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Specific Policies and Procedures

• 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 who are under 18 and are 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.

• Child Safe Reporting Policy

  Introduction

  To help keep children safe, we must create, maintain and improve our child safe reporting practices to ensure they remain effective. Everyone in our organisation must:

  • know what to report, who to report it to and how to report it
  • report any concerns about the safety or welfare of a child or young person immediately
  • feel confident that concerns and allegations will be dealt with honestly and fairly
  • feel confident in reporting unacceptable behaviour around children and young people

  ensure the safety and wellbeing of the child is paramount when an allegation is made.

   

  Definitions of harm and abuse (what to report)

  Psychological abuse

  Includes bullying, threatening and abusive language, intimidation, shaming and name calling, ignoring and isolating a child, and exposure to domestic and family violence.

  Physical abuse

  Includes physical punishment such as pushing, shoving, punching, slapping and kicking, resulting in injury, burns, choking or bruising.

  Sexual abuse

  Includes the sexual touching of a child, grooming, and production, distribution or possession of child abuse material (often known as photography).

  Grooming

  The 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 sexually abuse the child.

  Misconduct

  Inappropriate behaviour that may not be as severe as abuse, although could indicate that abuse is occurring and would often be in breach of an organisation鈥檚 Child Safe Code of Conduct*, including showing a child something inappropriate on a phone, having inappropriate conversations with a child or an adult sitting with a child on their lap.

  Lack of appropriate care

  Includes not providing adequate and proper supervision, nourishment, clothing, shelter, education or medical care.

  Note: As a relevant entity, our organisation must also report .

   

  Types of Complaint (what to report)

  All complaints should be reported. This includes:

  • criminal conduct
  • disclosures of abuse
  • unacceptable behaviour around children and young people that breaches our Child Safe Code of Conduct
  • suspicion of harm or abuse to a child or young person

  reportable conduct.

   

  Making a Complaint

  Everyone in our organisation has the right to make a genuine complaint and won鈥檛 be punished if they do. This includes children and young people, staff members and volunteers. Reporting abuse is mandatory and encouraged 鈥� it is never obstructed or prevented.

   

  Reporting obligations (who to report to)

   

  Reporting criminal conduct

  Contact NSW Police on 131 444 for anything you consider could be a criminal offence. This includes sexual assault, physical assault, grooming offences, and producing, disseminating or possessing child abuse material.

  Note: It is a criminal offence for adults not to report to police if . In addition, people employed in child-related work may be subject to a criminal offence if .

  Reporting risk of significant harm

  Any person who has reasonable grounds to believe that a child or young person is at risk of significant harm (ROSH) can report to the Department of Communities and Justice (DCJ) on 132 111 (this is a 24-hour service).

  Mandatory reporters must report to the if they have reasonable grounds to suspect a child is at ROSH.

  Reporting allegations and convictions

  Relevant entities must notify the Office of the Children鈥檚 Guardian of reportable allegations or convictions (that is, reportable conduct). This includes sexual offences, sexual misconduct, ill-treatment of a child, neglect of a child, an assault against a child, failure to protect a child or failure to report if a child has been harmed, as well as any behaviour that causes significant psychological harm to a child.

  Reporting breaches of our Child Safe Code of Conduct

  All complaints must be reported to our child safe contact officers.

   

  Risk management strategies (how to report)

  To ensure the immediate and ongoing safety of the child:

  • establish the welfare and safety of the child and take steps to ensure the child is removed from the risk
  • reassure them and remain calm
  • listen carefully without interrupting
  • don't ask leading questions or any additional questions once you've established there is a genuine concern (to not compromise future investigations by NSW Police or DCJ)
  • support them, reassuring the child that they have done the right thing, that you believe them and that the abuse is not their fault
  • explain what will happen, including timeframes
  • don鈥檛 make promises you can鈥檛 keep
  • don鈥檛 confront the alleged perpetrator
  • seek guidance if you are unsure about what to do.

  It is the child safety officer鈥檚 role to conduct a risk assessment after receiving an allegation, to ensure the safety of all people involved and maintain the integrity of the investigation

   

  Procedural fairness, including privacy and confidentiality (how to report)

  Any allegation of abuse will be treated in a fair, transparent and timely manner. Workers subject to an allegation will be notified when a disciplinary hearing will take place and what will occur at the hearing. We follow the obligations defined under the Privacy Act 1988 (Commonwealth), and relevant reportable conduct investigations are conducted with the OCG鈥檚 Reportable Conduct Directorate.

