Digital Safety Policy

1. About this policy

1.1. Digital safety is the responsibility of everyone. This Digital Safety Policy recognises Non-Trivial’s commitment to ensuring the digital safety of our staff, volunteers, participants and anyone who comes into contact online with Non-Trivial and our work.

1.2. Non-Trivial aims to be welcoming, encouraging, and safe for all participants. All Non-Trivial People are therefore required to abide by this Digital Safety Policy on all Non-Trivial virtual platforms and any other virtual platforms that Non-Trivial People use to interact with each other. This Digital Safety Policy identifies the risks of online activity and the steps we are taking to mitigate them. 

1.3. Non-Trivial works with, and comes into contact with, volunteers, staff and participants who may be children and/or adults at risk. Some of our online activities include: holding virtual group sessions between participants and staff, communicating and collaborating via online platforms, holding virtual one-to-one mentoring sessions between staff and participants.

1.4. This purpose of this policy is to:

1. Ensure that the safety and wellbeing of children and adults at risk is paramount specifically when children or adults at risk are using the internet, social media or other online technologies to engage with Non-Trivial’s staff, volunteers and its work;
2. Provide Non-Trivial People with the overarching principles that guide our approach to online safety;
3. Ensure that we operate in line with our values and within the law in terms of how we use online technologies.

1.5. This policy supplements and should be read in conjunction with Effective Ventures Foundation’s Safeguarding Policy and Code of Conduct (Effective Ventures Foundation (“EV UK”) is the legal organisation of which Non-Trivial is a part) and Non-Trivial’s other policies and procedures including our: Code of Conduct; Anti–Harassment and Bullying Policy; and Student Privacy Summary. 

1.6. This policy applies to the use of all electronic devices used to access the internet, including desktop computers, laptops, tablets and smartphones and also any personal devices used to access Non-Trivial’s systems.

2. Definitions 

2.1. Non-Trivial People means persons who interact with, or on behalf of, Non-Trivial, including:- 

1. A child is anyone under the age of 18. 
2. An adult at risk is a person aged 18 years or over who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of themselves, or unable to protect themselves from either the risk of or the experience of abuse, neglect or harm.
3. A member of staff is a person working on behalf of Non-Trivial, including permanent, fixed term or casual contracts.
4. A volunteer at Non-Trivial is someone who: (i) has a defined role with clear tasks and responsibilities; (ii) is unpaid; (iii) is doing something that benefits participants, visitors and/or staff and the wider aims of Non-Trivial.
5. A participant is someone who has been selected to participate in a Non-Trivial programme.
6. A contractor is anyone who arranges or undertakes a contract to perform a service or do a job in relation to any activity of Non-Trivial.  

2.2. For the purposes of this policy, an independent agent is any former Non-Trivial Person, who no longer has any connection with Non-Trivial. Connection is a matter of fact and degree to be assessed on a case by case basis, and will depend on the circumstances. However, where an individual has any ongoing connection to Non-Trivial, they must fully comply with the requirements of this policy.

3. General principles of online behaviour 

3.1. Non-Trivial has a Code of Conduct which we expect all Non-Trivial People to comply with – this applies equally to online and in-person interactions.

3.2. Non-Trivial’s policy is that all electronic interactions between staff, volunteers, participants and others interacting with, and on behalf of, Non-Trivial should take place via our corporately managed online systems and collaboration tools, such as Discord, Slack, Zoom, Google Meet, or by email. Connecting on professional social media (e.g. LinkedIn) is also permitted and encouraged.

3.3. Non-Trivial staff, volunteers, and contractors should not use non-professional social media platforms (e.g. Facebook, Instagram, Whatsapp, or any other non-professional forms of communication such as text messaging) to communicate with participants, children or adults at risk except in the most exceptional circumstances (for example, if communication is needed for some practical purpose and other communication channels are not working or are temporarily unavailable). If this happens, then a report of the incident should be made to Non-Trivial’s Safeguarding Lead, by email (peter@non-trivial.org) or by phone (+44 7 383 842 314).

