CS1 - Develop a Child Safety Policy

Issue Date	Effective Date	Version
14/12/2023	01/07/2024	1.0

Purpose of this Guideline

To provide guidance to owners or operators of aquatic facilities in the development and implementation of a Child Safety Policy.

Description

The owner or operator of an aquatic facility should develop a child safety policy to keep children and young people safe whilst in the facility or participating in any programs and activities associated with the facility.

Policy Contents

Statement of Commitment

The policy should include a statement of commitment that should serve as a public statement of the organisation’s commitment to child safety. The statement of commitment should be shared and communicated in the following ways:

Displayed in a prominent location within the centre
Communicated to patrons through newsletters and other direct mail
Within brochures
Within staff induction packs
Displayed in staff rooms
Shared regularly within staff meetings and staff communications
The aquatic facility owner or operator’s obligation to safeguard children and young people at all times within the facility and in its programs or activities
The obligation to provide a safe workplace for employees, volunteers, contractors and visitors
Ensuring that the facility and its programs and activities are welcoming, safe and inclusive to children, young people and their carers
The owner or operator’s obligations to comply with relevant regulatory instruments
The owner or operator’s expectations that employee, volunteer and contractor behaviour is appropriate at all times

While larger organisations and those that have a higher level of responsibility for children will develop a locally developed statement that seeks to specifically address the organisations approach and specific references to other organisational policies, and reference specific services, smaller organisations may seek to utilise a template.

The following template may serve as a basis for an aquatic facility’s development of a statement of commitment:

[INSERT NAME OF AQUATIC FACILITY] is committed to child safety.

We want children to be safe, happy and empowered.

We support and respect all children, as well as our staff and volunteers.

We are committed to the safety, participation and empowerment of all children.

We have zero tolerance of child abuse, and all allegations and safety concerns will be treated very seriously and consistently with our robust policies and procedures.

We have legal and moral obligations to contact authorities when we are worried about a child’s safety, which we follow rigorously.

[INSERT NAME OF AQUATIC FACILITY] is committed to preventing child abuse and identifying risks early, and removing and reducing these risks.

[INSERT NAME OF AQUATIC FACILITY] has robust human resources and recruitment practices to reduce the risk of child abuse by new and existing board members, staff and volunteers.

[INSERT NAME OF AQUATIC FACILITY] is committed to regularly training and educating our board members, staff and volunteers on child abuse risks.

We are committed to the cultural safety of Aboriginal children, the cultural safety of children from culturally and/or linguistically diverse backgrounds, and to providing a safe environment for children with a disability.

A statement of commitment if developed should consider stated positions on the following:

The aquatic facility owner or operator’s obligation to safeguard children and young people at all times within the facility and in its programs or activities
The obligation to provide a safe workplace for employees, volunteers, contractors and visitors
Ensuring that the facility and its programs and activities are welcoming, safe and inclusive to children, young people and their carers
The owner or operator’s obligations to comply with relevant regulatory instruments
The owner or operator’s expectations that employee, volunteer and contractor behaviour is appropriate at all times

Child Safety Policy

Policy Scope

The policy should include an introductory section. The introductory section should include information relating to the scope of the policy. The scope should include:

Who the policy applies to; such as employees, volunteers, contractors and/or visitors to the facility, programs or activities
The name of the aquatic facility and the owner and / or operators
The location of the facility

The scope should be sufficiently broad so the policy can be applied to a wide range of situations where people interact with children and young people.

In instances in which the aquatic facility is an operating unit of a broader organisation such as a local Council, consideration needs to be given as to whether an all encompassing organisational policy provides adequate coverage for the clientele, and programs and services provided at the aquatic facility, and if not, then ancillary policy and procedures should be developed for the aquatic facility.

Authority and Governance

The policy should include who has authorised the document and who is responsible for its implementation and for organisational compliance. This information should include:

Preparation details, including the date of preparation and other terms of reference
Authorisation details (person(s) responsible)
Document control information

Legislative and Regulatory Requirements

The policy should outline how policies and procedures support compliance with the 10 National Principles for Child Safe Organisations and/or state / territory regulations, industry standards and guidelines.

