New Meaning Training (NMT) recognise the benefits and opportunities which technology and social media offer to teaching and learning. We provide internet access to all learners and staff and encourage the use of technologies in order to enhance skills, promote achievement and enable lifelong learning. However, the accessibility and global nature of the internet and social media mean that we are also aware of potential risks and challenges associated with such use.
Our approach is to implement appropriate safeguards within NMT while supporting staff and learners to identify and manage risks independently and with confidence. We believe this can be achieved through a combination of security measures, training, guidance and implementation of our policies.
As part of our duty to safeguard learners, we will do all that we can to make our learners and staff stay safe online and to satisfy our wider duty of care.
2. Scope
The policy applies to all learners and staff and all members of the NMT community who have access to NMT IT systems and use social media, both on the premises and remotely. Any user of NMT IT systems must adhere to and accept the Acceptable Use Agreement.
The Online Safety and Social Media Policy applies to all use of the internet and forms of electronic communication such as email, mobile phones, instant messaging, webinar and video conferencing.
3. Responsibilities
The Learning Services Support team is responsible for maintaining this policy.
The following are responsible for implementing it:
The Safeguarding Manager & Designated Safeguarding Leads (DSLs) are responsible for keeping up to date with new technologies and social media apps and their use, as well as attending relevant training. They will oversee records of incidents, report any developments and liaise with the local authority and external agencies to promote online safety and safe use of social media within NMT.
The Safeguarding Manager & DSLs will provide support for learners dealing with issues related to online safety and social media.
All NMT tutors embed online safety and safe use of social media as part of their programmes.
All NMT staff stay alert to and respond appropriately to any potential or actual online safety or social media issue.
4. Security
NMT will do all that it can to make sure the NMT network is safe and secure. Every effort will be made to keep security software up to date. Appropriate security measures will include the use of enhanced filtering and protection of firewalls, servers, routers and workstations to prevent accidental or malicious access of NMT systems and information. Digital communications, including email and internet postings, over the NMT network, will be monitored in line with the Acceptable Use Policy.
NMT complies with guidelines set out by the Counter Terrorism Internet Referral Unit (CTIRU) and has a statutory duty to ensure their systems cannot be used to access any of the websites on the CTIRU list.
All NMT staff must not leave their laptops unattended when learners are present, or if they are not being used. Laptops should be stored in a safe and secure location at the centre in these scenarios.
5. Use of Photography and Videos
NMT often use photographs and film to capture achievements and help promote successes within NMT. Via our website and social media platforms we like to be able to share these events with parents. We are however mindful of the safety of our learners.
As confirmed in the Data Protection Act, NMT ensures written consent is sought from the parent or carer of any learner under the age of 18 before any photographs are taken or from the learner themselves if they are over 18. If consent is given, we will make a clear agreement with the parent or carer as to how the image will be used (for example, in a brochure or website) and how widely (as part of a NMT newsletter for all parents, etc.). Our agreement with parents and learners includes how images will be stored, how long they will be stored for and how they will be disposed of.
Due consideration will be given to the appropriateness of clothing and posture, and details such as a learner’s name or age will not be shared unless integral to the use of the image (such as the acceptance of an award) in particular when additional identifiers are being shared.
We acknowledge the right of parents and learners to withhold or withdraw consent at any point in time of the duration the learner is at NMT.
6. Online Safety
Online safety is defined for the purposes of this document as the process of limiting the risks to children, young people and vulnerable adults when using Internet, Digital and Mobile Technologies (IDMTs). This is done through a combined approach using policies, procedures and education, including training.
Online safety risks can be summarised under the following four headings:
Content
Exposure to age-inappropriate material.
Exposure to inaccurate or misleading information.
Exposure to socially unacceptable material, such as that inciting violence, hate or intolerance, sites promoting radicalisation or pornography.
Exposure to illegal material, such as images of child abuse.
Illegal downloading of copyrighted materials e.g. music and films.
Contact
Grooming using communication technologies, potentially leading to sexual assault, child sexual exploitation and radicalisation.
The use of assumed identities on gaming platforms.
Bullying via websites, mobile phones or other forms of communication device.
