Online Safety within ‘Keeping children safe in education’ 2016
This article was published on the 6th June 2016 (last updated 20.12.16 at 14:15) and will be subject to review and amendment as required. On the 26th May 2016 the DfE published the updated ‘Keeping children safe in education’ guidance ready for implementation in September 2016. ‘Keeping children safe in education’ is statutory guidance from the Department for Education issued under Section 175 of the Education Act 2002, the Education (Independent School Standards) Regulations 2014 and the Non-Maintained Special Schools (England) Regulations 2015. All schools and colleges must have regard to ‘Keeping children safe in education’ when carrying out their duties to safeguard and promote the welfare of children and schools and colleges should comply with the guidance unless exceptional circumstances arise. ‘Keeping children safe in education’ contains information on what schools and colleges should do and sets out the legal duties with which schools and colleges must comply in order to keep children safe. It should be read alongside statutory guidance ‘Working together to safeguard children’ and the DfE departmental advice ‘What to do if you are worried a child is being abused - Advice for practitioners’. This post will focus on elements of the document which are relevant to online safety and will be highlighting additions and changes regarding schools and colleges statutory duties and responsibilities. It is strongly recommended that Designated Safeguarding Leads (DSLs) read the entire document when looking at their current safeguarding practice and considering any required actions for September 2016.
- ‘School’ describes all schools whether maintained, non-maintained or independent, including academies and free schools, alternative provision academies, maintained nursery schools and pupil referral units.
- ‘College’ describes all further education colleges and sixth-form colleges as established under the Further and Higher Education Act 1992, and relates to their responsibilities towards children under the age of 18, but excludes 16-19 academies and free schools (which are required to comply with relevant safeguarding legislation by virtue of their funding agreement).
- ‘Staff’ describes all members of staff working within a school or college setting including teaching and non-teaching staff and volunteers. This may include staff working on site even if they are not employed directly by the school/college for example catering staff etc.
- Black font indicates a direct quote from the new guidance
- Blue font is used to highlight recommendations, best practice and useful links from the Kent County Council Education Safeguarding Adviser (Online Protection)
- Red font indicates a possible action point for DSLs, Governing bodies, Headteachers and proprietors to consider in readiness for September 2016.
Part one: Safeguarding information for all staff
What school and college staff should know and do
- Safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who comes into contact with children and their families and carers has a role to play in safeguarding children. (p.5)
- All school and college staff have a responsibility to provide a safe environment in which children can learn. (p.5)
- All staff members should receive appropriate safeguarding and child protection training which is regularly updated. In addition all staff members should receive safeguarding and child protection updates (for example, via email, e-bulletins and staff meetings), as required, but at least annually, to provide them with relevant skills and knowledge to safeguard children effectively. (p.6)
Types of abuse and neglect
- All school and college 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. (p.11)
- 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 ... serious bullying (including cyberbullying)... (p.11)
- Does our school/college anti-bullying policy identify cyberbullying and outline the school/college's response to any concerns reported?
- Sexual abuse: 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. (p.11)
- UK Safer Internet Centre
- Childnet International
- South West Grid for Learning
- London Grid for Learning
- Northern Grid (Digitally Confident)
- Does our school/college safeguarding and child protection policy clearly identify the use of technology as a potential risk to members of the community?
Specific safeguarding issues
- All staff should have an awareness of safeguarding issues... Staff should be aware that behaviours linked to the likes of …. sexting puts children in danger. (p.12)
- UK Safer Internet Centre
- Childnet - Sexting and the Law
- Childnet - Hot Topic - Sexting
- Childnet - "Picture this" resource
- Spirto Resources
- SWGfL - "So you got naked online" booklet
- Think U Know 14+
- Think U Know 11-13
- NSPCC -Share Aware Resources
- Parents Info - what is and isn't legal
- ChildLine - Zipit app
- UKCCIS Sexting Guidance for schools and colleges
- Does our school/college policies identify sexting as a possible risk for children?
- Does our school/college provide training and appropriate information to members of staff regarding identifying concerning behaviours which may be linked to sexting?
- All staff should be aware safeguarding issues can manifest themselves via peer on peer abuse. This is most likely to include, but not limited to: bullying (including cyber bullying), gender based violence/sexual assaults and sexting. Staff should be clear as to the school or college’s policy and procedures with regards to peer on peer abuse. (p.12)
- Does our school/college provide training to members of staff regarding peer on peer abuse, including cyberbullying and sexting?
