This policy was agreed by KLS Trustees on 25th November 2020.
This policy is reviewed annually (or earlier if the law changes).
It will be reviewed again in September 2022.
Note: This Digital Safeguarding Policy should be read and followed in conjunction with KLS’ Safeguarding Policy (including Child Protection and Vulnerable Adults)
- About Katherine Low Settlement
Katherine Low Settlement is a charity that has been serving Battersea and the wider Wandsworth community since 1924. We are dedicated to building stronger communities and enable people to challenge and find ways out of poverty and isolation.
We run a range of our own community projects to support older people, refugee communities, women and children, young people and families. In addition to these direct community services, we also use our premises to act as a local hub for other charities and community groups, so that as partners, we can meet the diverse needs of the communities of Wandsworth. Each week we work with 45+ charities and community groups supporting more than 1,100 people. Visit www.klsettlement.org.uk
- Katherine Low Settlement’s Safeguarding Policy
Katherine Low Settlement (KLS) is fully committed to safeguarding the welfare of all children, young people and vulnerable adults using its services (either in person and/or online) and its building. It recognises its responsibility to take all reasonable steps to promote safe practice and to protect these children, young people and vulnerable adults from harm, abuse and exploitation regardless of age, gender, disability, ethnicity or sexual identity. KLS acknowledges its duty to act appropriately when it receives any allegations, reports or suspicions of abuse. Paid staff and volunteers will work together to encourage an ethos which embraces difference and diversity and respects the rights of children, young people and vulnerable adults.
This policy covers all children, young people and vulnerable adults accessing digital services run and managed by the Settlement. Other organisations renting rooms or office space in the building have their own separate safeguarding policies, child protection policies and/or vulnerable adult’s policies.
The policy is endorsed by the Katherine Low Settlement’s Trustees and will be reviewed annually to make sure it remains relevant and appropriate to the needs of KLS and its children, young people and vulnerable adults.
This Digital Safeguarding Policy is freely accessible to all. This means that KLS will share copies of this policy with staff and volunteers as part of their induction and training. All KLS’ policies will appear on its website. An information poster with the names of staff responsible for Safeguarding will be displayed in the building and circulated to organisations using the building. Hard copies of this policy will be available upon request.
Note: A separate KLS Safeguarding Policy (including Child Protection and Vulnerable Adults) should be read and followed in conjunction with this Digital Safeguarding Policy.
- For further information about Safeguarding visit:
https://learning.nspcc.org.uk/ – NSPCC
www.londonscb.gov.uk – Child Safeguarding
http://www.scie.org.uk/publications/adultsafeguardinglondon/index.asp – Adult Safeguarding
www.wscb.org.uk – Wandsworth Safeguarding Board
- What does this policy cover?
This policy specifically covers all Katherine Low Settlement’s online and digital activities.
This includes but is not limited to email; websites; social media channels (such as Facebook, Twitter, YouTube, Instagram, WhatsApp, SnapChat, Tik Tok, LinkedIn etc.); all blogging platforms; staff and volunteer platforms; other digital platforms such as Zoom, Skype, Microsoft Teams, Google Hangouts; all ICT devices (including phones) and internet connectivity that is provided by KLS.
This policy explains our approach to protecting members, volunteers and staff. [Note: ‘members’ is the term that KLS refers to, otherwise known as clients, customers, service users]. We are constrained by the terms of service of third-party social media providers in our approach. We promote safe use, but we also recognise that some issues will only be able to be handled by the service provider and the user themselves.
- KLS’s digital safeguarding principles
In order to uphold these principles our volunteers, members and staff must:
- Ensure that social media accounts are set up appropriately.
- Make it clear on personal social media accounts using disclaimers that their views, thought and opinions are personal and not reflective of KLS policies, procedure or guidance.
- Make sure that technical solutions are in place to reduce access to inappropriate content on devices owned or used by KLS. These could be filtering or monitoring software for example parental controls.
- Ensure the correct permissions are in place before taking and using photographs on mobile devices.
