent harm. students may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger. They may be abused by an adult or adults, or another student or students. The following definitions are taken from The British document entitled ‘Working Together to Safeguard Children’ (2024).  

Physical Abuse  

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

Emotional Abuse  

The persistent emotional maltreatment of a child, such as causes severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child’s participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), 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 in isolation.  

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; they may also include non-contact activities. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.  

Neglect  

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:  

provide adequate food, clothing and shelter (including exclusion from home or abandonment).

protect a child from physical and emotional harm or danger.

ensure adequate supervision (including the use of inadequate caregivers).

ensure access to appropriate medical care or treatment It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Student-on-Student Abuse, Sexual Violence and Sexual Harassment

The Group recognise that students are capable of abusing their peers either face to face or online. There are many different forms of student-on-student abuse including, but not limited to:

Bullying (including cyberbullying).

Physical abuse, such as kicking, hitting, shaking, biting, hair pulling, or otherwise causing physical harm.

Sexual violence, such as sexual assault.

Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment which may be standalone or part of a broader pattern of abuse.

Harmful sexual behaviour, referring to any student, who demonstrates behaviour outside of their normative parameters of development including, but not limited to, abusive or violent behaviours.

Sharing of nudes and semi-nude images and/or videos

Initiation/hazing type violence and ritual.

Upskirting.

Student-on-Student abuse should never be tolerated or passed off as “banter” or “part of growing up,” nor will harmful sexual behaviours be dismissed as “the same” or “just having a laugh”. The victim and perpetrator will be offered appropriate support and reassured that matters will be taken seriously. The Group takes a zero-tolerance approach to reports of sexual violence, sexual harassment, sexism, misogyny/misandry, homophobia and biphobic behaviours The Group will support students where the incident has occurred outside of the School or online, and these incidents will be treated equally seriously.

While bullying between students is not a separate category of abuse, it is a very serious issue that can cause considerable anxiety and distress. The School recognises that students with special educational needs and disabilities (SEND), health conditions, or those who identify as LGBT or are perceived to identify as LGBT, can be more prone to peer on peer group isolation than other students and will consider extra pastoral support for those students. All incidents of bullying should be reported and managed in accordance with the School’s Anti Bullying Strategy.

Sexual Violence and Sexual Harassment between Students

Sexual violence and sexual harassment can occur between students of any age and sex. It can also occur through a group of students and young people sexually assaulting or sexually harassing a single student or group of students.

Students and young people who are victims of sexual violence and sexual harassment are likely to find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment.

Sexual violence and sexual harassment exist on a continuum and may overlap. They can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Members of staff should be aware that some groups are potentially more at risk. Evidence shows girls, students with SEND and LGBT or perceived LGBT students are at greater risk of student-on-student abuse.

Those students identifying as LGBT will have additional pastoral support available should they require this to ensure they have a trusted adult who they can be open with. Our Group acknowledges the need to treat everyone equally, with fairness, dignity and respect. Any discriminatory behaviours are challenged, and students are supported to understand how to treat others with respect. We also have a duty to report and record any of the above incidents.

Members of staff should be aware of the importance of:

making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up.

not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh”, ‘‘what girl do’’, or “boys being boys.”

challenging 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.

Sexual Harassment

When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of student-on-student sexual harassment. Sexual harassment is likely to: violate a student’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. 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 (the school will consider 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.

Online Sexual Harassment

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

non-consensual sharing of sexual images and videos.

sexualised online bullying.

unwanted sexual comments and messages, including, on social media; and

sexual exploitation; coercion and threats

Responding to a Report of Sexual Violence or Sexual Harassment

The initial response to a report from a student 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. If staff have a concern about a student or a student makes a report to them, they should follow the Group referral process for reporting a concern and speak to a member of the DSL team.

Disclosure:

In the event that one student makes a disclosure about another student, the general principles of listening and reporting to the DSL remains the same. Each disclosure will be treated purely on the facts, and no-one prescribed solution can be seen as a best fit. The reporting arrangements are the same as for any case of abuse. All students involved, whether perpetrator or victim, are treated as “at risk” and will be supported.