- Expert and professional organisations are best placed to provide up-to-date guidance and practical support on specific safeguarding issues. …bullying including cyberbullying… child sexual exploitation (CSE) and Annex A....preventing radicalisation – and Annex A….sexting.(p.12)
- Annex A contains important additional information about specific forms of abuse and safeguarding issues. School leaders and those staff that work directly with children should read the annex. (p.13)
Part two: The management of safeguarding
Legislation and the law
- Governing bodies and proprietors (in Part two unless otherwise stated this includes management committees) must ensure that they comply with their duties under legislation. They must have regard to this guidance to ensure that the policies, procedures and training in their schools or colleges are effective and comply with the law at all times (p.15)
- Do our school/college leaders have an understanding of the relevant legislation which applies to online safeguarding?
- Governing bodies and proprietors should ensure there are appropriate policies and procedures in place in order for appropriate action to be taken in a timely manner to safeguard and promote children’s welfare. (p.14)
- This should include:
- an effective child protection policy; and
- a staff behaviour policy (sometimes called the code of conduct) which should amongst other things include - acceptable use of technologies, staff/pupil relationships and communications including the use of social media. (p.14-15)
- UK Safer Internet Centre
- Childnet International
- South West Grid for Learning
- London Grid for Learning
- Northern Grid (Digitally Confident)
- Does our school/college child protection policy include online safety (either within the policy itself or references a separate online safety policy)?
- Does our school/college staff behaviour policy (or code of conduct or Acceptable Use Policy) cover the acceptable use of technology, including communication via social media?
- How do we ensure that this information is communicated with and understood by all members of staff?
- How do we communicate any changes or updates in our policies with staff?
The designated safeguarding lead
- Governing bodies and proprietors should appoint an appropriate senior member of staff, from the school or college leadership team, to the role of designated safeguarding lead. The designated safeguarding lead should take lead responsibility for safeguarding and child protection. (p.15)
- It is a matter for individual schools and colleges as to whether they choose to have one or more deputy designated safeguarding lead(s). Any deputies should be trained to the same standard as the designated safeguarding lead. (p.15)
- Whilst the activities of the designated safeguarding lead can be delegated to appropriately trained deputies, the ultimate lead responsibility for safeguarding and child protection, as set out above, remains with the designated safeguarding lead. This responsibility should not be delegated. (p.15)
- The designated safeguarding lead and any deputies should liaise with the local authority and work with other agencies in line with Working together to safeguard children. (p.15)
- The designated safeguarding lead and any deputies should undergo training to provide them with the knowledge and skills required to carry out the role. The training should be updated every two years. (p.15-16)
- In addition to their formal training, as set out above, their knowledge and skills should be updated, (for example via e-bulletins, meeting other designated safeguarding leads, or taking time to read and digest safeguarding developments), at regular intervals, but at least annually, to keep up with any developments relevant to their role. (p.16)
- Is the school/college DSL considered to be the lead person responsible for online safety?
- If not, have any other persons responsible had appropriate training to enable them to support the DSL?
- If appropriate, has the school identified other members of staff who may have skills, expertise or interests that may enable them to support the DSL?
- If so, who are they and have they had appropriate training to enable them to support the DSL?
- Has the DSL (and any other appropriate members of staff as identified by the school/college) had appropriate training to enable them to respond to online safety concern?
- Does this training include developing an up-to-date awareness of both risks and benefits of technology and an awareness of both national and local policy and procedures.
- Governing bodies and proprietors should ensure that all staff members undergo safeguarding and child protection training at induction. The training should be regularly updated. Induction and training should be in line with advice from the LSCB. (p.17)
- In addition all staff members should receive regular safeguarding and child protection updates (for example, via email, e-bulletins, staff meetings), as required, but at least annually, to provide them with relevant skills and knowledge to safeguard children effectively. (p.17)
- Governing bodies and proprietors should recognise the expertise staff build by undertaking safeguarding training and managing safeguarding concerns on a daily basis. Opportunity should therefore be provided for staff to contribute to and shape safeguarding arrangements and child protection policy. (p.17)
- How does our school/college provide appropriate, up-to-date and relevant whole staff training which includes online safety?
- How does our school/college involve staff in developing and contributing to online safety policies and procedures?
- As schools and colleges increasingly work online it is essential that children are safeguarded from potentially harmful and inappropriate online material. As such governing bodies and proprietors should ensure appropriate filters and appropriate monitoring systems are in place. Additional information to support governing bodies and proprietors is provided in Annex C.
