Safeguarding children and young people policy

Purpose

The purpose of this policy is to:

1. Affirm Make-A-Wish Australia’s commitment to the safety and protection of children and young people.
2. Facilitate the prevention of child abuse or risk of harm occurring within Make-A-Wish Australia, ensuring a zero-tolerance policy.
3. Work towards an organisation culture of child safety.
4. Prevent child abuse or risk of harm within Make-A-Wish Australia by identifying and removing risks of harm.
5. Ensure that all parties are aware of their responsibilities for identifying possible occasions for child abuse or risk of harm and for establishing controls and procedures for preventing such abuse and/or detecting such abuse when it occurs.
6. Provide guidance to all Make-A-Wish Australia representatives as to action that should be taken where they suspect any abuse or harm within or outside of the organisation.
7. Ensure consistency in child safe practices in all states.
8. Provide a clear statement to employees/volunteers and all other representatives forbidding child abuse or risk of harm.
9. Outline the responsibilities of partners, suppliers and “wish” partners and supporters.
10. Provide assurance that any and all suspected or actual child abuse or risk of harm will be reported and fully investigated.

Scope

This policy applies to anyone who represents Make-A-Wish Australia, defined as employees, employee contractors, volunteers and board members (henceforth known as representatives), when they are representing Make-A-Wish either in a physical capacity or working online.

This policy applies to all Make-A-Wish Australia representatives in all states in Australia that Make-A-Wish Australia operates in.

It also outlines how we work with key stakeholders with regards to child safety including:

• Partners and Suppliers who provide services or support to Make-A-Wish
• Partners & Suppliers connected with the delivery of wishes “Wish Partners & Supporters”
• Make-A-Wish Ambassadors

Policy

Make-A-Wish Australia is committed to promoting and protecting at all times the best interests of children and young people involved in its programs, including when interacting in person or online.

All children, regardless of their gender identity, race, religious beliefs, age, ability, sexual orientation, or family or social background, have equal rights to protection from abuse and harm.

Child safety is a shared responsibility between Make-A-Wish Australia, all employees, volunteers, board members, workers, contractors, associates, members and all other representatives of the Make-A-Wish Australia community. Make-A-Wish Australia will consider the opinions of children and young people to develop child safety policies.

Make-A-Wish Australia supports and respects all children, employees and volunteers. Make-A-Wish Australia is committed to the cultural safety of First Nations children, and those from culturally and/or linguistically diverse backgrounds, and to provide a safe environment for children with different abilities. This is done through an ongoing commitment to training and development.

If any person believes a child is at immediate risk of abuse or harm, telephone 000.

Responsibilities

Board

The Board of Make-A-Wish Australia has ultimate responsibility for the detection and prevention of child abuse or risk of harm and is responsible for ensuring appropriate and effective internal control systems are in place.

The Board is also responsible for ensuring that appropriate policies and procedures and a Child Safety Code of Conduct are in place.

Chief Executive Officer (CEO)

The CEO of Make-A-Wish Australia is responsible for:

1. Dealing with and investigating reports of child abuse or risk of harm as required;
2. Ensuring that all employees, employee contractors and volunteers are aware of relevant laws in each state, organisational policies and procedures, and the Child Safety Code of Conduct;
3. Ensuring that all adults within the Make-A-Wish Australia community are aware of their obligation to report suspected sexual abuse, physical abuse and or harm of a child in accordance with these policies and procedures (specifically the Reporting Guidelines);
4. Ensuring that all employees, employee contractors and volunteers are aware of their obligation to observe the Child Safety Code of Conduct;
5. Providing support for employees, employee contractors and volunteers in undertaking their child safety responsibilities, including the prevention of opportunities for harm to occur;
6. Ensuring that access to training and development and emotional support (such as access to an independent counsellor through EAP) is provided to employees and volunteers. (This may include training about how to identify indicators of harm or abuse, cultural awareness, facilitating participation and empowerment of children, responding to diverse needs and disabilities, and how to comply with this Policy, Reporting Guidelines and the Codes of Conduct); and
7. Managing enquiries, including from the media, relating to suspected child abuse or risk of harm.

