Banadir Language School

Safeguarding and Child Protection Policy

Banadir Language School

Version 1.0

Date published: TO BE COMPLETED: date the policy goes live on the website

Next review date: TO BE COMPLETED: date 12 months after publication

Owner: the Designated Safeguarding Lead (named in Section 9)

This is the public version of our policy. Any parent, student, teacher or visitor may read it. If you would like it read to you, or explained in Somali, please contact us using the details in Section 9.

1. Purpose

This policy explains how Banadir Language School keeps children safe in online classes.

It exists so that:

every child is safe in every lesson,
every parent knows exactly what happens in a lesson and what is recorded,
every teacher knows the rules and can be held to them,
anyone with a worry knows who to tell, including someone outside the school.

This policy is written in plain words on purpose. It is a set of promises you can test, not a statement of good intentions.

2. Who this policy applies to

This policy applies to:

every teacher, including the founder and headmaster,
every person who helps run the school, paid or unpaid,
every person who can see a class, a class recording, or student records,
every student under the age of 18, and their parent or guardian,
anyone who works on the school's website or systems.

Everyone in this list must read this policy and follow it. Teachers sign a separate one page conduct agreement (see Section 11).

A note on age. For safeguarding purposes, a child is any person under the age of 18. We use 18 for every student, in every country, with no exceptions.

3. What the school believes

A child's safety comes before the timetable, before the lesson, and before the school's reputation.
Safety is built from practices, not promises. A rule that cannot be checked is not a rule.
Children and adults learn in separate classes. They are never taught together.
No adult should ever be alone with a child on a video call.
A parent has the right to know what is recorded, who can see it, and when it is deleted, before their child ever appears on screen.
A parent must be able to raise a concern with someone who is not the founder, and who does not work for the founder.
Saying no to a recording must never cost a child their place, their lesson, or their teacher's attention.
If we get something wrong, we say so, we write it down, and we fix it.

4. How the school keeps children safe

These are the practices we actually follow, in every class, every time.

4.1 Children and adults are taught separately

Children's classes and adult classes are separate classes, with separate class lists and separate class links.
An adult student is never placed in a children's class. A child is never placed in an adult class.
The only adults in a children's class are the teacher and, where a parent chooses to sit in, that child's own parent or guardian.

4.2 Every class is a small group class

We do not teach children one to one on video.
Every children's class has more than one student enrolled and present. This is deliberate. Several students in the room means several witnesses, and it means no child is ever alone on a call with an adult.
If only one child arrives for a children's class, the lesson does not run as a one to one. The teacher waits with the door open. If no second student has joined after 10 minutes, the teacher ends the call and tells the parents' group that the class will be rescheduled.
A parent may sit in on their own child's class at any time, without asking in advance.

4.3 Only known people get into the class

The waiting room is switched on for every class. Nobody enters the class automatically.
The teacher admits each person one at a time, by name, and checks that name against the class list.
An account with a name we do not recognise is not admitted. If a student is using a family member's account, the parent must tell us the account name in advance.
The class link is sent only to enrolled students and their parents. It is never posted in public and never shared with anyone outside the class.
The teacher can see everyone in the class at all times and removes anyone who should not be there.

4.4 We check who the student is, and who the parent is

Before a child is enrolled, we take the child's full name and date of birth, and the full name and contact details of the parent or guardian.
We ask the parent to show proof of the child's age and proof of the parent's own identity, and we record that this check was done. We do this because the law that applies to students living in Somalia requires the identity and the age of both the child and the guardian to be verified.
We take written parental consent for every student under 18, for every country, with no exception. The law that applies to students living in Kenya requires parental consent for a child and gives no exemption for education, so we apply the stricter rule to everybody rather than sorting children by country.
Enrolment for a child is not complete until the parental consent form is signed and returned.

4.5 How teachers behave towards children

All contact with a child goes through the class or through the parent. A teacher never messages a child privately.
Teachers use only school accounts to contact students and parents. Never personal social media, never personal phone numbers.
Teachers do not accept friend or follower requests from students under 18.
Teachers do not ask a child for personal information beyond what enrolment needs.
Teachers do not meet a student in person alone.
A teacher never promises a child that a worry will be kept secret. If a child tells a teacher something that suggests they are not safe, the teacher must pass it on.

4.6 Roles and cover

The school has a named Designated Safeguarding Lead and a named Deputy (Section 9). The founder may hold one of these roles but never both.
If the Lead is unavailable, or if the concern is about the Lead, the Deputy takes it, and the independent outside contact can also be used at any time.

