Introduction

1.1 Purpose of this Policy

This policy sets out how Providence English Private School (PEPS) safeguards and promotes the welfare of every student in our care. It describes our statement of intent, the legal and regulatory framework we operate within, the roles and responsibilities of our community, our three-tier safeguarding training structure, and the procedures staff, parents and students follow to recognise, respond to and report a concern.

This is the school's principal safeguarding document. It should be read alongside the Behaviour & Discipline Policy, Anti-Bullying Policy, Health & Safety Policy, Digital Citizenship Policy, Inclusion Policy, Candidate Absence Policy and Whistleblowing arrangements, all of which support the same aim: keeping every child safe.

1.2 Scope

This policy applies to all students at PEPS, from FS2 to Year 13, and to all staff, governors, volunteers, contractors, visitors and third parties working with or around students, on and off site, including school transport, trips and extracurricular activities.

1.3 Statement of Intent

We are committed to:

• Providing a safe environment for students to learn and develop, in which children feel confident to raise concerns about their own welfare or that of others.
• Identifying students who are suffering, or likely to suffer, significant harm, and taking appropriate action with the aim of making sure they are kept safe, both at home and at school.
• Ensuring all staff and volunteers understand their responsibilities in being alert to the signs of abuse and responsible for referring any concerns to the Designated Safeguarding Lead (DSL).
• Following carefully our procedures for recruitment and selection of staff and volunteers, and ensuring appropriate action is taken in the event of an allegation being made against a member of staff, volunteer or contractor.
• Providing safeguarding and child protection training for all staff, at the level appropriate to their role, in accordance with the three-tier training framework described in Section 5.
• Reviewing and updating this policy at least annually, or sooner if required by a change in legislation, regulatory guidance, or the outcome of a case review.

Legal and Regulatory Framework

This policy is written with reference to the child protection and safeguarding legislation and regulatory guidance applicable in the United Arab Emirates and the Emirate of Sharjah. Full references are provided in Appendix B.

In particular, this policy is underpinned by:

• Federal Law No. (3) of 2016 concerning Child Rights, known as Wadeema's Law, which establishes the fundamental rights of the child in the UAE, including the right to protection from all forms of abuse, neglect and exploitation, and places a duty on anyone in contact with children — including teachers and school staff — to report suspected abuse to the competent authorities.
• Reporting duty: Wadeema's Law places a legal obligation on school staff, as persons in regular contact with children, to report suspected cases of abuse or neglect to the relevant authority. This duty cannot be delegated away or ignored, and applies regardless of a staff member's role or seniority.
• UAE Cabinet Resolution No. (52) of 2018 concerning the Executive Regulation of Wadeema's Law, which sets out the practical mechanisms for implementing child protection duties.
• The National Child Protection Policy in Educational Institutions in the UAE, issued by the Ministry of Education, which applies to all public and private educational institutions in the UAE, whether delivering education in person or remotely, and sets out the roles and responsibilities of schools, staff, parents and educational authorities in protecting children.
• The UAE School Inspection Framework, under which the protection, care, guidance and support of students is inspected as a distinct performance standard, evaluated by the Sharjah Private Education Authority (SPEA) for schools operating in Sharjah.
• The oversight of the Sharjah Private Education Authority (SPEA), the regulatory body for private education in Sharjah, established by Emiri Decree No. 45 of 2018, which licenses, inspects and monitors PEPS's compliance with child protection and safeguarding requirements.
• Federal Decree-Law No. 34 of 2021 on Combating Rumours and Cybercrimes, which is relevant to online safety, cyberbullying and the misuse of technology to harm a child.
• The United Nations Convention on the Rights of the Child (UNCRC), ratified by the UAE, which underpins the principle that the best interests of the child are the primary consideration in all actions concerning children.

Where relevant, this policy is also informed by internationally recognised best practice frameworks referenced by British-curriculum schools, such as Keeping Children Safe in Education and Working Together to Safeguard Children, used to benchmark practice rather than as UAE legal requirements.

Definitions

3.1 Safeguarding and Child Protection

Safeguarding is the broader, proactive duty to protect children's health, wellbeing and rights, and to enable them to grow up in circumstances consistent with safe and effective care, including through good pastoral practice, supervision and a positive school culture.

Child Protection is the more specific activity undertaken to protect individual children who have been identified as suffering, or likely to suffer, significant harm.

3.2 Categories of Abuse

There are four recognised categories of abuse. A child may experience one or more than one type at the same time.

Staff do not need to be certain that abuse is taking place before raising a concern. It is very important that staff report all concerns, however minor they may seem — the responsibility for deciding what happens next sits with the Designated Safeguarding Lead, not with the member of staff who noticed the concern.