  Additionally:

  • all information is recorded on our reporting form for complaints and allegations
  • all reporting forms for complaints and allegations are stored securely and only accessed by those in the organisation with responsibility for oversight of the investigation
  • information may be exchanged under Chapter 16A of the Child and Young Persons (Care and Protection) Act 1998, with other agencies who have responsibilities relating to the safety, welfare or wellbeing of children or young people
  • our organisation maintains the privacy of those involved in accordance with our obligations under the Privacy and Personal Information Protection Act 1998

  if an incident is found to be substantiated, likely outcomes or responses will be determined by HR or from advice given by relevant authorities (police, DCJ or OCG).

   

  Complaint Process (how to report)

  Once a complaint has been made, use this step-by-step process to make sure it鈥檚 appropriately followed up:

  • steps taken to remove child from harm
  • incident recorded
  • reporting obligations met, if necessary
  • investigation conducted, keeping everyone involved up to date with what鈥檚 happening
  • offering ongoing support to the child as needed

  reviewing the incident and updating the organisation鈥檚 child safe policies, if necessary.

   

  How we publicise our Child Safe Reporting Policy

  To ensure everyone in our organisation is aware of our Child Safe Reporting Policy and their reporting obligations we:

  • hold information sessions about our child safe policies and how they apply to families, workers and children
  • create and display important information from our Child Safe Reporting Policy that describes what to report, who to report to and how to report, including fact sheets, brochures and posters
  • provide workers with internal and external (as appropriate) training opportunities so they understand our processes for complaints and allegations
  • create and promote age- and ability-appropriate programs for children and young people that explain what do if they feel sad, angry or concerned.
• 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:
  鈥� when a child or young person tells you they are at risk or have been harmed
  鈥� when your own observations of a particular child or young person鈥檚 behaviour and/or injuries lead you to suspect they are at risk, or harm is occurring
  鈥� 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)
  鈥� 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.

• Human Resources Policy - Child Safe Particulars

  Purpose of this policy

  The aim of this policy is to make sure that all ACCM staff responsible for recruitment, induction and training of staff at ACCM College uphold our child safe recruitment, induction and training practices.

  The policy sets out the processes for child safe recruitment of staff and volunteers for any child-related roles. The policy also includes the induction process for new recruits and volunteers, and further training that may be required at times for all staff, including volunteers.

  This is to make sure they continue to have the required skills to prevent risk of harm to children.

  Who the policy is for

  This policy is for staff undertaking recruitment of staff or volunteers for child-related roles.

  The child safe recruitment and induction processes set out in this policy must be applied to anyone we are considering for a child-related role at ACCM College

  This includes roles that involve any of the following:

  • Coaching, Training or contact with students under the age of 18
  • being alone with children or engaging with them in a way that is not observed or monitored (which includes phone or video contact).
  • taking part in activities with children away from the organisation鈥檚 usual location
  • having access (online or paper based) to a child鈥檚 or children鈥檚 personal and/or confidential information
  • transporting children
  • having any other type of unmonitored contact with children.

   

  Processes for child safe recruitment for staff

  1. We include our commitment to child safety in our advertising

  Our job advertisements include details about our organisation鈥檚 commitment to being child safe. We let potential staff members know at the outset that we uphold children鈥檚 rights and take implementation of the Child Safe Standards seriously, and that everyone who works with children must have a cleared Working with Children Check. We provide a link in the job ad to our Statement of Commitment to Child Safety.

  2. We conduct a robust interview process for new employees

  This process involves:

  1. Setting up an interview panel: we decide who will take part in the selection process to help pre-assess the applicants and conduct the interviews
  2. Short-listing: we pre-assess applicants鈥� suitability to work with children and develop a short list
  3. Having the interview: we decide on the questions we want to ask. For child-related roles, questions will generally focus on the applicants鈥� experience working in previous child-related roles
  4. Assessing candidates and making the final selection: the panel discuss the interviews and make notes on strengths and weaknesses to help them decide on the best candidate.

