The

British
Council

Child Protection Policy

How we safeguard
the children and young people
we work with

Updated December 2011

Contents

1 Introducing the Child Protection Policy ..........................................................................................3

1.1 Why we need a revised Child Protection Policy.......................................................................................... 3
1.3 What is a Child Protection Policy?............................................................................................................... 3
1.4 Who is defined as a child?........................................................................................................................... 4
1.5 Who is the audience for the Child Protection Policy?................................................................................. 4
1.6 What are our responsibilities? .................................................................................................................... 4
1.7 How the Child Protection Policy fits with other policies within the British Council ................................... 4
1.8 Principles underpinning the Child Protection Policy ................................................................................... 5
2 Understanding Child Protection Issues...........................................................................................6
2.1 What are we protecting children from?...................................................................................................... 6
2.2 General definitions of child abuse............................................................................................................... 6
2.3 Cultural sensitivity ....................................................................................................................................... 7
3 Child Protection Focal Point.............................................................................................................7
4 Preventative Actions .........................................................................................................................8
4.1 Child Protection Code of Conduct ............................................................................................................... 8
4.2 Recruitment and Employment .................................................................................................................... 8
4.3 Induction, Training and Support.................................................................................................................. 9
4.4 Media, communication & information........................................................................................................ 9
5 Reporting – Responding to Allegations & Concerns ...................................................................10
6 Support and Resources ..................................................................................................................12
Appendix 1 - Child Protection Focal Point Role Description...............................................................13
Appendix 2 - Child Protection Code of Conduct...................................................................................14
Appendix 3 – Child Protection Reporting Flowchart............................................................................15
Appendix 4 – Child Protection Reporting Pathway ..............................................................................16
Appendix 5 – Creating, Managing & Disposing of Child Protection Records....................................19
Appendix 6 - Handling a Disclosure From a Child...............................................................................22
1 Introducing the Child Protection Policy

1.1 Why we need a revised Child Protection Policy

The British Council engage annually with up to two million children directly and seven million
children indirectly; these numbers are set to increase with our growth targets. Children participate
in a wide range of regulated activity 1 organised by our staff and implementing partners and which
are delivered on or off British Council premises involving frequent and intermittent contact including
overnight stays.

Over recent years, there has been increasing recognition that the abuse of children can and does
happen in organisations, and a growing acceptance of the potential risks to children from adult
unintentional acts and deliberate actions. Unintentional acts can happen due to a lack of ‘due
diligence’ and organisational negligence. It can lead to acts of harm such as child injury or
abduction due to inadequate care and supervision or lack of policies and procedures to inform staff
planning and practice. It can also emerge from a lack of staff compliance with legal requirements.
Deliberate actions are taken by people with intent to abuse children. Research and practice tell us
that predatory offenders with the intent to abuse children sometimes deliberately place themselves
in an organisation and/or job that give them access to children.

The British Council has long been concerned about the welfare and safety of children and
recognises that we have a fundamental duty of care towards all children we engage with. We take
our responsibility seriously to ensure we are doing all we can to protect children from abuse, both
from within and outside the organisation, and to take appropriate action if such abuse occurs.

A new, comprehensive Child Protection Policy was drafted in October 2010, to update and bring us
in line with current international good practice and regulatory requirements. This was followed by a
period of consultation with overseas offices and key personnel and panels from within the British
Council. Feedback from the consultation exercise was then incorporated into this, the final version
of the Child Protection Policy. The development of the new Child Protection Policy was lead by the
Corporate Child Protection Team with the support of Stephanie Delaney, an independent
consultant (Child Protection Specialist), based in Asia.

1.2 Purpose of a Child Protection Policy

Child protection is not just about health and safety. Even though we have a Health & Safety
Policy, and carry out risk assessments, this does not cover all the situations and circumstances we
need to address in relation to the protection of children. Therefore we need an additional policy that
considers all aspects and steers us as an organisation to do all that we can to keep children safe
and operate ethically.

Its purpose is to help us to develop a common understanding of child protection issues,

develop good practice across the diverse and complex areas in which we operate and thereby
increase accountability in this crucial aspect of our work. This policy, when put into practice, will
help make sure that children are protected. It also ensures that staff and other representatives
are protected. This aspect of good governance is also critical in maintaining the reputation and
credibility of the British Council.

1.3 What is a Child Protection Policy?

A Child Protection Policy is an organisation’s commitment to protect children from abuse,
exploitation and organisational negligence. This is reflected in the way an organisation
conducts its activities and the way staff behave. Child Protection Procedures are how an
organisation puts its policy into action. Examples of typical organisational child protection policy
& procedures include safer recruitment and screening processes for those working with the

1
As defined in Schedule 4 part 1 of the Safeguarding Vulnerable Groups Act 2006
3
British Council, codes of conduct for staff, guidance on the appropriate use of children’s images
and information and requirements for staff to report suspected or actual abuse.

For the British Council major challenges in developing a Child Protection Policy arise due to the
number of countries and different contexts we work in, and the diversity of our operations. This
Child Protection Policy sets out the broad framework and expectations, and it is recognised
that at country level teams will have to identify how to implement the policy, given the local
operating conditions and legal provisions.

Where it is not possible to comply with the policy (for example if there are laws governing
employment which affect local recruitment practices) this must be brought to the attention of
the Head of Child Protection (for contact details see Section 6) who can advise and assist
country offices in finding alternative, practical solutions.

