Last updated: 1 May 2026
Introduction
1.1 Definition of Safeguarding
Safeguarding is the action taken to promote the welfare of children and protect them from harm. It is everyone’s responsibility and applies to all students within Pamoja courses.
Safeguarding includes:
- providing help and support as soon as concerns emerge;
- protecting students from maltreatment, including online harm;
- preventing impairment of students’ mental and physical health or development;
- taking appropriate action to support student welfare within Pamoja’s role and remit.
1.2 Definition of Child Protection
Child protection is the activity undertaken to protect specific children who are suffering, or who are likely to suffer, significant harm.
Child protection is therefore a specific part of safeguarding, whereas safeguarding is broader and includes prevention, early identification, support and appropriate escalation.
1.3 Common Terminology
- Abuse: a form of maltreatment of a child. Abuse may be caused by an adult or another child and may occur once or over time.
- Allegation: a claim or concern that a person may have behaved in a way that has harmed, or may harm, a student.
- Agencies: an authority, business or organisation that provides services in relation to child protection.
- Child protection: action taken to protect a specific child who is suffering, or likely to suffer, significant harm.
- Disclosure: when a person makes a safeguarding or child protection concern known.
- Designated Safeguarding Lead (DSL): staff who have undergone Level 3 Designated Safeguarding Lead training and are part of the Safeguarding Team.
- Event: online lesson events, webinars, and any conferences organised by Pamoja Education.
- Harm: physical, emotional, sexual or psychological damage or injury, including harm caused through neglect, exploitation or online activity.
- Incident: an occurrence, observation, communication or pattern of behaviour that raises safeguarding concern.
- One-to-one: one adult in a setting with one student.
- Online Lesson Event (OLE): a scheduled online learning event organised as part of a Pamoja course. Students may not always attend these in real time due to time zones, commitments or the flexible nature of the course model.
- Partner school: is a school in a contractual relationship with Pamoja Education, with lead responsibility for the safeguarding of their students
- Referral: the process of formally requesting support from another agency, including but not limited to medical facilities and the police.
- Safeguarding reporting form: the Microsoft form used by Pamoja staff to report safeguarding concerns to the Pamoja DSL team.
- Safeguarding Team: Pamoja DSLs and senior safeguarding staff from Faria Online Schools responsible for safeguarding oversight, advice, escalation and review.
- Safer Recruitment: recruitment processes intended to help ensure that staff and contractors are suitable to work with children. Usually coordinated by HR staff.
- Site-based Coordinator (SBC): the nominated operational contact at the partner school for Pamoja students. For non-urgent safeguarding concerns, the Pamoja DSL will normally contact the SBC and request contact with the school DSL.
- Staff: all employees of Pamoja Education and the wider Faria Online Schools, including full-time & part-time permanent staff, contractors, and volunteers.
- Student: a child or young person enrolled on a Pamoja course, including students aged 18 or over, where they are enrolled as school students.
- Technology: electronic systems and devices used for learning, communication, photography, video, audio recording, data storage or platform access
1.4 Policy Guiding Principles
Pamoja Education:
- takes safeguarding and child protection seriously and responds appropriately;
- expects all staff, contractors and volunteers to report safeguarding concerns promptly using the safeguarding reporting form;
- recognises that the welfare of students is of paramount consideration;
- recognises that partner schools retain primary safeguarding responsibility for their students;
- works within an international context and uses UK safeguarding guidance as a good-practice framework while recognising local legal and cultural contexts;
- does not provide a 24-hour safeguarding or crisis response service;
- expects urgent risk identified outside UK working hours to be escalated to emergency services where appropriate, with the SBC copied where possible, and the safeguarding reporting form completed to inform the Pamoja DSL team;
1.5 Policy Aims
This policy aims to:
- set clear safeguarding expectations of all Pamoja Education staff;
- define Pamoja’s safeguarding role in relation to partner schools;
- support staff to recognise and respond to safeguarding concerns, including concerns arising online;
- maintain a clear reporting route for suspected or disclosed abuse;
- ensure concerns are recorded factually, securely and promptly;
- support effective communication with partner schools through the SBC and, where required, the school DSL;
- ensure safer recruitment checks are completed for staff and contractors working with students.
