Safeguarding Policy

Statement of Intent

The Franconian International School is committed to building and maintaining an environment that proactively safeguards our students, promoting their personal growth, wellbeing, and care.

This Policy intends to establish a holistic, comprehensive approach to safeguarding, embracing the United Nations Convention on the Rights of the Child. It is written in accordance with the recommendations of the International Task Force on Child Protection, and furthermore in alignment with the Code of Ethics of the Council of International Schools (CIS), and with CIS International Accreditation Standards (notably standards A4, B6, E2, E3, and F2).


The FIS Safeguarding Policy sets forth the steps our employees, volunteers, visitors, and externally contracted staff, coaches and occasional workers are required to take in order to safeguard and promote the welfare of students, and to respond promptly and effectively, should abuse or endangerment be observed, suspected, or disclosed. It also outlines the communication and collaboration maintained with parents as regards safeguarding matters.


The Policy must be followed by all employees, volunteers, visitors, and externally contracted staff and coaches and occasional workers. Externally contracted staff currently include the school bus drivers and the cleaning staff.  Sections of the Policy refer to the communication and education offered to parents around child protection themes, as well as to expectations upon students for community safety.

The primary audience of the Policy are the above named, who must be familiar with its purpose and requirements. As such, familiarization with the Policy forms a key part of the induction of new employees.  It is the responsibility of the school to put in place a protocol to notify visitors and occasional workers of the key points and implications of this Policy. The Policy will also be an important source of information and guidance for parents and students.

There are no school-related situations where the Policy does not apply.

Actions advised or required by a legally authorized higher organization will supersede the contents of this Policy.

There are no conditions or restrictions to the Policy;
There are no exclusions or special situations to the Policy.

Related Policies, Procedures, Forms, Guidelines, and Other Sources

See Appendix 2.


The Policy was largely developed during the school year 2019-2020, using the existing policy as a basis but drawing widely on current and evolving best practices. After further review, the Policy was finalized in Semester 1 of the school year 2020-21 by the Safeguarding Team and Head of Academic Affairs. The policy was last reviewed and updated in January 2023.

Publication Information

The Policy is for both internal and external publication.

Policy approved date: May 16, 2022
Policy effective date: June 15, 2022
Policy supersedes: Child Protection Policy (February 2021)
Policy last reviewed and updated: January 24, 2023
Next policy review date: February 1, 2024 (reviewed/updated as appropriate and as needed, and at least annually)

Policy Statement

1. Roles and Responsibilities

1.1 FIS Board of Directors

  1. Acts as the legal representative of the school.
  2. Ensures that the appointed Head of School: is fully informed of the responsibilities related to safeguarding, has adequate training and knowledge of the duty to safeguard students as recommended by the International Task Force on Child Protection, and ensures clearly defined responsibilities for safeguarding.
  3. Promotes the commitment of the school to safeguarding students in its communications with the FIS community.
  4. A member of the Board has designated responsibility for safeguarding at the governance level.

1.2 Head of School

  1. Ensures that all employees are informed of and have access to the content of the FIS Safeguarding Policy.
  2. Supports all employees in fulfilling their duties under this policy.
  3. Designates appropriate employees to serve on the FIS Safeguarding Team and makes provisions for their ongoing training and professional development.
  4. Supported by the Safeguarding Team, consults with school legal advisors when questions pertaining to obligations under German or international law arise.
  5. Provides opportunities for all employees to receive regular professional learning on safeguarding procedures, as outlined in section 6.5 of this policy.
  6. Confirms with Human Resources that all new employees have completed screening procedures as set out in section 6.6 of this policy.
  7. Ensures that a protocol is in place to inform visitors to the school, and occasional workers, of the school’s commitment to safeguarding, and of the key points and implications of this policy.
  8. Maintains oversight of the school’s crisis management/emergency plans and, with the Safeguarding Team, ensures regular review and revision, and that all employees are informed of and practice these procedures.
  9. Informs potential candidates of the duties contained in the FIS Safeguarding Policy when recruiting, and determines their suitability and commitment to safeguarding students.
  10. Ensures all employees know the names and locations of all members of the Safeguarding Team.
  11. Ensures that the parent community is informed about the FIS’ commitment to safeguarding students.
  12. Stays informed of ongoing safeguarding cases conducted by the Safeguarding Team.
  13. Provides the final approval, or delegates this responsibility to the Safeguarding Team, when police or emergency personnel must be contacted in order to protect the welfare of a student.
  14. Is informed in all cases where an official report is made to Child and Youth Services offices (Jugendamt).

1.3 Safeguarding Team 

1.3.1 Safeguarding Team Rationale 

The FIS Safeguarding Team takes a multidisciplinary approach to safeguarding and to child protection incident response. Each member holds a specific role within the team to assure a thorough, balanced, and shared effort in all matters pertaining to safeguarding our students. The Senior Leadership Team is represented within the team. Experience has shown that a team approach is effective in sound and transparent decision-making in safeguarding situations. The team meets regularly for consultation, development, review, and debriefing of anonymized cases.

