Child Safe Environments Policy

Introduction

Coastal Clarity Allied Health is committed to providing safe, welcoming, inclusive and child-centred environments in which children and young people are respected, heard, supported and protected from harm or risk of harm. Coastal Clarity Allied Health recognises that the safety and wellbeing of children and young people is a shared responsibility. The organisation takes a proactive and preventative approach to child safety and does not rely solely on responding after an incident has occurred.

Coastal Clarity Allied Health understands its legal, professional and ethical responsibilities to protect children and young people from harm or risk of harm and to respond appropriately when concerns arise. This policy establishes Coastal Clarity Allied Health’s approach to promoting child safety and wellbeing, identifying and managing risks, supporting the participation of children and young people, and preventing, recognising, reporting and responding to harm or risk of harm.

This policy supports Coastal Clarity Allied Health’s compliance with applicable South Australian child-safe environment requirements and aligns with the National Principles for Child Safe Organisations.

Purpose

The purpose of this policy is to establish and maintain a child-safe environment at Coastal Clarity Allied Health where the safety, wellbeing, rights and participation of children and young people are prioritised in all aspects of service delivery.

Coastal Clarity Allied Health is committed to:

Promoting the safety and wellbeing of children and young people and taking all reasonable steps to prevent harm or risk of harm from occurring within, through or in connection with services provided by Coastal Clarity Allied Health.
Developing and maintaining an organisational culture that prioritises child safety and wellbeing across leadership, governance, recruitment, training, professional practice, service delivery and risk management.
Identifying, assessing and managing foreseeable risks that may result in harm or risk of harm to children and young people.
Ensuring all employees, contractors, students, volunteers and other relevant persons understand their responsibilities for promoting child safety and for identifying and responding appropriately to concerns about the safety and wellbeing of children and young people.
Providing clear guidance regarding the appropriate response to concerns, disclosures, allegations and incidents involving harm or risk of harm, including circumstances arising within or outside Coastal Clarity Allied Health.
Ensuring children and young people are treated with dignity and respect, are listened to and are supported to participate in decisions affecting them in a manner appropriate to their age, development, communication needs and circumstances.
Promoting an inclusive and culturally safe environment that respects the diverse backgrounds, identities, abilities, cultures, beliefs and circumstances of children, young people and their families.
Maintaining clear expectations that abuse, neglect, exploitation, grooming, bullying, discrimination, harassment, inappropriate conduct and other behaviour that may place a child or young person at risk of harm are unacceptable.
Ensuring relevant workers understand and comply with applicable legislative and regulatory requirements relating to child safety, including Working with Children Check requirements and mandatory reporting obligations.
Ensuring concerns about the safety or wellbeing of children and young people are taken seriously and are appropriately responded to, reported, documented and managed in accordance with legislative requirements and organisational procedures.
Supporting a culture in which children, young people, families, carers, workers and other relevant persons feel safe to raise concerns, provide feedback or make a complaint about child safety and wellbeing.
Regularly reviewing and improving child-safe policies, procedures, practices, risk controls and training to support continuous improvement in the safety and wellbeing of children and young people.

Scope of Policy

This policy applies to all activities undertaken by Coastal Clarity Allied Health in connection with the provision of services to children and young people.

As a sole-trader practice, this policy primarily applies to the Founder / Business Owner and any contractors, students, volunteers, placement personnel or other persons engaged by Coastal Clarity Allied Health where applicable.

The policy applies across all service settings, including:

community settings;
educational or childcare settings;
home-based services, where provided;
online and telehealth services;
electronic and digital communication;
professional meetings and consultations; and
any other environment in which Coastal Clarity Allied Health provides or arranges services.

The policy applies to concerns arising during service delivery or from information received through observations, disclosures, communications, parents or carers, other professionals or other relevant sources.

Where another organisation controls a service environment, Coastal Clarity Allied Health will cooperate with that organisation’s relevant child-safe procedures while continuing to meet its own legal, professional and ethical obligations.

