Guide to writing or reviewing your child safe policy

Abuse against a child may take the form of:

• sexual
• physical
• mental or emotional (psychological)
• neglect.

Includes all children and young people under the age of 18 years.

A general complaint such as ‘the swings are too dangerous’, should not be confused with reports regarding concerns, allegations or disclosures of child abuse and harm.

The term used when a child reveals they have been abused. In this context, it is usually verbal or written. A child may not recognise they are making a ‘disclosure’ as such – they may only want to talk about something that is upsetting them.

A process where a person manipulates a child or group of children and sometimes those looking after them, including parents, carers, teachers and leaders. They do this to establish a position of ‘trust’ so they can then later abuse the child.

Harm is the resulting effect on a child after they have been sexually, physically, mentally or emotionally abused or neglected.

Worker or workers include all

• business owner/s
• employees
• volunteers
• work placement students
• contractors
• board/committee members.

This section needs to explain your organisation’s commitment to keeping children safe.

It must be written in plain language and be easy for workers, children, families and the community to understand.

Your commitment should align with the 10 National Principles for Child Safe Organisations.

What to include

Your policy must clearly state that:

• children are valued and respected
• your organisation is committed to the safety and wellbeing of children
• your policy meets South Australian child safety laws, including the:
  • Children and Young People (Safety) Act 2017
  • Child Safety (Prohibited Persons) Act 2016
• your organisation aligns with the National Principles for Child Safe Organisations
• all children are welcomed and included, regardless of ability, sex, gender, culture or background
• Aboriginal and Torres Strait Islander children, and children from diverse backgrounds are actively supported to express their culture, beliefs and unique identities
• racism, bullying and harassment are not tolerated
• your organisation supports equity and fairness
• a child safe culture is modelled and supported by everyone in the organisation, at all levels.

This section should outline the policy's scope, including who it applies to and how it aligns with the 10 National Principles for Child Safe Organisations.

What to include:

• who the policy applies to – for example all individuals involved in the organisation, including:
  • business owners
  • employees
  • volunteers
  • contractors
  • work placement students
  • board or committee members
• collective term – throughout this policy, these individuals may be referred to collectively as workers or personnel
• if workers, or the people the policy applies to, must agree in writing that they will follow the policy.

Why this matters

Clearly defining who the policy applies to helps ensure everyone understands their responsibilities and follows the same standards.

This section should explain how your organisation shares its child safe policy and involves children and families, in line with Principles 2 and 3 of the National Principles for Child Safe Organisations.

What to include

The ways you:

• explain to children what they should expect from workers so they understand what acceptable and unacceptable behaviour is
• teach children protective behaviours – refer to the Child Safe Reporting Guide (DOCX 8.1 MB)
• make your child safe policy and procedures available to children and families – for example, on request, on your website, or in a welcome pack
• encourage children to take part and give feedback – for example, involving them in decisions and explaining their rights in ways they can understand, including their right to feel safe and be heard
• involve families in your organisation, including encouraging their children to give feedback
• collect feedback from children– for example, surveys, informal discussions, or inviting them to join a board, committee or youth focus group.

Why this matters

This helps children and families understand your policies and have a say in how your organisation keeps people safe.

This section should explain the standards of behaviour expected of your organisation and its workers when working with children, in line with Principles 4 and 6 of the National Principles for Child Safe Organisations.

What to include

• a comprehensive and clear list of expected behaviours when working with children – for example, what workers must do and must not do
• that all concerns and breaches of the code of conduct, no matter how small, must be reported
• how you encourage and support workers to speak up about all concerns and breaches
• how a breach of the code of conduct can be reported such as who to report to and contact details – different options may be required to be suitable for children, parents and workers
• what will happen if the code of conduct is breached – for example, disciplinary action or termination of employment, depending on the seriousness of the behaviour.

Why this matters

This helps everyone understand what safe behaviour looks like and what happens when standards are not met. Reporting all breaches, including minor ones, can help identify patterns of behaviour that may place children at risk, for example grooming by other workers.

Resources

Use the Child Safe Code of Conduct Guide to develop your code of conduct. If your organisation has a separate code of conduct, replace this section with a reference to that document.

