Do we really need more training for people working and volunteering with children? Isn’t abiding by Principle 7 of the National Principles for Child Safe Organisations enough?
The simple answer is no, it’s not enough.
Right now, it is easier to be trusted to work or volunteer with children than it is to pour a pint at the pub.
Principle 7 of the 10 National Principles for Child Safe Organisations requires staff and volunteers to receive education and training in knowledge, skills and awareness to keep children and young people safe. Since their development all Australian states and territories have implemented Child Safe Standards for Organisations who work with children and young people. These Standards aim to meet Principle 7 through compelling organisations to provide training to staff and volunteers in child safety. But the quality, content and delivery of training provided is unspecified, unmonitored, inconsistent, and in most cases, lacks lived experience insight, and a focus on children’s relational needs while also at risk of exacerbating inequalities in responses to children, particularly those from marginalised community groups.
Australian Childhood Foundation and Australians with lived experience of sexual abuse during childhood are calling for national Working with Children Check (WWCC and their equivalent) legislative reform. We believe states and territories can increase the safety of children and young people in their jurisdictions through introducing mandatory child abuse prevention and early intervention training for all new WWCC registrations and renewals.
While the WWCC will always be limited as a screening tool – most perpetrators of child abuse do not have a criminal record – the Check could become a powerful tool for child abuse prevention and early intervention by arming each registered adult working or volunteering with children with the information they need to keep children safe.
The Foundation has already had positive meetings with the Federal Government, as we call for federal funding and training development that each state and territory can legislate into their Working With Children Check. This would mean that mandatory training provided to WWCC holders will be consistent, of a high quality, developed alongside those with lived experience of child sexual abuse and will support a national harmonisation of WWCCs, as recommended almost ten years ago by the Royal Commission into Institutional Responses to Child Sexual Abuse.
In our reports, ‘Hear us Now, Act Now’ and ‘More than a check: Enhancing the Working with Children Check Scheme to strengthen the safety net around children’ from the Our Collective Experience Project, led by a Lived Experience Advisory Committee whose members and chair are people with lived experience of childhood sexual abuse we:
- detailed what some 350 adults with experience of childhood sexual abuse wished the adults around them had known, said, and done differently that may have kept them safe;
- found that those who work with children and young people today still do not have enough training or knowledge to know how to prevent, intervene with and respond to child abuse;
- highlighted no less than 37 media reports of adults in 2024 who worked with children and weres charged and/or convicted of sexually harming and abusing children and young people.1
- emphasised that because of the requirement of training and a passed test in order to obtain a Responsible Service of Alcohol (RSA) Certificate, it is easier to work and volunteer with children and young people than it is to serve alcohol to adults – currently there is no requirement for holders of a WWCC to be trained in the safety and protection of children; and
- argued for a nationally consistent mandatory training program about child sexual abuse (and other forms of abuse and violation against children and young people) be introduced as part of the application processes for WWCCs.
Children need us to do more. It is clear that the WWCC scheme is flawed in its capacity to protect children. It is, however, an existing platform that can be used to strengthen the protective perimeter around children. The WWCC approval process at present is purely administrative. Many WWCC holders do receive access to some training about child abuse but many others don’t or receive training of unknown content and quality that may fail to genuinely improve child protection. The government could ensure effective training through mandating its own through the Check, which could be built upon by institutions where WWCC holders work and volunteer.
Our research highlights the ignorance of WWCC holders to the tactics of perpetrators and non-verbal signs that children show us when abuse is occurring. Our research also highlights the limited capacity of WWCC holders to talk to children in ways that are developmentally appropriate about risk and safety. The language used by adults is often not understood by children such that even if an adult enquires about the safety of a child, the child often doesn’t understand the question being asked. Words like ‘hurt’ and ‘abuse’ can mean different things to children and/or not be understood at all. Adults rely too often on the child to disclose that abuse is happening despite evidence that most victims disclose some 20 years or more later, if ever.
Our research also highlights that available training more often focusses on the problem of abuse than the needs of children for relationships with safe adults and how to foster these. Without these relationships children are left at risk and alone, any abuse therefore left uncovered and unchecked.
More than 5.8 million adults in Australia hold a WWCC. The provision of mandatory training as part of the application process that addresses the limitations of current approaches identified by our research provides a critical opportunity to strengthen our protection of children.
So far, we have met with the offices of the Federal Attorney General and other relevant Ministers, as well as Federal Shadow Ministers, and state and territory Ministers relevant to Working with Children Check legislation.
The responses we have received have been primarily positive and supportive with our biggest success being NSW passing a motion that it will investigate how to reform its WWCC legislation to include mandatory child abuse prevention training, as well as that the NSW government will advocate to the federal government the importance of federal funding for the development of such training that can be nationally consistent.