Child Safety, Wellbeing and Participation

Coastal Clarity Allied Health recognises that every child and young person has the right to:

feel safe and be protected from abuse, neglect, exploitation and other harm;
be treated with dignity, respect and fairness;
have their views listened to and taken seriously;
participate in decisions affecting them in an age- and developmentally appropriate way;
have their communication needs recognised and supported;
access services free from discrimination, bullying, harassment and intimidation; and
have a trusted adult or support person assist them to express concerns or make a complaint.

Children and young people will be encouraged, where appropriate to their age, development, communication style and circumstances, to express their views and preferences, participate in decisions about their services, ask questions, provide feedback, raise concerns and make complaints.

Communication will be adapted to the child’s individual needs. This may include visual supports, simplified language, alternative communication systems, additional processing time, interpreters, communication devices or involvement of a trusted support person.

Coastal Clarity Allied Health recognises that children and young people may communicate distress, discomfort or concerns in different ways. Developmental difference, disability, neurodivergence, communication difference or behaviour of concern will not be used as a reason to dismiss or minimise a possible indicator of harm.

Cultural Safety, Inclusion and Accessibility

Coastal Clarity Allied Health is committed to providing culturally safe, inclusive and accessible services.

Services will be provided without discrimination based on characteristics including disability, developmental difference, neurotype, race, cultural or linguistic background, sex, gender, gender identity, sexual orientation, age, religion or socioeconomic circumstances. Reasonable adjustments will be considered to support the participation, communication, safety and wellbeing of children and young people.

Coastal Clarity Allied Health recognises and respects the cultural identity, rights and needs of Aboriginal and Torres Strait Islander children and young people and is committed to culturally safe practice.

Communication and Access to this Policy

This policy will be communicated to relevant workers, children, young people and their families or carers through appropriate means.

This may include:

the Coastal Clarity Allied Health website;
service information or welcome materials;
direct provision on request;
discussion during service commencement where appropriate; and
staff, contractor or student induction and training.

The policy will be made available in an accessible format where practicable.

Children, young people and families will be encouraged to ask questions about the policy and how Coastal Clarity Allied Health promotes and protects child safety.

Workers will be informed of their responsibilities under this policy and relevant reporting obligations.

Code of Conduct

Coastal Clarity Allied Health maintains a separate Child Safe Code of Conduct that establishes expected standards of behaviour when working with children and young people.

The Code of Conduct addresses:

respectful and professional relationships;
professional boundaries;
physical contact;
one-to-one service delivery;
communication and digital communication;
privacy and confidentiality;
photography and recording;
unacceptable conduct;
responding to concerns and disclosures;
reporting obligations; and
consequences of breaches.

The Code of Conduct forms part of Coastal Clarity Allied Health’s child-safe framework and must be followed whenever services are provided to children and young people.

Recruitment, Screening and Suitability

Coastal Clarity Allied Health recognises that appropriate recruitment, screening and supervision are important child-safety measures. The Founder/Director will maintain a current Working with Children Check where required and will comply with applicable South Australian screening requirements. Where Coastal Clarity Allied Health engages contractors, students, volunteers or other workers who may work with children or young people, the Director will determine applicable screening, suitability, induction and supervision requirements before the person undertakes child-related work. Coastal Clarity Allied Health will not knowingly engage a person who is prohibited from working with children.

Where concerns arise regarding the suitability or conduct of a person engaged by Coastal Clarity Allied Health, appropriate action will be taken to protect children and young people and meet any relevant reporting obligations.

Training and Professional Development

The Director will maintain appropriate knowledge and training relating to child safety, mandatory reporting and responding to harm or risk of harm.

Training and professional development may include:

recognising indicators of harm or risk of harm;
mandatory reporting;
responding to disclosures;
professional boundaries;
child participation;
culturally safe practice;
trauma-informed communication;
online safety;
privacy and confidentiality;
complaints handling; and
risk management.

Relevant training will be refreshed at appropriate intervals and in accordance with applicable legislative, regulatory and professional requirements. As a minimum best-practice interval, child-safe-environment and mandatory reporting training will generally be refreshed every three years. Training records will be maintained where applicable.

