1. Policy Statement
CyberTips Bermuda is committed to protecting every child and young person who participates in our programmes, workshops, presentations, online resources, educational activities, and digital services.
The safety, dignity, privacy, and wellbeing of children are fundamental to every aspect of our work. We maintain a zero-tolerance approach to abuse, exploitation, neglect, bullying, discrimination, harassment, grooming, and any conduct that places a child at risk.
This policy applies to all CyberTips Bermuda staff, contractors, volunteers, presenters, facilitators, consultants, guest speakers, technology partners, and any individual acting on behalf of the programme.
This policy supports compliance with the Personal Information Protection Act 2016 (PIPA), including Sections 5, 6, 7, 9, 13, 14 and 16 concerning responsibility, lawful processing, security safeguards, privacy notices, breach management, and the protection of children's personal information.
2. Purpose
This policy establishes standards for protecting children participating in:
- School workshops and community presentations
- Youth programmes and teacher training sessions
- Parent education events and summer programmes
- Online learning activities and virtual workshops
- Educational videos and downloadable resources
- Interactive digital tools
- Cyberbullying and online safety reporting
- Public awareness campaigns
3. Scope
This policy applies to Cabinet Office employees, CyberTips Bermuda staff, contractors, volunteers, guest presenters, school and community partners, technology providers acting on behalf of CyberTips Bermuda, and any person interacting with children during CyberTips activities.
The policy applies whether activities occur in schools, Government buildings, community centres, libraries, sporting venues, online, through video conferencing, through the CyberTips website, or through educational platforms.
4. Definition of a Child
For the purposes of this policy, a child is any individual under eighteen (18) years of age.
Where personal information is collected from children through digital services, CyberTips Bermuda also complies with Section 16 of the Personal Information Protection Act 2016 regarding children using information society services.
5. Guiding Principles
CyberTips Bermuda is committed to:
- Placing children's safety before all operational objectives
- Respecting the rights and dignity of every child
- Creating safe and inclusive learning environments
- Protecting children's privacy
- Promoting equality regardless of race, gender, disability, religion, nationality, sexual orientation, or family background
- Taking immediate action where safeguarding concerns arise
6. Code of Conduct
Every CyberTips representative shall:
- Treat every child with dignity and respect
- Maintain professional boundaries at all times
- Use age-appropriate language
- Promote positive behaviour and encourage respectful participation
- Report safeguarding concerns immediately
Representatives shall never:
- ×Meet privately with a child without appropriate supervision
- ×Request personal social media connections or exchange private contact details
- ×Communicate through personal messaging applications
- ×Engage in inappropriate physical contact
- ×Humiliate, ridicule, threaten, or intimidate a child
- ×Share offensive or inappropriate material
- ×Photograph or record children without appropriate consent
7. Online Safety
CyberTips Bermuda delivers educational content through digital platforms. To protect children online:
- Interactive tools collect the minimum information necessary
- Educational tools such as the Digital Hygiene Calculator and Password Strength Checker operate locally within the user's browser wherever practical
- No behavioural advertising is used and no profiling of children is undertaken
- Children are never encouraged to disclose unnecessary personal information
- Moderated environments are used for live online workshops
- Private messaging between presenters and children is prohibited
- Recording of online sessions requires prior approval and appropriate consent
8. Photography, Video and Media
CyberTips Bermuda recognises that photographs and video recordings are personal information under PIPA when an individual is identifiable. Photographs or recordings of children shall only be taken with approval from the organising school or organisation, with parent or guardian consent where required, and for educational, promotional, or documentation purposes only.
CyberTips Bermuda will not publish identifying personal information alongside children's photographs, use images in a misleading context, sell or license children's images, or permit unauthorised photography during activities.
9. Collection of Children's Personal Information
Personal information relating to children shall be limited to information necessary for programme administration, safeguarding, reporting, or educational delivery. Examples include name, school, year level, parent or guardian contact information, emergency contact information, accessibility requirements, and workshop attendance.
Information shall not be collected unless there is a legitimate purpose consistent with Sections 6, 10, and 11 of PIPA.
10. Parent and Guardian Consent
Where required, CyberTips Bermuda will obtain consent before registering children for workshops, collecting personal information, recording sessions, photographing participants, publishing media, or conducting surveys involving children.
Consent shall be clear, informed, and capable of being withdrawn where appropriate.
11. Safeguarding Concerns
Every representative has a duty to report concerns involving:
- Abuse, neglect, grooming, or online exploitation
- Child sexual abuse material
- Sextortion or cyberbullying
- Threats of violence or self-harm concerns disclosed during activities
- Any behaviour placing a child at immediate risk
Concerns shall be reported immediately through established Government safeguarding procedures and, where appropriate, to the Bermuda Police Service or the Department of Child and Family Services. CyberTips Bermuda does not investigate allegations independently where statutory agencies have jurisdiction.
12. Confidentiality
Safeguarding information shall be shared only with authorised individuals who have a legitimate need to know.
Confidentiality shall never prevent reporting where a child is believed to be at risk of harm.
13. Security of Information
Children's personal information shall be protected using administrative, physical, and technical safeguards consistent with Section 13 of PIPA. Measures include secure storage, encrypted transmission where appropriate, restricted staff access, password-protected systems, audit logging, and secure destruction of records.
14. Training
Every person delivering CyberTips programmes shall receive appropriate safeguarding training covering:
- Child protection responsibilities and online safety
- Cyberbullying and grooming awareness
- Mandatory reporting procedures
- Privacy obligations under PIPA
- Appropriate professional boundaries
Training shall be reviewed regularly.
15. Reporting Concerns
Anyone who believes a child participating in a CyberTips activity is at risk should report the concern immediately.
Safeguarding concerns involving CyberTips programmes may also be directed in writing to the Cabinet Office, Government of Bermuda, with the subject line "CyberTips Safeguarding Concern".
16. Policy Review
This policy shall be reviewed annually or earlier where required by legislative changes, operational changes, or safeguarding best practice. All revisions shall be approved by the Cabinet Office.