- Date:
- 1 July 2022
What do non-school providers have to do?
Providers must have child safe strategies, policies, and practices, and tailor them to their environment and student cohort.
They must create and maintain a child safe culture, and:
- follow the VRQA guidelines
- have clear policies and procedures, supported by governance and operational arrangements, that address each Standard
- ensure agreements with third-party service providers require them to comply with the Standards.
Ready to get started?
This checklist helps non-school providers comply:
Guidance and evidence requirements for each Standard is also available.
1. Culturally safe environments
Respecting and valuing Aboriginal experiences and identities.
About the Standard
Establish a culturally safe environment in which the diverse and unique identities and experiences of Aboriginal children and young people are respected and valued.
This Standard focuses on acknowledging and respecting Aboriginal culture and the safety and wellbeing of Aboriginal children.
It is important to note that this Standard applies even if you consider there are no Aboriginal children at your provider.
How to comply
A non-school provider must ensure that they:
- develop a policy or statement or revise existing ones (for example a Child Safety and Wellbeing Policy) that:
- commits to a culturally safe environment for Aboriginal children
- includes a no-tolerance approach to racism and measures to identify and confront racism with appropriate consequences
- support Aboriginal children to express and enjoy their cultural rights
- support the participation and inclusion of Aboriginal children and their families
- provide training to staff and volunteers to understand the importance of Aboriginal culture and understand its importance to the wellbeing and safety of Aboriginal children.
Examples of compliance
A non-school provider complying with this Standard may:
- provide opportunities to engage with the local Aboriginal community
- display plaques to acknowledge traditional owners
- instruct students about Aboriginal history and culture
- update existing policies (for example the student code of conduct, student and staff handbooks, bullying and complaints policies) to ensure all instances of racism by students, staff, volunteers or visitors are addressed with appropriate consequences
- place leaders at the front of anti-racist action
- engage with local Aboriginal communities, Aboriginal families or staff to:
- seek advice on how to create a culturally safe environment
- ask for feedback and input into policies, procedures and practices
- identify ways to respect and value Aboriginal culture through teaching and learning
- provide incursions for students
- provide Aboriginal cultural training to staff and volunteers
- use a Welcome to Country or an Acknowledgement of Country
- celebrate NAIDOC week
- fly the Aboriginal and Torres Strait Islander flags.
2. Child safety and wellbeing
Building a strong organisational child safe culture.
About the Standard
Child safety and wellbeing is embedded in organisational leadership, governance and culture.
By building an organisational culture of child safety, non-school providers can help keep children safe.
This Standard seeks to create a culture of child safety through:
- information sharing
- recordkeeping
- governance arrangements
- preventing, identifying and mitigating risks to children.
This is important in an education setting where children will be learning alongside adults.
How to comply
A non-school provider must ensure that they:
- develop a Child Safety and Wellbeing Policy or review an existing child safety policy to ensure compliance with the new Standards
- have a Child Safety Code of Conduct with clear guidelines about behavioural standards and responsibilities of staff, volunteers and visitors in relation to child safety and wellbeing
- follow up on all breaches of the Child Safety Code of Conduct
- develop a risk register or review existing register that identifies and manages child safety risks and the risk of child abuse, and is contextualised to the providers’:
- student cohort, including vulnerable student cohorts (refer to 9. Child safety in physical and online environments)
- online and onsite environments
- offsite activities (for example, excursions, sporting events, workplace training, third-party providers)
- visitors, staff and volunteers
- adult learning environment
- seek parent or guardian consent for each excursion
- provide evidence the governing body reviews the effectiveness of risk management strategies (for example, in agendas or minutes of meetings)
- provide all staff and volunteers (as appropriate to their role) with training that covers information sharing and recordkeeping obligations
- create, collect and store documents relating to child safety incidents.
Examples of compliance
A non-school provider complying with this Standard may:
- publish its Child Safety and Wellbeing Policy and Child Safety Code of Conduct on its website
- ensure leaders promote a culture of child safety and reporting of all incidents
- ensure the governing body understands the Child Safe Standards and has appropriate, oversight of child safety at the provider
- annually review their risk register and risk management strategies for their effectiveness and to identify any new risks
- make sure that staff, and volunteers understand the requirements for:
- child safety information sharing
- recordkeeping.
3. Child and student empowerment
Giving children a voice to speak up when something isn’t right.
About the Standard
Children and young people are empowered about their rights, participate in decisions affecting them and are taken seriously.
