Internet, Photographs and Mobile Phones
REGULATIONS AND STANDARDS
The Fostering Services (England) Regulations 2011:
Regulation 11 - Independent fostering agencies—duty to secure welfare
Regulation 12 - Arrangements for the protection of children
Regulation 14 - Duty to promote contact
Regulation 16 - Education, employment and leisure activities
Fostering Services National Minimum Standards
STANDARD 4 - Safeguarding Children
RELEVANT GUIDANCE
Internet Matters - advice for professionals, parents and young people on a wide range of digital safety issues including the digital passport.
Refuge and Risk: Life Online for Vulnerable Young People - research into the risks and dangers for vulnerable young people online. The report discusses the types of risk they encounter, which are exacerbated by their vulnerabilities.
NSPCC Report Remove Tool - The tool enables young people under the age of 18 to report a nude image or video of themselves which has appeared online. The Internet Watch Foundation will review these reports and work to remove any content which breaks the law.
UK Council for Internet Safety (UKCIS) Digital Passport - a communication tool to support children and young people with care experience to talk with their carers about their online lives.
Childnet Parents and Carers Toolkit - Resources that offer practical tips and advice on different aspects of keeping children safe online.
Child Safety Online - A Practical Guide for Parents and Carers whose Children are using Social Media
Sharing Nudes and Semi-Nudes: Advice for Parents, NSPCC
Talking to Your Child About Online Sexual Harassment (Children’s Commissioner)
The Dark Web Explained (for Professionals)
The Dark Web Explained (for Parents and Carers)
UK Safer Internet Centre - Resources for helping children and young people stay safe online, including details of the Professionals Online Safety Helpline.
FMSE Alert - The National Crime Agency's CEOP Education have issued an alert to education settings across the UK in response to the threat of ‘sextortion’ or online blackmail.
Help if you're worried about 'sextortion' or online blackmail (Internet Watch Foundation)
Child sexual exploitation by organised networks: Investigation Report
Child exploitation disruption toolkit (GOV.UK) - updated toolkit published 19/7/22
Contents
- Introduction
- Encouraging Safe Use of the Internet
- Risks
- Indicators
- Photographs
- Mobile Phones
- Use of Artificial Intelligence (AI)
- AI Imagery
- Sharing Nudes and Semi-Nudes
- Further Information
1. Introduction
Different ways of communicating with friends are important to a child/young person and are now a way of life from an early age. When a child is placed with foster carers, it is important to find out their background and whether the internet, photographs and mobile phones contributed towards any abuse so that their use can be planned safely for all children, and particularly those where it has been an issue.
Foster carers should ask their supervising social worker and the child's social worker for advice and information.
Carers' knowledge of different media will vary, but it is important that they do all they can to safeguard children when using the internet and mobile devices.
The Placement Plan should identify any risks or issues associated with the use of a computer, mobile phone or gaming equipment, particularly in relation to bullying, sexual exploitation or other risk-taking behaviours, and, where appropriate, assess the risk and how to manage the child or young person's use safely. The use of social media/electronic communication as a way of maintaining contact with family and friends should be outlined in the child's Care Plan (see also Contact with Parents, Siblings and Others Procedure).
If a foster carer is concerned in any way about a child's behaviour or the child expresses something that the carer is worried about in relation to social media, they should discuss this with their supervising social worker.
There is a correlation between online risk and real-life vulnerability, which means care-experienced children have an increased risk of encountering online harm. Young people with prior offline vulnerabilities are at greater risk of harm online than children and young people with none. For example, young people with eating disorders, Looked After Children and young people, and those with communication challenges may use technology to communicate and socialise in ways they cannot achieve without it. Denying online access to children can be abusive in itself (for example, loss of opportunity to develop resilience, risk of alienation, risk of turning to secret devices).
Working Together to Safeguard Children 2026 makes clear that harm can occur inside or outside the home, including in foster care and online, and that there can be overlap between online harm and harm experienced in person. Children may also experience more than one form of harm at the same time. Foster carers should be aware of threats such as online harm, grooming, sexual exploitation, criminal exploitation and radicalisation, and of new and emerging technologies, such as AI, and the role that online platforms, including gaming and social media platforms, can play in grooming children and in facilitating or causing harm. Concerns about a child’s online life should be considered alongside any other concerns about the child and shared with the supervising social worker and the child’s social worker.
