Online Safety within “Inspecting safeguarding in early years, education and skills settings” from September 2015.

Please note this post has been updated following the September 2016 revision. Please find the most up-to-date post here.

This post follows on from a post which highlights online safety within Ofsted’s Common Inspection Framework available here. Please be aware that these posts should not be read in isolation.

Please be aware that this post will only highlight elements reflective of online safety and should be read within the wider context of the documentation. Italic content indicates a direct quote from the new guidance and standard font in blue highlights best practice and recommendations.

The common inspection framework comes into effect from 1 September 2015 and remains in draft until that point. Minor amendments may be made to the text prior to September. This post was published in June 2015 and last updated in December 2015.

Online Safety within “Inspecting safeguarding in early years, education and skills settings”, September 2015.

The full document can be found here

  • 10. Safeguarding action may be needed to protect children and learners from:
    • neglect. May include failure to protect children from risk to content online which poses a significant risk of harm and  issues caused by problematic internet use by parents/carers.
    • sexual abuse. Will include online sexual abuse and exploitation.
    • emotional abuse. Will include cyber/online bullying.
    • bullying, including online bullying and prejudice-based bullying. Explicitly references online/cyber bullying as a safeguarding issue..
    • racist, disability and homophobic or transphobic abuse. This may take place online.
    • radicalisation and/or extremist behaviour. This may take place online.
    • child sexual exploitation and trafficking. This may take place online.
    • the impact of new technologies on sexual behaviour, for example sexting. This specifically highlights online safety as a safeguarding issue.
    • teenage relationship abuse. This may take place online.
  • 11. Safeguarding is not just about protecting children, learners and vulnerable adults from deliberate harm, neglect and failure to act. It relates to broader aspects of care and education, including:
    • online safety and associated issues. Ofsted state that the term ‘online safety’ reflects a widening range of issues associated with technology and a user’s access to content, contact with others and behavioural issues. It is often referred to as “e-Safety”. This highlights that online safety should be considered to be a safeguarding issue.