4.7 Records and privacy

Student and parent details are held only where they are needed to run the school, in accounts controlled by the school, protected by passwords.
We do not sell or share student or parent details.
Recordings are governed by Section 5 below.

5. The recording rules

Every class is live on video and is recorded. There are two different recordings, made for two different reasons, kept in two different places, for two different lengths of time. A parent gives, or refuses, permission for each one separately.

Recording 1: the safeguarding copy. Its only purpose is to allow a concern to be investigated if one is raised.

Recording 2: the lesson replay copy. Its only purpose is to let a student in that class watch the lesson again if they missed it or want to revise.

The table below sets out both.

	Safeguarding copy	Lesson replay copy
Why it exists	So a concern can be investigated	So enrolled students can watch the lesson again
Who can open it	The Designated Safeguarding Lead and the Deputy only, and only after a concern has been raised	The students enrolled in that class, the teacher of that class, and the Designated Safeguarding Lead
How it is opened	Through the school's own protected storage, by password	Through the student's own login on the school platform
Where it is kept	The school's own access controlled storage, Google Drive	The school's own student platform, Moodle
How long it is kept	Deleted within 30 days	Removed within 14 days of the lesson
Downloads	Not possible	Turned off

The school will

Ask for written parental consent before a child appears in any recording, and explain what the recording is for.
Put two separate questions on the consent form, one for the safeguarding copy and one for the lesson replay copy, and never treat an answer to one as an answer to the other.
Put two tick boxes on every consent question, "I give permission" and "I do not give permission", so that a parent has to make a choice and a blank form is never read as a yes.
Announce out loud, at the start of every class, that the class is being recorded.
Start the recording only after the class has begun and stop it before any informal chat at the end.
Delete the safeguarding copy within 30 days.
Remove the lesson replay copy within 14 days of the lesson.
Keep the safeguarding copy beyond 30 days only when it is needed for a concern that has been raised, and only until that concern is closed, and write down the reason for holding it.
Keep the lesson replay copy behind each student's own login, so that only the enrolled students of that class can reach it.
Turn downloads off on the lesson replay copy.
Let a parent change their mind at any time, and act on that within 5 working days.
Let a child who does not have permission to be recorded attend the class with their camera off, and take part fully in the teaching.
Tell parents in writing if a recording is ever seen by anyone outside the list above, and why.

The school will not

Record a child whose parent has not given permission for that specific purpose.
Treat consent for one purpose as consent for the other.
Put any class recording on YouTube, Vimeo, TikTok, Facebook, Instagram, or any other public or semi public video site.
Share a recording by a link that works for anyone who has it, forward it on WhatsApp, or send it as an email attachment.
Allow a recording to be downloaded.
Use any lesson recording in advertising, marketing, promotion, or a public showreel.
Show a recording to anyone outside the access list in the table above, unless the law requires it or a child's safety requires it.
Record anything outside the scheduled lesson, including conversations before the class starts or after it ends.
Keep a recording for longer than the periods stated above, except where Section 5, promise 8 applies.
Teach a child one to one on video.
Put a child in a class with adult students.
Penalise a child, in marks, attention, or class place, because their parent said no to recording.

The opt out, and what it means in practice

If a parent ticks "I do not give permission":

the child keeps their place in the class,
the child attends the class live, with their camera off,
the child is not in the recording,
the child speaks, asks questions, answers, and is corrected exactly like every other student,
the child receives the same homework, the same feedback, and the same reports,
nobody in the class is told which children are recorded and which are not.

Saying no to a recording is not a disadvantage. It costs the child nothing.

6. How to raise a concern

You do not need proof and you do not need to be certain. If something worries you, tell us. It is our job to look into it, not yours.

You can raise a concern about anything: something you saw in a lesson, something your child said, a recording, a message, the way a teacher spoke, or the school itself.

There are four routes. You may use any of them, in any order. You do not have to start at the top.

Route 1. The Designated Safeguarding Lead.

Contact details in Section 9. This is the normal route for most concerns.

Route 2. The Deputy Safeguarding Lead.

Contact details in Section 9. Use this if the Lead is away, or if you would rather not speak to the Lead.

Route 3. The independent outside contact. This route does not go through the founder.

Contact details in Section 9.

This person is not employed by the school. He does not report to the founder and the founder is not his manager. He is named on this page so that no concern about the school, or about the founder himself, has to be brought to the founder first.

Use this route if:

your concern is about the founder or headmaster,
you have already raised something and nothing happened,
you would simply rather talk to somebody outside the school.

He will listen, write down what you tell him, and tell you what will happen next. He will not tell the founder your name if you ask him not to, unless a child is at risk and the law requires it.

