The

British
Council
Child Protection Policy
How we safeguard
the children and young people
we work with

Updated January 2011

Contents
1

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

1.1

WhyweneedarevisedChildProtectionPolicy.......................................................................................... 3

1.3

WhatisaChildProtectionPolicy?............................................................................................................... 3

1.4

Whoisdefinedasachild?........................................................................................................................... 4

1.5

WhoistheaudiencefortheChildProtectionPolicy?................................................................................. 4

1.6

Whatareourresponsibilities? .................................................................................................................... 4

1.7

HowtheChildProtectionPolicyfitswithotherpolicieswithintheBritishCouncil ................................... 4

1.8

PrinciplesunderpinningtheChildProtectionPolicy ................................................................................... 5

Understanding Child Protection Issues...........................................................................................6

2.1

Whatareweprotectingchildrenfrom?...................................................................................................... 6

2.2

Generaldefinitionsofchildabuse............................................................................................................... 6

2.3

Culturalsensitivity ....................................................................................................................................... 7

Child Protection Focal Point.............................................................................................................7

Preventative Actions .........................................................................................................................8

4.1

RecruitmentandEmployment .................................................................................................................... 8

4.2

Training,supervisionandsupport............................................................................................................... 9

4.3

ProfessionalCodeofConduct ................................................................................................................... 10

4.4

Media,communication&information...................................................................................................... 10

Reporting Responding to Allegations & Concerns ...................................................................10

Support and Resources ..................................................................................................................13

Appendix 1 Child Protection Reporting Flowchart............................................................................14

Appendix 2 Creating, Managing & Disposing of CP Records ..........................................................15

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 activity1 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 organisations 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
1

As defined in Schedule 4 part 1 of the Safeguarding Vulnerable Groups Act 2006


& procedures include safer recruitment and screening processes for those working with the
British Council, codes of conduct for staff, guidance on the appropriate use of childrens 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.

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 childs 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 childs 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 childs 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 childs basic physical and / or psychological
needs, likely to result in the serious impairment of the childs 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.

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.
Broad areas of responsibility for the Child Protection Focal Point include:

Supporting Country Directors in implementing the Child Protection Policy

Acting as a first point of contact for staff on all child protection issues
Maintaining list of local specialist child welfare, health and law enforcement contacts
Providing advice and support to staff concerned about a child protection issue and deciding
what action to take
Responsibility for escalating a concern to the Corporate Child Protection Team and/or
notifying senior managers as appropriate
Referring cases to specialist child welfare and/or law enforcement agencies as appropriate
Keeping accurate records that are data protection complaint.

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.
7

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

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

Recruitment and Employment

Safe recruitment and checks that are undertaken as part of the recruitment process are the
organisations 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 are to work directly 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.


For more detailed guidance refer to the British Council Vetting Policy and Safer Recruitment
Guidance2.

4.2

Training, supervision 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 complete the mandatory child protection basic awareness e-learning module3.
2. All staff are informed about the Child Protection Policy, and given the opportunity to discuss
its implications for them with both their line manager and the Child Protection Focal Point
as part of their induction / orientation.
3. In general staff are not allowed to work alone with a child somewhere which is secluded or
where they cannot be observed. It is acceptable for staff to work alone with a child where
there are visibility panels / windows in doors.
4. All activities are supervised by staff. The number of staff will be determined according to
the age and capacity of the children, and should always be sufficient with the necessary
skills and qualifications consistent with the scope of work / role expected.
5. Where the British Council arranges for visits, no child should be left unsupervised with a
visitor to a programme or scheme.
6. No activity or programme is undertaken with children without the express written permission
of their parents / guardians.
7. Where overnight trips are required or staff need to accompany a child for activities, clear
guidance is given in the Accompanying Adults Directive about the expected behaviour of
the staff and any measures that should apply.
8. In the case of overnight trips, in general, no staff should stay alone in a bedroom with a
child unless they are the childs parent/guardian. We appreciate that in some situations
children may not wish to be alone, or it may be more culturally appropriate to share rooms.
If this is the case then the situation must be discussed with the Child Protection Focal Point
before the trip.
9. Any accommodation provided must be in single sex rooms (i.e. boys and girls not sharing
rooms)
10. All staff should sign a Code of Conduct specific to the protection of children (see following
section) before working with any children.
11. 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.
12. Where staff are contracted by other employers, or when working with partners, the British
Council will ask for information on how the organisation works to protect children (such as
their child protection policy).