- Does our school/college clearly view online safety as a safeguarding concern?
- Has our DSL, governing body/proprietor etc. read and understood annex C?
- Have the Governor's accessed the UKCCIS online safety for school Governors guidance?
- Can this document be used to help provide evidence of strategic Governor oversight?
Opportunities to teach safeguarding
- Governing bodies and proprietors should ensure children are taught about safeguarding, including online, through teaching and learning opportunities, as part of providing a broad and balanced curriculum. This may include covering relevant issues through personal, social, health and economic education (PSHE), tutorials (in FE colleges) and/or – for maintained schools and colleges – through sex and relationship education (SRE). (p.17-18)
- How does our school/college current teach children about online safety?
- Are all year groups receiving online safety education that is relevant, up-to-date and appropriate to them?
- Is there a clear scheme of work which identifies relevant and appropriate teaching resources?
- Is the online safety curriculum differentiated to our learners needs, ages and abilities?
- How does the school/college identify and target children who may require more specific educational approaches to enable them to build online safety skills?
- How are children and young people involved in the development of the online safety curriculum?
- Is the online safety curriculum integrated throughout the academic year?
- Is the online safety curriculum integrated throughout all subject areas?
- How does our school/college use external speakers to complement our own internal education approaches?
- Whilst it is essential that governing bodies and proprietors ensure that appropriate filters and monitoring systems are in place; they should be careful that “over blocking” does not lead to unreasonable restrictions as to what children can be taught with regards to online teaching and safeguarding. (p.18)
- How does the governing body/proprietor make informed decisions regarding the school/college filtering and monitoring systems and associated decisions?
- How is this captured and recorded?
- From September 2015 all inspections by Ofsted have been made under: A new common inspection framework: education, skills and early years. Inspectors will always report on whether or not arrangements for safeguarding children and learners are effective. Ofsted has published a document setting out the approach inspectors should take to inspecting safeguarding: Inspecting safeguarding in early years, education and skills settings. Individual inspectorates will also report on safeguarding arrangements and have published frameworks which inform how they inspect the independent schools that are not inspected by Ofsted at: School Inspection Service and Independent Schools Inspectorate. (p.18)
- Are all members of staff (especially leadership staff) aware of online safety within the Ofsted Common Inspection Framework?
- Has the school/college reviewed current practice and identified areas for improvement?
Allegations of abuse made against other children
- Staff should recognise that children are capable of abusing their peers. Governing bodies and proprietors should ensure their child protection policy includes procedures to minimise the risk of peer on peer abuse and sets out how allegations of peer on peer abuse will be investigated and dealt with. The policy should reflect the different forms peer on peer abuse can take, make clear that abuse is abuse and should never be tolerated or passed off as “banter” or “part of growing up”. It should be clear as to how victims of peer on peer abuse will be supported. (p.19)
- Peer on peer abuse can manifest itself in many ways. Governors and proprietors should ensure sexting and the school or colleges approach to it is reflected in the child protection policy. The department provides searching screening and confiscation advice for schools (link). Child Exploitation Online Protection Centre (CEOP) has recently updated their sexting guidance: Sexting in Schools and Colleges. (p.19)
- Is the DSL familiar with local and national guidance for responding to allegations of abuse against other children?
- How has the DSL communicated this information to other members of staff?
Annex A: Further information
Further information on child sexual exploitationChild sexual exploitation is a form of sexual abuse where children are sexually exploited for money, power or status. It can involve violent, humiliating and degrading sexual assaults. In some cases, young people are persuaded or forced into exchanging sexual activity for money, drugs, gifts, affection or status. Consent cannot be given, even where a child may believe they are voluntarily engaging in sexual activity with the person who is exploiting them. Child sexual exploitation does not always involve physical contact and can happen online... (p.52-53) Child sexual exploitation (CSE) may involve the role of the internet to identify potential victims or as a tool to coerce and blackmail children into performing sexual acts, both on and offline. The internet may also be provided to children as a “gift” by perpetrators, for example in the form of new mobile phones and devices. In some cases CSE can entirely take place online, for example children being coerced into performing sexual acts via webcam, and may not always result in a physical meeting between children and the offender. DSLs should be aware of national and local policy and procedures regarding CSE. The Kent County Council online safety policy template and guidance covers responding to online CSE concerns. Further information about local approaches, including the CSET team and Operation Willow is available. The KSCB CSE toolkit is available to enable DSLs to consider possible risks. Multi-agency CSE training is also available via the KSCB. Action point:
- Does the safeguarding and child protection policy include responding to the risk of CSE?
