Child Protection Programme
CIS believes that every child has the right to grow up in a healthy, safe, secure and supportive environment.
The school endorses the United Nations Convention on the Rights of the Child (UNCRC) to which Hong Kong is a signatory, and seeks to be a positive learning community that promotes well being, free from hazards and harm. The school adopts a strict zero tolerance policy towards the mistreatment or abuse of children.
Mindful of the special role that schools play as protectors of children, and in light of growing awareness of the harm that can be caused by child abuse, CIS runs a comprehensive programme of Child Protection overseen by school leaders and two designated members of the Board of Governors.
Details are outlined in a school-wide Child Protection Policy (see below) that encompasses:
- rigorous recruiting and vetting practices applicable to direct hires, contract staff, and all affiliated personnel, including volunteers,
- a Code of Conduct (see Policy below) signed by all personnel (as above),
- a Code of Conduct for visitors (see Visitors Do's & Dont's below),
- regular training for all personnel, as well as students and parents,
- dedicated Child Protection Officers and other responders,
- and clear protocols for reporting and enquiring into matters of concern.
For enquiries about Child Protection at CIS, please write to firstname.lastname@example.org
For relevant staff for Hangzhou CIS, please see the Hangzhou Faculty page.
- Expectations for All Staff & Volunteers
- Expectations for Parents, Guardians & Caregivers
- Expectations for Visitors
- Expectations for Students
- Key Roles, Responsibilities & Training
- Definitions & Indicators of Abuse
- Reporting of Incidents, Concerns & Follow-Up Procedures
- APPENDIX I: Staff & Volunteer Code of Conduct (HK & HZ)
- APPENDIX II: Visitor Code of Conduct (HK & HZ)
- APPENDIX III: Hangzhou CIS Visitor Policy
- Appendix IV: Visitor Do's & Don'ts (HK & HZ)
- Appendix V: Peer Abuse Policy
- Appendix VI: CIS DISCLOSURE POLICY
- Appendix VII: Procedures for Managing Child Protection Allegations Made Against A Member of the CIS Staff or Community (including service vendors)
Chinese International School (CIS) believes that every child has the right to grow up in a healthy, safe, secure and supportive environment. The school endorses the United Nations Convention on the Rights of the Child (UNCRC), which has been ratified by China and the Hong Kong SAR, and seeks to be a positive learning community that promotes well being, free from hazards and harm. The school adopts a strict zero tolerance policy towards the mistreatment or abuse of children.
Mindful of the special role that schools play as protectors of children and of the harm that can be caused by child abuse, CIS has adopted this Child Protection Policy to ensure that all members of the CIS community understand CIS’s approach to child protection and have clear and helpful guidelines for their behaviour, including measures to prevent and address the specific issue of child abuse, which is defined as also including child neglect.
This policy informs all aspects of the school’s activities and operations, including how staff and other affiliated personnel are selected and asked to conduct themselves, and how all learning activities and other programmes are designed and delivered. Initial implementation involved a thorough review of potential risks, new positions of responsibility to anticipate and minimise risks, and the introduction of new practices for all community members. Ongoing implementation will involve an annual audit to monitor implementation and to continue to assess, identify, eliminate or control risks in all domains of the school’s activities.
CIS’s child protection programme focuses on prevention, but also includes clear steps to be taken when there are concerns that a student has been harmed or is being harmed. CIS uses the term “child protection” to refer both to measures to ensure safety and prevent harm generally and to measures to address specific cases of concern. (Some organisations may use the term “safeguarding” to refer to measures mitigating against potential harm to children, as distinguished from the term “protection” to refer to measures mitigating against harm already experienced by a child.)
CIS’s actions will be governed by Hong Kong law, or the laws of Hangzhou or other relevant jurisdictions.
In the event that students experience abuse or neglect in any aspect of their lives, CIS seeks to be a safe haven. The key document addressing the school’s responsibilities in such cases is The Hong Kong Social Welfare Department’s Protecting Children from Maltreatment – Procedural Guide for Multi-disciplinary Co-operation (Revised 2020) and specifically Annex 10: Role of Educational Services and the Education Bureau’s Circular No. 1/2020 Handling Suspected Cases of Child Maltreatment and Domestic Violence, which states that ‘Protecting children from maltreatment is the collective responsibility of various professionals who may come into contact with children. Effective child protection is built on close co-operation across disciplines’.
Families and other community members need to be aware that CIS and its staff will sometimes be required to make a report to the Social Welfare Department, and they are asked to support the school’s decision to do so. In the event that abuse or neglect is suspected to come from a student’s family, the school will identify an approach to help in protecting the student.
In all instances, the school will maintain the confidentiality to the extent appropriate of the student, the student’s family, staff involved in the case, or any other relevant persons.
Inclusivity of All CIS Students
While a child is normally understood to be a person below the age of 18, CIS takes its duty of care for children to encompass all of its currently enrolled students, including those who may have reached or surpassed the age of 18.
Elements of This Policy
CIS requires all adults on either of our campuses or working with our students on or off campus to understand and uphold CIS’s approach to child protection. Expectations are detailed in Sections II-IV. This policy also incorporates the Codes of Conduct, information and education/training to be provided, definitions of abuse, and procedures for reporting concerns. The aim is to provide clear and supportive guidelines to assist our staff, families and other community members in understanding the boundaries between what is appropriate conduct with regard to students and what behaviours will not be tolerated because they are harmful or potentially harmful.
Please be aware that other aspects of CIS’s full programme of child protection may be covered in other policies, procedures or guidelines in the Staff, Student and Parent Handbooks.
All policies of the school are endorsed by CIS’s Board of Governors.
The school has high expectations with regard to the personal conduct of all adult community members with respect to the care and safety of children.
Staff and volunteers include all individuals:
- hired to work on CIS’s Hong Kong or Hangzhou campuses,
- hired to work with students on or off campus,
- or volunteering to work with students in a supervisory role,
- those in short-term roles (e.g., cover teachers, invigilators or visiting professionals),
- those individually employed,
- employed through a sub-contractor (e.g., some security/maintenance staff, service vendors or camp/trip providers),
- or living with or employed by staff members residing within the Hangzhou CIS Residential Building (e.g., family members, caregivers, cleaners, etc.)
Background & Reference Checks
All staff and volunteers are subject to the school’s Background and Reference Check Policy. The school’s Background and Reference Check Policy ensures that all individuals hired to work on campus, or to work with students on or off campus, or volunteering to work with students in a supervisory role, are subject to satisfactory background and reference checks prior to employment or taking part in any school activity for the first time.
All existing staff will need to have an updated background check every two academic school years.
Child Protection Responsibilities
It is the responsibility of all staff and volunteers to:
- Read, understand and comply with this policy;
- Comply with the Staff & Volunteer Code of Conduct (see Appendix I);
- Be familiar with the definitions and indicators of abuse (which is defined as including neglect) that are identified in this policy;
- Be ready to make a report as detailed in this policy, if warranted;
- Cooperate fully in any follow-up measures, including investigations.
Information, Training & Acceptance of this Code of Conduct
At the time of hiring, all members of staff will be specifically briefed on this policy, including the Staff & Volunteer Code of Conduct; and will be required to acknowledge that they have read, understand and will comply with all policies of the school, including the Staff & Volunteer Code of Conduct.
Staff will also receive regular training to ensure their continued readiness to comply with this policy, including the Staff & Volunteer Code of Conduct.
If individually employed, they must provide an undertaking that they have read, understand and will comply with the Child Protection Policy and Staff & Volunteer Code of Conduct, as provided by CIS.
If employed through a sub-contractor, the sub-contractor must provide an undertaking that the personnel they employ to work at or with CIS have read, understand and will comply with the Child Protection Policy and Staff & Volunteer Code of Conduct, as provided by CIS.
Responsibilities of Volunteers and of Staff Overseeing Volunteers
It is the responsibility of all staff overseeing volunteers to ensure that, prior to performing a volunteer role, all volunteers with roles involving the supervision of students (e.g., trip chaperones, event monitors, etc.):
- understand their roles;
- understand the school’s approach to child protection;
- complete an undertaking attesting that they have not committed any criminal offence and have no sexual criminal conviction record;
- understand and comply with the Staff & Volunteer Code of Conduct (see Appendix I).
The above measures for volunteers apply to all volunteers with roles involving the supervision of students, irrespective of whether the volunteers may be former staff, current or former CIS parents or alumni, or bear any other prior relationship to the school.
Volunteers performing roles that do not involve the supervision of students (e.g., CISPTA General Committee, Alumni Board, Annual Fund Advocates, etc.) are not required to complete the above undertaking, but should still understand the school’s approach to child protection and uphold the Staff & Volunteer Code of Conduct (see Appendix I), Visitor Code of Conduct (see Appendix II), and Hangzhou CIS Visitor Policy & Code of Conduct (see Appendix III).
Disciplinary Action & Other Consequences
Individuals who engage in conduct that is inappropriate, harmful, potentially harmful or in any other way incompatible with the Staff & Volunteer Code of Conduct will be personally liable for their acts. This may involve disciplinary proceedings, which, depending on the seriousness of the misconduct, may result in summary dismissal. It may also result in civil liability and, in certain circumstances, criminal consequences. Incidents involving harm to or neglect of, or potential harm to or neglect of, students can constitute gross misconduct which may result in summary dismissal of staff.
In the event of an investigation, the school may place any member of staff involved on paid leave and/or suspension on full pay and benefits should the school deem this necessary.
The school reserves the right to report any complaint to the police or other authorities of Hong Kong, Hangzhou, or other relevant jurisdictions, in which case the perpetrator may be subject to sanctions arising from criminal offences. The perpetrator may also be held liable in civil actions under relevant legislation or in separate legal actions.
The school has the highest expectations with regard to the personal conduct of all adult community members with respect to the care and safety of children.
- When a family joins CIS, parents will be asked to familiarise themselves with the school’s policies and procedures and to acknowledge that they have read, understand and will uphold them. Special reference will be made to this Child Protection policy and parents’ specific responsibilities with regard to the school’s approach to child protection.
- Annually, at the time of re-enrollment, parents will be asked to acknowledge that they have read, understand and will uphold the Child Protection Policy and other school policies and procedures, including the Visitor Code of Conduct (see Appendix II) and Hangzhou CIS Visitor Policy & Code of Conduct (see Appendix III). (Parents will be offered annually updated information to help them understand the school’s policies and procedures.)
- It is the responsibility of parents to ensure that they brief any household staff, temporary guardians, or other caregivers involved in the care of CIS students and/or regularly coming to campus about CIS’s approach to child protection. Such persons will be expected to understand and uphold the Visitor Code of Conduct (see Appendix II) and Hangzhou CIS Visitor Policy & Code of Conduct (see Appendix III).
- Parents are reminded of the school’s requirement that at least one parent/guardian be in full-time residence in Hong Kong with the student. The school expects that CIS students will receive close adult care and supervision in their home environment at all times and, regardless of age, will not be regularly left alone or unsupervised.