The signs of successful safeguarding arrangements

  • 13. In settings that have effective safeguarding arrangements, there will be evidence of the following:
    • Children and learners are protected and feel safe. Those who are able to communicate know how to complain and understand the process for doing so. There is a strong, robust and proactive response from adults working with children and learners that reduces the risk of harm or actual harm to them. Adults working with them know and understand the indicators that may suggest that a child, young person or vulnerable adult is suffering or is at risk of suffering abuse, neglect or harm and they take the appropriate and necessary action in accordance with local procedures and statutory guidance.
      • This will include children being and feeling safe in the online environment as well as offline and at school or within the setting.
      • This may also include considerations regarding the technology access children have within the school/setting, for example does the school/setting use an accredited internet service provider (ISP) and use appropriate filtering, monitoring and/or security systems to ensure that the school/setting network is safe and secure.
      • This may include working closely with parents/carers to ensure that the school/settings online safety ethos and approach is shared. Schools and settings should seek to ensure that parents/carers understand e-safety issues and risks and their roles and responsibilities and may offer a range of opportunities to support them with this such as specific e-Safety workshops, information on school websites/newsletters, child led education etc.
    • Leaders and managers have put in place effective safeguarding and staff behaviour policies that are well understood by everyone in the setting.
      • Schools and settings will need to include online safety either as a separate and specific policy or embedded within safeguarding.
      • Kent’s online safety (e-Safety) policy templates can be found here
    • Staff and other adults working within the setting are clear about procedures where they are concerned about the safety of a child or learner and there is a named and designated lead who is enabled to play an effective role in pursuing concerns and protecting children and learners
      • The designated lead will need to act as the overall lead for online safety and coordinate whole school/setting online safety approaches and act as the lead for dealing with online safety issues that arise. The person  appointed as the online safety lead does not need to have vast technical knowledge as online safety is not a technical role/responsibility; however it would be helpful if they had some basic knowledge and understanding of technology.
      • To assist the DSL, they should access appropriate training to ensure they have a higher level of expertise regarding online safety which can then be shared and cascaded with other staff accordingly.
      • Is it recommended that the online safety lead is a member of the leadership or management team due to the requirements and expectations of the role (they need to be able to direct school/setting resources and attend appropriate meetings where there is a concern) and to ensure that online safety is given strategic consideration across all areas of the school/setting.
      • It is recommended that schools/settings elect the Designated Safeguarding Lead (DSL) as the online safety lead/coordinator as online safety concerns may often cross the Child Protection threshold and require referrals to other agencies.
      • Some schools/settings will choose to elect another member of staff but the DSL will hold responsibility for child protection concerns and therefore must always be made aware of and involved with any disclosures or incidents and capture and record online safety concerns, whole staff training etc.
      • Many schools/setting are choosing to support the role of the online safety lead by setting up online safety groups, teams or committees who can support the online safety lead and share workloads and tasks. These teams involve key stakeholders including relevant members of staff, children and parents. This means that key members of the community are involved in developing the ethos and in establishing a whole school/setting approach to e-Safety.
      • The procedure for children, parents and staff to use when reporting any online safety concerns must be clearly communicated – for example on the school/setting website.
      • Staff training  must be specific to the settings procedures and must ensure that all staff are clear how to recognise, respond and refer online safety concerns.
    • Children and learners can identify a trusted adult with whom they can communicate about any concerns. They report that adults listen to them and take their concerns seriously. Where children or learners have been or are at risk, such a trusted adult has been instrumental in helping them to be safe in accordance with agreed local procedures. Children who are unable to share their concerns, for example babies and very young children, form strong attachments to those who care for them through the effective implementation of the key person system.
      • This will include online safety. The fear of losing internet privileges or not being taken seriously (e.g. being told to not using the internet or that staff/parents don’t “understand” or see the point of social networking, gaming or chat sites and apps) can be a common reason why children and young people don’t speak to adults about problems online. If staff ignore or fail to acknowledge the advances in technology then they will be ignoring a major part of children’s lives. If schools/settings are to understand  and help children effectively then they must acknowledge and understand the true nature of the world in which they live.
    • Any child protection and/or safeguarding concerns are shared immediately with the local authority or other relevant agency in the area where the concerned professional is working and a record of that referral is retained. There is evidence that any agreed action following the referral has been taken promptly to protect the child or learner from further harm. There is evidence, where applicable, that staff have an understanding of when to make referrals when there are issues concerning sexual exploitation, radicalisation and/or extremism or that they have sought additional advice and support. Children and learners are supported, protected and informed appropriately about the action the adult is taking to share their concerns. Parents are made aware of concerns and their consent is sought in accordance with local procedures unless doing so would increase the risk of or actual harm to a child.