The introductory section of the policy should contain a list of references and compliance standards used in the compilation of the policy.

Statement of Activities and Associated Risks

The owner or operator of the aquatic facility should describe the child safety risks identified as having a significant impact and / or that require some form of Operational Procedure.

Glossary, Abbreviations and Definitions

A glossary, abbreviations or definitions section may be included. Typically, these sections explain key terminology and / or any abbreviations used in the policy.

Roles and Responsibilities

The policy should establish roles and responsibilities for staff and management.

Roles and responsibilities should be designed to suit the needs of each aquatic facility owner or operator and be reflected in any and all job descriptions provided to employees and volunteers.

Example roles and responsibilities may be displayed in a table, such as:

Role	Responsibilities
Chief Executive Officer	Ultimate responsibility to ensure regulatory and legal obligations are met Protect and maintain organisation’s reputation and standing Ensure organisation operates in line with community standards. Meet the expectations of shareholders, Council, board of directors or other governing parties
Senior Management	Develop, monitor and review appropriate policy frameworks Address any changes to legislation or regulation and ensure they are adhered to Plan and implement resources for policies and procedures to be delivered Resource the delivery of policy frameworks
Facility Managers	Ensure local practices and procedures reflect organisational policy Ensure a record of all recruitment, induction, onboarding and in-service training is kept on site, including valid WWCC or equivalents Ensure periodical / in-service training for safeguarding children and young people for all facility staff, volunteers and contractors (for example online training) Ensure risk management reflects operational realities and contexts and is regularly reviewed Ensure policies and procedures are upheld by contractors and volunteers Take all reasonable steps to protect and safeguard children and young people Role model appropriate behaviours and conduct at all times and take allegations seriously Ensure appropriate investigation procedures are followed
Child Safety Officer	Provide ongoing education and awareness training to the facility’s workforce Develop child safe messages for the aquatic facility and its programs and services Contribute to or develop local policies, procedures and resources which strengthen the organisation’s approach to child safety management Provide information and support to decision-makers and stakeholders Support partners and stakeholders to work collaboratively with key services to ensure child safe approaches are culturally safe, disability and inclusion aware and appropriate for children and young people from diverse backgrounds Provide a point of contact for investigations, reporting and notifications
Team Leaders	Build and promote child safe team culture reflective of the organisational vision Role model appropriate behaviours and conduct at all times and take allegations seriously Have an in depth knowledge of policies and procedures Report and document incidents and allegations to management Obtain and maintain a valid WWCC (or the equivalent required) and ensure team members do also Ensure team members are trained and onboarded in line with organisational policies Take all reasonable steps to protect and safeguard children and young people
Employees and Volunteers	Build and promote a local culture reflective of the organisation’s vision Represent appropriate behaviours and conduct at all times Report any breaches of child safe policy, procedure or codes of conduct to management Obtain and maintain a valid WWCC (or the equivalent required) Take all reasonable steps to protect and safeguard children and young people Participate in education and training programs as required by the employer
Contractors and/or suppliers	Work within the policies and procedures of the organisation Sign in and out of the facility when attending and leaving Avoid situations where you may be on contact with children or young people without other adults present Provide work orders to the facility management and have these signed upon completion and inspection of work Participate in any training or induction processes required by the facility

Child Safety Officer

Through the policy development and risk management process, the organisation may consider the feasibility of introducing a dedicated Child Safety Officer in line with the Royal Commission into Institutional Responses to Child Sexual Abuse Final Report Recommendations.

A Child Safety Officer can be a current employee, or it may be a new position made available. This role can:

Provide ongoing education and awareness training to the facility’s workforce
Develop child safe messages for the aquatic facility and its programs and services
Contribute to or develop local policies, procedures and resources which strengthen the organisation’s approach to child safety management
Provide information and support to decision-makers and stakeholders
Support partners and stakeholders to work collaboratively with key services to ensure child safe approaches are culturally safe, disability and inclusion aware and appropriate for children and young people from diverse backgrounds
Provide a point of contact for investigations, reporting and notifications

Code of Conduct for Child Safety

The policy should include a Code of Conduct for Child Safety.

