As you may be aware, the updated Keeping Children Safe in Education guidance came into effect yesterday, September 5th 2016. You can read more about the updates in our blogs from June and July below:
The updated guidance places schools in a position where they need to demonstrate effective policies, processes and procedures to manage technology in order to mitigate safeguarding risks. In a high number of schools we have spoken with, this is achieved through the implementation of software products and services. Many of these technology-based answers are sold on the basis that they will ensure compliance with the statutory guidance, and in effect, enable your school to be compliant. Unfortunately, this is somewhat misguided.
Take this example of a commonly used, e-safety software platform that shall remain nameless. The software resides on the school computers, checking words, phrases and website visits to identify links to safeguarding risks. All this data is then sent to a central system owned by the software company and reviewed by their program and personnel. The school is then notified of any perceived safeguarding issues. In this model, schools are essentially outsourcing the assessment of safeguarding to a software company, whose staff and systems are geared towards a more generic service, with limited or no understanding of how and by whom potential safeguarding issues should be assessed within the school. Given this, schools choosing these options are placing themselves at risk of not being compliant, given their own staff do not determine how to interpret and evaluate the monitoring on their networks.
The Hidden Gaps in Compliance
Unfortunately, the use of software to gather and analyse data does not satisfy every statutory requirement to mitigate technology-related safeguarding risks. In practice, the purpose of the software is often defeated before it’s begun by the gaps in knowledge related to the design of the associated policies and processes. It is often the case that, even with the most diligent approach, senior leaders will be too close to the issues to spot the gaps in their safeguarding strategy. Recently, there a number of cases where these gaps are hidden until they are revealed by a school inspection.
In order to ensure full compliance for schools, we have developed a significant safeguarding component to our standard Health Check service. This is conducted by consultants who are former police detectives and experts in the field of child protection and safeguarding in schools. The service is designed to provide a comprehensive, root and branch review of the school’s safeguarding provision and deliver a clear action plan to ensure the school achieves full compliance. Throughout this review, we meet with the Headteacher, the school’s Designated Safeguarding Lead (DSL) and the ICT or Network Manager, to assess the school’s approach to limiting a child's exposure to inappropriate content, contact and conduct. This goes beyond a review of the school’s filtering and monitoring systems, to include published policies governing the management of technology, HR policies and the effectiveness of the staff code of conduct.
The safeguarding component is completed at the same time as the rest of our Health Check and includes:
- Logging onto different devices through the user profiles you have and testing the effectiveness of your filtering, using specific safeguarding terms
- Identifying any concerns at a software or solution level, documenting these and issuing them to your filtering provider
- Reviewing effectiveness of monitoring software, or assessing the need should there not be any in place
- Review the management processes and information flow associated with effective online safety. Including filtering policies, risk profiling of users, notification of concern and training
- Creating a proactive network rather than reactive, with regard to network safeguarding concerns
- Risk assessment of current access to social media
- Effectiveness of your HR policies, code of conduct, digital safety policies, in order to discuss and identify weaknesses and/or areas for improvement
- A training session with all leaders, ensuring a consistent and up to date message is provided
The structure of the ICT and Safeguarding Health Check allows us to take a step back from the everyday pressure of a school community, absorb information from key members of your team, review technology, assess risk and help marry key safeguarding components together, therefore creating a safer online environment, network and approach within your school.
Expert Seal of Approval
Specifically, our Health Check follows the statutory guidance that takes effect from September 5th 2016, by evaluating the ability of the school to reasonably limit children’s exposure to the following risks:
Content: being exposed to illegal, inappropriate or harmful material
Contact: being subjected to harmful online interaction with other users
Conduct: personal online behaviour that increases the likelihood of, or causes harm
The assessment that we undertake is not something that schools traditionally have the expertise or welfare support structure to complete. Our safeguarding consultants are all ex-police detectives from the child protection team. They are trained professionals with the knowledge and experience to effectively assess your ICT systems, policies, processes and management structure for areas of improvement. They have worked as part of online investigation teams, covering a broad range of safeguarding concerns. They understand the types of images, videos and other content that users could access and have the welfare support structure should this cause any distress.
The outcome of the safeguarding component is identified within our Health Check report and the risk-weighted action plan. This provides you with measurable, data driven issues and actions from which to implement an effective approach to online safety. For reasons of confidentiality, the safeguarding report is provided separately from the main report and only distributed to the Designated Safeguarding Lead and Headteacher.