ISNS Child Protection Policy and Procedures

ISNS promotes the values of respect, integrity, compassion and responsibility and seeks to “foster wellness”. The ISNS Child Protection Policy seeks to protect the student, the family, and the ISNS community. It ensures that the right to protection and access to confidential support systems is available to all students. 

The following policy is adapted with permission from the Jakarta Intercultural School’s Child Safeguarding Policy and Procedures Handbook 2015-2016.

You can view the Chinese version here:

儿童保护政策和流程手册中文版

Duty of Care

Child abuse and neglect are of growing concern in schools throughout the world. Child abuse and neglect are violations of a child’s human rights and are obstacles to a child’s education as well as to his/her physical, emotional, and social development. The International School of Nanshan Shenzhen (ISNS) has an institutional responsibility to protect children. In this role we need to ensure that all children in our care are afforded a safe and secure environment in which to grow and develop, no matter from what cultural background they come.  As educators, we have the opportunity to observe and interact with children over time on a daily basis and are in a unique position to identify children who need help and protection.  As such, we have a professional and ethical obligation to identify children who are in need of protection and to take steps to ensure that the child and family avail themselves of the services needed to remedy any situation that constitutes child abuse or neglect. 

All faculty and staff at the International School of Nanshan Shenzhen are mandated to report their concerns about the well-being of any student. Reporting and follow up of all suspected incidences of child abuse or neglect will proceed in accordance with Standard Operating Procedures linked to this policy. Furthermore, cases of suspected child abuse or neglect may be reported to the appropriate employer, to the respective consulate in China, to the appropriate child protection agency in the home country, and/or to local authorities. 

The International School of Nanshan Shenzhen endorses the Convention on the Rights of the Child (of which our host country, China, is a signatory and seeks to be a safe haven for students who may be experiencing abuse or neglect in any aspect of their lives) as well as the Domestic Violence Law of China. The International School of Nanshan Shenzhen will distribute this policy annually to all parents and applicants, will communicate this policy annually to students, will provide annual training for all faculty and staff, and will make every effort to implement hiring practices to ensure the safety of children. In the case of a staff member reported as an alleged offender, the International School of Nanshan Shenzhen will conduct a full investigation following a carefully designed course of due process.

Definition of Child Abuse and Neglect

The International School of Nanshan Shenzhen has a rich and diverse community with multiple cultural beliefs, values, and practices. To respect the global nature of the community, for the purposes of our child safeguarding policy, we have chosen to follow the World Health Organization’s (WHO) definition of abuse and neglect. 

The WHO declares: 

“Child abuse or maltreatment constitutes all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power.” 

For the purposes of this document a CHILD is defined as being any person under the age of 18 or any person enrolled at ISNS as a full-time student, even if that person has reached his/her 18 birthday. 

A detailed explanation of the different types of child abuse and possible symptoms is given below. 

Forms of Abuse

Physical abuse 

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

Emotional abuse 

Emotional abuse is the persistent emotional maltreatment of a child such as to cause 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 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, though it may occur alone. 

Emotional Neglect is a dimension of Emotional Abuse. 

Neglect and negligent treatment 

Neglect is the persistent failure to meet a child’s basic physical, educational 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 caregiver failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. 

Sexual abuse 

Child sexual abuse is the involvement of a child in sexual activity that he or she does not fully comprehend, is unable to give informed consent to, for which the child is not developmentally prepared and cannot give consent, or that violate the laws or social taboos of society. Child sexual abuse is evidenced by this activity between a child and an adult or another child who by age or development is in a relationship of responsibility, trust or power, the activity being intended to gratify or satisfy the needs of the other person. 

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

Indicators that a child may be suffering abuse:

The following physical and emotional/behavioral indicators may suggest that a child is in need of support and potentially at risk of/or suffering from some form of abuse. They may also be an indication of something else such as bereavement or other temporary trauma. It is important to report anything seen or observed so that trained counselors can meet with the student to assess what support the student needs, whatever the reason. 

Possible Physical indicators:

• Injuries (bruises, welts, cuts, burns, bite marks, fractures, etc.) that are not consistent with the explanation offered (e.g. extensive bruising to one area) 


• Presence of several injuries (3+) that are in various stages of healing

• Repeated injuries over a period of time

• Injuries that form a shape or pattern that may look like the object used to make the injury (e.g. 
buckle, hand, iron, teeth, cigarette burns)

• Facial injuries in infants and preschool children (e.g. cuts, bruises, sores, etc.)

• Injuries not consistent with the child's age and development 


• Bald patches on child's head where hair may have been torn out

• Repeated poisonings and/or accidents

• Frequent psychosomatic complaints, headaches, nausea, abdominal pains

• Child is unwashed or hungry

• Unattended medical and dental needs 

• Ingestion of cleaning fluids, medicines, etc. 