The Code of Conduct should be applicable to all employees, volunteers and third parties (contractors and visitors).

The Code of Conduct should outline the principles and standards that all employees, volunteers and third parties (visitors etc) are expected to abide by when employed, volunteering in association with, contracted to or visiting the facility, its programs and activities.

See CS3 for more information on Code of Conduct.

Other Requirements

The Child Safe Policy should make provisions for other matters such as, but not limited to, how the aquatic facility or organisation will:

Establish a culturally safe environment in which the diverse and unique identities and experiences of Aboriginal children are respected and valued
Emphasise the importance of family and community involvement and describes ways this involvement can occur including providing the opportunity for input into the development and review of the organisation’s child safe policy and practices
Approach policy breaches
Report on child safety matters
Keep records relating to child safety
Manage risk relating to child safety and how child safety integrates with the broader risk management policy framework of the organisation

Communication (internal)

An aquatic facility owner or operator should communicate its policy and commitment to child safety to internal parties such as employees, volunteers, management, contractors, and consultants.

A variety of methods should be used to ensure appropriate communication is provided and received by applicable personnel. These may include:

Recruitment / job advertisements for new employees
Employee onboarding / induction information
Newsletters
Noticeboards
Intranets and other online working spaces / platforms (including applicable social media)
Hard copy communication such as memos, communication diaries, brochures and / or factsheets
Briefings at employee meetings (including occupational health and safety representative meetings)
Consultation with relevant stakeholder groups (including employee unions and human resources departments)

Communication (external)

An aquatic facility owner or operator should communicate its policies and commitments to child safety to external parties such as visitors and contractors and also ensure that the information is accessible by families and the community. The information should also include details on the organisations governance, complaints management and the opportunities for input by families and the community into decision making. A variety of communication methods may include:

Signage at entries / exits to the facility(s)
Signage at important points of the facility(s)
Include key information in contracts and enrolment forms for contractors, facility hire, memberships, programs and activities.
Any online platforms – such as websites and / or social media platforms acting as a main communication source for the facility with its stakeholders
Hard copy communication; such as
- newsletters (regular or ad-hoc program newsletters)
- brochures and / or factsheets - available at regular and consistent areas of information at the facility – such as reception or notice boards

Communication of the policy should also be made to children and young people participating in and attending where appropriate for their age and development.

Access to information, supports and complaints processes should be provided and communicated in ways that are safe, accessible and easy to understand.

Policy Breaches

Breaches of the Child Safety Policy should attract appropriate investigation and/or disciplinary measures. This should be outlined in the policy and in alignment with state and territory laws and organisational policies and procedures.

If an individual has reasonable belief that a breach of the policy has occurred, initial action should be:

Act in the best interest of the child or young person
Act promptly to ensure the safety of the child or young person
Act in a manner that provides privacy to the situation and the child or young person

Procedures and Practices

An aquatic facility owner or operator should document all child safety-related procedures, which may be referenced within the child safety policy (refer to 1.7) or documented within a separate procedures and practices manual, or another appropriate documentation system available to staff, volunteers, contractors and management.

The procedures should consider and reference how they assist the organisation in addressing the 10 National Child Safe Principles.

Consultation and involvement of stakeholders in the development, review and implementation of procedures is recommended.

The procedures should be documented, easily understood and address the organisation’s approaches to the following:

Risk management
Complaints management
Internal and external reporting
Engagement and communications with families and communities
Policy and procedure reviews and improvement process
Online and physical environments
Staff and volunteers induction and training
Staff and volunteers recruitment and screening
Record keeping
Code of Conduct development and review
Policy breaches

Organisational leaders should champion and model compliance with policies and procedures

REFERENCES

Staying Safe

Keep your family safe, no matter where you are