1.6 Related Policies and Procedures
This policy should be read alongside the following policies and procedures:
- Faria Education Group Code of Conduct (Appendix 1)
- Safeguarding and Reporting Procedures (Appendix 2)
- Students at increased safeguarding risk (Appendix 3)
- Guidelines for When a Child Makes a Disclosure (Appendix 4)
- Pamoja Safeguarding Reporting Form
- Online Safety Policy
- Webcam Use Guidance
- Academic Integrity Policy 2.0
- SOP - Academic Integrity (from 2025)
- Pamoja Responsible Use Policy for AI.docx
- Data Protection Policy
- Safer Recruitment Procedures
- Low-Level Concerns Procedure
- Whistleblowing Policy
- Managing Against Staff Policy
- Disciplinary Policy
- Staff Acceptable Use / Communication Guidance
- Forum or Community Moderation Guidance (where applicable)
Please note that this list is not exhaustive and will be reviewed regularly.
2. Roles and responsibilities
2.1 All Staff
All staff must:
- understand that safeguarding is everyone’s responsibility;
complete required safeguarding training before working directly with students or within the required induction period;
complete safeguarding refresher training as required; - be alert to signs of abuse, neglect, exploitation, radicalisation, online harm and mental health concerns;
- immediately report safeguarding concerns to the DSLs using the safeguarding reporting form;
- contact a Pamoja DSL directly where a concern is urgent during UK working hours;
- where urgent risk arises outside UK working hours, contact emergency services where appropriate, copy in the SBC where possible, and complete the safeguarding reporting form;
- not investigate concerns independently;
- not promise confidentiality to students;
- Staff should also follow the guidance in Appendix 4 where a student makes a disclosure;
- use approved communication channels only;
- comply with the Faria Education Group Code of Conduct (Appendix 1)
- report safeguarding concerns following the procedures outlined in Appendix 2.
2.2 The Designated Safeguarding Leads
Pamoja DSLs will:
- take operational responsibility for safeguarding concerns reported within Pamoja;
- review safeguarding reporting forms and determine appropriate next steps;
- provide advice and support to staff;
- maintain detailed, accurate and secure safeguarding records;
- liaise with the SBC and request contact with the school DSL for non-urgent school-linked safeguarding concerns;
- contact the school DSL directly where the urgency or seriousness of the concern requires this;
- where appropriate, support referral to relevant agencies, normally in consultation with the partner school;
- consider cultural, legal and jurisdictional context when responding to international safeguarding concerns;
- seek external safeguarding advice where needed;
- ensure safeguarding training and procedures remain current and that all new staff receive training and existing staff receive refresher training every 2 years;
- contribute to internal case reviews where required;
- maintain appropriate safeguarding oversight and report trends or concerns to senior leadership.
2.3 The Head of Safeguarding
The Head of Safeguarding will:
- lead and support the Pamoja DSL team;
- provide oversight for complex cases;
- provide advice on allegations against staff as guided by International Centre for Missing and Exploited Children – e.g. International Protocol for Managing Allegations 2024.pdf;
- ensure this policy is reviewed at least annually;
- ensure safeguarding records, training and reporting processes are monitored;
- report safeguarding themes, risks and recommendations to senior leadership;
- ensure appropriate escalation where a person is dismissed or leaves due to risk of harm to students, including referral to relevant statutory or regulatory bodies where required.
2.4 Partner Schools and Site-based Coordinators
Partner schools retain primary safeguarding responsibility for their students.
The Site-based Coordinator is Pamoja’s nominated operational contact at the partner school. For non-urgent safeguarding concerns, the Pamoja DSL will normally contact the SBC and request contact with the school DSL.
Partner schools are expected to:
- maintain local safeguarding oversight of their students;
- provide appropriate SBC contact details;
- respond to safeguarding communication from Pamoja in a timely manner;
- identify the appropriate school DSL or safeguarding contact when needed;
- take forward local safeguarding action in line with their own policies, local law and statutory obligations.
