Online Safety Policy

2023-2024

Agreed by Governors May 2022

Review Date: September 2024

Contents

Policy Development / Monitoring / Review 3 Schedule for Development / Monitoring / Review 3 Scope of the Policy 4 Roles and Responsibilities 5 Governors / Board of Directors: 5 Headteacher and Senior Leaders: 5 Online Safety Coordinator: 5 Network Manager / Technical staff: 6 Teaching and Support Staff: 6 Designated Safeguarding Lead: 7 Online Safety Group: 7 Students: 8 Parents / Carers: 8 Policy Statements 10 Education – Students 10 Education – Parents / Carers 11 Education – The Wider Community 11 Education & Training – Staff / Volunteers 11 Technical – Infrastructure / Equipment, Filtering and Monitoring 12 Mobile Technologies (including BYOD) 13 Use of digital and video images 14 Data Protection 16 Communications 17 Social Media - Protecting Professional Identity 19 Unsuitable / Inappropriate activities 21

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Responding to incidents of misuse 22 Illegal Incidents 1 Other Incidents 3 School Actions & Sanctions 4

Policy Development / Monitoring / Review

This Online Safety policy has been developed by a group including:  ● Headteacher

● Senior Leaders

● Network Manager

● ICT Coordinator

● Staff – including Teachers, Support Staff, Technical staff

Consultation with the whole school community has taken place through a range  of formal and informal meetings.

Schedule for Development / Monitoring /  Review

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The school will monitor the impact of the policy using:

● Logs of reported incidents

● Monitoring logs of internet activity (including sites visited) / filtering  ● Internal monitoring data for network activity

● Surveys / questionnaires of

= students

= staff

Scope of the Policy

This policy applies to all members of Co-op Academy Bebington community  (including staff, students / volunteers, parents / carers, visitors, community  users) who have access to and are users of ICT systems, both in and out of  school.

The Education and Inspections Act 2006 empowers Headteachers to such extent  as is reasonable, to regulate the behaviour of students when they are off the  school site and empowers members of staff to impose disciplinary penalties for  inappropriate behaviour. This is pertinent to incidents of cyber-bullying or other  Online Safety incidents covered by this policy, which may take place outside of  the school. The 2011 Education Act increased these powers with regard to the  searching for and of electronic devices and the deletion of data. In the case of  both acts, action can only be taken over issues covered by the published  Behaviour Policy.

Co-op Academy Bebington will deal with such incidents within this policy and  associated behaviour and anti-bullying policies and will inform parents / carers

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of incidents of inappropriate Online Safety behaviour that take place out of  school.

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Roles and Responsibilities

Governors / Board of Directors:

The Academy Governing Council (AGC) is responsible for the approval of the  Online Safety Policy and for reviewing the effectiveness of the policy. A member  of the IEB has taken on the role of Online Safety Director. The role of the Online  Safety Director will include:

● regular meetings with the Online Safety Co-ordinator

● regular monitoring of online safety incident logs

● to receive information concerning the regular monitoring of filtering logs ● reporting to relevant AGC meeting

Headteacher and Senior Leaders:

● The Headteacher has a duty of care for ensuring the safety (including online  safety) of members of the school community, though the day to day  responsibility for online safety will be delegated to the Online Safety Co ordinator.

● The Headteacher and another member of the Senior Leadership Team  should be aware of the procedures to be followed in the event of a serious  online safety allegation being made against a member of staff.

● The Headteacher is responsible for ensuring that the Online Safety  Coordinator and other relevant staff receive suitable training to enable  them to carry out their online safety roles and to train other colleagues, as  relevant.

● The Headteacher will ensure that there is a system to allow for monitoring  and support of those in school who carry out the internal online safety  monitoring role. This is to provide a safety net and also support to those  colleagues who take on important monitoring roles.

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● The Senior Leadership Team will receive regular monitoring reports from  the Online Safety Co-ordinator.

Online Safety Coordinator:

● leads the Online Safety Group

● takes day to day responsibility for online safety issues and has a leading  role in establishing and reviewing the school online safety policies and  documents

● ensures that all staff are aware of the procedures that need to be followed  in the event of an online safety incident taking place.

