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Pulling the Plug on Cyberbullies: Should Schools be Responsible for Sticks and Stones Thrown in Cyberspace?

His name is Ghyslain Raza, but you may know of him as “Star Wars Kid”, a portly 15-year-old student at a Quebec private high school who had filmed himself wielding a mock light saber, pretending to be a Star Wars character in combat. The two-minute video was supposed to be private, but he left it lying around at his school where three students, who did not know the teenager, came across the video, posted it on the Internet on April 14, 2003, adding a message inviting people to make insulting remarks about the clip.

Unfortunately for him, it wasn’t just his friends who found the footage so amusing. The video went ‘viral’. One Web log that posted the video was allegedly downloaded 1.1 million times, and by October 2004 one Internet site dedicated to the video had recorded 76 million visits. According to UK marketing firm The Viral Factory, it became the most downloaded video of 2006. So mortified was the teenager that he dropped out of school and finished the semester at a psychiatric ward. According to the student, “It was simply unbearable, totally. It was impossible to attend class.” More than 35 other revised versions of the video clip, created by other people, have found their way to the Internet, with additional sound and visual effects.

This is an extreme but far from unique example of the devastation wrought by cyber-bullying, the term given to internet conduct in which students harass other students by e-mail and on the internet. Given the potentially devastating consequences of cyberbullying, should schools have the power to discipline their students engaging in this form of harmful conduct?

A major issue confronting school boards is that cyberbullying usually does not take place at school, although its effects can later reverberate among students during school hours. Students may post offensive material from home, or other times outside of school hours, but the targets are fellow classmates. Is it appropriate for a school board to discipline a student for posting such material simply because the postings are being accessed by other students at school or target other students? At the same time, with power comes responsibility – if school boards have the power to discipline students for their behavior outside of school, are schools then to be mandated with the responsibility to essentially monitor and censor the world-wide web? Just how far should a school board’s jurisdiction extend regarding inappropriate off-school student e-conduct?

School Boards, Cyber Bullies and the US Courts

Although it does not appear that a Canadian court has yet ruled on the issue, the scope of a school’s jurisdiction to take action against cyberbullying as been dealt with by U.S. courts, where cyberbullying has been analyzed in the context of a student’s First Amendment Right to freedom of speech.

A First Amendment Right to be a Cyberbully?

Even in the U.S., where freedom of speech receives its most liberal interpretation, Courts recognize that public schools have an affirmative obligation to instill in students the “fundamental values of ‘habits and manners of civility’ essential to a democratic society” and to teach students “the boundaries of socially appropriate behavior”. As such, where a student engages in lewd, vulgar, or plainly offensive speech at school, the school may regulate such speech as part of its duty to convey to its students “the essential lessons of civil, mature conduct.”

Unfortunately, when faced with cyberbullying, a School Board’s hands may be tied. Consider the November 2009 decision of the U.S. Federal District Court, J.C. v. Beverly Hills Unified School District et al. In that case, the plaintiff, a female student at the Beverly Vista High School referred to as J.C., had recorded a four-minute and thirty-six second video of her friends talking about a classmate of theirs, C.C. in a derogatory manner, referring to her as a “slut”, a “spoiled brat” and other unflattering terms. During the video, J.C. instigates this conversation, encouraging her friends to their ‘rant’ about C.C. In the evening on the same day, J.C. posted the video on “YouTube” from her home computer. (The New York Times reports that J.C.’s father, Evan Cohen, who is a music industry lawyer in Los Angeles, has refused to remove the video, and has posted it on YouTube “as a public service”). The video exhibit can be viewed at this link: http://www.youtube.com/watch?v=j6LM6tWNoQo).

While at home that evening, J.C. contacted 5 to 10 students from the School, including C.C., and told them to look at the video on YouTube. C.C. told the plaintiff that she thought the video was mean. J.C. offered to take the video off the website, but C.C. asked her to keep the video up; apparently, C.C.’s mother had advised that she tell J.C. to keep the video up so that they could present it to school administrators the next day.

The video received 90 “hits” that evening. The next day, C.C. and her mother spoke with school counselor about the video. C.C. said she faced “humiliation” and had “hurt feelings”, and did not want to go to class. The counselor spent roughly 20-25 minutes counseling C.C., eventually convincing her to attend her classes. The school administrators then pulled J.C. from class and demanded that she write a statement about the video, and instructed her to delete the video from YouTube, and from her home computer. School administrators questioned the other students in the video, and asked each of them to make a written statement about the video. The school then suspended J.C. from school for two days after obtaining an opinion from a lawyer. No disciplinary action was taken against the other students in the video.