1.3.2 General Safeguarding Team Responsibilities

  1. Attend a permanent monthly meeting for safeguarding policy and program development and review.
  2. Serve as a resource for employees around safeguarding-related themes.
  3. Maintain appropriate confidentiality regarding all safeguarding cases.
  4. Ensure that written records of safeguarding referrals and all subsequent actions are kept, and stored securely. Refrain from using electronic forms of communication to share specific details of safeguarding cases.
  5. Maintain regular professional learning and training in safeguarding.
  6. Support Safeguarding Leads in designing and delivering employee training in safeguarding procedures.
  7. Convene immediately in the event of an emergency or urgent safeguarding situation (individual team members, as required).
  8. Preserve objectivity and maintain ethical duty by removing self from participation in a case in the situation that the team member has or has had a social relationship with members of the child’s family (dual relationship/conflict of interest), or if other reasonable concerns regarding the presence or potential of bias apply.

1.3.3 Additional Responsibilities: Safeguarding Leads 

  1. Take lead responsibility in the school for safeguarding and child protection, acting as the main points of contact in all safeguarding concerns.
  2. Where appropriate, consult with other Safeguarding Team members on (anonymized) cases.
  3. Determine together with the Head of School who will serve as the official representatives of the school in particular safeguarding cases.
  4. Annually review, revise, communicate, and monitor the effectiveness of all written safeguarding policy and procedure, in collaboration with the Head of Academic Affairs.
  5. Lead on designing, delivering, and regularly reviewing safeguarding-related professional learning for employees.
  6. Possess appropriate training and experience in safeguarding procedure and local, national and international legal requirements.
  7. Ensure a child’s new school is informed of current or past safeguarding issues upon recommendation of the Safeguarding Team.
  8. Honor the rights of the parents to be informed of matters that affect their child’s welfare, except in those cases where the Safeguarding Team has determined that, after assessing the risk, informing the parent would be detrimental to the wellbeing of the child. Generally, take the lead on communications with parents.

1.3.4 Additional Responsibilities: Head of Primary School and Head of Secondary School 

  1. Support and advise employees on their duties and responsibilities when safeguarding issues arise.
  2. Support Counselors in the enactment of their duties as outlined in this Policy.
  3. Actively monitor students of concern and establish contact with families of students when and as needed.
  4. Actively monitor students’ attendance and establish contact with families of students with excessive absences.

1.3.5 Additional Responsibilities: Head of Wellbeing

  1. Serve as curricular leader of the safeguarding curriculum; ensuring the adoption, implementation, documentation and review of safeguarding curriculum at all levels, in collaboration with the Assistant Head of School Curriculum.
  2. Serve as Chair of general Safeguarding Team meetings, maintaining secure written agendas and minutes.
  3. In collaboration with applicable colleagues, develop, regularly review and revise, and support in the training for and delivery of safeguarding curriculum.

1.3.6 Additional Responsibilities: School Counselors

  1. Maintain case notes on a regular basis of all students on their caseload.
  2. Ensure appropriate disclosure to all students and parents seeking counseling services regarding the limits of confidentiality and their duty to inform.
  3. Know the school’s crisis management/emergency plans.
  4. Stay current on risk assessment techniques and procedures.
  5. Establish and maintain professional networks with other counselors, including local counselors; participate in the AGIS Counselor Working Group: and support agreements for shared services when needed.
  6. Utilize external professionals (Insofern Erfahrene Fachkraft) for anonymous case consultation.
  7. Inform Heads of Section when safeguarding issues arise during the course of their work.
  8. Advise the Safeguarding Team on current practice, International School Counselor Association standards, overall child/adolescent development and the age-appropriateness of possible interventions considered by the team in response to a referral.
  9. Support the Head of Wellbeing in the development and review of the safeguarding curriculum.
  10. Deliver the established safeguarding curriculum and/or support teachers in the implementation and delivery of the safeguarding curriculum.

1.3.7 Additional Responsibilities: External Support Liaison

  1. Establish meaningful and effective relationships with local authorities and external agencies that are able to provide appropriate support and advice on matters related to child protection.
  2. Communicate when necessary with Jugendamt (either the respective social worker, or a member of staff with respective qualifications and experience) regarding the issue, with the matter discussed with them in an anonymized form. Communicate with the police and other external agencies as deemed appropriate by the Safeguarding Team.
  3. Keep up-to-date with training regarding German law, policy, procedure.
  4. Must be able to communicate in the German language.

