ONLINE SAFETY AND COMMUNICATION POLICY 

 

PURPOSE AND SCOPE

TCT strives to ensure that all children (anyone under 18) and adults at risk are safeguarded from abuse and have an enjoyable tennis experience.

This document sets out how the TCT uses the internet and social media, and the procedures for doing so. It also outlines expectations for online behaviour and communication with children.

The principles in this policy apply no matter which current or future technology is used.

The purpose of this policy is to:

• Protect children involved with our organisation and who make use of technology (such as mobile phones, tablets, games consoles and the internet).

• Provide staff, coaches and volunteers with policy and procedure information regarding online safety and inform them how to respond to incidents

• Ensure our organisation operates within the law regarding how we behave online

 

This policy applies to all staff, coaches, volunteers, players, parents/carers and any other individuals associated with TCT.

 

WE RECOGNISE THAT

• the online world provides everyone with many opportunities; however, it can also present risks and challenges

• we have a duty to ensure that all children and adults involved in our organisation are protected from potential harm online

• we have a responsibility to help keep children safe online, whether or not they are using network and devices

• all children, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation, have the right to equal protection from all types of harm or abuse

• working in partnership with children, their parents, carers, and other organisations is essential in helping them to be responsible in their approach to online safety.

 

WE WILL SEEK TO KEEP CHILDREN SAFE BY

• understanding the safety aspects, including what is acceptable and unacceptable behaviour for staff, coaches, volunteers, and children, when using website, social media, apps and other forms of digital communication • being aware that it doesn’t matter what device is being used for digital interaction, but that the same safety aspects apply whether it is a computer, mobile phone, or game console

• when using social media or video conferencing platforms (including live streaming), ensure that we adhere to relevant legislation and good practice

• ensuring the person managing our organisation’s online presence is suitably trained and experienced

• providing staff with policy and procedure information regarding online safety and inform them of how to respond to incidents

 

MANAGING OUR ONLINE PRESENCE

Our online presence through our website or social media platforms will adhere to the following

guidelines:

• all social media accounts will be password-protected, and at least two members of staff and/ or volunteers will have access to each account and password

• social media accounts will be monitored by a designated person, who will have been appointed by the committee

• the designated person managing our online presence will seek advice from our Welfare

Officer / County Safeguarding Officer and the LTA to advise on safeguarding requirements as required

• the designated person will remove any inappropriate posts, explaining why, and informing anyone who may be affected (as well as the parents of any children involved)

• account, page and event settings will be set to 'private' so that only those invited can see their content

• social media pages/groups (e.g. Facebook pages/groups) used to communicate with children must be an organization, community or sports group and not personal

• identifying details such as a child's home address, school details, telephone number or email will not be posted on social media platforms

• any posts or correspondence will be of a professional purpose

• we'll make sure children are aware of who manages our social media accounts and who to contact if they have any concerns about the running of the account

• parents will be asked to give their consent for us to communicate with their children through social media, via video conferencing platforms or by any other means of communication

• parents will need to give consent for photographs or videos of their child to be posted on social media

• all of our accounts and email addresses will be appropriate, fit for purpose and only used for venue/county specific activities

• video conferencing sessions will be password protected to maintain children’s privacy and prevent exposure to inappropriate or harmful content by third parties

 

WHAT WE EXPECT OF STAFF, COACHES AND VOLUNTEERS

• they should be aware of this policy and behave in accordance with it

• they should seek the advice from our Welfare Officer / County Safeguarding Officer and the LTA if they have any concerns about the use of the internet or social media

• any messages they wish to send out to children must be sent through the designated person responsible for the organisation's online presence

• they must not 'friend' or 'follow' children from personal accounts on social-media and maintain the same professional boundaries online as they would in person when using organisation accounts

• they must make sure any content posted is accurate and appropriate

• they must not communicate with children via personal accounts or private messages

• they must communicate with parents through email or in writing, or use an organisational account, profile or website rather than via personal social media accounts