- Parents are reminded that they or another formally designated adult will be required to meet students returning from Hangzhou CIS or other school travel at designated pick-up points, such as the airport or school, rather than allowing children to return home on their own. Requirements will be specified in Hanghzou CIS or trip information.
- Parents are reminded of the requirement to disclose to the school any information that may affect the student’s school experience, including but not limited to medical conditions and learning, behavioural, psychological or emotional needs or concerns. Parents should keep their children’s school directory profiles up to date and also promptly communicate with the Homeroom teacher/Advisor/Head of House, school nurse, school counsellor or other relevant member of staff any changes, especially in advance of a trip.
- Parents are also reminded of the requirements to 1) supply and maintain up-to-date contact details for two Emergency Contacts, who must be adults who can act on behalf of parents if parents cannot be contacted, and also 2) to supply Temporary Guardian information every time that both/all parent/guardian(s) of a student are absent from Hong Kong; this should include: a. dates of parent/guardian absence, b. contact details of a Temporary Guardian, and c. signed acknowledgement by the Temporary Guardian.
Failure to meet either of these requirements will require discussion with the school about the student’s future enrollment status at CIS.
- Families and other community members need to be aware that CIS and its staff will sometimes be required to make a report to the Social Welfare Department, and they are asked to support the school’s decision to do so.
- In the event that abuse or neglect is suspected to come from the student’s family, the school will identify an approach to help in protecting the student.
Household Staff, Temporary Guardians, or Other Caregivers
- It is the responsibility of parents to ensure that they brief any household staff, temporary guardians, or other caregivers involved in the care of CIS students and/or regularly coming to campus about CIS’s approach to child protection.
- Such persons will be expected to understand and uphold the Visitor Code of Conduct (see Appendix II) and Hangzhou CIS Visitor Policy & Code of Conduct (see Appendix III).
Social Media and Chat Groups
Parents must observe the school’s guidelines for school-endorsed class/house parent chat groups, which have been developed with child protection in mind.
These guidelines state that:
- Only group photos should be posted; individual and close-up photos should not be posted.
- Students appearing in photos posted should not be identified by name.
- Photos posted in such chat groups should not be further shared on other social media or otherwise shared with the public.
Please note that guidelines for posts on the school’s own social media platforms are that posts must be constructive and serve to illustrate key aspects of student learning, school life or school values. Posts should not identify the full names of students, but may use first names and year levels (or in the case of posts in Chinese, may use surnames and year levels).
Because social media platforms, their features, and the social norms around their use are subject to rapid change, parents are reminded to be sensitive and responsible in their use of all social media, including non-school endorsed platforms; make sure their privacy settings are set appropriately; and be vigilant so as not to inappropriately share photos and personal details of other people’s children, as well as their own children.
Primary School Class Parent Guidelines
- Short Visitor Do’s & Dont’s” appear on this page and are also displayed at school entrances and appear on visitor badges as reminders to visitors.
- The full Visitor Code of Conduct and Hangzhou CIS Visitor Policy & Code of Conduct follow in Appendices II & III. All visitors are asked upon arrival to read, sign and uphold the Visitor Code of Conduct in order to ensure student safety and protection.
Students are expected to treat each other with courtesy and respect, and bullying is not tolerated.
For expectations, as well as procedures when expectations are not met, see these sections of the Parent Handbook for policies relating to Primary students:
And these sections of the Student Handbook for policies relating to Secondary students:
- Attendance and Punctuality;
- Standards of Behaviour;
- Bullying Policy;
- Technology Responsible Use Policy.
These expectations apply equally to Hangzhou CIS students. Hangzhou CIS also has additional expectations of students that take into consideration the residential setting. Please see the Hangzhou CIS Student and Parent Handbooks.
- Students receive regular instruction and guidance in a variety of settings about appropriate behaviour among students and between students and other community members.
- With specific regard to child protection, the school provides students at every year level age-appropriate lessons so that they understand their needs, rights and responsibilities with regard to personal safeguarding. Lessons also informs students of who they may speak to at school should they have concerns about their own situation or that of other students.
- The school’s expectations for students and the school’s child protection measures also apply when students are engaged in activities and trips off campus. Measures to assess and minimise risk are a required element of the planning of all trips, in and outside of Hong Kong.
Disciplinary Action & Other Consequences
Students who engage in conduct that is inappropriate, harmful, potentially harmful or in any other way incompatible with the Student Handbook will be subject to sanctions as outlined in the above documents.
Subject to law and the circumstances, the school may be required to inform the police or other authorities of Hong Kong, Hangzhou, or other relevant jurisdictions.
In all cases, strict confidentiality will be maintained to the extent appropriate.
CIS recognises that sexuality is a normal part of human nature. Learning about this aspect of human nature is a normal part of childhood and adolescence, and age-appropriate education will be provided.
At the same time, the school takes the view that community members have the right to expect that school premises and school activities will be free of sexual behaviours. For this reason, CIS adopts a strict zero tolerance policy to sexual activity and/or physically intimate activity on the school’s campuses and during school activities. Sexual activity and/or physically intimate activity is understood to cover a range of behaviours, including non-touch behaviours such as sexting or other online or offline behaviours.
If students are found to have engaged in sexual activity and/or physically intimate activity, because of the variables involved the school will review the situation on a case-by-case basis and respond with an action plan that addresses behaviours of concern, physical and emotional/psychological effects, and disciplinary consequences.
In some cases the school’s response may also involve determining if sexual activity and/or physically intimate activity is inappropriate sexual behaviour or abuse. It should be noted that sexual behaviour involving a student or students will be considered abuse if it occurs without the consent or understanding of one party, as a result of coercion, or with a difference in age, responsibility, trust or power between the parties.
All staff and volunteers, including members of the Board of Governors, are required to undergo basic-level training in child protection that must be refreshed annually.
- New staff will receive an induction briefing and materials until such time in the school year when they can undergo full basic-level training.
- Members of the school’s Leadership Team and Child Protection Officers are required to undergo advanced-level training in child protection that must be refreshed every two years. It is also expected that during the interim period between advanced-level training of a comprehensive nature, they will also take part in presentations, conferences or other professional development in various specific topics that will enhance their ability to improve child protection at CIS.
Board of Governors
- Endorses this policy as part of the full Policy Handbook and holds oversight over the school’s child protection programme.
- The Chair and Vice Chair are designated to lead the Board’s oversight measures for child protection and serve as points of contact with the school leadership on such matters.
- The Chair and Vice Chair are the designated contact persons in the event that concerns arise involving the Head of School.
- In their individual capacities, Board members adhere to the Staff & Volunteer Code of Conduct.
Current office holders:
- Andrew Brandler, Chair
- Venantius Tan, Vice Chair
Head of School, Deputy Head of School, Heads of Primary or Secondary, or Director and Deputy Director of Hangzhou CIS
- Serve as leaders of the school’s child protection programme, including this policy.
- Appoint CPO(s).
- Appoint Child Protection Response Team, as necessary.
- Ensure that the procedures outlined in this policy are followed appropriately and fairly in the interests of students and in accordance with Hong Kong law and Social Welfare Department guidelines, or the laws of Hangzhou or other relevant jurisdictions.
Current office holders:
- Sean Lynch, Head of School
- Li Bin, Deputy Head of School
- Anne Gardon, Head of Primary
- Christine Doleman, Head of Secondary
- Sally Zhang, Director of Hangzhou CIS
Child Protection Officer(s) (CPOs)
Separate CPOs are appointed for Primary, Secondary and Hangzhou CIS, and two of these persons will also be designated as Lead and Deputy CPO for the whole school.
- Act as first-line responders to whom concerns regarding harm to a student are reported.
- Serve as coordinator of a Child Protection Response Team, if appropriate.
The Lead CPO also holds these responsibilities:
- Manages any liaison with the Social Welfare Department or other relevant authorities.
- Coordinates implementation of this policy.
- Ensures regular training for the various stakeholder groups covered in this policy.
- Maintains all confidential CP records for CIS Hong Kong students.
The CPO for Hangzhou CIS will hold these responsibilities:
- Manages any liaison with relevant local authorities.
- Maintains all confidential CP records for Hangzhou CIS students.
Current office holders:
- Jenny Chadwick, Assistant Director of Student Life - Lead CPO & CPO for Secondary
- Nick Panza, Primary Counsellor - Deputy CPO & CPO for Primary
- Brian Mulcahy, Deputy Head of Secondary, Director of Student Life (Secondary) - Deputy CPO Secondary
- Tracy Hayes-Williams, Head of Student Life & Administrative Services (Primary) - Deputy CPO Primary
- Sarah Roderick, Head of House - CPO for Hangzhou CIS
- Teck Wee, Head of House - Deputy CPO & CPO for Hangzhou CIS
These will include all other counsellors not appointed as CPOs above and other persons who may be designated to served in this role.
- Act as first-line responders to whom concerns regarding harm to a student are reported.
- Serve as coordinator of Child Protection Response Team, if appropriate.
Current office holders:
- Tim Conroy-Stocker, Head of Counselling, Secondary
- Monica Chang, Secondary Counsellor
- Sarah Daly, Secondary Counsellor
- Jamie Li, Primary Counsellor
- Ann Mok, Secondary Counsellor
- Adrian Huen, Director of Finance & Business Administration
- Xie Li, Head of Office, Hangzhou CIS
Responders to Concerns Involving Staff
- The Deputy Head of School, Director of Finance & Business Administration, Director of Community Relations, and Director and Deputy Director of Hangzhou CIS will act as first-line responders to whom concerns involving a member of staff are reported.
- Maintain confidential child protection records relating to staff cases.
Current office holders:
- Li Bin, Deputy Head of School
- Adrian Huen, Director of Finance & Business Administration
- Catherine Han, Director of Community Relations
- Sally Zhang, Director of Hangzhou CIS
Child Protection Response Team
- Coordinates initial fact-finding in the event of cases of concern.
- Supervises follow-up actions and ongoing support to students, families or staff, as necessary.
Child Protection Committee
- Is comprised of staff members from across the school.
- Meets monthly to review all aspects of the Child Protection programme, ensure compliance with the school’s CP policy and current best practice, and implement modifications as necessary.
- Annually reviews and updates this policy and the various Codes of Conduct.
