Online Safety, ALN and the Children’s Wellbeing and Schools Act: Why Wales Needs Smarter Safeguarding

Published 14 May 2026

This is a follow-on article in our series: The Children’s Wellbeing and Schools Act in Wales: A Guide for ALN and Electively Home Educating Families.

Online safety is not a side issue for families raising children with Additional Learning Needs.

For many ALN children and young people, digital life is not simply entertainment. It may be part of learning, communication, regulation, social connection, identity, independence, EOTAS, home education, therapy, hobbies or friendship.

That makes online safety more complicated.

A child may need technology to access the world.

The same technology may also expose them to risk.

That is why we need a smarter safeguarding conversation.

Not panic.

Not blanket suspicion.

Not “just take the device away”.

Not an assumption that every family can use the same parental controls in the same way.

We need online safety approaches that understand ALN, assistive technology, children outside school, AI-enabled risks, social vulnerability and the difference between technical skill and social understanding.

The key message is simple:

A child can be digitally skilled and socially vulnerable at the same time.

This is not an anti-safeguarding article

Learn Without Limits CIC is pro-safeguarding.

Online harms are real. Grooming, coercion, bullying, image-based abuse, sexual exploitation, scams, self-harm content, eating disorder content, extremist content, harmful algorithms, private messaging risks and AI-generated abuse are not imaginary.

Parents are right to be concerned.

Professionals are right to take online safety seriously.

Policy-makers are right to ask whether platforms have been allowed to expose children to risks for too long.

But safeguarding has to be intelligent.

If online safety policy does not understand ALN, it may miss the children who most need protection.

If it treats all children as though they use technology in the same way, it may fail disabled children, neurodivergent children, chronically unwell children, home-educated children, children on EOTAS, children with communication needs and children whose school placement has broken down.

We do not have to choose between children’s safety and family rights.

Wales needs both.

What law is already in play?

There is no single “online safety law for ALN families”.

Instead, several legal and policy frameworks overlap.

The Online Safety Act 2023 places duties on online services and platforms. GOV.UK explains that the Act requires services to tackle illegal content, including child sexual abuse material, grooming and exploitation, and to protect children from harmful and age-inappropriate content [1]. Ofcom is the regulator responsible for implementing and enforcing the Act. Ofcom has published children’s safety codes and guidance, including duties around risk assessment, age assurance, safer recommender systems and protecting children from harmful content [2], [3].

The ICO Children’s Code, also known as the Age Appropriate Design Code, contains standards for online services likely to be accessed by children. The ICO explains that the code is designed to help online services comply with data protection law and protect children’s data online [4].

The Children’s Wellbeing and Schools Act 2026 is different. For Wales, our previous articles have focused on the children not in school framework. Welsh Government says the measures include children who are educated at home, under agreed flexi-schooling arrangements or in local authority EOTAS provision. It also says that when assessing suitability, local authorities must consider any ALN and whether the education is suitable to those needs [5].

Welsh ALN law still matters too. The Additional Learning Needs and Education Tribunal (Wales) Act 2018 created the IDP system. Welsh Government guidance explains that ALN may include a disability that prevents or hinders a learner from accessing education or training facilities generally available to others of the same age [6]. Law Wales explains that the ALN Act introduced Individual Development Plans and rights of appeal to the Education Tribunal for Wales [7].

Criminal law also matters. The Crown Prosecution Service guidance explains that computer-generated or AI-generated indecent images of children can be prosecuted as pseudo-photographs where they appear to be photographs [8]. Victim Support explains that threatening to share an intimate image without consent can itself be an offence, whether or not the image exists [9].

So the law is not empty.

But it is fragmented.

Different laws deal with platforms, privacy, education, ALN, criminal behaviour, data protection and safeguarding.

What families often need is help understanding how those pieces fit together in real life.

Where the law helps

The legal direction is broadly moving away from “parents must solve this alone”.

That matters.

For years, many families felt they were expected to protect children from online risks while platforms continued to design systems that encouraged addictive engagement, contact from strangers, algorithmic rabbit holes, harmful content and poor reporting routes.

The Online Safety Act changes some of that by placing duties on services, not just parents. GOV.UK says the Act is designed to tackle illegal content, protect children from harmful material, and give users stronger ways to report concerns [1]. Ofcom’s children’s safety work includes age assurance, risk assessments, safer recommendation systems and protections from harms such as pornography, suicide, self-harm and eating disorder content [2], [3].

The Children’s Code also matters because it shifts attention towards privacy by design, high privacy settings and children’s best interests in online services [4].

