Coronavirus - What Should Schools Be Doing?
At the time of writing, the risk to individuals in the UK of contracting Novel Coronavirus (COVID-19) in the UK remains low, but it is becoming clear that the measures being taken to contain the virus may have an impact on many independent schools.
Government guidance is being issued and updated as the situation develops by the Department of Health and Social Care and the Foreign and Commonwealth Office (FCO).
What You Should Do Now
We recommend that all types of independent school, not just boarding schools with international pupils, should take steps to review and assess the risks presented by both the virus and the measures that are required to be taken to comply with government guidance to guard against it being spread within the UK.
As with any risk assessment, you should first aim to identify areas of risk and then consider what steps the school can reasonably take to mitigate the risks you have identified.
Boarding schools are required to have a 'Foreseeable Crisis Plan' and as a matter of good practice other schools should have one too. This should be brought to the attention of staff, governors and other stakeholders.
What Are the Risks to Your School?
The risks you identify may reach into more areas of the operation of the school than you might first expect, and are likely to include:
- staff and pupils who intend to return to school after visiting other countries that are subject to guidance that has been issued by the FCO
- arrangements with contractors and peripatetic staff
- arrangements with third party users of the school site, in particular but not limited to residential courses and users of sports or other facilities
- arrangements with associated schools in China or elsewhere whose operations may be affected directly by quarantine restrictions
- exchange visits or other educational trips or tours
- school transport arrangements
The steps that should reasonably be taken to mitigate the risks will not be the same for all schools and will depend on the circumstances. In particular, you will need to understand whether the risk mitigation measures themselves give rise to other risks that need to be managed.
For example, if you identify that staff members intend to travel to high risk areas, and that necessitates a quarantine period before they can resume their duties, what will be the impact of their absence on the school and can you reasonably take steps to mitigate that impact? If they cannot work from quarantine, do they need to be paid? Can the school require that they don't put themselves at risk by not travelling? The answer will depend on many factors, such as the impact of their absence, the personal reasons for travelling, level of risk in the area, the government advice, insurance and the school's contract with them.
Another example may arise if you have a lettings agreement with a residential course provider. Whether or not you can require them not to host children from high risk areas will depend on the terms of the contract you (or your trading subsidiary) have with the provider, and that will feed into your strategy.
There is detailed guidance and advice available on the FCO and Department of Health and Social Care websites and for those schools who are members of ISC associations (including but not limited to the BSA and ISBA) there is additional guidance specifically for schools.
Should you require any advice on your specific circumstances, then we will of course be pleased to help. Please contact Tabitha Cave in our Regulatory Compliance team on 0117 314 5381, or complete the form below.