Targeted Provision - Filtering and Monitoring process and procedures

1. Introduction

Here at Targeted Provision we ensure that no young person is left disadvantaged or unable to access their tuition due to a lack of suitable ICT resources. We also give direct access to support from our internal ICT team, to help YP and their primary carers access tuition successfully if they are experiencing technical difficulties.

Where it is identified that a young person requires the loan of ICT equipment to successfully engage, we may offer the loan of:

• A Chromebook.

• A wifi booster, should their home internet need improving.

We take our responsibility to protect young people who have access to one of our ICT devices very seriously and have a number of filtering and monitoring measures and procedures in place, to ensure that the risk of them being subjected to, or accessing inappropriate materials via a TP device, is kept to a minimum.

We also ensure that while safety is kept as the top priority, that systems in place are dynamically assessed in terms of the age and Key Stage of the young person, to ensure they are able to use the equipment effectively for their level of education and subject and without unreasonably impacting teaching and learning as advised in KCSiE (Keeping Children Safe in Education), guidance.

This policy outlines our Filtering and Monitoring processes, including how this feeds into our safeguarding processes.

2. TP’s Filtering and Monitoring Software

All TP loaned devices are preloaded with advanced AI supported filtering and monitoring software from Securly. This software is active 24 hours a day and includes:

• Sentiment Detection using advanced artificial intelligence (AI), designed to detect cyberbullying, self-harm, depression, violence, and other threat factors by identifying the emotional sentiment behind the words being used, while applying contextual intelligence to differentiate between benign and potentially dangerous language. If the system identifies that a young person may be at risk, an instant alert is sent to our safeguarding team.

• Advanced auditing capabilities to ensure a safe online environment, even outside of scheduled tuition sessions. Sentiment Detection and image detection are also applied to emails, G Suite and Office365 cloud drives on the loaned device to enable the identification of harmful content in emails sent and received, as well as in attachments and stored documents. Our safeguarding team is instantly notified of flagged activity, including copies of the actual content that needs reviewing.

• 24/7 “life saving alerts” where our devices are monitored for activity indicating risk of active suiciding behaviours, or identifying signs of severe bullying, depression, or violent acts. Where these risks are identified, our safeguarding team will receive an immediate alert to enable real time action in helping to safeguard that young person.

• Parents/Carers have access to a fully integrated companion application that gives them visibility into their young person's online activity on a TP loaned device. Enabling them to take an active role in their young persons online activities and be notified of any risky behaviors.

3. Initial processes before the loan of a TP owned device

Where it is identified that a young person would benefit from the loan of a TP owned ICT device, the following process is followed:

• The educational coordinator flags to the ICT Team that a device is required. This sends an automated alert to both the ICT team and the DSL.

• The DSL will review the YP’s information and dynamically assess risk to the young person on the following scale:

a. Low Risk Loan: The YP has no identified risks regarding online activity and the device being loaned is one such as a wifi extender. Tutor to visually monitor and supervise the safe use of YP owned devices during tuition sessions.

b. Medium Risk Loan: The YP will have access to the TP loaned device for tuition, which will remain in their possession outside of the tuition sessions. We have not been made aware of any identified risks regarding online activity for the YP. The device will be set up to include our filtering and monitoring software and the device will undergo random user checks throughout the loan. The device will also undergo regular tests to ensure that all filtering and monitoring software is working correctly and these checks will be recorded in a centralised log. A monthly activity report from the device will be set up for the safeguarding team to review.

c. High Risk Loan: The YP has identified risks in relation to access to online devices, a history of inappropriate online behaviours or wider contextualised safeguarding risks. They may have a Targeted Provision ISP (individual support plan) or SRR (Safeguarding Risk Review). The device will be set up to include our highest level of dynamic filtering and monitoring software and the device will undergo regular active user checks throughout the loan. The device will also undergo regular tests to ensure that all filtering and monitoring software is working correctly and these checks will be recorded in a centralised log. The tutor will receive additional support and advice on what to do if they have concerns regarding the YP’s use of the device. A weekly activity report from the device will be set up for the safeguarding team to monitor.

• The DSL will liaise with the ICT team to inform them of the level of filtering and monitoring measures required for the device before it is sent to the YP. The device will also be tested prior to its dispatch and a centralised record will be made of the results of this test.

• Prior to the despatch of the TP loaned device, The ICT team will send a user agreement to the primary carer which clearly informs them of the filtering and monitoring processes on the device and guidance on what is and is not acceptable use. The Primary carer must sign and return this document before the device is dispatched to them.

4. What happens if we receive an activity alert?

If our filtering and monitoring system alerts us to concerning activity from a TP loaned device, the following process is followed:

• The Filtering and Monitoring system alerts the DSL that a concern has been identified.

• The DSL reviews the content of the alert and will take one of the following actions:

a. The content of the alert is low level and could be related to the YP’s work. The DSL will contact the tutor to ascertain whether their sessions are currently covering topics related to the flagged content. If this is the case, the alert will be archived with no further action required.

b. The content of the alert is low level, but indicates that the YP may be using the device out of tuition sessions or at inappropriate times. The DSL will contact the primary carer to let them know the content of the alert and this will be recorded on our safeguarding systems for monitoring. The alert will be stored until the end of the tuition, with no further action required.

c. The content of the alert is a clear concern but does not indicate the risk of immediate harm or contextual safeguarding risks to the YP. The DSL will contact the primary carer to talk to them about the content of the alert, then complete a safeguarding report which will be shared with the commissioning party. Higher level monitoring of the YP’s tuition and loaned device will commence. The alert will be stored for one academic year (or the duration of the tuition if longer), and a copy made available to the commissioning party via the safeguarding report.

d. The content of the alert presents a clear risk of harm to the YP or others. The DSL will ask the ICT team to immediately disable the device and contact the Primary carer to inform them of the content of the alert. Following this a safeguarding report will be completed and sent to the commissioning party and Team Around the Child. The tuition may be placed on pause and a review will be held regarding next steps. A full risk assessment will be conducted in terms of how the tuition will progress and what safety control measures are required. The loaned TP device may be recalled, or heightened monitoring measures applied to help keep the YP safe. The alert will be stored indefinitely.

e. The content of the alert indicates the YP is at risk of immediate and significant harm or death. If deemed appropriate the DSL will contact the emergency services, followed by the primary carer (unless the primary carer is implicated), to alert them and to let them know the emergency services have been called. The DSL will ask the ICT team to immediately disable the device. The DSL will then inform the commissioning party and the Team Around the Child at the earliest opportunity, following confirmation of the YP’s safety, and will complete a MASH referral where necessary. The tuition may be placed on pause and a review will be held regarding next steps. A full risk assessment will be conducted in terms of how the tuition will progress and what safety control measures are required. The loaned TP device may be recalled, or significantly heightened monitoring measures applied, to help keep the YP safe. The alert will be stored indefinitely.

5. If you have any questions, please contact:

Emma Stanway: DSL, SMHL and Online Safety Officer, at: emma@targetedprovision.com

Rachel Greathead: DDSL, Prevent Lead and Deputy Online Safety Officer at: rachel@targetedprovision.com