CHILD SAFE ENVIRONMENT POLICY

Commitment to the safety of children and young people

We are committed to providing a safe environment to all children and young people. Our policy complies with the Children and Young People (Safety) Act 2017, the Child Safety (Prohibited Persons) Act 2016 and aligns with the National Principles for Child Safe Organisations.

We value and respect children and young people and welcome them regardless of their abilities, sex, gender, or social economic or cultural background. Bullying and harassment won’t be tolerated.

Scope of policy

This policy applies to all employees, volunteers, work placement students and contractors referred to throughout the policy collectively as workers.
All workers are required to agree in writing to accept and act in accordance with the policy.
 

Communication

This child safe policy and related documents are available to children, young people and their families on our website, and on request.
This child safe policy and related documents are provided to all workers as part of their induction following recruitment.
We encourage and respect the views of children and young people and involve them in decision making as appropriate.  We provide clear age-appropriate or developmentally appropriate explanations to children and young people including their right to safety, their right to be listened to and that they can provide feedback or make a complaint if they have a concern, to any worker or ask their parent/guardian to do this on their behalf.  We will listen to and act upon any complaints or concerns that a child or young person raises with us.

Code of Conduct

Caring for children and young people brings additional responsibilities for all workers. We are responsible for promoting and protecting the safety and wellbeing of children and young people by:
 •sticking to the organisation’s child safe policy at all times and taking all reasonable steps to ensure the safety and protection of children and young people
 •treating everyone including those of different race, ethnicity, gender, gender identity, sexual orientation, age, social class, physical ability or attributes and religious beliefs with respect and honesty and ensure equity is upheld
 •being a positive role model to children and young people in all conduct with them
 •setting clear boundaries and maintaining appropriate behaviours with children and young people – boundaries help everyone to understand 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 one to one consulting, coaching, instruction or other activity
 •being alert to children and young people who have been harmed, or may be at risk of harm and reporting this quickly to the Child Abuse Report Line (13 14 78)
 •responding quickly, fairly and transparently to any 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.
 •Play & Learn OT staff will comply with Occupational Therapy Board of Code of Conduct which outlines professional boundaries, ethical behaviour and unacceptable behaviour.  [Occupational Therapy Board of Australia - Codes and Guidelines]
 •Play & Learn OT staff will align behaviour with the Australian Occupational Therapy Competency Standards 2019  [Occupational Therapy Board of Australia - Australian occupational therapy competency standards]

Workers must not:
 •engage in rough physical games
 •develop any ‘special’ relationships with children and young people that could be seen as favouritism such as the offering of gifts or special treatment
 •do things of a personal nature that a child or young person can do for themselves, such as toileting or changing clothes
 •discriminate against any child or young person because of age, gender, cultural background, religion, vulnerability or sexuality.

Breaches or suspected breaches of the Code of Conduct should be reported as soon as practicable to management either in person, by telephone on 0414687836, or via email at rachel@playot.com.au.  Breaches or suspected breaches of the Code of Conduct will be taken seriously and dealt with quickly, fairly and transparently.
Any worker who breaches the Code of Conduct will face disciplinary action and depending on severity of the breach, the worker may have their employment terminated.  

Recruitment

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
 •clear position descriptions that include our commitment to child safety and wellbeing
 •face-to-face interviews that use behavioural questions to determine the applicant’s knowledge of child safeguarding
 •at least 2 referee checks and qualification checks.

In accordance with the Child Safety (Prohibited Persons) Act 2016, our organisation is registered with the DHS Screening Unit and we link all Working with Children Checks (WWCC). All workers who will be working in a role with children and young people must hold a current, not prohibited WWCC issued by the Screening Unit of the Department of Human Services and provide evidence of this prior to employment and renew this every 5 years. We will verify the accuracy of all WWCCs in the DHS Screening Unit portal as required by law.

We will immediately contact the Department of Human Services Screening Unit when we become aware of certain information regarding any person involved with our organisation, including any serious criminal offence, child protection information, or disciplinary or misconduct information.  

