Role Models E-Safety Policy

INTRODUCTION

E-Safety encompasses Internet technologies and electronic communications such as mobile phones as well as collaboration tools and personal publishing.

It is the duty of Role Models to ensure that every child in our care is safe, and the same principles should apply to the ‘virtual’ or ‘digital’ world as would be applied to the physical buildings where we run our courses.

This Code of Practice is drawn up to protect all parties: the students, the staff and the company and aims to provide clear advice and guidance on how to minimise risks and how to deal with any infringements.

This Code of Practice is made available to all staff members.

Also see E-Safety Agreement.

Also see our Communications, Email, and Internet Policy.

AIMS

• To set out the key principles expected of all members of the community at Role Models with respect to the use of ICT-based technologies.
• To safeguard and protect the children and staff of Role Models.
• To fulfil the responsibilities imposed by UK and EU laws and regulations in respect to data protection and privacy.
• To assist course staff working with children to work safely and responsibly with the internet and other communication technologies and to monitor their own standards and practice.
• To set clear expectations of behaviour and/or codes of practice relevant to responsible use of the internet for educational, personal or recreational use.
• To ensure that all members of the Role Models community are aware that unlawful or unsafe behaviour is unacceptable and that, where appropriate, disciplinary or legal action will be taken.
• To minimise the risk of misplaced or malicious allegations made against adults who work with children.

SCOPE

• This code of practice applies to the whole Role Models community including management, board directors, all staff employed directly or indirectly by the Company and all pupils.
• Role Models’ management and directors will ensure that any relevant or new legislation that may impact upon the provision for e-Safeguarding within company will be reflected within this code of practice.
• The company reserves the right to interrupt working contracts, exclude children from courses and take any legal action that it deems appropriate where this code of conduct is not adhered to. This is pertinent to incidents of cyberbullying, or other e-Safeguarding-related incidents covered by this code of practice, which may take place out of the courses we offer, but is linked to membership of the company.

CONTEXT AND BACKGROUND

The technologies

ICT in the 21st Century has an all-encompassing role within the lives of children and adults. New internet and online technologies are enhancing communication and the sharing of information.

Current and emerging Internet and online technologies used in school and, more importantly in the case of Role Models, used outside school by children and staff include:

1. The Internet – World Wide Web
2. E-mail
3. Instant messaging (often using simple web cams, e.g. Instant Messenger)
4. Web based voice and video calling (e.g. Skype)
5. Online chat rooms
6. Online discussion forums
7. Social networking sites (e.g. Facebook)
8. Blogs and Micro-blogs (e.g. Twitter)
9. Podcasting (radio / audio broadcasts downloaded to computer or MP3/4 player)
10. Video broadcasting sites (e.g. You Tube)
11. Music and video downloading (e.g. iTunes)
12. Mobile phones with camera and video functionality
13. Smart phones with e-mail, messaging and internet access
14. CCTV Recordings

Our whole Company approach to the safe use of ICT

Creating a safe ICT learning environment includes three main elements:

1. An effective range of technological tools
2. Policies and procedures, with clear roles and responsibilities
3. E-Safety teaching is embedded into the staff training and schemes of work

ROLES AND RESPONSIBILITIES

E-Safety is recognised as an essential aspect of strategic management of this company, with the support of its directors, Role Models aims to embed safe practices into the culture of the company.

Management team

• The management is ultimately responsible for ensuring the safety (including e-safety) of members of the company.
• All safeguarding issues will be dealt with following the procedures within this code of practice and the Safeguarding Procedures. See also our Offline Safeguarding Policy and Online Safeguarding Policy.
• The management ensures that this code of practice is implemented across the company via the usual monitoring procedures.
• The management is responsible for ensuring that all relevant staff receive suitable training to enable them to carry out their e-Safeguarding roles.
• The management should be aware of procedures to be followed in the event of a serious e-Safeguarding incident.

E-Safety Co-ordinator

Our DSL (Designated Safeguarding Lead) is also an e-Safety Co-ordinators. The role of the e-Safety Co-ordinator includes:

• To promote an awareness and commitment to e-Safeguarding throughout the company.
• To take day-to-day responsibility for e-Safeguarding within the company and to have a leading role in establishing and reviewing e-Safeguarding policies and procedures.
• To ensure all staff are aware of the procedures that need to be followed in the event of an e-safety incident taking place.
• To provide training and advice for staff.
• To receive reports of e-safety incidents and create a log (in our CRM system, Podio) of incidents to inform future e-safety developments.

