1. Introduction

The aim of this policy and the accompanying guidelines is to protect and maintain the welfare of all pupils at The British School of Amsterdam and to adhere to Dutch national procedures relating to child protection. In so doing, we also ensure that members of staff at The British School of Amsterdam are protected and supported in the administration and application of the Child Protection Policy. All information and communication within the area of Child Protection must be treated with strict confidentiality, but key to the success of this policy is the duty of care staff have in putting children at the centre of our work, and ensuring lines of communication are followed carefully, given the complex nature of our school setting and the length of time pupils can be here. The safeguarding and protection of our pupils is the responsibility of every member of staff at the school.

Child Protection covers five main categories:

  • Physical abuse
  • Emotional abuse
  • Sexual abuse (including sexual exploitation)
  • Domestic Violence
  • Neglect

1.1. The role of all School staff

Any member of staff who has a concern about a child’s welfare should follow the referral processes set out below:

  1. All staff members should be aware of the systems within the school which support Child Protection; these will be explained to them as part of staff induction as well as at the start of every school year. This will include this policy, the Safeguarding Policy, Staff Code of Conduct https://britams.fireflycloud.net/policies/staff-code-of-conduct and the role of the Designated Safeguarding Lead (DSL), and Deputy DSLs.
  2. No single professional can have a full picture of a child’s needs and circumstances. If children and families are to receive the right help at the right time, everyone who comes into contact with them has a role to play in identifying concerns, sharing information and taking prompt action.
  3. On the basis of his or her knowledge and experience, the professional bears a direct responsibility for the development and health and safety of the child with whom he or she comes into contact, either directly or indirectly, in the course of his or her profession.
  4. In a case where child abuse (or neglect/concern related to child protection), has been identified, the professional bears the responsibility that the overall aim of reporting is to ensure that the abuse stops as quickly as possible.
  5. The professional should be capable of identifying signs given by pupils and their environment as possible indications of child abuse. He or she is required to maintain his or her knowledge and expertise in this regard by means of independent study or further training and instruction.

1.2. Roles and responsibilities

For the purpose of this policy and within the language of child protection practice, the Designated Safeguarding Lead (DSL) with responsibility for Child Protection is Helen Rigelsford (Child Protection Officer).

Each Head of School is a Deputy Designated Safeguarding Lead (DDSL) and their deputies will will take on this role in their absence (shown in brackets):

Early Years: Mrs Claudia van der Laar Newson (Mrs Linda Nagieh)

Junior School: Mr Stuart May (Mrs Abi Byrne, Ms Hannah Williams)

Senior School: Mr Gareth Evans  (Senior School Deputy Head Pastoral) (Mr Christian Nicholson, Senior School Deputy Head Academic) 

The Supervisory Board member with responsibility for Safeguarding and Child Protection is Mr. J. Cameron Webb.  

All personnel at The British School of Amsterdam (including visitors, volunteers and students on placement) are required to report instances of actual or suspected child abuse, including neglect, to either the Designated Safeguarding Lead (DSL) or Deputy Designated Safeguarding Lead (DDSL) (of the section in which they work) responsible for Child Protection. Staff must ensure that if the DSL or their usual DDSL is unavailable, they report to another DDSL within the School.

Helen Rigelsford (DSL) is the focal point for staff that have child protection concerns and is the first point of contact for external agencies pursuing child protection investigations.

It is the overall responsibility of the DSL to decide on the action to be taken, including whether to contact outside agencies/ Social Care Teams, or to make a Melding (formal report), and to oversee that a record is kept of the action taken by the School. In practice, this is normally overseen by the Head of School as DDSL for each school section. The School is also able to seek advice from Edwin Herzberg, Qualified Provider of Child Protection Training (Trainer Inzake Kindermishandeling).

The School recognises its responsibility to attend Child Protection conferences with outside agencies.