Recognising Harm or Risk of Harm

For the purposes of this policy, harm includes physical or psychological harm, whether caused by an act or omission, including harm caused by sexual, physical, mental or emotional abuse or neglect.

Under the current South Australian framework, a child or young person may be considered to be at risk where they have suffered harm or there is a likelihood that they will suffer harm of a kind against which children are ordinarily protected.

Potential indicators of harm or risk of harm may include, but are not limited to:

unexplained or repeated injuries;
significant changes in behaviour;
fear of a particular person;
sexualised behaviour or knowledge that is inappropriate for the child’s developmental stage;
disclosures of abuse or other harm;
significant neglect;
inadequate supervision;
exposure to domestic or family violence;
exploitation;
persistent signs of emotional or psychological distress;
concerning online interactions; or
information received from another person indicating possible harm or risk of harm.

An individual indicator does not necessarily establish that harm has occurred. Concerns must be considered in context and in light of the child’s individual circumstances. Developmental difference, disability, neurodivergence, communication difference or behaviour of concern must not be used as a reason to dismiss or minimise a possible indicator of harm.

Reporting and Responding to Harm or Risk of Harm

Coastal Clarity Allied Health will comply with all mandatory reporting obligations that apply under current South Australian legislation and will respond promptly to concerns that a child or young person has been harmed or may be at risk of harm.

The Director and all persons engaged by Coastal Clarity Allied Health are responsible for understanding and complying with the child-safety and reporting obligations that apply to their role.

Where a person is a mandated reporter under the Children and Young People (Safety) Act 2017, they must report to the Department for Child Protection where, in the course of their paid or voluntary work, they suspect on reasonable grounds that a child or young person is, or may be, at risk of harm.

A mandated reporter does not need to be certain that harm has occurred or be able to prove that harm has occurred before making a report. A report must be made as soon as reasonably practicable after the required suspicion is formed.

Mandatory reporting is an individual legal obligation. A mandated reporter must make the report directly to the Department for Child Protection and must not delay a required report while waiting for approval, permission or confirmation from Coastal Clarity Allied Health, a parent or carer, another professional or another person.

Reports of suspected harm or risk of harm are made to the Child Abuse Report Line (CARL) on 13 14 78. CARL operates 24 hours a day, 7 days a week.

Serious concerns must be reported to CARL by telephone. This includes circumstances involving immediate or imminent danger, serious harm, serious injury or death, chronic neglect, certain concerns involving infants, abandonment or current lack of supervision, credible threats of serious harm, and certain concerns involving sexual abuse.

In an emergency, including where a child or young person is in immediate danger or requires urgent police or emergency assistance, 000 must be contacted.

For non-urgent concerns, a report may be submitted through the Department for Child Protection’s e-CARL online reporting system where appropriate.

Where a person is not a mandated reporter, they must still take concerns about the safety or wellbeing of a child or young person seriously and raise the concern with the appropriate person within Coastal Clarity Allied Health, where appropriate, and take any other action required by law, professional obligations or organisational procedures.

Nothing in this policy prevents or discourages a person from making a report directly to the Department for Child Protection where they are legally required or otherwise entitled to do so.

Coastal Clarity Allied Health will support workers to understand their individual responsibilities and will not prevent, discourage or retaliate against a person who makes a genuine child-safety report.

Where a report has been made, Coastal Clarity Allied Health will continue to consider the child’s immediate and ongoing safety and wellbeing and will provide appropriate support within the scope of its role, provided that doing so does not interfere with or compromise any statutory investigation.

Coastal Clarity Allied Health will follow current Department for Child Protection guidance regarding the appropriate reporting pathway and will comply with any directions provided by relevant authorities.

Responding to a Disclosure

Where a child or young person communicates a concern or discloses harm or risk of harm, Coastal Clarity Allied Health will:

remain calm and provide a safe and supportive response;
listen without interrogating;
allow the child or young person to communicate in their own way;
take the disclosure seriously;
acknowledge what the child or young person has communicated;
avoid leading, suggestive or unnecessary questions;
avoid promising secrecy or confidentiality that cannot be maintained;
explain, in an age-appropriate way, that information may need to be shared to help keep them safe;
record relevant information accurately and as soon as practicable;
assess whether a report or other action is required;
make any report required by law; and
follow directions from the relevant authority.