The e-Safety Co-ordinator is also responsible for:

• Supporting the company in providing a safe technical infrastructure to support working and teaching.
• Ensuring that users may only access the company’ networks and devices through a properly enforced password protection policy.
• Ensuring that provision exists for misuse detection and malicious attack.
• Taking responsibility for the security of the company’s ICT system.
• Ensuring that access controls exist to protect personal and sensitive information held on company’s devices.
• Ensuring that appropriate physical access controls exist to control access to information systems and telecommunications equipment situated within the company’s premises.
• Ensuring that appropriate backup procedures exist so that critical information and systems can be recovered in the event of a disaster.

Staff

The duties of the staff include:

• To have an up to date awareness of e-safety matters and of the current e-safety code of practice and procedures.
• To adhere to the company’s employee Data Protection Policy, section 10 within our IT Security Policy.
• To read, understand and adhere to the E-Safety Agreement.
• To report any suspected misuse or problem to the e-Safety Co-ordinator for investigation / action / sanction.
• To model safe and responsible behaviours in their own use of technology.
• To ensure that all digital communications with students / parents / carers should be on a professional level and only carried out using official company systems.
• To supervise and guide pupils carefully when engaged in learning activities involving technology.
• To ensure that pupils understand and follow the e-safety and acceptable use policies.
• To ensure that in lessons where internet use is pre-planned pupils should be guided to sites checked as suitable for their use and that processes are in place for dealing with any unsuitable material that is found in internet searches.

COMMUNICATION

Staff

• This E-Safety Policy is provided to all members of staff as part of their onboarding process.
• All amendments will be stated to the team verbally and the link to this policy will be re-circulated.
• All members of staff are asked to read the company’s E-Safety Agreement.
• Staff will be made aware that Internet traffic can be monitored and traced to the individual user. Discretion and professional conduct are essential.
• All members of staff will be made aware that their online conduct out of school could have an impact on their role and reputation. Civil, legal or disciplinary action could be taken if they are found to bring the profession or institution into disrepute, or if something is felt to have undermined confidence in their professional abilities.

TRAINING

• As part of the induction process all new staff receive information and guidance on this e-Safeguarding policy and the E-Safety Agreement.
• All staff will be made aware of individual responsibilities relating to the safeguarding of children within the context of e-Safeguarding and know what to do in the event of misuse of technology by any member of the Role Models community.

STUDENTS

We believe it is better to support children in finding their way around the Internet with guidance and positive role modelling rather than restrict Internet use to a few trusted sites.

Despite the best efforts of our staff and/or occasionally students may come cross something on the Internet that they find offensive, unpleasant or distressing. Students are told at the start of each course to always report such experiences directly to an adult at the time they occur, so that action can be taken. The action will include:

1. Making a note of the website and any other websites linked to it.
2. Informing the e-Safety Co-ordinator
3. Logging the incident on our CRM system, Podio
4. Discussion with the pupil about the incident, and how to avoid similar experiences in future.

MANAGING ICT SYSTEMS AND ACCESS

• Role Models will be responsible for ensuring that access to its ICT systems is as safe and secure as reasonably possible.
• For full detail, see our IT Security Policy.

EMERGING TECHNOLOGIES

• Emerging technologies will be examined for educational benefit and a risk assessment will be carried out before use in our courses is allowed.
• Prior to deploying any new technologies within the company, staff will have appropriate awareness training regarding safe usage and any associated risks.

MANAGING DIGITAL CONTENT

Thought needs to be given whenever images, video and sound, including the use of course-generated assets and those found on the internet, are used in our courses or promotional materials. In order to ensure compliance with GDPR regulations and to respect privacy, we need to be careful when sharing these images, videos and sounds online.

Written permission from parents or carers will be obtained for the following locations before photographs of pupils are published. Parents and carers may withdraw permission, in writing, at any time.

