We are thrilled that the Information Commissioner’s Office (ICO) has published its final Age Appropriate Design Code. What does this mean for you and the safety of children online? This ground-breaking piece of regulation is the result of lengthy consultation between the ICO and key stakeholders including our DigiSafe team at LGfL, and heralds a momentous step towards safeguarding young people’s experience in the digital world.
Aimed at online services that are likely to be accessed by children – e.g. social media platforms, content streaming services, online games, apps, devices, search engines and other websites – it places the responsibility on industry to prevent children’s data being exploited in ways that undermine their safety and wellbeing. The term ‘likely’ in bold above is very significant because this means the code isn’t just aimed at providers which would admit that their services are ‘designed for’ or ‘aimed at’ children, so the scope is much wider!
What does the code say?
The Age Appropriate Design Code outlines a set of15 robust standards that these online service providers should meet. You can read the standards here, but in summary:
the child’s best interests should be of primary consideration when planning or designing online services
settings must be “high privacy” by default
geolocation settings that allow a child’s location to be shared should be switched off by default
‘nudge’ behaviour encouraging children to reduce or switch off their privacy settings should not be deployed
services should provide an obvious sign to the child when they are being monitored by parental controls
options which use profiling should be switched ‘off’ by default
personal data collection from children should be kept to a minimum and only where there is a compelling reason
there is detailed guidance on the approach to be taken for users of different ages.
Regulation and enforcement:
It is encouraging that the Code defines children as under the age of 18 – this is higher than existing UK data protection law where there is only a 13-year-age limit for children to legally give consent to being tracked online. Additionally, the regulator has powers to take action for any breach of the Code– Baroness Kidron, who introduced the Code into UK legislation said:
“An online service must say what they do, do what they say or be held accountable – in this case they face fines of up to 4 percent of their turnover, which could mean billions for the largest tech companies. If you say you don’t host violent, harmful or suicide promoting material, then you must not, or face enforcement action.”
Share these developments with your staff and parents, but remind them that whilst the Code provides greater confidence that their children can safely learn, explore and play online, it can never replace parental supervision, communication, education and guidance.
For many parents and teachers, keeping up with young people’s use of technology and the latest trends often presents a challenge. With the growing popularity of livestreaming, I often get asked by teachers how they can keep children safe. We therefore dedicated last week’s webinar to this topic, and just in case you missed it, you can watch it below and read on for some useful advice:
What exactly is
Not to be confused with video chats such as Skype where you can chat via video to a person, livestreaming enables anyone to broadcast a video in live time to an audience. A key difference is that whilst you can select who you chat with during a video chat, livestreaming doesn’t offer that level of control because you are streaming to a public audience – so it’s literally like going out into the park and standing on a box, where anyone who happens to be out there can watch and interact with you. All that’s required is an internet enabled device such as a mobile phone or tablet, and an app, social media site or website to broadcast it.
Why is it so
popular with children?
Livestreaming offers young people a great way to stay connected and be part of their peer group as well as gaining exposure to a wider community, where they can interact with their viewers. Whether it’s to showcase a talent, express their identity or share significant events, they are at that moment the star of their show. As for for the audience, it provides an avenue to follow, participate and keep track of other people’s lives, be it friends, family or celebrities. Whilst several livestreaming apps have specifically been developed, a number of social media apps like Facebook live and Instagram’s live video feature have integrated this feature into their platforms almost as an afterthought.
So what are the
As with any innovation around technology, it is
important to be aware of the risks to ensure children can maximise these
opportunities in a safe and meaningful way. Our DigiSafe pupil online safety
survey last year in which 40,000 pupils took part, provided a worrying insight
into young people’s experiences livestreaming, made even more concerning given
the increase in the use of these services:
Almost a quarter have livestreamed with someone they
haven’t met in person
More than 1 in 20 pupils had been asked to
change or get undressed on screen – a particular concern is that the youngest (7
– 8-year olds) were just as likely to be asked to get undressed as students in
the first 4 years of secondary school. Whereas predators may trick older
children into undressing online, as opposed to coerce or request, they may also
hide behind a challenge for younger children, such as “Let’s see how quickly
you can change into your swimming costume.”