Child Safe Code of Conduct Guide (DOCX 5.9 MB)

This section should explain how your organisation recruits suitable people to work or volunteer with children and ensures they have the skills, knowledge and support needed to keep children safe, in line with Principles 5 and 7 of the National Principles for Child Safe Organisations.

What to include

• child safety responsibilities are included in role descriptions
• your commitment to child safety is included in job advertisements
• you ask child safety questions during face-to-face interviews
• at least two referee checks are completed
• the ways you meet the requirements of the Child Safety (Prohibited Persons) Act 2016 – this includes making sure all relevant people have a current Working with Children Check (WWCC) with a ‘not prohibited’ result
• which people in your organisation must have a WWCC – requirements depend on the type of service your organisation provides
  • in general: all persons running the organisation such as business owners, board/committee members, directors, mangers and all paid and unpaid workers aged 14 and over who will be working in a role with children must have a current, cleared WWCC
  • sports, recreation, arts and cultural clubs or associations: all people running the organisation and all workers aged 14 and over must have a current, cleared WWCC, even if they do not work directly with children
  • health, disability care support, religious and similar services:
    • all people running the organisation must have a current, cleared WWCC
    • workers aged 14 and over must have a current, cleared WWCC if they work with or have contact with children. Contact includes physical contact, being near a child, or communicating in person, by phone, online or in writing with a child.
• your organisation is registered with the DHS Screening Unit
• you check all relevant persons have a not prohibited WWCC issued within the last 5 years before the person starts work by generating a worker screening certificate through your organisational portal
• an interest in all WWCCs is registered through your organisational portal
• WWCC records are kept for all relevant workers
• you make sure checks are renewed every 5 years and verify the status remains as cleared through your organisation portal
• you tell the DHS Screening Unit if you become aware of concerning information about a person – for example, serious criminal offences, child protection concerns or any misconduct by submitting a Section 19 report through your organisational portal
• consider if there are other screening checks your organisation may require such as National Police Check or an NDIS Worker Check. If so, include relevant details
• your induction process includes:
  • tour of premises and introduction to colleagues
  • overview of child safe policies and procedures
  • reporting obligations
  • clear expectations of acceptable and unacceptable behaviours.
• what support you provide workers such as:
  • regular oversight as they become familiar with their role
  • regular supervision sessions that include child safety and wellbeing
  • regular performance reviews or having a child safety officer who supports and educates workers
  • regular child safe training – see the Training for workers section on this page for more information.

Why this matters

This helps you choose safe and suitable people, reduces the risk of harm to children, reduces worker turnover and less time spent managing underperforming workers.

Resources

Use the Child Safe Recruitment, Induction and Support Guide to develop this section. If your organisation has a Child Safe Recruitment, Induction and Support policy, replace this section with a reference to that document.

Child Safe Recruitment, Induction and Support Guide (DOCX 5.6 MB)

This section should explain how your organisation ensures workers have the skills, knowledge and support needed to keep children and young people safe, in line with Principles 5 and 7 of the National Principles for Child Safe Organisations.

Training is part of the National Principles to make sure workers:

• have the knowledge and skills to recognise signs of harm to children
• can respond properly, including meeting mandatory reporting duties
• understand how to create safe environments for children.

Each organisation can decide what training their workers need to complete so they have this knowledge and understand their legal responsibilities for mandatory reporting.

What to include

You must explain:

• what training you and your workers complete about child safety and mandatory reporting, for example
  • reading the Mandatory Reporting Information or
  • completing approved training such as Safe Environments Through Their Eyes or Responding to Risk of Harm, Abuse and Neglect
  • cultural competency training for all workers, including how to create culturally safe environments
• how often this training must be completed to keep knowledge up to date – for example, every 3 years
• this training helps workers:
  • recognise signs of harm
  • respond to harm, including mandatory reporting
  • create safe environments for children and young people
• team meetings where child safety is a standard agenda item.

Why this matters

This helps workers understand their responsibilities and respond appropriately to keep children and young people safe. It also helps the organisation to efficiently and effectively identify and respond to unacceptable, harmful or offending behaviour as it occurs.

