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Child Protection Policy

POLICY STATEMENT AND OBJECTIVE

    1. Nexus are fully committed to safeguarding to provide a safe environment for our learners to learn and grow while supporting them in their development so they may thrive to the best of their ability.
    2. We recognise our responsibility to take reasonable steps to promote safe prac;ces and to protect children from abuse, exploitation, and harm by providing a safe, secure, and child-friendly organisation with a strong culture of concern and commitment to protec;ng the best interests of children and young adults.
    3. At Nexus, we acknowledge our duty to act appropriately in response to any allegations
    4. The purpose of Nexus Safeguarding and Child Protection Policy is to
      1. Identify the roles and responsibilities of the staff (including temporary staff), governors, and volunteers to play a full and active part in safeguarding and protecting learners using the United Nations Convention on the Rights of the Child (UNRC) as a means of reference.
      2. Demonstrate the school’s commitment to safeguarding children by:
        • Setting out expectations in respect of training;
        • Ensuring that those responsible for recruitment are aware of how to apply safeguarding principles in employing staff;
        • Setting out expectations of how to ensure learners are safeguarded when they potentially come into contact with non-school staff, e.g. volunteers, contractors etc.;
        • Outlining how complaints against staff/child on child-on-child abuse will
          be handled with the use of a safe and secure system.

SCOPE

  1. This document applies to all Nexus staff, governors, and volunteers.
  2. This Policy sets out the broad framework and expecta;ons rela;ng to safeguarding children. It articulates why safeguarding is important and the actions the organisation will take to meet our responsibilities when interacting with children and young adults.
  3. Every school shall have a detailed guide and operating procedure that put this policy into practice and ensure that all school representatives and partners are aware of their responsibility to uphold it, the code of conduct they must always follow, and the ramifications for misconduct in the event of breaching this. It also sets out the procedures, framework, and guidelines in place to safeguard against abuse and respond effectively to incidents.
  4. The policy does not cover staff concerns, which are addressed under Human Resources and other organisational policies.

TERMS AND DEFINITIONS

  1. An allegation is any concern that an adult/child has:
    • harmed or abused a child, including physical, emotional, or sexual harm or abuse, exploitation, and neglect
    • behaved in a way that could constitute a criminal offence towards or related to a child
    • behaved in a way that indicates they are not suitable to work with children in their personal, professional or community life
  2. Child abuse is any physical or emotional maltreatment, sexual abuse or exploitation, or negligent treatment by any person in which the child’s well-being, health, and safety are in jeopardy.
  3. Child protection or safeguarding refers to protecting children from maltreatment; preventing impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of their right to safe and effective care; and taking ac;on to enable all children to have the best outcomes. (The terms child protection and safeguarding are used interchangeably in this document.)
  4. Nexus – the term “school” or “Nexus” used in this document refers to Nexus Interna;onal School, Malaysia.
  5. Staff/Employee refers to all those working for or on behalf of the school, full-;me or part-;me, in either a paid or voluntary capacity, including boarding environment staff(if applicable).
  6. Senior Leadership Team or SLT are the senior leadership team, from ;me to ;me at Nexus, including, but not limited to the Principal, Heads of Primary and Secondary schools and the Head of Boarding
  7. DSL refers to the Designated Safeguarding Lead at Nexus. Safeguarding team refers to the Nexus DSL, any appointed Deputy Designated Safeguarding Leads and the school counsellor.
  8. Refer to Glossary A of the Working Together to Safeguard Children 2023: Statutory Guidance for the extensive list of types of Abuse.

