ONLINE SAFETY POLICY

Policy Statement

This document is based on guidance from the Department for Education’s Keeping Children Safe in Education and NSPCC advice on Online Safety. The effectiveness of the policy will be monitored and reviewed annually through the number of reported incidents of a breach of online safety.

Staff and Host families

The Shell Education Code of Conduct for Staff and host families has been made available and explained to staff and host families to ensure that there is an awareness of how to communicate online with students as well as how to minimise the risks attached to digital and video images of them.

Host families play a crucial role in ensuring that the students who stay with them use the internet and mobile devices in accordance with the guidance contained within this policy and the Host family Handbook. The DSL takes the lead with online safety and will deal with any concerns raised as outlined in the procedures included in this policy.

Key Safeguarding Contact Details

Designated Safeguarding Lead (DSL) Olga Bernstein 

Phone: +44(0)7770 925045 (available 24/7)

Email: contact@shelleducation.co.uk

Students

Students are responsible for using the internet and mobile devices in accordance with the guidance in the Student Handbook. Students must know the importance of adopting good online safety practice and reporting misuse, abuse or access to inappropriate materials and know how to report these concerns. Shell Education further supports students in raising their awareness of how to stay safe online through our social media updates, policies and website.

Online Safety – Areas of risk

An effective approach to online safety empowers a school, college, guardian or host family to protect and educate children in their use of technology and establishes mechanisms to identify, intervene in and escalate any incident where appropriate.

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, for example web pages, indecent images of children or pro-eating disorder or self-harm websites

•      contact: being subjected to harmful online interaction with other users, for example cyberbullying or grooming; and

•      conduct: personal online behaviour that increases the likelihood of, or causes, harm.

What is online abuse?

The NSPCC define online abuse as any type of abuse that happens on the web, whether through social networks, playing online games, doing remote learning or using mobile phones. Children and young people may experience cyberbullying (bullying that takes place using technology including social media sites, mobile phones, gaming sites), grooming (building an emotional connection with a child to gain their trust for the purposes of sexual abuse, sexual exploitation or trafficking), sexual abuse, sharing of nudes or semi-nudes, ‘sexting’ or youth produced imagery, sexual exploitation, county lines gang recruitment, radicalisation or emotional abuse from people they know as well as from strangers.

Shell Education  clearly has a role to play in reporting signs of possible online abuse early so that prompt action can be taken to protect any children who are found to be at risk.

Possible signs of online abuse:

The NSPCC list possible signs of a child experiencing abuse online if they demonstrate a change in behaviour or unusual behaviour:

o  Being upset after using the internet or their mobile phone;

o  Unwilling to talk or secretive about their online activities and mobile phone use;

o  Spending much more or much less time texting, gaming or using social media;

o  Many new phone numbers, texts or e-mail addresses show up on their mobile phone, laptop or tablet;

o  After texting or being online they may seem withdrawn, upset or outraged;

o  Not wanting to go to school and/or avoiding meeting friends and school mates;

o  Avoiding formerly enjoyable social situations;

o  Difficulty sleeping;

o  Low self-esteem.

Set Boundaries

Shell Education  encourage staff and host families to set an appropriate agreement with students in order to supervise internet access and set boundaries about what they can and cannot do online. If a child breaks the rules, we would ask the host family to restrict internet access for an agreed period of time.

Below is some suggested advice for talking to children about online safety:

https://www.thinkuknow.co.uk/parents/articles/having-a-conversation-with-your-child/

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/talking-your-child-staying-safe-online/

Host families are asked to use privacy settings, parental controls and built in internet safety

features provided by the major internet service providers. The UK Safer Internet Centre has

guides for parental controls (host families).

https://www.saferinternet.org.uk/advice-centre/parents-and-carers/parental-controls-offered-

your-home-internet-provider

For parents and host families experiencing any internet safety issues with their students, the NSPCC have set up a helpline: 0808 800 5002

Filters and monitoring

Shell Education asks host families to be doing all that they reasonably can to limit children’s exposure to the above risks from the IT systems at the home. As part of this process, host families should ensure appropriate filters and monitoring systems are in place. Whilst considering their responsibility to safeguard and promote the welfare of children, and provide them with a safe environment in which to learn, host families should consider the age range of their pupils, the number of pupils, and how often they access the IT system.

The NSPCC website ‘Online Safety’ outlines controls that host families can implement to filter and

monitor what a child in their house can see, including checking that parents know how to use

privacy settings and reporting tools:

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/

The NSPCC provide advice for host families on parental controls which allow a number of

different things to happen including filtering and blocking content, setting different profiles so

that each family member can access age appropriate content and restricting information that

can be shared:

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/parental-

controls/

Staying safe on mobiles, smartphones and tablets

The NSPCC advice for tracking children’s online activity via devices includes:

Location tracking, taking and sending pictures, setting up parental controls, public wifi, parent protection apps.

Full details can be found on the website:

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/

Information on sexting can be found here:

https://www.childline.org.uk/info-advice/bullying-abuse-safety/online-mobile-safety/sexting/

Childnet also have useful information on their website:

https://www.childnet.com/help-and-advice/nudes-11-18-year-olds/

Social network sites

Children and young people connect online with friends, make new friends and browse the internet for information, chat with others and play games. This may include using search engines, sharing images, watching videos, using social network sites, playing games and chatting with people through online gaming.