Managers

Managers at Make-A-Wish Australia must: 

1. Promote child safety at all times, in particular to employees and volunteers within their team;
2. Assess the risk of child abuse or harm within their area of control and eradicate or minimise any risk to the extent possible;
3. Educate employees and volunteers about the prevention and detection of child abuse or risk of harm and ensure that they have completed the mandatory training;
4. Facilitate a culture of supporting and empowering children and valuing children’s opinions;
5. Facilitate the reporting of any inappropriate behaviour, suspected abusive activities or breaches of any Codes of Conduct; and
6. Ensure that employees and volunteers in their team are properly screened, have a valid police check and Working with Children Check, Blue Card or state-based equivalent prior to commencing any interaction with children and receive the required staff induction as it relates to child safety. This includes monitoring the ongoing validity of WWCC or equivalent.

Management should be familiar with the types of abuse and harm that might occur within their area of responsibility and be alert for any indications of such conduct.

Child Safety Officers

The following persons are nominated Child Safety Officers at Make-A-Wish Australia:

• Chief Operating Officer
• Wish Program Manager
• Participation Manager

Child Safety Officers must:

1. Understand and comply with Make-A-Wish Australia’s Safeguarding Children and Young People Policy, Reporting Guidelines and Child Safety Code of Conduct, including the requirement for reporting any suspected child abuse or risk of harm to the relevant state and territory regulatory authorities or police department;
2. Fully cooperate with relevant state and territory regulatory authorities or police department in their investigation of suspected child abuse or risk of harm;
3. Report any suspicions or complaints of child abuse or risk of harm immediately to the CEO and to any external regulatory authorities and/or the police;
4. Provide advice and support to fellow Make-A-Wish representatives to assist them to comply with the relevant state based requirements and related policies and procedures;
5. Respond to any changes in legislation and promptly advise the CEO who will in turn advise the Board;
6. Act as a key contact for wish families on any safeguarding children matter; and
7. Ensure complaints are accurately and confidentially recorded within the Salesforce Database, and Incident Register.

Make-A-Wish Representatives:

Make-A-Wish Representatives share the responsibility for the prevention and detection of child abuse or risk of harm, and must:

1. Familiarise themselves and comply with the relevant state and territory laws, this Policy, the Child Safety Code of Conduct and Make-A-Wish Australia’s policy and procedures in relation to child safety and wellbeing,;
2. Report any reasonable belief that a child is at risk of child abuse or harm to the relevant state and territory regulatory authorities and/or police and fulfil their obligations pursuant to the relevant state’s Child Safety Reporting Guidelines;
3. Report any suspicion that a child may be at risk of child abuse or harm immediately to a Child Safety Officer (or, if a Child Safety Officer is involved in the suspicion, to the CEO. If the CEO is involved in the suspicion, to a member of the Board);
4. Provide an environment that is supportive of all children and young people’s emotional and physical safety whether interacting physically with a child or online;
5. Complete all compulsory training and development as soon as reasonably practicable;
6. Hold a valid WWCC or state based equivalent for the state in which they reside as in accordance with their relevant state legislation;
7. Ensure Make-A-Wish Australia is linked to their WWCC or state based equivalent, so that the organisation is notified if there are any changes to their WWCC or state based equivalent (e.g. it expires);
8. Contact their manager prior to any interstate work (physically travelling to another state or territory) in order to arrange appropriate interstate WWCC or state based equivalent;
9. Empower and support children to raise their concerns in accordance with child safe standards;
10. Value and respect the opinions of children and young people;
11. Comply with all reasonable directions by Make-A-Wish Australia;
12. Immediately notify their supervisor or one of the Child Safety Officers should their WWCC or state based equivalent expire, be revoked, or they believe it is at risk of being revoked; and
13. Notify a Child Safety Officer if they identify a risk to child safety or, procedures they believe should be put into practice to ensure risks are minimised.

