By Dan Furness, CIS Head of Safeguarding & Well-being and Dr Leila Holmyard, International Safeguarding Researcher & CIS Advisor

 

We began accrediting fully online schools in 2023 and are seeing more CIS member schools engaging with online providers as a way of expanding their curriculum, offering more choice and flexibility to students. 

Further, AI tools are increasingly being integrated into student learning experiences and all schools need to consider how to apply safeguarding principles in these contexts. Many of the same safeguarding considerations apply as in physical schools, including governance, leadership, policy and reporting protocols.

Here, we describe twelve key safeguarding considerations for online schools to consider when reviewing their safeguarding procedures. They should be applied as appropriate to the online learning provider, recognizing that online schools can vary in the scope and type of services they provide. 

International schools can also use this guidance in evaluating the safeguarding arrangements of online learning providers.

 

 

1. Communication

Online schools should consider the expectations they have of students, teachers, and parents regarding online communication. 

Key questions: 

• Is all communication kept within the school’s learning platform and, if so, how is this overseen and monitored? 
• Does the school record lessons, and if so, how is this recording stored safely? 
• What guidance is provided regarding the sharing of personal information and communication outside the school’s platform? 
• If all communication is kept within the school platform, how does the school approach requests from graduating students who may wish to stay connected with former classmates and teachers?

 

2. Age & needs of students

Online schools must carefully consider the ages and needs of their students, especially where they are in digital learning spaces with much older or younger peers. 

For example, in mixed age settings, younger children may be exposed to age-inappropriate content and topics, particularly if communication is unmonitored by the school. 

Many online schools support students in transition from or between other educational settings and so need to be aware that this can increase their vulnerability to harm.

Furthermore, online schools should consider how they address the learning needs of individual students, including those with disabilities, mental or physical health challenges, or commitments that make traditional schooling impossible for them (such as student-athletes). 

Key questions: 

• How does the online school identify and support the individual needs of students? 
• What is the age range of students participating in the programme? 
• Are there limits around the maximum age range within one class? 
• Is the age of students considered when developing communication guidelines for communication, including forums? 
• How are these guidelines communicated and implemented?

 

3. Monitoring systems

Online schools should implement monitoring and filtering systems to control online activities within the learning platform (in accordance with relevant data protection laws in their region). 

This helps to safeguard students from accessing or sharing harmful content, and reduce the risks of peer-on-peer harm and abuse. 

The following questions should be considered when students use their own devices or use school-provided devices at home. 

Key questions: 

• Are there recording protocols for online meetings and lessons, and, if so, are the protocols proportionate to the risk? 
• What legislation and ethical standards support or guide the implementation of monitoring, filtering and recording systems? 
• How are these measures communicated to teachers, students and parents? 
• Is there a clear process for reviewing the monitoring system outputs in an ethical and systematic way?

 

 

4. Local and global context

As online schools serve their global student body, it’s important that they take account of all legal and contextual considerations in its safeguarding policies and practices and how these relate to the students in their country. 

Key questions: 

• What general training and guidance is provided to teachers and other employees about working in the global space with an international student body? 
• What specific safeguarding considerations does the school consider in relation to its context serving a global student body? 
• How does the school support the mental health and well-being of its students, especially if they are transitioning from high-risk jurisdictions or conflict areas?

 

5. Avenues for reporting

It’s important that students and staff know who they need to report to when they experience or become aware of harm being caused. Online schools might have similar reporting procedures to physical schools but will need to think carefully about how these are communicated to and understood by staff, students and parents.

Key questions: 

• Is there a member of staff designated as the safeguarding lead? 
• Do they have the time, training and resources to fulfil this role? 
• What avenues are there for students to report if they feel unsafe in a virtual classroom, session or forum and to report wider concerns (including off-platform concerns)? 
• Is there a digital way for students to flag or report concerns within the learning platform? 
• If a student or teacher flags a concern, who receives it? 
• How are reports managed in terms of time zones? 
• What are the processes by which reports are responded to and addressed? 
• Does the school have access to or relationships with counsellors and external consultants who support the school in responding to concerns about safeguarding, mental health and well-being? 
• Does the school have anonymous reporting procedures that allow for two-way communication to earn trust and allow for the full details of a disclosure to be shared?

 

6. Expectations of & guidelines for students

When students join an online school it’s important they have access to and understand the expectations of them at school and the guidelines for their behaviour and learning in a digital school. 

