Policy working drafts — EF Legacy International Online School

Academic Integrity Policy

# Academic Integrity Policy — Draft v0.2

## Standard
Learners must submit work that truthfully represents their own knowledge, effort and permitted collaboration.

## Prohibited conduct
Plagiarism, contract cheating, unauthorised AI-generated submission, impersonation, collusion, fabricated data, unauthorised materials, answer sharing and interference with assessment systems are prohibited.

## AI
AI tools may be used only where a teacher or assessment instruction permits them. Learners must disclose material AI assistance where required. AI must not be used to impersonate a learner or defeat an assessment's purpose.

## Prevention
The School teaches citation, research, source evaluation, responsible AI use and assessment rules. Assessment design may use question variation, oral follow-up, drafts, process evidence and time controls.

## Investigation
Concerns are documented and reviewed by authorised academic staff. Learners are given an opportunity to respond. Evidence, context, age and seriousness are considered.

## Outcomes
Possible outcomes include education/correction, resubmission, mark adjustment where permitted, formal warning, reassessment or disciplinary action. External awarding-body rules apply where relevant.

## Privacy
Monitoring must be lawful, proportionate and disclosed. Safeguarding and privacy override unnecessary surveillance.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic coordinator. A named, verified role-holder and deputy must be recorded before operation.

1. Explain permitted collaboration, sources and AI use for each task before learners submit it.
2. Review suspicious work using drafts, task history and an opportunity for the learner to explain; an automated detector is not a decision.
3. Document findings and proportionate outcomes with an appeal route; do not publicly accuse or shame a learner.

Required evidence: dated case or activity record, responsible person, decision and rationale, restricted supporting evidence, next action and review date. Record only information needed for the policy purpose. Relevant authority and qualified professional review remain required before adoption.

Review triggers: a material incident, change in law or regulator instructions, a failed control test, or the scheduled review date. Changes create a new version; previous decisions and versions are retained in the audit record.

Accessibility / Inclusion Policy

# Accessibility / Inclusion Policy — Draft v0.2

## Commitment
The School aims to remove avoidable barriers to participation and make reasonable, lawful adjustments based on learner need and programme requirements.

## Platform
Core learning functions should support keyboard navigation, semantic structure, screen readers, captions/transcripts where available, readable text and responsive/mobile access.

## Learning materials
Documents should use accessible headings, text alternatives where relevant and formats that do not rely solely on colour or images. Low-bandwidth/downloadable alternatives are provided where licensing allows.

## Accommodations
Approved accommodations may include extended time, breaks, alternative formats, adjusted schedules and other arrangements consistent with learning outcomes and external awarding-body rules.

## Connectivity/device barriers
Support may include asynchronous alternatives, compressed resources, catch-up plans and reasonable submission flexibility.

## External examinations
Access arrangements for Cambridge or other external examinations require the awarding body/exam centre's own approval and deadlines; internal accommodations do not automatically transfer.

## Confidentiality
Accommodation information is shared only with staff who need it to deliver the adjustment.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Learning support lead / EdTech lead. A named, verified role-holder and deputy must be recorded before operation.

1. Ask about functional learning barriers through an appropriate private route and agree reasonable support.
2. Check keyboard access, readable structure, plain-text alternatives, mobile layout and low-bandwidth delivery; record actual test results.
3. Review whether the adjustment enables the intended learning or assessment; escalate formal exam arrangements through the approved centre.

Admissions Policy

# Admissions Policy — Draft v0.2

## Purpose
EF Legacy International Online School will use a fair, documented and human-reviewed admissions process. Payment alone never creates admission or enrolment.

## Scope
This policy applies to enquiries, applications, baseline/placement assessment, academic review, offers, waitlisting, conditional acceptance, enrolment and withdrawal.

## Principles
- Applications are assessed against programme readiness, age/academic history, prior curriculum, subject suitability, language/access needs and the School's capacity to support the learner.
- The School does not discriminate unlawfully and will consider reasonable accommodations and access needs.
- Regulatory status and programme availability must be verified before formal enrolment opens.
- Cambridge-pathway applications remain preparation-only until the applicable approval/authorisation and delivery-readiness gates are satisfied.

## Required evidence
Applications may request identity, date of birth, previous school/curriculum, academic reports, learning needs, language information, guardian/emergency details and technology/internet access. Only information necessary for admissions and education is collected.

## Review
Admissions decisions are made by authorised staff. Possible outcomes are: documents pending, baseline assessment required, academic review, accepted, conditionally accepted, waitlisted or declined. Reasons and review notes must be recorded internally.

## Offers and enrolment
An offer must identify the programme, conditions, fees if applicable, subject conditions and response date. A learner becomes enrolled only after offer acceptance, required documentation, programme availability and all legal/regulatory gates are satisfied.

## Appeals
Applicants may use the School's Appeals or Complaints process. Decisions must not be altered merely because a payment was made.

## Records
Admissions records are retained securely under the Privacy/POPIA and Data Retention policies.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Registrar / academic principal. A named, verified role-holder and deputy must be recorded before operation.