The child or young person will not be pressured to provide more information than they are voluntarily communicating and will not be expected to repeatedly recount their experience unnecessarily.

Concerns Relating to a Worker or Other Adult

Where a concern relates to the Director, contractor, student, volunteer, family member, professional or another adult involved with a child or young person:

the safety and wellbeing of the child will be prioritised;
any mandatory reporting obligation will be met;
relevant authorities will be contacted where required;
the person who is the subject of the concern will not influence the reporting decision;
relevant directions from authorities will be followed; and
appropriate interim safeguards will be implemented.

Where necessary, a person may be removed from child-related duties pending appropriate advice, assessment or investigation.

Coastal Clarity Allied Health will not conduct an internal investigation where doing so may interfere with a statutory investigation.

Complaints and Feedback

Coastal Clarity Allied Health welcomes complaints, concerns, suggestions and feedback from children, young people, families, carers and other relevant persons.

Children and young people and their families or carers will be informed that concerns may be raised verbally or in writing and that they may involve a trusted support person or advocate.

Complaints and feedback will be managed in accordance with the Coastal Clarity Allied Health Complaints, Disputes and Feedback Policy.

No person will be disadvantaged, threatened, intimidated or treated unfairly because they raise a genuine concern or make a complaint.

Where a complaint raises a concern about harm or risk of harm, criminal conduct, serious misconduct or another matter requiring external notification, Coastal Clarity Allied Health will take appropriate action and meet any applicable reporting obligations.

A complaint does not replace or delay a mandatory report where a legal reporting obligation exists.

Risk Management and Safe Service Delivery

Coastal Clarity Allied Health will identify and manage foreseeable risks to children and young people associated with its services and environments.

Relevant risk areas may include:

physical contact;
one-to-one service delivery;
professional boundaries;
physical environments;
online and telehealth services;
electronic communication;
photography and video;
privacy and confidentiality;
transport, where applicable;
community or home-based services, where applicable;
interactions with families and other professionals; and
inappropriate or unsafe behaviour by adults.

Risk controls will be proportionate to the service being delivered and will be reviewed when circumstances, services or identified risks change.

One-to-one professional service delivery is not, by itself, considered inappropriate. Coastal Clarity Allied Health will maintain appropriate professional boundaries, visibility and safeguards appropriate to the setting and service.

Digital and Online Safety

Coastal Clarity Allied Health will use digital communication and technology appropriately and professionally.

The organisation will:

use professional communication channels;
maintain appropriate professional boundaries;
avoid inappropriate personal or social-media relationships with children and young people;
consider the child’s safety, privacy and communication needs when providing telehealth or digital services;
protect electronic records and communications; and
obtain appropriate consent before photographs, videos or recordings are created or used.

Privacy, Confidentiality and Information Sharing

Coastal Clarity Allied Health will protect the privacy and confidentiality of children, young people and their families in accordance with applicable privacy law and professional obligations.

Information will be collected, used, stored and disclosed appropriately and securely.

Confidentiality does not prevent information from being shared where disclosure is required or authorised by law, including mandatory reporting and circumstances involving serious safety concerns.

Child-safety information will only be shared with persons or authorities who are authorised or legally entitled to receive it, or where disclosure is otherwise required or authorised by law.

Documentation and Record Keeping

Coastal Clarity Allied Health will maintain appropriate records relating to child-safety concerns, including where relevant:

concerns raised;
disclosures;
observations;
actions taken;
reports made;
advice received;
referrals;
follow-up actions; and
relevant communications.

Records will be factual, objective, accurate and stored securely.

Records should distinguish between:

information directly observed;
information provided by a child, young person or another person; and
professional observations or opinions.

Records will be maintained in accordance with Coastal Clarity Allied Health’s privacy, record-keeping and information-management requirements.