- Make sure that they have parental permissions before contacting any young member under 14 years of age, or vulnerable adults, even if they have contacted you first.
- Make every effort to ensure that members understand why and how they must use social media responsibly and safely using the appropriate privacy settings.
- We recognise that digital safeguarding is an important part of all our work, and we are committed to always delivering best practice.
- Ensure our projects, activities, programmes and campaigns support all of our members, volunteers and staff to stay safe online.
- Use best practice digital safeguarding for technical solutions, processes and procedures.
- Help our staff and volunteers to support members in being effective online.
- Take best practice action when a digital safeguarding incident occurs.
- Support and train appropriate staff and volunteers in digital safeguarding.
- Have appropriate links with key organisations to raise awareness and refer and report incidents.
- Risk-assess all projects, initiatives, programmes, activities, services and campaigns to make sure appropriate digital safeguards are in place.
- Who is responsible for digital safeguarding across KLS?
KLS’ Safeguarding Leads are responsible for digital safeguarding in KLS. They are:
As a member, volunteer, or staff member, if you know of an allegation, concern or disclosure incident you must inform KLS Safeguarding Leads.
When an incident happens in a meeting or activity or a member raises an issue at an online meeting, you must deal with it the same way as other safeguarding incidents. If you aren’t sure about how to handle incidents you should contact KLS Safeguarding Lead (Aaron Barbour, CEO) on [email protected] and 020 7223 2845.
KLS is committed to the protection of our members, volunteers and staff and will only share information with other agencies where there are significant concerns, or a potential crime has been committed.
- What do we mean by digital safeguarding?
Digital safeguarding means: ‘the protection from harm in the online environment through the implementation of effective technical solutions, advice and support and procedures for managing incidents’.
KLS is committed to the safeguarding and protection of all members, volunteers, staff and users of our digital services and social media channels, and we apply the same safeguarding principles to KLS’s activities whether they are offline or online.
This means protecting our members, volunteers and staff from online harms such as:
- Online bullying and harassment
- Sexual exploitation and grooming online
- Discrimination and abuse on the grounds of any protected characteristic
- Sharing of illegal and inappropriate imagery
- Impersonation and hacking
- Disinformation and misinformation
- The oversharing of personal information
Online-safety risks are traditionally categorised as one of the 3 Cs: Content, Contact or Conduct (identified by Professor Tanya Byron’s 2008 report “Safer children in a digital world”). They do not stand in isolation, however, and it is important to understand the interplay between all three.
The main areas of risk for KLS community can be summarised as follows:
- Exposure to inappropriate content, including online pornography, ignoring age ratings in games (exposure to violence associated with often racist language), substance abuse
- Lifestyle websites, for example pro-anorexia/self-harm/suicide sites
- Hate content including incitement
- Content validation: how to check authenticity and accuracy of online content
- Grooming (sexual exploitation, radicalisation etc.)
- Online bullying in all forms
- Social or commercial identity theft, including passwords
- Aggressive behaviours (bullying, trolling, etc)
- Privacy issues, including disclosure of personal information
- Digital footprint and online reputation
- Health and wellbeing (amount of time spent online (Internet or gaming), gambling, body image, etc)
- Sexting (sending and receiving of personally intimate images) also referred to as SGII (self-generated indecent images)
- Copyright (little care or consideration for intellectual property and ownership – such as music and film)
More detail is given below.
- What is online bullying and harassment?
Online bullying can be offensive, intimidating, malicious, insulting behaviour and abuse of power which humiliates or denigrates the other person. It can involve one or more person. This can be known as ‘trolling’ when the user deliberately starts quarrels or upsets people by posting inflammatory or off-topic messages in an online community.
Online harassment can come in the form of unwanted verbal conduct online which has the purpose or effect of violating the dignity of a person and or creating a hostile, degrading, humiliating or offensive environment. It can be related to personal characteristics of an individual, such as age, sex, race, disability, sexual orientation, gender identity, religion or belief or nationality.