1.4 Who is defined as a child?

In this policy, a child is defined as anyone who has not reached their 18th birthday irrespective
of the age of majority in the country where a child is, or their home country. ‘Children’ therefore
means ‘children and young people’ throughout. Although the national law in the country we are
working in may have a different age at which a child is considered an adult, or have a different
age at which a child can give consent or is responsible, we use the definition of a child
according to UK and international law since the British Council is a UK organisation working
internationally. This comes from the UK Children Act, 1989 and United Nations Convention on
the Rights of the Child, 1989. The United Nations Convention for the Rights of the Child is the
international framework which sets out the specific rights of children; it is the most widely
ratified international human rights instrument which over 190 countries have signed.

1.5 Who is the audience for the Child Protection Policy?

The policy covers and positively benefits children we engage with throughout the organisation.

This policy is mandatory for all British Council staff, world wide. For the purposes of this policy
‘staff’ is defined as anyone who works for the British Council, either in a paid or unpaid, full or
part time capacity. This includes directly employed staff, trustees, contractors, agency staff,
consultants, volunteers and interns.

It also covers implementing partners whom we fund, and who we should expect to agree to
work under the policy as a condition of their involvement with the British Council.

1.6 What are our responsibilities?

Everyone shares responsibility for safeguarding and promoting the welfare of children irrespective
of individual roles.

Our policy is for all staff to be responsible for implementing this policy and the reporting procedure
detailed in section five if they receive or become aware of any of the following situations in relation
to:
 any allegation of or concern about actual or suspected situations of abuse involving a
child or children known to the British Council
 any allegation of or concern about actual or suspected staff misconduct and/or criminal
activity involving the abuse of a child or children whether or not they are known to the
British Council

1.7 How the Child Protection Policy fits with other policies within the British
Council
There are numerous policies and procedures that have already been developed by the British
Council. This policy is not intended to contradict or undermine these, but instead to
complement and reinforce attempts to protect children contained in other policies. Over time,
some of these policies may be harmonised with the Child Protection Policy to ensure that there
are no contradictions. In the meantime, if discrepancies exist, then guidance should be sought

4
from the British Council Corporate Child Protection Team, who will be able to support country
offices in making the best decision for children.

1.8 Principles underpinning the Child Protection Policy

A number of key principles underpin the provisions of the Child Protection Policy. These
include:

 Best interests of the child are paramount and shall be the primary consideration in
our decision making.

 Child centred and rights based approach in order to keep children sharply in focus in all
our planning and direct work. Some of the worst child protection incidents have happened
when staff have lost sight of the child and their rights to be protected.

 Equality of opportunity to ensure that all children have the opportunity to enjoy our
activities safely regardless of their gender, ability, race, ethnicity, circumstances or age.
Vulnerable children will require particular attention in order to optimise their safety needs
and promote their access to important opportunities.

 Taking responsibility in order to meet our obligations regarding our duty of care towards
children, and taking action where we believe that a child is at risk or is actually harmed.

 Recognising and acknowledging that an element of risk exists, and while we may never be
able to totally remove this, we need to do all we can to reduce it or limit its impact.

 Honesty and transparency by informing those we work with, including children, about our
Child Protection Policy, and the way we work to try and protect children.

 Confidentiality to protect sensitive personal data. Information should only be shared and
handled on a need to know basis, that is, access to the information must be necessary for
the conduct of one's official duties. Only individuals who have legitimate reasons to access
the information are allowed to receive it.

 Supporting and training those working with the British Council to recognise and respond
to child protection risks and incidences.

 Working with others to protect children. This includes involving law enforcement and
specialist child welfare agencies where necessary.

 Monitoring the implementation of the Child Protection Policy. The Child Protection Policy
will be reviewed every three years.

1.9 Complaints
In this policy it is important to understand the difference between a complaint and an allegation
as our response will be different. Complaints are generally an oral or written expression of
dissatisfaction or concern about facilities or services. An allegation is an oral or written
declaration of wrong doing or assertion of misconduct or criminal behaviour, the validity of
which has not been established yet. This section deals with a complaint about the
implementation of the Child Protection Policy by the British Council. Go to section 5 of this
policy for advice on how to respond to allegations of misconduct or criminal behaviour.

Children and their parents or carers who wish to make a complaint to express dissatisfaction or
concern about how they have been treated by the British Council regarding the implementation
of this policy should in the first instance speak with their main contact point at the British
Council, who can then arrange for the appropriate follow up actions to be taken. Alternatively,
people can contact the Child Protection Focal Point (see Section 3 for further information).
Country Directors may decide on additional procedures for how to best handle complaints

5
overseas, but the key issues are that the process must be accessible and be communicated.
The Corporate Child Protection Team is available to provide advice and support as required.

For staff employed by the British Council, grievance procedures already exist within ‘Essential
HR’ in terms of how to complain about unfair treatment.

2 Understanding Child Protection Issues

It is important when considering child protection that we have a shared understanding of child
protection and what it means. If we do not fully understand what we are protecting children
from, then it is unlikely that we will be successful in our efforts.

2.1 What are we protecting children from?

In the context of this policy, when we talk about ‘child protection’ we do not mean preventing
accidents (covered by our Health and Safety Policy) or making sure that a child’s rights (principally
as defined in the United Nations Convention on the Rights of the Child) are fully implemented.
Instead we are referring specifically to the protection of children from abuse.

The British Council uses the definition of abuse commonly used by the World Health
Organisation:

‘Child abuse’ or ‘maltreatment’ 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’

2.2 General definitions of child abuse

Internationally, four main categories of abuse are generally recognised:

Physical Abuse: This may involve hitting, shaking, throwing, burning or scalding, drowning,
suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused
when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child who
they are looking after.

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

Neglect: This is the persistent failure to meet the child’s basic physical and / or psychological
needs, likely to result in the serious impairment of the child’s physical or cognitive
development. For example, inadequate care and supervision which leaves a child in a
dangerous situation where they could be harmed (but only where this can be avoided).

