ONLINE SAFETY POLICY

Next Review Date: September 2028, or as necessary

1. Introduction and Purpose

Digital technology is part of everyday life at CEDEC International Schools, supporting teaching, learning and communication across all four campuses. Alongside its benefits, the school recognises that the internet and connected devices carry risks to children's safety and wellbeing, and that keeping students safe online is an integral part of the school's wider safeguarding duty of care.

This policy sets out how CEDEC International Schools promotes the safe and responsible use of technology by students, staff, parents/carers and visitors, and how the school prevents, identifies and responds to online safety incidents.

This policy should be read alongside the school's:

•      Child Protection and Safeguarding Policy

•      Behaviour Policy

•      Anti-Bullying Policy

•      Acceptable Use Policy (students)

•      Staff Code of Conduct

•      Email Usage Policy

•      Online Learning Policy

2. Legal and Regulatory Context

This policy has been developed with reference to the legal and regulatory framework applicable to schools operating in Lagos State, Nigeria, including:

•      The Child's Rights Act 2003 (Federal) and the Lagos State Child Rights Law 2007

•      The Cybercrimes (Prohibition, Prevention, etc.) Act 2015

•      The Nigeria Data Protection Act 2023

•      The Violence Against Persons (Prohibition) Act 2015, where applicable

3. Scope

This policy applies to all students, staff (teaching and non-teaching), Governors, and visitors across all four CEDEC campuses, and covers the use of school-owned and personal devices, networks and platforms while on school premises, on school transport, at school-organised off-site activities, and in any online interaction connected to the school (e.g. school-run social media, school email, the school portal).

4. Roles and Responsibilities

4.1 Governors

The Governors have overall strategic responsibility for online safety and receive regular updates on online safety incidents, trends and the school's technical safeguards.

4.2 Head of School (Kindergarten and Primary) and Principal (Secondary)

The Head of School and the Principal are responsible for the day-to-day implementation of this policy on their respective campuses, for ensuring staff are appropriately trained, and for ensuring online safety incidents are handled consistently with this policy.

4.3 Designated Safeguarding Lead (DSL)

Each campus has its own Designated Safeguarding Lead. The DSL is the first point of contact for any online safety concern with a child-protection dimension (for example, a student being contacted inappropriately online, cyberbullying, exposure to harmful content, or concerns about a student's online behaviour). The DSL leads the school's response to such incidents and determines whether escalation to external agencies is required.

4.4 IT Team

Each campus has an IT team representative. The IT team is the first point of contact for technical issues (e.g. device faults, portal or email access problems, connectivity). Where an online safety incident has a technical dimension — such as the need to preserve evidence, block access, or review system logs — the DSL will involve the IT team representative as part of the response, but the IT team is not the first point of contact for concerns with a child-protection dimension; that route is always the DSL.

4.5 Teaching and Support Staff

All staff are responsible for following the Staff Code of Conduct and Email Usage Policy, for modelling safe and professional online behaviour, for delivering online safety education as part of the PSHEE curriculum, and for reporting any online safety concern to the campus DSL without delay.

4.6 Students

Students are expected to follow the Acceptable Use Policy and to tell a trusted adult if they see something online that worries or upsets them, or if someone online makes them feel unsafe.

4.7 Parents/Carers

Parents and carers are asked to support the school's approach to online safety at home, to engage with the guidance the school shares, and to raise any concerns about their child's online experience, whether arising in or out of school, with the campus DSL.

5. Education and Training

5.1 Students

Online safety is taught as part of the PSHEE curriculum in every class, covering age-appropriate topics such as safe and responsible use of the internet, recognising and responding to online risks, digital wellbeing, and respectful online communication.

5.2 Staff

All staff receive online safety training as part of induction and on an ongoing basis, covering: how to recognise the signs that a student may be at risk online, how to respond to and report a concern, and their own responsibilities under the Staff Code of Conduct and Email Usage Policy.

5.3 Parents/Carers

The school shares online safety guidance with parents/carers through the school portal and school communications, to support a consistent approach between school and home.

