Child Protection Guidelines and Procedures Effective: 24 January 2017
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ISKL Mission The International School of Kuala Lumpur provides an exceptional education that challenges each student to develop the attitudes, skills, knowledge and understanding to become a highly successful, spirited, socially responsible global citizen.
The Vision for Our Students To walk in a harmonious environment where care follows closely behind; learning is stimulated, curiosity is sparked, vision is cultivated, and action is inspired.
ISKL School-wide Learning Results (SLRs)
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Summary of Changes/Version Record Date
24 January 2017
CPGP approved at closed door board session.
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Table of Contents Part I: Introduction 1. Introduction from the Head of School 2. Scope and purpose of these guidelines and procedures 3. ISKL Board of Directors and accrediting agency expectations 4. Relevant research and ISKLâ€™s Malaysian context 5. ISKL Child Protection Guiding Statement
Part II: Child Protection Guidelines and Procedures 1. Definition of terms / signs and symptoms of abuse 2. Child protection roles and responsibilities 3. Prevention a. Campus security and facilities management b. Human resources management c. Education and training i. Educating students - Empowering students to be their own advocates ii. Educating parents - Engaging parents as our partners in child protection iii. Educating faculty and staff - Four Guideposts to Healthy Adult-Student Relationships 4. Response Procedures a. Overview of response procedures i. Flowchart for reporting and investigating allegations b. Types of disclosures: i. Harm to Self ii. Student - Student iii. Faculty/Staff - Student iv. Parent - Child v. Outsider or Online - Student 5. Summary
Part III: Appendices Appendix 1 - School Personnel Roles and Responsibilities Appendix 2 - Monitoring the CPP Appendix 3 - References
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Introduction from the Head of School Dear ISKL Community, The International School of Kuala Lumpur takes the protection of our children seriously. In keeping with our mission, vision, and core values, we have had in place Board Policies and Administrative Regulations that provide us with clear guidelines and procedures regarding child protection and safety. As we continue to evaluate and improve upon what we do utilizing best practice in all aspects of child protection, here are our Child Protection Guidelines and Procedures to ensure that everyone is aware of what we are doing to keep children safe...all day, every day. The framework of these guidelines and procedures is based on the United Nations â€˜Convention on the Rights of the Child,â€™ of which Malaysia is a signatory. It is also based on the Malaysia Child Act 2001, which makes it clear to all parties concerned that abuse, neglect, abandonment, or exposing a child to physical and/or emotional injuries while in Malaysia is punishable by law [Act 611]. As part of these guidelines and procedures, as mandated by ISKL Board policy, ISKL is committed to work in cooperation with Malaysian and international agencies and to fully cooperate with these agencies for the best interest of the child. In addition, ISKL will: 1. Provide thorough background checks on all employees. 2. Utilize best practices with respect to preventative safety measures on all campuses, at all times. 3. Provide training to faculty and staff on the signs of neglect and abuse, and the need to report abuse if they suspect a student is being abused. 4. Provide age appropriate lessons for all grade levels to help students understand personal safety, needs, and rights. 5. Continue to foster partnerships with our community stakeholders. 6. Provide materials and information sessions to all members of our community to help them better understand our policies and procedures. 7. Develop and implement best-practices procedures to conduct preliminary inquiries when there are disclosures of suspected child abuse or neglect involving a student at ISKL, either at home or at school or school events. 8. Ensure that it meets internationally recognized accreditation standards (i.e. CIS/WASC).
At ISKL we understand how vital it is for school employees and parents, with local and international agency cooperation, to work together in a unified partnership to honor and uphold these Child Protection Guidelines and Procedures adopted by the ISKL Board. Sincerely, Dr. Norma J. Hudson Head of School 5 Return to the Table of Contents
Scope and Purpose of these Guidelines and Procedures The purpose of the ISKL Child Protection Guidelines and Procedures (CPGP) is to provide a framework to institute child protection practices that create a sustainably safe environment for our students and to institute child protection procedures for preliminary inquiries when there is an allegation of child abuse or neglect. This CPGP handbook contains information about protecting our students from physical abuse, emotional abuse, sexual abuse, and neglect. Our efforts include student-student interactions, faculty/staff-student interactions, parent-child interactions, and students engaging in online interactions with others. It is divided into two major sections, an introduction and our procedures: 1. The introduction provides a context for these guidelines and procedures. This section includes: ● A message from the Head of School. ● A summary of expectations for child well being from the ISKL Board of Directors and our accrediting agencies. ● Relevant background information about child protection and the context of child protection in the international community of ISKL. ● ISKL’s Child Protection Policy Statement. 2. The procedures section includes: ● A set of key definitions, as well as signs and symptoms of physical, emotional, and sexual abuse, and neglect. ● A description of the different roles and responsibilities in implementing our comprehensive child protection procedures. ● The steps we take to prevent abuse or neglect from happening to our students. ● The procedures we follow to conduct preliminary inquiries and follow-up on any allegations of abuse or neglect to our students. Note that the details of these procedures are defined in a separate document titled “Preliminary Inquiry: Alleged Child Abuse or Neglect.” We believe that being ready for the common child protection issues that arise will increase our ability to respond to the uncommon and difficult cases. The results of implementing our child protection program include increased trust between teacher and student, increased discussion about safety issues in general between teacher and child, and even increased comfort of parents to talk with their child. When these procedures are in place and our community is aware of the procedures, worst-case scenarios are handled with less difficulty and more community support. This handbook does not include detailed information about our procedures for securing our campuses or our procedures when there is an emergency. These procedures are included, along with others, in ISKL’s Crisis Response Manual.