The plaintiff, J.C., sued the School District, arguing that they had violated her First Amendment rights by punishing her for making the YouTube video and posting it on the Internet. She argued that the School had no authority to discipline her because her conduct took place entirely outside of school:

  • The video was made and posted by J.C. outside of school hours and off of school property.
  • There was no evidence that any student viewed the YouTube video on his or her cell phone while at School. In fact, the School had specifically blocked access to YouTube and other social networking websites on its computers, and prohibited students from using their cell phones on campus in any manner.
  • The only time that the video was viewed on campus was during the school administrator’s investigation of the video.

It’s an interesting question – how much power, (and conversely, responsibility?) does a school have for disciplining students who commit cyberbullying?

Now, in J.C.’s case, the Court looked to a 1969 decision of the U.S. Supreme Court, Tinker v. DesMoines Independent Community School District, which had held that a school may regulate a student’s speech or expression if such speech causes or is reasonably likely to cause a “material and substantial” disruption to school activities or to the work of the school.

Applying the “Tinker Test”

In Tinker, two high school students and one junior high school student wore black armbands to school in protest of the Vietnam War. School officials asked them to remove the armbands, but they refused. Pursuant to a school policy adopted just days before in anticipation of a protest, the students were suspended until they would return to school without the armbands.

The lower court upheld the suspension, but the Supreme Court reversed it. In an oft-quoted passage, the Court noted: “It can hardly be argued that either students or teachers shed their constitutional rights to freedom of speech or expression at the schoolhouse gate.” The Court found that the students’ expression constituted political speech. Although the issues raised by such speech were undoubtedly controversial – the propriety of the Vietnam War – the students’ conduct was “a silent, passive expression of opinion, unaccompanied by any disorder or disturbance on [their] part.” The rule coming out of this case is as follows:

A student may express his opinions, even on controversial subjects, so long as doing so does not (1) materially and substantially interfere with the requirements of appropriate discipline in the operation of the school, or (2) collide with the rights of others.

Conversely, school discipline is appropriate where (3) the facts reasonably lead school authorities to anticipate substantial disruption of, or material interference with, school activities as a result of the student’s speech.

What did this mean for J.C.?

1. Did J.C.’s conduct substantially interfere with the requirements of appropriate discipline at the school?

In J.C.’s case, the School had to address the concerns of an upset parent and a student who temporarily refused to go to class, and that five students missed some undetermined portion of their classes on May 28, 2008. The Court was of the opinion that this did not rise to the level of a substantial disruption. In reaching this conclusion, the Court noted that J.C.’s video was not violent or threatening. There was no reason for the School to believe that C.C.’s safety was in jeopardy or that any student would try to harm C.C. as a result of the video. C.C. never testified that she feared any type of physical attack as a result of the video. Instead, C.C. felt embarrassed, her feelings were hurt, and she temporarily did not want to go to class. The Court was of the opinion that these concerns could not, without more, warrant school discipline.

The Court stated that C.C.’s hurt feelings did not cause any type of school disruption. C.C. did not confront J.C. or any of the other students involved in the video, either verbally or physically, while at school, nor did she indicate any intention to do so. Although C.C. was upset, the Court noted that it took the school counselor, at most, 20-25 minutes to calm her down and convince her to go to class.

The School Board’s emphasized young students often say hurtful things to each other, and that students with limited maturity may have emotional conflicts over even minor comments. However, the Court was of the opinion that the school could not suspend a student simply because another student took offense to their speech, without any evidence that such speech caused a substantial disruption of the school’s activities.

Furthermore, the School Board did not show that the actions they took to resolve the situation created by the video were outside the realm of ordinary school activities. The Court stated that:

As long as students have attended school, some get sent to the principal’s office for possible discipline, some seek counseling from the school counselors, and upset parents on occasion. For the Tinker test to have any reasonable limits, the word “substantial” must equate to something more than the ordinary personality conflicts among middle school students that may leave one student feeling hurt or insecure. Likewise, the mere fact that a handful of students are pulled out of class for a few hours at most, without more, cannot be sufficient. Tinker establishes that a material and substantial disruption is one that affects “the work of the school” or “school activities” in general. The School’s decision must be anchored in something greater than one individual student’s difficult day (or hour) on campus.”