1. Check authorisation before accepting a formal application; verify identity, guardian authority where applicable and required documents.
2. Use a baseline and academic review to record a reasoned placement recommendation; give the applicant missing-document and decision notices.
3. Retain the review, offer conditions and enrolment decision separately; no paid enrolment before applicable launch gates open.

Anti-Bullying Policy

# Anti-Bullying Policy — Draft v0.2

## Definition
Bullying is repeated or serious harmful behaviour involving power imbalance or intimidation and may occur through messages, social spaces, live lessons, exclusion, impersonation or distribution of harmful content.

## Reporting
Learners and guardians can report bullying to staff or through designated support/safeguarding routes. Retaliation is prohibited.

## Response
The School preserves relevant evidence, assesses immediate safety, supports affected learners and investigates proportionately. Safeguarding escalation is used where risk is serious.

## Intervention
Responses may include boundaries, restorative work where safe, behaviour consequences, supervision, support plans and referral to external authorities where required.

## Privacy
The School shares outcomes only to the extent appropriate; one family does not receive another learner's confidential records.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Safeguarding lead / academic principal. A named, verified role-holder and deputy must be recorded before operation.

1. Receive and record reports, protect affected learners and assess the risk of further contact.
2. Review patterns and evidence without requiring the affected learner to confront the alleged aggressor.
3. Record safety measures, accountable outcomes and a follow-up check; escalate threats or abuse through safeguarding channels.

Appeals Policy

# Appeals Policy — Draft v0.2

## Scope
This policy covers eligible appeals against specified academic, admissions, disciplinary or administrative decisions. It does not replace external awarding-body appeal procedures.

## Grounds
An appeal should identify procedural error, material new evidence, unreasonable application of policy or another recognised basis. Disagreement alone may not be sufficient.

## Submission
Appeals are submitted within the stated timeframe, identify the decision challenged and provide supporting evidence.

## Independence
Where practical, the reviewer must not be the person who made the original decision. Conflicts of interest are disclosed.

## Outcome
The reviewer may uphold, vary, remit for reconsideration or overturn the decision where authorised. Reasons are recorded and communicated.

## External examinations
Cambridge or other awarding-body enquiry/appeal rules, deadlines and fees apply to external examination results and prevail over internal procedure.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic principal / independent reviewer. A named, verified role-holder and deputy must be recorded before operation.

1. Check the appealed decision, grounds and relevant records; acknowledge receipt without prejudging the outcome.
2. Appoint a reviewer who was not the original decision-maker where practicable and record any unavoidable conflict.
3. Give the reviewed decision and reasons, correct affected records where necessary and preserve the original audit history.

Assessment Policy

# Assessment Policy — Draft v0.2

## Purpose
Assessment supports learning, determines progress and provides defensible evidence of achievement.

## Assessment model
The School may use diagnostic, formative and summative assessment, assignments, projects, tests, oral work, practical work, coursework, mock examinations and internal examinations where appropriate to the subject.

## Design
Every assessment must record purpose, learning outcomes, date/window, duration, instructions, allowed materials, rubric/mark scheme, submission rules and any approved accommodation.

## Marking and moderation
Teachers mark against approved criteria. High-stakes internal assessments and samples of routine work are subject to moderation according to the Marking and Moderation Policy. Marks may not be altered without traceable reason and audit history.

## Feedback
Learners receive timely feedback that identifies strengths, misconceptions and next steps. Feedback should support improvement rather than merely report a number.

## Access and accommodations
Approved accommodations, including extended time or alternative arrangements, are applied consistently and recorded without exposing unnecessary sensitive information.

## External qualifications
Internal assessment and online proctoring do not replace Cambridge or other awarding-body final-examination requirements. External requirements prevail where applicable.

## Integrity and records
Identity confirmation, declarations, session evidence and originality checks may be used where lawful and proportionate. Assessment records, submissions, marks, moderation and appeals are retained in the academic record.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic coordinator / subject teacher. A named, verified role-holder and deputy must be recorded before operation.

1. Prepare a purpose, skill map, original task, timing, allowed resources and marking criteria before release.
2. Record accommodations and authenticity checks; give criterion-linked feedback and a practical next learning action.
3. Escalate disputed marks through moderation and appeals; keep an assessment version and an authorised evidence trail.

Attendance Policy

# Attendance Policy — Draft v0.2

## Purpose
Attendance in an online school includes meaningful participation, not merely logging in.

## Expectations
Learners are expected to attend scheduled live lessons where required, complete asynchronous learning, submit required work and respond to reasonable teacher contact.

## Recording
Attendance may record present, late, excused absence, unexcused absence and asynchronous participation. Technical failure must not automatically be treated as misconduct.

## Absence
Guardians/learners should notify the School of illness, travel, connectivity failure or other significant absence. Staff record the reason only to the extent necessary.

## Intervention
Patterns of absence trigger contact and, where needed, a support or catch-up plan. The School considers health, disability, unstable connectivity, travel/sport commitments and safeguarding context.

## Catch-up
Recorded lessons where authorised, notes, downloadable resources, alternative tasks and teacher support may be used to restore learning continuity.

## Escalation
Persistent unexplained absence is escalated to academic leadership and, where safeguarding concerns arise, to the designated safeguarding function.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Registrar / teacher. A named, verified role-holder and deputy must be recorded before operation.

