1 Stop Health Pty Ltd believes that every child has a right to be safe from harm and the risk of harm, at all times. To be cared for through the provision of allied health services in a way that allows them to reach their full potential.

2.4 CHILD AND YOUNG PEOPLE SAFE ENVIRONMENTS POLICY

1. Purpose

This policy aims to demonstrate, ensure and support the strong commitment by 1 Stop Health Pty Ltd, personnel and customers to child safety including establishing and maintaining child safe and child friendly policy, services and environments. This policy reflects our commitment to provide a safe environment where every child and young person has the right to be treated with respect, feel respected, valued, encouraged to reach their full potential and is safe and protected from harm and the risk of harm.

2. Commitment to Child and Young People Safety

1 Stop Health Pty Ltd believes that every child has a right to be safe from harm and the risk of harm, at all times. To be cared for through the provision of allied health services in a way that allows them to reach their full potential. We aim to build an environment which is both child safe and child friendly where children and young people feel respected, valued, and encouraged. All children and young people are embraced regardless of their abilities, sex, gender, or social economic or cultural background and equity is upheld. The wellbeing and best interests of children (0-18 years of age) serviced are our priority. We will support the rights of the child and will act without hesitation to ensure a child safe environment in which bullying, and harassment will not be tolerated. We aim to provide health services which reflect the intent and principles of Child Safe Environments Legislation and Compliance requirements, where a child safe culture is championed, modelled and implemented at all levels of the organisation.

1 Stop Health Pty Ltd will through good practice principles aim:
• to take a proactive and participatory stance on child protection, child harm and risk of harm issues.
• to ensure that the safety and wellbeing of children is paramount consideration when providing services, environments, developing activities, codes of conduct, policies and management practices.
• to value and embrace the opinions and views of children.
• focus on encouraging and assisting children to build skills that will allow them to participate in society to their full potential.
• are mandatory reporters and will take action to protect children from physical, sexual, emotional and psychological harm or risk of harm.
• We aim to ensure policies are developed and reviewed in collaboration with stakeholders involved with our organisation.

3. Context

As providers of children’s allied health services and coordination of government funding we identify as a designated ‘prescribed organisation’. We aim to ensure that the environments and actions of our organisation, policies, procedures and personnel reflect and meet child safe standards as set out in Children and Young People (Safety) Act 2017 commenced October 2018, The Child Safety (Prohibited Persons) Act 2016 and align with the National Principles for Child Safe Organisations. We aim that personnel meet NDIS Worker Screening Rules and NDIS Incident Management and Reportable Incidents Rules 2018, including compliance checks.

The Policy is based around legislation Children and Young People (Safety) Act 2017 commenced October 2018 and NDIS Worker Screening Rules and NDIS incident Management and Reportable Incidents Rules 2018.
The policy aims to align and comply with the legislation associated with children’s health services.
• Children and Young People (Safety) Act 2017 commenced October 2018,
• The Child Safety (Prohibited Persons) Act 2016
• Statutes Amendment (child Sexual Abuse) Act 2021
• Spent Convictions Act 2009
• Spent Convictions Regulations 2011

• NDIS Act 2013 https://www.legislation.gov.au/Details/C2018C00276
• NDIS Act rules https://www.legislation.gov.au/Series/C2013A00020/Enables
• NDIS Incident Management and Reportable Incident Rules 2018
• NDIS Worker Screening Rules 2018

4. Scope

This policy, from the date of review endorsement, applies to all employees, contractors, room rental agreements, partner health organisations, children and young people, parents, carers and other individuals involved in 1 Stop Health Pty Ltd. 1 Stop Health Pty Ltd staff, contractors, volunteers, students and renters are all referred to as personnel within this policy.

All personnel are required to agree in writing to read, accept and act in accordance with this policy and Code of Conduct by signing the actual policy. A copy of all signed statements is maintained in the Compliance Register.

5. Communication

5.1 We ensure that everyone to whom this policy applies is aware of and has an opportunity to engage with the policy and Child Safe Code of Contact as they request and are able.

The child safe environments policy and related policies and documents are available upon request; are displayed within the therapy office waiting rooms; are provided as part of the NDIS service agreement pack / signing session and explained at appropriate customer communication and understanding levels by all personnel.

Social media platforms allow our customers to have an increased awareness of our organistional aims and commitments and ongoing input into their appropriateness and review.