As a result, there wasn’t a disruption of sufficient magnitude to satisfy the Tinker test.

2. Was the School Board’s decision to suspend J.C. based on a reasonable belief that the YouTube video was likely to cause a substantial disruption in the future?

The school’s administrative principal testified that she believed classes would be disrupted by the video as a result of students “gossip[ing]” and “passing notes” in class instead of focusing on the lesson, and “children worr[ying] about whether or not something she had said had been videotaped and whether or not that would show up online.”

The Court did not feel that the fear that students would “gossip” or “pass notes” rose to the level of a substantial disruption. Rather the speech must create something more than a “mild distraction or curiosity”. The Court noted that, had the School Board shown, for example, that C.C. and the students in the video engaged in a verbal dispute during class over similar comments in the past, or that J.C. and C.C. often were disciplined for arguing with each other during school, that may have changed the analysis but there was no such evidence. The Court agreed that thirteen-year-olds often say mean-spirited things about one another, and accepted that C.C. was upset, even hysterical, about the YouTube video, and that the School’s only goal was to console C.C. and to resolve the situation as quickly as possible, the Court “would not uphold school discipline of student speech simply because young persons are unpredictable or immature, or because, in general, teenagers are emotionally fragile and may often fight over hurtful comments.” Thus, the School’s fear that thirteen-year-old students might pass notes in class and worry about their reputation while in school did not support the School’s decision to suspend J.C.

3. Does J.C.’s Speech Impinge On the Rights of Others?

Tinker held that a school may regulate student speech that interferes with the “the school’s work or [collides] with the rights of other students to be secure and be let alone.” In other words, speech that “impinge[s] upon the rights of other students” may be prohibited even if a substantial disruption to school activities is not reasonably foreseeable.

This prong of the Tinker test has rarely been applied by lower courts, however, in part because the Court’s analysis in Tinker focused primarily on whether a substantial disruption was reasonably foreseeable. The School Board relied, in part, on Ninth Circuit case of Harper v. Poway Unified School District.

Harper v. Poway Unified School District

The case of Harper considered a student’s decision to wear a T-shirt with a religious message condemning homosexuality during the school’s “Day of Silence”; a day that was intended by the school to “teach tolerance of others, particularly those of a different sexual orientation.”On that day (and the day after), student Tyler Harper came to school wearing a T-shirt on which the words “Homosexuality is Shameful” were handwritten. Harper was sent to the principal’s office and was not permitted to return to class for the rest of the day.

Shortly thereafter, Harper brought suit against the School District, alleging (among other things) a violation of his First Amendment rights. The district court denied Harper’s request for a preliminary injunction, and the Ninth Circuit affirmed. Analyzing the case under the rights of others prong from Tinker, the Ninth Circuit found that the speech constituted a “verbal assault [to public school students] on the basis of a core identifying characteristic such as race, religion,

or sexual orientation.”. The court found that: “It is simply not a novel [or disputed] concept, however, that such attacks on minority students can be harmful to their self-esteem and to their ability to learn. Thus, the court held that student speech that attacks “particularly vulnerable” students on the grounds of “a core characteristic” – namely, race, religion, and sexual orientation – impinged on the rights of others and could be regulated under Tinker. The court, however, expressly limited its holding to speech attacking students on those three grounds, and even declined to extend its holding to remarks based on gender.

In J.C.’s case, the School Board argued that the Harper case stood for the fact that “California schools have an obligation to protect students from psychological assaults that cause them to question their self worth.” Although the Court acknowledged that the School was attempting to protect C.C. from psychological harm, the Court did not feel that Harper permitted the school to regulate any speech that could cause some emotional harm to a student. Rather, the Court in J.C. adopted very narrow interpretation of this prong of the Tinker Test, holding that a school could only regulate harmful speech if it attacked students on the basis of race, religion, or sexual orientation.

Based on all of the above, the Court decided that the School Board had acted improperly in deciding to suspend J.C.

Where Do They Go from Here? The 3rd Circuit’s Split Decisions

The role that a School Board may play with respect to regulating cyberbullying is by no means clear cut. Just last month, a federal appellate court re-heard argument in a pair of cases that both involve high school students who were suspended for creating fake MySpace pages on their home computers to ridicule their principals.