The victim must always be reassured that they are being taken seriously and that they will be supported and kept safe. The victim will never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment, nor would a victim ever be made to feel ashamed for making a report.

Where there has been a report of sexual violence between peers, the DSL will make an immediate risk and needs assessment, considering:

The victim.

The alleged perpetrator.

The other students (and, if appropriate, staff) at the School.

Proximity of the victim and alleged perpetrator.

Shared classes, bedrooms, and boarding houses.

Risk assessments will be recorded and kept under review.

All concerns, discussions and decisions will be recorded in writing. At the end of the investigation, a review will be held to determine whether there is a pattern of concern, problematic or inappropriate behaviour. Where a report is known to be malicious, the School will consider what disciplinary action is appropriate.

All members of staff should understand that, just because there are no reports of student-on-student abuse within a particular House, Tutor Group or Year Group, that it does not mean that it is not happening; it may simply mean that it is not being reported. Therefore, it is vital that staff report any concerns relating to student-on-student abuse to the DSL or DDSL immediately.

The School will ensure that students are aware of how they can report student-on-student abuse, and that they are aware of the procedures that the School will follow once a report has been made. These procedures will be well-promoted, and in a format that is easily accessible and easily understood.

Abuse of Trust

All staff are made aware that inappropriate behaviour with or towards students is unacceptable. Staff should note that it is an offence for a member of staff, an auxiliary/contracted member of staff, a volunteer or anyone else in a position of trust with our students to:

intentionally touch a student in a sexual way.

have a sexual relationship with a student, even if the relationship is consensual.

cause or incite a student to engage in sexual activity.

intentionally engage in sexual activity in the presence of a student; or for the purposes of sexual gratification cause a student to watch a third person engaging in a sexual activity or look at an image of any person engaging in sexual activity.

A position of trust exists between a staff member and a student, even if the member of staff does not directly teach the student or have any other form of direct contact with the student.

One to One Teaching

Members of staff working in one-to-one situations with students present a higher level of safeguarding risk. Teachers and others should recognise this possibility and plan and conduct such meetings/lessons/tutorials to ensure that they are transparent and open to scrutiny.

All members of staff receive training during the Annual Safeguarding Training in September of each year and at Induction relating to one-to-one situations. Line managers should ensure that each member of their teams have read and understood this policy.

Where an individual meeting or lesson needs to take place, members of staff should consider their environment carefully to minimise the risk of misunderstanding. Any space in which private meetings take place should have visual access to the room or a door left open, or the member of staff must inform a colleague that a meeting, lesson or interview is taking place.

Members of staff should not arrange meetings with students in remote, secluded areas of the school. They should ensure that there is visual access and/or an open door in one-to-one situations. Should a student become distressed, anxious or angry during such a meeting, or should anything happen which could be misinterpreted or give rise to a concern, this must be reported to the DSL as soon as possible.

Late evening individual meetings in quiet places present significant risk and should be avoided.

Reporting Concerns about Safeguarding and/or Student Protection

All/any concerns about Safeguarding or Student Protection must be reported immediately to the DSL or one of the deputy DSLs in the DSL’s absence.

Once a staff member has reported a concern, they must not continue to investigate or pursue any other line of action, without a direct request to do so from the DSL or Executive Headteacher.

Student Protection Concerns

If you are concerned about the behaviour of a colleague towards a student or students, you may worry that you have misunderstood the situation or wonder whether a report could jeopardise a colleague’s career. However, any concern about a member of staff must be raised immediately, (see section below), regardless of how unlikely there would be any substance to the concern. No further action may be necessary, but it is important that such information is brought to the School’s attention as soon as possible. You must remember that in all situations the welfare of the student is paramount.

Our reporting procedures for managing concerns/allegations against staff, (including supply staff, volunteers or Head Office c and contractors), apply when staff have, or are alleged to have:

Behaved in a way that has harmed a student or may have harmed a student.

Possibly committed a criminal offence against or related to a student.

Behaved towards a student or students in a way that indicates that he or she may pose a risk of harm to students.

Behaved or may have behaved in a way that indicates they may not be suitable to work with students.

When you report a concern of this nature you can expect:

The concern to be taken seriously.

