British Council Child Protection Policy
Content designed for or likely to appeal to a high proportion of children
Links between British Council pages
Links to external sites
Advice for children and parents
Interactivity and children’s sites
Risk assessment of moderators
Children and private online space
Privacy and consent
Parental consent
Interactivity and older children
Standards of behaviour

Introduction
We aim to provide children with challenging, educative, enjoyable and interesting content to help them make sense of the world in which they live. But, at the same time, we must take all reasonable measures to safeguard the welfare of children and young people - both as contributors and consumers of content.

The British Council recognises it has a particular duty towards all children using its services. It follows the widespread practice of defining a child as any young person under the age of 18 years.

British Council Child Protection Policy
Our dealings with children must be based on the British Council’s child protection policy:

			we treat children with dignity and respect in all areas of our work
			we seek to reduce, manage or avoid all known and foreseeable risks to children arising from our work
			by doing so we also protect individual staff members and the organisation as a whole.

Implementation of the child protection policy covers:

			recruitment safeguards (taking action to prevent unsuitable individuals from working with children)
			practical guidelines (encouraging all staff who are responsible for delivering services for children – including on-line services – to follow good practice guidelines in all aspects of their work)

The emphasis of the British Council’s child protection policy is on preventing rather than identifying harm. However, we recognize there may be occasions when staff, customers or external contacts have concerns about actual or potential harm to children. This child protection policy makes provision for complaints and whistle-blowing, ensuring any such concerns can be acted upon without delay.

Staff with management responsibility for services aimed at children – including online services – must ensure procedures for complaints and whistle-blowing are easily accessible by external customers and staff members equally.  

Every member of British Council staff is expected to understand their responsibilities in child protection. These include the responsibility to conduct themselves appropriately when working with children, both in face-to-face and virtual contexts.

Content designed for or likely to appeal to a high proportion of children
Those planning British Council web pages must be clear about whether they are likely to be accessed by children and choose material accordingly.

We must take all reasonable measures to ensure children are not caused anxiety or distress as contributors or consumers.

We must balance our responsibility to protect children from unsuitable content with their rights to freedom of expression and freedom to receive information. The responsibility to protect will normally take precedence, in line with our duty of care.

Links between British Council pages

			Any material on the British Council Home page must be suitable for a general audience, including children
			The first click from the British Council home page must not lead straight to a page that includes material that is unsuitable for a general audience.

Links to external sites
We must take special care before linking to an external site. This must involve checking the content on the third party site and taking care about where it might lead to directly. If we offer a search service for children’s sites, it must be designed for children and each site must be chosen and reviewed for suitability by the operational team concerned.

For an audience of children, we must never link to unmoderated chat rooms. This recognises the danger of children being lured into meeting adults after initial contact in chatrooms.

Advice for children and parents
Staff with editorial responsibility for online services must ensure users have access to safe-use guidelines. Different versions must be made be available for different audiences, for example, younger children, teenagers and parents.

Moderated sites must give clear information on the services offered and on the means of moderation used. They must also ensure users have some way of contacting the moderator if a difficulty or concerns arises while using the service.

Interactivity and children’s sites
Message boards and interactive spaces designed to appeal to children where users can post content are premoderated.

All messages must be checked for suitability by a moderator before they are published.

The sites must include an explanation of what premoderation means and how it works.

Any proposal to use an alternative form of moderation must be able to demonstrate that this offers an equivalent level of child protection and must be referred to Senior Internet Business Development Manager.

Risk assessment of moderators
Under the British Council’s child protection policy, all posts which have a clear and unavoidable need for direct access to children are subject to criminal records clearance. This includes moderators of sites which are either aimed at children or likely to be accessed by them. The recruitment, training, supervision and management of staff in such posts must follow the standards set out in the child protection policy.

This also applies to staff moving to positions as moderators of services for children, from positions with responsibility for delivering services to other audiences.

Line managers, or other staff with editorial responsibility for moderators, must carry out a risk assessment, in consultation with Human Resources staff. This must take account of:

			what opportunity the post offers for virtual contact with children
			how far the postholder is in a position of trust and authority in relation to young users
			what access the post gives to personal information about children
			how closely the process of moderation is supervised.

