3.1.3 Online Safety
AMENDMENTMinor amendments were made to this chapter in March 2022, to include information on sexting. Section 8, Procedures for Reporting Concerns was also revised.
Traditionally the term online Safety was synonymous with protection against Sexual Exploitation and Cyberbullying however in 2021 professionals should be aware that this term additionally covers education, advice and protection around areas including, Criminal Exploitation, Radicalisation, Cybersecurity and Health and Wellbeing all of which have a large 'online' component.
The continual growth and widespread use of the Internet, mobile phone and gaming technology has significantly enhanced our ability to communicate, share information, images, be entertained, and learn. There are enormous benefits to using digital media, which has revolutionised our lives. It is important to recognise that digital technology is integral to the lives of children and young people in today's society and that the majority have widespread access to the internet on their mobile phones, tablets and gaming devices via WiFi. Much of their WiFi access is free and unrestricted both publicly and in the home. This can make parental control of content and contact very challenging.
Many of these technologies are used as powerful tools for teaching and learning in schools and other educational settings. Within school children are heavily protected in the online environment, and much work has already been done in our schools with staff, pupils and parents/carers to raise awareness of the risks associated with using digital technology. The boundaries of technology reach far beyond the school gate and we have a responsibility, therefore, as part of the wider duty of care, to safeguard and promote the welfare of children and young people and help them develop the skills to look after themselves both in and out of school. We also have a responsibility to take action against those who harm children and young people via digital technology.
Online safety awareness has been extended to some Children's Services and partner agencies who work with children and young people. The challenge is to roll this out to the wider community whilst keeping abreast of new technological developments and to empower parents and other responsible adults so that they can concentrate on the behaviours of children and young people online which expose them to increased risk rather than the technology itself. As professionals it is important that we refrain from vilifying individual apps or games, which change frequently but rather concentrate on the behaviour within the app or game that increases risk. The Covid 19 pandemic has undoubtedly changed the online landscape for us all but particularly our young people. Going forward it will be increasingly necessary to adopt contextual safeguarding techniques within the online space and have much more nuanced conversations with young people about their behaviour and being safe. As in the real world we must not blame young people for their exploitation online particularly if they are in an age inappropriate space. The fault always lies with those who choose to exploit or abuse children.
This procedure is about safeguarding children and young people in a digital generation. However, due to the vulnerability of some adult practitioners to being cyberbullied and the exponential use of social media, guidance is provided for practitioners to be able to safeguard themselves online.
Appendix3: Guidance for Practitioners to Minimise the Risk of Misconduct Allegations related to Digital and Interactive Technology provides guidance to practitioners to better be able to safeguard themselves. Organisations should have their own Acceptable use Policy consistent with their organisations protocols. This should be shared with all stakeholders using the organisation's systems. This should be linked to their Online Safety Policy.
The effects of abuse suffered by children and young people via digital technology are the same as that which occurs via personal contact. Indeed, some physical and sexual abuse may occur as a result of initial contact online via digital technology or indeed can be wholly carried out online. However, the impact may be more severe in some cases as the abuse can take place in the home, where a child or young person should feel safe. Therefore, it is the responsibility of all practitioners to ensure they know what to do if they suspect a child or young person is involved, or at risk of involvement, either as a victim or perpetrator, of exploitation of any type online or via digital technology. The purpose of this procedure is, therefore, to provide guidance to all those working with children, young people and their families in Sheffield.
The aims of this procedure are as follows:
- To define the different types of digital technology and the risks they present to children and young people;
- To provide guidance to practitioners regarding the safeguards that should be in place to protect children and young people using digital technology, whatever the setting;
- To provide information about some risk indicators in relation to the internet and digital technology;
- To provide guidance to practitioners as to what action they should take if they are concerned about a child or young person related to digital and interactive technology, and provide information about legislation;
- To provide guidance to practitioners about how to minimise risk for themselves, so that they do not inadvertently leave themselves open to allegations of practitioner misconduct from children and young people, or their parents / carers.
4.1 Online Safety
This is the generic term that refers to raising awareness about how children, young people and adults can protect themselves whilst using digital technology and online environments, and also interventions that can reduce the level of risk for children and young people.
Please see NSPCC Learning on Online Abuse for more information.
Online Safety covers the following areas – Please see UK Council for Child Internet Safety - Education for a Connected World for more information.
