1 POLICY INTRODUCTION AND AIMS 2 POLICY SCOPE 3 LINKS WITH OTHER POLICIES, LEGISLATION AND GUIDANCE 4 ROLES AND RESPONSIBILITIES 4.1 Senior Leadership Team 4.2 Designated Safeguarding Lead 4.3 MyTutor employees managing the technical environment 4.4 All MyTutor employees 4.5 Tutors 4.6 Learners 4.7 Guardians 5 EDUCATION AND ENGAGEMENT 5.1 Online Safety Training 5.2 Awareness and engagement with guardians 6 REDUCING ONLINE RISKS 7 SAFER USE OF TECHNOLOGY 7.1 MyTutor learning platform 7.2 Filtering and monitoring 7.3 Managing Personal Data Online 8 SOCIAL MEDIA 8.1 Expectations 8.2 Employee and tutor use of social media 9 RESPONDING TO ONLINE SAFETY INCIDENTS 9.1 Concerns about learner’s welfare 9.2 Misuse 10 MONITORING AND REVIEW 11 USEFUL LINKS AND SOURCES OF DATA 11.1 Guidance and resources 11.2 National organisations/legislation |
1. POLICY INTRODUCTION AND AIMS
The internet and associated devices, such as computers, tablets, mobile phones and games consoles, are an important part of everyday life. However, these modern technologies have created a landscape of challenges and dangers that is still constantly changing. In order to ensure that MyTutor provides a safe environment for learning, we adhere to the following principles:
Online safety is an essential part of safeguarding and, as such, we have a duty to ensure that all users are protected from potential harm online.
Online safety education is an important preparation for life. Learners and tutors should be empowered to build resilience and to develop strategies to prevent, manage and respond to risk online.
The purpose of the online safety policy is to:
Safeguard and protect all users accessing the MyTutor platform from online harm and abuse.
Identify approaches to educate and raise awareness of online safety via training, news bulletins and lunch and learn meetings.
Enable all employees (including volunteers) and tutors to work safely and responsibly, to model positive behaviour online and to manage professional standards and practice when using technology.
Identify clear procedures to use when responding to online safety concerns.
The issues classified within online safety are considerable, but can be broadly categorised into four areas of risk:
Content: being exposed to illegal, inappropriate or harmful material; for example pornography, racist or radical and extremist views, and in some respects fake news.
Contact: being subjected to harmful online interaction with other users; for example children can be contacted by bullies or people who groom or seek to abuse them.
Commercial: for example young people can be unaware of hidden costs and advertising in apps, games and on websites.
Conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example making, sending and receiving explicit images, cyberflashing, or online bullying.
2. POLICY SCOPE
This policy applies to all MyTutor employees, tutors, external contractors, volunteers and other individuals who work for, or provide services on behalf of MyTutor, as well as learners and guardians. It applies to the access to MyTutor systems, the internet and the use of technology, using devices provided by the learner’s school or on personal devices.
The policy also applies to online safety behaviour such as cyber-bullying, which may take place outside of the online lesson or MyTutor platform, but involves a person working for, or on behalf of, MyTutor. MyTutor will deal with such behaviour within this policy and associated behaviour and discipline policies and will, where known, inform the school or guardian of any incidents of inappropriate online behaviour that take place within MyTutor lessons or on our platform via messages.
Any incidents of an individual registered on the MyTutor platform using abusive or inappropriate language, or acting inappropriately within a free meeting or within the lesson space will be actioned in accordance with our terms and conditions.
3. LINKS WITH OTHER POLICIES, LEGISLATION AND GUIDANCE
This policy links with a number of other MyTutor policies, including:
MyTutor’s Privacy policy
MyTutor’s Safeguarding policy
Tutor Code of Conduct
Acceptable Use Agreements (AUA’s) for employees, tutors, guardians and learners
The following legislation also informs this policy:
Keeping Children Safe in Education (2024)
The Online Safety Act (2023)
For the avoidance of doubt, this is a mandatory policy and applies to all tutors and MyTutor employees.
4. ROLES AND RESPONSIBILITIES
4.1 The Senior Leadership Team (SLT) will:
Have overall accountability for online safety at MyTutor.
Ensure that online safety is viewed as a safeguarding issue and that practice is in line with national guidance and legislation, as stated in The Online Safety Act, as well as the statutory guidance “Keeping Children Safe in Education” and in accordance with the Government’s filtering and monitoring standards.
