Al Fajer
Private School
All policies
DRAFT FOR STAFF REVIEW — not an approved or published policy. Highlighted [NEEDS AFS INPUT] items still need the school's confirmation.

AFS-POL-2642 items need input

Safeguarding & Child Protection Policy

⚠️ SAFEGUARDING-CRITICAL POLICY — REQUIRES HUMAN SIGN-OFF BEFORE USE This policy touches child safety. Before it is published or relied upon, Al Fajer Private School leadership must: (1) fill every [NEEDS AFS INPUT] placeholder, (2) name the school's designated safeguarding lead (DSL) and deputy with real contact details, and (3) formally adopt it with real dates. Nothing in this document has been invented to fill those gaps.

DOCUMENT CONTROL

Policy Reference AFS-POL-26 (proposed scheme — see _ADAPTATION_NOTES.md) [NEEDS AFS INPUT: confirm policy-numbering scheme]
Date Adopted [NEEDS AFS INPUT]
Last Review Date [NEEDS AFS INPUT]
Next Scheduled Revision (yearly) [NEEDS AFS INPUT]
Version Author Date Changes
0.1 [NEEDS AFS INPUT: policy owner] [NEEDS AFS INPUT] Adapted for Al Fajer Private School (KG1 – Grade 6, American curriculum) from the source policy

Table of Contents

  1. Introduction
  2. Aims
  3. Procedures
  4. Training
  5. Responsibilities
  6. Procedures for Managing Concerns
  7. Children Who Are Absent from Education
  8. Domestic Abuse
  9. Radicalization and Extremism
  10. Honor-Based Violence and FGM
  11. Modern Slavery
  12. Child-on-Child Abuse
  13. Racist Incidents
  14. Anti-Bullying
  15. Online Safety
  16. Supporting Children
  17. Students with Special Educational Needs and Disabilities
  18. Positive Physical Intervention / Use of Reasonable Force
  19. Record Keeping
  20. Information Sharing & Confidentiality
  21. Communication with Parents
  22. Support and Supervision of Staff
  23. Safer Recruitment and Selection of Staff
  24. Dealing with Allegations of Abuse against Staff
  25. Position of Trust
  26. Complaints or Concerns Expressed by Parents, Students, Staff or Volunteers
  27. Whistleblowing (Confidential Reporting)
  28. Photography and Use of Images (including handheld devices)
  29. Staff–Student Relationships
  30. Health & Safety
  31. Safe Environment
  32. Staff Obligations and the Duty to Report Concerns
  33. Neutral Notifications
  34. Challenge and Escalation
  35. Monitoring and Evaluation
  36. Extended-Day and Holiday Activities
  37. Arrangements for Visiting Speakers
  38. Events/Activities Involving Multiple Schools

AFS SAFEGUARDING & CHILD PROTECTION POLICY

Al Fajer Private School recognizes our moral responsibility — and our responsibilities as a school licensed by the Bahrain Ministry of Education — to safeguard and promote the welfare of all students. We endeavor to provide a safe and welcoming environment where children are respected and valued. We are alert to the signs of abuse, neglect and exploitation and follow our procedures to ensure that children receive adequate support, protection and justice. Child protection forms part of the School's safeguarding responsibilities.

The School is committed to safeguarding and promoting the welfare of children from KG1 to Grade 6. We expect all staff (teachers, administrators, clerical and support staff, and members of the governing body) to share this commitment in their attitudes and actions. Such a determination is firmly based on the fact that child protection and safeguarding are everyone's responsibility. Parents are made aware of the Policy: it is on the School website. The Policy will be amended and improved, without delay, in the light of experience, learning from implementation and any changes arising from serious case reviews.

Child protection, safeguarding and promoting welfare. Child protection, safeguarding and promoting the welfare of children is defined for the purposes of this Policy as protecting children from maltreatment; preventing impairment of children's health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes. In this connection, safeguarding is an overarching term which encompasses all activities regarding the safety and well-being of children under the age of 18 years.

Staff should not see child protection and safeguarding as isolated concepts but as features that run across a wide range of policy areas. These include:

School Details — Safeguarding Team

The source policy named individuals across multiple schools; AFS is a single KG1 – Grade 6 school, and the table below is role-based. Every name and contact must be completed and kept current.

Role Name, Position & Contact
Designated Safeguarding Lead (DSL), member of the school leadership team [NEEDS AFS INPUT: name, position, phone, email]
Deputy Designated Safeguarding Lead (DDSL) [NEEDS AFS INPUT: name, position, phone, email]
Designated Safeguarding Lead for Kindergarten (KG1 – KG3) [NEEDS AFS INPUT: name, position, phone, email]
Safeguarding lead for extended-day / holiday activities (if operated) [NEEDS AFS INPUT: confirm whether AFS operates extended-day or holiday programs, and who holds safeguarding duty for them]
Governance-level safeguarding oversight [NEEDS AFS INPUT: AFS ownership/governance — the member of the School's governing body responsible for safeguarding]
School safeguarding email [NEEDS AFS INPUT: AFS safeguarding email]
School safeguarding telephone [NEEDS AFS INPUT: AFS safeguarding phone]

Throughout this Policy, "governing body" is used as a placeholder for the School's governance structure. [NEEDS AFS INPUT: AFS ownership/governance — confirm the actual body and titles]

1.0 Introduction

1.1 This Policy is based on internationally recognized child-protection practice and on the requirements that apply to schools in the Kingdom of Bahrain. [NEEDS AFS INPUT: confirm the safeguarding framework AFS formally adopts — the source policy cited UK guidance ("Working Together to Safeguard Children", "Keeping Children Safe in Education"), which has not been carried over]

1.2 In the absence of a specific statutory provision on safeguarding and local government agencies, the School will work with the relevant Bahraini authorities and with local agencies in the area of child welfare and child protection.

