ELC strives to be transparent with how we collect and use information we gather about you on this site. Your privacy is important to us.

This Privacy Statement explains how ELC uses personal information and applies to all users who access, view, visit, download, or otherwise interact with www.elcmy.edu.my  (the Site). By visiting the Site, you are accepting the practices described in this Privacy Statement. If you do not agree to these practices, do not access, view, visit, download, or otherwise interact with the Site. If you have any questions or comments concerning ELC’s Privacy Statement, please contact us by sending an email to info@elcmy.edu.my. You can also contact us via mail at: Unit 3.01, 3^rd Floor, Wisma Bukit Bintang, No. 28 Jalan Bukit Bintang, 55100, Kuala Lumpur.

ELC Malaysia is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

ELC Malaysia may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1^st July 2019.

What we collect

Personal Information is information that can be used to identify, locate, or contact an individual. ELC collects the following types of Personal Information:

Contact Information: Contact Information allows ELC to communicate with you. Examples of Contact Information include, but are not limited to, your name, accurate postal addresses, valid email address, or other addresses at which you receive communications from or on behalf of ELC.

Transaction Information: ELC automatically receives and records some information from your browser when you visit the site, such as your IP address, cookies and data about which pages you visit on the site through the use of log files provided by our third-party tracking-utility partners. This information helps us analyze and understand how the site works for users. Information that is gathered includes, but is not limited to, information about how you interact with ELC, information about how you use ELC’s sites, email, other communications, and applications, and how you interact with other users.

Posted Information: If you chose to post a comment on our blog, we may collect information regarding your name and the content of your post. It is important to note that any content you post on the blog is publicly displayed and will be seen by other users of the Site.

How ELC Collects Personal Information

• ELC prompts you to provide Personal Information (including Contact Information) when you interact with the Site or contact ELC
• ELC collects Transaction Information when you use the Site. For example, ELC may track the pages you view, the methods of communication that may be offered on or through the Site from time to time. ELC uses cookies and related technologies to collect information about your computer and your interaction with the Site and our partner websites.
• ELC also collects Transaction Information when you contact ELC via telephone, email, or other methods of communication.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and for the following reasons:

• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
• We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computers hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at info@elcmy.edu.my

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Policy and Procedures for safeguarding the welfare of students

1. Overview

ELC recognises its responsibility with respect to safeguarding the welfare of any young person, vulnerable adult and indeed all students that may be attending ELC. ELC is committed to maintaining a safe and supportive environment and to ensuring that all staff and host families accept and recognize their responsibilities in this regard.

The purpose of this policy is to:

• Provide protection to all students and in particular the young people and vulnerable adults attending ELC
• Provide staff and host families with guidance on procedures they should adopt in the event that they suspect a young person or vulnerable adult may be experiencing or be at risk of harm.
• Avoid making staff or host families vulnerable to suspicion of any form or abuse

The policy applies to all Directors, staff and host families of ELC.

2. Policy details

ELC seeks to safeguard children, young people and vulnerable adults by:

• Informing students of their rights and ensuring they are familiar with safeguarding procedures
• Ensuring students are aware of personal safety measures in particular regarding accommodation, transport and nightlife
• Holding interviews with students on a regular basis
• Ensuring that all applicants for positions at ELC are interviewed and asked to provide at least two references (and ensuring that all references are followed up)
• Ensuring that all new employees are subject to a probationary period of no more than 12 weeks and ongoing employment will only be offered if ELC is confident that the applicant can be safely entrusted with young people and vulnerable adults.
• Ensuring that all ELC staff are given and induction and regular training to ensure that they recognise the symptoms of possible abuse and understand how they should respond to any suspicions of abuse
• Acting promptly, professionally and confidentially to any concerns
• Reviewing the policy on an annual basis or more frequently should this be deemed as required
• Appointing a Safeguarding Officer (Anne Ang) and ensuring that staff and students are informed of her role