Abuse occurs in settings where children feel they can’t speak up. Educating children about their rights and empowering them to speak up helps reduce the risk of abuse. This Standard requires non-school providers to create a culture that:
- informs children about their rights to safety, information and participation
- provides children with access to sexual abuse prevention programs in an age-appropriate way
- values and promotes student participation
- recognises the importance of friendships and peer support
- equips staff and volunteers to identify and act against signs of abuse and harm.
How to comply
A non-school provider must ensure that they:
- provide staff and volunteers with training to recognise and be attuned to signs of harm to children
- provide children with sexual abuse prevention programs and other relevant information in an age-appropriate way
- inform students about their rights including to safety, information and participation
- provide opportunities for students to have a voice in decisions affecting them
- are responsive to children's feedback.
Examples of compliance
A non-school provider complying with this Standard may:
- provide child-appropriate and accessible information to students about:
- what child abuse is
- appropriate adult behaviour
- how they can raise concerns about abuse or make a complaint (ensure these processes and procedures are child friendly)
- any support services (for example counselling, access to youth workers or other services)
- provide information in a way children can understand through:
- welcome packs
- curriculum
- information sessions
- posters
- website
- newsletters
- provide opportunities for students to express their views and participate in decision affecting them by holding forums or providing opportunities for students to provide feedback on policies and procedures or the provider’s practices relating to child safety
- train staff and volunteers to help them understand, recognise and act on signs of child abuse or harm
- ensure the leadership team and staff take student concerns seriously.
A non-school provider can show the importance of friendships and peer support by:
- discussing healthy boundaries for friendships
- offering buddying or mentoring programs for new students
- providing support to children who may feel isolated.
4. Family engagement
Keeping families, carers and communities informed and involved in promoting child safety.
About the Standard
This Standard requires non-school providers to involve families and carers in development of child safety policies and procedures and keep them informed about the providers approach to child safety.
Involving families and carers helps providers create a child safety culture that is contextualised to their student cohort and community. It also helps providers to gain community support for their approach to child safety.
How to comply
A non-school provider must ensure that they:
- develop a policy, statement or document or revise an existing document that includes strategies for engaging with families, carers and community
- seek the input of families and carers in decisions impacting their children
- involve families, carers and communities when developing or reviewing child safety policies and practices
- communicate with families and communities about:
- how to raise concerns about child safety
- the provider’s approach to child safety
- the provider’s operations and governance as it relates to child safety
- take into account the diversity of families, carers, and students.
Examples of compliance
A non-school provider complying with this Standard may:
- run information sessions about its child safety approach, including information about the provider’s operations and governance
- involve families and carers in development and review of policies and procedures, for example through:
- informal meetings
- forums
- surveys
- newsletters or emails
- provide welcome packs to new families and carers containing:
- child safety information
- how to raise concerns
- complaints processes
- provide clear and accessible information to diverse families and carers.
5. Diversity and equity
Supporting children from different backgrounds, characteristics or beliefs.
About the Standard
Equity is upheld and diverse needs of children are respected in policy and practice.
This Standard requires non-school providers to pay particular attention to the needs of vulnerable students. Non-school providers will often have vulnerable student cohorts who may be at greater risk of harm.
Non-school providers must support vulnerable children and make sure that all children feel welcome and supported in policy and practice.
How to comply
A non-school provider must ensure that they:
- make sure all staff and volunteers understand the diverse circumstances of children and how to support and respond to those children
- review existing documents or strategies to meet requirements or develop a new policy or document
- provide support, information and complaints processes for all students that are:
- accessible to children
- culturally safe
- easy to understand
- support and respond to the needs of vulnerable children, including children who are:
- Aboriginal
- from culturally and linguistically diverse backgrounds
- have a disability
- unable to live at home
- lesbian, gay, bisexual, transgender or intersex.
Examples of compliance
A non-school provider complying with this Standard may:
- discuss needs of vulnerable students with families or carers and implement supports or provide access and information about services for those students
- develop complaints processes and procedures that:
- are available in a range of different languages (as appropriate)
- make it easy for students to raise concerns
- are child-centred
- are culturally safe
- involve parents or carers in the process
- consider the support children may need to raise a complaint
- have youth workers or other supports for children, or provide information about where children can access support services
- communicate zero tolerance for discrimination and bullying
- publish diverse images of students in publications.
6. Suitable staff and volunteers
People working with children are suitable and supported to understand child safety and wellbeing.
About the Standard
A child safe culture is built and maintained by leadership, staff and volunteers that understand and value their role in protecting children from harm.
Non-school providers ensure children are safe by only employing staff that are suitable to work with children. Do this by ensuring recruitment, referee checks and pre-employment screening are focused on child safety. Provide staff and volunteers with induction and training about the child safety policies and procedures they must uphold.
