What Makes a Good Child Safeguarding Policy?

By Stephanie Johnson, LICSW

A vital component of an international school’s infrastructure is the policies and procedures put in place to help ensure student safety. Safeguarding policies are important because they demonstrate an organization’s commitment to keeping children safe, they provide a common set of standards and expectations, and they outline what to do if there is a concern about a child.

A child safeguarding (or child protection) policy is generally one of a cluster of related protocols that outline the approach and actions a school will take to care for the physical and emotional health of its students. This article will focus on the important components of a child safeguarding policy as well as briefly outline related policies that are important to the well-being of the school community.

Defining Child Abuse

A school Safeguarding Policy should start with a definition of child abuse. This definition should be linked to larger statutory guidance and/or international human rights policy. The most common legislation used as a foundation for school safeguarding policies is that of the United Nations Convention on the Rights of the Child (UNCRC).

Most child protection policies have a section that describes/defines various types of child maltreatment (i.e., physical, sexual, emotional abuse and neglect) and how to recognize them. This helps provide a common understanding of the signs and symptoms of abuse so that all members of the community can take action if they see possible risks.

It is important, as well, that the school operates in accordance with local laws about child abuse; this should be referenced in the policy. The International Center for Missing and Exploited Children (ICMEC) has a good list of country-specific legislation and can be found here. However, due to variations in country laws, schools may have more comprehensive safeguarding policies than the host country. For example, a school may strongly discourage corporal punishment, and despite the fact that it is permitted in the host country, contact parents who use this form of discipline to discuss alternative approaches.

A good policy is clear, easily understood, and endorsed by all members of the school community. The policy should be approved by the school’s governing body, reviewed on a regular (annual) basis, and be easily located (featured as part of the school’s web page for example).

A school safeguarding policy should not just discuss what to do if a child is harmed. It should also define the school’s commitment to:

Preventing abuse (through education, awareness)
Protecting students from harm (through safe hiring practices, facility safety, etc.)
Supporting students and/or families if a child is harmed (through intervention and/or referral to support agencies)

Supervision

An important component of any school safeguarding policy/procedure is the identification of the person/people in charge of child protection. Schools should have these people/groups identified in their policy:

Designated Safeguarding Lead (DSL) or Chief Child Protection Officer who has oversight and responsibility for child protection. This may be the Head or Director of the school or someone with the organizational power to enforce policy and implement action.
Child Protection Officers that are trained to take reports (often school counsellors or administrators)
Child Safeguarding Committee that meets to discuss implementation of the various components of the overall child protection plan.

While schools differ in who takes these specific roles, it is important that someone is in charge of keeping the safeguarding agenda moving forward and who has time in their schedule designated for this. Some schools identify a Safeguarding Manager who is responsible for making sure child safety is a priority in all areas of the school and remains an ongoing, dynamic part of the school agenda.

Procedures

Child protection procedures should outline what to do if there is a concern about a child and how to make a report of suspected abuse. Within the guidelines for reporting concerns, several areas should be clearly addressed:

Concerns about school staff — There should be a specific mention of what to do when there are concerns about inappropriate behavior towards children by school employees.
Whistleblowing policy — It should be clearly stated that people who report concerns in good faith will not be penalized or discriminated against after making a report.
“Low-level concerns” — A method for people to report concerns that may not rise to the level of abuse but seem questionable or inappropriate. Many perpetrators of abuse violate small boundaries as they establish contact with their victims, so observing and tracking this is important.
Self reporting — A way for staff to report if they do something that differs from standard practice, falls outside the code of conduct, or could be questioned as a safeguarding concern (examples: staff inadvertently finding themselves alone with a student, staff needing to enter a child-only bathroom).
Concerns about administration — There should always be another person accessible to discuss child safeguarding concerns if you are not satisfied with an outcome, or if you have safety concerns about someone in administration.
Past abuse — Disclosures of abuse that took place in the past or concerns about staff or students who are no longer at the school should be taken seriously and acted upon. A perpetrator may be continuing to abuse; a victim of past abuse may still need support. School policy should address how this is managed and integrate it into their reporting process.

Codes of Conduct

It is very important that schools have Codes of Conduct so that all members of the community know the expectations for behavior; it is a key part of the structure on which child safety rests. Staff should know what is/is not permitted in their interaction with students. Students should know the boundaries of behavior in and out of school and the consequences of infractions. Parents should know the school expectations around communication, volunteering, and privacy. This provides a sense of security and containment in schools, which are increasingly complex institutions.