1.3 This Policy has been prepared in consultation with the school leadership team and the School's governing body. The governing body will review the Policy on an annual basis and the efficiency with which child-protection duties have been carried out. The review should involve knowledge of any live cases and how the Policy was applied to them.

1.4 The governing body takes seriously its responsibility to protect children from harm, safeguard and promote the welfare of children, and to work together with other agencies to ensure adequate arrangements within the School to identify, assess, and support children who are suffering harm (whether actual or likely), children in need and children at risk.

1.5 We recognize that all adults, including staff and members of the governing body, have a full and active part to play in protecting students from harm, and that the child's welfare is our paramount concern. Wherever the word "staff" is used, it covers ALL staff on-site, including support staff working with children. To this end, the School will make this Policy available in both English and Arabic and will include ancillary, security and administrative staff in safeguarding training.

1.6 All staff have a duty to promote a caring, protective and safe environment that fosters the social, physical and moral development of the individual child.

2.0 Aims

2.1 The aims of this Policy are:

2.2 We recognize that because of the day-to-day contact with children, school staff are well placed to identify concerns early and to observe the outward signs of abuse. The School will, therefore:

2.3 We seek to ensure that the child's wishes and feelings are taken into account when determining what action to take and what services to provide to protect children from harm. To this end, we will ensure:

2.4 To support each child's development in ways that will foster security, confidence and independence.

2.5 To provide an environment in which all children feel safe, secure, valued and respected, and also feel confident to approach adults if they are in difficulties, believing they will be effectively listened to.

2.6 To raise the awareness of all staff of the need to safeguard children and of their responsibilities in identifying and reporting possible cases of abuse.

2.7 To provide a systematic means of monitoring children known or thought to be at risk of harm, and ensure we, the School, contribute to assessments of need and support packages for those children.

2.8 To emphasize the need for good levels of communication among all members of staff.

2.9 To develop a structured procedure within the School, which will be followed by all members of the School, in cases of suspected abuse or where there are significant concerns about the well-being of a child. This means that any disclosure or suspicion of abuse will be reported to a Designated Safeguarding Lead (DSL), who is in turn responsible for informing the Principal. Where there is reasonable cause and abuse has been suspected, the Principal will ensure that the chair of the governing body is informed and that relevant external agencies are contacted.

2.10 To develop and promote effective working relationships with other local welfare agencies as appropriate within Bahrain.

2.11 To ensure that all adults within the School who have regular access to children have been checked as to their suitability to work unsupervised with children.

3.0 Procedures

3.1 Our School procedures for safeguarding children have been prepared in accordance with the requirements of the Kingdom of Bahrain and recognized international safeguarding practice. As such, we ensure that:

4.0 Training

4.1 When staff and volunteers join AFS, they will be informed of the safeguarding-children arrangements in place. This Policy will be referred to, and they will be told who the DSL and deputies are, who acts in their absence, and what this role includes.

4.2 Staff are required to read this Policy including its Appendices, the Behavior, Rewards & Sanctions Policy, and the School's Staff Code of Conduct Policy.

4.3 All staff, volunteers and members of the governing body will receive an induction in safeguarding children.

4.4 The induction program will include basic safeguarding information relating to signs and symptoms of abuse, how to manage a disclosure from a child, when and how to record a concern about the welfare of a child, advice on safe working practice, the School's Safeguarding & Child Protection Policy, the Staff Code of Conduct Policy, and the identity of the DSL and deputies.

4.5 All volunteers, substitute staff and regular visitors to the School will be told where the Policy is kept, given the name of the DSL and deputies, and informed of the School's procedures for reporting concerns. A leaflet summarizing the key issues for volunteers and regular visitors will also be available at security.

4.6 All staff will receive training in child protection and safe working practice, updated at least every three years. Training will include signs and symptoms of abuse, neglect and exploitation, as well as specific safeguarding issues. It will also include how to record and report abuse both within the School and to the relevant child-welfare authorities.

4.7 In addition, staff will receive safeguarding and child-protection updates from the DSL as required, but at least annually.

4.8 Staff with specific responsibility for safeguarding children will undertake additional training at a level suitable to their role and responsibility, updated every two years. In addition to formal training, the DSL and deputy/ies will update their knowledge regularly.

5.0 Responsibilities

5.1 The governing body is responsible for the appointment, liaison and monitoring of the DSL, in discussion with the Principal. This will include a periodic review to ensure that effective training has occurred.

5.2 The governing body and the Principal will ensure that:

5.3 The Principal will ensure that:

5.4 The Designated Safeguarding Lead is responsible for:

6.0 Procedures for Managing Concerns

Teachers and other staff in schools are in a unique position to observe children's behavior over time and often develop close and trusting relationships with students.

6.1 If a child discloses directly to a member of staff, the following advice to staff will be followed:

6.2 All concerns, discussions and decisions (together with reasons) made under these procedures should be recorded in full via the School's electronic safeguarding log within [NEEDS AFS INPUT: AFS student-information system].

6.3 The School manages this by providing:

6.4 Every member of staff, including volunteers working with children at our School, is advised to maintain an attitude of "it could happen here" where safeguarding is concerned. When concerned about the welfare of a child, staff members should always act in the interests of the child and have a responsibility to take action as outlined in this Policy. They should not assume a colleague or another professional will take action and share information that might be critical in keeping children safe.

