CS2 - Risk Management for Child Safety

Purpose of this Guideline

To provide guidance for the planning of child safety policy, practices and procedures based on sound risk management practices and objectives.

Description

All children and young people are vulnerable to abuse or neglect.

Aquatic facilities should put in place systems and processes to help prevent risk, abuse or neglect to children and young people.

Risk analysis provides a foundation for systems and processes that safeguard children and young people within an organisation.

While it is not possible to eliminate every child safety risk, aquatic facilities should treat and manage child safety with a focus on preventing and reducing child abuse or neglect.

The owner or operator of an aquatic facility should conduct a Child Safety Risk Assessment in accordance with the Guidelines for Safe Pool Operations – Risk Management section (or an alternative appropriate standard, such as ISO 31000:2018 Guidelines for risk management) to identify the hazards and risks of failing to safeguard and protect children and young people at the facility, or in a program or activity associated with the aquatic facility.

When conducting a risk assessment for child safety at an aquatic facility, an owner or operator should consider all relevant matters including:

• The specific context of the service delivery
• The physical environment (more detailed below)
• The nature of interactions between children (including young people) and adults
• The nature of interactions between children young people
  The vulnerability of children and young people in each environment, program or activity
• Options available to engage with children and young people and their families about child safety to build confidence and self-esteem in vulnerable children
• The risks related to employees, volunteers, contractors and visitors
• The risks to the organisation that would eventuate should a child safety incident occur at the facility, or in one of its programs or activities
• The number, characteristics and behaviour of users of the aquatic facility at different times and within different activities
• The type and frequency of activities in the aquatic environment at the aquatic facility

An aquatic facility should analyse and evaluate these risks for different programs and / or services as risks and the risk treatment measures may vary significantly throughout different parts of a facility or through different programs and activities.

Type and frequency of activities

Certain activities and programs carry greater opportunity for child safety risks to occur and may need additional treatment measures to safeguard children and young people. (I.e., an adult yoga class carries little risk of an incident by comparison to a children’s swimming lesson.)

For each activity, program and/or area of the facility, consider the following:

• Time of activity
• Duration of activity (i.e. hour, half day, full day)
• Type of activity (swim lesson, carnival, sports, etc.)
• Locations within the aquatic facility which will be used for the activity
• Supervision arrangements of staff delivering the activity (public swimming lesson supported by backup supervision from lifeguards and duty managers, vs private swimming lesson without backup supervision)
• The preventative measures taken to reduce the likelihood of incidents (pre-employment checks, child safety training and induction, regular spot checks of procedure adherence, proactive supervision of personnel and an embedded child safe culture)

Types of activities may be structured or unstructured and may include, but not limited to:

• Activities that occur behind closed doors, such as first aid treatment or personal or medical care
• Activities that require changerooms to be used
• Any underwater aquatic activities
• Aquatic exercise activities
• Ball games
• Birthday parties and celebrations
• Floating play equipment or inflatable play equipment
• Hire of the facilities
• In water filming
• Introduction and use of temporary amusement equipment
• Lifesaving activities
• Running, jumping and diving
• School carnivals, excursions and activity days
• Sporting competitions and events (i.e. water polo)

In assessing risk consider the areas where activities occur, such as:

• Distance between program areas, other work areas and facilities and the response times for Lifeguards and other staff
• The location of other areas requiring supervision (i.e. change rooms, isolated areas)
• CCTV coverage of relevant locations

The owner or operator of the aquatic facility should document the risk treatment measures which are intended to reduce the likelihood of child abuse in the risk assessment including:

• Information collected about employees, volunteers and contractors prior to and/or during employment relating to child safety, such as:
• Proof of personal identity
• Information about professional or industry qualifications
• The person’s history of working with children
• References that address the suitability of a job where there is interaction with children
• The training provided to employees, volunteers and contractors relating to child safety, including how to:
  • Identify and mitigate child safety risks
  • Protect a child or young person’s right to privacy
  • Relevant Codes of Conduct (policies and procedures)
  • Relevant facility design arrangements
  • Relevant supervision arrangements and procedures

Aquatic facilities should review and monitor risks and regularly review their risk assessment.

An aquatic facility owner or operator should communicate and consult regularly with internal and external stakeholders as part of the risk management process.

Safeguarding employees, volunteers and contractors under the age of 18

The owner or operator of an aquatic facility should also ensure the safeguarding of employees or volunteers under the age of 18 years. This may include ensuring appropriate arrangements are in place in the context of:

• Travel and accommodation (if applicable)
• Whether young employees can be left alone altogether or alone with a single adult staff member, for example on late or early shifts
• Ensuring adequate checks and balances are in place for recruitment of employees under the age of 18 who may be ineligible for a Working with Children Check or its equivalent.

Parent and carer support arrangements

To mitigate some risk, it may be appropriate to recruit the support of parents and / or carers. For example:

• Having a parent or carer present in the room while staff deliver first aid
• Being available to take children to the toilet should the child need to go during a swim lesson or program activity

Contract Management Arrangements

If the operator of an aquatic facility is a third party contractor who has been engaged by the owner of the facility, who in many instances will be a local government, the operator is likely to be bound by the requirements of that local Council. The local council’s procurement policies about engaging third party contractors is likely to set out processes to protect children from risks of child abuse and harm, such as requiring all contractor’s compliance with the organisation’s Code of Conduct and Child Safety and Wellbeing Policy. Third party contractors should therefore be familiar with the procurement requirements, and any child safety requirements of the Council upon the contractor.

REFERENCES

• Guidelines for Safe Pool Operations  - Risk Management
• National Principles for Child Safe Organisations (2018) Child Safe Organisations National Principles
• Victorian Government, Department of Education, Child Safety Risk Management
• Risk Management and the Child Safe Standards Part 1 Responding to risk