Harrow Beijing Safeguarding Appendices
Appendix 1

Key definitions of Safeguarding and Child protection at HBJ

Pg. 2

Appendix 2

Designated Safeguarding Leadership Team at HBJ

Pg. 3

Appendix 3

Our Safeguarding guiding principles

Pg. 4

Appendix 4

The HBJ Student Support Committee

Pg. 5

Appendix 5

Safeguarding reporting procedure at HBJ

Pg. 6

Appendix 6

E-safetyPg. 8

Appendix 7

Low Level Concern Guidance 2023-24

Pg. 9

Appendix 8

Allegations against Staff or Volunteers report template

Pg.16

Appendix 9

Distance learning Protocol – Code of Conduct

Pg.18

Appendix 10

Level of need threshold 2023

Pg.23

APPLIES TOSLT RESPONSIBILITYLAST UPDATEDREVISIONS: (Reviewer to enter initials & date)

All Staff, Governors, Contractors, Visitors etc.
DSL
Aug 2023
PLY 03.08.2023

Appendix 1
Key definitions of Safeguarding and Child protection at HBJ
Key Terminology
Safeguarding and promoting the welfare of children refers to the process of protecting
children from maltreatment, preventing the impairment of health or development, ensuring thatchildren grow up in circumstances consistent with the provision of safe and effective care andtaking action to enable all children to have the best outcomes.
Child protection refers to the processes undertaken to protect children who have been
identified as suffering, or being at risk of suffering significant harm.
Members of staff refers to all those working for or on behalf of the school, full time or part time,
including contracted staff such as cleaners and kitchen staff, temporary or permanent, in either apaid or voluntary capacity.
Child includes everyone under the age of 18. However, our duty to promote the welfare andhealth and safety applies to all students in our care whether they are under or over the age of18.
Parent refers to birth parents and other adults who are in a parenting role, for example stepparents, guardians, foster carers and adoptive parents.

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Appendix 2
Designated Safeguarding Leadership Team at HBJ
Designated Safeguarding Lead
(Whole School)

Peter Lynch

plynch@harrowbeijing.cn

Deputy Safeguarding Lead (Upper
School)Lee Olsson

lolsson@harrowbeijing.cn

Deputy Safeguarding Lead (Lower
School)Clare Boyden

cboyden@harrowbeijing.cn

Deputy Safeguarding Lead
(Chinese Culture)

Rosemary Zhao

rzhao@harrowbeijing.cn

Deputy Safeguarding Lead
(City Campus)

David Mayers

dmayers@harrowbeijing.cn

Deputy Safeguarding Lead
(City Campus)

Portia Gao

pgao@harrowbeijing.cn

Key safeguarding contacts:
Phil Akerman

Head of Harrow Beijing

pakerman@harrowbeijing.cn

Ahmed Hussain

Nominated Safeguarding Governor

ahussain@aisl-edu.com

Mingzhu Wei

Bilingual School Counsellor

mwei@harrowbeijing.cn

Samantha Sys

School Counsellor

ssys@harrowbeijing.cn

Imogen Dunhill

Safeguarding Support Officer

idunhill@harrowbeijing.cn

EXTERNAL CONTACTS:
Tim Gerrish OBE

International Child Protection Advisor

tim@icpa.co.uk

Council of International Schools: Safeguarding

info@cois.org

SRE in Schools

susie.march@live.com

Local Police Service

Contact
Culture):Government Offices and Agencies

via

DSL

(Chinese

Contact GA officeMarie Stopes: Beijing

www.mariestopes.org.cn

National Embassies in Beijing

As appropriate via website

Save the Children (Beijing)

public@chinadevelopmentbrief.cn

NSPCC (UK)+44 (0)800 800 500

Olivia’s Place (Elliott’s Corner)

Tel: +86 (0)10 6461 6283

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Appendix 3
Our safeguarding guiding principles
Core safeguarding principles
The School’s core safeguarding principles are:
•
•
•

•

Safeguarding children is everyone’s responsibility.
Listening to Children and to all members of the community is fundamental tosafeguarding and is in the best interest of the child
Harrow Beijing school is committed to a ‘speak up culture’ and believes in the notionthat if you see something or sense something then you should say something – noconcern is considered too small.
All staff must have the attitude of ‘it could happen here’ with regard to safeguarding.

1.4.2: Core operational principles•

All staff have a responsibility for the implementation of this policy;•

Any concerns regarding safeguarding and/or child protection must be reported using
the safeguarding reporting procedure on MyConcern as soon as practicable andwithin 6 hours.

•

Any concerns where a child is at an immediate risk of harm or has disclosed abuseshould be reported immediately to DSL or, when unavailable, a member of the DSL
Team and followed up with a MyConcern Report as soon as practicable and within 6hours.

•

If a crime has been committed, it should be reported to the DSL or, when unavailable,
the DSL team immediately and followed up with a MyConcern Report as soon aspracticable and within 6 hours.

•

All staff must know who the members of the Designated Safeguarding Leadership
Team are;•All safeguarding and child protection concerns must be treated in the utmost
confidence;•

The DSL Team must report all concerns in line with the requirements of the People’s
Republic of China and in line with best practice as defined in the UK4

Appendix 4
The HBJ Student Support Committee
In addition to the DSL Team, the following member of staff is a sitting member of thesafeguarding committee:
Dr. James Rupasinha

Senior Educational Psychologist

The chair-person of the safeguarding committee is the Designated Safeguarding Lead – Peter
Lynch.

The HBJ Student Support Committee
•
•

•

•

•
•

will be chaired by the DSL
membership comprises the DSL Team namely, but not exclusive to, the DDSLs,
Educational Psychologist, who will review or raise Child Protection or Safeguarding
issues as part of their work;
will help to coordinate arrangements for the longer-term protection and support ofeach child who has made allegations of abuse, or is alleged to have suffered fromabuse, taking his/her wishes into account;
will make arrangements where feasible for any child who has been the subject ofabuse to receive necessary counselling and support by agreement with his parents,
where appropriate;
will support any child who is subject to a Child Protection Plan; andwill ensure through a House Leader / Tutor / Class Teacher that appropriate supportand safeguards are in place together with a Care Plan where appropriate.