Spyware, e.g. use of Remote Access Trojans/Tools to access private information or spy on their victim.
Conduct
Online behaviour that increases the likelihood of, or causes, harm.
Making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying.
Commerce
Exposure of minors to inappropriate commercial advertising.
Exposure to online gambling services.
Commercial and financial scam.
6.1 Cybercrime
Cybercrime is criminal activity committed using computers and/or the internet. It is broadly categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer).
Cyber-dependent crimes include:
Unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s computer network to look for test paper answers or changing grades awarded.
‘Denial of Service’ (Dos or DDoS) attacks or ‘booting’. These are attempts to make a computer, network or website unavailable by overwhelming it with internet traffic from multiple sources.
Making, supplying or obtaining malware (malicious software) such as viruses, spyware, ransomware, botnets and Remote Access Trojans with the intent to commit further offence, including those above.
Young people with particular skills and interest in computing and technology may inadvertently or deliberately stray into cyber-dependent crime.
If there are concerns about a learner in this area NMT staff must:
Report the concern on CPOMS and talk to the Safeguarding Manager or a DSL.
The Safeguarding Manager or DSL should consider referring into the Cyber Choices programme. This is a nationwide police programme supported by the Home Office and led by the National Crime Agency, working with regional and local policing. It aims to intervene where young people are at risk of committing, or being drawn into, low-level cyber-dependent offences and divert them to a more positive use of their skills and interests.
NMT Staff are aware of the Prevent Duty to protect young people from radicalisation and extremism. Online activity could be a possible way that learners are gaining information about radicalisation or extremism and may be sharing this with other learners.
NMT centres have in place appropriate web filtering systems so that learners cannot view potentially extreme material. NMT Staff also understand the need to be vigilant about what content learners are viewing.
If an NMT staff member has a concern about a learner viewing radical or extreme content they must:
Report the concern on CPOMS and speak to the Safeguarding Manager or a DSL.
The Safeguarding Manager or DSL will assess the concern and decide if a referral needs to be made to the First Response Team and passed by them to the Channel coordinator.
6.3 Online Abuse
Online abuse is any type of abuse that happens on the internet, facilitated through technology like computers, tablets, mobile phones and other internet-enabled devices.
It can happen anywhere online that allows digital communication, such as:
Social networks
Text messages and messaging apps
Email and private messaging
Online chats
Comments on live streaming sites
Voice chat in games
Children and young people can be revictimised (experience further abuse) when abusive content is recorded, uploaded or shared by others online. This can happen if the original abuse happened online or offline.
Children and young people may experience several types of abuse online:
Bullying/cyberbullying
Emotional abuse (this includes emotional blackmail, for example pressuring children and young people to comply with sexual requests via technology)
Sexting (pressure or coercion to create sexual images) or sharing of nudes/semi-nudes
Sexual abuse
Sexual exploitation
If an NMT staff member has a concern that a learner is experiencing or instigating online abuse:
Report the concern on CPOMS and speak to the Safeguarding Manager or a DSL.
The Safeguarding manager or DSL will assess the concern and decide if a referral needs to be made to the First Response Team or if there is an immediate risk of harm they should call the police.
6.4 Grooming
Grooming is “a process by which a person prepares a child, significant adults and the environment for the abuse of the child” (Craven, 2006). Grooming can happen anywhere, including online.
Perpetrators may use online platforms to build a trusting relationship with the child in order to abuse them. This abuse may happen online or the perpetrator may arrange to meet the child in person with the intention of abusing them.
Children and young people can be groomed by a stranger or by someone they know – such as a family member, friend or professional. The age gap between a child and their groomer can be relatively small.
Grooming techniques can be used to prepare children for sexual abuse and exploitation, radicalisation and criminal exploitation.
If an NMT staff member has a concern that a learner is being a victim of grooming:
Report the concern on CPOMS and speak to the Safeguarding Manager or a DSL.
The Safeguarding Manager or DSL will assess the concern and decide if a referral needs to be made to the First Response Team or if there is an immediate risk of harm they should call the police.
