1. Purpose
This policy sets out the minimum safety framework and environments that Bloom Speech Pathology (Bloom SP) adheres to. It is written to demonstrate our strong commitment to establishing and maintaining child safe environments, and is aligned with legislation and children’s rights as set out in:
• The Children’s and Young People (Safety) Act 2017;
• Child Safety (Prohibited Persons) Act 2016;
• National Principles for Child Safe Organisations;
• The SA Office of Guardian for Children and Young People;
• Charter of Rights for Children and Young people in care; and
• The Council of Australian Governments, National Framework for Protecting Australia’s children

2. Scope
This policy applies to all employees and persons involved with Bloom SP, including employer, employee, students, children, young people, parents, guardians and families.

3. Policy Statement
3.1. Children and young people have the right to be safe from harm, grow up free of violence or exploitation, and develop physically, intellectually and socially with dignity.
3.2. Child Protection is the responsibility of the whole community. The community needs to provide safety systems and practices to minimise risks and respond appropriately when children have been harmed or are at risk of harm.
3.3. Bloom SP has a responsibility and moral obligation to support the health, safety and wellbeing of all children by taking reasonable care to protect children from foreseeable harm.
3.4. Bloom SP child safe practices are built upon risk prevention. The emphasis is on the child, young person or family receiving a service.

