Type: Policy
Classification: Operational
Policy Number: SCS2026020
Released: 29 June 2026
Rescinds/Replaces: SCS2023024
1.1 Sydney Catholic Schools (SCS) maintains a strict zero-tolerance policy regarding child abuse, neglect, and exploitation, fostering a culture where child safety is a paramount, shared responsibility. Grounded in Catholic faith values, SCS prioritises a physically, emotionally, and culturally safe environment through rigorous mandatory training for all staff and volunteers. This commitment is supported through compliance with the Children’s Guardian Act 2019 (NSW), the National Catholic Safeguarding Standards and the Office of the Children’s Guardian’s (OCG’s) NSW Child Safe Standards, ensuring that complaints and allegations of child abuse are responded to through clear, child‑focused processes that prioritise the safety, wellbeing and voice of children and young people.
1.2 The purpose of this policy is to establish the mandatory process that SCS staff must comply with in accordance with the requirements of the NSW Children’s Guardian’s Act 2019 (‘the Act’) in relation to reportable conduct. Information for students, parents and carers about making a complaint can be found in the Resolution of Complaints Policy.
2.1 This policy applies to all employees or workers within SCS including volunteers and contractors with child-related roles.
3.1 SCS is responsible and accountable for promoting a culture in which all employees uphold their duty of care to children and young people. SCS employees must:
3.1.1 maintain professional boundaries with students,
3.1.2 adhere to child-safe practices,
3.1.3 understand and comply with their reporting obligations, and
3.1.4 maintain practices in line with the NSW and Catholic Child Safe Standards.
3.2 SCS achieves this by ensuring that:
3.2.1 employees receive training regarding the reportable conduct scheme and SCS’ obligations to address allegations against staff,
3.2.2 employees are provided with clear instructions to follow when allegations are made, and
3.2.3 opportunities to prevent harm to children and promote safety and wellbeing are identified at an individual and systemic level.
4.1 SCS must comply with the Reportable Conduct Scheme (Scheme) set out in Part 4 of the Children’s Guardian Act 2019 (NSW).
4.2 Under this scheme, SCS must notify the OCG of any allegation of reportable conduct or reportable conviction involving an employee, regardless of whether the conduct occurred within or outside the workplace. SCS is also required to investigate and respond to all allegations of reportable conduct toward a child, including exempt allegations, in a fair and timely manner.
4.3 A child is defined as a person under the age of 18 years. Where a complaint relating to a student who is over the age of 18 years is made, a similar investigation process will be followed even though the Scheme does not apply.
4.4 The Scheme responds to matters where a child has been or may have been harmed by a person. Regardless of whether an allegation of inappropriate behaviour of staff toward a child reaches the threshold for reporting to the OCG, SCS takes all complaints seriously and responds in accordance with the Resolution of Complaints Policy.
5.1 Employee: is any person employed by SCS in a paid capacity, including:
5.1.1 any individual engaged directly or indirectly to provide services to children,
including staff on short term contracts,
5.1.2 volunteers,
5.1.3 parent volunteers who engage in child-related work, and
5.1.3 persons including clergy and religious engaged in ministry or school activities.
5.2 Head of the relevant Entity: The Executive Director of SCS is the Head of Relevant Entity (HRE) in respect of all legislative responsibilities pursuant to Part 4 of the Act for Catholic systemic non-government schools within the Archdiocese of Sydney.
5.3 Reportable Allegations: refers to an allegation that an employee has engaged in conduct that may constitute reportable conduct. The threshold for reporting a reportable allegation is intentionally low and is separate from the threshold for making a finding.
5.4 Reportable Convictions: refers to a conviction or finding of guilt (even without a recorded conviction) of an offence involving reportable conduct.
5.5 Reportable Conduct: section 20 of the Act defines reportable conduct as specific types of behaviour involving children under 18 years of age, regardless of whether the conduct occurred within or outside the workplace, and whether or not any criminal proceedings have commenced or concluded. Reportable conduct includes:
(a) a sexual offence committed against, with or in the presence of a child,
(b) sexual misconduct with, towards or in the presence of a child,
(c) ill-treatment of a child,
(d) neglect of a child,
(e) an assault against a child,
(f) an offence under section 43B (failure to protect) or 316A (failure to report) of the Crimes Act 1900, and
(g) behaviour that causes significant emotional or psychological harm to a child.
5.6 Exempt Conduct: Certain conduct is exempt from notification to the OCG under section 41 of the Act.
5.7 Exempt conduct includes reasonable physical contact for the purpose of discipline, management or care, and physical force that is trivial or negligible, provided that the matter is still investigated and recorded under workplace processes. In these circumstances, SCS is not required to provide an entity report unless the matter involves conduct outside the exempt category.