1 in 6 said something else had happened that
had made them feel uncomfortable – with levels of discomfort much higher for
those in primary school
Since carrying out the survey, research carried
out by the Internet
Watch Foundation revealed that 98% of publicly available livestreamed child
sexual abuse images involved children aged 13 and under, with 28% of them below
the age of 10. As well as inappropriate contact, young people
could also be exposed to age inappropriate sexual or violent content, abusive
and offensive comments and bullying from their audience. Children may freely
give out their social media contact details in order to attract more followers,
often broadcasting alone from their bedrooms – this is the equivalent of
letting strangers into their home without parents realising. With those
vulnerable often seeking validation online, positive comments and compliments
could also encourage risky behaviour, and because of the live nature, content
cannot be edited or moderated and once streamed, could be recorded and shared. The
thrill of being live may also reduce their inhibitions, encouraging them to say
or do things they wouldn’t normally do, which in turn could have an impact on
their digital footprint, with repercussions for their online reputation in
terms of how others may see them in the future – think about university
applications and employment opportunities.
How can teachers
The curriculum provides several opportunities to share good practice, build resilience and promote critical thinking skills online. Teachers can go to livestreaming.lgfl.net to download classroom resources, posters and our ready to use CPD powerpoint with top tips and activities on livestreaming for staff training and discussion starters:
You may also want to take a look at Thinkuknow’s #LiveSkills, designed to help primary and secondary pupils think critically about who they interact with, and how to respond to pressure and manipulation online, whilst Childnet’s To Stream or not to stream provides fun scenario based activities to support classroom discussion.
What can parents
There are several resources available for parents at parentsafe.lgfl.net, providing practical steps and tips to ensure a safe and enjoyable experience online. As well as disabling location services and enabling privacy settings, so children are only streaming to friends they know, parents could think about being present, especially with younger ones, and consider what the surrounding room or location could give away in terms of personal information.
Discussion and involvement with their online life is key – regular conversations about who their friends are, what apps they enjoy and how they are engaging with them is always useful. Parents can also become moderators to keep things in check and find out more about the apps their children are using from the NSPCC Net Aware site. CEOP have produced a short animation called #WhoIsSam, highlighting the importance of parents and carers talking openly to their children about being safe online, healthy relationships and speaking out if anything happens online that worries them or doesn’t feel right. You can also download factsheets on live streaming for parents/carers and professionals to use alongside the animation.
For primary pupils, a general conversation about staying safe online using NSPCC’s Pants Rule and Pantosaurus video is also useful to help understand what parts of the body should stay private, and that this rule applies online as well. Parents can get further advice about managing livestreaming and reporting concerns in Thinkuknow’s A Short Guide to Livestreaming
Its not all doom and gloom though, so don’t forget to highlight the positives with balanced messages and remind children that if someone asks them to do something online, they can always say no, end the stream, and talk to a trusted adult.
• Cyberbullying: a whole school approach – 13th November 2019 • Serious Youth Violence – 4th December 2019 • Fake News – 15th January 2020 • Engaging Parents with Online Safety – 12th February 2020 • A Guide for Governors – 11th March 2020 Sign up here and ask your questions in advance.
Welcome back to the new academic year! We’ve been busy all summer developing a new training programme to help you keep up with all the new legislation, ensure compliance and and implement effective practice around safeguarding.
As you are aware, ‘Keeping Children Safe in Education’ has just been updated (September 2019) – so we have commissioned brand new translations of KCSIE Part 1, to reflect the latest changes and updates, to be available mid-September in 11 key community languages. You can download the current versions now at: kcsietranslate.lgfl.net
And remember, if it’s hard to get out of school you can always join our 4pm TWILIGHT webinars – designed to cover new DfE guidance, livestreaming, bullying, youth violence, fake news, and engaging parents / governors with online safety. Sign up for our webinars now at digisafewebinar.lgfl.net
We were delighted to be joined by a DfE Prevent lead last week for our very first ever LGfL DigiSafe webinar. You can now listen to the full audio here if you missed out on the day. As promised, I’ve provided a summary below, along with top tips, strategies and the latest resources to support you and your school.