- Does this include the use of technology as a tool for CSE within all appropriate policies?
- Has the DSL had appropriate training regarding CSE?
- How does the DSL communicate awareness and understanding of CSE (including online CSE) to staff?
- How are children educated to be aware of CSE (including online CSE) appropriately to their age and ability?
Further information on preventing radicalisationProtecting children from the risk of radicalisation should be seen as part of schools’ and colleges’ wider safeguarding duties, and is similar in nature to protecting children from other forms of harm and abuse. During the process of radicalisation it is possible to intervene to prevent vulnerable people being radicalised. (p.54-55) Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. It can happen in many different ways and settings. Specific background factors may contribute to vulnerability which are often combined with specific influences such as family, friends or online, and with specific needs for which an extremist or terrorist group may appear to provide an answer. The internet and the use of social media in particular has become a major factor in the radicalisation of young people. (p.55) Schools must ensure that children are safe from terrorist and extremist material when accessing the internet in schools. (p.56) This highlights the role of the internet as a tool in the radicalisation of young people and also in the potential accidental and deliberate exposure of young people and adults to extremism views and content. This section highlights that procedures for responding to radicalisation may be set out in existing safeguarding policies and separate policies are not necessary. DSLs should be aware of national and local policy and procedures regarding radicalisation. The Kent County Council Safeguarding and Child Protection Policy template and online safety policy template and guidance covers responding to radicalisation concerns. Further information about Prevent Duty and the Kent approach (including procedures, tools and training) can be found on Kelsi . The Department for Education has also published advice for schools on the Prevent duty. The Government has also launched a website called educate against hate, which is designed to equip school and college leaders, teachers and parents with the information, tools and resources they need to recognise and address extremism and radicalisation in young people and this includes online issues. Action point:
- Does the safeguarding and child protection policy include responding to the risk of radicalisation?
- Does this include the use of technology as a tool for radicalisation within all appropriate policies?
- Has the DSL had appropriate training regarding radicalisation and Prevent?
- How does the DSL communicate awareness and understanding of radicalisation (including online) to staff?
- How are children educated to be aware of radicalisation (including online) appropriately to their age and ability?
Annex B: Role of the designated safeguarding leadThis section (p.58-60) highlights the roles and responsibilities of the DSL(s) including managing referrals, multi-agency working, training, record keeping, awareness raising and availability. These roles and responsibilities will also apply to online safety concerns, especially as some online issues may require referral to other agencies and schools/colleges will need to raise awareness of recognising, responding, recording and referring online safeguarding issues with all members of staff.
Annex C: Online safetyThe use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation - technology often provides the platform that facilitates harm. An effective approach to online safety empowers a school or college to protect and educate the whole school or college community in their use of technology and establishes mechanisms to identify, intervene and escalate any incident where appropriate. (p.61) This clearly identifies online safety as a safeguarding responsibility and highlights the need for schools and colleges to ensure that all members of their communities are able to develop appropriate understanding and skills to prepare them to respond to online safety issues. The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk:
- content: being exposed to illegal, inappropriate or harmful material
- contact: being subjected to harmful online interaction with other users
- conduct: personal online behaviour that increases the likelihood of, or causes, harm (p.61)
- Does the online safety curriculum cover the full range of potential online risks which children may encounter?
Filters and monitoringGoverning bodies and proprietors should be doing all that they reasonably can to limit children’s exposure to the above risks from the school or colleges IT system. As part of this process governing bodies and proprietors should ensure their school has appropriate filters and monitoring systems in place. Whilst considering their responsibility to safeguard and promote the welfare of children, and provide them a safe environment in which to learn, governing bodies and proprietors should consider the age range of their pupils, the number of pupils, how often they access the schools IT system and the proportionality of costs Vs risks. The appropriateness of any filters and monitoring systems are a matter for individual schools and colleges and will be informed in part by the risk assessment required by the Prevent Duty. The UK Safer Internet Centre has published guidance as to what “appropriate” might look like: UK Safer Internet Centre: appropriate filtering and monitoring Guidance on e-security is available from the National Education network (NEN). Buying advice for schools is available here: buying for schools. (p.61) Governing bodies and proprietors must make informed decisions regarding the safety and security of the internet access and equipment available in their settings. Governing bodies and proprietors must ensure that the welfare of children and young people is paramount at all times. Any decisions taken regarding filtering and monitoring systems should be taken from a safeguarding, educational and technical approach and should be justifiable and documented. When reviewing filtering and monitoring systems and approach some governing bodies and proprietors may wish to undertake an approach which includes robust risk assessments and a through comparison which identify both the benefits and limitations of the services. The UK Safer internet Centre have put together excellent guidance for schools and colleges about appropriate filtering and monitoring : UK Safer Internet Centre: appropriate filtering and monitoring. It is recommended that governing bodies, proprietors and DSLs read and consider this guidance when considering their filtering and monitoring systems and any associated decisions. Schools may also wish to approach their broadband provider to consider the range of tools available to them which may enable them to develop strategies to control and supervise their internet use and systems appropriately. Kent schools and settings using the EIS School Broadband system will be using the LightSpeed system which already has a range of tools which may enable schools to be able to demonstrate they have an understanding of appropriate filtering and monitoring and have systems already in place. Further information about LightSpeed can be accessed via EiS. Both Lightspeed and EiS have completed a response form for the UK Safer Internet Centre. Action point:
- Does the Headteacher/governing body/proprietor understand the current school/college filtering/monitoring systems?