Make-A-Wish “Wish Partners & Suppliers”

Wish Partners & Suppliers are provided with Make-A-Wish Australia’s Wish Partners and Suppliers Child Safety Code of Conduct, and Make-A-Wish Australia’s policy and procedures in relation to child safety, and must:

1. familiarise themselves and comply with all requirements therein;
2. report any reasonable belief that a child is at risk of child abuse or harm to the relevant regulatory authorities and/or police;
3. report any suspicion that a child is at risk of child abuse or harm immediately to a Child Safety Officer at Make-A-Wish (or, if a Child Safety Officer is involved in the suspicion, to the CEO. If the CEO is involved in the suspicion, to a member of the Board);
4. provide an environment that is supportive of all children/young people’s emotional and physical safety, whether interacting physically with a child or online;
5. empower and support children to raise their concerns in accordance with Child Safe Standards; and
6. value and respect the opinions of children.

Make-A-Wish “Ambassadors”

Ambassadors are provided with Make-A-Wish Australia’s Child Safety Code of Conduct, and Make-A-Wish Australia’s policy and procedures in relation to child safety, and must;

1. familiarise themselves and comply with all requirements therein;
2. report any reasonable belief that a child is at risk of child abuse or harm to the relevant regulatory authorities and/or police.
3. report any suspicion that a child is at risk of child abuse or harm immediately to a Child Safety Officer at Make-A-Wish (or, if a Child Safety Officer is involved in the suspicion, to the CEO. If the CEO is involved in the suspicion, to a member of the Board);
4. provide an environment that is supportive of all children/young people’s emotional and physical safety, whether interacting physically with a child or online;
5. empower and support children to raise their concerns in accordance with child safe standards; and
6. value and respect the opinions of children.

Make-A-Wish Partners & Suppliers

Make-A-Wish Partners and Suppliers are advised of Make-A-Wish Australia’s obligations as a child safe organisation and have access to Make-A-Wish’s Commitment to Child Safety statement.

Employment of New Personnel

Make-A-Wish Australia undertakes a comprehensive recruitment and screening process for all new representatives which aims to:

1. promote and protect the safety of all children under the care of the organisation;
2. identify the safest and most suitable people who share the values of Make-A-Wish Australia and its commitment to protect children; and
3. prevent a person from working/volunteering at Make-A-Wish Australia if they pose a risk to children.

Make-A-Wish Australia requires all representatives to pass through the organisation’s recruitment and screening processes prior to commencing their engagement with Make-A-Wish.

Make-A-Wish Australia will ensure that new representatives:

1. obtain a clear National Police Check as conducted by Make-A-Wish Australia at the commencement of employment and at regular intervals throughout their engagement;
2. hold a valid WWCC or state based equivalent as per relevant state legislation (paid or volunteer, as directed by Make-A-Wish Australia);
3. successfully pass such interviews as required by internal procedures, including relevant questions about their suitability to work with children;
4. successfully pass thorough reference checks as required under Make-A-Wish Australia’s procedures, which includes relevant questions about the candidate’s suitability to work with children;
5. are provided with and trained on Make-A-Wish Australia’s Values, Child Safety Code of Conduct and Safeguarding Children and Young People Policy and procedures; and
6. are subject to online searches (e.g. Google, Linkedln) to identify other important sources of referees.

Ensuring the ongoing suitability of representatives is the responsibility of Managers regarding representatives in their team.

Risk Management

Child safety is part of Make-A-Wish Australia’s overall risk management approach. This includes a child safety committee, with representatives from across the organisation who meet regularly and as required to review and discuss matters.

Make-A-Wish Australia has a risk and compliance framework to proactively identify and mitigate child safety risks. Members receive regular training sessions as required in relation to child safety.

There are certain factors which increase the risk of abuse for children, including children with disabilities and serious illnesses. Make-A-Wish Australia takes every step to ensure the safety of wish children through their Wish Journey. The best interests of the wish child are our paramount consideration.

Empowerment and inclusion

Make-A-Wish Australia is committed to building a diverse and inclusive environment that reflects the community we serve. A publicly available Diversity, Inclusion and Belonging charter is available.

Make-A-Wish Australia implements the following strategies to contribute to the cultural safety of First Nations children and young people:

• Acknowledgements of country
• Cultural awareness training

Make-A-Wish does not tolerate racism. Any racism that is identified will be confronted and addressed with appropriate consequences.