      • This will include formally reporting and recording online safety concerns.
      • Schools/settings should be aware of relevant contacts within local authorities (for example the Education Safeguarding Adviser (Online Protection) based within the Education Safeguarding Team in Kent) and ensure these are communicated accordingly with their communities.
    • Any risks associated with children and learners offending, misusing drugs or alcohol, self-harming, going missing, being vulnerable to radicalisation or being sexually exploited are known by the adults who care for them and shared with the local authority children’s social care service or other relevant agency. There are plans and help in place that are reducing the risk of harm or actual harm and there is evidence that the impact of these risks is being minimised. These risks are kept under regular review and there is regular and effective liaison with other agencies where appropriate.
      • This will include  online safety concerns. Schools/settings should ensure they are familiar with local safeguarding board procedures with regards to specific safeguarding issues e.g. www.kscb.org.uk
      • Leaders can register with the Kent e-Safety Blog and UK Safer Internet Centre newsletter to help enable them to keep up-to-date with emerging trends, new resources and content.
    • Children and learners are protected and helped to keep themselves safe from bullying, homophobic behaviour, racism, sexism and other forms of discrimination. Any discriminatory behaviours are challenged and help and support are given to children about how to treat others with respect.
      • This will include online bullying (cyberbullying) and also online discrimination, including homophobic, racist and sexist comments.
      • Schools/settings should ensure that their anti-bullying policy is robust and covers online bullying. Templates and links can be found here
    • Adults understand the risks posed by adults or learners who use technology, including the internet, to bully, groom, radicalise or abuse children or learners. They have well-developed strategies in place to keep children and learners safe and to support them to develop their own understanding of these risks and in learning how to keep themselves and others safe. Leaders oversee the safe use of technology when children and learners are in their care and take action immediately if they are concerned about bullying or children’s well-being. Leaders of early years settings implement the required policies with regard to the safe use of mobile phones and cameras in settings.
      • Online Safety is clearly identified as a leadership and management issue with a need for strategic oversight and awareness.
      • Leaders may wish to start by auditing current practice using tools such as the Kent Schools Online Safety audit tool, the SWGfL’s 360 safe  tool (which can enable schools to work towards and accreditation) or for other settings, Online Compass.
      • This point also highlights the importance of online safety being viewed as a whole school/setting safeguarding issue and not a technical concern. The means that whole staff training (not just for teaching staff) must be in place.
      • Leaders and managers need to ensure that staff training is appropriate and specific to the setting. External support (such as external agencies providing training either online or in person) can be beneficial but may not always sufficiently explore the settings own policies and procedures or have sufficient understanding of local safeguarding procedures. If external support is used then it must be underpinned and extended by the leaders and managers to ensure that all staff are aware of the settings requirements, expectations and procedures.
      • Staff training must be up-to-date, relevant and delivered regularly for all staff. It is recommended that settings ensure training enables staff to develop and build their online safety knowledge and understanding throughout the staff training calendar. Some schools/settings have found success by offering several shorter focused sessions throughout the year covering topics such as professional responsibilities and reputation which are underpinned by whole school/setting safeguarding training and staff induction.
      • Adults in schools/settings need to be able to discuss online safety with children in a confident and age appropriate way. School/setting curriculums should be flexible, relevant and engage pupils’ interests and encourage them to develop resilience to online risks.
      • Online safety is not the sole responsibility of the computing/ICT curriculum and must be woven throughout the curriculum . One-off events/assemblies or lessons regarding online safety will not be effective or adequate practice. Online safety education should start within early years and be developed throughout the year by all year/age groups. It is good practice for all staff to reference ways in which safeguarding and online safety can be reinforced within their lesson plans.
      • External support will be helpful to enable schools/settings to re-enforce key messages but must not be used in isolation to provide online safety education to children, young people and learners.
      • The Digital Literacy Scheme of Work may be useful to enabling schools/settings to achieve this.
      • Settings should ensure they participate in national events such as Safer Internet Day.
      • This highlights that online safety is not just about educating children about the risk of “grooming” by strangers and highlights that children can also be at risk of harm by their peers. A focus purely on grooming would be inadequate.
      • This highlights the important role that leaders and managers have to play in ensuring that there are relevant, clear, up-to-date and effective policies (either specific to online safety or embedded within other policies) regarding the safe use of technology, inducing social media and devices.