Resources

Use our Recruitment, Induction and Support Guide to develop training processes that can be included in your child safe policy.

Child Safe Recruitment, Induction and Support Guide (DOCX 5.6 MB)

This section should explain how your organisation reports and responds to concerns, allegations or disclosures of abuse, harm or risk of harm to children, in line with Principle 6 of the National Principles for Child Safe Organisations.

Note: This section applies only to abuse, harm or risk of harm. It should not include general complaints or feedback.

What to include

The headings below are provided to help you understand the types of information that should be included in this section. You do not need to use these headings in your child safe policy.

Reporting concerns and disclosure

• all concerns should be reported and this includes criminal conduct, risk of harm, disclosure or suspicion of abuse and unacceptable behaviour around children that breaches your Child Safe Code of Conduct
• children, families and workers in your organisation have the right to report a genuine concern and won’t be punished if they do
• how children and families can report a concern and the ways they can do this
  • include an option suitable for the ages of children you provide services to such as, they can tell any worker
  • for families include name of the role they should report to and the relevant contact details
• information for workers to assist them support a child who is disclosing abuse such as what they should and shouldn’t do or say.

Worker reporting responsibilities

• all adults have a responsibility to care for children, and part of that responsibility is reporting when it is required
• if a child is at immediate risk of harm, the worker who identifies the risk should immediately report to SA Police on triple zero
• if a child discloses abuse and there is concern it is of a criminal nature, the worker should immediately contact SA Police to protect the child and minimise contamination of any evidence
• all adult workers must report child sexual abuse by another worker to SA Police on 131 444 and must protect children from sexual abuse by another worker. Failure to do so is a criminal offence
• any person who has reasonable suspicion that a child has been or is at risk of harm should report direct to the Child Abuse Report Line (CARL) on 13 14 78 as soon as practicable. Note: mandated reporters have a legal obligation to make a report if the suspicion arose during the course of their paid or unpaid work
• how information to report harm is available on the South Australian Department for Child Protection website – Reporting suspected harm of children and young people.

Mandated reporters

Describe who the mandated reporters are in your organisation:

• mandated reporters should be described using the actual roles in your organisation, not the whole list copied from legislation
• as required by law, this may include:
  • paid or unpaid workers who provide services to children and young people
  • managers who are responsible for, or directly supervise, those services
  • in religious or spiritual organisations, all workers – both paid and unpaid – must report concerns.

Internal reporting processes

• an internal report must be made for all concerns including those reported to the Child Abuse Report Line (CARL) or SA Police and information on how they are to do this.

Organisations responsibilities

The steps you will take to manage a concern or allegation such as:

• confirm the child has been removed from immediate harm
• confirm concern has been documented and reporting obligations to the Child Abuse Report Line (CARL) or SA Police have been met
• where a report has been made to SA Police or CARL, gain their advice and approval before starting an internal investigation
• what you will do if a worker is reported to CARL or SA Police for alleged abuse and harm to a child, to ensure the ongoing safety of all children in your organisation. For example, they will be removed from any role involving contact with children until investigations are complete
• how you will investigate where appropriate, including breaches of policies, codes of conduct and practices and the steps you will take to conduct an investigation
• how you will keep all persons up to date
• how you will review the incident and update your child safe policy and any other child safe policies and procedures if necessary.

Records, privacy and outcomes

• all information about an incident is documented and all documents are securely stored in a confidential file separate to (but referenced in) the worker’s personnel file
• information relating to the management of the worker will be included in their personnel file
• the outcome if an incident is substantiated will be dependent on the severity of the incident and advice provided by SA Police and Department for Child Protection and may include verbal warning, disciplinary action, increased supervision, retraining and termination of employment
• your organisation maintains the privacy of those involved in the incident, including the person making the report, the child and the alleged perpetrator
• the ways you will continue to support children, young people and their families after a report is made. This may include ongoing services or referrals to appropriate external support services.

Why this matters

This ensures children and young people are protected from abuse and harm and all workers understand their legal responsibilities. It also helps the organisation respond quickly, safely and in line with the law.