Functions of the Student Support Committee
•

•

•
•

Communication: to work with all stakeholders in communicating the needs of thechild, focusing on ensuring student physical and mental well-being and safety. To
maintain a flow of information into the committee about the different needs ofstudents and the flow of information out to different stakeholders about supporting
those needs.
Discussion: the scope and scale of the committee will involve different staff at
different times depending on the agenda. The professionals consider a 360
review of the child. The committee will also review and agree referrals to theschool counsellors.
Administration: to work with all stakeholders in keeping all relevant material, notes
and documents relating to the work the SSC does.
Support and guidance: to design and implement support plans and provide
guidance for students that are a safeguarding concern.

5Appendix 5
Safeguarding reporting procedure at HBJ
What to do if you have a safeguarding concern about a child
There will be occasions when a member of staff may suspect that a child may be at risk, buthave no ‘real’ evidence. The child’s behaviour may have changed, his actions may reveal
confusion or distress, or physical but inconclusive signs may have been noticed. The child may
have a sign or their behaviour may indicate possible abuse. In this circumstance, where thechild is NOT at immediate or significant risk of harm, the following action should be takenby the member of staff:

Harrow International School Beijing Safeguarding Concern Reporting
Procedure
Staff member is concerned about a child’s physical and emotional wellbeing due toa sign/symptom/evidence.
Staff member should log in to MyConcern (available from the Staff Portal)• This should be done as soon as practicable and BEFORE the child leaves
school that day.
Once logged in to MyConcern the staff member should:• Click on ‘Report a Concern’• Complete the ‘Report a Concern’ form
• Click on the orange ‘Submit Concern’ button
Once you have submitted your concern it is immediately delivered to the DSL
Team for their attention and action as appropriate.

It is not the role of staff members to commence their own investigations into safeguarding
concerns. This must be the role of the DSL team. The staff member can, however, provide thechild with an opportunity to talk. This information should then be included in your MyConcern
Report.

What to do if a child discloses abuse or significant harm to you
It takes a lot of courage for a child to disclose that they are being abused. They may feelashamed, particularly if the abuse is sexual; their abuser may have threatened what will
happen if they tell; they may have lost all trust in adults; or they may believe, or have been
told, that the abuse is their own fault.
If a child talks to a member of staff about any risks to their safety or wellbeing, the staff member
will need to let the child know that they must pass the information on – staff are not allowed6

to keep secrets and must never promise to do so. The point at which they tell the child thisis a matter for professional judgement. If they jump in immediately, the student may think thatthey do not want to listen. If left until the very end of the conversation, the child may feel that
he has been misled into revealing more than he would have otherwise.
During their conversations with the children members of staff will:
Don’t

Do:
Be accessible and receptive
Listen carefully

React strongly
Jump to conclusions especially about theabuserTake it seriously

Speculate or accuse anybody

Reassure them that they were right to tell
Say what will happen next

Tell them you will keep his secret

Consult immediately with DSL

Ask leading questions

Make a careful record of what was said

Make promises you cannot keep
Stop them from speaking freely
Tell them to stop talking so you can go
and fetch the DSL

In summary, if a child makes a disclosure of abuse and/or significant or possible immediate
harm then the following actions should be taken:

Harrow International School Beijing Safeguarding Concern Reporting
Procedure – Child Disclosure/Significant/Immediate Risk
Staff member should immediately inform a member of the DSL Team in person.

Staff member should provide a verbal summary of the disclosure/significant andimmediate risk along with any evidence.

DSL Team will then take action as appropriate.

Staff member completes MyConcern Report.

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Appendix 6
E-safety
The use of technology has become a significant component of many safeguarding issues.
Child sexual exploitation; radicalisation; sexual predation: technology often provides theplatform that facilitates harm. An effective approach to online safety empowers a school orcollege to protect and educate the whole school or college community in their use oftechnology and establishes mechanisms to identify, intervene in, and escalate any incident
where appropriate.
The breadth of issues classified within online safety is considerable, but can be categorised
into three areas of risk:• content: being exposed to illegal, inappropriate or harmful material; for example,
pornography, fake news, racist or radical and extremist views;• contact: being subjected to harmful online interaction with other users; for example,
commercial advertising as well as adults posing as children or young adults; and• conduct: personal online behaviour that increases the likelihood of, or causes, harm; forexample, making, sending and receiving explicit images, or online bullying.

The School’s e-safety policy is incorporated in the Digital Literacy, E- Safety & IT Access(Student) (HS27), and can be found on the Student Portal. This explains how we try to keep
children safe in School. Cyber-bullying and sexting by children, via texts and emails, will betreated as seriously as any other bullying-type behaviour and will be managed through ouranti-bullying procedures. The following measures are in place to promote e-safety within the
School:•••Digital Literacy, E- Safety & IT Access (Student) (HS27)- protects all parties byclearly stating what is acceptable and what is not. Upper School students who bring
their own devices (BYOD) are expected to sign the digital code of conduct at the startof each academic year and before access can be given to the School’s ICT facilities.
Induction and Education - all children are inducted in appropriate use of the School’s
ICT facilities and other aspects of this policy upon arrival. Subsequently, US House
Tutors remind children at the start of each academic year about their obligations andcode of conduct.
Monitoring -the School will exercise its right to monitor the use of computer systems,
including the monitoring of internet use, interception of e-mails and the deletion of
inappropriate materials at all times. In circumstances where the School believes
unauthorised use of the computer system is, or may be taking place, or the systemise,or may be, being used for unlawful purposes, the School reserves the right to inform
appropriate authorities and provide documentary evidence. The computer network is
owned by the School and may be used by children to advance and extend theirknowledge and understanding.