ROLES & RESPONSIBILITIES

  1. The Governing Body
    1. The School Governing body, namely the Board of Governors (Taylor’s Schools) have a strategic leadership responsibility that supports an overarching culture of safeguarding
      the school and checking that the culture has become embedded. This is fulfilled through:
        • ensuring that adults who work in the school, including volunteers, don’t pose a risk to learners
        • ensuring all staff who work directly with children undertake training so that they know how to respond to concerns and are kept up to date with policy and practice
        • ensuring all staff who do not work directly with children (working with the senior
          leadership team and designated safeguarding lead(s) either read Part one or Annex A (a condensed version of Part one) of the Keeping Children Safe In Education 2023 (KCSIE 2023)
        • learners being taught about staying safe
        • an environment where learners feel confident to approach any member of staff if they have a worry or problem
    2. The governing body is responsible for ensuring that
      • Mechanisms are in place to assist staff in understanding and discharging their role and responsibilities
      • All reasonable measures are in place to minimise children’s exposure to the safeguarding risks associated with the school’s IT system. This can be achieved by implementing appropriate filtering and monitoring systems within the school while regularly assessing their effectiveness. The governing body must ensure that the School’s leadership team and staff are aware of and understand the implemented measure, effectively managing them and knowing how to report
        concerns
      • an annual assessment of the School’s policies and procedures regarding the safeguarding and well-being of its learners, considering a comprehensive report on child protection matters provided by the DSL is conducted. The review aims to verify that all obligations pertaining to the School’s governance in relation to safeguarding have been fulfilled.
  2.  The Safeguarding Governor
    1. The Safeguarding Governor is a member of the school governing body who sits on the board.
    2. The Safeguarding Governor for the schools serves as a link between the School Designated
      Safeguarding Lead (DSL) and the board and is responsible for:
        • Overseeing the processes and stays up to date on relevant guidance and policy, ensuring the board is made aware of any changes to their safeguarding responsibilities. The School DSL will provide regular reports (at least termly) to the Safeguarding Governor.
        • Reporting to the governing board upon meetings with the DSL and any visits/interactions
          with staff and learners.
  3. The Principal and the school Senior Leadership Team will ensure:
    • The Safeguarding Governor is a member of the school governing body who sits on the
      board.
    • The School’s Safeguarding Policy is complied with.
    • Provide a safe environment in which children can learn;
    • Safeguarding systems are put in place to deter possible abusers who may have access to
      learners whilst the school is in loco parents and will manage effectively any allegations or
      concerns about abuse when they arise;
    • Select Designated Safeguarding Leads (DSL) and Deputy DSLs;
    • The DSL a2ends the appropriate required training; and
    • Termly updates to Safeguarding Governor at the School’s BOG mee;ng pertaining to
      safeguarding detailing any changes to the policy and procedures, training undertaken by
      the DSL, deputies and/or by all staff and members of the school board, the number and type of incidents/cases, and the number of children on the Child Protection register (anonymised)
  4.  Designated Safeguarding Lead(s) (DSL)
    All schools will have at least one DSL, appointed by the School Principal. The DSL is responsible
    for:
    • Coordinating action within the school on safeguarding and child protection issues;
    • Making prompt contact with the responsible authorities (upon consultation with legal advisers) to refer a child where there are concerns that a child may need help or is at risk (including possible abuse), making all referrals in writing following a telephone call to the respective authorities or agencies where this is deemed to be the action that provides most safety and prevention of harm for learners;
    • Liaising with any relevant adults (e.g. Head of School, Principal, class teacher or learner Welfare) and other services such as external professional counselling, attorney, or local authorities concerning safeguarding matters;
    • Advising on the response to safeguarding concerns and acting as a source of support and expertise to staff;
    • Informing parents about any concerns about a learner’s welfare or any ac;on taken to safeguard and promote a learner’s welfare, providing this does not compromise the learner’s safety, except where informing a parent would put a learner at greater risk;
    • Keeping and monitoring the record management, confidentiality, and storage of records concerning child protection;
    • Ensuring that appropriate safeguarding arrangements are in place for educational visits;
    • Raising awareness about safeguarding and child protection on an ongoing basis;
    • To share updates on policy changes, training undertaken by staff, the number and type of incidents/cases, and the number of children on the Child Protection register (anonymised) at the BOG;
    • Providing the Principal with a report for the School Board on a termly basis.