- Li Bin, Deputy Head of School
- Anne Gardon, Head of Primary
- Tracy Hayes-Williams, Head of Student Life & Administrative Services (Primary)Deputy CPO Primary
- Christine Doleman, Head of Secondary
- Laszlo Varro, Head of Administrative Services (Secondary)
- Brian Mulcahy, Deputy Head of Secondary, Director of Student Life (Secondary), Deputy CPO Secondary
- Jenny Chadwick, Assistant Director of Student Life - Lead CPO & CPO for Secondary
- Nick Panza, Primary Counsellor - Deputy CPO & CPO for Primary
- Tim Conroy-Stocker, Head of Counselling, Secondary
- Monica Chang, Secondary Counsellor
- Jamie Li, Primary Counsellor,
- Adrian Huen, Director, Finance & Business Administration
- Jerry Szombathy, Director of Operations, Head of Administrative Services
- Allan Fraser - Director of Sports & Activities
All staff and volunteers should familiarise themselves with the following definitions of what constitute abuse and typical indicators, and they should be vigilant and prepared to make a report to the CPO and/or a counsellor if they believe there is reason for concern. Staff are not expected to make a judgement about whether their concerns may or may not ultimately constitute abuse.
It should be noted that children who experience abuse will respond differently and some children will be more vulnerable than others. Children with special educational needs or with disabilities may face additional challenges. Special care and follow-up to support both victims and perpetrators will be required in the event of cases of peer abuse.
Child abuse is broadly defined as any act of commission or omission that endangers or impairs the physical/psychological health and development of an individual under the age of 18 committed by individuals, singly or collectively, who by their characteristics (e.g., age, status, knowledge, organisational form) are in a position of differential power that renders a child vulnerable. (Note: CIS takes its duty of care to extend to all of its currently enrolled students, regardless of age and including those who may have reached or surpassed the age of 18.)
Child abuse is not limited to a child-parent/guardian situation, but may involve anyone entrusted with the care and control of a child -- e.g., child-minders, relatives, teachers, coaches, etc. Abuse may also be committed by a person unknown to a child, although it should be noted that perpetrators tend not to be strangers.
Types of Abuse
There are four main areas of child abuse, as outlined below.
It should be noted that some of the indicators listed below may be signs of problems other than abuse, and the advice of school counsellors or other trained professionals along with additional information will normally be required. Definitions of abuse can be complex and may also involve culturally-specific child-rearing behaviours, gender and role responsibilities, and expectations.
Neglect occurs when parents/guardians fail to provide for a child’s basic needs such as food, clothing, shelter, medical care, education and emotional needs, or fail to provide appropriate adult supervision or guardianship over extended periods of time.
Possible indicators of neglect:
- Child is dirty or unkempt.
- Child is often poorly or inappropriately dressed for the weather.
- Child is repeatedly late or absent from school.
- Child demonstrates excessive affection-demanding or attention-seeking behaviour.
- Child does not want to go home.
- Child is left for extended, age-inappropriate, periods of time without parent/guardian.
- Parents/guardians do not respond to repeated or urgent communications from the school.
2. Physical Abuse
Physical abuse is any non-accidental injury where adults physically hurt, injure or kill a child. This may involve hitting, shaking, squeezing, burning, hair-pulling, attempted suffocation or drowning, giving a child poisonous substances or inappropriate drugs or alcohol, holding a child against his or her will, extreme physical discipline, disfigurement or other cruel or inhumane acts, disregard for a child’s pain and/or mental suffering, as well as failure to take reasonable steps to prevent the occurrence of any of the above.
Possible indicators of physical abuse:
- Unexplained bruises, burns, lacerations, fractures or other injuries to any part of the body.
- Injuries inconsistent with information offered by the child.
- Injuries that regularly appear after holidays or other absences.
- Non-visible signs of impairment to a child’s physical or mental health or functioning (e.g., sleep deprivation, or inadequate, unhealthy diet).
3. SEXUAL ABUSE
Sexual abuse is the involvement of dependent, developmentally immature children and adolescents in sexual activities which are unlawful, or to which they are unable to give informed consent, or which violate the social taboos of family roles. This covers any contact and non-contact behaviours that result in children being used for the sexual gratification of others, including but not limited to touching genitalia, intercourse, involvement with pornography, indecent exposure, etc., and regardless of whether the child or children involved perceive themselves as victims or not.
Sexual abuse has characteristics that differ from other forms of child abuse and warrant special attention. While physical abuse is often the result of immediate stress and not usually planned, sexual abuse usually requires planning with results that are more harmful. The planning, referred to as “grooming”, often results in victims accepting the blame, responsibility, guilt and shame for the sexual behaviour of the offender. Sexual abuse requires far more secrecy than other forms of child abuse and so is more difficult to detect.
Possible indicators of sexual abuse:
- Sexually explicit play, language, knowledge or behaviour (e.g., sexting) that seems age-inappropriate.
- Discomfort in walking or sitting.
- Persistent complaints of stomach disorders or pains.
- Involuntary urination or soiling.
- Reluctance to undress for PE or swimming, or fear of bathrooms.
- Bruises, scratches or other evidence of physical trauma or bleeding in the genital area.
- Sexually transmitted infections in a child of any age.
- Attention-seeking behaviour, self-mutilation or substance abuse.
- Unusual interpersonal relationship patterns.
- Discomfort with or lack of trust in a familiar or specific adult.
It should be noted that many victims, through a process of manipulation, whether in person or online, etc., which is referred to as “grooming”, are taught that the sex is a form of love, and so tend to love their offender and may present as happy and well-adjusted children without negative symptoms because of their perception of being loved.
For student-to-student cases, please see Expectations for Students above.
4. PSYCHOLOGICAL/EMOTIONAL ABUSE
Psychological/emotional abuse is the emotional ill treatment or rejection of a child leading to significant emotional disturbance or trauma, or impaired behavioural, cognitive, affective or physical functioning or development. The ill treatment may involve a range of behaviours including a constant lack of love and affection, withholding affection, isolating, shouting, extreme criticism, verbal attacks, threats, scapegoating, excessive demands on a child’s performance, intimidation, threatening behaviour, or exposure to domestic violence. It can also involve harassment or indifference on the basis of race, culture, gender or disability. It may involve a repeated pattern of behaviour or a single extreme incident.
Possible indicators of psychological/emotional abuse:
- Over-reaction to mistakes or continual self-deprecation.
- Delayed physical/mental/emotional/social development.
- Sudden speech disorders, elective mutism/deafness.
- Inappropriate emotional responses or fantasies.
- Self harm or suicidal thoughts/attempts.
- Eating disorders or appetite disturbances.
- Disruptive behaviour or conduct problems.
- Marked deterioration in academic performance.
- Rocking, banging head or regression.
- Isolation or alienation.
- Sleep disturbance.
- Failure to make healthy relationships with peers.
The Responsibility to Report
All staff are expected to raise their concerns, no matter how small. What may seem like a minor matter by itself may represent a more serious concern together with other information known to the CPO. Members of staff will not be expected to respond to concerns alone or to make a judgment about whether abuse has taken place, but they are expected to raise their concerns, report any indicators of abuse as identified in this policy that they may have encountered, or other information giving reasonable cause.
It should be noted that individual cases may vary significantly from one another, and no single reporting and handling protocol is likely to address all of the circumstances of a particular case.
Reporting Possible Harm to a Student
Concerns should be reported to the one of the CPOs or Additional Responders (see Key Roles & Responsibilities).
Reporting Possible Misconduct by a Member of Staff
If concerns involve another member of staff, the report should be made to the staff designated as first-line responders for such cases -- the Deputy Head of School and/or the Director of Finance and Business Administration and/or the Director of Community Relations -- or relevant Head of Primary/Secondary or Director/Deputy Director of Hangzhou CIS. If concerns involve the Head of School, the report should be made to the designated members of the Board of Governors, who as noted above are the Chair & Vice Chair.
Names of specific individuals may be found, above, in “Key Roles & Responsibilities”.
Protection for Members of Staff Making A Report
In accordance with the school’s Disclosure Policy, the school will take reasonable steps to protect from victimisation or retaliation in connection with their involvement in making a report any staff member who makes a report in good faith. The school will not tolerate any behaviour whereby a member of staff victimises another person because he/she files a report, is about to file a report or is otherwise involved in a report (e.g., as a witness) relating to an allegation of harm to a student. Victimisation in any form will be subject to disciplinary action and may result in termination.
In all cases, actions will be conducted in a manner that ensures that information is documented factually and that strict confidentiality is maintained to the extent appropriate.
All documentation of the investigation will be kept in hard copy in a locked safe in the designated Lead CPO’s office, and will not be kept digitally or in an individual student’s file. Records sent to schools to which the student may transfer will be flagged to let the receiving school know there is a confidential file for the student. The school will make every attempt to share information deemed to be in the student’s best interest.
STEP 1: Initial Fact-Finding & Response Team
When a student reports abuse to a staff member or there is reasonable cause to believe that abuse is occurring, the relevant staff member should immediately make a report.
All reports should include a written statement using the
The CPO will:
- Secure the immediate physical safety of the student, if that is a concern.
- Report the case to the relevant Head of Primary/Secondary or Director/Deputy Director of Hangzhou CIS.
- Take initial steps to gather information regarding the report.
- Form a school-based Child Protection Response Team, as needed, to address the report.
- When a report concerns a member of staff, the designated first-responder receiving the report will take the steps listed above, in lieu of the CPO, and relevant Head of Primary/Secondary or Director/Deputy Director of Hangzhou CIS will serve as coordinator of the Child Protection Response Team.
- For cases involving students of Hangzhou CIS, Step 1 will involve the CPO for Hangzhou CIS reporting to the Lead CPO. Should reporting to authorities be deemed appropriate, reporting will be to Hong Kong authorities as outlined in the Protecting Children from Maltreatment – Procedural Guide for Multi-disciplinary Co-operation (Revised 2020) of the Hong Kong Social Welfare Department and the Education Bureau’s Circular No. 1/2020 Handling Suspected Cases of Child Maltreatment and Domestic Violence.
- The Child Protection Response Team will include:
- the relevant CPO(s),
- relevant Head of Primary/Secondary
- the relevant school counsellor,
- and may include:
- Head of School,
- Deputy Head of School,
- School nurse,
- Secondary Head of Year,
- Hangzhou CIS Head of House,
- or other individuals who the relevant Head(s) of School deems appropriate.
- A CPO will normally serve as overall coordinator of the Child Protection Response Team.
- The Child Protection Response Team will be responsible for initial fact-finding, which may involve:
- Interviewing relevant staff.
- Speaking with the student(s) if appropriate.
- Consulting with relevant staff to review the student’s history in school.
- Documenting information relevant to the case.
- Notifying the student’s family, as appropriate.
The Child Protection Response Team will also be responsible for supervising measures under Steps 2 & 3, if deemed necessary.
STEP 2: Action Plan
Based on the initial fact-finding, a plan of action will be developed to assist the student and family. Possible actions that may take place are:
Based on the initial fact-finding, a plan of action will be developed to assist the student and family. Possible actions that may take place are:
- Discussions between the student and CPO (or counsellor, as appropriate), using age-appropriate strategies, in order to gain more information.
- In-class or other on-campus observations of the student by an appropriate teacher, counsellor, or administrator.
- Meetings with the family to present the school's concerns.
- Referral of the student and family to an external professional counsellor or relevant specialist.
