Skip to content
Digital conduct and safeguarding policy

1. Document date and review schedule

Executive Leadership Team (ELT) approval date: 13 April 2026.

Next ELT review date: April 2027.

2. Responsibilities

Responsibility for updating and securing approval of this Policy from the ELT is assigned to the Designated Safeguarding Lead.

The ELT is responsible for reviewing and approving the Policy.

3. Purpose of this Policy

This Policy forms part of the DofE’s Safeguarding Framework to safeguard participants and guide DofE staff and volunteers in working safely in digital spaces.

It outlines the charity’s policy, procedures and expected behaviours for interactions in digital environments. It applies to all DofE staff (including temporary, freelance and casual staff) and to volunteers who are engaged directly by the charity. It should be read in conjunction with the DofE Safeguarding Policy and other related policies.

As part of our Safeguarding Framework, the Policy sets out our expectations of anyone delivering DofE programmes or supporting DofE activities, such as Licensed Organisations (LOs), Approved Activity Providers (AAPs), or any other organisation or individual we may jointly work with. These organisations must also comply with safeguarding legislation and guidance provided by relevant UK statutory bodies.

The DofE Safeguarding Procedures must be followed whenever a safeguarding concern arises. While legal duties apply to children, the DofE applies the same principles to all young people and adults at risk engaged in our work.

Definitions of the terms used in this Policy can be found in the Glossary of Terms in the DofE Safeguarding Policy.

The Policy and associated training are not intended to include guidance around online harms faced by young people. Please speak to the Safeguarding Team for more information on those risks.

The purpose of this Policy is to

  • Ensure that all young people and adults are kept safe from harm when interacting digitally with the DofE charity and its delivery partners
  • Provide DofE staff and its volunteers/network members with the overarching principles that guide our approach to digital safety, including our expectations of delivery partners
  • Ensure that, as an organisation and as individuals, we operate in-line with our values and within the law in terms of how we use digital devices and services.

4. Policy statements

4.1 Safeguarding principles

DofE’s Safeguarding principles

  1. The welfare of the child, young person or adult at risk is paramount
  2. All children, young people and adults regardless of age, race (including nationality, ethnic or national origin), sex, gender reassignment, disability, religion or belief, sexual orientation, marriage or civil partnership, pregnancy or maternity, have the right to equal protection from all types of harm or abuse
  3. Safeguarding must be person-centred, going beyond “protected characteristics” in order to recognise risks and barriers that some may experience (e.g., criminal record, immigration status or neurodivergence)
  4. Safeguarding is everyone’s responsibility, and everyone must play their full part in safeguarding children, young people, and adults at risk
  5. All delivery partners of the DofE must adhere to the highest of safeguarding standards and practice and must adhere to DofE’s Safeguarding Framework
  6. Children, young people, adults at risk and their families and carers should be seen as key partners in safeguarding and at the centre of all decision-making wherever possible
  7. Everyone must contribute to a safeguarding culture where people are listened to, and allegations, concerns or views and wishes are taken seriously.
4.2 Breach of the Policy

The DofE will take appropriate action in the event of breach of this Policy.

If staff or volunteer conduct is found to contravene this policy, the DofE will deal with the matter in line with the charity’s relevant policies for managing staff and volunteers.

Where the breach occurs in a licensed organisation (LO or AAP), and the DofE becomes aware of the breach, we will deal with the matter in-line with the charity’s relevant policies for managing licences.

In all cases, we will follow the DofE Safeguarding Policy and Procedures. Where conduct is considered illegal or causes significant harm, the DofE will report the matter to the police and other relevant external agencies as appropriate.

The DofE is mindful that participants may behave in the digital space, in a way that is not in line with DofE Digital Behaviours (Section 12). In such cases, and in line with our Safeguarding Principles (Section 4.1), we may view the participant as someone who may be at risk and consider their safeguarding needs as well as those who may be affected, harmed or at risk from their behaviour. We will follow relevant UK law and report the matter to external agencies, where required.

4.3 Roles and responsibilities

The Designated Safeguarding Lead (DSL) has overall responsibility for ensuring this Policy is fit for purpose, understood by staff and volunteers, implemented effectively, and reviewed regularly.

All DofE staff and volunteers are responsible for making sure they understand how to implement this Policy in the context of their work and what procedures must be followed in the event of a digital safeguarding allegation being made.