GUIDING PRINCIPLES

  1. Whole school approach to safeguarding
    • Everyone in the school is involved in safeguarding. Safeguarding and child protection are the forefront and underpinning aspects of process and policy development. Ultimately, all systems, processes and policies should operate with the best interests of the child at heart.
    • Where there is a safeguarding concern, governing bodies and school leaders will ensure the child’s wishes and feelings are considered when determining what action to take and what services to provide.
    • All staff should be prepared to identify children who may benefit from early help (refer to clause 6.1).
  2. Commitment to Safeguarding
    • Safeguarding responsibilities are clearly defined, both within the school and in the governance, to ensure full implementation of the policy and ethical practice.
    • All staff and board members understand their roles, responsibilities, policies, and reporting procedures of suspected or disclosed maltreatment, including historical disclosure.
    • The School should have in place an agreement with parents ensuring that they have agreed to safeguarding and child protection principles applied by the school.
  3. Ensuring pupils are taught about safeguarding
    • Building safeguarding into learning supports pupils by helping them recognise, understand, and develop resilience to the risks around them. All learners at Nexus are taught about safeguarding in their curriculum, covering mental and physical health and well-being as well as online safety.
    • Learners (including those with special educational needs and other vulnerabilities) receive inclusive, age-appropriate education related to child safeguarding, including:
      • Healthy and respectful relationships
      • Boundaries and consent
      • Stereotyping, prejudice and equality
      • Body confidence and self-esteem
      • How to recognise an abusive relationship, including coercive and controlling behaviour
      • Concepts of and laws related to – sexual consent, sexual exploitation, abuse, grooming, coercion, harassment, rape, domestic abuse, so-called ‘honour’ based violence and how to access support and
      • What constitutes sexual harassment and sexual violence, and why these are always unacceptable
  4. Online Safety and Filtering & Monitoring
    • The School should have a clear policy on mobile and smart technology use, considering that learners may have unrestricted internet access. This includes addressing issues such as sexual harassment, bullying, sharing indecent images, and exposure to harmful content. Policies should reflect how these matters are managed on school premises and align with child protection guidelines.
    • With the advice of ICT staff, the governing body should ensure there are standards in place at the school to implement appropriate filtering and monitoring systems. The filtering and monitoring standards should:
      • Identify and assign roles and responsibilities to manage filtering and monitoring systems.
      • Review filtering and monitoring provisions at least annually
      • Block harmful and inappropriate content without unreasonably impacting teaching and learning.
      • Have effective monitoring strategies in place that meet the School’s safeguarding needs
    • For further details on filtering and monitoring, UK’s Department of Education’s Filtering and Monitoring Standards.
  5. Safeguarding training
    • The governing body (including the Safeguarding Governor) should receive appropriate safeguarding and child protection training at induction and then at regular intervals to ensure the school’s safeguarding policies and procedures are effective.
    • The DSL (and any deputies) should undergo training to provide them with the knowledge and skills required to carry out their role. The training should be updated annually.
    • All staff will receive appropriate and regular safeguarding and child protection training at induction and are recommended to be updated at least annually, so they are aware of the school’s safeguarding policies and procedures, and understand and know what to do if they are concerned about a learner.
    • The training will include recognising signs of abuse, understanding legal obligations, reporting procedures, and responding to disclosures from children.
    • There is a systematic process for the induction and training of new board members, school leaders and staff, which includes policies related to data protection, child protection, and safeguarding. Such training can be conducted by the DSL, the Principal, or the Safeguarding Governor, as appropriate.
    • All staff and volunteers should be made aware of the:
      • School Behaviour Policy
      • School’s procedures for managing children who are missing educa;on, or Absence Policy
      • Staff Handbook, which includes guidance on staff/ learner relationships and guidance on communications, including social media
      • Names and photographs of DSLs
      • Copy or link to Keeping Children Safe in Education
    • The School shall iden;fy the courses required based on the role of the staff and keep up-
      to-date records of all staff safeguarding training, including levels of training and dates.
  6. Safe Working Practice
    • Staff are responsible for their own actions and behaviour and must understand the need to maintain appropriate boundaries in their contact with learners. Staff should avoid any contact with learners which would lead any reasonable person to question their motivation and intentions.
    • Staff should work and be seen to work openly and transparently. Staff should continuously monitor and review their working practices to ensure they follow the guidance set out in the school safeguarding policy/guide.
    • All staff and visitors to the school are required to always wear an identity badge.
    • The visitor’s code of conduct in place for Nexus from time to time must always be
      complied with.
    • Any contact with learners using electronic media should be for professional reasons only. All communication with learners should be limited to professional matters. Staff must use school-assigned communication channels only. Staff must not communicate via communication channels which are not assigned by the School, e.g., personal email addresses and WhatsApp. Staff must not give to or obtain personal phone numbers from learners, except for very specific reasons which have been made clear to the Designated Safeguarding Leads. Staff should decline access to personal online profiles on sites, such as Facebook and Instagram, and set suitable privacy settings that they are comfortable with. Privacy settings must consider the interest of the School as well as follow the terms and conditions of employment.
  7. Safer recruitment
    • It is the expectation that the School adheres to the concepts of the policy and procedure for safer recruitment in education.
    • At least one member of the recruitment panel involved in the selection and recruitment of school staff is to undergo safer recruitment training.
    • As part of the Safer Recruitment process, the School’s Human Resources department shall ensure:
      • All staff will be subject to appropriate identity, qualification and health checks;
      • References will be verified and appropriate criminal record checks made (where possible);
      • To inform shortlisted candidates that online searches may be done as part of pre-recruitment due diligence checks;
      • To maintain records detailing the range of checks carried out on staff.
      • To only use employment agencies which can demonstrate that they positively vet their staff.
    • New staff
      New staff (including temporary staff) will be informed of their safeguarding and child protection responsibilities in the following ways:
      • All new staff who have direct contact with learners are required to sign a letter confirming that they have read and understood this Safeguarding Policy, Code of Conduct/Staff Handbook and the 9 key points of the SOAC Act 2017 (Sexual Offences Against Children).
      • All new staff will receive a safeguarding induction. At the induction, they will be sent a copy of this policy so they can read it as well as the key points of the SOAC Act, and sign a letter confirming that they have read and understood both documents. This will be kept in the staff’s personal file.
      • For staff who do not work directly with children (working with the senior leadership team and designated safeguarding lead(s)) shall be given appropriate training which should be based on Part One or Annex A (a condensed version of Part one) of the Keeping Children Safe In Education 2023 (KCSIE 2023)