• Consistent hunger 

• Nutritional deficiencies 

• Inappropriate dress for weather conditions 

• Poor hygiene persistent (untreated) conditions (e.g. Scabies, head lice, diaper rash, or other skin disorders) 

• Sexual drawings or language 

• Bedwetting 

• Eating problems such as overeating or anorexia 


• Self harm or mutilation, sometimes leading to suicide attempts 


• Substance or drug abuse 


• Venereal disease in a child of any age 

• Frequent urinary tract infections for young children both male and female

• Evidence of physical trauma or bleeding to the oral, genital, or anal areas

• Difficulty in walking or sitting 

• Not wanting to be alone with an individual 

• Pregnancy, especially at a young age

Possible Behavioral indicators:

• Refusing to change into PE clothes, fear of bathrooms 

• Child running away from home and not giving any specific complaint 

• Saying they have secrets they cannot tell anyone about 

• Parents are uninterested in child’s academic performance

• Suddenly having unexplained sexual knowledge, behavior, or use of language not appropriate to age level

• Unusual interpersonal relationship patterns

• Depression 

• Poor impulse control 

• Constant demand for attention and affection 

• Lack of parental participation and interest 

• Delinquency 

• Regularly displays fatigue or listlessness, falls asleep in class 

• Steals food, or begs for food from classmate(s) 


• Reports that no caregiver is at home

• Frequently absent or tardy

• Self destructive 

• Drops out of school (adolescent) 

• Takes over adult caring role (of parent)

• Lacks trust in others, unpredictable 

• Plans only for the moment 

• Runaway attempts and fear of going home

• Stilted conversation, vacant stares or frozen watchfulness, no attempt to seek comfort when hurt 

• Describes self as bad and deserving to be punished 

• Cannot recall how injuries occurred or offers an inconsistent explanation 

• Wary of adults or reluctant to go home

• May flinch if touched unexpectedly 

• Extremely aggressive or withdrawn

• Displays indiscriminate affection seeking behavior

• Abusive behavior and language in play 

• Poor sleeping patterns, fear of the dark, frequent nightmares 

• Sad, cries frequently

• Drug/alcohol misuse 

• Depression 

• Abandonment 

• Consistent lack of supervision

• Poor memory and concentration 

• Mental or emotional development lags 

• Behaviors inappropriate for age 

• Fear of failure, overly high standards, reluctance to play

• Fears consequences of actions, often leading to lying 

• Extreme withdrawal or aggressiveness, mood swings 

• Overly compliant, too well mannered 

• Excessive neatness and cleanliness 

• Extreme attention seeking behaviors 

• Poor peer relationships 

• Violence is a subject for art or writing 

• Complains of social isolation

• Forbidden contact with other children 

• Repeated communications from the school unheeded 

• Both parents or legal guardian are absent from China for any period of 24 hours or greater

• Parents cannot be reached in the case of emergency 

• Lack of appropriate supervision—this would include failure to provide proper adult guardianship* 
such as leaving children unsupervised at home for any extended period of time.


*Note: ISNS policy requires that one parent be a full time resident in China. Should parents/ guardian leave the country for any reason, the responsibility for informing the school of all appropriate contact details lies with the parent or guardian. Temporary Change of Guardian Forms are available from ISNS. These forms are expected to be completed prior to parents/guardians leaving the country. ISNS defines Caretaker as follows: An adult designated to make any and all legal, financial, social and medical decisions for the child in the parent’s or guardian’s absence. 

Physical Touch Guidelines

A strong part of the ISNS culture is the warmth and openness of relationships between staff and students. ISNS believes that this should be preserved while ensuring that all students remain safe and comfortable while at school.

In general, it is not appropriate for teachers and staff to have physical contact of any kind with a student who is above the age of eight or nine.  There are occasions when it is entirely appropriate and proper for staff to have physical contact with pupils, but it is crucial that they only do so in ways appropriate to their professional role and with the permission of the child. 

When physical contact is made with pupils this should be in response to their needs at the time, of limited duration, and appropriate given their age, stage of development, gender, ethnicity and background. Appropriate physical contact in schools may occur most often with younger pupils and should not happen out of public view.

It is not possible to be specific about the appropriateness of each physical contact, since an action that is appropriate with one child in one set of circumstances may be inappropriate in another, or with a different child. Staff should therefore limit their physical contact in most instances.

Physical contact should never be secretive, for the gratification of the adult, of a sexual nature, or represent a misuse of authority.

If a member of staff believes that an action could be misinterpreted, the incident and circumstances should be reported and documented.

This means that adults should:

•       Always approve any planned social contact with senior colleagues, for example when it is part of a reward scheme or pastoral care program

•       Advise administration of any regular social contact they have with a pupil which may give rise to concern

•       Report and record any situation which they feel might compromise the school or their own professional standing

•       Report any indications (verbal, written or physical) that suggest a pupil may be infatuated with a member of staff

•       Be aware that even well-intentioned physical contact may be misconstrued by the child, an observer, or anyone to whom this action is described

•       Never touch a child in a way which may be considered indecent

•       Always be prepared to explain actions and accept that all physical contact be open to scrutiny

•       Never indulge in horseplay, tickling, or fun fights

Physical contact which occurs regularly with an individual child or young person is likely to raise questions unless the justification for this is part of a formally agreed plan (for example in relation to pupils with SEN or physical disabilities). Any such contact should be the subject of an agreed and open school policy and subject to review. Where feasible, staff should seek the child's permission before initiating contact. Staff should listen, observe, and take note of the child's reaction or feelings and – so far as is possible - use a level of contact which is acceptable to the child for the minimum time necessary. 


Extra caution may be required where it is known that a child has suffered previous abuse or neglect. In the child's view, physical contact might be associated with such experiences and lead to staff being vulnerable to allegations of abuse. It is recognized that many such children are extremely needy and seek out inappropriate physical contact. In such circumstances staff should deter the child sensitively by helping them to understand the importance of personal boundaries.

Overall, the general rule of 'no or limited touch' should be followed in most instances.