Do bear in mind that with Ofsted focusing on equalities, safeguarding and the curriculum, this requires a holistic approach and is relevant to the whole school community – hence my summary may appear extensive, so do feel free to pick out whichever section is relevant to your role from the list below:
Expectations for schools
British Values – the golden thread in the curriculum:
Teaching Primary pupils about extremism and preparing for transition
Raising awareness through assemblies
Equipping staff to deal with challenging questions or controversial issues
Expectations for Schools:
As you know, schools have a legal responsibility to “have due regard to the need to prevent people from being drawn into terrorism”. What’s important to stress is that this is ultimately about safeguarding – protecting a young person from radicalisation is no different from safeguarding them from other forms of harm, such as gangs and child sexual exploitation. And from a safeguarding perspective, we know already that the dynamics and mechanisms around grooming are very similar, as are the vulnerabilities. With that in mind, it is essential to understand the threat to young people, so you can put the necessary preventative measures in place and engage effectively with parents, pupils & staff to ensure transparency and consistency.
2. Fundamental British Values – the Golden Thread in the Curriculum:
Whether we refer to Fundamental British Values or shared values, ultimately, what really matters is the values themselves and how they are embedded in school’s ethos and practices. Rather than teaching this explicitly, these values need to be promoted across the entire curriculum – a golden thread which permeates all aspects of school life. The curriculum provides many creative opportunities for promoting British values, with many schools already demonstrating good practice through subjects such as PSHE, RE, English, and Geography to introduce the concepts of democracy, the rule of law, individual liberty, and mutual respect and tolerance. Beyond the curriculum, a holistic approach can develop a strong school ethos to further foster these values – examples of effective practice include having:
Student councils to promote pupil participation in a democratic way
Circle time to promote critical thinking and opportunities to discuss current affairs
International days/visits to places of worship to celebrate cultural awareness
Fundraising initiatives to raise awareness and support for global humanitarian issues, e.g. the plight of refugees
Peer-mentoring programmes to build resilience, promote respect, social activism and support
Debating clubs to discuss local, national and global issues
Visits from authorities such as the police and youth justice organisations to reinforce the importance of the rule of law
3. Teaching Primary pupils about extremism and preparing for transition:
Fostering positive values such as tolerance and respect for others will help build resilience to extremist narratives and develop a moral compass – many primary schools will already be doing this. For ideas and examples of effective practice, visit the blog by Twinkl published in collaboration with Educate against Hate. Several primary schools have incorporated additional strategies or programmes to complement their values centred approach to learning. These include adopting:
I’d like to stress that building resilience to extremist narratives doesn’t have to involve talking about terrorist attacks directly, and it’s important that teachers make a judgement about what is appropriate for their pupils. Many primary school children will however be aware of prominent news events including terrorist attacks, either through social media or their friends and families – so addressing these topics head on can be helpful to provide reassurance and put fears at rest. This could take the form of a circle time activity where pupils are encouraged to talk about their feelings and emotions. To support primary teachers, guidance is available at:
Assemblies and collective worship sessions provide ideal opportunities to show how British values are relevant to all your pupils. These can include a series of themes around the building blocks of extremism, e.g. power, fairness, celebrating difference, respect, faith, tolerance and other issues contained within the values concept. There are several key dates that you can plan your assemblies around the school calendar, including:
Safer Internet Day – February
World Social Media Day – June
World Refugee Day – June
Anti-bullying Week – November
5. Equipping staff to deal with challenging questions or controversial issues around Prevent:
Independent research from Coventry University has highlighted confidence in having difficult conversations as a key concern for teachers. There are lots of examples of good practice happening in schools, and a key focus for the Department is ensuring that good practice is shared and accessible in order to build teachers’ confidence to having potentially challenging or sensitive discussions – I’d like to point out that you don’t need to be an expert in this area – it’s about being there to listen, providing reassurance to your pupils and knowing who you can signpost to if you don’t have an answer. Your History, RE, Politics and PSHE staff will be able to offer valuable insights and knowledge, along with staff who have experiences or backgrounds from various cultures and interests.