1.4 All Employees

  1. Are fully informed of and understand the safeguarding procedures as outlined in this policy.
  2. Are aware of and respond to the social and emotional needs of students in their care and are committed to safeguarding their wellbeing at all times.
  3. Are informed of and understand the guidelines for handling student disclosure.
  4. Are obliged to complete a confidential written referral to the Head of Section or Counselor when issues of safeguarding arise or potential signs/symptoms of abuse or neglect are made evident.
  5. Attend Safeguarding Team meetings when requested.
  6. Deliver the established safeguarding curriculum where appropriate and with the support of the section Counselor.
  7. Attend all relevant training sessions provided by the school on safeguarding policies and procedures.
  8. Refrain from making reports to parents or external agencies in safeguarding matters – instead they defer to the Safeguarding Leads and the Head of School.
  9. Adhere to Protective Practices (Section 2)
  10. Understand that any violence or abuse (either physical, verbal, or online) against students may, upon review of the individual case, lead to proportionate consequences.
  11. Are subject to the safeguarding measures put in place through the school’s recruitment practices and employment contracts.
  12. Must provide an up-to-date police check at the point of employment and every three years from that whilst employed.

1.5 Externally Contracted Staff, Volunteers, Coaches, External Instructors, External After School Activity Facilitators

  1. Upon commencement of their association with the school, are informed of the school’s commitment to safeguarding and child protection.
  2. Upon commencement of their association with the school, are fully informed of and understand the safeguarding procedures as outlined in this document.
  3. Attend the first available training session provided by the school on safeguarding policy and procedures, and thereafter on a minimum of an annual basis.
  4. Adhere to Protective Practices (Section 2).
  5. Must provide an up-to-date police check at the point of employment and every three years from that whilst employed (including interns under the age of 18).
  6. Understand that any violence or abuse (either physical, verbal, or online) against students may, upon review of the individual case, lead to proportionate consequences.

1.6 Visitors and Occasional Workers

  1. Are required to sign in at the reception upon arrival, and read and adhere to the safeguarding information presented to them at the Reception..
  2. Are informed of the school’s commitment to safeguarding and child protection.
  3. Wear a visitor badge, keeping it visible at all times.
  4. Adhere to Protective Practices (Section 2).
  5. Are not left unsupervised with students.
  6. Understand that any violence or abuse (either physical, verbal, or online) against students may, upon review of the individual case, lead to proportionate consequences.

1.7 Students

  1. Share responsibility for the safety and wellbeing of their peers.
  2. Do not use physical or verbal violence. Examples of verbal violence include remarks that discriminate against, disrespect, or otherwise negatively affect others.
  3. Understand that any violence or abuse (either physical, verbal, or online) against fellow students may, upon review of the individual case, lead to proportionate consequences. Report safeguarding, health and safety, or security concerns, whether witnessed or experienced, to an adult at school.

The Healthy Relationships curriculum will include reinforcement of the above.

1.8 Parents and carers

  1. Understand the safeguarding procedures as outlined in this policy.
  2. Provide the school with up-to-date contact information, keeping such information current, in case of emergency.
  3. Inform the school of any particular needs their child may have, or any circumstances at home that might affect their child’s performance at school.
  4. Share safeguarding, health and safety, or security concerns with the Head of School or a section Counselor.

2. Protective Practices

The following is a summary of the practices that will help to safeguard both students and the adults responsible for their care:

  1. Treat everyone with dignity and respect in line with the school’s guiding statements.
  2. Treat all students equally – do not show favoritism or develop friendships.
  3. Remember that you have been placed in a position of trust – do not abuse this.
  4. Remember that someone may misinterpret your actions.
  5. Respect students’ right to personal privacy.
  6. Act within appropriate boundaries even in difficult circumstances.
  7. Encourage an open and transparent culture.
  8. Create an environment where students feel safe to voice their concerns.
  9. Recognize that caution is required even in sensitive moments of coaching and counseling, such as when dealing with bullying, bereavement or abuse.

In order to ensure this, the school and its employees must:

  1. Report all allegations, suspicions and concerns immediately (before the end of the school day).
  2. Plan activities that involve more than one other person being present, or at least are within sight or hearing of others.
  3. Avoid unacceptable situations within a relationship of trust; for example a friendship, romance, or sexual relationship with a student who is over the age of consent.
  4. Provide access to a safe space, such as the school counseling office, for students to talk about any concerns they may have.
  5. Inform a colleague or leave the door ajar when working with or otherwise supporting individual students.
  6. Report any situation where you may have unintentionally put yourself in a compromising position.
  7. Follow the structures set in place within this Policy, as well as in related school policies.

With acknowledgment to the UK Scout Association’s Young People First, and Berlin Brandenburg International School.

3. Identification, Response, and Reporting

3.1 Identification of Child Safeguarding Concerns

How may mistreatment be revealed?
Signs and symptoms of abuse, harm, or neglect in general can vary greatly; some abused children do not display any symptoms as listed below, and behavior that is out of character is not in itself an indication of mistreatment. Nonetheless, mistreatment may be indicated through:

  1. Observations of signs and symptoms, such as:
  • unusual behavior
  • unexplained injuries
  • emotional withdrawal – showing a lack of trust in adults and/or peers
  • eating problems
  • delayed development
  • timidity/nervousness
  • mood swings or aggression
  • deterioration in academic performance or under-achievement
  • tiredness
  • continuous lack of physical hygiene
  • delay or refusal to seek healthcare/mental health services
  • fear of returning home or parents being contacted
  • chronic physical ailments with no reasonable source
  1. Allegations or reports of mistreatment made by another person; perhaps a concerned student, colleague, or parent.
  2. Disclosure made by the student.