- Health and Wellbeing, Sleep, Body image, Balance of on and offline activity, Mental Health, Purchasing drugs online, Accessing positive health information and identifying misinformation e.g. Pro Suicide or Pro Anorexia;
- Sexual Exploitation including the sharing of Nudes and Semi Nudes. See Sharing Nudes and Semi-nudes: Advice for Education Settings Working with Children and Young people;
- Cyberbullying Please see NSPCC Bullying and Cyberbullying Learning;
- Gang Culture and Criminal Exploitation;
- Cybersecurity and cyber criminality e.g. Hacking;
- Radicalisation including verifying information.
It is important to note that in general terms an action that is illegal if committed offline is also illegal if committed online. It is recommended that legal advice is sought in the event of an online issue or situation.
The Serious Crime Act 2015
Introduced an offence of sexual communication with a child. This applies to an adult who communicates with a child and the communication is sexual or if it is intended to elicit from the child a communication which is sexual and the adult reasonably believes the child to be under 16 years of age.
The Act also amended the Sex Offences Act 2003 so it is an offence for an adult to arrange to meet with someone under 16 having communicated with them on just one occasion (previously it was on at least two occasions).
Computer Misuse Act 1990
This Act makes it an offence to:
- Erase or amend data or programs without authority;
- Obtain unauthorised access to a computer;
- "Eavesdrop" on a computer;
- Make unauthorised use of computer time or facilities;
- Maliciously corrupt or erase data or programs;
- Deny access to authorised users.
Data Protection Act 2018 and UK GDPR
This protects the rights and privacy of individual's data. To comply with the law, information about individuals must be collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully. The Act states that person data must be:
- Fairly and lawfully processed;
- Processed for limited purposes;
- Adequate, relevant and not excessive;
- Not kept longer than necessary;
- Processed in accordance with the data subject's rights;
- Not transferred to other countries without adequate protection;
- Data subjects have the right to request information stored about them.
Freedom of Information Act 2000
The Freedom of Information Act gives individuals the right to request information held by public authorities. All public authorities and companies wholly owned by public authorities have obligations under the Freedom of Information Act. When responding to requests, they have to follow a number of set procedures.
Communications Act 2003
Sending by means of the Internet a message or other matter that is grossly offensive or of an indecent, obscene or menacing character; or sending a false message by means of or persistently making use of the Internet for the purpose of causing annoyance, inconvenience or needless anxiety is guilty of an offence liable, on conviction, to imprisonment. This wording is important because an offence is complete as soon as the message has been sent: there is no need to prove any intent or purpose.
Malicious Communications Act 1988
It is an offence to send an indecent, offensive, or threatening letter, electronic communication or other article to another person.
Regulation of Investigatory Powers Act 2000
It is an offence for any person to intentionally and without lawful authority intercept any communication. Monitoring or keeping a record of any form of electronic communications is permitted, in order to:
- Establish the facts;
- Ascertain compliance with regulatory or self-regulatory practices or procedures;
- Demonstrate standards, which are or ought to be achieved by persons using the system;
- Investigate or detect unauthorised use of the communications system;
- Prevent or detect crime or in the interests of national security;
- Ensure the effective operation of the system;
- Monitoring but not recording is also permissible in order to:
- Ascertain whether the communication is business or personal;
- Protect or support help line staff.
Telecommunications Act 1984
It is an offence to send a message or other matter that is grossly offensive or of an indecent, obscene or menacing character. It is also an offence to send a message that is intended to cause annoyance, inconvenience or needless anxiety to another that the sender knows to be false.
Criminal Justice & Public Order Act 1994
This defines a criminal offence of intentional harassment, which covers all forms of harassment, including sexual. A person is guilty of an offence if, with intent to cause a person harassment, alarm or distress, they:
- Use threatening, abusive or insulting words or behaviour, or disorderly behaviour; or
- Display any writing, sign or other visible representation, which is threatening, abusive or insulting, thereby causing that or another person harassment, alarm or distress.
Protection from Harassment Act 1997
A person must not pursue a course of conduct, which amounts to harassment of another, and which he knows or ought to know amounts to harassment of the other. A person whose course of conduct causes another to fear, on at least two occasions, that violence will be used against him is guilty of an offence if he knows or ought to know that his course of conduct will cause the other so to fear on each of those occasions.
Protection of Children Act 1978
It is an offence to take, permit to be taken, make, possess, show, distribute or advertise indecent images of children in the United Kingdom. A child for these purposes is a anyone under the age of 18. Viewing an indecent image of a child on your computer means that you have made a digital image. An image of a child also covers pseudo-photographs (digitally collated or otherwise). A person convicted of such an offence may face up to 10 years in prison.
