Safeguarding in international schools in Hong Kong: a DSL guide

This guide covers Hong Kong. Mainland China has its own rules, so read the China guide if your school is there.

The Education Bureau (EDB) registers schools. Section 10 of the Education Ordinance (Cap 279) says every school must be registered or provisionally registered. Section 42 says no one may teach in a school unless they are a registered or permitted teacher.

The EDB lists international schools as private and self-financing. The schools' own profiles on the EDB site show many teaching the International Baccalaureate (IB). Some say the Council of International Schools (CIS) or the Western Association of Schools and Colleges (WASC) accredits them.

The Protection of Children and Juveniles Ordinance (Cap 213) defines a child in need of care or protection. That includes a child who has been assaulted, ill-treated, neglected or sexually abused (section 34(2)).

Section 27 of the Offences against the Person Ordinance (Cap 212) covers ill-treatment and neglect of a child under 16 by a person in charge. The maximum on indictment is 10 years in prison.

The newest law is the Mandatory Reporting of Child Abuse Ordinance (Cap 650), in operation since 20 January 2026. No law read for this guide names a designated safeguarding lead (DSL). That role comes from accreditation standards such as those of the International Task Force on Child Protection (ITFCP).

The laws here were read on e-Legislation, the government's legal database, on 19 October 2026. This is general information, not legal advice. Confirm current law with local counsel and the relevant authority.

Yes, if they are specified professionals under Cap 650. For other countries, read mandatory reporting laws for international schools.

A specified professional must report as soon as practicable. The trigger is a reasonable ground to suspect that a child is suffering serious harm, or is at real risk of it. It must come to their notice at work (section 4).

Schedule 1 lists 25 types of specified professional. They include registered and permitted teachers working in a specified school, and wardens of boarding schools. Registered nurses, social workers and educational psychologists are listed too.

A specified school is any school under the Education Ordinance, except government, post-secondary-only and exempted non-formal schools. On this reading, international schools are specified schools. Counsel should confirm this for yours.

Teaching assistants, drivers and security staff are not on the list unless they hold a listed registration. Your policy should still ask them to tell the DSL at once.

A specified professional who fails to report commits an offence (section 4(4)). The fine is at level 5, which a Social Welfare Department leaflet gives as HK$50,000. On conviction on indictment the person is also liable to 3 months in prison.

There are exceptions in section 4(2). You need not report if you honestly and reasonably believe an accident alone caused the harm, and neglect played no part. The same goes if the child caused it alone, or another child did, unless the act was sexual.

You need not report harm that an Authority has told you about, that you have already reported, or that you honestly and reasonably believe another specified professional has reported.

A child is anyone under 18. Schedule 2 lists four kinds of serious harm.

• Harm that endangers life or health and needs urgent treatment, such as a fracture or burn.
• Harm that endangers psychological health or development, such as prolonged trauma.
• Coercing or enticing a child into rape, incest or other listed sexual acts.
• Neglect by a responsible person that endangers the child's life or health.

If a child is in immediate danger, call 999 for the Police Emergency Call Centre, then tell your DSL.

For a non-emergency report, phone or visit a police station or a Family and Child Protective Services Unit (FCPSU) of the Social Welfare Department (SWD). The SWD hotline is 2343 2255 and runs around the clock. Outside office hours, an outreach team takes over.

Then give the facts in writing on the government's Reporting Platform, as soon as practicable. The Authority sends a code to your mobile phone to open it. Teachers who saw the same harm can report as a team.

For advice, Against Child Abuse runs a Parent-child Support Line on 2755 1122. It is not an Authority under Cap 650, so a call there does not meet the legal duty.

Put 999, 2343 2255 and your DSL's name on one page, in English and Traditional Chinese. Check the numbers each term.

ITFCP-based standards ask staff to pass any concern to a named lead. Keeping children safe in education (KCSIE) does the same in England but has no legal force in Hong Kong.

Cap 650 adds a personal duty. Each specified professional must report serious harm to the Authority. Section 9 bans anyone from wilfully blocking a report, or imposing a rule that has that effect.

The EDB's FAQ says a specified professional needs no consent from the principal before reporting. Telling the principal does not replace the report. Tell the principal too, so the school can start its crisis plan.

One procedure can serve both. Every adult tells the DSL the same day, and a specified professional who meets the Cap 650 test also reports without waiting. Ask counsel whether a DSL-first rule could count as obstruction.

• Threshold: Cap 650 covers serious harm. Your policy should still pass on every concern.
• Other children: harm done solely by another child is outside the duty unless sexual. Your policy should still cover it.
• Secrecy: never promise a child secrecy. The EDB FAQ says to explain the referral to the child.

The Personal Data (Privacy) Ordinance (Cap 486) has applied since 1 August 1996. It sets six data protection principles. They cover collection, retention, use, security, openness and access.

Principle 3 bars using data for a new purpose without consent. Section 60B exempts use that a law requires or authorises, such as a report under Cap 650.

Section 33 would restrict sending personal data out of Hong Kong. The Ordinance marks it as not yet in operation. This guide found no rule in the Ordinance that requires data to stay in Hong Kong.

Principles 2 and 4 still apply when a supplier handles your records, inside or outside Hong Kong. Use contracts or other means to stop misuse and over-long retention. Ask counsel about the Privacy Commissioner's guidance before you send records abroad.

EDB Circular No. 15/2025 asks schools to keep child abuse records centrally, apart from the general student file, with access limited and recorded. A parent may ask for access, and the Ordinance governs that request.

The Government publishes its Guide for Mandated Reporters in Traditional Chinese, Simplified Chinese and English. Write your reporting route in English and Traditional Chinese, then add any other language your staff speak.

EDB Circular No. 15/2025 says staff may say harm instead of abuse with families, because the words can mean different things.

Regulation 58 of the Education Regulations (Cap 279A) says no teacher shall administer corporal punishment to a pupil. The Global Initiative to End All Corporal Punishment of Children reported in March 2020 that it was still lawful at home. Ban it for every adult in your code of conduct.

The Police run the Sexual Conviction Record Check (SCRC) for child-related work. EDB Circular No. 15/2025 says schools must run it when they appoint staff, so ask the EDB how that applies to your school.

The SCRC covers a list of sexual offences only. The Police issue the Certificate of No Criminal Conviction for visa and adoption cases only. For overseas staff, ask for police checks from every country where they have lived, as in safer recruitment for international schools.

Use this list in your first month. Share it with your Head and your deputy DSL. Laws change, so confirm anything here with local counsel and the relevant authority.

• Ask counsel which of your staff are specified professionals under Cap 650.
• Write one reporting route naming 999, the SWD hotline 2343 2255, your district FCPSU and the DSL.
• State that specified professionals report personally and that no one may block a report.
• Publish the route in English and Traditional Chinese, and check the numbers each term.
• Run the SCRC and check teacher registration for every new hire.
• Keep child protection records apart from student files, with access limited and logged.