Child Safe Environments Policy

Purpose of policy

Two Way Street (TWS) aims to provide an environment that minimises the risk of children and young people being harmed in any way whilst in the care of TWS and to protect staff from the possibility that allegations of child maltreatment could be falsely made against them, as a result of their work. Harm to children and young people thrives in secrecy, therefore to prevent harm or risk of harm TWS will develop and maintain an open and aware culture where staff, children and young people are aware of appropriate and inappropriate behaviour.

TWS believes it also has a responsibility to its staff to protect their right to confidentiality unless allegations against them are substantiated.

This policy will outline the roles and responsibilities of everyone involved in the organisation.

Commitment to the safety of children and young people

TWS understands it has a duty of care to act immediately to protect and preserve the safety and wellbeing of the children and young people in its care. TWS is committed to diversity and values all children and young people equally, regardless of their abilities, sex, gender or social-economic or cultural background.

TWS believes that the best way to ensure children and young people’s protection at TWS is to establish an environment that minimises risks and sets out clear safeguards for staff to follow. It is for this reason and the commitment to being a part of a community that takes responsibility for children and young people’s safety that TWS has developed this policy.

This policy complies with the child safe environment provisions of the following:

• Children and Young People (Safety) Act 2017,
• Child Safe (Prohibited Persons) Act 2016, and
• National Principles for Child Safe Organisations.

Scope of policy

All staff will be fully informed about their responsibilities to implement and adhere to TWS’s child protection policies and procedures. All staff includes permanent employees, contractors, volunteers and students who perform duties during TWS’s hours of operation (paid or unpaid).

Communication

All child safe environments policies are made available to staff on a shared access drive. All staff are required to sign an agreement that they accept and act in accordance with this policy. This policy is publicly available on the TWS website footer at https://twowaystreet.com.au/.

Participation

TWS will encourage children and young people who access our services to tell us how they think we’re doing and how we can better support them. Rate Our Services Aided Language Displays are available in every clinical room and TWS clinicians are expected to regularly engage with clients and provide opportunities for feedback and discussion. This is incorporated into the therapeutic sessions to empower children and young people who use Augmentative and Alternative Communication on how to direct their care and services and how to discuss and communicate their needs and concerns.

Codes of Conduct

All staff are required to uphold the values of TWS and agree and act in accordance with the following Codes of Conduct:

• Speech Pathology Australia Code of Ethics
• The NDIS Code of Conduct
• Code of Conduct for Certain Health Care Workers
• TWS Child-centred Code of Conduct

TWS Child-centered Code of Conduct

Caring for children and young people brings additional responsibilities for employees and volunteers of our organisation. All TWS employees and volunteers are responsible for promoting and protecting the safety and wellbeing of children and young people by:

• complying to this child safe policy at all times and taking all reasonable steps to ensure the safety and protection of children and young people
• treating everyone (this includes staff, volunteers, students, children, young people and parents) 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 your conduct with them
• foster children’s self-esteem and positive self-image
• setting clear boundaries about appropriate behaviour between yourself and the children and young people who access services at TWS – 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 during sessions
• being alert to children and young people who are, 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 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.

Employees and volunteers 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 or that their parent/guardian assists them with, such as toileting or changing clothes
• discriminate against any child or young person because of age, gender, cultural background, religion, vulnerability or sexuality.

Any suspected breaches of any of these Codes of Conduct must be immediately raised with the employee’s supervisor for further investigation. If an employee is found to have breached a Code of Conduct, the TWS Director will commence performance management proceedings. Depending on the seriousness of the breach, these actions may include:

• coaching, mentoring, and role-modelling of appropriate behaviour with children and young people,
• professional development, including repeated RRHAN-EC training or ’Through their eyes’ training, and/or
• summary dismissal for gross misconduct.

Recruitment 

TWS meets the requirements of the Child Safety (Prohibited Persons) Act 2016 and ensures that all staff provide a valid Working with Children Check from the Screening Unit of the Department of Human Services. TWS will ensure a new working with children check is obtained every 5 years prior to expiry, or as required by the Department of Human Services.

