Safeguarding in Kazakhstan's international schools: local law

An international school in Astana or Almaty answers to two sets of expectations at the same time. Safeguarding in Kazakhstan's international schools has to satisfy the accreditation framework the school has chosen, usually the Council of International Schools or COBIS, with the International Task Force on Child Protection standards behind it. It also has to satisfy the duties that Kazakh law places on any legal entity working with children. Schools tend to write those as one policy and one procedure, which is the right instinct. It takes more drafting than it looks.

I coordinated CIS accreditation at Miras International School in Astana, and one question came back in every policy review. When a teacher hears something in a corridor on a Tuesday afternoon, who does she tell, and what happens next inside the school and outside it? The accreditation standard answers the first half of that question well. Kazakh legislation answers the second half, in different vocabulary, through different bodies, on different deadlines. A member of staff trained on only one half will hesitate at the point where the two meet.

The starting point is the Law of the Republic of Kazakhstan dated 8 August 2002 No 345, On the Rights of a Child in the Republic of Kazakhstan. Article 10 states that the state ensures the personal integrity of the child and protects the child from physical and mental violence, from cruel, rude or degrading treatment, from harassment (bullying), and from acts of a sexual nature. That article sets the principle. The operating duty on a school sits in a different document, the Code of the Republic of Kazakhstan dated 26 December 2011 No 518-IV, On Marriage (Matrimony) and Family.

Article 117 of that Code obliges individuals and legal entities to inform the bodies carrying out the functions of trusteeship and guardianship immediately about orphans and children left without parental care, at the place where those children are found. A school is a legal entity, so the duty reaches the institution as well as the person who happened to hear something. Article 82 covers the sharper case. Where a child is in instant danger to life or health, the trusteeship and guardianship body removes the child on the basis of an act of the local executive body, notifies the prosecutor immediately, and files a claim in court within seven days. The school removes nobody. The school is the source of the information that starts all of it.

Amendments dated 30 December 2025 No 246-VIII added a further layer to the child rights law. They created a regional authorised children's rights protection body, which carries the state functions of guardianship and custody of minors, coordinates the early detection of violations, and visits the children on its list at least once every six months. Under Article 7-17 the education authorities must promptly notify that body about minors identified as being at risk by educational psychologists and social educators, including minors who have reported violence and abuse. Law enforcement keeps its own powers under Article 7-16. Alongside those bodies the state runs contact centre 111, a free line on family, women's and children's rights that operates around the clock and routes emergency calls on to medical, police and legal services.

Kazakh legislation on children moves quickly, and several of the provisions above were introduced or reworded within the last two years. Every date and article here comes from the consolidated English texts published on adilet.zan.kz by the Ministry of Justice and read in September 2026. Before any of it reaches a school policy, the school's lawyer should confirm the current wording, and the school should confirm with the local authorities which regional office it actually reports to.

The child rights law defines harassment (bullying) as systematic actions of a humiliating nature, harassment or intimidation, and it puts a number on the word systematic: two or more times. As a legal category that is sensible, because liability needs a threshold. As an instruction to a teacher it is poor. The ITFCP standards, and the practice CIS evaluators expect to see, ask staff to pass on the first thing they notice, long before anyone knows whether it will happen twice.

This is where training written abroad breaks down in a Kazakh school. A module bought from a UK provider tells staff to report a concern. A member of staff who has read the national definition concludes that a single incident does not qualify. Both are correct inside their own frame, and the school has to say which frame the staff member is working in. The wording I have seen hold up is plain: report the first time, and let the designated safeguarding lead, with the school's lawyer, decide which legal category the matter falls into.

English statutory guidance needs the same care. Keeping children safe in education 2026 came into force on 1 September 2026 and applies to schools and colleges in England. Many international schools in Kazakhstan model their policy on it, which is a defensible choice, and it carries no legal force in Astana. Saying so inside the policy stops a member of staff citing a duty that does not exist here. I have written separately about which parts of KCSIE transfer to a school outside England.

In an international school in Kazakhstan the teaching staff work in English and a large part of the adult community does not. Drivers, security officers, kitchen teams, cleaners, nurses and administrative staff work in Russian or Kazakh, and several of them are the adults a child sees first in the morning and last in the evening. Training that exists only in English reaches the people least likely to receive a disclosure.

Translation on its own does not close the gap, because the vocabulary does not map. There is no single settled Kazakh or Russian term for safeguarding as the international sector uses it. Russian-language practice reaches for защита прав ребёнка, the protection of children's rights, which is a narrower and more legal idea than the everyday noticing the ITFCP standards describe. A module can be translated accurately and still leave a security officer unsure what he has been asked to do on Monday morning. A bilingual review by someone who knows both the language and the school's procedure fixes it, and it is a small piece of work. I have set out the difference in translation and localisation of safeguarding training, and the role-specific side in training for drivers, security, catering and nursing staff.

Article 12 of the Law of the Republic of Kazakhstan dated 21 May 2013 No 94-V, On Personal Data and their Protection, states that personal data shall be stored by the owner or operator, and by any third party, in a database located in the territory of the Republic of Kazakhstan. That paragraph came from an amendment in force from 1 January 2016. Article 16 allows trans-border transfer to states that ensure protection of personal data in accordance with the same law, and otherwise only on listed grounds, the first of which is the consent of the individual or a legal representative.

Article 25 adds two obligations a school can act on this term. A legal entity that owns or operates personal data must appoint a person responsible for organising the processing of personal data, and it must notify the competent authority of a personal data breach from the moment it detects one. Safeguarding files are among the most sensitive records a school holds, so the question of where the database sits belongs in the procurement conversation and not in the incident review afterwards. Ask any supplier where the data is stored, who else can read it, and what happens to it when the contract ends. The rest of those questions sit in a buyer's guide for safeguarding training software.

An evaluator will read the reporting route and then ask three members of staff to describe it. The distance between the document and the three answers is the finding. The paperwork below closes that distance, and none of it needs a consultant.

• One reporting route on one page, in English, Russian and Kazakh, naming the designated safeguarding lead and the deputy by name and by room.
• A written statement of who decides on an external referral, to which body, and within what time.
• Contact centre 111 and the emergency numbers posted where staff and students can read them.
• Training records showing who completed what, on what date, and in which language.
• A named reviewer and an approval date against every training module the school issues.
• The school's own definitions set beside the national legal definitions, with the difference explained in one sentence.

SafeguardIS builds a school's training from that school's own safeguarding and child protection policies, so what staff learn is what the school actually does, including the local reporting route. The designated safeguarding lead reviews and approves every module before staff see it. Publishing requires a named reviewer's declaration, and the content is hashed and logged, so a year later the school can show which version a member of staff completed and who approved it. Certificates are countersigned by the head of school and the designated safeguarding lead, and each one carries a code anyone can check on a public verification page.

Training ships in English, Russian and Kazakh today, which covers most of the adult community in a school in Kazakhstan. If your staff work in a language the platform does not ship yet, I build that language in for your school as part of the pilot. Staff can also ask an AI policy assistant questions that are answered from the school's own policies. The designated safeguarding lead keeps every safeguarding decision, and no child's details belong in a chat window. A policy audit feature checks the school's documents against ITFCP-aligned expectations and produces an action plan, and I run live workshops in English and Russian as well as whole-school safeguarding audits. Miras International School in Astana is the pilot school. To see how this reads in the languages your staff use, book a 20-minute walkthrough.