5.2 All personnel are provided with the child safe policy, code of conduct and associated policies as part of the induction process. All personnel are required to agree in writing to read, accept and act in accordance with this policy and Code of Conduct. A copy of all signed statements is maintained in the Compliance Register.

Policy updates are provided for review and education as part of professional and administrative meetings as appropriate. Ongoing training in child safe environments and mandatory reporting is provided as part of the requirement for working within a child environment and for our organisation.

5.3 Children’s participation

All personnel encourage and support children who use our services to ‘have a say’ about those things that are important to them and that they are in a safe environment. We value diversity and do not tolerate any discriminatory practices. We value and respect the views of children and young people who access our services and involve them in decision making as appropriate. We listen to and act on any concern’s children, their parents, families or carers, raise with us by our formal complaints and feedback systems or informal verbal suggestions or queries.

Child rights are displayed within therapy waiting rooms and ongoing information provided during therapy to support these rights as appropriate, to ensure that children and young people know their rights to safety, to be listened to and that they can provide feedback or make a complaint if they have a concern, to any worker or ask their parent/guardian to do this on their behalf. Children, families and other consumers are made aware through formal and informal information or directly as part of therapy requirements that staff are mandatory reporters for harm or risk of harm and what this process may look like or involve for them. Privacy policies and procedures, NDIS Incident Management and Reportable Incident Policies and Complaints and Feedback systems are provided to all customers. Developmental specific and age specific resources are utilised as appropriate to support understanding, engagement and participation in the development and maintenance of child safe environments.

Feedback on service provision and systems is sought as part of our quality systems and children and young people are included as an integral part of this process as appropriate.

6. Code of Conduct

6.1 Child Safe Code of Conduct:

As a service provider to children (0-18 years of age) all our personnel are responsible for promoting and protecting the safety and wellbeing of children and young people by:

• Following the organisation’s child safe policy at all times and taking all reasonable steps to ensure the safety and protection of children and young people.
• Abiding by the organisation’s Child Safe Code of Conduct in conjunction with the policy 3.2 Code of Conduct including NDIS Code of Conduct and their specific health professional Codes of Conduct.
• Treating everyone including those of different race, ethnicity, gender, gender identity, sexual orientation, age, social class, physical ability or attributes and religious beliefs with respect and honesty and ensure equity is upheld.
• Be a positive role model to children and young people in all conduct with them.
• Set clear boundaries about appropriate behaviour between yourself and the children or young people present or being treated in the Practice – boundaries help everyone to understand their roles.
• Ensure children and young people understand their rights and explain to the child or young person in age- / developmentally appropriate language what they can expect during the service, particularly where treatment involves physical contact.
• Ensure that where diagnosis or treatment requires an image of a child or young person to be taken, the child, young person and their parents or carers (where applicable) clearly understand the way the image will be used. Permission must be obtained before any images are taken.
• Ensuring another adult is always present or in sight when conducting 1:1 therapy or any associated activities, unless detrimental to the child or young person.
• Being alert to bullying and discriminatory behaviours and responding promptly and appropriately.
• Listening and responding appropriately to the views and concerns of children and young people.
• Encouraging children and young people to ‘have a say’ on issues that are important to them.
• Being alert to children and young people who have been harmed or may be at risk of harm and reporting this quickly to the Child Abuse Report Line (13 14 78).
• Raise any concerns, problems or issues with management as soon as possible.
• Record and act quickly, fairly and transparently on any complaint made by a child, young person or their parent/guardian.
• Follow the NDIS Code of Conduct; Practice Standards and Incident Management / Reportable Incident policy / NDIS rules 2018.
• All personnel will not:
– Take part in any unnecessary, non-therapeutic physical contact with a child or young person.
– Engage in rough physical games.
– Discriminate against any child or young person because of age, gender, cultural background, religion, vulnerability or sexuality.
– Develop any ‘special’ relationships with children or young people outside of the professional relationship that could be seen as favouritism such as offering gifts or special treatment.
– Do things of a personal nature that a child or young person can do for themselves such as toileting or changing clothes.
– Harm or create a risk of harm for any child in any way.

6.2 Breaches

Breaches or suspected breaches of the Code of Conduct should be reported as soon as practicable to management either in person, by telephone (08 87255383), by mail: 1 Eleanor St Mt Gambier SA 5290 or via email at info@1StopHealth.com.au. Breaches or suspected breaches of the Code of Conduct will be taken seriously and dealt with quickly, fairly and transparently, with support, information and direction provided as per the Complaints and Feedback Policy. Through the provision of Complaints and Feedback Information Sheet customers will be assisted to access supports and navigate barriers to engage in the complaints and feedback system in relation to a breach of our Child Safe Code of Conduct. Any misconduct or disciplinary matters are reported to the DHS Screening Unit as required by law.

