Just as education has progressed immensely, so too have boarding houses and the facilities associated with them. However, while there has been an ongoing trend of schools trying to improve their approach to safety and child protection, boarding schools have been identified as being among the highest risk of any educational environment in terms of their cumulative risk of child sexual abuse. With this in mind, there is a clear necessity for boarding schools to implement an effective framework for risk management. A recent CompliSpace Webinar discussed how boarding schools should approach risk management.
Of the 183 boarding schools operating around Australia, 130 people registered to attend the Webinar on Thursday 10 August: The Boarding School Enigma - Balancing Enterprise Risk Management and Student Care, presented by CompliSpace Managing Director David Griffiths. A recording of the Webinar is accessible here.
The Webinar occurred in the days leading up to the Australian Boarding Schools Association’s Leaders Conference, which was held over August 13-14. The Webinar focused specifically on:
- following an enterprise risk methodology through Risk Management Standard ISO 31000;
- identification of boarding risks and situating them within a common risk language;
- providing a framework for boarding risks and outlining the Boarding Standard; and
- boarding risk management in the particular context of child protection and excursion.
For more information about the Boarding Standard, see our briefing paper here: AS 5725:2015 Boarding Standard for Australian schools and residences.
The feedback received from the Webinar indicated that schools remain uncertain on the extent of their legal and regulatory obligations, and the most effective ways to manage boarding risks. A summary of the questions asked, with responses, is given below.
1. How should schools manage the use of boarding facilities by students/staff from other schools or for commercial purposes?
There are many situations in which a school’s boarding facilities may be used by third parties, such as for school holiday sports competitions and as part of an excursion. Refer to our previous School Governance article for further discussion on venue hire scenarios.
Regardless of the particular context in which boarding facilities are used by third parties, a school has an obligation under WHS/OHS/OSH laws to consult, cooperate and coordinate with schools and other third parties organising events to communicate safety systems. An example would be deciding who will have responsibility for the supervision of students from other schools during their activities.
It is also crucial to conduct due diligence on the third party to ensure they have fulfilled their own safety obligations and have a comprehensive health and safety system in place. Examples of due diligence queries would include the expertise/experience of staff and student healthcare information.
2. What is the best way to achieve effective records management in the context of boarding, including knowing how long to keep records?
School records which constitute personal information (including sensitive information and health information in relation to students) are covered by the Privacy Act 1988 (Cth), which prescribes many processes and requirements for the handling and disclosure of personal information. However, it does not prescribe particular retention periods for schools.
Some guidance on the time period for record retention is given by state and territory record-keeping guidelines for government schools, which non-government schools could consider adopting. Refer to our previous School Governance article for more information on record keeping in schools.
However, there are clear difficulties regarding records management in terms of the sensitivity of information; a clear example would be records associated with historical child abuse complaints. By taking a risk-based approach to records management, boarding schools should consider keeping their records indefinitely in order to mitigate against any scenario in which its trust and accountability may be questioned.
3. What are the differences between logistical risks in a dispersed model of boarding school buildings, versus the risks associated with a single centralised facility?
In a centralised boarding facility, students eat, sleep, recreate, and study for 18 hours a day in a single relatively confined area, which provides clear benefits in terms of replication of effort and replication of school systems. However, in boarding schools with a dispersed model, each boarding house will often have its own distinct culture.
In both logistical models, risk cascades from the top, overseen by the head of the boarding house. This means that assurance reporting will also be different between a centralised and dispersed model, as the distinct cultures of a dispersed board school will invariably cause different levels of institutional risks.
This is not to say that dispersed models should be avoided; risk management should be standardised as appropriate, without losing the clear benefits of a varied organisational culture. Refer to a previous School Governance article written by Dr Alec O’Connell for more information on the importance of school culture.
4. Where do boarding operations fit in an overall risk matrix in terms of all school activities?
Boarding risks are but one of a myriad of internal, stakeholder and external macro risk categories which need to all be considered together in order for a school to manage its risks consistently and cohesively. The likelihood and consequence of a boarding risk will ultimately depend upon the school’s overall risk management process and how it rates other kinds of risks, for example student safety risks in the playground.
Invariably, a school’s policies and procedures for boarding should be well integrated in their overall approach to policy management, however this will depend upon the school’s sophistication and maturity in terms of its risk and compliance infrastructure.
As an example, the manner in which a school manages boarding child protection risks cannot be considered in isolation, instead being managed consistently with the school’s broader child protection policies and procedures. Refer to our previous School Governance article for more information on the risks of child abuse in boarding schools.