• On the company’s website
• In the prospectus and other printed promotional material
• In display material that may be used around the office and other premises
• Recorded or transmitted on a video or via webcam in an educational conference

Staff will only use Role Models’ equipment to create digital images, video and sound. In exceptional circumstances, personal equipment may be used with permission from the management provided that any media is transferred solely to a company’s device and deleted from any personal devices.

In particular, digital images, video and sound will not be taken without the permission of participants; images and video will be of appropriate activities and participants will be in appropriate dress; full names of participants will not be used either within the resource itself, within the file name or in accompanying text online; such resources will not be published online without the permission of the staff and pupils involved.

If students are involved, relevant parental permission will also be sought before resources are published online.

Parents may take photographs at Role Models’ events: however, they must ensure that any images or videos taken involving children other than their own are for personal use and will not be published on the internet including social networking sites.

Storage of images

• Any images, videos or sound clips of pupils must be stored on the company’s server protected by appropriate passwords and never transferred to personally owned equipment.
• Staff are not permitted to use personal portable media for storage of any images, videos or sound clips of pupils. Role Models are permitted to use them to take photos for End of Day Emails but agree to delete these at the end of the week, as per our Safeguarding Policy.

E-MAIL

See our Communications, Email, and Internet Policy.

MOBILE PHONES AND PERSONAL DEVICES

See our Communications, Email, and Internet Policy.

CHAT, DISCUSSION AND SOCIAL NEWORKING SITES

See our Communications, Email, and Internet Policy.

DELIBERATE MISUSE OF THE INTERNET FACILITIES

Role Models has to act within the law, which means it has, in turn, to ensure that its students and its staff are doing so, by enforcing the Rules and Regulations as explained in this Policy. Therefore, any breach of these Rules will be treated by Role Models as a serious disciplinary matter. If the breach or misuse results in a data breach Role Models commits to reporting any such breach to the ICO (Information Commissioners Office) and notifying appropriately data subject and data controllers without undue delay.

StudentsIf students are due to be using the internet as part of our course, they will be made aware of the rules for using the Internet safely and appropriately before the start of the course they attend.

Where a student is found to be using the Internet inappropriately, for example to download games, or search for unsuitable images, then sanctions will be applied according to the nature of the misuse, and any previous misuse.

Sanctions will include:Unsuitable material (e.g. online games, celebrity pictures, music downloads, sport websites etc)

1. Initial warning from course teacher
2. Report to Role Models management
3. Letter to parent/carer

Offensive material (e.g. pornographic images, racist, sexist or hate website or images etc)

1. Incident logged and reported to the Management.
2. Call/letter to parent/carer
3. Meeting with Parent/Carer
4. Subsequent incidents will be treated very seriously by the company and may result in exclusion and/or police involvement.

HOW WILL COMPLAINTS REGARDING E-SAFETY BE HANDLED?

The company will take all reasonable precautions to ensure that users access only appropriate material. Methods to identify, assess and minimise risks will be reviewed regularly. However, due to the global and connected nature of Internet content, it is not possible to guarantee that access to unsuitable material will never occur via a company computer. Role Models cannot accept liability for material accessed, or any consequences of Internet access.

Staff and students, when relevant, are given information about infringements in use and possible sanctions.

Our e-Safety Coordinator acts as first point of contact for any complaint. Any complaint about staff misuse is referred to the Board of directors.

CYBERBULLYING – Online bullying and harassment

By cyber-bullying, we mean bullying by electronic media. It is an aggressive, intentional act carried out by a group or individual using electronic forms of contact repeatedly over time against a victim who cannot easily defend him/herself. Cyberbullying is insidious; it can be conducted 24 hours a day, seven days a week, following children into their private space and outside course hours. It can be anonymous. The audience is large and can be reached rapidly. Unlike other forms of bullying, a single incident can be experienced as a multiple attack – a video posted to a website can be copied to many different sites. Bystanders can become accessories by passing on a humiliating message. Messages on social networking sites remain there to damage social life and friendships.

Cyberbullying (along with all other forms of bullying) of any member of the Role Models community will not be tolerated.

We encourage all staff and students to discuss any concerns or worries they have about online bullying and harassment with staff.

We are committed to reviewing our policy and procedures annually. This policy was last reviewed in January 2024.