6.3 Personnel Breaches

1 Stop Health Pty Ltd personnel are required to abide by the organisation’s Codes of Conduct. The Codes of Conduct outlines standards of behaviour required in the performance of related duties and incorporates the NDIA Code of Conduct and associated support materials.

Personnel acknowledge understanding and agreement of the organisation Code of Conduct by signing a copy of the code at commencement of their position, placement or contract and as review of policies requires. Personnel are encouraged to discuss any part of this policy with the Directors if they are unsure of how it applies.

Additional Codes of Conduct such as the NDIA code of conduct are highlighted throughout policies including but not limited to the Child Safe Policy; Communication Policy; Information Technology Policy and Work Health and Safety Policies.

A copy of this Child Safe Code of Conduct is to be published and displayed by suitable means to allow all personnel to become aware of their responsibilities and to enable compliance with its terms and conditions. Child Safe policy and code of conduct will be reviewed at meetings from time to time as deemed necessary and appropriate to meet personnel and organisational requirements.
Any personnel who suspect or becomes aware that any Code of Conduct or Policies may be breached must report the matter to the Directors immediately, including any information or evidence that they have.
Where personnel are unsure of their own conduct in relation to the operation of this Code of Conduct Policy, they must bring the matter to the attention of the Directors for discussion and clarification of the policy and its application to their particular circumstances, as soon as they become aware of a breach, or potential breach.
Personnel who are in breach of any Code of Conduct Policies, or suspected of being in breach of policy, are dealt with in accordance with the normal disciplinary process that applies at 1 Stop Health Pty Ltd or which form part of the Contractors Management Services Agreement for Consortium members. In severe or repeated instances, or where a fundamental breach of the employment contract occurs, termination of the employment or contractors’ agreement may occur. Any misconduct or disciplinary matters are reported to the DHS Screening Unit as required by law.

7. Recruitment

7.1 1 Stop Health Pty Ltd and its contractors (within known as 1 Stop Health Pty Ltd) – take all reasonable steps to ensure that it engages the most suitable and appropriate people to work with children and young people within the specialised children’s services the organisation provides. The following recruitment practices are undertaken:

• Outlined commitment statement and policies which maintain and support child safe environments guide recruitment and selection of appropriate personnel for the organisation.
• Position descriptions and any employment advertising will refer to the organisation’s commitment to child safety and wellbeing and expectations of applications to engender the same commitment as the organisation provides specialised children’s services.
• Employment of personnel to risk assessed roles is outlined in position descriptions and subsequent compliance requirements and personnel qualities.
• Employment policies and procedures are developed to reflect the organisations commitment to child and young person safe environments, thereby ensuring applications provide a written application, are interviewed face to face in person or online with knowledge of child safeguarding being explored during the interview process.
• 2 referee and qualification checks are undertaken.
• All compliance documentation is provided before employment is confirmed.

7.2 We abide by laws and legislation related to working with children in any Australian State that is practiced in, including the Child Safety (Prohibited Persons) Act 2016 and the NDIS Worker Screening Rules 2018. In accordance with the Child Safety (Prohibited Persons) Act 2016, our organisation is registered with the DHS Screening Unit, and we link all Working with Children Checks (WWCC) of our personnel to the organisation.

The organisation is registered with the NDIS Quality and Safeguards Commission to enable NDIS worker screening checks to be completed and linked to the organisation.

7.3 We conduct DHS Working with Children Checks, General Employment Screenings, Disability Employment Screenings and / or Vulnerable Person Employment Screening, for personnel working with children and young people in prescribed / risk assessed positions and who may be in contact with children and young people within the organisation.

All personnel who are classified as being in a Risk Assessed position and who will be working with or near children and young people must hold current, not prohibited WWCC issued by the Screening Unit of the Department of Human Services, provide evidence of this prior to their employment and renew these every 5 years. We verify the accuracy of all WWCCs in the DHS Screening Unit portal as required by law.

