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Digital Safeguarding Policy

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DIGITAL SAFEGUARDING POLICY

SCHOOL AIMS

  • To ensure a supportive, happy and secure environment for learning.
  • To encourage the physical and emotional well-being of each individual.
  • To use innovative pedagogy and technology to enrich learning.
  • To empower students and staff to navigate Artificial Intelligence (AI) safely and responsibly, fostering ethical engagement and critical thinking.
  • To encourage internationalism, providing students with the skills, dispositions, and knowledge to participate in an increasingly interconnected world.

RATIONALE

At Discovery Bay International School, safeguarding our students and staff is our main priority. With technology playing such an essential role in all our classrooms, all members of the school community must be responsible for safeguarding our students as they use digital resources.

PURPOSE

  • Set out the fundamental principles expected of all members of the Discovery Bay International School community concerning the use of technologies.
  • Safeguard and protect all students and staff.
  • Assist school staff working with children safely and responsibly with technologies and monitor their standards and practices.
  • Set clear expectations for behaviour and/or codes of practice for the responsible use of technology (including AI) by the whole school community for educational, personal, or recreational purposes.
  • Have clear structures to deal with online abuse, such as online bullying.
  • Ensure that all members of the school community know that unlawful or unsafe behaviour is unacceptable and that, where appropriate, disciplinary or legal action will be taken.
  • Minimise the risk of misplaced or malicious allegations against adults working with students.


SCOPE

This policy applies to all members of Discovery Bay International School community (including staff, students, volunteers, parents/carers, and visitors) who have access to and are users of Discovery Bay International School IT systems, both in and out of school.

RISKS TO OUR SCHOOL COMMUNITY

The main areas of risk for our school community can be summarised as follows:

Artificial Intelligence

  • Inputting sensitive, personal, or identifiable information related to members of the DBIS community and DBIS itself into public generative AI models
  • Engaging in the use of chatbots beyond a specific assigned task (i.e. as a companion)
  • Creating deepfakes, including circulating such content or threatening others with such actions

Content

  • Exposure to inappropriate content
  • Lifestyle websites promoting harmful behaviours
  • Hate content
  • Scams and clickbait
  • Content validation: how to check the authenticity and accuracy of online content


Contact

  • Grooming (sexual exploitation, radicalisation, etc.)
  • Over-reliance on AI chatbots (forming parasocial relationships, etc.)
  • Online bullying in all forms
  • Social or commercial identity theft, including passwords

Conduct

  • Aggressive behaviours (bullying)
  • Privacy issues, including disclosure of personal information
  • Digital Footprint and Online Reputation
  • Health and well-being (amount of time spent online, gambling, body image, peer pressure)
  • Consensual and non-consensual self-generated intimate images and/or videos, including those generated using AI, e.g. deepfakes
  • Copyright (consideration for intellectual property and ownership)


Enterprise AI

As a school, we subscribe to and pay for educational licences to access Google Gemini for Education. In line with their Terms of Service, this ensures that the data we enter into Gemini for Education is not used to train the model itself, nor will it be reviewed by Google. Crucially, this ensures all personal and confidential data stays securely within our own DBIS domain.

Because of these data protection guarantees, staff must never paste personal, confidential, or work-related pupil data into any other unapproved AI model, whether it is a free public version or a paid personal subscription, etc.

This includes, but is not limited to, student names, grades, behaviour notes, SEND details, report comments, and safeguarding concerns. Inputting this sensitive or identifiable information into unapproved generative AI models, even just to "rephrase" a sentence, is strictly prohibited and constitutes a data protection breach and a safeguarding risk

Staff must use only the school-approved enterprise tool; no other AI model may be used with school data (including, but not limited to, student reports, digital media, and SEND documents) without explicit permission from DBIS.

AI Models for teaching and learning

The following is a list of AI models approved by DBIS for teaching and learning. If you wish for a new AI model to be trialled/approved, please reach out via email to the Head of Learning Technologies:

DIGITAL CITIZENSHIP CURRICULUM

Discovery Bay International School has a clear, progressive Digital Citizenship curriculum, which is taught through the Learning for Life and Learning Technologies curriculum and within other curriculum areas where appropriate. This covers a range of skills and behaviours appropriate to age and experience, including provisions for providing background knowledge to AI before students engage with the technology itself. The main aim of this curriculum is to equip students with the necessary knowledge and skills to avoid the risks outlined above.

