​​​1.  ​Purpose

1.1The purpose of this policy is to outline Brisbane Catholic Education's (BCE) approach to safeguarding students, and adults-at-risk, from abuse and exploitation.

1.2 This policy:

• adheres to BCE's obligations in respect of the United Nations Convention on the Rights of the Child and QLD and Commonwealth Government legal requirements including any child safe standards or similar obligations required by the State or the Queensland Education Non-State Schools Accreditation Board
• embodies the National Catholic Safeguarding Standards (NCSS) by operationalising the commitment of BCE as a Catholic Entity to ensure the safety of all who encounter BCE's educational services and Catholic faith community, including students and adults-at-risk. It satisfies criterion under Standard One of the NCSS and forms part of BCE's Safeguarding Response Plan
• operates under the auspice of the Archdiocese of Brisbane Safeguarding Framework
• is an enabler as part of BCE's Strategic Plan.

1.3  This policy applies to all:

• employees, contractors and volunteers (including clergy, religious) who engage with BCE offices or schools;
• BCE workplaces inclusive of activities, processes and services, coordinated by BCE while performing and in connection with work for BCE, whether those activities are in the workplace, away from the workplace, online or outside work hours.

1.4  This policy does not apply to BCE students as they are the recipients of BCE services, and their behaviour and responsibilities in safeguarding are addressed in appropriate student related policies and procedures.

2.    Policy Statement

2.1  Our vision and Catholic values call on us to safeguard those vulnerable to abuse and exploitation so they may engage in a successful and positive education and faith experience.

2.2  BCE has zero tolerance to all forms of abuse and exploitation.

2.3  In BCE the safety and wellbeing of students and adults-at-risk are paramount.

2.4  BCE's approach to safeguarding is both preventative and responsive. This approach seeks to:

• prevent abuse and exploitation, by embedding safeguarding practices across our operations
• enabling students and adults-at-risk to contribute to safeguarding policies, procedures and practices, seeking their views and ensuring their participation in decision-making processes that affect them

• enable a culture where it is safe for all to question conduct or practices that may pose a risk to safety and wellbeing and promptly recognise, react and report safeguarding concerns
  
• effectively respond to safeguarding concerns and those impacted, to minimise harm.
• comply with our reporting obligations
• enable BCE's Strategic Plan.

2.5  BCE's approach to safeguarding is underpinned by key principles which outline how we approach the safeguarding of students and adults-at-risk. These principles are embedded in the work of schools and all BCE function areas. Safeguarding principles are outlined in Annexure 1.

2.6. BCE embeds safeguarding in all aspects of governance, leadership and operations. Key governance roles collectively assume responsibility for the oversight of the implementation of BCE's safeguarding responsibilities and response to the National Catholic Safeguarding Standards. These governance arrangements and accountabilities for safeguarding are outlined in Annexure 2.

​2.7  BCE recognises that safeguarding is everyone's responsibility. BCE also has specific safeguarding roles across its schools and offices to provide subject matter advice and/or undertake the identified roles to protect students and adults-at-risk. Key BCE safeguarding roles are outlined in Annexure 3.

2.8 ​The following key documents support BCE's primary approach to protecting student and adults-at-risk from abuse and exploitation:

• Archdiocese of Brisbane Safeguarding Framework
• Catholic Education Archdiocese of Brisbane Code of Conduct (for Employees)
• Child and Youth Risk Management Strategy
• Code of Conduct for Volunteers and Other Personnel
• Employee Misconduct Procedure
• National Catholic Safeguarding Standards
• Pre-Employment Checks Procedure
• Recruitment Selection and Appointment Procedure
• Risk Management Policy/Procedure
• Student, Parent and Guardian Complaints Management Policy/Procedure
• Student Protection Policy/Procedures including the Student Protection Processes and Guidelines
• Workplace Bullying and Unlawful Discrimination Policy
• Workplace Investigations Procedure
• Workplace Sexual Harassment and Related Unlawful Behaviours Policy
• Working with Children Check (Blue Card Screening) Procedure.