   

  3. Check references

  Each candidate must provide the details of two referees.

  At least one of the referees should be someone from their most recent role.

  Referees should have directly supervised or managed the applicant in a professional capacity.

  If the applicant has never worked before or has just left school, character references may be acceptable However, these should not be from family members or be given as much weight as professional references.

  We ask each referee whether they see any issues with the applicant working with children.

   

  4. Screen and verify applicant鈥檚 Working with Children Check

   In NSW all adult workers in child-related work, whether paid or unpaid, must hold a WWCC clearance or a current application for a Working with Children Check (WWCC) clearance (unless they are subject to an ).

  Employers have legal obligations around working with children. It is against the law to engage anyone in child-related work without a WWCC. If a worker or volunteer requires a WWCC, there are actions our organisation must take.

   

  Before commencing employment, we make sure the applicant has a cleared WWCC and we verify it on the .

  We keep records for each verified worker, including:

  1. Full name
  2. Date of birth
  3. WWCC number
  4. Verification date
  5. Verification outcome
  6. Expiry date of WWCC
  7. Whether the worker is in paid or volunteer work.

  We continue to monitor and act to:

  • keep all workers and volunteers鈥� WWCC details up to date
  • remind employees to renew which they can do up to 3 months before their WWCC expires, and
  • remove anyone whose WWCC status is barred, interim barred, whose WWCC cannot be found or has expired from child-related work. We can only employ people who have an Application number or WWCC clearance in child-related work.

   

  If ACCM is notified that someone is barred from working with children

  A person is barred from working with children if the Office of the Children鈥檚 Guardian (OCG) has determined that the person is a risk to working with children.

  When the OCG bars a person in our organisation from working with children, they will contact the person registered as our 鈥榗ontact person鈥� when we initially registered as an employer in the WWCC system. The purpose of the initial contact is to determine whether the worker is currently working in our organisation, and whether they are working with children.

  It is important that we respond to this request promptly and accurately.

  If we have confirmed that the worker is working with children in our organisation, the OCG will issue a formal written notification advising us to remove the worker from working with children.

  Once this has been received, we need to take immediate action and respond to the OCG in writing, confirming that the worker has been removed from working with children.

  A record must be kept of our actions. This information should be treated confidentially and only the people in the organisation who need to know this should be advised.

  More information on how to manage a barred worker can be found in the OCG鈥檚 handbook and on

   

  Child safe induction

  ACCM College recognises that making sure a staff member is safe and suitable to work with children is an ongoing process. Inductions for staff and volunteers include:

  • an overview of all our child safe documents, including our Child Safe Code of Conduct (to be read and signed), the Child Safe Risk Management Plan and our Child Safe Reporting Policy, ensuring that that new staff and volunteers are advised of their reporting obligations and how to identify and raise a child safety concern
  • a tour of our premises explaining any physical risks new recruits should be aware of (which are included in our Child Safe Risk Management Plan) and relevant behaviours on site as set out in our Code of Conduct, including the use of personal devices
  • ensuring new recruits complete required child safe training (see below), and
  • monitoring and supervision.

  We support new recruits with appropriate instruction and feedback when needed, including regular oversight as they become familiar with the new role.

  There is also a 6-month probationary period for all workers to make sure they are a good fit with our organisation.

   

  Child safe training

  New staff and volunteers should complete required child safe training. We encourage everyone to do introductory through the OCG.

  Staff and volunteers also receive ongoing child safe training. We encourage everyone to do additional through the OCG, dependent on their role in the organisation. We also ask staff and volunteers to complete Enter name of eLearning course on the .

   

  Child Safe Code of Conduct review

  Staff are told when we are reviewing our child safe policies and we invite them to contribute.

  The Director of RTO Operations will review this policy annually unless there are any incidents, in which case it will be reviewed immediately.

   

• 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	Extremely 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 is no requirement to transport a student. In exceptional circumstances, parents/guardians would 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鈥檚 licence The vehicle used must be registered, insured and in roadworthy condition
  Supervision	There are limited Face to Face (F2F) 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 video session is used)
  Taking images of children and young people	Written consent of child /young person and their parent/guardian is required for any photos or recordings Where consent is requested, 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.

• 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.

• 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 : 1800 551 800

  Contact them by phone or through their 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
  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