ROLES AND RESPONSIBILITIES

Each member of our school community has a role to play in safeguarding our students as they use digital technologies.

Students are taught an appropriate Digital Citizenship curriculum that addresses ongoing trends in an ever-evolving technological landscape.

Staff are provided with regular updates as and when major revisions are made to associated policies relating to the use of technology for work purposes.

Examples of staff roles and responsibilities are detailed in the table below:

Role

Key Responsibilities

Head of School

Marc Morris

  • Be adequately trained in offline and online safeguarding in line with statutory guidance and relevant local requirements
  • Lead a ‘safeguarding’ culture, ensuring that online safety is fully integrated with the whole school's safeguarding
  • Take overall responsibility for online safety provision
  • Take overall responsibility for data management and information security, ensuring the school’s provision follows best practices in information handling
  • Be responsible for ensuring that all staff receive suitable training to carry out their safeguarding and online safety roles
  • Be aware of procedures to be followed in the event of a severe online safety incident
  • Ensure suitable ‘risk assessments’ are undertaken so the curriculum meets the needs of our students
  • Receive regular monitoring reports from the Director of IT and the Head of Learning Technologies
  • Ensure that there is a system in place to monitor and support staff who carry out internal online safety procedures, e.g. Director of IT, Head of Learning Technologies
  • Ensure the school council is regularly updated on the nature and effectiveness of the school’s arrangements for online safety
  • Ensure the school website includes relevant information.

Head of Learning Technologies

Nicolas Ng

  • Take day-to-day responsibility for online safety issues and a leading role in establishing and reviewing the school’s online safety policy/documents
  • Promote an awareness and commitment to online safety throughout the school community
  • Ensure that online safety education is embedded within the curriculum
  • Oversee the delivery of the online safety element of the Learning Technologies curriculum
  • Communicate regularly with SLT and the designated Child Protection Lead to discuss current issues, review incident logs and filtering logs
  • Ensure that all staff are aware of the procedures that need to be followed in the event of an online safety incident
  • Ensure that online safety incidents are logged as a safeguarding incident
  • Facilitate training and advice for all staff
  • Oversee any surveys/feedback on online safety issues
  • Be aware of the potential for serious child protection concerns
  • Liaise with the Director of IT

Designated Child Protection Leads

Hannah Tait

Simon Oakley

  • Be aware of the potential for serious child protection concerns.
  • Ensure that online safety incidents are logged as a safeguarding incident
  • Communicate regularly with SLT to discuss current issues and review incident logs

Director of IT

Alisdair Rendell

  • Report online safety-related issues that come to their attention to the Head of Learning Technologies
  • Manage the school’s computer systems, ensuring the school password policy is strictly adhered to, and systems are in place for misuse detection and malicious attack (e.g. keeping virus protection up to date)
  • Ensure the school uses appropriate IT systems and services, including filtered Internet Service
  • Ensure the school’s policy on web filtering is applied and updated on a regular basis
  • Keep up to date with the school’s Digital Safeguarding policy and all other interrelated policies
  • Ensure that the use of school technology and online platforms is regularly monitored and that any misuse/attempted misuse is reported to the online Head of Learning Technologies
  • To ensure appropriate backup procedures and disaster recovery plans are in place
  • To keep up-to-date documentation of the school’s online security and technical procedures

Teachers

  • Embed Digital Citizenship standards in the curriculum
  • Model safe and responsible behaviour in their own use of technology (including AI) at all times, e.g. use of passwords, logging off, use of content, research skills, and copyright.
  • Supervise and guide pupils carefully when engaged in learning activities involving online technology (including extracurricular activities if relevant)
  • Ensure that students are fully aware of research skills and are fully aware of legal issues relating to electronic content, such as copyright laws
  • Lead regular discussions as part of the Learning for Life curriculum to support students
  • Read and adhere to the school’s Code of Conduct
  • Read, understand and adhere to the school’s Acceptable Use Policy.

