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Safeguarding policy

Introduction

The Great Aussie Bush Camp (GABC) is committed to being a best-in-class operator that ensures the safety, protection, and welfare of all our guests, including every child, young person, and adult at risk.

Our Commitment is to ensure that every child and young person has the right to be safe and protected. We believe that all young people have the right to grow and learn in an environment which is caring and nurturing.  We positively encourage all children and young people to succeed and celebrate their achievements, regardless of gender, race, sexuality, ability, or culture.

This policy sets out our commitment, expectations, and responsibilities for creating a child-safe environment, in compliance with relevant legislation across operating states (NSW, VIC, QLD) and the National Principles for Child Safe Organisations. It provides clear expectations on the procedures that should be adopted in the event of any employee suspecting a child, young person, or adult at risk may be experiencing, or be at risk of harm.

Scope

This Policy applies to all GABC employees, prospective employees and job applicants, as well as contractors, consultants, volunteers, apprentices/trainees, work-experience participants and third‑party partners engaged by or acting on behalf of GABC.  As a cohort, we refer to these stakeholders as workplace participants.  They must be made aware of this policy, and the requirement for them to act in accordance with it, for the period of their engagement.

This policy is applicable to any interaction employees have with other people in the workplace or through association with the workplace.

Definitions

Child / Children: Any person under the age of 18 years.

Young person: For this policy, includes anyone aged 15–17.

Adult at risk: An adult who is vulnerable due to a specific circumstance or need.

Child abuse: Any act or omission that endangers a child’s physical or emotional health, development, or wellbeing, including physical abuse, sexual abuse, emotional abuse, neglect, and exposure to family violence.

Grooming: Deliberate actions to establish an emotional connection with a child to lower their inhibitions for the purpose of sexual abuse.

Child-related work: Paid or unpaid work involving direct contact with children where that contact is a usual part of the role.

Working with Children Check (WWCC): A legal screening involving a national police check and review of findings to determine suitability to work with children in applicable states (e.g., NSW, VIC, QLD).

Mandatory reporter: A person legally required by law in their jurisdiction to report a reasonable suspicion that a child is at risk of significant harm.

Reasonable suspicion: A fair and practical reason to believe abuse has occurred, based on observation, disclosure, or credible information.

Designated Safeguarding Lead (DSL): The centre-based employee responsible for coordinating child protection matters, providing advice, and making appropriate referrals.

Workplace means where GABC’s work takes place, work-related locations (e.g., client sites, worksites, public spaces, remote sites) and places where workplace participants do things related to work, including outside normal working hours (e.g., conferences, social events, business trips and work parties).

The workplace is physical and virtual. It includes work-related interactions, written communication including letters, notes, minutes of meetings and all other physical communication, verbal communication either over the telephone or in person in and outside the workplace.  The use of  technology and social media even if workers are not using our resources – for example, work email, personal email, personal or work phone or mobile (including calls and SMS), personal social media account (e.g., Facebook, Twitter, Instagram or LinkedIn), personal or work video communication platforms (Zoom, MS Teams or Skype), work account on a chat platform (e.g., Slack or MS Teams) and a personal account on a chat platform (such as WhatsApp or Facebook Messenger).

Workplace participant means persons who work for us in any paid or unpaid capacity (including as a contractor or volunteer), as a job applicant or workplace visitors (including as a customer).

Our Child Safe Commitment

We prioritise the safety, wellbeing, and inclusion of all children. Specific consideration is given to the needs of vulnerable groups including:

  • Aboriginal and Torres Strait Islander children and Pacific children.
  • Children from culturally and linguistically diverse backgrounds.
  • Children with disabilities.

We endeavour to ensure diverse cultural perspectives are respected, while recognising that such differences do not diminish a child’s right to be safe or the organisation’s responsibility to protect the child from harm.

We actively encourage children to participate in decision-making, express their views, and know their rights.