1.3. What staff should look for

All members of staff should be aware of the signs of abuse and neglect so that they are able to identify cases of children who may be in need of help or protection.  Types of abuse and neglect are annexed to this policy.

Members of staff working with children are advised to maintain an attitude of it can happen here where child protection is concerned. When concerned about the welfare of a child, a staff member should always act in the best interest of the child. Knowing what to look for is vital to the early identification of abuse and neglect.

Recognising Abuse and Neglect

Obvious non-accidental injuries, wounds or marks which are not consistent with the explanation given, and incidents reported by the child or others must always be reported to the DSL (or DDSL) immediately.

The risk indicators listed below may be significant in the light of other concerns, and must always be discussed with the DSL / DDSL. However, these factors should not be seen in isolation but must be considered within the context of your knowledge of the child and their family. Those that might indicate possible problems are:


  • Unusual tiredness, inadequate clothing, poor personal hygiene, changes in appetite, reluctance to change for PE
  • Unexplained absence, persistent lateness, reluctance to go home
  • Sudden behaviour/mood changes (acting out, bullying, hyper-activity, attention seeking)
  • Being withdrawn, isolating from other children, regressing to the behaviour of a younger child, lack of concentration, signs of depression, obsessive behaviour, failure to seek comfort when hurt
  • Low self esteem, self injury, unease or unusual behaviour with men/women, soiling, inappropriate sexualised play/drawings, the sexual harassment of other children
  • Staff should report any incident of sexualised play to the relevant Headteacher, even if it seems to be part of the natural maturing process. It is important that Headteachers have all information about sexualised play in order that a full picture of frequency and type of play can be taken into account. This will ensure that a full picture can be built of the child and his/her possible needs.

Things said by or about children

  • That they have been beaten, hit with an implement, improbable/inconsistent explanations
  • That they are “picked on” or treated differently from their siblings
  • That they are worried about a friend

The carer/child relationship

  • Constant negative comments about the child
  • The parent/carer hitting the child publicly, or the child’s apparent fear of the carer
  • Persistent failure to collect the child
  • Sudden changes in the parental attitude towards staff
  • The child assuming responsibility for the adult
  • Alcohol or substance abuse by the parent/carer

Points to Consider

  • Children from all cultures are potentially subject to abuse and neglect. Cultural factors neither explain nor condone children being placed at risk of significant harm – the needs of the child as an individual must be the basis for investigation.
  • Children with special educational needs (SEN) and/or disabilities are statistically at a greater risk of abuse because they often have a greater physical dependency upon adults, or they may have less social contact beyond their families, and may not have the capacity to verbalise their worries and concerns. These children are also at greater risk of being left out or bullied and may need more access to mentoring and support.
  • Staff must be sensitive to the needs and vulnerability of children whose names are already subject to Child Protection Plans and those who are Looked After in Public Care.
  • Advice from the Department of Education for the UK, What to do if you are worried a child is being abused – advice for practitioners, provides more information and understanding and ways of identifying abuse and neglect. Examples of potential signs of abuse and neglect are highlighted throughout the advice and will be particularly helpful for staff. Staff should also refer to Keeping Children Safe in Education 2022. The NSPCC (based in the UK and in English) and Veilig Thuis (based in the Netherlands) websites also provide useful additional information on the types of abuse and what to look out for.

If staff  are unsure they should always speak to a the  DSL, Principal or a Headteacher.

2. Child Protection Procedure

2.1. What to do if you suspect abuse

Whenever a member of staff suspects abuse, or a child volunteers information, they must:

  • Seek information tactfully and carefully, listen, take notes of the discussion immediately afterwards and ACT QUICKLY.
  • Not promise the child that they can keep the information confidential
  • Inform the Designated Safeguarding Lead (DSL)or a Deputy DSL
  • Be discreet

Concerns are always shared, however minor.

