Safeguarding considerations for Schools: Remote provision of education, online safety and cyber awareness

While the majority of pupils will be expected back in school in September, in certain circumstances schools will be expected to offer children access to remote education which should be planned for now.

For instance, remote education will need to be provided to pupils who are unable to attend school because they are complying with clinical and/or public health advice. Schools will also need a contingency plan in the event of a local outbreak in which the school might be closed, and therefore schools are expected to offer immediate remote education. This is explored further in the DfE reopening guidance, including expectations for remote education and resources to support schools in delivering it:

• In terms of the expectations, the DfE states that schools are expected to consider how to continue to improve the quality of their existing offer and have a strong contingency plan in place for remote education. When developing these contingency plans, schools should consider the DfE’s expectations (as set out in its reopening guidance), which include a focus on the curriculum, high quality remote education resources, and engagement / responsiveness of staff. Of particular note, is the DfE’s expectation that schools provide printed resources, such as textbooks and workbooks, for pupils who do not have suitable online access. Therefore, schools should review the DfE’s expectations to ensure their remote provision would comply, and consider any particular children for whom additional arrangements may need to be in place (including younger pupils, pupils with SEND, or those who do not have sufficient access to the internet).
• There are a range of remote education resources available, as set out in the DfE’s guidance. The DfE has also separately published case studies demonstrating schools’ remote education practice.

We have set out below particular considerations for remote provision of education.

Even in the context of lockdown easing in many areas, it remains likely that pupils will spend more time online / on social media due to social distancing, and in certain cases remote teaching and learning. Accordingly, schools should remain particularly alive to the risks presented (such as cyberbullying, peer-on-peer abuse and sexting). Examples of this we have seen through case work is where a pupil puts pressure on another pupil (often younger) to create a video of themselves saying something offensive or abusive.

Online safety should form part of the risk assessment process, with strategies in place to manage identified risks. The DfE has produced specific guidance in relation to safeguarding pupils and staff in the remote environment which includes reference to various resources for schools: DfE Remote Education Guidance. This guidance also includes links to external resources regarding remote education, including from The Key for School Leaders, the NSPCC and the UK Safer Internet Centre.

It may also be a good time to remind pupils (and parents) about online behaviours between peers as well as how to stay safe when online. This may be reflected in E-safety or Acceptable Use policies, and Anti-bullying policies relating to cyberbullying. Pupils may also need to be reminded of the risks of creating a digital footprint, and that images or videos created on platforms such as Snapchat and TikTok can be captured and shared.

Parents, in turn, should be encouraged to use filters and set age-appropriate parental controls on digital devices at home to help ensure a safe online environment. Parents should also know what sites the school will ask their child(ren) to use and the staff their child(ren) will interact with. Where parents choose to supplement the school’s online offer with support from third parties, schools should emphasise the importance of securing online support from a reputable organisation/individual who can provide evidence that they are safe and can be trusted to have access to children.

All staff should be reminded of the school’s safeguarding and child protection policy and procedures and what to do if they see or hear something worrying during an online session and/or a child makes a disclosure remotely. Schools should also ensure there is a ‘safe space’ for pupils to ask questions and raise concerns, as well as signposting children to age appropriate practical support, such as:

• Childline - for support
• UK Safer Internet Centre - to report and remove harmful online content
• CEOP - for advice on making a report about online abuse

During the summer term, many schools and staff provided education remotely through a variety of technology solutions and, as explained above, high quality remote education is expected to continue in certain circumstances. These arrangements require particular safeguarding considerations to protect both staff and pupils. Suitable risk assessments should be in place for remote learning generally, with steps in place to minimise any identified risks.

Schools should consider providing guidance to staff, pupils and parents in terms of safe access to remote learning. As above, staff should also be reminded that the staff code of conduct/staff behaviour policy will continue to apply to online and distance learning arrangements. Any existing codes of conduct, behaviour, acceptable use or e-safety policies should be reviewed and checked to see if they need to be updated in light of the current situation, and to reflect the fact that the same principles apply equally to the remote learning environment.

For instance, in order to protect staff, teachers may be advised insofar as possible to:

• Deliver the content in a neutral location with no personal items in sight;
• Be dressed appropriately (i.e. work clothes, not loungewear);
• Ensure their family members are out of the room;
• Check the content reflects the pupil cohort taking account of the needs of any vulnerable pupils (including those with SEND);
• Communicate with parents and pupils within school hours as much as possible (or hours agreed with the school to suit the needs of staff);
• Consider if any sessions are being delivered 1:1, and whether any additional protections should be in place; and
• Manage IT arrangements wherever possible to ensure that staff do not use their personal phones or email addresses to contact pupils / parents.