How to comply
The minimum standards for non-school provider registration already require providers to maintain registers of staff and volunteers':
- Working with Children clearance or
- Victorian Institute of Teaching registration (Victorian Certificate of Education teachers).
Be clear about staff and volunteers that work with children.
If in doubt about whether staff or a volunteer works with children, assume they do.
Ensure relevant staff and volunteers and members of the governing body receive an induction that includes:
- the Child Safety and Wellbeing Policy
- the Child Safety Code of Conduct
- records management, information sharing and reporting obligations
- policy and procedures for managing complaints and concerns.
Make sure job advertisements have clear statements about:
- the job’s requirements, duties and responsibilities regarding child safety and wellbeing
- the job occupant’s essential or relevant qualifications, experience and attributes in relation to child safety and wellbeing.
Ensure all volunteers working with children have a current Working with Children clearance.
Sight, verify and record the person’s Working with Children clearance or equivalent such as a Victorian Institute of Teaching (VIT) registration.
Ensure there are procedures for ongoing supervision and monitoring of staff and volunteers. This includes evaluating staff for compliance with the Child Safety Code of Conduct and a focus on child safety at performance appraisals.
Examples of compliance
A non-school provider complying with this Standard may:
- develop or review existing recruitment procedures to ensure they focus on child safety and require pre-employment screening and references relating to a person’s suitability to work with children
- maintain a register of Working with Children and Victorian Institute of Teaching registrations and have procedures for maintaining the currency of the register
- provide induction to all new staff, volunteers and members of the governing body, which includes:
- their responsibilities to children
- record keeping, information sharing and their reporting obligations
- develop questions about child safety in job interviews. Plan interview questions which aim to:
- uncover applicant’s understanding of child safety
- any red flags
- screen volunteers that work with children.
7. Complaints processes
Ensure that processes for complaints and concerns are child focused.
About the Standard
This Standard requires non-school providers to have effective processes that:
- support children and young people to raise complaints
- ensure that they can appropriately respond to, and report suspected child abuse.
The complaints policies and procedures must be:
- child focused
- easy to understand
- culturally safe
- accessible.
This means children can understand what to do and who to talk to if anything makes them feel uncomfortable or unsafe. This includes procedures that children can understand and follow if they need to.
Non-school providers must ensure that they:
- take complaints seriously, and respond to them promptly and thoroughly
- co-operate with law enforcement
- meet reporting, privacy and employment law obligations.
How to comply
A non-school provider must ensure that its complaints policy:
- is updated to be child focused, culturally safe, accessible and easy to understand
- specifies the behaviour and procedures staff and volunteers must follow when they:
- receive a complaint
- become aware of a child safety concern
- specifies processes when staff breach policies and procedures including:
- the Child Safety Code of Conduct
- their obligations to act
- describes how children who make a complaint or raise a concern will be supported
- describes how it will act to protect children throughout an investigation
- outlines a timely response to complaints and investigation process
- clearly identifies the roles and responsibilities of leadership, staff and volunteers
- covers all obligations related to:
- recordkeeping
- information sharing
- reporting.
Examples of compliance
A non-school provider complying with this Standard may:
- provide procedures that allow for anonymity
- engage families, carers, students and the provider community when developing its policies and procedures
- design its complaints processes for children, not just adults
- offer information in diverse formats to ensure accessibility for the provider community such as:
- Braille
- assistive technologies
- different languages
- visual aids
- make its complaints policies and procedures available by:
- posting them on a website
- distributing them through the non-provider's newsletter or a handbook
- including them in both student and staff induction resources.
8. Child safety, knowledge, skills and awareness
Building a child safe culture through training and information.
About the Standard
This Standard seeks to ensure staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.
Providers must provide training to staff and volunteers so they can protect children from harm and:
- create child safe environments
- respond to allegations of abuse.
How to comply
Under the previous Standards, non-school providers had to provide child safety training to staff and volunteers. There are new requirements on what the training must cover.
A non-school provider must ensure that their child safety training includes:
- how to build culturally safe environments for children
- information sharing and recordkeeping obligations
- identifying and managing child safety risks
- how to recognise indicators of child harm including harm caused by other children
- how to support and implement the Child Safety and Wellbeing Policy and Child Safety Code of Conduct
- the procedures for responding to complaints and concerns about child abuse
- ensuring staff understand their reporting obligations
- how to respond effectively to issues of child safety and wellbeing and supporting colleagues who disclose harm.
Provide child safety training to volunteers that work with children. This doesn't mean that volunteers receive identical training to staff. Training should be appropriate to the nature and responsibilities of the volunteer’s role.
