Safeguarding & Child Protection Policy

1. Policy Statement
Bluefin Watersports Sdn Bhd is committed to providing a safe, positive and enjoyable environment in which every child can learn to swim. The welfare of the child is our paramount concern.
We believe that no child should ever experience abuse or harm. We are committed to protecting all children in our care from physical, emotional and sexual abuse, and from neglect, and to promoting their wellbeing at all three of our sites.
This policy applies to everyone who works with or on behalf of Bluefin — employees, coaches, assistants, volunteers, contractors and management — regardless of role or seniority.
2. Legal & Best-Practice Framework
This policy is grounded in Malaysian law and adopts the best-practice standards of Swim England, so that Bluefin meets both local legal obligations and international coaching standards.
Source
What it provides
Child Act 2001 (Malaysia)
The primary law protecting children (any person under 18) in Malaysia, including duties to report a child in need of protection.
Sexual Offences Against Children Act 2017
Creates specific offences relating to child sexual abuse and grooming, and duties on those working with children.
Personal Data Protection Act 2010
Governs how we store and handle personal and sensitive information about children and families.
Swim England ‘Wavepower’
The aquatic-sector safeguarding standard we adopt for coaching conduct, safer recruitment and reporting practice.
Throughout this policy a child means any person under the age of 18.
3. Roles & Responsibilities
Designated Safeguarding Lead (DSL)
The DSL holds lead responsibility for safeguarding at Bluefin. The DSL receives all concerns, decides on action, makes external referrals, keeps secure records and arranges training.
DSL: Sam France

Everyone at Bluefin must

Understand and follow this policy and the Coaches Code of Conduct.
Recognise the signs of abuse and know how to respond and report.
Report any concern about a child’s welfare to the DSL without delay.
Never attempt to investigate or resolve a safeguarding concern alone.

4. Safer Recruitment
Bluefin seeks to prevent unsuitable people from working with children through careful recruitment:

All coaching roles require an application, interview and at least two references, which are checked.
Identity, qualifications and relevant certifications (coaching, first aid, lifesaving) are verified.
Background/criminal-record checks are obtained where available and permitted under Malaysian law.
All new staff complete a safeguarding induction before working unsupervised with children.
New staff work under a probation period with supervision and review.

5. Code of Behaviour
Good practice — always:

Treat all children with respect and dignity.
Maintain appropriate, visible and open interactions at all times.
Ensure another adult is present or within sight during any contact with a child.
Explain and keep to the minimum any physical contact needed for safety or technique.
Maintain correct class ratios (1:5 for Little Fins and Learn to Swim up to Level 3, 1:8 from Level 4+; 15:1 Swim Team)..

Never:

Be alone with a child out of sight of others, or take a child alone in a vehicle.
Enter changing rooms when children are present, other than to supervise appropriately.
Photograph or film a child on a personal device.
Engage in private messaging or social-media contact with a child.
Use inappropriate language, shout at, humiliate or physically punish a child.
Do things of a personal nature for a child that they can do for themselves.

6. Photography & Filming

Photographs and video are taken only on Bluefin equipment, by authorised staff, for approved purposes.
We rely on the media consent given in our Terms & Conditions; parents may opt out in writing at any time.
Images are stored securely and used only in line with our Personal Data Protection obligations.
Coaches and parents must not film or photograph other people’s children.

7. Recognising Abuse
Abuse takes four main forms. Coaches are well placed to notice changes because of the physical, observable nature of swimming.
Type
Possible indicators
Physical
Unexplained bruises, marks or injuries, especially in unusual places; fear of changing or of a particular person.
Emotional
Withdrawal, low self-esteem, excessive fear of failure, over-reaction to mistakes.
Sexual
Sexual knowledge or behaviour beyond the child’s age; distress; disclosures.
Neglect
Persistent hunger, poor hygiene, inadequate clothing, being left unsupervised or unwell.
These signs do not prove abuse, but they mean you must report your concern to the DSL.

8. Responding to a Concern or Disclosure
If a child tells you something, or you have a concern — do:

Stay calm and listen carefully without interrupting.
Reassure the child that they were right to tell you.
Take it seriously and let the child know you must pass it on to keep them safe.
Record exactly what was said or seen, in the child’s own words, as soon as possible.

Do not:

Promise to keep it secret — you cannot.
Ask leading questions, investigate, or confront anyone.
Delay. Pass the concern to the DSL the same day.

9. Reporting Procedure
Follow these steps for any safeguarding concern:

Immediate danger? If a child is at immediate risk of harm, call the Police on 999 first.
Record what you saw or were told, factually, in the child’s words, with date and time.
Report to the DSL the same day. The DSL decides on next steps.
The DSL refers externally where needed — to the Department of Social Welfare (JKM), Talian Kasih, or the Police.
Confidentiality is maintained throughout — information is shared only with those who need to know.

External reporting contacts (Malaysia):
Talian Kasih (national helpline): 15999 / WhatsApp 019-261 5999 · Police & emergency: 999

10. Allegations Against Staff or Volunteers
Concerns about the behaviour of a member of staff or volunteer are treated with the same seriousness as any other concern.

Report the concern to the DSL immediately. If the concern is about the DSL, report to the Deputy DSL or management.
The person may be suspended from contact with children as a neutral, precautionary step while matters are assessed — this is not a presumption of guilt.
The DSL will follow the reporting procedure and take advice, involving external authorities where required.
All parties are treated fairly and confidentially throughout.

11. Records & Confidentiality

Safeguarding records are factual, dated and stored securely with restricted access.
Personal and sensitive data is handled in line with the Personal Data Protection Act 2010.
Information is shared only on a strict need-to-know basis to protect the child.

12. Training & Review

All staff receive safeguarding checks, induction and refresher briefings.
This policy is reviewed at least annually, and after any significant incident or change in law.
The DSL is responsible for keeping the policy and contacts current.