Sexual Offences Act 2003
The offence of grooming is committed if you are over 18 and have communicated with a child under 16 at least once (previously twice) (including by phone or using the Internet) it is an offence to meet them or travel to meet them anywhere in the world with the intention of committing a sexual offence. Causing a child under 16 to watch a sexual act is illegal, including looking at images such as videos, photos or webcams, for your own gratification. It is also an offence for a person in a position of trust to engage in sexual activity with any person under 18, with whom they are in a position of trust. (Typically, teachers, social workers, health professionals, connexions staff fall in this category of trust). Any sexual intercourse with a child under the age of 13 commits the offence of rape.
Public Order Act 1986
This Act makes it a criminal offence to stir up racial hatred by displaying, publishing or distributing written material which is threatening. Like the Racial and Religious Hatred Act 2006 it also makes the possession of inflammatory material with a view of releasing it a criminal offence.
Obscene Publications Act 1959 and 1964
Publishing an "obscene" article is a criminal offence. Publishing includes electronic transmission.
Human Rights Act 1998
This does not deal with any particular issue specifically or any discrete subject area within the law. It is a type of "higher law", affecting all other laws. In the context of work with young people, human rights to be aware of include:
- The right to a fair trial;
- The right to respect for private and family life, home and correspondence;
- Freedom of thought, conscience and religion;
- Freedom of expression;
- Freedom of assembly;
- Prohibition of discrimination;
- The right to education.
These rights are not absolute. The school is obliged to respect these rights and freedoms, balancing them against those rights, duties and obligations, which arise from other relevant legislation.
The Education and Inspections Act 2006
Empowers school Head Teachers, to such extent as is reasonable, to regulate the behaviour of students / pupils when they are off the school site and empowers members of staff to impose disciplinary penalties for inappropriate behaviour.
Counter-Terrorism and Security Act 2015
From 1 July 2015 all schools, registered early years childcare providers and registered later years childcare providers are subject to a duty under Section 26 of the Counter-Terrorism and Security Act 2015, in the exercise of their functions, to have 'due regard to the need to prevent people from being drawn into terrorism'. See also Children Vulnerable to or from Extremism Procedure.
Section 33 of the Criminal Justice and Courts Act 2015
This refers to the offence dealing with Revenge Pornography, this is a law for adults, over the age of 18, which says that it is illegal to share or make public sexually explicit images of someone else, without their consent, with the intent to cause distress. See Section 33 of the Criminal Justice and Courts Act 2015.
Domestic Abuse Act 2021
With effect from 29 June 2021, section 69 Domestic Abuse Act 2021 expanded so-called 'revenge porn' to include threats to disclose private sexual photographs and films with intent to cause distress.
6. Categories of Risk
Safer Children in a Digital World: The Report of the Byron Review (DCSF, 2008) highlighted the following categories of risk to children and young people.
This includes illegal or inappropriate content of Internet website's, games, e-mails, mobile phones or other communication. This may include inappropriately accessing material that is of a sexual or violent nature including child abuse or adult pornography, age inappropriate online gaming; extremist websites/apps/users which include animal rights activists, terrorism, Islamic fundamentalism or right wing extremism; websites/ apps/users promoting gangs and weapons; and health issues such as pro-suicide or eating disorder website's. Offences may be committed in accessing and distributing the material on such sites.
Issues related to conduct include anti-social or illegal behaviour such as illegal downloading of music or video files, hacking into systems and profiles and the buying or selling of illegal items e.g. drugs.
One issue of concern is self-taken sexually explicit images or nudes. These are taken via webcam or by mobile phone camera and then distributed. Whilst some young people may think such images are solely for their 'boyfriend/girlfriend' for example, these can be widely circulated via the Internet or mobile phones and can be redistributed by offenders.
Sexting is a term which many young people do not recognise or use, therefore it is important that when discussing the risks of this type of behaviour with children and young people the behaviour is accurately explained.
It is a crime to take, make, permit to take, distribute, show, possess, possess with intent to distribute, or to advertise indecent photographs or pseudo-photographs of any person below the age of 18. Children and young people need to be aware that they may be breaking the law when taking and distributing "nudes " but prosecution will usually only take place when it is considered to be in the public's best interest. The current National Police Chief's Council (NPCC) position is that:
'ACPO does not support the prosecution or criminalisation of children for taking indecent images of themselves and sharing them. Being prosecuted through the criminal justice system is likely to be upsetting and distressing for children especially if they are convicted and punished. The label of sex offender that would be applied to a child or young person convicted of such offences is regrettable, unjust and clearly detrimental to their future health and wellbeing.'