Members of Staff also receive advice regarding the use of social networking and electronic
communication with children, which follows the guidance given in the document ‘Guidance
for Safer Working Practice for Adults who Work with Children and Young People’ (DfE
March 2009).

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Appendix 7
Low Level Concern Guidance 2023/24(Adapted with Guidance from KCSiE 2023)
Low Level Concern School Statement
At Harrow Beijing Low-level concerns are about a member of staff, supply staff, volunteer orcontractor should be reported as per paragraph 432 KCSIE 2023.
Reports about supply staff and contractors should be notified to their employers, so any
potential patterns of inappropriate behaviour can be identified.
Harrow Beijing will ensure there is an environment where staff are encouraged and feel
confident to self-refer, where, for example, they have found themselves in a situation which
could be misinterpreted, might appear compromising to others, and/or on reflection they
believe they have behaved in such a way that they consider falls below the expected
professional standards.
Low level concerns
At Harrow Beijing, the safety and wellbeing of children and adults in our school is dependent
on the vigilance of all our staff and community and their prompt communication to the DSL or
Head, of any concerns, no matter how small, about any conduct by an adult which causes
you to doubt that adult’s suitability to work with or have access to children. It is to be madeclear that all references in this section to “adult” should be interpreted as meaning any adult(defined above) and any visitor, unless otherwise stated.
Harrow Beijing is conscious of its duty of care to pupils and colleagues and will always act,
including if alerted to the possibility of abuse arising from situations or persons outside theschool setting. The notification and prompt handling of all concerns about adults isfundamental to safeguarding children. It helps to identify and prevent abuse and to protect
adults against misunderstandings or misinterpretations. It also encourages openness, trust
and transparency and it clarifies expected behaviours. At Harrow Beijing those raisingconcerns or reporting allegations in good faith will always be supported, and adults in respectof whom concerns or allegations have been raised will not suffer any detriment unless theconcern or allegation is found to be substantiated.
Code of Conduct
At Harrow Beijing, all staff must behave responsibly and professionally in all dealings withchildren/colleagues and specifically with pupils for whom they have a duty of care. All staff
must follow the procedures set out in our ‘Staff Code of Conduct including the Safeguarding
Policy/KCSiE2023’.
At Harrow Beijing staff should always avoid behaviour which might be misinterpreted byothers. As a result of their knowledge, position and/or the authority invested in their role, alladults working with children and young people are in positions of trust in relation to the young
people in their care. A relationship between a member of staff and a pupil cannot be a
relationship between equals. There is potential for exploitation and harm of vulnerable young
people and all members of staff have a responsibility to ensure that an unequal balance ofpower is not used for personal advantage or gratification. Staff should note that it is anoffence for a person aged 18 or over and in a position of trust to touch a child in a sexual way
or have a sexual relationship with a child, even if the relationship is consensual. A position oftrust could arise even if the member of staff does not teach the child.
Our low-level concern guidance
At Harrow Beijing the aim of the school’s Low-Level Concern Guidance is to facilitate aculture in which the clear values and expected behaviours which are set out in our Staff
Code of Conduct are lived, constantly monitored, and reinforced by all staff. In particular, theintention of this guidance is to:9• Staff at Harrow Beijing to maintain a culture of openness, trust and transparency in which
staff are confident and clear about expected behaviours of themselves and their colleagues,
the delineation of boundaries and reporting lines.
• Staff at Harrow Beijing to ensure they feel empowered to raise any low-level concern,
whether about their own or a colleague’s behaviour, where that behaviour might beconstrued as falling short of the standards set out in our Staff Code of Conduct.
• Staff at Harrow Beijing to provide for responsive, sensitive, and proportionate handling ofsuch concerns when they are raised – maintaining on the one hand confidence that concerns
when raised will be handled promptly and effectively whilst, on the other hand, protecting
staff from false allegations or misunderstandings.
What is a low-level concern?
At Harrow Beijing a low-level concern for this purpose is any concern, no matter how smalland even if no more than a ‘nagging doubt’, that an adult may have acted in a mannerinconsistent with the school’s Code of Conduct or simply – even if not linked to a particular
act or omission – a sense of unease as to the adult’s behaviour particularly towards oraround children.
Low-Level Concerns about self (self-reporting) From time to time an individual may findhim/herself in a situation which might appear compromising to others, or which could be
misconstrued. Equally, an individual may for whatever reason have behaved in a manner
which on reflection he/she considers falls below the standard set out in the Code of Conduct.
Self-reporting in these circumstances is encouraged as it demonstrates both awareness ofthe expected behavioural standards and self-awareness as to the individual’s own actions or
how they could be perceived. As such, the school sees self-reporting of low-level concerns
as an important means of maintaining a culture where everyone aspires to the highest
standards of conduct and behaviour.
Guidance Continued...

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Low-Level Concerns about an adultFrom time to time an individual may notice behaviour or actions in others which leave themconcerned. These are behaviour or actions which fall short of a formal allegation of abuse.
These tend to be behaviours which indicate that our Code of Conduct has not been met. Anysuch concerns can be dealt with as a Low-Level Concern.
What should I do if I have one?
Where a low-level concern exists, it should be reported to the DSL or to the Head as soon asreasonably possible and, in any event, within 24 hours of becoming aware of it (Where theconcern relates to a particular incident). This is done by creating a referral using Harrow
Beijing’s electronic CONFIDE system which can be logged into using MYCONCERN.