Physical Contact Between Students

Teachers should educate, monitor and provide adequate supervision of students so that physical contact between students is always appropriate and not of an abusive, violent or sexual nature.

Hitting, kicking, pinching, fighting and other violent physical contact should be stopped immediately by any adult who witnesses it happen.  Adults should intervene in such cases in a non-physical manner if possible by verbally asking the students to stop the violent contact.  If physical intervention is required in order to stop violent contact between students, it should be done in with as much care as possible so as not to injure or harm the students.  Standing between the two students as a barrier to prevent them from having contact with one another is likely to be the most effective means of prevention.  Students should not be physically restrained by an adult unless that is the only option available to prevent serious harm from happening.  Students who engage in violent physical contact should be referred to the principal for follow up intervention.  A written record of any incidents of physical violence on the part of students must be kept.

Ordinary contact between students during play or athletics is acceptable.

Public displays of affection between students beyond a friendly hug are discouraged on campus.  Any display of affection should be age-appropriate.  Students should be educated and encouraged to conduct themselves in a professional manner in the school setting in order to prepare them for later professional working environments.  Students should understand that public displays of intimate affection are not appropriate in a professional environment.

Standard Operating Procedures (SOP)

There are three main elements to our child safeguarding policy and procedures:

•       Prevention through the creation of a positive school atmosphere and the     teaching and pastoral support offered to students. 


•       Protection by following agreed procedures, ensuring all staff are trained and supported to respond appropriately and sensitively to child safeguarding concerns.

•       Support for students who may have been abused.

Organizational Framework

Child Protection is the responsibility of all adults in the school, but especially those working directly with students.  All adults have a “Duty of Care” responsibility to report concerns to the Senior Leadership Team (Head of School and Principals). Additionally, there are key people within the school organization who have specific responsibilities to assess and evaluate those concerns in accordance with child safeguarding procedures. These people are designated as the ISNS Child Protection Team.

The ISNS Child Protection Team will be comprised of the Head of School, the division Principals, the Counsellors and designated Child Protection Officers.  The names of the Child Protection Team for the current year are listed in Annex 1, “Key Contacts” of this policy.

The role of the Head of School is to review all cases referred to him/her, to consult with the Child Protection Team, and to ensure that adequate resources and support are provided in order to respond and deal with all cases in an appropriate and effective manner. 

The development of appropriate procedures and the monitoring of good practice are the responsibilities of the Counselling Team and the Senior Leadership Team.  Improving policies or practices based on lessons learned from specific incidents should occur as needed.  It is the role of the Senior Leadership Team and Counsellors to ensure that all staff employed, including temporary staff and volunteers within the school, are aware of the school’s child protection policies and procedures, and to advise staff as to how these policies and procedures should be implemented. The Senior Leadership Team is responsible for ensuring that child protection policies and procedures are followed within the school.

All incidents of suspected abuse, neglect or misconduct which appear to violate child safety and well-being must be reported to a member of the Senior Leadership Team.  If for some reason none of the Senior Leadership Team members are available, the Counsellors and designated Child Protection Officers are authorized to act in their absence.  

On an annual basis, the Senior Leadership Team and Counsellors are responsible for:

·  Reviewing the Child Protection Policy and Procedures Manual

·  Training staff on the Child Protection Policy and Procedures.

·  Reviewing the number and nature of concerns or incidents logged across the school with the goal of preventing future incidents.

The Child Protection Team’s ultimate aim is to ensure that every child’s interests are protected.

Safe Environment

The ISNS campus is a fenced and gated area that is protected by 24-hour security personnel.

All visitors to the campus must present an acceptable form of identification at the guard station and receive a visitor’s badge before being granted permission to enter.

Students in the primary school (K3-Grade 5) are not permitted to leave campus at the end of the day without a parent or guardian being present.  If they ride the bus, they are required to have a parent or guardian present at the drop-off site.

Any student who leaves campus during the school day must have prior parent permission.

Students are only permitted to enter and exit through the main gate.

All classrooms, offices, and venues where students are permitted to enter must have a clear line of sight into them at all times.  Teachers and staff are not permitted to obstruct the view into their classroom or office.

All areas of the school are under surveillance by CCTV cameras which are recording 24 hours per day.  Video recordings are stored on a secure server for 90 days.  Restrooms do not have CCTV cameras in them but have cameras covering the entrance way so that a record of entries and exits can be kept.

Separate bathrooms are designated on campus for students and for adults.  If it is necessary for an adult to enter a students’ restroom, they must do so with at least one other adult present.  Students are not permitted to enter the adult restrooms at any time.  Cleaning of student restrooms must be completed when students are not present.

All teachers must keep a record of when students leave their classroom to use the restroom or go on an errand outside of the room.  To reduce the number of students who may come into contact with one another, no more than one student is permitted to leave the classroom at a time to use the restroom.

Adults should never be alone with a student in an area that is not fully visible to others.

A supervision schedule is in place so that all areas are adequately supervised while students are on campus.

Safe Recruitment

It is the school’s responsibility to ensure, as far as is practicable, that its employees are suitable people to work with children. ISNS has implemented a number of checks during its recruitment process with the aim of ensuring that:

• Candidates with a tendency towards child molestation are deterred from applying to the school.

• Candidates who have a criminal record or about whom there have been some concerns regarding their suitability to work with children are not offered a position.

• Successful candidates fully understand their responsibilities towards Child Protection while employed at the school.

• ISNS maintains appropriate records that might be required in a possible future investigation or inquiry.

