1 Information on Internet Technology:
1.1 Introduction:
The educational and social benefits for children in using the internet should be promoted, but that this should be balanced against the need to safeguard children against the inherent risks from internet technology. Further, as a school we need to be able to teach children to keep themselves safe whilst on-line.
This aim of this policy is to provide an effective Online Safety strategy to enable these aims to be achieved and support staff to recognise the risks and take action to help children use the internet safely and responsibly.
1.2 Benefits and risks
Computing covers a wide range of activities, including access to information, electronic communications and social networking. As use of technology is now universal, children need to learn computing skills in order to prepare themselves for the working environment and it is important that the inherent risks are not used to reduce children’s use of technology. Further, the educational advantages of computing need to be harnessed to enhance children’s learning.
The risk associated with use of technology by children can be grouped into 4 categories.
1.2.1 Content
The internet contains a vast store of information from all over the world which is mainly aimed at an adult audience and may be unsuitable for children. There is a danger that children may be exposed to inappropriate images such as pornography, or information advocating violence, racism, suicide or illegal and anti-social behaviour that they are unable to evaluate in a critical manner.
1.2.2 Contact
Chat rooms, gaming sites and other social networking sites can pose a real risk to children as users can take on an alias rather than their real names and can hide their true identity. The sites may be used by adults who pose as children in order to befriend and gain children’s trust (known as “grooming”) with a view to sexually abusing them.
Children may not be aware of the danger of publishing or disclosing personal information about themselves such as contact details that allow them to be identified or located. They may also inadvertently put other children at risk by posting personal information and photographs without consent.
The internet may also be used as a way of bullying a child (or for child on child abuse), known as online bullying. More details on this can be found in section 4.5 of this policy.
1.2.3 Commerce
Children are vulnerable to unregulated commercial activity on the internet that could have serious financial consequences, such as fraud or identity theft, for themselves and their parents. They may give out financial information, for example, their parent’s credit card details, in response to offers for goods or services without seeing the fraudulent intent. Contact via social networking sites can also be used to persuade children to reveal computer passwords or other information about the family for the purposes of fraud.
1.2.4 Culture
Children need to be taught to use the internet in a responsible way, as they may put themselves at risk by:
- becoming involved in inappropriate, anti-social or illegal activities as a result of viewing unsuitable materials or contact with inappropriate people
- using information from the internet in a way that breaches copyright laws
- uploading personal information about themselves, including photographs, on social networking sites without realising they are publishing to a potentially global audience
- online bullying and child on child abuse (see section 4.5 for further details)
- use of mobile devices for the purposes of sexual harassment such as the consensual and non-consensual taking and distribution of inappropriate images of the young person (sexting) that cannot be removed from the internet and can be forwarded on to a much wider audience than the child intended.
Children may also be adversely affected by obsessive use of the internet that may have a negative impact on their health, social and emotional development and their educational attainment. They may visit sites that advocate extreme and dangerous behaviour such as self-harm or suicide or violent extremism, and more vulnerable children may be at a high degree of risk from such sites. All children may become desensitised to pornography, violence, sex and drug use or self-harm by regularly viewing these on-line.
2 School Online Safety strategies:
2.1 Whole school approach
Computing is now a key part of the school curriculum as well as a key element of modern communications technology that is widely used, and one of the key aims of computing is to ensure that pupils are aware of online safety messages. This is part of the school’s responsibility to safeguard and promote the welfare of pupils, as well as the duty of care to children and their parents to provide a safe learning environment.
Gloucester House ensures a holistic approach to online safety by ensuring:
- Staff are aware that online safety is an element of many safeguarding issues as technology can be used to aid many forms of abuse and exploitation, for example sexual harassment and cyberbullying, and are aware of the use of technology in peer on peer abuse.
- When developing new policies, we ensure online safety and the impact of technology is considered and what safeguards need to be put in place, including policies/procedures in behaviour and staff conduct.
- That consistent messages are given to staff and pupils and that everyone understands the online safety policy: staff should receive suitable training around online safety and similar messages are taught to pupils.
- Staff are aware of the importance of ensuring their own use of technology complies with school policies, particularly in terms of contact with pupils, and that there are clear policies, procedures available to staff on expectations for online behaviour.
- There is a clear link between the online safety policy and the behaviour policy that sets out expected standards for pupil’s online behaviour and expected sanctions for breaches.
- School’s online safety policies should be reviewed regularly and staff training refreshed in order to ensure that they remain relevant in the face of changing technologies.
For more information refer to:
DfE non-statutory guidance on teaching online safety: https://www.gov.uk/government/publications/teaching-online-safety-in-schools
DfE statutory guidance on RSE:
2.2 Purpose and description
Gloucester House has an online safety strategy in place based on a framework of policy, practice, education and technological support that ensures a safe online learning environment that maximises the educational benefits of ICT whilst minimising the associated risks. Its purpose is to:
- promote the use of technology within the curriculum
- protect children from harm
- safeguard staff in their contact with pupils and their own use of the internet
- ensure the school fulfils its duty of care to pupils
- provide clear expectations for staff and pupils on acceptable use of the internet.
In particular, schools must ensure the following:
- A safe internet platform that provides filtering software to block access to unsuitable sites, anti-virus software and monitoring systems (for example the London Grid for Learning platform).
- This includes robust filtering and monitoring systems that comply with the Department of Education Filtering and monitoring standards for schools and colleges. Meeting digital and technology standards in schools and colleges
Schools/colleges may also use resources available on the London Grid for Learning website to help them to monitor their systems.
- A culture of safe practice underpinned by a strong framework of online safety policy that ensures everyone is aware of expected standards of on-line behaviour.
- Children are taught to keep themselves and others safe on-line and use technology responsibly; this should be achieved by working in partnership with parents and carers and raising awareness of the potential risks of internet use.
2.3 Roles and responsibilities
Gloucester House online safety strategy is inclusive of the whole school community, including all staff and steering group members and links with parents and carers. The strategy is approved by the steering group and is overseen by the head teacher and fully implemented by all staff.
2.3.1 Head teacher’s role
Head teachers have ultimate responsibility for online safety issues within the school including:
- the overall development and implementation of the school’s online safety policy and ensuring the security and management of online data
- ensuring that online safety issues are given a high profile within the school community
- linking with the Steering Group and parents and carers to promote online safety and forward the school’s online safety strategy
- ensuring online safety is embedded in staff induction and training programmes
- deciding on sanctions against staff and pupils who are in breach of acceptable use policies and responding to serious incidents involving online safety.
