Safeguarding & Child Protection Policy

Including Online Safety, Staff Conduct, Safer Recruitment, Live Lessons and One-to-One Sessions. IWS Online School is committed to safeguarding and promoting the welfare of all children and young people who learn with us.

This policy is mandatory reading for all staff, volunteers and contractors. It must be read before working with any IWS student.

1. Policy Statement

IWS Online School (“IWS”, “the School”, “we”) is committed to safeguarding and promoting the welfare of all children and young people who learn with us.

Although IWS delivers education online, our duty of care is the same as any school. The welfare of the child is our first priority. Every child has the right to learn in a safe, respectful and supportive environment, free from abuse, neglect, exploitation, bullying, discrimination and inappropriate adult contact.

Safeguarding is everyone’s responsibility. Every adult working with or on behalf of IWS must understand this policy, follow it in practice, and report concerns immediately.

This policy explains how IWS prevents harm, recognises safeguarding concerns, responds to disclosures, manages online safety risks, maintains professional boundaries, recruits staff safely, and works with parents, carers, partner schools and safeguarding authorities.

2. Purpose of This Policy

This policy is designed to:

• protect children and young people who learn with IWS;
• provide clear safeguarding expectations for all staff and representatives of IWS;
• explain how concerns about a child should be reported, recorded and escalated;
• set clear rules for online lessons, one-to-one sessions, communication and professional conduct;
• support safe recruitment, vetting and staff training;
• ensure safeguarding information is handled securely and shared appropriately when necessary to protect a child;
• ensure IWS has a consistent approach across different countries and time zones;
• meet the safeguarding expectations of our accrediting body, Cambridge Assessment International Education, and reflect best practice in line with UK statutory safeguarding guidance.

3. Scope of This Policy

This policy applies to:

• all IWS students, including prospective students attending trial lessons or discovery sessions;
• all parents, carers and guardians interacting with IWS;
• all staff, teachers, tutors, Success Coaches, administrators, admissions staff, contractors and volunteers;
• partner schools, agents and third parties who interact with IWS students;
• all online learning spaces, including live lessons, one-to-one sessions, group lessons, student clubs, forums, chat functions, emails, recordings and learning platforms;
• any in-person IWS activity, including summer schools, events, assessments or meetings.

Where a student is based outside the UK, IWS will consider both UK safeguarding good practice and the child protection laws and reporting systems of the country where the child lives.

4. Legal and Regulatory Framework

Regulatory position. IWS Online School is a Cambridge Assessment International Education registered centre. It is not currently registered as an independent school with the Department for Education (DfE) under the Education Act 2002. As such, UK statutory guidance — including Keeping Children Safe in Education (KCSIE) and Working Together to Safeguard Children — is not legally binding on IWS in the same way it is on registered independent or maintained schools. However, IWS voluntarily commits to meeting the standards set out in this guidance because it represents best practice for any organisation providing education to children. IWS also has legal obligations under the Acts listed below that apply to all persons and organisations working with children, regardless of registration status.

This policy has regard to the following legislation and guidance:

Primary Legislation

• Children Act 1989 — welfare of the child is paramount; duty of care obligations.
• Children Act 2004 — s.11: duty on all agencies and persons working with children to safeguard and promote their welfare.
• Education Act 2002 — safeguarding duties for education providers; applied voluntarily by IWS.
• Safeguarding Vulnerable Groups Act 2006 — regulated activity and barring.
• Protection of Children Act 1978 — indecent images of children.
• Sexual Offences Act 2003 — sexual offences against children.
• Female Genital Mutilation Act 2003 (as amended by the Serious Crime Act 2015) — FGM and mandatory reporting duty.
• Modern Slavery Act 2015 — child trafficking and exploitation.
• Counter-Terrorism and Security Act 2015 — Prevent duty (applied as best practice by IWS).
• Domestic Abuse Act 2021 — children as victims of domestic abuse.
• Online Safety Act 2023 — duties for online services used by children; key child-safety duties in force from 25 July 2025.
• UK GDPR and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 — lawful processing and sharing of personal data.
• Equality Act 2010 — protected characteristics; duty not to discriminate.
• Human Rights Act 1998 — right to life; right not to be subjected to inhuman or degrading treatment.
• Children’s Wellbeing and Schools Bill (currently progressing through Parliament, 2025–26) — this policy will be updated to reflect any new duties introduced when the Bill is enacted.
• Relevant international child protection laws and mandatory reporting requirements, as applicable to the countries where IWS students are based.
• UN Convention on the Rights of the Child.