Where young people are voluntarily sending/sharing sexual images or content with one another the police may use the 'outcome 21' recording code.
This outcome code allows the police to record a crime as having happened but for no formal criminal justice action to be taken. Crimes recorded this way are unlikely to appear on future records or checks, unless the young person has been involved in other similar activities which may indicate they are at risk.
The discretion about whether to disclose non-conviction information rests with each Chief Constable managing the process. Although no guarantee can be provided, it will be a very small number of unusual cases which may lead to a further disclosure.
One of the main concerns relating to contact is the risk of physical and / or sexual abuse, and the resulting psychological trauma suffered as a result of this. Exploitation can take place through meeting or can be wholly online via webcam. Children and young people can be groomed online by both adults and other young people for the purpose of sexual exploitation. Grooming can take place online in environments such as, social networks, online gaming, chatrooms, private messaging services etc.
Children and young people can also be groomed and radicalised online with a view to being drawn into extremist and terrorist behaviour. From 1 July 2015 all schools, colleges, registered early years childcare providers and registered later years childcare providers are subject to a duty under Section 26 of the Counter-Terrorism and Security Act 2015, in the exercise of their functions, to have 'due regard to the need to prevent people from being drawn into terrorism'. See also Children Vulnerable to or from Extremism Procedure.
Cyber bullying is defined as "the use of Information Communications Technology (ICT), particularly mobile phones and the internet, deliberately to upset someone else" (DfE definition).
Cyberbullying may take the form of hate crime, as an issue of race, disability and / or sexual orientation or gender identity.
- It differs from other forms of bullying, for example:
- The bullying can be pervasive as the child or young person can be accessed any time, including in their home and personal space where they would normally feel safe;
- There is no control over the size of the audience;
- There is often no closure as it is difficult to know if the problem has been contained or if it will resurface;
- Bullies often think they are anonymous;
- Evidence of cyberbullying can be obtained from mobile phones and websites such as social networks.
- It may be used as a form of revenge and is sometimes used to 'get even' when the victim can become the perpetrator. Bystanders can become accessories to the bullying, e.g. through laughing at the messages and / or texts, through distribution or contributing to the messages;
- Mobile phones, social networks and online gaming are some examples of where victimisation takes place. Cyberbullying is greater outside than inside school, but its origins and consequences may be in school;
- Trolling is when disrespectful, abusive and bullying comments are deliberately left on a webpage or social networking profile so that the reader is made to feel bullied, sad or threatened.
Adults working with children and young people are also vulnerable to being cyberbullied and are particularly susceptible to risks from social networking.
The fourth category of risk to children and young people is through commercial exploitation. This may take place through online gambling, or financial scams, for example. Social networks also have targeted advertising in user profiles.Security in the online world is made more complex for children and young people by the expansion of social media apps and games to incorporate a wide range of online functions e.g. social media, chat functions, in app purchases, photo sharing, location information, one to one messaging and live video streaming. This makes the protection of their privacy more complex and the implications of any lapses far-reaching.
7. Minimising Risk
For children to safely benefit from the opportunities and experience the internet offers they need to access age appropriate Online Safety education as part of PSHE. Keeping Children Safe in Education 2018 required that children have a progressive online safety education from ages 5-18 and this is reiterated in the RSHE guidelines published for first teaching in September 2020.
Sheffield City Council e-Learning Service produced an Online Safety curriculum which is available to all schools through Learn Sheffield. The same service has produced the Sheffield RSHE curriculum 2020 in which Online safety education had been subsumed. This is also available through Learn Sheffield.
7.1 Supporting Parents to Safeguard their Children
We need to ensure that those who care for children are equipped with the knowledge and understanding of how to keep them safe and what to do if things go wrong.
It is important that we support parents by raising awareness of the benefits, risks and dangers to help them understand more about what their children are doing online. We need to offer practical advice and guidance on how to keep their family safe online and what to do if things go wrong.
