Editorial Policy issues
This guidance note relates to the following Editorial Guidelines:
- Children and Young People as Contributors
See Editorial Guidelines Section 9: Children and Young People as Contributors
- Harm and Offence
See Editorial Guidelines Section 5: Harm and Offence
- Privacy
See Editorial Guidelines Section 7 Privacy - Competitions, Votes and Interactivity
See Editorial Guidelines Section 17 Competitions, Votes and Interactivity
See also the Guidance Note on Working with Children and Young People as Contributors, which covers working face to face with children but does not deal with online issues.
Key points
- Any online safeguarding concerns, whether related to online grooming or child abuse images, must be referred to the Head of Safeguarding, Policy and Compliance [1] immediately.
- In the course of our work if we suspect a person under 18 may be at risk, or we are alerted to a child welfare issue, the situation must be referred promptly to the divisional Working with Children Adviser [2] or, for independent production companies, to the commissioning editor. If we are concerned about an adult, including a member of staff, working with a child the situation must be referred promptly to the 大象传媒 Safeguarding Lead [3] or Head of 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 大象传媒 Safeguarding Lead or, for independent production companies, the commissioning editor should be informed urgently.
- We should apply the principles of the 大象传媒 Child Protection Policy in our dealings with children and young people. [5]
Where a content producer is alerted to a serious case of cyberbullying, they should refer the case to the Head of Safeguarding, Policy and Compliance [6] immediately.
If you find that child sexual abuse images or video have been sent by whatever means to a 大象传媒 electronic space, you should contact the Head of Safeguarding, Policy and Compliance [7] immediately. - If you find that material which is criminally obscene or incitement to racial hatred have been sent by whatever means to a 大象传媒 electronic space, you should contact the 大象传媒 Investigations Service [8].
- People who moderate or host should be properly recruited, trained and supervised and have the appropriate formal checks
- We should be very careful about how much personal information we collect from children and particularly careful about how much we reveal about them on any 大象传媒 site
- When we ask children for personal information or user contributions, we should consider what degree of parental consent is appropriate
- Messages and other user contributions on children鈥檚 sites will normally be checked by a moderator before publication.
Guidance in full
- Introduction
- Part 1: Online Child Safety
- - 大象传媒 Child Protection Policy
- - Suspected 鈥済rooming鈥�
- - Cyber-bullying
- - Reporting child sexual abuse images
- - Moderators, Hosts and Statutory Checks
- Part 2: Risk, Privacy and Consent
- Part 3: Content
- - Moderation
- - Search
- - Links
Introduction
The Editorial Guidelines state that we must safeguard the welfare of children and young people who contribute to our content. We must take due care over their physical and emotional welfare 鈥� their welfare must take priority over any editorial requirement.
(See Editorial Guidelines Section 9: Children and Young People as Contributors: Introduction 9.1)
We should take care 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 鈥済rooming鈥�.
This Guidance Note is designed to give advice to content producers who work with children and young people online. It deals with safety, privacy, consent, conduct and content issues including user contributions. It should also be useful for content producers who don鈥檛 deal regularly with children and young people online, helping them to identify where prompt action is necessary.
Part 1: Online Child Safety
鈥淕rooming鈥� 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鈥檚 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 鈥済rooming鈥� 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 鈥済roomed鈥�. Others may raise an issue in an oblique or tentative way which may make it hard for a non expert to identify. While we should not exaggerate the frequency of 鈥済rooming鈥� behaviour, the key is to refer any incident of suspected 鈥済rooming鈥� promptly to the Head of Safeguarding, Policy and Compliance [9] immediately who will be responsible for reporting it to the appropriate authorities. This team works to an escalation protocol for suspected 鈥済rooming鈥�, and other serious online risks to children, which has been agreed with the Child Exploitation and Online Protection Centre (鈥淐EOP鈥�) and the NSPCC.
When a content producer refers a report of suspected grooming on to Head of Safeguarding, Policy and Compliance [10] they should also tell their divisional Working with Children Adviser [11]. 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 大象传媒 site to report suspected grooming incidents directly to CEOP.
Bullying is the most common form of behaviour that children and young people complain about online.
Cyber bullying is much harder 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 大象传媒 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 大象传媒 Online) to victimise a named individual, they should refer the case promptly to the Head of Safeguarding, Policy and Compliance [12] immediately who will report it to the appropriate authorities. They should also tell their the divisional Working with Children Adviser [13].
Reporting child sexual abuse images
If a 大象传媒 person finds that a child sexual abuse images or video have been uploaded or emailed or otherwise sent by a member of the public to a 大象传媒 electronic space, they should contact the Head of Safeguarding, Policy and Compliance [14] immediately who will be responsible for reporting it to the Child Exploitation and Online Protection Centre.
The 大象传媒 person should not delete the material, save it to a shared space or forward it onwards until advised to do so by the relevant agency. They should tell their nominated Child Protection Policy Manager.
If a 大象传媒 person finds such material on a non 大象传媒 space, they should report it direct to the Internet Watch Foundation [15]. They should not delete the material or save it to a shared space. Staff should also alert their manager to the incident.
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
All chatrooms and message boards on 大象传媒 platforms that are designed for children under 13 must be pre-moderated.
Moderators, whether in house or employed by an external commercial company, must be appropriately vetted through the Government鈥檚 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.