3.3 Peer-on-Peer Abuse

Children can, and do, abuse other children. This is referred to as peer-on-peer abuse, and can take many forms, including bullying (including online/cyberbullying), physical abuse, sexual violence and sexual harassment, and gender-based violence. Abusive behaviour by one child towards another is never acceptable and will never be dismissed as 'banter', 'part of growing up', or a normal part of a relationship. Any such concern is treated with the same seriousness as abuse by an adult, and is addressed through this policy alongside the school's Anti-Bullying Policy and Behaviour & Discipline Policy.

3.4 Other Safeguarding Concerns

Beyond the four core categories of abuse, staff should also be alert to other specific safeguarding concerns that may affect a child's welfare, including online safety risks, radicalisation and exposure to extremist views, forced marriage, female genital mutilation, substance misuse, self-harm, and children missing education. Any such concern is raised with the DSL in the same way as any other safeguarding concern, following the procedure in Section 7.

3.5 Key Roles

• Designated Safeguarding Lead (DSL): the senior member of staff with lead responsibility for safeguarding and child protection across the school.
• Deputy Designated Safeguarding Lead: a trained member of staff who supports the DSL and deputises in their absence.
• Designated Safeguarding Team: the DSL, deputy DSLs, and other core members (such as the School Counsellor and School Nurse) who together coordinate the school's safeguarding response.

Roles and Responsibilities

Safeguarding is everyone's responsibility. Every adult working with, or on behalf of, PEPS students has a part to play, but certain roles carry specific, named responsibility.

4.1 The Principal / Head of Centre

• Has overall responsibility for safeguarding and child protection across the school, and is accountable to the Governing Body and to SPEA for the school's compliance with this policy and applicable UAE legislation.
• Ensures the Designated Safeguarding Lead and deputy DSLs are appointed, trained to Level 3, and given sufficient time, status and resource to carry out the role effectively.
• Acts as the case manager where an allegation of abuse is made against a member of staff, in line with Section 8, other than where the allegation concerns the Principal, in which case the Chair of the Governing Body assumes this role.
• Ensures this policy is reviewed at least annually and communicated to all staff, parents and, in an age-appropriate way, students.

4.2 Designated Safeguarding Lead (DSL)

The DSL takes lead responsibility for safeguarding and child protection, including:

• Acting as the first point of contact for any member of staff, student or parent who has a safeguarding concern.
• Managing referrals to the Ministry of Education's Child Protection Unit, the Sharjah Child Protection Centre, the Ministry of Interior's Child Protection Centre, and/or the Police, as appropriate to the nature and urgency of the concern.
• Maintaining accurate, confidential, and secure safeguarding records for every child about whom a concern has been raised, kept separately from the child's general school file.
• Coordinating the school's response where a concern involves a child of determination, an English Language Learner, or another student who may need additional support to communicate or be understood, working with the Inclusion Support Team.
• Ensuring that all staff receive Level 1 induction training on appointment, and that Level 1/2 training is refreshed regularly.
• Liaising with children's social care, the Police, and other agencies as required, and attending or contributing to any multi-agency meetings concerning a PEPS student.
• Reporting, at least annually, to the Principal and Governing Body on the operation and effectiveness of this policy, anonymised as appropriate.

4.3 Deputy Designated Safeguarding Leads

Deputy DSLs are trained to the same Level 3 standard as the DSL and are authorised to carry out the DSL's functions in their absence. At least one deputy DSL is available at all times the school is in session, including during off-site trips and extracurricular activities where practicable.

4.4 All Staff

• Complete Level 1 safeguarding induction training before, or as soon as possible after, starting work at the school, and refresh this training regularly.
• Remain alert to signs that a child may be at risk of harm, whatever their role.
• Report any concern to the DSL (or a deputy) as soon as possible, and always on the same day the concern arises, following the procedure in Section 7.
• Never investigate a concern themselves, promise a child confidentiality, or take independent action outside of this policy.
• Maintain professional boundaries with students at all times, in line with the school's Staff Code of Conduct.

4.5 School Counsellor and School Nurse

The School Counsellor and School Nurse are core members of the Designated Safeguarding Team, providing pastoral and medical expertise to inform the school's response to a concern, and supporting the wellbeing of a student and their family throughout a safeguarding process, in line with the school's Whole-School Wellbeing Policy and Health & Safety Policy.