Sexual Abuse: This involves forcing or enticing a child to take part in sexual activities, whether
or not the child is aware of what is happening or gives consent. The activities may involve
physical contact, including penetrative (e.g. rape) or non-penetrative acts. They may also
include non-contact activities, such as involving children in looking at, or in the production of,
pornographic materials or watching sexual activities, or encouraging children to behave in
sexually inappropriate ways.

Other types of abuse commonly recognised, such as commercial sexual exploitation and
trafficking, are complex manifestations of a combination of the above four categories. It is
6
important to highlight that bullying is also a form of abuse as it is an act of aggressive behavior
in order to intentionally hurt another person or persons, mentally, physically and/or sexually.
Abuse can take place in many forms and anywhere, that is, in the family, community or on the
Internet. Abuse is also manifesting itself in digital and augmented technologies such as smart
phones. This can be virtual or real and can take many forms including sexual harassment and
child pornography. It should be remembered that although we commonly think of adults as
those who abuse children, children can also be the perpetrators.

2.3 Cultural sensitivity

The British Council seeks always to work in ways which are culturally sensitive and that respect
the diverse nature of the people we work with. We recognise that there are many different ways
of thinking and taking care of children and making sure they are protected. It is acknowledged
that protecting children and being culturally sensitive can be a difficult balancing act, especially
given the situation in many of the countries where we work. As an international organisation,
however, we endorse the United Nations Convention on the Rights of the Child general
principle that all the rights guaranteed by it must be available to all children without
discrimination; and article 19 which affords equal rights to protection for children from abuse.
Every child matters everywhere in the world. Culture must not be used as a reason or excuse
to abuse children.

The Corporate Child Protection Team is available to give guidance in terms of how to interpret
the policy and its application in the light of local circumstances.

3 Child Protection Focal Point

In order to assist with the implementation of the Child Protection Policy all Country Directors
must nominate someone to act as the Child Protection Focal Point. This need not be a senior
person within the organisation, but it should be someone who has the necessary skills and
commitment to taking on an additional role and where possible who speaks the local language.
If they are not a senior member of staff, they will require support from a senior responsible
officer who has the necessary status and authority within the country management team to
ensure the policy is implemented effectively.

In many countries a single Child Protection Focal Point will be sufficient, but a deputy should
be available to act in their absence. In larger countries where there is a wide geographic area
or in large operations where different parts of the operation (e.g. teaching, exams, and
programme) work with a lot of children, it may be necessary to have a number of deputies
representing each operational business area who are lead and coordinated by the Country
Child Protection Focal Point.

The main function of the Child Protection Focal Point is to support the implementation of the
Child Protection Policy. Broad areas of responsibility for the Child Protection Focal Points are
divided across three key areas: prevention and planning, communication and awareness
raising and incident management. For more information on the specific roles and
responsibilities, reference the role description, contained in Appendix 1 on page 13.

While at first sight this role can seem onerous, it is important to emphasise that this need not
be the case. If staff are made aware of, and take their responsibilities to protect children
seriously, there should be relatively little for the Child Protection Focal Point to do – except if a
situation of abuse occurs.

For UK operations, and work within the UK, the Head of Child Protection acts as the Child
Protection Focal Point.

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4 Preventative Actions
The most important key to child safety is prevention. It is widely recognised that organisational
awareness and good practice can promote positive staff action or behaviour, reduce opportunities
for offending and will enable early detection and response.

4.1 Child Protection Code of Conduct

Since ideas about child care vary, all staff who works with children must sign up and abide by
the child protection code of conduct, contained in Appendix 2 ( on page 14), which describes
the behaviour expected of them and their responsibilities in relation to children they come into
contact with as a result of their work with the British Council.

4.2 Recruitment and Employment

‘Safe’ recruitment and checks that are undertaken as part of the recruitment process are the
organisation’s first chance to deter potential offenders. The British Council will take all
reasonable measures to prevent unsuitable individuals from working with children. The majority
of people who want to work with the British Council are well motivated and without them the
organisation could not operate. Unfortunately, however, some individuals may use the
organisation to gain access to children for abusive and exploitative motives. Research and
practice tells us that predatory offenders with the intent to abuse children sometimes
deliberately place themselves in organisations and / or job roles that allow them access to
children. Opportunistic and situational offenders are reactive and responsive to cues given out
by the environment. It is therefore crucial to have some sort of screening process for
individuals entrusted with the care of children.

The British Council will take the following measures to ensure that only those who do not pose
a risk to children are employed or involved in its work:

1. All job, contract and service advertisements must state that the British Council works to
protect children and that those seeking work will be assessed regarding their suitability to
work with children.

2. Before employing any staff, background screening checks must be conducted to ensure
their suitability. This includes independent references and police checks (where available).

3. Where staff is engaged in ‘regulated activity’ (direct work with children), additional care
must be taken to ensure that they are suitable. This should include checking identification,
qualifications and obtaining references from previous employers.

4. Staff should be asked to sign a self declaration statement confirming that they have no
convictions for any offence involving any type of harm to a child or children, and should
declare anything that may affect their suitability to work with children.

5. In exceptional circumstances, it may not be possible to obtain background checks and

references. In these situations a careful assessment should be made as to whether it is
appropriate for the person to be put in the position of working alone with child.

6. Where allegations are made about staff, careful consideration must take place about the
appropriateness of the person continuing to work with the British Council. This may include
suspension during any internal or external investigation and dismissal if the allegation is
proved.

HR should be consulted and involved in all processes concerning directly employed staff to
ensure that workers’ employment rights are not violated. The first point of contact with HR
should be the office that was responsible for appointing the staff member / where their contract
was issued.