1. Record attendance against the actual scheduled learning event; distinguish live attendance from submitted asynchronous work.
2. For a missed event, check the reason through an authorised contact and agree a catch-up action.
3. Repeated absence triggers documented support and safeguarding consideration; do not treat a platform login as proof of participation.

Behaviour Policy

# Behaviour Policy — Draft v0.2

## Expectations
Learners are expected to treat others respectfully, participate honestly, use technology responsibly and follow reasonable staff instructions related to learning and safety.

## Online conduct
Harassment, threats, discriminatory abuse, sexual misconduct, doxxing, impersonation, deliberate disruption, cyberbullying and attempts to compromise systems are prohibited.

## Responses
Behaviour responses should be proportionate, educational and age-appropriate. Possible steps include conversation, restorative action, warning, support plan, restricted feature access, disciplinary review or suspension/withdrawal where lawfully justified.

## Context
Disability, learning needs, safeguarding context and reasonable accommodations are considered before conclusions are drawn.

## Fairness
Serious consequences require recorded evidence, an opportunity to respond and an appeal route where applicable.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Teacher / academic principal. A named, verified role-holder and deputy must be recorded before operation.

1. Explain expected behaviour, teaching context and proportional responses before an incident occurs.
2. Record the behaviour and its effect, hear relevant accounts and consider support or accessibility needs.
3. Apply an explained response and review it; route safeguarding concerns separately and avoid public humiliation.

Business Continuity Policy

# Business Continuity Policy — Draft v0.2

The School plans for disruption to platform access, connectivity, staffing, supplier availability, examination arrangements, facilities/administration and key third-party services.

Critical priorities are learner safety, communication, preservation of records, continuity of scheduled learning where feasible, assessment integrity and restoration of essential systems.

Continuity measures may include asynchronous resources, alternative communication channels, timetable adjustment, substitute teaching arrangements, controlled exports/backups and manual contingency processes.

Responsibilities, contact chains and recovery priorities are reviewed at least annually and after material incidents. A disruption does not justify bypassing safeguarding, privacy or examination rules.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic principal / operations lead. A named, verified role-holder and deputy must be recorded before operation.

1. Identify essential teaching, safeguarding, communication and finance functions and their dependencies.
2. Prepare an outage alternative with plain-text work, authorised contact routes and realistic recovery priorities.
3. Run a documented exercise, record what failed and improve the plan; a written plan is not evidence that a recovery test passed.

Child Protection Policy

# Child Protection Policy — Draft v0.2

## Purpose
This policy defines the School's response where there is reasonable concern that a child may have experienced or be at risk of abuse, neglect, exploitation or grooming.

## Reporting
Staff record factual observations, disclosures and actions promptly. They do not promise absolute secrecy, interrogate the child or contact an alleged perpetrator in a way that could increase risk.

## Escalation
Concerns are referred immediately to the designated safeguarding/child-protection role. That role determines lawful referral to guardians, emergency services, social services or other authorities, taking account of whether guardian contact could itself create risk.

## Digital evidence
Relevant messages, recordings, files or system logs may be preserved lawfully. Access is restricted.

## Staff allegations
Allegations involving staff are escalated outside the direct reporting line where necessary and managed with child safety, fairness, confidentiality and applicable law in view.

## Learner support
The School maintains educational continuity and appropriate support without requiring the learner to repeatedly recount traumatic details.

## Records
Child-protection records are separate from routine learner records and retained under restricted-access rules.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Designated safeguarding lead / recruitment lead. A named, verified role-holder and deputy must be recorded before operation.

1. Complete required checks and verify the responsible adult’s role before child-facing work begins.
2. Use approved contact channels, visibility and boundaries for interactions; avoid unsupervised private communication outside authorised arrangements.
3. Record and escalate concerns through the safeguarding process; a clean check does not replace supervision.

Complaints Policy

# Complaints Policy — Draft v0.2

## Purpose
EF Legacy provides a fair route for learners, guardians, staff and stakeholders to raise concerns without retaliation.

## Informal resolution
Where appropriate, concerns should first be raised with the staff member or function closest to the issue. Informal resolution is not required for safeguarding, harassment, serious misconduct or conflicts of interest.

## Formal complaint
A formal complaint should identify the concern, relevant dates, people involved, evidence and desired resolution. The School records receipt and assigns an impartial reviewer.

## Process
The reviewer gathers relevant information, protects confidentiality on a need-to-know basis and gives affected parties an opportunity to respond. Safeguarding matters are diverted to safeguarding procedures.

## Outcome
The complainant receives a reasoned outcome to the extent privacy permits. Actions may include correction, explanation, service improvement, staff action or referral to another process.

## Escalation
Where permitted, unresolved complaints may be escalated to senior leadership or the Appeals process. External rights are not removed by this procedure.

## Records
Complaint records are access-controlled and used for trend analysis without exposing unnecessary personal detail.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Registrar / governing body delegate. A named, verified role-holder and deputy must be recorded before operation.

1. Acknowledge the issue, check conflicts of interest and identify the appropriate investigator.
2. Record the evidence, requested resolution and response timeframe; use an independent route for complaints about the investigator.
3. Issue a reasoned outcome and escalation route; urgent safeguarding concerns go directly to the safeguarding process.

