Common gaps and trends in safe use of digital technologies policies

The ESB has identified common areas where services have not met a key requirement or element within their safe use of digital technologies and online environment policies. These common areas are:

• Purpose of policy: The purpose of the policy must be clearly stated to include “taking images or videos of children while providing Early Childhood Education and Care”. The policy must address child safe practices for the use of electronic devices at the service. 
   
• Exceptions: Part 3 of the National Model Code outlines “Essential purposes for which use and / or possession of a personal electronic device may be authorised for purposes other than taking images or recording videos of children”. Technology failure, disability related and emergency situations are common exceptions that are missed, and policies must explicitly recognise each exception. 
   
• Storage protocols: Approved Providers and their services should have strict controls in place for the appropriate storage and retention of images and videos of children. The policy must outline these protocols clearly for all staff at the service to ensure they understand and comply with the requirements.

Approved Providers are encouraged to internally review and update their policies to ensure they have addressed all components of the National Model Code. There is no requirement to resubmit updated policies to the ESB.

ESB recently commenced proactively checking safe use of digital technologies policies and procedures throughout services during unannounced visits. During these visits, ESB has identified trends associated with policy implementation, including: 

• Exceptions documentation missing: Services should have formal processes documented for exceptions and requests for exceptions. 
   
• Data storage: Services must have a clear understanding of their obligations for storing images and videos in line with their policy’s storage protocols. 
   
• Smart watches: May be permitted only where the device does not have the capability to take photos, videos or audio recordings, and where any approved use is clearly documented.
   
• Service-issued devices: is any digital device that is owned, supplied, or otherwise authorised by the Approved Provider or service for work-related purposes. Under the National Model Code, this includes (but is not limited to) mobile phones, tablets, laptops, and wearable digital devices provided by the service for staff use.

The National Model Code Guidelines are available to support Approved Providers to embed the National Model Code within their policies and practice.  For further information, visit the ACECQA website.