Northern Territory Safeguarding Policy

1. Statement

1. 
   1. All people, regardless of their age, gender, race, religious beliefs, disability, sexual orientation,
   or family or social background, have equal rights to protection from abuse or harm.
   2. The St Vincent de Paul Society – Northern Territory (the Society) commits to promoting and
   protecting the wellbeing and human rights of people who interact with or are supported by the
   Society - particularly those that may be at higher risk of abuse, neglect or exploitation.
   3. The Society has no tolerance for abuse, neglect or exploitation. We will take a child-centred,
   trauma-informed approach and survivor-centred in our approach to managing reports and
   incidents.
   4. All members, volunteers, staff, contractors, consultants and third-party providers of the
   Society share responsibility for protecting children and vulnerable adults from abuse and
   harm. Beyond this, particular people have specific responsibilities, and they must carry out
   their safeguarding duties without exception.
   5. The Society will manage and reduce the risk of abuse and harm through background checks,
   screening, risk management, training and supervision and having policies and processes to
   manage incidents and reports of abuse or harm.
   6. The Society will ensure children, their parents/ guardians and vulnerable adults have access
   to information about the Society's policies and procedures in a format and communication
   style that is accessible to them.

2. Purpose

7. The St Vincent de Paul Society, Northern Territory (the Society) and SVDP Housing NT LTD
(Housing) are committed to being a Child Safe Organization and have zero tolerance for
abuse or harm towards children or vulnerable adults. This Policy outlines the Society and
SVDP Housing’s Safeguarding practices.
8. The purpose of this policy is to:
• Help protect people who interact with or are assisted by the Society
• Define the key terms we use when talking about protecting people or safeguarding
• Set out how the Society manages safeguarding risks and guides members, volunteers
and staff on how to implement the Society's Safeguarding practices
• Set out the specific roles and responsibilities of persons working in and with the Society,
regarding safeguarding
• Outline how the Society manages incidents and concerns of abuse or harm
• To support a positive and effective internal culture towards safeguarding.

3. Scope

9. This Policy applies to all Northern Territory and SVDP Housing NT LTD members,
volunteers and staff including Board members, contractors, consultants and third-party
providers.
10. For this policy, references to the Society mean St Vincent de Paul Society - Northern
Territory (the Society) and SVDP Housing NT LTD (SVDP Housing).
11. For the purpose of this policy, employees, contractors, consultants will be referred to as
staff or staff members.
12. The Policy applies to the Society’s and SVDP Housing services, programs, activities and
conference work, operations and other work as they involve engagement with children
(people under 18 years of age) or vulnerable adults (clients/companions over the age of
18), have access to client information, contact with family members of clients, community
members, members of the public (for example the Society's retail shops), and members,
volunteers and staff.

Equity and Diversity

10. The Society will ensure that all children, and vulnerable adults, with which we interact are
treated equally and respectfully by:
a) Promoting inclusive practices
b) Fostering an environment where everyone feels valued and supported
c) Ensuring equal access to resources, opportunities and support services
d) Promoting and understanding, acceptance and celebration of diverse
cultures, beliefs and perspectives
e) Implementing safeguarding measures for all individuals, taking into account
their unique needs and circumstances
f) Ensuring children, their parent/ guardians and vulnerable adults have access
to information about relevant Society policies and procedures in a format and
communication style that is accessible to them.

11. The Society recognizes the additional circumstances that may increase the risk of abuse
or harm in communities including:

a) Culturally and linguistically diverse communities (CALD)
b) First Nations Peoples
c) Those who are unable to live at home
d) Children and adults who identify as part of the LGBTIQA+ community
e) Children and adults with a disability, experiencing mental health conditions or
illness
f) People experiencing social or financial hardship.