However, one of the key challenges we have met during our discussions is the belief that the implementation of Principle 7 of the National Principles for Child Safe Organisations and its associated state and territory-based Child Safe Standards are enough and that nationally consistent mandatory training is unnecessary.
In this blog post, we outline:
- how Principle 7 and supporting Child Safe Standards have been implemented and are monitored in each state and territory;
- how our proposed reform to legislation governing Working with Children Checks (and their equivalents) can work toward addressing gaps and limitations that exist in each system and increase child safety.
Child Safe Standards by State
Victoria’s Child Safe Standards
Victoria implemented seven Child Safe Standards in 2016 and a further four in 2022. All organisations and groups who provide services or facilities for children or engages a child as a contractor, employee or volunteer, has a legal obligation to comply with the Child Safe Standards. Standard 8 of Victoria’s Child Safe Standards corresponds with National Principle 7 and states:
Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.
In complying with Child Safe Standard 8 organisations must, at a minimum, ensure:
8.1 Staff and volunteers are trained and supported to effectively implement the organisation’s Child Safety and Wellbeing Policy.
8.2 Staff and volunteers receive training and information to recognise indicators of child harm including harm caused by other children and young people.
8.3 Staff and volunteers receive training and information to respond effectively to issues of child safety and wellbeing and support colleagues who disclose harm.
8.4 Staff and volunteers receive training and information on how to build culturally safe environments for children and young people.
Victoria’s Child Safe Standards and compliance indicators are thorough, but limitations exist in their implementation and consistency. These include:
- The Child Safe Standards regulator, the Commission for Children and Young People, Victoria and its co-regulators2 do not provide organisations with accreditation. Instead, their roles in monitoring and compliance are reactive in that they respond to concerns or complaints made about an organisation or service.
- Regulators do not routinely assess the quality, content and/or delivery of training provided to staff and volunteers.
- Different organisations will have different capacities to produce and provide effective child safety training programs to staff and volunteers creating inconsistencies in care provided to children and young people.
Current minimum requirements and compliance indicators do not reference issues highlighted as important by people with lived experience of child sexual abuse, such as the necessity for adults to understand:
- The scale of the issue of child abuse types.
- How to promote children’s rights, voices, and autonomy.
- How to create safe relationships with children.
- How to talk to children about things that are important to them.
- The tactics perpetrators use to groom whole communities, not just children.
Introducing mandatory training within WWCC processes will enhance implementation of and compliance to Victoria’s Child Safe Standards by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, consistent and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
New South Wales Child Safe Scheme
NSW introduced new laws in February 2022 and created the NSW Child Safe Scheme. Under the Child Safe Scheme, certain child-related organisations3 in NSW must put into action the Child Safe Standards recommended by the Royal Commission into Institutional Responses to Child Sexual Abuse. All child-related organisations in NSW should apply the NSW Child Safe Standards to better prevent and respond to child abuse. The Office of the Children’s Guardian is responsible for regulating organisations that must comply with the Child Safe Scheme.
The NSW Child Safe Standards correspond with the National Principles with Standard 7 stating:
Staff are equipped with the knowledge, skills and awareness to keep children safe through continual education and training.
Organisations are advised to apply the standard by:
- Leaders provide ongoing education and training opportunities for all staff.
- Training provides staff with the knowledge, skills and confidence to prevent and identify abuse, and to respond to complaints.
- Staff who are involved in roles and situations with higher risk, or who work with vulnerable children, are provided with opportunities for more advanced training.
- Where possible the organisation employs a child safety officer who is responsible for training
- Training is regularly reviewed in response to emerging best practices.
- Conferences and other forums are attended to learn about improvements in child safe practices.In New South Wales, as within Victoria, compliance with the Child Safe Standards is not monitored and reviewed across all organisations by the Office of the Children’s Guardian (OCG). Although the OCG provides extensive resources and training for organisations to use, the content and quality of training organisations use for adults within child safe organisations is not set by the government. NSW is less prescriptive than Victoria regarding how organisations can effectively meet the Child Safe Standard related to training those who work with children. As with Victoria the NSW Child Safe Scheme, implementation guidance and resources are thorough, but limitations exist in their implementation and monitoring. These include:
- The Child Safe Scheme regulator, the Office of the Children’s Guardian (OCG) does not provide organisations with accreditation. Instead, their role in monitoring and compliance is enacted when the OCG finds that an organisation is not willing to meet the Standards. In these circumstances the OCG can:
- monitor and organisation’s use of the Standards;
- investigate concerns; and/or
- use their enforcement powers under the law.
- The OCG does not routinely assess the quality, content and/or delivery of training provided to staff and volunteers.
- Different organisations will have varying capacities to provide effective child safety training programs to staff and volunteers creating inconsistencies in care provided to children and young people.