In Layshock v. Hermitage School District, Judge Terrence F. McVerry of the Western District of Pennsylvania found that school officials went too far when they suspended Justin Layshock for creating a fake profile on MySpace.com, which parodied Hickory High School’s principal, referring to him as a “big steroid freak,” a “big hard ass” and a “big whore” who smoked a “big blunt.” The school district had suspended Layshock for 10 days, and sent him to an alternative program. He also was prohibited from attending his graduation ceremony

In J.S. v. Blue Mountain, Judge James M. Munley of the Middle District of Pennsylvania upheld a 10-day suspension of a student who posted a profile on MySpace in March 2007 that showed a photo of principal James McGonigle and described him as a pedophile and a sex addict whose interests included “being a tight ass,” “fucking in my office” and “hitting on students and their parents.”

Both cases were appealed, but the 3rd Circuit also proved to be split, issuing two apparently conflicting rulings on the same day. The court re-heard the argument in the cases last month, on June 3, 2010 and the decisions are currently pending.

The Canadian Approach: A Negative Impact on the School Climate

The only Canadian case that appears to have dealt with cyberbullying to date is a decision of the Child and Family Services Review Board, R.T. v Durham Catholic District School Board. The Review Board was asked to consider whether the School Board had acted properly in expelling a student for cyberbullying even though the behavior did not occur at school or at a school related activity. Cyberbullying was not considered in the context of a right to freedom of speech, but rather in the context section 310(1) of Ontario’s Education Act, R.S.O. 1990, c. E-2, which empowers a School with the authority to expel a student if the student’s conduct has a negative impact on the school climate. Although the legal framework for this decision differs dramatically from U.S. cases, the practical considerations are somewhat similar.

The cyberbully, referred to as V.K., was a 13 year old student in Grade 8 at a school in Ontario. In January 2008, the bully was added to the Facebook Page of another female student at the school. V.K. had set up a profile using a Facebook name and profile that was very similar to the victim, and began impersonating her and contacting the victim’s friends.

V.K. then began sending threatening email messages to the victim such as “…U DON’T WANT ME TO GET MAD BECAUSE THEN ILL KILL YOU RIGHT IN UR SLEEP OR AT SCHOOL ON MONDAY.”, and “ ….I am gonna come to school on Monday and kick ur ass. im gonna kill u. ok? ok!”

The victim’s father learned about the threatening emails, contacted the police and Facebook and also spoke to the school’s vice principal, informing her of his concerns regarding threatening emails that his daughter had received. He was concerned about his daughter’s safety, as one message was a threat that his daughter would be killed while attending an upcoming Grade 8 camping trip.

Facebook had also closed the bully’s account three times, which she re-opened. The Police retained a computer expert, who discovered that the bully was actually the Student, V.K. He explained that she had, in fact, created 11 email accounts to impersonate some students, and she had been investing a large amount of time managing and monitoring the accounts, as well as reopening some of them when they were shut down.

In March of 2008, V.K. was expelled from the School for engaging in activities or patterns of behaviour on or off school property that caused her continuing presence in the school to create an unacceptable risk to the physical or mental well-being of other students in the school. The fear of significant harm generated by the Facebook communications and the subsequent knowledge that this was committed by one of the pupils at the school led the School Board to find that the school climate was negatively impacted by the infraction.

V.K.’s mother appealed the decision to expel her daughter to the Review Board. Pursuant to regulation, the Review Board was required to consider the effect the effect of the bully’s behavior on the school climate and certain other “mitigating factors” and “other factors”, as follows:

Mitigating factors

2. For the purposes of …the Act, the following mitigating factors shall be taken into account:

1. The pupil does not have the ability to control his or her behaviour.

2. The pupil does not have the ability to understand the foreseeable consequences of his or her behaviour.

3. The pupil’s continuing presence in the school does not create an unacceptable risk to the safety of any person. O. Reg. 472/07, s. 2.

Other factors

3. For the purposes of subsections 306 (2), 306 (4), 310 (3), 311.1 (4) and clauses 311.3 (7) (b) and 311.4 (2) (b) of the Act, the following other factors shall be taken into account if they would mitigate the seriousness of the activity for which the pupil may be or is being suspended or expelled:

1. The pupil’s history.

2. Whether a progressive discipline approach has been used with the pupil.

3. Whether the activity for which the pupil may be or is being suspended or expelled was related to any harassment of the pupil because of his or her race, ethnic origin, religion, disability, gender or sexual orientation or to any other harassment.