● provides training and advice for staff

● liaises with the Co-op Central Team

● liaises with school technical staff

● receives reports of online safety incidents and creates a log of incidents  through Smoothwall to inform future online safety developments ● attends relevant committee meeting of Directors

● reports regularly to Senior Leadership Team

Network Manager / Technical staff:

The Network Manager / Co-ordinator for ICT is responsible for ensuring:  ● that the school’s technical infrastructure is secure and is not open to  misuse or malicious attack

● that the school meets required online safety technical requirements and  any Co-op Online Safety Policy / Guidance that may apply.

● that users may only access the networks and devices through a properly  enforced password protection policy, in which passwords are regularly  changed

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● filtering policy is applied and updated on a regular basis and that its  implementation is not the sole responsibility of any single person. That  they keep up to date with online safety technical information in order to  effectively carry out their online safety role and to inform and update  others as relevant

● that the use of the computer systems is regularly monitored in order that  any misuse / attempted misuse can be reported to the Online Safety  Coordinator for investigation and action.

● that monitoring systems are implemented and updated as agreed in school  policies

Teaching and Support Staff:

Are responsible for ensuring that:

● they have an up to date awareness of online safety matters and of the  current school Online Safety Policy and practices

● they have read, understood and signed the Staff Acceptable Use Agreement  (AUP)

● they report any suspected misuse or problem to the Online Safety  Coordinator for investigation and action

● all digital communications with students / parents / carers should be on a  professional level and only carried out using official school systems ● online safety issues are embedded in all aspects of the curriculum and  other activities

● students understand and follow the Online Safety Policy and acceptable  use policies

● students have a good understanding of research skills and the need to  avoid plagiarism and uphold copyright regulations

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● they monitor the use of digital technologies, mobile devices, cameras etc in  lessons and other school activities and implement current policies with  regard to these devices

● in lessons where internet use is pre-planned, students should be guided to  sites checked as suitable for their use and that web filtering is in place to  prevent unsafe internet searches. All breaches are reported through  smoothwall

Designated Safeguarding Lead:

Should be trained in Online Safety issues and be aware of the potential for  serious child protection / safeguarding issues to arise from:

● sharing of personal data

● access to illegal / inappropriate materials

● inappropriate on-line contact with adults / strangers

● potential or actual incidents of grooming

● cyber-bullying

Online Safety Group:

The Online Safety Group has wide representation from the school community,  with responsibility for issues regarding online safety and the monitoring of the  Online Safety Policy including the impact of initiatives. The group will be  responsible for regular reporting to the Academy Governing Council( AGC).  Members of the Online Safety Group will assist the Online Safety Coordinator  with:

● the production / review / monitoring of the school Online Safety Policy /  documents.

● the monitoring of the school filtering policy.

● mapping and reviewing the online safety curricular provision – ensuring  relevance, breadth and progression

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● monitoring network / internet / incident logs

● consulting stakeholders – including parents / carers and the students about  the online safety provision.

Students:

● are responsible for using the school‘s digital technology systems in  accordance with the Student Acceptable Use Agreement

● have a good understanding of research skills and the need to avoid  plagiarism and uphold copyright regulations

● need to understand the importance of reporting abuse, misuse or access  to inappropriate materials and know how to do so

● will be expected to know and understand policies on the use of mobile  devices and digital cameras. They should also know and understand  policies on the taking / use of images and on cyber-bullying.

● should understand the importance of adopting good online safety practice  when using digital technologies out of school and realise that the school’s  Online Safety Policy covers their actions out of school, if related to their  membership of the school

Parents / Carers:

Parents / Carers play a crucial role in ensuring that their children understand the  need to use the internet / mobile devices in an appropriate way. The school will  take every opportunity to help parents understand these issues through parents’  evenings, newsletters and the school website. Parents and carers will be  encouraged to support the school in promoting good online safety practice and  to follow guidelines on the appropriate use of:

● digital and video images taken at school events

● access to parents’ sections of the website and on-line student records

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● their children’s personal devices in the school

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Policy Statements

Education – Students

Whilst regulation and technical solutions are very important, their use must be  balanced by educating students to take a responsible approach. The education  of students in online safety is therefore an essential part of the school’s online  safety provision. Children and young people need the help and support of the  school to recognise and avoid online safety risks and build their resilience. Online safety should be a focus in all areas of the curriculum and staff should  reinforce online safety messages across the curriculum. The online safety  curriculum should be broad, relevant and provide progression, with  opportunities for creative activities and will be provided in the following ways:

● A planned online safety curriculum should be provided as part of  Computing lessons and should be regularly revisited

● Key online safety messages should be reinforced as part of a planned  programme of assemblies and pastoral activities

● Students should be taught in all lessons to be critically aware of the  materials they access on-line and be guided to validate the accuracy of  information.