For ALN families, this direction is welcome.

Children should not have to be harmed before platforms act.

Parents should not have to reverse-engineer every algorithm.

Schools and families should not be left trying to manage risks created by product design choices they cannot see or control.

But platform regulation is only part of the answer.

It does not automatically solve the ALN-specific problem.

Many online safety conversations assume that technical skill equals safety.

It does not.

Some ALN children and teenagers are extremely capable with devices, games, coding, settings, apps, servers, video editing, AI tools, online communities or workarounds.

They may be far ahead of the adults around them technically.

But that does not mean they understand the social consequences.

A young person may know how to:

join a private server;
create multiple accounts;
use a VPN;
use AI tools;
edit an image;
use a chatbot;
bypass a filter;
move between platforms;
hide an app;
make online purchases;
copy, share or screenshot content.

But they may still struggle to recognise:

grooming;
coercion;
manipulation;
fake intimacy;
blackmail;
social pressure;
financial scams;
sexual risk;
reputational harm;
permanence;
consent;
unsafe dares;
exploitative peer groups;
when a “friend” is not really a friend.

That gap matters.

A child can be digitally skilled and socially vulnerable at the same time.

This is especially important in the age of AI. AI tools can create persuasive text, realistic images, synthetic voices, fake identities, personalised responses and emotionally convincing interactions. Some children may understand how to use the tool without understanding how the tool may be used against them.

That is not a failure of intelligence.

It is a safeguarding issue.

Assistive technology complicates “just lock it down” advice

Many online safety conversations assume parents can simply remove a device, block an app, restrict the internet or apply standard parental controls.

For some families, that may be possible.

For many ALN families, it is not that simple.

A child or young person may need technology for:

AAC or communication;
speech-to-text;
text-to-speech;
screen readers;
captions;
visual support;
online tutoring;
EOTAS;
home education;
assistive software;
emotional regulation;
special interests;
social connection;
independence practice;
reduced-demand learning;
contact with trusted adults.

For some children, the device is not just entertainment.

It may be their voice.

It may be their classroom.

It may be their regulation tool.

It may be their bridge to friendship.

It may be the only way they can access education at all.

That means generic advice can miss the point.

“Just take it away” may remove communication.

“Just block the app” may remove learning.

“Just use standard parental controls” may not work properly with assistive tools.

“Just supervise” may not reflect the reality of caring responsibilities, sleep deprivation, work, multiple children, disability, poverty or family crisis.

Our earlier LWL article on online safety and vulnerability made this point clearly: many ALN and chronically unwell young people depend on assistive technology such as screen readers, AAC, voice dictation, captions, smart assistants and AI tools, and these tools are rarely considered properly in mainstream safeguarding guidance [10].

That article currently needs repair, so we will fix it as part of this online safety cluster. The point remains important.

Online safety policy cannot assume that every parent can lock down technology without also locking down access.

The Children’s Wellbeing and Schools Act does not solve online safety

The Children’s Wellbeing and Schools Act is often discussed in the same wider safeguarding climate as online safety, but families need clarity.

The Act’s Wales-facing children not in school framework is mainly about visibility, registration, information duties and local authority oversight of children not in school [5].

That may matter for safeguarding.

It may also matter for ALN children whose education has become less visible because they are home educated, on EOTAS, on a reduced timetable, absent, waiting for provision or stuck after placement breakdown.

But a register is not the same as online safety.

A local authority knowing that a child is not in school does not automatically mean anyone understands:

what platforms the child uses;
whether the child relies on assistive technology;
whether parental controls work with that technology;
whether the child is socially vulnerable online;
whether the child is isolated;
whether online spaces have become the child’s main social world;
whether AI tools are being used safely;
whether EOTAS or online tutoring platforms are accessible and safe;
whether the child’s IDP addresses digital access or safeguarding.

This is why our position is balanced.

We can support proportionate safeguarding.

We can support stronger duties on platforms.

We can support better child protection from grooming, exploitation and harmful online design.

We can also say that monitoring children outside school is not the same as securing suitable education, and it is not the same as making them safe online.

Visibility is not prevention.

Recording is not support.

Safeguarding needs relationships, access, education, practical tools and trust.

Online safety for children outside school needs special care

Children outside school may rely more heavily on digital spaces.

This can include children who are:

electively home educated;
receiving EOTAS;
on online tutoring packages;
unable to attend school because of anxiety, burnout or health needs;
recovering from placement breakdown;
isolated from peers;
waiting for a suitable setting;
using online communities for friendship or identity;
using specialist technology to communicate.

