Child Safeguarding Policy


WISS seeks to be a safe haven for students who may be experiencing abuse or neglect in any aspect of their lives. WISS endorses the Convention on the Rights of the Child, of which the host country, China, is a signatory.

Child safeguarding concerns include suspected, alleged, self-disclosed, or witnessed abuse of a child by anyone associated within or outside the School, which must be inquired into and followed by appropriate action.

Child Abuse – The World Health Organization states that 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.”



The People’s Republic of China (PRC) declares that it protects a wide range of children’s rights through domestic legislation and by ratifying and joining the relevant international treaties such as the United Nations Convention on the Rights of the Child (UNCRC). The PRC Constitution provides for the state protection of children and prohibits maltreatment of children. Among many laws and regulations providing children’s rights protection, the primary law in this field is The PRC Law on the Protection of Minors (first passed in 1991, revised in 2006) (Minors Protection Law). The revised Minors Protection Law entered into force on June 1, 2007. This law outlines the responsibilities of families, schools, and the government regarding the protection of children’s rights and judicial protection.

The Protection for Minors Law is currently under review and is to be published June 1, 2021.



PRC Law on the Protection of Minors (PRC, 1991)

United Nations Convention on the Rights of the Child (UNCRC, 1990)

International Task Force on Child Protection (COIS, 2021)

NSPCC Safeguarding (National Society for the Protection and Care of Children (NSPCC), 2021) 



WISS fully recognizes its moral and statutory responsibility to safeguard and promote the welfare of all children. Child safeguarding standards defined by WISS consider varying cultural contexts and adhere to all known local and international laws. When given reasonable cause to believe that these rights are violated, WISS will seek all available resources to restore those rights.

Through this policy, WISS strives to ensure that:

  • All children, regardless of age, gender, ability, culture, race, language, religion, or sexual identity, have equal rights to safeguarding.
  • All staff members have equal responsibility to act on any suspicion or disclosure that may suggest a child is at risk of harm.
  • Children and staff involved in child safeguarding issues will receive appropriate support.
  • All staff is provided with the necessary information to enable them to meet their child safeguarding responsibilities.
  • Consistent good practice.
  • The School’s commitment to child safeguarding is demonstrated to students, parents, and other partners.
  • The Designated Safeguarding Leads (DSLs) or School Director report all concerns in accordance with the People’s Republic of China requirements and in line with best practice as defined by organizations such as the Council of International Schools (CIS).
  • Allegations of abuse are dealt with according to the associated policy.

All WISS staff must:

  • Correctly implement this policy.
  • Immediately report any concerns regarding Safeguarding to the building Principal or School Director.
  • Read and act in accordance with the code of conduct within this policy, General Policy, and Personnel Policy.
  • Know who the trained DSLs are.
  • Ensure that all safeguarding concerns are treated with the utmost confidence and under the guidance of DSLs.
  • Report suspected incidences of child abuse or neglect whenever they have reasonable cause to believe that a child has suffered or is at risk of suffering abuse or Reporting and follow-up of all suspected incidences 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 consulate in Shanghai, to the appropriate child protection agency in the home country, and/or to local authorities. 



WISS recognizes that all matters relating to child protection are highly confidential. The School Director or the DSLs will share that information on a “need to know, what, and when’ basis. Concerns about individuals should never be discussed elsewhere, inside or outside the School, unless in confidential meetings for that purpose.



6.1 Key Safeguarding Contacts:

Position Name Email
School Director Greg Brunton

Fiona Morris (EY)

Lisa Ellery (Primary)

Myles d’Airelle (Secondary)

Designated Safeguarding Leads

Fiona Morris

Myles d’Airelle

6.2 Designated Safeguarding Leads (DSLs):

  • Manage safeguarding concerns.
  • Collect the concern, record, and store as per policy.
  • Manage disclosure, reporting, and recording concerns about a student.
  • Ensure that all staff receive annual safeguarding training.