8
For more detailed guidance refer to the British Council Vetting Policy and Safer Recruitment
Guidance 2 .

4.3 Induction, Training and Support

Once staff has been recruited they need to be adequately trained and supervised to ensure
that any risks to children are minimised. This will be achieved through ensuring that:

1. All staff is inducted on child protection as it is essential that all staff is aware of their own
responsibilities, as well as organisational policy and practice. Child protection induction
must include completion of the global mandatory e-learning course –Child Protection Basic
Awareness – which will introduce the new starter to:

 The child protection policy

 The role of the Child Protection Focal Point and how they might be contacted
 Safe project planning and delivery
 What they should do in the event of a disclosure
 What to do if they have concerns about the welfare of a child
 How to recognise signs of abuse
 What to do if they have concerns about a staff member
 Where to go for advice and support within the organisation

In addition to this it is recommended good practice for the new starter to have a briefing on
the local child protection arrangements in place e.g. name of Child Protection Focal Point.

2. All staff will have access to advice, support and training regarding child protection and the
implementation of the Child Protection Policy, via the Child Protection Focal Point and the
Corporate Child Protection Team.

Where staff are contracted by other employers, or when working with partners, the British
Council will brief them on our child protection policy and ask for information on how the
organisation works to protect children (such as their child protection policy).

4.4 Media, communication & information

The British Council has a policy regarding the media and the use of images (including
photographs and recordings) and stories regarding children (the ‘Acceptable Usage Policy’).
This should be applied in all situations. Specifically relating to child protection, we will:

1. Ensure that personal information is kept confidential unless we have the agreement of the
child and their parent/guardian, except where it is necessary to pass this to a specialised
child welfare or law enforcement agency in relation to a child protection incident.

2. Use images of children which are respectful (not degrading, or showing sexual images of
children naked or partially clothed).

3. Reproduce images of children only where we have the written permission of their parents /
guardians.

4. Make clear to children and their families that agreement to providing information or images
is not a condition of involvement in British Council activities and programmes.

5. Staff should be informed about the policy of the British Council in relation to the use of
technology (such as computers and mobile phones), and understand that they must not use
this technology for the purpose of accessing, producing or distributing any information or
violent or sexual images that are harmful for children. This includes adult pornography.

2
These documents are currently being finalised – please contact the Head of Child Protection for further information in the meantime, if
necessary
9
5 Reporting – Responding to Allegations & Concerns
It is anticipated that, if this policy is properly implemented, the chances of an actual situation of
abuse occurring from within the organisation will be reduced. Even so, incidents may still arise
or information comes to light about the behaviour of another staff member which creates cause
for concern. We may also become aware of situations of actual or suspected abuse from
outside the organisation.

Child protection is a tricky and complex area. Speaking out when there is child abuse can be
difficult. The nature of child abuse means that it is hard to acquire concrete evidence. Staff is more
likely to be faced with indirect statements from children, non verbal clues and signs which can be
inconsistent. When actual disclosures of abuse are made they are often retracted. For this reason,
when faced with child abuse, staff are more likely to have feelings of concern; an intuition or
suspicion that something is happening but doubt their judgement and/or feel uncomfortable about
saying anything or raising the concern as they do not believe they have enough evidence. Because
of the often secret and intimidating nature of abuse and the severe impact it can have on children,
however, it is essential that people speak out.

It is not the responsibility of staff to decide whether or not child abuse has taken place. All staff,
however, have a responsibility to act on any concerns by reporting these to the Child Protection
Focal Point and/or Corporate Child Protection Team. They are a specialist and confidential
resource available for staff to talk to about any concerns, no matter how small and insignificant
they may seem, and will provide advice and support and decide what action to take.

To ensure that all such situations are handled appropriately and effectively, a reporting
mechanism has been created:

1. All allegations and concerns of abuse must be taken seriously, irrespective of the identity of
the alleged perpetrator and victims, and regardless of how ‘unbelievable’ the situation may
seem.

2. All staff must report any of the following situations in relation to:
 any allegation of or concern about actual or suspected situations of abuse involving a
child or children known to the British Council
 any allegation of or concern about actual or suspected staff misconduct and/or criminal
activity involving the abuse of a child or children whether or not they are known to the
British Council in accordance with the Reporting Flow Chart, contained in Appendix 3
on page 15.

3. No staff member can agree to keep information regarding actual or suspected abuse
‘private’ as a personal confidence. In general, the British Council will seek to discuss our
concern with the child in a way that is appropriate to the child’s age and understanding, and
with their parents/guardians, and seek their agreement if making a referral to a specialist
agency. However, there will be situations where this may place the child in danger. A
decision to refer to a specialist agency without informing the child and without obtaining the
consent of their parents/guardians should always be taken by the Child Protection Focal
Point in consultation with the Regional Child Protection Manager/Head of Child Protection.

4. Reports must be made, and decisions and actions taken, according to the Reporting Flow
Chart.

5. The British Council is not an investigative authority. It is essential that referrals be made, in
accordance with the Reporting Flow Chart, to the relevant child welfare and law
enforcement agency to ensure that appropriate protection and support is given to the child,
and that any evidence is collected in accordance with the law.

6. A written record of all child protection reports, including any decisions made, must be kept
up to date by the Child Protection Focal Point and logged on the child protection reporting
10
 form within the recommended time scales stated in the Reporting Flow Chart. This should
include details of any referrals made to specialist agencies.

7. All sensitive and personal data must be kept confidential (including the names of anyone
who makes a report of abuse), and be shared on a strictly ‘need to know basis’, that is,
access must be necessary for the conduct of one’s official duties. Guidance regarding the
storage of such information is attached in Appendix 5 (on page 19)

8. Referrals must be made to a specialist child welfare and law enforcement agency when
sufficient evidence exists that an allegation or concern is a serious welfare and/or criminal
matter, according to the Reporting Flow Chart. Apart from referrals to child welfare and law
enforcement agencies, no details regarding the circumstances of children and their families
will be passed to other individuals or organisations without the express permission of the
child and their parents / guardians.