2.3.2 Steering Group’s role:
- Governing bodies have a statutory responsibility for pupil safety. A Steering Group at Gloucester House provide this support and challenge. As such this group are made aware of online safety issues, and provide support to the head teacher and senior leadership team in the development of the school’s online safety strategy.
- The Steering Group ensure that there are policies and procedures in place to keep pupils safe online and that these are reviewed regularly.
- The Steering Group should liaise with IT staff and service providers to annually review school IT filtering and monitoring systems to check their effectiveness and ensure that the school leadership team are aware of what provision is in place and how to escalate any concerns.
- The Steering Group are subject to the same online safety rules as staff members and sign an Acceptable Use Agreement in order to keep them safe from allegations and ensure a high standard of professional conduct. In particular, the Steering Group always use business email addresses when conducting school business.
2.3.3 Online Safety Co-ordinator’s role:
Ben Neasom is the designated Online Safety Co-ordinator; she is responsible for co-ordinating Online Safety policies on behalf of the school. As is accepted good practice she is also the Designated Safeguarding Lead (DSL).
The Online Safety co-ordinator is responsible to:
- develop, implement, monitor and review the school’s Online Safety policy.
- ensure that staff and pupils are aware that any online safety incident should be reported to them.
- ensure online safety is embedded in the curriculum
- provide the first point of contact and advice for school staff, Steering Group, pupils and parents/carers.
- liaise with the trust’s network manager, the head teacher and nominated Steering Group Member to ensure Gloucester House remains up to date with online safety issues and to address any new trends, incidents and arising problems and that the school has appropriate filtering and monitoring systems in place
- assess the impact and risk of emerging technology and the school’s response to this in association with IT staff and learning platform providers
- raise the profile of online safety awareness with the school by ensuring access to training and relevant online safety literature.
- ensure that all staff and pupils have read and signed the acceptable use policy (AUP).
- maintain a log of internet related incidents and co-ordinate any investigation into breaches.
- report all incidents and issues through the trust’s risk management and safeguarding systems.
- report significant incidents and issues to Camden’s online safety officer.
In addition, it is an Ofsted recommendation that the Online Safety Co-ordinator receives recognised training via CEOP or E-PICT in order to carry out their role more effectively. In Camden, this is available from the CLC.
2.3.4 The Trust’s IT manager’s role alongside the Online Safety Coordinator:
- the maintenance and monitoring of the school internet system including anti-virus and filtering and monitoring systems.
- carrying out monitoring and audits of networks and reporting breaches to the Online Safety co-ordinator.
- supporting any subsequent investigation into breaches and preserving any evidence.
2.3.5 Role of school staff:
All school staff have a dual role concerning their own internet use and providing guidance, support and supervision for pupils. Their role is:
- adhering to the school’s online safety and acceptable use policy and procedures
- communicating the school’s online safety and acceptable use policy to pupils
- keeping pupils safe and ensuring they receive appropriate supervision and support whilst using the internet
- planning use of the internet for lessons and researching on-line materials and resources
- reporting breaches of internet use to the Online Safety Co-ordinator and complete an Online Safety Incident Log as appropriate
- recognising when pupils are at risk from their internet use or have had negative experiences and taking appropriate action, for example referral to the Online Safety co-ordinator
- Teaching the Online Safety and digital literacy elements of the new curriculum.
2.3.6 Designated Safeguard Leads
Where any online safety incident has serious implications for the child’s safety or well-being, the matter should be referred to the designated safeguarding lead for the school who will decide whether or not a referral should be made to Children’s Safeguarding and Social Work or the Police.
2.3.7 SEND
All of our pupils are considered particularly vulnerable because of their special needs and for some because of the level of guidance/supervision that they may receive outside of school. Because of this they need a higher level of guidance on online safety practice as well as closer supervision.
2.4 Pupils with special educational needs and disabilities (SEND)
Pupils with learning difficulties or disability may be more vulnerable to risk from use of the internet and may need additional guidance on online safety practice as well as closer supervision.
Where necessary the OSC:
- liaises with IT service to discuss any requirements for further safeguards to the school IT system or tailored resources and materials in order to meet the needs of pupils with SEND
- liaises with parents, carers and other relevant agencies to develop online safety practices for pupils with SEND
- remains up to date with any developments regarding emerging technologies and online safety and how these may impact on pupils with SEND.
2.5 Working with Parents and Carers
It is essential to involve parents and carers in the development and implementation of online safety strategies and policies; most children will have internet access at home or own mobile devices and might not be as closely supervised in its use as they would be at school.
Therefore, parents and carers need to know about the risks so that they are able to continue online safety education at home and regulate and supervise children’s use as appropriate to their age and understanding.
Gloucester House offers online safety training opportunities to parents in order to provide them with information to help them keep their child safe online. The CSCP online safety leaflet for parent/carers is also available on the school website:
The head teacher, Steering Group and the online safety coordinator should consider what strategies to adopt in order to ensure parents are aware of online safety issues and support them in reinforcing online safety messages at home.
Parents/Carers should be provided with information on computing and the school’s online safety policy when they are asked to sign acceptable use agreements on behalf of their child so that they are fully aware of their child’s level of internet use within the school as well as the school’s expectations regarding their behaviour. Parents should also be informed that they can contact the school’s online safety co-ordinator if they have any concerns about their child’s use of technology.
We regularly consult and discuss online safety with parents/carers and seek to promote a wide understanding of the benefits of new technologies together with the associated risks.
- Parents/Carers are asked to read through and sign acceptable use agreements on behalf of their child on admission to the school (appendix 3b).
- Parents/Carers are required to make a decision as to whether they consent to images of their child being taken and used in the public domain (e.g., on school website)
- Parents/Carers will be expected to sign a Home-School agreement during the admissions process containing the following statement or similar:
“We will support the school approach to on-line safety and not deliberately upload or add any text, image, sound or video that could upset or offend any member of the school community”
Parents and carers need to know about the risks so that they are able to continue online safety education at home and regulate and supervise children’s use as appropriate to their age and understanding.
- Parents are provided with information on computing and the school’s Online Safety policy at the start of their child’s placement, so that they are fully aware of their child’s level of internet use within the school as well as the school’s expectations regarding their behaviour.