3.2 Guidance for what to do when responding to a disclosure 

If a student discloses abuse or harm, limit the conversation to 1) asking open-ended, non-leading questions to facilitate disclosure; 2) determine the wellbeing of the student, and 3) provide support.

Questioning must be limited to critical information in order to:

  • Understand the basic facts
  • Determine the immediate safety of the child
  • Determine if the child/adolescent needs immediate psychological or medical attention

When talking with a student who discloses abuse, DO: 

  • Remain calm, supportive, and reassuring.
  • Make sure that the setting is appropriate.
  • Believe the child/adolescent and validate their feelings.
  • Listen openly and allow the child/adolescent to speak freely.
  • Be aware of your non-verbal messages and facial expressions.
  • Reassure the child/adolescent that they are not to blame for the situation.
  • Reassure the child/adolescent that they did the right thing by telling.
  • Let the child/adolescent know what you need to do and why, explaining that information will only be shared with people who need to know.
  • Allow the child/adolescent control where feasible: give them choice where possible.
  • Write up careful notes afterwards of what was said, using actual words wherever possible.
  • Tell the Section Head or Counselor, and log an incident report via CPOMS before leaving school. If the situation is urgent, first speak with a Section Head/Safeguarding Lead or Counselor. If you are uncertain about how to log via CPOMS, a Section Head/Safeguarding Lead or Counselor can assist.

When talking with a student who discloses abuse, DO NOT: 

  • Try to investigate or question the child/adolescent, except to clarify what you have heard. Do not ask leading or unnecessary questions or try to gather details about what the child/adolescent is disclosing.
  • Display shock, anger, or disapproval of the abuser or the situation.
  • Make assumptions.
  • Criticize, place blame on, or judge any persons or the situation.
  • Suggest that the child/adolescent may be to blame in any way for what happened.
  • Make promises you cannot keep.
  • Agree to keep information secret/confidential.
  • Delay emergency action to protect a child/adolescent.
  • Express disbelief in what the child/adolescent is saying.
  • Discuss with your colleagues or anyone outside of the Safeguarding Team.


  • the student does not want to go home, this must be considered an emergency. Contact a Head of Section, Counselor, Head of School, or Deputy Head of School immediately.
  • you believe the student will go home, back to class, or elsewhere, to continued abuse, contact a Head of Section, Counselor, Head of School or Deputy Head of School immediately.
  • you feel distressed, seek support from a member of the Safeguarding Team. Do not discuss the disclosure with other colleagues or openly around the school.

4. Reporting and Responding to Safeguarding Concerns

4.1.1 Reporting concerns about students

Step 1

In the instance that abuse, harm, neglect, or endangerment is observed, suspected, or disclosed, report concerns to a Safeguarding Lead or a Counselor before leaving school, and record the concern via CPOMS as soon as possible after the incident.

When reporting and recording a safeguarding concern, please share:

  • As full account as possible of what you saw, heard, etc – factual or based on fact (professional opinion can be given, but if so, should be supported by setting out the facts and observations upon which the opinions are based)
  • If it was a student disclosure, report what the student said, using their own words as much as possible
  • Time and place of disclosure
  • The demeanor of the student
  • Any information provided to the student about what would happen next

Wellbeing concerns

Wellbeing and mental-health-related concerns are not always safeguarding concerns; however, they should also be reported to the Counselor via CPOMS. Indicators may include lack of energy, focus, interest, or interpersonal connection; persistent ups or downs in mood; continuous lack of personal hygiene; deterioration in academic work or achievement; patterns of toilet breaks or lateness; or anxious feelings or behaviors.

Logging onto CPOMS

If logging in from a FIS staff computer, use the CPOMS icon in the “Managed bookmarks” folder on the upper toolbar of the Chrome browser. If logging in from elsewhere, use If you are uncertain about how to log via CPOMS, a Section Head/Safeguarding Lead or Counselor can assist.

Step 2

In the case of safeguarding concerns, the Safeguarding Lead or Head of School will convene a school-based response team, and take initial steps to gather information regarding the reported incident, following the Safeguarding Reporting and Response Flowchart. The response team will include as deemed necessary: Safeguarding Leads, counselors, teachers, school nurse, and/or other individuals.

Follow-up actions will be conducted in a manner that ensures that information is documented factually and that strict confidentiality is maintained. External authorities may be invited to participate in the collection and evaluation of evidence and in determining further steps.