For some children, online life may reduce isolation.

It may give access to learning.

It may support identity, creativity, gaming, coding, friendship, hobbies or confidence.

But it may also create risk.

A child who has lost trust in school or adults may seek belonging elsewhere.

A young person who is lonely may become attached quickly.

A child who communicates differently may be easier to misunderstand or manipulate.

A teenager who is technically capable may still miss coercive intent.

A child with impulsivity, anxiety, trauma, literal interpretation or low danger awareness may need more explicit teaching, repetition and trusted adult involvement.

That is why the answer cannot be either “the internet is bad” or “leave them alone”.

The answer has to be child-specific.

Why AI changes the risk landscape

AI does not create every online risk from scratch.

Many risks already existed.

Grooming, bullying, image-based abuse, scams, coercion, blackmail, parasocial attachment and harmful content are not new.

But AI can make some risks faster, cheaper, more convincing and harder for children to recognise.

Recent UK reporting has highlighted concern that identifiable school photos can be misused to create AI-generated sexual images for blackmail. The Guardian reported that experts and authorities were urging schools to remove or limit identifiable pupil photographs online because criminals were using AI to create sexually explicit images from ordinary school images [11].

The law may already capture some AI-generated abuse. CPS guidance says high-quality computer-generated or AI-generated indecent images can be prosecuted as pseudo-photographs where they appear to be photographs, and that the law applies regardless of method of creation [8].

But prevention is still difficult.

Once an image is online, a child and family may have very little control over what happens next.

That matters for all children.

It may matter especially for ALN children who may struggle to understand:

why a public image can be misused;
how quickly screenshots spread;
why a fake image can still cause real harm;
why a chatbot may not be a friend;
why someone asking for secrecy is a red flag;
why a threat can be criminal even if the image is fake;
why shame should not stop them asking for help.

Victim Support explains that threatening to share an intimate image can be an offence whether or not the image exists [9]. That point matters because children may be blackmailed over images that are altered, fake, AI-generated or claimed to exist.

The legal framework is trying to catch up.

Families need practical guidance now.

A useful way to see the legal landscape

Framework	What it helps with	Where ALN families may still face gaps
Online Safety Act 2023	Platform duties around illegal content, child safety, harmful content, reporting and age assurance [1], [2], [3]	Does not create a bespoke ALN online safety pathway. Does not solve assistive technology compatibility or family-level safeguarding needs.
ICO Children’s Code	Privacy by design, children’s data, high privacy defaults and best interests [4]	Focuses on data protection, not all content risk. Does not guarantee that parental controls work for AAC, screen readers or AI tools.
Children’s Wellbeing and Schools Act 2026	Visibility of children not in school in Wales, including EHE, flexi-schooling and EOTAS, with ALN to be considered in suitability [5]	Does not itself provide online safety planning, assistive technology guidance or AI-risk support for children outside school.
Welsh ALN law	IDPs, ALP, participation and challenge rights for children and young people with ALN [6], [7]	Does not directly regulate platforms or online social spaces. Digital access and online safety may need to be raised within the child’s IDP or support planning.
Criminal law	Grooming, child sexual abuse material, image-based abuse and threats may be criminal [8], [9]	Often acts after harm or threat has occurred. ALN children may not recognise, report or explain risk early.
Equality and disability principles	Disabled children should not be excluded from education, communication or services because standard systems do not fit their needs [6]	Online safety policies do not always build in disability access, assistive technology or cognitive vulnerability from the start.

This is why families need more than slogans.

They need joined-up safeguarding that understands access as well as risk.

Questions parents can ask

Parents do not need to become lawyers.

But some practical questions can help.

If your child uses technology for learning, EOTAS, home education or communication, you may want to ask:

What platforms, apps or devices does my child need for education or communication?
Are parental controls available on those tools?
Do those controls work with AAC, screen readers, speech-to-text, captions or other assistive technology?
Who has checked the privacy and safety settings?
Does my child understand private messaging, screenshots, fake accounts and AI-generated content?
Does my child know what to do if someone asks for secrecy, images, money, personal information or a private chat?
Does my child know that fake images can still be harmful and that threats should be reported?
If my child has an IDP, should digital access, online learning, assistive technology or online safety be discussed in the review?
If my child receives EOTAS or online tutoring, who is responsible for checking the platform, supervision arrangements and communication rules?
If a local authority is assessing suitable education at home, will it understand that technology may be both access and risk?
If my child is socially isolated, what safe, supported routes to friendship and activity are available?