While staff codes of conduct vary from school to school, there are certain components that should be included in all employee expectations:

Sexual contact between adults and students is never acceptable. In some cases, the age difference between upper school students and newly hired teachers or interns is quite small. However, school employees, interns, and external providers are all part of an adult/child power differential that makes sexual or romantic relationships inappropriate.
Staff should avoid being alone with students in areas that are not highly visible. They should not give special treatment or gifts to students.
School staff should not engage on social media with students, unless they are using a platform that is specific to educational instruction.
Staff should never share rooms with students on school trips.
Staff should avoid entering student toilets or changing areas.

What Takes Place When a Safeguarding Concern Is Raised

The exact process for managing a report/concern about child safety often varies from school to school. However, most investigations into child safeguarding include several stages: information gathering, determination of severity, intervention, and documentation. Schools may have more or less involvement in this process depending on the local laws and philosophy of the host country’s child protection agencies.

Information Gathering and Determination of Severity

The first steps in responding to a concern is to gather information to determine the credibility and severity of the concern. This may involve talking to the student(s), family, other teachers, and/or the school nurse. It should include checking to see if concerns have been raised the past. School staff need to determine the exact nature of the concern (physical abuse, bullying, self-harm, etc.), if the concern is an isolated incident or ongoing issue, and whether there is imminent risk to the child.

Selecting the Intervention

The type of intervention selected depends on the severity of the concern; there is a wide range of responses schools can take. It is important to remember that, when it comes to child protection, doing nothing is not an option. Lower level cases often involve increasing support and guidance to the students and families. However in the rare case that a school feels a child is in imminent danger of serious abuse, they might need to contact agencies outside of school support systems.

Here are some possible actions a school might take:

Provide school-based services to the child/family.
Referral to an outside provider (counselor, doctor, etc.).
Contacting local child protection agencies.
In extreme cases, contacting local law enforcement agencies.

Documentation

Keeping a record of concerns and outcomes is a vital part of safeguarding at school. It helps to protect everyone in the school community by demonstrating that concerns are taken seriously, investigated, and acted upon (or determined to be unfounded). Documentation helps determine if there is a consistent pattern of low-level concerns that might signal there is a larger issue taking place. All documentation of safeguarding concerns should be stored in a safe, locked location to protect the privacy and confidentiality of those involved.

A note about confidentiality. It is important during all phases of the investigation that privacy and discretion are upheld. Only people who need to know the information about the allegation should be informed or questioned. However, strict confidentiality cannot always be guaranteed. In most countries, school personnel are mandated reporters, which means they must share information to appropriate people/agencies about a child who is in danger.

Other Policies and Procedures

A child safeguarding policy provides the framework for a school’s commitment to community safety and well-being. Other policies also support this effort and should exist alongside the safeguarding policy. Here are some examples:

Missing Child Policy — Defines procedure in the event a child cannot be located.
Fire/evacuation/emergency procedure — Clear guidelines about what to do in case of emergency in school, including accounting for children, and practice drills.
Student health — Schools should have a comprehensive health care policy for identifying students with health issues, responding to medical emergencies, and addressing acute mental health needs.
Acceptable use policy — Sets guidelines for electronic communication and use. Defines how school information systems can be used and consequences for misuse.
Photography policy — Guidelines for how to protect student safety and privacy in photographs and videos of school life.
Safer recruitment policy — Defines the process the school takes to ensure employees are vetted and safe to work with children.
Attendance — Clarifies attendance policy and response to students with frequent absences.
Anti-bullying policy — Defines what a school does to prevent bullying and address it if it does occur.
Drug and alcohol use policy — Defines rules about drug and/or alcohol use by students and staff and consequences.

In summary, a comprehensive child protection policy and procedure for managing safety concerns should be the cornerstone of a school’s approach to student well-being. A safeguarding policy sits alongside other policies and procedures that clarify the rights and responsibilities of all members of the community. There are many resources to assist organizations in developing good safeguarding policies such as The Council of International Schools and Keeping Children Safe. You can also contact the author at her website.

Stephanie Johnson is a clinical social worker with over 20 years of experience working in international communities around the world. She consults with schools and counsels expats to help build healthy systems and happy lives abroad. She currently lives in Croatia and can be found at http://www.stephaniejohnsonconsulting.com/.