Step 3

Course of action – this could include

  • Providing support for child and family within the school
  • Outside referral for support and/or counseling
  • Seeking advice from external authorities/agencies
  • Reporting to external authorities
  • If a school employee or service provider is found to endanger the protection and/or welfare of students, the response may include (involuntary) leave of absence, termination of contract, referral to law enforcement, or other disciplinary measures deemed appropriate.
  • If a student is found to endanger the protection and/or welfare of students, the response may include disciplinary measures deemed appropriate and/or referral to law enforcement.
  • Following up with staff member who reported concern.


4.1.2 Safeguarding Reporting and Response Flowchart

4.1.3 Notifying parents/carers

The default option is for the school to discuss any safeguarding concern about a student with their parents. This must be handled sensitively and the Head of School or Safeguarding Lead will make a determination in line with German law as to whether and when involving the parent(s) is in the best interest of the student. If the school believes that notifying the parents could increase the risk to the student or exacerbate the problem, advice may first be sought from an “insoweit erfahrene Fachkraft” or Child and Youth Services.

4.2 Concerns regarding adults in school 

It is FIS employee’s professional obligation to take action if concerned about a colleague’s adherence to the Safeguarding Policy. Likewise, any concern about an adult’s suitability to work with students, no matter how small, should be reported. Potential actions include:

  • Have an open conversation with the colleague regarding your concern. Encourage the colleague to tell the Head of Section/Deputy Head of School/Head of School and to ask them to let you know that the conversation took place, so that the reporting loop is closed.
  • If unsure how to respond, or which action to take, seek the advice of a member of the safeguarding team.
  • Report the concern directly to a Safeguarding Lead/Counselor/Head of School as you would with any other safeguarding concern.. They will then take action as appropriate.

Should student abuse, harm, neglect, or endangerment be observed or suspected of the Head of School, the report should be made directly to the FIS Chair of the Board (mailto:).

In the event of an allegation against an adult in the school, the Head of School and the Safeguarding Leads follow the procedure outlined in the International Task Force on Child Protection Protocol for International Schools in the first case.

4.3 Concerns regarding Safeguarding Team practice

Should a FIS employee have a concern as to whether a member of the Safeguarding Team has fulfilled their duty appropriately, they should raise this directly with the employer.

5. Confidentiality and Professional Duty-of-Care

Approaches to providing students with the best possible support require a well-rounded picture, which can only occur when Heads of Section and Counselors can build an overview to students’ unique situations and needs. As such, it is critical that confidentiality guidelines are followed, as considerations around extenuating circumstances, privacy, legality, ethics, and duty of care can arise.

No individual teacher should be in a position of being the sole bearer of sensitive student information and may not promise confidentiality to a student in any situation.

If a student:

  • discloses sensitive, personal information about themselves,
  • expresses concern for their wellbeing or the wellbeing of others, or
  • indicates potential harm to self or others in any form,

The school employee should clearly explain to the student that their responsibility is to share this information with either the Head of Section or Counselor in order to protect and best support the student. Above all, the emotional wellbeing and mental health of the student must be supported and harm minimized. Explain to the student the rationale for sharing this information, creating a safe space to continue the conversation together with the Head of Section or Counselor, and letting the student know that the situation will be handled with discretion and above all with the student’s needs at the fore.


In some cases certain information will stay confidential to the Head of School, Deputy Head of School, Head of Section, and/or Counselor, who act in accordance with ethical and legal guidelines for confidentiality. On a case-by-case basis, certain information may only be shared with school employees on a need-to-know basis, when the information is agreed upon by the student and/or parents, and/or deemed necessary to optimize the student’s safety and learning. In this way, sensitive information is shared only to recipients who are in a position to benefit the student if they have the shared information. Colleagues must remember that not all information can be shared freely, and should refrain from acting upon information shared informally, trusting that the actions of the Safeguarding Team are in accordance with the abovementioned ethical and legal guidelines for confidentiality.

6. Related School Policy and Procedures that Safeguard Students

6.1 Attendance

Absence from school, or lateness, may be a consideration in identifying child protection concerns. Similarly, partial unexplained absence during the school day will be a cause for concern.

The school has procedures for the monitoring of absence, and prompt follow up.

The FIS complies with German law regarding attendance, as set out in:

Bayerisches Gesetz über das Erziehungs- und Unterrichtswesen (BayEUG) in der Fassung der Bekanntmachung vom 31. Mai 2000 (GVBl. S. 414, 632) BayRS 2230-1-1-K

Abschnitt VII Schülerinnen und Schüler – Artikel 56 Rechte und Pflichten

6.2 Admissions

At the time of admission, the following documentation is secured:

  • Legal documents that refer to parental custody.
  • Parental agreement per signature of the Home-School Partnership, and all that this entails, including legal rights of children to a safe upbringing.

6.3 Safeguarding Considerations on Overnight Field Trips, Sports Tournaments and Homestays

Students may be more vulnerable in off-campus situations for a variety of reasons. Because rules and routines can differ, interactions with new adults occur, and relationships and expectations can be easily blurred, safeguarding is therefore embedded in the Field Trip and Travel Policy.

