In Part 1 of this series, we looked at the implementation of the National Principles by each state and territory and found that most jurisdictions will soon expect, or already require, child related organisations to integrate the National Principles into their policies and practices.
National Principle 1
The National Principles are designed to embed a culture of child safety in all child-related organisations. Indeed, the first and foremost of the National Principles, National Principle 1, requires that child safety and wellbeing be embedded in organisational leadership, governance and culture. All of the other National Principles hang off this first one: if National Principle 1 is not in place in a school, compliance with the rest will not be possible.
Ultimately the National Principles leave it open to schools as to the specific strategies that they choose to adopt to comply with each Principle, including National Principle 1. But there are some practical steps that schools can take to embed child safety in their leadership, governance and culture.
In addressing the issue of how to address cultural issues, ASIC provides the following view which can be translated to the school environment:
“To address cultural and conduct-related issues it is imperative that firms focus first and foremost on setting the right tone from the top. It is also important to:
- cascade cultural values to the rest of the organisation;
- translate values into actual business practices; and
- staff accountability;
- effective communication and challenge;
- recruitment, training and rewards, and
- governance and controls.”
The ways that this can be applied to schools is discussed below.
Set the Tone from the Top
A school’s commitment to the creation and maintenance of a child safe culture must be kept high on its agenda for daily discussion. This commitment must be driven from the top, and in particular, from a school principal who holds a unique position of leadership and authority within a school, akin to a captain of a ship. Simply put, if a principal does not understand the importance of strong governance, risk, compliance and policy management in creating a child safe culture, or chooses to ignore it, it is unlikely that a child safe culture will be established.
In the school environment, this means that the development of a culture of awareness regarding child safety (and governance, risk, compliance and policy management issues generally) requires a total commitment from all members of the school governing body and leadership team.
Steps that a school might take here include child safety being a standing item in board, leadership team and staff meetings, and appointing a ‘child safety champion’ at the board level.
Not only does cultural change require strong leadership from ‘the top’ of a school, it also requires a clear vision, considerable planning, allocation of resources and the discipline to execute a plan over time.
Understanding the complexity of the change management process simply highlights the level of commitment that is required by school governors and leadership teams. This is particularly the case in schools that, by default, have multiple stakeholders (e.g. students, staff, parents, volunteers, alumni, regulators, local communities) with influences often expanding over generations. Schools with religious affiliations must also consider religious principles and teachings. Change management is also a key consideration for schools with unionised workplaces.
Integrated Governance, Risk, Compliance and Policy Management Framework
Child safety does not occur in a vacuum. The nature of child abuse means that it can happen anytime and anywhere. In reality, delivering on a commitment to the creation and maintenance of a child safe culture requires the establishment and communication of a clear and comprehensive integrated governance, risk, compliance and policy management framework within a school.
Human Resource Management Practices (Including Training)
From a cultural perspective, a school’s commitment to developing an appropriate human resources infrastructure and to ensuring that staff complete training on child safety policies and procedures will also constitute a demonstration of its commitment to a culture of compliance with the National Principles and in relation to child safety.
Incident Management (Including Processes for Reporting and Responding to Child Safety Incidents and Concerns)
The inadequacy of statutory reporting regimes in effectively managing child abuse within schools has prompted lawmakers to introduce broader obligations on schools to make internal reporting easier, including:
- providing a safe and supportive environment for reporting child safety incidents
- ensuring staff, volunteers, families and children know how to recognise child abuse and other inappropriate behaviour towards children, know how to report this, and feel comfortable doing so
- appointing a Child Protection Officer/s (or similar) to receive initial reports and ensure appropriate responses.
The logic behind these initiatives is unassailable. To develop a culture of child safety, schools must ensure ease of reporting from all key stakeholders and also ensure that, when reports are made, they are responded to appropriately.
In developing a child safe culture, it is important for schools to ensure that students understand what is considered inappropriate behaviour and that they (and their parents) feel safe and comfortable in raising or discussing their issues or concerns. In order to achieve this outcome schools should at a minimum:
- provide age appropriate education to children about standards of behaviour, healthy and respectful relationships (including sexuality), resilience, and child abuse awareness and prevention
- ensure that children have a clear mechanism for raising concerns and are comfortable in doing so
- regularly gather feedback from children as to whether they do understand their rights and feel that they will be taken seriously if they report a concern and whether they feel safe in doing so
- ensure that provisions are made for children with disabilities and for those from culturally diverse backgrounds.
Finally, it is critical that a school has systems and processes in place to effectively monitor the overall effectiveness of its child safe program and to take appropriate actions to make improvements to the effectiveness of the program on an ongoing basis.
While schools commonly adopt a structured policy review cycle (e.g. next review date) the speed of change in the child protection space caused by the Royal Commission and the likelihood of a move towards harmonisation of child protection laws in Australia over the next 5 to 10 years means that schools should be moving towards a more dynamic continuous improvement process.
Such a process can only work in practice if a school has developed a fully integrated governance, risk, compliance and policy management framework which is regularly reviewed having regard to a school’s risk profile and risk appetite, changes in laws monitored through a formal compliance program and analysis of incidents which may be indicative of failures in current systems.
What Should Schools Do?
Schools should start to amend policies and procedures where required to meet the National Principles and commence the culture change process. Schools that have already incorporated the National Principles into their policies and procedures must regularly review and improve their implementation, and should therefore use this time to reflect whether these changes are indeed creating a child safe culture and environment for their students.
In Part 3 of this series we provide some practical ideas on how schools can implement the remaining National Principles.