Statutory and Best-Practice Guidance

• Keeping Children Safe in Education (KCSIE) 2025 — DfE statutory guidance, followed by IWS as best practice. The edition applying from 1 September 2026 will be adopted at next review.
• Working Together to Safeguard Children 2026 — DfE statutory guidance, followed by IWS as best practice.
• Prevent Duty Guidance for England and Wales 2023.
• Information Sharing: Advice for Practitioners Providing Safeguarding Services 2024.
• Inspecting safeguarding in early years, education and skills settings — Ofsted 2023.

5. Safeguarding Principles

IWS follows these safeguarding principles:

• The welfare of the child is paramount.
• Safeguarding is everyone’s responsibility.
• Concerns must be shared quickly and never ignored.
• Staff must not investigate concerns themselves.
• Children must be listened to, taken seriously and supported.
• Information must be recorded accurately and shared only with those who need to know.
• Data protection law must never be used as a reason to delay sharing information where a child may be at risk.
• Online learning requires clear boundaries, secure systems and active monitoring.
• Safer recruitment and staff training are essential to preventing harm.
• IWS will act in the best interests of the child, even where concerns involve adults, staff, parents, carers, partner schools or third parties.
• Safeguarding practice must be anti-discriminatory and anti-racist. Racism and discrimination will never be used to explain away or minimise a safeguarding concern.

Where information is shared to protect a child, IWS does so in line with data protection law, which permits the sharing of personal data — including special-category data — where necessary to safeguard a child.

6. Key Safeguarding Roles and Responsibilities

6.1 Governing Body / Proprietor

The governing body and proprietor hold overall accountability for safeguarding at IWS. They must ensure that:

• an effective safeguarding and child protection policy is in place, reviewed at least annually and published on the school website;
• a named governing body safeguarding lead is appointed with appropriate training;
• the DSL has sufficient time, resource and authority to carry out their role effectively;
• all required pre-employment checks are completed before staff work with students, and the Single Central Record (or equivalent) is maintained and up to date;
• the school contributes to multi-agency safeguarding arrangements where relevant;
• the governing body receives an annual safeguarding report from the DSL;
• governors and proprietors complete safeguarding training appropriate to their role;
• safeguarding is considered as part of all decisions about school strategy, operations and expansion.

6.2 Designated Safeguarding Lead (DSL)

The DSL leads safeguarding and child protection at IWS. The DSL must be a member of the senior leadership team and must have sufficient time allocated to fulfil the role effectively. Every member of staff must know who the DSL is and how to contact them.

The DSL is responsible for:

• receiving and managing safeguarding concerns from all staff;
• deciding what action is required in each case, including whether to make a referral to children’s social care, the police, the LADO or equivalent authority;
• maintaining secure and confidential safeguarding records;
• ensuring all staff understand and can follow safeguarding reporting procedures;
• supporting students, staff and families where safeguarding concerns arise;
• attending and contributing to child protection conferences, strategy discussions and multi-agency safeguarding meetings as required;
• ensuring cross-border safeguarding routes are identified and maintained for countries where IWS students are based;
• keeping safeguarding procedures under review and initiating policy updates when required;
• completing DSL-specific training every two years and refreshing knowledge and skills at least annually;
• ensuring the school’s filtering, monitoring and digital platform safeguards are reviewed at least annually;
• reporting to the governing body on safeguarding matters at least annually.

When the DSL is unavailable (including outside UK business hours), the Deputy DSL assumes all DSL responsibilities. A rota for out-of-hours cover is maintained by the DSL and made available to all staff. Contact details for both the DSL and Deputy DSL are published in Section 33.

6.3 All Staff

All staff must:

• read and follow this policy before working with any IWS student;
• complete safeguarding and online safety training before working with children, and update it at the required intervals;
• understand the signs of abuse, neglect, exploitation and online harm;
• report all concerns to the DSL on the same day — do not wait to be certain;
• maintain professional boundaries at all times;
• use only approved IWS communication channels;
• never promise confidentiality to a child where safeguarding is involved;
• record concerns factually and promptly;
• cooperate with safeguarding referrals and investigations;
• report concerns about adults, including low-level concerns;
• challenge and report any discriminatory or racist behaviour they witness, including in online sessions.

7. Types of Abuse and Harm

Safeguarding concerns may include, but are not limited to, the following. Staff do not need to decide whether abuse has occurred — they only need to recognise that something may be wrong and report it to the DSL.

8. Specific Safeguarding Issues

In addition to the types of abuse in Section 7, all staff should be aware of the following specific safeguarding issues. Annex B of KCSIE 2025 contains further detail on each topic.

8.1 Female Genital Mutilation (FGM) — Mandatory Reporting

Mandatory reporting duty. Under s.74 of the Serious Crime Act 2015, any member of staff who, in the course of their work, discovers that an act of FGM appears to have been carried out on a girl under 18 has a personal, non-delegable duty to report this to the police. This duty cannot be delegated to the DSL. The staff member must make the report themselves, and must also inform the DSL. ‘Discovers’ means the child discloses it directly, or the staff member observes a physical indicator. Suspicion alone does not trigger the mandatory duty, but must still be reported to the DSL as a safeguarding concern.