Online examples of this abuse include abusive messages, exclusion from groups, malicious or insulting comments and sharing offensive imagery.
- What is sexual exploitation and grooming online?
Sexual exploitation and grooming online is the act of developing a relationship with a child or vulnerable adult with the intention of abusing them. Offenders use emotional and psychological tricks to build relationships. The abuse can take place online or offline.
Non-contact abuse is where a child or vulnerable adult is encouraged to share live or still images of themselves of a sexual nature. They can be forced to commit sex acts or to perform on web cams or built in cameras in phones and other devices.
- What is discriminatory abuse online?
It can be an offence to stir up hatred – known as inciting hatred – on the grounds of the following protected characteristics:
- Religion or belief
- Sexual orientation
- Gender reassignment
- Marriage or civil partnership status
- Pregnancy and maternity
The content of a website can also be illegal when it threatens or harasses a person or a group of people. If this is posted because of hostility based on protected characteristic, it can be considered a hate crime.
Illegal material could be in words, pictures, videos, and even music and can include:
- Messages calling for racial or religious violence
- Web pages with pictures, videos or descriptions that glorify violence against anyone due to a protected characteristic, for example their race, religion, disability, sexual orientation or because they are transgender
- Chat forums where people ask other people to commit hate crimes
- What is the sharing of illegal and inappropriate imagery online?
The sharing of illegal and inappropriate imagery online (sometimes known as sexting) can fall into two categories: illegal and inappropriate.
‘Illegal’ is child sexual abuse imagery and imagery that incites violence, hate or terrorism.
‘Inappropriate’ in this context could mean the sharing of pornography, violent content, racist content and homophobic, biphobic or transphobic content.
It is an offence to share inappropriate imagery of anyone under the age of 18 and could result in a conviction.
- What is cyberstalking online?
Cyberstalking is the repeated use of electronic communications to harass or frighten someone, for example by sending threatening communications.
- What is impersonation and hacking online?
Impersonation and hacking online is where a user pretends to be somebody else, and they may hack into their profile and share information, imagery or posts for example, on behalf of that person.
- What is disinformation and misinformation online?
Misinformation and disinformation are the acts of spreading knowledge that is incorrect.
Disinformation is the deliberate intent to spread information which is known to be incorrect.
Misinformation is where an individual may not be aware of the fact that they are sharing inaccurate information, for example they share information or content that they believe to be true.
- What is the sharing of personal information online?
Personal information includes information that makes an individual personally identifiable. This can include name, date of birth, address, phone number, email address and social media profile name. It may also include identifying details based on an individual’s protected characteristic.
- The law
KLS adheres to all relevant UK laws relating to users of our digital platforms, third party social media and the use of our ICT equipment.
Relevant laws include:
- Protection from Harassment Act 1997
- Malicious Communications Act 1988
- Communications Act 2003
- Sexual Offences (Amendment) Act 1992
- Computer Misuse Act 1990
- The Equality Act 2010
- Criminal Justice Act 2003
- Sexual Offences Act 2003
- Serious Crime Act 2015
- Data Protection Act 2018
This list is not exhaustive. We review any changes in legislation to make sure we are compliant.
- How will breaches in this policy be managed?
Any breach of this policy by staff will be managed under the staff disciplinary procedure. Staff can find this procedure in the KLS Staff Handbook.
Any breach of this policy by volunteers will be managed under KLS Volunteer Policy (found on our website).
Any member/user of KLS and/or the general public can make a complaint following KLS Complaints & Compliments Policy (found on our website).
KLS Digital Safeguarding Procedures
The above was KLS Digital Safeguarding Policy. What follows below are the procedures for putting the policy into practice. This is not a definitive list. KLS will give appropriate training to accompany this policy and procedures.
The online space is an increasingly important area for KLS, and we recognise the opportunities and challenges that this brings.