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ISKL Board of Directors and Accrediting Agency Expectations These ISKL Comprehensive Child Protection Guidelines and Procedures are consistent with the expectations outlined in the ISKL Board Policy Manual and in the rubrics guiding ISKL’s accreditation by the Council of International Schools (CIS) and the Western Association of Schools and Colleges (WASC). The ISKL Board Policy Manual, particularly in relation to all entries regarding student life, makes student safety and well being a highest priority. Student Health and Safety are covered in sections 3.0 and 4.3. These expectations are further developed and explained in the ISKL Code of Ethics for Teachers and Administrators (Section C.2F.1 in the Administrative Regulations). The ISKL Code of Ethics for Teachers and Administrators contains the four main sections below. Each of these sections is further defined and explained in the Administrative Regulations. 1. Administrators and teachers will guide children, youth and adults in the pursuit of knowledge and skills, to prepare them in the way of knowledge and skills, to prepare them in the way of democracy, and to help them to become happy, useful, self-supporting citizens. 2. Members of the teaching profession share with parents the task of shaping each student’s purposes and acts toward socially acceptable ends. The effectiveness of many methods of teaching is dependent upon cooperative relationships with the home. 3. The teaching profession occupies a position of public trust involving not only the individual teacher’s personal conduct, but also the interaction of the school and the community. Education is most effective when these many relationships operate in a friendly, cooperative and constructive manner. 4. Members of the teaching profession have inescapable obligations with respect to employment. These obligations are nearly always shared employer-employee responsibilities based upon mutual respect and good faith.
The CIS has specific expectations regarding student safety and well being as part of the accreditation process. CIS Expectations: These expectations are developed and explained through the nine (9) standards of Domain E: The Students’ Learning and Well Being. 1. Standard E1. The school environment is characterised by openness, fairness, trust, and mutual respect to support students' learning and well-being, listen to their views and develop their leadership qualities. 2. Standard E2. The school has documented and implemented effective written policies to safeguard and promote the welfare of children who are students at the school. 7 Return to the Table of Contents
3. Standard E3. The school implements policies and procedures in relation to anti-bullying, child protection, complaints, security, safeguarding, behaviour, discipline, sanctions, rewards and restraint, health education and boarders' health records. 4. Standard E4. The standards of health, safety and security are supported by written policies and effective procedures, which exceed, where possible, local regulatory requirements. 5. Standard E5. The school has policies and procedures in place to provide safety against hazards such as fire, earthquake or intruders: these exceed, where possible, local regulatory requirements. 6. Standard E6. The school provides health care and health education to support students' wellbeing and enhance access to learning opportunities. 7. Standard E7. There is an effective and implemented written policy and procedures, including risk assessment, to support the health and safety and security of students on activities outside the school. 8. Standard E8. The school offers university/college counselling, assessment, referral, educational and career planning guidance suitable to the age/maturation of all the students in its care. 9. Standard E9. Those students and families making transitions between the divisions of the school, and in and out of the school, are supported effectively through advice, counselling and appropriate information.
The WASC, as of the date of adoption, has not released their standards for child protection. They will be included in future revisions of the CPGP when available.
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Relevant Research and ISKL’s Malaysian Context International schools, like ISKL, are unique relative to our home country schools. Our students and faculty come from diverse backgrounds around the world where cultural norms and national laws might be quite different. This diversity is then placed in a new country where there are are yet another set of norms and laws. Given this diversity and the potential reasons why children may not be able to talk about any victimization they might have experienced, it is even more important for our school personnel to be knowledgeable about child protection. In addition to the ISKL’s School Board Policy, Administrative Regulations, and the CIS/WASC standards, we have obligations to local, national, and international laws protecting the rights of children, including the United Nations ‘Convention on the Rights of the Child,’ of which Malaysia is a signatory. In addition, Malaysian law and the Child Act 2001 make it clear to all parties concerned that abuse, neglect, abandonment or exposing a child to physical and/or emotional injuries is punishable by law [Act 611]. ISKL, in cooperation with Malaysian and international partners, is vigilant regarding these child protection matters. Each year these guidelines and procedures will be distributed to parents, and communicated to students, faculty, staff, and contractors. ISKL faculty, staff and contractors are trained on the possible warning signs of abuse and on our Board mandated reporting guidelines. All ISKL employees have a duty and personal responsibility to act in the best interests of a child. ISKL procedures require all faculty and staff to report any suspicion of neglect or abuse to the child’s counselor, who initiates a preliminary inquiry into the report. By enrolling your child at ISKL, you agree with the ISKL Board policy to work in partnership with the school to protect children from all forms of child abuse.