- We provide regular parent/carer sessions to share information and good practice around Online Safety.
- If there is a specific issue or a greater concern/vulnerability the Online Safety Officer would work alongside the case co-ordinator to put in a bespoke package
Where remote online learning is being used, parents should be made aware of what arrangements have been made, which websites children will be accessing and any member of staff they will be interacting with online.
3 Online Safety policies
3.1 Accessing and monitoring the system:
- Access to the school’s computers and internet system is via class based log-ins and passwords for pupils. The passwords should be known / entered by staff. For staff access is by individual login and password. Visitors can access the system and be given a separate adult group log-in, with the permission from the head teacher or Online Safety co-ordinator
- The Online Safety Co-ordinator keeps a record of all log-ins used within the school for the purposes of monitoring and auditing internet activity.
- Staff are required to change their password every 3 months
- Network and technical staff responsible for monitoring systems should be supervised by a senior member of their management team.
- The Online Safety Co-ordinator and teaching staff carefully consider the location of internet enabled devices in classrooms and teaching areas in order to allow an appropriate level of supervision of pupils depending on their age and experience.
3.2 Confidentiality and Data Protection:
- The school will ensure that all data held on its IT systems is held in accordance with the principles of the Data Protection Act 2018. Data will be held securely and password protected with access given only to staff members on a “need to know” basis.
- Pupil data that is being sent to other organisations will be encrypted and sent via a safe and secure system such as Egress/SIMS. Any breaches of data security should be reported to the head teacher immediately.
- Gloucester House have limited CCTV, however this does not record, and is solely used for visual health and safety purposes.
3.3 Acceptable use policies
- All internet users within the school are expected to sign an acceptable use agreement on an annual basis that sets out their rights and responsibilities and incorporates the school Online Safety rules regarding their internet use. (See appendix 1 & 2).
- For primary school pupils, acceptable use agreements will be signed by parents on their child’s behalf at the same time that they give consent for their child to have access to the internet in school (see appendix 1).
- Secondary school pupils and their parents should both sign the acceptable use policy, and use of the internet in schools is dependent on signing this agreement (see appendix 2).
- Staff are expected to sign an acceptable use policy on appointment and this will be integrated into their general terms of employment (see appendix 3C). Copies of all signed acceptable use agreements will be stored electronically within staff files.
3.4 Teaching Online Safety
3.4.1 Responsibility
One of the key features of our Online Safety strategy is teaching pupils to protect themselves and behave responsibly while on-line. There is an expectation that over time, pupils will take increasing responsibility for their own behaviour and internet use so that they can be given more freedom to explore systems and applications with a lessening amount of supervision from staff.
- Overall responsibility for the design and co-ordination of Online Safety education lies with the head teacher and the Online Safety co-ordinator, but all staff should play a role in delivering Online Safety messages.
- The Online Safety Co-ordinator is responsible for ensuring that all staff have the knowledge and resources to enable them to do so.
- Teachers are primarily responsible for delivering an ongoing online safety education in the classroom as part of the curriculum.
- Rules regarding safe internet use are posted up in all classrooms and teaching areas where computers are used to deliver lessons.
- The start of every lesson where computers are being used should be an opportunity to remind pupils of expectations on internet use and the need to follow basic principles in order to keep safe.
- Schools are required to teach about online bullying as part of statutory Relationships Education (primary), Relationships and Sex Education (secondary) and health education (all schools)
- Teachers should ensure that the school’s policy on pupils’ use of their own mobile phones and other mobile devices in school is adhered to
- Teachers may wish to use PSHE lessons/Circle times as a forum for discussion on Online Safety issues to ensure that pupils understand the risks and why it is important to regulate their behaviour whilst on-line.
- Staff are aware of those children who may be more vulnerable to risk from internet use, generally those children with a high level of experience and good computer skills but coupled with poor social skills.
- Staff should ensure that pupils’ own mobile devices have been handed in to the office at the beginning of the day to be returned at the end of the day.
- Staff should ensure that children using Network enabled computers are appropriately supervised. I.e. Computers including laptops should be positioned so that staff can see the screens as they move about the classroom.
3.4.2 Content
Pupils are taught all elements of online safety included in the computing curriculum so that they:
- use technology safely and respectfully, keeping personal information private; identify where to go for help and support when they have concerns about content or contact on the internet or other online technologies;
- can evaluate and apply information technology, including new or unfamiliar technologies, analytically to solve problems;
- are responsible, competent, confident and creative users of information and communication technology.
Primary pupils are taught all elements of online safety included in:
Statutory Relationships Education:
- about different types of bullying (including cyberbullying), the impact of bullying, responsibilities of bystanders (primarily reporting bullying to an adult) and how to get help
- that people sometimes behave differently online, including by pretending to be someone they are not.
- that the same principles apply to online relationships as to face-to-face relationships, including the importance of respect for others online including when we are anonymous.
- the rules and principles for keeping safe online, how to recognise risks, harmful content and contact, and how to report them.
- how to critically consider their online friendships and sources of information including awareness of the risks associated with people they have never met.
- how information and data is shared and used online.
Statutory Health Education includes:
- that bullying (including cyberbullying) has a negative and often lasting impact on mental wellbeing
- that for most people the internet is an integral part of life and has many benefits.
- about the benefits of rationing time spent online, the risks of excessive time spent on electronic devices and the impact of positive and negative content online on their own and others’ mental and physical wellbeing.
- how to consider the effect of their online actions on others and know how to recognise and display respectful behaviour online and the importance of keeping personal information private.
- why social media, some computer games and online gaming, for example, are age restricted.
- that the internet can also be a negative place where online abuse, trolling, bullying and harassment can take place, which can have a negative impact on mental health
- how to be a discerning consumer of information online including understanding that information, including that from search engines is ranked, selected and targeted
- where and how to report concerns and get support with issues online.
Secondary pupils are taught all elements of online safety included in statutory Relationships and Sex Education:
- about different types of bullying (including cyberbullying), the impact of bullying, responsibilities of bystanders to report bullying and how and where to get help.
- their rights, responsibilities and opportunities online, including that the same expectations of behaviour apply in all contexts, including online.
- about online risks, including that any material someone provides to another has the potential to be shared online and the difficulty of removing potentially compromising material placed online.