9. Names of those who are alleged to be a risk to children will also be passed on to law
enforcement agencies where it is suspected that a crime may have been committed, for
investigation in accordance with relevant legislation. This will normally be the local police
agency, although where either the alleged abuser or the child is from another country, a
report should also normally be made to the appropriate embassy in country. This is
because, for some crimes and in some countries, legalisation exists to prosecute suspected
offenders in their home country if the local legislation is not comprehensive or is not
implemented.

10. Where a member of staff is the subject of an investigation (but not when making a report),
an Internal Child Protection Investigation Panel will be convened by the Head of Child
Protection. The panel will work alongside any formal police investigation. The composition
of the panel depends on the nature of the allegation or concern but will routinely consist of
a representative from Human Resources and Legal.

11. In situations where non local staff (e.g. British Council employed expatriates) are suspected
to be involved, either as the victim or the perpetrator, the local relevant Embassy should be
informed regardless of diplomatic status. This is important because, in some countries
where there are weak laws to protect children, perpetrators can be prosecuted in their own
home country. Many embassies have a police liaison officer who can work with local police
to ensure that evidence and information is collected in the appropriate way, and that
support is offered to victims.

12. Where abuse is sent or received via the Internet or other technologies (such as child
pornography images), even if this is received in the form of ‘Spam’ or passed on to the
British Council from another organisation, the images MUST NOT be sent via the Internet
to law enforcement agencies or to any other person working for the British Council,
including the Corporate Child Protection Team. Instead they should be contacted and
asked to advise how to send the information. This is because the distribution of child abuse
images (i.e. child pornography) is illegal under international (and in some cases domestic
law). Links to websites can be sent to law enforcement agencies by email.

13. When a child protection investigation involving a staff member concludes, decisions and
actions must be taken in accordance with the Reporting Flow Chart.

14. If a report of abuse is made, or concerns are raised, even if the situation is ultimately found
to be untrue, no retaliatory action will be taken against the person making the report in line
with our ‘Speaking Out Policy’. If, however, the report is found to be malicious, the staff
member will be offered support and Human Resources will decide on the course of action
relating to disciplinary and suspension issues.

15. Each country office should maintain a Child Protection Briefing Note which includes
information about specialised child welfare and law enforcement agencies and the

11
 appropriate mechanism under the national law for reporting concerns so that this
information is readily to hand.

16. It is understood that there will be unanticipated situations where staff will have to apply their
independent judgment. They should do so in a way that is consistent with the principles of
the policy and in consultation, when possible, with the Child Protection Focal Point and an
available senior manager. Where staff do have to apply their own judgement in relation to a
child protection issue, and it is not possible to consult with the Child Protection Focal Point,
the Child Protection Focal Point should be advised of the situation as soon as possible.

17. Any difficulties or confusion regarding how to apply the Reporting Flow Chart should be
referred to the Corporate Child Protection Team for further assistance and guidance.

6 Support and Resources

The Corporate Child Protection Team has further information and advice about keeping
children safe and child protection. There are also excellent child protection resources outside
the British Council, which are published in local languages, or are written specifically to
address the local, or country, situation. To access these resources and find out who to contact
for advice and support, click on the link to the child protection intranet page.

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Appendix 1 - Child Protection Focal Point Role Description

Main purpose: To support the Country Director with the day to day operationalisation of the British
Council’s Child Protection Policy. The final accountability on child protection policy compliance lies
with the Country Director.

Technical advice from the Regional Child Protection Manager is available for all the tasks listed
below:

Prevention & Planning

1. Coordinate the drafting of a Child Safe Action plan, ensuring involvement of all relevant staff 3 .
2. Coordinate the effective implementation and monitoring of the Child Safe Action Plan. In bigger
countries this involves leading the Child Protection Working Group. In smaller countries it
involves leading on action plan updates in already existing meeting forums. 4
3. Establish links with local specialist child welfare, health and law enforcement contacts in order
to have information available if an incident occurs and/or external advice is needed.
4. Keep an overview of safer recruitment guidelines and support recruitment managers to
implement them.
5. Ensure that all staff are aware of key child protection resources required to plan and deliver
child safe activities, and provide advice when needed. 5

Communication & Awareness Raising

1. Ensure that all staff is aware of the child protection policy and the role of the Child Protection
Focal Point.
2. Promote the global mandatory child protection e-learning modules and provide short staff
awareness raising sessions as required.
3. Keep up to date with available communication resources developed at corporate level and
promote the usage of these.

Incident Management
1. Act as first point of contact for child protection concerns, and escalate concerns to the
Corporate Child Protection Team and/or Senior Manager as appropriate.
2. With guidance from Regional Child Protection Manager, liaise with in-country child welfare
and/or law enforcement agencies and, as far as possible, ensure that the child(ren) receives
adequate support.
3. Keep an accurate record of incidents and ensure that they are data protection compliant.

Suggested CPFP deliverable :

Key Deliverable: To coordinate and ensure the effective implementation of the child
protection policy.

Measurements: (to be chosen and adapted by each focal point and their line manager)
1. Ensure successful creation and implementation of the Child Safe Action Plan, involving all
relevant staff
2. Ensure that staff is aware of child protection through completing the mandatory e-learning tool
and through other training tools and awareness sessions.
3. Ensure that information about the British Council’s commitment to keeping children safe is
openly displayed and available to customers (including children and parents) and partners.
4. Ensure that if a child protection incident happens, the focal point is acting as first point of
contact for child protection concerns, and escalates concerns to the Corporate Child Protection
Team and/or Senior Manager as appropriate.