6.4 Student Education and Behavior

The Head of Wellbeing and Assistant Head of School/Curriculum, liaising with Counselors, Head of PHE, and other relevant colleagues develop, review, revise, and support Healthy Relationship education through Homeroom, Advisory, and PHE.

Curricular themes will include:

  • Using safety language
  • Safe and unsafe touch
  • Ways to keep ourselves safe
  • Advocating for others and self
  • Digital citizenship / online safety

6.5 Online Safety and Remote Learning

Students may be vulnerable when online, and in a remote learning environment, for a variety of reasons. Online safety forms an integral part of Student Education (see 6.4). It is embedded within the Remote Learning Protocol.

The Remote Learning Protocol outlines safeguarding practices to be undertaken by staff, and includes online etiquette for students and staff, and especially guidance regarding one-on-one contact with students in a remote environment.

6.6 Employee Education and Training

The FIS Safeguarding Team, in collaboration with the SLT, leads on developing and facilitating all safeguarding and child protection-related professional learning for employees. Colleagues who are hired mid-year complete a relevant training package to cover missed content.

6.6.1 Annual training for all FIS employees:

  • Reporting procedures and policies at the FIS
  • Signs and symptoms of abuse and neglect
  • How to handle student disclosures
  • Confidentiality requirements
  • Protective practices

6.6.2 Regular training for all FIS employees

  • Healthy Relationships curricular overview and understanding/use of common language
  • Cultural issues relevant to child protection
  • Suicidal ideation and Non-Suicidal Self Injury (NSSI) response
  • modus operandi of child sex offenders and Lessons from Serious Case Reviews

6.6.3 Regular training for Homeroom Teachers, Advisors, and other employees who deliver Healthy Relationships curriculum (to commence school year 2022-2023)

  • Establishing a safe, compassionate, open community
  • Maintaining fidelity of curricular content across classes and grade levels
  • Regular practice, debriefing, and consultation in handling various situations that may arise while teaching curriculum
  • Handling difficult questions and using protective interrupting
  • The one-step removed discussion strategy

6.6.4 Training for externally contracted staff, volunteers, coaches, external instructors, external after school activity facilitators

  1. Reporting procedures and policies at the FIS
  2. Signs and symptoms of abuse and neglect
  3. How to handle student disclosures
  4. Confidentiality requirements
  5. Protective practices

6.6.5 Regular training for core Safeguarding Team members

All team members attend relevant workshops that are endorsed by the International Task Force on Child Protection at least every two years (as recommended by CIS and ITFCP). Additionally, team members keep their knowledge and skills updated at regular intervals (for example via regular reading or webinars on themes around safeguarding, or discussing with Safeguarding Team members at other schools) to keep up with any developments relevant to their role.

6.6.6 Local German training for External Support Liaison

The member/s of staff responsible for External Support Liaison will attend relevant workshops, ensuring compliance with local and national law, expectations, and procedures.

6.7 Safer Recruiting Practices

The FIS is committed to safer recruitment practices, and value these as critical to keeping students safe. Aligned with the recommendations of the International Taskforce on Child Protection (ITCP), we hold ourselves to a high standard of effective recruiting practices with specific attention to child protection.

Specific practices undertaken at the FIS during the recruitment process include:

  • The employer and HR receives safer recruitment training
  • Job adverts and the school website explicitly state the school’s commitment to child protection
  • Every job description has a reference to safeguarding responsibilities
  • In case of educational positions, candidates are requested to provide five confidential references at least three of which at the Assistant Principal level or above, three of whom should be from the current or most recent post
  • Learning assistants and candidates for non educational positions are requested to provide three confidential references, one of which should be from the current or most recent post
  • Interviews include relevant safeguarding questions
  • At least two supervisory references are contacted directly via professional phone numbers or email addresses; one of which must be via phone or video conference
  • Relevant safeguarding questions are asked during the reference checking
  • Employer provides HR with outcomes of the reference check in writing
  • Candidates complete a personnel questionnaire consisting of personal and professional information
  • Candidates make a declaration of full disclosure and acknowledge that any agreement of employment or subsequent employment may be terminated immediately for misrepresentation
  • The school conducts an internet search of the candidate
  • Candidates provide any police background checks from the past two years which may already be in their possession
  • Employees have to provide police background checks from all the countries they have resided in for more than six months, if possible

6.8 Parent Education and Communication

Upon enrolling their child at the FIS, parents are informed via the Home-School Partnership documentation of the German Civil Code Book 8, Article 1631.2, which states that “children have a right to non-violent upbringing. Physical punishment, psychological injuries and other degrading measures are inadmissible.” Parents are required to sign and return documentation to demonstrate that they have read and understood this.