3.4. During all online interactions, whether on professional or non-professional platforms, Non-Trivial People should be aware of possible imbalances in power or authority and act in line with their obligations under the Anti-Harassment Policy and in accordance with paragraph 5.3 of this policy at all times.

3.5. Individuals who were previously Non-Trivial People may only use non-professional social media platforms to communicate with other individuals where both or all of the individuals concerned are independent agents. There must be a clear disconnection from Non-Trivial before any communications on personal platforms take place.

Example: A previous participant and previous volunteer or staff member, who may have met through activities associated with Non-Trivial, should not communicate via non-professional social media platforms where one or both individuals maintain a role (paid or unpaid) that benefits any members, or the wider aims, of Non-Trivial. 

Example: Two individuals meet and identify a mutual connection at Non-Trivial. However, neither individual has any ongoing connection with Non-Trivial. Both are now independent agents and are therefore outside the remit of the Digital Safety Policy.

3.6. Regardless of which online technology is being used, we expect that Non-Trivial People adhere to the behaviours outlined in this policy to ensure the safety and wellbeing of all participants.

3.7. In addition to the policies mentioned above, we expect Non-Trivial People to comply with the following general principles of online behaviour:

1. Always use our corporately managed online systems and collaboration tools for formal programme-related communications;
2. Maintain a professional level of conduct in your use of online technologies at all times when communicating with anyone with a connection to Non-Trivial;
3. Be respectful, considerate and not use inappropriate, offensive, threatening or suggestive language; 
4. Respect interpersonal boundaries and be appropriately formal in communications;  
5. Do not deliberately browse, download, upload, share or discuss material that could be considered offensive or illegal;
6. Do not send anyone material that could be considered threatening, bullying, offensive or illegal;
7. Do not use online technologies in any way which could:

• breach our obligations with respect to the rules of relevant regulatory bodies;
• breach any obligations contained in those policies relating to confidentiality;
• breach our Code of Conduct or Anti-harassment and Bullying Policy, or EVF’s Safeguarding Policy;
• breach the provisions of the Student Privacy Summary or EVF’s Privacy Policy; or
• breach any other laws.

4. Video/conference calling

4.1. Non-Trivial’s main online conferencing service used for the delivery of its programmes is Discord. This service is used for programme sessions with participants and volunteers, and for any other communications between participants and Non-Trivial People that occur as part of Non-Trivial's activities.

4.2. Where online video/conferencing platforms are being used with participants who are children or adults at risk, Non-Trivial’s Code of Conduct and EV UK’s Safeguarding Policy will also apply.

4.3.
In addition, the following principles should be followed when using video calling/conferencing technology to keep participants safe:

1. All online meetings should be accessed through work-based accounts linked to work email accounts.
2. Always use a password where feasible. 
3. Participants should ordinarily have their cameras switched on and their first name clearly visible to ensure full transparency.
4. For the protection of participants, and so that any incidents can be easily investigated, all group video calls and all calls between staff and participants and/or volunteers held on centralised Non-Trivial accounts will be recorded (note that there is no requirement to record ‘staff to staff’ or ‘participant to participant’ calls). Consent for recording will be sought from parents of children if identifiable, or from the individual themselves if they are over 18. Individuals should be aware that they can withdraw consent. Recording should only be used for the agreed purposes and never made on personal devices. Data collected from participants via recording will be used, stored and deleted in line with the Student Privacy Summary and EV UK’s Privacy Policy. 
5. Make sure you are in a neutral area, showing nothing personal or inappropriate and be aware of anyone in the background who could be seen or heard. Consider using the “blur background” functionality where this is available. Avoid joining sessions from a public space.
6. Dress appropriately for sessions as you would if the sessions were face to face.
7. Only screen share appropriate materials essential for delivering the session. When screen sharing, close all other browser windows and online content to avoid sharing inappropriate, irrelevant, or sensitive information.
8. Do not take photos or screen shots of the session unless this has been agreed in advance for a particular purpose. 
9. Generally, it is best practice to have two adults present if you are online with children. If you are using break out rooms, then plan to have enough adult supervision to cover the groups (the recommended minimum ratio is 1 adult to 10 children). 
10. Ad hoc virtual one-to-ones between staff and participants are acceptable but the safeguarding lead should be notified in advance, and the call should be held on a Non-Trivial account and be recorded (where appropriate consent has been given in advance).
11. If there is an incident, such as a participant behaving in an inappropriate, disruptive or abusive way, remove the participant from the session and/or terminate the session immediately (depending on what course of action is most appropriate in the circumstances). Report the incident in line with paragraph 8.1 of this policy. Report to the police if a criminal offence has occurred (for example, where abusive behaviour is motivated by hostility or demonstrates hostility towards the victim's disability, race, religion, sexual orientation or transgender identity, this is known as ‘hate crime’, is a criminal offence and must be reported). 
12. Bear in mind that safeguarding disclosure may take other forms online, for example you may see or hear evidence of activity that concerns you in someone’s home. Report any concerns in line with paragraph 8.1 of this policy.