FGM is child abuse and a criminal offence in the UK. It includes all procedures that involve partial or total removal of the external female genitalia for non-medical reasons. IWS staff must:

• be alert to risk indicators such as: a girl requesting extended absence before a family holiday; family discussions about FGM; a girl appearing distressed or withdrawn after a period of absence; or a direct disclosure;
• not attempt to discuss concerns with the family before consulting the DSL, as this could increase the risk to the child;
• refer directly to the DSL for any FGM concern, and personally report to the police if they have discovered that FGM has taken place on a girl under 18;
• record the concern accurately, including the child’s own words.

8.2 Honour-Based Abuse (HBA) and Forced Marriage

Honour-based abuse (HBA) is a term used to describe a collection of practices used predominantly — but not exclusively — to control the behaviour of a person in order to protect the perceived honour of the family or community. HBA encompasses physical, emotional and sexual violence, as well as forced marriage, FGM, and other coercive acts. It can affect children of any background, gender or nationality.

Forced marriage is a specific criminal offence under the Anti-social Behaviour, Crime and Policing Act 2014. It differs from an arranged marriage, in which both parties freely consent. Concerns about forced marriage can be reported to the Forced Marriage Unit: 020 7008 0151 (or +44 20 7008 0151 for international callers).

Warning signs of HBA or forced marriage include: absences for extended family trips; a student expressing fear about returning home; a student being withdrawn from school; a sudden engagement or marriage; or direct disclosure. Staff must never attempt to mediate or contact the family before consulting the DSL, as this can significantly escalate risk to the child.

8.3 Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)

CSE and CCE are forms of abuse in which children are manipulated, coerced or deceived into sexual activity or criminal activity, often in exchange for gifts, affection, money or status. Children may not recognise that they are being exploited. County lines drug trafficking is a common form of CCE. Warning signs include: unexplained gifts or money; associating with older or unknown individuals; going missing; unexplained behavioural changes; sudden withdrawal; and fearfulness or aggression.

Online grooming for CSE purposes can begin through gaming platforms, social media, or other digital channels — all of which are relevant in an online school context. Any concern must be referred to the DSL without delay.

8.4 Looked-After Children (LAC) and Previously Looked-After Children (PLAC)

Children who are in the care of a local authority (looked-after children) or who have previously been in care are among the most vulnerable pupils. They may have experienced significant trauma, placement instability, or disrupted education. Working Together 2026 reinforces the link between care planning and child protection planning.

IWS will appoint a Designated Teacher for Looked-After Children: Anika van der Westhuizen. The Designated Teacher is responsible for:

• maintaining and contributing to a Personal Education Plan (PEP) for each looked-after pupil;
• liaising with the pupil’s virtual school head, social worker and, where appropriate, Independent Reviewing Officer;
• ensuring any safeguarding concern about a looked-after pupil is communicated promptly to their social worker;
• ensuring looked-after pupils have access to appropriate pastoral support within IWS’s provision.

Previously looked-after children (including those who have been adopted, have a special guardianship order, or have left care) retain vulnerabilities associated with their earlier experiences. Staff should be alert to the particular needs of this group and refer any concerns to the DSL.

8.5 Children with Special Educational Needs and Disabilities (SEND)

Children with SEND are statistically more vulnerable to abuse and may face additional barriers to communication and disclosure. They may be more reliant on adult support, less able to recognise or report concerning behaviour, or more likely to have their concerns dismissed or misunderstood.

All staff working with pupils with SEND must:

• be particularly alert to unexplained changes in behaviour or presentation, which may manifest differently than in non-SEND pupils;
• make reasonable adjustments to safeguarding procedures to ensure SEND pupils can communicate concerns — including using alternative communication methods, visual aids, or trusted intermediaries;
• not assume that a SEND pupil’s distress or challenging behaviour is solely disability-related — it may indicate abuse or neglect.

Any concern about a SEND pupil must be referred to the DSL in the same way as any other safeguarding concern.

8.6 Domestic Abuse

The Domestic Abuse Act 2021 recognises children as victims in their own right where they see, hear or experience the effects of domestic abuse, including coercive control. Working Together 2026 includes strengthened guidance on identifying abusive behaviour in intimate relationships and coercive control.

In an online school context, staff should be alert to: students disclosing conflict or violence in the home; distress or fearfulness around family members during sessions; visible domestic incidents in the background of a live session; or students disclosing abuse in their own intimate relationships (see also Section 24, Child-on-Child Abuse). Any such concern must be reported to the DSL.