Regular parental communication and workshop opportunities take place in areas including:

  • The school’s legal duty to safeguard our students, and accompanying information on policy and practice
  • How and where to share safeguarding concerns, as well as on how the school responds to concerns and allegations when raised
  • Digital citizenship, online safety, and how parents can support their children in these areas
  • Positive behavioral support at school and at home

6.9 Professional Networks

School Leadership and the Safeguarding Team establish and maintain professional networks with:

  • Child welfare agencies in the Erlangen region
  • Erlangen and Bavarian school authorities
  • AGIS Administrators and Counselors
  • Local doctors, psychologists, and other medical professionals
  • Erlangen police

7. Definitions

Some of the below terms appear within the Policy, others provide definitions and background to the terms used in employee training.

Child Protection

Activity that is undertaken to protect specific children and adolescents who are suffering or may potentially suffer from abuse, harm, or neglect.


Measures to protect the health and wellbeing of children and adolescents to live free from abuse, harm, and neglect.

Danger to others

Any present, recent, or imminent situation where a child is thinking about or engaging in actions which can cause substantial harm to others (for example, sharing/offering drugs, violent actions, or promoting violence in others).

Danger to self

Any present, recent, or imminent situation where a child is thinking about or engaging in actions which can cause them serious harm (for example, substance abuse, suicide, self-harm, actions which risk criminal prosecution).

Emotional abuse

A pattern of verbal aggression, insults, threats, put-downs, lies, denial of affection, or age-inappropriate expectations that cause emotional distress, lack of a sense of safety, lack of a sense of self-worth, chronic fright, cognitive impairment, or induce social isolation.


Failure of a caretaker to provide for a child’s basic needs; neglect can be physical, medical, educational, and/or emotional.

Peer-on-peer abuse 

Any form of physical, sexual, emotional and financial abuse, and coercive control exercised between children, and within children’s relationships (both intimate and non-intimate), friendships, and wider peer associations.

Physical abuse

Intentional infliction of physical injury to a child, or failing to take reasonable steps to prevent physical injury. Adults who inflict physical abuse as a form of discipline or as consequences of misbehavior are in violation of German law.

Psychological abuse

See Emotional abuse.


Nonsuicidal self-injury, often simply called self-injury, is the act of deliberately harming one’s own body, such as cutting or burning oneself. It is typically not meant as a suicide attempt. Rather, this type of self-injury is a harmful way to cope with emotional pain, intense anger and frustration. While self-injury may bring a momentary sense of calm and a release of tension, it is usually followed by guilt and shame and the return of painful emotions. Although life-threatening injuries are usually not intended, with self-injury comes the possibility of more serious and even fatal self-aggressive actions.

Sexual abuse

Forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (i.e., rape) or non-penetrative acts. They may include non-contact activities, such as involving children in the production or viewing of pornographic material or encouraging children to behave in sexually inappropriate ways. In addition to the criminal acts defined by German criminal law (see below), this Policy applies when a school employee makes or attempts to initiate contact of a sexual nature with a student regardless of whether that student is of full legal age or not and to sexual contact between students when one of those involved does not understand, cannot give consent to, and/or which causes emotional and/or physical harm.

In accordance with German law, this policy also applies to sexual contact between students under 14 years of age, sexual contact between a student under 21 years of age with a student under 14 years of age, or non-consensual sexual activity/intercourse with a student 14 years of age or above.

Suicidal ideation

Thoughts, ideas, or ruminations about the possibility of ending one’s life, ranging from thinking that one would be better off dead to formulation of elaborate plans.


Appendix 1 Safeguarding Team Response to Safeguarding Concerns: Managing Allegations


  1. Confidentiality. The allegation response process involves only those who need to know in order to best support student needs at the time. Those involved will often include the original reporter of the allegation, employees or students identified as having significant knowledge of or involvement in the concern, the student’s homeroom teacher or advisor and parents/carers, applicable members of the Safeguarding Team, and Head of School.
  2. Preserving Objectivity. It is the ethical duty of Safeguarding Team members to remove themselves from participation in a case if they have or have had a social relationship with members of the child’s family (dual relationship). Other reasonable concerns regarding the presence or potential of bias also apply.
  3. Priority. Safeguarding cases take immediate priority over other school responsibilities.

Record Keeping

1. Data and Documentation. The school follows the Bavarian Schulordnung regulations, as set out here: BaySchO: Teil 5 Schülerunterlagen (vergleiche Art. 85 Abs. 1a BayEUG) (§§ 37–42) – Bürgerservice (

The most relevant sections are Articles 37 – 41:

Article 37 Defines data and documentation.
Article 38 Defines usage of data and documentation (and important points regarding confidential data and documentation)
Article 39 Defines which data and documentation can be or need to be processed to which appropriate constituents
Article 40 Defines compulsory periods of record keeping for student data and documentation listed in section 37 (37 1.a – d: 50 years, 37 1.e – f 1 year, 37 2a-b 2 years)
Article 41 Defines constituents who have the right to access student data and documentation

Importantly, Article 37 stipulates that the respective member of staff remains bound to confidentiality in regard to student data and documentation, and that the duty to maintain confidentiality, as named in Criminal Code section 203 part 1, remains unaffected.