4. Policy
4.1. Families and those that we are delivering services to must understand how Bloom SP provides a child safe environment and our obligation to respond appropriately when children have been harmed or are at risk of harm. Families and the general public can access the Bloom SP Child Safe Environment policy via our website – www.bloomspeech.com.au.
4.2. Policy and Procedure Standards
4.2.1. Bloom SP staff have access to Bloom SP’s Child Safe policy and compliance is expected. Any breach is treated with utmost seriousness.
4.2.2. Bloom SP will assess potential sources of harm in human resource practices, record keeping, physical spaces and client activities and implement strategies to reduce risk.
4.2.3. Bloom SP staff are made aware of the importance of their own responsibility in upholding this policy and understand that they are mandatory reporters.
4.3. Child Safe Environments
4.3.1. A child safe environment is a safe and friendly setting where children and young people are protected and feel respected; valued and encouraged to reach their full potential; and are heard.
4.3.2. Bloom SP is guided by child safe environments in The National Framework for Creating Child Safe Environments whereby a child safe organisation consciously and systematically:
• Creates an environment where children’s safety and wellbeing is the centre of thought, values and actions.
• Places emphasis on genuine engagement with and valuing of children
• Commits to diversity whereby children and young people of different races, ethnicities, gender, sexual orientation, age, social class, physical ability or attributes and religious beliefs are respected and equity is upheld
• Creates conditions that reduce the likelihood of harm to children and young people
• Creates conditions that increase the likelihood of identifying any harm
• Responds to any concerns, disclosures, allegations or suspicions of harm.
4.3.3. As noted below in worker screening and recruitment practices and training, supervision and support. Bloom SP has created and maintains an open and aware culture where staff and children are aware of appropriate and inappropriate behaviour.
4.3.4. Bloom SP staff will ensure clear observation of child occupied areas through the following means:
• Inclusion of parent/guardian or primary support person (school staff, guardian) at all times unless there is a compelling reason not to do this
• Where the parent/guardian or primary support person is not present in the room, all doors are kept open and visual and/or at a minimum auditory monitoring must be ensured
• Where the above conditions are unable to be met for compelling reasons, an agreement must be written up with the parent that ensures appropriate measures are taken and a strategy is in place (for example: real time video monitoring or recording)
4.3.5. Prior consent is required for video or photo footage, and it will be stored securely and used purely for record keeping and assessment. See Privacy policy for further details.
4.4. Code of conduct
4.4.1. Bloom SP staff will comply with Bloom Speech Pathology Code of Conduct, a copy can be provided to clients and families on request. Refer to ‘Bloom SP Code of Conduct’ attachment.
4.4.2. Bloom SP staff will comply with Speech Pathology Australia’s Code of Ethics. Families can request a copy of this.
4.4.3. Bloom SP will apply with the Health Community Services and Complaints Commissioner (HCSCC) Code of Conduct for Certain Health Care Workers. A copy is displayed at our Clinic and in Employee Orientation Checklist.
4.4.4. Bloom SP staff will align behaviour with the Speech Pathology Australia Professional Standards https://speechpathologyaustralia.cld.bz/Speech-Pathology-Australia-Professional-Standards-2020
4.4.5. Bloom SP staff will also comply with policies and procedures of relevant external stakeholders (Catholic Education, DECD, Lutheran schools etc)
4.4.6. Bloom SP will follow any procedures recommended by child protection authorities, when dealing with any allegations of harm or risk of harm of children.
4.5. Worker Screening and Recruitment
4.5.1. Bloom SP will ensure that recruitment decisions are based on merit and the successful candidate is appointed with consideration to the skills and qualification required for the role.
4.5.2. Bloom SP will conduct face-to-face interviews where possible and complete reference checks.
4.5.3. Bloom SP will ensure that all workers understand their responsibilities by providing position descriptions and relevant information relating to guidelines from Speech Pathology Australia.
4.5.4. Bloom SP has the responsibility to ensure appropriate workers screening is completed during recruitment, is maintained during employment and compliant with the requirements of the Child Safety (Prohibited Persons) Act 2016.
4.5.5. All staff and volunteers (over the age of 14 years) working with children and young people must hold a valid ‘not prohibited’ Working with Children Check issued by the Screening Unit of the Department of Human Services. A DCSI clearance can be held until it expires then a WWCC from DHS must be obtained.
4.5.6. Blooms SP requires the following current documentation for staff –
• Speech Pathology Australia Membership, and as such staff will abide by the Speech Pathology Australia Code of Ethics.
• Australian Drivers Licence
• Working With Children Check (every 5 years)
• Reporting Abuse and Neglect (RAN – EC) training (every 3 years)
• Child Safe Training (every 3 years)
• Insurance – Professional indemnity Insurance and public liability insurance (yearly)
4.5.7. Bloom SP manage on-boarding of new employees through an Orientation Checklist.
4.5.8. Bloom SP will manage the ongoing employment relationship ensuring long-term fit through coaching, support and performance reviews.
4.5.9. Should any of the above registrations, memberships or insurances lapse, it may inhibit staff from performing the inherent requirements of the role and employment may be terminated.
4.5.10. Bloom SP will work with staff to develop procedures to ensure appropriate workers screening is maintained.
4.5.11. Bloom SP must notify the relevant government agency if during recruitment it is identified that a person has applied for a child related role who is deemed a prohibited person.
4.5.12. Bloom SP must only employ a person who is not a prohibited person and has provided a copy of the current relevant clearances.
4.5.13. A person must not apply for or remain in child-related employment if deemed a prohibited person and any staff member that becomes a prohibited person must inform the Director immediately.
4.6. Training and Support
4.6.1. Bloom SP staff need to learn about the nature of child harm and risk of harm and develop an awareness of how and why some children are harmed.
4.6.2. Bloom SP support staff to understand our child safe policies, mandatory reporting obligations, and their responsibilities to help create a child safe/friendly environment.
4.6.3. Support:
– Performance appraisals provide opportunity to discuss areas of concerns and evaluation
– Employee induction includes staff receiving copy of Child Safe Environment policy
– Supervision is provided to all employees through a variety of means including but not limited to; phone calls, work shadowing and face to face meetings
4.6.4. Training:
– It is compulsory for Bloom SP staff to undertake suitable child safe environment training. Reporting Abuse and Neglect (RAN – EC) and Child ‘Safe Environments: Through their eyes’ training must occur periodically on a regular basis ie every 3 years.
– Ensure staff read and have access to the Mandatory Notification Information Booklet (also included in employee checklist as part of employee induction)
– Professional development opportunities are encouraged to build knowledge and skills regarding the wellbeing and development of children and young people.
4.7. Mandatory Notification
4.7.1. Bloom SP supports mandatory reporting to appropriate statutory bodies.
4.7.2. Bloom SP employees are classified as mandated reporters under the Children and Young People (Safety) Act 2017. Employees can refer to the Mandatory Notification Information Booklet for further information.
4.7.3. Bloom SP will act thoroughly and quickly, with top importance placed on ensuring the safety and protection of children and young people.
4.7.4. Bloom SP staff are obligated to notify the Department of Child Protection via the Child Abuse Report Line (CARL) on 13 14 78 as soon as practicable if they suspect on reasonable grounds that a child or young person has been, or is at risk of being, harmed. If a child or young person is in immediate danger call SA Police on 000.
4.7.5. Reporting concerns:
1. Bloom SP staff will document any concern or incidents in the client file.
2. The Bloom SP staff member, using their knowledge from ‘Reporting Abuse and Neglect’ training will make a report to the Child Abuse Report Line as deemed necessary. They will complete the following template to support them with the process: Bloom SP mandatory-notification-record-template
3. Upon reporting, the Child Abuse Report Line team can provide information to the Bloom SP staff member about if, when & what to inform the family about.
4. Bloom SP will follow advice from CARL to support the employee and/or child or young person. This could include:
– Referral to appropriate support services eg. Kids helpline on 1800 55 1800 or youth helpline on 1300 13 17 19
– Continuing to provide a service to the child or young person and their family and monitoring their circumstances
5. Bloom SP staff will inform the director of CARL report

6. Bloom SP staff members have a right to take any action to ensure that children and staff are safe at all times. This may involve contacting the police if any person or family makes threats against staff.
7. Any person who believes on reasonable grounds that a child has been harmed or is at risk of harm may report their concerns to the Child Abuse Report Line. This means any person, including non-mandated licensed children’s services are able to make a report when they believe that a child or young person is at risk of harm and in need of protection.