4.6 Governing Body

• Ensures the school has robust safeguarding arrangements in place and that this policy meets current legislative and regulatory requirements.
• Appoints a link governor for safeguarding, who meets with the DSL regularly and provides an independent line of oversight and challenge.
• Ensures safer recruitment practice is followed for the appointment of all staff and volunteers (Section 9).

4.7 Parents and Carers

• Are familiar with this policy and support the school's safeguarding arrangements.
• Provide the school with accurate emergency contact and medical information, and update it promptly when it changes.
• Raise any concern about their own child's welfare, or that of another child, with the class/subject teacher or directly with the DSL.

4.8 Students

• Are taught, in an age-appropriate way through the curriculum and pastoral programme, how to recognise unsafe situations, and who they can talk to if they are worried about themselves or a friend.
• Know that any member of staff will listen to them and take their concern seriously, and that they will not get in trouble for raising a genuine concern.

The Three-Tier Safeguarding Training Framework

PEPS applies a three-tier training model, consistent with the levels of safeguarding training recognised across UAE and international schools, so that the depth of training a member of staff receives matches their level of contact with, and responsibility for, students.

This policy itself is written to Level 3 standard: it is the master reference document underpinning the training, decision-making and case-management responsibilities of the Designated Safeguarding Lead and deputy DSLs, while remaining the single policy referred to by all staff, parents and students regardless of their own training level.

Training records for all three levels are maintained by the DSL and are available for inspection by SPEA.

Responding to a Concern or Disclosure

6.1 If a Child Discloses to You

Any member of staff may be the person a child chooses to talk to. If a child discloses that they are being harmed, or you otherwise become concerned about a child's welfare:

• Stay calm, and listen carefully without expressing shock or disbelief.
• Do not promise the child confidentiality — explain, gently and age-appropriately, that you will need to tell someone whose job it is to help.
• Do not ask leading questions or investigate — your role is to listen, not to interview the child.
• Reassure the child that they have done the right thing in telling you, and that it is not their fault.
• As soon as possible afterwards, write down what was said, in the child's own words as far as possible, with the date, time and any names mentioned, and pass this to the DSL the same day.

6.2 Recording a Concern

Every concern, however small it may seem, is recorded in writing using the Recording a Concern form (Appendix C) and passed to the DSL or a deputy without delay. Records are factual, timely, and kept securely and confidentially, separate from the student's general school file, in line with Section 10.

6.3 Referral and Escalation Procedure

The following procedure applies once a concern has been raised:

6.4 Confidentiality and Information Sharing

• Information about a safeguarding concern is shared only with those who need to know, on a strict need-to-know basis.
• Staff never discuss a safeguarding case with colleagues who are not involved, with the wider school community, or on social media or other public platforms.
• Where sharing information with parents could increase risk to the child (for example, where a parent is the subject of the concern), the DSL decides, in consultation with the relevant authority where necessary, whether and how parents are informed.
• Information is shared with external agencies in accordance with UAE data protection requirements and only to the extent necessary to protect the child.

Allegations Against Staff, Volunteers or Contractors

PEPS takes any allegation that a member of staff, volunteer, contractor or agency worker may have behaved in a way that has harmed, or may harm, a child, extremely seriously. Such allegations are managed in accordance with this section, distinct from the general referral procedure in Section 6, to ensure both the child and the adult concerned are treated fairly.

• Any allegation against a member of staff is reported immediately to the Principal, who acts as the case manager, unless the allegation concerns the Principal, in which case it is reported to the Chair of the Governing Body.
• The case manager considers, without delay, whether there is cause to suspect a child is suffering, or is likely to suffer, significant harm, in which case a referral is made immediately to the relevant authority (Section 6.3) and/or the Police, in parallel with any internal process.
• Where appropriate, the case manager considers whether interim measures are needed to protect students while the matter is looked into, such as adjusting the member of staff's duties or, in serious cases, suspension — noting that suspension is not, in itself, an indication of guilt.
• The individual against whom the allegation is made is informed of the nature of the allegation, as far as this does not compromise the safety of the child or the integrity of any investigation, and is treated fairly and supportively throughout the process, in line with the school's HR and disciplinary procedures.
• The case manager maintains a confidential record of the allegation and its outcome, retained in accordance with the school's records retention arrangements, distinguishing clearly between an allegation that was substantiated, unsubstantiated, unfounded, or malicious.
• Where an allegation is found to be malicious, the school considers what disciplinary action may be appropriate against the person who made it, recognising that a genuine concern raised in good faith, which subsequently proves unfounded, is never treated as malicious.

Safer Recruitment

PEPS is committed to safer recruitment practice for all staff, volunteers and regular contractors who will have contact with students, in order to deter, reject or identify individuals who might pose a risk to children.