Resources

Use our Child Safe Reporting Guide to develop your mandatory reporting process that can be included in your child safe policy. If your organisation has a mandatory reporting process, replace this section with a reference to that document

Child Safe Reporting Guide (DOCX 8.1 MB)

This section should explain how children and their families can provide feedback or make a general complaint, and how your organisation responds, in line with Principle 6 of the National Principles for Child Safe Organisations.

This section applies only to general feedback and complaints – it should not include concerns about harm or risk of harm to children that should be covered in the section for Reporting and responding to harm or risk of harm.

What to include

The headings below are provided to help you understand the types of information that should be included in this section. You do not need to use these headings in your child safe policy.

How people are informed

How children and their families are told they can give feedback or make a complaint at key times, such as:

• at their first appointment
• as part of a welcome pack or introduction when they join the organisation.

Ways to provide feedback or make a complaint

The different ways people can share feedback or make a complaint, such as:

• speaking to any worker
• by phone – include the number
• by email – include the email
• using child-friendly options, such as simple forms, pictures or support from a trusted adult
• posters or materials are available to show children and young people how to give feedback or make a complaint.

How complaints are managed

How the organisation follows a clear process to manage feedback and complaints such as:

• listening carefully and taking all concerns seriously
• the person receiving the complaint or feedback will make a record of it if received verbally
• if a worker receives a complaint, they must forward it to management as soon as possible
• prioritising the safety and wellbeing of children when handling complaints
• responding with an outcome in a timely way
• making sure decisions are fair for everyone involved (procedural fairness)
• recording and securely storing information about the complaint or feedback.

Training and external support

• workers receive training to recognise and respond to feedback and complaints
• you share information about external support agencies if people are not satisfied with the outcome, options include:
  • Health and Community Services Complaints Commissioner – phone: 08 8226 8666
  • Australian Human Rights Commission – www.humanrights.gov.au or phone: 1300 656 419
  • South Australian Equal Opportunity Commission – www.equalopportunity.sa.gov.au or phone: 08 8207 1977.

Why this matters

This helps ensure everyone knows how to speak up, feels listened to, and trusts that complaints will be handled fairly and properly.

This section should explain the risks to children and young people in your organisation and how those risks are identified, assessed and managed, in line with Principle 8 of the National Principles for Child Safe Organisations.

Note: this does not relate to general WHS risks such as slips, trips and falls.

What to include

• the organisation identifies and manages risks to the safety and wellbeing of children and young people. These risks may relate to:
  • situational risks – these risks relate to situations that may create opportunities for harm, such as:
    • adults being alone with children
    • adults forming relationships with children that could involve physical contact and emotional closeness
    • physical sites and settings in your organisation and online environments that provide opportunity for grooming to occur
  • vulnerability risks – these risks relate to factors that may make some children more vulnerable to harm, such as:
    • age (some children are more vulnerable to certain types of abuse at certain ages)
    • physical or intellectual disability
    • children not feeling confident to speak up
    • children who have experienced prior maltreatment
    • out-of-home care arrangements or challenging home environments
    • different cultural background
  • propensity risks – these risks relate to behaviours or characteristics that may increase the likelihood of harm, such as:
    • when an adult has an inclination to abuse children
    • other children in the organisation displaying harmful sexual behaviour
  • organisational risks – these risks relate to systems, culture or practices within the organisation, such as:
    • leaders not supporting or prioritising child safety
    • a lack of understanding or awareness of grooming and child abuse
    • unclear expectations around worker-child relationships
    • not listening to and respecting children
    • children not having access to a trusted adult
    • close-knit and longstanding relationships between co-workers
    • protection of the organisation over the safety of children
    • ineffective child safe policies and procedures
    • inadequate recruitment and reporting processes
• you consider and demonstrate the National Principles for Child Safe Organisations through your risk management planning
• each risk is assessed considering the likelihood of the risk happening and if the risk happened, how significant the consequence would be to a child
• a Child Safe Risk Management Plan (CSRMP) is developed that identifies individual risks to children in your organisation and includes your strategies for each identified risk to prevent or lower the risk of abuse and harm occurring
• you include children in identifying risks and suggesting ways to improve their safety
• the ways you publicise your CSRMP so all workers and stakeholders are aware of it
• you review your CSRMP regularly, such as once every year.