The Child Safety (Prohibited Persons) Act 2016
In November 2016 new laws were passed in South Australia to strengthen background checks for people wanting to work or volunteer with children and young people.
The Child Safety (Prohibited Persons) Act 2016 will restrict people who pose an unacceptable risk to the safety of children from working or volunteering with them. It is an offence for an organisation to engage a person in a work or volunteer role in these circumstances.
NDIS Worker Screening Rules (2018)
For registered NDIS providers delivering NDIS supports and services in South Australia, from 1 July 2018 any worker engaged in a risk assessed role must have:
• Department of Human Services Working with Childrens Employment Screening check.
• Department of Human Services Child-related Employment Screening check issued before 1 July 2019.
• Until they expire (five years from date of issue) or are revoked.
Any new personnel delivering NDIS supports or services in South Australia requires a DHS WWCC and a NDIS Disability Worker Check. For personnel whose existing check expires after 1 July 2019, a WWCC check, and a NDIS Disability Worker Check is required. A Working with Children Check is not the total compliance requirement for the purposes of providing NDIS services and supports.
For non-registered NDIS providers, a NDIS Disability Check is not required, however is recommended as best practice for our organisation. At a minimum DHS Disability Worker Check is required prior to gaining the NDIS Disability Worker Check.

7.4 In the event that personnel or applicant are not willing to consent to a DHS / NDIS employment screening checks or cannot furnish a WWCC and NDIS screening check or does not have a valid assessment of their criminal history report or other acceptable evidence, they will be precluded from working with children or under the NDIS in any prescribed position.

7.5 Each applicant is responsible for meeting the cost of obtaining a criminal history report /appropriate DHS employment screening checks, unless negotiated individually with 1 Stop Health Pty Ltd or Consortium Member. Volunteer screening checks are free.
Work experience students under the age of 14 or not undertaking work experience for more than 7 calendar days in a year are exempt from a Working with Child Check.
Under NDIS rules work experience students are exempt from requiring a disability employment check if they are supervised during direct client contact, otherwise require an appropriate check.

7.6 1 Stop Health Pty Ltd ensure DHS employment screening checks are dealt with in accordance with the standards developed by the Department of Human Services. Records are kept securely, and processes are transparent.

7.7 A record of currency of DHS working with children/vulnerable/disabled people employment screening and/or NDIS screening compliance requirements are maintained in the Compliance Record, with risk assessed role descriptions; employees DOB, name and address; any associated documentation for a period of 7 years.

7.8 We advise the Screening Unit (DHS) and the NDIS Quality and Safeguards Commission when the organisation becomes aware of certain information regarding any person involved with our organisation, including any serious criminal offence, child protection information or disciplinary or misconduct information.

8. Training, Supervision and Support for personnel

1 Stop Health Pty Ltd seeks to attract and retain the best personnel through provision of high quality, appropriate training, ongoing support, education and supervision. We aim to ensure personnel feel valued, respected and fairly treated.

We ensure that personnel who work with children and young people have ongoing supervision, support and training to ensure they understand the organisation’s child safe environments policies, Codes of Conduct, mandatory reporting obligations, how to build culturally safe environments and their responsibilities to create a child safe and friendly environment.

Supervision and Support:

• Induction of personnel includes reading and signing child safe policy, procedures, code of conduct and child safeguarding requirements such as mandatory reporting, cultural safety, record keeping, confidentiality agreement, supervision and information sharing.
• Ongoing staff meetings, organisational meetings and planning session highlight child and young people safety information, updates, complaints, feedback and future planning / changes/development.
• Multidisciplinary team meetings and child specific team meetings may include discussion, processes and support required to ensure mandatory reporting as required and reduction of harm or risk of harm.
• Senior therapists provide guided supervision and support to developing therapists.
• Senior therapists seek guidance and support from mentors or appropriate specialty organisations or consultants as required.
• Directors provide guidance and support to all personnel as outlined in policies and procedures.
• Yearly performance appraisals will incorporate child safeguarding and compliance requirements.