    • Volunteers
      • Any parent or other person/organisation engaged by the school to work in a voluntary capacity with learners will be subjected to all reasonable vetting procedures.
      • Volunteers will be subject to the same code of conduct as paid employees of the school.
      • Volunteers will at no ;me be given responsibility for the personal or intimate care of learners, and will not be left unsupervised with learners.
      • Volunteers who work at the School will not be left alone and unsupervised in charge of learners.
  8. Risk Assessment and Monitoring
    • The school is to identify strategic priorities linked to safeguarding. Keeping up to date with guidance and policy is important, but it is strategy that sets direction, maintains focus, and ensures continued improvement.
    • The school’s leadership team will regularly undertake a self-assessment or audit of their safeguarding procedures and identify any potential risks and the relevant mitigation actions to avoid or minimise such risks.
    • The School’s safeguarding policies and guides are to be reviewed annually (as a minimum) and updated if needed, so that it is kept up to date with safeguarding issues as they emerge and evolve, including lessons learnt, and is available publicly either via the school website or by other means.
  9. Other Related Policies and Procedures
    1. The School will have an effective safeguarding guide and procedures that put this policy into practice. The safeguarding guide will be supplemented with operating guides that manage the following aspects:
      • Alcohol, Drugs, Education & Abuse
      • Attendance – safeguarding response to children who are absent from
        education, particularly on repeat occasions and/or prolonged periods
      • Behaviour Management / Behaviour policy – prevents bullying, including
        cyberbullying, prejudice-based and discriminatory bullying.
      • Counselling Policy
      • Data Protection and Information Sharing
      • E-Safety or Online Learning
      • Health and Safety Policy and Guideline
      • Managing Allegations Protocol
      • Safer Recruitment Standards
      • School Staff Code of Conduct / Handbook
      • Visitor Management
      • Guardianship Policy
  10. Boarding
    • The school’s policies and procedures concerning child safeguarding meet the needs of boarding learners, staff, and facilities. These include child protection, encompassing expectations for healthy relationships, both physical and virtual; complaints; behaviour management, including an;-bullying and restraint;
      security; and health and safety reporting and record-keeping, which exceed, where necessary, local regulations.
  11. Photography, Filming and Recording
    • Photographs, films, and other recordings of individuals are considered personal information and, as such, are protected by privacy law in the same way as other personal information.
    • In most circumstances, if the captured images are to be used by the school, generic consent from parents would have been obtained through the Enrolment Terms and Conditions. The School will obtain explicit consent from the parents should the filming or photography be directed at a certain learner(s) and the
      images will be used for external media.
    • The School allows parents (or guardians) to take photos or videos during sports events within the following guidelines:
      • All young people featured in photographs/recordings must be appropriately dressed.
      • Only photography or videography for personal use is permitted.
      • Capturing of images for the purpose of business, official or commercial activities are totally not allowed unless explicit consent and agreement of all affected parties have been obtained.
      • Parents should not publish photos or videos that also contain images of other children unless consent from the affected parties has been obtained. If the parent of one of the other children is uncomfortable with the shared images and asks the parent to take the photo down, common courtesy would suggest that the photo be taken down.
      • The recording should ideally focus on the activity. Where possible, images of children/young people should be recorded in small groups.
      • Prior to or at the start of the event, the School event coordinator will send an announcement to remind parents and guests about the above guidelines for capturing images involving young children.
    • The Principal or the Heads of School are responsible for:
      • advising parents or carers when photographs, films or other recordings of learners are to be taken and how they will be stored and used
      • obtaining parent or carer permission before learner photographs, films or other recordings are made publicly available
      • providing parents or carers with the choice to withhold or withdraw consent for their child to be photographed or filmed in certain circumstances
      • considering whether to allow parents or carers to photograph or film their children participating in school events or performances
      • managing how and when others collect and publish photographs and, or film of learners
      • ensuring that when engaging a professional photographer, a confidentiality clause relating to appropriate information handling is included in the agreement or contract between the photographer and the school.Taking photographs or video by parents or guardians for personal use falls under the so-called “household exemption” under the GDPR, which provides that the GDPR does not apply when a person processes personal data (for example, a photograph of someone) in the course of a purely personal or household activityPhotos taken for official school use or commercial use are covered by the Privacy Act (PDPA and GDPR), and parents
        and learners should be advised why they are being taken.
  12. Confidentiality
    1. When listening to a child disclosing information associated with child protection and safeguarding matters, s/he should not investigate or ask leading questions if seeking clarification and should recognise the importance of not making assumptions.
    2. If a child discloses informa;on to a staff member, the staff member should ensure that they do not promise to keep the disclosure confiden;al, and the child should be advised that the concern will be shared on a ‘need-to-know’ basis only to not compromise the child’s safety or wellbeing. The staff is to report to the DSL
      immediately.
    3. If parents wish to share such information with the school, they must be aware that
      it will not be possible to guarantee confidentiality. The school can reassure parents, however, that if they wish, the source of the information can remain anonymous.
    4. The School will ensure that the confidentiality of information is maintained by keeping records in a safe and secure place with access strictly limited.
    5. The School shall refer a child to the appropriate authority with their parents/carers unless doing so could put the child at greater risk of harm, or impede a criminal investigation. If in doubt, the School will consult with the appropriate safeguarding authorities.
  13. Records
    1. When handling child protection and safeguarding concerns, brief and accurate
      written notes will be kept. These records should include:
      • A clear and comprehensive summary of the concern/allegation – using the informant’s words, including ;me, date and location where the alleged incident took place, details of what happened, what was said and who was present (e.g. identity of the child, alleged perpetrator), who it was reported to; ensuring that this record is signed (by the person making the report), dated and immediately passed on to the DSL.
      • Details of how the concern was followed up and resolved
      • Details of all contact with parents/guardians
      • Notes on any action taken, decisions reached, reasons for the decisions made, and the outcome
    2. Any additions or changes should be added to the initial record without altering the original.
    3. Child protection/safeguarding records are
      • Not open to learners or parents and should be kept confidential and stored securely (which may be on a secure online platform such as CPOMS)
      • To be kept separately from educational records and in separate files per child
      • To be protected with a different password (if stored electronically) from the child’s other files
      • Accessible only by the DSLs and Deputy DDSLs .