If in doubt whether a volunteer works with children, assume they do.
Examples of compliance
A non-school provider complying with this Standard may:
- promote continuous learning and provide regular ongoing education and training
- ensure staff build their knowledge and ability to keep children safe
- have and maintain a register of staff and volunteers trained to identify signs of child abuse
- make sure leadership and governing body members:
- model and champion child safety
- receive child safety training
- review and revise existing child safety training to ensure that it meets requirements.
9. Child safety in physical and online environments
Helping children have safer and more positive experiences online and in person.
About the Standard
This Standard ensures physical and online environments promote safety and wellbeing while minimising the opportunity for children to be harmed.
A non-school provider must identify and mitigate risks to children in in their online and physical environments. It is important to think about risks created by the non-school provider's:
- structure
- culture
- activities
- physical and online environments
- third-party arrangements.
Non-school providers must identify and reduce risks, and address new risks as they arise, in both physical and online environments. They must do this without impacting a child's:
- right to privacy
- access to information
- social connections
- learning opportunities.
Child safety policies, procedures and practices must minimise the risk of harm.
How to comply
A non-school provider must:
- develop a risk management plan or risk register that identifies and manages risks of harm in both physical and online environments
- ensure that third-party procurement policies include child safety requirements
- set expectations for how staff and students interact online by:
- developing or endorsing a policy or statement on online conduct and safety
- reviewing or revising an existing Child Safety and Wellbeing Policy or Child Safety Code of Conduct
- reviewing its internet use policy for students and staff.
Examples of compliance
A non-school provider complying with this Standard may:
- use a risk management plan or risk register to manage risk in physical spaces, for example:
- blocked off or out of sight spaces
- rooms with lockable doors
- children learning alongside adults
- offsite locations such as camps, sporting events, workplaces, excursions or home stays
- promote a culture of online safety by:
- monitoring online interactions
- running information sessions on eSafety
- installing filtering software on provider-based devices
- publishing its internet use policy
- undertake child safety due diligence when engaging third parties to:
- make child safety a feature in written agreements
- nominate a staff member responsible for collecting third-party compliance information
- be clear about actions if suppliers fail to meet child safety requirements.
10. Implementation of child safety practices
Checking regularly that policies and procedures are up to date.
About the Standard
This Standard requires child safety policies and procedures to be continuously reviewed and improved. Being a child safe organisation requires continuous improvement and capability building. Child safe organisations:
- have an open and transparent culture
- learn from child safety incidents
- put the interests of children first.
Non-school providers must regularly review, evaluate and improve policies and procedures. They must also:
- analyse complaints, concerns and safety incidents to:
- identify causes and systemic failures
- inform continuous improvement
- report on the findings of relevant reviews of child safe practices to staff and volunteers, families, carers, children and the community.
How to comply
A non-school provider must:
- regularly review, evaluate and improve its child safety practices
- identify causes or system failures by analysing:
- complaints
- concerns
- safety incidents
- ensure continuous improvement in child safety policies, procedures and practices (for example, by implementing recommendations arising out of review of practices or analysis of causes or system failures)
- report outcomes of reviews to staff, volunteers, provider community, families and students
- ensure policies and procedures are regularly reviewed.
Examples of compliance
A non-school provider complying with this Standard may:
- regularly review its child safety and wellbeing policies and procedures
- make sure policies and procedures record a date of approval
- commit to reviewing a policy or procedure prior to its date of expiry
- remember to consult and engage with students, families, carers and the provider community on relevant findings.
11. Documentation of child safety practices
Putting all the requirements of the Standards into action.
About the Standard
This Standard requires non-school providers to apply all the Child Safe Standards and document how they do so. Non-school providers must:
- make policies and procedures easy to understand
- develop policies and procedures through stakeholder consultation and best practice models
- make sure organisational leaders champion and model compliance with policies and procedures.
Non-school providers must have all the required policies and procedures to support child safety.
How to comply
A non-school provider must:
- have policies and procedures that:
- address all the Standards
- are easy to understand
- develop policies and procedures using best practice professional development, research or consultation
- ensure staff and volunteers understand and implement child safety practices
- nominate champions or advocates who promote the Standards and compliance.
Examples of compliance
A non-school provider complying with this Standard may show that leaders 'champion and model' procedures in a variety of ways.
Particularly if the provider's child safety culture is prominent in:
- public-facing policies, procedures and practices
- communications to parents, carers, students and the provider community
- visual displays
- governing body oversight.
A non-school provider may also have implemented child safety through:
- policies and procedures that are part of a comprehensive working system
- a monitoring or performance framework
- continuous improvement practices
- communication strategies and practices.