- Consultation with the relevant officer of the Hong Kong Social Welfare Department (SWD staff can provide advice, especially in cases where there are doubts as to whether or not to make a formal report).
- Consultation with legal counsel, as appropriate.
- Consultation with other local authorities, as appropriate.
In general, most cases that are determined to involve the following issues will be handled in-house by school counsellors and/or CPOs:
- Student relationships with peers.
- Parenting skills related to disciplining children at home.
- Student-parent relationships.
- Mental health issues such as anxiety, low self-esteem or grieving.
Cases that are determined to involve the following issues will typically be referred to outside specialists:
- Mental health issues such as depression, psychosis, dissociation or suicide ideation.
Cases that are determined to involve the following issues will always be reported to the Social Welfare Department for investigation and may also be referred to other outside specialists:
- Severe and ongoing physical abuse,
- Sexual abuse and incest.
In extreme cases, when abuse is ongoing or concerns remain about the safety of a student, reports may be made to:
- The Social Welfare Department.
- The Hong Kong Police.
- The Education Bureau.
- Other relevant authorities.
- Authorities of other relevant jurisdictions, including but not limited to Hangzhou.
STEP 3: Ongoing Support
Subsequent to a reported and/or substantiated case of child abuse, the CPO and/or counsellor will:
- Maintain contact with the student and family to provide appropriate support and guidance.
- Provide the student’s teachers and relevant Head(s) of School with ongoing support.
- Provide resource materials and strategies for teacher use.
- Maintain contact with any outside therapists to update them on the progress of the student in school.
- Maintain contact with the Social Welfare Department or other relevant authorities, as appropriate.
Creating a healthy, safe, secure and supportive learning environment for students is the first priority of Chinese International School, and all staff, volunteers and other personnel have a responsibility to act with care, maturity, integrity and accountability to ensure that this is achieved and that students are always protected.
The following is a list of standards that staff and volunteers are expected to uphold, as well as inappropriate behaviours to avoid. Please be aware that this list is not exhaustive, and the underlying goal of protecting students should be kept in mind at all times.
This Staff & Volunteer Code of Conduct applies to all individuals hired to work on campus, or to work with students on or off campus, or volunteering to work with students in a supervisory role, and to all interactions with students regardless of age or location, both in their professional and private lives.
Staff & Volunteers Must Always:
1. Maintain a Safe & Positive School Environment
- Remember that your first priority is the protection and wellbeing of students.
- Treat every student in your care with courtesy, care and respect -- just as you would treat any adult member of the school community and as you would wish to be treated yourself.
2. Identify & Report
- Take responsibility for knowing what constitutes a potential risk, for promptly identifying situations that may place a student at risk of harm, and for managing, minimising or eliminating such risks.
- Take responsibility to immediately report any concerns to one of the Child Protection Officers (CPOs) and/or responders. (In the case of concerns involving another member of staff, report to the Deputy Head of School, Director of Finance & Business Administration, Director of Community Relations, or Director or Deputy Director of Hangzhou CIS.)
- This is a mandatory CIS requirement, and may differ from requirements under Hong Kong law. All reports should include a written statement using the Child Protection Reporting Form.
- Cooperate fully in any follow-up measures, including investigations.
3. Maintain Visibility
- Make yourself as visible as possible to other adults when working with students, and avoid putting yourself in situations where your behaviour could be open to question and therefore misinterpreted. (A general guideline is to conduct meetings in locations that are public and visible, with doors open and other adults present, preferably on campus.)
- Be sure you are never in a situation where you are alone with a student and not visible to others -- e.g., inviting a student to one’s own place of residence, car, or other private location; visiting a student’s home or room; or when on trips, sleeping alone in the same room with a student -- unless authorised by a parent/guardian, or in the case of medical or other emergency. (A general guideline is to have another student or adult in the room or near vicinity while talking to a student after school; or for example, to take two or more students to the bathroom together.)
- Take special care in boarding, residential or travel situations, which may pose additional risks due to dormitory/bedroom/sleeping area configurations and a casual atmosphere. (A general guideline would be to arrange meetings only in public areas and to clearly alert students and other adults to your presence when necessary to enter dormitories or other sleeping areas.)
4. Communications, Media & Online Behaviour
- Use materials and media with age-appropriate language and content.
- Conduct communications with students using school-sanctioned channels or platforms.
- Follow the school’s guidelines for Online Learning and social media use.
- Do not establish or seek to establish social contact with students outside of school. This includes students who have left the school who are under the age of 18.
- Make sure photos, video and other media serve a constructive school purpose and present students and activities appropriately and respectfully.
- Upload photos and video to school servers and delete from personal devices within 24 hours or at the completion of a school trip.
- Take special care in the online learning situation, which has created spaces where the professional/academic and domestic/private lives of staff, students and parents have become visible to each other.
5. Appropriate Language & Discipline
- Only use language or discipline that is corrective and aims to teach, rather than language or discipline that is harsh and that aims to punish or humiliate.
- Avoid all physical punishment.
6. Fair, Equal & Respectful Treatment
- Always treat students fairly and equally so no students are favoured or excluded.
- Give comments, suggestions or advice to students that are about learning and learning-related work, performance and efforts. Do not give comments, suggestions or advice -- whether positive or negative -- about a student’s physical appearance or other overly personal matters.
- Do not give or receive gifts without parent or guardian knowledge (refer to the school’s Gift Policy).
- Never act in ways that may exploit a student. Never ask or directly or indirectly coerce a student to provide labor or services, especially those that result in the adult’s gratification, profit, or other financial or personal advantage.
7. Appropriate Clothing & Physical Contact
- Wear clothing which is appropriate to the learning and environment and context.
- Limit physical contact to safe practice related to physical activities such as sports, or medical or other emergencies, and make sure that contact is age-appropriate, respectful and safe.
- Never engage with a student in any emotional or romantic relationship, sexual activity and/or physically intimate activity, or behaviour that could be interpreted as the above, including flirtatious or seductive looks, regardless of the student’s age, and regardless of the definition of legal consent and the age of majority in Hong Kong or other relevant jurisdictions. (In the interest of transparency, any concerns regarding a student’s perceived infatuation with a staff member should be reported to the staff member’s supervisor to allow third-party monitoring of the situation.)
- CIS premises are non-smoking, whether indoors or outdoors.
- Please use restrooms designated for adults.
- Please also familiarise yourself with emergency evacuation signage and proceed to the nearest exit in case of an alarm.
Our campuses are protected by CCTV.
(Staff & Volunteers are asked to sign a form indicating that they agree to uphold this Staff & Volunteer Code of Conduct.)
All members of the public visiting the CIS Hong Kong and Hangzhou campuses must sign and follow this “Visitor Code of Conduct”. A shorter “Visitor Do’s & Don'ts” is prominently displayed at all entrances and on visitor badges (see Appendix IV).
While you are on campus, keep your badge prominently displayed at all time and help us maintain a healthy, safe and secure learning environment for all our students.
Please do not:
- As a visitor, you must never be alone with students. Please keep yourself visible to other members of our community.
- You must never touch students. Please avoid intruding on students’ personal space and do not reciprocate physical contact from a student.
- Do not seek to contact students outside of CIS. Do not give your contact details or other personal information to students and do not accept or keep any personal information you may receive about students.
- Do not give to or accept from students inappropriate materials, money, gifts or favours, and do not show favouritism to particular students in any other way.
- Please do not smoke on our campus, whether indoors or outdoors.
- Be mindful of your language and conduct. Treat students with the same courtesy, care and respect as adult members of the school community, while at the same time avoid being overly familiar with students. Be aware that language and conduct appropriate in other settings may not be appropriate at our school.
- Request permission from an adult, not student, before taking photos and videos. Even when permission is granted, avoid close-ups or images that include student names and personal details. Do not post images on social media and delete images after use.
- Use adult-only washrooms. All washrooms are clearly marked. Be aware that you may need to proceed to another floor to find an appropriate washroom.
- Report hazards or concerns to the person hosting you or other staff in charge. These may include physical hazards, as well as behaviour that is disrespectful, harmful, or suspicious, whether by students or adults, between students, or between students and adults.
- Exit the school in case of an alarm. Evacuation information is posted throughout the campus. Familiarise yourself with evacuation routes and be prepared to proceed to the Sports Field or other designated area in the case of a fire alarm or other emergency.
Our campus is protected by CCTV.
(To indicate that they agreed to uphold this Visitor Code of Conduct, visitors will be asked to sign a form with the Code and the date and reason for their visit.)
All members of the public visiting Hangzhou CIS must follow these procedures, and sign and follow the Visitor Code of Conduct, as below.
- On arrival, report immediately on arrival to the Guard Station at the main entrance to the Residential Building where they will be asked to sign in.
- On signing in, all visitors will be issued with a visitor badge which must be worn for their entire visit. All visitors will also be asked to read and sign the Visitor Code of Conduct.
- A shorter “Visitor Do’s & Don’t’s” is prominently displayed at all entrances and on visitor badges.
- Before leaving, visitors must return their visitor badge and sign out at the Guard Station.
Visitor Access to Residential & Academic Buildings
Visitors are not permitted access to the Residential and Academic Buildings unless chaperoned by a member of the Hangzhou CIS staff. This rule also applies to Parents/Guardians, students’ extended family and other guests of students. Such persons may request access to the Residential Building up to 9pm, but permission must be requested in advance from the Director of Hangzhou CIS, Sally Zhang.
Contractors must make advance arrangements to visit the school and must be met by a member of staff before access is allowed. Contractors must wear their visitor badge at all times and sign and uphold the Visitor Code of Conduct like any other visitor.
Members of the Greentown School Community
Students and staff are encouraged to be hospitable to our friends and neighbours in the Greentown school community. However, visitors must be accompanied at all times and must never be given independent access to the Residential and Academic Buildings.
Open Days & School Functions
On special occasions, the Hangzhou CIS premises will be open to all visitors. Visitors should note that during these occasions, members of staff and students will be assigned duties to monitor the premises and may ask visitors to identify themselves. Access to dormitories, the entire Residential Building, or other areas may be restricted, at the discretion of the Director.
Employees or Resident Adult Family Members of CIS Staff
Caregivers, private cleaners or anyone regularly visiting campus or living on campus for an extended period of more than 48 hours must undergo formal Child Protection training and read, sign and uphold the Staff & Volunteer Code of Conduct. After such training, they will be given residential swipe cards, which give access to the lift and front door of their residence only. Non-lift access should only be used in exceptional circumstances and, like any other visitor, they should not enter other areas of the Residential and Academic Buildings without a staff chaperone. General access to the corridors and rubbish bins is only permissible for those of the appropriate gender. Such persons must wear their visitor badge at all times.