3. Safeguarding Officers Duties:

• Responsibility for safeguarding young people and vulnerable adults at ELC
• Ensuring that all staff (in liaison with the Director of Studies), are familiar with the ELC Safeguarding Policy and Procedures and know how to respond to suspicions or allegations
• Ensuring that the safety information provided to students staying in ELC apartments and other accommodation is up to date
• Ensuring that all incidents are sensitively, confidentially and promptly responded to; fully recorded and reported to the management team as appropriate and at the earliest opportunity
• Informing the relevant authorities of any allegations of serious harm or abuse by any person living or working with, or looking after young people or vulnerable adults

4. Staff Communications and Training

The following information is provided to staff during inductions and ongoing training and orientation.

a) Identifying abuse:

ELC recognizes that it can be difficult to identify abuse as it has various forms. However, below are some typical indicators to watch for:

• unexplained injuries
• student describing an abusive act that has happened to them
• another student telling you of their concern about a friend / fellow student
• sexually explicit behaviour in games / activities
• serious distrust of adults or other students
• difficulty in making friends / socialising with other students
• personality changes and behavioural changes
• changes in dress which may be covering up bruises etc.
• avoiding sports etc. when previously they have been participants

b) Reacting to suspicions of abuse:

• Remain calm and receptive while listening carefully
• Communicate with the student in a way that is appropriate to their age and level of comprehension
• Be aware of your body language and any non-verbal messages you are giving
• Make it clear that you are taking the concern seriously
• Reassure them that they are doing the right thing in telling you about it
• Reassure them that they should not feel guilty
• Let them know that you are going to do everything you can to help them and what may happen as a result
• Do not promise to keep the information a secret

5. Procedures

a) Procedure to follow if abuse is suspected:

Inform the ELC Safeguarding Officer if:

• you notice any significant physical and behavioural changes
• you suspect that an adult is a threat to a student in some way
• a student makes any comment that gives cause for concern
• there is any deterioration in the students general well-being

When reporting to the Safeguarding Officer make a note of what was said and who was present and report this information immediately.

The Safeguarding Officer will take appropriate actions, which may involve external agencies and contacting parents/guardians.

b) Procedure to follow if staff, students or host family members are accused of abuse:

If a member of staff, a student or member of a host family is accused of any form of abuse, such suspicions will be reported to the Safeguarding Officer

The person against whom the allegation is made will be informed of the allegation and interviewed immediately. Following the interview, if there is any potential substance to the allegation:

• for staff and directors: they will be suspended from their duties pending further investigation
• for students: they will be required to suspend their attendance at the school and find alternative accommodation
• for homestay families: all students will be immediately removed and rehoused and all future bookings suspended until the matter has been fully investigated
• confidential records will be kept of the allegation and all subsequent proceedings
• unfounded allegations will result in all rights being re-instated. Founded allegations will be passed on to the police and will result in a termination of employment / provision of homestay services

Note that ELC endeavours to uphold the confidentiality of students, parents/guardians, staff and host families at all times.

6. Student Communications

Students are made aware of ELC’s Safeguarding policy through their day one orientation and their student handbook. Their day one orientation also includes informs students of personal safety precautions including:

• Avoiding night-time transport and walking home alone (including taxis)
• Drink-spiking
• Areas to avoid at night in Malaysia
• What to do in an emergency

The Accommodation and/or Safeguarding Officer arranges an interview during the first week of Under 18s stay and then monthly. For over 18s this interview takes place within the first 4 weeks if they are staying for more than 12 weeks. The academic team conducts a further interview at 24 weeks for long-term bookings.

Interviews will:

• Cover accommodation, general health and well-being and school life
• Check that there are no concerns with any member of the household
• Getting to school and home ok? Any safety concerns?
• Any concerns with teachers, staff or other students?
• Excursions/Social activities student aware of procedures and has teachers phone number?
• Keeping safe make sure student is aware of emergency phone numbers
• All interview notes will be recorded and saved in BECAS or the Safeguarding Folder (if confidential)

The Safeguarding policy is published on the ELC website (we have a new website due up in late Jan 2014).

7. Additional measures for students under 18 years of age.

The school treats all students as independent, mature individuals and students who are under the age of 18 years will be treated in the same way. The usual personal and academic support arrangements will apply to students who are under 18 years. However, the School acknowledges that anyone under the age of 18 living in Malayia is legally a child and recognises that students under the age of 18 may therefore have additional needs in relation to their support and welfare.