      • Leaders should also work together with IT staff to ensure that all school/setting systems and devices are appropriately monitored and documented in a way which enables the settings to fulfil its safeguarding responsibilities. It must however be very clear that online safety is not solely the role of technical staff and sufficient support (especially regarding supervision and reporting concerns) must be in place to enable technical staff to fulfil this role. Many schools are involving technical staff within online safety groups to ensure this approach and role is clearly defined.
      • There should be clear procedures to follow regarding online concerns. These should apply to staff, children and families and could be included as part of the school/settings child protection and safeguarding practices.
      • This will include ensuring that all members of the school/setting community understand appropriate online behaviour and conduct. This should mean that the school/setting has a clear policy which includes a relevant, understood and respected Acceptable Use Policy (AUP). The e-Safety (online safety) policy and AUP should be reviewed regularly (at least annually) and be developed with input from pupils, parents/carers and staff. The AUP should include clear guidance regarding safe and appropriate online conduct, especially electronic communication between staff and pupils and their parents/carers.
      • Kent’s online safety (e-Safety) policy templates can be found here
      • Leaders of early years settings have specific expectations to ensure that they understand and implement the required policies with regard to the safe use of mobile phones and cameras in settings. This will apply to staff as well as children and visitors/volunteers.
      • There should be an awareness of the role of mobile technologies for all settings and leaders must ensure that clear guidance is given to all staff  and students regarding expectations regarding use of personal devices. This should be highlighted within induction and staff training and also covered within the school acceptable use policy and safeguarding policies and wider education approaches.
    • Leaders and staff make clear risk assessments and respond consistently to protect young babies, children and learners while enabling them to take age-appropriate and reasonable risks as part of their growth and development.
      • This will include risk assessments regarding the safe and appropriate use of technology such as when using tablets, mobile devices or social media. Risk assessments should be taken seriously and be used to promote e-safety and online resilience.
    • Children and learners feel secure and, where they may present risky behaviours, they experience positive support from all staff. Babies and young children demonstrate their emotional security through the attachments they form with those who look after them and through their physical and emotional well-being. Staff respond with clear boundaries about what is safe and acceptable and they seek to understand the triggers for children’s and learners’ behaviour. They develop effective responses as a team and review those responses to assess their impact, taking into account the views and experiences of the child or learner.
      • Risky behaviours will include children taking risks online; therefore all members of staff need to have an understanding of the online world and the range of risks posed as well as the potential benefits to children.
      • Staff and children should have a clear understanding of what is considered to be acceptable and unacceptable online behaviour and there must be a clear procedure to follow where there is a concern.
    • Positive behaviour is promoted consistently. Staff use effective de-escalation techniques and creative alternative strategies that are specific to the individual needs of children and learners. Reasonable force, including restraint is only used in strict accordance with the legislative framework to protect the child and learner and those around them. All incidents are reviewed, recorded and monitored and the views of the child or learner are sought and understood. Monitoring of the management of behaviour is effective and the use of any restraint significantly reduces or ceases over time.
      • Schools/settings should positively reinforce good positive online behaviour and celebrate children’s successes. Many schools are developing digital leaders, ambassadors or champions to provide good role models for online behaviour.
      • This could also include working with children to develop school/setting policies and to educate and engage with families and the wider community in the online safety agenda.
      • Online safety incidents should be formally reported and recorded in line with other safeguarding concerns.
      • After any incidents or concerns schools/settings should review practice and identify any lessons learnt.
    • There are clear and effective arrangements for staff development and training in respect of the protection and care of children and learners. Staff and other adults receive regular supervision and support if they are working directly and regularly with children and learners whose safety and welfare are at risk.
      • This will include recognising and establishing online safety as part of safeguarding and child protection training for all staff.
    • The physical environment for babies, children and learners is safe and secure and protects them from harm or the risk of harm.
      • This will include technology considerations with regards to devices and appropriate filtering which is monitored appropriate by the school/setting.
    • All staff and carers have a copy of and understand the written procedures for managing allegations of harm to a child or learner. They know how to make a complaint and understand policies on whistleblowing and how to manage other concerns about the practice of adults in respect of the safety and protection of children and learners.
      • This may include allegations or concerns regarding online behaviour, therefore clear guidance which supports the school/settings safeguarding culture should be provided to staff. This should address (via induction, training and AUPs) the school/settings expectations regarding appropriate and professional behaviour and communication e.g. appropriate use of school equipment and using school/setting provided devices/communication channels so that contact takes place within clear and explicit professional boundaries which is transparent and open to scrutiny.
      • Kent’s online safety (e-Safety) policy templates can be found here