Copyright / Content Licensing Policy

# Copyright / Content Licensing Policy — Draft v0.2

## Principle
EF Legacy uses original, openly licensed, lawfully purchased or permission-based content.

## Third-party materials
Staff must verify the licence or permitted educational use before uploading, reproducing, adapting or distributing copyrighted materials.

## Cambridge/publisher resources
Official syllabuses may be linked from authoritative sources. Copyrighted textbooks, past papers, mark schemes and publisher digital books are not republished or sold as EF Legacy stock unless the applicable rights/permissions and supplier relationship are verified.

## Learner work
Learners retain rights in their original work subject to agreed educational-use permissions. Public display requires appropriate permission.

## AI
AI-generated or assisted material must not be assumed copyright-clear. Human review and source checks are required.

## Takedown
Potential infringement is investigated and access may be suspended while rights are clarified.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Resource custodian / academic coordinator. A named, verified role-holder and deputy must be recorded before operation.

1. Record the source, rights holder and permitted use for each third-party resource.
2. Link to authoritative public material where appropriate; distribute copies only under verified permission or a valid applicable basis.
3. Review licences and expiry before continued delivery; original EF Legacy resources do not imply endorsement by an examination body.

Data Retention Policy

# Data Retention Policy — Draft v0.2

## Purpose
Records are retained for legitimate educational, legal, safeguarding, financial, regulatory and operational needs, then securely deleted or anonymised when no longer required.

## Categories
Retention schedules distinguish learner academic records, admissions, assessment evidence, finance, contracts, staff files, safeguarding records, communications, security logs and regulatory evidence.

## Holds
Deletion is suspended where records are subject to a dispute, safeguarding matter, legal hold, audit or active regulatory requirement.

## Minimisation
Temporary uploads, duplicate working files and unnecessary copies should not be retained indefinitely.

## Deletion
Deletion/anonymisation must be authorised and auditable. Backups expire through controlled lifecycle processes rather than ad hoc manual deletion.

## Safeguarding
Safeguarding records follow their own restricted retention requirements and are not automatically deleted merely because a learner leaves.

## Review
Retention periods are reviewed against South African law, regulator/awarding-body requirements and contractual obligations before publication.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Information officer / records custodian. A named, verified role-holder and deputy must be recorded before operation.

1. Maintain a record-category schedule with a justified retention period, responsible custodian and disposal method.
2. Before disposal, check statutory requirements, disputes, safeguarding needs and any preservation instruction.
3. Log authorised disposal and verify copies and backups are handled under the approved schedule; unresolved periods require review, not guessing.

Disaster Recovery Policy

# Disaster Recovery Policy — Draft v0.2

## Scope
Covers restoration of critical digital services and records after severe technical failure, data loss, security incident or provider outage.

## Priorities
1. Authentication/security containment
2. Learner/safeguarding-critical records
3. Admissions/SIS/LMS and communications
4. Assessment/grade records
5. Finance/payment reconciliation
6. Content and non-critical services

## Recovery
Recovery uses documented infrastructure/deployment sources, managed backups where available and verification before services are reopened.

## Integrity
Restored data is checked for completeness and unauthorised change. Payment and assessment records receive additional reconciliation.

## Testing
Recovery assumptions should be tested periodically. Results and remediation actions are recorded.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: EdTech lead / records custodian. A named, verified role-holder and deputy must be recorded before operation.

1. Define backup scope, protected access, restoration priorities and reviewable recovery objectives.
2. Perform an authorised restoration test on appropriate non-production or controlled data; verify integrity and role restrictions.
3. Record timing, gaps and corrective actions; do not mark recovery capability verified without a completed test.

Online Safety / eSafety Policy

# Online Safety / eSafety Policy — Draft v0.2

## Purpose
The School uses technology for learning while reducing risks from inappropriate contact, content, conduct and commercial exploitation.

## Accounts and access
Users must use their own accounts, protect credentials and follow role-based access rules. Account sharing and attempts to access another person's records are prohibited.

## Communication
School learning and support communication should use approved channels. Staff maintain professional boundaries and do not solicit private/off-platform contact with minors except through approved emergency processes.

## Live lessons and recordings
Recording must be purposeful, disclosed and access-controlled. Learners must not redistribute recordings or screenshots without permission.

## Content and communities
Harassment, sexual content involving minors, hate, threats, doxxing, scams and harmful exploitation are prohibited. Reporting routes must be visible.

## AI and third-party tools
Tools are assessed for privacy, age suitability, educational purpose and data handling. Learner data should not be uploaded into unapproved services.

## Incidents
Security or online-safety incidents are reported, contained, documented and escalated to safeguarding or information-security functions as appropriate.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: EdTech lead / safeguarding lead. A named, verified role-holder and deputy must be recorded before operation.

1. Configure approved learning tools, age-appropriate access, moderation and clear reporting routes before use.
2. Teach learners how to report unwanted contact, harmful content or account compromise without forwarding harmful material unnecessarily.
3. Preserve necessary evidence safely, restrict immediate exposure and route each incident to technical and safeguarding owners as appropriate.