Child Protection

The School shall implement various measures depending on the available information obtained when a complaint is made. The School shall collaborate with external entities such as local authorities and the police (as required).

  1. Early Help refers to the support provided to children and families when an issue arises, with a primary focus on improving children’s outcomes. The Designated Safeguarding Lead (DSL) typically takes the lead in collaborating with other agencies and initiating inter-agency assessments when early help is deemed necessary. It is important to regularly review such cases and consider referring the child to relevant Children’s Care organizations or therapists if their situation does not show improvement or deteriorates. School staff should be particularly vigilant for signs indicating the potential need for early help, especially in children who are:
    • disabled or have additional needs,
    • those with special educational needs,
    • young carers,
    • those exhibiting an involvement in antisocial or criminal behaviour,
    • those frequently is missing/go missing from home,
    • misusing drugs, alcohol or any other substances themselves,
    • at risk of radicalisation or exploitation,
    • facing challenges within their family such as substance abuse,
    • at risk of ‘honour’-based abuse such as Female Genital Mutilation or Forced
      marriage,
    • persistently absent from education, including persistent absences for part of the school day,
    • privately fostered children or those with guardiansDetailed information on early help can be found in Chapter 1 of Working Together to Safeguard Children.
  2. Children in Need
    Children in need are those who require additional support to achieve or maintain their health and development (likely to be significantly impaired without the provision of services or is disabled).

  3. Children at Risk of Significant Harm
    If there is reasonable cause to suspect that a child is or will likely experience significant harm, the local authorities i.e. police and Childline for Malaysia (for Malaysia) must be notified by the School so they may determine if ac;on is needed to protect the child’s welfare, especially in cases of abuse, neglect, or external threats. In the event of a child being injured, the school may take the child to the nearby government hospital for examination. If there are indications of potential abuse, neglect, or external dangers, it becomes the responsibility of the hospital to carry out the required actions. Should there be an investigation, the school’s action may be determined on the advice given by the investigating agency. Refer to Appendix 2.

