RELATED GUIDANCE

Support for Parents and Carers to Keep Children Safe Online (gov.uk)

Guidance – Sharing Nudes and Semi-Nudes: Advice for Education Settings Working with Children and Young People (gov.uk) – guidance on responding to incidents and safeguarding children and young people.

Guidance: Education for a Connected World (UK Council for Internet Safety) – a framework to equip children and young people for digital life

Guidance: Challenging Victim Blaming Language and Behaviours when Dealing with the Online Experiences of Children and Young People (UK Council on Internet Safety) – guidance for professionals on how to effectively challenge victim blaming language and behaviours and advice on best practice

Keeping Children Safe in Education Part five: Child-on-child Sexual Violence and Sexual Harassment (Department for Education, 2024)

1. Introduction

Technology is a big part of everyday life, bringing educational and social benefits and opportunities for children and young people. However, there are potential harms which children and young people may encounter when online, including online child abuse, bullying, harassment or criminal exploitation. The consequences and impact of online child abuse can be just as severe as abuse experienced offline.

The term ‘victim’ has been used within this chapter to describe a child or young person who has experienced online abuse, in any form. This includes abuse from an adult, or another child or peer. In practice, different terms may be used, for example victim or survivor. Many children or young people who have experienced online abuse would not consider themselves a victim, and would not refer to themselves as such.

2. Risks

The breadth of issues classified within online safety is considerable and ever evolving. Keeping Children Safe in Education Part Two: The Management of Safeguarding (Department for Education, 2024) categorises them into four areas of risk (‘the 4Cs’):

  1. content: being exposed to illegal, inappropriate, or harmful content, for example: pornography, fake news, racism, misogyny, self-harm, suicide, radicalisation, and extremism;
  2. contact: being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes;
  3. conduct: online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images, for example consensual and non-consensual sharing of nudes and semi-nudes and / or pornography, sharing other explicit images and online bullying; and
  4. commerce: risks such as online gambling, inappropriate advertising, phishing and / or financial scams.

The Sexual Offences Act 2003 and the Online Safety Act 2023 set out several criminal offences in relation to harmful online activity, and these should be reported to the police for investigation of possible criminal offences (alongside any safeguarding referral).

Some of the main categories of safeguarding risks are now considered in more detail.

2.1 Risk of sexual harm

See also Sexual Exploitation and Abuse (Including Organised Sexual Abuse) chapter.

Indecent images of children: Making, possessing, and distributing any imagery of someone under 18 which is ‘indecent’ is illegal.

Sending a photograph or film of genitals (‘cyberflashing’): It is a criminal offence to intentionally send a photograph or film of any person’s genitals to another person either with the intention that the recipient will see the genitals and be caused alarm, distress or humiliation, or for the purpose of obtaining sexual gratification (inserted into the Sexual Offences Act 2003 by the Online Safety Act 2023).

Threatening / blackmailing children into sending indecent images / carrying out indecent acts online: This is  an offence under the Sexual Offences Act 2003.

Sharing or threatening to share intimate photograph or film: This is a criminal offence under the Online Safety Act 2023.  A person would ‘share’ the film/image if they, by any means, give or show it to another person, or make it available to another person. This includes electronic sharing, for example by posting a photograph or film on a website or emailing to someone. ‘Film’ or ‘photograph’ covers data that can be converted into such an image – for instance data stored on a hard drive or disc.

Sharing nudes and semi-nudes: Children may be encouraged, or may choose, to share nude or semi-nude images online with other children and young people.

Guidance – Sharing Nudes and Semi-Nudes: Advice for Education Settings Working with Children and Young People (gov.uk) uses the term ‘sharing nudes and semi-nudes’ to mean the sending or posting of nude or semi-nude images, videos, or live streams by young people under the age of 18 online.

For example:

  • a person under the age of 18 creates and shares nudes and semi-nudes of themselves with a peer under the age of 18;
  • a person under the age of 18 shares nudes and semi-nudes created by another person under the age of 18 with a peer under the age of 18;
  • a person under the age of 18 is in possession of nudes and semi-nudes created by another person under the age of 18.