Make-A-Wish Australia is passionate about inspiring children and young people to use their imagination to develop their wish, and implements the following strategies to empower children and young people to participate in decisions that affect them:

The Wish Journey is designed to inspire imagination.

• Make-A-Wish’s mission is that the child’s imagination should drive the wish and the child has lots of input in decision-making about their wish.
• We work with the wish child and their family to design a wish that meets their diverse needs.
• We pay particular attention to complex medical needs to ensure accessibility of our Wish Journey.

Any child who is concerned about their safety should call 000.

Families

Make-A-Wish Australia welcomes feedback from families and communities on how we can improve our child safety approach. We want to work with families and ensure you have a say in keeping Wish children safe.

Please e-mail: childsafety@makeawish.org.au with any concerns or feedback.

Child safety is the responsibility of every adult in Australia.

Information about our child safety approach is available on our website, in documentation from Make-A-Wish at the application stage and from your Make-A-Wish Australia wish representative at any time throughout the Wish Journey.

Reporting

Children, families, and any other person may report a child safety concern, complaint, allegation or disclosure to Make-A-Wish Australia at any time by emailing childsafety@makeawish.org.au. Reports will be handled promptly, thoroughly sensitively and fairly.

All Make-A-Wish representatives must comply with the Child Safety Code of Conduct, available on the Make-A-Wish Australia website. If you think a Make-A-Wish representative has not complied with a Code of Conduct, please report this by emailing: childsafety@makeawish.org.au

Any Make-A-Wish representative who has reasonable grounds to suspect abusive activity must immediately notify the appropriate state-based regulatory authorities or the police as required by legislation. They must also immediately advise one of the nominated Make-A-Wish Australia Child Safety Officers about their concern. This is outlined in the Child Safety Reporting Guidelines for each state.

In situations where a Make-A-Wish representative is conducting an activity in another state and territory to the one they normally work in, and where there are reporting requirements in both states, the Make-A-Wish representative must notify the appropriate regulatory authorities or the police in both states. For example, if a Make-A-Wish representative that generally works in New South Wales but has reasonable grounds to suspect child abuse or risk of harm when conducting an activity in Victoria, the representative must report as required by legislation in New South Wales and Victoria.

Also, in situations where a Make-A-Wish representative is conducting an activity in another state or territory to the one they normally work in, that representative must, prior to the interstate activity, discuss the need for any interstate WWCC (or equivalent) with a Child Safety Officer.

In situations where the Child Safety Officer is suspected of involvement in the activity, or if the person having the suspicion does not believe the matter is being appropriately addressed or dealt with, the matter should be reported to an alternative Child Safety Officer, or to the next highest level of supervision (i.e. CEO, then Board).

When any report is made to a Make-A-Wish Australia Child Safety Officer, that Child Safety Officer is responsible for ensuring:

• the report is taken seriously and responded to promptly, thoroughly, sensitively and fairly; and
• the child (and family concerned, as appropriate) receives appropriate support or assist the child and family concerned to find the appropriate support. For example, this could be by reaching out for a conversation with the child or family member, or providing details of other support services (such as Orange Door).

Make-A-Wish Australia maintains a confidential reporting culture which respects the privacy of individuals while maintaining adequate record keeping of child safety issues. All Make-A-Wish representatives have a right to report any concerns that they have of inappropriate behaviour toward children and will not suffer any professional or legal consequences provided they report in ‘good faith’.

These protections ensure that the report:

• Cannot result in the reporter being seen as unprofessional, or having breached professional ethics
• Does not make the reporter liable for any disciplinary or legal action (including in cases that are not proven).

Mandated reporting

1. Select classes of people in the community are required by law to report to the Child Protection Unit of the relevant state based regulatory authority. Please refer to the relevant state’s Child Safety Reporting Guidelines for the applicable reporting requirement.
2. Individuals who are mandatory reporters must comply with their reporting requirements and do not need permission from Make-A-Wish Australia before reporting. However, mandatory reporters can contact the Child Safety Officers for assistance in determining if a report needs to be made and in making a report.
3. All Make-A-Wish Australia representatives should report child safety concerns to a Child Safety Officer. Representatives should also be aware that reporting requirements apply to all adults in some states and should refer to the relevant Child Safety Reporting Guidelines for more information.