- Current minimum requirements and compliance indicators do not reference issues highlighted as important by people with lived experience of child sexual abuse, such as the necessity for adults to understand:
- The scale of the issue of child abuse types.
- How to promote children’s rights, voices, and autonomy.
- How to create safe relationships with children.
- How to talk to children about things that are important to them.
- The tactics perpetrators use to groom whole communities, not just children.
Introducing mandatory training within WWCC processes will enhance implementation of and compliance to the NSW Child Safe Scheme by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
South Australian Child Safe Environment Program
South Australia has the Child Safe Environment Program4 which requires some organisations to develop child safe policies based on the National Principles and submit a compliance statement to South Australian Department of Human Services (DHS) via an online portal.
DHS also facilitates the Safe Environments Through Their Eyes training program for staff and volunteers of the following organisations and groups:
- allied health practitioners
- accommodation or residential services for children (including school camp providers)
- services provided by religious organisations
- childcare or child-minding services
- coaching or tuition services
- disability services for children
- commercial services provided directly to children (including face painters, photographers)
- sports
- transport services for children
- any other service or activity declared by section 7 of the Child Safety (Prohibited Persons) Act 2016.
This includes State authorities, non-government organisations, sole traders and people working in partnerships.
The Child Safe Environment Program within the DHS assess an organisation or service’s policies against the Children and Young People (Safety) Act 2017, the Child Safety (Prohibited Persons) Act 2016 and the National Principles for Child Safe Organisations. Organisations submit their compliance statement and provide supporting documentation such as policies and procedures. The Department of Human Services provides Safe Environments: Through their eyes (SE:TTE) training and guidelines to writing child safe policy and how to address the National Principles however:
- The Compliance Statement process is self-led and relies on organisation, groups and individuals working with children to register.
- It is only “recommended that organisations requiring staff and volunteers to work with children and young people attend training to understand their mandatory notification obligations.”
- Organisation have the option of providing their own child safety training.
- It is unclear if the compliance statement process requires organisations to provide the content of training provided to their staff and volunteers and whether the quality, content and/or delivery is assessed for appropriateness or effectiveness.
- It is also unclear if evidence of which or how many staff/volunteers have participated in training.
- The topics covered in the SE:TTE training has a strong focus on reporting obligations and protocols versus issues highlighted as important by people with lived experience of child sexual abuse, such as the necessity for adults to understand:
- The scale of the issue of child abuse types.
- Tactics used by those who abuse children.
- How to promote children’s rights, voices, and autonomy.
- How to create safe relationships with children.
- How to talk to children about things that are important to them.
Introducing mandatory training within WWCC processes will enhance implementation of and compliance to the South Australian Child Safe Environment Program by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
Tasmanian Child and Youth Safe Organisations Framework
Tasmania’s child safety legislation came into effect in 2024 with the commencement of the Child and Youth Safe Organisations Act 2023 (Tas). Tasmania has implemented 10 Child Safe Standards which align with the National Principles for Child Safety.
As with the National Principles Standard 7 states Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.
These laws establish the Child and Youth Safe Standards and the Reportable Conduct Scheme Tasmania. The Independent Regulator is the statutory body that oversees these frameworks.
Tasmania’s Child and Youth Safe Organisations Framework (the Framework) including the Child Safe Standards and the Reportable Conduct Scheme are part of the State’s response to the Royal Commission into Institutional Responses to Child Sexual Abuse. Tasmania further implemented the Independent Regulator to oversee these frameworks and to provide guidance, advice, education, training and resources to support organisations to follow the Framework.
Tasmania’s Commission of Inquiry into the Tasmanian Government’s Responses to Child Sexual Abuse in Institutional Settings made 191 recommendations which included:
- Registration to Work with Vulnerable People Scheme reform; and
- Implementation of professional development and training for adults working and volunteering with children and young people as a priority. The Independent Regulator’s is to support organisations in building their capability to “prevent, identify, and respond to harm to children and young people in a child-centred way.” It is independent from government and reports to parliament rather than a Minister. The Independent Regulator’s website states it:
- will assist organisations to comply with the Child and Youth Safe Standards including the Universal Principle and monitor ongoing compliance.
- will assist organisations to implement the Reportable Conduct Scheme and oversee investigations.