We support our team to recognise and respond to child safety concerns confidently and appropriately.

We recognise that:

  • Safeguarding and child protection is Everyone’s Responsibility.
  • The welfare of the child, young person, and adult at risk is paramount.
  • Working in partnership with children, young people, adults, and their parents, carers, and other agencies is essential in promoting their welfare.
  • There is no place for extremist views of any kind within GABC.

We will endeavour to safeguard children, young people, and adults at risk by valuing them, listening to them, and respecting them.

We explicitly prohibit the use of corporal punishment and ensure all employees adhere to the GABC Code of Conduct.

Legislative Compliance

This policy and our practice at GABC comply with the Victorian Child Safe Standards, Queensland Child Safe Standards, NSW Child Safe Standards, and the National Principles for Child Safe Organisations.

We meet all required legislative requirements to keep children safe in each jurisdiction we operate within. This includes adherence to each state’s Working with Children Check (WWCC) scheme and the relevant Reportable Conduct Schemes (NSW and VIC currently, QLD when fully commenced).

The policy is based on, but not limited to, the following laws and regulations:

  • Children and Young Persons (Care and Protection) Act 1998 (NSW)
  • Child Protection (Working with Children) Act 2012 (NSW)
  • Children’s Guardian Act 2019 (NSW)
  • Child Wellbeing and Safety Act 2005 (VIC)
  • Working with Children Act 2005 (VIC)
  • Child Protection Act 1999 (QLD)
  • Working with Children (Risk Management and Screening) Act 2000 (QLD – Blue Card system)

Regardless of specific legislative reporting requirements for mandated reporters, All adults have a criminal law obligation to report known sexual offences against a child to the police. NSW also includes child physical abuse in these criminal laws.

Working with Children Checks

All GABC employees (permanent, casual, and temporary), contractors, and volunteers, regardless of whether they have direct or incidental access to children, must hold and maintain a current, valid Working with Children Check (WWCC) clearance appropriate to their role (e.g., a Paid WWCC clearance for all employees). All employees are required to link their WWCC to their employing GABC entity.

A Volunteer WWCC is only valid for unpaid child-related work and cannot be used for paid roles.

Code of Conduct

All team members, contractors, and volunteers must adhere to the GABC Code of Conduct.

They must:

  • Treat children with dignity, respect, and courtesy;
  • Act as positive role models;
  • Maintain professional boundaries;
  • Use appropriate language and tone;
  • Avoid situations where they are alone with a child unless necessary and approved within established safety protocols;
  • Report all concerns or breaches immediately to Head of People and Culture or General Manager.

Prohibited behaviours include:

  • Physical punishment, intimidation, or aggression;
  • Inappropriate touching or sexualised behaviour;
  • Private, unsupervised meetings or electronic communications with children outside of approved channels;
  • Exchange of personal contact details or social media connections with students/clients.

Recognising Abuse and Taking Action

We ensure and emphasise that everyone in our organisation understands and knows how to respond to concerns of abuse and neglect. If you have any concerns, it is important that you follow the reporting procedures outlined in the Responding to disclosures section of this policy.

GABC workplace participants have a moral & legal obligation to ensure that all children are safe from harm.

Child safeguarding concerns may arise in a range of ways. You may become aware of suspected or likely abuse because:

  • you have seen something
  • a child says they have been abused
  • somebody else has told you they are concerned
  • there has been an allegation against a team member
  • there has been an anonymous allegation
  • an adult has disclosed they are abusing a child
  • an adult has disclosed they were abused as a child

Also remember that you may not always be working directly with the child but may become concerned because of difficulties experienced by the adults e.g:

  • Peer domestic abuse incidents
  • Mental health issues
  • Substance and alcohol abuse incidents

Other concerns may be:

  • Children living away from home or who have gone missing
  • Peer abuse including bullying
  • Sexual harmful behaviours in children
  • Race and racism
  • Violent extremism
  • Sexual exploitation
  • Female genital mutilation
  • Forced marriage
  • Concealed pregnancy
  • Child trafficking
  • Online-safety

