Updated & reviewed on September 9th, 2026

Iliani Procedure for Dealing with Safeguarding Reports

Purpose and scope

The purpose of this document is to provide procedures for dealing with reports of breach of Iliani Education Group Safeguarding Policy, where the safeguarding violation is:

• Against staff, clients, students, prospective clients and members of the general public.

• Perpetrated by staff, partners or associated personnel.

Procedures

1. Report is received

1.1 Reports may arise during online tutoring sessions, digital communications, or virtual programme activities, and must be handled in accordance with this procedure. Reports can reach the organisation through various routes. This may be in a structured format such as a letter, e-mail, text or message on social media. It may also be in the form of informal discussion or rumour. If a staff member hears something in an informal discussion or chat that they think is a safeguarding concern, they should report this to Iliani’s Safeguarding Focal Points Shan Shan Chen (sunny@ilianieg.com) or Kaven Naidoo (kaven@ilianieg.com).

1.2 If a safeguarding concern is disclosed directly to a member of staff, the person receiving the report should bear the following in mind:

• Listen

• Empathise with the person

• Ask who, when, where, what but not why

• Repeat/ check your understanding of the situation

• Report to the Safeguarding Focal Point

1.3 The person receiving the report should then document the following information:

• Name of person making report

• Name(s) of alleged survivor(s) of safeguarding incident(s) if different from above

• Name(s) of alleged perpetrator(s)

• Description of incident(s)

• Dates(s), times(s) and location(s) of incident

1.4 The person receiving the report should then forward this information to the Safeguarding Focal Point or appropriate staff member within 24 hours.

1.5 Due to the sensitive nature of safeguarding concerns, confidentiality must be maintained during all stages of the reporting process, and information shared on a limited ‘need to know’ basis only. This includes senior management who might otherwise be appraised of a serious incident.

1.6 If the reporting person is not satisfied that the organisation is appropriately addressing the report, they have a right to escalate the report, either up the management line (including the Board) or to an external statutory body. 

1.7 Where a safeguarding concern indicates immediate risk of harm to a child or vulnerable person, emergency services or the appropriate child protection authority must be contacted without delay, in parallel with internal reporting.

1.8 Safeguarding concerns must never be resolved informally or handled solely at a managerial or programme level.

2. Assess how to proceed with the report

2.1 Appoint a Decision Maker for handling this report. The Decision Maker shall be a senior individual authorised by Iliani, independent from the alleged incident, and may include a Safeguarding Focal Point or delegated senior manager.

2.2 Determine whether it is possible to take this report forward

• Does the reported incident(s) represent a breach of the safeguarding policy?

• Is there sufficient information to follow up this report?

2.3 If the reported incident does not represent a breach of Iliani Safeguarding Policy, but represents a safeguarding risk to others (such as a child safeguarding incident), the report must be referred to the appropriate external statutory body, unless doing so would increase risk to the survivor.

2.4 If the report raises any concerns relating to children under the age of 18, seek expert advice immediately. If at any point in the process of responding to the report (for example during an investigation) it becomes apparent that anyone involved is a child under the age of 18, the Decision Maker should be immediately informed and should seek expert advice before proceeding.

2.6 If the decision is made to take the report forward, ensure that there is relevant expertise and capacity to manage a safeguarding case internally or through external capacity if necessary.

2.7 Clarify what, how and with whom information will be shared relating to this case. Confidentiality should be maintained at all times, and information shared on a need-to-know basis only. Decide which information needs to be shared with which stakeholder – information needs may be different.

2.8 Check your obligations on informing relevant bodies when you receive a safeguarding report. These include (but are not limited to) statutory bodies. When submitting information to any of these bodies, think through the confidentiality implications very carefully.

3. Provide support to survivor where needed/requested

3.1 Provide appropriate support to survivor(s) of safeguarding incidents. 

NB: this should be provided as a duty of care even if the report has not yet been investigated. Support could include (but necessarily not limited to):

• Psychosocial care or counselling

• Medical assistance

• Protection or security assistance (for example being moved to a safe location)

3.2 All decision making on support should be led by the survivor.

4. Assess any protection or security risks to stakeholders

4.1 For reports relating to serious incidents: undertake an immediate risk assessment to determine whether there are any current or potential risks to any stakeholders involved in the case, and develop a mitigation plan if required.

4.2 Continue to update the risk assessment and plan on a regular basis throughout and after the case as required.

5. Decide on next steps

5.1 The Decision Maker decides the next steps. These could be (but are not limited to):

• No further action (for example if there is insufficient information to follow up, or the report refers to incidents outside the organisation’s remit)

• Investigation is required to gather further information

• Immediate disciplinary action if no further information needed

• Referral to relevant authorities

5.2 If the report concerns associated personnel (for example contractors, consultants or suppliers), the decision making process will be different and may include terminating a contract with a supplier/partner based on the actions of their staff. Although associated personnel are not staff members, we have a duty of care to protect anyone who comes into contact with any aspect of our programme from harm. 

5.3 If an investigation is required and the organisation does not have internal capacity, identify resources to conduct the investigation. 

6. Make decision on outcome of investigation report

6.1 Any findings of misconduct will be addressed in accordance with the Iliani Code of Conduct and relevant contractual provisions.

6.2 The Decision Maker makes a decision based on the information provided in the investigation report. Decisions relating to the Subject of Concern should be made in accordance with existing policies and procedures for staff misconduct.

6.3 If at this or any stage in the process criminal activity is suspected, the case should be referred to the relevant authorities unless this may pose a risk to anyone involved in the case. In this case, the Decision Maker together with other senior staff will need to decide to decide how to proceed. This decision should be made bearing in mind a risk assessment of potential protection risks to all concerned, including the survivor and the Subject of Concern.

7. Conclude the case

7.1 Document all decisions made resulting from the case clearly and confidentially.

7.2 Store all information relating to the case confidentially, and in accordance with Iliani policy and local data protection law.

7.3 Record anonymised data relating to the case to feed into organisational reporting requirements (e.g. serious incident reporting to Board, safeguarding reporting to donors), and to feed into learning for dealing with future cases.

Associated policies and procedures

  1. Safeguarding policy 

  2. Code of Conduct

  3. Safeguarding guideline 

  4. Procedure for Dealing with Safeguarding Reports (this document)