Managing Safeguarding Risk
12. The Society manages the risks of safeguarding applying an approach that is:
• Holistic. The Society and members, volunteers and staff will work to prevent,
detect and take action on incidents

• Risk-based. The Society will regularly assess the risks to people in its
operations and develop controls to mitigate those risks
• Person- Centred, Trauma Informed and Survivor-centred. The Society
will put survivors at the heart of its approach to safeguarding
• Lawful. The Society will ensure that it understands and complies with the
law in everything it does.
13. The Society will manage the risk of safeguarding by:
• Having up-to-date and documented risk assessments to manage physical and
online risks
• Maintaining a register of the Society’s legal obligations for safeguarding,
workplace health and safety in areas in which it operates
• Considering the needs of children and vulnerable adults with additional
vulnerabilities, learning or cognitive difficulties or individuals who require
additional support
• Respecting the rights, independence, dignity and personal privacy of children
and vulnerable adults
• Implementing policies, procedures and systems that introduce controls to
reduce the likelihood and consequence of incidents
• Having safeguarding and incident management processes in place
• Monitoring and reviewing its safeguarding practices to ensure continuous
improvement and the effectiveness of its safeguarding approach.

Identifying abuse or harm of children or vulnerable adults
14. Abuse or harm includes all forms of physical, psychological and emotional abuse:
a) Any significant detrimental to the physical, psychological or emotional well-being or
development of a child
b) Sexual abuse, harassment or sexual criminal offences
c) Emotional or psychological including threats of, or actual violence, verbal, emotional
or social abuse
d) Physical abuse
e) Grooming
f) Systemic abuse
g) Cultural or identity abuse, such as racial, sexual or gender-based discrimination or
hate crime
h) Restrictive practices
i) Coercion and exploitation
j) Financial abuse
k) Neglect including concern regarding a parent or guardian's concern or failure to
access medical care
l) Abuse of power.
m) Abuse or harm may be a singular incident, multiple events or a pattern or behavior
including action and inaction.

Managing reports of abuse or harm

17. A concern about a child or vulnerable adult may be identified from:
• the observations of Society members, volunteers and staff
• the observations of another person or organisation
• a disclosure where a child or young person, or another adult, says something that
indicates that they or another child or young person may be at risk of harm.
18. The Society requires all members, volunteers and staff to report any concern of abuse or
harm to a child or vulnerable adult as soon as practicable and by the end of the day/ shift
to the Safeguarding Officer and their manager, supervisor or Conference President.

Child:

A child is any person/s under the age of eighteen years.

Vulnerable adults:

The Society considers all clients/ companions interacting with or engaging with the Society to
be vulnerable adults. The Society requires members, volunteers and staff to report:
• Any concerns related to Domestic or Family Violence including sexual assault
• Any abuse or harm that abuse or harm:
a) that is connected with the delivery of the Society's activities, programs,
or services occurred at:
o a Society premises, office, retail store, service, program or
o an off-site work location such as home visitation, community
visitation, day outings or
b) was perpetrated or alleged to have been perpetrated by a member of
the public (including family members or friends), Society members,
volunteers and staff or another client or an external service provider
c) is related to a child or vulnerable adult or involves domestic violence
and is disclosed to Society Personnel but did not occur at a Society
premises, office, retail store, service or program.
19. If a person wants to make an anonymous report about an allegation of abuse or
harm from a member, volunteer or staff member towards a child or vulnerable adult
they may:
• Report the concern anonymously under the Safeguarding children
and vulnerable adults Policy or
• Report under the Whistleblower Protections Policy.

External reporting

20. The Society will comply with its legal obligations, and external and contractual regulations
such as reporting any suspicion of a criminal offence to the Police or external regulatory
authority.
21. All adults in the Northern Territory, people aged 18 years and older, are legally required
to report concerns of abuse or harm of children to Police or the NT Child Protection Line
(Territory Families) and any Domestic, family and sexual violence to the Police.
22. Managers, supervisors and staff must ensure external reporting is completed.
23. Services and programs that are funded through Aged Care must manage and report
incidents and concerns of abuse or harm, according to the Society’s Safeguarding Policy and in line with Aged Care Legislation, Serious Incident Response Scheme and Aged
Care Quality Standards.
• Priority One Incidents- must be reported within 24 hours of becoming aware of
the incident. Priority One includes the following:
o a physical or psychological injury or discomfort that needs medical or
psychological treatment
o unlawful sexual contact or inappropriate sexual conduct
o the unexpected death of a person using aged care
o the unexplained absence of a person receiving care.
• Priority Two incidents- must be reported within 30 days of becoming aware of
the incident.
o Priority Two incidents are all other incidents.
• Refer to the Serious Incident Response Scheme for more information.