And regarding its enforcement, it has the powers to:
- request information or documents to determine whether an organisation is complying with the Child and Youth Safe Standards and/or Universal Principle
- enter premises without consent when it is deemed necessary to ensure the organisation is complying with the Child and Youth Safe Standards and/or Universal Principle
- issue a notice to produce information or documents within certain timeframes to determine compliance
- issue a notice to comply when the Independent Regulator believes on reasonable grounds that the organisation is not complying with the Child and Youth Safe Standards and/or Universal Principle
- issue infringement notices to organisations or individuals for non-compliance offences
- share information with anyone to protect and promote the safety and wellbeing of childrenIntroducing mandatory training within the Registration to Work with Vulnerable People Scheme processes will enhance implementation of and compliance to the Tasmania’ Child and Youth Safe Organisations Framework by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
Queensland
In September 2024 the Queensland Government passed the Child Safe Organisation Act 2024 which, in Schedule 1, sets out the categories of organisations and businesses that need to comply with the Child Safe Standards. In line with the National Principles and other states, Standard 7 states Staff and volunteers are equipped with the knowledge, skills and awareness to keep children safe through ongoing education and training.
Implementation of the Child Safe Standards will commence from 1 October 2025 and managed over a staged approach that spans until 2030. Alongside this is Queensland’s Reportable Conduct Scheme which will commence from 1 July 2026 and will be introduced through a staged approach, with all reporting organisations required to comply by 1 July 2027.
In early 2025 the Queensland Child Death Review Board announced it had formally commenced a review into system responses to child sexual abuse. The review will make recommendations for any improvements needed to the laws, policies, procedures and practices across the early childhood education and care, police and Blue Card systems (Queensland Working with Children Check).
The Queensland Family and Child Commission (the Commission) has oversight of the Child Safe Standards and Reportable Conduct Scheme. Its role is to support organisations to implement the standards and issue compliance notices if the Commission believes a child safe entity is failing to implement or comply with the child safe standards.
Currently all resources and training materials provided by the QFCC are accessed via links to resources developed by other states and territories.
Introducing mandatory training within the Blue Card system processes will enhance implementation of and compliance to the Queensland Child Safe Standards by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
Western Australia
Western Australia is yet to implement legislation, state-based Child Safe Standards or an independent oversight system. Currently the WA Department of Communities is working with other government agencies, the community services sector, peak bodies and other jurisdictions to drive the implementation of the National Principles for Child Safe Organisations.
The Commissioner for Children and Young People Western Australia also supports implementation of the National Principles through the provision of implementation guidelines and a self-assessment tool.
The Department of Communities is responsible for the administration of Working with Children Check processes under the Working with Children (Screening) Act 2004.
The Department of the Premier and Cabinet is leading the policy work to develop an Independent Oversight System for Child Safe Standards, which includes the monitoring and enforcement of the National Principles. However, this work does not appear to have progressed beyond sector engagement and a request for public comment via a survey in late 2020, early 2021.
Introducing mandatory training within the Working with Children Check processes will enhance implementation of and compliance to the National Principles for Child Safe Organisations by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
Australian Capital Territory
In the ACT, from 1 August 2024, amendments were made to the Human Rights Commission Act 2005 that made it mandatory for all organisations that provide services for children and young people to commence implementing the ACT Child Safe Standards Scheme (the Scheme). The Scheme has adopted the ten Child Safe Standards of the National Principles.
The Children and Young People Commissioner (CYPC) is supporting the implementation of the Scheme across by working with organisations and sectors. The CYPC currently provides limited information, resources, support, and training on implementing the Standards.
The CYPC’s website states that oversight of the Scheme’s implementation will be risk-based with a focus on education and capacity building rather than compliance and enforcement.
The CYPC does not currently provide training on child safety. Training for mandatory reporters on keeping children and young people safe is provided by the ACT Government. Mandatory reporting of sexual abuse and non-accidental physical injury is a legal requirement for some professionals and unpaid workers who work with children in the ACT.
The ACT’s Working with Vulnerable People registration is administered by the Community Services Directorate, ACT Government.
Introducing mandatory training within the Working with Vulnerable People processes will enhance implementation of and compliance to the National Principles for Child Safe Organisations by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.
Northern Territory
The Northern Territory has adopted the National Principles but has yet to implement any territory-specific legislation, standards, guidelines or support for organisations working with children. The Office of the Children’s Commissioner Northern Territory currently provides some information about the National Principles and Child Safe Organisations but does not speak to oversight or compliance. The Northern Territory has currently not implemented a Reportable Conduct Scheme.
Current links to information and resources are directed to the National Principles website.
Currently the Northern Territory’s Working with Children Clearance process administered by Northern Territory Police is the territory’s only mandatory form of increasing child safety in organisations.
Introducing mandatory training within the Working with Children Clearance processes will enhance implementation of and compliance to the National Principles for Child Safe Organisations by:
- Ensuring staff and volunteers enter organisations and community groups with a nationally recognised minimum standard of training that is lived experience-led, trauma-informed and expert developed, tested, and is recognised as international best practice.
- Enabling all adults who work and volunteer with children and young people, no matter where that is across the country, will have a base level of shared, foundational knowledge about preventing child abuse and keeping children safe, upon which child safe organisations can refresh and build upon.