NSW Health has supported proposals in the Office of the Children’s Guardian’s (OCG) Regulating child safe organisations in NSW discussion paper.

There is a strong appetite from within our public health system for creating child safe environments. Health’s response to the discussion paper was informed by significant input from local health districts, specialty health networks and pillar organisations. The response promotes building on existing good practice and includes suggestions for how the standards can be implemented and monitored in diverse service settings across the health system.

NSW Health will continue working closely with the OCG on the regulation of child safe standards.

Last updated: 02 February 2023
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NSW Health has a vision that children, young people and their families are supported by the public health system to live free of violence, abuse and neglect and their adverse effects. We provide responses to all forms of interpersonal violence, including child abuse and neglect, domestic and family violence, sexual assault and for children and young people displaying problematic or engaging in harmful sexual behaviour.

NSW Health has made a commitment in response to the Royal Commission into Institutional Responses to Child Sexual Abuse to ensure our public health institutions are child safe and that strong direction and clear guidance is given to our workforce to meet our responsibilities to child protection and well-being.

NSW Health Secretary, Ms Elizabeth Koff

Almost every citizen in NSW interacts with the public health system over the course of their life. Each interaction with a NSW Health institution is an opportunity to keep children safe from harm. We can do this by ensuring children are safe in our care, educating everyone in our organisations about violence, identifying and intervening early where violence has occurred, and minimising the impact of violence through therapeutic responses. Experiences of violence, abuse and neglect have serious impacts on people’s physical and emotional health, contributing to a range of negative health outcomes.

NSW Health is promoting a cultural shift across all NSW Health services towards person-centred and trauma-informed care and practice, based on recognition that all Health workers have a responsibility to contribute to the prevention and response to interpersonal violence.

The inquiries of the Royal Commission into Institutional Responses to Child Sexual Abuse strengthened Health’s commitment to ensuring our public health institutions are child safe. Implementation and monitoring of compulsory child safe standards is key to improving the safety of children in organisations.

Regulation of public health services

In what ways is a principle-based approach a good fit for regulating child safe organisations in NSW?

What types of organisations should be regulated to meet child safe standards in NSW?

​What sorts of organisations should help to co-regulate child safe standards?

The NSW public health system is large and complex, comprising a broad range of public facing services and system enablers with varied organisational structures. In consulting on this discussion paper, we heard overwhelming enthusiasm and support for mandatory child safe standards, along with a monitoring and oversight framework. We heard about good practice that is already occurring in Health entities, and a need for strong leadership and coordination both within NSW Health and from the Office of the Children’s Guardian (OCG) to embed a child safe culture in all aspects of the system.

We support a principle-based, co-regulatory approach to the oversight of child safe standards in public health organisations in NSW. The public health system has an existing regulatory framework with the Ministry of Health as the main system operator and leadership body. The Ministry monitors and supports continuous improvement in the health system through a variety of levers, including requirements in service level agreements, policy directives and mandatory training. The NSW Health Pillar organisations1 support and improve the system, for example, the Clinical Excellence Commission is supportive of exploring opportunities to integrate the Child Safe Standards into quality improvement processes.

Compliance with the child safe standards could be incorporated into these existing mechanisms. For example, service level agreements could require Local Health Districts and Specialty Hospital Networks to complete self-assessments against the standards and implement a quality improvement plan. The Ministry of Health could use periodic reporting to promote good practice, provide additional support to address systemic areas for improvement, and identify where performance management is required. The views of children and families must be incorporated into priority setting, decision-making and auditing to provide a full picture of progress in implementing the standards, both at the service level and in oversight. Collaboration with the OCG as a coregulator would bring additional rigour, expertise and leadership.​

The child safe standards are consistent with the strategic direction and policy frameworks that guide the health system.

