Child Safety and Wellbeing Policy

Our commitment

Every child has the right to be safe, to feel safe and to be treated with dignity and respect.

GIofAI is committed to providing a safe, respectful and inclusive environment for every child participating in our programs.

We have zero tolerance for child abuse, grooming, exploitation, neglect, bullying, harassment, discrimination or inappropriate conduct towards children.

Child safety is the responsibility of everyone involved in delivering GIofAI programs.

Who this policy applies to

This policy applies to anyone involved in GIofAI programs for children, including:

• employees
• teachers and coaches
• contractors and freelancers
• moderators and technical hosts
• volunteers
• mentors and guest speakers
• anyone who has access to children or children's personal information

Everyone working directly with children must comply with this policy and the GIofAI Child Safe Code of Conduct.

Child-safety responsibility

GIofAI appoints a Child Safety Officer to coordinate and oversee the day-to-day implementation of this policy.

The Child Safety Officer is responsible for:

• receiving and responding to child-safety concerns and complaints
• ensuring required worker screening is completed
• coordinating appropriate child-safety induction
• maintaining necessary child-safety records
• overseeing child-safety controls within GIofAI programs
• coordinating responses to incidents or allegations
• arranging or making reports to relevant authorities where required and within their authority

All employees, contractors, freelancers, teachers, coaches and other workers must cooperate with the Child Safety Officer and promptly report child-safety concerns.

Where applicable law places a specific obligation on another office holder, GIofAI will ensure that obligation is fulfilled in accordance with the law.

GIofAI may engage independent legal, safeguarding or investigation professionals where specialist expertise or independence is required.

Conflicts of interest and independent escalation

A person must not investigate or determine a child-safety complaint or allegation where they:

• are personally involved in the matter
• are the subject of the complaint
• have an actual or reasonably perceived conflict of interest

In those circumstances, the matter will be referred to an appropriate non-conflicted member of the GIofAI Advisory Board or, where appropriate, an independent qualified professional.

The Advisory Board member may:

• oversee the matter
• ensure immediate child-safety risks are addressed
• seek independent legal or safeguarding advice
• recommend or arrange an independent investigation where appropriate
• ensure relevant actions and decisions are appropriately documented

GIofAI will ensure that reporting obligations to police, child-protection authorities, regulators or other authorities are completed where required by law.

Where applicable law assigns a specific responsibility to a director, office holder, Head of Entity or another person, that responsibility remains with that person and will be fulfilled in accordance with the applicable law.

Screening and suitability of workers

People who work directly with children must complete any child-related screening required by applicable law.

This may include:

• a Working with Children Check
• a Blue Card
• an equivalent child-related clearance

GIofAI will verify required clearances before a person begins child-related work.

Before working directly with children, relevant workers, contractors and freelancers must:

• understand this policy
• agree to the Child Safe Code of Conduct
• complete required screening
• complete appropriate child-safety induction
• understand how to report a concern

GIofAI will maintain appropriate records of screening and induction.

Workers who do not interact with children or access sensitive children's information will be subject to controls appropriate to their role.

Safe online delivery

GIofAI programs may be delivered online. Reasonable safeguards include:

• controlled admission to online sessions
• checking participants against enrolment records
• supervised breakout rooms
• appropriate controls over screen sharing, chat and file sharing
• restricting unauthorised access
• maintaining appropriate attendance or session records where required

Workers must not have unnecessary unsupervised one-to-one online interactions with children.

Where practical, GIofAI will use:

• one authorised adult with a group of children, or
• an additional authorised adult where individual or very small-group interaction is necessary

If a session unexpectedly creates an inappropriate one-to-one situation, the worker should return the child to the main session, involve another authorised adult or end the interaction.

Communication with children

A parent or guardian is GIofAI's primary administrative contact for a child.

Workers must not privately:

• text or call a child
• contact a child through personal email accounts
• connect with a child through personal social-media accounts
• invite a child into private messaging channels
• arrange unauthorised private meetings
• ask a child to keep communications secret

Program communication should occur through approved GIofAI channels.

Cameras, recordings and personal information

Children will not be excluded simply because they do not wish to use a camera. Where camera use supports participation or supervision, GIofAI may encourage it, but reasonable alternatives should be available.

GIofAI does not routinely record children's sessions.

Where recording is required for a legitimate purpose, parents or guardians will be informed about:

• what will be recorded
• why it is required
• how it will be used
• who may access it
• how long it will be retained

Appropriate consent will be obtained where required.

Workers and participants must not make unauthorised recordings. Children's photographs, video, audio and personal information must be appropriately protected.

AI and technology

Children may only use AI and technology tools approved by GIofAI for the relevant program. The current list is published in the Approved Tool Register.

Unless specifically assessed and approved:

• children must not enter personal information into AI tools
• workers must not enter children's personal information into public AI tools
• child-safety complaints or incident information must not be entered into public generative AI services
• children's photographs, videos, voice recordings or other sensitive information must not be uploaded into AI systems

GIofAI will use reasonable care when selecting technology for children's programs.