7.2 Adhering to Acceptable Use Policies in all Establishments
There is a requirement to ensure that children, young people and staff use the internet and related technologies appropriately and safely. The implementation of an Online Safety policy and acceptable use policies for young people and staff should provide a structure to safe online safety practice. These may be built into existing safeguarding policies and practice but they should clearly identify ways in which these technologies can and cannot be used and the procedures and support strategies for misuse. See Appendix 1: Online Safety Policy for an exemplar Policy and Appendix 2: Guidance for Practitioners to Minimise the Risk of Misconduct Allegations related to Digital and Interactive Technology. Online Safety incidents should always be referrered to the DSL who should follow the standard safeguarding routes for reporting. The responsibility for Online Safety lies with the DSL.
While there is no guaranteed method of protecting users when on line, there are some software solutions that can filter or block content. The majority of Sheffield schools obtain their unfiltered Internet feed from Virgin Media and then use the "Smoothwall" filtering and monitoring solution. This automatically includes update information from the Internet Watch Foundation but there is also the facility for schools to choose their own filtering requirements from within the general provision. This provision is currently being explored for use in other children's settings. In other settings, where the Internet feed is not filtered, then individual machines can have specific filtering software applied. This needs to be undertaken with the agreement of senior management.It should be noted that no filtering system is totally secure with methods to bypass system being freely available and updated at least daily. The best filtering solution for young people is supervision, education and an open dialogue with parents and supervising adults so that the young person can report concerns without risking losing access to technology.
8. Procedures for Reporting Concerns
If you are concerned that an offence has been committed, or a child or young person is at risk due to their, or another's, use of digital or interactive technology, the following steps should be taken.
If a worker is concerned that a child has suffered, or is likely to suffer, Significant Harm, a telephone referral must be made as soon as possible to Children's Social Care: see Local Contacts. For more information see Making a Referral following the Identification of Child Safety and Welfare Concerns.
In an emergency, ring 999 to contact South Yorkshire Police.
If a practitioner believes a child has additional needs or is a child in need, but is not likely to suffer Significant Harm, they should refer them to the Multi-Agency Support Team (MAST). The MAST will undertake An FCAF, refer them to the Interim FCAF Panel / Allocation Panel, and as a result appropriate support services will be put in place for the child and their family, in order to improve their outcomes. See Local Contacts for contact details.
If your concern is about cyberbullying, commercial exploitation, inappropriate or illegal content of website's etc. but you do not think a child or young person is likely to suffer Significant Harm, then you should ring South Yorkshire Police.
Online safety help for professionals is available from the UK Safer Internet Centre Professional Online Safety Helpline. E-mail: email@example.com. Telephone: 0344 381 4772. Web: UK Safer Internet Centre: Professional Reputation.
Online help and reporting of sexual exploitation is available through the Child Exploitation and Online Protection (CEOP) Advice, Help and Support Centre.
A wide variety of advice for professional is available on The Report Harmful Content Website - This includes valuable information on how to report through regularly used social media and gaming sites.
Useful Reports for background knowledge:
UK Council for Child Internet Safety - Education for a Connected World - Although intended for Educational use this document will give professionals a good insight into the scope of Online Safety in 2021 and the opportunities and risks that is affords to children and young people of all ages.
Ofsted Review of Sexual Abuse in Schools and Colleges (including Online) - This report is useful reading for everyone working in schools or with children and young people.
Internet Matters – Vulnerable Children in a Digital World - This report begins to classify the additional risks that vulnerable children and young people face in the digital space.
Children's Commissioner For England Life in 'Likes' (2018) - This report gives insight into the digital lives of 8-12 year old children and their parents.
Children's Commissioner for England Who Knows What about Me (2018) - This report gives professionals an insight about how much data is stored about young people online.
The Children's Commissioner for England's Digital Section - a useful place for professional to get current information. It has recent useful reports to help them understand app use, gaming and gambling etc.
Ofcom Children's Media Lives: Life in Lockdown - This will give professionals a valuable insight into how children's lives online have changed as a result of the Covid19 pandemic.
Advice Pages for Parents – Also useful for professionals:
NSPCC Net Aware - Advice about individual Apps
Coram Children's Legal Centre - LawStuff is run by Coram Children's Legal Centre and gives free legal information to young people on a range of different issues. See Children's Rights in the Digital World in particular.
Report Harmful Content – This site looks at armful content in its broadest terms and advises on reporting it in each individual app.
NSPCC Report Remove Tool – The tool enables young people under the age of 18 to report a nude image or video of themselves which has appeared online. The Internet Watch Foundation will review these reports and work to remove any content which breaks the law.
UK Council for Internet Safety (UKCIS) Digital Passport – A communication tool to support children and young people with care experience to talk with their carers about their online lives.