6.5 All staff are encouraged to report any concerns that they have and not see these as insignificant. On occasions, a referral is justified by a single incident such as an injury or disclosure of abuse. More often, however, concerns accumulate over a period of time and are evidenced by building up a picture of harm over time; this is particularly true in cases of emotional abuse, neglect and exploitation. In these circumstances, it is crucial that staff record and pass on concerns in accordance with this Policy to allow the DSL to build up a picture and access support for the child at the earliest opportunity. Reliance on memory without accurate and contemporaneous records of concern could lead to a failure to protect.

6.6 All staff should be aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognize their experiences as harmful. For example, children may feel embarrassed, humiliated, or threatened. This could be due to their vulnerability, disability or language barriers. This should not prevent staff from having a professional curiosity and speaking to the DSL if they have concerns about a child. It is also important that staff determine how best to build trusted relationships with children which facilitate communication.

6.7 It is not the responsibility of school staff to investigate welfare concerns or determine the truth of any disclosure or allegation. All staff, however, have a duty to recognize concerns and pass the information on in accordance with the procedures outlined in this Policy.

6.8 The Designated Safeguarding Lead should be used as the first point of contact for concerns and queries regarding any safeguarding concern in our School. Any member of staff or visitor to the School who receives a disclosure of abuse or suspects that a child is at risk of harm must report it immediately to the DSL or, if unavailable, to a deputy DSL. In the absence of either of the above, the matter should be brought to the attention of the most senior available member of the school leadership team.

6.9 All concerns about a child should be reported without delay, and a handwritten record should be made as soon after the disclosure as possible, using the child's words as far as possible. Members of staff are also able to log a concern via the School's electronic safeguarding system.

6.10 Following receipt of any information raising concern, the DSL will consider what action to take, and all information and actions taken, including the reasons for any decisions made, will be fully documented.

6.11 Anybody can make a referral. If the child's situation does not appear to be improving, the staff member with concerns should press for reconsideration by raising concerns again with the DSL and/or the Principal. Concerns should always lead to help for the child at some point.

6.12 Any member of staff who does not feel that concerns about a child have been responded to appropriately and in accordance with the procedures outlined in this Policy should raise their concerns with the Principal or the governing-body member responsible for safeguarding.

7.0 Children Who Are Absent from Education

7.1 We recognize that a child being absent from education for prolonged periods and/or on repeat occasions is a potential indicator of abuse or neglect.

7.2 Staff are made aware of these procedures at induction and through our Attendance & Punctuality Policy. We will make every attempt to obtain more than one emergency contact number for each child registered at the School, to ensure we are able to make contact with a responsible adult when a child is missing education and is also identified as a welfare and/or safeguarding concern.

7.3 We will notify the Bahrain Ministry of Education, as required, when removing a child from the school roll at standard and non-standard transition points. [NEEDS AFS INPUT: confirm current MoE notification requirements — the source policy referred to UK local authorities]

7.4 We will ensure that we follow these procedures for dealing with children who go missing from education, particularly on repeat occasions, to help identify the risk of abuse, neglect and exploitation, and to help prevent the risks of their going missing in the future.

8.0 Domestic Abuse

8.1 We recognize that exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse: they may see, hear, or experience the effects of abuse at home. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

8.2 We teach our students, in an age-appropriate way suited to young children, what safe, kind and respectful relationships look like.

8.3 All concerns regarding domestic abuse will be reported to the DSL, who will ensure that appropriate support is available to the child and make referrals where the threshold for intervention is met.

9.0 Radicalization and Extremism

9.1 The School recognizes that children can be vulnerable to extremist ideology and radicalization. We recognize that safeguarding against radicalization and extremism is no different from safeguarding against any other vulnerability in today's society.

9.2 The School will ensure that:

9.3 We encourage students to respect the values of the Kingdom of Bahrain, including the rule of law, the King's Charter, individual liberty and mutual respect, and tolerance of those with different faiths and beliefs, alongside the School's own values of loyalty and integrity, and intellect, optimism and creativity.

9.4 We will use relevant information, tools and resources to help our staff and parents to recognize and address extremism and radicalization in children.

10.0 Honor-Based Violence and Female Genital Mutilation (FGM)

10.1 We recognize that our staff are well placed to identify concerns and take action to prevent children from becoming victims of female genital mutilation (FGM) and other forms of so-called honor-based violence (HBV), and we provide guidance on these issues through our safeguarding training.

10.2 If staff have a concern regarding a child who might be at risk of HBV, they should inform the DSL, who will activate the School's safeguarding procedures and liaise with the Police and the relevant child-welfare authorities as appropriate.

10.3 Where FGM appears to have taken place (whether discovered through disclosure by the victim or visual evidence), the School will report the matter to the Police. Staff who fail to report such cases may face disciplinary action. We will provide guidance and support to our teachers on this requirement as needed.

11.0 Modern Slavery

11.1 All staff should be observant for signs, or receiving intelligence, relating to modern slavery.

11.2 The School bears an obligation where it has reasonable grounds to believe that a person may be a victim of modern slavery or human trafficking.

11.3 Staff need to be aware of this duty and inform the DSL should they suspect or receive information that either parents or their children may be victims of modern slavery.

12.0 Child-on-Child Abuse

AFS is a KG1 – Grade 6 school. This section is framed for young children; the source policy's content aimed at teenagers (sexting typologies, upskirting, initiation violence) has been removed.

12.1 We recognize that children can also be harmed physically, sexually or emotionally by their peers or siblings, and that even very young children can behave in ways that hurt others.