Training:

• All professional allied health staff need to comply with mandatory professional development as outlined by their professional bodies and registration requirements. 1 Stop Health Pty Ltd monitors therapist qualifications, ongoing education registration dates in compliance register and maintains records of these documents for 7 years.
• All personnel and specific mandatory notifiers / risk assessed role personnel will read, understand and sign that they have undertaken completing the Mandatory Notification Information Booklet available at: https://dhs.sa.gov.au/__data/assets/pdf_file/0003/103179/CSE-Mandatory-notification-information-booklet.PDF
This will be completed during induction or as required for updating of knowledge and skills.
• All personnel within the organisation will undertake Child safe training offered through an accredited organisation every 3 years – Safe Environments: Through their eyes training.
Completion records and dates of this training are maintained within the Compliance Register.
Where organisational and therapy service are provided to the Department for Education’s (DfE) sites personnel may be required to undertake the DfE Responding to Risks of Harm, Abuse and Neglect – Education and Care training (RRHAN-EC). This may be in place of the Safe Environments training, or in addition to it and will depend upon agreements signed with each individual DfE school or service provider. We encourage all personnel to undertake this 2-hour online Fundamentals bridging course from the SAFE Environments through their eyes one day training. https://www.education.sa.gov.au/working-us/rrhan-ec/fundamentals-course-responding-risks-harm-abuse-and-neglect-education-and-care
Completion records and dates of this training are maintained within the Compliance Register.
• All personnel are encouraged to read the National Principles for Child Safe Organisations and supporting documentation. https://childsafe.humanrights.gov.au/sites/default/files/2019-02/National_Principles_for_Child_Safe_Organisations2019.pdf
• All personnel will be encouraged to undertake Cultural competency training that includes content on how to build culturally safe environments as offered within the organisation. Completion records and dates of this training are maintained within the Compliance Register.
• Training will be funded by the organisation in negotiation with personnel.

9. Reporting and responding to harm or risk of harm

9.1 We aim to ensure that children and young people are safe from harm and risk of harm. Bullying and harassment of any kind is not tolerated in any form.

9.2 Definition of Harm
Section 17 of the Safety Act defines ‘harm’ to mean physical or psychological harm (whether caused by an act or omission), including harm caused by sexual, physical, mental or emotional abuse or neglect.

9.3 Mandated Notifiers
Mandated notifiers in the organisation are personnel who:
• Provide services to children and young people.
• Are qualified registered allied health professional.
• Who are identified as risk assessed roles within the organisation under NDIS Incident Reporting and Management guidelines 2018 – Directors, Managers, Therapy and Administrative staff. Refer Policy 3.19.2 Risk Assessed roles for employment.
• Hold management positions in the organisation the duties of which include responsibility for or direct supervision of the provision of those service to children and young people.
• All personnel associated with 1 Stop Health Pty Ltd are classed as mandatory notifiers due to the organisation being a specialised child service health provider.

9.4 Mandatory Reporting
All personnel as mandatory reporters have a legal obligation to notify the Child Abuse Report Line (CARL) on 13 14 78 as soon as practicable if they have a reasonable belief that a child or young person is or may be at risk of harm.

If the child or young person is at immediate risk, report to South Australian Police (SAPOL) on 000.

In cases involving Aboriginal children and young people, support is provided by Yaitya Tirramangkotti – an Aboriginal team, via the CARL number.

Online reporting is available via:
https://my.families.sa.gov.au/IDMProv/landing.html

With both phone and online reporting personnel are required to provide detailed information about the child or young person and situation of harm. Follow the directed prompts.

Information about making appropriate reports of harm or risk of harm is available from the South Australian Department of Child Protection website:
https://www.childprotection.sa.gov.au/reporting-child-abuse

https://www.childprotection.sa.gov.au/reporting-child-abuse/report-child-abuse-or-neglect

9.5 Even if not a mandatory reporter, any person can report harm or risk of harm to a child or young person. The individual who identifies the harm or risk of harm is required to make the report to the authorities and can request the support of another worker or personnel to do so if required.

All adult workers (even if not mandatory notifier) have a legal obligation to report child sexual abuse to the police and to protect a child from sexual abuse. Failure to meet these obligations may be considered a criminal offence.

9.6 Following a report being made to CARL or SAPOL personnel must make an internal incident report to management as per incident reporting policy and procedure. All information regarding the report is stored securely in a separate file.

We will be guided by the Department of Child Protection and / or SAPOL after a report has been made as to whether we can conduct an internal investigation.

9.7 All personnel will undertake Child Safe Training every 3 years and additional training required by DfE and DCP related to mandatory reporting booklet and associated information as updated and provided to personnel from time to time. A record of this training and future needs is maintained within the compliance register.