6.5 Impact of Online Abuse
Whether abuse happens online or offline it can have a long-lasting impact on a child’s overall wellbeing. Online abuse can lead to:
Anxiety
Self-harm
Eating disorders
Suicidal thoughts
Trouble sleeping, nightmares
Behavioural problems
Social withdrawal
Self-blame
Flashbacks or intrusive thoughts
Cyberbullying has similar effects to offline bullying. It can lead to:
Falling behind in education
Depression
Anxiety
Other mental health difficulties
Cyberbullying can make young people feel more frightened and helpless than bullying that happens offline. Contact from cyberbullies can happen at any time, anywhere and this can make young people feel like they can’t escape.
Experiencing abuse online can also cause additional effects:
Young people may be afraid of sexual images being shared online or being viewed in the future, particularly if the perpetrator has made threats about sharing sexual images in order to blackmail the young person into complying with further abuse.
Being filmed can lead some young people to feel uncomfortable around cameras.
Young people who have been in constant contact with the person who abused them via digital technology can become very fatigued – especially if they were in contact during the night. They may also feel powerless and frightened.
Some young people who were abused online feel that this made them more vulnerable to further abuse by sexualising them, leading them to drink heavily or take risks or reducing their sense of self-worth and confidence.
A child or young person may be reluctant to speak out about the abuse they’ve experienced online.
They may:
Not understand that they are being abused.
Feel dirty and ashamed.
Be too embarrassed to share the sexual details of what’s happening to them.
Be afraid because of threats of violence from the abuser.
Have been told by the abuser that they won’t be taken seriously.
Have established an emotional attachment with the abuser and don’t want to get them into trouble.
They may blame themselves for the abuse and not expect to get any support. This might especially be the case if they have experienced unsupportive approaches from school, peers and family.
6.6 Recognising Online Abuse
It is important for NMT Staff to be able to recognise the possible signs of online abuse, especially as learners may be reluctant to speak out about something they are going through.
A child or young person going through online abuse may:
Spend much more or much less time than usual online, texting, gaming or using social media.
Be withdrawn, upset or outraged after using the internet or texting.
Be secretive about who they’re talking to and what they’re doing online or on their mobile phone.
Have lots of new phone numbers, texts or e-mail addresses on their mobile phone, laptop or tablet.
Loneliness, social isolation and family problems may make young people more vulnerable to being groomed online.
Children and young people with special educational needs (SEN) or disabilities are particularly vulnerable to online abuse.
A child or young person with SEN or a disability may:
Have low self-confidence, seeing themself as an ‘outsider’.
Lack strong peer networks and be less likely to tell a friend when they experience upsetting things online.
Have more unsupervised time online, with fewer structures and boundaries.
7. Social Media for Learners
As part of our duty of care to our learners, NMT sets out guidelines, below, for learners when using social media. Staff are encouraged to discuss these guidelines with learners and monitor that they are using social media safely when attending an NMT premises.
Learners should follow the guidelines below at all times:
Do not enter into a “friends” relationship online with someone you do not know.
Do not use social media to harass, threaten, insult, defame or bully another person or entity; to violate any NMT policy; or to engage in any unlawful act, including but not limited to gambling, identity theft or other types of fraud.
Do not access or participate in social media which insights hatred or promotes radicalisation.
Set up privacy settings carefully, ensure you are not sharing any information that you do not want to and check these on a regular basis.
Participating in social media use as part of an NMT or course activity is optional.
Discussions on NMT branded social media should be appropriate and NMT or Course related.
When posting on sites linked to NMT or when mentioning or referring to NMT on social media do not:
Use foul or abusive language.
Harass, threaten, insult, defame, blackmail or bully another person.
Refer to any other member of the NMT community, whether learner or staff, in a derogatory or insulting manner.
Post or comment in any way that reflects poorly on NMT or is deemed to interfere with the conduct of NMT Business.
Posting of messages that are deemed inappropriate will be dealt with under the learner disciplinary procedure.
Copies of inappropriate posts may be reported to parents/ guardians and the appropriate authorities. Before you post a message, think carefully about its content and ask yourself how you would feel if you received that message or know that it may be disclosed in court.
Any form of abuse or cyber-bullying will be dealt with under the learner disciplinary procedure.
