How to Create a Compliance Culture that Protects Students, Staff and School Reputation

Published
22 August 2019

During the last decade, there has been an inordinate amount of research conducted into what determines culture in organisations and, in more recent times, what determines culture in schools.

Dr Alec O’Connell, Headmaster of Scotch College, Western Australia, in a School Governance article noted that “Culture is the habit of being pleased with the best and knowing why. It is a way of saying ‘this is how things are done around here’. Focusing on your culture provides purpose, provides accountability for exceeding performance and models the organisation's core values.”

 

The Importance of Culture

Interestingly, culture is often described by students, parents and teachers as intangible. That being said a visitor or a prospective parent can walk into a school and know immediately whether they want to be there or not. The same applies to the students and the staff. They will tell you that they can ‘feel’ the culture.

That culture that they ‘feel’ is the result of numerous elements that come together, including the school’s academic, physical, social and emotional environment. People learn to see and do things at an unconscious level and their experiences, values and cultural background lead them to see and do things in a certain way. Culture is generally not conscious to the members within the community.

But culture is conscious to school leadership and effective school leaders realise that they can influence and cultivate a positive culture in their school.

Why does this matter? Because culture directly affects how successful students are. It also affects how safe they are.

This article explores how to achieve a culture that protects students, staff and your school reputation - and that your staff will embrace.

 

Policies are a Great Starting Point

Documented policies are a key driver for cultural change. In fact, the only reason that a policy is usually developed is to try and establish desired behaviour outcomes.  The reality however is that policies don’t change culture to make schools compliant. People do.

From a compliance perspective simply having a set of current policies in place does not mean a school is meeting its regulatory obligations. Effective compliance can only be achieved when policies are embedded into the culture of the school, so that staff understand what they are required to do and then actually do it. It is essentially a move from the conscious to the unconscious. The behaviours become embedded and policy and practice become as one.

Just imagine that you have just received the update for your mobile phone, and you are required to tick the box that says “I have read and agree to the new Terms and Conditions”. How many people simply tick the box to get on with the update? Most of us, let’s admit it. How many actually READ all of the terms and conditions? We have been culturally ‘trained’ to expect that there will be few changes to our current contracts and so, out of urgency or expediency, we tick the box and move on.

The same can apply to schools that release policies and request staff to tick a box or sign off that they have read them. It is easy to tick and say “yes” because, for most staff, there are far more pressing matters to attend to.

 

The Royal Commission Puts a Spotlight on the Importance of a Child Safe Culture

The findings from the Royal Commission into Institutional Responses to Child Sexual Abuse (Royal Commission) made it clear that while having documented policies is critical, policies by themselves do not create a child safe culture which, of course, is the desired outcome in organisations providing child services.

For years, the team at CompliSpace has worked with schools to help them establish and maintain policies and procedures that assist in the development of a compliance and safety culture. We have however always known that having an up-to-date suite of documented policies and procedures is only the beginning of the process.

To successfully create a positive culture within schools, it is not enough for staff to only know what is required – they also need to understand, do and prove that they do what’s required. They need to engage with and enact the requirements of the policies in order to embed their behaviours into what is the ‘norm’ (i.e. the culture).  In other words, just having policies and procedures is not enough.

As a company CompliSpace’s vision is to “simplify risk, compliance and policy management so that organisations (including schools) can focus on what they do best”. For schools that means focusing on teaching, student learning and keeping students safe.

To enable this vision, we created a framework to help affect cultural change in schools. The framework is called ‘P-LAR’ and the result is called ‘Policy to Culture’.

Last week, CompliSpace was honoured as one of Australia and New Zealand’s Most Innovative Companies for 2019, when we were named in the 2019 AFR and BOSS Magazine Most Innovative Companies List for the P-LAR framework that assists our clients to embark on the ‘Policy to Culture’ journey through the delivery of risk and compliance content through enabling technology platforms.

 

What is P-LAR and How Does it Deliver ‘Policy to Culture’ for Schools?

Policy to Culture is all about bringing policies to life within a school. This involves transforming words on a page to understanding, action and ownership.

The P-LAR framework has four essential elements that work together to help our clients’ journey from policy to culture:

 (P) Policy: KNOW what’s required. We provide key policies tailored to an organisation’s circumstances that cover the who, how, when, what and why of each policy.

(L) Learning: UNDERSTAND what’s required. We provide associated learning and development to help staff understand the policies.

(A) Assurance: DO what’s required. We provide an assurance workflow management tool and content to ensure that key elements of an organisation’s policies ‘come to life’.

(R) Reporting: PROVE (and improve) compliance. The final part of the process is to provide high-quality reporting, for the board, executive and at an operational level. Reporting enables enhanced decision-making and sets the platform for continuous improvement within a school.

 

How Does P-LAR Work in Practice?

In the school sector CompliSpace delivers a suite of 14 content modules including enterprise risk management, school registration, child protecton, student care and welfare, workplace safety, human resources, complaints handling, privacy, overseas students, boarding, whilstblower and fraud & corruption.

Each of these modules is delivered through the P-LAR framework which includes:

P - appropriate policies that meet state and territory requirements
L - staff learning to train staff and track understanding of those policies and procedures
A- Assurance – tasks, actions, incident capture and risk registers mapped to the policies and procedures
R - reporting that gives data with respect to the overall effectiveness of the implementation of the module.

Our content modules, mapped against the P-LAR framework, now assist over 600 schools to create a positive culture of compliance and child safety and wellbeing, that is embedded in all levels of an organisation from leadership to staff.

Of course, for all schools the journey towards the development of a positive compliance and safety culture will be unique.  We are however very proud of the fact that P-LAR is making a positive impact in the school sector, as evidenced by client feedback including:

David Dobbie, Business Manager of Coomera Anglican College, a co-educational K-12 school of 1500 students and over 200 staff in Upper Coomera, Queensland, who says that working with CompliSpace “changed the culture of our College, placing compliance at the forefront of many of our processes and bringing a sense of ownership to our staff.”

Shane Hennessy, Director of Boarding at Sacred Heart College in Adelaide, a Catholic co-educational 7-12 school in the Marist tradition, said in relation to Sacred Heart’s adoption of CompliSpace’s boarding program There was a gap in our documentation and staff understanding before. Our place is now safer in reality and safer in legality, due to the Standard and the CompliS­pace Boarding Program. This gives me confidence that we are doing everything we can to ensure a safe environment for our boarders and staff.”

 

Summary

The P-LAR framework helps to ensure that people working with children and young people understand their legal and regulatory obligations and put them into practice.

James Field

James is the CEO and co-founder of CompliSpace. He is a highly experienced business executive and legal and corporate governance practitioner, with over 25 years’ experience in the design and implementation of enterprise corporate governance programs across a wide range of industry sectors. James has been a qualified legal practitioner since 1986. He is an active member of the Australian New Zealand Education Law Association (ANZELA) as well as being a Fellow of the Governance Institute of Australia.