Prevention of Future Deaths reports · 2021

Frances Thomas

Regulation 28 report to prevent future deaths, reference 2021-0408, written 26 Nov 2021. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report26 Nov 2021
Reference2021-0408
DeceasedFrances Thomas
CoronerKaren Henderson
Coroner areaSurrey
CategoryOther related deaths · Suicide (from 2015)
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

IN THE SURREY CORONER’S COURT 
IN THE MATTER OF: 

__________________________________________________________ 

The Inquest Touching the Death of Frances Rose Thomas 
A Regulation 28 Report – Action to Prevent Future Deaths 
__________________________________________________________ 

THIS REPORT IS BEING SENT TO: 

  Secretary of State for Education 

1  CORONER 

Dr Karen Henderson, HM Assistant Coroner for Surrey 

2  CORONER’S LEGAL POWERS 

I make this report under paragraph 7(1) of Schedule 5 to The Coroners 
and Justice Act 2009. 

3 

INVESTIGATION and INQUEST 

On  28th  November  2018  I  commenced  an  investigation  into  the  death  of 
10th
October  2021  I  concluded  the 
Frances  Rose  Thomas  On  the 
Investigation. The medical cause of death given was: 

1a. Suspension 

I returned a conclusion of 
minimally contributed to by the failures of: 

 with Frankie’s death more than 

1.  Stepping Stone School: 

a.  To provide an effective e-security system as tasked to do so by 

the department of Education. 

b.  To ensure Frankie’s use of the iPad was monitored to confirm 

her 

 safety. 

c.  To provide Frankie with supervision when not attending 

lessons despite having an Educational Health Care Plan in 
place. 

 2. 

: 

a.  A lack of robustness in their policies to remove age 

content that allowed Frankie to read 
inappropriate 
stories on their platform on the day of her death featuring 
, an act 

which she goes on to complete herself. 

4  CIRCUMSTANCES OF THE DEATH 

Frances Rose Thomas (Frankie) was a vulnerable teenager with a number 
of significant underlying difficulties including childhood trauma, high 
functioning autism, oppositional behaviour and impulsivity. 

Stepping Stones School is a school for students with moderate physical or 
learning difficulties. Frankie was offered a place in year 8 and started in 
April 2016 with an Educational Care Plan in place. Throughout her time 
at the school Frankie often refused to attend lessons and at the time of her 
death rarely attended more than one lesson a week. When not attending 
lessons, she was left on her own without any formal supervision. During 
this time, she had access to a school computer and an iPad. 

During the Inquest I heard evidence Frankie only had access to the 
 during school time using electronic devices supplied by the 

school. There was an e-security system in place for school computers but 
it was not monitored by nominated safeguarding leads. This allowed 
Frankie (as it did for all students) to freely access the 
observation as to what websites were being accessed and for an 
assessment to be made of their appropriateness. Furthermore, the iPads 
had no e-security system in place at all, again allowing Frankie to freely 
access the 

 without any supervision. 

 without any 

On the day of her death, Frankie was found to have accessed 

 The stories that Frankie accessed on this platform featured 

. After school Frankie 

went home and undertakes a similar act resulting in her death on 25th 
September 2018. 

 
 
 
 5  CORONER’S CONCERNS 

1.  I heard evidence that the Department of Education have devolved 
responsibility  for  e-security  systems  with  schools  having  to 
‘tender’  for  web  filtering  software  and  hardware.  However,  the 
guidelines  issued  by  the  Department  of  Education  require 
updating and are insufficiently robust to ensure their effectiveness 
and meet the changing demands of 

 e-security in schools. 

2.  There is a wide range of software vendors providing different lists 
of  blocklists  with  different  vendors  enabling  different  categories 
with  no  oversight  or  regulatory  guidance  by  the  Department  of 
Education  as  to  what  ‘blocklists’  are  either  acceptable  and/or 
suitable for a school environment. 

3. 

is not a specifically blocked 

 and not only can it be 
accessed by Key Stage 4 students there is encouragement to do so 
in some schools. However, I heard evidence that the sites Frankie 
. 
accessed through 
independent  scrutiny  by 
Furthermore, 
  to  remove  age  inappropriate  stories  put  on  their 

inadequate 

there 

is 

platform. 