6.3 The Safeguarding Response Team comes together when there is reasonable cause to follow up on a disclosure. This team is made up of a combination of relevant persons, which could include: the School Director, building Principal, Designated Safeguarding Leads, and Local Government Liaison, and relevant counselor (s). Additional members may include Deputy Principals, Homeroom or Advisory teacher, the building Nurse, and/or any other teachers deemed essential to support the response to the situation. 



7.1 Physical abuse is defined as “any non-accidental physical injury to the child” and can include, but are not limited to, striking, kicking, burning, or biting the child.

7.2 Neglect is the persistent failure of a parent or other person responsible for meeting a child’s basic physical, physiological, and/or safety needs that may result in serious impairment to the child’s health or development.

7.3 Sexual abuse involves forcing or enticing a child to participate in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (i.e., rape) or non-penetrative acts. They may include non-contact activities, such as involving children in producing or viewing pornographic material or encouraging children to behave in sexually inappropriate ways.

7.4 Emotional abuse is the persistent ill-treatment of a child to cause severe and adverse effects on a child’s emotional development. 



8.1 General Expectations

All WISS employees will ensure that all data relating to all students is confidentially managed in accordance with the requirements of this policy and applicable national or local guidance, laws, or regulations.

Those reporting any Safeguarding concerns will adhere to the proper lines of communication, ensuring confidentiality. The DSLs will support the agreed process, and the School will give detailed information about the proper lines of communication in the induction process and at the beginning of every academic year.

WISS has a duty to ensure that professional behavior applies to relationships between staff and students. All staff members are clear about what constitutes appropriate behavior and professional boundaries.

Induction training will be based upon the Code of Conduct.

WISS recognizes that some people who may be unsuitable for working with children may use volunteering as an opportunity to gain access to students. The HR Department and relevant supervisory staff will ensure that regular volunteers (including gap students and interns) are properly screened and determine whether to proceed with criminal record and identity checks. All regular volunteers will also receive the relevant level of Safeguarding training.

8.2 Safeguarding Whistleblowing Guidance

A staff member may recognize that something is wrong but may not feel able to express concerns because of loyalty to colleagues or fear of harassment or victimization. Every individual has a responsibility to raise concerns about unacceptable practices or behavior concerning the safety and welfare of our students. We encourage all adults to ensure that students are their priority and should not be unnecessarily at risk. This is known as “whistleblowing”. Every individual has a responsibility to raise concerns about unacceptable practices or behavior concerning the safety and welfare of our students.

Reasons for whistleblowing:

  • A Board member, the School Director, or DSL is covering up a safeguarding incident or is not acting in accordance with this policy
  • A Board member, the School Director, or DSL is suspected of inappropriate behavior regarding child safeguarding

How to raise a concern about a colleague or member of school staff:

  • Concerns should be expressed as soon as possible. The earlier a concern is expressed, the sooner action can be taken. The concern should express exactly what practice is causing concern and why.
  • Concerns about a Board member should be referred to the School Director.
  • Concerns about the School Director should be referred to a Designated Safeguarding Lead.
  • Concerns about a DSL should be referred to the other DSL or the School Director.
  • The staff member specified in any whistleblowing procedure should be informed about the nature and progress of any inquiries.
  • It is recognized that whistleblowing can be difficult and stressful. Advice and support will be made available to the staff member who came forward.

8.3 When a Child Discloses to You

It takes a lot of courage for a child to disclose that they are being abused. They may feel ashamed, particularly if the abuse is sexual; their abuser may have threatened what will happen if they tell; they may have lost all trust in adults; or they may believe, or have been told, that the abuse is their own fault.

If a child talks to a staff member about any risks to their safety or wellbeing, the staff member will need to let the child know that they must pass the information on – staff are not allowed to keep secrets and must never promise to do so. The point at which they tell the child this is a matter of professional judgment. If they jump in immediately, the student may think that they do not want to listen. If left until the very end of the conversation, the child may feel that he has been misled into revealing more than he would have otherwise.