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ISKL Child Protection Policy Statement Child abuse and neglect are concerns throughout the world. Child abuse and neglect are violations of a childâ€™s human rights and are obstacles to the childâ€™s education as well as to their physical, emotional, and spiritual development. The International School of Kuala Lumpur (ISKL) supports the UN Convention on the Rights of the Child, of which our host country, Malaysia, is a signatory. All faculty, staff, and contractors employed at the International School of Kuala Lumpur must report suspected incidents of child abuse or neglect whenever the faculty, staff or contractor has reasonable cause to believe that a child has suffered, or is at significant risk of suffering, abuse or neglect. Reporting and follow up of all suspected incidents of child abuse or neglect will proceed in accordance with administrative regulations respective to this policy. Furthermore, cases of suspected child abuse or neglect may be reported to the appropriate employer, to the respective embassy, to the appropriate child protection agency in the home country, and/or to local authorities. The International School of Kuala Lumpur seeks to be a safe haven for students who may be experiencing abuse or neglect in any aspect of their lives. Each year these guidelines and procedures will be distributed to parents, and communicated to students, faculty, staff, and contractors. ISKL faculty, staff, and contractors are trained on the possible warning signs of abuse and on our Board mandated reporting guidelines. Annually, ISKL will conduct an audit of its child protection guidelines and procedures in order to refine and update policies in line with best practices and lessons learned. In the case that an ISKL employee, contractor, or volunteer is reported as an alleged offender, the International School of Kuala Lumpur will conduct a full inquiry following a carefully designed course of due process, keeping the safety of the child as the highest priority.
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Part II - Child Protection Guidelines and Procedures Definition of Terms / Signs and Symptoms of Abuse Child Protection is a broad term used to describe philosophies, policies, standards, guidelines and procedures to protect children from both intentional and unintentional harm. A Child Protection Policy is a statement of intent that demonstrates a commitment to protecting students from harm and makes clear to all what is required in relation to the protection of students. It serves to create a safe and positive environment for children and to demonstrate that the school is taking its duty and responsibility seriously. Child protection concerns include suspected, alleged, self-disclosed, or witnessed abuse of a child by anyone associated within or outside the school which must be investigated and followed by appropriate action. According to the World Health Organization, child abuse constitutes “all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power.” A person may abuse a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional (e.g. school) or community setting; children may be abused by individuals known to them, or more rarely, by a stranger. Often children may experience multiple forms of abuse simultaneously, further complicating the problem. Most child abuse is inflicted by someone the child knows, respects, or trusts. The impact of child abuse can persist for a lifetime after the abuse has been committed. Some victims of abuse are resilient and may not display observable signs of abuse; however, all forms of abuse have the potential for long-term impact on the victims. An important point to consider is that children often are exposed to multiple forms of abuse and suffer a myriad of symptoms. Abuse challenges the self-value, self-esteem, and sense of worth of its victims, rendering them hopeless, helpless and unable to live a complete life. Long term impact of child abuse includes: • Poor educational achievement • Inability to live according to plan/ability • Inability to coexist, cooperate or work with others • Inability to express love / or accept love • Prone to mental health problems • Post-traumatic stress disorder (PTSD) • Poor peer relations 11 Return to the Table of Contents
• Inability to complete responsibilities • Inability to care for self / Eating disorders • Lack of self-confidence, prone to addiction • Inability to lead family • Low self-esteem, depression and anxiety • Attachment difficulties • Self injury (e.g. suicide attempts)
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Child abuse is when a child is harmed physically, emotionally or sexually through mistreatment or neglect. Physical Abuse is causing internal or external physical injury, not by accidental means. Extreme discipline that causes the child pain or mental suffering is considered abuse. Physical abuse could include but is not limited to: • Hitting
• Kicking • Pushing • Shaking • Throwing • Suffocating • • Biting • Poisoning
• Drowning Burning
Possible indicators* of physical abuse: • Unexplained bruises, welts, cuts or fractures on any part of the body • Bruises of different ages or colours • Injuries reflecting the shape of an object • Injuries that regularly appear after absences • Unexplained burns or burns with a pattern • Injuries inconsistent with the information given by the child • Bald patches where hair may have been torn out • Fear of going home • May flinch if touched unexpectedly • Extremely aggressive or withdrawn • Poor sleeping patterns, frequent nightmares • Poor memory and concentration • Changes in emotion and/or behaviour
*Indicators in and of themselves do not constitute abuse or neglect. Together with other indicators and concerns they may warrant a referral to the CPCRT. Emotional Abuse is a pattern of behavior where a child is subjected to continuous and hurtful verbal abuse, which disregards a child’s emotional well-being. Emotional abuse could include but is not limited to: • Insults comparisons criticism • Put downs expectations
• Negative • Excessive • Rejection • Inappropriate • Yelling / swearing • Harmful threats
Possible indicators of emotional abuse: • Fear of failing • Fear of consequences, can lead to lying • Mood swings, withdrawal or aggressiveness • Mental or emotional development lags • Social isolation • Low self esteem, depression 13 Return to the Table of Contents
• Frequent psychosomatic complaints (e.g. headaches, nausea, stomach ache) • Bedwetting and/or diarrhea
Sexual Abuse is any act where an adult or a more powerful person includes a child in a sexual activity. Typically this occurs to satisfy the needs of the person in power. It can be consensual or not, and many cases of sexual abuse are done by a family member or someone the child knows and trusts; therefore, children can be groomed, blamed, or manipulated to keep secrets. Sexual abuse could include but is not limited to: • Penetrative or non-penetrative sexual acts • Sexual intercourse, anal or oral sex • Touching of genitals or breasts • Undressing or exposing oneself • Forced viewing of sexual acts, genitals, or pornographic media • Developmentally inappropriate conversations about sexual content • The exploitation of a child in prostitution or other unlawful sexual practices
Possible indicators of sexual abuse: • Sexual knowledge, behaviour or language not appropriate to age level • Unusual relationship patterns • Sexually transmitted infection in a child of any age • Frequent urinary tract infections in both boys and girls • Evidence of physical trauma or bleeding to the oral, genital or anal areas • Difficulty in walking or sitting • Bedwetting • Not wanting to be alone with an individual • Pregnancy, especially at a young age • Extremely protective parenting • Having secrets that they cannot tell anyone about • Reluctance to change into PE clothes, fear of bathrooms • Behavioural/emotional disturbances
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Neglect is chronic or persistent failure to meet a child’s basic physical or psychological needs, in the context of resources reasonably available to the family. Neglect could include but is not limited to: • Inadequate food, shelter and clothing • Lack of hygiene • Not protecting a child from other forms of abuse • Lack of supervision by a parent or legal guardian • Not providing needed medical treatment • Emotional isolation, lack of affection/attention • Failure to support a child’s educational needs
Possible indicators of neglect: • Child is hungry or inadequately dressed or unwashed • Parents are uninterested in child’s academic performance • Parents do not respond to repeated communications from the school • Parents or legal guardian are absent for more than 24 hours** • Parents or legal guardian cannot be reached in the case of an emergency • Child does not want to go home, feels lonely and uncared for at home • Unattended medical or dental needs • Developmental delays • Irregular or non attendance in school • Demands constant attention and affection • Regularly displays fatigue or listlessness • Self destructive behaviours • Lack of trust in others
**Note: ISKL guidelines requires that a parent or legal guardian be a full time resident of Kuala Lumpur. Should parents/guardian leave Kuala Lumpur for any reason they are required to complete a temporary guardianship form. These guardianship forms are stored in the divisional administrative offices.