• they must copy in parents or at least one other member of staff, coach or volunteer should to any communications sent to children • they must avoid communication with children beyond dedicated event or activity timings , unless it is necessary for professional purposes (i.e. emergencies, whilst on a trip, etc.) and contacting the parents is not possible

• they must sign off any communication in a professional manner, avoiding the use of emojis or symbols such as kisses (“X’s”)

• they will respond to any concerns reported through social media in the same way as a faceto-face disclosure, in accordance with our safeguarding policy

• they must not engage in sexting, or send pictures or messages that are abusive, obscene, inappropriate, indecent, or menacing to anyone

• they must ensure any 1-2-1 sessions with children involve the parents/carers being able to supervise their child, or alternatively, that another coach/member of staff is present. This supervision would not necessarily require the parents to be in the same room, as long as they are able to check in on the session

WHAT WE EXPECT OF CHILDREN

• they should be aware of this policy

• they will sign and adhere to the acceptable use statement for internet and social media use

• they will behave responsibly online and refrain from any bullying or abusive behaviour

 

WHAT WE EXPECT OF PARENTS/CARERS

• they should be aware of this policy and behave in accordance with it

• they should seek the advice from our Welfare Officer if they have any concerns about the use of the internet or social media

• they should communicate with staff, coaches and volunteers in a professional and appropriate manner

• they must not engage in sexting, or send pictures or messages that are abusive, obscene, inappropriate, indecent or menacing to anyone • they will ensure their children understand and sign the acceptable use statement for internet and social media use on all devices

 

USING MOBILE PHONES OR OTHER DEVICES TO COMMUNICATE

When using mobile phone or other devices to communicate, we will take the following precautions to help keep children safe:

• staff, coaches, and volunteers will communicate through parents directly or copy them into all messages to children

• where it is necessary to contact children directly, and it is not possible to copy for the parents into the message, we will seek parental consent to do this or include a second practitioner

• In some circumstances it may be necessary for staff, coaches and volunteers to message children directly for logistical reasons and it is impractical to text the parents, for example cancelling or rescheduling the lesson.

• Where this type of one-to-one communication by text message is needed, the message will not be deleted from the device to ensure an audit trail exists.

• messages will be used for professional communication, such as reminders about lesson times, meeting points etc.

• If staff, coaches and volunteers only have one mobile phone, and it is not possible to have a second business phone, they will ensure the parents and child understand this and agree and adhere to clear boundaries.

• if a child tries to engage a member of staff, coach or volunteer in a conversation which is not of a professional manner (for example, their personal life), the member of staff, coach or volunteer will:

end the conversation or not reply

inform the Welfare Officer / County Safeguarding Officer as soon as possible and

arrange to address the matter with the child and their parents appropriately

if the conversation raises safeguarding concerns, notify the LTA as soon as possible

 

USING MOBILE PHONES/DEVICES DURING ACTIVITIES

So that all children can enjoy and actively take part in tennis activities, we discourage the use of mobile phones/devices. As part of this policy, we will:

• make children aware of how and who to contact if there is an emergency or a change to

previously agreed arrangements

• inform parents of appropriate times they can contact children who are away on trips

• advise parents that it may not be possible to contact children during activities and provide a contact within the venue or organisation who will be reachable should there be an emergency

• explain to children how using mobile phones during activities has an impact on their safe awareness of their environment, and their level of participation and achievement

 

SITUATIONS REQUIRING ONE-TO-ONE COMMUNICATION

Some roles are directly positioned to support a child’s well-being and are therefore delivered in one-to-one environments (upon receiving written parental consent). These roles are usually members of the well-being group (Performance Lifestyle Advisors, Sport Psychologists, Clinical Psychologist, Medical Doctor) and collectively have the expertise to support any concerns raised to player or staff well-being.

Practitioners in this group may at times be required to maintain confidentiality in regards to wellbeing support. This confidentiality may also extend to certain follow up communication, e.g. emails which relate to what was discussed in the session. This means that it may not necessarily be appropriate to include parents or other practitioners in the sessions or related communications.

