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Child safety: Have your say on the NQF Consultation Regulation Impact Statement pt 2

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CELA has analysed the National Quality Framework Consultation Regulation Impact Statement (CRIS) which covers a wide range of areas for improvement on which your opinion is sought.

We are specifically seeking your feedback on three key areas, which are being covered in a series of Amplify articles.

In this, our second article of the series, we ask for your opinion on proposed changes to the NQF arising from the Royal Commission into Institutional Responses to Child Sexual Abuse. The opportunity we have is to align the NQF with the Child Safe Principles, and to introduce consistent record keeping to support children.

By Megan O’Connell, CELA Research and Policy Manager


The review of the National Quality Framework is a significant milestone in the quality journey for early childhood education and care.

The review commenced with an issues paper in 2019, but was placed on hold due to COVID-19. A Consultation Regulation Impact Statement (CRIS) has been released, which contains a wide range of issues on which your opinion is sought by the end of April.

Why your opinion is vital

Now is the time to ensure our sector is well placed to deliver on the vision contained in the NQF of continuous improvement in the provision of quality education and care, and improving outcomes for children.

In this Amplify we highlight key issues related to the Institutional Responses to Child Sexual Abuse which are being addressed in the NQF CRIS, and ask key questions on which we welcome your feedback. The opportunity we have is to align the NQF with the Child Safe Principles, and to introduce consistent record keeping to support children.

If you have something to say, please click on our survey link at the end of the article. You can answer as many or as few questions as you like. You are also welcome to complete the CRIS survey or provide a submission yourself.

Key topic 1: Embedding the National Child Safe Principles

There are a small number of gaps between the National Principles for Child Safe Organisations and the NQF. Key areas requiring strengthening regard volunteers, online environments including video surveillance and the role of organisational culture in reducing children’s exposure to the risk of abuse. Options proposed range from aligning assessment, requiring policies and procedures to meet the principles and amending the regulations to address the gaps.

CELA notes the importance of all organisations abiding by the National Child Safe Principles and of these principles being implemented in a consistent manner. Amending the regulations will increase the burden on providers, such as requiring volunteers to be aware of their child protection obligations, but this is outweighed by the added protection to children.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • How do you currently respond to the National Principles for Child Safe Organisations?
  • What costs or challenges do you foresee in implementing the Child Safe Principles?

Key topic 2: Updated record keeping requirements

The Royal Commission recommends that institutions retain records related to child abuse allegations or incidents for at least 45 years, and that records relevant to child safety and wellbeing are kept in an indexed, logical and secure manner.

Currently providers are required to keep records relating to incidents and allegations until the child is 25. Options proposed range from guidance on record keeping, to legislative change to store for 45 years, to requirements to store according to Royal Commission recommendations.

CELA is proposing that an alternative option may be for government to facilitate centralised record storage, for example of cases reported to the Office of the Children’s Guardian in NSW.

CELA notes that the requirement to store records for 45 years (or as otherwise specified by a Royal Commission) may have a significant cost imposition on services. It is important that all providers meet community expectations around record keeping standards and storage. However, given the high level of service transfers, name changes and closures that occur over an extended time frame, CELA raises the possibility of records being stored centrally.

Organisations such as the Office of the Children’s Guardian already receive records of serious incidents or accidents. Storing records centrally could maximise access to records over time and ensure systematic records management.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • How do you currently store older records related to abuse allegations or incidents?
  • What would be the cost of storing records for an additional 20 years?
  • Are there other options you can foresee that would assist in ensuring clear, accessible record keeping?
Have your say via this survey link

Workforce: Have your say on the NQF Consultation Regulation Impact Statement Pt 1

In last week’s Amplify we covered the topic of Workforce. If you haven’t had a chance to review and share your opinion yet, we invite you to read last week’s article and share your thoughts.

 

Share your views on Workforce
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