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.

In accordance with the Staff Recruitment Policy, the following requirements must be met during the recruitment process:

• Application to TWS must include resume and written expression of interest
• A clear position description will be provided to the candidate which will include roles and responsibilities, documentation required for employment, values, expectations on professional conduct and a commitment to child safety and wellbeing.
• 1 interview as a minimum with the Director of Two Way Street and, if possible, at least 1 other staff member to meet and interview. These interviews will be completed in person and/or online.
• A minimum of 2 referee checks will be completed by an authorised person (Director or General Manager)

For employment at TWS, staff must provide the following documentation:

• Responding to Risks of Harm, Abuse and Neglect – Education and Care (RRHAN-EC) masterclass training and valid refresher certificate/s
• Valid Working with Children Check
• Speech Pathology (SP) Australia membership certification confirming Certified Practising Speech Pathologist status (SPs only)
• SP degree parchment (SPs only)

All staff will be oriented to TWS’s policies and procedures and code of conduct. Whenever possible new staff will have a period of time to work alongside current staff to familiarise themselves with the clients, families and TWS procedures prior to taking up their new role in a full capacity.

 Supervision, training and support for employees and volunteers

TWS requires all staff to participate in training on child protection organised by relevant child protection authorities or support agencies.

TWS will:

• ensure that staff are knowledgeable about current legislation and reporting requirements related to child protection and maltreatment and that a system for reporting and recording suspicious incidents is in place
• ensure staff understand their responsibility as mandated reporters
• provide access to current information about the procedures to be taken in relation to allegations of the harm or risk of harm to children and young people
• ensure a guidebook to recognising signs of harm or risk of harm including abuse or neglect will be made available to all staff to remind them of the possible signs of harm, and the procedures they should follow if a child or young person in their care displays behaviour or physical signs that could indicate harm has taken place (Reporting Abuse and Neglect – Participants Handbook)
• regularly remind staff about TWS’s policies, procedures and confidentiality requirements in regard to child protection
• ensure staff complete masterclass RRHAN-EC training followed by refresher training every 3 years or as required by the Department for Education.

Reporting and responding to harm or risk of harm

Mandated notifiers have a legal obligation to notify the Child Abuse Report Line (CARL) as soon as practicable if they suspect on reasonable grounds that a child or young person is or may be at risk of harm. All TWS employees are mandated reporters and are supported and encouraged to report the reasonable belief that a child or young person is or may be at risk of harm and in need of protection.

Reporting concerns

1. In the course of work hours, if the TWS staff member forms the view that a child or young person has been or is at risk of harm they must report to CARL on 13 14 78 or if a child or young person is at immediate risk, the TWS staff member will report to South Australia Police (SAPOL) on 000. The person who identifies the harm is the person to make the report to CARL/SAPOL.
2. No other staff will be given identifying information about the family unless an authorised person (Director or General Manager) feels that they need to know.
3. An authorised person may provide support to the staff member when they make a report to authorities if requested. 
4. The authorised person or staff member has discretion whether and if so when to notify the family involved that they are making a report. This will depend on whether notifying the family increases risk of harm to the child or young person. When the suspected harm involves severe physical injury or sexual abuse, the family will generally not be notified before a report is made. TWS will in these cases be guided by Child Protection as to if and when to notify the family.
5. TWS and each staff member have a right to take any action to ensure that children and staff are safe at all times. This may involve contacting the police if any person or family makes threats against staff.
6. As part of the standard procedure, the staff member will make careful documentation of concerns and any action taken. This report will be reviewed by an authorised person and confidentially and securely stored. 

Following a report 

Following a report to CARL, clinical sessions with TWS will remain in place with the child or young person and TWS staff will continue to monitor their circumstances. 

