Type: Policy
Classification: Operational
Policy Number: SCS2026019
Released: 29 June 2026
Review Date: 29 June 2029
Rescinds/Replaces: SCS2023025

1.1 Sydney Catholic Schools (SCS) is committed to ensuring the safety, welfare and wellbeing of all children and young people. This policy sets out the approach to identifying, responding to and reporting concerns of risk of significant harm (RoSH) and outlines SCS’s legislative obligations. It reflects a commitment to embedding child safety within leadership, governance and culture, supporting staff to understand their responsibilities in recognising concerns, sharing information appropriately, and maintaining accurate records to promote the safety and wellbeing of students, consistent with the NSW Child Safe Standards and the National Catholic Safeguarding Standards (Standard 1).

1.2 The policy seeks to:
1.2.1 recognise mandatory reporting to the NSW Department of Communities and Justice (DCJ) as central to the protection of children and young people,
1.2.2 ensure staff understand their legal and duty‑of‑care obligations in relation to the safety, welfare and wellbeing of students,
1.2.3 ensure staff recognise and respond to indicators of harm, and utilise appropriate information‑sharing mechanisms, and
1.2.4 provide guidance to staff when concerns do not meet the statutory threshold, including referral to internal and external support.

2.1 This policy applies to all staff and all staff are deemed to be engaged in child related work and this policy applies to:
2.1.1 all employees of SCS, whether or not they are employed in connection with work or activities that relate to children in a paid or volunteer capacity,
2.1.2 any person engaged by SCS to provide services to children and young people, and
2.1.3 all Religious and clergy, whether employed, on stipend, or in a volunteer capacity who are engaged in an SCS workplace or engaged in activities that relate to children and young people.

3.1 SCS acknowledges that employees who deliver educational services have legal responsibilities as mandatory reporters when concerns arise that a child or young person may be at risk of significant harm.

3.2 SCS is committed to:
3.2.1 responding to all concerns, current or historical, regarding child safety, welfare and wellbeing,
3.2.2 supporting staff in fulfilling mandatory reporting obligations to DCJ,
3.2.3 ensuring strong procedures for reporting, record keeping, and information exchange,
3.2.4 promoting early intervention, preventative practices and engagement with families,
3.2.5 providing appropriate support for students regardless of whether a statutory report is required and
3.2.5 ensuring that the child protection policies are accessible by families and the public.

3.3 Reports are made to DCJ when concerns meet the threshold of significant harm. Where the threshold is not met, SCS will consider alternative supports, including wellbeing referral pathways and external agencies.

4.1 A child or young person is at risk of significant harm when concerns for their safety, welfare or wellbeing exist to a significant extent. A matter is significant when it is not minor or trivial, and may reasonably be expected to produce a substantial and demonstrably adverse impact on the child or young person.

4.2 A child is a person under 16 years. A young person is a person aged 16-17 years. There are no mandatory reporting obligations for students 18 years of age. Concerns relating to students of adult age are to be addressed through a pastoral response or a referral to youth/adult services for support.

4.3 Risk of Significant Harm (RoSH) may arise from a single act or from accumulative harm associated with repeated lower‑level concerns.

Indicators of harm include, but are not limited to:
4.4 Physical Abuse: occurs when a child or young person suffers, or is at risk of suffering, non‑accidental physical injury. This may include:
4.4.1 bruising, cuts, abrasions, burns or fractures with unexplained or implausible explanations,
4.4.2 shaking, striking, hitting, kicking, choking, or other forms of physical harm, and
4.4.3 repeated injuries, particularly where patterns (accumulative harm) are evident.

4.5 Sexual Abuse: includes any sexual act or threat imposed on a child or young person. This may involve:
4.5.1 sexual touching, exposure, or penetration,
4.5.2 exploitation through pornography, grooming, coercion or manipulation,
4.5.3 exposure to sexualised environments, and
4.5.4 online exploitation.

4.6 Neglect: refers to a parent/carer’s failure to provide for a child’s basic physical or psychological needs, resulting in or placing them at risk of significant harm. Neglect may include:
4.6.1 Basic Physical Needs Not Met
inadequate food, shelter, clothing or hygiene, unsupervised access to dangerous environments or lack of supervision generally, abandonment.
4.6.2 Medical Neglect
failure or refusal to seek essential medical, dental or mental health care, and withdrawal of necessary treatments needed to prevent harm.
4.6.3 Educational Neglect
failure to enrol a child in school or ensure regular attendance in accordance with the Education Act 1990, and
persistent unexplained absences.

4.7 Emotional or Psychological Harm: occurs when a child experiences sustained, repetitive or egregious behaviours that undermine their emotional wellbeing. Examples include:
4.7.1 persistent rejection, hostility, humiliation or scapegoating,
4.7.2 exposure to behaviours that frighten or distress them,
4.7.3 excessive or unreasonable disciplinary practices, and
4.7.4 carers behaving in ways that result in serious psychological harm.

