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AVM Child Protection Policy ( under POCSO act 2012)

“To become the exemplary Institution that develops future ready, successful happy individuals grounded in human values ”

1. GUIDING PRINCIPLES:

The school is committed to safeguarding the interests of all children under its care and is responsible for their emotional and physical well-being.

  1. Best Interest of the Child: Every administrative, protective, or statutory action taken under this policy shall prioritize the physical safety, emotional recovery, and mental well-being of the child above all institutional or corporate concerns.
  2. Child Participation & Voice:Children are recognized as active, autonomous participants in their own safety. The school guarantees a supportive environment where children are empowered to speak, and their testimonies are taken seriously without institutional minimization.
  3. Confidentiality & Privacy:Complete identity protection is legally and operationally guaranteed. No details of any survivor, disclosure, or ongoing investigation shall ever be leaked, broadcasted, or discussed broadly.
  4. Non-Discrimination:This policy applies uniformly and unconditionally to every child associated with AVM, completely irrespective of their gender, caste, race, religion, socio-economic background, physical capabilities, or academic standing.
  5. Timely Intervention & Support:Delayed safety protocols constitute a form of secondary institutional trauma. The school commits to immediate internal containment, rapid statutory protection, and instant access to mental health professionals upon the receipt of any alert.
  6. Accountability & Transparency:Clear reporting lines, explicit definitions of duties, and unwavering cooperation with state law enforcement are maintained to eliminate institutional cover-ups or systemic complacency.

2. SCOPE AND APPLICABILITY:

A. Stakeholder Applicability: This policy applies unconditionally to all individuals operating within or associating with the AVM eco-system, categorized as follows:

  1. Staff: Senior management, administrative heads, teaching staff, non-teaching staff, interns, sub-staff, security teams, and all ancillary personnel.
  2. External Parties: Parents, guardians, visitors, alumni, third-party vendors, external coaches, independent contractors, and visiting faculty.

B. Geographic and Operational Coverage: Protections and behavioral regulations are active across:

  1. On-Campus Spaces: Classrooms, laboratories, washrooms, playgrounds, administrative wings, and auditoriums.
  2. Extended Environments: School-sanctioned transport routes, field trips, excursions, outstation sports meets, camps, and inter-school competitive events.
  3. Temporal Boundaries: Active during standard school hours, during any extended or remedial coaching clinics, and at any time students are under the physical or digital supervision of AVM employees.

C. Statutory Legal Definitions:

  1. Child – Legal Definition: Any person below the biological age of 18 years, as explicitly defined and legally mandated under the Protection of Children from Sexual Offences (POCSO) Act, 2012.
  2. Sexual Assault: Any act involving non-consensual physical contact with explicit sexual intent— including touching a child's private parts, forcing a child to touch another's private parts, or any other unwanted physical boundary violation—as defined under Section 7 of the POCSO Act.
  3. Sexual Harassment: Non-contact interactions executed with explicit sexual intent, including uttering sexually colored remarks, making obscene sounds or gestures, exhibiting explicit or pornographic media, or repeatedly following, watching, and tracking a minor (stalking) across physical or digital spaces as defined under Section 11 of the POCSO Act.
  4. Aggravated Offense: Any sexual assault, exploitation, or harassment committed by individuals occupying a position of trust or authority (including school management, principals, educators, and support staff) is automatically classified as an Aggravated Offense under the POCSO Act, carrying non-dilutable, severe statutory penalties (minimum 20 years to life imprisonment).
  5. Disclosure: Any instance where a child communicates an experience of sexual abuse, grooming, or boundary violation—whether directly through spoken words, written notes, digital text, or indirectly through behavioral changes— instantly triggers the school's mandatory 24-hour statutory reporting timeline.

3. LEGAL FRAMEWORK:

This policy stands in strict conformity with the statutory mandates, penal codes, and child welfare amendments of the Republic of India:

  1. The Protection of Children from Sexual Offences (POCSO) Act, 2012 (incorporating all active amendments mandating minimum sentencing and institutional compliance).
  2. The Juvenile Justice (Care and Protection of Children) Act, 2015 (specifically regarding protection against institutional abuse and corporal harm).
  3. The Information Technology Act, 2000 (governing digital safety, cyberbullying, online grooming, and explicit media violations involving minors).
  4. The Bharatiya Nyaya Sanhita (BNS), 2023 (governing general criminal acts, physical boundaries, and institutional criminal liabilities).

4. CHILD PROTECTION COMMITTEE (CPC) COMPOSITION & RULES (2026-27)

To ensure multi-campus safety oversight, the active Child Protection Committee (CPC) for the academic year 2026-27 is constituted as follows:

MEMBERS BW & SANTACRUZ BE JUHU
Principal Ms Jyoti Kumar Mrs. Shobha Iyer Dr. Anuradha Sridhar
Vice Principal Ms. Sheetal Jain Mrs. Lakshmi Sengupta -
School Head/
Senior Subject Head
Ms. Nihraika Jaisinghani - Ms. Neelam Deokule
Counsellor Ms Janvi Dedhia Ms. Krushi Shah Ms. Tanisha Jhajj
Male Teacher Mr. Sudhakar Gavhane Mr. Sunil Bhaidasna Mr. Amit Shukla
Female Teacher Ms. Sana Hussain Ms. Yogita Thakur Ms. Shraddha Pillai
Male Student Representative ******** ******** ********
Female Student Representative ******** ******** ********
Parent Representative Ms. Bageshree Borgharkar Ms. Anshu Batra Mr. Mukul Jain
Parent Representative Ms. Hariyali Parikh Dr. Tushna Menon Ms. Minauti Patil

5. MANDATORY REPORTING CONTEXT & STEPS:

  1. Universal Duty of Disclosure: Every single individual employed by or associated with the AVM Group of Schools is designated as a Mandatory Reporter under Indian law.
  2. Mandatory Reporting Matrix: If any staff member observes, suspects, or receives information regarding an incident of Child Sexual Abuse (CSA), they must report the facts immediately and directly to any of the following designated authorities:
    • The Campus Principal
    • The Campus Vice Principal
    • The School Counselor
    • Any active Member of the Child Protection Committee (CPC)
  3. Conflict of Interest & Absence Bypass Protocols:
    • General Line: The Principal will be notified immediately upon receiving an alert.
    • CPO Unavailability: If the Principal is physically absent or unreachable during a safety emergency, the reporter must bypass them completely and report directly to the Vice Principal to ensure the statutory reporting clock never stops.
    • Accusations Involving Leadership: If a child protection allegation or boundary violation is raised directly against a CPO, a Member of the CPC, or the Principal, the reporter must completely bypass the campus chain of command.
    • The report must be submitted directly to the AVM Group Chairperson or designated Managing Board Trustee to guarantee an uncompromised, objective evaluation.
  4. No Internal Structural Investigations: Staff and school management are strictly prohibited from conducting independent investigations, confronting the accused, demanding confessions, or attempting to gather evidence prior to law enforcement notification.
  5. The Strict 24-Hour External Police Clock: In total compliance with Section 19 of the POCSO Act, the Principal/CPC is legally bound to notify the local Special Juvenile Police Unit (SJPU) or local police station, within 24 hours.
  6. Statutory Penalty for Non-Reporting: Under Section 21 of the POCSO Act, anyone who deliberately fails to report a child sexual offense shall face mandatory criminal prosecution.

6. STRENGTHENING STUDENT REPRESENTATIVE MANDATE:

Student representatives are vital links in building campus safety.

  1. Core Responsibilities: They shall serve strictly as awareness ambassadors and peer sensitization leaders, helping to propagate age-appropriate safety literacy, boundary awareness, and a culture of reporting among their peers.
  2. Strict Confidentiality and Operational Bans: To safeguard the privacy of minors and protect student representatives from emotional distress or social friction, student representatives are strictly prohibited from:
    • Participating in any active investigations or evidence evaluation.
    • Attending disciplinary proceedings or committee trials against staff/students.
    • Accessing confidential case summaries, safety forms, or identity-revealing documents.