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Child Protection Groups - Roles and Responsibilities At ISKL, there are two important groups which directly support our Child Protection Policy. These groups play specific roles in the development and implementation of our prevention and responsiveness stages. These two groups are: 1. Child Protection Team (CPT) 2. Child Protection Case Response Team (CPCRT)
The ISKL Child Protection Team (CPT) The CPT ensures that there is a comprehensive Child Protection Program (CPP) in place at the school and annually monitors the effectiveness of the program. Specific tasks include: • Ensure a comprehensive CPP is in place for school. • Ensure/guide professional development for training for all faculty, staff, volunteers, and contractors regarding the CPP. • Oversee development of and revisions to CPGP. • Ensure/guide parent education programs to support understanding of the objectives and goals of the CPP policy. • Serve as a resource group in working with cases requiring child protection; assist reporting and follow-up disclosures to the school leadership or where appropriate. • Supports school credentialing. The Child Protection Team (CPT) will consist of: • Director of Risk Management and Student Services--serves as head of CPT • Administrator – Head of School or designated principal(s) • Divisional Psychologist(s) • Counselor(s) • Student Health Coordinator(s) • Representative from each division • Additional resources (as appropriate) The CPT meets at least twice annually: 1) The first meeting is to plan for the school year. 2) The second meeting will be to conduct the internal audit of the CPGP based on best practices and lessons learned. The team will assess implementation and make recommendations for implementation of new or revised procedures. The team will also assess faculty and staff readiness and qualifications, including which additional training or certifications should be pursued. 16 Return to the Table of Contents
3) Additional meetings may be held as necessary.
The ISKL Child Protection Case Response Team (CPCRT) When there is an allegation of abuse, ISKL will standup a CPCRT to respond to that specific allegation. The purpose of the CPCRT is to respond to allegations of abuse. It is essential for the CPCRT to recognize the limitations of their expertise and to involve local resources or other consultant expertise as necessary. The team will gather needed information to determine what the next steps should be. The Child Protection Case Response Team (CPCRT) will consist of: • The individual (when an adult) reporting the case • Director of Risk Management and Student Services (as inquiry manager) • Counselor (as case manager) • School psychologist • Student Health Coordinator • School personnel making the report in accordance with school policy and procedures • Division-level principal • Division-level administrator or other designee(s) as determined by Head of School • Depending on case, involvement of local resources or consultant expertise The CPCRT will meet based on need. The team will look at school policy and the nature of the abuse in order to determine the next steps for action.
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Prevention Campus Security and Facilities Management ISKL views security of our students, faculty, and staff as a collaborative process that enables student learning and growth to occur in a supportive and nurturing environment. As such, we have implemented a variety of measures, both physical and procedural, that improve our ability to provide that environment. Central among these are measures that reduce the likelihood of a child protection incident from occurring, including the implementation of background checks for those with access to our students, relationships with the Malaysian polis, and a vigilant and trained guard force. The Risk Management and Student Services team includes trained professionals with backgrounds in criminal investigations, physical security, student health, and risk mitigation. We maintain relationships with a variety of professionals that improve our ability to provide a safe environment for our students. These include Malaysian and third-country experts in child protection.
Human Resources Management ISKL conducts background checks on faculty, staff, volunteers and coaches, including contractors, as a condition of hiring. Reports are submitted to the Human Resources Office prior to commencement of duties. ISKL includes language regarding background checks into its employment contracts. Background checks have a five year lifecycle and will be re-done every five years. In order to make recruitment decisions, a full review of potential candidatesâ€™ previous employment history, qualifications and professional references (confidential) occurs. For qualified candidates, confidential personal reference checks are performed before a job offer is extended. Search Associates and International School Services (ISS) are used as recruiting agencies for the majority of our faculty hired overseas. The prospective employee web page states requirements for prospective faculty.
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Education and Training Educating Students - Empowering Students to be Their Own Advocates Our students need to be empowered to advocate for their own well being. The counselors at each division play a key role in these efforts, especially in their role regarding social/emotional well being, as does the pastoral care aspect of our divisional programs. In the Elementary School this is achieved through counselors working with classroom teachers to teach students the fundamentals of child protection. In the Middle School, the Health curriculum and the Homegroup program include information for students about personal advocacy and safety. In the High School, Health course and the Advisory Program engage students in personal advocacy and healthy relationships training. The High School counselors also have an opportunity to work more closely with students in Grade Level Seminars.
