Safeguarding Policy, Commitment Statement and Code of Conduct

This month we will discuss some items that are fundamental to safeguarding – the Safeguarding Policy, Commitment Statement and Code of Conduct.  These documents are key to compliance with Standard 1 of the NCSS but they also relate to specific Indicators in Standards 4, 5, 7, 8, 9 and 10!  So getting these right is very important as the adequacy (or otherwise) of these documents has significant flow on effects in terms of compliance with the NCSS.

Firstly, let’s talk about the Commitment Statement – this should be a relatively simple and brief statement of the entity’s commitment to safeguarding.  It should clearly indicate that the entity has zero tolerance to child abuse and ideally should be a standalone document that is provided in multiple formats (digital and print).  In addition to being easily accessible on the entity’s website, this document should be prominently displayed in the entity’s key locations (e.g. the diocesan or provincial office, in parishes/key ministries/premises, in retreats or holiday houses etc).  We also recommend that for those entities that have overseas ministries, or for parishes/ministries with a significant multi-cultural community, the commitment statement be translated into other languages as appropriate. 

In relation to the Safeguarding Policy, again, brief is better!  The most effective policies we’ve seen are those that state the key safeguarding requirements and intentions of the Church entity in the policy document (usually less than 10 pages) which is then supported by a number of appendices or support documents which go into more detail on key aspects of the policy such as risk management, recruitment, complaints handling etc.  The reason for this is to make the document user-friendly and accessible to all people. 

During an audit, we often find the following areas are missing or not adequately included in the Safeguarding Policy:

  • evidence that the Child Safeguarding Policy is specific to the context of the Church Authority and its operations.  This means including some descriptive information about the organisation in terms of charism, purpose, objectives etc which makes the policy more meaningful and relevant to the entity;
  • emphasising the zero tolerance approach to child abuse (this should be repeated from the commitment statement);
  • emphasising that the policy applies to all personnel – this includes clergy, religious, employees, volunteers and other relevant parties;
  • a description of the Church entity’s understanding and definitions of abuse – the NCSS glossary lists various categories of abuse; 
  • a statement which reflects an understanding of the diverse needs of all children – we usually look for specific wording such as that contained in Criteria 4.3;
  • reference to legislative reporting requirements, including a recognition of mandatory reporting and/or reportable conduct requirements; and
  • breach management processes (e.g. standing down from ministry, disciplinary action, dismissal etc) where the policy is breached. 

In relation to the Code of Conduct, this document should again be simple and straightforward and clearly outline the expectations of the entity in relation to both acceptable and unacceptable behaviours when dealing with children.  During an audit, we often find the following areas are missing or not adequately included:

  • emphasising that the Code applies to all personnel – this includes clergy, religious, employees, volunteers and other relevant parties.  NB: whilst some organisations have different Codes for clergy/religious and for employees/volunteers, we recommend this be avoided if possible.  The existence of “different” or special Codes of conduct for particular groups may inadvertently suggest that there are different standards of behaviour for different people, whereas a code of behaviour should apply universally to everyone in the organisation;
  • a statement which reflects an understanding of the diverse needs of all children – we usually look for specific wording such as that contained in Criteria 4.3;
  • guidelines on acceptable and appropriate use of technology and internet – this should include clear boundaries and acceptable/unacceptable behaviours for online conduct and communication between adults and children (including through email and social media) as well as requirements around taking, storing and using images of children (where relevant); ans
  • breach management processes (e.g. standing down from ministry, disciplinary action, dismissal etc) where the Code is breached.

The Safeguarding Policy, Commitment Statement and Code of Conduct should be disseminated to all personnel and should be key documents used for both safeguarding induction (for new personnel) and also as a key component of the general safeguarding training.  In particular the Code should be signed/acknowledge by all personnel, with records kept of this acknowledgment.  The documents should be easily accessible on the organisation’s website (less than four clicks to find them) and we also recommend a printed copy be available in key locations, as well as in parishes and ministries, so that those who don’t easily have access to the internet can still access these documents. 
Finally, the documents should be endorsed and promoted by the Church Authority and subject to regular review – at least on a three yearly cycle.  The review process should involve obtaining feedback from personnel on their understanding of the safeguarding policies and practices, including any obstacles or challenges in implementation, as well as consultation with children, families, carers and communities as appropriate.
 
For more information, refer also to the support materials for Standard 1 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 – tania@cpsltd.org.au or call 1300 603 411.