If you have a concern that a child or young person is at risk of harm, you should refer this to your nominated Child Protection Policy Manager. However, if you suspect a child is at immediate risk of harm and the nominated manager cannot be contacted immediately, the police should be alerted at once.
See Guidance Note on Working with Children and Young People as Contributors for more details on the BBC Child Protection Policy.
However, there are some online risks which are either not covered in the Policy or only covered in outline. See below for detailed guidance on how to deal with them.
"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 public interactive spaces 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. Abusers might send adult pornography to children in an attempt to lower their sexual inhibitions. Alternatively, they might persuade children to send them sexual images of themselves and use them to make the child feel guilty and ashamed or to blackmail or bully them into going further. In some cases, communication with a child may involve no explicit sexual content. It is aimed at simply gaining the child's trust and confidence, for example by befriending a child who is being bullied online.
The result of this "grooming" process is that children can, and often do, 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. While we should not exaggerate the frequency of "grooming" behaviour, the key is to refer any incident of suspected "grooming" promptly to the CBBC Interactive Executive Management Team, 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 team can be contacted via the internal global address list under CBBC Interactive Executive Management Team. A member of the team will be available on the phone on call until 9 pm every day. Where necessary, the number can also be accessed externally via the BBC switchboard.
When a content producer refers a report of suspected grooming on to the CBBC Interactive Executive Management Team, they should also tell their nominated Child Protection Policy Manager. 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.
Bullying is the most common form of behaviour that children and young people complain about online.
Children distinguish less and less between their lives offline and online so cyber bullying may not be a very useful concept for them. But it does highlight the fact that new forms of communication bring new opportunities for misuse as well as new benefits. Unlike other traditional forms of bullying, cyber bullying can follow children and young people into their private spaces and outside school hours so it may be much harder to get away from. Cyber bullies can spread their messages instantly to a very wide audience and they can often do this without identifying themselves.
Some examples of cyber bullying:
Using social networking sites To post nasty or threatening comments on someone's profile To set up fake profiles or hate sites to humiliate the victim To send chain emails and attachments or SMS messages with intent to hurt To hack into someone's account and send offensive messages to others
Filming, texting, or using Bluetooth to circulate offensive pictures
Using Instant Messenger to coerce others into "ganging up" online on an individual
Pre-moderation of BBC spaces designed for children will help protect our users from cyber bullying. In other BBC spaces, active hosting can help to encourage an atmosphere where bullying or harassment is not acceptable. Bullying or harassment on BBC spaces are likely to be in breach of the House Rules and can usually be dealt with and escalated in the normal way. See Guidance Note on Moderation, Hosting, Escalation and User Management.
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 promptly to the CBBC Interactive Executive Management Team who will report it to the appropriate authorities. They should also tell their nominated Child Protection Policy Manager.
Reporting Child Sexual Abuse Images
If a BBC 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 BBC electronic space, they should contact the CBBC Interactive Executive Management Team, who will be responsible for reporting it to the Child Exploitation and Online Protection Centre.
The BBC 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 BBC person finds such material on a non BBC space, they should report it direct to the Internet Watch Foundation at www.iwf.org.uk
The Internet Watch Foundation operates a hotline reporting system for members of the public and IT professionals to report their exposure to specific forms of potentially illegal content online. These are:
child sexual abuse images hosted anywhere in the world
criminally obscene content hosted in the UK
incitement to racial hatred content hosted in the UK
If a BBC person finds that criminally obscene content or incitement to racial hatred have been uploaded or emailed or otherwise sent by a member of the public to a BBC electronic space, (or if a link to such content has been sent to us to publicise the content rather than to report and remove it) they should contact the BBC Investigation Service by phone or email with details of the incident for advice. The BBC person should not delete the material or save it to a shared space. Staff should also alert their manager to the incident.
If a BBC person finds such material on a non BBC space, they should report it direct to the Internet Watch Foundation as above.
Moderators, Hosts and Statutory Checks
BBC interactive spaces have moderators and usually have hosts. Moderation improves the user experience by removing content which breaks the site's House Rules. It also provides additional safety for children's interactive spaces by removing material which might create additional content, conduct or contact risks e.g. by avoiding publication of a child's mobile phone number or of bullying messages from another child. Hosts can improve the user experience for children by welcoming new members, encouraging positive behaviour and defusing disputes before they get out of hand.
While online moderators and hosts don't meet the users of these interactive spaces face to face, they do have virtual contact with them, they may be in a position of trust and authority over them and they may also have access to personal information about them. This means that individuals should be properly recruited, trained and supervised so that unsuitable candidates are identified and excluded, before children are put at risk.
In addition, the Safeguarding Vulnerable Groups Act 2006 introduces a new Vetting and Barring scheme for people who wish to work with children , including anyone "moderating a public electronic interactive communication service which is likely to be used wholly or mainly by children". The Independent Safeguarding Authority will maintain two new barred lists and the above roles will require an Enhanced Criminal Records Bureau check against these lists. There will be criminal penalties for barred individuals who seek or undertake work with children and for employers who knowingly take them on.
The age of a "child" under this law includes anyone under 18 and the Act appears to apply to sites where a majority of that site's users are under 18.
Independent companies working for the BBC in this area will need to comply with these requirements.
Information Policy and Compliance can offer more advice.