During their conversations with the child, staff members will:

  • Allow the child to speak freely.
  • Remain calm and not overreact – the child may stop talking if they feel they are upsetting their listener.
  • Give reassuring nods or words of comfort – “I’m so sorry this has happened”, “I want to help”, “This isn’t your fault”, “You are doing the right thing in talking to me”
  • Not be afraid of silences – staff members must remember how hard this must be for the child.
  • Under no circumstances ask investigative questions – such as how many times this has happened, whether it happens to siblings too, or what the student’s parent(s) think about all this.
  • At an appropriate time, tell the child that to help them, the staff member must pass the information on.
  • Not automatically offer any physical touch as comfort. It may be anything but comforting to a child who has been abused.
  • Avoid admonishing the child for not disclosing earlier. Saying things such as “I do wish you had told me about this when it started” or “I can’t believe what I’m hearing” may be the staff member’s way of being supportive, but it could be interpreted by the child to mean that they have done something wrong
  • Tell the child what will happen next. The child may agree to go to see the building Principal. Otherwise, let the child know that someone will come to see them before the end of the day.
  • Report verbally to the building Principal or a DSL, even if the child has promised to do it by themselves.
  • Write up their conversation as soon as possible on the Confidential Record of Concern (CRoC) form and submit it to the building Principal or DSL.
  • Seek support for themselves if they feel distressed,

8.4 Self-reporting

Occasionally, a staff member may have a personal difficulty that they know is affecting professional conduct and practice. Staff have a responsibility to discuss such a situation with their building Principal so that professional and personal support can be offered. While such reporting will remain confidential in most instances, this cannot be guaranteed when personal difficulties raise concerns about the welfare or safety of students in the School.

8.5 Safe Touch

Due regard should be given to Safe Touch. There are occasions when physical contact with a student is necessary. Examples of this could include but are not exclusive to:

  • Holding the hand of a young student when going to another learning space or when walking together around school and school trips (dependent on age/need).
  • Comforting a distressed student (hand lightly on shoulder).
  • Congratulating or praising a student (shaking their hand).
  • Demonstrating how to use a musical instrument.
  • Demonstrating exercises or techniques during PE lessons.
  • Giving first aid treatment.


When there is cause to suspect child abuse or neglect, it is the responsibility of the staff member to report his or her suspicions directly to the building Principal or DSLs. It is the Principal’s responsibility to inform the DSLs and School Director of the suspected case of child abuse or neglect.

Any staff member who has reason to believe that a student is at immediate or significant risk of harm has a duty to forward this information without delay to their building Principal or the School Director.

All staff, faculty, and administrators are mandated to report incidences of abuse and neglect.  All WISS employees are also required to report suspicion of abuse or neglect.  All reports of abuse and neglect must be made to the building Principal within 24 hours for immediate response using the Confidential Record of Concern (CRoC) document.

If the abuse or neglect allegation involves a staff or faculty member of WISS, the administration will follow school policy regarding ethical professional behavior in accordance with the WISS General Policies and WISS Personnel Policy.

If a staff member is reported as a suspected offender, WISS will conduct a full inquiry.




The Confidential Record of Concern and subsequent documentation of the inquiry will be kept in a confidential file. This file will be stored as a paper copy only. This document will be held in a locked safe in the School Director’s office. This safe can only be accessed by DDLs. 

Confidential records may only be released with parental consent. One exception to this is if the   School believes the child continues to be at risk. In these cases, WISS has the responsibility to relay potential safety concerns to the new school.



When a child discloses abuse or there is reasonable cause to believe that abuse is occurring, the teacher will seek advice from their building Principal or School Director within 24 hours. The building Principal or School Director will notify the Safeguarding Response Team and then take initial steps to gather information regarding the reported incident. 

In all cases, follow-up activities will be conducted to ensure that information is documented factually and that strict confidentiality is maintained. The following procedure will be used:

  1. Interviewstaff members as necessary and document information relative to the  
  2. Consultwith school personnel to review the child’s history in the  

       3a. If warranted, forward the report to the Safeguarding Response Team (Move to Step 2). 
       3b. If the report is not substantiated, enter the case into the central record and update the original reporter. 