- not to provide material to others that they would not want shared further and not to share personal material which is sent to them.
- what to do and where to get support to report material or manage issues online.
- the impact of viewing harmful content.
- that specifically sexually explicit material e.g. pornography presents a distorted picture of sexual behaviours, can damage the way people see themselves in relation to others and negatively affect how they behave towards sexual partners.
- that sharing and viewing indecent images of children (including those created by children) is a criminal offence which carries severe penalties including jail
- how information and data is generated, collected, shared and used online.
Statutory Health Education should include:
- the similarities and differences between the online world and the physical world, including: the impact of unhealthy or obsessive comparison with others online (including through setting unrealistic expectations for body image, how people may curate a specific image of their life online, over-reliance on online relationships including social media, the risks related to online gambling including the accumulation of debt, how advertising and information is targeted at them and how to be a discerning consumer of information online
- how to identify harmful behaviours online (including bullying, abuse or harassment) and how to report, or find support, if they have been affected by those behaviours.
3. 5 Staff training and conduct:
3.5.1 Training:
- All school staff and Steering Group members should receive training with regard to IT systems and online safety as part of their induction and this should include a meeting with the Online Safety Coordinator and the Network Manager.
- Staff should also attend specific training on online safety available from the CSCP https://cscp.org.uk/training so that they are aware of the risks and actions to take to keep pupils safe online. School management should ensure that staff attend regular update training in order to ensure they can keep up with new developments in technology and any emerging safety issues.
Camden City learning Centre offers whole school training including updates as well as training for governors and parents. https://camdenlearning.org.uk/camden-learning-centre-clc/
3.5.2 IT and safe teaching practice
During their induction our staff are made aware of the importance of maintaining professional standards of behaviour with regards to their own internet use, particularly in relation to their communications with pupils.
Staff should refer to the following for further guidance:
Trust Staff use of social media policy https://intranet.tavistockandportman.nhs.uk/contentobject/32561/Staff-use-of-social-media
Camden social media policy for school staff
Schools and Nurseries Safeguarding Policies – Camden Safeguarding Children Partnership — CSCP
The following points should be followed by staff to ensure that their behaviour is not open to misinterpretation and to safeguard them from misplaced or malicious allegations.
- Photographic and video images of pupils should only be taken by staff in connection with educational purposes, for example school trips.
- Staff should always use school equipment and only store images on the school computer system, with all other copies of the images on personal mobile devices erased.
- Staff should take care regarding the content of and access to their own social networking sites and ensure that pupils and parents/Carers cannot gain access to these.
- Staff should ensure that any materials published on their own social networking sites are neither inappropriate nor illegal.
- Staff should be particularly careful regarding any comments to do with the school, the trust or specific pupils that are communicated over the internet; remarks that are private may go to a wider audience and raise questions regarding confidentiality.
- Staff should not post any comments about specific pupils or staff members on their social networking sites or any comments that would bring the school or their profession into disrepute.
- Staff should not engage in any conversation with pupils via instant messaging or social networking sites as these may be misinterpreted or taken out of context.
- Where staff need to communicate with pupils regarding school work, this should be via the school email system and messages should be carefully written to ensure that they are clear, unambiguous and not open to any negative interpretation.
- When making contact with parents or pupils by telephone, staff should only use school equipment. Pupil or parent numbers should not be stored on a staff member’s personal mobile phone and staff must avoid lending their mobile phone to pupils.
- Staff should ensure that personal data relating to pupils is stored securely and encrypted if taken off the school premises.
- Where staff are using mobile equipment such as laptops or I-pads provided by the Trust, they should ensure that the equipment is kept safe and secure at all times.
- When making contact with parents or pupils by email, staff should always use their school email address or account. Personal email addresses and accounts should never be used.
3.5.3 Passwords:
- When using personal logons to access the computer, staff should lock the computer when they leave it.
- Change passwords whenever there is any indication of possible system or password compromise.
- Do not record passwords or encryption keys on paper or in an unprotected file.
- Only disclose your personal password to authorised ICT support staff when necessary, and never to anyone else. Ensure that all personal passwords that have been disclosed are changed once the requirement is finished.
- Never tell a child or colleague your password.
If you are aware of a breach of security with your password or account inform Kirsty Brant/ITimmediately.
3.5.4 Exit Strategy:
When staff leave, their line manager should liaise with the network manager to ensure that any school equipment is handed over and that PIN numbers, passwords and other access codes to be reset so that the staff member can be removed from the school’s IT system.
3.6 Safe use of technology:
3.6.1 Internet and search engines
- When using the internet, children should receive the appropriate level of supervision for their age and understanding. Staff are aware that often, the most computer-literate children are the ones who are most at risk.
- Our children should be supervised at all times when using the internet. Although supervision of secondary school pupils may be more flexible, teachers should remain vigilant at all times during lessons.
- Pupils should not be allowed to aimlessly “surf” the internet and all use should have a clearly defined educational purpose.
- Despite filtering systems, it is still possible for pupils to inadvertently access unsuitable websites; to reduce risk, teachers should plan use of internet resources ahead of lessons by checking sites and storing information off-line where possible.
- Where teachers require access to blocked websites for educational purposes, this should be discussed and agreed with the Online Safety co-ordinator, who will liaise with the IT service provider for temporary access. Teachers should notify the Online Safety co-ordinator once access is no longer needed to ensure the site is blocked.
3.6.2 Evaluating and using internet content:
We teach pupils good research skills that help them to maximise the resources available on the internet so that they can use search technologies effectively, appreciate how results are selected and ranked, and be discerning in evaluating digital content.
3.6.3 Safe use of applications:
- School email – We do not currently have a school email system for pupils. When we do units of work in computing we use a web based virtual system that allows them to practice the skills by sending and receiving email from each other and to and from their teacher. However it is not actually connected to an external system.
- Social networking sites such as Facebook, Instagram and Twitter allow users to publish information about them to be seen by anyone who has access to the site. Generally, these would have limited use in schools but pupils are likely to use these sites at home.
- Gaming-based sites thatallow children to “chat” to other gamers during the course of gaming are often not properly moderated and may be targeted by adults who pose a risk to children. Consequently such sites are not be accessed via school internet systems
- Online communities and forums are sites that enable users to discuss issues and share ideas on-line. There may be times where we might assess that these have an educational value.