Financial / Fees Policy

# Financial / Fees Policy — Draft v0.2

## Publication
School fees are published only after approval. Draft/provisional figures are not payable fees.

## Separation
EF Legacy tuition, application/registration fees, Academy course fees, textbooks and third-party examination/assessment-centre costs are recorded separately.

## Invoicing
Invoices identify learner/customer, fee item, period, currency, due date, discounts/scholarships and payment reference.

## Admissions
Payment does not guarantee admission. Where an application fee is used, its purpose and refundability are disclosed before payment.

## Payment plans
Monthly, term or annual arrangements may be offered where approved. Late-payment processes must be proportionate and should not expose learner financial information.

## External costs
The School does not mark an external examination fee as its own tuition. Changes imposed by a third party are communicated transparently.

## Financial control
Refunds, adjustments and discounts require authorised records and audit trails.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Finance administrator / governing body. A named, verified role-holder and deputy must be recorded before operation.

1. Publish only adopted fees under verified school authorisation; distinguish tuition, resources and external examination costs.
2. Record the correct legal entity, invoice reference, concessions, due dates and verified payment state.
3. Handle disputes, arrears and changes under the real agreement and applicable obligations; no invented tax or deductibility treatment.

Information Security Policy

# Information Security Policy — Draft v0.2

## Objectives
Protect confidentiality, integrity and availability of learner, staff, financial, safeguarding and organisational information.

## Access control
Authentication, role-based access and row-level security are used. High-risk owner/security functions require stronger authentication where configured. Users receive least privilege.

## Secrets
API keys, OAuth tokens and passwords are not stored in browser-visible code or ordinary database fields. Secret references and server-side environments are used.

## Logging
Significant administrative, payment, permission and regulated-record actions are auditable. Logs are protected against ordinary user alteration.

## Vulnerability/patching
Dependencies, infrastructure and security findings are reviewed and remediated according to risk. Production changes pass controlled build/deployment checks.

## Incidents
Security events are contained, evidence preserved, affected credentials rotated where necessary, impact assessed and privacy/breach procedures triggered when applicable.

## Backups/continuity
Critical records use managed storage/database resilience and documented recovery procedures.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: EdTech lead / information officer. A named, verified role-holder and deputy must be recorded before operation.

1. Assign least-privilege access, require appropriate account protection and keep privileged credentials out of public clients.
2. Review access changes and logs; restrict compromised sessions and preserve relevant evidence during incidents.
3. Test controls using recorded results and follow the incident process; no statement that a system is universally secure.

Language Support Policy

# Language Support Policy — Draft v0.2

## Purpose
Language proficiency should be supported without lowering the academic integrity of a qualification.

## Identification
Admissions and baseline review may identify the learner's primary/additional languages and English-language support needs.

## Support
Support may include vocabulary development, structured reading/writing support, language scaffolds, tutoring/referral, additional practice and clear teacher feedback.

## Assessment
Language support must not give unauthorised assistance or alter external assessment rules. Translation, dictionaries or extra time are used only where permitted.

## Monitoring
Progress is reviewed and support is adjusted over time.

## Inclusion
Multilingual identity is treated as an asset. Learners should not be penalised for accent or background where those are not the assessed construct.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic coordinator / language support lead. A named, verified role-holder and deputy must be recorded before operation.

1. Identify the language demands of the task and assess the learner’s current access without equating accent with ability.
2. Provide vocabulary support, model responses and staged practice while preserving the intended skill.
3. Review work samples and adjust support; external examination language and access decisions require the relevant official process.

Learner Support Policy

# Learner Support Policy — Draft v0.2

## Model
Support is proactive, documented and matched to the learner's educational need.

## Routes
Support may include teacher office hours, academic intervention, catch-up plans, study-skills guidance, language support, technology/connectivity support, accommodations and referral to appropriate external professionals.

## Triggers
Attendance decline, repeated non-submission, assessment concerns, teacher flags, learner/guardian request or transition difficulty may trigger review.

## Plans
Where needed, a support plan records goals, actions, responsible staff, review date and outcome. Sensitive health or safeguarding details are not copied unnecessarily into ordinary support notes.

## Limits
Education support does not become medical, psychological or other regulated practice unless delivered by appropriately qualified professionals under the correct service arrangements.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Student support lead / academic coordinator. A named, verified role-holder and deputy must be recorded before operation.

1. Open a support record describing the learning barrier, agreed goal and functional support needed.
2. Assign a named lead, practical intervention, review date and consent or lawful basis for necessary sharing.
3. Review a work sample against the goal and revise support; wellbeing or protection concerns use the relevant specialist route.

Learning Material Development Policy

# Learning Material Development Policy — Draft v0.2

## Quality standard
Learning materials must align to the intended programme/syllabus, stated learning objectives, learner age/stage, accessibility needs and delivery model.

## Development cycle
Plan → author/select → academic review → copyright/licence check → accessibility review → pilot/quality check → approval → version control → scheduled review.

## Sources
Cambridge and other awarding-body specifications are used as authoritative curriculum references where applicable. EF Legacy does not reproduce copyrighted third-party material without permission.

## Digital design
Materials should support active learning rather than passive video consumption and include explanation, examples, practice, feedback opportunities and low-bandwidth alternatives where feasible.

## Versioning
Material changes are traceable. Retired materials are removed from active courses while preserving necessary audit history.

## AI
AI-assisted material must be reviewed by a competent human for accuracy, bias, copyright, age suitability and alignment before learner release.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Subject teacher / academic coordinator. A named, verified role-holder and deputy must be recorded before operation.

1. Map each resource to a learning intention and the correct syllabus version; record provenance and rights.
2. Review accuracy, examples, accessibility, task instructions and answers with a second competent reviewer.
3. Version the approved teaching material and record correction triggers; a draft sample is not a complete programme.

Marking and Moderation Policy

# Marking and Moderation Policy — Draft v0.2

## Marking
Markers use approved criteria/mark schemes and record marks and feedback in the controlled gradebook. Personal bias or undisclosed criteria must not influence outcomes.

## Standardisation
Where multiple staff assess comparable work, standardisation is used to align interpretation.

## Moderation
Moderation samples work based on assessment significance, risk and teacher/subject needs. Moderators record findings, required corrections and completion.

## Changes
Mark changes after release require a recorded reason and authorised workflow. Original evidence and audit trail are preserved.

## Conflicts
Staff declare conflicts and should not moderate their own disputed decision where an independent reviewer is available.

## External assessments
Awarding-body rules prevail for externally assessed components.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Subject teacher / moderator. A named, verified role-holder and deputy must be recorded before operation.

1. Publish criteria appropriate to the task and mark with evidence-linked reasons.
2. Independently moderate a representative sample including low, middle and high performance; resolve differences against criteria.
3. Document agreed changes and check whether the whole cohort needs remarking; preserve previous marks and appeal evidence.

Parent Code of Conduct

# Parent / Guardian Code of Conduct — Draft v0.2

Guardians support learning by maintaining accurate contact details, communicating respectfully, encouraging attendance/engagement and notifying the School of relevant barriers.

Guardians must not impersonate learners, complete assessed work for them, interfere with classes, harass staff/learners or attempt to access records of learners not legally linked to them.

Safeguarding concerns should be raised through the approved route rather than investigated independently through contact with other children.

The School respects guardian involvement while also protecting learner privacy, developmental autonomy and legal rights.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Registrar / academic principal. A named, verified role-holder and deputy must be recorded before operation.

1. Explain contact channels, privacy boundaries, response expectations and responsibilities around linked learner access.
2. Verify guardian links before sharing information; direct disagreements to the complaints process.
3. Record inappropriate contact and apply a proportionate communication plan while protecting the learner’s access to support.

Parent Communication Policy

# Parent Communication Policy — Draft v0.2

The School provides guardians with appropriate visibility into attendance, academic progress, reports, upcoming deadlines, fees/accounts and relevant announcements for learners legally linked to them.

Routine communication uses approved channels and is recorded where operationally significant.

Teachers are not expected to be continuously available; response expectations and office hours should be defined.

Sensitive safeguarding, staff HR, other learner information and confidential professional records are not disclosed through ordinary parent communication.

Changes to legal guardian authority or communication restrictions require verification before access is changed.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Registrar / teacher. A named, verified role-holder and deputy must be recorded before operation.

1. Verify the recipient’s guardian relationship and use approved contact channels.
2. Make notices clear about purpose, required action, deadline and whom to contact; record important delivery failures.
3. Escalate urgent protection concerns through safeguarding rather than ordinary newsletters or group messages.

Privacy / POPIA Policy

# Privacy / POPIA Policy — Draft v0.2

## Principles
EF Legacy processes personal information lawfully, for defined educational/operational purposes, with data minimisation, access control, accuracy, security and appropriate retention.

## Information processed
Depending on role and service, records may include identity/contact data, guardian relationships, academic records, attendance, support/accommodation information, payment/account records, communications and regulated evidence.

## Minors
Guardian consent/authority is recorded where required. Learner participation and privacy rights are respected according to age, maturity and applicable law.

## Purpose separation
Educational processing, safeguarding, contractual/payment processing and optional marketing are not treated as one blanket consent. Marketing preference is separate.

## Access
Learners, guardians, teachers, finance staff and safeguarding staff receive only the access needed for their function. Sensitive records receive stricter controls.

## Third parties
Service providers must have a lawful purpose and appropriate data protections. Data is not shared with advertisers as a condition of education.

## Rights and requests
The School maintains a process for access, correction, objection, deletion/anonymisation where lawful and related privacy requests.

## Breach response
Suspected breaches are contained, investigated, documented and escalated to the responsible information/privacy function, with notifications made where legally required.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Information officer / school administration. A named, verified role-holder and deputy must be recorded before operation.

1. Document why each data field is needed, the appropriate processing basis, access roles and notice given to the data subject.
2. Handle access, correction and deletion requests through an identity-checked register; consider applicable retention and legal holds before action.
3. Assess suspected unauthorised access promptly and follow the applicable reporting obligations; no generic promise of immediate deletion.

Refund Policy

# Refund Policy — Draft v0.2

Refund eligibility depends on the specific fee/product, timing, service already delivered, cancellation terms and applicable consumer law.

The published fee/product page must identify whether a charge is refundable, non-refundable or subject to conditions.