● Students should be taught to acknowledge the source of information used  and to respect copyright when using material accessed on the internet ● Students should be supported in building resilience to radicalisation by  providing a safe environment for debating controversial issues and helping  them to understand how they can influence and participate in decision making.

● Staff should act as good role models in their use of digital technologies the  internet and mobile devices

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● Where students are allowed to freely search the internet, staff should be  vigilant in monitoring the content of the websites the young people visit.  ● It is accepted that from time to time, for good educational reasons,

students may need to research topics (eg racism, drugs, discrimination)  that would normally result in internet searches being blocked. In such a  situation, staff can request that the Technical Staff can temporarily remove  those sites from the filtered list for the period of study. Any request to do  so, should be auditable, with clear reasons for the need.

Education – Parents / Carers

Some parents and carers may have a limited understanding of online safety  risks and issues, yet they play an essential role in the education of their children  and in the monitoring / regulation of the children’s on-line behaviours. Parents  may underestimate how often children and young people come across  potentially harmful and inappropriate material on the internet and may be  unsure about how to respond.

The school will therefore seek to provide information and awareness to parents  and carers through:

● Curriculum activities

● Letters, newsletters, web site

● Parents / Carers evenings

● High profile events / campaigns e.g. Safer Internet Day

Education – The Wider Community

The school will provide opportunities for members of the community to gain  from the school’s online safety knowledge and experience. This may be offered  through the following:

● The school website will provide online safety information for the wider  community

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● Supporting community groups e.g. youth / sports / voluntary groups to  enhance their Online Safety provision

Education & Training – Staff / Volunteers

It is essential that all staff receive online safety training and understand their  responsibilities, as outlined in this policy. Training will be offered as follows:  A planned programme of formal online safety training will be made available to  staff. This will be regularly updated and reinforced. An audit of the online safety  training needs of all staff will be carried out regularly.

● All new staff should receive online safety training as part of their induction  programme, ensuring that they fully understand the school Online Safety  Policy and Acceptable Use Agreements.

● It is expected that some staff will identify online safety as a training need  within the performance management process.

● The Online Safety Coordinator will receive regular updates through  attendance at external training events and by reviewing guidance  documents released by relevant organisations.

● This Online Safety Policy and its updates will be presented to and discussed  by staff during INSET sessions.

● The Online Safety Coordinator will provide advice / guidance / training to  individuals as required.

Technical – Infrastructure / Equipment, Filtering and Monitoring

The school will be responsible for ensuring that the school infrastructure /  network is as safe and secure as is reasonably possible and that policies and  procedures approved within this policy are implemented. It will also need to  ensure that the relevant people named in the above sections will be effective in  carrying out their online safety responsibilities:

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• School technical systems will be managed in ways that ensure that the  school meets recommended technical requirements outlined in Co-op  policy and guidance.

• There will be regular reviews and audits of the safety and security of school  technical systems

• Servers, wireless systems and cabling must be securely located and  physical access restricted

• All users will have clearly defined access rights to school technical systems  and devices.

• All users will be provided with a username and secure password by  technical support staff who will keep an up to date record of users and their  usernames. Users are responsible for the security of their username and  password.

• The “administrator” passwords for the school ICT system, used by the  Network Manager must also be available to the Headteacher or other  nominated leader and kept in a secure place.

• Network Manager is responsible for ensuring that software licence logs are  accurate and up to date and that regular checks are made to reconcile the  number of licences purchased against the number of software installations.

• Internet access is filtered for all users. Illegal content (including child sexual  abuse images) is filtered by the broadband or filtering provider by actively  employing the Internet Watch Foundation CAIC list. Content lists are  regularly updated and internet use is logged and regularly monitored.  There is a clear process in place to deal with requests for filtering changes.

• Internet filtering should ensure that children are safe from terrorist and  extremist material when accessing the internet.

