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19 Online Safety Incident and Breach Handling Procedure

Version 1.0 · issued 31 October 2026 · next review 31 October 2027

Purpose

This procedure defines what to do when there is an online safety incident or a breach of the school's online safety and recording privacy rules, including:

  • recorded lessons being shared;
  • unauthorised screenshots or screen recordings;
  • account misuse;
  • harmful content or bullying in group chat;
  • access to recordings by people who should not have it;
  • data or privacy breaches.
SignedProf. Rushna Sulyman

Scope

It applies to incidents involving pupils, staff and school systems or platforms, during live lessons and in recordings that only pupils may access.

SignedProf. Rushna Sulyman

Immediate actions: first response

Step 1: stop the risk

  • Where content is harmful or unsafe, remove or restrict access using the platform's moderation tools where they exist.

Step 2: preserve evidence

  • Preserve chat logs, any screenshots already in existence, URLs, timestamps, participant identifiers and any relevant system logs.
  • Do not take unnecessary screenshots beyond what the safeguarding or incident response requires.

Step 3: notify immediately

  • Tell the Online Safety Lead or the Designated Safeguarding Lead immediately, by email to growingroots1928@outlook.com, depending on how serious the incident is.
SignedProf. Rushna Sulyman

Classification of incidents

Low-level incident

  • A minor rule breach that does not involve harm, serious bullying or a safeguarding risk.

Moderate incident

  • Repeated inappropriate conduct, cyberbullying, or a concern that could escalate.

High-severity incident

  • A safeguarding risk, grooming indicators, explicit harmful content, threats, or a recording privacy breach involving unauthorised access or sharing.
SignedProf. Rushna Sulyman

High-severity incident: a recording privacy breach

Where recordings are accessed or shared in a way that suggests unauthorised viewing, including exposure beyond pupil-only access, the school will:

  • secure access immediately, by locking or revoking access for the affected accounts, restricting the recording where possible, and investigating how the access happened;
  • refer to the Designated Safeguarding Lead without delay, because the breach may indicate bullying, coercion or harmful intent;
  • investigate the incident by reviewing platform logs and the pupil accounts involved, and documenting what happened, when, and how far it spread;
  • contact only the responsible adults internally whose involvement is required for safeguarding actions; parents are not given recording links or access that would bypass pupil-only controls;
  • apply behaviour sanctions and online safety consequences in line with the Behaviour Policy and the Online Safety Policy;
  • remediate the weakness by updating permissions, access rules and moderation settings, and by giving pupils targeted reminders.
SignedProf. Rushna Sulyman

Investigation procedure

The Designated Safeguarding Lead or the Online Safety Lead will:

  • gather evidence and build a timeline;
  • identify the pupils and accounts affected;
  • interview staff or pupils where that is appropriate and safe;
  • record the findings and the decisions taken.
SignedProf. Rushna Sulyman

Outcomes and reporting

The school documents the incident summary, the actions taken, whether a safeguarding referral was made, and the corrective actions that will prevent a recurrence.

SignedProf. Rushna Sulyman

Review and learning

After an incident is resolved, the school reviews whether the rules and controls in place were adequate, and whether training, moderation or access controls need strengthening.

SignedProf. Rushna Sulyman

Review

This procedure is reviewed at least once a year and after any major online safety incident.

SignedProf. Rushna Sulyman

Signed for and on behalf of Growing Roots ltd

Prof. Rushna Sulyman

Online Safety Incident and Breach Handling Procedure · version 1.0 · issued 31 October 2026 · next review 31 October 2027