8.7 Mental Health

Poor mental health can be both an indicator of abuse or neglect and a risk factor for further harm. Staff are not expected to diagnose mental health conditions, but should report concerns to the DSL when a pupil:

• discloses or shows signs of self-harm or suicidal ideation;
• expresses hopelessness, worthlessness or a wish to disappear;
• shows sudden or prolonged changes in behaviour, mood or engagement;
• produces written work or messages suggesting significant distress;
• discloses eating-disorder concerns or extreme anxiety.

Staff must not promise confidentiality where there is a mental health concern that could involve risk of harm. A pupil who discloses suicidal ideation or intent to self-harm during a live session must not be left alone — the session should be paused, the DSL contacted immediately, and emergency services called if there is immediate danger.

8.8 Radicalisation and Prevent

IWS has a voluntary commitment to the Prevent duty under the Counter-Terrorism and Security Act 2015, as best practice for an online education provider working with children. IWS will:

• ensure all staff complete Prevent awareness training (WRAP or equivalent);
• maintain a culture of fundamental British values — democracy, the rule of law, individual liberty, and mutual respect and tolerance;
• apply appropriate filtering and monitoring to prevent access to extremist content via IWS platforms;
• refer any pupil at risk of radicalisation to the DSL, who will consult with local Channel or Prevent leads as appropriate.

Indicators of concern include: accessing or sharing extremist material; repeating extremist views; isolation from family or peers; secretive online activity; contact with unknown adults or groups; or sudden significant changes in behaviour or beliefs.

8.9 Private Fostering

A private fostering arrangement exists where a child under 16 (under 18 if disabled) is cared for for 28 days or more by someone who is not a close relative. Where IWS becomes aware of a private fostering arrangement, it will notify the relevant local authority, as is required practice under the Children Act 1989.

9. Anti-Discriminatory and Anti-Racist Practice

Working Together to Safeguard Children 2026 places an explicit requirement on all organisations working with children to embed anti-racist and anti-discriminatory practice within safeguarding. IWS is committed to this standard.

Racism and discrimination can be both a form of abuse and a barrier to identifying and responding to abuse. A child’s race, ethnicity, religion, nationality, gender, disability, sexual orientation, or any other protected characteristic must never be used to minimise, explain away, or delay a safeguarding concern.

IWS commits to:

• ensuring that all safeguarding assessments, decisions and responses are free from bias and are not influenced by a child’s background or identity;
• expecting all staff to challenge racism, discrimination and stereotyping when they observe it — including in live lessons, student communications and peer interactions;
• analysing safeguarding data at least annually to identify any disproportionality in outcomes for specific groups of pupils, and reporting findings to the governing body;
• ensuring that practitioners recognise how a child’s or family’s past experiences of racism and discrimination may affect their engagement with IWS and with safeguarding processes;
• providing all staff with training that includes anti-discriminatory practice;
• creating a culture in which all pupils and families are treated with dignity and respect, regardless of background.

Any member of staff who witnesses racist or discriminatory behaviour must report it to the DSL. Where such behaviour is directed at a child by another adult at IWS, it will be treated as a safeguarding concern and managed under the appropriate procedure.

10. Online Safety

Because IWS is an online school, online safety is central to safeguarding. IWS will take reasonable steps to ensure that:

• students use approved learning platforms and official IWS accounts;
• live lessons and one-to-one sessions are scheduled through official systems;
• students are taught how to behave safely and respectfully online as part of the curriculum;
• staff and students understand expectations for cameras, microphones, chat and screen-sharing;
• staff do not communicate with students through personal social media, personal email, gaming platforms or private messaging apps;
• online behaviour is monitored where appropriate;
• recordings are stored securely and used only for legitimate educational, quality-assurance or safeguarding purposes;
• concerns about online abuse, grooming, sextortion, cyberbullying, harmful content or inappropriate contact are reported immediately.

The school’s Online Safety Policy provides detailed guidance on platform use, acceptable use standards and monitoring. Staff should read it alongside this policy.

11. Live Lessons and One-to-One Sessions

Live lessons, trial lessons, tutoring, Success Coach sessions and one-to-one meetings must be managed safely. The following rules apply:

• Sessions must take place only on approved IWS platforms.
• Sessions must be scheduled through IWS systems and visible to the school.
• Staff must not move conversations to personal email, personal phone, messaging apps, social media, gaming platforms or other private channels.
• Parents/carers must be made aware that one-to-one online sessions may take place.
• Staff and students must be appropriately dressed and in a suitable learning environment.
• Staff must not conduct any session from a bedroom. All staff sessions must be conducted from a professional working environment with an appropriate or neutral background.
• Where a student can only access a session from a bedroom (e.g. due to housing or family circumstances), the tutor must: use the session recording function; report the situation to the DSL for awareness; and require the student to use a blurred or neutral background where possible.
• Staff must not take private screenshots, photos or recordings of students.
• Any official lesson recording must be handled in accordance with the Privacy Policy and the Lesson Recording Protocol.
• Staff must end or pause a session if they see or hear anything that raises a safeguarding concern, and must report it to the DSL.
• Any student behaviour involving nudity, sexual content, threats, abuse, bullying, discrimination or harmful content must be reported.
• If a student is in immediate danger during a session, staff must contact emergency services in the student’s country, then notify the DSL.