Route 4. The authorities where you live.

If you believe a child is in immediate danger, contact the police or the child protection service in your own country first. Do that before you contact us. Then tell us, so that we can act as well.

Emergency and child protection contacts: TO BE COMPLETED: the emergency and child protection numbers the school will list for each country where it has students

Children can raise a concern too. A student can tell any teacher, or write to the Lead, the Deputy or the independent contact using the details in Section 9. We take a child's worry seriously in the same way we take an adult's.

7. What happens after a concern is raised

We work to these timescales. If we cannot meet one, we tell you before it passes and we tell you why.

Step	Who does it	When
Immediate safety check. If a child may be in danger right now, we act at once, contact the authorities, and stop any class or contact that is part of the worry	Lead, or Deputy, or independent contact	Same day
We tell you we have received your concern, in writing	Whoever received it	Within 2 working days
We protect the evidence. Any recording connected to the concern is locked so it cannot be deleted on the normal 30 day or 14 day clock	Lead or Deputy	Within 2 working days
We write down what you told us and what we will do next, and send it to you	Lead or Deputy	Within 5 working days
Where the concern is about a person, that person is stood back from teaching or contact with children while it is looked into. This is not a punishment and it does not mean we have decided anything	Lead or Deputy	Immediately, and until the matter is closed
We look into it and give you a written outcome: what we found, what we decided, and what we changed	Lead or Deputy	Within 20 working days
If it takes longer than 20 working days, we send you a progress update, and another one every 10 working days after that	Lead or Deputy	Every 10 working days
If you are not satisfied with the outcome, you may ask the independent outside contact to review it. He will reply to you directly	Independent outside contact	Within 10 working days of your request

If the concern is about the founder, the founder takes no part in receiving it, deciding it, or reviewing it. The Deputy and the independent outside contact handle it between them, and the founder steps back from teaching the class involved until it is closed.

Records. Every concern is written down, whatever the outcome, with the date, what was said, what was decided, and by whom. These records are kept securely and separately from ordinary school records, and only the Lead and the Deputy can see them. Retention period: TO BE COMPLETED: how long concern records are kept, to be confirmed by the school with a legal adviser

Reporting outward. Where a concern suggests a child has been harmed or is at risk of harm, we report it to the police or child protection service in the country where the child lives. We do this whether or not the family asks us to.

8. Data protection and the law

We treat every student under 18 as a child, in every country, and we take written parental consent for every one of them.
The law that applies to students living in Kenya requires the consent of a parent or guardian before a child's personal data is handled, and gives no exemption for education. We therefore take parental consent for every child rather than deciding country by country.
The law that applies to students living in Somalia sets the age of a child at 18 and requires us to verify the identity and the age of both the child and the guardian. We therefore carry out that check at enrolment for every child.
A parent may ask us what data we hold about their child, ask us to correct it, and ask us to delete it. Write to the Lead using the details in Section 9. We reply within 20 working days.
Withdrawing consent for recording is explained on the consent form and in Section 5.

9. Who to contact

Designated Safeguarding Lead

Omar Ahmed, founder and headmaster

Email: info@banadirschool.com

Phone or WhatsApp: TO BE COMPLETED: school phone number

Deputy Safeguarding Lead

TO BE COMPLETED: full name of the deputy. This must not be Omar Ahmed. The founder may hold one of these two roles but not both

Role: TO BE COMPLETED: the deputy's role in or relationship to the school

Email: TO BE COMPLETED: deputy email address

Phone or WhatsApp: TO BE COMPLETED: deputy phone number

Independent outside contact, for any concern about the school or its founder

Salim, TheJamah

Email: hello@thejamah.com

Phone or WhatsApp: +1 631 417 0416

Salim is not employed by Banadir Language School and does not report to its founder. He is the school's website and systems developer, and he has agreed to receive concerns from parents, students and staff independently. You may contact him directly about anything in this policy, including a concern about the founder, without speaking to the school first.

Response times for all three contacts are set out in Section 7.

10. Related policies and documents

Parental Consent Form for Class Recording (signed before a child joins their first class)
Teacher Code of Conduct (signed by every teacher, including the founder)
Privacy Policy
Terms and Conditions
Refunds Policy

All of these are published on the school website. Ask us and we will send you a copy.

11. Review

This policy is reviewed at least once every 12 months, and immediately after any concern is closed, so that anything we learned is written into it.

Reviewed by: the Designated Safeguarding Lead, with the independent outside contact.

Next review due: TO BE COMPLETED: date 12 months after publication

Changes are dated and the version number is raised, so that a parent can see which version their child was enrolled under.