All staff and volunteers

  • Read, understand and adhere to the school’s Acceptable Use Policy.
  • Read and adhere to the school’s Code of Conduct
  • Report any suspected misuse or problem to the Head of Learning Technologies
  • Maintain an awareness of current online safety issues and guidance e.g. through CPD
  • Model safe, responsible and professional behaviours in their own use of technology

Students

  • Read, understand, sign and adhere to the student Acceptable Use Policy annually
  • Understand the importance of reporting abuse, misuse or access to inappropriate materials
  • Know what action to take if they or someone they know feels worried or vulnerable when using online technology
  • Understand the importance of adopting safe behaviours and good online safety practices when using digital technologies out of school, and realise that the school’s Digital Safeguarding Policy covers their actions out of school
  • Contribute to the annual confidential student survey that gathers information about their online experiences

Parents/Carers

  • Read, understand and promote the school’s Acceptable Use Policy with their child/ren
  • Consult with the school if they have any concerns about their children’s use of technology
  • Support the school in promoting online safety both in school and at home
  • Attend parent information sessions held regularly at the school



INCIDENT MANAGEMENT

While we take every precaution to ensure our students and staff are not at risk when using technology, we understand that digital incidents may still occur. The table below outlines examples of incidents that may occur at Discovery Bay International School with guidelines on how those incidents should be addressed and by whom:

Example of Incident

Person Responsible

Outcome

Student inadvertently accesses inappropriate content online in school.

Teacher
Director of IT
Head of LT

  • The teacher reminds the student that when they discover inappropriate content online, they should immediately close the page and report it to an adult.
  • The teacher should then report the content to the Director of IT, who will liaise with the Head of Learning Technologies to ensure the IT team immediately blocks the website containing it.
  • If the content viewed could be considered upsetting or severe, parents will be made aware.

Student intentionally accesses inappropriate content online.

Teacher
SLT Member
Director of IT
Head of LT
Year Group Leader

  • The teacher speaks with the student about this inappropriate behaviour using the Acceptable Use Policy as a reference point.
  • The incident is referred to the Year Group Leader, who will also speak with the student.
  • Depending on the nature of the content accessed and the child's age, parents may also need to be informed.
  • Students will lose access to technology for an agreed-upon period to reflect.
  • The Director of IT will block the website that the student accessed.
  • The Head of Learning Technologies will assess for future prevention.
  • A report is filed on iSAMS.

A student has gained access to another student’s password and used it.

Teacher
Head of LT
Director of IT
SLT member

  • The teacher refers the students to the Head of LT.
  • The Head of LT will speak with the student whose password has been stolen, reminding them of the importance of password protection and offering guidance on how to prevent this from happening in the future.
  • The student’s password will be reset by the IT team.
  • The student who used the password will meet with the Head of LT to discuss the reason the password was taken and used.
  • If the password was used with malicious intent, the student will be referred to the appropriate YGL and the appropriate SLT member notified.
  • A report is filed on iSAMS.

A student reports that they are being bullied online by another student at the school.

Teacher
SLT Member
Head of Wellbeing
Head of LT

  • The teacher speaks with the student and gathers information to determine the seriousness of the accusation and to collect the name(s) of the students involved.
  • The teacher refers the incident to the Year Group Leader.
  • The Year Group Leader will speak with all involved in line with our Anti-Bullying Policy.
  • A report is filed on the incident in iSAMS.
  • The Head of Learning Technologies and the Head of Wellbeing will assess for future prevention.

A student has downloaded apps and extensions to their school-owned device that are not age-appropriate

Teacher
Head of LT
Director of IT

  • The teacher speaks with the students about why this app has an age limit and reminds them of our agreement not to download such apps, using the Acceptable Use Policy as a reference point.
  • The teacher informs the Head of LT, who ensures that the app or extension is added to our school blacklist for the specific age group.
  • The Director of IT is kept informed of any updates to the blacklist.

A parent has raised a concern that their child has become withdrawn at home and is spending more time online than engaging in real-world activities.