Learners should report any abusive behaviour immediately to their tutor who will take action following the NMT Safeguarding Children and Young Adults Policy.
8. Social Media for Staff
All NMT staff must also follow guidelines when using social media.
These guidelines apply to: Posting to any NMT social media site; communicating with members of the NMT community including staff or learners; discussing NMT on any site; both when at an NMT premises and using the NMT network or through a personal account or using a personal phone, computer or other device from any other location.
8.1 Staff and Social Media relating to Young People
Staff should follow the guidelines below at all times in reference to young people:
Never have a “friend” relationship with a learner online, where personal details are shared.
Never have a learner’s mobile phone number on a personal phone, or give out a personal phone number to a learner. Always contact young people on a registered company phone.
When communicating with learners who are under 18 via email, where possible, NMT learner email addresses should be used.
Do not post a person’s photograph or video image without first obtaining permission and signed release forms from anyone depicted in the photograph or video (any photographs of children and young people under the age of 16 should have parental permission).
Protect confidential and sensitive information at all times (e.g. referring to sickness absence of others etc.).
Do not get involved in inappropriate conduct such as sexual (or other) harassment, bullying, discrimination, defamation, infringement of copyright and trademark rights, data protection and unauthorised disclosure of learner records and other confidential and private information.
Staff should not spend an excessive amount of time while at work using social media websites in a personal capacity. They should ensure that use of social media does not interfere with their other duties as this is likely to have a detrimental effect on productivity.
8.2 The NMT Brand
Staff should follow the guidelines below at all times in reference to the NMT brand:
Be professional; as an NMT employee you are an ambassador for the organisation. Protect the NMT brand and values at all times, do not make derogatory comments about NMT products, services, management, employees or systems.
Staff should not comment on anything related to legal matters, litigation, or any parties NMT may be in dispute with or anything that may be considered a crisis situation.
Do not access or participate in social media which incites hatred or promotes radicalisation.
Discussions on social media sites linked to NMT should be appropriate and be NMT or Course related.
If NMT staff see a post that mentions NMT in a negative light, regardless of who posted it, they should report it to the Marketing Manager as soon as possible.
Staff must not engage negatively with competitors in the name of NMT. Instead, staff should highlight any relevant conversations to the Marketing Manager to respond to.
When posting on sites linked to NMT or when mentioning or referring to Buckinghamshire College Group on social media do not:
Use foul or abusive language.
Harass, threaten, insult, defame or bully another person.
Refer to any other member of the NMT community, whether learner or staff, in a derogatory or insulting manner.
Post or comment in any way that reflects poorly on NMT or is deemed to interfere with the conduct of NMT Business.
Any breach in this Policy could result in an investigation and disciplinary procedures under the staff disciplinary policy. Serious breaches of this policy, for example incidents of bullying of colleagues or social media activity causing reputational damage to NMT, may constitute gross misconduct and lead to dismissal.
9. Learner use of technology
With the current unlimited nature of internet access, it is impossible for NMT to eliminate all risks for staff and learners. It is our view therefore, that NMT should support staff and learners to stay safe online through regular training and education. This will provide individuals with skills to be able to identify risks independently and manage them effectively.
Learner laptops have web filtering systems installed so that learners are unable to view potentially harmful content. Most learners also have a mobile phone, which are not allowed to be used during class time and usage is monitored during breaks if staff are concerned about what a learner is using their mobile phone for when at an NMT centre.
Online Safety Guidelines
Keep your personal information private – avoid sharing personal information such as your phone number, home address or photographs with people you don’t know in person and trust.
Use a strong and unique password for all of your online accounts – a combination of letters, numbers and symbols (and if you’ve ever shared it in the past, CHANGE IT).
Use private messages for people you know in person and trust; be careful of private messaging people you don’t know.
Know how to block someone if they make you feel uncomfortable or upset.
Think very carefully about meeting someone face to face who you only know online –NEVER do this alone, always talk to your parents or carers before you go ahead with this and take a trusted adult friend along with you.
Learners or staff should report any abusive behaviour immediately to the Safeguarding Manager or a DSL.