Approved refunds are linked to the original transaction and authorised through the finance workflow. Staff must not issue off-record cash-equivalent refunds.

Third-party examination, supplier or licensing charges may be non-refundable once committed externally; this must be disclosed where known.

This draft requires legal/consumer-law review before publication.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Finance administrator. A named, verified role-holder and deputy must be recorded before operation.

1. Check the actual payment, agreement, applicable obligations and refund reason; record a reasoned decision.
2. Use the original entity and authorised provider route, with approval and evidence before execution.
3. Confirm provider refund status and reconciliation separately from a cancelled service task; do not promise a refund that has not been processed.

Safeguarding Reporting Procedure

# Safeguarding Reporting Procedure — Draft v0.2

1. **Recognise:** notice a disclosure, observation, digital event or pattern that may indicate risk.
2. **Immediate safety:** if there is immediate danger, follow emergency/lawful protective action first.
3. **Record facts:** record what was seen/heard, date/time, people involved and immediate action. Avoid speculation.
4. **Report internally:** notify the designated safeguarding/child-protection function without unnecessary delay.
5. **Do not investigate:** staff do not interrogate the learner, confront an alleged perpetrator or promise secrecy.
6. **Decision/referral:** the safeguarding lead determines next lawful steps, including guardian contact, external referral or preservation of digital evidence.
7. **Restrict access:** case details remain in safeguarding records, not ordinary notes or group messages.
8. **Follow-up:** record actions, learner support, outcome/review and any system improvement required.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Designated safeguarding lead / deputy. A named, verified role-holder and deputy must be recorded before operation.

1. Provide an accessible private reporting route and explain when information may need to be shared for protection.
2. Record the concern, immediate safety response and designated escalation; use an alternative route for conflicts.
3. Keep access restricted and record referral, decision and follow-up; do not require a child to gather proof before reporting.

Safeguarding Policy

# Safeguarding Policy — Draft v0.2

## Commitment
The School places learner safety, dignity and welfare above convenience, reputation or operational speed.

## Scope
Safeguarding includes abuse, exploitation, neglect, harassment, grooming, online harm, self-harm concerns, unsafe adult conduct and other risks to a child or vulnerable learner.

## Roles
A designated safeguarding/child-protection role coordinates concerns, referral and record control. All staff have a duty to report concerns through the approved route and must not conduct amateur investigations.

## Immediate danger
Where a learner may be in immediate danger, emergency and lawful child-protection processes take priority. Staff preserve evidence and escalate without unnecessary delay.

## Online environment
Live classes, messaging, recordings, one-to-one contact, file sharing and community features must use approved channels and boundaries. Staff must not move learner relationships into private informal channels contrary to policy.

## Records
Safeguarding records are restricted from ordinary academic, finance and general administrative dashboards. Access is need-to-know and auditable.

## Recruitment and training
Relevant roles require identity/qualification verification, background/child-protection checks where lawful/applicable, code-of-conduct acknowledgement and safeguarding training.

## Review
Incidents and near misses are reviewed for systemic improvement without exposing confidential case detail.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Designated safeguarding lead / deputy. A named, verified role-holder and deputy must be recorded before operation.

1. Receive a concern privately, record the reporter’s words accurately and assess immediate safety needs.
2. Follow the applicable reporting and referral obligations through the designated lead; do not investigate beyond competence or promise absolute secrecy.
3. Restrict access, record referrals and follow-up, and use a separate route if the concern involves the designated lead.

Staff Code of Conduct

# Staff Code of Conduct — Draft v0.2

## Professional standard
Staff act honestly, competently, respectfully and within the boundaries of their role, qualifications and authority.

## Learner boundaries
Staff maintain professional communication, avoid sexual/romantic conduct with learners, do not exploit power imbalances and use approved channels for contact with minors.

## Safeguarding
Concerns are reported promptly. Staff do not suppress concerns to protect reputation or colleagues.

## Confidentiality
Learner, family, staff and business information is accessed only for legitimate work and shared on a need-to-know basis.

## Assessment
Staff do not fabricate marks, manipulate records, provide unauthorised assessment assistance or conceal conflicts of interest.

## Technology/AI
Staff protect credentials, use approved systems and do not upload confidential learner data into unapproved AI or third-party tools.

## Gifts/conflicts
Conflicts, inducements or relationships that could compromise professional judgement are disclosed.

## Breach
Serious breaches may result in investigation, access restriction, disciplinary action, referral to a professional body or lawful authority.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic principal / HR custodian. A named, verified role-holder and deputy must be recorded before operation.

1. Brief staff on confidentiality, appropriate contact, conflicts, boundaries and use of authorised systems.
2. Require disclosure of conflicts and concerns; use a private reporting route for alleged misconduct.
3. Document investigation and outcomes fairly; suspend unsafe access when necessary without representing an allegation as a proven fact.

Staff Development / CPD Policy

# Staff Development / CPD Policy — Draft v0.2

The School maintains a CPD record for relevant staff and plans development according to subject changes, pedagogy, online teaching, safeguarding, accessibility, assessment, moderation, technology and leadership needs.

New staff receive induction into systems, privacy, eSafety, safeguarding, assessment integrity and role boundaries.