From time-to-time personnel will provide opportunities for staff to attend information sessions about mandatory reporting obligations. We also ensure that staff have access to relevant information resources available from:

Department for Child Protection Ph 8124 4185
https://www.childprotection.sa.gov.au/reporting-child-abuse

Department for Education SA Ph: 8226 1000
https://www.education.sa.gov.au/working-us
RRHAN-EC Mandatory Notification Training

Screening Website
https://www.sa.gov.au/topics/rights-and-law/rights-and-responsibilities

Phone: 1300 321 592

9.8 Child Protection is everyone’s responsibility. We recognise that even where a report is made, we may still have a role in supporting the child or young person. We ensure that support is available for any personnel making the report, particularly where an ongoing service is provided to the child, young person and their family.

Following a report to CARL or SAPOL we will support the child or young person by:
• Referring the child, young person or their family to other appropriate services
• Continuing to provide a service to the child, young person and their family and monitor their circumstances as appropriate.

9.9 After making a mandatory notification to CARL/SAPOL all personnel must report to management any reasonable belief that a child or young person is being harmed or is at risk of harm by other personnel. We have a duty of care to report any concerns about the behaviour of personnel to management even if they are not mandated notifiers under the Children and Young People (Safety) Act 2017 commenced October 2018.

If a worker is reported to CARL or SAPOL for causing harm or risk of harm to a child or young person, they will be removed from any role that involves working with any child or young person and removed from the organisation until authorities have conducted their investigation.

9.10 NDIS Reporting
NDIS Incident Management and Incident Reporting Rules 2018 are outlined in 1 Stop Health’s 2.7 Reportable Incidents and Management Policy and procedures. Personnel are provided with education and ongoing support to report incidents occurring during the course of service provision and any contact / involvement with children or young people.
Reportable Incidents
A reportable incident is;
• The death of a person with a disability;
• Serious injury of a person with a disability;
• Abuse or neglect of a person with a disability;
• Unlawful sexual or physical contact with, or assault of a person with a disability;
• Sexual misconduct committed against, or in the presences of, a person with a disability, including grooming of the person for sexual activity;
• The use of a restrictive practice in relation to a person with a disability, other than where the use is in accordance with an authorisation of a state or territory body in relation to the person.
All personnel will report ANY incident that occurs, in relation to the provision of services to a NDIS client to the Directors as soon as they become aware of it.
The definition of an incident includes any acts, omissions, events or circumstances that occur by our personnel/ consortium members or the person with a disability, in connection with the provision of supports or services by/through 1 Stop health, that have done; could cause serious harm, or risk of serious harm to either the person with a disability, staff or another person.

Procedural fairness will be afforded to the person with a disability, and all involved in the incident.

The Incident Management System will be made available to and complied with by all personnel of 1 Stop Health.

The Incident Management System will be accessible and available to consumers of 1 Stop Health and education provided on its use as necessary.

10. Reporting and responding to complaints or feedback

10.1 1 Stop Health Pty Ltd is committed to providing effective, accessible, transparent, and equitable services. We value feedback and complaints, having a commitment to maintain a positive complaints culture within the organisation. We value feedback and complaints from contractors, staff, customers (children and young people), carers, guardians and others involved with the person with a disability, as a positive at all levels. Feedback and complaints offer personnel opportunities to reflect, impact on our organisational reputation within the community and assist to drive organisational change and improve services, products and customer service.
We believe that people with disability, children or young people have the same rights as other members of the community to pursue grievances. People with disability may face multiple barriers to making a complaint or providing feedback about their support or services. These include lack of experience asserting their rights as consumers, fear of retribution, negative experiences with complaints systems (including not being believed) and difficulty communicating what happened without support. Additionally, in the case of harm or risk of harm, people can face substantial barriers to making a complaint. We aim to develop and implement feedback and complaints systems that support utilisation by people with a disability, are children or young people and are inclusive of their capacities, needs and support systems.
We are committed to consistent, fair, and confidential complaint and feedback handling to resolve issues as quickly as possible. We aim to make it easy for people to make a complaint or feedback if they have concerns / positives and will treat all customers making complaint / feedback equally.

10.2 We have a dedicated policy 2.7 Complaints and Feedback Handling Policy which is to be read in conjunction with this Policy and is an integral part of quality service provision to customers, children and young people.
We follow a complaints and feedback procedure which is clearly outlined and documented in all policy, procedures and information provided to our customers and follows the outline:
Procedure Complaints
1. Receive and record complaint
2. Acknowledgement
3. Assessment
4. Planning
5. Investigation
6. Response/Resolution
7. Follow-up
8. Review and consideration of systemic issues

10.3 All reasonable steps will be taken to ensure that:
A person who makes a complaint, or a person with a disability or child or young person affected by an issue raised in a complaint, is not adversely affected as a result of the making of the complaint. A risk assessment of client safety, harm or risk of harm associated with the complaint is made and appropriate actions implemented.