Evidence to look for when inspecting safeguarding arrangements

  • 15. Inspectors should look for evidence … of the setting’s safeguarding arrangements:
    • the extent to which leaders, governors and managers create a positive culture and ethos where safeguarding is an important part of everyday life in the setting, backed up by training at every level. This will include online safety. It is essential that leaders, governors and managers are aware and engaged in online safety.
    • the application and effectiveness of safeguarding policies and safe recruitment and vetting processes. This will include online safety policies. Kent’s online safety (e-Safety) policy templates can be found here
    • the quality of safeguarding practice, including evidence that staff are aware of the signs that children or learners may be at risk of harm either within the setting or in the family or wider community outside the setting. This will include staff awareness of online safety, supported by appropriate and up-to-date training which is given sufficient status by leaders, governors and managers.
    • the timeliness of response to any safeguarding concerns that are raised. This will include the school/setting response to online safety concerns both internally by staff and safeguarding leads and also with regards to external reporting.

Inspecting how effectively leaders and governors create a safeguarding culture in the setting.

  • 17. Inspectors should evaluate how well schools, colleges and early years settings fulfil their statutory responsibilities and how well staff exercise their professional judgement in keeping children and learners safe.
  • 16. Inspectors should consider how well leaders and managers in schools, further education and skills providers and early years settings have created a culture of vigilance where children’s and learners’ welfare is promoted and timely and appropriate safeguarding action is taken for children or learners who need extra help or who may be suffering or likely to suffer significant harm.
  • 18. Inspectors will want to consider evidence that:
    • leaders, governors and supervisory bodies (where appropriate) fulfil legislative requirements, such as those for disability, safeguarding, and health and safety.
      • Many children and indeed some staff use the Internet regularly without being aware that some of the activities they take part in are potentially illegal so governing bodies, leaders and managers must be aware of the wider legal framework when addressing online safety concerns e.g. Sexual Offences Act 2003, Criminal Justice Act 1988, Protection of Children Act 1978, Malicious Communications Act 1988, Data Protection Act 1998, Computer Misuse Act 1990, Copyright, Design and Patents Act 1988, Obscene Publications Act 1959 and 1964, Protection from Harassment Act 1997, Regulation of Investigatory Powers Act 2000, Criminal Justice and Immigration Act 2008 and Education and Inspections Act 2006. Please note this list is not exhaustive.
    • safeguarding policies and procedures are in place and regularly reviewed to keep all children and learners safe.
      • Governing bodies and proprietors must have strategic oversight of the school/setting safeguarding ethos and agenda and ensure that online safety is embedded within  safeguarding responsibilities.
      • Children must be taught to manage risk and develop safe and responsible online behaviours.
      • Kent’s online safety (e-Safety) policy templates can be found here
    • children and learners feel safe.
      • Including feeling safe online.
    • staff, leaders, governors and supervisory bodies (where appropriate) and volunteers receive appropriate training on safeguarding that is updated regularly and know their responsibilities with respect to the protection of children, young people and vulnerable adults.
      • This will include online safety awareness and  training for all staff.
      • Online safety training may be delivered internally by designated safeguarding leads or via external support. When using external support, settings should ensure that key messages are developed and extended internally.
    • staff are supported to have a good awareness of the signs that a child or learner is being neglected or abused, as described in ‘What to do if you’re worried a child is being abused’
      • This will include awareness of online abuse and the possible impact on children.
      • This will include providing specialist training for staff regarding concerns such as radicalisation, FGM, CSE and sexting.
    • there is a designated senior member of staff in charge of safeguarding arrangements who has been trained to the appropriate level and understands their responsibilities with respect to the protection of children, young people and vulnerable adults and the safeguarding of all learners; for designated members of staff in schools and colleges this training should take place every two years.
      • The DSL will have responsibility for online safety and may require additional training to support them within this role. Kent schools can contact the Education Safeguarding Adviser (Online Protection) to discuss local support and training available.
    • the setting identifies children or learners who may be at risk.
      • This includes those at risk of harm online.
    • action is taken to raise awareness of children and learners in relation to a range of safeguarding matters, including domestic abuse or sexual exploitation.
      • This will include risk of online sexual exploitation.
    • there is a clear approach to implementing the Prevent duty and keeping children and learners safe from the dangers of radicalisation and extremism.
      • This will include the risks of radicalisation and extremism online.
      • The DfE has published new advice (1st July) to clarify the role of schools and childcare providers under the new ‘prevent duty’, and to help protect children from radicalisation. The new advice and social media guidance for school leaders has been issued to schools to ensure children and young people are safeguarded and schools can carry out the prevent duty, introduced as part of the Counter-Terrorism and Security Act 2015, which legally requires a range of organisations including schools, local authorities, prisons, police and health bodies to take steps to prevent people from being drawn into terrorism.
      • School/setting leaders will need to mindful of this new legislation also see the following link from SWGfL for more information.
    • the setting takes effective action to prevent and tackle discriminatory and derogatory language – this includes language that is derogatory about disabled people, and homophobic and racist language.
      • This may include online incidents.
    • children and learners are able to understand, respond to and calculate risk effectively, for example risks associated with child sexual exploitation, domestic violence, female genital mutilation, forced marriage, substance misuse, gang activity, radicalisation and extremism,and are aware of the support available to them.
      • This also includes risks associated with online (e-safety).
    • staff, leaders and managers understand the risks posed by adults or young people who use the internet to bully, groom or abuse children, young people and vulnerable adults; there are well-developed strategies in place to keep learners safe and to support them in learning how to keep themselves safe.
      • This specifically highlights the need for staff, leaders and managers to have increased awareness and knowledge of online safety and the need to develop children’s resilience.
    • staff, leaders and managers oversee the safe use of electronic and social media by staff and learners and take action immediately if they are concerned about bullying or risky behaviours.
      • This clearly identifies the need for leaders to be aware of devices and social media and benefits as well as risks.
    • appropriate arrangements are made with regards to health and safety to protect staff and learners from harm.
      • This will include safe and appropriate internet access.