- Chat rooms are internet sites where users can join in “conversations” on-line; instant messaging allows instant communications between two people on-line. In most cases, pupils will use these at home although some school internet systems host these applications.
3.6.4 Safety rules:
- Access to and use of personal email accounts, unregulated public social networking sites, chat rooms or gaming sites on the school internet system is forbidden and is usually blocked. This is to protect pupils from receiving unsolicited mail or contacts and to preserve the safety of the system from hacking and viruses.
- If there is an occasion where we identify a clear educational use for emails or social networking sites and forums for on-line publishing, they should only use approved sites such as those provided by the IT service provider. Any use of these sites should be strictly supervised by the responsible member of staff.
- Emails should only be sent via the school internet system to addresses within the school system or approved external address. All email messages sent by pupils in connection with school business must be checked and cleared by the responsible member of staff.
- Where teachers wish to add an external email address, this must be for a clear educational purpose and must be discussed with the online safety co-ordinator who will liaise with the learning platform provider.
- Apart from the head teacher, individual email addresses for staff or pupils should not be published on the school website.
- Pupils are taught to be wary of opening attachments to emails where they are unsure of the content or have no knowledge of the sender.
- Pupils are taught not to disclose personal contact details for themselves or others such as addresses or telephone numbers via email correspondence or on social networking sites.
- All electronic communications should be polite; if a pupil receives an offensive or distressing email or comment, they are instructed not to reply and to notify the responsible teacher immediately.
- Pupils are warned that any bullying or harassment via email, chat rooms or social networking sites will not be tolerated and will be dealt with in accordance with the school’s anti-bullying policy. This includes any correspondence or contact taking place outside the school and/or using non-school systems or equipment.
- Users are aware that as use of the school internet system is for the purposes of education or school business only, and its use may be monitored.
In order to teach pupils to stay safe online outside of school, they are advised:
- not to give out personal details to anyone on-line that may help to identify or locate them or anyone else, for example home address, name of school or clubs attended.
- to only use moderated chat rooms that require registration and are specifically for their age group.
- not to upload personal photos of themselves or others onto sites and to take care regarding what information is posted as there is no control where images may end up or who can see them.
- how to set up security and privacy settings on sites or use a “buddy list” to block unwanted communications or deny access to those unknown to them.
- to behave responsibly whilst on-line and keep communications polite.
- not to give out personal details to anyone on-line that may help to identify or locate them or anyone else
- not to respond to any hurtful or distressing messages but to let their parents or carers know so that appropriate action can be taken.
- not to arrange to meet anyone whom they have only met on-line or go “off-line” with anyone they meet in a chat room.
3.6.5 Video calling and remote learning
Video calling or live streaming enables users to communicate face-to-face via the internet using web cameras. (See Gloucester House Remote Learning policy.)
3.6.6 School website:
- Content should not be uploaded onto the school website unless it has been authorised by the Online Safety Co-ordinator and the head teacher, who is responsible for ensuring that content is accurate, suitable for the purpose and audience, and does not breach copyright or intellectual property law.
- The school administration team are responsible linking with the trusts communication team to ensure the secure and safe uploading onto the school website.
- To ensure the privacy and security of staff and pupils, the contact details on the website are the school address, email and telephone number. No contact details for staff are contained on the website.
- Children’s full names should never be published on the website.
- Links to any external websites are regularly reviewed to ensure that their content is appropriate for the school and the intended audience.
3.6.7 Photographic and Video Images:
- where the school uses photographs and videos of pupils for publicity purposes, for example on the school website, images should be carefully selected so that individual pupils cannot be easily identified.
- where photographs or videos of children are used, written permission must be obtained first from their parents or carers, who should be informed of the purpose of the image and where it will appear.
- children’s names should never be published where their photograph or video is being used.
- Staff should ensure that children are suitably dressed to reduce the risk of inappropriate use of images.
- images should be securely stored only on the school’s computer system and all other copies deleted.
- stored images should not be labelled with the child’s name and all images held of children should be deleted once the child has left the school.
- staff should not use personal devices to take photographs of pupils.
- school should inform parents that although they may take photographic images of school events that include other children, it is on the understanding that these images are for personal use only and will not be published on the internet or social networking sites.
3.6.8 Consent of Adults Who Work at the School:
Permission to use images of all staff who work at the school is sought on induction and a copy is located in the personnel file
3.6.9 Pupils own mobile devices:
The majority of pupils are likely to have mobile phones or other devices that allows them to access internet services, and these can pose a major problem for schools in that their use may distract pupils during lessons and may be used for online bullying. Many parents prefer their children to have mobile phones with them when travelling to and from school, in order to ensure their safety and enable them to contact home if they need to.
We have a system where by children have to give in their mobile phone/handheld systems to the office at the beginning of the day and can retrieve them at the end of the day. If a child repeatedly breaks this rule we will discuss with home the appropriateness of them bringing such devices in. If the device is being used in an inappropriate way it will be confiscated. Generally, use of personal mobile phones or other devices is forbidden in classrooms.
It is considerably more difficult to monitor wireless devices. We do not allow children to use their own wireless devices ordinarily though we do allow access to handheld devices such as tablets that are given to pupils by schools for education purposes. The same acceptable use agreements apply and that sanctions may be applied where there is a breach of school policy.
Where a pupil’s device is used for bullying or sexual harassment, we would confiscate the device until we have linked with parents/carers and other services, so that evidence can be gathered. We will refer to the government guidance available at: https://www.gov.uk/government/publications/searching-screening-and-confiscation
Staff should refer to the Trust Staff Use of Social Media Policy: https://intranet.tavistockandportman.nhs.uk/contentobject/32561/Staff-use-of-social-media
4 Responding to incidents
4.1 Policy statement
- All incidents and complaints relating to online safety and unacceptable internet use will be reported to the online safety co-ordinator in the first instance. All incidents, whether involving pupils or staff, must be recorded by the online safety co-ordinator on the online safety incident report log (appendix 4).
- A copy of the incident record should be emailed to Camden’s designated online safety officer at jenni.spencer@camden.gov.uk.