The DSL (assisted by the Deputy Designated Safeguarding Lead, DDSL) will:

  • Ensure that, where practical, there are systems in place to facilitate the monitoring of digital safety within the charity and that they receive reports on any breaches of this Policy
  • Ensure that staff and volunteers have an up-to-date awareness of the Policy and that all staff and volunteers are aware of the procedures that need to be followed in the event of a digital safeguarding incident taking place
  • Keep up to date with developments in digital safety.

Staff and volunteers are responsible for ensuring that they:

  • Have read and understood the DofE Safeguarding Policy, Code of Conduct, AI Governance and Risk Management Policy and this Policy (Digital Conduct and Safeguarding Policy)
  • Adhere to the behaviours and processes outlined in this Policy when carrying out their work or volunteering activity
  • Report any suspected misuse or abuse to the DSL/DDSL, in line with the Safeguarding Procedures
  • Make sure that digital communications with children, young people and adults at risk are appropriate and do not put anyone at risk.
4.4 Implementation and review

A copy of this Policy document will be made available to all new DofE staff and volunteers as part of their induction, and its provisions will be covered in core safeguarding training.

All staff and volunteers must sign a statement that they have received, read and understood this Policy, and this will be held on central record. The Director of People and Culture is responsible for ensuring that a process is in place to facilitate this.

The content of this Policy will be subject to a regular review cycle where recommendations may be made and monitored annually to ensure effective implementation of this Policy.

5. Procedures for DofE staff and volunteers

Reporting concerns

Unacceptable conduct in the digital environment will be taken extremely seriously by the DofE Award. This includes defamatory, discriminatory, offensive, bullying, harassment behaviour; illegal activity, extremist views/activity, accessing inappropriate material including pornographic material; a breach of data protection, confidentiality, copyright; and/or any other harmful content.

DofE staff and volunteers must report such incidents as soon as possible to the Safeguarding Team by emailing [email protected].

In line with our Safeguarding Policy and Procedures, participants, members of the public, staff and volunteers of LOs and AAPs may also report digital safeguarding concerns to the DofE Safeguarding Team by emailing [email protected].

6. Use of social media

DofE social media accounts are managed by the Digital Engagement Team, and they follow internal procedures and practices to ensure social media activity aligns with DofE’s strategic guidance and best practices.

  • Any complaints made via social media will be referred by the Digital Engagement Team to the relevant DofE team
  • If a journalist makes contact about content on social media, this should be passed to [email protected].

Guidance for DofE staff on the use of personal accounts can be found in the Acceptable use of IT systems policy which sets out the DofE’s guidelines on the correct use of all DofE systems and includes internet, social media, and electronic communications (email, messaging services, telephones including Voice Over Internet Protocol etc.) and the charity’s response to inappropriate use.

Staff and volunteers should also refer to and follow the Social media house rules when posting and engaging with DofE content.

Managing misuse:

  • When acting on behalf of the DofE, handle offensive comments swiftly and with sensitivity
  • If a conversation becomes offensive or unacceptable, DofE reserves the right to block, report and/or delete other users or their comments/posts
  • If the content is deemed potentially illegal or harmful, comments or posts must be reported to [email protected]. Please speak to the Safeguarding Team for advice and guidance.
  • If you feel that you or someone else is subject to abuse by DofE staff or volunteers through use of a social networking site, this action must be reported to the DSL or DDSL without delay.

7. Use of images

Many DofE activities involve recording images. These images may be created for publicity purposes, to celebrate achievement, or to provide records of evidence of the activity.

Whilst images are nearly always used for very positive purposes, adults need to be aware of the potential for these to be misused or manipulated for pornographic or ‘grooming’ purposes. Thought needs to be given when images are taken of young people or adults at risk who may be unable to question why pictures of the activities are taking place.

Staff and volunteers must not take photographs or videos of DofE participants who are under 18 on personal devices, e.g., mobile phones, tablets, personal cameras etc. If images are required for publicity or reporting purposes, they should be sourced via the LO or through the DofE Engagement Team who will gain the appropriate release permission via the model/case study release forms.

Storage of images is detailed in the Data Retention Policy and Schedule and Privacy Policy and Procedure.

Staff may post content:

  • Where the appropriate permission via model/case study release forms have been given to DofE. This can include re-posting DofE social media content, provided the above permission protocols have been followed when obtaining the image
  • From social media accounts owned by third parties such as LOs or other reputable authors, e.g., local authorities, other national youth bodies etc. This is because consent will have been obtained by the LO in-line with their licensing conditions or by other organisations in-line with their own policies. If in doubt, you should seek confirmation from that third party before posting.