CONFIDE™

How will my low-level concern be handled?
The DSL will discuss all low-level concerns s/he receives with the Head as soon as possible
and in any event within 24 hours of becoming aware of it. The Head will, in the first instance,
satisfy him/herself that it is a low-level concern and should not be reclassified as anallegation and dealt with under the appropriate procedure outlined in the safeguarding policy.
The circumstances in which a low-level concern might be reclassified as an allegation are
where:
a) the threshold is met for an allegationb) there is a pattern of low-level concerns which collectively amount to an allegation orc) there is other information which when taken into account leads to an allegation. Where theHead is in any doubt whatsoever, advice will be sought from the Designated Group
Safeguarding Lead and HR and if necessary, on a no-names basis. Having established thatthe concern is low-level, the DSL or Head (with the support of HR) as appropriate will discuss
it with the individual who has raised it and will take any other steps to investigate it asnecessary. Most low-level concerns by their very nature are likely to be minor and will be
dealt with by means of management guidance, training etc.
What records will be kept?
At Harrow Beijing where a low-level concern has been communicated, a confidential record
will be kept in the CONFIDE system which acts as a central file which logs all low-level
concerns. This is necessary to enable any patterns to be identified. However, no record will
be made of the concern on the individual's personnel file (and no mention made in job
references) unless either:a) the concern (or group of concerns) has been reclassified as an allegation as above; orb) the concern (or group of concerns) is sufficiently serious to result in formal action under
the school's grievance, capability, or disciplinary procedure.
Examples of Low-Level Concerns
At Harrow Beijing a low-level concern is any concern that an adult has acted in a way that:• is inconsistent with the staff code of conduct, including inappropriate conduct outside ofwork• doesn’t meet the threshold of harm or is not considered serious enough for the school orcollege to refer to the local authority. Low-level concerns are part of a spectrum of behaviour.
This includes:11• inadvertent or thoughtless behaviour• behaviour that might be considered inappropriate depending on the circumstances• behaviour which is intended to enable abuse. Examples of such behaviour could include:• being over friendly with children• having favourites• adults taking photographs of children on their mobile phone• engaging with a child on a one-to-one basis in a secluded area or behind a closed door •using inappropriate sexualised, intimidating or offensive language
Social Platforms
Staff at Harrow Beijing will not use personal email accounts, social networking sites, mobile
phones or other means of communication to contact children, unless required to do so forprofessional reasons. Please be aware that electronic communication that takes place over aschool network or platform may be subject to periodic monitoring.
Definitions for outcomes of allegation investigations
Substantiated: there is sufficient evidence to prove the allegation
Malicious: there is sufficient evidence to disprove the allegation and there has been adeliberate act to deceive
False: there is sufficient evidence to disprove the allegation
Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation(this does not imply guilt or innocence)
Unfounded: to reflect cases where there is no evidence or proper basis which supports theallegation being madeProcedure for dealing with allegations
In the event of an allegation that meets the criteria above, the headteacher (or Safeguarding
Governor where the headteacher is the subject of the allegation) – the ‘case manager’ – willtake the following steps:
Immediately discuss the allegation with the DSL. Where threshold of significant harm has
been met, the DSL Governor at AISL should be informed. This is to consider the nature,content and context of the allegation and agree a course of action, including whether further
enquiries are necessary to enable a decision on how to proceed, and whether it is necessary
to involve the police. The case manager may, on occasion, consider it necessary to involve
the police before consulting the DSL and Head – for example, if the accused individual isdeemed to be an immediate risk to children or there is evidence of a possible criminal
offence.
Inform the accused individual of the concerns or allegations and likely course of action assoon as possible after speaking to the DSL/Head (and the police or AISL, where necessary).
Where the police and/or AISL are involved, the case manager will only share suchinformation with the individual as has been agreed with those agencies.
Where appropriate (in the circumstances described above), carefully consider whether
suspension of the individual from contact with children at the school is justified or whether
alternative arrangements such as those outlined above can be put in place.
If immediate suspension is considered necessary, agree and record the rationale for thiswith the DSL. The records will include information about the alternatives to suspension thathave been considered, and why they were rejected. Written confirmation of the suspension
will be provided to the individual facing the allegation or concern within 1 working day, andthe individual will be given a named contact at the school and their contact details.
If it is decided that no further action is to be taken in regard to the subject of theallegation or concern, record this decision and the justification for it and agree with the DSL
what information should be put in writing to the individual and by whom, as well as what

12

action should follow both in respect of the individual and those who made the initial
allegation.
If it is decided that further action is needed, take steps as agreed with the DSL to initiate
the appropriate action in school and/or liaise with the police and/or EDB as appropriate.
Provide effective support for the individual facing the allegation or concern, including
appointing a named representative to keep them informed of the progress of the case andconsidering what other support is appropriate.
Inform the parents or carers of the child/children involved about the allegation as soon as
possible if they do not already know (following agreement with the GA/Communications
Department and/or the police, if applicable). The case manager will also inform the parents
or carers of the requirement to maintain confidentiality about any allegations made against
teachers (where this applies) while investigations are ongoing. Any parent or carer who
wishes to have the confidentiality restrictions removed in respect of a teacher will be advised
to seek legal advice.
Keep the parents or carers of the child/children involved informed of the progress of the caseand the outcome, where there is not a criminal prosecution, including the outcome of any
disciplinary process (in confidence).
Make a referral to the ICPC/Interpol/CEOP (or equivalent organisation if non-UK staff) andinform embassy for their country of origin where it is thought that the individual facing theallegation or concern has engaged in conduct that harmed or is likely to harm a child, or if theindividual otherwise poses a risk of harm to a child. All concerns pertaining to local staff
should be reported to the Ministry of Education, the EDB and the police.
All significant safeguarding concerns also need to be shared with DSL of AISL who is obliged
to report it to the Charity Commission.
Early Years
We will inform the Police and any relevant embassy of any allegations of serious harm orabuse by any person living, working, or looking after children at the premises (whether the
allegations relate to harm or abuse committed on the premises or elsewhere), and any action
taken in respect of the allegations.
If the school is made aware that the UK secretary of state has made an interim prohibition
order in respect of a British teacher, we will immediately suspend that individual fromteaching, pending the findings of the investigation by the Teaching Regulation Agency.
TimescalesThis is a guide based on best practice but is subject to outside agencies:• Any cases where it is clear immediately that the allegation is unsubstantiated or
malicious will be resolved within 1 week
• If the nature of an allegation does not require formal disciplinary action, we will
institute appropriate action within 3 working days
• If a disciplinary hearing is required and can be held without further investigation, we
will hold this within 15 working days
Specific actions
Action following a criminal investigation or prosecution
The case manager will discuss with the DSL and DSL (AISL), including disciplinary action, isappropriate and, if so, how to proceed, taking into account information provided by the police
and/or EDB.
Conclusion of a case where the allegation is substantiated13