Your identity to remain confidential (if this is your wish) unless you are later required to function as a witness in court proceedings.

To be protected as far as possible from victimisation or harassment.

Raising Concerns about a Member of Staff (including supply staff and contractors)

Allegations that meet the harms threshold may relate to a member of staff who has:

Behaved in a way that has harmed a student or may have harmed a student.

Possibly committed a criminal offence against or related to a student.

Behaved towards a student/students in a way that indicates they may pose a risk of harm to students.

Behaved or may have behaved in a way that indicates they may not be suitable to work with students.

Allegations that do not meet the harms test will be dealt with as a low-level concern (see below).

Should a student disclose abuse by a member of staff, the situation will be reported to the Executive Head immediately.

Should the allegation be made against the Executive Head, the situation must be immediately reported to the Group Safeguarding Lead, Howard Tuckett at ht@be.co without informing the Executive Head.

The Staff Code of Conduct offers clear guidance to protect staff from allegations of abuse.

Low Level Concerns

Low level concerns about a member of staff should be reported to the Head of School (KG, LS, US).

The term “low level concern” does not mean that it is insignificant, but that the behaviour towards a student does not meet the “harm threshold.” A low-level concern is any concern, no matter how small, and even if no more than causes a sense of unease or a “nagging doubt”, that an adult working in or on behalf of the School may have acted in a way that is inconsistent with the Staff Code of Conduct, including inappropriate contact outside of School.

Examples of this behaviour could include, but is not limited to:

Being over friendly with students.

Having favourites.

Taking photographs of students on their mobile phone.

Engaging with a student on a one-to-one basis in a secluded area or behind a closed door.

Using inappropriate, intimidating, or offensive language making a student feel uncomfortable.

Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is intended to abuse.

The School takes all concerns about safeguarding seriously and recognises that addressing low-level concerns is important in creating and embedding a culture of openness, trust and transparent in which the School’s values and expected behaviour of its staff are constantly lived, monitored, and reinforced by all staff. The School will address unprofessional behaviour at an early stage and will support the individual to correct it.

Low level concerns which are shared about supply staff and contractors will be notified to their employers and can be submitted via this form – Low-Level Concerns Form

Neutral Notifications

A neutral notification is where a member of staff either self-reports or reports a concern regarding a situation they have found themselves in which could be misinterpreted, might appear compromising to others, and/or they believe they have behaved in such a way that they consider falls below the expected professional standards.

All neutral notifications should be communicated with the DSL, and the DSL will decide whether further action is required.

All low-level concerns and neutral notifications are stored on Staff Safe File for the duration of the individuals’ employment with the School. Reports relating to supply staff and contractors are discussed directly with their employer.

The School will reflect and take steps to act on reported concerns in order to identify any patterns of concerning, problematic, inappropriate behaviour which may indicate an unacceptable culture, or weakness within the safeguarding system.

How to Deal with a Disclosure: 

A member of staff who is approached by a student should listen positively and try to reassure the student.  

The member of staff cannot promise complete confidentiality and should explain that they may need to pass on information to other professionals to help keep the student or other students safe.  

The degree of confidentiality should always be governed by the need to protect the student.  

Additional consideration needs to be given to students with communication difficulties and for those whose preferred language is not English. It is important to communicate with them in a way that is appropriate to their age, understanding and preference.  

All members of staff should know who the DSL is and who to approach if the DSL is unavailable, (Deputy DSLs).  

Guiding Principles:  

The Seven Rs  

Receive  

Listen to what is being said, without displaying shock or disbelief.

Accept what is said and take it seriously.

Make a note of what has been said as soon as practicable.

Reassure  

Reassure the student, but only so far as is honest and reliable.

Don’t make promises you may not be able to keep, e.g. ‘I’ll stay with you’ or ‘everything will be alright now’ or ‘I’ll keep this confidential.’

Do reassure, for example, you could say: ‘I believe you’, ‘I am glad you came to me’, ‘I am sorry this has happened’, ‘We are going to do something together to get help.’

Respond  

Respond to the student only as far as is necessary for you to establish whether or not you need to refer this matter, but do not interrogate for full details.