Instructions Issued to Students
Do not allow access to anyone not of the CIS community into the Residential or Academic Buildings. Direct all enquiries to the Deputy Director or Director. This also applies to Parents/Guardians, students’ extended family and other guests of students. Report immediately to a member of staff if you suspect a problem or notice a stranger unaccompanied by a member of our staff.
(To indicate that they agreed to uphold this Visitor Policy, visitors will be asked to sign a form with the Policy and the date and reason for their visit.)
Visitors Do's & Don'ts
Download our full Visitor Code of Conduct and submit it to your host prior to arrival on our Hong Kong or Hangzhou campus.
Thank you for helping us maintain a healthy, safe and secure learning environment for students.
Please do not:
- Be alone with students
- Touch students
- Seek to contact students outside of CIS
- Give to or take personal information from
students (likewise inappropriate materials,
money, gifts or favours)
- Smoke on campus (indoors or outdoors)
- Be mindful of your language and conduct
- Request permission before taking photos
- Use adult-only washrooms
- Report hazards or concerns to staff
- Exit the school in case of an alarm
Our campus is protected by CCTV.
The school’s Child Protection Policy is the foundational document committing Chinese International School (CIS) to the belief “that every child has the right to grow up in a healthy, safe, secure and supportive environment,” free from all types of abuse, and outlining the roles and responsibilities of every member of the CIS community, including students, staff, parents, volunteers, the Board of Governors, contract staff, and visitors in understanding, identifying and proactively safeguarding CIS students and other children from harm and abuse, as well as procedures to be followed in the event that signs of abuse are detected. This policy will be reviewed annually and updated in the interim, as may be required, to ensure that it continually addresses the risks to which students are or may be exposed. A number of staff and students will be involved in each annual review which involves, and is informed by, an assessment of the impact and effectiveness.
Purpose and Aim
This policy focuses specifically on inappropriate or harmful behaviours between peers, which in extreme cases may be characterised as “peer abuse” -- the term typically used at CIS -- or “peer-on-peer abuse”.
This policy outlines a planned and supportive response to prevent, mitigate and handle any such issues. Note that this policy follows the CIS Child Protection Policy’s definition of a child:
“While a child is normally understood to be a person below the age of 18, CIS takes its duty of care for children to encompass all of its currently enrolled students, including those who may have reached or surpassed the age of 18.”
The Responsibility to Report
The general rule of thumb with regard to inappropriate behaviour between peers is the same as for other areas of the school: all staff are expected to raise their concerns, no matter how small. What may seem like a minor matter by itself may represent a more serious concern together with other information known to counsellors or other responsible staff.
Members of staff are not expected to make a judgment about whether abuse has taken place, but they are expected to report any indicators of abuse identified in this policy that they encounter or raise any other concerns. Staff should not dismiss abusive behaviour as normal between young people and should not develop high thresholds before taking action. Staff should be aware of the potential uses of information technology for bullying and abusive behaviour between young people.
Inappropriate Behaviour, Bullying & Peer Abuse
There are many ways that children may act inappropriately to each other, and the vast majority of such behaviours are unlikely to rise to the level of bullying or peer abuse.
This is the definition of bullying in the Secondary Student Handbook:
“Bullying, including Cyberbullying, is the misuse of power, position and privilege. It is done to hurt, intimidate, coerce, frighten and to control.”
Online bullying/Cyberbullying is the use of technology (social networking, messaging, text messages, e-mail, chat rooms etc.) to harass, threaten or intimidate someone for the same reasons as stated above.
Online bullying can take many forms:
- Abusive or threatening texts, emails or messages
- Posting abusive comments on social media sites
- Sharing humiliating videos or photos of someone else
- Stealing someone’s online identity
- Spreading rumours online
- Trolling - sending someone menacing or upsetting messages through social networks, chatrooms or games
- Developing hate sites about another person
- Prank calls or messages
- Group bullying or exclusion online
- Anonymous messaging
- Encouraging a young person to self-harm
- Pressurising children to send sexual messages or engaging in sexual conversations
This is the definition of abuse in the Child Protection Policy:
“Abuse is broadly defined as any act of commission or omission that endangers or impairs the physical/psychological health and development of an individual committed by individuals, singly or collectively, who by their characteristics (e.g., age, status, knowledge, organisational form) are in a position of differential power that renders the individual vulnerable.”
While the differences between inappropriate behaviour, bullying and peer abuse will generally relate to the persistence of the behaviour and severity of harm, there are no absolute guidelines to determine at what point behaviour between peers has escalated to the point of bullying or the level of peer abuse.
Indicators of Abuse
Abuse issues may be disguised or may take place alongside behaviours that on their own are not typically characterised as abuse. It is important that inappropriate behaviours not be tolerated or dismissed as initiation or hasing-type rituals or “part of growing up”. Abuse is abuse and should never be passed off as ‘banter’, or ‘just having a laugh’.
Any of the following behaviours should always be reported as they are likely to be indicators of peer abuse or potentially abusive peer behaviour. Indicators that a child may be suffering from peer abuse may overlap with indicators of abuse by others (see Child Protection Policy, Section VII, Definitions & Indicators of Abuse).
- Physical: Behaviours such as biting, hitting, kicking, hair pulling, etc.
- Emotional: Persistent or severe emotional ill-treatment.
- Coercive: Exerting control over another person’s behaviour by using force or threats, or by causing fear.
- Relationship-related: A pattern of coercive behaviours (whether emotional, financial, sexual or physical) used to maintain power and control over a former or current intimate partner, such as threats, isolation, or intimidation.
- Online: Use of the phone, messaging, e-mail, chat or social networking platforms to harass, threaten or intimidate someone.
- Sexting: Sending or receiving of sexually explicit text, image or video.
- Sexual: Inappropriate conversation, language, materials, and a range of touch/non-touch, penetration and non-penetration, especially if aggressive, exploitative, degrading or involving younger peers.
- Gender-based: Harm directed against another person on the basis of gender or sex, motivated by perceived differences e.g. on grounds of race, religion, gender, sexual orientation, disability or other differences.
- Financial: Exerting control over another person’s money or other assets.
When a report is made, these are some of the factors that the staff responsible will consider in determining whether inappropriate behaviour has escalated to the level of bullying or peer abuse. An assessment of an incident between peers should be completed and consider:
- Chronological and developmental ages of everyone involved
- The difference in their power or authority in relation to age, race, gender, physical, emotional or intellectual vulnerability
- All alleged physical and verbal aspects of the behaviour and incident
- Whether the behaviour involved inappropriate sexual knowledge or motivation
- What was the degree of physical aggression, intimidation, threatening behaviour or bribery
- The effect on the victim
- Any attempts to ensure the behaviour and incident is kept a secret
- The child or young person’s motivation or reason for the behaviour, if they admit that it occurred
- Whether this was a one-off incident or longer in duration
- How to Report A Concern
As set out in the Child Protection Policy, if a member of staff has reasonable cause to believe that the behaviour is abusive or potentially abusive, the member of staff should make a report as soon as possible to one of the school’s Child Protection Officers, with a handwritten statement using the Child Protection Reporting Form.
If a member of staff does not believe the behaviour is abusive or potentially abusive, or is unsure, the behaviour should be reported within 24 hours to one of the following persons:
- Primary: Counsellor, Year Level Leader or Head of Student Life & Administrative Services
- Secondary: Counsellor, Head of Year or Director of Student Life.
As appropriate, and possibly in conjunction with other information, these persons may decide that the concern should be elevated to a Child Protection Report. In such cases, the original member of staff will be asked to provide further information and make a handwritten statement using the Child Protection Reporting Form.
Subsequent actions and procedures will follow the Child Protection Policy.
As an organisation devoted to the education of young people, Chinese International School (CIS) commits itself to the highest ethical standards and seeks to operate without danger, fraud, or other illegal or unethical conduct. There is therefore an expectation that staff conduct themselves with integrity (see Staff Handbook, Professional Standard for Teacher, Code of Conduct) and always prioritise the safeguarding of children. Staff also have a responsibility to report wrongdoing in the workplace or practices that could lead to harm to a child, a colleague, other persons, or the institution itself.
The aims of this policy are four-fold:
- to encourage staff (or other relevant persons) of their responsibility to raise concerns about wrongdoing or dangerous practices within the school;
- to reassure staff that their concerns may be raised without fear of reprisal and with the knowledge that they will be taken seriously;
- to offer protection to staff or other relevant persons who disclose concerns that are:
- based on information that is truthful;
- raised with good intentions to protect children, colleagues, other persons or the school itself;
- and made in accordance with the procedures outlined below;
to outline procedures for raising concerns and explain how the school will respond.
Scope of Policy
This policy applies to all school staff including full-time and part-time, temporary or contract staff, as well as volunteers, individuals undertaking work experience in the school, and all contractors working on school premises.
CIS also encourages other community members or members of the public to bring matters of concern to its attention, in the knowledge that the procedures outlined in this policy, while written with staff in mind, shall also apply.
When Concerns Arise
Employees are often the first to realise that there may be something seriously wrong within an organisation. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimisation. In the circumstances, they may find it easier to ignore the concern rather than report what may be only a suspicion of wrongdoing.
By contrast, CIS seeks to create a climate of honesty, openness and accountability, so that staff with concerns about any aspect of the school will feel comfortable to step forward and voice their concerns, knowing that the school will not overlook well-intentioned reports or disclosures.
All staff are expected to raise their concerns, no matter how small. What may seem like a minor matter by itself may represent a more serious concern together with other information known to relevant members of staff. Members of staff will not be expected to respond to concerns alone or to make a judgement about whether wrongdoing has taken place.
Safeguards for Staff Raising Concerns
- CIS recognises that the decision to raise a concern may be a difficult one and is committed to providing support to the member of staff.
- CIS will treat all such reports in a serious, sensitive and confidential manner. The identity of the member of staff raising the concern will be kept confidential to the extent possible - ie, on a strictly need-to-know basis for people directly involved in the management of the matter only.
- Any harassment or victimisation of, or reprisals against, a member of staff who raises a concern in good faith will not be tolerated.
- Any investigation into the concerns raised will not influence or be influenced by any disciplinary, contractual, or performance review proceedings involving the relevant member of staff.
Anonymous Disclosures or Allegations
Concerns raised anonymously are typically less powerful than those made with attribution, and a member of staff raising a concern is encouraged to put his or her name to such disclosure.
Disclosures or allegations made anonymously will need to be investigated at the school’s discretion, taking into account:
- the seriousness of the concern raised;
- the credibility of the concern;
- the likelihood of confirming the allegation from alternative credible sources.
If a member of staff raises a concern in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. If, however, the investigation shows that an individual has made a frivolous, ill-intentioned, or malicious allegation, or persists in making such allegations, disciplinary action may be taken.
Step 1: Raising a Concern
A member of staff should raise concerns to his or her Head of School, the relevant Head of Primary/Secondary or Director/Deputy Director of Hangzhou CIS, or another member of the school Leadership Team.
- If concerns involve the Head of School, the report should be made to the Chair or Vice-Chair of the Board of Governors.