Training Parents - Engaging Parents as Our Partners in Child Protection Our Head of School, divisional administrators, and divisional counselors are committed to engaging parents as our partners in child protection. We strive toward this goal through clear and consistent communication about our commitment to our Child Protection Guidelines and Procedures. This is done through Panther News, Parent Orientation Assemblies, Head of School Coffees, Grade Level Coordinator (GLC) meetings, and Parent Sessions organized by our counselors. In particular, the Parent Sessions organized by our counselors provide greater time to engage parents in talking about healthy adult-student relationships and the various ways we can work together in partnership for child protection.
Training Faculty, Staff, and Contractors - Ensuring Healthy Adult-Student Relationships We recognize the importance of educating our faculty, staff, and contractors about our commitment to Child Protection and about ways that adults can maintain and nurture healthy adult-student relationships. We annually train faculty, staff and contractors about our Child Protection Guidelines and Procedures. Our commitment to educating our faculty and staff goes beyond sharing information about our policies and procedures. This commitment is grounded in the work of David Wolowitz, who developed four guideposts which support healthy adult-child relationships. These four guideposts are (1) roles, (2) boundaries, (3) power, and (4) accountability. When interacting with other human beings, especially when it is an adult-student relationship, it is very helpful to use these four guideposts as guidance to making healthy decisions. 1. Regarding roles, the adult must a. Always act as a role model 19 Return to the Table of Contents
b. Stay in your professional role(s) c. Avoid peer or parent roles 2. Regarding boundaries, the adult must take responsibility to a. Set and maintain boundaries b. Keep boundaries clear, consistent and appropriate for the circumstances 3. Regarding power, the adult must a. Use their influence to promote positive developmental growth b. Be alert to the impact of their actions, not just their intentions c. Avoid creating dependency 4. Regarding accountability, the adult must a. Put the interests of the student first b. Act consistently with the expectations of the school c. Act transparently and unambiguously d. Communicate concerns about possible misconduct to the appropriate administrators
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Table 1: ISKL Child Protection Program Annual Calendar of Activities Timeframe
Inform Board, faculty and staff, students, and parents about Child Protection program at ISKL
Head of School
Inform new families of school Child Protection program
Admissions office, counselors
Convene Child Protection Team
Head of School
Review data from previous school year - develop implementation plans for current year
Child Protection Team
Train all faculty and staff on details of our program, individual responsibilities and how to manage disclosure
Principals, Counselors, Head of School
Implement annual plan
Child Protection Team and principals
Teach lessons to students
Inform parents in writing and hold parent evenings to discuss child protection
Ensure all new and returning faculty and staff, volunteers and contracted service providers sign code of conduct
Continue lessons within curriculum plan
Ensure lessons have been taught
Convene Child Protection Team to review implementation
Director of Risk Management
Review hiring practices to ensure: background screening, criminal history check, reference check includes discussion of child protection history
Head of School, H.R. Director, Principals, Director of Risk Management
Review/revise curriculum and recommend resources as needed
Principals, Curriculum Coordinator and teachers
Inform new families of Child Protection Program
Hold parent evening
Convene Child Protection Team - Update and review activities of first semester; make recommendations for areas of need.
Director of Risk Management
Orient new students to Child Protection Program
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Convene Child Protection Case Response Team
Case manager/inquiry manager
Train new hires on details of our program, individual responsibilities and how to manage disclosure
Principals, Counselors, Head of School
Case Synchronization Meeting
Director of Risk Management/Counselors
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Response Procedures ISKL’s commitment to preventing any form of harm to students is very strong. However, we are also prepared to respond to situations when there is a breach in these prevention strategies. The details of these procedures are presented in a separate document titled “Preliminary Inquiry: Alleged Child Abuse or Neglect.”