It should be noted that the school does not usually accept students under 18 years of age unless:

1. they are on a study tour with an accompanying adult who is responsible for them

2. there are exceptional circumstances (such as when an older brother or sister is studying at the school)

a) Parental responsibilities

The School is not able to take on the usual rights, responsibilities and authority that parents have in relation to a child, and does not act in loco parentis in relation to students who are under the age of 18 years. The School insists that guardianship / in loco parentis is arranged prior to the students arrival in Malaysia.

As a minimum, it is a condition of admission to the School that the parent or guardian of any student who is under the age of 18 years confirms, by signing and returning the schools parental consent form, their acceptance of the arrangements set out in this document. Where the parents remain abroad, the School requires, as a minimum, details of the parents 24-hour emergency contact number. The School requires a 24-hour emergency contact number for the childs guardian who is in Malaysia, and who will be accessible to the child and to the School should the need arise.

b) Contracts

As a student who is under the age of 18 years may not be able to enter into legal contracts, the School require a students parents to honour all obligations under any contracts with the School that the student enters into. By signing the schools parental consent form, the parent agrees to this.

c) Working with Children Check

All staff specifically engaged to teach students under 18 year of age (study tours) are required to undergo a Working with Children Check (WCC Check). Checks are to be carried out before employment starts or, where this proves impossible, at the earliest possible opportunity. This is supported by satisfactory references from the most recent and one other previous employer. A record is kept of all checks is to be kept and must include the name of the staff member, the date and number of the document.

d) Student accommodation

Parents should be aware that host family accommodation where the host family acts as in loco parentis is the most suitable arrangement for both the school and the student. All host families have completed a Working with Children Check (see above).

e) Excursions

Programs may involve compulsory or optional activities and trips. ELC is not able to take any additional responsibility for a student who is under the age of 18 years in relation to such activities. Unless indicated otherwise, by signing the parental consent form, parents give consent for the student to take part in these activities on that basis. The staff member leading the trip is always informed of any student under 18 going on the trip and those students must stay with the trip leader at all times.

f) Study tours excursion policy

• Where possible if there are students who are under 18 on an excursion, there should be 2 teachers accompanying each group.
• Under-18 students should be clearly identified on the passenger list.
• If a student marked as under-18 fails to arrive in the morning for the excursion, the teacher in charge of the group should call/text the group coordinator or the ELC Safeguarding officer.
• Teachers should ensure they have the mobile number of all under-18 students.
• Under-18 students should have the option of staying with the teacher during the day.
• Otherwise the student should be told to stay with other students during free time after a walking tour.
• Should the under-18 not have a mobile number then teachers should take the mobile number of other students in that group.
• Teachers should arrange to meet with the under 18 at some point during the day.

OR

• Students should contact the teacher by phone or text every 2 hours to clarify location and safety. If they don’t, teacher should contact the student.
• If teachers cannot contact an under-18, then teachers should try to contact another member of that group.
• Teachers should stay in a central location and be available to help if necessary.
• Teachers should call or text under-18 students one hour before departure time as a reminder.
• At the designated meeting time teachers should check the list to ensure that all under 18 students have returned.
• Should anyone under-18 fail to return on time teacher should try to contact the missing student(s). Unless student arrival is imminent, the teacher should wait a maximum of 15 minutes and then depart. One member of staff should wait at the departure point for 30 more minutes and continue to attempt to make contact.
• If unable to make contact, then that member of staff should contact the ELC Safeguarding officer who will contact the local police and inform them of the situation and inform the students emergency contact.
• The teacher should wait a further hour, continuing to attempt to contact student. Liaise with local police and the ELC Safeguarding officer before returning to school.

g) Alcohol and tobacco

It is illegal for alcohol and tobacco products to be sold to or bought by students who are under the age of 18 years. ELC will take reasonable steps to seek to ensure that the law is not broken control but cannot undertake to supervise any individual student.

h) Relationships with staff

It is a criminal offence for any person in a position of trust (which includes members of ELC staff) to engage in sexual activity with someone who is under 18 years.

i) Child protection

The School has a responsibility to protect those under the age of 18 years from abuse and will report any suspicions or allegations of abuse of children to the appropriate authorities. Procedures are as for the Safeguarding Policy outlined above.