Voluntary reporters

In addition to the mandatory reporting obligations above, any person who believes on reasonable grounds that a child is in need of protection from any form of child abuse, may disclose that information to the Police or relevant state authority.

Investigations

If the appropriate regulatory authority or the police decide to conduct an investigation of a report made, Make-A-Wish representatives must cooperate fully with the investigation.

Make-A-Wish Australia considers that it is not acceptable to delay taking action against an alleged perpetrator unless (or until) they have been charged with a criminal offence. Make-A-Wish Australia commits to taking action immediately following the receipt of a complaint and will ensure to actively participate in the investigation process and follow up with the state or territory based regulatory bodies to ensure that the issue has been appropriately dealt with.

Whether or not the authorities decide to conduct an investigation, the CEO will consult with the authorities to determine whether an internal investigation is appropriate. If it is decided that such an investigation will not conflict with any proceeding of the authorities, the CEO may decide to conduct such an investigation. All representatives must cooperate fully with an internal investigation.

Any such investigation will be conducted according to the rules of procedural fairness and natural justice.

The CEO will make every effort to keep any such investigation confidential, however, from time to time other Make-A-Wish Australia representatives may need to be consulted in conjunction with the investigation.

After an initial review and a determination the suspected abuse warrants additional investigation, the CEO shall coordinate the investigation with the appropriate investigators and/or law enforcement officials. Internal or external legal representatives will be involved in the process, as deemed appropriate.

Responding to an allegation against a Make-A-Wish Representative

If it is alleged that a Make-A-Wish Australia representative may have committed an offence or have breached the organisation’s policies or the Child Safety Code of Conduct, the person concerned may be suspended (with pay, where applicable) while the investigation is conducted.

Volunteers who are the subject of an investigation will need to surrender their identification badge and any Make-A-Wish equipment to the Volunteer Services Team until Make-A-Wish Australia advises otherwise.

Make-A-Wish Australia has full discretion to put in place safety management plans or take disciplinary action where it forms a reasonable belief that it is not safe for an employee or volunteer to interact with children in accordance with its duty of care.

If the investigation concludes that on the balance of probabilities an offence (or a breach of the organisation’s policies or Child Safety Code of Conduct) has occurred then disciplinary action may follow, up to and including dismissal or cessation of involvement with the organisation. The findings of the investigation will also be reported to any external body as required.

Record Keeping and Privacy

Children and young people have the right to privacy, access to information, social connections and learning opportunities online.

All collection, recording and consideration of personal information will be done in a way that respects the privacy of the individuals involved, unless there is a risk to someone’s safety. Make-A-Wish Australia has safeguards and practices in place to ensure any personal information is protected from loss or misuse.

Make-A-Wish Australia will only disclose information to inform third parties as authorised or required by law, including the relevant state/territory regulatory authority and police department.

Everyone is entitled to know how their personal information is handled, what will be done with it, and who will be able to access it. Please refer to Make-A-Wish Australia’s Privacy Policy for more information.

Please refer to Make-A-Wish Australia’s Privacy Policy for more information.

Reviewing

The Board will conduct a review of Make-A-Wish Australia’s child safety policies and Child Safety Code of Conduct, annually and as required. The review will seek to determine whether the organisation’s child safety policies or procedures require modification to better protect children under the organisation’s care. The annual review will also ensure the policies and Child Safety Code of Conduct meet any new legislative requirements.

Related documents

• Child Safety Code of Conduct
• Incident Register
• Reporting Guidelines by State
• Child Safety Report form
• Child Safeguarding at Make-A-Wish Litmos training course
• Australian Childhood Foundation E-learning modules
• Privacy Policy
• Child friendly versions of the Safeguarding Children and Young Person Policy

Definitions

“At risk” includes when:

• The child or young person has suffered harm.
• There is a likelihood that the child or young person will suffer harm.
• There is a likelihood that the child or young person will be removed from the state for an unlawful act or procedure to be undertaken.
• The parents or guardian of the child or young person are unable or unwilling to care for them.
• The child or young person is of compulsory school age but has been persistently absent from school without satisfactory explanation of the absence.
• The child or young person is of no fixed address.

