FOR INFORMATION - Safeguarding Briefing 13th January.
Please see Andrew Halls Safeguarding Briefing - 13th January 2020
Dear Colleague,
Read Theory and Safeguarding - Update from 2017
Read Theory is an education web site from the US that offers online reading activities for ‘all ages and abilities’. Some schools are using the website in school time, and recommending it for homework.
I hadn’t heard of Read Theory until a headteacher emailed me in 2017 concerned that she had heard there could be safeguarding risk.
Read Theory is free to use, children can set up accounts, and teachers can set up accounts for their pupils. The headteacher had heard that pupils could come across inappropriate websites.
In 2017, I created a pupil account and had a look. The site is funded by Google Adsense adverts, so it can be free to use. I used the site for about half-an-hour and found no inappropriate adverts on the site itself, but when you link to those ads, they offer further adverts. The ads on those sites offered links to further sites, which in turn easily led to a dating site featuring inappropriate images of women.
Last week, I was sent an email again raising safeguarding concerns. So, I reviewed the Read Theory site again. Many of the concerns that had been raised in 2017 seem to have been mitigated.
Read Theory’s privacy policy, updated in February 2018 says, ‘advertisements on our Site are non-targeted. This means personalised advertising (formerly known as interest-based advertising), has been disabled for all ads shown on this Site.
When I used the site again this week, I used incognito mode on my browser, so my web history would not affect the ads shown. None of the adverts that came up as I used the site were inappropriate. The ads ranging from Lego Friends, a computer game aimed at children, and business products, for example, an insurance company. Using my usual Chrome browser without any privacy settings brought up the same ads (except for a funeral directors’ which I hadn’t seen before), so it looks like their privacy policy is correct.
In 2020, it looks like the safeguarding concerns have been dealt with, and from that perspective the site seems suitable for use.
However, two issues potentially remain: compliance with data protection and GDPR; and the site’s terms of use.
I’m not an expert in GDPR, but as far as I understand it, a UK data holder must only process personal data in the EEA, and outside the EEA if the country has approval to do so from the EU. In the case of ReadTheory, the data (email address and a full name) is being processed outside the EEA by a company in the US who is not a member of Privacy Shield, as required by the EU. I think that this means Read Theory is not compliant with GDPR. Schools should check with their Data Protection Officer or legal provider.
Read Theory’s terms of use state that ‘the website is not available to any persons under the age of 13 whose registration has not been approved by a parent or legal guardian’. This seems to be waived when a teacher signs up their whole class. Schools ought to consider whether this means that parents should formally give permission to add their child to the site, if they are 12 or under.
Whilst the terms of use say, ‘minors’ continued use of the Site following parents’ or guardians’ review of our Parental Information Form is considered to constitute parental consent.’ However, the Parental Information Form does not include any details about the use of advertising content or how it is served.
It seems to me that the concern about advertising seems to have been alleviated. In school, filtering should take care of any inappropriate advertising that might slip through. At home of course this might not be the case. Schools should probably consider whether they should discourage unsupervised access at home, though there is no greater risk here, than with any other advertising on the home network.
A spokesperson for the company, Sean, said, 'We've actually had a complete change in ownership since 2017 and we are committed to creating a safe platform for users of all ages. We have a dedicated staff member whose sole responsibility is ensuring that no inappropriate content makes it past our filters. We recently completed an external audit and are now Kidsafe Certified. We won't claim to be perfect, but we take it seriously and move swiftly to combat any issues when they arise.
If you or others ever have concerns, please reach out to us directly here at support@readtheory.org. I'll make sure that whatever the issue is, it is resolved quickly.'
Data Protection Failure
A council has launched an investigation after confidential SEND information of about 50 pupils was shared in school assembly.
The presentation detailed how exam arrangements for children with additional support needs would be different, and listed individual pupils.
A spokesperson for the council said: "We apologise for the obvious upset and concern this has caused, particularly to those young people whose details were shown.
"Inquiries are under way to establish the full circumstances of this isolated incident and whether any individual learning requires to be provided."
Before using any slides in assembly, check and double-check the content.
SafeCall in Schools and Colleges: A lifeline for children and families forced into criminal exploitation (Missing People)
County Lines – Threat, harm and risk to pupils and students
The threat associated with County Lines drug distribution networks has rapidly grown with over 2000 identified drug lines operating across the UK, primarily through dedicated mobile phone lines. Children and young people are approached physically or online before being targeted, groomed and exploited by drug gangs. They are forced to transport and store drugs, weapons and cash between import and export areas as well as to work on the line, delivering and dealing drugs, usually crack cocaine and heroin, to vulnerable drug users.
The nature of County Lines and Child Criminal Exploitation is a rapidly changing picture of threat, harm and risk. Gangs and those wishing to exploit children and vulnerable adults are continuously adapting their business tactics to increase their chances of going undetected by law enforcement and other agencies.
While continued lateness and poor attendance over a number of days were previously strong indicators of possible involvement in County Lines (alongside wearing two layers of clothing), there is now a move towards being missing for shorter periods during a school day. This new trend avoids triggers being hit within school or college, and staff not being alerted as promptly to the missed lessons and absence.
SafeCall provides a national telephone based support service to those in crisis caused by County Lines including young people, families/carers and professionals. The helpline operates 24 hours a day, seven days a week on
For young people we provide crisis support, whether that is at 3PM on a Monday afternoon or 3AM on a Saturday morning. We are there to help them with safety planning and mapping, mobilising help from other agencies and supplying them with a free safety device (Ownfone) where appropriate.
Referring to SafeCall
To refer a young person or family member (with their consent) there are a number of ways you can contact the team:
Complete the online referral form here:
https://www.missingpeople.org.uk/how-we-can-help/safecall/974-are-you-a-professional.html
Email - safecall@missingpeople.org.uk
Telephone Safecall - 0208 392 5710 between 10.00 – 18.00 hours Monday to Friday
Telephone Missing People Helpline 24 hours, 7 days a week - 116 000 (who will respond outside of Safecall office hours)
Download more information about SafeCall: SafeCall in Schools and Colleges https://www.safeguardinginschools.co.uk/safecall
Safeguarding pupils placed with alternative providers - VIDEO
The new Ofsted Framework is very clear about the responsibility of mainstream schools towards their pupils who have been placed in off-site education. In this video, I explain the five areas that Ofsted will look for. (Click image to play)
Pupil-friendly safeguarding policy
I have a particular gripe about safeguarding and child protection policies. Whenever we write, we should bear in mind the needs of our audience. Strangely, we almost never do that when we write a policy and it can end up not communicating clearly enough. Often the document uses professional language, jargon and abbreviations which make it difficult to understand.
A safeguarding policy is commonly written for staff and governors, but it must be available to parents via the website. Is it written clearly enough for them. How about pupils, is safeguarding adequately explained to them.
Some schools are writing 'pupil-friendly' safeguarding policies and a Safeguarding.Pro member this week asked to see examples. If you have one we can share, we'd love to see it. You can send it by email to office@safeguardingonschools.co.uk
Forthcoming Seminars
Seminars can be booked online using the links below, by replying to this email stating the course you wish to attend, or by simply phoning Emma or Hollie at our office on 01223 929269.
Advanced Safeguarding for DSLs
LONDON Tuesday 28th January 2020 FULL
LONDON Tuesday 25th February 2020 Book Online
MANCHESTER Wednesday, 11th March 2020 Book Online
BIRMINGHAM Thursday 19th March 2020 FULL
BIRMINGHAM Thursday 26th March 2020 Book Online