Child Protection and Vulnerable Persons (Child Safe Environment) Policy

Reviewed Jun 2020, Dec 2020, Dec 2021, Updated Jun 2022, Reviewed Jul 2023, Updated Nov 23, Reviewed Dec 2023; Updated April 2024

Child Protection and Vulnerable Persons (Child Safe Environment) Policy
Policy Statement

Students have the right to safety and to have their concerns and ideas listened to.

ACCM College recognises the need to have in place procedures to identify and action situations where there are concerns for the safety, welfare and wellbeing of students; and to ensure a open communication process.

Students, including young people, are encouraged to provide feedback to us and participate in the ongoing development and improvement of our policies and procedures.

ACCM College is committed to and will be proactive in providing a safe environment, particularly for students under 18 and young and vulnerable people. This includes a no tolerance approach to bullying and harassment.

ACCM will seek the input and views of young people, their guardians and/or carers on all aspects of its operations and especially this Child Protection Policy and Procedures.

ACCM College will report to the appropriate government agency concerns for the safety, welfare and well being of students who are under 18 years of age.

In the case of students over 18, where there is concern for their safety or well being, act to obtain assistance from the relevant agency or support body.

ACCM College will implement internal policies and procedures to ensure that staff who will have face to face contact with students under 18 will be screened for child protection offences in accordance with required legislation.

Procedures will include processes to monitor staff interaction and access to information for students under 18.

Policy Scope

This policy addresses the requirements and needs of the range of child protection legislation across all states and territories that we operate in. 

This policy and procedures apply to all staff, which includes paid employees, any contractors and any volunteers (including work experience)

This policy will remain published and updated on the ACCM website as well as be referenced and linked in student and staff inductions.

Policy Purpose

This policy represents the position of ACCM as a provider of educational services where some students will be under 18 and some students will be vulnerable for a range of reasons; and who may be at risk of harm.

The intention of this policy is to ensure protective practices for all:

  • children, young people (under 18 years of age) and
  • vulnerable people

are implemented by ACCM to:

  1. keep them safe (inclusive of cultural safety) from deliberate or inadvertent risk of harm and
  2. provide them with an understanding of such protective practices.

This policy provides all ACCM staff and contractors (our “personnel”) with an understanding of their responsibilities (as agreed to under the terms of their engagement) to keep children and young people safe, while fostering a culture of openness and respect of cultural diversity.

We recognise that all children have a right to be safe from harm, regardless of age, culture, religion, gender, sexuality, identity or disability.

This Policy also sets out the responsibilities of managers and team leaders across ACCM.

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


    ·         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

  • 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
    Western Australia 1800 273 889 Central Intake Team
    Victoria Child Protection Regional Divisions
    Tasmania  1800 000 123 Strong Families Safe Kids Advice and Referral Line
    ACT 1300 556 729 Child and Youth Protection Services

Code of Conduct for Working With Children and Young people to Ensure a Child Safe Environment

Providing training for children and young people brings additional responsibilities for employees of ACCM College. 

All employees of ACCM College are responsible for promoting the safety and well-being of children and young people by:

• Adhering to the ACCM College Child Protection and Vulnerable Persons Policy at all times and taking all reasonable steps to ensure the safety and protection of children and young people

• Treating everyone with respect and honesty (this includes staff, clients, volunteers, students, children, young people, school advisers, guardians, carers and parents)

• Remembering to be a positive role model to children and young people in all your conduct with them

• Setting clear boundaries about appropriate behaviour between yourself and the children and young people who are students at ACCM – boundaries help everyone to carry out their roles

• Listening and responding appropriately to the views and concerns of children and young people

being alert to bullying behaviours and responding promptly and appropriately

• Ensuring another adult is always present or in sight when conducting face to face one-to-one coaching, instruction or other activities with a person under 18

• Being alert to young people who are at risk of harm or have been harmed and reporting this quickly in accordance with College Reporting Rules and/or to the Child Abuse Report Line (13 14 78)

• Responding quickly, fairly and transparently to any serious complaints made by a child, young person or their parent/guardian

• Encouraging children and young people to ‘have a say’ on issues that are important to them

• Providing feedback to both children and parents or guardians


Reporting suspected breaches of this code or other inappropriate behaviour of other staff or contractors.


Employees and contractors of ACCM College, by accepting their employment / engagement contract, agree that they will not:

• Engage in physical contact with students or clients, other than customary greetings e.g. shaking of hands

• Develop any ‘special’ relationships with children and young people that could be seen as favouritism such as the offering of gifts or special treatment

• Ask unnecessarily personal questions of students or engage or allow personal discussion, regardless of who initiates the discussion

• Discriminate against any child or young person because of age, gender, cultural background, religion, vulnerability or sexuality

• Offer personal gifts or special treatment

• Ignore efforts by a young person to reach out for help related to a child protection matter

• Use language that is offensive or has a sexual connotation or be regarded as bullying, demeaning or harassing

• Make contact with students for any reason other than in the normal course of their job role, and limit after hours contact or use of personal phones for that contact only with supervisor knowledge of the reasons for it and with approval. This includes a ban on communicating or interacting with students via social media except where a specific job task eg acknowledging a Student of the Month Award.


Students or their family or guardians or other involved parties can report breaches of this Code directly to the College CEO by email, phone or web contact.

 Failure to comply with this Code of Conduct to Ensure a Child Safe Environment will be treated as a staff disciplinary action.

Compliance and Relevant Legislation

ACCM and its personnel have obligations nationally and across all states and territories.

This policy complies with the following legislation and related regulations and working with children check processes:

The legislative definition of harm includes:

Physical harm or psychological harm (whether caused by an act or omission) and, without limiting the generality of this subsection, includes such harm caused by sexual, physical, mental or emotional abuse or neglect.

Psychological harm however, does not include emotional reactions such as distress, grief, fear or anger that are a response to the ordinary vicissitudes of life.

The legislative definition of ‘At Risk’ includes:
  • The child or young person has suffered harm.
  • There is a likelihood that the child or young person will suffer harm.
  • There is a likelihood that the child or young person will be removed from the state for an unlawful act or procedure to be undertaken.
  • The parents or guardian of the child or young person are unable or unwilling to care for them.
  • The child or young person is of compulsory school age but has been persistently absent from school without satisfactory explanation of the absence.
  • The child or young person is of no fixed address.

[Refer to s18 Children and Young People (Safety) Act SA 2017 for the full definition]

State or Territory Specific Information

  • South Australia
    Policy Review 

    ACCM will, at a minimum, review the policies and procedures once every 5 years as required by the Children and Young People (Safety) Act 2017

    Policy Update

    ACCM will will lodge a new child safe environments compliance statement with Department of Human Services each time we review and update our policy.