6. Acceptable Use

Detailed rules governing students' use of school systems and devices are set out in the school's Acceptable Use Policy. Detailed rules governing staff conduct online, including use of the school portal, work email and professional social media use, are set out in the Staff Code of Conduct and the Email Usage Policy. Rules specific to online/remote learning are set out in the Online Learning Policy.

Breaches of acceptable use are handled in accordance with the Behaviour Policy (for students) or the Staff Code of Conduct (for staff), as appropriate.

7. Technical Safeguards

7.1 Accounts and Access

All staff are provided with a school work email address and access to the school portal. Access to school systems is granted on a role-appropriate basis.

7.2 Filtering and Monitoring

The IT team is in charge of filtering and monitoring across all devices used in school, and all platforms (portal, email).  All reviewed filtering/monitoring reports are submitted to the head of school daily. All staff are responsible for in-class supervision of student device and internet use.

7.3 Internal Staff Communication (WhatsApp)

The school operates a staff WhatsApp group for informal, staff-internal communication only. This platform is not used to communicate with parents or students, and must not be used for that purpose. Staff must not use personal messaging apps, including WhatsApp, to contact students individually under any circumstances.

7.4 Devices

Staff members can bring their devices into the school, but they are subject to this policy while within the school premises. Students are permitted to bring electronic devices that have been linked to parents, according to the Acceptable Use Policy.

8. Images, Video and Communications

8.1 Consent for Images

Parental/carer consent is obtained before images or video of students are used by the school, in line with the school's admissions and consent processes. Staff members are not permitted to take pictures of students on personal devices.

8.2 School Social Media

The school maintains official Facebook and Instagram accounts, which are school-run (not managed by individual teachers). Access to post on these accounts is restricted to authorised staff, and content is reviewed before publication to ensure it does not compromise student safety or privacy (for example, avoiding identifying information alongside images of students).

8.3 Staff–Parent and Staff–Student Communication

Approved channels for staff communication with parents/carers are: telephone, the school portal messenger, and school email addresses. Approved channels for staff communication with students are limited to school systems (the school portal and school email), in line with the Staff Code of Conduct. Personal phone numbers, personal social media and personal messaging apps must not be used to contact parents or students.

9. Data Protection

This section sets out the school's baseline commitments regarding personal data processed in connection with online safety:

•      Personal data (including safeguarding records relating to online safety incidents) is stored securely and access is restricted to those who need it

•      Personal data is retained only as long as necessary and in line with applicable record-retention requirements

•      Data is processed in accordance with the Nigeria Data Protection Act 2023

10. Responding to Online Safety Incidents

10.1 Reporting Route

The school operates two distinct reporting routes:

•      Technical/IT issue with no safeguarding dimension (e.g. device fault, access problem) should be reported to the IT team representative on your campus.

•      Any online safety concern with a child-protection dimension (e.g. cyberbullying, inappropriate contact, exposure to harmful content, concerning student behaviour online) should be reported immediately to the campus Designated Safeguarding Lead.

Where an incident with a child-protection dimension also has a technical component (e.g. evidence needs to be preserved, or access needs to be blocked), the DSL will bring in the IT team representative as part of the response. Note that the IT team is never the first point of contact for such concerns.

10.2 Handling the Incident

On receiving a report, the DSL will:

·       listen to and record what has been reported;

·       take any immediate steps needed to safeguard the student(s) involved;

·       determine whether the matter is illegal in nature and requires referral to external authorities

·       determine whether the matter should be handled internally under the Behaviour Policy; and record the incident and the action taken.

10.3 Recording

All online safety incidents with a safeguarding dimension are recorded by the DSL in the school's safeguarding records. A safeguarding concerns form should be filled for this incident

11. Monitoring and Review

This policy is reviewed at least annually, and sooner if there is a significant change in technology use, a new legal or regulatory requirement, or following an incident that indicates the policy needs updating. Review is led by the Head of Safeguarding, Head of School, the Principal, and the IT team, and is reported to the Governors.