- Where the incident or complaint relates to a member of staff, the matter must always be referred to the head teacher for action under staff conduct policies for low level incidents or consideration given to contacting the LADO under the CSCP guidance on dealing with allegations against staff where this is appropriate. Incidents involving the head teacher should be reported to the chair of the Steering Group.Managing Allegations Against Staff and Volunteers & LADO – Camden Safeguarding Children Partnership — CSCP
- The school’s online safety co-ordinator should keep a log of all online safety incidents and complaints and regularly review the information for evidence of emerging patterns of individual behaviour or weaknesses in the school’s online safety system, and use these to update the online safety policy.
- Online safety incidents involving safeguarding issues, for example contact with inappropriate adults, should be reported to the designated safeguarding lead, who will make a decision as to whether or not to refer the matter to the police and/or Children’s Safeguarding and Social Work in conjunction with the head teacher.
Although it is intended that online safety strategies and polices should reduce the risk to pupils whilst on-line, this cannot completely rule out the possibility that pupils may access unsuitable material on the internet. Neither the school nor the London Borough of Camden can accept liability for material accessed or any consequences of internet access, but all reasonable precautions will be taken to ensure a safe online learning environment.
4.2 Unintentional access of inappropriate websites
- If a pupil or teacher accidently opens a website that has content which is distressing or upsetting or inappropriate to the pupils’ age, staff should immediately (and calmly) close or minimise the screen.
- Staff should reassure pupils that they have done nothing wrong and discuss the incident with the class to reinforce the online safety message and to demonstrate the school’s “no blame” approach.
- The incident should be reported to the online safety co-ordinator and details of the website address and URL provided.
- The online safety co-ordinator should liaise with the network manager or learning platform provider to ensure that access to the site is blocked and the school’s filtering system reviewed to ensure it remains appropriate.
4.3 Intentional access of inappropriate websites by a pupil
- If a pupil deliberately accesses inappropriate or banned websites, they will be in breach of the acceptable use policy and subject to appropriate sanctions (see section 5).
- The incident should be reported to the online safety co-ordinator and details of the website address and URL recorded.
- The online safety co-ordinator should liaise with the network manager or learning platform provider to ensure that access to the site is blocked.
- The pupil’s parents/carers should be notified of the incident and what action will be taken.
4.4 Inappropriate use of IT by staff:
- If a member of staff witnesses misuse of IT by a colleague, they should report this to the head teacher and the online safety co-ordinator immediately. If the misconduct involves the head teacher, the matter should be reported to the chair of the Steering Group.
- The online safety co-ordinator will notify the network manager so that the computer, laptop or other device is taken out of use and securely stored in order to preserve any evidence. A note of any action taken should be recorded on the online safety incident report form.
- The online safety co-ordinator will arrange with the network manager or learning platform provider to carry out an audit of use to establish which user is responsible and the details of materials accessed.
- Once the facts are established, the head teacher will take any necessary disciplinary action against the staff member and report the matter to the Steering Group and the police where appropriate. Where appropriate, consideration should be given to contacting the LADO for advice.
- If the materials viewed are illegal in nature the head teacher or Steering Group member should report the incident to the police and follow their advice, which should also be recorded on the online safety incident report form.
4.5 Online bullying:
4.5.1 Definition and description
Online bullying is defined as the use of technology such as email and social networking sites to deliberately hurt or upset someone or harass or threaten. Unlike physical forms of bullying, the internet allows bullying to continue past school hours and invades the victim’s home life and personal space. It also allows distribution of hurtful comments and material to a wide audience.
Online bullying is extremely prevalent as pupils who would not consider bullying in the physical sense may find it easier to bully through the internet, especially if it is thought the bullying may remain anonymous.
Bullying may take the form of:
- rude, abusive or threatening messages via email or text.
- posting insulting, derogatory or defamatory statements on blogs or social networking sites.
- setting up websites that specifically target the victim.
- making or sharing derogatory or embarrassing images or videos of someone via mobile phone or email (for example, sexting/“happy slapping”).
Online bullying can affect pupils and staff members. Often, the internet medium used to perpetrate the bullying allows the bully to remain anonymous. In extreme cases, online bullying could be a criminal offence under the Harassment Act 1997 or the Telecommunications Act 1984.
4.5.2 Dealing with incidents
The following covers all incidents of bullying that involve pupils at the school, whether or not they take place on school premises or outside school. All incidents should be dealt with under the schools’ behaviour policies and the child on child abuse guidance. Schools and Nurseries Safeguarding Policies – Camden Safeguarding Children Partnership — CSCP
- School anti-bullying and behaviour policies and acceptable use policies should cover the issue of online bullying and set out clear expectations of behaviour and sanctions for any breach.
- Any incidents of online bullying should be reported to the online safety co-ordinator who will record the incident on the incident report form and ensure that the incident is dealt with in line with the school’s anti-bullying policy. Incidents should be monitored and the information used to inform the development of anti-bullying policies.
- Where incidents are extreme, for example threats against someone’s life, or continue over a period of time, consideration should be given to reporting the matter to the police as in these cases, the bullying may be a criminal offence.
- As part of online safety awareness and education, pupils should be told of the “no tolerance” policy for online bullying and encouraged to report any incidents to their teacher.
- Pupils should be taught:
- to only give out mobile phone numbers and email addresses to people they trust
- to only allow close friends whom they trust to have access to their social networking page
- not to send or post inappropriate images of themselves
- not to respond to offensive messages
- to report the matter to their parents and teacher immediately.
- Evidence of bullying, for example texts, emails or comments on websites should be preserved by the young person as evidence.
Any action taken on online bullying incidents must be proportional to the harm caused. For some cases, it may be more appropriate to help the pupils involved to resolve the issues themselves rather than impose sanctions. This may be facilitated by a Gloucester house pupil committee, the community meeting or a class/group meeting.
4.5.3 Action by service providers
All website providers and mobile phone companies are aware of the issue of online bullying and have their own systems in place to deal with problems, such as tracing communications. Staff or parents/carers can contact providers at any time for advice on what action can be taken.
- Where the bullying takes place by mobile phone texts, the mobile phone company can be contacted to ask them to trace the calls. The pupil should also consider changing their phone number.
- Where the bullying takes place by email, and the messages are being sent from a personal email account, contact the service provider so that the sender can be traced. The pupil should also consider changing email address.
- Where bullying takes place in chat rooms or gaming sites, the pupil should leave the chat room or gaming site immediately and seek advice from parents or teachers. Bullying should be reported to any chat room moderator to take action.