j) Notification

The relevant teachers will be notified, prior to class placement, of any student who is under the age of 18 years on entry to the school.

k) Absenteeism

Students under 18 are reported absent to the Director of Studies at the earliest opportunity and steps made to ascertain the whereabouts and safety of the student. An interview with an absent under-18 student to check reason for absence and check whether there are causes for concern, outcome to be recorded on students file on BECAS.

l) Parental involvement

It is ELC’s usual policy that it deals with students and not with parents and this approach will also apply to students who are under the age of 18 years. ELC will correspond with parents only in cases such where the students welfare and progress is considered at risk.

m) Emergency contact

It is particularly important that emergency contact details are provided for students under the age of 18 years and such students and/or their parents are required to supply this information prior to their arrival at ELC. If a medical emergency arises and it is not possible for the school to contact the named individuals, a senior staff member will, on behalf of the students parents or guardians give such consent to treatment as is in the best interests of the student. By signing the parental consent form, the students parents or guardians indicate their consent to this.

Safety Risk Assessment Policy and Procedures

1. Introduction

This policy and procedures establish the process for the management of health and safety risks faced by ELC and outline the schools legislative responsibilities in respect to risk management of Workplace Health and Safety (WHS).

The Work, Health and Safety Act 2011 places a duty on the school to eliminate or minimise risks to the health and safety of its employees, students, contractors and visitors. The policy applies to all activities and processes associated with the normal operations of ELC.

It is the responsibility of all Board members, staff and students to identify, analyse, evaluate, respond, monitor and communicate risks associated with any activity, function or process within their relevant scope of responsibility and authority.

WHS risk management combines technical, consultative and managerial approaches to identify any foreseeable hazard that has the potential to harm the health or safety of employees, students, contractors and visitors to the school.

ELC has the primary duty to ensure the health and safety of workers and other persons in the workplace. A duty to ensure health and safety requires ELC to manage risks:

• by eliminating health and safety risks so far as is reasonably practicable
• if it is not reasonably practicable to eliminate the risks, by minimising those risks so far as is reasonably practicable

Deciding what is reasonably practicable to protect people from harm requires weighing up certain matters, including the likelihood of a hazard or risk occurring and the degree of harm that would result, and then making a judgment about what is reasonable in the circumstances.

2. Definitions

Risk is the likelihood that a harmful consequence (death, injury or illness) might result when exposed to a hazard. Risk is characterised and rated by considering two characteristics:

1. Probability or likelihood (L) of occurrence

2. Consequence (C) of occurrence.

This is expressed as R (risk) = L (likelihood) x C (consequence).

Likelihood is a qualitative description of probability or frequency.

Consequence is the outcome of an event, being a loss, injury, disadvantage or gain. There may be a range of possible outcomes associated with an event.

Risk Management is the application of a management system to risk and includes identification, analysis, treatment and monitoring.

3. Responsibilities

ELC Board of Directors has a responsibility to:

• Exercise due diligence to ensure that ELC complies with the WHS Act and Regulations. This includes taking reasonable steps to:

– Gain an understanding of the hazards and risks associated with school operations

– Ensure that ELC has and uses appropriate resources and processes to eliminate or minimise risks to health and safety

The Managing Director has a responsibility to:

• Ensure, so far as is reasonably practicable, that workers and other persons are not put at risk from work carried out by ELC
• Ensure, so far as is reasonably practicable, that:

– the workplace, including entry and exit and anything arising from the workplace are without risks to health and safety

– the fixtures, fittings or plant are without risks to health and safety

– the plant, substance or structure is without risks to health and safety

• Establish and implement risk management systems for school functions and activities

Staff have a responsibility to:

• Comply with WHS Policy, procedures and instructions to ensure a safe workplace
• Contribute to the establishment and implementation of risk management systems for all functions and activities of ELC
• Take corrective action to guard against hazards at work, or report those hazards which cannot be immediately corrected

4. Risk Assessment

ELC understands the concept and process of risk assessment to be as follows:

4.1 Concept of risk assessment

Risk assessment is a systematic examination of any activity, location or operational system in order to control hazards and manage risk. A risk assessment enables an individual to:

• identify hazards
• understand the likelihood and potential consequences of the hazards (i.e. the risk)
• review the current or planned approaches to controlling the risks
• add new control measures where required

4.2 Process of risk assessment

The process of risk assessment involves 4 basic steps:

1. Identify hazard & analyse consequences (potential injury, property damage, etc.)

2. Assess risk (probability, frequency, severity of injury or loss & determine action (methods of removing or reducing risk)

3. Implement controls (redesign, removal, new methods, audit)

4. Evaluate controls & review procedures regularly

4.3 Timing and necessity of risk assessment

Managing work health and safety risks is an ongoing process that is triggered when changes affect ELCs work activities changes such as:

• New program start-up
• Changing work practices, procedures or the work environment
• Purchasing new or used equipment or using new substances
• Planning to improve productivity or reduce costs
• New information about workplace risks becomes available
• Responding to workplace incidents (even if they have caused no injury)
• Responding to concerns raised by workers, health and safety representatives or others at the ELC workplace
• As required by WHS regulations for specific hazards

5. Identifying hazards

5.1 Types and courses of hazards

Identifying hazards involves finding all of the things and situations that could potentially cause harm to people. Hazards generally arise from three aspects of work and their interaction:

• The physical work environment
• The equipment, materials and substances used
• The work tasks and how they are performed

Hazards can be generally classified into five broad areas:

1. Physical e.g. noise, light, UV radiation, heat, and cold

2. Chemical e.g. hazardous substances, poisons, vapours, and dust

3. Biological e.g. plants, parasites, and viruses

4. Mechanical/electrical e.g. slips, trips and falls, plant and equipment, ergonomics, and manual handling

5. Psychological e.g. stress, boring/repetitive work, violence/aggression, bullying

ELC endeavours to identify all foreseeable hazards, in particular, those arising from:

• Work premises
• Work practices and systems
• Manual handling and occupational overuse syndrome
• Layout and conditions of the workplace
• Physical working environment (electrocution, drowning, fire, explosion, slips, trips and falls, contact with moving or stationary objects, noise, heat, cold, vibration, static electricity and contaminated atmospheres)
• Hazardous substances

5.2 Methods of identifying hazards

ELC uses the following methods to identify hazards:

A. Workplace Inspections – Inspections of the workplace are conducted by the WHS Manager on a quarterly basis to identify the hazards that exist in the workplace. The WHS Manager in consultation with other staff, inspects and observes the workplace to identify any hazards. Hazards are documented on specific check sheets for the work area involved and recommendations provided for the WHS Manager / Management team. (Refer to documents 1-11)

B. Accident or Incident Report and Near-miss or Hazard Report – These reports are completed each time an incident, accident or hazard occurs. Completed reports are forwarded to the WHS Manager and a centralized register is maintained (the Workers Compensation Act requires a register of injuries be kept). The WHS Manager also provides advice on the action to be taken to prevent a recurrence of the incident, accident or hazard. (Refer to documents 12 & 13)

C. Safety Audits – Complete internal safety audits are conducted annually. The WHS manager provides an audit report and recommendations to the Management team. (Refer to document 17)

D. Consultation – In the workplace, the WHS Manager consults with staff on WHS matters and brings any issues and concerns to the attention of the management team. This may involve providing assistance and advice to management on WHS policies and procedures and investigating immediate risks to Health and Safety.

E. Health and Environmental Monitoring – Where particular risks to the health of people on school premises or to the environment exist, or are suspected, technical advice on hazard controls from both internal and external WHS practitioners is sought.

F. Incidental Identification – If staff notice a workplace hazard they should report the details to the WHS Manager, or if safe to do so, rectify the identified hazard themselves. All individuals have an obligation to guard against or protect others from any hazards or incidents as soon as they are recognised. If the hazards or incidents cannot be rectified immediately, the person must report the hazards or incidents to their supervisor on the Near-miss or Hazard Report. (Refer to document 13).

6. Assessing risk

All hazards have the potential to cause different types and severities of harm, ranging from minor discomfort to a serious injury or death. A risk assessment involves considering what could happen if someone is exposed to a hazard and the likelihood of it happening.