Based on the acquired information, a plan of action will be developed by the Safeguarding Response Team to assist the child and family. Actions that shall take place are: 

  • Building Principal, School Director, and others deemed necessary meet with family, present the School’s concerns, review the Child Safeguarding Policy, and establish an action plan
  • Ongoingobservations of the child by Safeguarding Response Team

Possible follow-up actions include: 

  • Referralof the student and family to external professional counseling;
  • Contact sponsoring employer regardingconcerns;
  • Consultationwith the consulate of the country of the involved family;
  • Consultation with theSchool’s legal advisor; 
  • Reportto local authorities, as per the Anti-Domestic Violence Law of the PRC, adopted at the 18th Session of the Standing Committee of the 12th National People’s Congress.

 Some cases of suspected abuse or neglect may be handled by School counselors, such as those involving: 

  • Student relationships withpeers;
  • Parentingskills related to disciplining children at home;
  • Student-parentrelationships;
  • Mentalhealth issues such as depression, low self-esteem, grieving, etc.

 Some cases will be referred to outside resources, for example: 

  • Mentalhealth issues such as depression, psychosis, dissociation, and suicidal 

 Cases reported for investigation and outside resources: 

  • Severeand ongoing physical abuse or neglect; 
  • Sexual abuse and 

 In extreme cases when families do not stop the abuse or concerns remain about the safety of the child, reports could be made to: 

  • The consulate of the country of the involvedfamily; 
  • Theemployer sponsoring the involved family; 
  • Local law 


After a reported and/or substantiated case of child abuse or neglect, the building Principal or School counselor will:

  • Maintaincontact with the child and family to provide support and guidance as appropriate.
  • Providethe child’s teachers with ongoing support.
  • Provide resource materials and strategies for teachers.
  • Maintain contact with outside therapists to update the progress of the child in School.
  • Hold follow-up meetings to evaluate progress.

 All documentation of the inquiry will be kept in the child’s confidential file. Confidential records may only be released with parental consent. One exception to this is if the School believes the child continues to be at risk. In these cases, WISS has the responsibility to relay potential safety concerns to the new School. 



WISS endeavors to ensure that we do our utmost to employ safe staff by following the guidance below.

13.1 WISS Staff

Safer recruitment means that all applicants will:

  • Complete an application form that includes their employment history.
  • Provide two referees, including at least one who can comment on the applicant’s suitability to work with children; check verbally at least one of these references.
  • Provide evidence of identity and qualifications.
  • Be checked in accordance with relevant police checks, meeting regulations as appropriate to their role.
  • Provide evidence to obtain a working visa in China.
  • Be interviewed.

Safer recruitment also means that the School will ensure that:

  • The candidate’s mental and physical fitness to carry out their work responsibilities is verified.
  • All new staff members undergo an induction that includes the School’s Child Protection and Safeguarding Policy and Procedures.
  • All staff sign to confirm they have received a copy of the Child Safeguarding Policy and Procedures.

13.2 Volunteers

Parents or other volunteers who help on an occasional basis must work under the supervision of a staff member and may not have any unsupervised contact with students. They must also sign the WISS Code of Conduct.

13.3 Contractors

WISS checks the identity of all contractors working on-site and requests police checks where appropriate.

13.4 Site Visitors

WISS shall maintain a Safeguarding Guide for all visitors. All visitors who come on campus be issued a visitor’s pass with a Safeguarding statement on the back which clearly instructs visitors about Safeguarding expectations while on campus.


WISS is an enclosed site in Qingpu, East Xujing. Once on the site, the buildings allow access to all areas of the School during the school day with a chipped ID card. All members of the school community are required to take responsibility for site security and remain vigilant about trespassers. The School’s Security Department provides oversight of the site and can be contacted 24/7 in an emergency via the School’s Director of Facilities or the School Director.

Visitors to the School, including contractors, are required to sign in at the main gate, where they will be given a visitor badge on a lanyard with safeguarding information. Subject to their position and purpose, visitors should be escorted. All visitors are expected to observe WISS safeguarding and health and safety regulations to ensure that children in the School are kept safe.