Children should also understand that AI-generated information may be inaccurate, inappropriate or misleading.

Respect, cultural safety and inclusion

GIofAI is committed to providing a respectful and inclusive environment for every child.

GIofAI does not tolerate:

• racism
• discrimination
• bullying
• harassment
• exclusion based on personal or cultural characteristics

Particular consideration will be given to the safety and participation needs of:

• Aboriginal and Torres Strait Islander children
• children with disability
• children from culturally and linguistically diverse backgrounds
• children requiring reasonable adjustments
• children who may experience barriers to participation or raising concerns

Children's rights

Every child participating in a GIofAI program has the right to:

• feel safe
• be treated with dignity and respect
• ask questions
• ask for help
• raise a concern
• protect their personal information
• speak to an adult they trust
• be taken seriously when something feels wrong

Children will not be punished or disadvantaged for raising a genuine safety concern.

Reporting a child-safety concern

Anyone working with GIofAI must report a child-safety concern as soon as practicable.

A worker does not need proof that abuse or harm has occurred before raising a concern.

If a child makes a disclosure

1. Listen calmly.
2. Take the child seriously.
3. Do not interrogate the child.
4. Do not ask leading questions.
5. Do not promise secrecy.
6. Take reasonable steps to protect the child from immediate harm.
7. Record what was said or observed accurately.
8. Notify the Child Safety Officer as soon as practicable on the same day.

Workers should not conduct their own investigation into child-safety allegations.

Responding to concerns

When GIofAI receives a child-safety concern, the Child Safety Officer or other authorised person will:

• consider the child's immediate safety
• make an appropriate written record
• determine what immediate protective action is required
• identify applicable reporting obligations
• make or arrange any legally required external reports
• protect relevant records and evidence
• inform the parent or guardian where appropriate

A parent or guardian may not be contacted immediately where doing so could:

• increase the risk to the child
• interfere with an investigation
• otherwise be inappropriate or unlawful

Where an allegation involves a worker, contractor or freelancer, GIofAI may temporarily remove that person from contact with children while the matter is assessed. This is a protective measure and does not, by itself, mean the allegation has been proven.

Mandatory reporting and external authorities

GIofAI will comply with applicable Australian child-protection, mandatory reporting and reportable-conduct requirements. Requirements may vary between Australian states and territories.

GIofAI will identify and comply with the applicable requirements based on the circumstances of each matter and may obtain specialist advice where appropriate.

Workers remain responsible for any personal statutory reporting obligations that apply to them. Reporting a concern internally to GIofAI does not remove an individual's legal responsibility to make an external report where required by law.

Complaints

A child, parent, guardian or worker may raise a child-safety concern directly with GIofAI. No special wording or formal complaint form is required.

Concerns may be raised:

• with a teacher or coach
• with another authorised GIofAI worker
• directly with the Child Safety Officer
• by email at childsafety@giofai.com.au

Urgent child-safety concerns will be addressed immediately. Other child-safety complaints will ordinarily be acknowledged within two business days.

Anonymous complaints may be accepted, although anonymity may affect GIofAI's ability to investigate or respond.

No person will be victimised or disadvantaged for raising a genuine child-safety concern.

Where the person receiving or handling a complaint has a conflict of interest, the matter will be escalated in accordance with Section 4 of this policy.

Nothing in this policy prevents a person from contacting police, child protection or a relevant regulator directly where they choose or are legally required to do so.

Privacy and records

GIofAI will keep appropriate records necessary for child safety and legal compliance. These may include:

• worker screening records
• child-safety induction records
• parental consent
• incident and complaint records
• reports made to external authorities
• relevant actions and decisions

Records relating to child-safety concerns must be factual, objective and stored securely. Access to child-safety information will be limited to people who have a legitimate reason to access it.

Records will be retained in accordance with applicable Australian legal and regulatory requirements.

How we handle personal information more generally is set out in our Children’s Programs Privacy Notice.

Breaches

A breach of this policy or the Child Safe Code of Conduct may result in appropriate action, including:

• additional training
• increased supervision
• restriction or suspension of access
• removal from a session
• termination of a contractor or freelancer engagement
• termination of employment where applicable
• referral to an appropriate external authority

Child-safety requirements apply regardless of whether a person is an employee, contractor, freelancer, volunteer, consultant, mentor or guest participant.

Review

This policy will be reviewed:

• at least annually
• following a significant child-safety incident
• following a material change in relevant law
• following a significant change to the way GIofAI delivers programs involving children

The policy will be updated where reasonably necessary.

Contact

A child, parent, guardian or worker may also contact police, child protection or another relevant authority directly where appropriate.

Our promise to children

If something worries you or does not feel right, tell your teacher, coach, parent, guardian, Child Safety Officer or another adult you trust.

You can also contact us at childsafety@giofai.com.au.