• ISNS will work with the Recruitment Agencies (ISS, Search Associates, etc.) to ensure that the reference checks and background screening undertaken by such agencies complements ISNS’s own recruitment protocols.

• Additional background checks will be carried out for all staff if there are concerns about the reliability of any police background check certificates.

Employment Records 


The following records will be maintained by ISNS in respect to every employee, either in hard copy or digital format. 


·      Full CV (any gaps in employment accounted for)

·      Signed statement of suitability by the candidate

·      Three signed verified letters of reference that cover at minimum the last two years of employment

·      A confidential phone or e-mail reference check from the most recent immediate supervisor

·      Police criminal background check report from home of record and/or most recent place of residence and employment

·      Additional background checks, including a social media search and sex offender registry report (if a need arises to obtain such documents)

·      Medical report

·      Certified copies of degrees and education certificates

·      Signed “Acknowledgement of Child Protection Code of Conduct”

·      Record of attendance for Child Protection Training.

ISNS’s Safe Recruitment Protocols are summarized below. 

Application:  Candidates must provide a copy of their resume and references.

Interview: At least one member of the interview process will have been trained in the Safe Recruitment protocols stated in this policy and will be tasked with asking candidates about their child safeguarding experiences.

Screening: Job offer will be made conditional on: Satisfactory references from at least three previous supervisors or appropriate professionals, a full medical screening, a police criminal record certificate from home of record and/or most recent place of residence, a signed statement of suitability from the candidate indicating that they do not have a criminal record and are fully suitable to work with children.

Contractual:  Employees are required to undergo a Child Protection training as part of their orientation and every year thereafter.  They must sign an acknowledgement that they have read the Child Protection Policy and will abide by the Code of Conduct.

HR Records: ISNS will maintain records to ensure compliance in respect of the above for every employee.

The Head of School, Principals, HR Team and any others involved in recruiting will review these “safe recruitment” practices on an annual basis.

ISNS’s Statement of Suitability is given in Annex 4.

Training

All adults who are regularly on ISNS’s campus will be expected to undergo appropriate training on a regular basis depending on their level of engagement with students and their roles with regard to Child Protection. Initial training will be delivered in-house, normally during the orientation process. Thereafter, staff will be expected to undergo a refresher training every year.  A record of training that has taken place will be filed with the HR department.  When possible, training will also be given to parents, volunteers and coaches who regularly interact with students on campus.

These groups will be trained in the elements of the Child Protection policy listed:


All Adults who are regularly on campus will be trained regarding:

·      General Duty of Care

·      ISNS Child Protection Policies and Procedures

·      Code of Conduct

·      Procedure for Reporting Concerns

Teaching Faculty will be trained in the areas listed above and:

·      Understanding Child Safeguarding

·      Types and symptoms of abuse

·      How to handle disclosures

Counsellors and others with designated roles will be trained in the areas listed above and:

·      Serious case reviews

·      Information on sharing and documentation

·      Framework for assessment

·      Specific types of abuse

·      Working with students and families

·      How to follow up with a reported concern

·      When to make referrals

Students will be trained through delivery of the counselling curriculum.

ISNS has adopted age-appropriate curriculum developed and implemented by the Guidance Counselling Department for each division: Lower PYP (K4 to Grade 2), Upper PYP (Grades 3 to 5), MYP (Grades 6 to 9), DP (Grades 10 to 12).  This curriculum is based on empowering students with three ways to protect themselves:

o   Recognize unsafe behavior

o   Report by telling a trusted adult

o   Refuse by learning how to say “No”

Child Protection Code of Conduct

ISNS is committed to the safety and protection of children. This Code of Conduct applies to all faculty, staff, employees, volunteers, and students who represent the school and who interact with children or young people in both a direct and/or unsupervised capacity.

The public and private conduct of faculty, staff, employees, students, and volunteers acting on behalf of ISNS can inspire and motivate those with whom they interact, or can cause great harm if inappropriate. We must, at all times, be aware of the responsibilities that accompany our work.

We should be aware of our own and other persons’ vulnerability, especially when working alone with children, and be particularly aware that we are responsible for maintaining physical, emotional, and sexual boundaries in such interactions. We must avoid any covert or overt sexual behaviors with those for whom we have responsibility. This includes seductive speech or gestures as well as physical contact that exploits, abuses, or harasses. We are to provide safe environments for children at ISNS.

We must show prudent discretion before touching another person, especially children, and be aware of how physical touch will be perceived or received, and whether it would be an appropriate expression of greeting, care, concern, or celebration. ISNS personnel and volunteers are prohibited at all times from physically disciplining a child.  Teachers who have children are also expected to refrain from physical forms of discipline at home in order set a positive example for the community.  Spanking and other forms of physical discipline can easily be misconstrued or seen as a form of abuse when children talk with one another.

Physical contact with children can be misconstrued both by the recipient and by those who observe it, and should occur only when completely nonsexual and otherwise appropriate, and never in private. One-on-one meetings with a child or young person are best held in a public area; in a room where the interaction can be (or is being) observed (classrooms are covered by CCTV); or in a room with the door left open and another staff member or supervisor is notified about the meeting.

On occasion, an adult may need to assist a young child who needs help with dressing, etc. This should be treated normally, with the child’s permission. If the adult feels that the circumstances or child’s response were unusual, then this should be reported using a Record of Concern so that the incident is logged in case it is referred to later.