Participation and feedback

24. The Society recognizes that parents/ guardians have the responsibility for the safety,
well-being and development of their child.
25. The Society engages in partnership with children, vulnerable adults, parents/guardian
families, and communities to develop safe, inclusive and supportive environments by:
• Informing and supporting the participation of children and vulnerable adults in
decisions that affect them
• informing and supporting the participation of children and vulnerable adults
parents/carers, families, and communities, as appropriate on issues that affect
them such as safety issues and the Society’s policies and procedures
• ensuring information is available in a format and communication method
accessible to them
• engaging children and their parents/guardians in decisions affecting their child
or young person
• engaging with vulnerable adults and their representatives (as required) in
decisions that affect the vulnerable adult.

Recruitment and background checks

26. The Society will apply strict recruitment and screening processes to ensure that
members, volunteers and staff are suitable to interact with children and vulnerable
adults. The following will be implemented:
• Requiring a valid Northern Territory Working with Children Check (Ochre Card) prior
to commencement, must be renewed every 2 years
• Completion of National Criminal History Checks (Police Check) prior to
commencement and every 2 years or
• For Aged Care services, NDIS worker's screening may be accepted
• Requiring all candidates and existing members, volunteers and staff to notify the
Society if they have been charged with harm, abuse or exploitation offences, or
have allegations, charges and convictions against them
• Completing Safeguarding questions in all interviews

•Completing targeted behavioural and safeguarding questions in all referee
interviews.

Training and education

27. The Society ensures members, volunteers and staff receive training on:
a. Mandatory Safeguarding training
b. Safeguarding refresher training every 2 years
c. Complaints management
d. Code of Conduct training
e. Risk Management
f. Incident Management
g. Records management and information sharing responsibilities
h. Reporting obligations
26. The Society provides supervision, mentoring support or annual performance reviews
regarding the implementation of their responsibilities and the Safeguarding children and
vulnerable adults Policy, as appropriate for their role.
Privacy and record keeping
28. The Society will collect, retain, destroy and disclose information about children and adult
clients according to the Society’s Privacy Policy and in line with the Northern Territory
Information Act 2002, Northern Territory Care and Protection Act.
29. The Society complies with requirements according to the National Privacy Principles
and the Privacy Act 1988 (Cth) to protect the personal information it holds. The Society
is required to keep all records for a minimum of seven (7) years from the date it was last
accessed or until the person has reached twenty five (25) years of age, whichever is
longer.
30. The Society will ensure reports, investigations and information related to abuse or harm of
children are kept for a minimum of fifty (50) years from the time of the report, in line with the
National Catholic Safeguarding Standards.
31. The Society’s ‘Authorised information sharers’ may receive, share or be required to share
information about a child or young person to assist in the safety and wellbeing of the child
or young person. Refer to Part 5.1A of the Northern Territory Care and Protection of
Children Act.

Consequences of Non-Compliance

32. The Society requires its members, volunteers and staff to comply with:
a. state and federal laws and the Society’s policies
b. external regulations and standards
c. Society policies, procedures and Code of Conduct.
33. The Society takes misconduct and breaches of Society policies and reserves the right
to:
a. implement disciplinary action against those it believes are responsible, which
may include dismissal;
b. take civil legal action;
c. report the matter to law enforcement, as required.