This could be via social media, gaming platforms, chat apps or forums. It could also involve sharing between devices via services like Apple’s AirDrop which works offline.

The sharing of nudes and semi-nudes can happen publicly online, in 1:1 messaging or via group chats and closed social media accounts.

Nude or semi-nude images, videos or live streams may include more than one child or young person. The term ‘nudes’ is used as it is most commonly recognised by young people and more appropriately covers all types of image sharing incidents. Alternative terms used by children and young people may include ‘dick pics’ or ‘pics’.

See also Section 3.2, Information on avoiding unnecessary criminalisation of children and:

2.2 Risk of physical and / or emotional harm

The risk of physical and / or emotional harm can include the following.

Children being exposed to online threats and harmful online ‘fake news’

The Online Safety Act 2023 introduced offences of threatening communications and false communications.

A person commits the false communications offence if they send a message conveying information that they know to be false, intending the message to cause non-trivial psychological or physical harm to a likely audience (that is, someone who could reasonably be foreseen to encounter the message or its content). It is not necessary to show that the sender intended to cause the harm to any of the likely audience in particular.

A person commits the threatening communications offence if they send a message conveying a threat of death, serious injury, rape, assault by penetration, or serious financial loss. This includes situations where the recipient fears that someone other than the sender of the message may carry out the threat. It does not matter if the content of the message is created by the person who sends it; a message can consist of or include a hyperlink to other content.

Children being exposed to content designed to cause them physical and / or psychological harm

The Online Safety Act 2023 introduced offences of sending or showing flashing images electronically with the intention of causing harm to a person with epilepsy. The offence may be committed by a person who forwards or shares the electronic communication, as well as by the person originally sending it.

The Act also introduced an offence of encouraging serious self-harm. It includes online communications capable of encouraging or assisting another person to seriously self-harm. It also includes an omission, such as encouraging or assisting a person to stop eating or taking required prescription medication. The person committing the offence need not know, or even be able to identify, the person or persons who receive the communication. So, a person who intends that a recipient or recipients of their communication will seriously harm themselves is guilty of an offence, even though they may never know the identity of those who receive the communication.

An offence can be committed whether or not serious self-harm occurs. In addition, a person who arranges for someone else to do an act capable of encouraging or assisting the serious self-harm of another person will also be committing an offence if the other person carries out that act.

This category would also include cyberbullying.

Preventing Bullying: Guidance for Schools on Preventing and Responding to Bullying (Department for Education, 2017) provides further information on tackling this form of online harm.

2.3 Children being groomed for the purposes of sexual and / or criminal exploitation

Under the Sexual Offences Act 2003 (as amended) it is an offence for a person (over 18 years) to engage in sexual communication with a child (under 16 years) (section 15A), or to meet a child (under 16 years) following sexual grooming (section 15).

See also chapters on Sexual Exploitation and Abuse (Including Organised Sexual Abuse) and Multi-Agency Child Exploitation Protocol.

2.4 Risk of exposure to extremist material / online radicalisation

For further information see Radicalisation and Violent Extremism chapter

Concerns about online radicalisation can be reported to the police on 101 and / or a Prevent referral can be made, so that the victim can get safeguarding support.

Any member of the public can report terrorist content they find online through the gov.uk referral tool – more information about what to report and what happens when you do can be found on the Action Counters Terrorism campaign.

Educate Against Hate Parents’ Hub provides resources and government advice for parents and carers on keeping young people safe from extremism, including online.

3. Children as Perpetrators as Well as Victims

3.1 Child-on-child abuse

The prevalence of online activity by children and young people makes it increasingly likely that children may be both victims and perpetrators of harmful online activity, which may involve the commission of criminal offences. An appropriate multi-agency response including police and safeguarding will be required in respect of all children involved. Children can abuse other children online. This can take the form of abusive, harassing, and misogynistic / misandrist messages, the non-consensual sharing of indecent images, especially around chat groups and the sharing of abusive images and pornography to those who do not want to receive such content. Child-on-child abuse can include cyberbullying, online threats of physical abuse, online threats and/or encouragement of sexual violence, online sexual harassment.