• The TWS staff member will continue to support the child or young person ensuring that they know they are believed and are being listened to. 
• Referrals to other relevant agencies will be made to ensure the child or young person and their family have access to specialised support. 
• Internal clinical reporting will be maintained to ensure actions and referrals are documented. 
• Services that can assist children, young people and their families including the Kids Helpline on 1800 55 1800 are visible in clinical areas.

Concerns about a member of TWS

In the event  of a reasonable belief that a child or young person is, or may be, at risk of harm by a member of the organisation, TWS authorised persons will respond quickly and thoroughly to ensure children and young people are safeguarded. 

If the concern is raised by a TWS staff member, the staff member will follow the procedure for reporting concerns and contact CARL or, if a child or young person is at immediate risk, SAPOL.

All actions taken will be relevant to the offence and TWS authorised persons will be guided by authorities. If the offence is serious and warrants dismissal, the TWS staff member will be summarily dismissed and TWS will fully comply with all required actions from authorities. Following a report that does not warrant immediate dismissal, the following action will be taken:

• A 12 month probationary plan will be created for the staff member relevant to their role and the nature of the report. The plan will be followed, progress and compliance reported, and sign off from the plan noted by an authorised person at the acceptable completion of all actions during the 12 month period.
• The staff member will be engaged with training organisations and complete additional training.
• Their duties may be revised during this period, while they complete their probationary plan and training.
• TWS authorised persons will contact relevant agencies for guidance to ensure that the probationary plan adequately addresses the needs of the person and maintains the safety of any child and young person receiving services from TWS.

Reporting and responding to complaints or feedback

Client feedback, both positive and constructive, is an essential part of helping us to continuously improve our service quality. Clients and staff can lodge a complaint in person, over the phone, by email or in writing with the TWS General Manager or Director.

TWS will:

• acknowledge receiving it in writing;
• investigate complaints by reviewing what happened;
• if appropriate, encourage discussion of concerns openly with the relevant staff member(s) or the General Manager or another senior staff member with the authority to resolve your complaint, including the Director;
• communicate the outcome of investigations to the complainant and ensure that any recommended improvements or changes are implemented effectively; and
• respond appropriately to the complaint.

Resolving complaints amicably gives TWS the opportunity to improve services and to learn from our mistakes. TWS takes complaints very seriously and will work hard to address and resolve them efficiently and effectively.

Risk Management

Identified risks for current service provision are identified through ongoing clinical discussion and review. Any newly identified risks to children or young people will be raised with the Director and General Manager for review, treatment, and inclusion in this policy.

Identified risk	Likelihood	Action to mitigate risk
One-to-one allied health sessions with a child or young person	High	SP to include parent, guardian or primary support person at all times in sessions unless there is a compelling reason not to do this.
One-to-one allied health sessions with a child or young person without a guardian in the same room	Low	If a support person has a compelling reason not to be in the room, the SP will keep all doors open and ensure visual and/or at minimum auditory monitoring by the parent, guardian or primary support person.
One-to-one allied health sessions with a child or young person without a guardian present	Low	If a support person has a compelling reason not to be present during sessions, the SP must advise the Director or General Manager prior to any sessions proceeding. They may choose to implement a written agreement with the parent that ensures appropriate measures are taken and a strategy is in place (for example real-time video monitoring or recording) or for sessions not to proceed until a suitable support person can be available during sessions.
Video and/or images of a child or young person taken during allied health sessions	Medium	When there is a clinical reason to take an image or video of a child or young person (for example assessing progress or for mentoring purposes with the clinical lead), the SP will do so using their TWS-supplied device only. As soon as the SP has wifi service, the image and/or video will be uploaded to the client’s file on the secure TWS server and the SP will delete the image and/or video from their device.

Policy Review

This policy will be reviewed at least once every five years in accordance with Section 115 of the Children and Young People (Safety) Act 2017 or sooner should a new risk, critical incident or concern require a review of this policy.

A new compliance statement will be lodged with the Department of Human Services each time this policy is reviewed/updated.

Date of last review: June 2022

Next review: June 2027