34. Disciplinary action and termination will be managed in line with the Society’s Northern
Territory Disciplinary and Termination Policy.
35. The Society does not take responsibility for any personal fines or legal costs related to
failure to meet legislative reporting requirements.
Roles and responsibilities
36. While the responsibility to protect people is shared by all who work at or with them,
some individuals have specific obligations with which they must comply.
37. The members of the Board must:
a. Ensure the Society has effective and appropriate ways to manage safeguarding
and legal compliance
b. Promote a culture of Safeguarding of children and vulnerable adults
c. Ensure the Society complies with legislative requirements under the Care and
Protection of Children Act 2007 (NT), Domestic and family violence act 2007,
Aged Care Quality, Aged Care Act 1997 (Cth), and the Criminal Code Act 1995
(Cth) and other relevant legislation
d. Ensure that the Society takes a child-centred, trauma-informed and survivor-centred
approach.
38. The Chief Executive Officer of the Society must:
a. Ensure the Society has effective and appropriate ways to manage
safeguarding and legal compliance
b. Oversee the implementation of this policy
c. Ensure the appointment of a Safeguarding Officer with appropriate skills and
competency
d. Ensure that reasonable steps are taken to protect people
e. Promotes a culture of Safeguarding of children and vulnerable adults
f. Ensure that reports to external authorities are made where required
g. Approve external investigations, investigation reports and outcomes.
39. The Safeguarding Officer of the Society, the Chief Operating Officer (COO), must:
a. Oversee reports of abuse and harm
b. Ensure that all members, volunteers and staff are aware of relevant laws,
policies and procedures, and the Society Code of Conduct
c. Ensure that all members, volunteers and staff are aware of their obligations
to report suspected incidents of abuse or harm
d. Provide support for members, volunteers and staff in undertaking
their responsibilities.
40. Executives must:
a. Oversee internal and external reports of abuse and harm in their area of
responsibility
b. Ensure that all members, volunteers and staff receive training relevant to
safeguarding
c. Ensure that all members, volunteers and staff are aware of their obligations
to report suspected incidents of abuse or harm

d. Provide support for members, volunteers and staff in undertaking
their responsibilities.
41. All managers, supervisors and Presidents of the Society must:
a. Promote a positive culture towards safeguarding
b. Implement this policy in their area of responsibility
c. Ensure that there are appropriate controls in place to prevent, detect and
respond to incidents
d. Facilitate the reporting of any suspected abuse, neglect or exploitation
e. Manage incidents and reports appropriate for their level of responsibility
f. Take a survivor-centric approach to potential incidents and ensure that any
incident is dealt with transparently and accountably.
42. All members, volunteers and staff of the Society must:
a. Familiarize themselves with the Code of Conduct, the Society’s policies and
procedures including Safeguarding policies
b. Participate in the Society’s Safeguarding and induction training as required for
their role and seek clarification regarding their responsibilities, if required
c. Cooperate with the Safeguarding Coordinator to manage incidents or contribute to
investigations, as required
d. Report any concern about abuse or harm of a child or vulnerable adult to the
Safeguarding Coordinator and their manager, supervisor or President.
e. Provide an environment that is supportive of everyone’s emotional and physical
safety.
43. Members, volunteers and staff working with the Society's Aged Care Services must abide
by the Society's Code of Conduct and the Code of Conduct for Aged Care.
44. All partners and contractors of the Society must:
a. Implement the provisions of this policy and the Society’s procedures in their dealings
with the Society.
a. Report any concerns that an incident may have taken place or taking place.
45. The Society’s HR Team must:
a. Support Safeguarding Officer, Executives and local managers to address
allegations of abuse and harm from members, volunteers and staff to
children or vulnerable adults
b. Oversee and manage recruitment processes.

Related Legislation/Standards/Policies

Crimes Act 1900 (Cth)
Aged Care Act 2007, in force as of 25 March 2024 (Cth)
Aged Care Quality Standards
Business Continuity Policy
Code of Conduct Policy
Disciplinary and Termination Policy
Compliments and Complaints
Policy
Conflict of Interest Policy
Northern Territory of Australia, Care and Protection of Children Act 2007, as in Force 25
March 2024
National Principles for Child Safe Standards
National Catholic Safeguarding Standards
Privacy Policy
Records Management Policy
Risk Policy
Whistleblower Protections Policy
Workforce Screening and Suitability Policy