Appendix 1: Online Safety Policy
- Benefits of the Internet for Children and Young People
- Managing Internet Use in Organisational Settings
- Publishing Images and Work on the Internet
- Managing other Technologies
- Assessing Risk
- Handling Online Safety Complaints
- Communicating the Contents of this Policy
Online Safety encompasses Internet technologies and electronic communications such as mobile phones and wireless technology. It highlights the need to educate children and young people about the benefits and risks of using new technology - including computers, mobile phones and online games - and provides safeguards and awareness for users to enable them to control their online experiences.
All partner organisations of Sheffield Safeguarding Children Partnership should assess the level of risk associated with the use of digital and interactive technology by children and young people in their care. Each agency needs to take appropriate steps to safeguard children, young people and staff, according to the level of risk identified. Because of the diverse nature of the work of our partner agencies, this will vary in each organisation. This Online Safety Policy provides overarching guidance to all agencies in Sheffield to safeguard children and young people. It can be adapted and used accordingly within each setting. It should also operate in conjunction with other policies including those for Behaviour, Bullying, Curriculum, Data Protection and Security. Model Online Safety Policies for Schools and for Early Years Education Providers are available on the Sheffield Children Safeguarding Partnership website.
Online Safety depends on effective practice at a number of levels:
- Responsible ICT use by all staff, children and young people; encouraged by education and awareness raising and made explicit through published policies;
- Support and guidance for parents, giving them the knowledge and confidence to be able to supervise their child's use of digital and interactive technology;
- Sound implementation of Online Safety policy in both administration and raising awareness, including secure network design and use;
- Safe and secure broadband filtering and monitoring solutions e.g. Smoothwall where applicable, or other firewalls;
- Network standards and specifications.
This policy provides guidance for agencies in relation to these issues. It specifically relates to the use of computers in organisations; it does not cover the use of mobile phones by children and young people. Organisations should have separate guidance in relation to this issue.
The responsibility for Online Safety should lie with the Designated Safeguarding Lead/Officer.
2. Benefits of the Internet for Children and Young People
The purpose of Internet use in organisations is to promote the wellbeing and achievement of children and young people, to support the professional work of staff and to enhance the organisation's management information and administration systems.
Internet use is an essential element in 21st century life for education, business and social interaction. It is also part of the statutory curriculum from the age of 5 years. Therefore our organisation has a duty to provide children and young people with quality Internet access and equip them with the skills to be safe whilst using digital and interactive technology.
Benefits of using the Internet include:
- Access to world-wide educational resources including museums and art galleries;
- Educational and cultural exchanges between children and young people world-wide;
- Access to experts in many fields for children and young people and staff;
- Professional development for staff through access to national developments, educational materials and effective professional practice;
- Collaboration across support services and professional associations;
- Improved access to technical support including remote management of;
- Networks and automatic system updates;
- Exchange of professional issues and administration data between local, regional and national organisations;
- Access to learning and communication wherever and whenever convenient.
The organisation's Internet access will be designed expressly for children and young people's use and includes filtering appropriate to the age of children and young people.
Children and young people will be taught what Internet use is acceptable and what is not and given clear objectives for Internet use.
Internet access will be planned to enrich and extend learning and personal development activities.
Staff will guide children and young people in on-line activities that will support learning outcomes, which are planned according to their age and maturity.
Children and young people will be educated in the effective use of the Internet in research, including the skills of knowledge location, retrieval and evaluation.
3. Managing Internet Use in Organisational Settings
This section provides guidance about how to manage the use of the Internet in the organisation. Children and young people should be provided with guidance in computer rooms.
Authorised Internet Access
The organisation will maintain a current record of all staff and children and young people who are granted Internet access.
All staff must read and sign the 'Acceptable Use Policy' or similar before using the organisation's ICT resource.
Parents / carers will be informed that children and young people will be provided with supervised Internet access.
Parents / carers will be asked to sign and return a consent form for children and young people's access.
World Wide Web
If staff or children and young people discover unsuitable sites, the URL (address), time, content must be reported to the designated manager or helpdesk within the organisation via the Online Safety coordinator or network manager.
The organisation will ensure that the use of Internet derived materials by children and young people and staff complies with copyright law.
Children and young people should be taught to be critically aware of the materials they are shown and how to validate information before accepting its accuracy.
Children and young people may only use approved e-mail accounts on the organisation system.
Children and young people must immediately tell a member of staff if they receive offensive e-mail.
