Child Safety Policy

1. Statement of Commitment

Children and young people with disability are among the most vulnerable members of our community. Research consistently shows they face a higher risk of abuse, neglect, and exploitation than non-disabled children. Safe Hands acknowledges this heightened risk and actively works to prevent harm through strong safeguarding practices, thorough screening, and a culture of open accountability.

We are committed to:

2. Scope

This policy applies to all Safe Hands staff, contractors, subcontractors, students on placement, and volunteers. For the purposes of this policy:

• A child is a person under 18 years of age
• A young person refers to anyone aged 15-17 years
• The policy applies whenever a worker has contact with a child during the delivery of NDIS-funded supports, in the participant’s home, in our facilities, in the community, or via telephone or online platforms

3. Legislative Framework

This policy is informed by and must be read alongside:

• Child Protection (Working With Children) Act 2012 (NSW) - mandatory Working With Children Checks
• Children and Young Persons (Care and Protection) Act 1998 (NSW) - mandatory reporting obligations
• National Disability Insurance Scheme Act 2013 (Cth) - NDIS worker screening requirements
• NDIS Practice Standards - Core Module, Quality Indicator 1.4 (Incident Management)
• NDIS Code of Conduct - obligations to act with respect and to prevent and respond to harm
• National Principles for Child Safe Organisations (Australian Human Rights Commission, 2019)
• United Nations Convention on the Rights of the Child (UNCROC, 1989)
• Disability Discrimination Act 1992 (Cth)

4. Recognising Child Abuse & Neglect

All workers are expected to be able to recognise indicators of abuse and neglect. The following are not exhaustive but represent common warning signs:

4.1 Physical Abuse

• Unexplained bruising, burns, fractures, or injuries inconsistent with the child’s level of development
• Injuries in unusual locations (inner arms, torso, back, face)
• A child who flinches when touched or seems afraid of certain adults
• Explanations for injuries that change or are inconsistent

4.2 Sexual Abuse

• Age-inappropriate sexual knowledge, language, or behaviour
• Physical symptoms including pain, bleeding, or injury to genital or anal areas
• Withdrawal, anxiety, or fear around specific adults
• Disclosure of sexual contact by the child (always take disclosures seriously)

4.3 Emotional Abuse & Psychological Harm

• Low self-esteem, extreme submissiveness, or constant need for approval
• Delayed emotional development or regression in behaviour
• A child who is excessively aggressive, anxious, or depressed without clear reason
• Adults who consistently humiliate, belittle, or threaten the child

4.4 Neglect

• Consistently poor hygiene, inappropriate clothing for the weather, or extreme hunger
• Untreated medical or dental conditions
• A child who is frequently absent from scheduled supports or school without explanation
• Being left alone or unsupervised in unsafe conditions

5. Mandatory Reporting

Under the Children and Young Persons (Care and Protection) Act 1998 (NSW), all Safe Hands workers are mandatory reporters. This means you are legally obligated to report to the NSW Department of Communities and Justice (DCJ) - Child Protection Helpline - if you have reasonable grounds to suspect that a child is at risk of significant harm.

5.1 Who to Report To

• NSW Child Protection Helpline: 132 111 (24 hours, 7 days)
• If the child is in immediate danger: Call 000 first, then report to the helpline
• NDIS Quality and Safeguards Commission: 1800 035 544 (for incidents involving NDIS supports)

5.2 Reporting to Your Manager

Before or after making an external report (not instead of), you must also notify your direct manager or the Director as soon as possible. The manager will activate the Incident Management process (POL-INC-001) and ensure all obligations are met.

6. Responding to a Child’s Disclosure

If a child discloses abuse or harm to you, how you respond in that moment matters enormously. Follow these principles:

7. Worker Screening & Recruitment

Safe Hands is committed to ensuring all workers who may have contact with children have undergone thorough screening prior to commencement. All applicable workers must hold and maintain:

• Working With Children Check (WWCC) - issued by the Office of the Children’s Guardian, NSW. Must be current before any contact with children. Worker number must be provided to Safe Hands.
• NDIS Worker Screening Check - issued through the NSW NDIS Worker Screening Unit. Mandatory for all workers delivering NDIS supports or who may have contact with NDIS participants including children.
• National Police Check - conducted at induction and renewed every 3 years
• Reference checks - two professional references checked for all direct support workers
• Identity verification - 100-point identity check at commencement

7.1 Ongoing Monitoring

Safe Hands will maintain a register of all worker screening clearances and their expiry dates. Managers must ensure clearances are renewed before expiry. If a worker’s WWCC or NDIS Worker Screening Check is revoked or suspended at any time, they must notify management immediately and will be stood down from any role involving child contact pending review.