The nature of online abuse means that it can very rapidly involve multiple children, for example children sharing images online / forwarding on content, sending links of content to others and / or posting things on online platforms such as social media.

See also Harmful Sexual Behaviour chapter

3.2 Avoiding unnecessary criminalisation of children

This is of particular relevance in relation to the sharing of nude / semi-nude images where both victim and perpetrator are under 18.

The law criminalising indecent images of children, for instance, was created to protect children and young people from adults seeking to sexually abuse them or gain pleasure from their sexual abuse. It was not intended to criminalise children and young people. The law was also developed long before mass adoption of the internet, mobiles and digital photography.

Despite this, children and young people who share nudes and semi-nudes of themselves, or peers, are breaking the law. Making, possessing, and distributing any imagery of someone under 18 which is ‘indecent’ is illegal. This includes imagery of the person making / sending the image if they are under 18.

Guidance – Sharing Nudes and Semi-Nudes: Advice for Education Settings Working with Children and Young People (gov.uk) stresses the importance of avoiding unnecessary criminalisation of children. Situations should be considered on a case by case context, considering what is known about the children and young people involved and if there is an immediate risk of harm. Often, children and young people need education and support for example, on identifying healthy and unhealthy behaviours within relationships and understanding consent and how to give it. Safeguarding action will also be required in cases where there is risk of harm.

Investigation by police of an incident of sharing nudes and semi-nudes does not automatically mean that the child / young person involved will have a criminal record. Once an incident is reported to the police, they will investigate and decide on an appropriate outcome. If an incident is found to have abusive and / or aggravating factors, the child or young person may receive a caution or conviction.

To mitigate the risk of children and young people being negatively impacted, the police are able to record the outcome of an investigation using an ‘outcome 21’ code should an incident be found to be non-abusive and have no evidence of any of the following:

  • exploitation;
  • grooming;
  • profit motive;
  • malicious intent (for example, extensive or inappropriate sharing; uploading onto a pornographic website);
  • persistent behaviour.

This means that even though a child or young person has broken the law, and the police could provide evidence that they have done so, the police can record that they chose not to take further action as it was not in the public interest.

It is possible for an incident of sharing nudes and semi-nudes recorded on police systems with outcome 21 to be disclosed on a DBS certificate. However, information falling short of conviction or caution can only be included on a DBS certificate when an individual has applied for an Enhanced Criminal Records Check. In such cases, it would be for a chief officer to consider what information (in addition to convictions and cautions held on the Police National Computer) should be provided for inclusion. That decision must be made on the basis that the chief officer reasonably believes the information to be relevant to the purpose of the disclosure (for example, someone taking up a position working with children) and considers that it ought to be included.

3.3 Support to all children

Keeping Children Safe in Education Part five: Child-on-child Sexual Violence and Sexual Harassment (Department for Education, 2024) provides information on managing harm between children, including online harm, and the importance of providing ongoing support for all affected children: victims, alleged perpetrators and other children who have been directly or indirectly affected.

If a child is convicted or receives a caution for an offence, risk assessments should be reviewed and updated to ensure relevant protections are in place for all the children affected.

4. Who to Contact / How to Make a Report

Anyone concerned that a child / young person may be at risk of significant harm due to online activity should make a referral to children’s social care (see Referrals chapter) so that safeguarding procedures can be implemented (see Section 7, Safeguarding Response).

In addition, there are specific referral channels for specific concerns.

4.1 Contact the police

Contact the police via 999 (emergency number) where:

    • a child is in immediate danger;
    • a threat has been made to a child’s life;
    • a child’s safety has been compromised;
    • a child is being forced to take part in sexual behaviours online.

Report other non-emergency situations (that is, those that do not require an immediate police response) by dialling 101.

4.2 Report sexual content / harm

If you are concerned that a child has been a victim of online sexual abuse or you are worried about the way someone has been communicating with a child online, you can report it to NCA-CEOP.