Information Rights can offer more advice.
Part 2: Risk, Privacy and Consent
We should be very careful about how much personal information we collect from children, taking advice where necessary from the Information Rights team. We should also be particularly careful about how much we reveal about them on any 大象传媒 site. When we publish personal information about children online, we should select information which is editorially necessary. We should 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 we invite children to send us information about themselves, for example a name and email address to enter a competition, we should explain why we need it 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 to us should only be used for the purpose for which it was sent.
- it should be retained securely and only for as long as we need it.
- it should not be revealed to a third party, unless they are a contractor or independent production company working for the 大象传媒 to deliver the programme or service. If they are, we should explain their involvement in language a child can understand
If in any doubt seek advice from Information Rights.
The age of consent in Data Protection Law in the UK for processing personal data has been set at 13. However there are additional editorial policy considerations that require parental consent for our use of such content for children under the age of 18.
Where content is submitted to the 大象传媒 by children under 13 through 大象传媒 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 13 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.
Where content features material from 13-17 year old children and young people, parental consent may not necessarily always be required unless the content is controversial or sensitive.
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. Our use must be in line with what they expect to happen with their personal details any content they provide to the 大象传媒
- 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
Information Rights can provide specific advice depending on the proposition and Editorial Policy may also be consulted. As a guide, here are four examples covering a range of consent methods
Example 1 - Blue Peter Newsletter
If a child wants to sign up to a routine Blue Peter email newsletter, we can be confident that all the content, suggestions and links in each edition will be suitable for children and we can be confident that Blue Peter will only use that email address for that purpose. The only information we are collecting from the child is their email address. So a prompt to the child to ask their parent for permission, with a requirement to complete the tick box before they can proceed, may be appropriate in these circumstances. It reminds the child that they should ask their parents for permission.
Example 2 鈥� Doctor Who Comic Maker
Children were invited to make and publish their own Doctor Who comic strip online out of a kit of parts provided online by the 大象传媒. This was personalised by the child sending in a picture of their own face, to create an avatar which was added to their comic strip.
Parents with a separate email address to their children were able to consent to their children sending us their picture, by email, and they did so in very large numbers. Random phone checks confirmed the validity of the consent. Other parents signed and posted a consent form downloaded from the site.
Example 3 - Child as online video producer
If we invite a child to make and send us a video for publication online in which they and their friends appear, we will need verifiable parental consent. Verifiable parental consent means explicit consent direct from a child鈥檚 legal guardian, usually in writing. We will want to be confident that the parent of the filmmaker has agreed to the child sending us the video and at the very least that the parent has confirmed that they have the consent of the parents of the other children who are clearly identifiable in the video as well.
By the same token, if we ask for a child to send us their mobile phone number, we are likely to need some form of verifiable parental consent. This is sensitive personal information in part because if you have the number, you can get in touch directly with that child.
Example 4 - Bugbears
Where the editorial proposition is such that children may be reluctant to register if they have to obtain their parent鈥檚 consent and the risks of publication are minimal, we may exceptionally decide not to collect parental consent.
For example, C大象传媒鈥檚 Bugbears animations used the voices of children, who recorded themselves. The animations were designed to allow children to express their fears and anxieties (which could have included problems with their parents) and how they dealt with them. The site did not identify the children who took part and it gave them the option of disguising their voices. Crucially, every Bugbear was carefully checked before publication so that if there was a risk of a child being identified through the detail of what they said or they were too distressed, we did not publish that contribution.
On occasion, with careful planning and a high level of transparency about the scope, it may be appropriate to ask a parent to give us 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. We 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 Working with Children site from Safety, Security and Resilience [16].
Part 3: Content
Moderation of user generated content
We should take special care to mitigate risk around content, contact and conduct when running message boards designed to appeal to children.
大象传媒 spaces designed to appeal to children and young people are usually pre-moderated. Any proposal to use any other form of moderation for children and young people will need to demonstrate that it offers a high level of child protection and must be referred to Editorial Policy.
Spaces which publish pictures or video from members of the public are usually pre-moderated. Any proposal to use any other form of moderation must be referred to Editorial Policy.
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. We may then wish to offer suitable online support or helpline information.
大象传媒 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 大象传媒 space which is not designed for children, the moderator will remove the message.
Where the 大象传媒 offers online search specifically for children, each site and associated subsite must be suitable .
Sites selected by us 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 大象传媒 site and offers them the choice of going on or returning to the 大象传媒 site.
Users should be able to alert the editorial owner of the 大象传媒 search engine if they find an approved site which contains harmful or inappropriate material.
While the selection and evaluation of suitable sites is done by 大象传媒 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.
The same principles apply to the selection of individual external links from pages aimed at children (eg C大象传媒 pages) as to the selection of external links to be included in any search services specifically for children (eg C大象传媒 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, C大象传媒 can advise on which external sites are appropriate for children.
[1] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[2] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[3] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[4] See Investigations site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[5] 大象传媒 Child Protection Policy
[6] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[7] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[8] See Investigations site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[9] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[10] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[11] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[12] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[13] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[14] See Working with Children advisers site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
[16] See Documents and Forms on the Working with Children site: available on Gateway for 大象传媒 staff or via commissioning editors for independent producers
Last updated July 2019