All staff must ensure that they record and report any conversations they may have with parents or pupils which may form part of a child protection concern, and pass to the Designated Safeguarding Lead (or Head of School as DDSL)

2.2. How to report concerns

If a member of staff is concerned about an incident, however minor, it is recorded on the School’s Child Protection Concern system (MyConcern)

MyConcern is the electronic Safeguarding Platform that the British School uses to record any concern about a pupil. It has a built in level of security and confidentiality which enables us to follow GDPR requirements. We emphasise in staff training that 'no concern is too small to share' and that adding all the concerns enables us to build up a picture of each individual pupil. All members of staff and regular workers and volunteers (including office staff, therapists, club providers, school keepers and Majest staff) have an account on My Concern. They are sent details for setting up their MyConcern account following initial child protection training. Accounts are set at either:

* Basic User - on which you can only record a concern,

* Trusted User - on which you record a concern and follow any concern if you have been added to the team for that concern by a DSL/DDSL and

* DSL - only for DSL/DDSLs and the Principal - which means you have access to all concerns, though in reality HoS usually only access concerns relating to pupils in their school section. An exception to this might be if the DSL recommends looking at a concern in a different section because of possible sibling involvement.

Record as much detail as possible on the MyConcern reporting page, recounting exactly what was said or seen, what you said and the background to the concern.

Once a concern form has been sent in on My Concern it comes to the immediate attention of the DSL/DDSLs and can be followed up quickly and efficiently. DSL/DDSLs also ensure ongoing follow up and can add members to a team round any concern or around the entire profile of a pupil (where more concerns can be seen at once). Thus, a class teacher or therapist or counsellor can be added as necessary.

If a parent or member of the public has Child Protection concerns, they can report it to the DSL. All staff, however, are responsible for not disclosing to members of the public details  about children who are on roll at the School. Additionally, they should always involve the Principal  in the event that a member of the public raises a CP concern so that the School can take advice from Veilig Thuis.  

Historical cases and concerns/allegations raised after an extended period of time: If a concern of a historical nature is raised (i.e. one that has taken place in a previous academic year) we will, in the first instance, check the CP records to see if anything has been recorded previously. Depending on the nature of the concern, we may ask why the issue has not been raised previously, but in any account we will record the concern, and the DSL will make a the decision as to what action needs to be taken; whether to follow the School's usual protocols in establishing a core meeting (if the child is still on roll) or refer the matter to VT if the child is no longer at the School.

2.3 What happens next - consultation

The Designated Safeguarding Lead or Deputy Designated Designated Lead decides what happens next. The DSL/DDSL will meet with the member of staff to consult and establish:

  • whether the signs observed are recognised by others;
  • whether others have observed additional signs;
  • whether the signs observed have also led others to suspect child abuse;
  • which subsequent steps need to be taken.

The Designated Safeguarding Lead or Deputy Designated Safeguarding Lead will also decide how to allocate duties and responsibilities with regard to the steps to be taken.

The DSL (or DDSL) normally speaks to the parent/carer before making a formal referral but, if she believes this might place the child or a member of staff at immediate risk, she will not alert the parent/carer. Staff raising concerns about a child will be told what has happened as a result of their report.

The DSL/DDSL responsible for child protection and who has been involved in the consulting procedure will make a written record of the consultation on MyConcern and is then legally obliged to follow the Dutch meldcode.

It is important to note that under the Dutch meldcode, a child/minor being witness to domestic violence is considered abuse in itself as it causes significant harm to the child/minor.

2.4 Care Team meeting

Following Consultation, the DSL/DDSL will share concerns with the School's Care Team to decide on further action. Note: within the BSA Care Team comprises the DSL, the relevant DDSL (Head of Early Years, Head of Juniors or the Senior School Deputy Head (Pastoral)),  spmetimes the Principal and possibly any therapists involved with the child or the School Counsellor in the Senior School. On occasion other relevant members of staff (for example the class teacher or reporting member of staff) may also be included on the Care Team.