Teacher
Year Group Leader
Head of Wellbeing
Head of LT

  • The parents are invited in to discuss this with the relevant teacher.
  • The Head of LT and/or Head of Wellbeing will support with conversations with parents.
  • The student is offered support from the school counselling service if needed.
  • The Head of Learning Technologies and the Head of Wellbeing will assess for future prevention.

A group of students has been posting images of themselves outside of school engaging in inappropriate behaviour, and this has been reported anonymously to the school.

SLT Member
Year Group Leaders
Head of LT
Parents
Head of Wellbeing

  • The students are referred to their Year Group Leader and reminded that online behaviours can be seen by a wider audience and can negatively affect their own reputation and the school's reputation.
  • Parents are informed of the nature of the incident.
  • The Head of Learning Technologies and the Head of Wellbeing will assess for future prevention.
  • SLT intervention dependent on severity.

A student has admitted that they shared an indecent image of themselves privately, but the image has now been shared with others.

Child Protection Lead
Head of School
Head of Wellbeing
Head of LT
School Counsellor

  • The incident is immediately referred to the designated Child Protection Lead.
  • Parents need to be informed and invited in to discuss with the Child Protection Lead.
  • The staff member should not ask to see any images and should avoid doing so even if somebody tries to show them.
  • The image must not be shared for the purpose of dealing with the incident.
  • The Head of Wellbeing and the Head of Learning Technologies are informed of the nature of the incident, but not necessarily of the names of those involved. If appropriate, additional lessons are added to the Learning for Life cycle for relevant year groups with a specific focus on Sexting.

A student threatens to release a deepfake intimate/inappropriate image of another student unless they are given money (Sextortion/Blackmail).

Child Protection Lead
Head of School
SLT Member
Head of LT
Director of IT
Year Group Leader
School Counsellor

  • The incident must be referred immediately to the designated Child Protection Lead and the Head of School, as it constitutes a criminal offence (blackmail/extortion) and a severe safeguarding breach.
  • The staff member receiving the initial report must not ask to see the image, must not handle or download the deepfake file, and must strictly avoid distributing it.
  • The victim student must be reassured, isolated from the perpetrator, and provided with support from the School Counsellor or Head of Wellbeing.
  • The Head of LT will immediately coordinate with the Director of IT to securely isolate the perpetrator's school-managed accounts or devices, if directed by law enforcement, ensuring that no digital evidence is destroyed and preventing any further transmission of the image.
  • Parents of both the victim and the perpetrator are immediately notified and invited into the school for separate, urgent meetings with the Child Protection Lead and SLT.
  • The school will consult with local law enforcement/police regarding the extortion element and follow their guidance on device management.
  • A comprehensive, high-priority safeguarding report is filed immediately on iSAMS.
  • Following immediate crisis management, the Head of LT and the Head of Wellbeing will assess the incident and update the digital citizenship curriculum, implementing targeted educational sessions for relevant year groups on the dangers, legal implications, and psychological impacts of AI-generated deepfakes and online extortion.


SOCIAL MEDIA

Students at Discovery Bay International School are taught about social networking, acceptable behaviours, and how to report misuse, intimidation, or abuse through our Digital Citizenship Curriculum. Parents are reminded about social networking risks and protocols through a number of parent forums and presentations. Parents are regularly reminded that they need to ask permission before uploading photographs, videos or any other information about other people to social networks.


Last Review: 24.06.2025

Created: 21.02.2025




APPENDIX A - School Policies and Documents Relevant to Digital Safeguarding


Legal Obligations

  • Copyright Policy
  • Personal Data Handling Policy
  • Personal Information Statement

Safeguarding

  • DBIS Code of Conduct
  • Child Protection policy
  • Anti-Bullying Policy

DBIS Standards (Teaching and Learning)

  • Learning Technologies Policy
  • Digital Citizenship Curriculum

Additional documents

There are additional documents related to these policies, which are integral to ensuring the safeguarding of our students:

Conduct agreements:

  • DBIS Community Acceptable Use Policy
  • Student BYOD agreement

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