Responding to Disclosures

When a child discloses abuse:

  • Stay calm and listen carefully (Be patient and focus on what you are being told.  Try not to express you own views and feelings.  Allow them time to talk freely and do not ask leading questions).
  • Believe and reassure the child that they are being taken seriously and will be supported.  (Reassurance can be a big impact.  If they have kept the abuse a secret it can have a big impact knowing they have shared what has happened.)
  • Tell them it is not their fault, and they have done the right thing telling you – Abuse is never a child’s fault.  It is important they hear and this this.
  • Avoid expressing anger or shock about what happened.
  • Do not promise confidentiality you cannot keep; explain what you will do next and that you must share this information with the appropriate safety officer.
  • Only gather information the child freely provides; do not seek further details beyond those the child wants to discuss.  Write up your conversation as soon as possible in the child’s own words (verbatim) – stick to the facts, and do not put your own judgement on it.
  • Do not discuss with any other employees or with any accompanying adults.  However, if you consider the child to be at immediate risk of harm tell the Head of People and Culture or General Manager straight away.

Reporting Procedures

Safeguarding and child protection is Everyone’s Responsibility. All employees must report any reasonable suspicion of abuse or neglect immediately.

Reportable concerns include, but are not limited to:

  • Physical abuse
  • Sexual abuse
  • Psychological/Emotional abuse
  • Neglect
  • Grooming

All concerns need to be reported to the Head of People and Culture or the General Manager immediately.

  • Reports can be made in person, via phone (02 4997 3044), email (safeguarding@bushcamp.com.au), or in writing (PO Box 127 Tea Gardens NSW 2324).
  • All reports are treated confidentially during the initial stage.
  • Allegations are escalated to the Police and/or the relevant state Child Protection Hotline (e.g., 133 627 in NSW) where required by law or company policy.
  • Employees under investigation for abuse will be suspended immediately and removed from Centre pending the outcome of the investigation; employment will be terminated if found guilty by investigation or court.
  • GABC will also report all allegations against an employee, student, or volunteer to external oversight bodies (like the CCYP in Victoria) as required by legislation.
  • If employees have concerns about their direct supervisor, managers or child safety leads they should contact the CEO or the authorities.

Confidential Record Keeping

GABC will maintain confidential records of all child safety concerns, incidents or complaints, regardless of whether they are classified as reportable.

Documentation Requirements

  • Records must include detailed descriptions of the concern or incident, supporting evidence, and all actions taken.
  • This includes completed incident forms, reports to authorities, and any follow-up actions.
  • Notes and observations should be clear, factual, and non-judgmental.
  • Documentation must include dates, times, locations, and details of any conversations.
  • Reports must be accurate, impartial, and free from derogatory or emotive language.

Storage and Access

  • All hard copy and electronic records will be securely stored.
  • Access will be restricted to the Organisational Safeguarding Lead and/or their deputy.

Retention Period

  • In line with Royal Commission recommendations, GABC will retain these records for 45 years.
  • Records will also comply with any obligations set by funding bodies, where applicable.

Appropriate Contact Boundaries

  • No exchange of personal contact details or social media connections with students/clients.
  • Any attempt by a student to initiate contact must be reported immediately to a manager or Designated Safeguarding Lead.

Recruitment & Screening

We ensure all necessary checks are made during recruitment. All positions advertised will include GABC’s child safe statement:

“The Great Aussie Bush Camp is committed to ensure that every child and young person has the right to be safe and protected. We require all applicants who volunteer or work at The Great Aussie Bush Camp to undergo a screening process prior to appointment, a process that includes, but is not limited to, reference checks and a working with children check”.

Position Descriptions and Safeguarding Responsibilities

All roles will have a formal position description that clearly outlines their duties, responsibilities and child safeguarding requirements.