- Where bullying involves messages on social networking sites or blogs, contact the website provider to request that the comments are removed. In extreme cases, the bully’s access to the site can be blocked.
- Parents/carers should be notified of any incidents and advised on what measures they can take to block any offensive messages on computers at home.
4.5.4 Online bullying of school staff
- We are aware that school staff may become victims of online bullying by pupils and/or their parents/carers. Because of the duty of care owed to staff, head teachers should ensure that staff are able to report incidents in confidence and receive adequate support, including taking any appropriate action against pupils and parents.
- Incidents of online bullying involving school staff should be recorded and monitored by the Online Safety coordinator in the same manner as incidents involving pupils.
- The issue of online bullying of school staff should be incorporated into any anti-bullying policies, education programme or discussion with pupils so that they aware of their own responsibilities.
- Staff should follow the guidance on safe IT use in section 4 of this policy and avoid using their own mobile phones or email addresses to contact parents or pupils so that no record of these details becomes available.
- Personal contact details for staff should not be posted on the school website or in any other school publication.
- Staff should follow the advice above on online bullying of pupils and not reply to messages but report the incident to the head teacher immediately.
- Where the bullying is being carried out by parents/carers the head teacher should contact the parent to discuss the issue. A home/school agreement with the parent can be used to ensure responsible use.
4.6 Harmful sexual behaviour online
The internet contains a high level of sexually explicit content and internet-based communications systems and social networking sites can be used to send sexually explicit messages and images. In some cases these actions may be harmful or abusive or may constitute sexual harassment or online bullying and because of the nature of online activities this can lead to more widespread harm and repeat victimisation.
Gloucester House is aware of online behaviours of a sexual nature that could constitute harmful behaviour:
- consensual and non-consensual sharing of nude and semi-nude images
- upskirting
- sexualised online bullying
- unwanted sexualised comments and messages
- sexual exploitation, coercion or threats
- coercing others into sharing images or performing acts online that they are not comfortable with.
Gloucester House is aware of the duty under statutory guidance Keeping children safe in education and Sexual violence and sexual harassment between children in schools and colleges which requires schools to have policies in place to deal with incidents of on-line sexual harassment. Schools should refer to the Child on child abuse and sexual violence and harassment guidance for schools and collegesfor further details on what actions need to be taken in response to online sexual harassment. Schools and Nurseries Safeguarding Policies – Camden Safeguarding Children Partnership — CSCP
Gloucester House ensures that pupils and their parents/carers are aware that producing and distributing sexual images to peers via the internet or mobile devices may be illegal. Pupils need to understand that once the image is sent, they have lost control of who it is distributed to and how it is used, and that there is a good chance that the image will be widely seen, possibly including parents/Carers.
Staff need to be able to react to incidents in a proportional manner so that the welfare of young people is safeguarded and no young person is unnecessarily criminalised. Guidance for responding to incidents is available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/551575/6.2439_KG_NCA_Sexting_in_Schools_WEB__1_.PDF
Schools should also be aware of when any of these behaviours may be linked to extra-familial harm such as the criminal or the sexual exploitation of a pupil or is being carried out as a gang- related activity. Staff should refer to the CSCP Extra-familial harm and child exploitation guidance for further details.
CSCP-extra-familial-harm-and-child-exploitation-guidance.pdf
4.7 Risk from inappropriate contacts with adults
Staff may be concerned about a pupil being at risk as a consequence of their contact with an adult they have met over the internet. The pupil may report inappropriate contacts or staff may suspect that the pupil is being groomed or has arranged to meet with someone they have met on-line.
School staff should also be aware of pupils being sexually abused on-line through video messaging such as Skype. In these cases, perpetrators persuade the young person concerned to carry out sexual acts while the perpetrator watches/records.
- All concerns around inappropriate contacts should be reported to the online safety co-ordinator and the designated safeguarding lead.
- The designated safeguarding lead should discuss the matter with the referring member of staff and where appropriate, speak to the pupil involved, before deciding whether or not to make a referral to Children’s Safeguarding and Social Work and/or the police.
- The police should always be contacted if there is a concern that the child is at immediate risk, for example if they are arranging to meet the adult after school.
- The designated safeguarding lead can seek advice on possible courses of action from Camden’s online safety officer in Children’s Safeguarding and Social Work.
- Staff will advise the pupil on how to terminate the contact and change contact details where necessary to ensure no further contact.
- The designated safeguarding lead and the online safety co-ordinator should always notify the pupil’s parents of any concerns or incidents and where appropriate, arrange to meet with them discuss what action they can take to ensure their child’s safety.
- Where inappropriate contacts have taken place using school IT equipment or networks, the online safety co-ordinator should make a note of all actions taken and contact the network manager or learning platform provider to ensure that all evidence is preserved and that an audit of systems is carried out to ensure that the risk to other pupils is minimised.
4.8 Risk from contact with violent extremists:
Many extremist groups who advocate violence use the internet as a means of either inciting violence against specific groups or providing information on preparing explosives or carrying out terrorist acts. Because of their personal circumstances, some young people may be susceptible to these influences and may be radicalised as a result of direct contact with online extremists or because they self-radicalise having viewed extremist materials online.
All schools have a duty under the Government’s Prevent programme to prevent vulnerable young people from being radicalised and drawn into terrorism. The main mechanism for this is Camden’s Channel Panel, a multi-agency forum that identifies young people who are at risk and develops a support plan to stop the radicalisation process and divert them from extremism.
- Staff need to be aware of the school’s duty under the Prevent programme and be able to recognise any pupil who is being targeted by violent extremists via the internet for the purposes of radicalisation. Pupils and staff should be warned of the risks of becoming involved in such groups and informed that accessing such websites is against school policies.
- The school should ensure that adequate electronic filtering is in place and review filtering in response to any incident where a pupil or staff member accesses websites advocating violent extremism.
- All incidents should be dealt with as a breach of the acceptable use policies and the school’s behaviour and staff disciplinary procedures should be used as appropriate.
- The online safety co-ordinator and the designated safeguarding lead should record and review all incidents in order to establish whether there are any patterns of extremist groups targeting the school and whether current school procedures are robust enough to deal with the issue.
- Where there are concerns that a young person is being radicalised or is in contact with violent extremists, or that their parents are and this is placing the child or young person at risk, schools should refer to MASH.
Schools may contact the Prevent Education Manager for advice on any of the above.