In some circumstances, practitioners who are not in the well-being group may need to communicate with a child directly. These situations should be limited to logistical or pastoral reasons. For example, to let the child know they are running late, to cancel or reschedule a session, or whilst on a trip it is necessary to call the player directly.

For all practitioners, where one-to-one communication takes place, an audit trail should be retained. For example, ensuring written communication (e.g. email, text messages, etc) are not deleted and that logs are kept of any telephone/video call.

 

PHOTOGRAPHY AND FILMING POLICY

 

PURPOSE AND SCOPE

TCT strives to ensure that all children (anyone under 18) and adults at risk are safeguarded from abuse and have an enjoyable tennis experience.

The purpose of this policy is to:

• protect children who take part in TCT s activities and events, specifically those where photographs and videos may be taken

• set out the overarching principles that guide our approach to photographs/videos being taken of children during our events and activities

• ensure that we operate in line with our values and within the law when creating, using and sharing photographs/videos of children.

This policy applies to all staff, coaches, volunteers, players, parents/carers and any other individuals associated with TCT.

 

WE RECOGNISE THAT:

• sharing photographs/videos of our activities can help us celebrate the successes and

achievements of our children, provide a record of our activities and raise awareness of our venue/county

• the welfare of the children taking part in our activities is paramount

• children, their parents/carers have a right to decide whether their photograph/video is taken

and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation

• consent to take photographs/videos of children is only meaningful when children, their parents/carers understand how the photographs/videos will be used and stored, and are fully aware of the potential risks associated with the use and distribution

• there are potential risks associated with sharing photographs/videos of children online.

 

RISKS OF SHARING PHOTOGRAPHS/VIDEOS ONLINE

Sharing photographs/videos of children on social media or other online platforms carries potential

risks. For example:

• children may become vulnerable to grooming if a photograph/video is shared alongside

information that makes them identifiable. This includes: personal details; a tag with location

information; visual details such as a school/venue uniform

• inappropriate photographs/videos of children may be shared online

• photographs/videos may be copied, downloaded, screenshotted or shared by anyone

• photographs/videos of children may be adapted and used inappropriately

• photographs/videos may appear in internet search results

• depending on the terms and conditions of using an online platform, the photographs/videos may be owned by the platform once it’s been posted. Platforms may then license

photographs/videos for use by third parties – such as for commercial purposes

• each photograph/video, and any comments on them, become a part of a child’s public image.

 

WE WILL SEEK TO KEEP CHILDREN SAFE BY

• always asking for written consent from a child and their parents/carers before taking and using a child’s photograph/video

• always explaining what photographs/videos will be used for, how they will be stored and what potential risks are associated with sharing photographs/videos of children

• if consent is withdrawn, take reasonable steps to remove the photographs/videos of the child from public view. It may not be possible to delete or destroy all photographs/videos that have been disseminated online (such as via social media) or in hard copy.

• only using first names of children, unless:

 it’s considered necessary – such as for elite /high profile child players

 it’s in the child’s best interests

 the child and parent have consented (and been informed how, where, in what context a photograph/video might be used, e.g. public website, or through social media, and are aware of potential risks)

• never publish personal information about children

• making sure children, their parents/carers understand how photographs/videos will be securely stored and for how long (including how we will control access to the photographs/ videos and their associated information)

• reducing the risk of photographs/videos being copied and used inappropriately by:

 only using photographs/videos of children in appropriate clothing

 avoid photographs/videos and camera angles that may be prone to misinterpretation or misuse

avoiding full face and body shots of children taking part in activities such as swimming where there may be a heightened risk of photographs/videos being misused

• using photographs/videos that positively reflect children’s involvement in the activity

• using business devices unless not practical / possible to do so. It is important that where personal devices are to be used, this is justifiable and not simply because that is the way it has always been done

• undertake reasonable spot checks on personal devices to monitor compliance

• setting expectations around consent and the use of any personal devices among staff, volunteers and young players

• if children and parents/carers do not consent to photographs/videos being taken, we will respect their wishes. We will agree in advance how they would like to be identified so the photographer/videographer knows not to take pictures of them. We will not exclude a child from an activity because we do not have consent to photograph/video them.

