Child Protection and Vulnerable Persons (Child Safe Environment) Policy

Procedures under the Child Protection and Vulnerable Persons Policy

• Tell Us If You Have Concerns About Your Treatment or Safety

  Student Concerns About Inappropriate Conduct or Being Harmed or at Risk of Harm

  Students seeking help should ask to speak confidentially to the Director of RTO Operations, CEO or Managing Director by email or phone.

  However if you feel more comfortable you can speak to your Student Adviser or other staff you are comfortable with.

  If you choose to speak to other staff they are required to report your concerns. 

  Other Parties

  ACCM will also act upon concerns raised by other parties eg parents, schools or employers.

  Other Concerns

  Any other concerns can be advised to any staff member or sent by email or post. Where they do not relate to child safety and protection these issues will be managed under our normal complaints processes.

• Obligations for Reporting Children at Risk - Procedures

  If a student is under 18 they are technically a child that falls under the Child Protection (Working with Children) Act NSW 2012 (and equivalent legislation in other states and territories).

  Under this legislation ACCM College staff have an obligation to report specific matters or concerns or reasonable suspicions.

  Reasonable grounds to form a suspicion/belief that a child or young person may be at risk may include:
  • when a child or young person tells you they are at risk or have been harmed
  • when your own observations of a particular child or young person’s behaviour and/or injuries lead you to suspect they are at risk, or harm is occurring
  • when a child or young person tells you that they know of someone who is at risk or has been harmed (they may possibly be referring to themselves)
  • when you hear about risk or harm to a child or young person from someone who is in a position to provide reliable information, eg a relative or friend, neighbour or sibling of the child or young person 

  ACCM College has internal procedures that guide staff on this process that are retained on the Dashboard Knowledge Base intranet. These procedures involve identifying and promptly notifying in accordance with the requirements of the relevant government agencies / police.

  In general the process is to directly immediately advise the relevant state/ territory authorities and to then complete an internal report directly to either the CEO or Managing Director.

  For example in South Australia this would involve a call to the Child Abuse Report Line (CARL) on 13 14 78. This must be done by the staff member who has identified the harm or risk of harm.  

  Staff in roles of immediate contact with students such as Student Advisers and Service One Officers, as well as ACCM Managers are required under law to report concerns ie they are mandated notifiers. Other staff can, and should, voluntary report where they have reasonable suspicions.

  However, in the instance of concerns about child sexual abuse, all personnel are to report these directly to the Police.

  Detailed staff guidance is in staff Dashboard.

• Work with Children History Checks

  a) ACCM College Policy is to require all Student Advisers, Administration, Service One staff and any contractors to obtain a clearance under the NSW Work with Children Check process when they are initially employed. Employment is conditional on obtaining a clear "check" and recruitment information will declare this as an essential criteria.

  b) ACCM College staff delivering classroom courses in other states where those courses may involve students under 18, will in addition be required to have equivalent state/territory checks undertaken such as the "not prohibited" Working with Children Check (WWCC) under the SA Child Safety (Prohibited Persons) Act 2016. ACCM College is registered with the SA DHS Screening Unit and will verify the accuracy of all WWCCs in the online portal.

  c) New recruits who show they have some history of working in states other than NSW will be asked to complete that states "check" where the information of any offences will not show in the NSW check.

  d) Required WWCCs will be renewed at the timeframes required eg every 5 years under SA legislation.

  e) The ACCM annual Risk Assessment process will specifically review if stronger WWCCs and other measures are required. This will be undertaken by the Director of Compliance in line with the risk assessment process, based on the potential contact with children of each staff member in their role. For example the SA Child Safety (Prohibited Persons) Act 2016 requires a review of the risk related to each employee in contact with children to be undertaken every 5 years.

  f) Staff in support roles will be required to undertake the same checks when assessed as being in a prescribed role.

  g) Reports are saved into the staff members confidential staff file on Dashboard. Where any adverse report is received, procedural fairness will be applied however, under no circumstances will the staff member remain employed in a role that has the potential for direct contact with children or vulnerable people.

  h) Records of WWCCs will be retained in the staff members confidential file .

  i) A student, parent, guardian or carer can request to see the relevant WWCC certificate, letter or report.