4.8 Domestic or Family Violence: places a child or young person at risk of serious physical or psychological harm when they are exposed to, or living in, a household where such violence occurs. Harm may arise from:
4.8.1 witnessing assaults,
4.8.2 being used as a shield or being inadvertently hurt, and
4.8.3 emotional distress caused by threats, coercion or controlling behaviour.

4.9 Carer Concern: harm may arise when a parent or caregiver’s behaviour compromises their ability to care for a child safely. These concerns may include:
4.9.1 problematic drug or alcohol use,
4.9.2 unmanaged mental health concerns,
4.9.3 inability or unwillingness to provide adequate care, and
4.9.4 relinquishing care of the child.

4.10 Danger to Self or Others: a child or young person may be at risk of significant harm where:
4.10.1 they pose a danger to themselves (e.g., self‑harm, suicidal behaviours), and/or
4.10.2 they pose a danger to other children or family members.

4.11 Accumulative Harm: arises where a series of lower‑level concerns accumulate over time to create a significant overall risk, even if individual incidents appear minor. Common indicators include:
4.11.1 repeated unexplained injuries,
4.11.2 chronic absenteeism,
4.11.3 ongoing exposure to conflict or stress, and
4.11.4 persistent failure to meet developmental needs.

4.12 Pre‑Natal Risk Factors: pre‑natal reports may trigger RoSH where:
4.12.1 the birth mother did not successfully engage with recommended support services
substance use, domestic violence or untreated health concerns place the unborn child at significant risk.

5.1 Under the Children and Young Persons (Care and Protection) Act 1998 (‘the Act’), SCS staff who deliver education services or supervise those who do so are mandatory reporters.

5.2 Mandatory reporters must report to DCJ where they have reasonable grounds to suspect a child or young person is at current risk of significant harm, based on concerns arising in the course of their work. While not all roles at SCS, including volunteers and central office staff are ‘legally’ designated mandatory reporters, any individual in these roles who provides information relating to RoSH to a mandated reporter, triggers a reporting obligation. The mandatory reporter must then refer the concern to the Principal.

5.3 Some concerns relating to alleged abuse by a staff member towards a child or young person may also fall under the Reportable Conduct Scheme and in addition to reporting risk of significant harm to DCJ, the SCS Reportable Conduct Policy will apply.

5.4 Mandatory reporting responsibilities do not generally extend to concerns arising in a staff member’s private life, although ethical responsibilities remain and consideration should be given to making a RoSH report to DCJ as a concerned member of the community.

5.5 All staff in face to face work with children must complete annual training in child protection which includes information about Mandatory Reporting obligations as mandated by the NSW Education Standards Authority.

6.1 SCS uses a centralised, structured approach to reporting RoSH concerns.

6.2 Identification and Initial Action
6.2.1 When a staff member identifies concerns through the course of their work about a child or young person that may constitute RoSH, they must immediately report the concerns to the Principal.
6.2.2 Although centralised reporting is in place to assist with comprehensive reporting, monitoring and support of children and young people, SCS staff hold an individual responsibility as a mandatory reporter regardless of the opinion of others and if they hold child protection concerns for a child or young person these should be thoroughly discussed with the Principal.
6.2.3 The Principal will promptly:

  • Use the Mandatory Reporter Guide (MRG) to determine whether the threshold for reporting is met, and/or
  • Consult with the SCS Child Protection Team for advice on (02) 9568 8298, or
  • Consult with the SCS Student Wellbeing Team for advice on (02) 9568 8485.

At the Principal’s discretion or in their absence, the reporting of RoSH may be delegated to another senior staff member, who will also follow the processes set out in this policy.

6.3 Making a Report to DCJ
6.3.1Where the threshold is met, the Principal will report to DCJ using the Child Story Reporter Portal or by phone to 132 111.
6.3.2 The Principal is the delegated mandatory reporter within SCS. In accordance with the MoU with DCJ, once a staff member has reported to the Principal, their mandatory reporting obligation is considered discharged.
6.3.3 A copy of the RoSH report must be provided to the SCS Child Protection Team by email to child.protection@scs.catholic.edu.au.

6.4 Students over the age of 18 years
6.4.1 Although SCS students over the age of 18 are not subject to the Act, staff should still respond to concerns by:

  • considering wellbeing supports,
  • providing assistance in accessing external services, and
  • assessing household risks to younger siblings

6.4.2 If an allegation or concern involving a student over the age of 18 constitutes a serious crime (indictable offence of 5 years imprisonment) then the mandatory reporting to NSW Police provisions in section 8 below apply.