Arriving at judgements about safeguarding arrangements

  • 33. Inspectors will also consider the extent to which leaders, managers and governors ensure that arrangements to protect children and learners meet statutory requirements, promote their welfare and prevent radicalisation and extremism (including online). The evidence for this will contribute to the inspectors’ evaluation of the effectiveness of safeguarding. Evidence gathered in relation to attendance, behaviour – for example bullying – and how well children and learners understand how to keep themselves safe may also contribute, to a greater or lesser degree, to this judgement. Staff in settings need to be particularly sensitive to signs that may indicate possible safeguarding concerns (including online). These could include, for example, poor or irregular attendance, persistent lateness, children missing from education, forced marriage or female genital mutilation.
  • 34. Inspectors will make a judgement on the personal development, behaviour and welfare of children and learners by evaluating, where applicable, the extent to which the provision is successfully promoting and supporting children’s and learners’ safety (including online). In order to make this judgement, inspectors will consider, among other things, children’s and learners’ understanding of how to keep themselves safe from relevant risks such as exploitation and extremism, including when using the internet and social media. Inspectors should include online safety in their discussions with pupils and learners (covering topics such as online bullying and safe use of the internet and social media). Inspectors should investigate what the school or further education and skills provider does to educate pupils in online safety and how the provider or school deals with issues when they arise.
    • Inspectors will be speaking to children  about online safety, therefore it is important that schools/settings can be confident that their online safety education is appropriate to the needs of the children and that all staff understand and promote the school/settings e-Safety ethos and culture throughout the school/setting.
    • Schools/settings should be able to demonstrate that their online safety approaches are proactive and seeks to prevent harm by building resilience through an embedded and progressive scheme of work, as well as being reactive, by responding to specific concerns as and when they arise.
    • This means that online safety expertise should be shared within the school/setting  (not just in one-off subjects or assemblies) and that schools/settings need to be able to demonstrate internal capacity to enable children to build resilience and respond to risks.
    • Schools/settings should not rely solely on external partners to developer online safety education to children and families. Schools/settings must be able to demonstrate ownership of any online safety concerns and their own practice and therefore work in partnership with external organisations.
  • 35. In relation to early years, inspectors should consider how staff promote young children’s understanding of how to keep themselves safe (including online) from relevant risks and how this is monitored across the provision.

Online Safety should therefore be embedded throughout all school and settings safeguarding practice and is clearly identified as an issue for leaders and managers to consider and address. Online safety is an essential element schools and education settings safeguarding responsibilities and should be considered to be a key priority for all members of staff.

The online safety agenda has shifted towards enabling children to manage risk, rather than filtering/blocking and therefore requires a comprehensive and embedded curriculum which is adapted specifically to the needs and requirements of children and the technology with which they are exposed too.

 The SWGfL has also published a summary of this guidance here

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