• Communication of Policy and Rights to Students

  The National Principles for Child Safe Organisations state that children and young people should be informed about their rights; and that issues raised are taken seriously.

  To this end ACCM actively publishes this policy and related procedures and policies.

  Specifically, this Policy is linked in the Student Induction Online content. This ensures students have quick access to the up to date policy at all times and are aware that their input and feedback is encouraged. It also allows students quick access to information about how to raise a concern.

  It is also publicly available so that families, guardians, school-based traineeship co-ordinators, government officials and other interested parties can view it on this website.

  ACCM College commits to listen to and act upon any complaints or concerns that a child or young person raises with us, and complaints about harm or risk of harm will be treated as a matter of urgency.

  Concerns about harm can also be raised via any of the other contact channels available to students and will be escalated to the CEO for immediate action.

• Recruitment, Training, Supervision and Support for Staff

  Recruitment of Staff

  To ensure we engage the most suitable people to work with children and young people we have the following recruitment practices in place:

  • our commitment to child safety is included in all job advertisements
  • applicants are advised of WWCC requirements and of our commitment to child safety and the obligations under this Policy and the Code of Conduct
  • face-to-face interviews that use behavioural questions to determine the applicant’s knowledge of child safeguarding
  • at least 2 referee checks where referees are asked specifically about working with people under 18

  Training and Supervision

  ACCM College recognises the importance of training and supervising staff on these issues so that we don't become complacent.

  Formal training is set for each staff member as a Professional Development Activity.

  This includes:

  • Annual review of the Mandatory Notification Information Booklet 
  • Completing the Safe Environments: Through their eyes training course or Responding to Risk of Harm, Abuse and Neglect Training course every 3 years 
  • In-house courses on child safe environment aspects

  Supervision of staff is undertaken in a variety of ways including observance of Dashboard student information accessed (in particular that of young students), tracking and monitoring of phone calls made, as well as more traditional in person supervision by team leaders and managers.

  Support for staff is provided by ready access to their Team leader for discussion about issues that they come across or that concern them.

• Risk Assessment and Management - Specific Risks to Children

  ACCM College, as part of its Risk Management Plan, has a specific item that identifies, assesses and takes steps to minimise and prevent harm to children, young people and vulnerable students because of the action or inaction of a person representing the College.

  Annually the Director of Compliance will conduct this Risk Assessment to identify any new risks, re-assess those identified and implement mitigation and control steps.

  Specific risks to be addressed include:

  • National Principles for Child Safe Organisations are not suitably embedded
  • lack of staff awareness and/or training
  • use of photos without consent of parent / guardian
  • records secured and access is recorded and limited to a needs basis

   Identification of Risks or occurrence of an incident or identification where awareness of this policy or procedures are low, will trigger a review of these risks and the policy and procedures.

  Latest Risk Assessment Outcomes

  This year's Risk Assessment identifies only low level risks given the nature of the remote delivery mode, staff monitoring processes, and controlled access to information. These risks did not require further action.

   

  Identified risk	Actions to minimise risk
  Physical contact	·         Limited physical contact is required given our main delivery method of on-line learning ·         For face to face training any physical contact must be appropriate to the delivery of content being provided ·         where physical contact is required, this is undertaken in a safe way by explaining why contact is required and what will happen, and asking the child/young person for their permission (or their family if this is more appropriate) before proceeding ·         unnecessary physical contact is not allowed
  Online communications	·         The Code of Conduct prohibits social media interaction outside specific and limited job use. ·         Emails sent and received are stored and can be viewed ·         Dashboard emails are stored and shown in the interaction history. ·         Standardised emails are used in most cases, with customisations able to be viewed.
  Transport of children and young people	·         As an online provider there are limited needs to transport a student and this would require specific approval and arrangements ·         parents/guardians must provide consent before transporting a child or young person under 18; and employees must not be alone in a vehicle with a child or young person ·         ACCM Staff driving must have a valid, unrestricted driver’s licence ·         The vehicle used must be registered, insured and in roadworthy condition
  Supervision	·         There are limited F2F interactions with children given the online delivery. ·         Where F2F may involve young people under 16 or vulnerable people specific rules will be put into place about staff supervision and also ensuring safe departure from the site ·         If staff are providing one to one consultation with a child or young person, it will be in line of sight of another adult (including where via a zoom session)
  Taking images of children and young people	·         consent of child /young person and their parent/guardian is required for any photos or recordings ·         Where consent is requests, disclosure will be made as to how the image is to be used and consent must be provided by the child, young person and parent/guardian ·         images must be presented in a way that de-identifies the child or young person except with their express permission
  Privacy and confidentiality	·         all files and documents containing confidential information will be stored privately in a locked filing cabinet under the control of the CEO ·         digital files containing confidential information shall be protected electronically by restricting the access to only those requiring it to perform their duties and requiring strict security protocol such as strong passwords and 2FA ·         ACCM employees must not disclose information regarding any child or young person without written consent of the child, young person and their parent/guardian and within the standard ACCM procedures, with the approval of their Team Leader.