2. Allegation Response Notes and Summaries. Notes must be maintained, including relevant demographic facts; contacts with school employees, parents or guardians; external therapists and/or external agencies; copies of written correspondence, external diagnostic information; and permissions obtained related to the presenting issue. Allegation response notes must focus on the presenting issue, progress, next steps, and conclusions. The Safeguarding Team member leading the allegation response is responsible for documenting the case process and conclusion.

3. Storage. Safeguarding Incident Report Forms, Allegation Response Notes and Summaries, and all related documentation are stored in the child’s counseling file. Copies of the Safeguarding Incident Response Form and Allegation Response Summaries are kept in the Head of Section’s files.

4. Archived Documents. All counseling files are archived in the Counselor’s office. Files are securely stored in the counseling archives for two years past the graduation date (or expected graduation, for students who transferred), after which files are destroyed.

Appendix 2: related policies, procedures, forms, guidelines, and other sources

This policy has been developed in alignment both with the school’s Guiding Statements, and with the guidance on best practice contained within the following CIS/IB/NEASC/ISCA-approved documents:

Legal Guidelines

The procedures for safeguarding at the Franconian International School are established in accordance with the following local, national and international legal guidelines and requirements (in the case of German law, the German-language version is the legal reference):

German Civil Code Book 8 (Sozialgesetzbuch VIII – Kinder- und Jugendhilfegesetz) 

The most significant components for this Policy being (translated):

  • Children have a right to non-violent upbringing. Physical punishment, psychological injuries and other degrading measures are inadmissible (Section 8, Article 1631.2)
  • Children and young people have the right to turn to Child and Youth Services in all matters to do with upbringing and development. They have the entitlement to counseling without the knowledge of the legal guardian if counseling is necessary because of an emergency conflict situation and as long as the objective of the counseling would be defeated by informing the legal guardian (Section 8, Article 8.2, 8.3)
  • Identifying data of the child shall be anonymized or pseudonymized before transmission to a third specialist who does not belong to the Child and Youth Services, as far as the fulfillment of the risk assessment permits (Section 64, 2a)
  • Should the Child and Youth Services be informed of serious grounds for concern, in terms of endangerment to the welfare of a child or young person, a risk assessment will be undertaken, in collaboration with more than one specialist personnel. In this case, the legal guardians as well as the child or young person are to be included, provided that the safeguarding of the child or young person would not thereby be compromised (Section 8a, Article 1)
  • In agreements with institutions providing services under this law, it shall be ensured that 1) the safeguarding mandate is observed in the case where a person is aware of the danger to a child or a young person supervised by them, 2) a risk assessment is conducted with an experienced expert in an advisory capacity, and 3) the child or young people are included in the risk assessment, as long as the effective safeguarding of the child or adolescent is not called into question (Section 8a, Article 4)

German Constitution (Deutsches Grundgesetz) 

  • The care and upbringing of children is the natural right of parents and a duty primarily incumbent upon them. The state shall watch over them in the performance of this duty (Article 6.2)

UN Convention on the Rights of the Child (in particular):

  • States Parties undertake to ensure the child such protection and care as is necessary for his or her wellbeing, taking into account the rights and duties of his or her parents, legal guardians, or other individuals legally responsible for him or her, and, to this end, shall take all appropriate legislative and administrative measures (Article 3.2)
  • States Parties shall ensure that the institutions, services and facilities responsible for the care or safeguarding of children shall conform with the standards established by competent authorities, particularly in the areas of safety, health, in the number and suitability of their staff, as well as competent supervision (Article 3.3)
  • States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child (Article 19)
  • States Parties recognize the right of every child to a standard of living adequate for the child’s physical, mental, spiritual, moral and social development (Article 27.1)
  • States Parties agree that the education of the child shall be directed to the development of the child’s personality, talents and mental and physical abilities to their fullest potential, and the development of respect for the child’s parents, his or her own cultural identity, language and values, for the national values of the country in which the child is living, the country from which he or she may originate, and for civilizations different from his or her own (Article 29.1.a,c)

Related Policies

This Policy also relates to the following FIS Policies and Procedures, which are referenced in the Policy Statement as appropriate:

  • FIS School Handbook, including guidance on behavior, attendance and online safety.
  • Admissions Policy
  • Home-School Partnership
  • Field Trip Policy
  • Remote Learning Protocol November 2020


The following further resources were referenced in the completion of this document:

Safeguarding Policy documents from the International School of Hamburg (a significant proportion of this Policy is taken or adapted from the policies of ISH, with their permission, and applied to the context of the FIS), as well as from a number of other schools within the Association of German International Schools (AGIS).

Next Post
Assessment Policy
Previous Post
Student Policy: Smoking, Vaping, Alcohol, Drugs and other Substances