2.5 Speaking to parents and outside agencies

The Care Team will decide who will speak to parents (usually the DDSL).

After speaking to the parents, the DL/DDL will decide whether to complete a Melding to Veilig Thuis (VT) or whether to make a formal referral to a therapist, the School Doctor, the OKA or another relevant outside agency. (see 5 Meld Code)

Note: It is only possible to make a report to VT without first having conducted a conversation with the parent/guardian when:

  • The safety of the child, the parents/carers, yourself or any other individual is threatened
  • If you have good reason to believe that the parent will break contact with you upon hearing the information

2.6 Ongoing

The Care Team will decide which member of staff (usually the Headteacher (DDL)) will coordinate the ongoing care, including communicating the outcome of the referral to the parents and the class teacher. All communications and meeting notes will be kept on MyConcern.

If at any point it becomes apparent that the suggested referrals are not having an impact, the Care Team will instigate a Melding to VT for further support.

(See translation of Dutch Meldcode below (5) for details of the basis for this procedure)

2.7 Instances where children are at risk of abuse by other children

The School recognises that children may be at risk from child-on-child abuse. In these circumstances, the procedure will remain the same as set out in the reporting code below, and advice sought from VT if the Care Team decides that there is a likelihood that the abuse is actual. The School will use its pastoral system to ensure that both children are supported and that staff are supported in dealing with the situation. This may also lead to a review of the School’s safeguarding procedures. Child-on-child abuse can involve, but is not limited to bullying, sexting, sexual violence, sexual harassment, initiation ceremonies.

2.8 Strategic opportunities for staff to raise concerns

As well as the duty on all staff to report any concerns of child abuse, the School will regularly table the discussion of Child Protection at Management Meetings and within CPD and Supervision Meetings (see CPD policy). If in doubt, please consult the Designated Lead/ Deputy Lead for advice.

2.9 Allegations against staff

In the event that an allegation of child abuse is made against a member of staff/volunteer, in the interest of both parties the named person may be suspended on full pay until the allegation has been fully investigated by members of the Management Team and/or the relevant member of the Supervisory Board and all other relevant parties, and the allegation is either proven or disproved.

The amended Youth Services Act (Wet of Jeugdhulpverlening) stipulates that professionals have an obligation to report child abuse committed by others who work in the same organisation. Upon receiving such a report, the management of the organisation is obliged to inform either the police or Veilig Thuis immediately to ask them for advice. In a case where a member of staff/professional is thought to be guilty of child abuse, the step plan does not apply.

Keeping Children Safe in Education 2022 stipulates that where there are concerns about a member of staff these must be reported immediately. In our school such reports go either to the Head of School or to the Principal.

Staff should also make sure that they discuss any low level concerns about colleagues with their Head of School in the interests of keeping our pupils safe. Staff are also encouraged to make self reports on occasions that they realise they may have made a mistake and put either their pupil/s or themselves at risk. The Head of School, in consultation with the DSL and the Principal, will be responsible for deciding whether and how to respond.

2.10. Confidentiality

Information concerning individual children and/or families must only be divulged to those who are lawfully entitled to this. Staff are required to speak to the DSL and be aware of the danger of placing a child or colleague at risk.

All records pertaining to Child Protection should be written accurately on MyConcern. In the case of children moving from the School, a copy of the MyConcern file must be sent under separate cover to the receiving school. It is also kept on MyConcern at the BSA under the  'archived' section. 

Data Protection: The child’s parents should be informed of the information we are collecting and processing as far as possible, unless there is a real concern that a child may be at risk from greater harm by informing a parent/carer. In the case where a parent cannot be informed, the School will ensure that the reasons for this are noted on the records.

2.11. Staff training

All staff will receive appropriate safeguarding and child protection training at least once per year, during the Autumn term, to provide them with the relevant skills and knowledge to safeguard children effectively. In addition, staff members will receive safeguarding and child protection updates, as required.