12. Professional Boundaries and Staff Conduct

All staff must maintain clear professional boundaries with students. Staff must not:

• contact students through personal accounts or private channels;
• share personal phone numbers, personal email addresses or social media profiles with students;
• ask students to keep secrets;
• give or receive personal gifts without school approval;
• arrange private meetings with students outside official IWS systems;
• use over-familiar, sexual, intimidating, discriminatory or inappropriate language;
• take private screenshots, photos or recordings of students;
• store student data on personal devices unless authorised and secure;
• discuss students inappropriately outside work;
• use student information for any non-school purpose.

Any breach of professional boundaries must be reported to the DSL or senior leadership immediately.

Where the concern relates to adult behaviour that appears to fall below expected professional standards but does not appear to meet the harm threshold, staff should complete the IWS Low-Level Concern Reporting Form and submit it to the DSL, Executive Principal or nominated senior safeguarding lead. If the concern suggests that a child has been harmed, may have been harmed, or is at immediate risk, it must be reported immediately under the safeguarding or allegation procedure instead.

13. Responding to a Concern or Disclosure

If a child tells a member of staff something that may be a safeguarding concern, the staff member must:

• listen calmly and carefully;
• take the child seriously;
• reassure the child that they have done the right thing by speaking up;
• avoid asking leading questions — do not press for details;
• not promise to keep the information secret;
• explain that the information must be shared with the DSL to help keep them safe;
• record the child’s words as accurately as possible, including exact phrases used;
• report the concern to the DSL on the same day;
• report immediately if the child is at risk of immediate harm.

Staff must not investigate the concern themselves, contact the alleged person responsible, or discuss the matter with others who do not need to know.

If a child is in immediate danger, staff should contact the emergency services in the country where the child is located and then inform the DSL as soon as possible.

After reporting the concern to the DSL, the staff member must complete the IWS Safeguarding Concern Reporting Form as soon as possible, and normally on the same working day. In an emergency, staff must contact emergency services and/or the DSL immediately and complete the form afterwards. The form must be factual and objective.

14. Recording Safeguarding Concerns

All safeguarding concerns must be recorded promptly, accurately and objectively. Records should include:

• the child’s full name;
• date and time of the concern or disclosure;
• the platform or setting where the concern arose;
• what was seen, heard or reported;
• the child’s own words where possible;
• names of any other people involved or present;
• any immediate action taken;
• the name of the person making the record;
• the date and time the concern was reported to the DSL.

Opinion must be clearly separated from fact. Safeguarding records must be stored securely and separately from ordinary academic records, with access restricted to the DSL, Deputy DSL and authorised senior staff only.

IWS uses the Safeguarding Concern Reporting Form as the standard internal record for child protection and safeguarding concerns. Completed forms must be shared only with the DSL or Deputy DSL and stored in the restricted safeguarding records area. Safeguarding records must not be stored in ordinary academic files, Trello boards, general HR folders, public folders or open shared drives.

15. Information Sharing and Data Protection

IWS will handle safeguarding information carefully, confidentially and lawfully. However, safeguarding information may be shared without consent where this is necessary to protect a child, prevent harm, comply with a legal duty or make a referral to the relevant authority.

Information may be shared with:

• children’s social care or equivalent child protection authorities;
• police or law enforcement;
• the Local Authority Designated Officer (LADO) or equivalent;
• partner schools where necessary;
• parents or carers, unless doing so would place the child at greater risk;
• medical or emergency services;
• regulators, legal advisers or safeguarding professionals where required.

This reflects the lawful bases set out in the Privacy Policy, including legal obligation, vital interests and the substantial-public-interest/safeguarding conditions for special-category data. Data protection law does not prevent the sharing of information to protect a child — the threshold for sharing is whether it is necessary, proportionate and lawful.

16. Allegations or Concerns About Adults

Any concern about the behaviour of an adult working with or on behalf of IWS must be taken seriously. This includes concerns about staff, teachers, tutors, Success Coaches, contractors, volunteers, agents, partner-school staff, senior leaders, or anyone else who may have contact with students.

Concerns may include behaviour that:

• has harmed a child or may have harmed a child;
• may be a criminal offence involving a child;
• indicates a person may pose a risk to children;
• suggests a person may not be suitable to work with children;
• breaches professional boundaries;
• creates discomfort or concern even if it appears minor.

