The pathway depends on the information, not the label used by the person raising it. A concern spoken casually can still disclose child safety risk, misconduct or a notifiable complaint. Staff must listen for substance and assess what action is required.

Complaint, concern or ordinary frustration?

• A complaint expresses dissatisfaction and may seek a response, remedy or review.
• A concern provides information about possible risk, conduct, practice or wellbeing and may require action even when no remedy is requested.
• A grievance generally concerns an employee’s work, treatment, relationship or employment.
• Feedback can be positive, neutral or improvement focused and may not allege wrongdoing.
• Ordinary frustration or “whinging” may not require a formal process, but it must not be used to dismiss information about risk, rights, safety, misconduct or repeated workplace issues.

Your first role is to receive enough information to identify safety needs and the correct pathway. It is not to test the person, reach a finding, confront the subject or conduct an informal investigation.

Helpful responses

Do not

• ask leading, repeated or suggestive questions;
• promise a particular outcome or timeframe before assessment;
• contact the person who is the subject of a child safety allegation;
• tell a parent or carer before seeking advice where this could increase risk or compromise an investigation;
• ask colleagues for opinions or circulate the allegation;
• delete, edit, crop or annotate original evidence; or
• delay action while waiting for a written complaint.

Before deciding whether information is a complaint, grievance, conduct matter or statutory report, identify whether a child or adult needs immediate protection, medical attention or emergency assistance.

Immediate actions may include

• calling 000 for immediate danger, a life threatening concern or a crime in progress;
• providing first aid or urgent medical care;
• separating a child from an immediate source of harm without interviewing them;
• maintaining supervision and accounting for all children;
• preserving the scene, physical evidence, digital records and contemporaneous notes;
• obtaining urgent advice from Victoria Police or Child Protection;
• ensuring the alleged subject does not influence witnesses or records; and
• contacting the appropriate NERPSA manager as soon as immediate safety is secured.

After immediate safety is addressed, continue through all applicable internal and external pathways. One report does not automatically satisfy every obligation.

Child safety reporting can involve several overlapping duties. Follow the current NERPSA Child Safe Environment and Wellbeing Policy, PROTECT guidance and the Four Critical Actions. Seek advice when unsure, but do not use uncertainty to delay protective action.

Possible pathways

• Victoria Police for immediate danger, suspected criminal conduct or advice about a possible crime;
• DFFH Child Protection where a mandatory reporting threshold is met or a child may need protection;
• The Orange Door or another relevant service for family violence or wellbeing support where appropriate;
• internal notification to the Nominated Supervisor, Education Manager and Approved Provider pathway;
• VECRA notification by the Approved Provider for applicable serious incidents, complaints, allegations or risks;
• Reportable Conduct notification by the Head of Organisation to the Social Services Regulator; and
• information sharing under CISS or FVISS where authorised and appropriate.

Make a further report if new information creates a further belief or indicates a new instance or risk of abuse. Record advice received, the person or authority contacted, date, time, reference number and agreed actions.

Escalate according to the type and seriousness of information. Staff report to the appropriate NERPSA role promptly, while direct emergency, mandatory or statutory action still occurs when required.

Important distinctions

• A service complaint may also be a notifiable complaint, child safety concern, OHS hazard or conduct allegation.
• A staff grievance is not the correct pathway for a child safety allegation, although employment issues may run alongside it.
• An allegation does not need to be substantiated before it is reported or notified.
• Reportable Conduct notification is the responsibility of the Head of Organisation, but staff must report allegations internally immediately.
• VECRA notifications are generally made by the Approved Provider through the required system, but staff must provide information without delay.
• VIT, WorkSafe, Victoria Police, Child Protection or another body may also require separate action depending on the facts.

A good record shows what was known, observed, said, decided and done. It separates fact, direct quotation, professional assessment and information supplied by another person.

Record

• date, time, location and people present;
• the source of the information and how it was received;
• exact words where possible, especially a child’s words or a threat;
• observable actions, injuries, presentation and environmental conditions;
• open questions asked and responses given;
• immediate safety and support actions;
• people and authorities contacted, with time, advice and reference numbers;
• evidence preserved and where it is securely stored;
• decisions, reasons, action owners and due dates; and
• follow up, new information and whether further reports were made.

Do not place child safety allegations in ordinary program notes, personal notebooks, shared staff chats or unsecured email chains. Use the required confidential record and submission pathway.

People must be able to raise genuine concerns without retaliation, victimisation, intimidation or adverse treatment. Whether formal whistleblower protections apply depends on the nature of the disclosure, the person making it, who receives it and the applicable law and NERPSA policy.

Good faith reporting

• does not require the person to prove the concern before raising it;
• may be mistaken without being knowingly false;
• must be handled with appropriate confidentiality and procedural fairness;
• must not lead to retaliation because the person reported or participated in a process; and
• does not protect knowingly false information, deliberate misuse of a process or unrelated misconduct.

Follow up must include

• checking that required reports and notifications were completed;
• continuing risk assessment and protective arrangements;
• supporting the child, family, reporter, witnesses and affected employees as appropriate;
• maintaining confidentiality without preventing lawful reporting or support;
• recording new information and making further reports where required;
• monitoring for retaliation, interference or record tampering;
• communicating only information that can lawfully and fairly be shared; and
• reviewing policy, supervision, systems, training and QIP actions.