8. Appropriate Behaviour with Children

All workers must observe the following standards of behaviour when working with children. These boundaries exist to protect children and workers alike.

8.1 Conduct Standards - DO

• Treat every child with dignity, respect, and kindness
• Seek the child’s permission before any physical contact (e.g., personal care, therapeutic touch)
• Ensure personal care activities are conducted with privacy and explained in advance
• Work in visible areas where possible; avoid one-on-one situations in closed or private spaces
• Use language that is age-appropriate and that the child understands
• Follow the child’s care plan and only provide support that is within your role
• Promptly report any boundary concerns - your own behaviour or a colleague’s

8.2 Conduct Standards - DO NOT

• Do not engage in any form of physical punishment or use force beyond what is immediately necessary to prevent harm
• Do not engage in sexual conduct, sexual conversation, or sexually suggestive behaviour with a child - this is a criminal offence
• Do not share personal contact details (phone, social media, personal email) with a child or their family
• Do not photograph or film a child without prior written consent from the child’s parent/guardian and management approval
• Do not show a child or allow them access to inappropriate material
• Do not make promises to a child that you cannot keep or that undermine their relationship with their parents/carers
• Do not place yourself in a situation where you are alone with a child in a private space without another adult present or visible

9. Online Safety

Where Safe Hands delivers any support via online platforms (video calls, messaging, apps), the following additional requirements apply when children are involved:

• All online sessions must be conducted on Safe Hands’s approved platforms only
• A parent or guardian should be present or immediately accessible during online sessions with children where possible
• Workers must not communicate with children via personal social media accounts, personal messaging apps, or any platform not approved by management
• Sessions should not be recorded without explicit written consent from the parent/guardian
• If a child discloses abuse during an online session, the worker must follow the same reporting procedures as for in-person disclosures

10. Empowering Children & Young People

Safe Hands believes children have the right to participate in decisions about their own supports and to understand what they can expect from us. We will:

• Explain to children (in ways they can understand) what supports they will receive and who will provide them
• Ask children for their feedback on their supports and take it seriously
• Ensure children know they can say no to a support or a worker and that their wishes will be respected and escalated appropriately
• Provide children with information about who they can speak to if they are unhappy or feel unsafe (including the NDIS Commission and Bravehearts: 1800 272 831)
• Communicate with children in a manner appropriate to their age, ability, and communication needs
• Involve children in their own support planning to the fullest extent possible

11. Confidentiality & Privacy

Information about a child will only be shared on a need-to-know basis and in accordance with our Privacy & Information Management Policy (POL-PRV-001). However, confidentiality will never be used as a reason to withhold information from child protection authorities when there is a risk of significant harm to a child. The safety of the child always takes precedence over confidentiality.

If a child asks a worker to keep something a secret, the worker must explain, gently and clearly, that they cannot always keep secrets if someone could be hurt - but that they will do everything they can to help keep the child safe.

12. Training & Culture

Safe Hands fosters a culture where child safety is everyone’s responsibility. We achieve this through:

• Induction training: All workers complete child safety training before commencing work with children
• Annual refresher: All staff complete child protection refresher training every 12 months
• Scenario-based learning: Practical training on recognising abuse, responding to disclosures, and appropriate conduct
• Open reporting culture: Workers are encouraged - and expected - to raise concerns about a colleague’s behaviour with a child without fear of reprisal
• Leadership accountability: Senior leadership models child-safe values and responds visibly and seriously to any child protection concern

13. Breaches of This Policy

Any breach of this policy is treated as a serious matter. Depending on the nature and severity of the breach, consequences may include:

• Immediate suspension from duties pending investigation
• Internal disciplinary process, up to and including termination of employment or contract
• Mandatory reporting to the NSW Child Protection Helpline, NDIS Commission, or NSW Police
• Referral to the Office of the Children’s Guardian for WWCC revocation
• Referral to the NDIS Worker Screening Unit for screening clearance review

Workers who report concerns about child safety in good faith are protected from any adverse action under this policy and under NSW law.

14. Key Contacts & Resources

15. Related Documents

• Incident Management & Reporting Policy (POL-INC-001)
• Feedback & Complaints Policy (POL-CMP-001)
• Human Rights & Participant Rights Policy (POL-RTS-001)
• Privacy & Information Management Policy (POL-PRV-001)
• Code of Conduct
• Worker Screening Procedure
• Incident Report Form (FORM-INC-001)