12.2 At a school of our age range, this is most likely to include, but is not limited to:

12.3 Harm caused by children can be just as damaging as harm caused by an adult, so it is important to remember the impact on the child harmed as well as to focus on support for the child exhibiting the harmful behavior. Such harm will always be taken as seriously as abuse perpetrated by an adult, and the same procedures will apply in respect of any child who is suffering or likely to suffer significant harm.

12.4 Staff must never tolerate or dismiss concerns relating to child-on-child harm, and must not pass it off as "just teasing," "just having a laugh," or "part of growing up."

12.5 We will ensure, through training, that staff, volunteers and members of the governing body have an understanding of the range of child-on-child harm and will be made aware of how to recognize and manage such issues. Staff will be given the skills to identify and manage harmful sexual behavior in an age-appropriate way (see Appendix 4).

12.6 Staff should be aware that some groups are potentially more at risk — for example, girls and children with special educational needs and disabilities.

12.7 Staff should be aware that such incidents and/or behaviors can be associated with factors outside the School and can occur between children outside the School. Staff, and particularly the DSL, should always consider the context in which such incidents and/or behaviors occur — this is known as contextual safeguarding.

12.8 Where the harm is physical, verbal, bullying or cyberbullying, recording of such incidents and any consequences will be applied in line with our Behavior, Rewards & Sanctions Policy and Anti-Bullying Policy. The School will not accept the excuse of "banter" for what it deems to be inappropriate references to any person or persons. Where a child makes a safeguarding allegation of a sexual nature against another student in the School, the DSL should seek advice before commencing an investigation or contacting parents. This may mean, on occasion, that the School is unable to conduct its own investigation into such incidents.

12.9 Reports of incidents of a sexual nature between children will be responded to in line with this Policy and the School's reporting procedures. [NEEDS AFS INPUT: confirm the safeguarding framework AFS adopts — the source policy cited UK guidance here]

12.10 Support for children who have been harmed will be in line with the support outlined in the School's Behavior, Rewards & Sanctions Policy and Anti-Bullying Policy.

12.11 Depending on the nature of the harm, the School may need to consider providing measures to protect and support the child harmed, the child exhibiting the behavior, and other students and/or staff in the School, by means of a risk assessment. The risk assessment should be recorded and kept under review.

13.0 Racist Incidents

13.1 Our policy on racist incidents is set out within our separate Anti-Bullying Policy and acknowledges that repeated racist incidents, or a single serious incident, may lead to consideration under child-protection procedures.

13.2 We maintain a log of racist incidents in School.

14.0 Anti-Bullying

14.1 Our policy on anti-bullying is set out in our separate Anti-Bullying Policy. [NEEDS AFS INPUT: an Anti-Bullying Policy is not in the current AFS policy set — create it or remove this reference]

14.2 To allow or condone bullying may lead to consideration under child-protection procedures. All incidences of bullying, including cyberbullying, racist and gender-related bullying, will be dealt with in accordance with the School's Anti-Bullying Policy.

14.3 We recognize that children with special needs and/or disabilities are more susceptible to being bullied. We maintain a log of bullying incidents in School.

14.4 We recognize that there will be occasions when bullying incidents will fall within child-protection procedures or may be deemed criminal activity, and that it may be necessary to report the concerns to the Police.

15.0 Online Safety

15.1 The DSL understands the unique risks associated with online safety and has the relevant knowledge and up-to-date capability required to keep children safe while they are online at School.

15.2 The DSL is able to recognize the additional risks that children with special educational needs and disabilities face online — for example from online bullying and grooming — and has the capability to support these children to stay safe online.

15.3 All members of staff are trained in, and receive regular updates on, online safety and recognizing and reporting concerns.

15.4 The School's Online Safety Policy and ICT acceptable-use expectations recognize that Internet safety is a whole-school responsibility, involving staff, students, the governing body and parents.

15.5 Children may expose themselves to danger, whether knowingly or unknowingly, when using the Internet and other technologies. Because our students are young children, staff and parents carry the primary responsibility for supervising and guiding their use of technology.

15.6 The School recognizes its responsibility to educate its students, teaching them the appropriate behaviors and early critical-thinking skills to enable them to remain safe when using the Internet and related technologies. These issues are addressed within the curriculum, in the PSHE program and in assemblies.

15.7 The breadth of issues classified within online safety is considerable and ever-evolving, but can be categorized into four areas of risk:

15.8 We will ensure that filters are in place to prevent access to unsuitable sites, and we will monitor the use of the school network and Internet to ensure that any student or staff member attempting to access inappropriate, abusive or harmful material is appropriately advised and/or supported.

15.9 Any classroom use of generative artificial intelligence (AI) is age-appropriate, directed and supervised by staff, in line with the School's Online Safety Policy.

15.10 Where there is a need for remote education, communication with parents will ensure an awareness of what children are being asked to do online, which websites they will need to access, and who they will be interacting with. This will help parents to monitor and ensure online safety at home.

16.0 Supporting Children

16.1 We recognize that a child who is abused or witnesses violence may feel helpless and humiliated, may blame themselves, and may find it difficult to develop and maintain a sense of self-worth.

16.2 We recognize that AFS may provide the only stability in the lives of children who have been abused or who are at risk of harm.

16.3 We accept that research shows that the behavior of a child in these circumstances may range from that which is perceived to be normal to aggressive or withdrawn.

16.4 AFS supports all students by:

17.0 Students with Special Educational Needs and Disabilities

17.1 We recognize that children with special educational needs and disabilities can face additional safeguarding challenges, and these are discussed in staff training. These additional barriers can include:

17.2 We will always consider extra pastoral support for children with special educational needs and disabilities to address these additional challenges (see the School's SENDA Policy).