The vast majority of people who take or view photographs or videos of children do so for entirely innocent, understandable, and acceptable reasons. Sadly, some people abuse children by taking or using images, so we must ensure that we have some safeguards in place.

To protect our children, we will:

  • Seek parental consent for photography of our students through the School’s

Terms & Conditions when children are admitted to the School.

  • Seek parental consent for photography of students, which may be extraordinary

e.g., photos of children in marketing materials used in the wider community.

  • Demonstrate respect, care, and caution when including photographs of students

in Newsletters, Blogs, and any other School publications.

  • Encourage children to tell us if they are worried about any photographs that are taken of them.


The following essential and relevant policy documents can all be accessed on WISS SharePoint:

  • General Policies
  • Personnel Policy
  • A-Z Handbook
  • Code of Conduct
  • Health Policy
  • ID Card Policy
  • Lockdown Policy
  • and other safety related policies


WISS will distribute this policy annually to all parents (newly enrolled and re-enrolled), communicate this policy annually to students, provide annual training for all staff, and make every effort to implement hiring practices to ensure the safety of children in the School’s care.


Two-year audit cycle.


  • Indicators of Abuse and Neglect


Appendix 1 – Indicators of Abuse and Neglect


Child Safeguarding is a broad term used to describe philosophies, policies, standards, guidelines, and procedures to protect children from both intentional and unintentional harm. In this document, the term “child safeguarding” applies to the protection of children in international schools. Please note that this definition also includes harm to self.

Child Safeguarding Policy is a statement of intent that demonstrates a commitment to protecting students from harm (to self and from others) 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 demonstrate that the School is taking its duty and responsibility seriously. This policy considers that schools will provide appropriate child safety classes supported with a well-defined curriculum to increase children’s ability to understand abuse prevention.

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 inquired into and followed by appropriate action.

Child Abuse – 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 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. International school communities have unique characteristics that school personnel must be aware of in terms of the individuals who are around our children. School personnel should be knowledgeable of the potential reasons children may not be able to talk about any victimization they might have experienced.

To increase the WISS community’s awareness, this document focuses on four main categories of abuse and provides basic information about the physical and behavioral signs associated with each type.


Physical abuse may involve hitting, punching, shaking, throwing, poisoning, biting, burning or scalding, drowning, suffocating, or otherwise causing intentional bodily harm to a child. (These symptoms could also indicate harm to self, such as cutting and suicidal thoughts).

Signs of physical abuse:

  • Bruises, burns, sprains, dislocations, bites, cuts
  • Improbable excuses given to explain injuries
  • Injuries that have not received medical attention
  • Injuries that occur to the body in places that are not normally exposed to falls, rough games, etc.
  • Repeated urinary infections or unexplained stomach pains
  • Refusal to discuss injuries
  • Withdrawal from physical contact- 17 –
  • Arms and legs kept covered in hot weather
  • Fear of returning home or of parents being contacted
  • Showing wariness or distrust of adults
  • Self-destructive tendencies
  • Being aggressive towards others
  • Being very passive and compliant
  • Chronic running away


Emotional abuse is the persistent emotional ill-treatment of a child so as to cause severe and adverse effects on a child’s emotional development. It may involve: conveying to children that they are worthless or unloved; that they are inadequate or valued only insofar as they meet the needs of another person; age or developmentally inappropriate expectations being imposed on children; causing children frequently to feel frightened; or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of ill-treatment of a child, though it may also occur alone.

Signs of emotional abuse:

  • Physical, mental, and emotional development is delayed
  • Highly anxious
  • Showing delayed speech or sudden speech disorder
  • Fear of new situations
  • Low self-esteem
  • Inappropriate emotional responses to painful situations
  • Extremes of passivity or aggression
  • Drug or alcohol abuse
  • Chronic running away
  • Compulsive stealing
  • Obsessions or phobias
  • Sudden under-achievement or lack of concentration
  • Attention-seeking behavior
  • Persistent tiredness
  • Lying


Sexual abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (i.e., rape) or non-penetrative acts. They may include non-contact activities, such as involving children in producing or viewing pornographic material or encouraging children to behave in sexually inappropriate ways. Children involved in commercial sex work are victims of sexual abuse, whether they perceive themselves as victims or not.