BCE takes seriously any breach of this Safeguarding Policy and any policies or procedures related to safeguarding of students and adults-at-risk. A breach of this policy, or related policies and/or safeguarding practices, may amount to a breach of the BCE Code of Conduct, and may result in disciplinary action including termination of employment, contract or other form of engagement with BCE as appropriate.

3.    Associated Legislation and Documents

3.1 Legislation

• Child Protection Act 1999 (Qld)
• Criminal Code Act 1899 (Qld)
• Education (Accreditation of Non-State Schools) Act 2017 (Qld)
• Education (Accreditation of Non-State Schools) Regulation 2017 (Qld)
• Education (General Provisions) Act 2006 (Qld)
• Education (Queensland College of Teachers) Act 2005 (Qld)
• Privacy Act 1988 (Cth)
• Working with Children (Risk Management and Screening) Act 2000 (Qld)
• Working with Children (Risk Management and Screening) Regulation 2020 (Qld).

3.2 Related BCE Documents

• BCE Reconciliation Action Plan
• Catholic Identity Framework
• Code of Conduct for Parents and Visitors to our Community
• Employee Diversity, Equity, and Inclusion Strategy
• Health, Safety and Wellbeing Policy
• IT Acceptable Use Policy
• Managing Challenging Student Behaviour Procedure
• Molum Sabe Aboriginal and Torres Strait Islander Education Strategy
• People Policy
  
• Police Intervention in Schools Procedure
• Preventing and Responding to Student Bullying and Harassment Policy
• Records Management Policy and Procedure
• Workplace Complaints Procedure
  
• Student Diversity and Inclusion Policy
• Student Wellbeing Policy.

3.3 Other Relevant Documents

• National Principles for Child Safe Organisations
• United Nations Convention on the Rights of the Child
• United Nations Declaration on the Rights of Indigenous Peoples
• United Nations Declaration on the Rights of Disabled Persons

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4.  Definitions

​Adult-at-Risk (NCSS Ed, 2)	Means any person aged 18 years and over who is at increased risk of experiencing abuse, such as people: who are elderly with a disability who suffer from mental illness who have diminished capacity who have cognitive impairment who have suffered previous abuse who are experiencing transient risks who in receiving a ministry or service are subject to a power imbalance ​who identify as Aboriginal and/or Torres Strait Islander who are of diverse sexuality who have any other impairment or adversity that makes it difficult for them to protect themselves from abuse. who are from a culturally and linguistically diverse background
​Abuse (adult) (NCSS Ed, 2)	​For the purpose of this Policy, means the improper treatment of a person that results in the actual and/or likelihood of causing physical or emotional harm. Abuse can come in many forms, such as: physical or verbal maltreatment, neglect, injury, assault, violation, rape, unjust practices, crimes, exploitation, or other types of aggression. There are several categories of abuse of adults, such as: Sexual abuse Physical abuse Emotional/psychological abuse Neglect Elder abuse Financial abuse Exploitation. Within the context of the Catholic Church and faith-based entities, it is also important to recognise spiritual abuse1 as an additional subtype of abuse.​
​Abuse (child) (NCSS Ed, 2)	​For the purpose of this Policy, the definition of child abuse refers to any behaviour or treatment by parents, caregivers, other adults or older adolescents that results in the actual and/or likelihood of causing physical or emotional harm to a child. Such behaviours may be intentional or unintentional and can include acts of omission (i.e., neglect) and commission. Child abuse and neglect is commonly divided into five subtypes: physical abuse emotional/psychological abuse neglect sexual abuse exposure to family violence. The abuse may occur through online means.
​Contractor	​Means an individual or organisation engaged to perform work for a BCE school or office. A contractor is somebody who is not a school or office employee or worker. Contractors may include music instructors, sport coaches, canteen staff, IT consultant, technicians, cleaners, groundsperson, plumbers, painters, builders and other maintenance workers.
​Exploitation (NCSS Ed, 2)	​Is the deliberate maltreatment, manipulation or abuse of power and control over another person. It is taking advantage of another person or situation usually, but not always, for personal gain. It may include exploitation through online methods.​
​Safeguarding	​Means promoting the wellbeing of students and adults-at-risk and creating safe environments that protect them from abuse and exploitation. We do this through: student protection, wellbeing and participation expecting our people, operations, and activities to promote wellbeing and do no harm developing and maintaining systems and practices that prevent harm, alongside procedures to respond effectively to any concerns about safety and wellbeing enabling people to raise concerns or question conduct or practices that may pose a risk to safety and wellbeing complying with reporting obligations reviewing concerns or complaints to inform continuous improvement.
​Safeguarding Committee (NCSS Ed, 2)	​Means a committee established to advise and support the Church Authority (e.g. BCE) on all matters relating to safeguarding, including the development and implementation of a Safeguarding Implementation Plan and coordinating annual self-audits at a local level. Committee members need relevant and varied professional expertise in relation to safeguarding, child protection, organisational culture and structure, policy development or similar. The Committee includes lay women and men.
​Safeguarding Response Plan	​Means a documented plan which articulates actions to be taken across the entity to ensure safeguarding practices are in place. It includes actions, strategies, responsibilities, delegations, and accountabilities, and tracks review and progress. It is overseen by the Safeguarding Committee. It is a Safeguarding Implementation plan as referred to in the Catholic National Safeguarding Standards ed 2.​
​Safeguarding Culture (NCSS Ed, 2)	​Means embedding safeguarding into everything an organisation does. In promoting this culture, students and adults-at-risk will understand they will be listened to, supported, and know appropriate action will be taken on their behalf​
​Student	​Means any student enrolled at BCE regardless of their age.
​Student Protection	​Student Protection is the part of safeguarding. It includes BCE's structures, processes, practices and programs to respond to allegations and incidents of abuse, exploitation and risks of harm to students.​
​Student Wellbeing	​The processes and practices to support students to realise their own abilities to cope with normal stresses of life, to work productively and fruitfully, and to make a contribution to their community. Student wellbeing is seen as encompassing the following domains: spiritual wellbeing, psychological wellbeing, physical wellbeing, social wellbeing, emotional wellbeing, cognitive wellbeing and cultural wellbeing.
​Volunteer	​A volunteer is anyone who willingly works or ministers for free under the approval and direction of the school or BCE offices under an established agreement.​