Training, supervision and support for workers

We have strategies in place to supervise, train and support workers to understand our organisation’s child safe policy, their mandatory reporting obligations, how to build culturally safe environments and their responsibilities to create a child safe and friendly environment. Our strategies include:
 •Training:
 - as part of their induction, ensure all workers read and understand the Mandatory Reporting Information Booklet available at: https://dhs.sa.gov.au/__data/assets/pdf_file/0003/103179/CSE-Mandatory-notification-information-booklet.PDF
 - complete Safe Environments Through Their Eyes AND Responding to Risk of Harm, Abuse and Neglect training every 3 years  
 - include child safety as a standing item on meeting agendas

 •Supervision:
 - regular supervision sessions that include a focus on child safety and wellbeing

 •Support:
 - an induction process for all new workers including a copy of this policy document
 - regular performance appraisals that discuss child safeguarding
 - appointing a child safety officer who has an educative role within our organisation.
  

Reporting and responding to harm or risk of harm

We aim to ensure that children and young people are safe from harm and risk of harm. Section 17 of the Safety Act defines ‘harm’ to mean physical or psychological harm (whether caused by an act or omission), including harm caused by sexual, physical, mental or emotional abuse or neglect.

Mandated reporters in our organisation are workers who:
 •provide services to children and young people
 •hold a management position in the organisation the duties of which include direct responsibility for, or direct supervision of, the provision of those services to children and young people.

Mandated reporters have a legal obligation to report the Child Abuse Report Line (CARL) on 13 14 78 as soon as practicable if they have a reasonable belief that a child or young person has been harmed or may be at risk of harm. If the child or young person is at immediate risk, report to South Australia Police (SAPOL) on 000.  

Even if not a mandated reporter, any person can report harm or risk of harm to a child or young person. The individual who identifies the harm or risk of harm is encouraged to make the report to authorities and can request the support from another worker to do so if required.

Information about making appropriate reports of harm or risk of harm is available from the South Australian Department for Child Protection website: https://www.childprotection.sa.gov.au/reporting-child-abuse.  
All adult workers (even if not a mandated reporter) have a legal obligation to report child sexual abuse to the police and to protect a child from sexual abuse. Failure to meet these obligations may be considered a criminal offence.

Following a report being made to CARL or SAPOL workers must make an internal report to management.  
We will be guided by the Department for Child Protection and/or SAPOL after a report has been made as to whether we can conduct an internal investigation.

If a worker is reported to CARL or SAPOL for causing harm or risk of harm to a child or young person, they will be removed from any role that involves working with any child or young person until authorities have concluded their investigation.

Following a report to CARL or SAPOL we will support the child or young person by:
 •referring the child, young person or their family to other appropriate services
 •continuing to provide a service to the child, young person and their family and monitor their circumstances.
We will document all information received regarding the report and store this securely in a separate file.  

Reporting and responding to general complaints or feedback

Providing opportunities for complaints and feedback ensures that children, young people and their families feel valued and respected and enables us to improve the quality of our service.  Children, young people and their families are informed that they can provide feedback or make a complaint as part of their welcome pack when they join the organisation, and this information is also available on the website.

Compliments, complaints or feedback can be provided verbally or in writing to any worker or direct to management either by telephone on 0414687836, via email at rachel@playot.com.au. We will deal with all complaints and feedback received promptly, sensitively and fairly.  

We will:
 •listen to the complaint/feedback
 •the person receiving the complaint will make a record of it if received verbally
 •advise of the time expected for an outcome
 •if a worker receives a complaint, they must forward it to management as soon as possible
 •management will respond to the complainant with an outcome in a timely manner
 •clearly document and securely store decisions and actions taken in response to complaints and feedback
 •make sure that procedural fairness is followed at all times.