Local legislative provision must always be taken into account in considering child protection measures. This means that for British Council operations in some countries, it will not be appropriate to request criminal records information for prospective or existing staff. In such cases, greater emphasis must be given to other recruitment safeguards and to the training, supervision and management of staff once in post.

Children and private online space
Until a reliable method of digital identification is available, the use of private online space where strangers can routinely meet and exchange personal information carries an unacceptably high level of risk. This is because private space cannot be monitored to safeguard child users. Any proposal to make use of private space in British Council online services must be referred to Senior E-Strategy Manager.

Privacy and consent
Great care must be taken in collecting and disclosing personal information about children through British Council online services. When we publish personal information about children online, we must only select information which is editorially justified, while taking account of the risks to children (particularly young children) from publication of personal information. Combinations of written and visual information are a particularly sensitive area. The Data Protection Officer can advise about what information it might be suitable to reveal.

British Council moderators must not post messages containing e-mail addresses on children’s message boards. Where a child is clearly identified as having posted an e-mail address on a board which is not designed for children, the moderator must remove the message.

Where we invite children to send us information about themselves, for example a name and e-mail address to enter a competition, we must explain why we need it in language that children can understand

It is particularly important that younger children do not get into the habit of easily revealing personal details about themselves or their family on the internet. Any information children send to us:

			must only be used for the purpose for which it was sent
			must be retained securely and only for as long as we need
			must not be revealed to a third party.

Parental consent
When we ask children for personal information online, we must also consider what degree of parental consent is appropriate. Parental consent is obtained by:

			prompting a child to ask for it (the minimum)
			requiring the use of a clickable box to confirm that it has been obtained before the child can proceed
			requiring verifiable parental consent, e.g. a signed letter or personal telephone call from a parent or guardian.

Factors to consider in deciding which approach is appropriate include:

			the age and maturity of the child – will they understand what is going to happen to the information we want them to send?
			their expectations – does our use accord with what they expect to happen?
			the sensitivity of the information
			the risks associated with sending it – in particular, the risk of harm to the child
			the length of time we are storing it
			the security of the information while held by the British Council.

The information we request will have varying degrees of sensitivity and may require different levels of parental involvement. For example, if we ask a younger child (say, below age 13) for a name and e-mail address to enter a competition and the information is to be deleted after the winner has been declared, we must also ask for confirmation (via the click-able box, as above) that parental consent has been obtained. Where we want to collect and store a child’s mobile phone number, verifiable parental consent is essential

Interactivity and older children
Interactive areas where teenagers are encouraged to discuss their problems must include some form of general support, for example by posting the addresses of a reasonable range of useful websites, plus the telephone number of a child protection helpline. In the UK, this would include the National Society for the Protection of Cruelty to Children, which is 0800 800 5000.

Reviews of third-party sites that are likely to attract older children and young people, like sports sites, must make it clear if interactive areas on these third-party sites are unmoderated.

Standards of behaviour
The following standards of behaviour are included in the revised edition of the British Council’s Code of Conduct for staff (to be issued during 2005-06).

			General principles:- The British Council treats children with dignity and respect in all areas of its work. It takes all reasonable measures to control known and foreseeable risks to children involved in its activities.
			The standards of behaviour set out below are especially relevant to staff who work directly with children, including English language teachers and assistants, examiners, staff responsible for programmes in the arts and education, and staff managing online services designed for younger audiences. These expectations apply equally to line managers of people in such positions.
			If you work with children, you are in a position of trust. It is important that you acknowledge the influence you have on children’s development.
			You must take care to ensure your behaviour is appropriate at all times. This is important not only in safeguarding children, but also in protecting staff from wrongful accusation.

You are expected to pay particular attention to:

			the age, experience and cultural background of a child, and whether this makes him or her more vulnerable
			a child’s physical or mental disability, and whether this makes him or her more vulnerable
			avoiding unnecessary or inappropriate situations in which no other adult is present (with the exception of planned situations, such as language classes, where other members of British Council staff know where you are and for how long)
			understanding local norms around physical contact between children and adults
			avoiding sexually suggestive behaviour, or any physical contact likely to cause a child fear or embarrassment
			encouraging mutual respect, listening and co-operation among participants in a British Council activity
			challenging aggressive or sexually suggestive behaviour.

You must always act on any concerns you have about the behaviour of British Council staff or other adults involved in an activity designed for children – or likely to attract them.