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This guidance is important. It is based on current
legislation and guidance. It reflects legal duties which Blandford RFC owes.
Implementing this guidance should help discharge this legal
obligations.
Blandford RFC Websites Websites are a key part
of the daily operation of most clubs. They are probably the most flexible way
to communicate with members, and to anyone interested in joining a club. They
also have the potential to be a very safe way to communicate with children,
given their wide accessibility.
However, in the same way that a club
has responsibility for the physical safety of a junior member when visiting the
club's premises, the club must also ensure that there is nothing on its website
which could harm a child, directly or indirectly. The Junior Section Blandford
RFC is responsible for the content of its website.
There are 2 key
risks to guard against, and which are constant themes in the more detailed
provisions in this guidance:
- Disclosing personal information about a child to people
accessing the website. This could be the child's name, address, or any
information about a child's life, interests or activities which would help a
stranger target a child, or engage that child in conversation.
- Abusive or inappropriate content (photos, video or
text), on the site itself or on linked sites.
Website content generally There are three main
child protection risks associated with content:
- Inappropriate content (for example violent, sexual or
hateful content). Although it is possible to impose restrictions on access, it
is overwhelmingly likely that children will be able to access all areas of a
club's website. Indeed, most clubs will positively want the website to generate
interest among children. The risk applies both to text on the club's website,
and on any linked websites.
- Bullying: This could be material on the site which
criticises or humiliates a child. It could also be information which places
undue pressure on the child to participate in some aspect of a club's
activities.
- Disclosure of personal information of children. This
could lead to grooming.
Blogs Weblogs (also known as Blogs) are a type
of content which is becoming commonplace on websites. The creation of a blog is
straightforward. It does not require technical or design expertise, and it can
be updated remotely. Blogs present two particular challenges:
- A central part of the attraction of a blog is that it is
updated frequently. However the same risks apply to its content as apply to all
other content on the site. A club cannot distance itself from the content of a
blog it chooses to include on its site.
- Blogs often contain a lot of opinion, as opposed to
purely factual information.
Currently the Blandford RFC Website does not have the
facility for a blog.
Linked sites Many sites contain links
to other sites. This could be for commercial reasons, such as the sites of
sponsors or advertisers, or simply to communicate information to be found on
other websites. Before creating a link, a club should check thoroughly the
content of the other website, both for child protection reasons, and to ensure
the content poses no other risk to the club's reputation. Once a link is
included on the site, the club should check its content periodically (the
frequency of the checks depending on how frequently the content changes), and
remove any link immediately if concerns arise.
An additional concern
with linked commercial sites is inappropriate advertising or marketing aimed at
children. The advertising industry is self-regulating through the Advertising
Standards Authority (ASA), and has produced detailed guidelines covering
marketing to children.
Recommendations:
- Content must be checked that is it appropriate to be
seen by children, and that it does not have the potential to bully, before it
is included on the website. Sometimes these decisions can be finely balanced.
If there is any doubt, the text should not be included.
- The responsibility for checking content needs to be
allocated clearly to individual(s) who understand properly the issues involved.
This may well be the individual at the club with responsibility for child
protection, but this is not essential. The individual should be familiar with
this guidance. The content of the Blandford RFC website will be checked on a
regular basis by both the Webmaster and Club Safeguarding Officer.
- In the unusual circumstance that it is possible any
content will go onto the website without being checked by someone else (such as
a blog) the club must satisfy itself that the author is sufficiently aware of
child protection risks, and the content of this guidance, to be able to
self-check effectively.
- Where members of the public can email comments which
would then appear on the website (often called a message board, or chatroom, or
discussion forum) the content of these emails should be checked before
appearing on the website. Publication should not be automatic. This facility is
not available on the Blandford RFC website.
- If a Blandford RFC receives any complaints about
content, it will remove the content in question immediately, and reinstate it
only once the complaint has been resolved. The Blandford RFC Webmaster is to
react quickly in the event of any complaint.
- Personal information about children over and above the
child's name should not feature on the website.
- Links to another website should not be placed on the
Blandford RFC website until a check of the site's content has been undertaken
and is satisfied that the content is appropriate. It is good practice to
discuss any proposed link with the owner of the other website, and obtain the
owner's assurance that the linked site is designed to be suitable for children
at all times of the day or night (some websites' content is different and more
adult during the night). If the linked site has marketing content aimed at
children, the club should obtain a further assurance from the other websites
owner that it complies with ASA guidelines.
- The content of linked sites should be checked thoroughly
at least once every 6 months.
- If Blandford RFC learns of any concerns over the content
of the linked site, it should investigate immediately. Unless it is clear that
there is no need for concern, the link should be removed immediately, and any
decision to restore only made after the concern has been investigated.
Photos and video Photos and video clips
can make any child featured vulnerable to grooming if information about the
child (name, address, activities or interests) is also disclosed. Furthermore,
posting an image on the website carries a risk that the image could be taken
and adapted for an inappropriate use.
Recommendations:
- Use group images, rather than individual images.
- For images of individual children (such as in action
shots) where possible use models or illustrations.