If the child, young person or their family is not happy with the outcome from the complaints process they can contact:
 •National Disability Insurance Scheme 1800 800 110
 •Health and Community Services Complaints Commissioner 8226 8666
 •Australian Health Practitioners Regulation Agency 1300 419 495
 •Occupational Therapy Australia 1300 682 878
 •Australian Human Rights Commission Online: www.humanrights.gov.au Tel: 1300 656 419
 •South Australian Equal Opportunities Commission (for complaints relating to discrimination) Online: www.eoc.sa.gov.au Tel: 08 8207 1977.

Risk management

Identified Risk

Actions to Minimise Risk

Culture of organisation is not child-safe focussed

•child focused Code of Conduct is in place that sets the behavioural standards expected including what happens when a breach occurs
 •the National Principles for Child Safe Organisations are embedded in policies and procedures
 •we meet the requirements of the Children and Young People (Safety) Act 2017 (which mandates child safe environments) and the Child Safety (Prohibited Persons) Act 2016 (which mandates Working with Children Checks) 

Workers harm children/young people

•recruitment processes including undertaking referee checks to ensure the suitability of persons before they are employed/volunteer with our organisation
  •interview questions (no prior preparation) should gauge an applicant’s understanding of child safe principles and actions that would be taken to prevent harm to children and young people
 •all workers have WWCC with ‘not prohibited’ result prior to working with children and young people, renew WWCCs every 5 years and status remains as not prohibited 

Workers don’t understand their obligations to report harm and risk of harm to the Child Abuse Report Line (or SA Police if child/young person is at immediate risk)

•all workers read and understand the Mandatory Reporting Information Booklet
 •all workers complete Safe Environments Through their Eyes AND Responding to Risk of Harm, Abuse and Neglect – Education and Care training every 3 years
 •all workers must abide by the child safe environments policy and Code of Conduct (latter is signed on commencement with organisation) 

Physical contact

•any physical contact must be appropriate to the delivery of services 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

•cyber safety and social media guidelines are in place and provided to all workers
 •appropriate supervision is provided for all online activities
 •workers must not communicate with children or young people via social media 

Transport of children and young people

•workers must not transport a child or young person unless specifically approved
 •parents/guardians must provide consent before transporting a child or young person
 •worker must have a valid, unrestricted driver’s licence
 •vehicle must be registered, insured and in roadworthy condition
 •worker must not be alone in a vehicle with a child or young person 

Supervision

•children and young people are to be supervised by parents/ guardians at all times
 •when providing one to one consultation with a child or young person, it will be in line of sight of another adult 

Taking images of children and young people

•consent of child young person and their parent/guardian required
 •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 

Physical environment

•maintain a risk register that is reviewed annually to ensure effectiveness
 •conduct risk assessments for all activities
 •ensure all equipment is in good working order 

Privacy and confidentiality

•all documents containing confidential information will be stored privately in a locked filing cabinet (or similar place with restricted access)
 •digital files containing confidential information shall be protected electronically by restricting the access to only those requiring it to perform their duties
 •workers must not disclose information regarding any child or young person without written consent of the child, young person and their parent/guardian

Related policies and procedures

This policy must be read in conjunction with the following documents, policies and/or procedures:
Children and Young People (Safety) Act 2017
Child Safety (Prohibited Persons) Act 2016
Play & Learn OT mandatory-notification-record-template
Play & Learn OT Complaints Policy
Orientation Checklist
Mandatory Report Guide – The Structured Decision Making System 2018
Occupational Therapy Board of Code of Conduct
Australian Occupational Therapy Competency Standards 2019
National Principles for Child Safe Organisations
 

Policy review

We will, at a minimum, review this policy and the related procedures once every 5 years as required by the Children and Young People (Safety) Act 2017.
  We will also review this policy when:
 •new or added risks are identified for children or young people, which may require a change in the policy or procedures
 •a critical incident where a child or young person has experienced harm through involvement in the organisation
 •concerns are raised by anyone involved in your organisation about child safety or welfare in the organisation
 •awareness or compliance to the child safe policy and/or procedures is low
 •legislative changes/requirements. We will lodge a new child safe environments compliance statement with the Department of Human Services each time we review and update this policy.    

Last updated: 31/05/2024

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