6.1 SCS must notify the OCG of a reportable allegation or reportable conviction within seven business days of becoming aware of the matter. SCS must then provide a finalised entity report or an update within 30 calendar days.
6.2 The role of the OCG is to audit, oversee, monitor and review the employer’s response to reportable or exempt allegations/convictions including assessment of the allegation, risk assessment, risk management, appropriateness of findings and may request further information or review of decisions.
6.3 Under the reportable conduct scheme, SCS must notify the OCG and investigate all reportable conduct allegations involving employees, even if the conduct occurred outside the workplace.
6.4 SCS must report all reportable conduct allegations to NSW Police, the Department of Communities & Justice (DCJ) and the NSW Education Standards Authority (NESA).
6.5 SCS must seek permission from NSW police prior to commencing its internal investigation. This can include a direction from police not to inform the person who is the subject of the allegations.
7.1 Allegations of inappropriate conduct of an employee towards a child must be managed differently from other complaints. Any employee who becomes aware of such a concern must immediately report it to the Principal/Manager, who must then promptly contact the Child Protection Team for advice, assessment, history checks, risk assessment and to determine the appropriate investigation pathway. (Child Protection Team: (02) 9568 8298 or child.protection@scs.catholic.edu.au)
7.2 If the allegation concerns the Principal/Manager, the matter must be reported directly to the Child Protection Team.
7.3 Concerns or allegations must be reported even when:
7.3.1 no formal complaint has been made, and
7.3.2 the information is provided anonymously or confidentially.
7.4 No employee should attempt to investigate a concern themselves before reporting it to their Principal/Manager or the Child Protection Team.
7.5 When employees are uncertain about whether conduct is reportable, they should seek advice from the Child Protection Team. Principals/Managers must also consider any additional obligations, including reporting offences to the NSW Police under the Crimes Act 1900 and their responsibilities as Mandatory Reporters to DCJ.
8.1 A risk assessment must be conducted when a reportable allegation is received. Risk assessments must also be reviewed as new information is received during the investigation and at the conclusion of the investigation. Where possible SCS will apply the least intrusive risk management strategies necessary to address the identified risks. These actions are aimed at mitigating risk and should not be construed as disciplinary action or an indication that an adverse finding has been made.
8.2 SCS may delay informing an employee of an allegation where necessary to avoid creating a health or safety risk or when directed to by Police or DCJ.
9.1 There are two processes applied to managing child protection complaints:
9.1.2 low level complaints (exempt conduct) and those involving low risk are
managed by the Principal or SCS Manager, and
9.1.2 complaints involving more serious allegations (typically an allegation of reportable conduct/conviction) or those that suggest a higher level of risk, are investigated by the Child Protection team (or outsourced to an external investigator where necessary).
9.2 The investigation process will typically involve:
9.2.1 interviewing the alleged victim and witnesses,
9.2.2 gathering other relevant evidence,
9.2.3 writing to the employee detailing the allegations and requesting a response,
9.2.4 preparing an investigation report,
9.2.5 making findings on the outcome of the investigation, and
9.2.6 actioning the outcome and any recommendations.
9.3 SCS must observe the principles of procedural fairness at all stages of the investigation. If an adverse finding against an employee is proposed in a reportable conduct investigation, the employee will be informed in writing and given the opportunity to provide a further submission before a final decision is made.
9.4 Employees have the right to access information about the process and the allegations made, reasonable notice of meetings and decisions, the opportunity to respond to allegations, and access to support persons, including union or legal representation.
9.5 Any children, young people or families participating in the investigation will be provided with clear and age appropriate information about the investigation process including confidentiality.
9.6 Relevant parent/carer consent is obtained prior to interviewing children and young people; child centered practices will be used throughout the process, and relevant support services are offered.
10.1Confidentiality must be maintained at all stages of a reportable conduct investigation. Information must be shared strictly on a need‑to‑know basis. Employees who are the subject of an allegation must not discuss the matter with colleagues or others, except for their support person, legal or union representative.
10.2 Staff who breach confidentiality in relation to a reportable conduct investigation may be the subject of a separate misconduct inquiry.
11.1 At the conclusion of an investigation, the decision maker must determine whether the allegation is sustained or not sustained on the balance of probabilities. Potential findings may include:
11.1.1 a finding that the allegation was not sustained
11.1.2 a finding of reportable conduct,
11.1.3 a finding of professional misconduct or a breach of the SCS Code of Professional Conduct.
11.2 Potential outcomes of an investigation may include:
11.2.1 no further action,
11.2.2 disciplinary action (e.g. a warning or termination of employment),
11.2.3 targeted professional development,
11.2.4 mentoring and counselling, and
11.2.5 changes to policy and practice.