If you see sexual images or videos of someone under 18 online, report it anonymously to the Internet Watch Foundation who can work to remove them from the web and help to identify victims and survivors.

4.3 Report harmful content

To report other forms of harmful online content (other than online child sexual abuse imagery), see Report Harmful Content. This provides advice and resources on how to report a variety of different issues you may see online including:

  • threats;
  • impersonation;
  • bullying and harassment;
  • self-harm or suicide content;
  • online abuse;
  • violent content;
  • unwanted sexual advances.

It also offers advice on When you Should go to the Police.

4.4 Report extremist content / radicalisation

Concerns about online radicalisation can be reported to the police on 101 and / or a Prevent referral can be made, so that the victim can get safeguarding support.

Any member of the public can report terrorist content they find online through the gov.uk referral tool – more information about what to report and what happens when you do can be found on the Action Counters Terrorism campaign.

5. Education, Protection and Prevention

Filtering and age-appropriate parental controls on digital devices can be used to restrict children’s access to age-inappropriate content. Filtering and Monitoring Standards for Schools and Colleges (Department for Education) provides further information.

Internet Matters has step-by-step guides on setting up parental controls to control what content children can access online.

The UK Safer Internet Centre has guidance on how to switch on family-friendly filters to prevent age-inappropriate content being accessed on devices.

The NSPCC has more information for parents or carers with concerns about their child seeking inappropriate or explicit content online.

Apps to help children stay safe online

The BBC has a website and app called Own It, to help children navigate their online lives.

The UKCIS Digital Passport is a resource for care-experienced children and young people and their carers. It is a communication tool created to support children and young people with care experience to talk with their carers about their online lives.

Other useful resources include:

It is also important to ensure that practitioners working with children and young people are aware of the risks posed to children by online activity and how children can be protected and encouraged to help protect themselves. This should include being able to recognise the additional risks that children with special educational needs and disabilities (SEND) face online, for example, from bullying, grooming and radicalisation, to enable practitioners to have the capability to support children with SEND to stay safe online. Agencies should provide suitable training for staff working with children and young people.

Useful resources include:

6. Terminology and Avoiding Victim Blaming Language

Victim blaming is any language or action that implies (whether intentionally or unintentionally) that a person is partially or wholly responsible for abuse that has happened to them. It is harmful and can wrongfully place responsibility, shame or blame onto a victim, making them feel that they are complicit or responsible for the harm they have experienced. For example:

  • in the context of non-consensual nude image sharing, telling the child or young person that they should not have sent the image in the first place;.
  • after an abusive message online, suggesting that it is the fault of the child / young person for accepting a friend request from someone they did not know on social media;
  • using language such as that a child or young person ‘shouldn’t place themselves in danger’ or ‘put themselves at risk’ by doing x or using y.

Guidance: Challenging Victim Blaming Language and Behaviours when Dealing with the Online Experiences of Children and Young People helps practitioners to understand that the responsibility always lies with the person who abused the child or young person. The guidance also offers practical steps to help practitioners practice and advocate for an anti-victim blaming approach, in a constructive and supportive way.

6.1 Children and young people may feel they are to blame

One of the greatest barriers to a child or young person seeking help and reporting online abuse, is feeling they are to blame for something that has happened to them. When practitioners working with the child or young person speak or behave in such a way that reinforces this feeling of self-blame, the impact of the abuse the child or young person has already experienced may be greater, leading to a longer recovery. In contrast, positive responses can reduce feelings of post-traumatic stress which a young person may experience as a result of abuse occurring. They can also encourage other children and young people to report their online experiences.

6.2 Children and young people’s experiences may not be treated as a safeguarding concern

When victim blaming occurs, there is a risk of diminishing the child or young person’s experiences, leading to a lack of, or an inappropriate, safeguarding response. This could be by practitioners initially dealing with an incident or by those involved subsequently. This can have a devastating impact for the child or young person who has experienced abuse and make it less likely that they, or their peers, will have the confidence to disclose abuse in the future. In addition, victim blaming attitudes can prevent families, friends and wider society from recognising certain behaviours as abuse.