Overview of Response Procedures As per Administration Regulations B.3.2: all ISKL employees including staff, faculty, and administrators are mandated to report suspicion or incidences of child abuse or neglect to the student’s counselor, who then informs the divisional principal. All ISKL employees, volunteers, and contractors will be trained on a yearly basis in identifying signs of abuse and neglect and the appropriate steps they should take if they suspect or observe the occurrence of these events. The first step is to report their concerns to the counselor of the student(s) involved in the incident as soon as they can reasonably do so. If they do not know who the counselor is, the witness will report the allegation to the Director of Risk Management. The report must be made within 24 hours. ISKL staff are also prepared to respond to reports of potential abuse from students, families, and other community stakeholders. Once the allegation has come to the counselor’s attention, the counselor’s top priority is to support the immediate safety of the student. Steps to ensure student safety are dependent on the allegation and surrounding circumstances and may include: ● Supervising, limiting, and/or eliminating contact with the alleged abuser ● Informing necessary stakeholders (e.g., parents, teachers) ● Informing additional school professionals in order to support the safety of siblings and other family members ● Identifying safe places and/or supportive adults ● Sharing community or school resources with the student and/or the student’s family ● Encouraging and supporting access to a medical examination ● Collaboration with other stakeholders who can support the student’s safety Once the student’s immediate safety is secured, the counselor and one other member of the CPT shall interview the employee, student, or other stakeholder who made the report and collect necessary background information as it pertains to the allegation. If the findings determine there is no reasonable cause for a formal preliminary inquiry, the counselor would conduct appropriate steps to further promote the safety and well-being of the student(s) involved. This might include observing or meeting with the student(s), having follow-up conversations with the individual(s) that made the report, and/or consulting with and providing resources to the student’s family. When a preliminary inquiry is initiated, this will be noted in PowerSchool; details about the inquiry and the support provided will be maintained in a separate confidential file at the school. 23 Return to the Table of Contents
If there is reasonable cause If there is reasonable cause based on the allegation or report, the counselor will share this with the principal and Director of Risk Management to inform them a formal preliminary inquiry is needed. With the guidance of the principal, the CPCRT is stood up. It is the responsibility of the principal to report the incident, and the rationale for the need to investigate the allegation, to the Head of School. The Head of School then informs the Board Chair that the preliminary inquiry has begun. The CPCRT would then follow the format provided by the “ISKL Preliminary Inquiry Child Abuse and Neglect Report.” These steps include but are not limited to: documentation of contacts related to the allegation, including dates; review of previous historical concerns based on a file review; interviews with appropriate teachers or counselors; interview and consultation with the nurse or appropriate administration; and finally interview(s) by appropriate team member(s) with the child. For the sake of the child’s comfort, the interview should take place in the counselor’s office with two clinicians present, one to interview and one to record. Clinicians then cross validate what they heard during the session and discuss possible follow up questions and/or next steps. Given the nature of these situations, no two preliminary inquiries will be alike. The time frame of the preliminary inquiry and how it is conducted will depend on the developmental age of the child, the allegation(s), background information obtained, the preliminary inquiry process, and findings. Communication should be ongoing between the CPCRT, the Principal, and Head of School in order to provide updates and agreement with respect to moving forward and action steps that might be required regarding the inquiry findings. Preliminary Inquiry Findings Do Not Support Allegations Once the preliminary inquiry is complete, the CPCRT will write up a report of findings and share these findings with the principal, who shares this with the Head of School. If the Head of School, after consulting with the CPCRT, concludes the allegations of neglect or abuse were not substantiated, they will share these conclusions with the Board Chair. Although the allegations were not substantiated, the child’s counselor will provide appropriate follow up services to the child and the child’s family if needed. Follow up services could include meeting with the student, providing recommendations to classroom teachers for supporting the student (while maintaining confidentiality with regard to the inquiry), and/or working with the student’s family to provide consultation and resources. Preliminary Inquiry Findings Do Support Allegations If the Head of School, after consulting with the CPCRT, concludes the allegations of neglect or abuse were substantiated, she/he would share this conclusion with the Board. The Head of School then determines the next appropriate steps given the unique situation of every inquiry. 24 Return to the Table of Contents
Report Suspicion of Abuse Directly to Royal Malaysian Polis Woman and Child Protection Division (D-11) Given the sensitivity of investigating an allegation of abuse involving a student from an international school in Malaysia, the Assistant Commissioner of Police, Director of the Bukit Aman’s Woman and Child Protection Division (D-11), requests that the Head of School contact and report the situation to her directly, as she would supervise the formal police investigation. The Principals would also work with the child’s counselor and team to determine additional options to support the student and family.
Confidentiality As the inquiry is a confidential matter, all records will be kept in the child’s confidential file. When children transfer to a different school, the new school is informed there is a confidential file. ISKL will make every attempt to inform the child’s new school of the previous inquiry and findings in order to protect the child. Members of the preliminary inquiry team are also required to hold the conduct of the inquiry and findings confidential.
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ISKL Protocols for Inquiry and Response to Six forms of Suspicion, Allegation or Disclosure of Abuse There are seven types of potential suspicions, allegations, or disclosures of abuse involving different populations identified here, and we are prepared to respond to each of them. The core of our response is consistent, regardless of the type of disclosure, and follows the process outlined in the Response Procedures section of this document. The seven types of potential suspicions, allegations, or disclosures of abuse are listed below: 1. Disclosure involves Threat of Harm to Self 2. Disclosure Involves Threat of Harm to Other Students (Student-Student) 3. Disclosure Involves Faculty/Staff-Staff/Faculty 4. Disclosure Involves Faculty/Staff - Student 5. Disclosure Involves Parent/Outsider - Child or Student 6. Disclosure Involves Outsider/Online - Student 7. Disclosure Involves Other Scenarios Protocols for managing these disclosures are outlined in detail on this document: Protocols for Inquiry and Response
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Summary What do our Child Protection Guidelines and Procedures mean for the ISKL community? ISKL is defining a standard for the treatment of all children and youth - that they be treated with respect and dignity at all times. We believe that ISKL has a professional and ethical obligation to protect all children and youth in our care. Child abuse is a violation of a childâ€™s human rights and has detrimental effects on a childâ€™s physical, cognitive, emotional, behavioral, and social development. Child abuse occurs when a child is harmed physically, emotionally or sexually through mistreatment or neglect. The effects of abuse can be long lasting and pervasive. Child abuse and neglect, whether that be in a childâ€™s home, neighborhood or school, is a concern throughout the world. ISKL takes these issues very seriously, and as educators we are keenly aware of the extreme importance of providing children a safe and secure educational environment in which to develop, grow, and thrive, every moment of every day. ISKL is very committed to providing best practice prevention methods and procedures to assure every child is always safe. We work in collaboration with local and international partners to assure we continue to maintain the highest standards of care regarding these matters, while always providing a stimulating, secure environment in which to learn. These guidelines and procedures will be distributed to parents each year and by enrolling your child at ISKL you agree to work in partnership with the school to ensure our children are safe and protected. Teachers and staff will be trained each year on how to identify and report abuse and neglect. We need to ensure that all children and youth in our care are afforded a safe and secure environment in which to grow and develop. Children and youth have legal and moral rights and when given reasonable cause to believe that these rights have been violated, ISKL will seek all available resources to restore those rights.