Where an allegation may meet the harm threshold, it must be reported immediately to the Executive Principal or the appropriate senior safeguarding lead. If the allegation concerns the Executive Principal, it must be reported to the Board/Proprietor/Chair.

Where there is a UK connection, the DSL or senior leader will consider whether the matter must be referred to the LADO. Where the student or adult is overseas, the equivalent local safeguarding authority should be considered. Where a person is dismissed or would have been dismissed for harming a child, a referral will be made to the Disclosure and Barring Service (DBS) and to any relevant regulatory body.

17. Low-Level Concerns

A low-level concern is any concern about adult behaviour that does not appear to meet the harm threshold but is still inconsistent with expected professional standards. Examples include:

• being over-familiar with a student;
• using personal communication channels;
• making inappropriate jokes or comments;
• giving individual students special attention without clear reason;
• failing to follow camera, recording or platform rules;
• poor professional boundaries.

Low-level concerns must still be reported promptly to the DSL, Executive Principal or nominated senior safeguarding lead. They will be recorded and reviewed so that patterns of behaviour can be identified early. Staff must feel able to report concerns without fear — raising a genuine concern is always the right thing to do.

Where the concern relates to the DSL, it must be reported to the Executive Principal or Board/Proprietor safeguarding lead instead. Low-level concern records must be stored securely and reviewed to identify any patterns, repeated behaviour, or escalation concerns.

18. Whistleblowing

Staff must raise concerns if they believe safeguarding is not being handled properly. This includes concerns that:

• a child protection concern has not been acted on;
• an adult’s behaviour is being ignored;
• records are not being kept properly;
• leaders are not following safeguarding procedures;
• there is pressure not to report a concern.

Staff may use the IWS Whistleblowing Policy and, where appropriate, contact external safeguarding bodies — for example the NSPCC whistleblowing helpline (0800 028 0285). No member of staff will be treated unfairly for raising a genuine safeguarding concern.

19. Safer Recruitment

IWS is committed to recruiting safely and preventing unsuitable adults from working with children. Before any member of staff, volunteer or contractor begins working with students, the following checks must be completed and recorded:

• Identity verification;
• Right to work in the UK (for UK-based staff);
• Verification of professional qualifications and employment history;
• Exploration of any gaps in employment history;
• Two references, including from the most recent employer where possible;
• Criminal-record checks appropriate to the person’s role and location;
• For UK-based staff in regulated activity: an Enhanced DBS check including a barred-list check where appropriate;
• For overseas-based staff: equivalent police or criminal-record checks where available, and additional overseas checks where the applicant has lived or worked outside the UK;
• An online search (social media and digital footprint check) for all shortlisted candidates, conducted before interview — results must be assessed against IWS safeguarding standards and recorded in the recruitment file;
• Prohibition or professional-status checks where relevant (e.g. Teaching Regulation Agency prohibition checks for UK teachers);
• Medical fitness where required for the role.

IWS will maintain a Single Central Record (or equivalent safeguarding recruitment record) of all pre-employment checks, which will be reviewed termly. At least one person involved in each recruitment process must have current safer-recruitment training.

Partner schools and agents working with IWS students are required to follow equivalent safeguarding standards. This requirement must be included in all contractual agreements with partners and agents.

20. Training and Awareness

All staff must complete safeguarding and online safety training before working with students. Training is provided at induction and must be updated at the required intervals.

20.1 Induction Training (before working with any student)

• This policy and the school’s child protection procedures;
• The role of the DSL and how to report a concern;
• Signs of abuse, neglect, exploitation and online harm;
• Professional boundaries, staff conduct and the Acceptable Use Policy;
• Online safety, platform rules, and live lesson safeguarding requirements;
• Safer working practice in an online environment.

20.2 All Staff — Ongoing Training

• Substantive safeguarding training: updated at least every three years.
• Annual briefing: key changes in legislation, guidance, risk, and IWS procedures — at least once per academic year.
• Prevent / WRAP training: completed before starting and refreshed as required by updated guidance.
• Anti-discriminatory practice: included in all substantive safeguarding training.

20.3 DSL and Deputy DSL

• DSL-specific training: every two years.
• Annual knowledge refresh: at least once per year, in addition to DSL-specific training.
• Specialist training as required by their role (e.g. online safety, counter-terrorism, CSE/CCE).

20.4 Governing Body / Proprietor

• Safeguarding training appropriate to their governance role, reviewed at each annual policy review.
• Named governing body safeguarding lead: additional training consistent with the DSL role.