4. How the suspension or expulsion would affect the pupil’s ongoing education.

5. The age of the pupil.

6. In the case of a pupil for whom an individual education plan has been developed,

i. whether the behaviour was a manifestation of a disability identified in the pupil’s individual education plan,

ii. whether appropriate individualized accommodation has been provided, and

iii. whether the suspension or expulsion is likely to result in an aggravation or worsening of the pupil’s behaviour or conduct.

In V.K’s case, the Review Board reached the following conclusions with respect to these enumerated factors:

A. Impact on the School’s Climate

In a letter to the Review Board, the victim described how she was affected by the threatening emails: she had trouble sleeping; she felt isolated; she was afraid for herself and for her family; she was closing the blinds at home and she was always watching over her shoulder. There was also some evidence that the victim’s sister, a student at the school, was also negatively impacted by the threats.

The Review Board was of the opinion that, since School Board was responsible for the safety of all students and since, V.K.’s actions were extremely serious, it would have been impossible for V.K. to return to the School once it was known that she was the author of the emails. The climate of the school would have been seriously affected.

B. Mitigating Factors

1. The pupil does not have the ability to control his or her behaviour.

V.K.’s mother argued that her daughter had attended school regularly and without incident. In her report cards, under cooperation with others and conflicts of resolution, most of her notes were marked excellent or good. Between grade 1 and grade 8, only one remark in grade 3 refers to conflicts with others: “At times, V.K. finds herself in conflict with others, but always endeavours to resolve conflicts in socially acceptable ways.”

The Board concluded that there was no evidence that V.K. did not have the ability to control her behaviour, so this factor did not apply to her.

2. The pupil does not have the ability to understand the foreseeable consequences of his or her behaviour.

V.K.’s mother argued that her daughter did not understand she would be suspended or expelled and that she did not understand the seriousness of her actions because, when she was eight years old, in grade 3, she had been diagnosed as having Central Auditory Processing Difficulty (CAPD), which caused difficulty was in decoding and integrating the information. The mother argued that, as a result, V.K. had difficulty communicating and used Facebook as a fantasy; she would never act out her threats.

The Review Board disregarded the diagnosis as being out of date. V.K.’s learning had not been adversely affected by the diagnosis of CAPD. Her report cards from 2000 to 2008 affirmed that she had strong skills and had no learning disability. In summary, V.K. worked very hard, but needed assistance and clarifications in some subjects. Most of her marks were in the 70’s. She was at level 2 and 3 in most of her subjects. Her weakest subject was math. The Board concluded that V.K. was a bright girl, that she did understand what she was doing and that her actions were even premeditated. For example, even though she knew that one of the victim’s fathers had contacted the school, Facebook and the police, she reopened the accounts on three occasions.

As such, the Review Board was of the opinion that V.K. did understand the foreseeable consequences of her actions; to impersonate students and reopen the accounts showed that she understood what she was doing.

3. Whether the activity for which the pupil may be or is being suspended or expelled was related to any harassment of the pupil because of his or her race, ethnic origin, religion, disability, gender or sexual orientation or to any other harassment.

V.K.’s mother stated that her daughter had been bullied all her life, that she was a victim and not a violent child. It was argued that V.K.’s threatening emails were her way of dealing with the daily harassment she endured and the isolation she experienced from other students. V.K. had been transferred from her previous school due to too much bullying, and that harassment that she had endured at the school was ignored.

The Review Board noted, however, that in all the report cards, only one comment made in Grade 3 referred to V.K. having conflicts with other students. The vice-principal, stated that, except for one incident in the schoolyard in January 2008, neither she, the principal, nor the teacher, had been informed of bullying incidents towards V.K. at their school. The issue was never raised between V.K.’s parents and the school. The past history of bullying at previous schools was never brought to their attention either. Had they known, they claimed, they would have put in place a plan of action to ensure that V.K. would be comfortable in her class. V.K.’s Grade 8 teacher gave evidence that she frequently had her students work in groups of 3 or 4 and never felt that V.K. was excluded. The members of the groups changed frequently, and no problems were ever reported to her.

V.K. was described as quiet, lacking confidence and not isolated by her peers. She had two close friends and she got along well in groups.

The Board claimed that discussions about bullying were woven throughout the school’s Religion and Family Life Program. The class expectations and the rules were clearly explained and discussed with the students. There was an anonymous box in the classroom where students can write their concerns. At the beginning of the year, students were required to sign a computer-use contract as part of the school’s Code of Conduct in their agenda, to ensure that they used their computers as an academic tool, rather than as a form of entertainment. Since V.K. did not participate at the hearing and without her direct testimony, the Review Board refused to make a finding that she had been bullied.

