Digital Safeguarding Policy

Purpose and Vision

The Amber Trust is committed to providing a safe environment for all its beneficiaries and to fulfilling its safeguarding responsibilities towards those who access our services. 

The Amber Trust is committed to practice which actively promotes the welfare and safety of children and young people and protects them from harm. We accept and recognise our responsibility to develop awareness of the issues, which cause children and young people harm. 

This policy sets out the expectations for all The Amber Trust teachers, staff, associated contractors, third party providers and users (hereafter referred to as staff) to ensure the protection of children and young people. 

As staff of The Amber Trust, it is our responsibility to raise concerns and report online incidents appropriately, using this policy and its procedures.

Who is this policy for?

This policy is for The Amber Trust staff and all users of The Amber Trust online services, website and platforms. It is directly related to The Amber Trust’s Safeguarding Children and Young People Policy.

What does this policy cover?

This policy specifically covers all The Amber Trust’s online and digital activities, plus all digital activities undertaken on behalf of The Amber Trust at a national, international, and regional level, on proprietary platforms (i.e. non-The Amber Trust affiliated) and third-party social media and devices.

This includes but is not limited to:

  • email,
  • social media channels, such as Facebook, X, YouTube, Instagram, WhatsApp, TikTok, and LinkedIn,
  • all blogging platforms,
  • volunteer platforms and other digital platforms such as Google Classroom and Chat, and Zoom,
  • all ICT devices (including phones), and
  • internet connectivity that is provided by The Amber Trust.

This policy explains our approach to protecting staff. 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.

Principles

In order to uphold these principles our staff must:

  • Ensure that social media accounts are set up appropriately.
  • Make it clear on personal social media accounts, using disclaimers, that their views, thoughts and opinions are personal and not reflective of The Amber Trust policies, procedure or guidance.
  • Make sure that technical solutions are in place to reduce access to inappropriate content on devices owned or used by The Amber Trust. These could be filtering or monitoring software for example parental controls. An external IT company is contracted for regular audits and updates to these safeguards.
  • Ensure the correct permissions, in writing by Google form or Word document, are in place before taking and using photographs on mobile devices.
  • All data handling under this policy will comply with the UK GDPR and Data Protection Act 2018. Staff must ensure that any digital records, including photos or recordings, are securely stored and deleted within retention guidelines.
  • Delete pictures after the event in accordance with The Amber Trust privacy policy.
  • Make sure that they have parental permissions, in writing by Google form or Word document, before contacting any participant under 18 years of age (or 16 if the participant is a parent), even if they have contacted you first.
  • Make every effort to ensure that young people 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.

We will:

  • Ensure our projects, activities, programmes and campaigns support all our staff and beneficiaries to stay safe online.
  • Use best practice digital safeguarding for technical solutions, processes and procedures.
  • Help our staff to support beneficiaries in being effective online.
  • Take best practice action when a digital safeguarding incident occurs.
  • Support and train appropriate staff 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?

The Designated Safeguarding Lead (DSL) has overall responsibility for digital safeguarding in The Amber Trust and works with the team on technical content and user advice. As a volunteer, or staff member, if you know of an allegation, concern or disclosure incident you must inform the DSL or Designated Safeguarding Person (DSP). The DSL or DSP will assess the incident and, if necessary, escalate it to external authorities.

When an incident happens in a meeting or a participant 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 the DSL or DSP for support. 

The Amber Trust is committed to the protection of our beneficiaries 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’. 

The Amber Trust is committed to the safeguarding and protection of all beneficiaries, staff and users of our digital services and social media channels, and we apply the same safeguarding principles to The Amber Trust’s activities whether they are offline or online.

This means protecting our beneficiaries and staff from online harms such as:

  • Cyberstalking: the repeated use of electronic communications to harass or frighten someone, for example by sending threatening communications.
  • Discrimination and abuse on the grounds of any protected characteristic. It can be an offence to stir up hatred – known as inciting hatred – on the grounds of the following protected characteristics:
  • Age
    • Sex
    • Race
    • Disability
    • 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.
  • Disinformation and misinformation: 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 realise that they are sharing inaccurate information, for example they share information or content that they believe to be true.
  • Impersonation and hacking: 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.
  • Online bullying and harassment (also known as cyber bulling).
    • 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.
  • Sexual exploitation and grooming online: the act of developing a relationship with a child 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 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.
  • Sharing of illegal and inappropriate imagery: 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.
  • The oversharing of personal information: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.

Digital Safeguarding Procedures

The Amber Trust supports our beneficiaries through a wide range of programmes and activities. We use third party social media channels like Instagram, Facebook and digital platforms such as The Amber Trust website to engage with our families and other stakeholders. 

We want to continue to provide a safe space for beneficiaries to explore and communicate online, so it is important that we understand the risks and issues that the online space brings and have the appropriate procedures in place.

These procedures detail what you need to do in order to keep to the policy. 