7. Safeguarding Response

7.1 Immediate actions and referral

Where practitioners have concerns that a child is a victim or perpetrator of online harm, they should discuss with their safeguarding lead. Where it is suspected that the child is at risk of significant harm, a referral should be made to children’s social care and safeguarding processes engaged which may include a multi-agency strategy discussion (see Referrals and Strategy Discussions chapters). Where there is an imminent risk of significant harm, steps must be taken to ensure the child’s immediate safety (see Immediate Protection chapter).

A referral should be made to children’s social care where the child is already known to them, for example, they are currently, or have in the past, been the subject of an early help or child protection plan.

A referral should also be made where there are believed to be wider safeguarding issues such as several children having been affected.

The police should be informed where there is a known or suspected criminal offence.  This should take place as soon as possible to enable swift preservation of evidence.

See also Section 4, Who to Contact / How to Make a Report for additional notifications in response to particular types of online harm.

7.2 Securing indecent images

Where the harm involves indecent images, the images should not normally be viewed by practitioners but should be referred to the police. Practitioners may themselves commit a criminal offence by viewing any indecent images. Guidance – Sharing Nudes and Semi-Nudes: Advice for Education Settings Working with Children and Young People (gov.uk) sets out the very limited circumstances where it may be necessary to view images, such as it being unavoidable because a child or young person has presented it directly to a staff member or nudes or semi-nudes have been found on an education setting’s device or network. Practitioners must never copy, print, share, store or save indecent images – this is illegal. If any devices need to be taken and passed onto the police, the device/s should be confiscated and the police should be called. The device should be disconnected from Wi-Fi and data, and turned off immediately to avoid imagery being removed from the device remotely through a cloud storage service. The device should be placed in a secure place, for example in a locked cupboard or safe until the police are able to come and collect it.

Viewing indecent images can be distressing for both children, young people, and adults and appropriate emotional support may be required.

7.3 Decision by schools and colleges not to refer to the police or children’s social care

Schools / colleges becoming aware of incidents involving nude / semi-nude images of children should hold an initial review meeting to establish:

  • whether there is an immediate risk to any child or young person;
  • if a referral should be made to the police and/or children’s social care.

An immediate referral to police and / or children’s social care should be made if at the initial stage:

  • the incident involves an adult. Where an adult poses as a child to groom or exploit a child or young person, the incident may first present as a child-on-child incident;
  • there is reason to believe that a child or young person has been coerced, blackmailed or groomed, or there are concerns about their capacity to consent (for example, owing to special educational needs);
  • the images or videos suggest the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent;
  • the images involves sexual acts and any child or young person in the images or videos is under 13;
  • there is reason to believe a child or young person is at immediate risk of harm owing to the sharing of nudes and semi-nudes, for example, they are presenting as suicidal or self-harming.

Guidance – Sharing Nudes and Semi-Nudes: Advice for Education Settings Working with Children and Young People (gov.uk) sets out the very limited circumstances where an education setting may decide to respond to an incident involving sharing of nude / semi-nude images between children without involving the police or children’s social care. They can still choose to escalate the incident at any time if further information / concerns are disclosed later.

The decision to respond to the incident without involving the police or children’s social care should only be made in cases where the designated safeguarding lead (or equivalent) is confident that they have enough information to assess the risks to any child or young person involved and the risks can be managed within the education setting’s pastoral support and disciplinary framework and, if appropriate, their local network of support. The reasons for not referring the incident should be recorded.

All incidents relating to nudes and semi-nudes being shared need to be recorded by education settings. This includes incidents that have been referred to external agencies and those that have not.

7.4 Multi-agency working

Many instances of online harm will involve possible criminal offences and so will necessitate a police response and safeguarding response. Educational establishments are often likely to be involved as guidance tell us that many of these events are likely to involve the child’s educational experience in some way, such as images of children being widely circulated between pupils.

Children accessing alternative educational settings, voluntary activities and specialist units should be considered with the context of this policy.

Multi-agency information sharing is important to enable effective assessment of risk and identification of other children who may be affected.

See also Information Sharing and Data Protection chapters.

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