  4. Reporting Concerns about a ChildAll staff members should know how to respond when a child discloses abuse or when concerns arise about a child’s welfare. They should listen attentively, provide reassurance, seek necessary context, and involve the designated safeguarding lead. The child should be informed about the confidentiality of the ma2er and what steps will be taken next.
  5. If a staff member has concerns about a child It’s
    important to follow these steps:
    • The staff should act immediately and report to the DSL / Child Protection team ensuring to follow Nexus policy and the school’s procedures in place.
    • If the DSL’s child is implicated or if a staff disagrees with the DSL’s actions when raising a child protection concern about a child, he /she should raise the matter with the Principal, or where the Principal is implicated with the Safeguarding Governor.
    • The School shall:
      • Choose to manage support for the child internally via the school’s own pastoral support processes;
      • Undertake an early help assessment; or
      • Make a referral to the appropriate authority for example as the child might be in need or suffering or likely to suffer harm.
    • If in event DSL or a Deputy DSL is not available, the staff should consider speaking to a member of the senior leadership team. Any action taken should be shared with the DSL as soon as possible.
    • Staff should ensure confidentiality as mentioned in clause
  6. Managing Allegations Against learners
    1. The School staff should be clear about the Safeguarding policy and procedures with regard to child-on-child abuse. The staff should recognise that children are capable of abusing other children (including online) and should be alert to possible indicators of child-on-child abuse.
    2. The school should ensure that there are:
      • Procedures in place to minimise the risk of child-on-child abuse ;
      • Systems in place (and they should be well promoted, easily understood and easily accessible) for children to confidently report abuse, knowing their concerns will be treated seriously;
      • Recognition that even if there are no reported cases of child-on-child abuse, such abuse may still be taking place and is simply not being reported
      • Processes in place on how allegations of child-on-child abuse will be recorded, investigated, and dealt with;
      • clear processes as to how victims, perpetrators and any other children affected by child-on-child abuse will be supported.
    3. Any expulsion related to safeguarding concerns will be reported to the Safeguarding Governor prior to the expulsion being carried out. The Safeguarding Governor will be consulted in such cases. The final decision will be in the interest of the child who is harmed.
  7. Managing Allegations against staff
    1. When a child discloses information to a staff member, the staff member is to report to the DSL immediately. Refer to clause 5.11 on ensuring the confidentiality of information shared.
    2. If a member of staff disagrees with the DSL’s actions or if the DSL/DSL team is implicated when raising a child protection concern about a child, he/she should raise the matter with the Principal, or where the Principal is implicated, with the Safeguarding Governor.
    3. Following a decision to investigate, the School shall create a multi-disciplinary allegations management team to help ensure that the necessary steps are taken and to provide a source of expertise to be drawn (as appropriate) by the person leading the school’s response to an allegation. The roles and responsibilities of each member is to be agreed upon and documented.
    4. A team leader is to be appointed. This person should be in a school leadership role and trained in child protection. He/She is accountable to other senior leaders in the school and the School Governing Body.
    5. The team should consist of the following roles:
      • DSL
      • Safeguarding Governor
      • Head of School and/or Principal
      • Taylor’s Office representative or someone from the School’s Board of Governors/Directors
      • Human Resources representative
      • School Counsellor (optional)
      • Legal adviser (optional)
      • Communications professional (optional)
      • Representative/s from the local community to consider cultural and
        linguistic needs (as necessary)
    6. The School is to establish a guide on managing allegations to promote transparency and protect confidentiality. The document shall be cross-referenced with this policy and should include:
      • the process of documenting allegations, recording decisions taken, how allegations and concerns should be reported and to whom (Principal and/or DSL);
      • specific steps to follow when responding to allegations of abuse (both current and non-recent) – the steps should be broad enough to accommodate different fact patterns and allegations;
      • steps taken to protect the privacy rights of the child or children who have allegedly been abused, of the alleged perpetrator, and others involved (for example, by only sharing information about the allegation on a ‘need to know’ basis);
      • the criteria and process for informing external agencies and what decisions should only be taken following an external agency’s decision as to how to proceed;
      • actions taken when external agencies are not able or willing to intervene, and/or where the behaviour does not meet the threshold for referral to external agencies; and
      • factors the school will consider in relation to the alleged perpetrator, including:
        • when to inform the alleged perpetrator of the allegation and the process the school will follow to address it;
        • how to uphold the alleged perpetrator’s employment and privacy rights and follow the principles of natural justice, which include advising the alleged perpetrator of the allegation and an opportunity to respond to it;
        • determining if and when the alleged perpetrator will be relieved from duty and if it will be paid or unpaid;
        • determining other appropriate interim remedies; and
        • support to be provided, such as counselling.
    7. Appendix 1 [Managing Allegations Process] illustrates the process for an effective response to an allegation of abuse (including details on Whistleblowing).
    8. The Taylor Education Group’s Whistleblower Policy details another avenue to report wrongdoing. This is applicable to all units under Taylor’s Education Group.

APPENDIX

  1. Managing Allegations Process
  2. Key Contact Information
  3. Safeguarding Report to Governors Template – Updated
  4. School Photography and Videography Opt-Out Form

REFERENCES

  1. Keeping Children Safe in Educa;on 2023 (KCSIE) Department of Educa;on, United Kingdom
  2. Managing Allega;ons of Child Abuse by Educators and Other Adults – Protocol for international Schools (Sept 2018)
  3. Safeguarding Policy, Network International School
  4. New Standards for Child Protection Adopted by School Evaluation Agencies – International
    Taskforce for Child Protection (ITFCP Standards)
  5. Visitor Management
  6. TEG Code of Conduct & Ethics Policy
  7. Management of Child Safeguarding Allegations, Keeping Children Safe (2019) 8.8 Whistleblower Policy
  8. Child Act No. 611, 2001 (Malaysia)
  9. Sexual Offences Against Children Act 2017

