Guidance: Interacting with children and young people online

Introduction

This guidance note is designed to give advice to content makers who work with children and young people online.

• Any online safeguarding concerns about under-18s, whether related to online grooming, child abuse images, or serious cases of cyberbullying, must be referred to the BBC Safeguarding Team^[1] immediately. Any images must not be shared.
• If, in the course of their work, content makers suspect that a person under-18 may be at risk, or they are alerted to a child welfare issue, they must refer it promptly to the BBC Safeguarding team^[2] or, for independent production companies, to the commissioning editor. If there is concern about an adult, including a member of staff, working with a child, the situation must be referred promptly to the Head of Safeguarding^[3] or Head of Corporate Investigations^[4] or, for independent production companies, to the commissioning editor.
• If a child is in immediate danger or requires medical attention, dial emergency services - 999 in the UK - and ask for the appropriate emergency service. The BBC Head of Safeguarding^[5] or, for independent production companies the commissioning editor, should be informed urgently.
• If material which is criminally obscene or incitement to racial hatred has been sent by whatever means to a BBC electronic space, contact the Head of Corporate Investigations^[6] or, for independent production companies, the commissioning editor.
• Content makers should apply the principles of the BBC Safeguarding Policy in their dealings with children and young people.

The Editorial Guidelines state that:

(See Editorial Guidelines 9.2.1)

Care must be taken to mitigate risk around content, contact and conduct when running interactive online spaces designed to appeal to children

Some risks to children online are either different or manifest themselves in different ways and there may be different ways of reducing risk or responding to reports of inappropriate or illegal conduct or contact e.g. when reporting suspected online "grooming".

Part 1: Online Child Safety

Suspected "Grooming" 

"Grooming" is a process used by a person who intends to abuse a child. It is about preparing the child for later abuse. Some child abusers use social media and live streaming to find and meet children. Abusers often use sophisticated methods to gain a child's trust and lure them into a world of secrecy, typically seeking to isolate them from sources of support such as friends, family or parents. The result of this "grooming" process is that children can feel personally responsible for the communication and the abuse that has taken place. Children often find it very difficult to ask for help or to tell anyone what is happening to them.

Some children may not be aware that they are being "groomed". Others may raise an issue in an oblique or tentative way which may make it hard for a non- expert to identify. The frequency of "grooming" behaviour should not be exaggerated, but the key is to refer any incident of suspected "grooming" to the BBC Safeguarding Team ^[7] immediately who will be responsible for reporting it to the appropriate authorities. This team works to an escalation protocol for suspected "grooming", and other serious online risks to children, which has been agreed with the Child Exploitation and Online Protection Centre ("CEOP") and the NSPCC. The divisional Working with Children Adviser should also be informed. A list of BBC nominated advisers can be found on the Safeguarding site.^[8]

If the Child Exploitation and Online Protection Centre or any other legitimate authority then ask for more personal information, the request should be referred to Programme Legal Advice and to Editorial Policy before responding.

It should also be possible for users of the BBC site to report suspected grooming incidents directly to CEOP.

Cyber Bullying

Bullying is the most common form of behaviour that children and young people complain about online.

Cyber bullying is hard to get away from as it follows children everywhere into their personal online spaces. Cyberbullies spread their messages instantly to a very wide audience and they can often do this without identifying themselves.

Pre-moderation of BBC spaces designed for children will help protect our users from cyber bullying which is in breach of the House Rules and can usually be dealt with and escalated in the normal way.

But where a content producer is alerted to a serious case of cyber bullying, for example where the bullies set up a hate site (which may not be on BBC Online) to victimise a named individual, they should refer the case to the BBC Safeguarding Team ^[9] immediately who will be responsible for reporting it to the appropriate authorities. The divisional Working with Children Adviser should also be informed. A list of BBC nominated advisers can be found on the Safeguarding site.^[10]

Reporting Child Sexual Abuse Images

• If a BBC person finds that a child sexual abuse image or video has been uploaded or emailed or otherwise sent by a member of the public to a BBC electronic space, they should contact the BBC Safeguarding Team ^[11] immediately. The Safeguarding team will be responsible for reporting it to the Child Exploitation and Online Protection Centre.

The BBC person should not delete the material, nor save it to a shared space nor forward nor share it onwards until advised to do so by the relevant agency.

If a BBC person finds such material on a non BBC space, they should report it direct to the Internet Watch Foundation ^[12].They should not delete the material, nor save it to a shared space nor forward nor share it onwards until advised to do so by the relevant agency. Staff should also alert their manager to the incident immediately. The Safeguarding team^[13] can advise further.

The Internet Watch Foundation operates a hotline reporting system for anyone to report child sexual abuse images hosted anywhere in the world.

Moderators, Hosts and Statutory Checks

Moderators, whether in house or employed by an external commercial company, must be appropriately vetted through the Government's Disclosure and Barring Service, which requires anyone coming into regular contact with children under 18 to be checked. Similar processes apply in Scotland and Northern Ireland.

The Working with Children site from Safeguarding has more details.^[14]

Part 2: Risk, Privacy And Consent

Personal Information

Be very careful about how much personal information is collected from children. The Information Commissioner's Code of Standards for children says that only the minimum amount of personal data needed to provide the elements of a service in which a child is actively and knowingly engaged should be collected and retained. Children should be given separate choices over which elements they wish to activate.^[15]

Take advice where necessary from the Information Rights team who can also advise on relevant privacy notices in language appropriate to the age of the children the content is aimed at.