KLS supports our members in developing their digital skills, through a wide range of programmes and activities. We use third party social media channels like Twitter, Facebook and digital platforms such as the KLS website to engage with our members, their parents/carers and volunteers. And staff and volunteers also use social media and the internet to communicate with one another, and with young members, their parents/carers and vulnerable adults.
We want to continue to provide a safe space for members to explore and communicate online, so it’s important that we understand the risks and issues that the online space brings and have the appropriate procedures in place.
These procedures are for members, staff and volunteers and should be read alongside KLS’ Digital Safeguarding policy (see above). They detail what you need to do in order to keep to the policy and they give information about what to you should do.
- Mitigations – how does KLS try to manage risk?
A range of measures are in place to mitigate and manage online risks:
- Minimising the personal information that is shared on third party social media channels.
- Seeking permission to share information about members and volunteers where appropriate.
- Supporting volunteers in setting up social media channels effectively.
- Removing and blocking offensive posts, comments and imagery.
- Supporting and advising members, volunteers and staff about how to block, and remove offensive posts, comments and imagery.
- Supporting members, volunteers and staff to block and report online bullying.
- Supporting members, volunteers and staff to remove users who break these rules.
- Encouraging the reporting of abuse.
- Supporting members and volunteers if and when an online bullying incident occurs.
- Report allegations to police and support others to report to the police.
- Signposting users to additional support services.
- Referring victims of online abuse to additional support.
See KLS Safeguarding Policy and Data Protection Policy for more information (these can be downloaded from KLS website).
- What is acceptable use of ICT, the internet, social media, mobile phones and digital technologies?
As staff and volunteers you must understand what’s acceptable. And you need to make sure young members and vulnerable adults know what is acceptable and unacceptable when using digital technology.
You must follow these procedures.
- Use of KLS equipment by members, staff and volunteers
Where devices are owned by KLS and/or access to devices is given by KLS, there must be necessary mitigations in place to protect members, staff and volunteers. These include:
- Technical solutions to reduce access to inappropriate content. These could be filtering or monitoring software, for example parental controls or up to date security software.
- Agreement to use the equipment safely, securely and responsibly.
Users of KLS’s equipment should never:
- Share, download, print or distribute any content that is defamatory, obscene, indecent, pornographic, offensive, discriminatory, sexual or violent or any other content that may cause harassment, alarm or distress.
- Use any KLS equipment to cause harassment, alarm or distress to others.
KLS members, staff and volunteers should always make sure that where access is offered or managed by KLS to young members or vulnerable adults, there is age appropriate supervision and quality assurance. Also, make sure that security and safety settings have been installed at the set-up stage. You should refer to the manufacturers best practice guides for full information.
- Use of mobile phones by KLS staff and volunteers
Where appropriate KLS staff are provided a work mobile phone. They should not use their personal devices.
As KLS staff or volunteer you may use mobile phones in any activities and sessions. This includes taking photos and films. However, permission must be obtained from parents/carers before photos and films are taken and images shared.
Staff and volunteers should always:
- Gain permission before taking pictures or films.
- Delete pictures from your device once they have been used for the purpose that they were taken for or 14 days after the event has taken place. You must check personal cloud back ups and make sure that pictures are deleted from here as well.
- Make sure that phones and other electronic devices that hold KLS data are password protected.
Staff and volunteers should never:
- Take photos of young members or vulnerable adults using your mobile phones without the explicit permission of parents or carers.
- Share imagery or personal information about young members or vulnerable adults on social media or the internet without consent of parent or carers.
- Use of mobile phones by members
Young members and vulnerable adults may bring their mobile devices to activities and meetings, but each KLS community service must decide this beforehand.
Members should always:
- Use their mobile phone appropriately and responsibly.
- Seek permission to share photos/imagery and videos.
Members should never:
- Use their device to bully, harass, alarm, distress or harm another young member or a volunteer
- Share images or videos on social media without permission.
- Access, download, view or distribute inappropriate, pornographic, discriminatory or hate material.
- Contact volunteers directly without their parents/carer’s permission, except in an emergency.
