Adopting Social Media Check
Enhancing Recruitment Processes with Automated Solutions
With the changes to the Keeping Children Safe in Education (KCSIE) guidelines, organisations like Lumen Learning Trust had to find innovative and efficient ways to ensure their recruitment processes were robust, compliant, and free from bias. The KCSIE guidelines necessitate rigorous background checks to ensure the safety and wellbeing of children. This need led them to adopt Social Media Check’s (SMC) automated solution in November 2022.
Gail Murphy, Operations Manager at Lumen Learning Trust, said:
“With the changes to the KCSIE guidelines, we needed an efficient, cost-effective and compliant way to conduct online checks. Social Media Check’s automated solution reduces the risk of subjectivity and unconscious bias and its ease of use and comprehensive reporting has enabled us to realise operational efficiencies in our recruitment process.”
Adopting the SMC solution has enabled Lumen Learning Trust to be assured regarding their compliance to the expectations regarding Social Media use by prospective candidates in their recruitment process. The Trust has run over 300 reports, each providing comprehensive insights and facilitating informed decision-making. The automated nature of the solution means that checks are conducted uniformly, minimising the risk of human error and bias. This standardisation is crucial in maintaining the integrity and fairness of the recruitment process.
About Lumen Learning Trust
After achieving an Outstanding judgement in leadership and management in February 2010 Saxon Primary School began to support vulnerable schools both locally and further afield, drawing on their own experience of being a school in Special Measures in 2007 to such a position of strength that it gained sponsorship status from the DfE in June 2013. It was designated a National Support School by the National College for Teaching and Leadership in September 2013. Lumen Learning Trust was established in Autumn 2013 as a natural development of the school-to-school support carried out by the leadership team at Saxon Primary. It currently consists of six member schools: Saxon Primary in Shepperton, The Echelford Primary in Ashford, Riverbridge Primary in Staines-upon-Thames – all in the Surrey borough of Spelthorne, Walton Oak School in Walton-upon-Thames in the Surrey borough of Elmbridge, Darley Dene Primary in Addlestone in the Surrey borough of Runnymede and Ewell Grove Primary & Nursery in Ewell in the Surrey borough of Epsom and Ewell.
Lumen Learning Trust puts the children’s needs at the heart of its provision. We are committed to enabling children become successful lifelong learners and happy, fulfilled adults who can make positive choices about their future.
How did Lumen Learning Trust solve the KCSIE conundrum?
Faced with the new KCSIE guidelines, Lumen Learning Trust initially conducted online searches manually, using a template to ensure members of the newly formed centralised HR team carried out a consistent approach. This proved unsustainable in terms of the labour-intensive nature of the process and the inherent difficulties in establishing if the correct individual’s accounts were being interrogated when aliases featured as user or profile names. In addition, the process required bespoke school filtering settings which became challenging operationally to maintain.
Key Steps in the Solution:
The success of the SMC solution at Lumen Learning Trust sets a precedent for other educational institutions. The Trust’s proactive approach in adopting new technology not only enhances their recruitment process but also ensures they remain at the forefront of best practices in safeguarding and compliance.
In conclusion, the partnership between Lumen Learning Trust and Social Media Check exemplifies how technology can be harnessed to meet stringent regulatory requirements while driving operational efficiencies. The Trust’s experience highlights the transformative potential of automated solutions in creating a safer, fairer, and more efficient recruitment process.
Background to guidance on KCSIE online checks
In January 2022, the Department for Education published a consultation on proposed changes to the statutory guidance for schools and colleges in England — Keeping Children Safe in Education (“KCSIE”).
In relation to safer recruitment, the DfE wanted to gauge whether schools and colleges agreed to a proposal that they should consider conducting online due diligence checks on publicly available information concerning shortlisted candidates. Seventy per cent of respondents to the consultation supported the proposal.
Whilst the DfE noted that many schools and colleges already carry out online searches as part of their safer recruitment processes, it was decided to implement the proposal by adding a new paragraph into Section 3: Safer Recruitment – stating that schools should consider online searches as part of their due diligence checks on shortlisted candidates.
The paragraph reads:
‘In addition, as part of the shortlisting process, schools and colleges should consider carrying out an online search as part of their due diligence on the shortlisted candidates. This may help identify any incidents or issues that have happened, and are publicly available online, which the school or college might want to explore with the applicant at interview.’
Whilst schools and colleges can choose not to carry out an online search, those who take this approach should record their reasons for their decision and ensure candidates are treated consistently.
The revised KCSIE guidance states that the purpose of the online search is to “identify any incidents or issues that have happened, and are publicly available online, which the school or college might want to explore with the applicant at interview”. The online search should be carried out on candidates once they have been shortlisted but before the interview stage
The focus of any online search should be “incidents or issues” that may cause concern regarding a candidate’s suitability to work with children. This may include, for example, offensive or inappropriate behaviour or language, drug or alcohol misuse, inappropriate images, discriminatory behaviour, and any other information that may raise concern as to an applicant’s suitability to work with children.
Where the findings are of a serious nature, then any further recruitment procedure is unlikely to take place. However, any such information that comes to light as a result of the online search which could cause embarrassment to either employer or employee, but would not preclude the candidate from being employed, can be discussed at interview.
The requirement is expressed as a “should” rather than a “must” (i.e. schools “should consider” carrying out an online search). KCSIE is clear that the use of the term ‘should’ in the statutory guidance means that the advice should be followed unless there is good reason not to.
The independent Schools Inspectorate has stated:
“Where the guidance states schools should do something, this should be followed unless the school has a good reason not to.”