Do not ask ‘leading’ questions i.e. ‘did he touch you?’ or ‘did she hurt you?’ Such questions may invalidate your evidence, (and the Student’s), in any later prosecution in court, (“leading the witness’’).

Do not ask the student why something has happened.

Do not criticize the alleged perpetrator; the student may care about him/her, and reconciliation may be possible.

Do not ask the student to repeat it all for another member of staff. Explain what you have to do next and whom you have to talk to.

Reassure the student that it will be a senior member of staff.

Report  

Share concerns with the DSL immediately.

If you are not able to contact your DSL or Deputy DSLs, and the student is at risk of immediate harm, contact the Police, as appropriate, directly.

Record  

Make some very brief notes at the time and write them up as soon as possible.

Record the date, time, place, person/s present and noticeable non-verbal behaviour, and the words used by the student. If the student uses sexual ‘pet’ words, record the actual words used, rather than translating them into ‘proper’ words.

If appropriate, complete a body map to indicate the position of any noticeable bruising.

Record facts and observable things, rather than your ‘interpretations’ or ‘assumptions.’

Remember  

Support the student: listen, reassure, and be available.

Complete confidentiality is essential. Share your knowledge only with appropriate professional colleagues, (DSL and/or Deputy DSL).

Review (led by DSL)  

Has the action taken provided good outcomes for the student?

Did the procedure work?

Were any deficiencies or weaknesses identified in the procedure? Have these been remedied?

Is further training required? What happens next?

Receiving a disclosure can be upsetting for a member of staff. As such, the school will seek to support a colleague who has experienced such a disclosure. Such support may include reassurance that they have followed procedure correctly and that their swift actions will enable the allegations to be handled appropriately. In some cases additional counselling may be needed and staff should be encouraged to recognise that disclosures can have an impact on their own emotions. 

Online Safety, Monitoring & Filtering

Each school in the Group has its own Online Safety Policy, which should be read in conjunction with this policy and will include further detail. These individual school policies reinforce the importance of online safety, monitoring and filtering. Each school’s Online Safety Policy will include the following online risks to students:

Disinformation: the deliberate creation and spread of false or misleading content, such as fake news.

Misinformation: the unintentional spread of this false or misleading content.

Conspiracy Theories: the belief that some influential or controlling organization or group is secretly responsible for a notable event or phenomenon.

The use of technology has become a significant component of many safeguarding issues such as student sexual exploitation, radicalisation and sexual predation. Technology often provides the platform that facilitates such harm.

The Group has had due regard to the additional information and support set out in KCSIE and requires that each of our schools has a whole-school approach to online safety and has a clear policy on use of communications technology in school.

Online safety is a running theme when devising and implementing Group or school 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.

It is essential that students are safeguarded from potentially harmful and inappropriate online material. The Group adopts a whole school approach to online safety to protect and educate students and staff in their use of technology, and establishes mechanisms to identify, intervene in, and escalate any concerns as appropriate. Online safety issues can be categorised into four areas of risk:

Content:

Being exposed to illegal, inappropriate, or harmful content, for example: pornography, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, extremism, misinformation, disinformation (including fake news) and conspiracy theories.

Contact:

Being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as Students or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes.

Conduct:

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 students are at risk this should be reported to the Head of school, (KG, LS or US).

The Group ensures that each school has the appropriate level of security protection procedures in place in order to safeguard their systems, staff and learners and review these procedures periodically to keep up with evolving cyber-crime technologies. Helpful guidance on cyber security including considerations can be found at the U.K’s cyber security training for school staff – NCSC.GOV.UK and at https://www.gov.uk/guidance/plan-technology-for-your-school.

Each school’s online safety policy should outline the appropriate filtering and monitoring which take places on school devices and school networks. It also outlines the expectations, applicable roles and responsibilities in relation filtering and monitoring.

Mobile Technology

Many students have unlimited and unrestricted access to the internet via mobile phone networks. This access means some students, whilst at school or college can sexually harass, bully, and control others via their mobile and smart technology, share indecent images consensually and non-consensually (often via large chat groups) and view and share pornography and other harmful content.

