On 17 April 2020, Moores ran a webinar for schools and organisations that work with children on maintaining a child safe online environment as a result of COVID-19. While some states have begun to ease restrictions, it is clear that online platforms will continue to be used by schools and organisations to engage with children. In other states such as Victoria and Tasmania, schools are expected to stay remote for the remainder of Term 2 unless medical guidance changes.
Following the webinar we received a significant number of questions, highlighting the complexity and uncertainty of remote learning. This article covers some of the FAQs.
Should organisations record one-on-one interactions between staff and children?
In general, we recommend against recording one-on-one interactions for the following reasons:
- Concerns regarding the organisation’s ability to securely store these recordings in accordance with your privacy policy and obligations (noting that some platforms such as Zoom automatically store recordings on the individual’s device as opposed to online platforms);
- Discomfort amongst children and staff members about being recorded;
- The need for revised consent forms, particularly if video recording;
- Manipulation of images captured to create inappropriate content (e.g. the use of Deep Fake or Photoshop); and
- Child safety concerns in relation to any sharing of confidential or private information that’s recorded.
Instead, we recommend that organisations provide guidance on what one-on-one interactions should look like such as requiring them to occur on the organisation’s platforms only and during school hours (or shortly before / after). Organisations should also ask staff members to keep a file note of any one-on-one interactions and should be ensuring they can have oversight of these occurring. This should be documented in policies such as a Remote Learning Code of Conduct.
If an organisation does choose to require recording, what are some safeguards that should be put in place?
Each organisation should carefully consider the unique child safety risks associated with its operations and whether it is appropriate to record interactions between staff and children. If an organisation resolves to direct staff to record their interactions with children, we recommend that it considers the following safeguards:
- Avoid video recording if possible (e.g. recording lessons online with slides and voice only is preferable to video recording);
- Only allow staff members to record interactions, and provide them with guidance on how to securely store the file;
- If video recording, encourage staff and students to blur backgrounds or use template backgrounds and ensure their location (and the location of children) is not obvious from the video;
- Consider if it is appropriate to delete the videos after a certain amount of time; and
- Be careful of meta-data that is recorded and stored.
What are some red flags for child abuse in the online environment that we should be aware of?
It is important that organisations continue to provide training and guidance to their staff members on identifying and responding to child safety concerns in an online context. Red flags may include:
- Signs of physical abuse if children are participating in video meetings;
- Recurring absence of attendance;
- Yelling or shouting in the background of meetings or communication with children;
- Children verbalising distress and requesting to attend schools physically;
- Signs of neglect such as children being in a different location each time or their location being an unsuitable living environment;
- Material that might come through in their other interactions with the organisation (e.g. writing about abusive content in their English assignment); and
- words or behaviour of parents / carers during staff member / parent discussions, such as abusive language towards their child or a lack of interest.
Where can we find your webinar on commonly used Apps by children and young people?
Moores recorded a webinar for Safer Internet Day on 11 February 2020, including an interview with Associate Professor Nicola Henry from RMIT University regarding commonly used Apps amongst children and young people and the child safety risks. You can find the recording on our news hub here.
What policies and procedures do you recommend that organisations put in place in relation to remote learning?
It is critical that organisations put in place policies and processes for online interactions with children. In particular, we recommend that organisations review, provide or implement:
- An online Code of Conduct for staff members that sets out key expectations when interacting with children online.
- An online Code of Conduct for children so that more mature children can understand the expectations on them, especially in relation to inappropriate behaviour such as cyberbullying.
- Guidance for parents – organisations need to recognise that as children are learning from home, and organisations have far less oversight of their activities than they would have in person. It is important that guidance is provided to parents such as popular online apps and games being used, and how they can play a role in ensuring child safety.
- Guidance for child safety officers – COVID-19 has presented complex challenges for the delivery of education and other services, but it is important that child safety does not fall to the side. Regulators have emphasised that child safety obligations continue to apply. Consider providing guidance and support to your child safety officers so that they can continue to champion child safety and facilitate compliance with reporting obligations.
Our previous article covers off on some other key tips for ensuring a child safe remote learning environment
What are some of the privacy considerations we need to be aware of?
An important part of child safety in an online context is protecting the privacy of children. Organisations will be collecting significantly more personal and sensitive information on children, potentially on platforms that they are not familiar with. We recommend that organisations review their privacy policy and make any changes needed to ensure compliance with the policy. For organisations using videoconferencing, please refer to our article on relevant privacy considerations.
How we can help
For more information or guidance regarding your child safety and privacy policy, get in touch with our expert child safety team. Please do not hesitate to contact us here.