These documents are currently being finalised please contact the Head of Child Protection for further information in the meantime, if
necessary
3
This is in development, and should be launched in mid 2011


13. Staff will have access to supervision, 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.

4.3

Professional Code of Conduct

Since ideas about child care vary, all staff should be required to sign a code of conduct
regarding the protection of children, the behaviour expected of them and their responsibilities in
relation to the children they come into contact with as a result of their work with the British
Council. Individual country offices should develop this code of conduct to fit their local
operating context.
While the code of conduct will vary from country to country, it should include:

4.4

Agreement to work under the Child Protection Policy as a condition of involvement with the
British Council
Provisions regarding acceptable behaviour in the workplace for example, not to use
physical punishment or chastisement, however acceptable or moderate it may seem, not to
use language intended to belittle or humiliate children and not to abuse children in any way
(including not to engage in any sexual activity with anyone below the legal age of sexual
consent)
To report any concerns they may have about the protection of children, in accordance with
this policy
To 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
Not to pay for sexual services, of any kind, with anyone under the age of 18 years old, even
if the age of sexual consent is under 18 years.

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.

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.
10


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 1 on page 12.
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 childs 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
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 ones official duties. Guidance regarding the
storage of such information is attached in Appendix 2.
11


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
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
12


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.

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.

Reviewed in January 2011

Next review in January 2012

13

Appendix 1 Child Protection Reporting Flowchart

ALLEGATION OR STAFF CONCERN ABOUT A CHILD OR

CHILDRENS WELFARE.
Q: Is it a life threatening situation?

Yes

LIFE THREATENING SITUATION

Take immediate action as required. Discuss situation
with available senior manager and parent/guardian.
Report immediately to relevant authorities (medical,
police or social welfare). Log incident on the child
protection intranet reporting form within 24 hours.

No

REPORT TO CHILD
PROTECTION FOCAL POINT
(CPFP) within 24 hours to
assess and decide what action
to take.
Q: Is there still a concern?

NO CAUSE FOR CONCERN

CPFP logs incident on the child
protection intranet reporting form
within 48 hours.
Q: Was the allegation malicious?

No

No Further
Action

Yes

No

STILL HAS CONCERNS

CPFP reports concern immediately to Regional
Child Protection Manager and informs senior
management in line as appropriate. CPFP to
log incident on the child protection intranet
reporting form within 24 hours.
Q: Is there enough information to take
immediate action?

Yes

No

CHILD PROTECTION INTERNAL ENQUIRY

More information required to decide appropriate
course of action. Regional Child Protection
Manager/Head of Child Protection conduct
enquiry within 3 working days to gather more
facts.
Q: Enquiry findings evidence need for further
action?

CONSULT LINE MANAGER

Line manager in consultation with
Human Resources to support staff who
have been the subject of a malicious
allegation and decide course of action
relating to disciplinary and suspension
issues.

Yes

Yes

IMMEDIATE ACTION NEEDS TO BE TAKEN

Sufficient evidence exists that concern is a breach of conduct, welfare and/or criminal matter.
Q: Does the concern involve a staff member?
Yes
No

Q: Is it a criminal matter?
No

REFERRAL TO SPECIALIST AGENCIES

CPFP referral to specialist agencies [social welfare or law
enforcement] in consultation with parent/guardian where
appropriate.

Yes

CONSULT HUMAN
RESOURCES
For breach of conduct cases
Human Resources informed to
decide course of action.

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.

This is to be done with the advice and support from a

Regional Child Protection Manager and/or the Head of
Child Protection. Liaison with Senior Managers in the line
and specialist agencies as appropriate.
BC involvement concludes here.