10.4 Referring Complaints
Complaints will be referred or notified to any other bodies in accordance with any requirements under relevant Commonwealth, State or Territory laws.

For example:
• Child protection agencies
• Work Health and Safety agencies
• Consumer Protection Agencies, and
• Medical or professional accreditation or monitoring bodies.
• NDIS Quality and Safeguards Commission

10.5 1 Stop Health Pty Ltd / contractor and individual allied health practitioner insurance bodies will be notified as required regarding complaints made and resolutions achieved.

10.6 If the person with a disability, child or young person are not happy with the outcome from the complaints process or if the complaint is not resolved to the client’s satisfaction, the Directors will advise the client that they have the right to contact other agencies to seek further resolution and provide them with details and assistance to access their options. These include the:
• NDIS Quality and Safeguards Commission 1800 035 544
Website: https://www.ndiscommission.gov.au/ – make a complaint link on site via the Complaint Contact Form
NDIA Reportable Incidents: reportableincidnet@ndiscommission.gov.au

• SA Ombudsman – ph: 08 8226 8699 or toll free 1800 182 150 or email: ombudsman@ombudsman.sa.gov.au
• Australian Government Office of the Privacy Commissioner for complaints relating to the Privacy act 1988 visit: http://www.oaic.gov.au/privacy/privacy-complaints

• Disability Advocacy and Complaints Service – ph: 1800 555 630

• Australian Health Practitioners Regulation Agency – ph: 1300 419 495 or https://www.ahpra.gov.au/ for online complaints process.

• Health and Community Services Complaints Commissioner – ph: 8226 8666

• Australian Human Rights Commission – ph: 1300 656 419 Online: www.humanrights.gov.au

• South Australian Equal Opportunities Commission (for complaints relating to discrimination) – ph: 08 82071977 Online: www.eoc.sa.gov.au

11. Risk Management

11.1 1 Stop Health Pty Ltd is committed to effective risk management as a strategy for protecting the organisation, customers and personnel from unnecessary injury, loss or damage relating to the business and activities the organisation undertakes.

We have in place a 1.6 Organisational Risk Management Policy, 1.6.1 Risk Management Registration Form and a 1.6.4 Business Risk Analysis Register. We also give consideration to NDIS requirements highlighted within the Client Reportable Incident and Management Guidelines 2018 and our 2.7 Client Reportable Incident and Management Policy. All personnel are required to read all associated policies and procedures.

11.2 To help maintain a safe environment for children, young people and those with disabilities, the organisation reviews its risks regularly and implements strategies to minimise and manage these risks.

11.3 Identified Risks

Identified risk: Culture of organisation is not child-safe focussed

Actions to minimise risk:
• child focused Code of Conduct is in place that sets the behavioural standards expected including what happens when a breach occurs.
• culture of management reflects our strong commitment to the safety of children and young people.
• the National Principles for Child Safe Organisations are embedded in policies and procedures.
• we meet the requirements of the Children and Young People (Safety) Act 2017 (which mandates child safe environments) and the Child Safety (Prohibited Persons) Act 2016 (which mandates Working with Children Checks)

 

Identified risk: Organisational workers harm children/young people

Actions to minimise risk:
• recruitment processes including undertaking referee checks to ensure the suitability of persons before they are employed/volunteer with our organisation.
• interview questions (no prior preparation) should gauge an applicant’s understanding of child safe principles and actions that would be taken to prevent harm to children and young people.
• all workers have WWCC with ‘not prohibited’ result prior to working with children and young people.
• WWCCs updated every 5 years and status remains as not prohibited.
• All personnel will have a NDIS Disability Worker Check with the appropriate clearance status.
• children and young people and their families have access to our Child Safe Environments policy and are given a copy of our complaints and feedback information sheets.
• Code of Conduct is displayed within the therapy waiting rooms

Identified risk: Organisational workers don’t understand their obligations to report harm and risk of harm to the Child Abuse Report Line (or SA Police if child/young person is at immediate risk)

Actions to minimise risk:
• all workers trained in Safe Environments – Through their Eyes on commencement and refresher training every 3 years after
• all workers trained in Responding to Risk of Harm and Neglect – Education and Care to level required for risk assessed roles on commencement and refresher training as required.
• all workers must abide by the child safe environments policy and Code of Conduct (latter is signed on commencement with organisation)