18.0 Positive Physical Intervention / Use of Reasonable Force

18.1 The School outlines its guidelines for the use of physical intervention within its Staff Code of Conduct Policy.

18.2 All staff acknowledge annually that they have read the Staff Code of Conduct Policy.

18.3 The School acknowledges that when applying reasonable force in response to risks presented by incidents involving children with special educational needs, disabilities or medical conditions, it is important to recognize their additional vulnerability and make every effort to reduce the occurrence of challenging behavior and the need to use reasonable force.

18.4 The School understands that physical intervention of a nature that causes injury or distress to a child may be considered under safeguarding-children or disciplinary procedures.

18.5 A record of all incidents of physical intervention that occur will be maintained by the DSL.

18.6 The School recognizes that touch is appropriate in the context of working with young children, and all staff are given safe-working-practice guidance to ensure that they are clear about their professional boundaries.

18.7 The School recognizes that the adoption of a "no contact" policy could leave staff unable to fully support and protect young students.

19.0 Record Keeping

19.1 Any member of staff receiving a disclosure of abuse from a child, or noticing signs or symptoms of possible abuse, should make notes as soon as possible (within the hour, if possible), writing down exactly what was said, using the child's own words as far as possible. All notes should be timed, dated and signed, with names printed alongside the signature.

19.2 Logging a concern about a child's safety or welfare should be completed via the School's electronic safeguarding system within [NEEDS AFS INPUT: AFS student-information system].

19.3 All records of a child-protection nature should be passed to the DSL, including case-conference minutes, child-protection plans and written records of any concerns. Child-protection records are kept securely under lock and key or password-protected, with only appropriate persons having access to them.

19.4 Any referrals made to other agencies will be copied prior to sending and stored in the child's child-protection file.

19.5 The DSL and deputies will maintain and regularly audit the School's child-protection records and ensure that each standalone file includes a chronology of significant events and that information and contact details are accurate and up to date.

19.6 The DSL and deputies will transfer the child-protection record in a safe and timely manner when a child moves school, ensuring a receipt of transfer is obtained.

19.7 The DSL and deputies may copy child-protection records generated by the School prior to transfer and retain them for as long as is necessary where there is justification for believing that the records may be required as evidence of the School's involvement with the child for legal purposes. When the records are no longer required, they will be securely disposed of.

20.0 Information Sharing & Confidentiality

20.1 The DSL and deputies disclose any information about a student to other members of staff on a need-to-know basis only.

20.2 All staff are made aware that they have a professional responsibility to share information with the relevant agencies in order to safeguard children.

20.3 All staff are made aware that they cannot promise a child to keep secrets which might compromise the child's safety or well-being. In addition, staff are aware that leading questions must not be asked of children, as this could affect the reliability of statements made.

20.4 Personal information will be processed fairly and lawfully in line with our duties under Bahrain's Personal Data Protection Law (PDPL, Law No. 30 of 2018) and will be held safely and securely. [NEEDS AFS INPUT: confirm with legal counsel that the PDPL is the data-protection basis governing AFS — the source policy cited the UK Data Protection Act 2018 and GDPR, which have not been carried over] However, we recognize that this is not a barrier to sharing information where the failure to do so would result in a child being placed at risk of harm.

20.5 We recognize that all matters relating to child protection are confidential.

20.6 When a child about whom concerns have been raised and recorded leaves the School, the DSL and deputies will consider whether it would be appropriate to share information with the new school in advance of the child leaving, to ensure that support is in place for when the child arrives.

(The source policy repeated three clauses here; the duplicates have been removed and the section renumbered.)

21.0 Communication with Parents

21.1 The School recognizes that good communication with parents is crucial in order to safeguard and promote the welfare of children effectively.

21.2 The School will always undertake appropriate discussion with parents prior to the involvement of another agency, unless to do so might place the child or an adult at further risk of harm or would impede a criminal investigation.

21.3 The School will ensure that parents have an understanding of the responsibilities placed on the School and staff to safeguard children, and of the School's duty to cooperate with other agencies in this respect.

22.0 Support and Supervision of Staff

22.1 The School recognizes that staff who have become involved with a child who has suffered harm, or appears to be likely to suffer harm, may find the situation stressful and upsetting.

22.2 The School will support such staff by providing an opportunity to talk through their anxieties with the DSL and to seek further support such as counseling or regular supervision, as appropriate.

22.3 We will enable supervision for the DSL through network meetings and direct consultation with the governing-body member responsible for safeguarding, to:

23.0 Safer Recruitment and Selection of Staff

23.1 The School has a written recruitment policy statement and procedures linking explicitly to this Policy.

23.2 The safeguarding statement is included in all job advertisements, publicity material, recruitment websites and candidate information packs.

23.3 The recruitment process is robust in seeking to establish the commitment of candidates to support the School's measures to safeguard children, and to deter, identify and reject people who might pose a risk of harm to children or are otherwise unsuited to work with them.

23.4 References are requested and scrutinized for all candidates, and any discrepancies or concerns are raised and discussed during the interview, including for any volunteers and internal candidates.

23.5 References are always requested directly from the referee and verified as being from a senior person with appropriate authority; electronic references are checked to ensure they originate from a legitimate source.

23.6 Where specific questions have not been answered satisfactorily, or insufficient information is provided, the referee will be contacted directly for further clarification. Where references are not forthcoming, despite reminders, the candidate will be asked to provide an alternative referee.

23.7 Shortlisted candidates will be informed that online searches, including social media, may be carried out during the recruitment process.