Further information is available in the CSCP guidance “Safeguarding children and young people from radicalisation and extremism” available at: https://cscp.org.uk/resources/radicalisation-and-extremism-resources/
4.9 Risk from sites advocating suicide, self-harm and anorexia:
Some internet sites advocate dangerous activities such as self-harming, suicide or anorexia. Other sites contain sexually explicit material or glorify risky and illegal behaviours like substance misuse.
Exposure to potentially harmful materials online may normalise the issue for young people and desensitise them to the harm. Most young people who visit these sites will not be adversely affected, but some vulnerable, less resilient young people may feel drawn to the sites which may trigger harmful or even fatal behaviours.
- The school should ensure that young people have an opportunity to openly discuss issues such as self-harming, suicide, substance misuse and anorexia as part of the PHSE curriculum.
- Pastoral support should be made available to all young people to discuss issues affecting them and to establish whether their online activities are an added risk factor
- Staff should receive the training needed to raise awareness of these issues so that they are able to identify those young people who are at risk, offer appropriate support and make appropriate referrals for help.
5 Sanctions for misuse of school IT
Individual schools are responsible for deciding what sanctions will be applied for breach of acceptable use policies. Sanctions applied should reflect the seriousness of the breach and should take into account all other relevant factors. The following is a framework recommended by LGfL that schools may want to adopt: For each point, schools may record their own detailed list of breaches and corresponding sanctions.
5.1 Online Safety Incident Log
Keeping an incident log can be a good way of monitoring what is happening and identify trends or specific concerns. (See Appendix 5)
5.2 Sanctions for pupils
Sanctions will be applied for breach of acceptable use policies. Sanctions applied will reflect the seriousness of the breach and take into account all other relevant factors. The following is a framework recommended by LGfL
5.2.1 Category A infringements
These are basically low-level breaches of acceptable use agreements such as:
- use of non-educational sites during lessons
- unauthorised use of email or mobile phones
- unauthorised use of prohibited sites for instant messaging or social networking.
Sanctions applied in the framework of Gloucester House behaviour policy/system. The incident will also be:
- recorded on the incident log
- Parents/Carers and other agencies notified as appropriate
- the online safety coordinator will be informed and the DSL if necessary
School policy: See Gloucester House behaviour policy
5.2.2 Category B infringements
These are persistent breaches of acceptable use agreements following warnings and use of banned sites or serious breaches of online safety policy that are non-deliberate, such as:
- continued use of non-educational or prohibited sites during lessons.
- continued unauthorised use of email, mobile phones or social networking sites during lessons.
- use of file sharing software.
- accidentally corrupting or destroying other people’s data without notifying staff.
- accidentally accessing offensive material without notifying staff.
Sanctions in addition to the behaviour system will be:
- referral to online safety co-ordinator.
- loss of internet access for a period of time.
- contacting parents/carers
School policy
5.2.3 Category C infringements
These are deliberate actions that either negatively affect school ICT systems or are serious breaches of acceptable use agreements or anti-bullying policies, such as:
- deliberately bypassing security or access
- deliberately corrupting or destroying other people’s data or violating other’s privacy
- online bullying
- deliberately accessing, sending or distributing offensive or pornographic material
- purchasing or ordering items over the internet
- transmission of commercial or advertising material.
Sanctions in addition to the behaviour system will be:
- referral to online safety co-ordinator
- referral to head of service
- loss of access to the internet for a period of time
- contact with parents/carers
- any sanctions agreed under other school policies.
- liaison with other services/DSL as indicated
5.2.4 Category D infringements
These are continued serious breaches of acceptable use agreements following warnings or deliberately accessing and distributing banned or illegal materials which may result in a criminal offence, such as:
- persistent and/or extreme online bullying
- deliberately accessing, downloading or disseminating any material deemed offensive, obscene, defamatory, racist, homophobic or violent
- receipt or transmission of material that infringes the copyright of other people or is in breach of the Data Protection Act
- bringing the school name into disrepute.
Sanctions could include:
- referral to head teacher
- contact with parents/carers
- possible exclusion
- removal of equipment
- referral to community police officer
- referral to Camden’s online safety officer
School policy
5.3 Sanctions for staff
These should reflect the seriousness with which any breach of acceptable use policies by staff members will be viewed given their position of trust and the need to ensure acceptable standards of behaviour by adults who work with children. Sanctions will be linked to the staff behaviour policy or code of conduct.
5.3.1 Category A infringements
These are minor breaches of the school’s acceptable use policy which amount to misconduct and will be dealt with internally by the head teacher as a low level incident in line with the school’s staff conduct policy.
- excessive use of internet for personal activities not connected to professional development
- use of personal data storage media (eg: removable memory sticks) without carrying out virus checks
- any behaviour on the world wide web and social media sites such as Twitter that compromises the staff member’s professional standing in the school and community, for example inappropriate comments about the school, staff or pupils or inappropriate material published on social networking sites
- sharing or disclosing passwords to others or using other user’s passwords
- breaching copyright or licence by installing unlicensed software.
Possible sanctions include referral to their line manager who will issue a warning. The Headteacher will be informed in addition to the Trust HR team for any relevant actions and recording on their staff file.
5.3.2 Category B infringements
These infringements involve deliberate actions that undermine safety on the internet and activities that call into question the person’s suitability to work with children. They represent gross misconduct that would require a strong response and possible referral to other agencies such as the police or Camden’s LADO under the CSCP guidance on dealing with allegations against staff and volunteers. https://cscp.org.uk/wp-content/uploads/2020/09/Managing-allegations-against-staff-and-volunteers-multi-agency-guidance-2020.pdf
- serious misuse of or deliberate damage to any school computer hardware or software, for example deleting files, downloading unsuitable applications
- any deliberate attempt to breach data protection or computer security rules, for example hacking
- deliberately accessing, downloading or disseminating any material deemed offensive, obscene, defamatory, racist, homophobic or violent
- receipt or transmission of material that infringes the copyright of other people or is in breach of the Data Protection Act
- bringing the school name into disrepute.
Possible sanctions include:
- referral to the head teacher
- removal of equipment
- referral to Camden’s online safety officer
- referral to Camden’s LADO or the police
- suspension pending investigation – the Trusts HR team will be involved in this and the Chair of the Gloucester House Steering Group informed.
- disciplinary action in line with the trust policies.