 

Identified risk: Physical contact

Actions to minimise risk:
• any physical contact must be appropriate to the delivery of services being provided.
• where physical contact is required, this is undertaken in a safe way by explaining why contact is required and what will happen and asking the child/young person for their permission (or their family if this is more appropriate) before proceeding.
• unnecessary physical contact is not allowed

 

Identified risk: Online communications

Actions to minimise risk:
• cyber safety and social media guidelines are in place and provided to all workers.
• appropriate supervision is provided for all online activities.
• workers must not communicate with children or young people via social media
Identified risk: Transport of children and young people
Actions to minimise risk:
• workers must not transport a child or young person unless specifically approved.
• parents/guardians must provide consent before transporting a child or young person.
• the worker must have a valid, unrestricted driver’s licence.
• the vehicle must be registered, insured and in roadworthy condition.
• a worker must not be alone in a vehicle with a child or young person

 

Identified risk: Supervision

Actions to minimise risk:
• children and young people are to be supervised by parents/guardians at all times.
• if child/young person not collected by parent/guardian at end of therapy, two adults are to stay with child/young person until they are collected.
• when providing one to one consultation with a child or young person, it will be in line of sight of another adult

 

Identified risk: Taking images of children and young people

Actions to minimise risk:
• formal written consent of child young person and their parent/guardian required.
• disclosure will be made as to how the image is to be used and consent must be provided by the child, young person and parent/guardian.
• images must be presented in a way that de-identifies the child or young person.
• images are stored securely as part of the child or young persons client documentation and is guided by privacy and confidentiality policies.

 

Identified risk: Physical environment

Actions to minimise risk:
• maintain a risk register that is reviewed annually to ensure effectiveness.
• conduct risk assessments for all activities.
• ensure all equipment is in good working order

 

Identified risk: Privacy and confidentiality

Actions to minimise risk:
• all documents containing confidential information will be stored privately in a locked filing cabinet (or similar place with restricted access)
• digital files containing confidential information shall be protected electronically by restricting the access to only those requiring it to perform their duties.
• workers must not disclose information regarding any child or young person without written / documented verbal consent of the child, young person and their parent/guardian – unless harm or risk of harm reporting requirements are met.

 

Identified risk: Off-site activities – DfE /school / day care / care facilities or community-based therapy activities

Actions to minimise risk:
• consent of parent or guardian must be given.
• when providing one to one consultation with a child or young person, it will be in line of sight of another adult.
• privacy when children or young people are bathing, toileting and dressing must be provided.
• children and young people will not be left under the supervision of unauthorised persons.
• children and young people have the right to contact their parents, or another adult, if they feel unsafe, uncomfortable, or distressed during the therapy session

Refer also to 1.6.4 Business Risk Analysis Register for additional general risks related to the provision of child and young people services.

12. Related Policy and Procedures

1.1 Organisational Overview
1.2 Organisational Chart
1.5 Organisational Development
1.6 Organisational Risk Management
1.7 Communication Policy
1.8 Information, Communication and Technology Policy
2.1 Service and Program Operation Policy
2.2 Client Clinical Management Policy
2.3 Client Access, Intake, Assessment Service Policy
2.5 Clinical Supervision Policy
2.6 Complaints Handling Policy
2.7 Reportable Incidents and Management Policy
3.1 Human Resources Policy Suite
4.1 Work Health and Safety Policy
4.3 Work Health and Safety Training Policy

13. Policy Compliance and Review
We will attempt to review this policy every 2 years as part of our Quality Assurance cycle but at a minimum, review this policy and the related procedures once every 5 years as required by the Children and Young People (Safety) Act 2017. We will also review this policy when:
• new or added risks are identified for children or young people, which may require a change in the policy or procedures.
• a critical incident where a child or young person has experienced harm through involvement in the organisation.
• concerns are raised by anyone involved in your organisation about child safety or welfare in the organisation.
• awareness or compliance to the child safe policy and/or procedures is low.
• legislative changes/requirements.

We will lodge a new child safe environments compliance statement with the Department of Human Services each time I/we review and update this policy. Documentation will be recorded as part of the Compliance Register.

Child and Young person Safe Environments Policy is authorised by the Directors.
Policy Date: March 2024
Review Date: March 2026 / 2029

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