All staff should be aware of the early help process and understand their role in it. This includes identifying emerging problems, liaising with the DSL or the relevant Deputy DSL, sharing information with other professionals to support early identification and assessment and, in some cases, acting as the lead professional in undertaking an early help assessment.

All staff should know what to do if a child tells them he/she is being abused or neglected. Staff should know how to manage the requirement to maintain an appropriate level of confidentiality whilst at the same time liaising with the relevant professionals such as the DSL or the relevant Deputy DSL. Staff should never promise a child that they will not tell anyone about the allegation, as this may ultimately not be in the best interest of the child.

Staff will take part in annual refresher sessions so that everyone is aware of the guidelines and procedures within this policy, KCSiE and the Meldcode and any other relevant updates. Outside providers who work within the School (peripatetic music teachers, club providers and enrichment providers, Majest staff) will also be counted as staff in the training cycle and will be provided with induction training and update training at a minimum of every two years.

Staff in regulated activity will be required to read Part 1 of KCSiE and Part 5, the child on child Sexual Violence and Sexual Harassment Guidance. Staff not in regulated activity will be required to read Annex A at minimum. All staff will understand what is meant by child-on-child abuse and how to respond.

The School's induction scheme for new members of staff includes information about the Child Protection Policy, The Safeguarding Policy, The Behaviour Policy, The Staff Code of Conduct and the Attendance Policy.

Specific training to cover an emerging need or crisis will also be given.

3. What staff should do if they have concerns about safeguarding/CP practices within the School

All staff and volunteers should feel able to raise concerns about poor or unsafe practice and potential failures in the School’s safeguarding regime and understand that such concerns will be taken seriously by the Management Team.

Appropriate whistle-blowing procedures, which can be found in the Staff Handbook, are in place for such concerns to be raised with the Management Team.

4. Flow chart of actions

5.  The step plan within the Dutch Meld code (reporting practice)


Step 1: Noticing signs of child abuse / neglect / or the witnessing domestic violence by a minor

Noticing difficulties in the development of a child, and discussing these with parents/guardians is an important aspect of the professionalism of all teachers and managers. This professionalism is expected in every contact with a child/minor and his/her parents/guardians. When attention is given to signals of child abuse/neglect/domestic violence this is often accompanied by a feeling that ‘something is not quite right’ beforehand. The observed signals, as well as any further information provided by parents, form the basis of any further action.

Step 2: Collegiate discussion / consultation and, if necessary, consultation with Veilig Thuis

The teacher or member of staff who first noticed the signs of child abuse/neglect/domestic violence will first discuss these with the Head of their school (DDSL) or the DSL and make a record on MyConcern. The DSL/DDSL may choose to seek (anonymous) advice from Veilig Thuis (VT), the advice and reporting centre for child abuse/neglect/domestic violence. 

Step 3 : Talk to the individuals involved (pupil/parents/guardians)

This step is to have a conversation with the individuals involved, including - wherever possible - the child him or herself. Parents/guardians should also be invited to discuss the concern at this stage. This conversation should not take place without the advice and usually the involvement of the DSL/DDSL.

Step 4: Assess whether domestic violence or child abuse has occurred. If in doubt, consult with Veilig Thuis.

At this point the care team will be convened within school to discuss the outcome of the meetings/conversations with pupils and parents/guardians. A decision will be made as to whether there is evidence to suggest domestic violence or child abuse/neglect has occurred. If in any doubt we will consult with Veilig Thuis for advice.

Step 5: Decision re whether to offer further support referral ourselves or whether to make a formal report (a melding) with Veilig Thuis

At this stage the care team will consult the decision table (afwegingskader) below to come to an agreement as to whether we are in a position to offer the onward help and referral the child/family needs to ensure that the negative situation stops as soon as possible and does not start again at a later date. If we feel it is not within our capability to do this then we will make a formal report (a melding) with Veilig Thuis. In the case that the school makes a formal report we should nearly always inform the parents/guardians and where appropriate the pupil of why we are taking this step and what will happen next.