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¹ Spiritual Abuse means abuse of a person that invokes a person's religious beliefs and faith to perpetrate harm. Spiritual abuse can occur as a secondary experience of abuse when abuse is perpetrated by someone in a position of spiritual authority and trust within the Church and can negatively impact a person's spirituality.

Document Control

Policy title:	Safeguarding Policy
Approver	Vicar for Administration
Delegation No.	7.6
Owner	Safeguarding Specialist
Date issued:	18/04/2024
Date review:	18/04/2027
Version No.	1.1

Annexure 1 – BCE's Safeguarding Principles​

BCE's approach to safeguarding is underpinned by the following principles:

• Child and people centred: Placing the child, and adult-at-risk, in the centre of our decisions and actions within our faith-filled educational communities.
• Prevention: The safety and wellbeing of students and adults-at-risk is a priority and systems and practices implemented across BCE are aimed at creating safe environments that eliminate and/or mitigate risks of abuse and exploitation. This means acting promptly on indicators of such incidents to minimise harm and analysing and reviewing learnings from complaints.
• Shared Responsibility: Safeguarding is everyone's responsibility including all employees, volunteers, contractors, students, parents and carers. BCE safeguarding practices enable everyone to name behaviour or practices that are inconsistent with the safety and wellbeing of students and adults-at-risk.
• Collaboration: Safeguarding is best informed by our continued engagement with parents/carers, students, ministries of the Archdiocese of Brisbane, survivors of abuse and external stakeholders. We actively engage with these groups about our safeguarding approaches and opportunities for continuous improvement.
• Participation: Students and adults-at-risk are informed about their rights and participate in decisions affecting them. Students will be listened to when they raise concerns about their safety and those concerns are taken seriously.
• Inclusive and Connected: Recognising diversity in our BCE community, supporting the involvement and participation of students, families and staff from diverse backgrounds through a deep understanding of cultural safety.
• Trauma informed: Prevention measures, and response to concerns and complaints are trauma informed.
• Risk Management: Risk assessment and management inform both the prevention strategies implemented and the process implemented to any report or complaint.
• Accountability: All suspicions, disclosures, complaints and incidents of abuse and exploitation are responded to effectively and reported as required to relevant authorities.
• Continuous improvement: A culture of feedback, review, learning and continuous improvement that is outcome focussed.