Similar arrangements should be in place for pupils/parents, with particular regard for those who may be participating in live sessions, for instance advising parents to ensure that pupils are learning in a neutral environment (not a bedroom) and are dressed appropriately. Pupils should be provided with and/or reminded of the expectations of their behaviour in relation to each other and staff (including issues such as cyberbullying, sexting etc), and reminded of any relevant policies such as acceptable use. Pupils must be clear as to how to raise any concern they may have.

Particular consideration should be given to any pupils with particular needs (whether learning, emotional or otherwise) or disabilities which may make aspects of the remote learning provision particularly challenging. Relevant staff (e.g. pastoral leads, SENCO, or particular academic staff) should consider any pupils who may have particular difficulties to consider what adjustments, strategies or support can be put in place to support them during remote learning, to take account of their individual circumstances.

Where schools consider that one-to-one remote sessions are appropriate (e.g. to provide pastoral care or support for pupils with SEND), this should be discussed and approved by the senior leadership team to assess any risks. For instance, as part of the risk analysis, depending upon the matter being discussed, and the particular needs of the pupil, it may be that schools arrange for a parent or additional staff member to be on the call.

Such arrangements should be documented on any individual pupil plans, and be monitored for effectiveness. This will help ensure the school is meeting the needs of those pupils, and mitigate against future complaints and claims for instance of a failure to make reasonable adjustments.

There is no right or wrong approach for schools – rather a risk-based strategy, taking account of the particular school context (including available IT systems, resources, age of children), regard to guidance, and with appropriate risk mitigation strategies in place. Schools should consider the approaches that best suit the needs of their pupils and staff and in light of any identified risks.

When considering whether to record sessions, school should consider any associated risks (for instance, do recordings protect staff if complaints were raised at a later date), and how to store such data in line with data protection laws. If schools are considering recording lessons that take place within the classroom (e.g. recording or live streaming a lesson for pupils who are studying remotely to watch), it is important that schools seek data protection advice, given the potential for pupils to be captured within this recording.

The government guidance states that all schools should be doing what they reasonably can to keep their children safe. For pupils who study remotely, it is important that staff who do interact with children, including online, continue to look out for signs a child may be at risk.

Clear reporting routes for staff - as well as pupils and parents - to raise safeguarding concerns is essential. Any concerns should be dealt with in accordance with the child protection policy and with appropriate referrals to social care and/or the police as appropriate. Schools may wish to review these existing arrangements to ensure they continue to be appropriate, or if additional or alternative arrangements need to be put in place.

Schools should also consider signposting the school community to the practical support and resources available for supporting online safeguarding, reporting harmful or upsetting content, as well as those platforms for pupils to confidentially report online bullying and abuse. (Details of these resources can be found here.)

There are IT / cyber security implications of any online learning environment, with consideration given to who is able to access what. Care must be taken around permissions and extent of access granted to pupils (and staff) through the remote routes, and content should suitable to the pupil cohort accessing it. These considerations should be documented with the school’s risk assessment, with strategies and measures taken in relation to these risks documented and monitored.

Schools should also continue to ensure that appropriate filters and monitoring systems are in place to protect children online when accessing the school’s IT systems or recommended resources online. Staff with the relevant technical knowledge to maintain safe IT arrangements should be identified, including additional points of contact in their absence.

There are also data protection considerations when relying on IT solutions, in particular in ensuring sensitive information is held securely and mitigating against data breaches/security incidents. The National Cyber Security Centre has published some NCSC Guidance for schools, and particularly for governors and trustees to help manage cyber-security issues in a proportionate way.

There are some helpful links relating to online safety support within the government’s COVID-19 remote education guidance here.

There are also some helpful links to various resources (here) to support parents to keep children safe online. In some areas, schools may also be able to seek online safety support from their local authority.

Schools should ensure, when communicating online with parents and pupils, that in so far as possible communications are within school hours (or hours agreed with the school to suit the needs of staff) and via school senior management approved channels.

To help safeguard staff, communications should be via school email accounts and using school devices (wherever possible). Staff should be reminded not to share any personal information with pupils and their parents. These measures will, in turn, help ensure compliance with data protection law.