5. Instant messaging

5.1. Non-Trivial’s main instant messaging tool used for the delivery of programmes is Discord. Non-Trivial People are expected to use these tools when communicating and collaborating for programme purposes. In doing so, the following policies should be adhered to: Anti–Harassment and Bullying Policy; Code of Conduct; Student Privacy Summary and EV UK’’s Safeguarding Policy.

5.2. In certain limited situations staff may need to contact volunteers or participants, or each other, by text message or other instant messaging applications as set out at paragraph 3.3.

5.3. Non-Trivial does not endorse the use of alternative instant messaging platforms for programme purposes. To the extent that these alternative platforms are used by Non-Trivial People to communicate and collaborate with each other for social/non-programme purposes, Non-Trivial expects the standards of behaviour described in this policy to be adhered to in accordance with 3.6 above.

5.4. As such, where Non-Trivial People are communicating with each other via any instant messaging platform, whether on a one-to-one basis or in a virtual group, Non-Trivial requires that its policies are properly adhered to, in particular our Anti-Harassment and Bullying Policy. Where communications are with a child and/or adult at risk, EV UK’s Safeguarding Policy and our Code of Conduct will also apply. 

5.5.
In addition, the following principles should be followed when using instant messaging platforms to keep participants safe:

1. Use organisation-registered phone numbers (not personal ones) as far as possible.
2. Ensure that messages are always appropriate and respectful. Do not use offensive or abusive language.
3. It is never appropriate for staff, contractors or volunteers to have personal/social contact with participants via instant messaging. Where any such contact is attempted or initiated over instant messaging by participants, then staff, contractors and volunteers should seek to divert the communication to a more appropriate channel (such as email) at the earliest opportunity. 
4. Be mindful of the need to maintain confidentiality and adhere to data protection law. 
5. It is never appropriate to communicate with Non-Trivial People using forms of instant messaging that automatically disappear (e.g. Snapchat).

6. Using other online technologies

6.1. Non-Trivial People using a new technology not specifically mentioned in this policy will be expected to behave with similar standards of behaviour to those outlined within this document.

7. Cyberbullying 

7.1. Cyberbullying will not be tolerated, and any instances of cyberbullying will be taken very seriously by Non-Trivial and dealt with under our Anti-Harrassment and Bullying Policy.

7.2. Anyone who witnesses or suspects cyberbullying should immediately report their concerns to the safeguarding lead in line with paragraph 8.1. If you feel comfortable in doing so, and it is appropriate in all the circumstances, intervene to prevent further harm from taking place.

7.3. Non-Trivial recognises that all categories of Non-Trivial People may be victims and will take appropriate action in either situation.

8. Dealing with Safeguarding issues arising from the use of technology

8.1. Everyone has a right to feel safe while engaging in our work. Any concerns about online behaviour, actions or other concerns, need to be reported to Non-Trivial’s Safeguarding Lead, by email (peter@non-trivial.org) or by phone (+44 7 383 842 314). Alternatively, report the incident to EVF’s Designated Safeguarding Officer, Susan Shi (susan@ev.org), in line with EVF’s Safeguarding Policy.