 

PHOTOGRAPHY AND/OR FILMING FOR PERSONAL USE

When children, parents/carers or spectators are taking photographs/videos for personal use:

• photographs/videos captured by the parent or carer (or another adult with the express permission of the parent or carer) of the child is permitted

• we will recommend that people check the privacy settings of their social media account to understand who else will be able to view any photographs/videos they share

• we will remind children, parents/carers who they can talk to if they have any concerns about photographs/videos being shared.

For specific events we run, we will publicise what will be allowed before the start of the event.

If a player wishes to enter into a private arrangement with a commercial photographer or videographer, the photographer or videographer must have the express consent of that player (or their parent or legal guardian where the player is under 18 years old) and will notify the venue

(including the Competition Organiser/Director for any event) of their attendance in advance.

 

USING OFFICIAL OR PROFESSIONAL PHOTOGRAPHERS

If TCT engages a photographer/videographer for an event, we will:

• follow a safe recruitment process

• provide the photographer/videographer with a clear brief about appropriate content and behaviour

• ensure the photographer/videographer wears identification at all times

• inform children and parents/carers that a photographer/videographer will be at the event and ensure they give written consent to any close up photographs/videos of their child*

• inform the photographer/videographer about how to identify – and avoid taking photographs/videos of children without the required parental consent

• clarify areas where all photography/filming is prohibited (i.e. toilets, changing areas, first aid areas)

• not allow the photographer/videographer to have unsupervised access to children

• not allow the photographer/videographer to carry out sessions outside the event or at a child’s home

• report any concerns regarding inappropriate or intrusive photography/filming.

*At some events, wide-angle and general photographs/videos of the event, the site, award ceremonies, and similar may be taken. It may not be reasonable, practical or proportionate to secure consent for every participating child in order to take such photographs/videos. In these circumstances, we will make clear to all participants and parents that these kinds of photographs/ videos will be taken, and for what purposes.

 

PHOTOGRAPHY AND/OR FILMING FOR WIDER USE

If people such as local journalists or professional photographers wish to operate at an event and share photographs/videos, we will ensure they have been given proper permission in advance and that they have provided us with the following information:

• the name and address of the person using the camera

• the names of children they wish to take photographs/videos of (if possible)

• the reason for taking the photographs/videos and/or what they will be used for

• a signed declaration that the information provided is valid and that the photographs/videos will only be used for the reasons given.

We will verify these details and decide whether to grant permission for the photographs/videos to

be taken. We will also ensure the children who are the intended subjects of the photographs/videos and their parents have given consent and inform the photographer of anyone who does not give consent. We will also inform children and parents/carers that an external photographer is present and ensure they are easily identifiable.

 

CONCERNS

If we become concerned that someone is taking photographs/videos without the necessary consent, we reserve the right to ask them to delete the photographs/videos and may ask them to leave and (depending on the nature of the concerns) follow our safeguarding procedures. If we become concerned that inappropriate photographs/videos have or are being taken, this will be reported to the Welfare Officer and LTA Safeguarding Team. It may also be necessary to report this to the police.

 

STORING PHOTOGRAPHS/VIDEOS

We will store photographs/videos of children securely and in accordance with data protection law.

Hard copies of photographs/videos will be kept in a locked drawer and electronic photographs/videos in a protected folder with restricted access. Personal devices will be set so as to not to

automatically upload photographs/videos to the cloud.

Photographs/videos of children will not be stored on unencrypted portable equipment such as laptops, memory sticks and mobile phones.

Photographs/videos will be deleted after use and not repurposed for personal use (e.g. marketing or otherwise);

When obtaining consent for photographs/videos, we will state how long they will be kept for.

Access to photographs/videos will be controlled, i.e. through a password protected folder

Photographs/videos which are deemed to be no longer necessary will be deleted, and in any event, will not be kept longer than consent was given for.