Note: The possibility to make a report to VT without first having conducted a conversation with the parent/guardian is only possible when:

  • the safety of the child, the parents/carers, yourself or any other individual is threatened
  • you have good reason to believe that the client will break contact with you upon hearing the information.

Decision Table (Afwegingskader) to refer to as part of the decision making at Step 5:

Detail of the five considerations and conclusions in steps 4 and 5 of the reporting code for Child Abuse and Neglect in the Netherlands

  1. Weighing the suspicion that there might be child abuse/neglect
  2. I have completed steps 1 to 3 of the reporting code and
  3. A On the outcome of the first three steps no further action is needed: complete and file dossier
  4. B I have a strong suspicion of abuse/neglect/domestic violence. The DSL and relevant senior leaders are aware of this. Continue to consideration 2.
  1. Safety
  2. On the basis of having gone through the first four steps of the reporting code we estimate that there is the likelihood of acute and/or systemic lack of safety for the child
  3. A. NO > continue to consideration 3
  4. B. YES or Possibly > Directly make an advice call to Veilig Thuis (anonymous case) or directly make a melding to Veilig Thuis. The considerations hereafter will be guided by and followed together with the support of Veilig Thuis
  1. Help 1
  2. Am I or is someone else in my school or a close partner with the school (therapists, OKT, for example) in a position to be able to offer effective help or to refer on to a relevant agency? And can the threat of abuse/neglect/domestic violence be averted by doing so?
  3. A. NO > Make a melding with Veilig Thuis, who will make a decision within 5 days and will feed this back to the reporting person
  4. B. YES > Continue to consideration 4
  1. Help 2
  2. Do those directly involved accept the need for help as it is organised in step 3 and are they prepared to actively be involved in this help?
  3. A. NO > Make a melding with Veilig Thuis
  4. B. YES > Put the agreed help in place, plan in evaluation times at which can be judged whether the effect is noticeable and/or measurable. Make the help of offered as concrete as possible and document the help offered. Agree exactly who will offer what and name a case manager. Agree which tasks all those involved will have, epecially the case manager so that the expectations of and for everyone are clear. Record what is agreed, carry it out and then continue to consideration 5.
  1. Result
  2. Does the help result, within the agreed time frames, in the previously recorded desirable outcome in respect to the safety, the welfare and/or the recovery of those directly involved?
  3. A. NO > Make a melding with Veilig Thuis
  4. B. Yes. > Finish the support with agreements about the monitoring and the safety of all those directly involved

Step 6 (at the BSA): Follow-up

When the Care Team has offered support/referrals to the family, they also discuss within the team who is going to be responsible for coordinating the care, moving forwards. The Care Team follows the advice of the support/referrals offered, and adjusts this as necessary. If it becomes apparent that it is still necessary, a ‘melding’ (report) to Veilig Thuis should be raised if the child abuse/neglect/domestic violence is ongoing or starts again. Finally, after-care is offered to the family/members of staff involved, and an evaluation is made by the Care Team as to how the case was handled. (Stappenplan translated by Helen Rigelsford May 2022)

Appendix 1

Types of abuse and neglect

All staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another.

Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children (peer-on-peer abuse)

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Sexual abuse: This involves forcing or enticing a child or young person to take part in sexual activities (not necessarily involving a high level of violence), whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Appendix 2

It is now compulsory that all staff who come regularly into contact with children read Part 1  of Keeping Children Safe in Education 2022 and Part 5  which is the Guidance about child on child  Sexual Violence and Sexual Harassment. Staff who do not regularly come into contact with children must read Annex A at minimum  the link to all the above can be be found here.

This conforms to Standard of the UK Government’s British Overseas School Standard 3 and 4, regarding welfare, health and safety and the suitability of proprietor and staff.