Once a potential hazard has been identified a risk assessment is initially conducted by the WHS Manager. This is recorded in the Risk Register (Refer to document 14). The following procedure is to be applied by any staff member when assessing risk:

a. How much harm could occur?

To estimate the amount of harm that could result from each hazard consider the following questions:

• What type of harm could occur (e.g. muscular strain, fatigue, burns, laceration)?
• How severe is the harm?
• Could the hazard cause death, serious injuries, illness or only minor injuries requiring first aid?
• What factors could influence the severity of harm that occurs? For example, the distance someone might fall or the concentration of a particular substance will determine the level of harm that is possible. The harm may occur immediately something goes wrong (e.g. injury from a fall) or it may take time for it to become apparent (e.g. illness from long term exposure to a substance).
• How many people are exposed to the hazard and how many could be harmed (in and outside your workplace)?
• Could one failure lead to other failures? For example, could the failure of your electrical supply make any risk controls that rely on electricity ineffective?
• Could a small event escalate to a much larger event with more serious consequences? For example, a minor fire can get out of control quickly in the presence of large amounts of unnecessary combustible materials.

b. How may the risk occur?

In most cases, incidents occur as a result of a chain of events and a failure of one or more links in that chain. If one or more of the events can be stopped or changed, the risk may be eliminated or reduced.

In thinking about how each hazard may cause harm consider:

• The effectiveness of existing control measures and whether they control all types of harm
• How work is actually done, rather than relying on written manuals and procedures
• Infrequent or abnormal situations, as well as how things are normally meant to occur.

c. What is the likelihood of harm occurring?

The likelihood that someone will be harmed can be estimated by considering the following:

• How often is the task done does this make the harm more or less likely?
• How often are people near the hazard? How close do people get to it?
• Has it ever happened before, either in your workplace or somewhere else? How often?

The level of risk will increase as the likelihood of harm occurring and its severity increases. The likelihood can be rated as one of the following:

• Certain to occur – expected to occur in most circumstances
• Very likely – will probably occur in most circumstances
• Possible – might occur occasionally
• Unlikely – could happen at some time
• Rare – may happen only in exceptional circumstances

7. Controlling risk

Risk control means taking action to first eliminate health and safety risks so far as is reasonably practicable, and if that is not possible, minimising the risks so far as is reasonably practicable.

When eliminating or seeking to minimise risk control measures must take into account any relevant legal requirements, which establish the minimum levels of risk control. Where additional control measures are required to reduce the risk, they should be considered according to the order in the following hierarchy of risk control which, as well as being in order of effectiveness to control risks, is also in order of the minimum amount of managerial effort required to maintain them.

• Eliminate the hazard – total removal of the hazard from the workplace
• Substitute the system of work, plant or substance with something safer, e.g. less hazardous cleaning agent
• Isolate the hazard from the employees, e.g. introduce a restricted work area in a laboratory
• Engineering controls, e.g. fume hoods and machine guarding
• Administrative controls, e.g. warning signs, rotation of tasks, training and routine maintenance
• Personal Protective Equipment (PPE), e.g. gloves, safety glasses and dust coats

Control measures may involve a single control measure or a combination of different controls that together provide the highest level of protection that is reasonably practicable.

1. Some problems can be fixed easily and should be done straight away by the staff member identifying the hazard or the WHS Manager who has identified or been informed of the hazard. This should still be recorded in the Risk Register (Refer to document 14).

2. Hazards which have been identified as high risk and which cannot be fixed quickly or easily must be brought to the immediate attention of the Managing Director as soon as possible.

3. For non-urgent hazards which require effort/planning/cost to resolve the management team prioritises areas for action at the monthly management meeting, focusing first on those hazards with the highest level of risk. A risk management plan is drawn up which identifies the hazards, what action needs to be taken, who will be responsible for taking the action and by when (Refer to document 15).

Attendance, progress and appeals policy

1. Attendance policy

If you have a student visa you are required by the Malaysian Government to attend a minimum of 80% of your classes. If your attendance falls below 80%, English Language Company is required to inform the Malaysian Government.