Supporting Children, Young People and Families

Following a child-safety concern or report, Coastal Clarity Allied Health will consider the child’s immediate and ongoing safety and wellbeing needs.

Where appropriate and lawful, this may include:

continuing appropriate services;
modifying service delivery;
referral to another service;
liaison with relevant professionals;
providing information or support to the family; and
following directions from the Department for Child Protection or South Australia Police.

Coastal Clarity Allied Health will not take action that could compromise a statutory investigation or increase risk to the child or young person.

Roles and Responsibilities

The Director is responsible for:

maintaining a child-safe organisational culture;
ensuring this policy is implemented;
maintaining required screening and training;
identifying and managing child-safety risks;
ensuring concerns are appropriately responded to;
complying with any mandatory reporting obligations that apply to their role;
maintaining appropriate records;
reviewing child-safe practices; and
ensuring relevant workers understand their responsibilities.

All persons engaged by Coastal Clarity Allied Health are responsible for:

following this policy and the Child Safe Code of Conduct;
maintaining appropriate professional boundaries;
promoting the safety and wellbeing of children and young people;
identifying and responding appropriately to concerns;
complying with any reporting obligations that apply to their role; and
raising concerns about unsafe practices or conduct.

Where a person has an individual mandatory reporting obligation, that obligation remains the responsibility of that person and must not be transferred to another person.

Protection from Detriment

Coastal Clarity Allied Health will not tolerate threats, intimidation, retaliation, victimisation or disadvantage against a person who raises a genuine child-safety concern, makes a complaint or fulfils a legal reporting obligation.

A person who makes a report in accordance with their legal obligations will not be disadvantaged by Coastal Clarity Allied Health for doing so.

Concerns about retaliation or inappropriate treatment following a report or complaint will be taken seriously and addressed appropriately.

Breaches and Non-Compliance

Failure to comply with this policy or the Child Safe Code of Conduct may result in appropriate action, which may include additional supervision or training, changes to duties, termination of engagement or other action appropriate to the circumstances.

Where conduct may constitute a criminal offence or create a risk of harm to a child or young person, the matter may also be referred to the relevant external authority.

Any response to an alleged breach will prioritise the safety and wellbeing of children and young people.

Policy Review

This policy will be reviewed at least every five years and earlier where required.

An earlier review may occur following:

legislative or regulatory changes;
significant changes to service delivery;
identification of new child-safety risks;
a serious incident;
a complaint or concern indicating a policy issue;
changes to relevant professional or regulatory requirements; or
other circumstances indicating that the policy requires amendment.

Where the policy or related child-safe procedures are reviewed and updated, Coastal Clarity Allied Health will lodge a new Child Safe Environment Compliance Statement as required.

Legislative Currency

This policy is based on the South Australian child-safe environment and mandatory reporting framework applicable at the time of approval.

As at the date of this policy, the Children and Young People (Safety) Act 2017 remains the legislation in force for mandatory reporting and child protection matters in South Australia.

The Children and Young People (Safety and Support) Act 2025 has received Royal Assent but has not yet commenced. Until that Act commences, Coastal Clarity Allied Health will continue to comply with the Children and Young People (Safety) Act 2017 and current Department for Child Protection guidance.

Coastal Clarity Allied Health will monitor relevant legislative and regulatory changes and update this policy when required.

When the Children and Young People (Safety and Support) Act 2025 commences, this policy will be reviewed and amended to reflect the new legislative requirements, including any changes to mandatory reporting obligations and thresholds.

Where there is any inconsistency between this policy and applicable legislation, the legislation will prevail.

Policy Statement

Coastal Clarity Allied Health is committed to creating and maintaining environments in which every child and young person is respected, heard, included and protected from harm or risk of harm.

Child safety is integral to the way Coastal Clarity Allied Health provides services, manages risk and makes professional decisions.

Where a legal reporting obligation exists, Coastal Clarity Allied Health and the individuals to whom that obligation applies will meet those obligations in accordance with current South Australian legislation and Department for Child Protection requirements.