And here are some excellent resources to support you along the way:
6. Promoting critical thinking and building resilience to online radicalisation:
In terms of how the risk manifests itself today, an obvious
area of vulnerability is online, with extremists making extensive use of
online platforms to incite hate, shape opinion and spread their ideologies. We
must therefore assume that anyone could
at some point be vulnerable online in
the absence of protective factors. Unrestricted access to inaccurate
content, misinformation and propaganda, together with the unregulated nature of
the internet bring new risks, further exacerbated by the volume of online
Points to consider
Research from Ofcom’s findings suggests more young people today prefer watching content on YouTube to TV.
Although schools will be providing appropriate monitoring & filtering in line with KCSIE’s statutory guidance, this doesn’t necessarily mean that young people won’t see age inappropriate content through their friends’ devices, Bluetooth or other avenues.
The good news
is that as school staff, you are in a unique position toempower all children, across all key
stages, to be critical thinkers, both off & online. Circle time, form time
discussions and opportunities for debate provide valuable openings to help
build resilience through the development of knowledge and support pupils
to think critically and independently. Useful resources to build into your
assembly and form time include:
Trust Me – lesson plans, presentations and guidance from LGfL and Childnet for primary and secondary teachers to start discussions around critical thinking, with a focus on content, contact, and propaganda material
fakenews.lgfl.net – cross-curricular activities, lesson plans, quizzes and videos to distinguish between fake and real news
IPrevent – guidance, interactive quizzes and case studies to support teachers, pupils and parents around extremism, grooming and cyberbullying
Tower Hamlets Prevent resources – lesson plans and activities for to support tutor discussion, assemblies and classroom discussion
7. Engaging parents:
Not all adults share the same use of social media as their children – so we also need to consider how to educate and empower parents and carers. Many schools have found it useful to invite parents to a school safeguarding session, which provides an opportunity to have a stall where you can raise awareness of Prevent as part of the wider safeguarding issues including online safety, FGM and CSE. Coffee mornings and parent evenings are also great opportunities to ask you pupils to present an online safety update, and carry out parent surveys. Remember to update your website with a link to Educate Against Hate which has an excellent section for parents, and you will also find some fantastic resources to signpost parents to at parentsafe.lgfl.net , including how to discuss a terrorist attack with your child.
A reminder that if teachers have a concern, they should follow their normal safeguarding procedures. This will usually involve speaking with their schools’ designated safeguarding lead who may suggest further discussion with the student or their parents. The Department for Education has established a counter-extremism helpline to avoid a situation where teachers feel there is no one willing to act on their concerns. Details are available on the Department for Education’s GOV.UK homepage and on EducateAgainstHate.com. There is also advice on this site about possible signs of radicalisation.
Do feel free to contact us or post a comment if you have any further questions, or would like further information on this topic. Email email@example.com or follow us @LGfLDigiSafe
Last month, after lenthy campaigning, the Information Commissioner’s Office (ICO) released their much anticipated Age Appropriate Design Code. You may have heard about this groundbreaking initiative, currently under consultation until 31st May 2019. But what exactly is it and why does it affect you?
Aimed at providers of social media platforms, content streaming services, online games, apps, devices, search engines and other websites, it outlines a code of practice for online services ‘likely to be accessed by children in the UK’. Through a set of 16 robust standards it ensures that the best interests of the child are the primary conditionduring the design and development phase. In doing so, it paves the way for parents and children to make informed choices and exercise control. This is vital, since many online services frequented by children were initially designed with adults in mind, well before the advent of new technologies when significant legislation around data protection and consumer rights enabled these services to bypass basic online safeguarding principles. It is worth noting also that the code is not restricted to services specifically directed at children, but are nonetheless likely to be used by under-18s, so even if the service claims to target adults, documented evidence is required to demonstrate that children are not likely to access the service in practice.