- Only use images of children in suitable dress, to
minimise the risk of inappropriate adaptation of the image
- If a child is named on the site, an image will not be
included (individual or group). If a child features in an image on the site,
the child's first name or last name, either in text on the site or in the image
file name will not be used.
- Parents (in this guidance, the term "parents" covers
whoever cares for the child), and the child if old enough to understand, should
be notified of the intended use of an image on the website. The image will not
be used if the parents or the child object (a requirement of the Data
Protection Act as well as good child protection practice), and the Safeguarding
Officer holds positive written consent. As Blandford RFC regularly uses certain
types of image, such as team photos or match photos, notification and a consent
request should be included in the information is given to junior members and
their parents upon joining the club.
- If consent was given initially, but is subsequently
withdrawn by parent or child, the image should be removed from the site.
Webcams and live image streams The use of
webcams on websites is becoming increasingly common, with pictures and sound
streamed live. It can be a very effective way to portray a club's activities
and atmosphere.
However control is difficult. Any live image stream, by
its nature, cannot be checked before transmission. Also, depending on the
siting of the camera, it may not be possible to limit the people whose image or
speech is transmitted. Furthermore there is a risk that images or speech could
help identify children, or contain personal information about those children,
and the image stream could attract unwelcome interest from potential abusers.
There is less risk when streaming a match or training session, compared to a
social event. Schools are advised not to have live image streams on publicly
available websites.
Risks are lessened if the streamed images are on a
part of the website where access is restricted, such as a members section.
However such restricted access prevents the images generating interest in the
club among members of the public.
Recommendations
- A club needs to give careful thought to why it wants its
website to stream images, what images it intends to capture, and how they will
be presented.
- Any transmitted image stream should be pictures only,
without sound, unless the removal of sound would not produce a true to life
record of the event.
- As far as possible, the images should be of groups of
people, not individuals.
- A club should try to notify all visitors (both adults
and children) whose image may be caught that a webcam is in operation. Usually
this is through the use of prominent notices placed around all entrances to the
area covered by the camera.
NOTE: Blandford RFC does not currently use and webcam
or live streaming on their website.
Mobile and on-line communication
with children Technology is moving very fast in this area. There are
now many different ways for people to communicate. In addition to land-lines,
there are mobile phones for voice and text, and most new phones incorporate
cameras that take still shots and video. Two-way video calling is set to grow
fast. On-line communication can be by email, instant messaging, chatrooms, and
social networking sites.
The risks posed by such methods of
communication arise from:
- The privacy: It is usually one-to-one (often chatrooms
have the facility for individuals to communicate 1:1 within the chatroom).
- The wide range of content that can be transmitted,
including content of a violent, sexual or hateful nature.
- The ease with which images can be forwarded onto
others.
- The difficulty in knowing truly who you are
communicating with. Where grooming happens, it often involves this type of
communication.
In sport, there are additional risks:
- Inappropriate pressure can be exerted by adults,
particularly coaches, on children (such as to play when injured).
- There can be inappropriate criticism of a child's
performance.
- An official position or role within a club, such as
Coach, can carry with it a level of authority, and engender a level of trust,
that facilitates the control of a child.
Against this background, a club needs to establish rules
covering how adults connected with that club communicate with children
connected with that club.
Recommendations:
- Blandford RFC Club Officials and Coaches must not
communicate with individual children by text or on-line at any time, on any
matter, unless there is an immediate risk to the welfare of that child which
can be lessened by such contact.
- When communication by phone is needed, where possible
Blandford RFC Club Officials and Coaches should speak to the parent of a
child.
- Blandford RFC Club Officials and Coaches may speak to
individual children on mobile phones provided they have prior consent from the
child's parents, and from the child if old enough to understand.
- Communication of club-related information to children by
email (such as training or match details), should be by email groups comprising
email addresses given by parents. Such emails should only come from specific
designated individuals, and children and their parents should know who these
designated individuals are. Lists of the individuals within these groups (names
only) should be publicised within the club, and easily available. Individuals
must consent before they are included in the lists, and must be removed from
the list if they wish to leave.
Implementing guidance The welfare of children
at Blandford RFC will only be protected properly if this guidance is
implemented effectively.
Recommendations:
- Based on this guidance, Blandford RFC has devised
written policies which cover its own particular circumstances, and meet its
particular needs, and ensure the policies are followed fully.
- The policies are widely publicised. They also published
on the club's website, and on display at the club (such as on notice boards).
They are also provided in the Club Handbook which is available to the parents
of each child at the club.
- Blandford RFC has clear written procedures that set out
how its policies are to be implemented. For example, policies should set out
how junior match reports will be checked before being put on the website, and
how email groups will be maintained. Procedures do not need to be publicised in
the way that policies are. Their focus is internal. They should ensure that
individual responsibilities are clearly defined and attributed, and people know
precisely what action is expected of them to discharge those
responsibilities.
- Blandford RFC has made it easy for children, their
parents or any interested individual to raise a child protection concern. This
has been achieved by appointing a designated individual with child protection
responsibility, and want concerns to be raised with that person. Details of the
club Safeguarding Officer are available on the club's website.
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