5. Breach of Policy or Code of Conduct
5.1. If families believe there has been breach of in the policy or code of conduct, direct complaints are welcomed and Bloom SP will work to resolve the issue.
5.2. The Director can be contracted via phone (m.0421 839 335); email (hello@bloomspeech.com.au); or through the Bloom SP website (https://www.bloomspeech.com.au).
5.3. Alternatively, a complaint can be made to the South Australian Health and Community Services Complaints Commissioner (HCSCC) https://www.hcscc.sa.gov.au/about/hcscc-services/
5.4. Process
5.1.1 Where a breach of policy or Code of Conduct has been identified, Bloom SP will review the information provided regarding the alleged breach. If clarification is required, this will be sought by engaging with the person who initially identified the breach.
5.1.2 Bloom SP will meet with the employee to discuss the alleged breach and they will have an opportunity to respond to the allegation.
5.1.3 Bloom SP will investigate the alleged breach, which may include interviewing other parties identified within the breach.
5.1.4 At all times Bloom SP will remain impartial; review the facts; be fair, just and reasonable; and keep all parties informed of the progress of the investigation while maintaining confidentiality.
5.1.5 If deemed necessary Bloom SP will access performance management, which may include coaching, counselling issuing a written warning, or in serious cases, termination of employment.

6. Feedback and Complaint Handling
6.1. Bloom SP are committed to dealing with complaints and feedback promptly, sensitively and fairly.
6.2. All feedback and complaints will be dealt with in line with the Bloom SP Complaints Policy.

7. Risk Management
Bloom SP risk management plan identifies risks to children and young people and the strategies in place to minimise and manage those risks to help maintain a child safe environment. Refer to Risk Management Plan (Supporting Document).

8. Supporting Document
This policy must be read in conjunction with the following documents, policies and/or procedures –
Children and Young People (Safety) Act 2017
Child Safety (Prohibited Persons) Act 2016
The National Framework for Creating Child Safe Environments
Bloom SP mandatory-notification-record-template
Bloom SP Complaints Policy
Orientation Checklist
Speech Pathology Australia Code of Ethics
Mandatory Notification Information Booklet
Professional Standards for Speech Pathologist in Australia
Health and Community Servicers Complaints Commissioner Code of Conduct for Certain Health Care Workers
National Principles for Child Safe Organisations

9. Persons Responsible
9.1. Employees are responsible for:
• Ensuring understanding around what a safe environment entails and how to identify harm and risk
• Ensuring worker screening and probity documents are current and maintained
• Ensuring notification to Bloom SP if the status of worker screening or probity requirements change
• Comply with this policy, regulations and legislative guidelines
9.2. The Director is responsible for:
• Ensuring employees understand their responsibilities and rights under this policy
• Ensuring worker screening and probity documents are current and maintained
• Reviewing and updating this policy in line with legislative and best practice updates, which under the Children and Young People (Safety) Act 2017 is five years.
• Supporting employees in handling feedback and complaints
• Managing queries and complaints in line with this policy

10. Definitions
CARL – Means the Child Abuse Report Line, ph 131478, or online electronic notification through E-CARL at https://www.childprotection.sa.gov.au/
Client – any person for which Bloom SP provides a service
Mandated reporter – A person who comes within one of the categories set out in Section 30 (3) of the Child and Young Person (Safety) Act 2017, and so has an obligation to report a suspicion of a type described in Section 31 of the Act
Staff – refers to employees and volunteers of Bloom SP. Is used interchangeably with Employee and Workers.
Reasonable suspicion – A suspicion is a state of mind. It is different from knowledge or belief. It requires more than a guess but does not need to be sufficient to form a belief as to the existence of an event or circumstance. There does not need to be proof that a child or young person is, or may be, at risk. However, there needs to be a factual basis for the suspicion. The suspicion must be ‘reasonable’. Whether a suspicion is reasonable will depend on various factors, including the surrounding circumstances and the plausibility of the information available to the mandatory reporter. A mandatory reporter should consider the following:
– Was the information obtained in the course of his or her employment (noting that employment is broadly defined in the Act)?
– On the information available, does the reporter have a suspicion that something might happen or might have happened?
– If the reporter has a suspicion that something might happen or might have happened, is it reasonable to rely upon the information which causes him or her to have the suspicion?
The mandated reporter must form the reasonable suspicion alone. The suspicion does not need to be accepted and discussed with staff members, managers, or parents/carers. Whilst the mandatory reporter might like to talk through the circumstances with another person, ultimately it is the mandatory reporter who needs to be satisfied that they hold a suspicion.

11. Variation and Review
11.1. Bloom SP will review this policy every five (5) years, if new legislation is introduced, if legislation is changed or as a result of feedback, complaints or risk management; whichever comes first.
11.2. Bloom SP will lodge a new child safe environments compliance statement with Department of Human Services each time the policy is reviewed and updated.
11.3. Latest Review date: April 2022