- If concerns involve the Board of Governors, the report should be made to the Head of School.
- If the member of staff feels they cannot express their concerns within the school, it is open to them to raise their concerns with the Hong Kong Education Bureau, or other relevant local authorities.
Step 2: Response & Initial Fact-Finding
The school leader receiving the report should:
- Take steps to secure the immediate physical safety of students or other persons, if that is a concern. If the matter is deemed to be a child protection issue, prompt action should be taken as per the Child Protection Policy.
- Take steps to gather basic information regarding the concern, such as the background and history of the concern; specific observations giving names, dates, and places where possible; and reasons for concern, either by asking the member of staff to provide a written statement or by taking notes of a verbal report.
- As appropriate, bring the concern to the attention of the Head of School, Director of Finance & Business Administration, full Leadership Team, or Chair or Vice-Chair of the Board of Governors.
- As necessary, immediately report the matter to relevant local authorities, such as the Police or Social Welfare Department.
At this stage concerns/allegations are neither accepted nor rejected.
Step 3: Investigation & Outcomes
The relevant school leaders will determine whether an investigation or other plan of action is required. The matter should be dealt with as expeditiously as possible. All reasonable steps should be taken to protect the confidentiality of the member of staff raising the concern unless the individual waives the right to confidentiality, or it is deemed that the nature of the concern raised makes confidentiality incompatible with fair disciplinary proceedings. In such cases, the individual should be informed that no further action can be taken without his or her agreement to waive the right to confidentiality.
The school may, at any point, seek advice on the disclosure process from an external consultant or legal counsel. In the case of fraud or financial irregularity, the matter may require reporting to the police.
In all cases, a point person should be designated to respond to the individual who raised the original concern. Within a maximum of 5 to 10 working days, the individual should receive a written acknowledgment of receipt of the concern, how the concern has been addressed, and an estimate of how long it may take to provide a final response.
The individual should also be kept clearly informed:
- of any next steps in which he or she may be involved, such as disciplinary or criminal proceedings that may require the individual to give a written statement, give evidence at a hearing, be publicly identified, etc.;
- of support that is available (eg, the ability to nominate a person not involved in the work area to which the concern relates to being present when providing a further statement);
- about whether the concern is ultimately deemed to be with or without substance or merit, although depending upon the nature of the concern it may not be possible to inform the individual of the outcome of any investigation;
- If, on preliminary examination, the concern is judged to be wholly without substance or merit, it will be dismissed. A record of the allegation will be kept on file.
- If it is judged that a case may exist, an appropriate investigation will be undertaken and a report produced, in accordance with the school’s Procedures for Managing Allegations. Accurate information relating to any subsequent investigation will be retained securely and where allegations have been proven to be unfounded, this will be clearly recorded. All disclosure cases must be reported, in a general way, to the Board of Governors.
- As a result of a complaint or concern raised by a member of staff, student, or another person, it may be necessary for the school to take disciplinary action against the staff member about whom the complaint is made. Disciplinary consequences will depend on the particular facts of each case and the school has absolute discretion to discipline any member of staff in any way it considers appropriate given the circumstances.
- Any reprisals against or victimisation of the member of staff raising a concern in good faith will be treated by the school as a serious disciplinary matter.
Taking the Matter Further
If no action is to be taken, and/or the member of staff is not satisfied with the handling of the concern, the individual may make a complaint under the school’s Grievance Policy.
An allegation (in this policy) refers to any concern that an adult working in the school has about another member of the CIS Staff or Community (including service vendors), who has:
a) harmed or abused a child, including physical, emotional, or sexual harm or abuse, exploitation, and neglect.
b) behaved in a way that could constitute a criminal offence towards or related to a child; or
c) behaved in a way that indicates they are not suitable to work with children.
This applies to any child the member of staff/volunteer has contact with in their personal, professional or community life.
Responding to an Allegation
Deliberately invented or malicious allegations are extremely rare. Anonymous allegations and allegations that are seen as malicious should be examined carefully and never dismissed based on the anonymity or perceived motivation of the referrer.
Responders for concerns involving staff leaders should always respond to an allegation, no matter how well respected or senior the alleged perpetrator, or how challenging or ‘troublesome’ the victim may be perceived to be.
In the case of the written disclosure of non-recent abuse, the response should be prompt and personal, avoiding a legal tone.
Surfacing of Allegations
An allegation describing or implying inappropriate behaviour (including bullying and harassment) by an adult (if an allegation is about a student, please refer to the Child Protection Policy and the Peer Abuse Policy) – may come to light in a number of ways, including:
- a written statement from the victim or another member of the school community (including students, alumni, current and former staff, or parents),
- written information may also be received via a social media post, an alumni questionnaire, or the monitoring of staff and student information services;
- a verbal or non-verbal (such as through play) disclosure or partial disclosure from the victim or another member of the school community (including students, alumni, current and former staff, or parents);
- a report to the school by a member of the public, or an external agency such as the police or health authorities;
- or a legal claim.
School leaders should always respond to an allegation, no matter how ‘well respected’ or senior the alleged perpetrator, or how ‘challenging’ or ‘troublesome’ the victim may be perceived to be. Deliberately invented or malicious allegations are extremely rare. Anonymous allegations and allegations that are seen as ‘malicious’ should be examined carefully and never dismissed based on the anonymity or perceived motivation of the referrer.
A Trauma-Informed Approach
When a child discloses that they or another child is being or has been abused or harmed, adopt a trauma-informed approach. A trauma-informed approach is a counseling method that:
- realises the widespread impact of trauma;
- understands potential paths for recovery;
- recognises the signs and symptoms of trauma in clients, families, staff, and others;
- responds by fully integrating knowledge about trauma into policies, procedures, and practices;
- and actively works to prevent re-traumatisation.
- Take any urgent actions needed to protect the child from imminent risk of harm. This may include emergency services to undertake a medical examination. (Be mindful of cultural sensitivities.)
- Report the allegation immediately to the Head of School/Head of Primary, or Head of School/Head of Secondary, or Head of School//Director of Hangzhou CIS, and the appropriate CPO.
- If the allegation involves the Head of School, report the allegation immediately to the Director of Finance and Business Administration.
Record the allegation as soon as possible.
Questioning should be limited to critical information in order to determine:
- the basic facts (Where and when did the incident take place? Which adult was involved?);
- the immediate safety of the child (Will the child encounter the alleged perpetrator within the next hour?);
- if the child needs immediate psychological or physical medical attention.
If the child is not forthcoming,
- ask if they would like to speak to another adult with whom they may feel more comfortable, such as a school counselor.
- ask open-ended, non-leading questions to facilitate disclosure, determine the well-being of the individual, and provide support.
- stay calm and show no signs of shock;
- listen and respond with empathy in a non-judgmental and open way;
- consider the disclosure seriously;
- remain calm, supportive, and reassuring;
- validate the child’s feelings;
- explain what you need to do (report to the appropriate senior member of staff) and why;
- allow the child control when feasible;
- consider the child’s language needs and whether support in another language is necessary;
- reassure the child that they have done the right thing in coming forward; and
- take notes and make a record as soon as possible following the disclosure.
- view images of children (rather ask for a brief description and secure a device as possible evidence for law enforcement);
- ask leading or unnecessary questions, or provide language for the child, if it is necessary to interview them;
- take notes during the disclosure;
- make promises that may not be able to be honoured (such as promising you won’t tell anyone or that this will never happen again);
- suggest that the child may be to blame in any way for what happened; or
- ask the child to wait until another person can be present to witness the disclosure.
Any member of staff who becomes aware of an allegation should make a record as soon as possible including:
- time, day of the week, date, and location of the disclosure/discovery;
- identity of the child and alleged perpetrator;
- details of the demeanour and behaviour;
- who it was reported to; and
- the name of the person making the report.
When documenting a child’s disclosure, record the statement using the child’s own words as soon as possible following the disclosure. Sign and date the record. Any additions or changes should be added to the initial record without altering the original.
Consider, in consultation with legal advisers where necessary, whether any external agencies need to be informed (see external reporting).
Consider seeking early legal advice from a law firm with experience handling child abuse cases before taking any further steps. Where it is not possible to identify a specialist local law firm, you may need to confer with an international law firm that has expertise in handling child abuse allegations, in addition to a local law firm that has expertise in local law.
Seeking early legal advice will help you to understand and comply with mandatory reporting obligations and other legal obligations, such as those pertaining to the rights of the alleged perpetrator.
The Deputy Head of School/Head of Primary, or the Deputy Head of School/Head of Secondary, or the Deputy Head of School/Director of Hangzhou CIS will lead the school’s response to the allegation.
Assessing risk and preserving evidence
In consultation with the school’s legal advisers and any external agencies, assess immediate risk and preserve evidence. Consider appointing one member of the school’s response team to lead necessary consultations with external agencies and put in place an interim risk assessment protecting children from further potential harm by the alleged perpetrator until they can be informed of the allegation.
Any steps taken to preserve evidence should, where possible, be taken in consultation with the school’s legal advisers and any external agencies. It may be necessary to involve the IT manager from an early stage to ensure the preservation of evidence. For example, this could involve removing the alleged perpetrator’s access to school systems prior to notifying them of the allegation or preserving the alleged perpetrator’s email and other digital accounts prior to restricting access.
Once access is restricted, offline systems and devices should not be investigated by IT personnel. It may also be necessary to secure personal school-provided devices (such as those of the alleged perpetrator and/or victim), but do not attempt to search or view images. Any devices that are secured should be shut down completely and immediately placed in a secure area. To prevent material from being deleted from the device after being secured (for example, via the cloud), devices can be placed in a lead-lined safe or, where one is not available, wrapped in aluminum foil. Provide the evidence to any external agency or to the person conducting an inquiry.
When assessing risk ask these questions
- Did the alleged abuse occur on school property?
- Is the alleged perpetrator in a position of trust or power? What is their role in the community?
- When will the alleged perpetrator next encounter children (including their own), and will they be alone with the children? Is there a possibility that the alleged perpetrator will be alone with a child in an isolated area or in a room without windows?
- Can contact with children be cancelled without tipping off the alleged perpetrator? If not, what measures can be put in place to increase supervision and minimise any one-to-one contact until the alleged perpetrator can be informed?
- Was the abuse carried out on school devices? What immediate steps should be taken to secure those devices? Can the school's IT manager shut down the alleged perpetrator’s access to the school's system without raising suspicions?
- Does the alleged perpetrator have any children at the school or a spouse working at the school? How should this be managed going forwards?
- Does the alleged perpetrator have access to children at home or in their community?