3. Pamoja Contextual Issues
| Contextual area of risk | Mitigation / Control measures |
| 3.1 Pamoja online context (e.g. online safety, geographical ‘remoteness’ of students) |
Student discussions moderated by teachers, with escalation procedures for breaches of conduct. Online safety guidance and policy embedded within onboarding and Canvas resources. Webcam Use Guidance for teachers. 2 yearly safeguarding training for all staff includes online-specific safeguarding risks and remote teaching scenarios. Exposure to online misinformation, disinformation, extremist content, conspiracy theories, AI-generated or manipulated content, and harmful online communities recognised as contextual safeguarding risks – see Academic Integrity Policy 2.0.docx and Pamoja Responsible Use Policy for AI.docx Staff encouraged to monitor sudden shifts in behaviour, language, participation or beliefs expressed in online spaces or submitted work. Clear expectations regarding professional boundaries, communication channels and acceptable online conduct. |
| 3.2 Safeguarding concerns arising in online lesson events or other online interactions |
Teachers trained to recognise safeguarding indicators within online interactions, including concerning disclosures, visible environmental concerns, signs of distress, coercion, abuse, neglect, exploitation or self-harm. Staff instructed to record concerns factually and escalate promptly through the safeguarding reporting form to the Pamoja DSL team and in the event of urgent concerns, to emergency services and copy in the Site-based coordinator (SBC) as the school’s operational safeguarding contact. Safeguarding concerns may arise through verbal comments, chat messages, camera backgrounds, student interactions, patterns of attendance or behaviour during online lesson events. Recognition that, due to global time zones and differing schedules, students may engage asynchronously with course content and may not always attend online lesson events in real time. Where an immediate risk is identified, staff follow emergency escalation procedures and contact local emergency services where appropriate. Staff advised not to investigate concerns independently or promise confidentiality to students. Procedures account for differing global time zones and the possibility that Pamoja DSLs may be unavailable outside local working hours. See Appendix 2 and Appendix 4 for reporting and disclosure guidance. |
| 3.3 Safeguarding concerns identified in written work, messages or platform communications |
Teachers informed that safeguarding concerns may present in assignments, reflective writing, assessment responses, direct messages, emails, discussion boards or AI-generated content submitted by students. Staff training to guide on recognition of indirect disclosures, references to abuse, suicidal ideation, exploitation, radicalisation, eating disorders, harmful relationships or significant wellbeing deterioration. Concerns escalated to the SBC via Pamoja DSLs using agreed reporting routes, with records retained securely and shared on a need-to-know basis. Platform communications retained within institutional systems where possible to support safeguarding review and audit trails. Guidance provided regarding appropriate staff responses to concerning disclosures made through asynchronous communication. |
| 3.4 Global operating environment and out-of-hours safeguarding |
Recognition that students, teachers and schools operate across multiple jurisdictions, cultures and time zones. Staff are instructed to report safeguarding concerns through the safeguarding reporting form to the Pamoja DSL team. The Pamoja DSL will normally liaise with the SBC and/or school DSL as appropriate. Escalation pathways clarify how urgent concerns should be managed where the DSL or SBC is temporarily unavailable. Staff provided with guidance on documenting and escalating concerns identified outside standard UK working hours. Safeguarding procedures designed to balance prompt action with sensitivity to local legal, cultural and child protection frameworks. |
| 3.5 Students missing from our courses |
|
| 3.6 Professional boundaries in online education |
|
| 3.7 International safeguarding issues |
|
| 3.8 Technology and platform-related risks |
|
| 3.9 Information sharing and record keeping |
|
4. Safeguarding Reporting Procedure
Detailed procedural guidance is provided in Appendix 2.
4.1 Standard Reporting Route
The normal route for safeguarding concerns is:
Pamoja staff member → safeguarding reporting form → Pamoja DSL → SBC / school DSL as appropriate
Staff must complete the Pamoja safeguarding reporting form as soon as possible after identifying a concern.
The report should include:
- the student’s name and course;
- the date, time and platform/location of the concern;
- factual details of what was seen, heard or received;
- the student’s exact words where possible;
- any immediate action taken;
- any relevant screenshots, messages or submitted work, where appropriate and lawful.
Staff should avoid opinion, speculation or investigation and should also follow the disclosure guidance in Appendix 4 where relevant.
4.2 Urgent Concerns During UK Working Hours
Where a student appears to be at immediate risk during UK working hours, staff should:
- contact a Pamoja DSL urgently;
- complete the safeguarding reporting form;
- follow DSL advice;
- preserve relevant records or platform evidence where appropriate.
- The Pamoja DSL will determine whether to contact the SBC, school DSL, emergency services or other relevant agencies.