Mitigations: how does The Amber Trust 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 participants and teachers where appropriate.
  • Removing and blocking offensive posts, comments and imagery.
  • Supporting and advising beneficiaries and staff about how to block, and remove offensive posts, comments and imagery.
  • Supporting beneficiaries and staff to block and report online bullying.
  • Supporting staff to remove users who break these rules.
  • Encouraging the reporting of abuse.
  • Supporting beneficiaries and staff 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.
  • Use accessible formats for digital communications where possible, and ensure privacy settings are compatible with accessibility tools.
  • The Amber Trust will provide regular safeguarding training tailored to staff and volunteers working with beneficiaries.
  • Due diligence in relation to privacy standards of any third-party platforms used (e.g. Teams, Zoom), or suppliers of products/services.
  • Ensuring compliance with GDPR and Online Safety Act.
  • Consideration of any additional controls required for marginalized groups, and/or those with additional needs.

What is acceptable use of ICT, the internet, social media, mobile phones and digital technologies?

As staff you must understand what’s acceptable. And you need to make sure young people know what is acceptable and unacceptable when using digital technology. You must follow these procedures.

Use of The Amber Trust equipment by staff and teachers

Where devices are owned by The Amber Trust, there are necessary mitigations in place to protect staff and teachers. These include:

  • Technical solutions to reduce access to inappropriate content and up to date security software managed by an external IT contractor.
  • Agreement to use the equipment safely, securely and responsibly.

Users of The Amber Trust’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 of The Amber Trust’s equipment to cause harassment, alarm or distress to others.

The Amber Trust staff should always make sure that where access is offered or managed by The Amber Trust to young people, 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 The Amber Trust staff and teachers 

As a staff member you must not use personal mobile phones in activities and sessions to deliver an activity or take photos, or on outings and trips.

When staff use phones provided for work for The Amber Trust, they must follow the rules below and they must get permission from parents/carers before they take photos or share images.

Staff should always:

  • Gain permission before taking pictures.
  • Download pictures onto our secure storage platforms (Sharepoint or Dropbox) within 14 days of being taken and then delete them from the phone. 
  • Follow The Amber Trust’s retention policy in relation to the deletion of photos. 
  • Make sure that phones and other electronic devices that hold The Amber Trust data are password protected.

Staff must never:

  • Take photos of young participants using personal mobile phones.
  • Share imagery or personal information about young participants on social media or the internet without consent of parent or carers.

Use of mobile phones by young people

Young people may bring their mobile devices to sessions, trips and outings.

Young people should always:

  • Use their mobile phone appropriately and responsibly.
  • Seek permission to share photos/imagery and videos.

Young participants should never:

  • Use their device to bully, harass, alarm, distress or harm another young participant, staff 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 staff or teachers directly without their parents/carer’s permission, except in an emergency, such as immediate risk of harm or risk to life.

Use of the internet and social media by staff and teachers

Staff and teachers 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 The Amber Trust policies, procedures or guidance.
  • Check any facts that are shared to avoid misinformation.
  • Check that those responsible for the management and operations of The Amber Trust social media accounts and other online accounts have set them up appropriately.
  • Report and record online incidents appropriately using the system set out in Amber’s Safeguarding policy.
  • Act in accordance with The Amber Trust’s Social Media Policy. 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.
  • If further advice is needed, please refer to Amber’s Safeguarding Policy for contact details of the DSL.

Staff and teachers should never:

  • Post, share, comment on or otherwise engage with online information or content (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 The Amber Trust into disrepute.
  • Share opinions which may be viewed as discrimination, harassment, victimisation or abuse.
  • Share photographs or communicate with young participants via social media privately without parent or carer permission.
  • Contact participants who are under the age of 18 (or 16 if that participant is a parent) directly using social media (via their personal accounts) without their parents or carers permission.
  • In addition, all staff and volunteers must maintain a stance of political neutrality when acting on behalf of The Amber Trust.

Use of the internet and social media by young people

Young participants should never:

  • Send friend requests or follow staff or teachers 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 of the sessions, trips or events.

Use of technology for virtual meetings by staff

Virtual meetings must not be recorded without consent. The virtual meeting organiser must check that recording and chat functionalities are disabled unless explicitly required and authorized by The Amber Trust. Password-protect meetings to prevent unauthorized access.

Staff should always:

  • Get written permission from parent/carer for children 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.
  • Check the environment that you are broadcasting from is free from distractions, respects privacy, and aligns with a professional setting. 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 or remain out of the background.
  • Make sure that an appropriate adult is in the vicinity during the call.
  • Make sure that a minimum of two adults are present throughout the video call. This also applies to break out rooms.
  • Stay online until all young people have safely left the meeting.
  • Check that materials that you share are suitable and age appropriate.

Staff should never:

  • Contact young people under 18 (or 16 if they are a parent) directly.
  • Be in a one-to-one conversation with a young person through video messaging.
  • Contact a young person or parent/carer using online virtual meeting calls outside of the pre-arranged meeting time.
  • If a staff member finds themselves in a one-to-one video meeting with a young person through no fault of their own, they should end the call politely and report the incident to the DSL. 

Use of technology for virtual meetings by young participants

Young people should always comply with the following rules, and these should be made clear in advance of any arranged meeting:

  • Have an appropriate adult in the vicinity if they are involved in a video call.
  • 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.
  • If a staff member feels that a child or young person is not complying with the rules above, they should end the call politely and report the incident to the Safeguarding Lead.

Signposting for children and families

We encourage all families benefitting from our music programmes to talk to their children about safeguarding and ensure they know how to report any concerns that arise. The following links provide useful information for these conversations:

Review frequency: Annual