Host families are advised to ensure that their own children and/or Shell Education  students know where the reporting functions are on each of the sites they use, how to block someone and how to keep information private.

The NSPCC encourage talking to children about social networks using ‘Net Aware’ to stay up to date with the social network sites and what you need to know about for example reporting and privacy settings:

https://www.net-aware.org.uk/

The NSPCC encourage talking to children about social networks and online privacy:

https://www.nspcc.org.uk/keeping-children-safe/online-safety/social-media/

Further reading:

NSPCC Online Safety:

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/

CEOP: Child Exploitation & Online Protection Centre – internet safety

CEOP: Thinkuknow: https://www.thinkuknow.co.uk/

UK Safer Internet Centre:

https://www.saferinternet.org.uk/

Internet matters – helping parents keep their children safe online:

https://www.internetmatters.org/

How social media is used to encourage travel to Syria and Iraq: A briefing note https://www.gov.uk/government/publications/the-use-of-social-media-for-online-radicalisation

Procedure for dealing with an incident which involves online services:

1.    Shell Education staff member receives the report of suspected online abuse from a student, parent or other source by face to face disclosure, email or telephone call.

2.    Shell Education Staff member adheres to the Safeguarding and Child Protection Policy including contemporaneously recording the disclosure in the most appropriate format (using the ‘Tell Explain Describe’ model if the information is being given by a student).

3.    The record of the disclosure is reported verbally as soon as practicable to the Designated Safeguarding Lead (DSL). The staff member must submit a written record of the disclosure to the DSL.

4.    The DSL will hold an emergency strategy meeting to discuss the incident, assess the alleged threat and risk to the child (including any relevant facts about the child which may affect their vulnerability including age and ability), implement an action plan and continue to review the situation until a resolution has been achieved.

5.    The meeting will be recorded with timed and dated entries within an incident record to record all actions and updates.

6.    The DSL will arrange for the young person to be helped and supported in recognition of the pressures (and possible vulnerabilities) they may have been under as a result of the suspected abuse. This could include helping them to understand how to recognise the early signs of online abuse, the wider issues and motivations of online abuse and making available relevant information and material. This help and support could be provided from accredited organisations such as the school, National Society for the Prevention of Cruelty to Children (NSPCC), ChildLine and National Crime Agency (NCA) – Child Exploitation and Online Protection Centre (CEOP) websites and helplines.

7.    The DSL will ensure that viewing of the images or other content is only made where there are good and clear reasons to do so (unless unavoidable because the student has willingly shown a member of staff), basing incident decisions on what the DSL has been told about the content of the imagery or other content. The DSL will ensure that staff members do not search through devices and delete imagery unless there is a good and clear reason to do so.

8.    The DSL will consider the need to ask for the student to produce the device as evidence. The viewing of any images, other content or seizing of any devices will be recorded including those present, date and time.

9.    The DSL will consider the need to contact another school, college, setting or individual and whether to contact the parents or carers of the children involved. In most cases parents should be involved unless there is good reason to believe that involving these parties would put the young person at risk of harm.

10.  The incident will be referred to a statutory agency (Children’s Services on the Local Authority telephone number or the police by dialling 101) immediately if there is a concern a young person has been harmed or is at immediate risk of harm (telephone the police by dialling 999). This would include information coming to light if at the initial stage:

• The incident involves an adult
• There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs)
• What you know about the imagery or other content suggests the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent
• The imagery or other content involves sexual acts and any pupil in the imagery is under 13
• You have reason to believe a pupil or pupil is at immediate risk of harm owing to the sharing of the imagery, for example, the young person is presenting as suicidal or self-harming. Where the material or activities found or suspected are illegal and there is no immediate risk to the child, The Child and Exploitation Online Paedophile Unit should be informed. If none of the above apply, the DSL may decide (with input from key stakeholders if appropriate) to respond to the incident without involving the police or children’s social care. The DSL can choose to escalate the incident at any time if further information/concerns come to light. The decision should be recorded in line with the Safeguarding Policy and Child Protection Policy, and regularly reviewed throughout the process of responding to the incident.

11.  The decision to respond to the incident without involving the police or children’s social care would be made in cases when the DSL is confident that they have enough information to assess the risks to pupils involved, and the risks can be managed within Shell Education support framework and network for the child.

12.  The DSL will advise to the young person to delete imagery or other content, and to confirm they have deleted the imagery. Young people should be given a deadline for deletion across all devices, online storage or social media sites on the basis that possession of youth produced sexual imagery is illegal. Where a young person refuses or is later discovered to have not deleted the images or other content, they are committing a criminal offence and the police may become involved. A record will be made of these decisions as per the Safeguarding Policy including decisions, times, dates and reasons. Shell Education may wish to invoke their own measures to discourage young people sharing, creating or receiving images in line with behaviour policies.

13.  Where the DSL is aware that youth produced sexual imagery or other content has been unavoidably viewed by a member of staff, the DSL should ensure that the staff member has appropriate support. Viewing youth produced sexual imagery or other content can be distressing for both young people and adults and appropriate emotional support may be required.

14.  Where police action has been instigated for an incident involving a member of staff or volunteer, Shell Education internal procedures will take place at the conclusion of the police action. A suspension will be likely to take place before the internal procedures begin.