With regard to students’ 3G, 4G and 5G accessibility on our campuses, whilst the Group believes that young people need educating about the benefits, it also minimises risk by:

Having a strict no phones policy. Students who need to bring phones or smartwatches to school will be required to hand them in to their form teachers during form time. Phones and devices will be securely locked away and returned to students at the end of the school day. Should a student attend an ECA, they are not permitted to use their phone until the ECA is over.

Artificial Intelligence (AI)

Generative artificial intelligence (AI) tools are now widespread and easy to access. Staff, students and parents/carers may be familiar with generative chatbots such as ChatGPT. We recognise that AI has many uses, including enhancing teaching and learning, and in helping to protect and safeguard students. However, AI may also have the potential to facilitate abuse (e.g. bullying and grooming) and/or expose students to harmful content. For example, in the form of ‘deepfakes,’ where AI is used to create images, audio or video hoaxes that look real. We will treat any use of AI to access harmful content or bully students in line with this policy and each schools’ behaviour policy.

Members of staff should be aware of the risks of using AI tools whilst they are still being developed and should conduct risk assessments for any new AI tool being used by the school.

Staff Induction and Training

All new members of staff undertake a set online safeguarding course, including Online Safety and the prevention from being drawn into terrorism, in addition to having a safeguarding briefing with the DSL or DDSL.

All new staff must read and be familiar with:

Safeguarding and Child Protection Policies and Procedures

Keeping Children Safe in Education KCSIE (Sept 2025) – Part One and Part Five

Staff Code of Conduct

Acceptable use of ICT Policy – Staff

Online Safety Policy and an understanding of the expectations, applicable roles, and responsibilities in relation to filtering and monitoring.

Students’ Behaviour Policy – Behaviour, Rewards and Sanctions Policy and Procedures

Anti-Bullying Strategy

Whistleblowing Procedure

Data Protection and Codes of Practice for Confidentiality – Students

Health and Safety Policy

All staff are required to:

Attend regular safeguarding updates from the DSL at the beginning of every academic year.

Confirm that they have read and understood Part One and Part Five of KCSIE each time KCSIE is updated by the Department for Education. This understanding may be evaluated through questionnaires and discussions as appropriate.

Undertake regular awareness training and receive updates to provide them with the relevant skills and knowledge to safeguard students effectively. The School provides these termly via, for example, e-bulletins, INSET days and staff meetings.

Know where and how to contact the DSL or DDSLs.

Recognise that students who are abused or witness violence may find it difficult to develop a sense of self- worth, may feel helplessness, humiliation and some sense of self-blame.

Recognised that students can be vulnerable and exploited by others: staff must be alert to the signs of vulnerability and/or susceptibilities to sexual harassment, sexual violence, violent extremism or indoctrination.

Know how to ensure that staff behaviour and actions do not place students or staff at risk of harm or allegations of harm to a student.

Know that any concerns about a member of staff’s behaviour towards a student(s) is reported appropriately.

Compulsory annual safeguarding refresher training for all staff will take place. Records of all training are kept, including induction and ongoing training.

All contractors and visitors to the School receive, as a minimum, the identity badge and contact details of the DSL and guidance on what to do if they are concerned about a Student or safeguarding practice at the School.

Whistleblowing  

Students cannot be expected to raise concerns in an environment where staff fail to do so.  

All members of staff must be clear regarding their compulsory duty to raise any concerns they may have about any issue over the management of Child Protection or Safeguarding, which may include the attitude or actions of colleagues, poor or unsafe practice and potential failures in the school’s safeguarding arrangements.  

All such concerns should be raised immediately directly to the Executive Head. 

Whistle-blowing concerns about the Executive Head should be made to:

BE Education Safeguarding Lead

Howard Tuckett

ht@be.co

Part 3: Policy Appendices 

DfE. National Minimum Standards for boarding schools, (2022).

Standard 8 – Safeguarding

8.1 The school should ensure that:

arrangements are made to safeguard and promote the welfare of students at the school; and

such arrangements have regard to any guidance issued by the Secretary of State

8.2 The school should ensure that all staff are aware that safeguarding and promoting the welfare of Students is everyone’s responsibility throughout the school and the boarding facilities.