CIS will always consider, in consultation with its legal advisers, whether there is a need to report to and engage external agencies. Apart from complying with the legal requirement of reporting some specific types of cases to the local government agencies including the Social Welfare Department, the Education Bureau, or the police, proactive reporting and transparency can lead to additional support and may protect the integrity of a criminal investigation related to evidence gathering and admissibility. In borderline cases, the school should always err on the side of caution and consult with local police or other agencies as to whether or not you should make a report. Where the local agencies do not engage, schools may be able to reach out to the police and/or government agencies from the country of origin of the alleged perpetrator or children concerned, depending on their nationality. In some cases, a victim and/or their parents may ask or instruct the school not to report the allegation to any external agency and not to share the details of the allegation with anyone. This should not deter reporting.
Inform CIS immediately if there is any request from the local government agencies or the police to make a statement or provide details of the incident, as legal representation may be required to ensure the most suitable assistance is provided to the agencies and police during their investigation of the incident.
Initial evaluation of allegation
Depending on the nature of the allegation and the school’s external agencies’ thresholds, it may be necessary to take some preliminary steps to evaluate the allegation prior to deciding on a course of action. These steps should only be taken after obtaining legal advice, as above, and may include, for example, reviewing the personnel files and child protection records, and contacting referees and teachers where the alleged perpetrator may have previously taught.
Ongoing Safeguarding Plan for the Victim
Identify the child’s needs and put in place a safety plan to support the child and family, which should:
- include any relevant information about the background of the child, including, for example, their home background and any mental health needs;
- involve the child and the child’s parents (assuming there are no legitimate reasons not to, such as where doing so would put the child at risk of harm) in preparing the safety plan.
- what the child wants to happen and who the child would like to be supported by, both inside and outside school;
- what language the child feels most comfortable communicating in and how the school can accommodate this; and
- how the parents and wider community might respond, considering the cultural or religious context, and what steps can be taken to mitigate and/or protect the child from any harmful responses;
Consult with and draw upon the support provided by external agencies and any other organisations or experts.
- Consider whether any targeted interventions are needed to address any wider safeguarding issues, mental health needs, or trauma;
- assess the risks that are faced by the child (for example, emanating from the abuse or wider safeguarding issues).
The plan may involve:
- appointing a trusted member of staff to support the child;
- asking the child’s teachers to be accommodating to the child’s needs and to make allowances where necessary;
- facilitating the delivery of health (including sexual and mental health) services and additional educational support;
- providing the child with information about further services;
- considering other forms of redress, which are set out below;
Consider how to build on strengths and positive aspects that the child possesses and/or is exposed to through trusting relationships with the child’s family, other students, or staff;
Set out the steps needed to implement the safety plan, and review the plan at regular intervals to ensure that real progress is being made which benefits the child.
Prevent further harm
Determine, in consultation with legal advisers and any external agencies, how to identify and protect any further victims within or outside the school community (locally or in other countries), including children or dependents of the alleged perpetrator.
Communication to staff, parents, and children at the appropriate time (to the extent possible and appropriate) about the allegation and encouraging them to share any concerns with a named adult can, in some circumstances, can be a good way to encourage individuals to come forward.
Legal advisers and any external agencies should be consulted prior to any communications being sent, and the school should consider consulting with a communications advisor regarding the communications and any media inquiries/responses.
Information sharing and communications
Inform the Chair of the Board and decide who else needs to be informed, ensuring no facts are disclosed, which would hinder any future investigation or inquiry or violate data protection or an employee or student rights. The response team leader should regularly update the Board Chair (or another Board member as appropriate) on all material developments.
Appoint one person from the school’s response team to be responsible for communications. Make sure they are aware of all the facts and that they keep this information confidential and secure until it needs to be communicated. It is important that confidentiality is maintained. It is helpful to consider how to manage speculation, leaks and gossip. No information should be offered to the media nor should any details be published that would identify any person under investigation, unless or until the person has been charged with an offence.
Decide whether any other external body needs to be informed at this time, such as any inspection, accreditation, regulatory, or insurance bodies. Decide what information should be provided, how it should be provided, and what should/can be done to protect confidentiality.
Consult with the school’s legal advisers and any external agencies prior to any communication being sent, including any communication to the victim and their family, the alleged perpetrator, staff, the wider school community, and/or the media.
Develop a set of talking points and, where possible and appropriate, seek input from relevant members of the school’s response team, the school’s legal advisers, any external agencies, and possibly a communications advisor. Make sure that what you communicate is consistent with any legal restrictions, such as privacy rights and defamation laws.
The person responsible for communications should begin to find answers to the following questions, with input from the Response Team Leader:
- Who knows about the allegation? What is the likelihood of the allegation becoming known more widely? What can be done to prepare for the allegation becoming known more widely?
- What should be communicated to the child and their parents at this stage?
- How should the school reassure the child and their parents, other children and the parent body, the alleged perpetrator, the staff, and the wider school community?
Create an incident file that includes a clear and comprehensive summary of the allegation, details of how the allegation was followed up and resolved, and a note of any action taken, and decisions reached. All relevant dates and times, days of the week, summaries of conversations with external agencies and advisers should be included. This should be kept in the confidential personnel file of the accused. The record should be retained at least until the accused has reached normal pension age or for a period of 10 years from the date of the allegation if that is longer.
This file should be kept confidential and secure by the Director of Finance and Business Administration (such as in a locked cabinet or as an encrypted digital file). Access to this file should be limited to a small number of named people (for example, the Head of School, Director of Finance and Business Administration, and Response Team leader). If another person needs to have access to the file they should apply in writing for permission and be prepared to justify their request. A record of the allegation and its outcome should be kept in the adult’s personnel file, even after the alleged perpetrator has left the school.
Consider maintaining a separate file with a short description of all allegations made against adults who work with children, with access restricted to the Head/Principal and another member of senior management.
Record any information relevant to the welfare of a child separately on that child's file.
Decide on a course of action
Investigation by an external agency or inquiry commissioned by the school?
If the police and/or child protection services decline to investigate initially and the school uncovers further evidence that suggests criminal activity, it should report this immediately to the police who may then choose to investigate. Equally, where the police complete an investigation, the school may still need to conduct its own safeguarding inquiry and/or evaluation of suitability.
This is because:
- the police will be working to a criminal threshold, whereas the school must determine if the alleged perpetrator is unsuitable to work with children;
- or the decision not to pursue an investigation or prosecution may be the result of several factors which do not mean that the alleged perpetrator did not do what they are accused of doing, and/or that the alleged perpetrator is necessarily suitable to work with children. These include, for example, lack of evidence, procedural failings, corruption, and a higher standard of evidence for criminal charges.
1. Even if the external agency does not investigate, it is important to ensure that any advice they have provided to the school is followed where possible.
When external agencies do not investigate, or their investigation is inconclusive or unreliable, the school will consider carrying out an inquiry to determine the facts and appropriate actions. The nature and scale of the school’s inquiry will differ significantly according to the specific circumstances of the allegation, any relevant internal policies (for example, child protection, peer abuse, disclosure and/or staff disciplinary policies), and local employment law.
The Response Team will decide (depending on the nature and scale of the allegation) who will conduct the inquiry.
For those conducting the enquiry, the following questions should be considered:
- What further information is required?
- Whether any immediate action needs to be taken to protect pupils
- When and what should the parents be told
- What should be said to the adult facing the allegation?
- Whether suspending the member of staff is required. The reason for suspension must be communicated to the person in writing within one day.
2. The school may wish to conduct an inquiry concurrently to the investigation carried out by the external agency or to conduct one following the investigation.
Sometimes it will be possible to carry out an inquiry without the wider school community becoming aware of the details of the allegation. Other times, members of the wider school community may become aware of the allegation. The inquiry will be interested in evidence that raises concerns about professional misconduct, but also evidence that supports the integrity of the alleged perpetrator.
Outcomes of an enquiry will generally fall into the following categories:
- Substantiated: There is sufficient evidence to prove the allegation.
- False: There is sufficient evidence to disprove the allegation.
- Unsubstantiated: This is not the same as a false allegation. It means that there is insufficient evidence to prove or disprove the allegation. The term, therefore, does not imply guilt or innocence.
- Malicious: There is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive.
In addition, there is a further outcome type (unfounded) which schools may wish to use, after liaison with their HR/legal advisors.
*Unfounded: there is no evidence or proper basis which supports the allegation being made. It might also indicate that the person making the allegation misinterpreted the incident or was mistaken about what they saw. Alternatively, they may not have been aware of all the circumstances.
Evaluation of suitability
Attempt to secure the cooperation of the alleged perpetrator, as this will provide an opportunity to determine their fitness to be around children.
As a finding of professional misconduct can have severe implications for the alleged perpetrator and can lead to a restriction on future practice or termination of employment, it is important that any inquiry is robust and that the various accounts are explored as fully as possible.
If you feel after conducting an inquiry that there is insufficient evidence to make an informed decision, consider engaging an external expert with relevant skills and experience, such as a forensic psychologist, to carry out an evaluation to determine the alleged perpetrator’s suitability to work with children. Conducting an evaluation of suitability to work with children is a highly specialised process requiring in-depth knowledge of alleged perpetrator behaviour and skills to examine fairly what can be sensitive information.
Guiding question: “Is this person suitable to work with children?”
This question must be considered even where a criminal investigation does not proceed.
Evaluating sexually inappropriate behaviour (including bullying and harassment)
A clinical evaluation of suitability with an individual accused of sexually inappropriate behaviour (including bullying and harassment) relies initially upon an exploration of the alleged perpetrator’s account in comparison with the evidence of the victim and others. Then the perspectives and beliefs expressed can be compared with clinical research and insights into those who have admitted sexually abusive behaviour. It is impossible to be conclusive where denial is maintained. The best that such an evaluation of suitability can offer is whether the perceptions and behaviours highlighted are consistent with what would be expected from someone who might behave in a sexually inappropriate manner.
Once a general course of action has been determined, consult with the school’s legal advisers and any relevant external agencies to address the following questions.
How will the school work with external agencies (and not against them)?
Make clear to all involved that the priority is the well-being of any children involved. In many jurisdictions, it is a requirement to inform law enforcement immediately after receipt of child sexual abuse allegations. If an external agency has convened a meeting to discuss the case, decide who from the school will attend and what the school wants to achieve. Determine who in the school will communicate with external agencies and implement the agreed actions.
Will the police or an external agency be coming on-site (for example, to make an arrest or conduct a search)?
If yes, discuss with the police the best approach so as not to cause unnecessary anxiety to the school community. For example, can the police arrest the alleged perpetrator at home or arrive in school in plain clothes and an unmarked vehicle?
When and how should you inform the alleged perpetrator of the allegation?
Although the alleged perpetrator should be informed of the allegation as soon as is reasonably possible, informing them too early could ‘tip-off’ the individual and give them time to destroy evidence. Always seek advice from and consult with the school’s legal advisers and any relevant external agencies before informing the alleged perpetrator.
How should you communicate with and support the alleged perpetrator?
The incidence of suicide amongst individuals who are the subject of allegations is high.