3
The Regional Child Protection Manager will provide close tailor-made support on this point
4
Country Director has the responsibility for ensuring that the focal point has the opportunity to share action plan updates in already
existing meetings/forums. Refer also to the outline of Country Director’s responsibilities in terms of child protection policy
implementation
5
All child protection resources are available on the child protection intranet site. The site is regularly updated with new additions.
13
Appendix 2 - Child Protection Code of Conduct

6
All British Council staff who work with children must sign up and abide by this Code of
Conduct.

ALWAYS:
 Listen to and respect children, empower them and let them participate in planning and
delivering activities as much as possible
 Be aware of situations which may present risks for children and take appropriate actions
 As far as possible, be visible when working with children
 Consider your physical appearance at work. Adults working with children should dress
appropriately for the task undertaken
 Contribute to ensure a sense of accountability amongst staff so that poor practice or potentially
abusive behaviour does not go unchallenged
 Report any concerns you may have about the protection or wellbeing of a child/children to
your Child Protection Focal Point, line manager or the corporate Child Protection Team
 Observe confidentiality and not talk about any situations of actual or suspected abuse that
occurs except in accordance with this policy. This is necessary to protect the privacy of
those involved
 If you are arranging or participating in an event or trip where children are present, you
MUST read Trips & Events: Child Protection Checklist
 Teachers are encouraged to use the document Code of Conduct for Children to develop
positive classroom environments and prevent bullying. Teachers are also encouraged to
consult the child protection intranet for resources on anti-bullying and positive discipline

NEVER:
 Hit or otherwise physically assault or abuse children
 Act in ways meant to shame, humiliate, belittle or degrade children
 Show differential treatment, or favour particular children to the exclusion of others
 Use language or make suggestions which are inappropriate, offensive or abusive
 Spend excessive time alone with children away from others
 Develop relationships with children which could in any way be seen as exploitative or abusive
 Develop intimate sexual relationships with children
 Pay for sexual services, of any kind, at any time, with anyone under the age of 18 years
old, even if the age of sexual consent in the country is under 18 years.
 Expose children to pornographic materials in electronic or any other form
 Permit children to take part in activities that are illegal, unsafe or abusive
 Whilst working:
o take or condone the taking of illegal drugs
o drink alcohol when with children (or prior to contact)
 Sleep in the same room as a child if this has not been agreed by their parent/guardian
 Invite, or allow, a child you have met through work into your home
 Offer to transport a child alone in a car
 Enter a child’s private home unless there is a responsible adult present.
 Use personal email accounts, social networking sites, mobile phones or other means of
communication to contact children. Always use business email accounts and copy in parents
when sending out communication to children.
 Take photos of children participating in British Council activities without getting consent from
the child when possible. Consent always needs to be given in writing by the parent/carer.
 Let allegations go unreported, including any made against them
 Agree to keep any information relating to the abuse of a child confidential. They should
always follow the procedures for reporting concerns
This is not an exhaustive or exclusive list. The principle is that staff should avoid action or behaviour
which may constitute poor practice or potentially abusive behaviour.

6
‘Staff’ is defined as anyone who works for the British Council, either in a paid or unpaid, full or part time capacity. This includes directly
employed staff, trustees, contractors, agency staff, consultants, volunteers and interns.
14
 Appendix 3 – Child Protection Reporting Flowchart

CONCERN ABOUT CHILD/CHILDREN

Q: Are there immediate concerns?
Note: If a child discloses an issue to you, remain calm and follow the guidelines for disclosure
I A
No I L
Yes
I L
GENERAL CONCERN
IMMEDIATE CONCERN OF IMMINENT HARM I
Note: Life threatening situation
Report immediately to the authorities Report to child protection focal point I S
CONTACT NUMBER AMBULANCE: (CPFP) I T
CONTACT NUMBER POLICE: I A
CONTACT NUMBER CHILD WELFARE CONTACT NUMBER CPFP: F
CONTACT NUMBER CPFP
I
F
I
I
I
CPFP RECEIVES REPORT OF CONCERN
Q: Is there still a concern?

No Yes I
STILL HAS CONCERN I
NO CAUSE FOR CONCERN
I
Q: Was the allegation malicious? Q: Is there enough information to take immediate action? I
CONTACT NUMBER REGIONAL CHILD PROTECTION MANAGER: C
No Yes I P
Review lessons CONSULT LINE No
I F
Yes
learnt or training MANAGER I P
needs identified. CHILD PROTECTION INTERNAL ENQUIRY I
Q: Enquiry findings evidence need for further action? +
I
No Yes I C
I P
IMMEDIATE ACTION NEEDS TO BE TAKEN I
Q: Does the concern involve a staff member? I T
Yes I E
No A
I M
Q: Is it a criminal matter? I
No REFERRAL TO SPECIALIST AGENCIES I +
Yes NAME OF LOCAL CHILD PROTECTION AGENCY:
INTERNAL CHILD NAME OF MAIN CONTACT PERSON: I
CONSULT SENIOR CONTACT NUMBER: I A
PROTECTION
MANAGEMENT IN LINE (Note: In coordination with Regional Child u
AND\OR HUMAN
INVESTIGATION PANEL I D
(Note: convened by Protection Manager. British Council involvement
RESOURCES Head of Child concludes here) I I
(Note: For negligence Protection) I T
and/or breach of code of
conduct) I
I +

PARALLEL
I H
REFERRAL TO LAW ENFORCEMENT
(Note: Head of Child Protection to lead on this) EXTERNAL INVESTIGATION I R
I
INVESTIGATION CONCLUDES I +
Q: Has the allegation or concern involving a staff member been substantiated? I
L
No Yes I E
I G
UNSUBSTANTIATED CRIMINAL ACTIVITY SUBSTANTIATED CRIMINAL ACTIVITY
I A
I L
I
INVESTIGATION REVIEW AND LESSONS LEARNT I
15 I
I
I
I
Appendix 4 – Child Protection Reporting Pathway

CONCERN ABOUT CHILD/CHILDREN

Question 1: Are there immediate concerns?