Recruitment and Interview Process

Interviews will include behavioural questions based on real-life situations, tasks, actions, and scenarios candidates have experienced. This approach helps recruiters assess whether applicants can uphold the organisation’s child safeguarding standards.

Employees involved in recruitment will receive training and ongoing support to carry out this responsibility effectively. We will also verify and maintain copies of all relevant certificates on file.

Consideration of Criminal History

GABC acknowledges that a criminal record does not automatically disqualify an applicant from employment. We consider legal restrictions on hiring certain ex-offenders and our obligations under the law. Disclosures may include spent convictions that are irrelevant to working with children; therefore, each case is assessed individually.

When evaluating whether to employ an ex-offender, we consider factors such as:

  • The nature and seriousness of the offence
  • When it occurred and evidence of rehabilitation
  • The sentence and any patterns of re-offending
  • Job requirements and safeguards in place to prevent harm

We document our assessment process, including any representations made by the individual.

All applicants undergo comprehensive reference checks (minimum two professional and two personal).

  • Personal referees must not be related to the applicant, must have known them for at least 12 months, and be able to speak to their suitability to work with children.
  • We require international police checks for all GABC Australia candidates who have worked or volunteered outside of Australia for a continuous period of more than 6 months during the past 10 years.
  • If pre-employment screening checks are negative and/or if GABC receive an updated report that contains concerning content, GABC will take the appropriate steps to ensure the employee does not pose a risk to children
  • GABC acknowledges that Working with Children Checks (WWCC) and/or Blue Cards alone do not assess someone’s suitability to work with children and must be considered in a suite of child safe recruitment strategies.

Training & Induction

Training is important to ensure that everyone at GABC understands that child safety is everyone’s responsibility.

GABC have a clear induction and training strategy detailing clear job descriptions, terms and conditions of employment, workplace participant responsibilities and all relevant procedures. Workplace participants receive safeguarding training throughout their career at GABC as part of their ongoing professional development.

All new workplace participants receive health and safety, and child safeguarding training as part of their induction and sign to record they have received and understood the training and documentation related to child safeguarding. All new colleagues will have a probationary review within the first month of employment and will then be observed and appraised at regular intervals throughout their period of employment. The Site Manager is responsible for ensuring this happens in line with GABC company policy.

All employees are provided with a copy of our Safeguarding Policy and the Code of Conduct, on commencement of their employment. They sign and agree to abide by this Code whilst employed.

We ensure at this early stage of employment that ALL new employees understand their obligations when working in a Child Safe organisation.

All employees participate in an induction process, which includes information sessions on Safeguarding and working in a Child Safe organisation. We ensure employees are appropriately trained in recognising and reporting safeguarding issues.

Throughout their employment, all staff members participate in regular reassessment and refresher training, during which safeguarding awareness is monitored, discussed, and evidenced. Constructive feedback is provided to each employee to ensure continuous improvement. This process supports all employees who work directly with students in consistently upholding the organisation’s Code of Conduct and Safeguarding Policy.

The Designated Safeguarding Lead (DSL) holds proactive responsibility for identifying training needs and for coordinating, administering, and delivering any additional safeguarding training required.

Contact Information

If you have any questions regarding this policy or wish to raise a concern, please contact your site manager, the Centre Based Designated Safeguarding Lead (DSL) on site, or the Operations Manager/Head of People & Culture via the details below:

Review and Updates

This policy will be reviewed annually, or in line with any key legislative changes, to ensure its ongoing effectiveness. The organisations Safeguarding Lead reports monthly on safeguarding as part of the business review with operating board members.

Right to Amend

The Company expressly reserves the right to amend or vary the Safeguarding Policy from time to time.  The Company will endeavour to take reasonable steps to notify staff of any significant change to this policy prior to the changes coming into operation.

This policy is entirely non-contractual and does not form part of the contract of employment. The Company reserve the right at its discretion to vary the full policy and review, update or withdraw as required.

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