If the allegation is substantiated and the individual is dismissed or the school ceases to use
their services, or the individual resigns or otherwise ceases to provide their services, thecase manager and the school’s personnel make a referral to:• the ICPC for consideration of whether inclusion on the barred lists is required and UK
embassy (if person is from the UK)• Embassy from country of origin and equivalent of ICPC for non-UK staff• Ministry of Education, the EDB and the police if staff member is Chinese.
If the individual concerned is a member of teaching staff, the case manager and personnel
adviser will discuss with the DSL AISL whether to refer the matter to the Teaching Regulation
Agency (or equivalent in country of origin for staff member) to consider prohibiting theindividual from teaching.
Individuals returning to work after suspension
If it is decided on the conclusion of a case that an individual who has been suspended canreturn to work, the case manager will consider how best to facilitate this.
The case manager will also consider how best to manage the individual’s contact with thechild or children/Staff who made the allegation, if they are still attending the school.
Unsubstantiated or malicious allegations
If an allegation is shown to be deliberately invented, or malicious, the headteacher, or otherappropriate person in the case of an allegation against the head, will consider whether any
disciplinary action is appropriate against the pupil(s)/Staff who made it, or whether the police
should be asked to consider whether action against those who made the allegation might beappropriate, even if they are not a pupil.
Confidentiality
The school will make every effort to maintain confidentiality and guard against unwanted
publicity while an allegation is being investigated or considered.
The case manager will take advice from the DSL/ police and EDB as appropriate, to agree:• Who needs to know about the allegation and what information can be shared• How to manage speculation, leaks and gossip, including how to make parents or
carers of a child/children involved aware of their obligations with respect toconfidentiality• What, if any, information can be reasonably given to the wider community to reduce
speculation• How to manage press interest if, and when, it arises
Record-keeping
The case manager will maintain clear records about any case where the allegation orconcern meets the criteria above and store them on the individual’s confidential personnel
file on CONFIDE for the duration of the case. Such records will include:• A clear and comprehensive summary of the allegation• Details of how the allegation was followed up and resolved• Notes of any action taken and decisions reached (and justification for these, as statedabove)
If an allegation or concern is not found to have been malicious, the school will retain therecords of the case on the individual’s confidential personnel file. We will retain all records
at least until the individual has reached normal pension age, or for 10 years from thedate of the allegation if that is longer.

14

We will retain all records at least until the individual has reached normal pension age, or for
10 years from the date of the allegation if that is longer.
The records of any allegation that is found to be malicious will be deleted from theindividual’s personnel file.
References
When providing employer references, we will not refer to any allegation that has been provento be false, unsubstantiated or malicious, or any history of allegations where all suchallegations have been proven to be false, unsubstantiated or malicious.
Learning lessons
After any cases where the allegations are substantiated, we will review the circumstances of
the case with the DSL AISL to determine whether there are any improvements that we canmake to the school’s procedures or practices to help prevent similar events in the future.
This will include consideration of (as applicable):• Issues arising from the decision to suspend the member of staff• The duration of the suspension• Whether or not the suspension was justified• The use of suspension when the individual is subsequently reinstated. We willconsider how future investigations of a similar nature could be carried out withoutsuspending the individualPete Lynch
Designated Safeguarding Lead 2023
August 2023

15

Appendix 8:
Allegations against Staff or Volunteers report template
Purpose of this report.
− Consider the referral− Share information− Consider the current allegation in the context of any previous allegations or concerns− Determine a way forward and agree actions to be taken by whom and by when.
− Risk assess to enable Safeguarding There are up to three strands in the consideration ofan allegation: ● A police investigation of a possible criminal offence;− Social care enquiries and/or assessment about whether a child is in need of protection orservices;− Consideration by an employer of disciplinary action.
Confidentiality Statement
Those involved are reminded that this is strictly confidential. Discussions should not beshared outside of those who are involved in the investigation unless they form part of theactions in this report. All agencies should develop procedures to ensure that the report isretained in a confidential and appropriately restricted manner. The report will aim to reflectthat all individuals who are discussed should be treated fairly, with respect and without
improper discrimination. All decisions undertaken will be informed by a commitment to equal
opportunities and effective practice issues in relation to race, gender, sexuality, religion anddisability. This report could be shared as part of criminal, civil or disciplinary proceedings, oras part of investigations concerning whether an individual should be barred from working withchildren or vulnerable adults. If further disclosure is felt essential, permission must be soughtfrom the author of the report. The report should not be photocopied or shared without theagreement of the author and must be kept in a restricted or confidential section of the agency
files.
Template –Employer and key people involved in theinvestigation. Name Job Role / Organisation

Chair/Lead:
Date:
Venue:
Minute Taker:
Running Order:
Report 1 - Detail of the concerns/allegations (toinclude current and any previous allegations,details of person/s any historical allegation relate
to-where necessary/appropriate):16

2. How this is relevant to their professionalrole/employment (including volunteering) withchildren:
3. Facts:

4. Risk assessment (consider the safety andwellbeing of child/ren identified):
5. Confirm support to subject (where necessary):
6. Agree feedback mechanism to the referrer(who, what, when):
7. Planning the management of theinvestigation/fact-finding:
8. Strategy for media or other enquiries (ifrelevant):
9. Next Steps / Actions (as Relevant):

