Digital Communications and Children (Under 18)

In light of the Information and Commissiner's Office (ICO) Age appropriate design: a code of practice for online services published on 2 September 2020, The FAs guidance on Digital communications and children is under review.

For more information about the ICO Age appropriate design: a code of practice for online services please visit - https://ico. org.uk/for-organisations/guide-to-dataprotection/key-data-protection-themes/ age-appropriate-design-a-code-ofpractice-for-online-services/

Whilst this review is undertaken we have retained guidance on communicating with 16 and 17 year olds in a position of trust role in football. 

WHEN COMMUNICATING WITH 16/17 YEAR OLDS WHO HOLD A POSITION OF TRUST AND/OR RESPONSIBILITY WITHIN FOOTBALL PLEASE ADHERE TO THE FOLLOWING GUIDANCE.

  • Signed parental/carer consent should be given prior to email, social networking and mobile phone communications with young people holding a position of trust. Ideally the adult(s) who will be communicating in this way should be named. The purpose for the communication should be made clear; 
  • Both parties to only communicate for the purpose of the identified professional role(s);
  • Email and/or social media communications between the parties should copy in either the parent/carer or Welfare Officer, or both;
  • Leagues appointing young referees to games must copy in another league official or parent/carer to their communications;
  • Do not use language that is directly (or could be misinterpreted as being) racist, sexist, derogatory, threatening, abusive or sexualised in tone in any communciation.
  • If any inappropriate communication or content is shared between an adult and an under-18-year-old, this must be reported immediately to the Club Child Welfare Officer who will seek advice from the County FA Designated Safeguarding Officer (DSO) and/or statutory agencies as appropriate.

VIDEO CALLS WITH CHILDREN - SPECIFIC GUIDANCE FOR COACHES/MANAGERS

Online video calls are a great way for coaches/managers to keep in touch with players and other coaches, by providing training ideas, tips on keeping fit and skills challenges online. As a coach/manager, it’s really important to keep appropriate boundaries in your digital space. Please ensure you continue to apply the principles of your code of conduct and remember that as a coach/manager even when encouraging players/coaching online you remain in a ‘relationship of trust1 ’. Follow the procedures outlined below to help keep you and those you are supporting safe online.

Setting up

  • Always work with groups, ensure you are inclusive when engaging with players;
  • Wherever possible involve a second coach/manager or club official;
  • All sessions online must be observable and interruptible;
  • Where players are aged under 18, communications must go to parents/ carers to accept or decline the player’s participation.
  • Are there any individual player circumstances which may mean their involvement may not be possible? How might you ensure they still feel included as part of the team/club?

The environment when using video facilities

  • The setting for the background should be in a neutral area, avoiding anything inappropriate being heard or seen. Some apps may offer customisation of avatars, usernames and customised virtual backgrounds. What you may use for personal use may be inappropriate to represent your club – so think about this and make any changes, before contacting anyone;
  • Do not host the session from a bedroom;
  • The background must not be blurred or obscured;
  • Coaches/managers and players must wear suitable clothing, as should anyone else in the household. Ideally other members of the household should not be in view when running your session(s).

Session content

  • The purpose of the session and what it will involve must be clearly outlined to all involved;
  • All communication provided must have an educational or supportive purpose, or both;
  • Language must be professional and appropriate. Please ensure any family members or others in the background also behave appropriately, if it is not possible for them to be out of view, and for them not to be heard during the session;
  • Under no circumstances should any part of the session be recorded as this may create a potential risk of hacking by child sex offenders accessing recordings of sessions. The National Crime Agency (NCA), the NCA has identified the potential for an increase in online child sexual abuse during the Covid-19 pandemic;
  • The session should be kept to a reasonable length of time, or the streaming may prevent the family 'getting on' with their day. 

If you need any further advice or information please contact the Hertfordshire FA County FA DSO who will be happy to help you. 

If you would like to access futher digital safeguarding guidance such as that provided by the NSPCC you will find useful links here.

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