Child and young person and children and young people means a child or young person who is under 18 years of age, unless otherwise defined by law or noted in this Safeguarding Children and Young Person Policy.

Child abuse or risk of harm means conduct and/or the risk of conduct towards, against, with or in the presence of a child or young person, including:

• physical violence or harm
• conduct of a sexual nature, including a sexual offence, sexual abuse, sexual misconduct and/or grooming
• significant emotional or psychological harm, or
• significant neglect.

Child Safety means any responsibility, measure, activity or initiative undertaken to safeguard children and young people from any form of harm.

Grooming: occurs when an adult communicates, by words or conduct, with:

• a child under the age of 16 years, or
• a person who has care, supervision or authority for a child under the age of 16 years, 

with the intention of facilitating the child’s involvement in sexual conduct with an adult. This definition applies unless it is otherwise defined by law or the Child Safety Reporting Procedure.

Make-A-Wish Australia Representative means any person who is acting on behalf of Make-A-Wish Australia and includes employees, employee contractors, volunteers, board members.

Make-A-Wish Australia “Ambassadors” means any person appointed to act in an Ambassador role for Make-A-Wish as part of fundraising, brand, wish, corporate and community partnerships.

Make-A-Wish Partners & Suppliers means any business, community organisation, sole traders who contribute financially through donations, Gift in Kind support or provide pro-bono or paid business services.

Make-A-Wish “Wish” Partners & Suppliers means business or community organisations/ sole traders who are involved in the delivery of a child’s wish.

National Police Check means a summary of an individual’s offender history in Australia and a record of their criminal history relating to convictions, finding of guilt or pending court proceedings. They are available from relevant state police or organisations accredited by the Australian Criminal Intelligence Commission.

Sexual abuse: means any act which exposes a child to, or involves a child in, sexual processes beyond his or her understanding or contrary to accepted community standards.

Sexual misconduct: includes behaviour, physical contact or speech or other communication of a sexual nature, inappropriate touching, grooming behaviour and voyeurism, unless otherwise defined by law.

Sexual offence: means a sexual offence committed against, with or in the presence of a child, whether or not a criminal proceeding in relation to the offence has been commenced or concluded, unless otherwise defined by law.

Reasonable grounds for belief is a belief based on reasonable grounds (see below) that child abuse has occurred when all known considerations or facts relevant to the formation of a belief are taken into account and these are objectively assessed. Circumstances or considerations may include the source of the allegation and how it was communicated, the nature of and details of the allegation, and whether there are any other related matters known regarding the alleged perpetrator.

A reasonable belief is formed if a reasonable person believes that:

• The child is in need of protection,
• The child has suffered or is likely to suffer “significant harm as a result of physical injury”, or
• The parents are unable or unwilling to protect the child.

A ‘reasonable belief or a ‘belief on reasonable grounds’ is not the same as having proof, but is more than mere rumour or speculation.

A ‘reasonable belief is formed if a reasonable person in the same position would have formed the belief on the same grounds. For example a ‘reason belief might be formed if:

• A child states they have been physically or sexually abused;
• A child states that they know someone who has been physically or sexually abused (sometimes the child may be talking about themselves);
• Someone who knows a child states that the child has been physically or sexually abused;
• Professional observations of the child’s behaviour or development leads a professional to form a belief that the child has been physically or sexually abused; and/or
• Signs of abuse lead to a belief that the child has been physically or sexually abused.

Reporting in ‘good faith’ means that a reporter holds a reasonable belief and is not acting on improper grounds such as malice or retaliation towards the alleged offender.

WWCC means the relevant clearance for a person to work with children in each State and Territory , such as a Working With Children Check issued in Victoria and a Blue Card issued in Queensland.

Policy Management:

Purpose: To ensure Make-A-Wish Australia is promoting and protecting at all times the best interests of children and young people involved in its programs

Owner: Belinda Wallin, Group Head of People and Volunteers

Date of next review: March 2027