Child Safe Environments Policy

Purpose of policy

Two Way Street (TWS) aims to provide an environment that minimises the risk of children 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. Child abuse thrives in secrecy, therefore to prevent child abuse; TWS will develop and maintain an open and aware culture where staff and children 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 of abuse 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 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’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’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 believes it has a responsibility to all clients to defend their right to care and protection. To support this right TWS will follow any procedures recommended by child protection authorities, when dealing with any allegations of abuse or neglect of children, and will ensure that all staff undergo appropriate professional development in this area. TWS will also document any concerns where a child may be at risk of harm that may have occurred outside of TWS and follow procedures to ensure the child is protected from harm. 

All staff will:

• foster children’s self-esteem and positive self-image through their interactions and relationships with children,
• role model appropriate behaviour and language, and
• build relationships with all children based on trust and will empower children to discuss and communicate their needs and concerns.

Code of Conduct

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

• Speech Pathology Australia Code of Ethics
• The NDIS Code of Conduct
• Code of Conduct for Certain Health Care Workers

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.

All persons other than employed staff who perform duties during TWS’s hours of operation (paid or unpaid) will be required to present a valid Working with Children Check.

In accordance with the Staff Recruitment Policy, all applicants will have a personal interview with the TWS Director. A reference check will be completed by the Director or delegated supervisor. 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
• understand their responsibility as mandated reporters
• access current information about the procedures to be taken in relation to allegations of child abuse or neglect
• ensure a guidebook to recognising signs of abuse or neglect will be made available to all staff to remind them of the possible signs of child abuse, and the procedures they should follow if a child in their care displays behaviour or physical signs that could indicate abuse 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 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, and the child’s parents are unable or unwilling to protect the child. 

Reporting concerns

1. In the course of work hours, if the TWS staff member forms the view that protective concerns exist; they must discuss these concerns as soon as possible with an authorised person ie. the Director or General Manager. If a child is at immediate risk, the TWS staff member will report to South Australia Police (SAPOL) on 000. 
2. Following discussions with the authorised person, a decision will be reached about whether a report will be made and the report will be made by the staff person directly.
3. No other staff will be given identifying information about the family unless the authorised person feels that they need to know. 
4. The authorised person may be present while the staff person makes the report if required. Note that an educator or any other person may independently make a report, regardless of whether the authorised person decides to do so.
5. The authorised person or staff person has discretion whether and if so when to notify the family involved that they are making a report. When the suspected abuse 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.
6. TWS and each staff member has 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.
7. As part of the standard procedure, staff, the authorised person, will make careful documentation of concerns and any action taken.

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

TWS will ensure clear observation of child-occupied areas through the following means:

• Inclusion of parent/guardian or primary support person at all times unless there is a compelling reason not to do this
• Where the parent/guardian or primary support person is not present in the room, all doors are kept open and visual and/or at a minimum auditory monitoring must be ensured. 
• Where the above conditions are unable to be met for compelling reasons, an agreement must be written up with the parent that ensures appropriate measures are taken and a strategy is in place (for example real-time video monitoring or recording).

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. 

Date of last review: March 2022