Depending on the jurisdiction and location of the school, local law enforcement may be responsible for a suicide strategy and offender welfare. In addition to liaising with the external agencies where appropriate, be open and transparent with the alleged perpetrator at the appropriate time, explaining the nature of the allegations, the process that will be followed, and the possible consequences. Take care that the alleged perpetrator has a good support system. If relevant, provide support to the alleged perpetrator’s family. Refer them to counseling and advise them to seek independent legal or trade union representation.
Appoint someone in school to be their point of contact. This person should not have a role in the investigation and should be independent of it. Keep them informed of developments in the process.
Is immediate dismissal and referral to any competent national authorities appropriate?
There are often clear child protection, communications, and reputational advantages to immediate dismissal. However, this decision should only ever be taken where appropriate in light of the evidence and the school’s duty to the alleged perpetrator. Seek advice from local employment lawyers to understand the legal, regulatory, and reputational risks involved.
Should you suspend the alleged perpetrator, with or without pay, pending the outcome of an investigation by an external agency or an inquiry commissioned by the school?
Subject to local law, it may be appropriate to suspend the alleged perpetrator if their continued presence in the school is (i) necessary to protect children, (ii) potentially putting children at risk, (iii) likely to influence an investigation or inquiry, or (iv) necessary to maintain confidence in the school. Where the alleged perpetrator is suspended, their keys and laptop should be secured and access to the school server cut off. Consider what the suspended alleged perpetrator is able to communicate and what the school should communicate to their community about their absence. Where the alleged perpetrator is to have a continued presence in the school, carry out a written assessment of the risks and agreed strategies for minimising the risks. This would need to take account of the fact that children can be accessed within a school even when it is not in the alleged perpetrator’s day to day duties. Continued presence would need to be based on a very clear and justifiable risk management plan.
What actions should the school take if the alleged perpetrator resigns?
The school should inform any external agencies involved in investigating the allegation. The investigation should continue despite the resignation so that it can determine the facts as far as possible and reach a conclusion.
This will enable the school:
- to refer the alleged perpetrator to any competent local or national authorities, including in the country where the school is located but also in the alleged perpetrator’s country of origin (see reporting obligations);
- to disclose details of the allegations and investigation findings in any reference (subject to local law, see providing references);
- to take action to protect against future abuse; and
- to maintain credibility in the school community.
- If police are involved and investigating, they will notify international law enforcement partners as required. Seek legal advice regarding the school’s obligation to report the allegations and findings to potential future employers in any jurisdiction.
Important points to remember
- Never agree with the alleged perpetrator that they can ‘leave quietly’. It is not acceptable under any circumstances to sign a confidentiality or nondisclosure agreement or to enter into a settlement agreement where that agreement prevents the school from completing an investigation, reporting the allegation to external agencies, or disclosing details of the allegation in a reference.
- Do not facilitate the alleged perpetrator’s travel out of the country when they are the subject of an inquiry or under investigation.
- Do not encourage the alleged perpetrator to resign.
- Do not undertake non-renewal of the alleged perpetrator’s contract as a means of removing the problem. Schools may consider these actions as easy solutions, but in fact, they may put other children at risk of serious harm and transfer the problem to another school. The school’s reputation could be at risk if abuse is uncovered later, and it comes to light that the school did not act appropriately or acted unfairly to an innocent member of staff who may be subject to rumour and gossip which in turn may damage their career.
- Allow staff to talk about the situation when they need to in appropriate settings.
- Show strong leadership to continue school life as normally as possible.
- Schedule specialist sessions with small groups of staff to help them to process their emotions and answer questions from children.
- Build trust with informal check-ins.
- Offer one-to-one sessions with clinical psychologists to any staff who feel particularly affected by the allegation.
- Reduce workload or allow time off for staff who are particularly affected by the allegation.
- Update staff on developments where possible and appropriate and debrief staff once any investigation and/or safeguarding inquiry is complete. Consult with legal advisers about what can and cannot be communicated.
Protect the victim and their family. The safety plan set out above should be regularly reviewed so that the school can continue to support the victim and their family for the duration of the child’s time at the school and, in some cases, after the child has left the school.
Protect any additional victims who come forward. Treat them in the same manner as any previous victims. Provide appropriate interventions and support for any victims who come forward. Meet with victims and their families so they can explain their experiences first-hand.
Protect other children in the school. Implement any immediate changes to the school’s systems and policies which the allegation has shown to be deficient (for example, supervision of children on school trips, choice of activity providers). Consider delivering small group sessions in an age-appropriate way to address specific educational needs. For example, if the abuse involved children exchanging indecent images of themselves with an adult, sessions addressing this issue are needed.
Protect and support staff. Allegations of abuse can be traumatic for the school community and can create a tense working environment for staff. In addition, staff may be experiencing a range of powerful emotions including guilt, disgust, anger, fear, and deep sadness. At the same time, they are often expected to support any children, families, or colleagues who may have been directly involved.
Making a decision
Where the school’s inquiry is complete, or where the external agency provides sufficient information to enable the school to make a decision on the alleged perpetrator’s employment, the school needs to decide what action to take, consulting with legal advisers and following the school’s staff disciplinary, child protection, peer abuse, disclosure, and safeguarding policies. This may take the form of a disciplinary hearing. The person selected to hold any hearing should typically not have been involved in managing the allegation previously and should hold a senior management position or be a governor. Ordinarily, the Head/Principal or a governor/trustee will hold the hearing. As set out above, the principles of natural justice should be followed, which require the details of the allegation to be provided to the alleged perpetrator who should be given the opportunity to put forward a defence and should be provided with a right of appeal. Where the person holding the hearing finds that the individual poses a risk to children, their contract should be terminated. Subject to legal advice and the school’s policies, this should normally be by way of dismissal.
Reporting obligations when an individual is dismissed for child protection reasons
CIS will always consider, in consultation with its legal advisers, whether there is a need to report to and engage external agencies. Apart from complying with the legal requirement of reporting some specific types of cases to the local government agencies including the Social Welfare Department, the Education Bureau, or the police, proactive reporting and transparency can lead to additional support and may protect the integrity of a criminal investigation related to evidence gathering and admissibility.
Providing references for the alleged perpetrator
Failing to properly disclose the findings of the investigation and reasons for dismissal in a reference could place a child at risk in the future. It could also subject the school to a claim for negligent misrepresentation by the subsequent school employing the individual. Similarly, it could also result in significant reputational damage, as the accurate perception would be that the school is passing along to the next school an employee who poses a risk to students.
At the same time, schools should be mindful of their obligation not to defame individuals in references or to violate their privacy rights. Typically, the truth is a defence to a defamation claim, but the ‘truth’ is subject to dispute in litigation. Local law differs significantly on these issues and the school should always seek advice from legal counsel familiar with local and national laws and, when in doubt, approval from the school’s insurer, before providing a reference in this context.
Reinstating and managing the reintegration of an alleged perpetrator
An individual should be reinstated only when the school is confident that they do not pose a risk of harm to children. It follows that there should not be restrictions placed on the individual’s access to children post reinstatement. Training on issues like professional boundaries and monitoring post-reinstatement may be needed to ensure, for example, that any breaches of the staff code of conduct are not repeated. Where the adult has been absent from work and/or where the allegation is widely known, consider how to communicate their return and how to support their return to work and the community.
Shared leadership between schools requires forthright and honest communications, including accurate factual references, free from conjecture, which demonstrates that student safety and wellbeing is paramount.
Responding to legal action against the school
If an adult abuses a student at the school, it is possible that the child and/or their family may file a lawsuit against the school. Any employer can in certain circumstances be liable for the actions of its employees or of people akin to employees (such as governors or volunteers). The law in this area is complex and it would be prudent for a school faced with a possible civil claim to seek legal advice at an early stage. School insurance policies ordinarily cover such claims (subject to an excess/deductible). While the insurer will usually appoint one of its panel lawyers to act, the school should establish at the outset the scope of the lawyer's role, the school’s rights to information and to participate in decisions as a client, and the lawyer's approach to abuse litigation. Work with the school’s insurer and law firm to ensure that they run the claims in a way that the school is comfortable with, including issues such as liability, limitation periods, apologies, and settlement agreements.
For more information, please see the resources section.
The school may also face legal action from the alleged perpetrator. While you should be aware of the risk that the alleged perpetrator could file a claim for unfair/wrongful dismissal and/or defamation, the more important obligation is the school’s duty to protect children. Understand the school’s potential liability under local employment and privacy law, review the school’s current insurance coverage, and promptly notify the insurance carrier about any potential claim. But do not allow the threat of a claim to deter further action, such as conducting an inquiry or an external assessment.
Following an Allegation
Debriefing and safeguarding review
Review the school’s handling of the allegation with the allegations management team, identifying any weaknesses in the school’s systems, understanding what can be done better or differently in the future, and revising procedures and training accordingly.
This can be done internally with different parties reflecting on lessons learned and recommending actions for the future. In some instances, you may wish to commission a formal review or audit to review the incident and improve practice. There are many different types of review available and the school should consider advance references carefully before contracting with a specialist to conduct the review. If the review team is going to interview children, victims, or possible victims of abuse, then their team should include a child protection specialist with experience and training in interviewing victims of abuse, to avoid any re-traumatisation. Factors including the number of interviewers, gender balance, neutrality, the age of the alleged victim, language considerations, cultural sensitivities, religious concerns, and others will be considered. The Head of School will have final decision-making authority on these matters.
Redress for victims
Consult with victims and other individuals affected by the abuse.
Discuss steps that the school can take to provide redress to individuals. Some options include:
- the opportunity to participate in an external review;
- the opportunity to tell their story and discuss their experience privately with members of the school board or leadership team;
- the opportunity to be involved in strengthening the school's procedures going forwards;
- setting up memorial lectures;
- funding research into organisational abuse; and
- internal review of honors or awards given to the offender, such as named buildings, scholarships, etc, including whether to withdraw them.
- Has the incident highlighted any training needs for staff, parents, or children?
- Did the allegation reveal inadequate boundaries between children and adults in the school?
- Did children, staff, or parents have concerns about the adult, and did they raise these with anyone? If so, how were these concerns dealt with? If not, why not? How can a safer culture be created for disclosing concerns?
- How was the adult recruited? Can safer practices in the recruitment process be implemented?
- How did the adult gain access to the victims and are there lessons to be learned?
- How did the school support and care for the victims and was this appropriate? Could more have been done?
- Has the incident highlighted any weaknesses in the school's systems or procedures (such as transports, the physical layout of buildings, or trips approval process)?
- Managing Allegations of Child Abuse by Educators and Other Adults Protocol for International Schools September 2018 (International Task Force on Child Protection Guidelines)
- ITFCP Statement of Commitment to Child Protection)
CIS's programme has been undertaken with extensive training of CIS staff and specialist advice from the Council of International School (COIS) International Taskforce on Child Protection and other child protection professionals. COIS is one of our accrediting bodies.