- If not, how can this be developed?
- How do the gHeadteacher/governing body/proprietor work with the technical team (e.g. broadband provider, IT Technicians, Network Managers or IT service providers) to make filtering and monitoring decisions?
- If so, how is this documented?
- Has the Headteacher/governing body/proprietor accessed the UK Safer Internet centre (and any local guidance) material regarding appropriate filtering and monitoring?
- Does the school/college understand that filtering and monitoring will not always be effective as removing risk?
- How do all members of staff ensure that technology in the classroom is used as safely and effectively as possible?
- Does the school provide all members of staff with clear expectations regarding use of technology e.g. supervision, pre-checking content before use, use of age appropriate tools, understanding of data protection concerns, clear risk assessments etc.
- Does the school/college have a policy regarding safe and appropriate use of mobile phones and personal devices?
Staff trainingGovernors and proprietors should ensure that as part of the requirement for staff to undergo regularly updated safeguarding training (paragraph 64) and the requirement to ensure children are taught about safeguarding, including online (paragraph 68), that online safety training for staff is integrated, aligned and considered as part of the overarching safeguarding approach. (p.62) This identifies that all members of staff must have access to appropriate, regular and up-to-date online safety training as part of their safeguarding training. Schools and colleges will need to consider how this is implemented within their own settings (e.g. integrated within existing safeguarding and child protection training or as separate and specific online safety training). Frequently during online safety training provided by the Education Safeguarding team, school leaders and non-teaching staff are absent. Whilst ensuring a whole staff group presence is difficult due to demands on time, resources and other commitments, a failure to identify online safety as a whole school issue could potentially undermine the school/colleges safeguarding practice, ultimately leaving children and adults vulnerable. Online safety training should be accessed by ALL members of staff, not just teaching staff. A child could disclose an online safety concern to any adult, therefore all members of staff (including external staff and volunteers) should be made aware of how to recognise, respond to, record and referral all safeguarding concerns, including online issues. School leaders must also access this training to ensure that messages are appropriate and consistent and also to demonstrate to staff that safeguarding is a key propriety at the school. Kent schools and colleges can access the Education Safeguarding Adviser (Online Protection) or the e-Safety Development Officer who provide centralised training as well as consultations and support for DSLs or can provide schools and colleges with bespoke whole staff training. Kent DSLs can access a template presentation via Education Safeguarding Adviser (Online Protection) or the e-Safety Development Officer to use as part of staff training. Other useful links to support staff training include:
- Childnet - Inset presentation
- Childnet - Guidance for working with young people
- Childnet - Guidance for you as a professional
- Childnet - Professional Reputation
- UK Safer Internet Centre - Professional Reputation
- UK Safer Internet Centre Helpline
- UK Safer Internet Centre Helpline FAQs
- KSCB - Safer Practice with Technology
- How does the school/college provide all members of staff with appropriate and up-to-date training regarding online safety?
- If so, is it embedded within safeguarding training or is it separate and specific?
- Is it provided to ALL members of staff, including non-teaching staff, school leaders and volunteers?
- Does staff training cover safeguarding children online as well as expectations for professional practice?
Information and support
There is a wealth of information available to support schools and colleges to keep children safe online. The following is not exhaustive but should provide a useful starting point:
- www.gov.uk/government/publications/the-use-of-social-media-for-online-radicalisation (p.62)
- How does the school/college (specially the DSL) keep up-to-date with developments within the online safety agenda?