20.5 Training Records

The DSL maintains a training log for all staff, reviewed termly. Gaps in training coverage are reported to the Executive Principal and governing body. Training records are made available on request to Cambridge Assessment International Education, Ofsted or any other relevant inspection body.

Students will receive age-appropriate online safety education and information about how to report concerns. Parents and carers will be told how to raise safeguarding concerns with IWS.

21. Attendance Monitoring as a Safeguarding Tool

In an online school, unexplained absence from live lessons or a sudden and prolonged withdrawal from engagement is equivalent to a child going missing from education — a recognised safeguarding risk. IWS treats unexplained non-attendance as a potential safeguarding concern.

The following procedure applies when a student is absent without explanation:

All absence-related safeguarding concerns must be recorded on the Safeguarding Concern Reporting Form and managed by the DSL. The DSL will inform the governing body of any case where a student remains unreachable for five or more working days.

22. Working with Parents, Carers and Partner Schools

IWS works in partnership with parents and carers to keep children safe. Parents and carers are normally informed about safeguarding concerns involving their child. However, IWS may delay informing a parent or carer if doing so could place the child at greater risk or interfere with a safeguarding referral.

Where a student is enrolled through a partner school or local organisation, safeguarding responsibilities must be agreed clearly in writing before the partnership begins. This must include:

• who is responsible for local safeguarding action;
• who the partner school’s safeguarding contact is;
• how concerns are reported between IWS and the partner;
• how urgent concerns are escalated;
• how records are shared securely;
• how local child protection laws are followed.

Where IWS arranges in-person activities, including summer schools, trips or events, a separate safeguarding risk assessment must be completed before the activity takes place.

23. Cross-Border Safeguarding

IWS teaches students in different countries. Safeguarding action must consider the child’s location, the adult’s location and any UK connection.

The DSL maintains a practical list of safeguarding reporting routes for each country where IWS has students (the Cross-Border Safeguarding Contact Appendix). This includes:

• emergency services;
• child protection authority / social care equivalent;
• police reporting route;
• child helpline where available;
• partner school safeguarding contact where relevant;
• UK reporting route where there is a UK connection.

Where local reporting routes are unclear, unsafe or unavailable, the DSL will seek advice from a recognised safeguarding authority and use UK safeguarding advice routes where appropriate.

24. Child-on-Child Abuse

IWS does not tolerate child-on-child abuse. This includes:

• bullying and cyberbullying;
• sexual harassment;
• discriminatory abuse;
• sharing or threatening to share nude or semi-nude images;
• online humiliation;
• coercion or blackmail;
• abuse in chat, forums, clubs or group lessons;
• harmful sexual behaviour;
• AI-generated or manipulated images used to bully, threaten or sexualise another child.

Child-on-child abuse must never be dismissed as “banter”, “drama”, “just a joke” or “part of growing up”. Concerns must be reported to the DSL and handled in a way that protects all children involved.

25. Nude or Semi-Nude Images

If a student shares, threatens to share, or is pressured to share a nude or semi-nude image, staff must:

• stay calm;
• not view the image again;
• not download, copy, forward, screenshot, save or print the image;
• not ask the student to send the image to anyone else;
• not investigate the matter themselves;
• report immediately to the DSL;
• record what happened factually.

The DSL will decide what action is required, including whether police, parents/carers, partner schools or child protection authorities should be contacted. This procedure applies to AI-generated and manipulated images as well as real images.

26. Mental Health and Wellbeing Concerns

Mental health concerns can be safeguarding concerns, especially where a child may be at risk of harm. See Section 8.7 for full guidance. Staff must report concerns such as self-harm, suicidal thoughts, severe anxiety or distress, eating-disorder concerns, sudden withdrawal, concerning written work or messages, comments about not feeling safe, domestic abuse or family crisis, or signs of coercion, control or exploitation.

Staff are not expected to diagnose or provide counselling. Their role is to report concerns and ensure the child receives appropriate support. Pupils in crisis must not be left alone in a virtual session.

27. Radicalisation and Extremist Content

See Section 8.8 for full guidance on radicalisation and the Prevent duty. Concerns must be reported to the DSL, who will consider whether a Prevent referral or equivalent local safeguarding referral is appropriate.

28. Use of Technology, AI and Digital Platforms

IWS recognises that online education creates specific risks, including misuse of digital tools. Staff and students must not use IWS platforms to:

• bully, harass or intimidate others;
• create or share harmful content;
• create or share sexual, violent, discriminatory or abusive material;
• misuse AI tools to impersonate, sexualise, manipulate or embarrass another person;
• create or share AI-generated sexual images of any person, including minors;
• record or screenshot others without permission;
• share login details or access another user’s account;
• bypass security controls;
• move school communication to private platforms.

Any misuse involving a child must be reported as a safeguarding concern.