CPD may include internal training, external courses, awarding-body training, professional reading, moderation/standardisation and peer development.

Completion evidence, provider, date, topic and renewal/next-review requirements are recorded where relevant. CPD does not substitute for required qualifications or professional registration.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic principal / staff member. A named, verified role-holder and deputy must be recorded before operation.

1. Identify a specific teaching or operational gap from evidence and set a development goal.
2. Record training or practice activity, participation evidence and how the staff member will apply it.
3. Review a subsequent work sample or observed practice; attendance at training alone does not establish improved competence.

Staff Recruitment Policy

# Staff Recruitment Policy — Draft v0.2

## Safer recruitment
Recruitment for roles involving learners prioritises competence, integrity and child safety.

## Verification
Before final appointment where applicable, the School verifies identity, qualifications, relevant teaching/subject competence, employment history/references, professional registrations such as SACE where relevant, and required background/child-protection checks.

## Records
Verification status and evidence references are stored in restricted staff records. Unverified credentials are never presented publicly as verified.

## Selection
Role requirements are documented. Interviews and assessments consider online-teaching capability, safeguarding understanding, subject knowledge and learner-centred practice.

## Appointment
A proposed staff record is not an appointment. Access is granted only after authorised approval and according to least privilege.

## Ongoing duty
Staff must disclose changes affecting professional registration, legal eligibility or safeguarding suitability.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: HR custodian / academic principal. A named, verified role-holder and deputy must be recorded before operation.

1. Define the role and workload; obtain genuine identity, qualification, experience and registration evidence where required.
2. Complete applicable safeguarding and criminal checks, references and competence review before child-facing assignment.
3. Record appointment, restrictions, expiry reviews and induction; do not publish a person as verified before checks are complete.

Student Code of Conduct

# Student Code of Conduct — Draft v0.2

Learners agree to:
- participate respectfully in live and asynchronous learning;
- protect account credentials and use only their own identity;
- submit honest work and follow assessment/AI rules;
- respect privacy, copyright and other learners' dignity;
- avoid bullying, hate, threats, sexual harassment, scams, doxxing and system interference;
- use communication channels for educational purposes;
- report safety concerns or harmful conduct;
- comply with reasonable exam, attendance and safeguarding instructions.

Responses to breaches are proportionate and follow the Behaviour/Academic Integrity processes. Learners retain the right to raise concerns or appeal eligible decisions.

## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Teacher / registrar. A named, verified role-holder and deputy must be recorded before operation.

1. Explain respectful participation, academic honesty, privacy and reporting routes in accessible language.
2. Record concerns using behaviour-specific descriptions and give the learner an opportunity to respond.
3. Agree support and proportionate consequences under adopted policies; retain review and appeal routes.

Teacher Performance Review Policy

# Teacher Performance Review Policy — Draft v0.2

## Purpose
Performance review supports teaching quality, learner outcomes and professional growth.

## Evidence
Review may consider lesson planning, observation, learner work, marking/feedback quality, attendance/engagement data, progress patterns, moderation outcomes, professional conduct, safeguarding compliance and CPD.

## Fairness
Single metrics are not used in isolation. Context, class profile and support needs are considered.

## Cycle
Teachers receive clear expectations, review discussion, strengths, development priorities and follow-up dates. Serious conduct or safeguarding matters follow the appropriate separate process.

## Improvement
Where concerns exist, a documented improvement/support plan sets actions, resources, responsibility and review dates.


## Operational procedure — working draft 0.2

Status: prepared for adoption review; no approval, appointment, legal opinion or operating result is asserted.

Accountable role: Academic principal / teacher. A named, verified role-holder and deputy must be recorded before operation.

1. Agree role expectations, workload and a review method before evaluating performance.
2. Use teaching plans, feedback, moderated work and learner support evidence; hear the teacher’s account and contextual constraints.
3. Record strengths, specific development actions, support and a review date without exposing learner or staff private records publicly.

Required evidence: dated case or activity record, responsible person, decision and rationale, restricted supporting evidence, next action and review date. Record only information needed for the policy purpose. Relevant authority and qualified professional review remain required before adoption.

Review triggers: a material incident, change in law or regulator instructions, a failed control test, or the scheduled review date. Changes create a new version; previous decisions and versions are retained in the audit record.

School policy working drafts · version 0.2

Academic Integrity Policy

Accessibility / Inclusion Policy

Admissions Policy

Anti-Bullying Policy

Appeals Policy

Assessment Policy

Attendance Policy

Behaviour Policy

Business Continuity Policy

Child Protection Policy

Complaints Policy

Copyright / Content Licensing Policy

Data Retention Policy

Disaster Recovery Policy

Online Safety / eSafety Policy

Financial / Fees Policy

Information Security Policy

Language Support Policy

Learner Support Policy

Learning Material Development Policy

Marking and Moderation Policy

Parent Code of Conduct

Parent Communication Policy

Privacy / POPIA Policy

Refund Policy

Safeguarding Reporting Procedure

Safeguarding Policy

Staff Code of Conduct

Staff Development / CPD Policy

Staff Recruitment Policy

Student Code of Conduct

Teacher Performance Review Policy