12.1 Under section 57 of the Act, SCS must, by verbal or written communication, inform the child and their parent or authorised carer of the progress and outcome of a reportable conduct investigation unless it is not in the public interest to do so. SCS may also disclose information to other agencies where required by law or where necessary to ensure the safety, welfare or wellbeing of children.
12.2 At the conclusion of the investigation, the Child Protection team will provide information verbally or in writing about the outcome of the investigation to the student and parent/carers in accordance with section 57 of the Children’s Guardian Act 2019.
13.1 Employees who are the subject of a reportable conduct investigation have the right to procedural fairness, access to information about the process, reasonable notice of meetings and decisions, the opportunity to respond, and access to support persons, including union or legal representation.
14.1 The records of a reportable conduct investigation must be held as confidential and secure records for a minimum of 45 years. Records must be stored separately from personnel files and accessible only to authorised staff. Requests for access to information will be handled in accordance with privacy legislation and the Government Information (Public Access) Act 2009.
15.1 SCS promotes a culture of child safety by ensuring that:
15.1.1 all employees are familiar with the terms of their employment contract and the SCS Code of Professional Conduct.
15.1.2 employees keep their interactions with children professional, even in less formal environments including extracurricular activities, and
15.1.4 employees do not engage with students outside of their role including on social media or other electronic media unless there is a clear educational or administrative purpose.
15.2 Regardless of whether an allegation of inappropriate behaviour by staff towards children reaches the threshold for reporting to the OCG, SCS takes complaints seriously and responds according to the SCS Resolution of Complaints Policy.
16.1 Executive Director (Head of Relevant Entity)
16.1.1 Acting as the Head of Relevant Entity (HRE) in respect of all legislative responsibilities pursuant to Part 4 of the Act for Catholic systemic non-government schools within the Archdiocese of Sydney.
- Ensuring that HRE responsibilities are met.
- Nominating delegate/s (Director, Safeguarding, Risk and Assurance and the Child Safeguarding Team, to ensure systems are in place to prevent, detect and respond to reportable conduct allegations and other child related allegations.)
- Lead SCS in fostering a culture which is proactive in ensuring the protection of children
16.2 Executive Leadership Team, Managers and Principals
- Ensuring awareness and compliance with strategies at the system and school level that relate to detecting, reporting and investigation of allegations of reportable conduct.
- Participate in analysis of data with the purpose of continuous improvement across the system.
- Participate in role specific training when opportunities are provided by the Child Safeguarding team.
16.3 Child Protection Team
- Assess all child related allegations and determine the appropriate investigative pathway.
- Complete a risk assessment and make recommendations to the Director: People & Culture in relation to changes to an SCS staff member’s work status and/or arrangements.
- Completing the 7 and 30 day reports to the OCG for any reportable conduct allegations and convictions made against staff members.
- Ensure investigations are conducted and recommendations made to the Director of Safeguarding, Risk & Assurance regarding proposed findings and action in a timely manner.
- Develop and deliver relevant and up to date training to SCS staff.
- Maintain records of investigations and store these records in secure confidential storage.
- Liaise with other agencies such as DCJ, NSW Police, NESA and the Children’s Guardian, as required.
- Provide regular reports to the HRE, SCS leadership team and the Board about child related allegations.
- Identify trends and appropriate actions to be taken to address emerging risk to the safety of children.
16.4 SCS staff
- Maintain professional boundaries with students.
- Maintain the care and protection of children and young people as paramount.
- Support the right of students, parents and other employees to bring forward complaints or allegations and to be heard without fear of reprisal.
- Maintain their understanding and awareness of their child safety obligations including to report inappropriate conduct involving a child or young person, the required standards of behaviour and the correct procedure for managing complaints.
- Maintain practices in line with the NSW and Catholic Child Safe Standards.
- Complete all mandatory training requirements on a timely basis.
- School leaders are required to provide support and guidance to SCS staff in maintaining professional standards related to relationships with students.
17.1 For advice or to report an allegation, staff should contact:
SCS Child Protection Team on (02) 9568 8298 or child.protection@scs.catholic.edu.au
Office of the Children’s Guardian: ocg.nsw.gov.au
17.2 This policy should be read in conjunction with the:
- Children’s Guardian Act 2019,
- Crimes Act 1900,
- Child Protection (Working with Children) Act 2012,
- National Catholic Safeguarding Standards,
- SCS Code of Professional Conduct,
- SCS Managing Risk of Significant Harm and Mandatory Reporting Policy,
- SCS Resolution of Complaints Policy.
• Policy Number: SCS2026020
• Document Rescinds / Replaces: SCS2023024
• 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