We must intervene when there is evidence of, or there is reasonable cause to suspect, that children are being abused in any way. Suspected abuse, neglect, or observed inappropriate behavior by another person towards a child must be reported as described in the Child Protection Policy of the school.  If an employee is observed to be acting inappropriately towards, or in the presence of, a student, then this must be reported to the Senior Leadership Team and will be dealt with confidentially according to due process.

Faculty, staff, employees, and volunteers should refrain from the illegal possession and/or illegal use of drugs and/or alcohol at all times, and from the use of tobacco products, alcohol and/or drugs when working with children. Adults should never buy alcohol, drugs, cigarettes, videos, or reading material that is inappropriate and give it to young people. Staff members and volunteers should not accept gifts from, or give gifts to, children without the knowledge of their parents or guardians.

Communication with children is governed by the key safety concept of transparency. The following steps will reduce the risk of private or otherwise inappropriate communication between ISNS parents, administration, teachers, personnel, volunteers, and minors:

Communication between ISNS (including volunteers) and minors that is outside the role of the professional or volunteer relationship (teacher, coach, host, etc.) is prohibited.

Where possible, email exchanges between a minor and a person acting on behalf of the school are to be made using a school email address. Electronic communication that takes place over a school network or platform may be subject to periodic monitoring.

Faculty, staff, and volunteers who use any form of online communications including social media (Facebook, WeChat, etc.) and text messaging to communicate with minors may only do so for activities involving school business.

Every employee will be expected to sign an Acknowledgement of the Code of Conduct with each contract renewal. A copy of the Code of Conduct and form are given in Annex 5.

Reporting Concerns

“Doing nothing is not an option.”

All adults have a duty to act if they have a concern about a child’s welfare. Abuse can take many forms. Frequently both victims and perpetrators work hard to conceal that abuse is taking place. A concern may just be a “gut reaction” to something heard or observed which doesn’t feel right. It may be more specific by way of a witnessed event or disclosure.

Concerns or alerts may be as a result of: 


a.    Observed student behavior (physical, emotional, change in behavior) 


b.    Hearsay (third party disclosure) 


c.     Disclosure (specific report made by a student directly or via a trusted adult) 


d.    Observed adult behavior (breach of Code of Conduct)

Whatever the nature of the concern, adults will be expected to:

2.    Recognize the concern. 


3.    Make a written report by completing a Record of Concern Form, Annex 6 which can be downloaded from the ISNS shared drive. 


4.    Pass on their concern to a Senior Leadership Team member within 24 hours.

5.    If the concern comes from a specific disclosure by a student, it must be reported before the close of the school day. 


Certain students may be the subject of discussion at team meetings. If the consensus of the team is that there is evidence that some of a child’s learning or behavioral issues may be due to some form of abuse, then a Record of Concern should be completed and submitted to the Principal responsible for that student at the conclusion of the meeting. 


Hierarchy of Reporting 


Under normal circumstances, a Record of Concern should be given to the Principal from the same division as the student about whom there is a concern.  The Principal is responsible to communicate the concern to the Head of School at an appropriate time.  Under certain circumstances, however, the report must be made to a person with the appropriate level of authority as follows: 


1.    If the Concern involves a member of the faculty or host country staff, the Report of Concern should be made to the Head of School since this may become a disciplinary matter. Unless it is absolutely necessary to reveal the identity of the person making a report about another member of staff, the identity of the reporting individual will remain confidential.

2.    If the Concern involves a visiting student (Community Sports or Service programs etc.), then the Report of Concern should go immediately to the Head of School.

3.    If the Concern involves a contractor, then the Report of Concern must be made to the Director of Operations and Finance and the Head of School.

4.    If the Concern involves the Head of School then the report should be made to the Executive Director of the school.

Handling a Disclosure

Any adult to whom a student makes a disclosure must:

Listen carefully to what is said.

Avoid interrupting or prompting. Let the child tell the story in his/her own words.

Use TED questions:

TELL me what happened

EXPLAIN what happened

DESCRIBE what happened

Reassure the child that they are right to speak up. Be calm, attentive, non-judgmental – don’t show any emotion other than sympathy.

Confidentiality – Make it clear that this cannot be kept a secret and that you have a duty to report it to a Principal or Counsellor who is properly trained to help students in this situation.

Question the child only if necessary to clarify something that is unclear such as when and where. Do not ask leading questions.

Action – Contact the child’s Counselor and complete a Report of Concern form (ROC) before you leave school that day.

Write it down – Use the child’s words as far as possible and record anything else that concerned you.

Handling Concerns

The individual who has noticed the concern or to whom the concern has been disclosed should submit a Report of Concern to the relevant Principal.  The Principal may discuss the Report with other members of the Child Protection Team to see if there is reasonable cause to be concerned.  If there appears to be reasonable cause to be concerned, relevant members the Child Protection Team, usually led by the Counsellor who normally works with the student, will undertake an initial assessment to establish whether the student is in need of support.

In order to make an initial assessment, it may be necessary to collect additional information:

·      If there is missing information (date, time, location etc.), go back to the original reporter and see if he/she has anything more to add to their report.

·      If the incident happened on campus, review any CCTV footage and make sure that any relevant footage is stored separately in a safe location since CCTV data is only stored for 30 days. (Head of School will assist with this).


·      If there are possible signs of physical abuse, a physical exam should be made and photographs taken (if the child permits).   A medical record of the examination should be kept by the Nurse’s Office. 


·      If there were other witnesses to an incident, these witnesses should also be asked to make written statements. 