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Part III: Appendices
Appendix 1 - School Personnel Roles and Responsibilities Appendix 2 - Monitoring the CPP Safe Environment Compliance Audit Self-Audit Form Appendix 3- References
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Appendix 1 - School Personnel Roles and Responsibilities
Board of Directors ● Approval of Child Protection (CP) Policy. ● Public statement of school as safe haven for children. ● Public statement of support for CP Policy. ● Meeting of parents with support for CP Policy as important topic. ● Attendance at board-level CP training. Head of School ● Create and support Child Protection Team (CPT). ● Initiate the process of the adoption of a Child Protection Policy and Child Protection program. ● Gain Board cooperation and approval for Child Protection Policy. ● Provide resources in the budget on an annual basis for the Child Protection Team to ensure resources as needed. ● Provide proactive leadership in connecting school with local child service agencies, with other schools. ● Ensure external organizations, vendors, contracted service providers and other entities comply with the school's Child Protection Program and that the school provides an annual in-service program for these personnel. Principals ● Direct oversight of Child Protection Team for adoption of CPP and CP Curriculum ● Review the CP Policies ● Coordinate the development of and ensure proper implementation of comprehensive Child Protection Program Director of Risk Management and Student Services ● Head of Child Protection Team. ● Heads preliminary inquiry of alleged abuse. ● Develop a calendar of professional development, instituting the curriculum and annual review cycle for the success of the program ● Ensure external organizations, vendors, contracted service providers and other entities comply with the school's Child Protection Program and that the school provides an annual in-service program for these personnel. Example: food service personnel, security personnel, school trips, coaches who are not part of school staff, after school activities personnel or other outsource agencies. ● Submit Child Protection Guidelines and Procedures to school lawyer for compliance with local laws and international conventions/obligations as required. ● Lead CPT audit of CPGP on an annual basis and as required. ● Maintain records of child protection training for all divisions and departments in conjunction with HR.
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Counselor or Divisional Psychologist ● First line responder to whom suspected cases of child abuse are reported. ● Maintains communication with divisional principal during preliminary inquiry process. ● Establishes and maintains communication with families as appropriate during or after inquiry process. ● Determines and implements steps to support student safety during inquiry process. ● Provides follow-up resources and support to students and families as appropriate, both during inquiry and after its completion. ● Consults with Head of School, Director of Risk Management and Student Services, and divisional principals to develop a calendar of professional development, instituting the program and annual review cycle for the success of the program. ● Leads professional development sessions for faculty, staff, volunteers, and contractors. ● Leads informational sessions for parents and community members about the child protection policy and supporting student safety. Teachers ● Understands role within CPT, most importantly as a mandated reporter when abuse is suspected, observed, or disclosed. ● Will serve on the CPT as needed. ● Attends necessary training for the Child Protection Program. Student Health Coordinator ● Applies professional and clinical knowledge in order to identify signs of child abuse and neglect. ● Documents and maintains accurate records, including the use of a body map to document and identify specific anatomical marks or injuries. ● Adheres to ISKL’s policy on Child Protection and refers to the appropriate person in accordance with this policy. ● Attends regular training and education in child protection.
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Appendix 2 - Monitoring CPP Annual CPGP Compliance Audit This questionnaire is designed to summarize, on an annual basis, the responses from teachers and others charged with the responsibility of implementing the personal safety/abuse prevention education classes for children. It collects both quantitative and qualitative data on training; implementation; teacher, parent, and student responses to the safety program; and the reporting of suspected cases of child maltreatment. Summarizing this data across the school can be useful in determining the overall state of program implementation. The questionnaire can easily be adapted for distribution to individual teachers. Principal/Head of School/Contact person: ________________________________ Phone: _______________ Fax: _______________ Email________________________________ Training 1. Are all current faculty, staff, contractors, and volunteers trained in (name of safety curriculum)? Yes
2. Do you need additional facilitators or staff to train your faculty, staff, contractors, and volunteers? Yes
No Comments: _________________________________________________________________
If you answered â€œYesâ€? to Question 3 above, how many staff do you need trained? _______________________________________________________ Abuse/Neglect Reporting 1. Did you or any of your staff file an abuse/neglect report in the 20XX/20XX school year? Yes
If yes, how many? _____________________
2. Age and gender of each of the child(ren) who was/were the subject of the reports: Age(s):___________________________
3. How many of the reports were made because a child disclosed some form of abuse or neglect? _____________________________ 32 Return to the Table of Contents
4. How many of the reports were made because an employee or volunteer observed or suspected that a child was being abused or neglected? Observed: _______ Suspected:________ Other:______________________ 5. How many reports were made because the abuse/neglect was observed, suspected or disclosed by someone else? Who? (a neighbor, another child, etc.) ______________________________________ 6. Who was suspected of committing the abuse or neglect that was reported? Family: _______ Neighbor:________ Another Child:________ Clergy:_________ School Staff or Volunteer:________ Other Known to the Child:_______ Stranger:________ 7. After a decision was made to contact (authorities), please indicate when the phone contact was made. immediate
within 24 hours
other, please describe _______________
8. On average, how long after the call were the written reports (if required) filed? _______________ 9. To what department or office were reports also made? Department/office contacted____________________ There was no notice to any outside department