Children and young people must not reveal personal details of themselves or others in e-mail communication, or arrange to meet anyone without specific permission.
Access to external personal e-mail accounts may be blocked.
E-mails sent to external organisations should be written carefully and authorised before sending, in the same way as a letter written on organisation headed paper.
Children, young people and their families should only contact members of staff of organisations using business email addresses or telephone numbers. This includes staff who they knew before becoming service users of the organisation. Any exceptions to this should be discussed with managers within the organisation. This is to safeguard the children, young people, their families and the member of staff from allegations of misconduct.
Organisations should manage/block/filter access to social networking sites as appropriate for children and young people and staff.
Children and young people and staff should be advised never to give out personal details of any kind which may identify them or their location.
Children and young people and staff should be advised to consider whether the photos they upload to any social network are appropriate to be seen in a public space and to control who can access their images.
Children and young people should be advised on security and encouraged to set passwords, deny access to unknown individuals and instructed how to block and report unwanted communications. They should be encouraged to invite known friends only and deny access to others.
Children, young people and their families should not contact members of staff via social networking sites. Staff should not accept them as friends on social networking sites and should be encouraged to review information posted about them on such sites.
The organisation will work with identified colleagues within SCC to ensure suitable filtering and monitoring systems are installed and used as effectively as possible.
Virus protection will be installed and updated regularly.
Security strategies should be discussed with the organisation's senior management team.
Protecting Personal Data
Personal data will be recorded, processed, transferred and made available according to the Data Protection Act 2018.
4. Publishing Images and Work on the Internet
Photographs that include children and young people will be selected carefully and will not enable individuals to be clearly identified.
Children and young people's full names will not be used anywhere on the organisation's Web site or Blog, particularly in association with photographs.
Written permission from parents or carers will be obtained before photographs of their children are published on the organisation's Web site (see The Use of Cameras and Images within Educational Settings).
Work can only be published with the permission of the children, young people and their parents or carers.
5. Managing other Technologies
Emerging technologies will be examined for educational and developmental benefit and a risk assessment will be carried out before use in the organisation is allowed.
Children and young people should not use mobile phones during time spent with staff from the organisation, without prior agreement from a relevant member of staff, e.g. teacher or key worker.
If children or young people send abusive or inappropriate text messages, this will be dealt with by a relevant member of staff, e.g. a teacher or key worker and may result in action being taken.
Staff will be issued with an organisation phone where contact with children and young people is required. They should not use their personal mobile phone to contact children, young people or their families.
6. Assessing Risk
The organisation will take all reasonable precautions to prevent access to inappropriate material. However, due to the international access available via the Internet, it is not possible to guarantee that unsuitable material will never appear on an organisation's computer. Neither the organisation nor Sheffield Safeguarding Children Partnership can accept liability for the material accessed, or any consequences of Internet access.
Any child, young person or member of staff who inadvertently accesses inappropriate sites or materials should immediately report the incident to the designated Online Safety lead officer and ICT Manager in the organisation.
The organisation should audit ICT use to establish if the Online Safety policy is adequate and that the implementation of the Online Safety policy is appropriate.
7. Handling Online Safety Complaints
Complaints of Internet misuse will be dealt with by the line manager as per the organisation's code of conduct.
Any complaint about staff misuse must be referred to a manager. This may either be the complainant's line manager, or the manager of the member of staff about who the complaint is being made. This may invoke the Sheffield Children Safeguarding Partnership, Allegations against Staff, Volunteers or Carers Protocol.
Children and young people and parents / carers will be informed of the complaints procedure.
Discussions will be held with South Yorkshire Police to establish procedures for handling potentially illegal issues. They can be contacted on 0114 220 2020.
8. Communicating the Contents of this Policy
Children and Young People
Rules for Internet access will be posted in all networked rooms and classrooms.
Children and young people and staff will be informed that Internet use will be monitored.
All staff will be given a copy of this policy, its importance explained and asked to sign the acceptable use policy for staff.
Staff should be made aware that Internet traffic can be monitored and traced to the individual user. Discretion and professional conduct is essential.
Parents / Carers
Parents / carers' attention will be drawn to this Online Safety Policy in newsletters, the organisation brochure and on the organisation's web site.
Appendix 2: Indicators of Risk of Sexual Exploitation via Digital and Interactive Technology
- Spending increasing amount of time on social networking sites and messaging apps;
- Unexplained increased mobile phone credits or new mobile phone;
- New contacts with people out of city;
- Spending increasing amounts of time with on line friends and less time with friends from school or neighbourhood;
- Going on line during the night;
- Being secretive. Using mobile phone for accessing social networks;
- Unwilling to share /show on line contacts;
- Concern that a young person's online friendship has developed into an off line relationship;
- Concern that inappropriate images of a young person are being circulated via the internet.