·      Obtain the student’s attendance records and academic records to see whether there are changes in patterns, if appropriate. 


·      Search the database to see if there have been any other Reports of Concern made about the possible victim, his/her family, or the alleged perpetrator. 

·      Talk with teachers who interact with the student on a regular basis. 


·      If the incident suggests that a member of staff, coach or contractor is involved, the Head of School should be alerted. Any disciplinary matters relating to a breach in the Code of Conduct will be dealt with by the Senior Leadership Team. 


Based on the data collected, the Child Protection Team will make an assessment as to the level of risk to the child’s well-being and agree on a strategy for working with the student and family. Most cases will be “low level” in terms of providing early intervention and giving a student and/or family counselling support.

If the child appears to be “at risk” i.e having suffered significant abuse that threatens his/her long-term well-being (i.e. a situation that cannot be resolved by parental / student education or intervention), then the Principal and Head of School must be informed of this fact.

It may be necessary to bring in outside agencies such as:

·      External investigator if there is a possible criminal act.

·      The Employer or Embassy if the alleged offender is a parent of a student. 


·      Appropriate Chinese authorities or other child protection agencies.

ISNS will maintain and regularly review a database of external agencies and other resources that can be called upon to provide additional resources and/or assistance where necessary. Such agencies may include SACAC, Child-Safe, and the Jane Group as well as individual therapists and counselors. ISNS will ensure that such agencies are able to provide support and are fully briefed annually, in case they need to be called upon. This will be the responsibility of the Child Protection Team.

The decision to involve outside agencies will be taken by the Head of School in consultation with the Child Protection Team and others as appropriate. Depending on the nature of the incident, the Crisis Management Protocol will be initiated.

The school will also endeavor to ensure that those staff involved with a case of child abuse receive appropriate counseling and support themselves so that they are able to maintain a highly professional standard of care without undue personal stress.

Record Keeping

Record keeping is essential to the gathering of information, and detailed notes must be kept of all meetings relating to a Child Protection issue.

The Incident Reporting System in ManageBac will be used to maintain a log of key events, meetings, documents, and final conclusion as a historical record of each case. The detailed, confidential case files relating to the incident will be maintained by the Counsellor assigned to the specific case. Separate guidelines will be developed on what and how evidence should be collected and/or preserved at the time that a concern is reported in case of a subsequent investigation.

Completed case files, with all original documentary evidence, must be sent to the Counsellor, who will ensure these files are maintained for the school for up to ten years after the student graduates.

Feedback

Each person who reports a concern should expect to receive feedback from the Principal or Head of School that the concern has been dealt with, although specific details as to the outcome will not necessarily be shared. If there is no feedback, and there is on-going cause for concern, then the reporter should follow-up to make sure that action is being taken.

Confidentiality

Confidentiality is an issue which needs to be discussed and fully understood by all those working with students, particularly in the context of child safeguarding. The only purpose of confidentiality in this respect is to benefit the student. A member of staff must never guarantee confidentiality to a student nor should they agree with a student to keep a secret, as where there is a child safeguarding concern this must be reported to a member of the Senior Leadership Team and may require further investigation in line with school procedure. Other staff will be informed of relevant information with respect to individual cases regarding child safeguarding on a “need to know” basis only. Any information shared with a member of staff in this way must be held confidentially to themselves.

In cases where a Report of Concern involves the disclosure of a Breach in the Code of Conduct observed by a colleague, reports must be made direct to the Head of School and confidentiality as to the source of the report will be preserved as far as feasible. The Report of Concern will be filed in a confidential file in the HR Department.

Partnering with Parents

All parents are required to commit to ISNS’s Child Wellness Covenant in Annex 7 on admission to ISNS. In particular, parents are required to inform the school if they are going to be absent from town and who will be the designated caregiver in their absence. Other information and training sessions will be provided periodically.

Use of ISNS Facilities by Community Groups

ISNS will endeavor to ensure that all Community groups who use our facilities outside of normal school hours understand ISNS’s Child Protection Policies and Procedures.  Coaches and other adults who interact regularly with ISNS students must sign the Code of Conduct acknowledgement indicating that they have received and read a copy of the Child Protection Policy.

Communications

Posters will be used to provide a summary of key aspects of ISNS’s Child Protection procedures for both adults and children and will be prominently displayed in classrooms and offices. The Child Protection Handbook will be available on the ISNS Faculty OneDrive and will be included in the online Faculty and Parent-Student Handbooks.

Policy Review

This policy will be reviewed on an annual basis by the ISNS Child Protection Team.

         Annex 1:  Designated Child Protection Team for 2020-2021

Annex 2 - United Nations Convention on the Rights of the Child

The UN Convention on the Rights of the Child includes 54 articles to which governments are expected to be signatories.   UN Convention on the Rights of the Child

The principle articles relevant to ISNS, include:

Article 3: The best interests of the child must be a top priority in all decisions and actions that affect children.

Article 12: Every child has the right to express their views, feelings and wishes in all matters affecting them, and to have their views considered and taken seriously.

Article 19: [Governments] must do all they can to ensure that children are protected from all forms of violence, abuse, neglect and bad treatment by their parents or anyone else who looks after them.

Article 39: Children who have experienced neglect, abuse, exploitation, torture or who are victims of war must receive special support to help them recover their health, dignity, self-respect and social life.