Support the Designated Safeguarding Lead (DSL) by ensuring they have sufficient training, time, support and resources to fulfil their responsibilities
Be aware of what to do in the event of a serious online safety incident, and will ensure that there are robust reporting channels for online safety concerns, including internal and national support
Receive regular reports from the DSL regarding online safety
4.2 The Designated Safeguarding Lead (DSL) will:
Ensure that all employees and tutors receive annual online safety training, as well as updates throughout the year in the form of bulletins and lunch and learn sessions.
Ensure that online safety practice is audited and evaluated regularly in order to identify strengths and areas for improvement.
Take lead responsibility for online safety (including understanding the filtering and monitoring processes and systems in place).
Promote an awareness of and commitment to online safety throughout MyTutor.
Act as the named point of contact on all online safety issues, and liaise with employees, tutors or other agencies, as appropriate
Ensure that all employees are aware of the procedures that need to be followed in the event of an online safety incident.
Report regularly to the Head of Legal and SLT on the incident log, internet monitoring, current issues, developments in legislation etc.
Ensure that any safeguarding concerns concerning school learners are reported to the school’s DSL, in accordance with their school’s safeguarding procedures.
4.3 MyTutor employees managing the technical environment will:
Apply appropriate technical and procedural controls to ensure that MyTutor’s IT infrastructure/system is secure and not open to misuse or malicious attack, whilst allowing learning opportunities to be maximised.
Keep up to date with MyTutor’s online safety policy and technical information in order to carry out their online safety role effectively and to inform and update others as relevant.
Provide technical support to the DSL and SLT in the implementation of online safety procedures.
Ensure that the filtering and monitoring process, as laid out in section 7.2, is applied and updated on a regular basis, and oversee the monitoring system.
4.4 All employees will:
Read, adhere to and help promote the online safety policy, Acceptable Use Agreements and other relevant policies and guidance.
Take responsibility for the security of the systems and the data they use, or have access to.
Model safe, responsible and professional behaviours in their own use of technology.
Have an up-to-date awareness of a range of online safety issues and how they may be experienced by children.
Report any concerns about online safety in relation to learners or tutors to the safeguarding team via CPOMS.
4.5 Tutors will
Maintain professional conduct during the entirety of the time they are in the lesson space (including before and after the learner enters/leaves) – this includes dressing appropriately, considering surroundings (background, other household members who may come into view etc.) and the blurring of the background if necessary.
Maintain the same boundaries and insist on the same standard of behaviour as if in a face to face lesson.
Understand that all sessions, including free meetings will be recorded for revision and safeguarding purposes. Distribution of the recording beyond participants who have automatic access is strictly prohibited.
Only use MyTutor platforms when conducting lessons and in communicating with parents or learners; social media should not be used to communicate nor lessons taken onto any other platform.
Report any concerns about online safety in relation to learners to the safeguarding team via CPOMS.
Embed online safety in their tutoring sessions.
Read, adhere to and help promote the online safety policy, Acceptable Use Agreements and other relevant policies and guidance
Take responsibility for the security of the systems and the data they use, or have access to.
Model safe, responsible and professional behaviours in their own use of technology.
Supervise, guide and monitor learners carefully when engaged in activities involving online technology.
4.6 Learners (at a level that is appropriate to their individual age, ability and vulnerabilities) will:
Read and adhere to MyTutor’s Acceptable Use Agreement.
Respect the feelings and rights of others both on and offline.
Take responsibility for keeping themselves and others safe online.
Report to a trusted adult, if there is a concern online.
Not make recordings, take screenshots/screengrabs or photographs, or store or distribute footage of tutors or other learners.
Dress appropriately for online lessons.
Ensure that they have a safe and appropriate place to participate from, and to blur their background if necessary.
Talk to someone that they trust If they have concerns about online safety, or if they feel they are being bullied. There are also external reporting routes you can use:
Childline – for support
CEOP – to make a report about online abuse
UK Safer Internet Centre – to report and remove harmful online content
4.7 Guardians will:
Read and accept the Acceptable Use Agreement.
Support MyTutor in online safety approaches by discussing online safety issues with their child and reinforcing appropriate, safe online behaviours at home.
Identify changes in behaviour that could indicate that their child is at risk of harm online.
Use MyTutor systems, such as learning platforms, and other network resources, safely and appropriately.
Take responsibility for their own awareness in relation to the risks and opportunities posed by new and emerging technologies.
Ensure that their child is monitored in their use of technology for online tuition sessions.