Why am I so excited?
As educators we have come a long way in raising awareness of risk and empowering pupils, parents and carers with strategies to stay safe online as part of our duty of care. Yet we all know that children are only as safe as the environment they occupy – their online world is a little like William Golding’s ‘Lord of the Flies’, the only difference being that here they inhabit a virtual island, unregulated and lacking in adult supervision, where they are unwittingly manipulated into forfeiting their personal information by entities masked behind the anonymity of their screens. A recent report by the Norwegian Consumer Council, Deceived by Design, warns that many big tech companies currently employ psychologists to design ‘sticky’ environments that nudge children to spend more time online and thereby generate greater profits. Tactics often used include the use of ‘dark’ patterns, or tricks incorporated in web and app design to encourage them to make choices they may not have intended to, like buying or signing up for something.
So last year when a group of pupil cybermentors at Greenford High School were invited to partake in a focus group by Revealing Reality, commissioned by the ICO to inform the Code’s development, I was thrilled. Their concerns were evident from the start, ranging from a lack of clarity around default privacy settings on social media, and the adult terminology used in terms and conditions notices, to confusion about how their data was being used and indirect ways their location and personal information could be tracked. Many also pointed out the varied strategies employed to extend their time online, such as positive feedback loops, reward cycles and forfeiting points if they paused in the middle of a game. Some pupils also admitted compromising these concerns, believing they had to agree to certain terms at the cost of missing out on these services altogether, in order to socialise and benefit from the apps their peers used. Seeing that their voices along with several others nationally have not only been heard but taken on board in shaping this vital piece of legislation is therefore great news.
So what does the Code mean?
You can access the entire document here – but I’ve taken the liberty of summarising key recommendations and significant nuggets that you will find useful for your discussions with pupils and parents below. These include, but are not limited to ensuring providers take responsibility for:
Establishing a high privacy default setting on all sites
Introducing robust age verification checks on platforms or treating all users as children
Limiting how children’s personal data is collected, used and shared
Disabling geolocation tools by default and providing an
obvious sign for children when tracking is active, which must default back to off
when each session is over
Removing targeted advertising as standard, unless there is a compelling
reason not to
Discouraging ‘nudge’ techniques from inciting children to engage in a certain way
and keep them online for longer. Examples include Snapchat ‘streaks’ or
Facebook ‘likes’, luring them to click on preferred options through use of more
prominent buttons, colours or fonts, or making it ‘difficult’ to manage their choices.
Instead of driving users to share personal data, guidelines require providers
to ‘nudge’ children towards healthy behaviours such as taking screen breaks
Ensuring privacy information, terms and condition are concise, transparent and
in age-appropriate language, with bite-sized explanations about how data is
used at the point of access
Requiring companies to show that all staff involved in the design and
development of services likely to be used by children comply with the code
And that’s not all – it will be statutory, with companies facing legal actionfor
failing to comply, and fines of up to £18 million or 45% of annual turnover
for serious breaches of data protection in line with General Data Protection
It’s worth noting that critics
have pointed out that in treating everyone like children, the code invariably
undermines user privacy by requiring the collection of credit card details or
passports for every user, and is an attack on the business model of online news
and many other free services, making it difficult to target advertising to
And whilst there are areas for clarification, I remain optimistic, and hope this has inspired you to discuss this ground-breaking code with your pupils – after all it will affect them and their insights are critical – so please collate their views, and respond to the consultation here. The safeguarding of our children online can only be effectively addressed through collective social mediation and critical thinking, focusing on the impact of online behaviour and environments. This requires a commitment by industry to take responsibility for safer online environments through improved design and monitoring, together with an inclusive and collaborative approach to education, with the child’s best interest at the heart of this. Furthermore, as technology rapidly evolves, it is vital for policy makers to keep abreast of these developments. Only then can we take an informed and consistent approach in addressing online risk, enabling young people to safely maximise the wealth of opportunities afforded by technology.