YES- IMMEDIATE CONCERN OF NO – GENERAL CONCERN

IMMINENT HARM (life threatening
situation)
Take immediate action as required. Report to Child Protection Focal Point
- If the CPFP is not available, (CPFP) within 24 hours to assess and
discuss the situation with decide what course of action to take.
available senior manager and
parent/guardian as appropriate.
- If concern relates to a clear
offender, separate the child from
the alleged offender.
- Report to relevant authorities
(medical, police or social welfare).
- Report the incident to the CPFP
at first opportunity and log
incident on the child protection
intranet reporting form within 24
hours.
Note: If a child discloses an issue to you remain calm and follow the guidelines
for dealing with a disclosure.

Question 2: Is there still a concern?

YES - STILL HAS CONCERNS NO – NO CAUSE FOR CONCERN

CPFP reports concern immediately to CPFP logs incident on the child
Regional Child Protection Manager and protection intranet reporting form within
informs senior management in line as 48 hours.
appropriate.

CPFP to log incident on the child Question 3: Was the allegation

protection intranet reporting form within malicious?
24 hours. YES – CONSULT NO
LINE MANAGER
Line manager in Review lessons
consultation with learnt or training
Human Resources needs identified
to support staff that
have been the
subject of a
malicious
allegation and
decide course of
action relating to
disciplinary and
Note: Please move on to question 4. suspension issues.

16
Question 4: Is there enough information to take immediate action?

YES - IMMEDIATE ACTION NEEDS TO NO - CHILD PROTECTION INTERNAL

BE TAKEN ENQUIRY
Reasonable cause exists that the More information required to decide
concern is either: appropriate course of action. Regional
 Staff breach of conduct Child Protection Manager/Head of Child
 Negligence Protection conduct enquiry within 3
 Welfare and/or criminal matter. working days to gather more facts.

Note– Please move on to question 6 Question 5 – Do the enquiry findings

provide a reasonable cause of
concern to warrant need for further
action?
YES – NO- NO CAUSE
REASONABLE FOR CONCERN
CAUSE
A reasonable There is no cause
cause exists that for concern, no
the concern is a grounds exist at
breach of conduct, this stage to
welfare and/or warrant any further
criminal matter action.

Internal enquiry
Note: Please report produced
move on to including
question 6. recommendations
for on-going
monitoring of case
if appropriate.

QUESTION 6: Does the concern involve a staff member?

YES NO - REFERRAL TO SPECIALIST

Question 7: Is it a criminal matter? AGENCIES
YES – INTERNAL NO – CONSULT CPFP to make a referral to specialist
CHILD HUMAN agencies [social welfare or law
PROTECTION RESOURCES enforcement] in consultation with
INVESTIGATION parent/guardian where appropriate.
PANEL
This is to be done with the advice and
Internal For negligence, support from a Regional Child Protection
Investigation Panel senior Manager and/or the Head of Child
will be convened management in Protection. Liaison with Senior Managers
by the Head of line informed to in the line and specialist agencies as
Child Protection to decide course of appropriate.
coordinate an action.
organisational
response. The For breach of
composition of the conduct cases
panel depends on Human Resources Note: BC involvement concludes here.
the nature of the informed to decide
allegation/concern course of action
but will routinely
consist of Head of
Audit, Head of

17
Legal and a
representative from
Human Resources.
Liaison with senior
management within
the line and
external agencies
as required.

REFERRAL TO LAW ENFORCEMENT

Head of Child Protection to inform Head
of Audit and Head of Legal to agree
immediate course of action including
referral to law enforcement. Human
Resources informed to suspend staff
subject of allegation pending criminal
investigation.

Note: Parallel External Investigation

INVESTIGATION CONCLUDES

Question 8: Has the allegation or concern involving a staff member been substantiated?

YES - SUBSTANTIATED CRIMINAL NO - UNSUBSTANTIATED

ACTIVITY CRIMINAL ACTIVITY
Staff subject of allegation informed of Staff subject of allegation informed of
outcome and dismissal action taken by outcome, reinstated and offered post
Human Resources. investigation support by Human
Resources.
INVESTIGATION REVIEW AND LESSONS LEARNT
Regional Child Protection Manager to update intranet reporting form within 24 hours.
Head of Child Protection to write a report including lessons learnt and
recommendations within 10 working days.

18
Appendix 5 – Creating, Managing & Disposing of Child Protection Records

It is important that any records that are created in the course of managing child protection
situations are created, managed and protected appropriately. The Data Protection Act 1998 is a
UK law to which the British Council is subject. It requires that personal information generated from
such records be:

 adequate, relevant and not excessive for the purposes(s) for which they are held
 accurate and where necessary kept up to date
 not kept for longer than is necessary for its purpose.

In any given situation, an accurate record should be kept, and should be signed by the person or
people making the statement. The following details should be included:

o date and time of incident/disclosure

o parties who were involved, including any witnesses to an event
o what was said or done and by whom
o any action was taken by the organisation to look into the matter
o any further action taken
o where relevant, the reasons why a decision was taken not to refer those concerns to
a statutory agency
o any interpretation/inference drawn from what was observed, said or alleged should
be clearly recorded as such
o name of person reporting on the concern, name and designation of the person to
whom the concern was reported, date and time and their contact details

Retention of records
The following guidelines on handling and retention of records relating to child protection
situations are based on NSPCC (England and Wales) guidelines. If in doubt, contact the British
Council’s records management helpline RecordsandArchives@[Link], or contact the
Corporate Child Protection team.