4.  Some  websites  are  only  blocked  when  there  is  a  particular  key 

word  in  the  URL  If  the  relevant  trigger  word  (e.g. 

) is not there it makes it difficult for the filter to ‘see’ the 
content of the website to be able to block it, hence why stories on 
  could  be  read.  However,  there  are  software  systems 
available that acts as a ‘key logger’ and ‘screen reader’. Whilst this 
will  not  block  the  site  it  will  generate  a  report  to  the  nominated 
safeguarding  individual  for  further  action.  Yet  it  has  not  been 
considered or is part of the guidelines issued by the Department of 
Education 

5.  In  summary,  on  the  evidence  I  heard  there  appears  to  be 
inadequate  regulatory  oversight  with  now  outdated  guidance 
issued  by  the  Department  of  Education  with  regard  to  robust 
standards of e-security systems within schools. 

 
 6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I 
believe that the people listed in paragraph one have the power to take 
such action. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of its date; I 
may extend that period on request. 

Your response must contain details of action taken or proposed to be 
taken, setting out the timetable for such action. Otherwise you must 
explain why no action is proposed. 

8  COPIES 

I have sent a copy of this report to the following: 

1. 
2.  Stepping Stones School 
3. 
4.  The Chief Coroner 

In addition to this report, I am under a duty to send the Chief Coroner a 
copy of your response. 

The Chief Coroner may publish either or both in a complete or redacted 
or summary form. He may send a copy of this report to any person who, 
he believes, may find it useful or of interest. You may make 
representations to me at the time of your response, about the release or 
the publication of your response by the Chief Coroner. 

Signed: 

Karen Henderson 

DATED this 26th day of November 2021

Responses

1 response published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Department for Education (PDF)
Rt Hon Nadhim Zahawi MP 
Secretary of State 

Sanctuary Buildings   Great Smith Street   Westminster   London   SW1P 3BT 

   www.education.gov.uk/contactus/dfe 

Dr Henderson 
Assistant Coroner 

Dear Dr Henderson 

21 January 2022 

I received your Prevention of Future Deaths Report, regarding the tragic 
death of Frances Rose Thomas, on 6 December 2021.  

This is a heart-breaking case, and I share your concerns about the 
widespread availability of content online that promotes and advertises 
methods for suicide and self-harm. My thoughts are with Frances’ family 
and everyone that knew her. 

I would like to assure you that the department takes the issues raised in 
the report very seriously.  

My department’s Keeping Children Safe in Education (KCSIE) statutory 
guidance places a legal obligation on all schools and colleges to 
safeguard and promote the welfare of children. The breadth of issues 
classified within online safety is considerable but can be categorised 
into four areas of risk which are: Content, Contact, Conduct and 
Commerce. KCSIE is clear that schools and colleges should consider 
how online safety is reflected as required in all relevant policies and 
procedures and that governing bodies and proprietors should be doing 
all that they reasonably can to limit children’s exposure to risks from the 
school’s IT system. As part of this requirement, governing bodies and 
proprietors should ensure their school has appropriate filters and 
monitoring systems in place. To help schools understand what 
‘appropriate’ might look like, KCSIE signposts to further detailed 
guidance from the UK Safer Internet Centre. KCSIE is also clear on the 
options open to schools when considering monitoring. This ranges from 
physical monitoring, to log file information monitoring, to active (school 
led) and pro-active (third party led) monitoring.  

The appropriateness of any filter and monitoring systems is rightly a 
matter for individual schools. The needs of individual schools will be 
unique to their own local circumstances. For example, a small rural 
school’s filtering and monitoring needs will be different to that of a large 
urban school and the needs of primary schools will be different to the 

 needs of secondary schools. School leaders are best placed to decide 
what will be appropriate for their school and the needs of their children 
having regards to the strong expectations set out in KCSIE.  

  However, I am very aware that technology in this area evolves and 

changes rapidly and it is important that schools do not lose sight of this. 
As such, KCSIE is clear on the importance of a whole school approach 
to online safety. As well as filtering and monitoring, schools and 
colleges should also consider staff training, annual risk assessments 
reflecting the risks children face, educating children to navigate the 
online world safely, and a clear policy on the use of mobile technology. 
KCSIE signposts schools to tools and additional advice in this space. 
This includes, the “360 safe website”, which provides a free online 
safety self-review tool (12,575 schools in England are signed up), it can 
be found here: https://360safe.org.uk/. In addition, the UK Council for 
Internet Safety has published “Online safety in schools and colleges: 
Questions for the governing board”  which helps governors to challenge 
their senior leadership teams on the effectiveness of their schools 
online safety approach.  