2. Encouraging Safe Use of the Internet
Foster carers need to be aware that children who have experienced past trauma or have low self-esteem can be more vulnerable to the dangers associated with the internet. When communicating via the internet, young people tend to become less wary and talk about things far more openly than they might when communicating face to face.
The role of foster carers in helping children to learn how to use the internet safely is extremely important, and they must ask for support and/or further training if they lack confidence or knowledge in this area.
Foster carers should support young people to use social media and electronic communication safely and offer advice on what a young person should do if they receive a message which is inappropriate or upsetting. If foster carers have any concerns about a child's online activities, they should report them to the supervising social worker.
Foster carers should try to take part in a child's web browsing, particularly for a new child in placement; school homework is an ideal opportunity for this. Foster carers should explain the web's positive and negative sides and tell the child that if they are not sure about a site, they should talk to their foster carer. Some useful guidelines are:
- Time limits on computers should be agreed with the child/young person
- Appropriate internet security should be used on the computers to avoid access to inappropriate material
- Carers should set clear ground rules on the use of the internet
- Computers should be in areas of the house where adults can see what is being looked at, rather than in a bedroom
- If a young person has a laptop, then decide with them where and when they can use it if they are accessing the internet
- Carers should show an interest in the internet and encourage young people to be open about any concerns or problems
- Never allow a child to arrange a face-to-face meeting with someone they "meet" on the internet without first speaking to the child's social worker
- The child should never respond to messages that are rude, threatening, or make them feel uncomfortable. Encourage the child to talk to you about messages like this. If the child receives a message or sees something online that you are concerned about, keep a copy and make a note in the daily record
- Foster carers should discuss with a child/young person that people online may not be who they say they are.
Teaching the child to be cautious is important and can help when they start to use social networking sites like Facebook or X (formerly known as Twitter). Foster carers need to be aware that most mainstream social networking sites impose a minimum age limit of 13 on their membership. This includes Facebook. It is therefore not appropriate for children under 13 years old to use social networking sites, which are also used by adults. Prohibiting young people from using social networking sites is not realistic. A more effective way of helping to keep children safe when using social networking sites is to:
- Ensure young people set their privacy settings appropriately
- Pay attention to what information the young person is posting
- Encourage young people to share their social networking experiences with an appropriate adult.
Since 25 July 2025, under the Online Safety Act 2023, online services that are likely to be accessed by children must follow Ofcom’s Protection of Children Codes, including using highly effective age checks to prevent children from accessing pornography and other harmful content, such as material promoting self-harm, suicide or eating disorders. Age checks do not replace supervision and guidance from foster carers, and carers should be aware that children may try to get around them, for example by using a VPN.
Foster carers should ensure the child's profile and postings contain nothing that might expose their identity or whereabouts.
It is important that the child and the carer understand the site's terms and conditions.
Carers should try to equip the child with the skills to decide who to trust, even when they have not met the person face to face, and talk to the child/young person about what makes a real friend.
The Digital Passport is aimed specifically at Looked After Children, but may be a useful resource that can be adapted for any vulnerable child.
3. Risks
The internet and social networking sites can pose risks to children and young people, for example, in relation to sexual exploitation and abuse, bullying and radicalisation.
In relation to sexual abuse, this can include:
- Exposure to pornographic or other offensive material via the internet
- Abusive images of children (although these are not confined to the internet)
- A child or young person being groomed for the purpose of sexual abuse.
Social networking sites can be used by perpetrators as an easy way to access children and young people for sexual abuse. The Serious Crime Act 2015 introduced an offence of sexual communication with a child. This applies to an adult who communicates with a child, and the communication is sexual, or if it is intended to elicit from the child a communication which is sexual, and the adult reasonably believes the child to be under 16 years of age. The Act also amended the Sexual Offences Act 2003, so it is now an offence for an adult to arrange to meet with someone under 16, having communicated with them on just one occasion (previously it was on at least two occasions).
Internet abuse may also include cyberbullying. This is when a child is tormented, threatened, harassed, humiliated, embarrassed or otherwise targeted by another person or persons using the internet and/or mobile devices. In the case of online bullying, it is possible for one victim to be bullied by many perpetrators. In any case of severe bullying, it may be appropriate to consider the behaviour as child-on-child abuse.
Radical and extremist groups may use social networking to attract children and young people into narrow ideologies that are intolerant of diversity: this is similar to the grooming process and exploits the same vulnerabilities.
Children may be drawn to adopt a radical ideology through a failure to appreciate the bias in extremist material; in addition, by repeated viewing of extreme content, they may come to view it as normal.
Working Together to Safeguard Children 2026 places a stronger emphasis on identifying, understanding and challenging racism and discrimination. Foster carers should challenge racist, discriminatory or hateful content and behaviour online, and consider how a child’s experience of discrimination may affect their willingness to tell someone or seek help.
Keeping Children Safe in Education 2026, which the schools and colleges that children attend must follow, groups online risks into four areas. These provide a useful framework for foster carers and have been updated to reflect the increasing use of AI:
- Content: being exposed to illegal, inappropriate or harmful content, for example pornography, racism, misogyny, self-harm, suicide, radicalisation, extremism, misinformation, disinformation (including fake news), conspiracy theories and material featuring extreme sexual or physical violence
- Contact: being subjected to harmful online interaction with other users, or with generative AI applications that simulate this (such as chatbots), for example grooming or exploitation
- Conduct: online behaviour that increases the likelihood of, or causes, harm, for example making, sending and receiving explicit images (including images generated using AI) and online bullying
- Commerce: risks such as online gambling, inappropriate advertising, phishing and/or financial scams.
The Online Safety Act 2023 introduced new criminal offences, including:
- Sending a message with information the sender knows to be false with the intention of causing non-trivial psychological or physical harm to a likely audience without reasonable excuse
- Sending a message with a threat of death, serious injury, rape or serious financial loss where the sender intends the recipient to fear that the threat will be carried out (or is reckless as to whether the recipient has such fear)
- Sending or showing an electronic communication with flashing images with the intention to cause harm to a person with epilepsy
- Communicating, publishing or showing material capable (and with the intention) of encouraging or assisting the serious self-harm of another, even if the sender cannot identify the recipients and even if the self-harm does not occur
- Intentionally sending or giving images of any person’s genitals to another person with the intention to cause the recipient alarm, distress or humiliation, or for the purposes of sexual gratification whilst reckless as to whether the recipient will be caused alarm, distress or humiliation
- Four offences in relation to intentional sharing or threatening to share intimate images without consent, which do not necessarily require proof that the sender intended to cause alarm, distress or humiliation. (This replaces the previous offences relating to so-called ‘revenge porn’ where there was a requirement for an intention to cause distress).
Further offences have since been added to the Sexual Offences Act 2003. Since February 2026 it has been an offence to create, or request the creation of, a purported intimate image of an adult without their consent (for example, an AI-generated ‘deepfake’)(sections 66E and 66F inserted by the Data (Use and Access) Act 2025). Since 29 June 2026 it has also been an offence under the Crime and Policing Act 2026 to make, adapt, supply or offer to supply a ‘purported intimate image generator’ (often referred to as a ‘nudification’ app or tool).
Indecent images of children created by AI or computer software are ‘pseudo-photographs’ under the Protection of Children Act 1978 where they appear to be photographs, and it is an offence to make, distribute or show them (section 1). Possessing them is an offence under section 160 of the Criminal Justice Act 1988.
Sexually coerced extortion or ‘sextortion’ is a type of blackmail where someone tries to use intimate, naked or sexual photos or videos of children and young people to make them do things they don't want to do. Sometimes, these photos or videos are taken without their knowledge, and the person uses these to blackmail the child and force them to pay money or do something against their will.
Criminals often target people who use dating apps, social media platforms, webcam/live streaming sites or websites related to pornography. They might pretend to be someone else online and become friends with the child. Later, they might threaten to share pictures or videos with a child’s family and/or friends. See: Internet Watch Foundation, Help if you're worried about 'sextortion' or online blackmail.
See also: UK Safer Internet Centre, Sextortion.
The National Crime Agency's CEOP Education have issued an alert to education settings across the UK in response to this threat: FMSE Alert. The alert will help professionals to:
- Recognise and understand financially motivated sexual extortion
- Raise awareness and help-seeking behaviours amongst children and young people
- Give suitable messaging and support to parents and carers
- Support victims of financially motivated sexual extortion.
4. Indicators
The initial indicators of online abuse in children are likely to be changes in behaviour and mood. Clearly, such changes can also be attributed to many innocent events in a child's life and cannot be regarded as diagnostic. However, changes to a child's circle of friends or a noticeable change in attitude towards the use of a computer or phone could have their origin in abusive behaviour. Similarly, a change in their friends or not wanting to be alone with a particular person may be a sign that something is upsetting them.
Children often show rather than tell that something is upsetting them. There may be many reasons for changes in their behaviour, but if foster carers notice a combination of worrying signs, they should seek help or advice. They should contact their supervising social worker. A list of sources of further information and support organisations is in the Related Guidance section at the top of this chapter. If foster carers believe that a child is at risk of significant harm, they must follow the agency’s safeguarding procedures without delay. Uncertainty about sharing information should never prevent action being taken to protect a child.
5. Photographs
If it is appropriate to take pictures or videos, always ask the child's permission first and make sure they are clear on who will see them and why.
Foster carers should try to take photographs regularly of the child/young person to help record their life; it may also help when putting together their Life Story book.
Carers should be clear on who can give consent for the child to have their picture taken or be filmed for school, etc. This should be set out in the child’s Placement Plan and delegated authority arrangements.
6. Mobile Phones
Mobile phones offer text messaging, taking pictures, sending and receiving them, sending and receiving video clips and soundtracks, as well as access to the internet, which means a child can download pictures and videos.
With a camera phone, a child/young person can also send pictures of themselves, friends and where they live, which can have security implications for some Looked After Children.
Mobile phone network providers operate a barring and filtering mechanism to prevent those under 18 years accessing 18-rated content. The service can be provided for both contract and pay-as-you-go phones. Foster carers are advised to explore this with the network provider that a child/young person uses, or see what other services they offer.
7. Use of Artificial Intelligence (AI)
Artificially generated content and AI tools such as chatbots, image generators and homework assistants are increasingly being used by children. However, as with other areas of online use, these may pose a number of risks for children. Although AI can be a powerful learning tool for children, without the proper guidance they may be exposed to misinformation, privacy risks and unhealthy dependence. It is therefore essential for staff and carers to ensure that children are adequately safeguarded from the risks of abuse through artificial intelligence (AI) systems. Some of these risks include:
- Children viewing violent, sexual or disturbing information
- Children receiving harmful advice or unsafe instructions. For example, a child may ask an innocent question and may receive adult-level information/advice
- Children receiving incorrect or misleading information. AI systems can reflect biased viewpoints presented as facts which children may not recognise easily
- Privacy and data risks. Children may share personal information with an AI tool without realising the consequences
- Over-reliance on AI tools. If children rely too much on AI tools for guidance this may affect their ability to think critically. AI should support learning, not replace it
- Emotional attachment to AI tools such as chatbots. Children may be inappropriately influenced by AI responses relating to feelings or life decisions.
Keeping Children Safe in Education 2026 now recognises harmful interaction with generative AI applications that simulate human contact (such as chatbots) as a contact risk, and the making, sending and receiving of explicit images generated using AI as a conduct risk.
In order to ensure children are adequately safeguarded against the risks of artificial intelligence (AI) tools and systems, staff and carers should ensure that:
- Children do not share any personal information such as names, schools, family information and photos of themselves and others with AI tools
- Children are taught that AI systems and tools do not always give correct answers and may generate biased views or misleading information. All information from AI tools and systems should be checked with trusted sources or adults
- Carers should remain alert to the use of AI-generated content in bullying, exploitation, coercion, impersonation, fraud, image manipulation and abuse. Any AI-generated content that causes harm or places a child at risk should be responded to through the use of the foster home’s safeguarding procedures in the same way as other forms of online abuse
- AI tools and systems are used for learning, not cheating. AI tools should be used to explain concepts, encourage critical thinking and generate ideas with children, not to generate work and submit it as their own
- Children understand that images, videos, or messages online may be generated by AI tools and could be misleading or fake. They should verify all information generated by AI tools before believing or sharing it
- Children are only using AI tools approved by parents, teachers or guardians and are not downloading any unknown apps or files without permission.