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• School technical staff regularly monitor and record the activity of users on  the school technical systems and users are made aware of this in the  Acceptable Use Agreement.

• An appropriate system is in place for users to report any actual / potential  technical incident / security breach to the Online Safety Coordinator. • Appropriate security measures are in place to protect the servers, firewalls,  routers, wireless systems, work stations, mobile devices etc from accidental  or malicious attempts which might threaten the security of the school  systems and data. The school infrastructure and individual workstations  are protected by up to date virus software.

• An agreed policy is in place for the provision of temporary access of “guests”  (eg trainee teachers, supply teachers, visitors) onto the school systems by  means of a ‘Guest’ network.

• An agreed policy is in place that allows staff to download executable files  and install programmes on school devices only after agreement has been  obtained from Technical Support.

• An agreed policy is in place regarding the use of removable media (eg  memory sticks / CDs / DVDs) by users on school devices. Personal data  cannot be sent over the internet or taken off the school site unless safely  encrypted or otherwise secured.

Mobile Technologies (including BYOD)

Mobile technology devices may be school owned/provided or personally owned  and might include: smartphone, tablet, notebook / laptop or other technology  that usually has the capability of utilising the school’s wireless network. The  device then has access to the wider internet which may include the school’s  learning platform and other cloud based services such as email and data  storage.

Online Safety Policy 2019

All users should understand that the primary purpose of the use mobile /  personal devices in a school context is educational. The mobile technologies  policy should be consistent with and interrelated to other relevant school  policies including but not limited to the Safeguarding Policy, Behaviour Policy,  Bullying Policy, Acceptable Use Policy, and policies around theft or malicious  damage. Teaching about the safe and appropriate use of mobile technologies  should be an integral part of the school’s Online Safety education programme.

● The school allows:

Use of digital and video images

The development of digital imaging technologies has created significant benefits  to learning, allowing staff and students instant use of images that they have  recorded themselves or downloaded from the internet. However, staff, parents /  carers and students need to be aware of the risks associated with publishing

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digital images on the internet. Such images may provide avenues for  cyberbullying to take place. Digital images may remain available on the internet  forever and may cause harm or embarrassment to individuals in the short or  longer term. It is common for employers to carry out internet searches for  information about potential and existing employees. School will inform and  educate users about these risks and will implement policies to reduce the  likelihood of the potential for harm:

● When using digital images, staff should inform and educate students about  the risks associated with the taking, use, sharing, publication and  distribution of images. In particular they should recognise the risks  attached to publishing their own images on the internet e.g. on social  networking sites.

● Written permission from parents or carers will be obtained before  photographs of students are published on the school website / social media  / local press.

● In accordance with guidance from the Information Commissioner’s Office,  parents / carers are welcome to take videos and digital images of their  children at school events for their own personal use (as such use is not covered by GDPR). To respect everyone’s privacy and in some cases  protection, these images should not be published / made publicly available  on social networking sites, nor should parents / carers comment on any  activities involving other students in the digital / video images.

● Staff and volunteers are allowed to take digital / video images to support  educational aims, but must follow school policies concerning the sharing,  distribution and publication of those images. Those images should only be  taken on school equipment, the personal equipment of staff should not be  used for such purposes.

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● Care should be taken when taking digital / video images that students are  appropriately dressed and are not participating in activities that might bring  the individuals or the school into disrepute.

● Students must not take, use, share, publish or distribute images of others  without their permission.

● Photographs published on the website, or elsewhere that include students  will be selected carefully and will comply with good practice guidance on the use of such images.

● Students’ full names will not be used anywhere on a website or blog,  particularly in association with photographs.

Data Protection

Personal data will be recorded, processed, transferred and made available  according to the GDPR Act 2018 (updated 21) which states that personal data  must be:

• Fairly and lawfully processed

• Processed for limited purposes

• Adequate, relevant and not excessive

• Accurate

• Kept no longer than is necessary

• Processed in accordance with the data subject’s rights

• Secure

• Only transferred to others with adequate protection.

The school must ensure that:

● It will hold the minimum personal data necessary to enable it to perform its  function and it will not hold it for longer than necessary for the purposes it  was collected for.

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● Every effort will be made to ensure that data held is accurate, up to date and  that inaccuracies are corrected without unnecessary delay.