  We have significantly strengthened online safety in KCSIE in recent 

years - especially in 2021. This includes considering how online safety 
is reflected as required in all relevant policies and considering online 
safety whilst planning the curriculum, any teacher training, the role and 
responsibilities of the designated safeguarding lead and any parental 
engagement.  

  We continue to review what more we can do to support schools and 

colleges and see where we can strengthen the guidance further. On 11 
January, we launched a public consultation on KCSIE which runs until 8 
March. To help us build the evidence base, we have included a 
question specifically relating to filtering and monitoring systems, which 
asks schools if they feel able to make informed decisions on which 
filtering and monitoring systems your school or college should use? 
Following consultation, we plan to publish revised guidance later this 
year.   

  Furthermore, to support schools to have the appropriate safeguarding 
systems in place, under both child and data protection legislation, we 
will also be launching a set of digital, data and technology standards 
from Spring 2022, including standards on data and cyber security, and 
how to support more robust monitoring and filtering. Through 
consultation with the education and technology sector, we will explore 
options on how to ensure schools meet these standards to support 
system-wide safeguarding policies and how we can further support 
them to understand and improve their digital environments. 

In May 2021, the government published the draft Online Safety Bill, 
which will give tech companies new responsibilities to protect their 
users. It will apply to services which host user-generated content or 

 
 facilitate user-to-user interactions, as well as to search services. 
Services in scope will have to remove and limit the spread of illegal 
content, such as content which assists or encourages suicide. The 
strongest protections in the Bill are for children. Where in-scope 
companies are likely to be accessed by children, they will be required to 
do far more to protect children from content and activity which is legal 
but may be harmful to them, such as bullying and the promotion of self-
harm online.  

  We have confirmed our decision to appoint Ofcom as regulator and our 
intention to give them a range of enforcement powers which will include 
substantial fines and, where appropriate, business disruption measures 
(including blocking). There will also be a criminal offence for senior 
managers who fail to ensure their company complies with Ofcom’s 
information requests, to push strong compliance in this area. 

  The Bill was subject to pre-legislative scrutiny by a Joint Committee of 

MPs and Peers, who reported with their recommendations on 14 
December 2021. We are considering fully and carefully these 
recommendations and are committed to introducing the Bill as soon as 
possible. In the meantime, we are working closely with Ofcom to ensure 
that the implementation of the framework is as short as possible, 
following passage of the legislation. We are also clear that companies 
should not wait for the legislation to protect their users online. 

  We are also working with the Children’s Commissioner to support 

parents to help their children navigate the internet safely and recently 
met with technology companies to ask them to do more to keep young 
people safe, ahead of the Online Safety Bill coming into effect. The 
Children's Commissioner is working on her final recommendations to us 
and to DCMS, which we will fully consider and respond to in due 
course.    

  Let me turn now to your concerns about the periods Frankie was left 
unsupervised. There is an expectation that when in school, children 
should be in class. We do, however, recognise that there may be 
occasions where an exception is made for some children as it may not 
be in their best interests to be in class. That said, even when not in 
class, children should still have access to suitable learning with 
appropriate support and supervision. In deciding what was appropriate 
we would expect a school or college to take account of any 
vulnerabilities and complex needs that a child might have.   

  The government recognises that more broadly the current Special 

Educational Needs and Disabilities (SEND) system could be improved, 
we are therefore currently conducting a SEND Review covering a wide 
range of SEND issues and expect to publish proposals from that 
Review for public consultation in a Green Paper in the first 3 months of 
2022. 

   Finally, with regards to the concerns raised specifically in relation to 

WATTPAD, I must advise that this issue falls outside of this 
department’s remit but has been passed to DCMS for its consideration, 
I am also aware that DCMS is working closely with DHSC on tackling 
harmful suicide/self-harm content online.  

Yours sincerely,    

Rt Hon Nadhim Zahawi MP 
Secretary of State for Education

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