Signs of sexual abuse:

  • Pain or irritation to the genital area
  • Vaginal or penile discharge
  • Difficulty with urination
  • Infection, bleeding
  • STDs
  • Fear of people or places
  • Aggression
  • Regressive behaviors, bedwetting, or stranger anxiety
  • Excessive masturbation/Sexually provocative
  • Stomach pains or discomfort walking or sitting
  • Being unusually quiet and withdrawn or unusually aggressive
  • Suffering from what seem physical ailments that cannot be explained medically
  • Showing fear or distrust of a particular adult
  • Mentioning receiving special attention from an adult or a new “secret” friendship with an adult or young person
  • Refusal to continue with School or usual social activities
  • Age-inappropriate sexualized behavior or language


Neglect is the persistent failure to meet a child’s basic physical or physiological needs, likely to result in serious impairment of the child’s health or development.

Some indicators of neglect:

  • Medical needs unattended
  • Lack of supervision
  • Consistent hunger
  • Inappropriate dress
  • Poor hygiene- 19 –
  • Inadequate nutrition
  • Fatigue or listlessness
  • Self-destructive
  • Extreme loneliness
  • Extreme need for affection
  • Failure to grow
  • Poor personal hygiene
  • Frequent lateness or non-attendance at School
  • Low self-esteem
  • Poor social relationships
  • Compulsive stealing
  • Drug or alcohol abuse


The impact of child abuse can persist for a lifetime after the abuse has been committed. Some victims of abuse are resilient and thus manage to function and survive. Much research has established the relationship between long-term child abuse and lifetime health and wellbeing, especially if the children do not get appropriate support to help them cope with the trauma.

The most important point to consider is that children often are exposed to multiple forms of abuse and suffer a myriad of symptoms.

Furthermore, all forms of abuse have the potential for long-term impact on the victims and can affect the victim’s ability to function as a human being. 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:

  • Poor educational achievement
  • Inability to complete responsibilities
  • Inability to live according to plan/ability
  • Inability to care for self
  • Inability to coexist, cooperate or work with others
  • Lack of self-confidence, prone to addiction
  • Inability to express love / or accept love
  • Inability to lead family, constant health problem
  • Prone to mental health problems
  • Low self-esteem, depression, and anxiety
  • Post-traumatic stress disorder (PTSD)- 20 –
  • Attachment difficulties
  • Eating disorders
  • Poor peer relations, self-injurious behavior (e.g., suicide attempts)

In addition to knowing the signs of victimization, below are some early warning signs to look out for in potential offenders:

Signs of offenders (students):

  • Unusual interest in sex, sexualizing inanimate objects and activities
  • Does not stop sexual misbehavior when told to stop
  • Uses force and coercion in social situations
  • Unusual intensity when discussing sex and sexuality
  • Socializes with children much younger
  • Gives gifts, requires secrecy in relationships

Signs of offenders (adults):

  • Has “favorite” student or child
  • Attempts to find ways to be alone with children
  • Inappropriate language, jokes, and discussions about students/children
  • Sexualized talk in the presence of students/children
  • Gives private gifts or has private chats on social media

What happens after suspected abuse or neglect is reported? 

Where there is cause to suspect child abuse or neglect, it is the responsibility of the staff member to report his or her suspicions to a DSL or building Principal. In all cases, the building Principal will be notified. It is the responsibility of the building Principal to inform the School Director of the suspected case of abuse or neglect.

All staff, faculty, and administrators are mandated to report incidences of abuse and neglect. All WISS employees are also required to report suspicion of abuse or neglect. All reports of abuse and neglect must be made to a DSL, building Principal, or School Director within 24 hours for immediate response.