Appendix 1 – Managing Allega=ons Process

  1. An allegation may come from the victim, DSL or another member of the school community (including learners, alumni, current and former staff, parents or guardians) in the form of:
    • A written statement that describes or implies inappropriate behaviour by an adult/child;
    • A verbal disclosure or partial disclosure;
    • Monitoring of staff and learner information services or social media use;
    • Information provided by a member of the public, local authorities or other external
      agencies;
    • A legal claim.
  2. All allegations, which have implications for the safety and welfare of learners, will be taken seriously and investigated in line with the school’s other policies without any delay. Any anonymous allegations and allegations should be examined carefully and never dismissed based on anonymity or the perceived motivation of the referrer.
  3. Immediate actions / considerations includes:
    • Responding with empathy in a non-judgemental and open way;
    • Explaining the necessary steps required and the reasons for doing so;
    • Taking brief and concise notes and record them;
    • Report the allegation to the DSL. If staff members have concerns about the DSL, he/she should raise the matter with the Principal, or where the Principal is implicated, with the Safeguarding Governor.
    • Take any urgent actions needed to protect the child from imminent risk of harm, including emergency services to undertake a medication examination (while being mindful of cultural sensitivities);
    • Consider seeking legal advice and if required informing other external agencies;
    • The Principal is to decide who will lead the coordination of the school’s response to the
      allegation and if a multi-disciplinary allegation team is necessary (depending on the size/type of the allegation).
  4. Assessing the allegation/concern, risk and preserving evidence
    • Put in place an interim risk assessment protecting children from further potential harm by the alleged perpetrator;
    • Any steps taken to preserve evidence, where possible, be taken in consultation with your legal advisers and any external agencies (e.g. removing access to school systems, preserving emails and other digital accounts, securing any school-provided devices before informing the alleged perpetrator of the allegation. IT personnel are reminded to not search or view any material but instead to safely store the devices/records and provide them to the person conducting the inquiry.
  5. External Reporting (Reporting to local/national authorities) – Where this is deemed to be the
    action that provides most safety and prevention of harm for the learner, discuss the need/legal
    requirements of engaging with external agencies with legal advisers.
  6. Safeguarding – Consult with a legal adviser and/or external agencies (if required) to
    determine/ensure to:
    • Identify and protect victim/s and their family from further harm within or outside the school community;
    • Protect any additional victims who come forward, other children in the school;
    • There is a safety plan for the child/victim and there are steps to implement the plan;
    • Protect and support the School staff.
  7. Communications
    • The Principal is to inform the Safeguarding Governor and decide who else needs to be
      informed, ensuring no facts are disclosed that would hinder any future investigation or inquiry or violate data protection or employee or learner rights. The designated lead should regularly update the Safeguarding Governor (or another Board member as appropriate) on all material developments. Communication should be immediate without waiting for the BOG meeting to update about developments on the safeguarding issue.
    • The School is to appoint one person to be responsible for communications and they are aware of all the facts and they keep this information confidential and secure until it needs to be communicated. This person should be given the authority to consult with a communications advisor regarding the communications and any media inquiries/responses.
    • The designated lead/team is/are to decide with the consultation with a legal adviser whether any other external body needs to be informed at this ;me, such as any inspection, accreditation, regulatory, or insurance bodies. The team is to decide on what information should be provided, how it should be provided, and what should/can be done to protect confidentiality.
    • The Principal is to consult with your legal advisers and any external agencies before any communication is sent, including any communication to the victim and their family, the alleged perpetrator/abuser, staff, the wider school community, and/or the media.
  8. Record-keeping – An incident file that includes relevant details is to be created and its
    confidentiality is to be maintained
  9. Further response – Inquiry
    In the case of allegations against a staff, consultation with Taylor’s Group People & Culture, legal advisers and any relevant external agencies/expert (as required and as appropriate), the School:
    • Shall carry out an inquiry to determine the facts, appropriate actions (dismissal/suspension, with or without pay) on the alleged perpetrator, communication plan on informing the alleged perpetrator and other action plans that includes the consideration of the possibility of the alleged perpetrator resigning. Refer to TEG Handling Discipline & Misconduct Policy for details on appropriately handling disciplinary issues or misconduct
    • Is to attempt to secure the cooperation of the alleged perpetrator to provide him/her the opportunity to determine their fitness to be around children.Where allegations are against a child, in consultation with the School’s SLT, legal advisers and any relevant external agencies/expert (as required and as appropriate), the School shall carry out an investigation to determine the facts, appropriate actions (suspension/expulsion), communication plan on informing both families (victim and abuser) and Taylor’s Office and other action plans that includes the consideration on the possibility of the alleged abuser withdrawing from the School. Refer to the school’s respective Procedures and Guidelines for details on appropriately handling disciplinary issues
  10. Making a decision – Post inquiry
    Upon completion of the Inquiry or when there is sufficient information for decision making, in
    consultation with legal advisers and any relevant external agencies/experts (as required and as appropriate), the School
    • shall decide on actions to be taken which may take the form of a disciplinary hearing that will be conducted by someone who was not involved in managing the allegation previously, hold a senior management position, is a governor or as identified by the Safeguarding Governor. Any findings on the investigation, decisions made and reasons for the action should be properly documented in a reference.
    • If the alleged perpetrator/abuser is found to pose a risk to children, their contract should be terminated / should be expelled (subject to legal advice and School’s policies). Relevant authorities are to be notified accordingly.
    • Shall be mindful of their obligation to not defame any individuals in references or to violate their privacy rights.
    • If the alleged perpetrator/abuser does not pose a risk of harm to children, the alleged perpetrator/abuser may be reinstated and are to be monitored post-reinstatement.
  11. Whistleblowing
    Taylor’s Schools is committed to protecting individuals who report safeguarding concerns from any form of retaliation or victimisation. Any attempts to intimidate, harass, or discriminate against whistleblowers will be treated as serious misconduct and may result in disciplinary action, up to and including termination of employment or expulsion from the school community.