The goal is not to frighten families.

The goal is to make invisible risk and invisible access needs visible.

What schools, local authorities and providers should understand

Schools, local authorities, EOTAS providers, online tutoring providers and policy-makers need to understand that ALN online safety is not generic online safety with a disability label added at the end.

They should ask:

Does this child need technology to communicate?
Does this child rely on technology to access learning?
Does this child understand social risk at the same level as their technical ability?
Is the child more vulnerable because of isolation, anxiety, trauma, impulsivity, literal interpretation, learning disability or communication differences?
Are online safety lessons accessible to this child?
Are safety policies realistic for this family?
Are restrictions blocking access?
Are access needs being mistaken for parental permissiveness?
Are online risks being discussed in IDP, EOTAS or transition planning where relevant?

A safeguarding approach that removes access without replacing it is not enough.

A safeguarding approach that allows access without support is not enough either.

The right question is:

How do we protect this child while preserving communication, education and inclusion?

Where parent peer support can help

Parent peer support cannot replace safeguarding advice, legal advice, policing, social care, health services, school safeguarding routes or specialist support.

But trusted parent communities can still play a useful role.

LWL’s parent peer community has been useful in practical safeguarding terms. Over the years, parents have sometimes used the community to sense-check concerns, ask where to go next, or understand whether something may need urgent action. Where parents have identified online risks that sit beyond peer support, the community has helped signpost them promptly towards the appropriate authorities or specialist routes. On occasion, that has included the police.

We do not discuss individual cases publicly, and peer support is not a substitute for safeguarding, legal or policing advice.

But this experience matters.

It shows that trusted parent communities can play an early-warning and signposting role when families are worried, confused or unsure whether an online situation has crossed a line.

This is especially important for ALN families, because parents may be trying to work out whether a child’s behaviour reflects curiosity, vulnerability, coercion, misunderstanding, exploitation, distress or something more urgent.

A safe community does not tell parents to ignore concerns.

A safe community helps parents find the right route quickly.

Where LWL fits

This is exactly why LWL talks about prevention, bridging and progression.

Prevent means giving families clearer guidance before risk escalates.

Bridge means supporting families through the messy middle, where education may already be disrupted, the child may be online more, and parents may be trying to manage learning, safety, wellbeing and trust at the same time.

Progress means helping children and young people move towards safer, more supported routes into education, community, skills, further learning, volunteering, employment or independence.

Online safety belongs in the Prevent layer.

It also belongs in the Bridge layer for children whose education has broken down.

And it belongs in the Progress layer because young people need to learn how to navigate digital life safely as they move towards adulthood.

This is not about replacing parents, schools, police, social care, health services, regulators or platforms.

It is about helping families understand the landscape and ask better questions.

It is also about feeding real-world parent insight back into policy.

Because if policy only sees “children online”, it will miss the children who are online because that is where their education, communication and connection now happen.

We have also written about when online engagement becomes emotional dependency, because emotional pull, attachment, algorithms and vulnerability can all matter when children are spending more time online [12].

We will be repairing and updating our earlier article on online safety, vulnerability and safeguarding for ALN and chronically unwell teens as part of this online safety cluster [10].

The key message

Online safety matters.

Safeguarding matters.

Platform accountability matters.

Children outside school matter.

ALN rights matter.

Assistive technology matters.

AI risk matters.

Family privacy matters.

None of these should be treated as disposable.

The right debate is not “safeguarding versus rights”.

The right debate is whether safeguarding is being designed intelligently enough to protect the children who do not fit the standard model.

For some ALN children, technology is not just risk.

It is access.

For some ALN children, online spaces are not just entertainment.

They are connection.

For some ALN children, technical ability does not mean social safety.

Trusted parent communities can also help families act earlier, as long as everyone understands where peer support ends and specialist or statutory safeguarding routes begin.

If Wales wants safer children, it needs more than visibility.

It needs proportionate, disability-aware, ALN-aware safeguarding that understands how children actually live, learn and communicate.

Legal disclaimer

This article is for general information only. It is not legal advice, safeguarding advice, technical advice or clinical advice.

Online safety, safeguarding, criminal law, education law, ALN, EOTAS, home education, disability rights and data protection can be complex. Families facing immediate risk, exploitation, threats, grooming, image-based abuse, self-harm risk or criminal behaviour should seek urgent support from the appropriate emergency, safeguarding, policing, school, local authority, health or specialist advice route.