23.8 All staff working within the School who have substantial access to children have been checked as to their suitability, including verification of their identity and qualifications, criminal-record checks from their country or countries of origin/residence, and a Bahraini good-conduct certificate. [NEEDS AFS INPUT: AFS safer-recruitment regime — confirm the full set of checks; the source policy relied on UK DBS and barred-list checks, which have not been carried over]

23.9 All teachers working within the School have been checked to ensure that there are no prohibitions, sanctions or restrictions in place that might prevent them from working with children.

23.10 The School seeks written assurance from substitute-staff and third-party agencies, alternative providers, teacher-training providers and contractors that they have undertaken all appropriate checks on any of their staff who work with, or have regular contact with, our students.

23.11 Enhanced criminal-record and background checks are undertaken for the Principal and all members of the governing body.

23.12 International hires must provide criminal-record checks from each country in which they have recently lived, in addition to the Bahraini good-conduct certificate.

23.13 The School maintains a single central record of recruitment checks for audit purposes; this is checked and updated regularly and records all the recruitment checks undertaken by the School.

23.14 Any member of staff who begins work before all required checks have been verified will not be left unsupervised with children and will be subject to a risk assessment.

23.15 Volunteers will be supervised at all times. A risk assessment will be undertaken to help decide whether any additional checks are required.

24.0 Dealing with Allegations of Abuse against Staff

24.1 We acknowledge that a student may make an allegation against a member of staff or a volunteer. If such an allegation is made, the member of staff receiving the allegation will immediately inform the Principal.

24.2 All school staff should take care not to place themselves in a vulnerable position with a child. Staff must also ensure that their behavior and actions do not place students or themselves at risk of harm or of allegations of harm to a student. It is always advisable for interviews or work with individual children or parents to be conducted in view of other adults. Specific situations put staff in closer work with students: sports coaching, email or phone communication, and school trips. Staff should ensure absolute probity in these specific situations; for example, all communication should always be on a formal level. This includes professional conduct on social-networking sites.

24.3 Should a student make an allegation against any member of staff, our paramount concern will be for child safety and well-being, and the allegation will be treated in strict confidence.

24.4 If an allegation is made against the Principal, this must be immediately reported to the School's governing body [NEEDS AFS INPUT: AFS ownership/governance — confirm to whom allegations against the Principal are reported], and this can be done without informing the Principal.

24.5 In all cases of an allegation being made, and prior to undertaking any investigation, the School will immediately consider the nature, content and context of the allegation and agree on a course of action, including any involvement of the Police. Discussions will be recorded in writing, and communication with both the individual and the parents of the child/children agreed.

24.6 Where a member of staff is dismissed because they harmed, or posed a risk of harm to, a child — or would have been dismissed had they not resigned — the School will notify the relevant Bahraini authorities (see 3.1.14). [NEEDS AFS INPUT: confirm with legal counsel AFS's referral obligations — the source policy referred cases to UK bodies (DBS, Teaching Regulation Agency), which have not been carried over]

24.7 AFS will make every effort to maintain confidentiality and guard against unwanted publicity. In the event of an allegation made against a member of staff, the School is aware of its obligations to do its utmost to protect the anonymity of the member of staff during the investigative stage. This is to protect staff in the event that an allegation is found to be unfounded or malicious.

24.8 The School will follow the same safeguarding policies and procedures for allegations regarding an incident that occurs when an individual or organization is using the school premises for the purpose of running activities for children, such as community groups or sports associations.

25.0 Position of Trust

25.1 The School recognizes that, as adults working in the School, we are in a relationship of trust with the students in our care, and acknowledges that abusing that trust is a grave breach of this Policy and may be a criminal offense.

25.2 All AFS students are young children. Any sexual or otherwise exploitative conduct by an adult toward a student is abuse, will be dealt with under child-protection procedures, and will be reported to the Police and the relevant authorities.

(The source policy's provisions about students over the age of consent have been removed: they cannot apply in a KG1 – Grade 6 school.)

26.0 Complaints or Concerns Expressed by Parents, Students, Staff or Volunteers

26.1 The School recognizes that listening to children is an important and essential part of safeguarding them against abuse, neglect and exploitation.

26.2 To this end, an expression of dissatisfaction or disquiet in relation to an individual child will be listened to and acted upon in order to safeguard his/her welfare.

26.3 The School will also seek to ensure that the child or adult who makes a complaint is informed not only about the action the School will take, but also given an indication of the length of time that will be required to resolve the complaint.

26.4 The School will also endeavor to keep the child or adult regularly informed as to the progress of his/her complaint.

26.5 The School's Complaints Policy is readily available.

27.0 Whistleblowing (Confidential Reporting)

27.1 The School has a Whistleblowing Policy that staff should refer to.

27.2 The School recognizes that children cannot be expected to raise concerns in an environment where staff fail to do so. Thus, all staff should be aware of their duty to raise concerns about the attitude or actions of others.

27.3 Any member of staff may make a referral to external agencies. Staff should report concerns about poor or unsafe practice and potential failures in the School's safeguarding regime. Such concerns can be raised directly with the Principal or through the School's whistleblowing channel. [NEEDS AFS INPUT: AFS whistleblowing channel — the source policy named group executives, which has not been carried over]

27.4 Whistleblowing concerns about the Principal should be reported directly to the School's governing body. [NEEDS AFS INPUT: AFS ownership/governance contact for concerns about the Principal]

28.0 Photography and Use of Images (including handheld devices)

28.1 The welfare and protection of children are paramount, and consideration should always be given to whether the use of photography will place children at risk. Images may be used to harm children — for example, as a preliminary to grooming or by displaying them inappropriately on the Internet, particularly social-networking sites.