Be particularly careful about how much is revealed about children on any BBC site. When publishing personal information about children online, only information which is editorially necessary should be selected. Be very sensitive to concerns that publication of too much information could put a child, particularly a younger one, at risk. Combinations of written and visual information are a particularly sensitive area. Editorial Policy can advise about what information it might be suitable to reveal:

• where children are invited to send information about themselves, for example a name and email address to enter a competition, it should be explained why it is needed in language which children can understand.
• it is particularly important that younger children should not get into the habit of easily revealing particularly sensitive personal details about themselves or their family on the Internet.
• any information children send should only be used for the purpose for which it was sent.
• it should be retained securely and only for as long as is needed.
• it should not be revealed to a third party, unless they are a contractor or independent production company working for the BBC to deliver the programme or service. If they are, their involvement should be explained in language a child can understand
• Any personal information must be stored and disposed of according to the BBC data protection policy ^[16]

If in any doubt seek advice from Information Rights.

The Guidelines say:

(See Editorial Guidelines 9.4.28)

Parental Consent

The age of consent in Data Protection Law in the UK for processing personal data has been set at 13. However the Editorial Guidelines state that parental consent should normally be sought before interviewing anyone under the age of 16, or otherwise involving them in output. For those aged 16 and 17 it may still be appropriate to seek parental consent, depending on the circumstances of the young person and the nature of the programme and contribution, including whether the content is sensitive or the contributor could be considered vulnerable.

(See Editorial Guidelines 9.4.3 – 9.4.11)

Where content is submitted to the BBC by children under 16 through BBC functionality or signed in services, parents will normally have given upfront consent for the activity. Be aware that when relying on parental consent, legally, parents will then still have the right to withdraw that consent. This should be made clear to parents in any communications sent to them.

Where content includes other children under 16 their parents or legal guardians should also be contacted for their consents. In some cases, it may be appropriate for a school to provide consent for children depending on the nature of the editorial content and how it is obtained.

Factors to consider when deciding what form of consent may be appropriate:

• the amount and sensitivity of the information
• the age and maturity of the child. Will they understand what is going to happen to the information or the contribution we want them to send?
• their expectations. Use must be in line with what they expect to happen with their personal details in any content they provide to the BBC
• the sensitivity of the information
• the risks associated with sending the information or publishing the content. What is the likelihood of any adverse effects for the child?
• the editorial context

Editorial Policy can provide specific advice on securing parental consent depending on the proposition.

On occasion, with careful planning and a high level of transparency about the scope, it may be appropriate to ask a parent to give the BBC ongoing verifiable parental consent to their child supplying personal information or user generated content up to a certain level or category over a period of time. Content makers might then only have to go back to the parent again for additional consent about new information or user generated content at a more sensitive level or category, within that period of time. It should be easy for a parent to revoke an ongoing level or category of such consent at any time. Such an arrangement would require the specific approval of Information Rights and Editorial Policy.

To help children protect themselves online, there are social media guidelines templates to send to parents and young contributors on the Working with Children site from Safeguarding.^[17]

Part 3: Content

Moderation of User Generated Content

Special care should be taken to mitigate risk around content, contact and conduct when running message boards designed to appeal to children.

The Editorial Guidelines state that:

(See Editorial Guidelines 17.4.56 – 17.4.63)

Online spaces which publish pictures or video or other digital content from members of the public are usually pre-moderated.

Every online space must be able to implement a swift, robust and appropriate escalation strategy if, for example, illegal or harmful material is posted or if illegal conduct is suspected. See referrals in the Introduction earlier.

(See Editorial Guidelines 17.4.58 – 17.4.59)

On some occasions, it may not be appropriate to publish a message, even though it does not break the House Rules, because the content is very personal or the child is in distress. It may then be appropriate to offer suitable online support or helpline information.

(See Editorial Guidelines 15.4.28)

BBC moderators will not post messages containing personally identifiable information such as email addresses, social media usernames or phone numbers. Where a child under 13 is clearly identified as having posted an email address on a BBC space which is not designed for children, the moderator will remove the message. 

Search

Where the BBC offers online search specifically for children, each site and associated subsite must be suitable.

Sites selected by the BBC as being suitable for children should not include unmoderated comments, private messaging features, or dynamic advertising. All sites should be regularly reviewed for continued inclusion in the service.

Users should see an interstitial which makes it clear that they are about to leave the BBC site and offers them the choice of going on or returning to the BBC site.

Users should be able to alert the editorial owner of the BBC search engine if they find an approved site which contains harmful or inappropriate material. See referrals in the Introduction earlier.

While the selection and evaluation of suitable sites is done by BBC editorial staff, technical measures may also help. For example, automated keyword alerts may help to alert the editorial owner of the search engine to any significant changes to an approved site.

Links

The same principles apply to the selection of individual external links from pages aimed at children (eg. CBBC pages) as to the selection of external links to be included in any search services specifically for children (eg CBBC Search) - see above.

Links on global navigation pages which appear on pages designed for children should be suitable for a general audience.

For an audience of children, we should not link to any sites whose minimum age for participation is 13 or more.

(See guidance: Links and Feeds)

Where programmes or sites designed for children are featuring difficult stories or issues which may require online support including links to external charities, CBBC can advise on which external sites are appropriate for children. BBC Action Lines Homepage features a permanent BBC Bitesize Action Line for Young People.

1. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
2. [email protected], See Safeguarding Contact Use site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
3. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
4. See Corporate Investigations site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
5. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
6. See Corporate Investigations site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
7. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
8. Working With Children Advisors. ↩
9. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
10. Working With Children Advisors. ↩
11. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
12. Internet Watch Foundation. ↩
13. [email protected], See Safeguarding Contact Us site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
14. See Safeguarding/staff checks on Gateway. ↩
15. See Age Appropriate Design: a Code of Practice. ↩
16. See Data Protection Handbook: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩
17. See Resources/Documents on the Safeguarding site: available on Gateway for BBC staff or via commissioning editors for independent producers. ↩