This article covers information in the white paper Non-Financial Governance Reporting for Non-Government Schools, prepared by CompliSpace Pty Ltd. Please refer to this document for additional information.
Financial, enrolment and education performance reports received by non-government school boards paint a helpful picture of the school’s performance, assisting boards with making key strategic decisions by providing useful data on outcomes.
However, these reports only tell a partial story of the overall performance of a school. In many ways, it is measurable non-financial information that enhances a board’s decision-making ability, ensuring they are able to guide the school towards achieving core strategic goals and objectives.
Measurable non-financial information can include:
To produce board reports on the risk management of a school, a school should have developed a Risk Management Program which enables reports to be generated on macro operation risks and key strategic risks, but that is also capable of producing specific reports on topics such as reputational risks.
It is important for all boards to recognise that risk management is a continuous and dynamic process. Reports are often provided on a quarterly basis with movements in risk ratings highlighted. It is common for risk management to be a standing item on a board’s agenda, providing board members with an opportunity to raise any particular risk concern that they may have outside formal reporting periods.
Producing board reports on a school’s compliance should start with ensuring a Compliance Program is in place. With the myriad of laws and regulations that apply to schools, most boards take a ‘risk-based approach’ to compliance, meaning that they focus on those compliance obligations that are likely to present the greatest risk to the school in the event of a breach.
This means that a Compliance Program needs to be able to monitor and report on various obligations, including those arising under child protection, workplace safety, school registration and privacy.
At a minimum, a school board should receive a quarterly compliance report which highlights any:
- significant upcoming compliance obligations and/or changes to registration standards
- legal and regulatory compliance breaches
- complaints received with respect to a particular compliance area
- corrective actions needed.
Boards could also request positive confirmations from members of the leadership team as to the school’s compliance with key legal and regulatory obligations on an annual cycle, by requiring Attestation Reports to be compiled on particular topics. For example, schools with boarding facilities should consider an Annual Boarding Compliance Attestation Report based on the new Australian Boarding Standard AS 5725:2015.
School boards should develop processes to ensure adequate documented policies and procedures are in place, and that they are maintained up-to-date with key legal changes and best practices.
Boards should also ensure systems are in place for document ‘version control’ so that, when the need arises, copies of board policies at a point in time in the past can be retrieved.
Complaints handling programs generally refer to complaints received from key stakeholders such as students, parents, members of the wider school community (e.g. former students) and members of the local community. Staff complaints are generally referred to as ‘internal grievances’ and are managed as part of a school’s human resources function.
Without a properly structured Complaints Handling Program, many complaints may not be captured effectively, and therefore cannot be reported upon.
A Complaints Handling Report should be provided to the board at least quarterly, summarising complaints and analysing any trends that may indicate systemic issues arising within the school community.
School staff members are often described simultaneously as a school’s biggest asset and biggest risk. It is therefore very important for a school board to ensure that its school is complying with its workplace relations obligations. Core workplace relationships obligations are often found in awards or enterprise agreements. There is also a myriad of laws that deal with staff-related issues such as those dealing the discrimination and equal opportunity employment.
It is also important that a school board monitor other key data relating to staff management such as:
- relief teacher employment
- internal grievances
- remuneration against industry benchmarks
- training and professional development
- performance appraisals
- satisfaction levels.
Workplace Health and Safety
The harmonised workplace health and safety (WHS) laws require school board members and senior executive managers (such as the Principal and Business Manager) to undertake due diligence to ensure that a school complies with legislative obligations. Similar obligations apply under OHS and OSH laws in Victoria and WA respectively.
School boards need to ensure that they receive robust reporting of measurable data with respect to WHS issues.
While WHS will often be a standing agenda item, the presentation of statistical information should be undertaken at least quarterly with historical trend analysis. Common measurable data includes identified hazards, changes in hazard risk ratings, corrective actions and safety audits.
Many schools undertake independent safety audits every 2-3 years through which the school’s safety management systems are reviewed against the Australian Standards for WHS Management Systems and WHS Audits.
Student Safety and Welfare
It is important to clearly distinguish between ‘workplace safety’ and ‘student safety’, particularly for board reporting purposes. A school’s student duty of care obligation requires all schools and teachers to take reasonable steps to protect students from any injury that is reasonably foreseeable, and is separate to obligations which arise under WHS laws.
Common safety hazards that relate to student safety rather than workplace safety include those relating to student health management (e.g. anaphylaxis, asthma), student welfare (e.g. counselling services) and behaviour (e.g. student bullying).
To uphold student safety, boards should ensure that they receive robust reporting of measurable data with respect to student safety issues, including:
- identified student safety hazards and changes in hazard risk ratings
- bullying and other high-risk behavioural incidents
- student injuries and near misses
- staff training (especially around high risk areas such as first aid and student health management)
- safety audits and corrective actions
- excursions undertaken
- insurance claims and premium rate changes.
Child protection laws vary between states and territories, however, most jurisdictions have legal obligations with respect to mandatory reporting of child abuse and working with children checks.
A key recommendation of the Final Report of the Royal Commission into Institutional Responses to Child Sexual Abuse is that institutions including schools adopt the Royal Commission’s 10 Child Safe Standards. A board looking to implement the Child Safe Standards should undertake certain initiatives which include making child safety a standard meeting agenda item, as well as appointing a Child Safe Trustee or ‘Children’s Champion’ to the board. It is also now becoming more frequent to see school boards requesting their executive to provide an Annual Child Protection Compliance Attestation Report.
While the focus of the Royal Commission has been on 'institutional abuse' it is important to remember that the vast majority of child protection incidents that a school will consider will relate to abuse of children outside the school environment.
School boards should ensure that they receive robust reporting of measurable data with respect to child protection issues. Such data would include changes in the school’s child protection policy and child protection risks assessments.
To ensure they are accounting for their own performance and the efficacy of their decision-making, school boards should also be looking inward at internal board performance metrics. Data should be collected with respect to:
- progress against strategic goals and objectives
- board performance evaluation
- school principal performance evaluation
- succession planning
- conflicts of interest
- related party transactions.
Other Key Reporting Areas
Measurable non-financial information can come from various sources and varies depending on the nature of each school, including the current level of governance, risk, compliance and policy (GRC&P) management maturity within the school.
There are various other key reporting areas which should form part of the data considered by the school board on a regular basis, including:
- student attendance
- information and communications technology (ICT), including security and internet usage
- key stakeholder engagement, including students, parents, former students and members of the community
- property and facilities management, including the adequacy of facilities and equipment
- special projects
- insurance, including changes in coverage and insurance claims
- legal or regulatory action against the school.
Each board member needs to have a good understanding of how their schools’ policies and procedures are structured, and their overall reporting capabilities. This knowledge will allow board members to receive high-level reporting and be confident that they can gain detailed information if they need to.
School boards should undertake a review of their current reporting and take a risk-based approach to prioritising any additional non-financial information they feel will enhance their decision-making ability. Non-financial reports can clearly enhance the decision-making ability of school boards, improving the ability of schools to achieve their strategic goals and objectives.