Key questions: 

• Does the student induction process and code of conduct address the following?
  • expectations of online behaviour and communications
  • use of social media
  • guidance and access to resources about online safety
  • appropriate dress code and location guidance for joining any virtual learning sessions
  • how to report concerns
• How are these concepts revisited with students throughout their learning programme? 
• What opportunities are there for students to contribute to the review and development of these supportive processes and guidelines?

 

7. Home-school partnership

Parents, carers and guardians are key partners for safeguarding. This is especially so when students learn online, whilst being physically in their home. Online schools should build trusted relationships with parents and students, including pathways for reporting safeguarding concerns about student safety or well-being. 

Key questions: 

• How does the school raise awareness of safeguarding risks and communicate its safeguarding processes to parents/carers/guardians? 
• Does the school use risk assessments when concerns involving the safety of the home environment are raised? 
• What opportunities are there for parents to provide feedback as it relates to online safety and safeguarding? 
• How can parents/guardians report a concern about their child’s online experience and/or mental health and wellbeing?
• How does the school help parents understand prevalent forms of harm both online and in real life?

 

8. Staff code of conduct & training

Digital environments are unique to each school, and, just like a physical school, online schools must ensure there is clear expectations for staff behaviour on and offline. Staff should receive the appropriate training to safeguard the students in their care. 

Key questions: 

• Do all staff, employees, and volunteers read and sign the code of conduct to acknowledge they understand expectations around their professional conduct? 
• Do all employees and volunteers undertake safeguarding training that references the staff code of conduct? 
• If so, how frequently? 
• Is the training differentiated by role and the unique context of an online school? 
• Does the training cover online forms of harm including: 
  • online grooming 
  • online radicalization
  • cyberbullying
  • online sexual harassment and abuse 
  • online sexual extortion 
  • use of generative AI
  • image sharing
  • access to harmful content online

 

9. Student education

Teaching children how to stay safe is a key cornerstone of any school safeguarding practice, and it’s no different in online schools. 

Key questions: 

• Does the school provide a safeguarding curriculum for students? 
• Is this taught by safeguarding-trained staff? 
• What considerations are made for the school’s local legal and cultural context? 
• Does it include but is not limited to online safety and safe, ethical and appropriate use of AI (see next point). 

 

10. Safe, ethical & appropriate use of AI

With the introduction of AI, students face new forms of harm and challenges to keep and stay safe. All schools face challenges regarding the use of AI, whilst also benefiting from this technology. 

Key questions: 

• Does the online school have a policy on the safe, ethical and appropriate use of AI? 
• Does this policy:
  • include the use of generative AI? 
  • cover the use of AI by students and staff? 
• Does the school use a closed AI system that only draws from information within the school community or does it use an open AI system? 
• If the school uses open AI, have they risk assessed doing so? 
• Does the school keep track of all the AI systems that staff and students are using in their school? 
• Do the school’s guidelines for the acceptable use of technology include the use of AI?

 

11. Data, security & safeguarding

With online access to students often being dependent on access to the student’s data and contact details, online schools must understand how they can safeguard this information and think critically about who can access it and why. 

Key questions: 

• Who has access to student data? 
• Is there training and a clear reporting process for non-teaching staff such as software developers who may come across a concern during the course of their work? 
• How does the school ensure that personal data is processed in accordance with data protection laws? 
• What features are available to teachers to support online safety such as the ability to block or mute participants from online classes?

12. Safer recruitment

Staff and volunteers in online schools may have regular, unsupervised access to children, and so it’s crucial that schools follow safer recruitment guidelines. 
Schools should refer to the International Taskforce on Child Protection Safer Recruitment Checklist for more guidance on this area. 

Key questions: 

• Does the online school have and implement internationally recommended safer recruitment guidelines for all employees, including those who are not working directly with students, such as their Board, software developers, marketing, customer support and sales team members? 
• How does the school assess and mitigate any gaps in background checks or references for risk? 
• Does the school adopt a waterfall technique to conduct deeper checks and references where criminal background checks are not available? 
• Does the school conduct online searches for a candidate’s digital footprint? 

 

Additional resources:

• Should we record virtual counselling sessions? And other questions … answered
• Safeguarding implications for online learning
• Virtual waiting rooms: Identifying safety & security challenges 

 

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Key questions this blog addresses:

• What are the essential safeguarding measures every online school should have in place?
• How should online schools manage online communication, monitoring/recording, and data protection to reduce online harms?
• What policies, training, and reporting pathways—including for AI use—do staff, students, and parents need to keep learners safe?