Annex 3 – The Domestic Violence Law of China 2015

Chapter I: General Provisions

Article 1: This law is formulated so as to prevent and stop domestic violence; to protect the lawful rights and interests of family members; to preserve equal, tranquil, and civilized family relationships; and to promote family harmony and social stability.

Article 2: Domestic violence as used in this Law refers to physical, psychological or other infractions between family members effected through the use of methods such as beatings, restraints, maiming, restrictions on physical liberty as well as recurrent verbal abuse or intimidation.

Article 3: Family members shall help each other, love each other, live in harmony, and perform familial obligations.

Countering domestic violence is the joint responsibility of the State, society, and every family. The State prohibits domestic violence in any form.

Article 4: People's government institutions at the county level or above with responsibility for efforts on women and children, are responsible for organizing, coordinating, guiding, supervising and driving relevant departments' efforts to counter domestic violence.

Relevant departments of people's governments at the county level or above, judicial organs, people's organizations, social organizations, residents' committees, villagers' committee, enterprises and public institutions, shall work to counter domestic violence in accordance with this law and relevant laws and regulations.

All levels of people's government shall ensure necessary funding for efforts to counter domestic violence.

Article 5: Efforts to counter domestic violence follow the principles of putting prevention first and combining education, corrections and punishment.

Efforts to counter domestic violence shall respect victims' true wishes and protect parties' privacy.

Minors, the elderly, persons with disabilities, and persons with serious illnesses who sustain domestic violence infractions shall be given special protections.

Chapter II: Prevention of Domestic Violence

Article 6: The State initiates publicity and education on family values, popularizing knowledge on combatting domestic violence and strengthening awareness of domestic violence.

Labor unions, the Communist Youth League, women's federations, and the Disabled Persons Federations shall each organize the initiation of publicity and education on family values and countering domestic violence, within the scope of their work.

Radio, television, newspapers, online networks and so forth shall initiate publicity on family values and countering domestic violence.

Schools and kindergartens shall initiate publicity on family values and countering domestic violence.

Article 7: Relevant departments of people's governments at the county level or above, judicial organs, and women’s federations shall include efforts to prevent and stop domestic violence in their operations training and statistics.

Medical establishments shall do a good job of recording treatment of victims of domestic violence.

Article 8: Township people's governments and neighborhood offices shall organize and develop efforts to prevent domestic violence, and residents' committees, villagers' committee and social work service organizations shall coordinate and assist them.

Article 9: All levels of people's government shall support social work service organizations in developing services such as mental health consultation, family relationship guidance, and education on prevention of domestic violence.

Article 10: People's mediation organizations shall mediate family disputes in accordance with law, to prevent and reduce the incidence of domestic violence.

Article 11: Employment units discovering that their personnel have domestic violence situations shall give criticism and education and do a good job of efforts to mediate or resolve family conflicts.

Article 12: Guardians of minors shall carry out family education and lawfully perform guardianship and educational duties in a civilized fashion, and must not commit domestic violence.

Chapter III: Disposition of Domestic Violence

Article 13: Victims of domestic violence, their legal representatives and close family may make a complaint, give feedback or seek aid from the perpetrator's or victim's unit, residents' committee and villagers' committee, women’s federation or other relevant unit. After relevant units receive a complaint of domestic violence, feedback or a request for aid, they shall give help and disposition.

Victims of domestic violence and their legal representatives or close relatives may also report cases to the public security organs, or raise a lawsuit in the people's courts.

Units or individuals discovering acts of domestic violence have the right to promptly discourage it.

Article 14: Where schools, kindergartens, medical establishments, residents' committees, villagers' committees, social work service organizations, relief management organizations, welfare organizations or their employees discover in the course of their work that a person lacking civil capacity or with limited civil capacity has suffered domestic violence or might have suffered domestic violence; they shall promptly report it to a public security organ. Public security organs shall preserve the confidentiality of those making reports.

Article 15: After public security organs receive a report of domestic violence, they shall promptly dispatch police, stop the domestic violence, and follow the relevant provisions in investigating and gathering evidence, assisting victims in receiving medical care, and evaluating injuries.

Where persons lacking civil capacity or having limited civil capacity are seriously physically injured or face a threat to their physical safety due to domestic violence, or are in dangerous situation such as having nobody looking after them, the public security organs shall notify and assist the civil affairs departments in having them placed in a temporary shelter, aid management organization or welfare organization.

Article 16: Where the circumstances of domestic violence are lighter and public security administrative sanctions are not given in accordance with law, the public security organs give the perpetrator criticism and education or issue a written warning.

Written warnings shall include content such as the identity of the perpetrator, a statement of facts on the domestic violence incident, and a prohibition against the perpetrator continuing to commit domestic violence.

Article 17: Public security organs shall send the written warning to the perpetrator and victims, and inform residents' committees and villagers' committees.

Residents' committees, villagers' committees and public security police substations shall make inspection visits of perpetrators and victims that have received written warnings, and oversee that the perpetrator does not commit further domestic violence.

Article 18: People's governments at the county level or districted-city level may, either independently or by retaining an aid management organization, establish residential shelters to provide temporary residential assistance to victims of domestic violence.

Article 19: Legal aid organizations shall provide legal aid to victims of domestic violence in accordance with law.

People's courts shall delay, reduce, or waive litigation fees for victims of domestic violence in accordance with law.

Article 20: People's courts trying cases involving domestic violence may verify facts of domestic violence on the basis of evidence such as public security organs' dispatch records, written warnings, and injury evaluation opinions.