Why this matters

Managing risks helps create a safe environment for children and young people. It ensures their wellbeing is protected and that workers understand how to prevent harm in all activities and settings. It also provides protection to workers and the organisation itself, in case there are potential allegations of abuse and harm.

Resources

Use our Child Safe Risk Management Guide to develop your risk management process that can be included in your child safe policy. If your organisation has a separate risk management policy and CSRMP, replace this section with a reference to that document.

Child Safe Risk Management Guide (DOCX 4.8 MB)

This section should explain which organisational policies and procedures support child safe environments and how they work together, in line with Principle 9 of the National Principles for Child Safe Organisations.

If all information related to providing child safe environments is in this policy, you do not need to include this section.

What to include

A list of related policies and procedures that the organisation maintains that relate to child safe environments.

Why this matters

Listing related policies helps ensure a consistent and coordinated approach to creating and maintaining a child safe environment. It also makes it easier for staff and stakeholders to understand how different policies work together.

This section should explain how your organisation regularly reviews and updates its child safe policy and related documents to support continuous improvement, in line with Principle 9 of the National Principles for Child Safe Organisations.

What to include

• the ways you involve children, families and workers when developing and reviewing your child safe policy documents
• your child safe policies and procedures are reviewed at least once every 5 years, in line with the Children and Young People (Safety) Act 2017
• you may also review the policy at other times, such as when:
  • new or increased risks to children and young people are identified
  • a serious incident occurs involving harm to a child or young person
  • concerns are raised about child safety or wellbeing within the organisation
  • there are changes to laws or requirements
• each time the policy is reviewed and updated, you will submit a new Child Safe Compliance (CSC) Statement with the Department of Human Services
• the date the policy was reviewed
• the date of the policy’s next review
• which role in your organisation is responsible for next review of the policy.

Why this matters

Regular review ensures the policy stays up to date, effective and aligned with current laws and best practice.

The examples below describe common forms of abuse and signs that a child may have experienced harm and can be included as an appendix in your child safe policy for workers to refer to.

Physical abuse

Examples of physically abusive behaviours

• physical punishment such as pushing, shaking, shoving, punching, slapping, choking, burning, biting or kicking
• giving a child alcohol or other drugs, or misusing medication
• fabricating or inducing illness.

Possible indicators of harm

• burns
• bald patches on the head
• poisoning
• bruises or welts on the face, back, legs, arms, buttocks or inner thighs
• bruises that resemble an object, such as finger marks, a handprint, teeth marks or a belt buckle
• multiple injuries, including old and new injuries.

Psychological abuse

Examples of psychologically abusive behaviours

• bullying, intimidation, shaming or name calling
• threatening or abusive language
• ignoring, frightening or isolating a child
• deliberately exposing a child to traumatic events, including domestic and family violence.

Possible indicators of harm

• not interacting with others
• regression in toileting behaviours
• hypervigilance
• extreme eagerness to please or obey adults
• delay in reaching developmental milestones
• difficulty trusting others or showing empathy.

Sexual abuse

Examples of sexually abusive behaviours

• grooming
• sexually touching a child
• penetration of the genital or anal area
• sending obscene messages or making obscene phone calls
• producing, distributing or possessing child abuse material.

Indicators of harm

• injury to genital or rectal area
• discomfort in urinating or defecating
• bruising or injury to breasts, buttocks, thighs
• disclosure of abuse by the child
• fear of harm, specific place or person
• deteriorating relations with adults / peers.

Neglect

Examples of neglectful behaviour

• lack of supervision
• not providing adequate nourishment, medical care, clothing or shelter
• failure to support a child’s education
• lack of nurturing, encouragement and support.

Possible indicators of harm

• regularly being left unsupervised
• stealing food or eating food found on the ground or in bins
• consistently appearing dirty or unwashed
• untreated health issues
• clothing unsuitable for weather conditions
• inadequate or no shelter.