● All personal data will be fairly obtained in accordance with the “Privacy Notice”  and lawfully processed in accordance with the “Conditions for Processing”.  ● It is registered as a Data Controller for the purposes of the General Data  Protection Regulation (GDPR)

● Responsible persons are identified - Senior Information Risk Officer (SIRO)  and Information Asset Owners (IAOs)

● Risk assessments are carried out

● It has clear and understood arrangements for the security, storage and  transfer of personal data

● Data subjects have rights of access and there are clear procedures for this to  be obtained.

● There are clear and understood policies and routines for the deletion and  disposal of data.

● There is a policy for reporting, logging, managing and recovering from  information risk incidents.

● There are clear GDPR clauses in all contracts where personal data may be  passed to third parties.

● There are clear policies about the use of cloud storage / cloud computing  which ensure that such data transfer / storage meets the requirements laid  down by the Information Commissioner’s Office.

Staff must ensure that they:

● At all times take care to ensure the safekeeping of personal data, minimising  the risk of its loss or misuse.

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● Use personal data only on secure password protected computers and other  devices, ensuring that they are properly “logged-off” at the end of any session  in which they are using personal data.

● Transfer data using encryption and secure password protected devices.

When personal data is stored on any portable computer system, memory stick  or any other removable media:

● the data must be encrypted and password protected

● the device must be password protected

● the device must offer approved virus and malware checking software  ● the data must be securely deleted from the device, in line with school policy  once it has been transferred or its use is complete

Communications

A wide range of rapidly developing communications technologies has the  potential to enhance learning. The following table shows how the school  currently considers the benefit of using these technologies for education  outweighs their risks / disadvantages:

Staff & other  

adults Students

Communication  Technologies

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Mobile phones may be brought to the  

school  

Use of mobile phones in lessons

Use of mobile phones in social time  

Taking photos on mobile phones / cameras  

Use of other mobile devices e.g. tablets  

Use of personal email addresses in school ,  

or on school network  

Use of school email for personal emails

Use of messaging apps  

Use of social media  

Use of blogs  

When using communication technologies the school considers the following as  good practice:

● The official school email service may be regarded as safe and secure and is  monitored. Users should be aware that email communications are  monitored. Staff and students should therefore use only the school email  service to communicate with others when in school, or on school systems  (e.g. by remote access).

● Users must immediately report, to the nominated person (Online Safety  Coordinator, Safeguarding Officer or a member of SLT) the receipt of any  communication that makes them feel uncomfortable, is offensive,

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discriminatory, threatening or bullying in nature and must not respond to  any such communication.

● Any digital communication between staff and students or parents / carers  (email, social media, chat, blogs, VLE etc) must be professional in tone and  content. These communications may only take place on official (monitored)  school systems. Social media must not be used for these communications.

● Personal information should not be posted on the school website and only  official email addresses should be used to identify members of staff.

Social Media - Protecting Professional Identity

All schools and local authorities have a duty of care to provide a safe learning  environment for students and staff. Schools and local authorities could be held  responsible, indirectly for acts of their employees in the course of their  employment. Staff members who harass, cyberbully, discriminate on the  grounds of sex, race or disability or who defame a third party may render the  school or local authority liable to the injured party. Reasonable steps to prevent  predictable harm must be in place.

The school provides the following measures to ensure reasonable steps are in  place to minimise risk of harm to students, staff and the school through: ● Ensuring that personal information is not published

● Training is provided including: acceptable use; social media risks; checking  of settings; GDPR; reporting issues.

● Clear reporting guidance, including responsibilities, procedures and  sanctions

● Risk assessment, including legal risk

School staff should ensure that:

● No reference should be made in social media to students, parents / carers  or school staff

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● They do not engage in online discussion on personal matters relating to  members of the school community

● Personal opinions should not be attributed to the school or local authority ● Security settings on personal social media profiles are regularly checked to  minimise risk of loss of personal information

When official school social media accounts are established there should be:  ● A process for approval by senior leaders

● Clear processes for the administration and monitoring of these accounts – involving at least two members of staff

● A code of behaviour for users of the accounts, including

● Systems for reporting and dealing with abuse and misuse

● Understanding of how incidents may be dealt with under school disciplinary  procedures

Personal Use:

● Personal communications are those made via personal social media  accounts. In all cases, where a personal account is used which associates  itself with the school or impacts on the school, it must be made clear that the  member of staff is not communicating on behalf of the school with an  appropriate disclaimer. Such personal communications are within the scope  of this policy

● Personal communications which do not refer to or impact upon the school  are outside the scope of this policy

● Where excessive personal use of social media in school is suspected, and  considered to be interfering with relevant duties, disciplinary action may be  taken

● The school permits reasonable and appropriate access to private social  media sites

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Monitoring of Public Social Media

● As part of active social media engagement, it is considered good practice to  proactively monitor the Internet for public postings about the school ● The school should effectively respond to social media comments made by  others according to a defined policy or process

The school’s use of social media for professional purposes will be checked  regularly by the Social Media and Marketing Officer and Online Safety Group to  ensure compliance with the school policies.

Unsuitable / Inappropriate activities

Some internet activity e.g. accessing child abuse images or distributing racist  material is illegal and would obviously be banned from school and all other  technical systems. Other activities e.g. cyber-bullying would be banned and  could lead to criminal prosecution. There are, however, a range of activities which  may, generally, be legal but would be inappropriate in a school context, either  because of the age of the users or the nature of those activities.  The school believes that the activities referred to in the following section would  be inappropriate in a school context and that users, as defined below, should  not engage in these activities in or outside the school when using school  equipment or systems. The school policy restricts usage as follows:

User Actions

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Responding to incidents of misuse

This guidance is intended for use when staff need to manage incidents that  involve the use of online services. It encourages a safe and secure approach to  the management of the incident. Incidents might involve illegal or inappropriate  activities (see “User Actions” above).

Illegal Incidents

If there is any suspicion that the web site(s) concerned may contain child abuse  images, or if there is any other suspected illegal activity, refer to the right hand  side of the Flowchart (below and appendix) for responding to online safety  incidents and report immediately to the police.

Student Behaviour & Exclusion Policy 2019

Other Incidents

It is hoped that all members of the school community will be responsible users  of digital technologies, who understand and follow school policy. However, there  may be times when infringements of the policy could take place, through  careless or irresponsible or, very rarely, through deliberate misuse.  In the event of suspicion, all steps in this procedure should be followed:

● Have more than one senior member of staff / volunteer involved in this  process. This is vital to protect individuals if accusations are subsequently  reported.

● Conduct the procedure using a designated computer that will not be used by  young people and if necessary can be taken off site by the police should the  need arise. Use the same computer for the duration of the procedure.

● It is important to ensure that the relevant staff should have appropriate  internet access to conduct the procedure, but also that the sites and content  visited are closely monitored and recorded (to provide further protection).

● Record the URL of any site containing the alleged misuse and describe the  nature of the content causing concern. It may also be necessary to record  and store screenshots of the content on the machine being used for  investigation. These may be printed, signed and attached to the form (except  in the case of images of child sexual abuse – see below)

● Once this has been completed and fully investigated the group will need to  judge whether this concern has substance or not. If it does then appropriate  action will be required and could include the following:

o Internal response or discipline procedures

o Involvement by Local Authority

o Police involvement and/or action

Student Behaviour & Exclusion Policy 2019

● If content being reviewed includes images of Child abuse then the  monitoring should be halted and referred to the Police immediately. Other  instances to report to the police would include:

o incidents of ‘grooming’ behaviour

o the sending of obscene materials to a child

o adult material which potentially breaches the Obscene Publications  Act

o criminally racist material

o promotion of terrorism or extremism

o other criminal conduct, activity or materials

● Isolate the computer in question as best you can. Any change to its state may  hinder a later police investigation.

It is important that all of the above steps are taken as they will provide an  evidence trail for the school and possibly the police and demonstrate that visits  to these sites were carried out for safeguarding purposes. The completed form  should be retained by the group for evidence and reference purposes.

School Actions & Sanctions

It is more likely that the school will need to deal with incidents that involve  inappropriate rather than illegal misuse. It is important that any incidents are  dealt with as soon as possible in a proportionate manner, and that members of  the school community are aware that incidents have been dealt with. It is  intended that incidents of misuse will be dealt with through normal behaviour /  disciplinary procedures as follows:

Actions / Sanctions

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Actions / Sanctions

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