7. CHILD-FRIENDLY DISCLOSURE MANAGEMENT GUIDELINES:

When a child approaches an educator, counselor, or staff member to disclose an experience of abuse or trauma, the receiving adult must strictly adhere to the following trauma-informed behavioral protocols:

  1. Remain Calm and Listen: Maintain neutral, steady, and unalarmed body language. Do not display physical shock, loud gasps, anger, revulsion, or intense emotional distress, as this causes secondary trauma and shuts down communication.
  2. Believe the Child: Accept the child's account completely without offering skepticism, analytical doubt, structural critiques, or probing questions. Show immediate unconditional validation.
  3. Reassure the Child: Comfort the child using clear, supportive statements. Use these exact phrases where possible: "Thank you for being brave enough to tell me. You did the right thing by speaking up. This is not your fault, and you are safe and supported here."
  4. Avoid Leading Questions: Do not engage in interrogation, demand graphic details, or ask questions that imply blame or cross-examine the child (e.g., avoid: "Why didn't you say no?" or "Why did you wait so long to tell me?"). Leave forensic evaluations entirely to statutory child welfare police teams.
  5. Avoid Making Unkeepable Promises: Do not promise absolute institutional secrecy (e.g., "I promise I won't tell anyone"). Be transparent and say: "I cannot keep this a secret because my job is to make sure you are fully safe, but I will only share this information with the exact specialists whose job it is to help you."
  6. Record the Disclosure Verbatim: Log the entire conversation on the internal Safety Concern Form within 1 hour/24 hours of the talk. Utilize the child's precise, exact vocabulary and phrasing without adding personal interpretations, adjectives, or editorial updates.
  7. Report Immediately: Move the information directly to CPC.

8. COUNSELING & POST-DISCLOSURE SUPPORT MEASURES

The school recognizes that safety does not end with a police report. AVM guarantees comprehensive post-disclosure psychological, academic, and physical support systems:

  1. Immediate Emotional Support: The survivor shall gain instant access to confidential, trauma-informed counseling through the certified School Counselor to manage immediate shock and emotional distress.
  2. External Professional Referrals: Where prolonged trauma tracking or deep psychiatric treatment is evaluated, the CPC will coordinate with parents to provide structured referrals to expert external child psychologists, therapists, or medical health networks.
  3. Academic Continuity and Support: During the recovery and trial phase, the school will ensure the child suffers no academic setbacks. Measures include flexible assignment deadlines, customized attendance relaxations, private remedial support, and examination accommodations.
  4. Institutional Reintegration Planning: If a child requires an extended leave of absence for recovery, the CPC, counselor, and class teachers will draft a customized, gentle reintegration blueprint to ensure the child returns to daily school life safely, comfortably, and free from peer isolation or social discomfort.

9. INTERIM WORKPLACE ISOLATION PROTOCOLS FOR THE ACCUSED

  1. Immediate Workplace Separation: The exact moment a credible allegation or formal complaint of child sexual abuse is leveled against any employee of the AVM Group, the institution will implement immediate protective administrative steps pending final police investigation.
  2. Non-Student-Facing Suspension/Reassignment: To secure the student body and eliminate any possibility of intimidation or evidence tampering, the school will place the employee under administrative suspension or temporarily reassign them to a remote, back-office administrative role that features absolute zero physical, visual, or digital contact with students.
  3. Non-Punitive Status Communication: This interim step is a protective isolation measure to preserve institutional safety and protect the integrity of the investigation. It shall be communicated to the school community neutrally and must not be framed as a pre-judgment or formal declaration of structural guilt.
  4. Absolute Zero-Contact Mandate: During the pending inquiry, the accused individual is strictly prohibited from entering school grounds, using school communication networks, or attempting to contact the victim, the victim's family, or potential witnesses.

10. AIRTIGHT ANTI-RETALIATION & GOOD FAITH CLAUSES

  1. Complainant Protection Shield: The AVM Group of Schools guarantees absolute legal, social, and academic protection to any student, parent, whistleblower, or staff member who flags a concern or makes an allegation of child abuse.
  2. Zero Tolerance for Penalization: Any attempt by management, educators, peers, or external parties to victimize, bully, isolate, academically disadvantage, or professionally target a complainant or reporting staff member will face an instant disciplinary trial, resulting in immediate termination of service or permanent expulsion from all AVM institutions.
  3. Good Faith Immunity Mandate: Staff members who report a concern to the CPC in good faith are fully protected under this policy. Even if an investigation subsequently finds the concern to be unproven or unfounded, no negative remarks, career impacts, or disciplinary actions will ever be taken against the reporter.
  4. False Reporting Clause: If it is irrefutably proven through a formal investigation that a deliberately false, fabricated, or malicious complaint was filed with oppressive intent to wrongfully defame an individual, the school may address the action through appropriate, severe disciplinary measures.