4.3 Concern Outside UK Working Hours
Pamoja does not provide a 24-hour safeguarding or crisis response service.
Where a concern arises outside UK working hours and appears urgent or immediate, staff should:
- contact emergency services local to the student where appropriate;
- copy in the SBC where possible;
- complete the safeguarding reporting form to inform the Pamoja DSL team;
- record the factual basis for the concern and any action taken.
Staff are not expected to provide crisis counselling, conduct risk assessments or investigate concerns. The priority is to take proportionate action where immediate safety appears at risk and ensure the concern is recorded for DSL review.
5. Responding to Disclosures
If a student makes a disclosure, staff must:
- listen calmly and without judgement;
- avoid leading or investigative questions;
- explain that concerns cannot be kept confidential;
- record the concern factually;
- report the concern promptly using the safeguarding reporting form;
- follow the urgent concern procedure where immediate risk is identified.
Detailed practical guidance for responding to disclosures is provided in Appendix 4.
6. Categories and Indicators of Abuse
Staff should be alert to the main categories of abuse and safeguarding risk, including:
- physical abuse;
- emotional abuse;
- sexual abuse;
- neglect;
- child-on-child abuse;
- online abuse;
- bullying and cyberbullying;
- sexual harassment and harmful sexual behaviour;
- child sexual exploitation;
- child criminal exploitation;
- radicalisation and extremism;
- domestic abuse;
- female genital mutilation;
- forced marriage;
- serious violence;
- suicide thoughts or behaviour;
- significant mental health concerns.
Pamoja staff are not expected to diagnose, investigate or determine thresholds of harm. Their responsibility is to recognise possible indicators, record concerns and report them through the safeguarding procedure.
Additional contextual guidance relating to mental health concerns and child-on-child abuse is provided in Appendix 5 and Appendix 6.
7. Child-on-Child Abuse
Pamoja recognises that children can abuse or harm other children, including online. Child-on-child abuse may occur through platform communications, discussion spaces, group work, online lesson events or external channels that affect the Pamoja learning environment.
Examples include:
- bullying, including cyberbullying;
- prejudice-based or discriminatory abuse;
- sexualised language or harassment;
- sharing or threatening to share nude or semi-nude images;
- coercive or controlling behaviour;
- abuse within intimate relationships between young people;
- peer pressure to participate in harmful online challenges;
- impersonation, humiliation or AI-generated/manipulated content.
Staff must not dismiss harmful behaviour as banter, immaturity or normal teenage interaction.
Where child-on-child abuse is suspected or disclosed, staff must complete the safeguarding reporting form. The Pamoja DSL will review the concern and determine appropriate communication with the SBC and school DSL.
Further operational guidance provided in Appendix 6.
8. Online Safety and Artificial Intelligence
Technology is a significant component of many safeguarding and wellbeing concerns.
Pamoja recognises risks relating to:
- harmful or inappropriate content;
- misinformation, disinformation and conspiracy theories;
- extremist content;
- online grooming or coercion;
- cyberbullying;
- harassment;
- impersonation;
- privacy breaches;
- image-based abuse;
- AI-generated or manipulated content, including deepfakes.
Students should receive appropriate online safety guidance through onboarding, Canvas resources and course expectations.
Staff should remain alert to safeguarding risks arising from AI use, including manipulated images or video, reputational harm, coercion, harassment, exploitation and exposure to harmful content. Concerns should be reported through the safeguarding reporting form.
See also the Online Safety Policy , Webcam Use Guidance, Academic Integrity Policy 2.0, SOP - Academic Integrity (from 2025) and Pamoja Responsible Use Policy for AI.docx
9. Mental Health and Wellbeing
Mental health concerns can, in some cases, indicate that a student has suffered or is at risk of suffering abuse, neglect or exploitation.
Staff may notice concerns through:
- submitted work;
- messages;
- sudden changes in tone or behaviour;
- withdrawal or reduced engagement;
- references to self-harm or suicide thoughts;
- concerning comments in online lesson events;
- peer reports of concern.
Staff should not attempt to diagnose mental health conditions. Where a mental health concern is also a safeguarding concern, staff must complete the safeguarding reporting form.
Where a student appears to be at immediate risk of harm, staff should follow the urgent concern procedure.
Additional guidance is provided in Appendix 5.