Relationship with Circumstance Action Retention Example

British Council
Child protection Documentation This and related This would
concerns that should be created records should include
British Council to confirm receipt be maintained concerns about
refers on to of referral, and for 6 years after physical, sexual,
 Customer/ authorities such this should be the last contact emotional or
student as the police or maintained by with the service negligent
equivalent British Council. A user. Records actions involving
 Third party written record of should be a child or
service the concern, destroyed with children,
provider not including approval of the disclosures from
defined above decisions made Head of Child a child about
should be Protection. being abused or
 Other maintained by information from
beneficiary of Country Director a third party
British Council or Child which might
(i.e. Protection Focal suggest a child
Scholarship or Point is being abused;
grant) concerns about
a parent or
another adult
that has contact
with British
19
 Council, or a
young person
who has been
abused by
another young
person
Child welfare In such Destroy the This could
concerns that circumstances A record one year include
British Council written record of after the concerns where
decide after the concern or child/adult a child has been
consultation, do allegation made concerned bullied, overly
not necessitate should be ceases to use pushy parents
a referral to maintained by the the service or a very
authorities such Child Protection unless the child distressed child
as the police or Focal Point. or adult are where the
equivalent continuing to distress is
. use your unrelated to
organisation. child abuse
Records should
be destroyed
with approval of
the Head of
Child Protection
Concerns about All records This could
people (paid (including include
and disciplinary allegations,
unpaid) who records) should convictions,
work be retained for 6disciplinary
with children. years after action, and
This might (but employment inappropriate
not necessarily) ceases. behaviour
result in referral towards
to authorities However if any children. For
such as the of the following example where
police or apply: an employee
equivalent. There were has breached
Employee concerns about the code of
of British the behaviour of conduct, a
Council an adult who record of the
was working behaviour, the
 Paid
with children action taken and
 Unpaid
where s/he outcome should
 Voluntary be recorded.
behaved in a
 Contractor way that has
 Consultant harmed, or may
have harmed, a
child;

The adult
possibly
committed a
criminal offence
against, or
related to, a
child;

The adult
behaved

20
 towards a child
in a way that
indicates s/he is
unsuitable to
work with
children

In such
circumstances
records should
be retained at
least until the
adult reaches
normal
retirement age,
or for 10 years
if that is longer.
Records should
be destroyed
with approval of
the Head of
Child Protection.
Criminal The actual
Records Bureau disclosure form
or other must be
disclosures destroyed after
obtained as part 6 months.
of the
employment
screening
process

Access to these records should be strictly limited to those immediately involved in the situation,
including the relevant Child Protection Team member, Country Director, Child Protection Focal
Point and HR representative. These records may also need to be shared with relevant authorities
such as the police where necessary.

Any record created in association with a child protection situation should be marked and handled
as PROTECT in accordance with the British Council Protective Marking Scheme (BCPMS).

When records are destroyed, they should be done so with the approval of the Child Protection
Manager / Head of Child Protection with advice from the British Council Departmental Records
Manager. Paper records should be destroyed using cross-cut shredder method, and details of
destruction should be registered and certified. For further information contact the British Council’s
records management helpline RecordsandArchives@[Link] .

21
Appendix 6 - Handling a Disclosure From a Child

What should you do if a child comes to you and tells you that they are being abused? It’s normal to
feel overwhelmed and confused in this situation. Child abuse is a difficult subject that can be hard
to accept and even harder to talk about. Children who are abused are often threatened by their
perpetrators to keep the abuse a secret. Thus, telling an adult takes a great amount of courage.
Children have to grapple with a lot of issues, including the fear that no one will believe them. Thus,
care must be taken to remain calm and to show support to the child throughout the disclosure
phase. The following guidelines will help lessen the risk of causing more trauma to the child and/or
compromising a criminal investigation during the disclosure phase.

Receive:
 Listen to what is being said without displaying shock or disbelief. A common reaction to news
as unpleasant and shocking as child abuse is denial. However, if you display denial to a child,
or show shock or disgust at what they are saying, the child may be afraid to continue and will
shut down.
 Accept what is being said without judgement.
 Take it seriously.

Reassure:
 Reassure the child, but only so far as is honest and reliable. Don’t make promises that you
can’t be sure to keep, e.g. "everything will be all right now". Reassure the child that they did
nothing wrong and that you take what is said seriously.
 Don’t promise confidentiality - never agree to keep secrets. You have a duty to report your
concerns.
 Tell the child that you will need to tell some people, but only those whose job it is to protect
children.
 Acknowledge how difficult it must have been to talk. It takes a lot for a child to come forward
about abuse.

React:
 Listen quietly, carefully and patiently. Do not assume anything – don’t speculate or jump to
conclusions.
 Do not investigate, interrogate or decide if the child is telling the truth. Remember that an
allegation of child abuse may lead to a criminal investigation, so don’t do anything that may
jeopardise a police investigation. Let the child explain to you in his or her own words what
happened, but don’t ask leading questions.
 Do ask open questions like "Is there anything else that you want to tell me?"
 Communicate with the child in a way that is appropriate to their age, understanding and
preference. This is especially important for children with disabilities and for children whose
preferred language is not English.
 Do not ask the child to repeat what they have told you to another member of staff. Explain what
you have to do next and whom you have to talk to.
 Seek advice from your line manager, child protection focal point or the corporate child
protection team.

Record:
 Make some very brief notes at the time and write them up in detail as soon as possible.
 Do not destroy your original notes in case they are required by Court.
 Record full information about the child and disclosure on the child protection intranet reporting
form.
 Record the date, time, place, words used by the child and how the child appeared to you – be
specific. Record the actual words used; including any swear words or slang.
 Record statements and observable things, not your interpretations or assumptions – keep it
factual.

22