29. Confidentiality

Safeguarding information is confidential but not secret. Staff must share safeguarding information only with the DSL or those who need to know in order to protect a child. Staff must not:

• discuss safeguarding concerns with colleagues unnecessarily;
• share safeguarding records through insecure channels;
• store safeguarding information on personal devices;
• speak to parents/carers about a concern unless instructed by the DSL;
• alert the alleged person responsible for harm;
• promise a child that information will be kept secret.

30. Record Retention

Safeguarding records will be kept securely and retained in accordance with the following periods:

Safeguarding records must not be included in routine data purge schedules. Deletion of safeguarding records requires the explicit authorisation of both the DSL and DPO. These periods reflect guidance from the Information Commissioner’s Office and recognised best practice in UK safeguarding.

When a student leaves IWS, their safeguarding file must be transferred securely to any receiving school, separately from the general academic file, directly to that school’s DSL. Where there is no receiving school, the DSL will follow local authority guidance.

31. Complaints About Safeguarding

Parents, carers, students or staff may raise concerns about safeguarding practice by contacting:

• Designated Safeguarding Lead: Michelle van Roon — [email protected]
• Deputy DSL: Elsie Eayrs — [email protected]
• Executive Principal: Matt Vickery — [email protected]
• Board / Proprietor safeguarding lead: Cigdem Karaman — [email protected]

Where a complaint concerns the DSL, it should be escalated to the Executive Principal or Board/Proprietor safeguarding lead. Where a person believes a child is at immediate risk, they should contact emergency services in the child’s location immediately.

32. Monitoring and Review

This policy will be reviewed at least annually — ordinarily in September each year. It will also be reviewed sooner if:

• there is a serious safeguarding incident;
• there is a change in law or statutory guidance, including the enactment of the Children’s Wellbeing and Schools Bill;
• IWS changes its platforms or learning model;
• a safeguarding audit recommends updates;
• feedback from staff, students, parents or partner schools identifies a gap;
• Cambridge Assessment International Education or any other inspection body issues revised safeguarding expectations.

The DSL is responsible for monitoring legislative developments — including the Children’s Wellbeing and Schools Bill and future editions of KCSIE and Working Together — and for proposing amendments to this policy. All staff will be notified of material changes and required to re-read the updated policy.

Final approval rests with the CEO. The next scheduled review date is September 2027.

33. Useful Contacts

Staff Declaration

All staff, contractors, volunteers and agents are required to confirm that they have read, understood and will comply with this Safeguarding & Child Protection Policy. A new declaration must be signed when a materially updated version of this policy is issued.

Where IWS uses an online HR or onboarding system, a timestamped electronic acknowledgement of this policy is accepted in place of a physical signature. Records of all declarations must be retained by the DSL.

Appendix A — What to Do If You Have a Safeguarding Concern

This is a quick reference for all staff.

• 1. Observe / receive — You notice a sign of concern, receive a disclosure, or hear information from a third party.
• 2. Stay calm — Do not investigate, do not ask leading questions, do not promise confidentiality. If a child is disclosing, listen carefully and use their own words in your record.
• 3. Immediate danger? — If you believe the child is in immediate danger, contact emergency services in the child’s country now. Then contact the DSL. Do not wait.
• 4. Record — Write down factually what you saw, heard or were told. Include: date, time, platform, the child’s own words, names of those present, and any action taken.
• 5. Report to DSL — Contact the DSL on the same day. Submit the completed Safeguarding Concern Reporting Form to the DSL. Do not share the concern with anyone else.
• 6. DSL action — The DSL will decide next steps: provide early help / family support; refer to children’s social care or equivalent; refer to police; or monitor and review.

If you cannot reach the DSL: contact the Deputy DSL. If neither is available and there is immediate risk, contact the police or children’s social care directly and inform the DSL as soon as possible.

Appendix B — What to Do During a Live Session

• 1. You see or hear something concerning — a visible injury, disclosure, distressing background, inappropriate behaviour, or anything that raises a safeguarding concern during the session.
• 2. Immediate danger? — If the child appears to be in immediate physical danger, or discloses suicidal intent: end the session, call emergency services in the child’s country, then contact the DSL immediately. Do not leave the child alone if they are in crisis and you can keep the connection.
• 3. No immediate danger — Continue or pause the session as appropriate. Do not question the student further. Act normally to avoid alerting any adult present.
• 4. After the session — Contact the DSL immediately. Do not wait for the next day. Record everything you observed using the child’s own words where possible.
• 5. Complete the form — Submit the Safeguarding Concern Reporting Form to the DSL on the same day.

Remember: session recordings may be used as safeguarding evidence. If a concern arises during a recorded session, ensure the recording is preserved and flag it to the DSL immediately.

Appendix C — Glossary

Mandatory reading for all staff · Review: September 2027