10. Record Keeping, Confidentiality and Information Sharing
Safeguarding records must be:
- factual;
- dated;
- securely stored;
- limited to relevant information;
- shared only with those who need to know.
Pamoja will share safeguarding information with partner schools where appropriate, normally through the SBC and/or school DSL.
Information sharing should be proportionate and in line with applicable data protection requirements. Staff must not store safeguarding records outside approved systems or discuss safeguarding concerns with colleagues who do not need to know.
Staff should also follow applicable Data Protection and Information Security policies.
11. Safer Recruitment
Pamoja is committed to safer recruitment for staff and contractors working with students.
This includes:
- identity checks;
- successful candidates for all positions provide or undergo a check through the UK Disclosure and Barring Service (DBS), or local agency equivalent;
- qualification checks where relevant;
- employment history review;
- appropriate criminal record or local equivalent checks;
- reference checks;confirmation that staff have read and agreed to the Faria Education Group Code of Conduct (Appendix 1);;
- safeguarding training requirements before or shortly after appointment, depending on role.
See also the Safer Recruitment Procedures.
12. Allegations and Low-Level Concerns About Staff
Pamoja recognises that a student or another person may raise a concern or allegation about a member of staff.
An allegation may indicate that a member of staff has:
- behaved in a way that has harmed, or may have harmed, a student;
- possibly committed a criminal offence relating to a student;
- behaved towards a student in a way that indicates they may pose a risk of harm;
- behaved in a way that raises safeguarding concerns, even if the behaviour appears low-level.
Low-level concerns include any concern, however small, that causes unease or a “nagging doubt” about an adult’s behaviour towards students.
Concerns about staff must be reported to the Head of Safeguarding or through the relevant internal reporting procedure. e.g. Low-Level Concerns Policy and Whistleblowing Policy. Where the concern relates to the Head of Safeguarding, it must be escalated to the appropriate senior leader.
All allegations and low-level concerns will be taken seriously, recorded and reviewed.
13. Supporting Staff
Pamoja recognises that staff involved in safeguarding concerns may find the situation stressful or upsetting.
Staff may seek support from a DSL or an appropriate senior member of Pamoja staff. Staff should not discuss safeguarding concerns informally or with people who do not need to know.
14. Policy Review
This policy will be reviewed at least annually, or sooner where there are significant changes in:
- safeguarding guidance;
- legislation;
- Pamoja operating model;
- platform use;
- contractual arrangements with partner schools;
- internal safeguarding procedures.
Relevant updates will be communicated to staff and reflected in training.
Appendix 1: Staff Code of Conduct
The Faria Education Group Code of Conduct is signed by all employees and contractors at the start of their employment and reviewed every 2 years during safeguarding refresher training.
Faria Education Group Code of Conduct
Faria Education Group
Safeguarding Staff Code of Conduct
This Safeguarding Code of Conduct applies to all members of the Faria Education Group, its subsidiaries and any person/s contracted by the Faria Education Group.
The purpose of this Code of Conduct is threefold:
- To confirm and reinforce the expectations in regard to safeguarding that the Faria Education Group has for its employees and contractors;
- To establish safe and consistent working practices;
- To provide a reference point when exercising investigative and disciplinary functions.
The Faria Education Group recognises the nature of our international community means that employees and contractors must navigate diverse cultural expectations and norms. As such, employees and contractors are expected to exercise professional judgment and act within the spirit of these guidelines at all times, seeking advice from the Safeguarding Team as necessary. In all situations, the physical and mental welfare of students is paramount.
This Code of Conduct applies to interactions with all students under the age of 18 and/or currently registered as a student in a school, programme or service affiliated with or delivered by Faria Education Group.
General Conduct
All personnel must:
- Undertake safeguarding training.
- Be familiar with the Safeguarding Policy and Reporting Procedures.
- Immediately report suspected or disclosed abuse to a Designated Safeguarding Lead.
- Maintain confidentiality of personal information, unless there is a need to report a concern.
- Seek guidance from a Designated Safeguarding Lead should you be in any doubt about the appropriateness of your own or another person’s conduct.
- Demonstrate respect and appreciation for diversity, including but not limited to age, disability, gender, marital status, race, ethnicity, religion and sexual orientation.
- Use appropriate language at all times, avoiding profanity, sexual innuendo, stereotypes, bullying, extremist or discriminatory language.