1. If your attendance falls below 90% we will issue you with a letter of warning and ask you to discuss your attendance with the Director of Studies.

2. If your attendance falls below 85% we will issue you with a second letter and ask you to discuss your attendance with the Director of Studies.

3. However, if your attendance falls below 80% we will issue you with another letter to inform you that we intend to report you to the Malaysian Government.

4. On receipt of this letter, you may make an appeal through English Language Companys Complaints and Appeals Process.

5. If your appeal is not successful, we will report you to the Malaysian Government and your visa may be cancelled with immediate effect.

2. Course progress policy

ELC is required by the Malaysian
Government to check that you are doing well with your studies. You will make good progress with your English if you use English as much as possible, participate regularly during classes and complete all of your homework, tests and activities.

Every 4 – 5 weeks (depending on your course), your teacher will complete a progress report for you. Assessment covers speaking, listening, reading and writing skills as well as grammar and vocabulary. It is based on your weekly test results, your homework and your language skills during class.

If your teacher thinks that you are not making satisfactory course progress:

1) He/She will meet with you to talk about it or ask you to meet the academic counsellor. You may be given the chance to move to another class or do extra activities to help you.

2) If your course progress does not improve during the next course module, ELC will issue you with a letter of warning and ask you to discuss your progress with the Director of Studies. ELC will continue to do everything we can to help you make satisfactory progress.

3) However, if you still do not achieve satisfactory progress during the next course module we will inform you that we intend to report you to the Malaysian Government.

4) On receipt of this letter, you may make an appeal through English Language Companys Complaints and Appeals Process.

5) If your appeal is not successful, we will report you to the Malaysian Government and your visa may be cancelled with immediate effect.

3. Appeals Procedure

If you have received a letter of intent to report you to the Malaysian Government for unsatisfactory attendance or course progress, you have the right to make an appeal against this decision within twenty days.

ELC can only consider an appeal if there are compassionate and compelling circumstances for your poor attendance and/or unsatisfactory progress. This means:

a) a serious illness or medical emergency for which you can provide medical certificates

b) close family trauma, for which statements from family members can be provided

If your attendance is below 70% no appeal can be considered.

How to make an appeal

1) Make an appointment with the Director of Studies. You may bring a support person with you to this meeting if you wish.

2) The Director of Studies will explain to you how your attendance or course progress have not met requirements and present documentary evidence of this.

3) You will be given the opportunity to explain why you wish to appeal this decision and may be asked to provide any documentary evidence.

4) You will be informed of the outcome of the appeals process in person and in writing within 5 working days.

5) Please remember that you should continue to attend all of your classes throughout this process.

6) If your appeal is not successful, we will report you to the Malaysian Government and your visa may be cancelled with immediate effect.

7) If your appeal is successful, you must continue to meet attendance/course progress requirements for the remainder of your course.

School regulations

Certificates

You will be awarded an ELC certificate when you complete your course.

On time Policy

Please be on time for class. Its very difficult for your teacher and the other students if many students are late. If you are more than 15 minutes late please join the class after the break. Your teacher must mark all absences from class.

English Only Policy

Please speak only English whenever you are at school. Your teacher will remind you to speak only English in class.

Attendance

It is very important that all students comply with the requirements of their visa. If you have a student visa, you must attend a minimum of 80% of your classes. If your overall attendance falls below 80% ELC is obliged by law to inform the Malaysian government. Please read your student handbook for detailed information about this.

Refunds

ELC is not able to offer you a refund after you have started your course.

Course extensions

If you would like to extend your course to study for longer at ELC, please contact reception by Wednesday of your final week.

Visa extensions

If you need to extend your visa you will need to talk directly to your agent if you used one or ask us for information at least 4 weeks before your visa expires.

Building regulations

Please do not smoke anywhere in the building or outside the front doors. Please do not take food or drink into classrooms or the library. Please only eat in the Eat Space on Level 3 café . No eating on the sofas.

Complaints

It is very important to us that you are satisfied with your course and the services provided by ELC. If you have a complaint please make an appointment with the Director of Studies. We will do everything we can to find a solution quickly. However, if your complaint has not been solved by or concerns the owners and operators of ELC, you may contact ELC Sydney at www.elc.edu.au