28.2 For this reason, consent is sought from parents that they agree to their children being photographed.

28.3 Only school-owned devices are permitted to be used to photograph any child.

28.4 Staff are not permitted to use their personal mobile devices or cameras in school to photograph or record students.

28.5 Staff must only take photographs or video of students — always on a school-owned device — for legitimate educational use or for publication approved under the School's Taking, Storing and Using Images of Children Policy. (The source policy was internally inconsistent on personal devices; this version resolves it in favor of school-owned devices only.)

28.6 Staff who wish to use their personal mobile devices or cameras in school for any other reason must first speak with the Principal. Staff who act in breach of this may be subject to disciplinary action.

28.7 Staff working in the Kindergarten (KG1 – KG3), for any amount of time, must read and adhere to the relevant section of the Online Safety Policy, and are reminded that mobile phones are not permitted outside of the Kindergarten office and faculty room.

28.8 Parents and visitors are not permitted to use their mobile phones or cameras in or around the Kindergarten setting without prior approval from the Principal or the designated Kindergarten lead.

28.9 Additional consideration is given to photographing vulnerable children.

28.10 Many families own handheld devices, and parents are encouraged to consider measures to keep their children safe when using the Internet at home and in the community.

28.11 Guidance regarding the use of mobile phones and other electronic devices is detailed in the Use of Mobile Phone Policy and the BYOD Policy.

28.12 The safe and appropriate taking, using and storage of images is outlined in the School's Taking, Storing and Using Images of Children Policy.

29.0 Staff–Student Relationships

29.1 Further guidance for staff is given in the Staff Code of Conduct Policy, which should be read in conjunction with this Safeguarding & Child Protection Policy.

29.2 The School provides advice to staff regarding their personal online activity and has strict rules regarding online contact and electronic communication with students.

29.3 Staff found to be in breach of these rules may be subject to disciplinary action or a child-protection investigation.

30.0 Health & Safety

30.1 The School's Health & Safety Policy reflects the consideration we give to the safeguarding of our children, both within the school environment and when away from school — for example, when undertaking school trips and visits.

30.2 Risk assessments are undertaken and reviewed regularly in respect of site security, the risk of children being exposed to extremist behavior, and the risk to and from children displaying harmful behavior.

31.0 Safe Environment

31.1 The School undertakes appropriate risk assessments and checks in respect of all equipment and of the building and grounds, in line with local guidance and regulations concerning health and safety.

31.2 The School has adequate security arrangements in place in respect of the use of its grounds and buildings by visitors, both in and out of school hours.

31.3 Visitors to the School — for example visiting speakers, theater groups or curriculum specialists — will be appropriately checked and vetted, to ensure they are not linked to extremist groups or promoting extremist or other harmful material (see Section 37 and the Visiting Speaker Policy).

32.0 Staff Obligations and the Duty to Report Concerns

32.1 All staff — including full-time, part-time, temporary and permanent members of staff, and volunteers — must adhere to the School's Staff Code of Conduct Policy, and a copy of that Policy is available to all staff.

32.2 The Staff Code of Conduct Policy provides details about the obligations of staff for keeping the School informed of reasons why they should not work with children.

32.3 Staff should be mindful of the need to consider safeguarding arrangements where children are engaged in close one-to-one teaching, particularly in performing arts and sports activities.

32.4 Specific guidance can be provided on a case-by-case basis by consulting with the DSL as required.

33.0 Neutral Notifications

33.1 From time to time, staff members may find themselves in a situation that they would not want to be in, which is unintentional and innocent. This could include receiving a friend request from a child on social media, entering a one-on-one situation with a child unexpectedly, or seeing a child in a state of undress (for example, when young children change clothes for PE or swimming).

33.2 All staff are required to report any such incidents to the DSL. This is to ensure that the staff member can be best supported if an allegation is made against them.

34.0 Challenge and Escalation

34.1 The School recognizes that professional disagreements may arise between agencies, and resolving problems is an integral part of cooperation and joint working to safeguard children.

34.2 As part of our responsibility for safeguarding children, AFS acknowledges that we must be prepared to challenge each other if we feel that responses to concerns, assessments, or the way in which plans are implemented are not safeguarding the child and promoting their welfare.

34.3 AFS is aware of escalation procedures for raising concerns in respect of poor practice, and of our responsibility to utilize these as and when necessary, in the interests of safeguarding and promoting the welfare of children.

35.0 Monitoring and Evaluation

35.1 Our safeguarding-children policy and procedures will be monitored and evaluated annually by:

36.0 Extended-Day and Holiday Activities

[NEEDS AFS INPUT: confirm whether AFS operates extended-day activities, after-school clubs run by external providers, or holiday programs — the source policy described the previous school's branded academies and holiday camps, which have not been carried over. If AFS does not operate such activities, remove this section.]

36.1 Where AFS hosts extracurricular or extended-day activities for students after school hours or during holidays, this Safeguarding & Child Protection Policy applies to all of the children attending the activities, including any children who are not enrolled at AFS.

36.2 Staff running such activities will have completed safeguarding training at the School, and a trained DSL or deputy DSL will be available to deal with any safeguarding concerns during these activities, including holiday periods (see the Safeguarding Team table above).

36.3 External activity providers must ensure that their safeguarding arrangements align with this Policy, and must present evidence that they have carried out suitability checks on their staff.

36.4 Any safeguarding concern we have about a child attending such activities who is not a student at AFS will be shared with the DSL at the child's own school, in accordance with the normal procedures for transferring files, and this will be done in a timely manner.