11. SAFE RECRUITMENT & CONTINUOUS HR SAFEGUARDS

  1. Rigorous Pre-Employment Screening: All offers of employment for teaching, non-teaching, administrative, and temporary support staff are strictly conditional upon clearing:
  2. Mandatory Police Verification: A valid, documented criminal record clearance certificate issued directly by local law enforcement authorities.
  3. Direct Reference Validations: There will be professional reference checks from previous employers, explicitly inquiring into past behavioral records or boundary issues regarding interactions with minors.
  4. Probationary Safety Monitoring: All newly appointed hires will undergo a mandatory probationary period of no less than 2 years. During this timeline, their physical and digital interactions with the student body will be monitored via scheduled and unannounced supervisory evaluations.
  5. Periodic Reassessment of Existing Hires: Safe recruitment is an ongoing cycle. The AVM Group will mandate bi-annual (every 2 years) background and behavioral reassessments for all existing employees. This requires the regular re-submission of refreshed self-declaration forms alongside updated, valid police clearance verifications.

12. DIGITAL SAFETY & ONLINE CONDUCT PROTOCOLS

  1. Ban on Private Digital Communication: Staff members are strictly prohibited from forming private digital connections, friendships, or socializing with current students across personal social media accounts (e.g., Instagram, Facebook, personal Snapchat, or private WhatsApp).
  2. Mandated Official Communication Channels: All digital communication regarding academics, school schedules, or institutional events shall take place exclusively through approved school platforms or official parent-teacher communication networks.
  3. Cyber Concerns Classified as Child Protection Issues: Acts of cyberbullying, online grooming, digital harassment, sextortion, or the unconsented sharing of inappropriate/explicit content involving minors shall be treated strictly as child protection concerns, triggering immediate CPC evaluation.
  4. Digital Citizenship Integration: Students across all grade levels shall receive regular, age-appropriate digital citizenship education, focusing on digital boundaries, data privacy, online risks, and healthy communication.
  5. Media and Photography Protocols: The school will closely monitor all media involving photographs or videos of students. No staff member or visitor may photograph or film students using personal devices without explicit administrative permission and parent consent. For public posts, any student visible in the background must be blurred out or rendered unidentifiable before publication.

13. PHYSICAL CAMPUS & TRANSPORT SAFETY

  1. Strategic Infrastructure Surveillance: Continuous monitoring via CCTV cameras will be maintained in high-risk common areas, corridors, entry/exit points, and school bus interiors.
  2. Restroom Segregation: Washroom facilities shall remain strictly segregated between staff and students, with student washrooms monitored externally by designated floor attendants.
  3. The Visible Door/Window Rule: All one-on-one remedial classes, music lessons, counseling sessions, or sports coaching clinics must occur in visible spaces.
  4. Autonomous Student Reporting Channels: The school will deploy secure, physical VR4U Drop-Boxes in unmonitored common areas (near counselor offices or library corridors). These secure boxes allow students to drop anonymous safety flags or POCSO/CSA complaints, and they shall be opened exclusively by the Principal/Counselor on a bi-weekly basis.
  5. Transport Safety Mandates:
    • Trained Female Attendants: The school mandates the presence of a trained female attendant or female teacher on all applicable bus routes, subject to operational feasibility.
    • Technical Standards: All school buses must be equipped with functional GPS tracking systems and interior CCTV cameras, monitored regularly by the transport security officer.

14. ANNUAL REVIEW CLAUSE

Policy Review Mandate: This Child Protection and POCSO Compliance Policy shall be reviewed annually by the centralized Child Protection Committee at the close of every academic year. It shall be continuously updated and amended whenever required to remain in lockstep with shifting statutory Indian laws, Supreme Court precedents, and global child safety best practices.

CLOSING STATEMENT

Arya Vidya Mandir Group of Schools is committed to cultivating a culture where every child feels safe, respected, heard, and empowered. Child protection is not merely a legal obligation, but a collective responsibility shared by every single member of our community.