Ensure that age-appropriate filtering or safe search is enabled at home. Information on setting this up can be found at: https://www.saferinternet.org.uk/advice-centre/parents-and-carers/parental-controls-offered-your-home-internet-provider and here: https://www.internetmatters.org/parental-controls/
Contact MyTutor regarding concerns related to their child in respect of safeguarding, child protection or online safety, for investigation by the DSL. Guardians can also report their concern via our external reporting form.
Understand that all sessions, including free meetings will be recorded and stored in line with our privacy policy, for safeguarding purposes. Any incidents of harmful, inappropriate or illegal behaviour will be reported to the police.
5. EDUCATION AND ENGAGEMENT
5.1 Online Safety Training
MyTutor requires all employees and tutors to complete annual online safety training, intended to raise awareness and promote safe and responsible internet use by:
Reinforcing online safety messages whenever technology or the internet is in use.
Ensuring that the needs of learners considered to be more vulnerable online, such as those with SEND or mental health needs, are met appropriately.
Teaching everyone to be critically aware of what they see online and shown how to validate information before accepting its accuracy.
Teaching everyone to respect and adhere to principles of academic integrity. This will include understanding the importance of producing their own independent work, being transparent and honest about any use of source material or generative applications, respecting copyright and using appropriate referencing conventions.
Supporting learners within lessons in building resilience to radicalisation by providing a safe environment for debating controversial issues and helping them to understand how they can influence and participate in decision-making.
Provide and discuss the Online Safety policy and employee and tutor Acceptable Use Agreements as part of induction.
Making employees and tutors aware that systems are monitored and activity can be traced to individual users. Employees and tutors will be reminded to behave professionally and in accordance with MyTutor’s policies when accessing our systems and devices.
Making employees and tutors aware that their online conduct away from MyTutor, including personal use of social media, could have an impact on their professional role and reputation within MyTutor.
Highlighting useful educational resources and tools which tutors could use, according to the age and ability of the learners.
Ensuring all employees are aware of the procedures to follow regarding online safety concerns affecting learners, colleagues, guardians or tutors.
5.2 Awareness and engagement with guardians
Guardians have an essential role to play, both in enabling children to become safe and responsible users of the internet and associated technologies, and to ensure their own behaviour remains in line with our acceptable use policy. MyTutor will build a partnership approach to online safety with guardians by:
Informing guardians about the security features of our online lesson space, who their child will be interacting with and how we will keep their child safe whilst using our platform.
Drawing guardians’ attention to MyTutor’s online safety policy and expectations.
Requiring guardians to read the Acceptable Use Agreement and discuss its implications with their children.
Promoting online safety to guardians via our website and communications.
6. REDUCING ONLINE RISKS
The internet is a constantly changing environment with new apps, devices, websites and material emerging at a rapid pace. MyTutor will pay due regard to this by:
Regularly reviewing the methods used to identify, assess and minimise online risks.
Examining emerging technologies for educational benefit and undertaking appropriate risk assessments before use is permitted.
Ensure that appropriate filtering and monitoring is in place and take all reasonable precautions to ensure that users can only access appropriate material and that any interaction does not involve communication that could be considered harmful, illegal or relating to terrorism.
Ensure, through online safety education and the acceptable use agreements, that learners, guardians, employees and tutors know that MyTutor’s expectations regarding safe and appropriate behaviour online apply at all times using the platform facilities (e.g lesson space, messaging service, uploading of materials etc).
7. SAFER USE OF TECHNOLOGY
7.1 MyTutor learning platform
MyTutor uses a wide range of technology in order to facilitate learning and engagement between tutors, learners and guardians. This includes access to:
Email and messaging
Generative artificial intelligence
Online lesson space
In order to ensure safe online learning and engagement, MyTutor sets out the following guidelines:
Tutors should always thoroughly check websites, tools, videos and apps for suitability before using them in the lesson space or recommending them for use at home.
All devices should be used in accordance with the MyTutor’s acceptable use policy and with appropriate safety and security measures in place.
Tutors and learners should consider copyright law and principles of academic integrity before using internet-derived materials (and where appropriate comply with licence terms and/or acknowledge the source of information).
7.2 Filtering and Monitoring
MyTutor runs as a remote company and, as such, uses a Virtual Private Network (VPN) to ensure all employees can access its systems securely, using Zero Trust Network Access. The VPN also has firewalls in place to inspect traffic, protect from malware and other threats, and allow certain groups within the company to access the appropriate online systems and block those who do not need that access.