4. How the suspension or expulsion would affect the pupil’s ongoing education.

After V.K. was suspended, daily homework assignments were sent to her residence and, upon their return to school, were corrected until the expulsion. V.K.’s mother enrolled her daughter in a new school, and no information was provided concerning the new school. As such, the Board found that V.K.’s on-going education was not affected.

5. The age of the Student

The Board found that V.K.’s age was not a relevant mitigating factor in this case.

6. In the case of a pupil for whom an individual education plan has been developed.

An individual education plan had been developed for V.K. from Grade 1 to Grade 4, but that at the time of the infraction she did not have an individual education plan. As such, this was not a relevant mitigating factor.

C. Other Factors

With respect to the other factors that must be considered when determining the seriousness of the incident, the Review Board concluded that the following factors applied:

1. Pupil’s history

V.K. did not have a history of engaging in threatening behaviour at the school. Regarding the incident in the school yard, the vice-principal dealt appropriately with the situation at that time. The Review Board did not examine this criteria in the absence of testimony from V.K.

2. Progressive discipline

V.K.’s mother stated that to expel her daughter from her school was an extreme measure and that no progressive discipline had been established by the school. The evidence demonstrated that V.K. did not have a computer in her room anymore and that the use of a computer was limited to school work.

The School’s position was that V.K.’s actions were extremely serious and negatively impacted the school climate to such an extent that progressive discipline techniques, which would have kept V.K. at the school, would not have been appropriate in this case. The Board agreed that given the facts of this case, no steps, other than expelling V.K. from School would have been effective given the School Board’s responsibility to ensure both the physical and emotional safety of all students attending its school.

Conclusions in V.K.’s Case:

The decision of the Review Board was unique in that, although V.K.’s cyberbullying did not occur at school or at a school related activity, it had a negative impact on the school climate. The fear of significant harm generated by the Facebook communications and the subsequent knowledge that this was committed by one of the pupils at the school caused the Review Board to find that the school climate was negatively impacted by the infraction. Having reviewed the mitigating and other factors, they held that V.K. had the ability to control her behaviour and to understand the foreseeable consequences of her behaviour. As such, the Review Board upheld the School Board’s decision to expel V.K.

Lessons for School Boards

The extent to which school boards may have responsibility for cyberbullying is still an open question. As such, school boards and their liability insurers may wish to consider the following issues:

  • Has your school board drafted and implemented policies that spell out acceptable technology use?
  • Has your school board reviewed its risk management programs and ensured that liability insurance coverage is provided for potential liability?
  • Does the school board know how students and staff are using the technology?
  • Is the school board’s policy on acceptable technology use up to date?
  • Does the school board’s policy specifically address online issues, including Internet privacy standards, instant messaging safety and use, and rules regarding technology storage?
  • Has your school board reviewed its technology uses?
  • If such a review is conducted, does the board’s review team include a school board trustee, central office personnel, the district’s IT expert, a school resource officer, school administrators, technology instructor and legal counsel?
  • For strategic planning purposes, has your school board assessed upcoming software applications and hardware installations?
  • Does your board know what resources are available at the school level to help deal with online issues, including electronic security?
  • Has your school board discussed the emerging legal issues surrounding new technologies and cyberbullying as well as potential responses and solutions for educators?
  • Has your school board kept staff, students and parents informed about cyberbullying communication technologies, including the latest on:
    • text messaging on cell phones and the use of built-in digital cameras;
    • emails, blogs, instant messaging, online student web-diaries, voice sent to cell phones containing insults, threats, mean-spirited or defamatory content; and
    • assumption of student identities via technology?
  • Has your school board implemented education programs for staff, students and parents about the seriousness of cyberbullying, including how to respond and when to ignore cyberbullying?
  • Has your school board ensured that each school understands the effect of technology on student privacy and school safety?
  • Has your school board integrated teachings about cyberbullying into classroom discussions and talked to students about responsible Internet use?

Regardless of whether cyberbullying occurs on or off of school property, schools should continue to consider student safety, assess whether any school rules were breached by off-school student conduct online and whether the e-conduct adversely affects student safety and welfare.

Thanks to http://jasonchatfield.com for granting us permission to post this cartoon!

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