This includes:

  • Charter on the Rights of Children and Young People in Healthcare Services in Australia
  • The First 2000 Days Framework
  • Strategic Framework for Integrating Care
  • Violence, Abuse and Neglect Redesign Program
  • Integrated Trauma Informed Care Framework (in development).

Health service organisations, including NSW Health facilities are required to be accredited against the NSQHS2. There is already some alignment between the NSQHS and the Child Safe Standards. Both sets of standards are focused on organisational safety and quality improvement and include aspects of governance, engaging with patients/children, and systems for supporting safe care. However, a specific focus on child safety is missing from the NSQHS. The Australian Commission on Safety and Quality in Health Care should consider whether child safety could be incorporated into the NSQHS, perhaps linking to the child safe standards approach in each state/ territory. Other health services regulatory bodies could similarly incorporate the child safe standards into their regulatory frameworks, for example the Standards for General Practices. Incorporating child safe standards into other regulatory standards could help to embed child safety as a core part of health service provision, rather than an optional peripheral.

Practice example

South Western Sydney Local Health District is prioritising child safety through its Strategic Plan 2018-21. One of the key strategies in the plan is to increase the involvement of children and young people as partners in care, consistent with the Charter on the Rights of Children and Young People in Healthcare Services in Australia.​​

Support for organisations

How should the OCG support organisations to build their capacity to meet the child safe standards?

Leadership and advocacy from the OCG is crucial to promote the cultural and systems change that will keep children safe in NSW organisations. The OCG’s current child safe training and other resources have been well received across NSW Health. Suggestions as to how the OCG could build on these successful capacity building tools, include:

  • developing a capacity building framework for senior executives, service managers and practitioners
  • self-assessment and quality improvement planning tools
  • partnering with NSW Health to develop engaging videos and learning tools that are tailored to health settings. Resources should feature children’s perspectives on their safety in health services. NSW Health could then incorporate these into our professional learning systems
  • implementation tools that are suitable for health services e.g. policies, protocols and audit templates
  • an expert consultation and advice service about what is required to meet the standards and assistance to resolve any issues.
  • working with universities, training bodies and professional associations to incorporate child safety into relevant professional training.

NSW Health also has contractual relationships with many external organisations, including community organisations. We can promote compliance by incorporating the child safe standards into selection processes, and contract and reporting requirements. OCG guidance and resources would be helpful to support contract managers to consistently implement this approach.

Support for children, families and communities

How can the OCG support parents, families and communities to encourage organisations to be child safe?

The engagement of children, families and communities is essential for child safe organisations. Along with building organisational capacity, the OCG should build child, family and community capacity to advocate for child safe organisations. Accessible resources and targeted information should improve children and families’ understanding of what child safety is, how to identify it and how to encourage organisations to work towards child safety.

In the Health context, children and families often have few choices about what services they access. Children and families need to be aware of the child safe standards and children’s rights, and be equipped with the knowledge and tools to engage in constructive conversations with organisations about child safety in healthcare.

Communications materials aimed at children and families would also be valuable in NSW Health. These products should be culturally and developmentally appropriate and organisations should be able to tailor materials for the local setting. This could include:

  • posters and communications materials for engaging children and families in their rights in healthcare settings and promoting access to child friendly complaints processes
  • tools to facilitate consultation with children about their safety, including about safe physical environments
  • resources to empower children and families in organisations and support their involvement in organisational decisions.

Ongoing consultation

To develop this response, NSW Health sought and collated input from Local Health Districts, Speciality Health Networks, Pillar Organisations and relevant branches across the Ministry of Health. There is a strong appetite from within our public health system for creating child safe environments. Promoting and building on existing good practice examples across Health will be important to effective implementation and regulation of the standards. We look forward to continuing to work closely with the OCG on the regulation of child safe standards in NSW.

Footnotes

  1. For more information on pillars and NSW Health organisation structure, see: NSW Ministry of Health structure.
  2. All hospitals and day procedure services and the majority of public dental services across Australia need to implement the NSQHS Standards.