MyTutor will monitor behaviour in the lesson space and via messaging on its portal, and the safeguarding team will review any lessons or messages that contain words or phrases that have been flagged as being harmful or illegal in nature, or pertain to terrorist ideology. This will then be actioned in accordance with MyTutor’s safeguarding procedures contained within our safeguarding policy.
7.3 Managing Personal Data Online
Personal data will be collected, processed, stored and transferred in accordance with the General Data Protection Regulations (GDPR). Full details regarding personal data collection, storage and processing can be found in MyTutor’s Privacy policy.
8. SOCIAL MEDIA
8.1 Expectations
The term social media includes (but is not limited to): blogs; wikis; social networking sites; forums; bulletin boards; online gaming; apps; video/photo sharing sites; chatrooms and instant messenger.
All employees, tutors, guardians and learners are expected to engage in social media in a positive, safe and responsible manner, at all times.
8.2 Employee and Tutor Use of Social Media
Safe and professional behaviour is outlined for all members of employees and to tutors upon induction.
9. RESPONDING TO SAFETY INCIDENTS AND CONCERNS
All employees and tutors will be made aware of the reporting procedure for online safety concerns, including: breaches of filtering, youth produced sexual imagery (sexting), self-generated images of sexual abuse as a result of online grooming, cyberbullying, cyberflashing and illegal content.
All employees and tutors must respect confidentiality and the need to follow the official procedures for reporting concerns.
Incidents will be managed depending on their nature and severity, according to relevant MyTutor policies.
After any investigations are completed, the DSL will debrief, identify lessons learnt and implement any changes in policy or practice as required.
If the DSL is unsure how to proceed with an incident or concern, the DSL will seek advice from the Legal Team within MyTutor.
Where there is suspicion that illegal activity has taken place, the DSL will contact the Police using 101, or 999 if there is immediate danger or risk of harm.
If an incident or concern needs to be passed beyond MyTutor (for example if a school pupil is involved or the public may be at risk), the DSL will speak with the Police and/or the Local Authority first, to ensure that potential investigations are not compromised.
9.1 Concerns about learners’ welfare
The DSL will be informed immediately of any online safety incident that could be considered a safeguarding or child protection concern.
The DSL will ensure that online safeguarding concerns are escalated and reported to relevant agencies.
MyTutor will inform the learner’s guardian, or their school where applicable, of any incidents or concerns involving their child/learner, as and when required.
9.2 Misuse
Tutors, learners, schools and guardians are informed of MyTutor’s complaints procedure.
Complaints about I.T misuse by tutors, learners or guardians will be dealt with under the relevant policies and procedures, and according to the nature of the complaint.
Any complaint about an employee misusing technology will be referred to the DSL who will liaise with the employee's line manager.
10. MONITORING AND REVIEW
The policy framework will be reviewed by the DSL at least annually, and in response to any new national guidance or legislation, significant developments in the use of technology, emerging threats or incidents that have taken place.
11. USEFUL LINKS AND SOURCES OF ADVICE
11.1 Guidance and resources
Keeping Children Safe in Education (2024)
Government guidance on filtering and monitoring standards
Teaching Online Safety in School (DfE)
Education for a Connected World (UKCIS)
Sharing nudes and semi-nudes: advice for education settings working with children and young people (UKCIS)
Harmful online challenges and online hoaxes (DfE)
Cyberbullying: understand, prevent and respond (Childnet)
Cyberbullying: advice for headteachers and school employees (DfE)
Self-generated child sexual abuse (IWF)
Generative artificial intelligence in education (DfE)
11.2 National Organisations/Legislation
The Online Safety Act 2023
Action Fraud: www.actionfraud.police.uk
CEOP - www.thinkuknow.co.uk and www.ceop.police.uk
Childnet: www.childnet.com
Get Safe Online: www.getsafeonline.org
Internet Matters: www.internetmatters.org
Internet Watch Foundation (IWF): www.iwf.org.uk
Lucy Faithfull Foundation: www.lucyfaithfull.org
ChildLine: www.childline.org.uk
Net Aware: www.net-aware.org.uk
The Marie Collins Foundation: www.mariecollinsfoundation.org.uk
UK Safer Internet Centre: www.saferinternet.org.uk
Professional Online Safety Helpline: www.saferinternet.org.uk/about/helpline. Telephone helpline: 0844 381 4772