10. Outcome: (Substantiated, False, Malicious,
Unfounded, Unsubstantiated)
11. AOB

17

Appendix 9
HBJ Child Safeguarding Policy’ remains in place during all aspects of online learning哈罗北京儿童安全保护政策全面适用于线上学习期间Rationale基本原则In addition to the HBJ Staff Code of Conduct specific guidelines will apply during external online
learning periods.
HBJ Staff should treat all students and colleagues with respect and dignity both face-to-face andonline and provisions should be made by the Learning Support Team for all students to accesslearning platforms and engagement. Wellbeing and Mindfulness approaches of the school community
to be monitored by the ALT, DSL and Phase Leadership Teams.
居家在线学习期间，员工除了须要遵守2023年哈罗北京员工行为准则，还须贯彻以下指导方针。
哈罗北京员工在线上和线下教学中均应尊重所有学生和同事，学术支持团队应为所有学生访问
学习平台及出勤提供支持。学校社区的福祉和关怀由学校高级管理层、儿童安全负责人和各阶
段领导团队负责监督。
Protocol行为规范
● Online communication with students should always be professional and objective but relaxed.
老师与学生的线上交流应始终保持专业、客观和积极轻松的态度。
● HBJ Staff should always maintain a professional relationship with the students whether at school or
not,including during online learning.
无论是否在学校，哈罗北京员工应始终与学生保持专业的关系，包含线上教学期间。
● HBJ Staff should always be vigilant in maintaining their privacy, for example, staff should be
mindful of what is in the background or what is on your screen when screen sharing when you areonline with students.
哈罗北京员工应始终注意保护个人隐私，例如，当您与学生在线共享屏幕时，员工应注意背景
或屏幕上的内容。
● HBJ Staff should ONLY communicate with students through their official school accounts
including @harrowbeijing and Seesaw.
哈罗北京员工仅允许通过学校平台账户（包括@harrowbeijing 和Seesaw）与学生沟通。
● HBJ Staff should always ensure that all communications are transparent and open to scrutiny.
哈罗北京员工应始终确保所有沟通都是透明的，并接受学校的儿童安全监管。
● HBJ Staff should not give our personal contact details to students including e-mail, home or mobile
telephone numbers, unless the need to do so is agreed with the appropriate people or there are
exceptional circumstances (this should be signed off by the appropriate member of SLT and or DSL).
哈罗北京员工不应向学生提供个人联系方式，包括私人邮件、家庭或手机号码，除非有相关人员批准，或有特殊情况(此类情况应由学校高级管理层成员和/或儿童安全负责人签字同意)。
● Communication with students, by whatever method, should take place within clear and explicit &professional boundaries. This includes the wider use of technology such as mobile phones, text
messaging, e-mails, digital cameras, videos, webcams, websites, social networking sites, online
gaming and blogs.

18

无论采用何种方式与学生进行交流，沟通内容都应遵循清晰、明确和专业的原则。此原则也涵
盖如使用手机、短信、电子邮件、数码相机、视频、网络摄像头、网站、社交网站、在线游戏
和博客等情境下。
● When working in one-to-one situations with children and young people every attempt should bemade to ensure the safety and security needs of both staff and students are met.
Pre-arranged meetings with students away from the school premises are ill-advised in every
circumstance unless a welfare visit needs to take place in line with the AISL Harrow Safeguarding
Procedures.
员工在与儿童和青少年一对一工作的情况下，应尽一切努力保障员工和学生的安全需求。
除非依照AISL哈罗学校儿童保护政策，经过相应的授权，否则员工在任何情况下都不允许和学生在校
外会面。
● One-on-one sessions between a teacher and a student are OK. For these sessions online, the student
should be given the option of just using voice (no video).
老师和学生之间可以进行一对一的谈话。线上教学期间，应允许学生仅开启语音（不开启摄像
头）。
● For data protection in line with the Chinese Data Protection Act, all audio/video files should only
be shared within the HBJ school community.
为符合《中华人民共和国数据安全法》中的数据保护政策，所有音频/视频文件只能在哈罗北
京社区内共享。
● When arranging face-to-face sessions with students at least one member of the Leadership Teamshould be invited to each session. All online learning should be accessible to parents through Seesaw.
在安排与学生面对面交谈时，应至少邀请一名学校领导团队成员参与会话。家长可以通过
Seesaw 了解孩子在线学习的情况。
● HBJ Staff should continue to monitor the Social and Emotional health of each student and eachother, and flag any concerns to the SLT and or DSL.
哈罗北京员工应持续关注每名学生及同事的社交和情绪健康，并将可能出现的问题报告给学校
高级管理层成员和/或儿童安全负责人。
● Students who are not engaged in their learning should be flagged with the appropriate Pastoral lead,
DSL and or Head of School.
未参与学习的学生应由相应的德育领导员、儿童安全负责人和/或校长予以标记。
● During online learning, if abuse of any kind is suspected these should be immediately reported to a
Designated Safeguarding Lead in line with our Child Protection Policy.
线上学习期间，如果疑似有任何形式的虐待体罚，应根据我校年儿童安全保护政策立即报告给指定的儿童安全负责人。
References参考
NSPCC Lone Working
CIS Distance/Online Learning Procedures
ICPA Covid-19 Procedures
Pete Lynch
DSL AISL Harrow Beijing哈罗北京儿童安全负责人August 2023

