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New Safeguarding statutory guidance - Are you compliant?

Over the past 12 months the government has published draft statutory guidance titled ‘Keeping Children Safe in Education’. In a recent keynote we presented, less than 10% of school leaders had read or were aware of the guidance and its impact on their school. In this article we explore the key aspects of the statutory guidance and the steps needed to manage compliance should it be implemented.

To understand what ‘compliant’ looks like, we need to first look at what Ofsted say it takes to be outstanding in the area of safeguarding. The following is excerpts from Ofsted:

Safeguarding is effective. Leaders and managers have created a culture of vigilance where pupils’ welfare is actively promoted. Pupils are listened to and feel safe. Staff are trained to identify when a pupil may be at risk of neglect, abuse or exploitation and then report their concerns.

Pupils have an excellent understanding of how to stay safe online and of the dangers of inappropriate use of mobile technology and social networking sites.

This, however,  is only half of the story; we need to take this and cross reference it with the new statutory guidance on ‘Keeping Children Safe in Education’. Deep within this document there are a number of key paragraphs that need digesting. These are:

  1. Schools and colleges are expected to assess the risk of children being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology. This means being able to demonstrate both a general understanding of the risks affecting children and young people in the area and a specific understanding of how to identify individual children who may be at risk of radicalisation and what to do to support them. Schools and colleges should have clear procedures in place for protecting children at risk of radicalisation. These procedures may be set out in existing safeguarding policies. It is not necessary for schools and colleges to have distinct policies on implementing the Prevent duty.
  1. Schools must ensure that children are safe from terrorist and extremist material when accessing the internet in schools. Schools should ensure that suitable filtering is in place. It is also important that schools teach pupils about online safety more generally.
  1. As schools and colleges increasingly work online it is essential that children are safeguarded from potentially harmful and inappropriate online material. As such governing bodies and proprietors should ensure appropriate filters and appropriate monitoring systems are in place. Children should not be able to access harmful or inappropriate material from the school or colleges ICT system. Governing bodies and proprietors should be confident that systems are in place that will identify children accessing or trying to access harmful and inappropriate content online. Guidance on esecurity is available from the National Education Network- NEN. Guidance on procuring appropriate ICT is available at: Buying ICT advice for schools.
  1. Whilst it is essential that governing bodies and proprietors ensure that appropriate filters and monitoring systems are in place; they should be careful that “over blocking” does not lead to unreasonable restrictions as to what children can be taught with regards to online teaching and safeguarding.

Our interpretation of this draft statutory guidance is that schools need effective monitoring systems in place to profile the online behaviour of children, and do so at an individual level so the risk (in terms of radicalisation and accessing inappropriate materials) of each child is known and can be managed. The challenge of implementing this though is compounded by the requirement to not ‘over block’ access to the internet.

Taking the Ofsted inspection guidance and the requirements of ‘Keeping Children Safe in Education’, schools will need to assess their current filtering / management technologies, safeguarding policies, usable acceptance policies, staff training and management processes to be compliant with the draft requirements.

Where to start?

We’ve broken down compliance into technical, management and training. The following is an overview of what we are doing with schools to ensure compliance:

Technological: Schools need to be able to profile the use of the internet on a per child basis. Not only this, but they need to have an understanding as to the context of the content that is being used and be in a position to intelligently review content that a child visits to evaluate at risk children. There are very few technologies out there that can do this, however, schools who manage their own filtering can buy or upgrade to products from Smoothwall and Fortinet. Those that have filtering provided by 3rd parties (such as Grid’s for Learning), need to either ensure their filtering provider is compliant (and provides access to real time data, per child) or install their own filtering appliance.

Management: In many schools it has been the ICT / Network Manager who has decided what websites to lock down or block. Likewise, it has been their job to provide data on those who may be in breach of school ICT usage policies. With this guidance, the management of what is appropriate falls to the individual responsible for safeguarding. This person needs to review the data provided by the technical systems and be in a position whereby they can judge the risk associated with each child. This will require robust internal processes and access to the data created by the filtering appliance. Overall, the lines between ICT and school management are blurring, requiring schools to develop clear lines of responsibility through tools such as a RACI.

Training: The technology that is being developed to meet this guidance will, shortly (next 12 months) provide each member of teaching staff with reports for each child in their class. Schools need to decide how to best use this data and decide on the type of training required for all their staff.

What to do next?

Inevitably this statutory guidance affects every school in the country. We are working with many schools on interpreting and assessing the impact of the guidance on their technical systems, management processes and staff training.

For any help with this topic or just to have an independent technology chat, book a consultation with a 9ine Education Consultant:

 

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