​Annexure 2 - BCE Governance Arrangements and Safeguarding Responsibilities

Archbishop of Brisbane - As the Local Ordinary, the Archbishop of Brisbane is the Canonical Steward for the Archdiocese of Brisbane. In addition, the Archbishop is the ultimate authority at civil law in relation to safeguarding in all ministries that operate under the auspice of the Archdiocese including BCE. The Auxiliary Bishops of the Archdiocese support the Archbishop in the exercise of his leadership across the Archdiocese.

For a detailed outline of safeguarding responsibilities held by personnel in the Catholic Archdiocese of Brisbane please refer to the Archdiocesan Safeguarding Framework under which this policy operates.

Executive Director of Catholic Education, Archdiocese of Brisbane

Upon delegation by the Archbishop, the Executive Director of Catholic Education is responsible for the oversight of the operation of the Catholic schools that make up the network known as BCE. The role of the Executive Director is to advance the mission of Brisbane Catholic Education which is to teach, challenge and transform through its service, support and leadership for Catholic education in the Archdiocese. A key function of this role is to oversee the implementation of the BCE Safeguarding Response Plan.

The Catholic Education Council - The Catholic Education Council provides strategic advice and recommendations to the Archbishop and the Executive Director of Schools on broad educational priorities and policies, as well as monitoring and reporting on the implementation of strategies and policies of BCE including the implementation of the BCE's Safeguarding Response Plan.

BCE Executive and the BCE Leadership Team - The role of the Executive and the Leadership Team is to promote a culture of safeguarding by encouraging and enabling early identification of behaviours or practices that are inconsistent with this policy. They are responsible for ensuring that safeguarding principles and BCE Safeguarding Response Plan are considered in organisational decision making and practices, and that BCE complies with its safeguarding civil and church legal obligations.

BCE Safeguarding Committee - It is the role of the BCE Safeguarding Committee to champion Safeguarding at BCE including oversight and monitoring of BCE's Safeguarding Response Plan and the effectiveness of BCE's safeguarding standards, policies, procedures and practices. The Committee reports to the BCE Executive on safeguarding matters and accountabilities.

Employees: The role of Employees is to promote safeguarding and model behaviours that support a safe culture and support the implementation, compliance with and continuous improvement of safeguarding standards, policies, procedures and practices.

​Annexure 3- Key Safeguarding Roles in BCE

Whilst Safeguarding is everyone's responsibility and every employee has responsibilities to protect students and adults-at-risk from abuse and exploitation, BCE has specific roles across its schools and offices to provide subject matter advice and/or undertake particular roles in protecting students and adults-at-risk. These include, although not limited to:

BCE Safeguarding Team – Provides leadership regarding the prevention and supports the response to abuse and exploitation of students and adults-at-risk. Advises Executive, Leadership and other stakeholders at BCE on the safeguarding of students and adults-at- risk including managing the implementation of BCE's Safeguarding Response plan and oversighting BCE's complaint handling procedures relating to safeguarding to ensure appropriate action is taken and continuous improvement.

BCE Employee Relations and Student Protection Team – Advises leadership and other stakeholders on the response and management of student protection concerns or breaches in the Code of Conduct that arise in a school or office context in order to support staff to meet reporting obligations and respond effectively to concerns of abuse or exploitation.

School Principals – Leads the development of a safeguarding culture in schools and ensures safeguarding requirements and practices are implemented effectively and any requisite reports made. Provides leadership regarding the prevention and response to abuse and exploitation of students and adults-at-risk in a school community.

Student Protection Contacts at each school – In accordance with the Education (Accreditation of Non-State Schools) Regulation 2017, each BCE school must have two Student Protection Contacts that receive reports from students regarding concerns about other student or adult behaviours towards the student and respond to those concerns.

BCE Harassment Contact Officer – Provides confidential support, advice and information to staff members who feel they have been the subject of workplace bullying, sexual harassment or discrimination at work.

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