    Here is a list of whistleblowing concerns within the context of safeguarding at Nexus:

    • Misconduct and Non-compliance: Any inappropriate behaviour, breaches of professional conduct, or failure to adhere to safeguarding policies and legal obligations by staff, volunteers, or the institution itself.
    • Child Protection and Well-being: Concerns related to child abuse, neglect, exploitation, or risks to the physical, emotional, or psychological well-being of learners.
    • Failure to Report and Follow Up: Instances where individuals fail to report safeguarding concerns or where previously reported issues are not adequately addressed or followed up on.
    • Conflict of Interest and Institutional Negligence: Cases involving conflicts of interest among those involved in safeguarding procedures or institutional negligence leading to systemic failures in safeguarding practices.
    • Lack of Transparency and Accountability: Concerns regarding a lack of transparency, accountability, or failure to communicate outcomes of investigations or involve relevant stakeholders in decision-making processes.
    • Cultural Dynamics and External Pressures: Instances where cultural or social dynamics within the school community contribute to safeguarding risks, or external pressures compromise the school’s ability to address concerns effectively.
    • Whistleblower Protection: Protection against retaliation, victimization, or adverse actions taken against individuals who report safeguarding concerns.

Appendix 2 – Key Contact Information

Appendix 4 – School Photography and Videography Opt-Out Form

This form is for parents to submit a request to opt-out of the consent to allow the use of
their child’s photo/video/image for the purpose of external marketing. Send this form to affected parents before the photo/video/image is used.

School Photography and Videography Opt-Out Form

(Complete and return this form to Nexus Marke;ng department ONLY if you do NOT give permission
for your child’s photo/video to appear in possible school publicity images)

Name:
Date:
Learner ID Number:

INFORMATION

I acknowledge acceptance of <School> (herein referred as “the School” or “<insert school acronym”)
policy in regard to the use of photographs, images, recordings, works or derivative works of my child
as stated in the Application for Admission under the section “Terms and Conditions Governing
Enrolment and Admission” which states that:

The School may and the parent/guardian hereby gives his/her consent to the School to take such
photographs, images, recordings, works or deriva;ve works of the child and to use, free of charge, such
photographs, images, recordings, works or deriva;ve works in any media and for whatever purpose as
the School shall deem fit, including without limitation for any promotional materials, including website of the School.

However, I hereby would like to opt-out of the use of photographs, video footage and/or audio for use
by the School for external marketing and promotional purposes across both online and offline
channels.

“External marketing” in this form refers to:
●  Advertising campaigns
●  Advertorials
●  Editorials
●  Official <insert school> social media channels
●  Local and international press

I understand this election above shall remain in effect from the date the returned signed opt-out form
is received by <insert school> for the remainder of my child’s time attending the School, or unless
otherwise stated in conjunction with policy change(s).

I further agree and acknowledge that <insert school> may gather, store and use photographs, images,
recordings, works or derivative works of my child in any of the school’s print or digital publications and
collaterals, such as the newsletters, brochures, leaflets, annual reviews, websites and exhibition
booths.

I also acknowledge that if my child participates in public events (such as sporting events or drama
production open to the community), the school may have little or no control over photographs taken
by media, other parents or community members attending the event.

I understand that I can decide to opt-in at any ;me in writing to the marketing department of <insert
school> at <insert email>

OPT-OUT OPTION

I,…………………………………………………………………………………………………………………………………………………… (Full name of parent/guardian) withdraw my child: …………………………………………………………………………………………………………………………………………….. (Full name of child, year and class) from the use of photographs, images, recordings, works or derivative works of my child by <insert school. for external marketing and promotional purposes across both online and offline channels.

Should I become aware of my child’s recognizable likeness in use by the School for public promo;onal
purposes, I understand that my first recourse is to no;fy the school’s marke;ng department and
request its removal.

By signing this, my child will be withdrawn immediately.

Learners 18 years of age do not require parental consent for photo use.

…………………………………
Name of parent:
Date:

David Griffiths

Principal

MA Education and Leadership (UK), PGCE (UK), BA Hons. Economics (UK)

David has almost 30 years experience in teaching and leadership. He is a facilitator and coach with the International Leadership and Management Programme (ILMP) for Middle and Senior Leaders both within and outside of Asia as well as being guest speaker at several events.

Leadership Experience:
Head of Primary, Head of Secondary Apple Distinguished Educator

Date Joined: 

September 2007