In light of this, unless a school has a good reason not to do so, it ought to carry out online searches on shortlisted candidates. Where a school decides not to carry out an online search, this decision, and the reasons for it, should be documented internally.
The problem with KCSIE guidance
Since its introduction, the clarity, or lack of it, concerning online checks has been highlighted and discussed by safeguarding experts, academies and legal firms. This not only refers as to whether a check should be undertaken but also as to how it should be undertaken.
In a recent article in Schools Week₁, Dai Durbridge from Browne Jacobson, legal experts in the education sector, said that:
“In its 2022 consultation response, the government recognised that online issues were already a problem. The majority of those online issues were, and still are, found on social media.
At that time, the government recognised that greater clarity was required, noting that “further detail should be provided on which sites to search, how far back to go and how to deal with information that is found”.
That clarity was not provided; it is needed now.
Most agree that to minimise the risk of discrimination and/or unconscious bias the search should be carried out by a member of staff not directly involved in the decision-making process.
However, where schools should look, how far back they should go and how the search should be carried out is open to interpretation and is the biggest cause of concern.
Some schools have adopted a manual approach. The obvious starting point is to undertake a search using a recognised search engine such as Google using the applicant’s name. The majority of searches will relate to posts on the major social media sites. However, manual searches are fraught with dangers:
Have you?
Ensured you’re checking the right individual? – Same name but wrong profile. Where a number of individuals appear in a name search, this may result in multiple searches being carried out particularly for common names. Other search criteria will often need to be added, making it a tedious, time consuming and, more importantly, an ineffective search compared to a technology solution.
Mistakenly identified protected characteristics not relevant to a hire? This refers to a personal trait that cannot be used as a reason to discriminate against someone and would include age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. A google search undertaken by a human is not only risky but also can be unlawful and costly. Although a search might seem easy, risks relating to discrimination and processing of personal data are less straightforward as highlighted in a recent tribunal case by Lewis Silkin₂.
Avoided unconscious bias and subjectivity? – This inevitably happens when there is human intervention in a search process. Unconscious bias is when an individual unknowingly makes decisions or judgements on the basis of assumptions, prior experience, prejudice or stereotype that may be held about a particular group of people. This bias can often relate to protected characteristics or even personal traits.
Gained consent of the individual? – Information posted on social media is considered to be in the public domain. Indeed, there is no law prohibiting or restricting employers from checking candidates’ or employees’ social media and permission to do so isn’t required but it must be conducted in compliance with relevant laws, such as the General Data Protection Regulation (GDPR) and the Equality Act 2010. However, to ensure effectiveness and compliance, it is considered best practice for employers to obtain consent by seeking the candidate’s permission and informing them about the nature and purpose of the checks to avoid discrimination and ensure fairness in the recruitment process.
Maintained a consistent approach to your search – Clearly defined parameters are necessary to ensure a consistent approach including which sites to search, how far back to go and how to identify what constitutes a risk. However, manual checks by their very nature can be inconsistent, prone to error and critical information can be missed due to the high volume of posts that can be found across several social media platforms, not withstanding the issue of finding protected characteristics.
Calculated the true cost of the time taken? – Deploying existing staff to undertake a manual search may seem a cheaper option. However, to conduct a thorough search across multiple platforms is time consuming and very often inefficient, and inconsistent. Collating and recording the information so that it can be accessible to others adds considerably to the man hours and the true cost. In addition, schools should consider the cost of a bad hire in terms of recruitment costs and possible reputational damage from media exposure that can take years to repair.
Created an auditable report? – Ofsted and ISI will expect to see concise documentation of how a search has been conducted to meet safeguarding requirements.
In March 2023, the Department for Education published (DfE) new filtering and monitoring standards. In Keeping Children Safe in Education (DfE), filtering and monitoring has been given greater emphasis. Filtering is preventative. It refers to solutions that protect users from accessing illegal, inappropriate and potentially harmful content online. It does this by identifying and blocking specific web links and web content in the form of text, images, audio and video.
Moreover, The UK Safer Internet Centre (UKSIC) states that schools should use filtering and monitoring systems to manage and block illegal and inappropriate content such as extremism, pornography, violent images and drugs. Therefore, it becomes unworkable for many HR and safeguarding leads in schools to even carry out a proper manual check if these filtering systems are effective.
Why undertake social media checks?
A social media check is designed to complement the range of standard recruitment checks that employers usually carry out. Many organisations require a Disclosure and Barring Service (DBS) check as part of the vetting process for prospective and current employees. Of course, a DBS check is a great way to ensure that individuals have a clean criminal record particularly where safeguarding and security is of paramount importance. Indeed, employers are responsible for ensuring that applicants are deemed safe to work with children and vulnerable adults, and cleared to work in regulated sectors. However, there are other behaviours that aren’t considered to be crimes but are equally important in assessing someone’s suitability for a role. A social media check provides a more holistic view of an applicant, giving the employer valuable insight into how a person is likely to behave in the workplace or fit with the values of the organisation.
What should employers look for in a candidate’s social media profile?
The purpose of the check is to identify any negative behaviours, views or attitudes that may be unacceptable in the workplace and could result in a bad hire or reputational damage to an organisation. This could include swearing and profanity, racism, nudity, violence, drugs or links to proscribed organisations. Search results should be reviewed and discussed with the applicant at interview. Whilst some findings might prevent the recruitment process proceeding, others may simply be naïve posts made years ago and the opportunity to edit or delete a post would be acceptable to both employer and candidate.
The value and advantages of a technology solution
A fully automated, technology solution to undertake social media checks using algorithms, machine learning and artificial intelligence overcomes many of the issues and pitfalls illustrated above.