INTERNAL CHILD PROTECTION INVESTIGATION PANEL

Internal Investigation Panel will be convened by the Head of Child Protection to coordinate an
organisational response. The composition of the panel depends on the nature of the allegation/concern
but will routinely consist of Head of Audit, Head of Legal and a representative from Human Resources.
Liaison with senior management within the line and external agencies as required.

PARALLEL
EXTERNAL
INVESTIGATION

INVESTIGATION CONCLUDES
Q: Has the allegation or concern involving a staff member been substantiated?

No

UNSUBSTANTIATED
CRIMINAL ACTIVITY
Staff subject of allegation informed of outcome,
reinstated and offered post investigation support
by Human Resources.

Yes

SUBSTANTIATED CRIMINAL ACTIVITY

Staff subject of allegation informed of outcome and
dismissal action taken 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.

14

Appendix 2 Creating, Managing & Disposing of CP 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
o
o
o
o
o
o
o

date and time of incident/disclosure

parties who were involved, including any witnesses to an event
what was said or done and by whom
any action was taken by the organisation to look into the matter
any further action taken
where relevant, the reasons why a decision was taken not to refer those concerns to
a statutory agency
any interpretation/inference drawn from what was observed, said or alleged should
be clearly recorded as such
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
Councils records management helpline RecordsandArchives@britishcouncil.org, or contact the
Corporate Child Protection team.

Relationship with
British Council

Customer/
student

Third party
service
provider not
defined above

Other
beneficiary of
British Council
(i.e.
Scholarship or
grant)

Circumstance

Action

Retention

Example

Child protection
concerns that
British Council
refers on to
authorities such
as the police or
equivalent

Documentation
should be created
to confirm receipt
of referral, and
this should be
maintained by
British Council. A
written record of
the concern,
including
decisions made
should be
maintained by
Country Director
or Child
Protection Focal
Point

This and related

records should
be maintained
for 6 years after
the last contact
with the service
user. Records
should be
destroyed with
approval of the
Head of Child
Protection.

This would
include
concerns about
physical, sexual,
emotional or
negligent
actions involving
a child or
children,
disclosures from
a child about
being abused or
information from
a third party
which might
suggest a child
is being abused;
concerns about
a parent or
another adult
that has contact
15

Child welfare
concerns that
British Council
decide after
consultation, do
not necessitate
a referral to
authorities such
as the police or
equivalent
.

Concerns about
people (paid
and
unpaid) who
work
with children.
This might (but
not necessarily)
result in referral
to authorities
such as the
police or
equivalent.
Employee
of British
Council
Paid
Unpaid
Voluntary
Contractor
Consultant

In such
circumstances A
written record of
the concern or
allegation made
should be
maintained by the
Child Protection
Focal Point.

Destroy the
record one year
after the
child/adult
concerned
ceases to use
the service
unless the child
or adult are
continuing to
use your
organisation.
Records should
be destroyed
with approval of
the Head of
Child Protection
All records
(including
disciplinary
records) should
be retained for 6
years after
employment
ceases.

with British
Council, or a
young person
who has been
abused by
another young
person
This could
include
concerns where
a child has been
bullied, overly
pushy parents
or a very
distressed child
where the
distress is
unrelated to
child abuse

This could
include
allegations,
convictions,
disciplinary
action, and
inappropriate
behaviour
towards
However if any children. For
of the following example where
an employee
apply:
has breached
There were
the code of
concerns about
the behaviour of conduct, a
record of the
an adult who
behaviour, the
was working
action taken and
with children
outcome should
where s/he
be recorded.
behaved in a
way that has
harmed, or may
have harmed, a
child;
The adult
possibly
committed a
criminal offence
against, or
related to, a
child;
The adult
16

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

Criminal
Records Bureau
or other
disclosures
obtained as part
of the
employment
screening
process

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.
The actual
disclosure form
must be
destroyed after
6 months.

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 Councils
records management helpline RecordsandArchives@britishcouncil.org .

17