6.5 Support for Students
6.5.1 If a staff member identifies a concern in relation to the safety, welfare and/or wellbeing of a student, the student will be provided with the opportunity to access appropriate supports which may include one or more of the following:

  • school based counselling where a local school counsellor is employed,
  • Student Wellbeing & Diverse Learning Team support,
  • referral to appropriate external support agencies for the student and/or family
  • risk assessment, and/or
  • return to school plan, counselling support plan, or Student Support Plan (SSP).

6.6 Informing Families
6.6.1 The Principal is not required to inform families when a report to DCJ has been made. Decisions should be based on guidance from SCS Child Protection and/or DCJ and consideration given as to whether informing the family would jeopardise the safety or wellbeing of the child or young person, or any other person involved.
6.6.2 At times it may be necessary for the School Counsellor or Principal to discuss with a student or their family, the concern which led to a mandatory report being made, in order to address ongoing risks occurring in the school or at home.

6.7 Protection for Reporters
6.7.1 Persons who make reports to the DCJ or institutions engaged in child related work under the Act are protected from liability for defamation and civil and criminal liability. The Act provides that such a report does not constitute a breach of professional etiquette or ethics, or amount to unprofessional conduct.
6.7.2 SCS strictly prohibits any form of detrimental action against individuals who, in good faith, make or intend to make a report under this Act. Detrimental actions include, but are not limited to, intimidation, harassment, discrimination, disadvantage, dismissal, or any form of prejudice in employment or service provision. Taking such actions, or even threatening to do so, can result in penalties including fines and imprisonment. Reports not made in good faith, characterised by bad faith or knowingly false material allegations, are not protected under the Act.

7.1 In addition to DCJ reporting, the Principal may be required to make a report to the NSW Police. In determining whether a report should be made to NSW Police, the Principal may contact the SCS Child Protection Team on (02) 9568 8298 or at child.protection@scs.catholic.edu.au.

7.2 The NSW Police should be contacted prior to DCJ where there is an imminent threat, danger or risk of immediate harm to any person, including to the child or young person, or to an SCS staff member, or any other person.

7.3 The circumstances in which a report to NSW Police should be made include, but are not limited to:
7.3.1 where a current or historical concern constitutes or involves a criminal offence, and/or
7.3.2 where there is an imminent threat, danger or risk of immediate harm to any person including to a child, young person or SCS staff member. In this case the Principal will make the report to Emergency Services via 000 where police attendance is required, as a matter of urgency,
7.3.3 where there is no imminent threat to any person, the Principal will contact the Police Area Command (PAC) to make the report and obtain an Event Number, and
7.3.4 other matters involving student education, intervention and general support can be reported to the police youth liaison officer.

8.1 Concerns regarding child safety must be treated as strictly confidential. Reporting staff must not disclose concerns outside the Principal (or most senior staff member onsite).

8.2 Reports made to DCJ or NSW Police are confidential and generally must not be shared without the approval of those agencies. This does not prevent the School Counsellor or Principal from having professional conversations with students or their families about the behaviors causing concern for the purpose of addressing ongoing risks to the child or young person.

8.3 Parents and carers of the child or young person for whom the concern has been raised, can not compel SCS to provide any information regarding the report. Families involved are to be directed to discuss such matters directly with DCJ and or the NSW Police.

8.4 The Principal may determine that a select number of teaching staff engaged directly with the child or young person require information about the RoSH to support their needs and address risk (for example, informing the classroom teacher or school counsellor).

8.5 SCS may exchange information in accordance with Chapter 16A where necessary to support a child or young person’s safety, welfare or wellbeing. Consent from the parent is recommended where safe and appropriate but is not mandatory. Information can be shared or requested to:
8.5.1 make a decision, assessment or plan, or
8.5.2 Initiate or conduct an investigation, or
8.5.3 provide any service relating to the safety, welfare or wellbeing of a child or children,
8.5.4 manage any risk to a child or class of children

8.6 RoSH reports are stored on Compass with the appropriate confidentiality restrictions applied.

8.7 The Principal is to maintain permanent records (never to be destroyed) of any RoSH reports to DCJ or reports to NSW Police securely in the student file.

9.1 Director, Safeguarding, Risk & Assurance
9.1.1 The Director of Safeguarding, Risk & Assurance is responsible for ensuring organisation-wide compliance with child protection obligations.This includes ensuring that safeguarding and child protection systems and operations in relation to addressing RoSH concerns within SCS is completed timely and compliant with legislation.

