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. Part 2 explored the concept of cultural change as required by National Principle 1: Child safety and wellbeing is embedded in organisational leadership, governance and culture. We explained that all of the other National Principles hang off National Principle 1: if National Principle 1 is not in place in a school, compliance with the rest will not be possible.

But in order to embed child safety into a school’s leadership, governance and culture, a school will need to address all of the remaining National Principles. Compliance with each National Principle is also its own separate requirement. While the National Principles leave it open to schools as to the specific strategies that they choose to adopt to comply with each Principle, there are some practical steps schools can take to meet these other National Principles. Indeed, in many cases schools may already be meeting these requirements, and it might be simply a matter of documenting existing practices by inserting these in the school’s policies and procedures.

National Principle 2: Children and young people are informed about their rights, participate in decisions affecting them and are taken seriously

This Principle recognises that establishing an environment of trust and inclusion at a school, by ensuring that all students:

• can express their views and raise concerns, with respect to all matters that affect them
• have their views and opinions taken seriously
• are educated about their rights and are included in policy consultation and development

enables students to speak up when they have concerns about their safety and that of their peers.

Most schools will already have formal and informal mechanisms in place for involving students in decisions that affect them, so compliance with some aspects of this Principle may simply be a matter of documenting this. But schools should consider whether these mechanisms are enough to involve children in all school decisions that affect them, not just those relating to child protection. If not, additional measures will need to be developed and documented.

Another step schools can take to establish an environment of trust and inclusion is to develop and implement (or documenting existing) strategies to promote and support friendship, encourage peer support and make the school’s physical environment friendly for children.

National Principle 3: Families and communities are informed and involved in promoting child safety and wellbeing

This Principle recognises that families have primary responsibility for the upbringing of their child, and that they are best placed to advise about their children’s needs and capabilities. In addition, it makes clear that cultural safety is a necessary part of child safety, and that to be culturally safe a school needs to engage with the communities that are relevant to that school, though respectful relationships and partnerships.

Steps that schools can take to meet this Principle include:

• making clear in policies that parents have primary responsibility for their child and have a right to participate in decisions affecting their child
• considering what communities are relevant to the school and involve them in creating a culturally safe environment
• ensuring that information about who are the school’s child protection officers, how to raise concerns or make complaints, and what behaviours are prohibited by the code of conduct is publicly available and promoted to parents in ways that take into account the cultural make-up of the school community
• ensuring that families and relevant communities have a say in the development and review of the school’s policies and practices.

National Principle 4: Equity is upheld and diverse needs respected in policy and practice

This Principle recognises that children and young people have diverse circumstances, and that many face additional vulnerabilities to child abuse and/or additional barriers to disclosing harm. To be a child safe organisation, schools must understand the diverse circumstances of their students and provide support and respond to those facing additional vulnerabilities or barriers.

Steps that schools can take to meet this Principle include:

• identifying the diversity makeup of the student body and consulting with a range of stakeholders from and with expertise in these diverse backgrounds when developing child safe policies and procedures
• ensuring that staff and relevant volunteers/contractors receive training on the particular additional vulnerabilities for children at the school
• involving children, cultural experts and relevant community leaders in developing and reviewing information about, and processes for, reporting and managing child protection incidents or concerns
• ensuring that the school has a diverse workforce, and that it provides training to staff and relevant volunteers about diverse cultures.

National Principle 5: People working with children and young people are suitable and supported to reflect child safety and wellbeing values in practice

Ensuring that people working or volunteering at a school are suitable is about much more than just complying with Working with Children/Working with Vulnerable People Check requirements. A focus on child safety needs to be embedded in each of stage of human resource management. A school’s policies and procedures for recruitment and selection processes, induction, supervision, and managing the performance of staff, volunteers and contractors all need to promote child safety.

Steps that schools can take to meet this Principle include:

• assessing all positions for the expected level of contact with children and including this, along with clear expectations about child safety responsibilities, in job descriptions
• providing copies of the code of conduct and child safe policy to all applicants for all positions at the school
• conducting verbal referee checks with appropriate referees and asking specific child safety related questions
• conducting annual performance appraisals for all staff and including children’s feedback in these.

National Principle 6: Processes for complaints and concerns are child focused

This Principle requires that effective and child-focused complaints processes be developed, that are accessible, responsive to and understood by children and young people, families, staff and volunteers. It requires consideration of cultural safety issues, of barriers to reporting or participating in complaints processes and of fairness to all parties involved in a complaint or investigation. The important thing to remember is that this Principle is not just about child protection complaints, but about ensuring that – for child related organisations such as schools – the entire complaints handling system has children’s rights and safety at its heart.

The National Office of Child Safety has prepared a Complaint Handling Guide: Upholding the rights of children and young people, which gives practical advice about how to develop, implement and maintain a complaint handing system that priorities child safety and promotes the rights of children and young people to have a voice in decisions that affect them.

An additional step that schools might take, with respect to processes for managing child protection related complaints, includes having clear procedures for staff about how to make external reports (i.e. beyond mandatory reporting to child welfare, police and reportable conduct bodies).

National Principle 7: Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training

This Principle expresses the importance of information, ongoing education and training being provided to staff and volunteers. Schools will need to consider:

• how and to whom ongoing education and training is provided (are volunteers and contractors included)
• what kind of information is available/provided to those who do not receive ongoing training
• what additional topics might need to be covered in annual training for staff and volunteers, such as identifying and responding to students with sexually harmful behaviours, creating cultural safety, and empowering children.

National Principle 8: Physical and online environments promote safety and wellbeing while minimising the opportunity for children and young people to be harmed

This Principle is all about risk management. A school’s risk management plans and risk registers should include, and address, risks to child safety that are related to the specific online and physical environments at the school.

National Principles 9 and 10: Implementation of the National Principles is regularly reviewed and improved; and policies and procedures document how the organisation is safe for children and young people

Documenting a school’s child safe policies, procedures and practices in a way that is accessible to students, families, relevant communities, staff and volunteers enables all stakeholders to be aware of how the school plans to meet its obligations to create an environment that is safe for children, assists in ensuring consistent application of child safe practices across the school and enables reporting of issues when they arise. But is also important to regularly review these policies and procedures, as well as how the school is faring in implementing the National Principles.

Step schools can take to meet this Principle include:

• regularly reviewing child safety policies, procedures and practices; involving children, families, communities and experts in these reviews; and being transparent about review results
• conducting systemic/root cause analysis of any child protection incidents that occur at the school, at school events or involve school staff/volunteers; and revising policy, procedure and practice when necessary
• regularly analysing child protection complaint and incident data for trends and systemic issues and revising policy, procedure and practice when necessary.

Conclusion

In the past, before the Royal Commission into Institutional Responses to Child Sexual Abuse, many organisations believed that they were safe for children simply because they were an organisation ‘about’ children. But the Royal Commission demonstrated the folly in that thinking. It takes a concerted, focused and well planned effort to be a child safe organisation. With mandatory compliance with the National Principles for Child Safe Organisations coming to every jurisdiction in Australia, it’s time for schools to start that process.