In all cases, staff should consider the safety and safeguarding of the individual(s) and whether there are any known factors which may place the individual(s) at risk if content relating to them is shared. Staff should be mindful that, even though consent has been obtained, circumstances may change or the participant, their parent or carer may not have considered the risks. Always seek advice from the DSL or DDSL if you are in doubt.

When using images for any publicity purposes, first names only should be used in any captions or editorial, and only if required. LO name and county/hometown can be added but only if the specifics are necessary for context.

Where surnames are required, e.g., press articles, permission must be sought from the participant/Award holder or parent/carer (under 18s) using the communications teams’ model/case study release forms, in line with the DofE Engagement Team’s media consent process.

8. Communication between staff, volunteers and participants

Communication between staff or volunteers with participants under 18 must only take place using DofE-approved methods. This includes through eDofE, an official DofE email address, Zendesk, a DofE-owned social media account, or a DofE contract phone. The eDofE messaging system should be the preferred method of communication, wherever possible.

Where a different method is used such as phone, text or suitable messaging app (e.g., Slack), it must be used in line with this Policy.

Staff may use text messaging or calls to communicate with participants, provided:

  • They are permitted to do so as part of performing their role and responsibilities (e.g., responsible for participants attending an event or activity) and not for social contact
  • They have documented consent from the participant or parents/carers to do so
  • The phone used is a DofE-issued contract mobile phone or DofE landline to ensure safeguarding, transparency, and accountability. In exceptional circumstances where a personal device needs to be used, permission should be sought from a line manager (and recorded) in advance where possible, or retrospectively if this is not possible (e.g. in an emergency situation)
  • Participants and parents/carers receive information about when and how contact will be made and have the choice of how they prefer to be contacted
  • Calls are logged on to the charity’s CRM system, the project/planning file, or another suitable team record to document the chronology and content of the calls / messages or the project/planning file, to document the chronology and content of the calls/messages
  • It is a case of an emergency or other unplanned circumstances that could not reasonably be anticipated

Staff must ensure a DofE contract phone is not used to contact participants outside of usual working hours, unless in an emergency. Voicemail messages must be kept for a period of no less than three months to enable access if required.

Direct contact may not be appropriate for an adult at risk, with care and support needs, due to communication, learning, or other additional needs. You should check with their carer including the participant as far as possible.

If in doubt, seek advice from the DSL/DDSL.

When using digital communications, staff and volunteers must:

  • Only contact participants for professional reasons
  • Not share any personal information with participants, e.g., they must not give their personal contact details to participants including private email, home or mobile telephone numbers
  • Not request, or respond to requests for, any personal information (e.g., home life, home address, relationships etc) from the participants, other than that which might be appropriate as part of their professional role
  • Be aware of, and use, the appropriate reporting routes available to them if they suspect any of their personal details have been compromised
  • Be careful in their communications with participants, to avoid any possible misinterpretation; ensure that all communications are transparent and open to scrutiny
  • Follow up calls (whether incoming or outgoing) with an email, to provide an audit trail. Where this is not appropriate (e.g., a call to check whereabouts due to late arrival), a short note logging the call(s) is sufficient. This should be kept on the project/planning file or CRM.
  • If in doubt, seek advice from the DofE DSL/DDSL and report any concerns.

9. eDofE

eDofE is a system, developed and maintained by DofE. Participants use it to record progress on their Award programme, adults record their DofE training and affiliations to LOs/AAPs and it is an important tool for DofE staff to use to manage the DofE Network.

Messaging functionality exists within eDofE which allows different users to contact each other within their hierarchy. All messages are monitored, passing through an automated system which analyses them for different words or phrases (and images if included in messages). Any activity of a nature which raises concern is followed up by the DSL/DDSL as appropriate.

Staff and volunteers must:

  • Use the eDofE messaging function as their primary method of communicating with young people, where possible
  • Report any images or content within eDofE that is of an inappropriate nature to the DSL/DDSL.

10. Video conferencing and virtual classroom tools

Calls using a webcam can be used for one-to-one communications and group conference calls and are considered appropriate if a project team or other group needs to discuss plans for events and activities.