19

Appendix 10
Single Central Record Guidance (SCR) 2023
SENTRY (FebruaryThis guidance has been created with due regard to the following DfE and BSO guidelines:• DfE ‘Keeping children safe in education’ 2023
Statement of Intent
At Harrow Beijing we are committed to promoting the safety and wellbeing of our staff, pupils
and visitors. Ensuring the safety of our school community is of paramount importance and,as a result, these guidelines have been created to establish a more comprehensive safer
recruitment procedure so that pupils feel safe at school.
A SCR (Single Central Record) is required as part of this process as it provides our schoolwith a record of all pre-employment checks, ensuring staff are safe to work in the school andwith children.
To ensure the school is recruiting suitable individuals for a role, employment checks will be
carried out by the Human Resources Team, Administration and the Head, in line with ourschool’s Recruitment and Selection Policy. The checks will include identity checks, right towork overseas checks, varying levels of Criminal Bureau checks/ICPC (depending on therole), as well as extended reference checks including online and social media presence.
These guidelines outline Harrow Beijing’s procedure for maintaining an up-to-date SCR inline with statutory requirements and guidance. It has been written in conjunction with
Keeping Children Safe in Education (2023).
British School Overseas Legal framework
This guidance has due regard to legislation, including, but not limited to the following:• The Data Protection Act 1998
• The General Data Protection Regulation• The Freedom of Information Act 2000
• The Education Act 2002
• The Education (Independent School Standards) Regulations 2014
Roles and responsibilities
The DSL is responsible for:• Ensuring all prospective members of staff and all employed members of staff have therequired level of ICPC checks.
• Deciding whether any prospective member of staff who holds a criminal conviction issuitable to work within the school.
• Informing AISL and the Designated Governor of any decisions made regarding disclosureof information.
• Ensuring the identity of all existing and prospective employees.
The School HR Manager, Head and DSL are responsible for:• Maintaining an up-to-date SCR by updating it upon employment of any member of staff, as
well as recording the identity and background checks made for other visiting staff to school.
• Ensuring any cover teachers, volunteers, contractors and/or any other visiting party toschool hold the relevant level of security check, including a DBS check.
• Analysing whether any members of staff or returning volunteers, contractors or any othervisiting party require an updated ICPC check.
• Ensuring the school obtain legible copies of documentation used to prove workers’ right towork in the UK, e.g. a copy of a passport.
• Ensuring that documentation evidencing workers’ right to work in the UK is up-to-date,especially if visas have an expiry date on them.
• Informing the LA of any decisions made regarding ICPC and other security checks.
• Ensuring that the data stored in the SCR is stored safely.
• Acting in accordance with this policy.

20

Harrow Beijing staff are responsible for:• Providing accurate and up-to-date information required for the SCR so that they cancontinue their employment at school.
• Informing the head of any changes in personal data or additions that need to be made to
the SCR.
Volunteers, contractors and other visiting parties are responsible for:• Providing accurate and up-to-date information required for the SCR, so that they cancontinue their employment at school.
• Informing the head of any changes in personal data or additions that need to be made to
the SCR.
Contents of our SCR
The SCR will detail checks for any member of staff or volunteers who will likely come in tocontact with a pupil. This includes the following:• Full time teachers, supply teachers and trainees• All other school staff, e.g. senior leaders• All members of the governing board• Any other individual likely to work in close proximity to the school’s pupils such as students(including volunteers).
The dates of the checks will be recorded on the school’s SCR in line with statutory
requirements outlined in KSIE 2023 para 129. When employing agency staff from a thirdparty organisation, the school will obtain written notification that the organisation has carriedout all of the relevant checks. The dates of the checks will be recorded on the school’s SCR
in line with statutory requirements outlined in KSIE 2023 para 130. The DSL must ensurethat the individual who presents themselves on their first day of employment is the subject ofall pre-employment checks.
A copy of photographic identification will be obtained and retained in line with data protection
requirements (see KCSIE 2023 para 135). School records will include the following, asdetailed in KCSIE 2023 para 129:• An identity check• A barred list check• An enhanced ICPC check (every 5 years)• A teacher prohibition check• Right to work abroad check• Professional qualifications check• Meet China Visa requirements
Storage
There will be only one copy of the SCR, created using the school electronic SENTRY
platform, which is only accessible to appropriate staff members. The school will not keepcopies of Criminal Bureau certificates (in line with KCSIE) but staff have to be prepared topresent them upon request. The school will keep a legible copy of employees’ evidence for
their right to work in their country of origin, e.g., a copy of their passport, in employees’
personnel files. All other documentation, such as photocopied proof of qualifications, will besafely stored in a secure, electronic personnel file in SENTRY. All certificates will be stored inaccordance with Harrow Beijing’s Data Protection policy.
Monitoring and review
At Harrow Beijing the SCR will be updated after each instance of an individual attending
school in an employment or voluntary capacity, or when any variation to the fields on the
SCR is required. Records kept on school leavers will be destroyed at least 6 months after

21

their departure. The SCR will be reviewed half-termly by the Head and DSL, ensuring all
safety checks are present and up-to-date. This will be reported to the school’s Safeguarding
Governor termly, via the DSL report. The scheduled review date for this guidance is annual
or in line with Harrow Beijing’s safeguarding policies. The Safeguarding Governor will review
the Single Central Record annually as part of the deep dive. Any changes to this guidance
will be communicated to the Head and HR and any staff members affected by the change.
Pete Lynch
Designated Safeguarding Lead
Assistant Headteacher
August 2023

22

Appendix 10

Identifying levels of need and what to do next at HBJThis document is a guide to assessing and meeting the needs of children and their families at AISL Harrow Beijing. It is not a ‘tick list’ and is to be
used as an aid to assist our school and internal systems and professional judgments/decision-making. It is important that HBJ Pastoral/Welfare
Assessments are based on a ‘big picture’ view of the child and their circumstances. This means that a clear system of identification, assessing,reporting, and acting is in place and consistent across the school.
This information is to help colleagues assess and understand the needs of a student and or family who may require additional support to thrive.
Most students will never go beyond Universal Services.
Other students will only dip into noted concern while others will need varying levels of support throughout their time at HBJ. The Levels of Need
are designed to support our school safeguarding and pastoral professionals when making decisions about what level of support a
student/students need and what tools and other departments/agencies are available to support this process.