- Arranging to meet people they have met on line;
- Concern that a young person is having an online relationship;
- Concern that a young person is being coerced to provide images or to perform sexual acts via webcam;
- Sharing of inappropriate images amongst friends.
- Concerned that a young person is being bribed by someone for their inappropriate on line activity;
- Concern that a young person is selling images via the internet for money;
- Concern that a young person is being drawn into providing increasingly provocative/sexualised images in exchange for payment or from fear of activity being revealed to significant adults;
- Negotiating a price for sexual activity/images;
- Concern that a young person is selling sexual services via the internet.
Appendix 3: Guidance for Practitioners to Minimise the Risk of Misconduct Allegations related to Digital and Interactive Technology
Advice can be found at Safer Internet Centre: Professional reputation.
All agencies will have their own professional codes of conduct, which this guidance does not intend to replace. It is guidance that relates specifically to helping professionals put safeguards in place to minimise the risk of any allegations of professional misconduct related to the use of digital technology and social media (e.g. Social networks such Facebook, Twitter, Linkedin, online gaming, etc.)
This guidance relates to all children up to the age of 18, whether or not they, or their families, are current or former pupils, students/service users. It is appreciated that you may have personal friends or the children of friends who are under the age of 18. But at all times you should ensure that you treat all those under the age of 18 with the respect they deserve, whoever the child or young person is.
You should always be mindful not to put yourself in a situation that may comprise you or be misinterpreted either by the child or young person, their friend, parent or carer, or any other person. This includes both personal and professional situations. It should be remembered that careless and inappropriate action in a personal setting, whether intended or not, could have significant implications for your professional life.There are few professionals who have allegations of professional misconduct related to digital technology or social media made against them. However, the impact of either an allegation or cyberbullying can be significant, both personally and professionally. Taking a few steps to be pro-active in minimising any risk to yourself, whilst you may think it unnecessary, is worth taking to avoid future complications.
Remember: as a professional working with children and young people, or their families, you may be vulnerable to have an allegation made against you or being the victim of cyberbullying. Sometimes this is a result of communication or a situation being misconstrued. Other times this may be an act of revenge taken against you for an incident that has resulted through your professional practice. It may also be that someone, through having complex needs of their own, may develop an unhealthy interest in you as a person.
Therefore the following steps are recommended to all professionals, and trainees who are or will be working with children, young people or their families.
Ten Steps to Minimise Professional Risk
- You should fully appreciate that the onus is upon you and not the child or young person to distance yourself from any potentially inappropriate situation;
- Regularly review all content about yourself on social networking sites, such as Facebook, Twitter etc. Particularly consider removing any personal information or photographs which could be manipulated and used against you;
- Regularly review your privacy settings on all social networking accounts;
- Do not give personal information such as email addresses or mobile telephone numbers to anyone who is, or has been, a pupil, student/service user or is a member of their family;
- If you wish to keep in contact with any child or young person under the age of 18, or their family, who has been a user of your service, ensure that you only use work emails or telephone numbers to communicate with them and that your Manager is aware of the contact;
- If there is any incident, related to this guidance, which involves a child, young person or their family, that causes you concern, report it immediately to your Line manager. Document it as soon as possible, according to your workplace procedures;
- Ensure you adhere rigidly to the Online Safety policy and Staff Acceptable Use Policy of your workplace. If you breach any part of the AUP, report it immediately as per your workplace procedures;
- Do not access any illegal or inappropriate websites on your personal computer/laptop or mobile phone. This includes illegal or inappropriate images of children, certain other types of pornography or extremist websites. It is illegal to access or download material that promotes or depicts criminal behaviour;
- Be very careful when liaising with others online (for example in social networks or using social media). Remember these are not private areas even though you may have privacy settings applied so likes, comments or complaints may be seen by others. Avoid inappropriate communication with individuals under 18, or with who you may be in a position of trust;
- Use your common sense and professional judgement and expertise at all times to avoid circumstances which are, or could be, perceived to be of an inappropriate nature or which could bring your organisation into disrepute. This relates particularly to social networking sites, social media and mobile phone technology;
- Remember, digital technology and social media may be the virtual world, but it has an impact on our real world online actions can have offline consequences.