Demystifying Audit: Robust human resource management
Tuesday, 15 December 2020
Standard 5 – Robust human resource management
With the COVID restrictions finally easing and churches able to host larger in-person numbers, we are seeing a revival for many Church entities who have had to suspend their activities or move them online throughout the year. With this comes a potential for broader engagement between Church and community, including interaction with new parishioners, helpers and volunteers. As such, I thought it a good opportunity to discuss safeguarding practices as they relate to recruitment of personnel.
Specifically, three criteria are relevant here:
- 5.1 - Recruitment, including advertising, interview questions, referee checks and personnel pre-employment screening, emphasises child safeguarding;
- 5.2 - Relevant personnel (including all seminarians, clergy and religious) have current working with children checks or equivalent background checks; and
- 5.3 - Personnel receive an appropriate induction and are aware of child safeguarding responsibilities, including reporting obligations.
The following points should be noted:
1. The safeguarding message should be prominent from the beginning of the recruitment – i.e. for an employee role, the job advertisement should clearly state the organisation’s commitment to child safety and the requirement for personnel to abide by safeguarding policies, as well as directing the applicant to the website to read the entity’s safeguarding policies. For a volunteer role, the application form (online or paper) should also emphasise the commitment to child safety, the requirement to abide by safeguarding policies and a link to these policies.
2. The job advertisement or volunteer application form would generally include information about the responsibilities and duties of the role – i.e. a position description. The position description should clearly contain the requirement to abide by safeguarding policies as well as a comment on whether this particular position will require formal background checks such as a working with children check (WWCC) or a national criminal history check. NB: not all roles require these checks and it is a common misconception that all employees or all volunteers working for a Church entity need them. Too often we see Church entities enforce a blanket rule asking everyone to get a check instead of really thinking about the role and what safeguarding risks (if any) the role is exposed to. For example, it is generally not considered necessary for office employees who are not child facing, or for a volunteer who only reads at Mass in front of the community, to have a WWCC. In addition, for some roles, such as those employees or volunteers who have unsupervised access to finances, assets, keys etc. a national criminal history check may be a more appropriate check. We have created some guidance to assist Church entities to risk assess their roles from a safeguarding perspective, and determine which roles require which type of check. You can find the guidance here.
What is important is that there is a consistent rule applied for all similar roles throughout the church entity. We often recommend that the church entity creates a matrix of key/common roles and defines the safeguarding checks required for each role. In addition, the Church entity should ensure that where an individual already has a WWCC (perhaps obtained through another organisation), that the WWCC is linked to the Church entity upon commencement. This will ensure the Church entity is notified should the WWCC be subsequently suspended or withdrawn.
We also recommend that position descriptions for existing employees and volunteers be updated to include the commitment to child safety, the requirement to abide by the safeguarding policies and the type of check(s) required for the role.
3. Once the resume/application is received, the job of vetting/screening the individual for the role begins. This would involve a series of interviews/questions/referee checks commensurate with the role. Whilst this process is usually formally documented for employees, we also recommend that the vetting process is documented for volunteers. Questions and referee checks should cover the applicant’s suitability to work with children, as relevant to that role.
4. The successful employee/volunteer should receive a safeguarding induction upon commencement. This should not be an onerous exercise and does not require the full safeguarding training as required by Standard 7. The safeguarding induction could be as simple as having a checklist which you complete together with the new employee/volunteer and should cover the dot points noted in 7.1.2:
- Child safeguarding commitment statement and safeguarding policy;
- Code of Conduct;
- Complaints Handling procedures;
- Reporting obligations (including mandatory reporting and reportable conduct where applicable);
- Reference to any risk assessment conducted/relevant to the role; and
- Reference to e-safety and the expectations around use of technology and communicating/working with others online.
The Church entity’s safeguarding approach for recruitment should be documented in the recruitment policy or, if there is no recruitment policy, it could be included as an appendix to the child safeguarding policy. In addition to the safeguarding approach, the recruitment procedures should specify the action to take if a WWCC has lapsed (e.g. formal follow up with the individual, standing down from ministry etc) as well as a system to follow up any individuals who have not received the required safeguarding induction.
Finally, note that the NCSS require that relevant safeguarding records be kept for 50 years – this includes details of WWCC and screening checks for all personnel, including those who have left the organisation.
For more information, refer also to the support materials for Standard 5 on the CPSL website.
To begin discussing a safeguarding audit with CPSL and to obtain a copy of the Schedule 2, please contact Tania Stegemann, Director of Compliance – firstname.lastname@example.org or call 1300 603 411.