Any other comments: ________________________________________________________________
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Self-Audit Form Purpose and Overview The intent of this self-assessment guide is to help ISKL determine to what extent we are implementing the overall policies for child safety at the agency level. This self-assessment can be used by leadership and staff to determine if all safe environment policies are being followed as well as to help determine where there might be a need for more training in the implementation of the Policy’s requirements. If the School Child Protection Policy is going to be effective in creating safe environments for children, it is important that all school personnel know: • How to create safe environments in their school • How to implement school policies concerning training of all faculty, staff and volunteers • How to implement school policies concerning background evaluations of employees and volunteers • How to implement (if applicable) the school’s policy on contractors, vendors, and other external individuals providing goods and services to the school when children are present • The name of the people responsible for the implementation of the Policy at the school • Who schedules the CP training for adults • Who is responsible (if applicable) for training children at the school • How to report allegations and to whom • What are the laws and resources in the country, with access to relevant authority of those laws • How to get outreach for a victim, his/her family, or the school community This self-assessment guide is intended as an internal document solely for the use of the school. 1. Is the existence of the school’s child safety policy and procedures publicized to all school personnel and parents? Yes
If Yes, describe the types and frequency of publications. (Examples might include publication in school bulletins, information provided at staff meetings, brochures and/or posters in the vestibules, take home letters, or school orientation materials). ___________________________________________________________________________ If No, provide explanation. _____________________________ 2. Do all school leadership, faculty, employees, and volunteers know when and how to report an allegation of sexual abuse of a minor? Yes
If No, provide explanation. _______________________________
3. Do school leadership and others know how to obtain outreach for victims? Yes
If No, provide explanation. _______________________________
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4. a) Are copies of the code of conduct and/or school standards of behavior made available to all personnel and volunteers in positions of trust who have regular contact with children? Yes
b) Is the code of conduct made available and clear to all other members of the school community? Yes
If No, provide explanation. ________________________________
5. Is safe environment/child abuse prevention training provided for all school adults as required? Yes
If No, provide explanation. ________________________________
6. Does the school participate in a multidisciplinary team or network with other international schools or government/nongovernment agencies? Yes
If No, provide explanation. ________________________________
7. a) Does school leadership ensure that background evaluations are conducted on all personnel to include faculty, staff, and other paid personnel and volunteers whose duties include ongoing, unsupervised contact with minors? Yes
b) Does the principal (if applicable) ensure that background evaluations are conducted on all school personnel (including volunteers) whose duties include ongoing, unsupervised contact with minors? Yes
If No, provide explanation. ________________________________
8. Does school leadership verify that background and criminal history checks have been conducted for contractors, vendors, consultants and others who provide goods and services to the school (in the presence of minors) or who bring minors onto school property? Yes
If No, provide explanation. ________________________________
9. If allegations of sexual abuse of children which have been brought forward during this current audit period: a) Has school leadership kept the school and its constituents informed? Yes
b) Has the school provided or facilitated outreach to affected persons or groups? Yes
Name of the person completing this self-assessment: _______________________________________
Appendix 3 - References 35 Return to the Table of Contents
AISA Child Protection Handbook. Association of International Schools in Africa (2014) Shanghai American School - Child Protection Policy Working Together to Keep Children and Young People Safe, Ministry of Social Development, New Zealand (2011) Safeguarding Children and Young People, Royal College of Nurses, United Kingdom (2014) Child Protection System in Malaysia. Ministry of Women, Family and Community Development and UNICEF, Malaysia (2013) Safe Guarding Children and Young People. Royal College of General Practitioners, UK (2011) https://www.childwelfare.gov/pubs/factsheets/long_term_consequences.cfm http://www.aifs.gov.au/cfca/pubs/papers/a143161/cfca11.pdf Finkelhor, D and Jones, L. (2006). Why have Child Maltreatment and Child Victimization Declined? Journal of Social Issues, 62(4): 685-716. Finkelhor, D. (2009). The Prevention of Childhood Sexual Abuse, The Future of Children, 19(2),169-194. Finkelhor, D. (2007). Prevention of Sexual Abuse Through Educational Programs Directed Toward Children. Pediatrics, 120(3), 643. Hopper, J. (2012). Child Abuse Statistics, Research and Resources, downloaded from www.jimhopper.com. Jones, L. and Finkelhor, D. (2009). Updated Trends in Child Maltreatment: Durham, NH. Crimes Against Children Research Center. Plummer, C. (2013, March). Using Policies to Promote Child Sexual Abuse Prevention: What is Working? Harrisburg, PA: VAWnet, a project of the National Resource Center on Domestic Violence. WHO and ISPCAN, (2006). Preventing child maltreatment: a guide to taking action and generating evidence. Malaysia are signatories to the 'Convention of the Rights of the Child,' (UNICEF). Keeping Children Safe in Education Today. NSPCC, UK (June 2013) Child Abuse and Neglect in the UK Today. NSPCC, UK (2012) Child and Partner Abuse. Ministry of Health, NZ (2002) Safe Guarding Children and Young People. Royal College of Nursing, UK (2014) 36 Return to the Table of Contents
Working Together to Keep Children and Young People Safe. Child, Youth and Family Services, Department of Social Welfare, NZ (2014) Child Maltreatment. National Association of School Nurses (January, 2014) Power point presentation on Malaysian Child Protection 2012 Child Protection Conference (Malaysia, 2012)
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