- Use of the internet and social media by staff and volunteers
Staff and volunteers should always:
- Make it clear on personal social media accounts – using disclaimers – that their views, thoughts and opinions are personal to them and not reflective of KLS policies, procedures or guidance.
- Check any facts that are shared to avoid misinformation.
- Check that those responsible for the management and operations of KLS social media accounts have set them up appropriately.
- Report and record online incidents appropriately.
- Act in accordance with the KLS’s Code of Conduct.
- Ensure that users are appropriately managed in accordance with the procedures set out here and all community guidelines and terms and conditions set out by third party social media providers.
Staff and volunteers should never:
- Post or share information including imagery that is discriminatory, of a sexual nature, pornographic, obscene, violent, offensive or content that may cause distress, harassment or alarm to others or bring KLS into disrepute.
- Share opinions which may be viewed as discriminatory abuse against anyone on the basis of the protected characteristics defined by the Equality Act 2010. These are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.
- Share photographs or communicate with young members or vulnerable adults via social media privately without parent or carer permission.
- Contact members who are under the age of 14 directly using social media (via their personal accounts) without their parents or carers permission.
- Use of the internet and social media by members
Young members and vulnerable adults should always:
- Use social media responsibly and safely.
- Use the appropriate privacy settings.
Young members and vulnerable adults should never:
- Send friend requests or follow volunteers individually/personally without their parents or carers permission.
- Use social media inappropriately or if they are underage.
- Bully, harass, intimidate, alarm or cause distress to another person using social media.
- Share pornographic, sexually explicit or inappropriate material.
- Post and share photos without the permission of other members or volunteers.
- Use of technology for virtual unit meetings by staff and volunteers
Virtual meetings held by KLS community services with its members must not be recorded. The virtual meeting organiser must check meeting settings to ensure that this facility is turned off.
External work meetings attended by KLS staff and volunteers with partner agencies and other charities can be recorded.
Staff and volunteers should always:
- Get written permission from parent/carer for young members and vulnerable adults to join in.
- Use the parent/carers online account unless the young member meets the age restriction for the platform you are using.
- Be dressed appropriately. Uniform isn’t necessary, but everyone must be fully dressed in clothing that covers top and bottom halves of the body.
- Check the environment that you are broadcasting from is suitable. Try to avoid making calls from bedrooms, but if this is not possible then blur the background or add a virtual background or position the device so that only a small part of the room can be seen.
- Ensure that members of your household are dressed appropriately – fully dressed in clothing that covers top and bottom halves of the body – or remain out of the background.
- Make sure that an appropriate adult is in the room with a young member during the call if they are a under 14.
- Make sure that an appropriate adult is in the vicinity during the call if they are 14 or over.
- Make sure that a minimum of two adult staff and/or volunteers are present throughout the video call – this also applies to break out rooms.
- At least one adult staff/volunteer on the video call must hold a current DBS check as required for their role.
- Stay online until all young members and vulnerable adults have safely left the meeting.
- Check the terms and conditions of social media sites to make sure they are suitable for the members.
- Check that materials that you share are suitable and age appropriate.
Staff and volunteers should never:
- Contact young members under 14 directly.
- Be in a one-one conversation with a young member or vulnerable adult through video messaging.
- Contact a young member, vulnerable adult or parent/carer using online virtual meeting calls outside of the pre-arranged meeting time.
- Use of technology for virtual meetings by members
Members should always:
- Have an appropriate adult with them in the same room if they are under 14 and involved in a video call.
- Have an appropriate adult in the vicinity if they are 14 or over and involved in a video call.
- Be fully dressed. Uniform isn’t necessary but they should be fully dressed in clothing that covers top and bottom halves of the body.
- Try to avoid making calls from their bedrooms, but if this is not possible then blur the background or add a virtual background or position the device so that only a small part of the room can be seen.
- Support organisations
These organisations offer additional support on a range of digital and safeguarding topics.
Contact the following KLS staff for more information, advice and guidance about safeguarding.
KLS Safeguarding Leads: