Safeguarding Policy For Children In Australia

Do you actually need a written safeguarding policy if you run dance classes, tutoring, junior sport, school holiday workshops or kids parties?

Yes, you usually should have one. In many situations, your legal, insurance, venue or partner obligations will expect it. The good news is that a safeguarding policy for children in Australia doesn't have to be a giant folder that no one reads. It should be a practical set of rules your team can follow on a busy Saturday morning.

For kids activity providers, child safety isn't only about doing the right thing. It's also part of running a stable business: hiring the right people, managing casual staff, dealing with contractors, keeping parents confident and avoiding messy disputes if something goes wrong.

Let's look at how to turn child safe obligations into a policy that works in real life.

Do I Need A Child Safe Policy For My Kids Activity Business?

Yes, if your business works with children, you should have a child safe policy that explains how you prevent, identify and respond to risks to children.

A child safe policy is often called a safeguarding policy, child safety policy, child protection policy or working with children policy. The name matters less than what it actually does.

Your policy should cover children under 18 who attend your programs, classes, camps, events or online sessions. It should also cover every adult involved in your business, including:

Employees, including casual and part-time staff
Contractors, such as guest coaches, tutors, photographers or entertainers
Volunteers and work experience students
Directors and managers
Parents or helpers who assist with activities
Any third party you bring into the program

Even if you're a small provider, your legal risk can be similar to a larger organisation. A written policy also helps you show that your business took child safety seriously. Without one, you may struggle to explain what your rules were, what staff were trained to do and how an incident was handled.

What Child Safety Laws Apply In Australia?

It depends on your state or territory, the type of service you provide and who works with the children.

There isn't one single child safety law that applies in exactly the same way to every kids activity provider across Australia. Instead, you need to think about a few overlapping rules.

National Principles And Child Safe Standards

The National Principles for Child Safe Organisations set out the broad expectations for keeping children safe. Many state and territory child safe standards are based on these principles.

Some child safe standards are legally enforceable for certain organisations, while others may apply through funding agreements, council requirements, school contracts, peak body rules, insurance policies or venue hire arrangements.

For example, if you run a holiday program from a local council facility, your venue hire agreement may require you to have a child safety policy, verified Working With Children Checks and an incident reporting process. If you partner with a school, the school may ask for your policy before letting you run an after-school program.

Several jurisdictions have also been expanding child safe and reportable conduct schemes, including Queensland's new child safe scheme being phased in from 2025. If you operate across states, don't assume one policy automatically meets every local requirement.

Working With Children Checks

Working With Children Check rules are state and territory based. The name also changes. For example, Queensland uses the Blue Card system, while other states and territories use Working With Children Check or Working With Vulnerable People terminology.

The rules can differ depending on whether the person is paid, volunteering, supervising children, working frequently or only attending once. Some exemptions may apply, but they can be narrow.

Your policy shouldn't simply say that staff need a check. It should explain:

Who needs a check before they start
Who is responsible for verifying it
How you record the check details and expiry date
What happens if a check expires, is refused, suspended or cancelled
Whether interstate workers need a local check

Don't rely on someone showing you a card once at induction. In many systems, you need to verify the clearance with the relevant authority and keep evidence of that step.

Mandatory Reporting And Reportable Conduct

Mandatory reporting rules also differ across Australia. Some people must report suspected child abuse because of their role, and some states have broader duties for adults in particular situations.

Reportable conduct schemes may require certain organisations to notify a regulator about allegations involving workers and children. The regulator might be a children's guardian, commissioner or similar body, depending on the state or territory.

Your policy should tell staff who to report concerns to inside your business, when external reporting may be required and when to call police or emergency services. If the rules are unclear for your program, get tailored advice for your state and activity type.

What Should A Safeguarding Policy Include?

Your safeguarding policy should include the rules your team needs to follow before, during and after any child-facing activity.

A useful policy is specific enough that a casual coach or tutor can read it and know what to do. Avoid vague statements like we value child safety without explaining the actual behaviour you expect.

Your Child Safety Commitment

Start with a short statement that your business is committed to the safety, wellbeing and inclusion of children. If you work with Aboriginal and Torres Strait Islander children, children with disability, culturally and linguistically diverse families or LGBTQIA+ young people, say how your business supports safe and respectful participation.

Roles And Responsibilities

Name the person responsible for child safety in your business. This might be you, your operations manager or a senior program coordinator.

Your policy should explain who handles:

Screening and onboarding workers
Approving rosters and supervision arrangements
Receiving child safety concerns
Contacting parents or carers
External reports to police, child protection or a regulator
Record keeping and policy reviews

Recruitment And Screening

Your policy should set minimum screening steps before someone works with children. Depending on the role, this might include identity checks, referee checks, interview questions, qualifications, Working With Children Checks and declarations about any child safety concerns.

For casual staff, make the process simple but firm. No verified clearance, no shift.

Code Of Conduct

This is the part your team will use most often. Your code of conduct and broader workplace policy should set rules for:

Appropriate physical contact, such as spotting in gymnastics or correcting dance posture
One-on-one time with a child
Toilets, change rooms and closed-door spaces
Transporting children
Overnight camps or excursions, if relevant
Taking photos or videos
Social media and direct messaging
Gifts, favouritism and personal relationships
Language, discipline and behaviour management

For example, if your dance teachers sometimes adjust a student's arm position, your policy can say that physical contact must be necessary for the activity, brief, respectful, explained to the child and never done in a private space.

Reporting And Responding To Concerns

Your policy should give a clear pathway for concerns. Include what staff should do if a child tells them something worrying, if they see concerning behaviour, or if a parent makes a complaint.

Use plain steps such as:

Listen to the child and stay calm.
Don't promise secrecy.
Make sure the child is safe right now.
Tell the nominated child safety contact as soon as possible.
Make a written record using the incident form.
Contact police, child protection or a regulator where required.

If there's an immediate risk to a child's safety, your policy should say to call 000.

Records, Privacy And Confidentiality

Child safety records can contain very sensitive information. Your policy should explain where records are kept, who can access them and how long you keep them.

The Privacy Act 1988 may apply to your business, depending on your turnover, services and how you handle personal information. Even if your business isn't covered by the Privacy Act, parents, schools and venues will still expect you to handle children's information carefully, ideally under a clear children's privacy policy.

How Do I Manage Casual Staff, Volunteers And Contractors?

You manage them by making your safeguarding policy part of the way they're engaged, trained and supervised, not just a document sitting in a shared drive.

This is where many small providers get caught out. You may have a core team you know well, then a rush of casual instructors over school holidays. Or you might bring in a contractor for a specialist workshop and assume they have their own child safety processes.

Say Mia runs a junior dance studio in Newcastle. During school terms, she has four regular teachers. In January, she hires casual helpers for a holiday camp and books a guest acrobatics coach as a contractor. If Mia only gives the policy to her regular teachers, the highest-risk period of the year is the least controlled.

To avoid that, build child safety into your worker paperwork and onboarding.

Employment Contracts And Volunteer Agreements

Your employment contracts and volunteer agreements should require workers to comply with your safeguarding policy, code of conduct, privacy policy and reporting process.

They should also let you take practical action if a worker breaches child safety rules. For employees, that may include temporarily removing them from child-facing duties or placing them on paid suspension while you investigate, subject to the employment contract, any applicable award or enterprise agreement, and Fair Work requirements. Unpaid stand down should only be used where it's legally available. For volunteers, it may include removing them from child-facing activities.

If you employ staff, remember your obligations under the Fair Work Act 2009 still apply. Child safety concerns need to be handled carefully, fairly and consistently, especially if disciplinary action is involved.

Contractor Agreements

Contractor arrangements need extra care because contractors aren't managed in exactly the same way as employees.

Your contractor agreement should deal with:

Working With Children Check requirements
Compliance with your safeguarding policy while delivering your program
Insurance and qualifications
Reporting obligations
Limits on subcontracting
Use of photos, videos and children's personal information
Your right to remove the contractor from the program if there's a safety concern

Templates often miss these details. Your documents work best when they match how your program actually runs.

What Rules Should I Have For Photos, Messaging And Online Classes?

You should have clear rules for images, direct communication and online sessions because these are common risk areas for kids activity providers.

Parents may expect photos from a concert, grading day or holiday workshop. Staff may also want to message families quickly about scheduling. None of that's automatically a problem, but it needs boundaries.

Photos And Videos

Your policy should explain when photos and videos can be taken, who can take them, how consent is obtained and where images may be used.

If you use photos in marketing, get clear consent from a parent or guardian. Be careful with children in foster care, family violence situations or sensitive family circumstances where publishing a child's image could create a real risk.

Also think about the Australian Consumer Law. If you tell parents that photos will only be used for internal learning, don't later use them in ads without permission. Your marketing claims and your actual practices need to line up.

Messaging Children And Parents

Your policy should usually require staff to communicate with parents or carers, not directly with children, unless there's a clearly approved reason.

For older children, such as teen tutoring or representative sport, direct messages may sometimes be practical. If you allow them, set rules. For example, messages should stay on approved platforms, be about the activity only, avoid late-night contact and include a parent, manager or official group channel where possible.

Online Classes

If you deliver tutoring, music, coaching or fitness sessions online, your policy should cover:

Whether one-on-one sessions are allowed
Whether sessions are recorded
Who can access recordings
Expected clothing and background settings
Parent or carer presence for younger children
How to report concerning behaviour online

Online programs can be safe and effective, but the same child safe principles still apply.

How Do Venue Hire And Parent Terms Fit In?

Your venue hire agreements and parent terms should support your safeguarding policy, not contradict it.

If you use hired venues, check whether the venue requires particular child safety steps. Councils, schools, community centres and sports clubs may ask for copies of your Working With Children Check records, insurance certificate, risk assessment or child safe policy.

Your venue agreement should also be clear about practical issues such as access to toilets, shared spaces, change rooms, emergency exits and whether other groups will be using the venue at the same time.

Your parent terms and conditions should explain the safety rules parents need to know, such as:

Drop-off and pick-up procedures
Who can collect a child
Late pick-up fees or processes
Medical information and emergency contacts
Behaviour expectations
Photo and video consent
How parents can raise a concern

This helps avoid confusion at the exact moment you need everyone to know what the rule is.

How Do I Put The Policy Into Practice?

You put the policy into practice by turning it into repeatable systems your team uses every week.

A child safe policy is only useful if people know about it and follow it. Start with the highest-risk parts of your business and keep the process manageable.

A Practical Rollout Plan

Map when and where children are in your care, including online sessions, excursions and changeover times.
List everyone who may have contact with children, including contractors and volunteers.
Check the Working With Children Check rules for each state or territory where you operate.
Write or update your safeguarding policy and code of conduct.
Update employment, contractor, volunteer, venue and parent documents so they line up.
Train your team before they work with children.
Create simple forms for incidents, complaints, consent and check verification.
Review the policy at least annually and after any serious incident.

You don't need to make this overly corporate. A two-page code of conduct that your casuals actually read can be more useful than a 40-page policy no one understands.

Common Mistakes To Avoid

Assuming a Working With Children Check is enough. It's only one part of child safety, not the whole system.
Forgetting contractors. If they deliver part of your program, your standards should apply to them too.
Having no rules for one-on-one contact. Tutoring, coaching and make-up lessons often create private settings, so set boundaries early.
Letting photos become informal. Staff using personal phones can create privacy and control issues.
Not recording concerns. If a pattern emerges later, good records help you act quickly and fairly.
Copying a policy from another provider. Your venue, staffing model, age group and activities may create different risks.

Key Takeaways

If your business works with children, you should have a practical safeguarding policy that applies to staff, casuals, contractors and volunteers.
Child safe requirements in Australia come from state and territory laws, Working With Children Check systems, child safe standards, reportable conduct rules and your commercial agreements.
Your policy should cover screening, supervision, physical contact, online conduct, photos, reporting, record keeping and consequences for breaches.
Your employment contracts, contractor agreements, volunteer documents, venue hire terms and parent terms should all support your child safety rules.
A policy is only useful if you train your team, verify checks, keep records and review the process regularly.

If you'd like help with your safeguarding policy, worker contracts, contractor arrangements or parent terms, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.

Do Kids Activity Providers Need A Safeguarding Policy?