- Not engage in an intimate physical or emotional relationship with a student.
- Avoid any physical contact with students.
- Ensure all communication with students is via the Faria Education Group internal systems and not share personal contact details, such as a personal email address, phone number or social network details.
- Not contact students on social media or store student information (such as an email address or phone number).
- Comply fully with any safeguarding inquiry.
Additional Protocols for Direct Interactions with Students, including School Visits and Education Conferences
All personnel must:
- Use only toilets and changing facilities designated for adults.
- Not consume alcoholic beverages or smoke when in the presence of students.
- Dress appropriately and avoid revealing or tight-fitting clothing.
- Not take photographs or videos of students unless permission is provided by a member of the Senior Leadership Team of their school.
- Ensure that photographs or videos of students taken with permission are immediately downloaded onto the Faria Education Group systems and deleted from personal devices.
- Ensure that photographs and videos of students are not shared on personal social media.
- Not engage with students socially unless as part of an organised activity.
Additional protocols for Online Teaching
All personnel must:
- Promote the welfare of students in their care by upholding a safe environment in which students feel secure and valued.
- Support the student’s development in ways that will foster confidence and independence.
- Ensure that all communication with students and sharing of electronic resources is through a platform approved by the Faria Education Group. The method of communication with students is Canvas inbox.
- Promote a culture of respect amongst students and report any instance of student communication which could be perceived as inappropriate.
- Maintain a professional tone in all communication.
- Adhere to all policies and procedures in Pamoja and Wolsey Hall documentation.
Appendix 2: Safeguarding and Reporting Procedures
Standard concern
- Staff member identifies concern.
- Staff member completes safeguarding reporting form.
- Pamoja DSL reviews concern.
- Pamoja DSL contacts SBC and requests contact with school DSL where appropriate.
- Actions and outcomes are recorded securely.
Urgent concern during UK working hours
- Staff member contacts Pamoja DSL urgently.
- Staff member completes safeguarding reporting form.
- DSL determines escalation route.
- SBC and/or school DSL contacted as appropriate.
- Actions and outcomes are recorded securely.
Urgent concern outside UK working hours
- Staff member contacts emergency services where appropriate.
- Staff member copies in SBC where possible.
- Staff member completes safeguarding reporting form.
- Pamoja DSL reviews on receipt.
- Follow-up with SBC/school DSL recorded securely.
Current safeguarding contacts:
safeguarding@pamojaeducation.com
Barbara Rangel (DSL) barbara.rangel@pamojaeducation.com
Amanda Jones (DSL) amanda.jones@pamojaeducation.com
Appendix 3: Students Who May Face Increased Safeguarding Risk
Some students may face additional barriers to recognising, reporting or escaping harm.
This may include students who:
- have SEND, disabilities or health conditions;
- have English as an additional language;
- are isolated or geographically remote;
- are experiencing discrimination;
- are affected by mental health concerns;
- are young carers;
- are at risk of exploitation, forced marriage, FGM or radicalisation;
- are affected by domestic abuse;
- are missing from education or showing reduced engagement;
- are in unstable living, care or guardianship arrangements.
Appendix 4: Guidelines for when a child makes a disclosure
Staff should:
- listen;
- remain calm;
- avoid judgement;
- avoid leading questions;
- record the student’s words;
- explain that the information must be shared with safeguarding staff;
- report using the safeguarding reporting form;
- contact a DSL directly if urgent during UK working hours;
- follow the out-of-hours urgent concern procedure where needed.
Staff must not:
- investigate;
- promise confidentiality;
- contact parents or families;
- confront alleged perpetrators;
- delay reporting;store safeguarding information outside approved systems.
Staff should also refer to Appendix 2 for reporting routes and escalation procedures.
Appendix 5: Mental Health
- Due to the developmental changes that are taking place, adolescents and teenagers are more prone to episodes of poor mental health, but there are many external factors that can also impact our students’ wellbeing, including family breakdown or bereavement, separation anxiety, pressure to succeed, body-image, on-line influences (sexualisation, bullying, materialism, harmful hoaxes and/or violence).
- If a student asks for help or advice, or a member of staff has concerns about their mental health, staff should report to the relevant DSL.
- The DSL may support communication with the partner school regarding appropriate sources of support available to the student.