The Department for Education has published guidance on Generative artificial intelligence (AI) in education and Generative AI: product safety standards, which set out the safety expectations for AI products used with children in education settings. These can also help foster carers to judge whether an AI tool is safe for a child to use.
8. AI Imagery
Artificially generated child sexual abuse material describes images of child sexual abuse that are partially or entirely computer-generated. They are usually produced using software which converts a text description into an image. This technology is developing rapidly; the images created can now be very realistic, and recent examples are difficult to differentiate from unaltered photographs.
Many popular, publicly available artificial intelligence tools automatically block attempts to create abusive material, but the large number of child sexual abuse images made using them that have been detected show that individuals have found ways around this. Typically, they are made using publicly available artificial intelligence tools that can be used and manipulated to produce images (and, increasingly, videos) depicting child sexual abuse.
It is already illegal to make, possess or distribute child sexual abuse images, including those that are AI-generated. Any AI-generated or digitally altered sexual image of a child should therefore be treated in the same way as any other indecent image of a child. Foster carers should not copy, forward or save the image, and should report the concern straight away to their supervising social worker and the child’s social worker, in line with the agency’s safeguarding procedures; the police may also need to be informed.
The Crime and Policing Act 2026 (Royal Assent 29 April 2026) creates a new offence of making, adapting, possessing, supplying or offering to supply a ‘CSA image-generator’, for example an AI model that has been made or adapted to create child sexual abuse material, with a maximum sentence of five years’ imprisonment. It also extends the existing ‘paedophile manuals’ offence in section 69 of the Serious Crime Act 2015 to cover pseudo-photographs and prohibited images. These provisions come into force on dates set by regulations, so the current position should be checked on legislation.gov.uk. See Crime and Policing Act 2026: child sexual abuse material factsheet.
9. Sharing Nudes and Semi-Nudes
This advice 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. 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’. Many professionals may refer to ‘nudes and semi-nudes’ as:
- Youth-produced sexual imagery or ‘youth involved’ sexual imagery.
- Indecent imagery. This is the legal term used to define nude or semi-nude images and videos of children and young people under the age of 18.
- ‘Sexting’. Many adults may use this term; some young people interpret sexting as ‘writing and sharing explicit messages with people they know’ rather than sharing images.
- Image-based sexual abuse. This term may be used when referring to the non-consensual sharing of nudes and semi-nudes.
Terms such as ‘revenge porn’ and ‘upskirting’ are also used to refer to specific incidents of nudes and semi-nudes being shared. However, these terms are more often used in the context of adult-to-adult non-consensual image sharing offences outlined in s.33-35 of the Criminal Justice and Courts Act 2015, Voyeurism (Offences) Act 2019 and s.67A of the Sexual Offences Act 2003. Terms such as ‘deepfakes’ and ‘deep nudes’ may also be used by adults and young people to refer to digitally manipulated and AI-generated nudes and semi-nudes.
Keeping Children Safe in Education 2026 has updated its definition of making or sharing nudes and semi-nudes to expressly include images and videos that have been digitally altered or wholly generated using AI (sometimes referred to as ‘deepfakes’ or ‘deep nudes’). All incidents of sharing nudes and semi-nudes, whether consensual or non-consensual, should be treated as a safeguarding concern and receive a proportionate safeguarding response, taking account of the circumstances, including the age of the children involved and any element of coercion or vulnerability.
10. Further Information
Legislation, Statutory Guidance and Government Guidance
Working Together to Safeguard Children 2026
Keeping Children Safe in Education 2026 - Part five covers child-on-child sexual violence and sexual harassment and replaces the withdrawn advice Sexual Violence and Sexual Harassment between Children in Schools and Colleges.
Crime and Policing Act 2026: child sexual abuse material factsheet
Generative artificial intelligence (AI) in education
Generative AI: product safety standards
Useful Websites
Royal College of Paediatrics and Child Health, Screen time and online harms: resources for members