Article 21: Where guardians commit domestic violence and seriously encroach their wards' lawful rights and interests, the people's courts may revoke guardianship credentials in accordance with law and separately appoint another guardian on the basis of an application by relevant persons or units such as the wards' close relatives, residents' committees, villagers' committees, or civil affairs departments of county level people's governments.

Perpetrators who have their guardianship qualifications revoked shall continue to bear the costs of maintenance, support, or custody for their wards.

Article 22: Labor unions, the Communist Youth League, women's federations, the Disabled Persons Federations, residents' committees, villagers' committees and so forth, shall conduct legal education of perpetrators of domestic violence, and when necessary may conduct psychological counseling of the perpetrators and victims.

Chapter IV: Personal Safety Protection Orders

Article 23: Where parties apply to people's courts for a personal safety protection order because they have suffered domestic violence or face an actual threat of domestic violence, people's courts shall accept it.

Where parties are persons with limited or no civil capacity, or are unable to apply for a personal safety protection order due to coercion or intimidation, their close relatives, public security organs, women’s federations, residents' committees, villagers' committees, or aid management organizations may apply on their behalf.

Article 24: Applications for personal safety protection orders shall be submitted in writing; where there is truly a difficulty in applying in writing, the application may be oral and the people's courts will enter it in the record.

Article 25: The basic level people's courts for the residence of the applicant, the residence of the subject of the application, or the location where domestic violence occurred have jurisdiction over personal safety protection order cases.

Article 26: Personal safety protection orders are issued by the people's courts as a ruling.

Article 27: The following conditions shall be met to make a personal safety protection order:

(1) Have a clear subject of the application;

(2) Have a specific request;

(3) have circumstances of having suffered domestic violence or facing an actual threat of domestic violence.

Article 28: After people's courts accept an application, they shall make a personal safety protection order within 72 hours, or reject the application; where the situation is urgent, it shall be made within 24 hours.

Article 29: Personal safety protection orders may include the following measures:

(1) Prohibiting the subject of the application from perpetrating domestic violence;

(2) Prohibiting the subject of the application from harassing, following, or having contact with the applicant or their close family;

(3) ordering the subject of the application to move out of the applicant's residence;

(4) Other measures for the protection of the applicant’s personal safety.

Article 30: The validity period for personal safety protection orders does not exceed six months, and they take effect on the date they are made. Prior to the expiration of a personal safety protection order, people's courts may withdraw, modify or extend it on the basis of an applicant’s applications.

Article 31: Where applicants are dissatisfied with the rejection of an application or where the subject of an application is dissatisfied with the personal safety protection order, they may apply to the people's court making the ruling for a single reconsideration within 5 days of the ruling taking effect. The enforcement of personal safety protection orders made by a people's court in accordance with law is not stopped during the period for reconsideration.

Article 32: After people's courts issue personal safety protection orders, they shall be served on the applicant and subject of the application, the public security organs, as well as residents ' and villagers ' committees and other relevant organizations. Personal safety protection orders are enforced by the people's courts; public security organs as well as residents' and villagers' committees shall assist in enforcement.

Chapter V: Legal Responsibility

Article 33: Where perpetrators commit domestic violence, conduct that constitutes a violation of public security management shall be given public security punishments according to the law. Where a crime is constituted, criminal responsibility shall be pursued in accordance with law.

Article 34: Where the subject of an application's violation of a personal safety protection order constitutes a crime, pursue criminal responsibility in accordance with law; where it does not constitute a crime, the people's courts shall give reprimands and may, on the basis of the severity, give a fine of up to 1000 yuan and detention of up to 15 days.

Article 35: Where schools, kindergartens, medical establishments, residents' committees, villagers' committees, social work service organizations, relief management organizations, welfare organizations or their employees do not follow article 14 of this law in making a report to the public security organs, causing serious consequences, the directly responsible management personnel and other directly responsible personnel are sanctioned by the competent administrative department at the level above or by that unit.

Article 36: Where state personnel who have anti-Domestic Violence duties derelict their duty, abuse their authority, or play favorites, they shall be punished in accordance with law; where it constitutes a crime, they shall be pursued for criminal responsibility in accordance with law.

Chapter VI: Supplementary Provisions

Article 37: Where persons living together other than family members commit acts of violence against each other, proceed with reference to this law.

Article 38: This law shall enter into force on March 1, 2016.

Source of text: http://news.xinhuanet.com/legal/2015-12/27/c_128571791.htm

Annex 4: Statement of Suitability

Annex 4: Statement of Suitability

Annex 5: Acknowledgment of Child Protection Policy and Code of Conduct (To be signed annually as part of the annual contract renewal process)

Annex 5: Acknowledgment of Child Protection Policy and Code of Conduct

Annex 6:  Report of Concern Form

Annex 6: Report of Concern Form

Annex 7: Child Wellness Covenant

Annex 7: Child Wellness Covenant

Annex 8: Additional Resources

Chinese Domestic Violence Law March 2015

http://news.xinhuanet.com/legal/2015-12/27/c_128571791.htm

Guidance for Safe Working Practice for the Protection of Children and Staff in Education Settings Published by The National Network of Investigation and Referral Support Coordinators

Talk About Touching Curriculum Scope and Sequence Committee for Children

UN Convention on the Rights of the Child

http://www.ohchr.org/en/professionalinterest/pages/crc.aspx

Canadian Department of Justice

https://www.justice.gc.ca/eng/rp-pr/cj-jp/fv-vf/mcb-cce/index.html