• All job advertisements and interviews make clear the school's commitment to safeguarding.
• Identity, right-to-work, and relevant qualifications are verified for every candidate before appointment.
• At least two references are obtained for every appointment, including, where possible, from the candidate's most recent employer working with children, and followed up directly rather than relying on open references alone.
• A police clearance certificate (or equivalent criminal record check from the candidate's country of residence and any country of prior residence, as applicable) is obtained before, or as a condition of, appointment, for all staff and regular volunteers with access to students.
• Any gaps in a candidate's employment history are explored and satisfactorily explained before appointment.
• All new staff receive Level 1 safeguarding induction, including this policy, the Staff Code of Conduct, and how to raise a concern, before, or as soon as possible after, they begin working with students.
• A single central record of recruitment checks is maintained by the school's HR function and the DSL, and is available for inspection by SPEA.

Online Safety

Online safety is treated as a core part of safeguarding, not a separate subject. Concerns about a student's online activity, exposure to harmful content, cyberbullying, or contact from an unknown adult are raised with the DSL in exactly the same way as any other safeguarding concern, using the procedure in Section 6.

The school's approach to safe and responsible use of technology, filtering and monitoring arrangements, and the curriculum for teaching students about online safety is set out in full in the Digital Citizenship Policy, which should be read alongside this policy.

Off-Site Activities, Trips and Transport

• This policy applies in full to all off-site activities, including field trips, sports fixtures, and the international trip, as well as to the school bus service.
• A named member of staff with Level 2 safeguarding training accompanies every off-site trip, and has a means of contacting a deputy DSL at all times.
• Risk assessments for trips and transport, including supervision ratios, are completed and approved in advance in line with the Health & Safety Policy.
• Bus supervisors and drivers are subject to the same safer recruitment checks as school staff, and receive Level 1 safeguarding training.

Working with External Agencies

PEPS works constructively and promptly with the Ministry of Education's Child Protection Unit, the Sharjah Child Protection Centre, the Ministry of Interior's Child Protection Centre, the Police, and other relevant statutory and support agencies, in the best interests of the child. The DSL is the school's primary point of contact for these agencies, and ensures that requests for information or attendance at meetings are responded to promptly.

Confidentiality, Record-Keeping and Data Protection

• All safeguarding records are stored securely, separately from a student's general school file, with access restricted to the DSL, deputy DSLs, and the Principal.
• Records are factual, dated, and distinguish clearly between what was observed, what was said (in the words used), and any opinion or professional judgement.
• Safeguarding records are retained in line with UAE data protection requirements and are transferred securely to a student's next school if they leave PEPS, where doing so is in the child's best interests.
• Personal data relating to a safeguarding concern is shared with external agencies only as necessary to protect the child, and never disclosed to unauthorised third parties.

Monitoring and Review

The DSL reports at least annually to the Principal and the Governing Body's link governor for safeguarding on the operation of this policy, including (in anonymised form) the number and nature of concerns raised, referrals made, and training completed at each level.

This policy is reviewed at least annually by the DSL, in consultation with the Principal and Governing Body, and is approved by the Principal on behalf of the Governing Body. It is also reviewed without delay if there is a change in UAE or Sharjah legislation or regulatory guidance, or where a serious incident or case review indicates a need for change.

Links to Other Policies

• Behaviour & Discipline Policy — how the school maintains a positive, respectful environment and responds to poor behaviour.
• Anti-Bullying Policy — how bullying, including peer-on-peer abuse and cyberbullying, is prevented and addressed.
• Digital Citizenship Policy — online safety, filtering and monitoring, and safe use of technology.
• Health & Safety Policy — supervision, risk assessment, and the safety of the physical environment.
• Inclusion Policy — additional support for Students of Determination and English Language Learners, including where a safeguarding concern intersects with a student's additional needs.
• Whole-School Wellbeing Policy — the pastoral and emotional support available to students and staff.
• Candidate Absence Policy — identifying and following up unexplained student absence.

Glossary of Terms

Legislative and Regulatory Framework References

Note: legislative references should be periodically verified against the Ministry of Education and SPEA's current published guidance, as regulatory documents are updated from time to time.

Recording a Concern Form

To be completed by any member of staff who has a safeguarding concern about a student, and passed to the Designated Safeguarding Lead or a deputy on the same day.

What Was Observed, Said, or Reported (Use the Child's Own Words Where Possible)

Any Immediate Action Taken

Three-Tier Training Framework — Summary

Key Contacts

Internal

External

External contact numbers should be verified periodically against official Ministry of Interior, Ministry of Education and SPEA sources, as they may be updated from time to time.