9.2 Principals
9.2.1 Principals are responsible for the development, implementation, culture building and publishing of Managing Risk of Significant Harm Policy in their schools or teams in accordance with this policy and any regulatory requirements. Principals are the delegated responsible person to report to DCJ when ROSH is identified. As referenced in DCJ MOU, all other Mandatory Reporters in their school community discharge their responsibility when notified to the principal.
9.2.2 Ensure that staff are aware of and understand the reporting, policies and procedures that inform and promote the protection of children and young people at risk within SCS.
9.2.3 Ensure any situation involving RoSH is treated with the utmost discretion, sensitivity and regard for the privacy and confidentiality of all persons involved.
9.2.4 Lead the school in fostering a culture which is proactive in responding to situations where a child or young person is at risk.
9.2.5 Ensure staff members receive annual professional development in relation to the indicators of child abuse and neglect, and information about the process for responding to concerns and mandatory reporting responsibilities.
9.2.6 Liaise with DCJ and other agencies as required.
9.2.7 Ensure that all exchanges of information in relation to children and young people’s safety, welfare or wellbeing comply with relevant legislation and guidelines.
9.2.8 Notify SCS Child Protection Team by email to child.protection@scs.catholic.edu.au when a RoSH notification is made to DCJ.

9.3 All SCS Staff
9.3.1 All staff are expected to be committed to understanding and complying with SCS Managing Risk of Significant Harm and Mandatory Reporting Policy by:

  • contributing to a culture where the student voice is respected, students are encouraged to raise concerns, feel safe and equipped to do so, and are able to report harm,
  • being aware of the indicators of child abuse and neglect, be observant for possible signs of abuse and neglect, including changes in the behaviour of children and young people that may be attributed to abusive situations,
  • responding appropriately to disclosures regarding abuse and neglect from children and young people,
  • complying with policies and procedures as required by this and related documents,
  • attending professional development and seeking support as required to facilitate the recognition and reporting of suspected risk of significant harm,
  • being willing to implement strategies and programs aimed at supporting children and young people at risk and establishing and maintaining a child-safe school environment within the scope of their role, and
  • reporting to the principal, manager or SCS Child Protection team if concerned about the Safety, Welfare or Wellbeing of any SCS student. Where concerned about sensitivity or confidentiality, please report directly to the SCS Child Protection team.

9.4 SCS Child Protection Team
9.4.1 Ensure mechanisms are in place so mandatory reports are made in a timely and compliant manner.
9.4.2 Provide advice and support to schools in relation to risk of significant harm concerns for students and families at risk.
9.4.3 Assist schools in using the online Mandatory Reporter Guide in determining whether concerns must be reported to DCJ Child Protection Helpline.
9.4.4 Liaise with DCJ and other agencies as required.
9.4.5 Ensure that all exchanges of information in relation to children and young people’s safety, welfare or wellbeing comply with relevant legislation and guidelines.
9.4.6 Deliver professional development to staff in relation to the indicators of child abuse and neglect, and information about the process for responding to concerns and mandatory reporting responsibilities.
9.4.7 Prepare reports for Executive Management and the Board about numbers and types of reports made by schools in relation to wellbeing concerns and students at risk of significant harm.

9.5 Parents and Carers
9.5.1 Must communicate with the school about any matters which pose a risk to the safety, welfare and wellbeing of a student.
9.5.2 Must seek information about reports directly from DCJ or NSW Police, and not the school.
9.5.3 Must engage positively with the school and Central Office staff to support a student, following any concern being raised around their safety, welfare and wellbeing, including in the development of Student Support Plans, medical and other assessments, counselling support and other recommendations.
9.5.4 Must work collaboratively and constructively with SCS in supporting the safety, welfare and wellbeing of all students.
9.5.5 Accept that upon enrolment to an SCS school, that SCS has mandatory reporting obligations for the safety and wellbeing of students and agree to respect and support SCS in meeting these obligations.

10.1 If you have any questions about the requirements set out in this policy, please contact the SCS Child Protection Team on (02) 9568 8298 or via email: child.protection@scs.catholic.edu.au.

10.2 This policy should be read in conjunction with:

  • Children and Young Persons (Care and Protection Act) 1998
  • NSW Crimes Act 1900 NSW
  • Children’s Guardian Act 2019
  • National Catholic Safeguarding Standards, Catholic Professional Standards Limited (2019) The National Response Protocol, Australian Catholic Safeguarding Limited (2021)
  • Child Safe Standards, NSW Office of the Children’s Guardian (2019)
  • Mandatory Reporter Guide

• Policy Number: SCS2026019
• Document Rescinds / Replaces: SCS2023025
• Date Released: 29 June 2026
• Review Date: 29 June 2029
• Policy Type: Operational
• Audience: Public
• Approved by: Executive Director
• Document Owner: Director: Safeguarding, Risk & Assurance

PRINTABLE PDF – MANAGING RISK OF SIGNIFICANT HARM & MANDATORY REPORTING POLICY