37.0 Arrangements for Visiting Speakers

37.1 The School has clear protocols for ensuring that any visiting speakers are appropriately supervised and suitable (see the Visiting Speaker Policy). The School's responsibility to students is to ensure that what they hear is appropriate to their age, and that the information is aligned to the ethos and values of the School.

37.2 The School is required to undertake a risk assessment before agreeing to a visiting speaker being allowed to attend the School. This will take into account any vetting requirements considered appropriate in the circumstances, in line with the Visiting Speaker Policy (including photo ID and CPR-number verification).

37.3 Visiting speakers will be expected to understand that, where appropriate, their session should actively promote the School's values — loyalty and integrity; intellect, optimism and creativity — and the values of the Kingdom of Bahrain, including the rule of law, individual liberty and mutual respect and tolerance of those with different faiths and beliefs, and at no point undermine these.

37.4 In some cases, the School may request a copy of the visiting speaker's presentation and/or footage in advance of the session being provided.

37.5 Visiting speakers, while on the school site, will be supervised by a school employee. On attending the School, visiting speakers will be required to show original current identification documents including a photograph, such as a passport or photo-card driving license.

38.0 Events/Activities Involving Multiple Schools

38.1 When taking part in events organized by other schools or organizations — e.g. sports or music events — the schools involved will consider what image guidelines should apply. For larger events, it is reasonable to expect that specific image guidelines should be in place. Where relevant, these should include reference to press images. Consideration should be given as to how those attending the event will be informed of the image guidelines that apply — e.g. a letter before the event, an announcement at the event, or information in any printed program.

38.2 Although the School will make reasonable efforts to safeguard the digital images of students, parents should be made aware that at some types of events it is not always realistic to strictly enforce image guidelines. The School cannot therefore be held accountable for the use of images taken by parents or members of the public at events.

38.3 Adequate supervision from members of the School's staff will ensure the safety of children, particularly where contact with the public occurs. Specifically, staff will be alert to any problems which may occur in bathrooms or changing areas, and this should form part of the risk assessment.


APPENDIX 1 – Recruitment & Selection Checklist

Planning

Vacancy Advertised

Applications

Invitation to Interview

Interview Arrangements

Interview

Summary of Documents

[NEEDS AFS INPUT: AFS safer-recruitment regime — confirm this checklist; the source policy's DBS/ICPC items have been replaced with the country-of-origin + Bahraini good-conduct pattern]

Conditional Offer of Appointment: Pre-Appointment Checks

References Sought

References Received and Verified

APPENDIX 2 – Criminal-Record Disclosure Information

Secure storage, handling, use, retention and disposal of criminal-record disclosures and disclosure information

General principles

Storage and access

Handling

Usage

Retention

Disposal

APPENDIX 3 – Recruitment of Individuals with Prior Convictions

Because AFS educates young children (KG1 – Grade 6), the School will not employ any person whose criminal-record or good-conduct history indicates that they may pose a risk to children. Disclosed convictions are assessed as part of the School's safer-recruitment procedures. [NEEDS AFS INPUT: AFS safer-recruitment regime — confirm the School's stance on the employment of individuals with prior convictions; the source policy relied on the UK DBS Code of Practice, which has not been carried over]

APPENDIX 4 – Recognition of Abuse

The following working definitions and indicators are used by the School. They are framed for the ages AFS serves (approximately 3 – 12); indicators specific to adolescents in the source policy have been removed.

What is Abuse?

Abuse, neglect and exploitation are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger — for example, via the Internet. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults, or by another child or children.

Indicators of Abuse

Caution should be used when referring to lists of signs and symptoms of abuse. Although the signs and symptoms listed below may be indicative of abuse, there may be alternative explanations. In assessing the circumstances of any child, any of these indicators should be viewed within the overall context of the child's individual situation, including any disability.

Emotional Abuse

Neglect

Physical Abuse

Sexual Abuse

Harmful Sexual Behavior by Children

APPENDIX 5 – Radicalization & Extremism

Preventing radicalization

APPENDIX 6 – Safeguarding Request Form

For the attention of the Designated Safeguarding Lead (DSL) at a student's previous school.

Dear Sir / Madam,

With regard to safeguarding and any relevant pastoral information, I would be grateful if you could complete the table below and return it, via email, to Al Fajer Private School at your earliest convenience.

If you would like to discuss any matters concerning this student, please feel free to contact me at [NEEDS AFS INPUT: AFS safeguarding email] or by telephone: [NEEDS AFS INPUT: AFS safeguarding phone].

Yours faithfully,

[NEEDS AFS INPUT: name] Principal, Al Fajer Private School

SURNAME OF CHILD
FIRST NAME OF CHILD
DATE OF BIRTH
NAME OF CURRENT SCHOOL
NAME OF SAFEGUARDING LEAD
DATES ATTENDED FROM: — TO:
ARE YOU AWARE OF ANY SAFEGUARDING CONCERNS REGARDING THIS STUDENT? (delete as appropriate) a. No, I am not aware of any safeguarding concerns about this student. / b. Yes, I enclose safeguarding / pastoral concerns information about this student.
CONFIDENTIAL ELECTRONIC DELIVERY Please email to [NEEDS AFS INPUT: AFS safeguarding email]. Please include the student's full name in the subject line.
DATE FILE SENT
SIGNED BY DSL

APPENDIX 7 – Safeguarding Flowchart

[NEEDS AFS INPUT: the source policy's flowchart page was blank in the extracted source document. AFS must insert its own safeguarding reporting flowchart here — staff member's concern → DSL (or deputy) → Principal → external agencies/Police — with the named contacts from the Safeguarding Team table on page 1.]