This table tells you what action to take once you have identified the level of needLevel of need
identified
Accessing Universal
Services(Universal services
are services that areavailable toeverybody and canbe accessed byanyone without
additional support)
Level 1: Noted
concern

Description

Student/Childisthriving
without
requirement for additional support and allneeds are being met by universal services,for example School, School Nurse, external
health or other

Pastoral/Welfare
Assessment required?

No

Student/child may require or would Referral made at thebenefit from additional input or support safeguarding/Pastoral
from a department in school or Welfare Meeting.
agency/agencies.
No Pastoral/Welfare
assessment required.

Action /Support

Ensure that all students and families are aware of the
Support Services and Provisions such as Health Services andSupport Groups/People that are available to them to accessboth internally and externally.

Students, children, young people, or families may need toaccess relevant universal services for advice/support suchas school, counselling, medical, dentist, optician, tutor, andsupport staff.
Students/Families may need support in doing this as
capacity is not there.

Concern is monitored
and recorded. Key staff
are informed and thecase is reviewed anddocumented through
MyConcern andmeetings.
Level 2: Additional
support(Early Help)

Student may require or would benefit
from additional input or support from anagency/agencies

This also relates to minor pastoral observations such as
behaviour, attendance, punctuality, and health.
This is recorded by DSL (Designated Safeguarding Lead) on
MyConcern

If a clear issue or area of
need is identified –School Safeguarding Pastoral/Welfare
Assessment or Care
Plan may not benecessary.

Offer key support yourself through pastoral/support
systems, work with another school professional or direct
to relevant universal service for additional support.

If several issues orneeds at Level 2 are
identified, a School
Pastoral/Welfare
Assessment should beundertaken.

KCSIE (Keeping Children Safe in Education) 22 requires us
to really pinpoint early help as a priority in our structure.

Based on results of Welfare Assessment – accessappropriate early help services and set up in school and a
Welfare Meeting to develop a Pastoral/Welfare Plan.

2

Level 3:
Academic/Pastoral
Welfare Assessment& PlanLevel 4:
Child In Need/Child
Protection

Pupils are experiencing multiple and/or
complex needs. The pupil is struggling toeffect change without the support andintervention of additional services inschool. There is a need for a greater levelof support including perhaps a home visit.

The child/student is unlikely to achieve
or maintain a reasonable standard ofhealth or development without theprovision of support services. The child’s
health or development is likely to besignificantly impaired, or further
impaired without the provision of
additional services. This is recorded as aserous Child Protection Case. A SCR(Single Central Record) (Serious Case
Review Meeting) will have taken place.
All previous levels of need have been
exhausted and put in place.

School Academic
Pastoral Welfare
Assessment should beundertaken andrecommendations
made forcolleagues/services
required to meetassessed levels of needshould start to form a
Welfare Plan at a
Pastoral Welfare
Intervention Meeting.

When a child begins to display emerging needs requiring
additional support, services already working with the childshould support the family by undertaking Pastoral Welfare
Assessment and developing an outcome Plan. This will
identify support from within the local school community ora specific intervention.

Likely that a Welfare
Assessment has been
done. At this stage refer
the case externally,
Medical Service, NGO,
Police or Embassy
Assistance. During theinvestigation, a School
Welfare Assessment
and Plan may be of
benefit as part of thisprocess. You may put
together a multi-agency
team to support which
may involve
professionals that are
external to HBJ.

Immediate referral externally where appropriate andpossible.

Appropriate support can be accessed by the Key Lead
Professional involved with the Pastoral/Welfare Plan.
All actions are recorded on MyConcern

All details are recorded in detail on MyConcern and there
is a clear record of actions and intervention on students
chronology.
A Child Protection Risk Assessment will be completed andlogged on MyConcern*Possible Safety Plan (Using Clear Protocols).Suicide.Self Harm
.Eating Disorder.Child on Child Abuse

3

Communication Structure
Safeguarding & Pastoral/Welfare Phase Review Meetings
In each phase of the school, a Safeguarding & Pastoral/Welfare steering Group is to be formed. There will be a steering group for each phaseincluding City Campus, Lower School, Upper School(Possibly Sixth Form). Depending on the section of the school and availability in attendanceshould be:
DSL, DDSL, Nurse, School Counsellor, SEND lead and Pastoral Lead. (Invited members may attend if there is a link to a specific case)
The Steering Group should meet bi-weekly to discuss vulnerable pupils and to consider
their needs in line with the school threshold level of need document (Above) and Safeguarding policy.
The AISL Harrow Beijing Safeguarding & Pastoral Welfare Team (Whole School)
PurposeThe purpose of the AISL Harrow Safeguarding & Pastoral Welfare Team (S&PWT) is a steering group to ensure that members of the Associate
Leadership Team & Governing Body can be fully briefed and thus enabled to scrutinise and hold to account those responsible for thesafeguarding of all pupil members of the AISL Harrow Beijing School community.
Membership
Assistant Head of Safeguarding & Pupil Safety, Head of HR (Human Resources) (Safer Recruitment), Head of Admissions, Cross Phase School
DSL’s, Lead Educational Psychologist, Head of Learning Support, Head of EAL, Head of Sport, Lead Nurse, Head of ICT & Digital Platforms(Online Safety) & Head of PSHE.
Reporting
The S&PWT is a school committee which reports to the ALT (Associate Leadership Team) & Governance. Health and Safety compliance andSafeguarding Team who report directly to the Safeguarding Governor and Head of AISL Harrow Beijing.
The Agenda, Actions and Minutes of the S&PWT are shared half-termly with the ALT, Governance, Compliance and Safeguarding members prior
to their meeting. Upon external inspection and Harrow Safeguarding Standards Reviews all minutes of the Safeguarding Team are shared with
the Head of Harrow Beijing.

4