8.3 It is essential that Students are safeguarded from potentially harmful and inappropriate online material. The school’s approach to online safety should be reflected in the Student protection policy, having regard to the Department’s Keeping Students safe in education guidance.

8.4 Keeping Students safe in education sets out that boarding schools have additional factors to consider with regard to safeguarding. As such it will be important that the boarding school’s Student protection policy (and/or other policies if appropriate) reflect:

the school’s policy on sexual relationships between Students (and importance of boarders understanding this policy).

the school’s approach to Student-on-Student abuse, reflecting the unique nature of boarding accommodation and the risks associated with Students sharing overnight accommodation.

the approach to protecting Students where there is a significant gender imbalance in the school.

the approach to harmful online content and how boarders’ devices are managed in terms of bringing a device into the school, and harmful content that may already be downloaded on to it, and the opportunity to download harmful content via 3,4 and 5G that will bypass the school’s filtering and monitoring systems.

This policy should be read with reference to the following other Key Policies

Safer Recruitment

Staff Handbook

Staff Code of Conduct

Staff Use of Social Media

Anti-Bullying

Online Safety and Acceptable Use for Staff and Pupils

Staff Use of Social Media

Student Use of Social Media

Intimate Care Policy

Appropriate Physical Contact Policy

Missing Students Policy

Children Missing from Education Policy

Pastoral Care Policy

Raising Concerns and Whistleblowing

Reasonable Force and Physical Restraint

Use of Alcohol by Staff in the Presence of Students

Each of the above policies should be readily available at your school. For immediate access to any of the WAIS Group policies, please contact Howard Tuckett at ht@be.co.

Further Information Specific to this School

Social Welfare Department – Family and Child Protective Services Contacts – Online

Social Welfare Department – Family and Child Protective Services Contact PDF

When contacting FCPSU select the office in the child’s home address district.

Cap 212 Offences against the Person Ordinance Section 27 Ill-treatment or neglect by those in charge of child or young person

Protecting Children from Maltreatment – Procedural Guide for Multi-disciplinary Co-operation (Revised 2020)

The arrangements for children missing from education.

EDB Student Mental Health Information

The “Three -tier School-based Emergency Mechanism” for Suicide Prevention

Teachers Law of the People’s Republic of China

Missing Students Policy

Children Missing from Education Policy

Pastoral Care Policy

Further Reading

NSPCC Responding to Children Who Display Sexualised Behaviour Guide

Student Health Service – Mental Health Self-Test Station

Shall We Talk – Psychological Distress Test

Developing Trauma Informed Approaches

Identifying Students Who May Need Mental Health Support

Signs of Abuse

Addendums

Temporary DSL Cover Arrangements During Extended Absence

In the event that the Designated Safeguarding Lead (DSL), Julie Richardson, is away from school for any extended period of time, the following temporary safeguarding leadership structure will be enacted to ensure continuity and compliance with safeguarding responsibilities:

Feifei Yang, Deputy Head of School, will assume the role of Acting DSL during the period of absence.

Rob Fox, Head of School, will provide support and oversight to the Acting DSL to ensure all safeguarding procedures and responsibilities are upheld.

All safeguarding concerns, disclosures, and referrals should be directed to Feifei Yang in the first instance, with Rob Fox available for consultation and escalation as needed.

The Acting DSL will have full access to safeguarding records, systems, and inter-agency contacts to perform the role effectively.

Staff will be notified of the temporary change in safeguarding leadership via internal communication channels, and updated contact details will be displayed in all safeguarding reference points across the school.

This arrangement will remain in place until Julie Richardson resumes her duties or an alternative DSL is formally appointed.

Part 4 – Record of Reviews and Updates

This policy was created by:

Howard Tuckett Safeguarding Lead, BE Education

On 28 March 2024

Last reviewed by:

Howard Tuckett Safeguarding Lead, BE Education.

On 20 June 2024

Last Updated by

Howard Tuckett Safeguarding Lead, BE Education.

on 24^th September 2025

Next Review Date 24^th September 2026

Safeguarding and Student Protection Policy

Contents:

Part 1: The Policy Statement.

Part 2: The Policy Procedure.