When staff or volunteers are communicating with those under 18 or adults at risk, they must choose a platform that:

  • Enables individual users to join without setting up an account
  • As far as possible, avoids sharing an individual users’ phone or email address with other users. This may be achieved by using the bcc function on email when sending out the link for the online meeting and platforms such as Zoom, Adobe Connect, Slack, or Teams for Schools and Students
  • Is free from marketing and advertising
  • Is flexible, enabling individual users to turn their microphones and webcams on and off
  • Uses a secure and encrypted connection (if unsure, check with DofE’s IT Team).
  • Is suitable for the target age group and enables their participation
  • Logs the date and time of the meeting and operates in office hours. When operating outside of normal office hours, the relevant line manager will be informed as part of the risk assessment and planning process.

Two adults must be present in all virtual group meetings with participants, and it is good practice to set a start and finish time.

At no point should a participant find themselves in one-on-one conversation with any single member of staff, volunteer or other adult. Other participants or DofE staff and volunteers must always be present.

Breakout room group sessions must contain at least three participants and should be checked in on by at least one member of staff or volunteer during the breakout period.

Staff and volunteers must obtain consent from the parent/carer before webcams are used with young people outside of the Licensed Organisations’ usual environment (e.g., the school classroom, youth charity meeting place or environments where the LO would normally meet or operate).

Before seeking such consent, full details of why a webcam is being used should be provided. This should also include information on the use of images, who is to be given authority to view them, and the security measures which will be implemented to prevent unauthorised access.

It is recommended that meetings with young people under 18 and adults at risk are not recorded. However, if recording takes place, children, young people, adults at risk, parents and carers, DofE Leaders and their Managers should be consulted. Written consent should be obtained from all parents and carers where recordings will be made. Consideration must be given to informed consent in relation to adults at risk (with care and support needs).

Any recordings should be retained for a limited time only and for no longer than is necessary. This will generally be a maximum of no more than 30 days from the recording taking place unless stated otherwise (e.g., recordings of training webinars).

It is the responsibility of the staff member who initiated any recording to ensure that all copies are destroyed after the stated date.

11. Chat functions and direct messaging

Staff and volunteers must use the messaging function in eDofE whenever possible to communicate with participants.

The use of direct messaging using social apps and chat functions may be used only where it is necessary, and the application used can provide an audit trail (see Section 8. Communication between staff, volunteers and participants section). This will usually be for one of DofE’s streams of planned direct work, e.g., Youth Ambassador Programme.

Direct contact with an adult at risk (with care and support needs), may not be appropriate due to communication, learning, or other additional needs. You should check with the participant and parent/carer (where appropriate). If in doubt, seek advice from the DofE DSL/DDSL.

12. Digital behaviour

Alongside the DofE Code of Conduct, which all DofE staff and volunteers must follow, the below describes standards of behaviour expected from everyone engaged in DofE activity within digital settings:

The DofE expects that DofE staff and volunteers facilitating the DofE programme will:

  • Be an excellent role model at all times
  • Ensure that all young people and adults at risk are safeguarded by following safeguarding policy and procedures
  • Immediately tell the police if you think a crime is committed or that a young person or adult at risk is at immediate risk of harm
  • Undertake regular safeguarding training appropriate to your role
  • Not share personal digital information (e.g., social networking profiles) with the young people that you meet through your role with DofE
  • Abide by the DofE data protection policies – Privacy Statement
  • Not deliberately bypass any systems designed to protect the charity or children, young people or adults at risk.

In addition, DofE staff and volunteers will:

  • Report any safeguarding concerns, allegations or disclosures as soon as possible (always within 24 hours) to [email protected]
  • Not attempt to install programmes of any type on the devices belonging to the charity without permission or authorisation from the DofE IT Team
  • Ensure that your digital activity does not bring the DofE into disrepute
  • Think carefully about how any digital communication might appear to a third party. Compared with conversations in the real world, technology increases the potential for messages to be seen out of context, to be misinterpreted or forwarded to others.

Think carefully about how any digital communication might appear to a third party. Compared with conversations in the real world, technology increases the potential for messages to be seen out of context, to be misinterpreted or forwarded to others.

It is DofE’s expectations that staff and volunteers will:

  • Treat each other with dignity and respect in line with the DofEs’ values
  • Respect one another’s privacy
  • Be responsible and accountable
  • Not share personal passwords or those of other users
  • Not download anything that you do not have the right to use.
13. Related policies, procedures and documents

Opportunity Finder

This link opens an external site. All content is not affiliated with DofE. Please click proceed if you understand these risks.