• Staff Child Protection Policy Breaches

  New recruits are advised of the Policy and Check Requirements at the time an offer of employment is made. Employment is conditional upon clearances being received and the new recruit agreeing to meet these Policy and Code of Conduct obligations.

  Professional Development activities ensure ongoing awareness of staff obligations in their duties.

  Concerns raised by students about staff will be treated seriously. 

  Allegations of breaches of the policy, particularly related to treatment of young people under 18 or vulnerable students, will be responded to urgently. This is likely to involve a formal report to both the NSW reporting agency (where the staff member is based) and the agency within the state or territory that that student resides and in specific circumstances also the Police. 

  We will be guided by those agencies on if and how an internal investigation is to be conducted, and fully support their investigation.

  While acknowledging that each matter requires thorough and careful investigation, ACCM will apply a child centric focus and, for the duration of the investigation, remove that staff member from contact with that child and from unsupervised contact with any other students under 18 or otherwise deemed vulnerable. In addition access to Dashboard will be limited to restrict access to data (such as private contact details) about that or other children. The employee will be advised of a change of duties and depending on the circumstances be required to work from home or be subject to stand down. They will be advised that any attempt to contact the student (by any means and in or outside of working hours), or anyone related to that student, will be cause for immediate dismissal and reporting to the relevant state / territory agencies or Police.

  ACCM will apply and cooperate with the investigation processes of the relevant state / territory agencies.

• Support for Students and Others Making Reports

  ACCM recognises its duty to support those involved in a child protection reporting incident:

  • the involved students
  • their family 
  • the staff member reporting the incident
  • others who may be traumatised or impacted.

  On a case by case basis the appropriate support will be arranged; whether external specialist support or internal support. In determining support needs we will consult the parties involved about their needs and preferences.

• Recording and Storing Information

  Reports and supporting information are stored in digital format in a range of protected ways:

  • user specific access to storage folders
  • password protected documents
  • password and 2FA login requirements

  This ensures good quality records are maintained, but access is limited on a need to know basis.

• Kids Help Line

  Children or young people who need help can contact the Kids Helpline: 1800 551 800

  Contact them by phone or through their WebChat Counselling service at https://kidshelpline.com.au

• Reporting Hotlines

  Reports are made based on the specific location of the child and based on the reporting guidelines of that state or territory.

   Noting that the Police are to be called on 000 for reporting children or vulnerable people at immediate risk.

  State / territory	Report Phone Details	Reporting Agency
  South Australia	131 478	Child Abuse Report Line (CARL)
  New South Wales	132 111	Child Protection Helpline
  Northern Territory	1800 700 250	Child Protection Reporting Line
  Queensland	1800 177 135	Child Safety After Hours Service Centre
  Queensland	Regional Intake Service centres	https://www.dcssds.qld.gov.au/contact-us/department-contacts/child-family-contacts/child-safety-service-centres/regional-intake-services
  Western Australia	1800 273 889	Central Intake Team
  Victoria	Child Protection Regional Divisions	https://services.dffh.vic.gov.au/reporting-child-abuse
  Tasmania	1800 000 123	Strong Families Safe Kids Advice and Referral Line
  ACT	1300 556 729	Child and Youth Protection Services