Safeguarding Policy - Mary MacKillop Today

Safeguarding Policy

What is Safeguarding?

Safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. This means protecting people, particularly children and vulnerable adults, from harm that arises from engaging with our staff or programs.

Child Safeguarding describes the specific actions that are taken to promote the welfare of children and protect them from harm. This encompasses protecting children from abuse and maltreatment, preventing harm to children’s health or development, and ensuring children grow up with the provision of safe and effective care that enables them to have optimum life chances and enter adulthood successfully.

Last updated 29 July 2021


Mary MacKillop Today is committed to the safety and wellbeing of all people who come into contact with our organisation and our programs, especially children and vulnerable adults. Mary MacKillop Today is committed to the rights and protection of all people regardless of their age, gender, nationality, religion or political beliefs.

We explicitly prohibit all forms of harmful behaviour including sexual exploitation, abuse and harassment of any kind against any persons, adult or child. We also prohibit exploitative, neglectful or emotionally abusive treatment of children. Mary MacKillop Today recognises our duty of care to take reasonable steps to ensure people are safe from harm (including victims/survivorsand whistle-blowers).

We are committed to demonstrating ongoing and effective leadership, communication, and to providing ongoing training and guidance to all persons within the scope of this Policy in the promotion and implementation of this policy.

Mary MacKillop Today is committed to creating an open and aware environment where concerns for the safety of children and vulnerable adults can be raised and managed in a fair and just manner to protect the rights of all.


What is Safeguarding? Safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. This means protecting people, particularly children and vulnerable adults, from harm that arises from engaging withour staff or programs.

Child Safeguarding describes the specific actions that are taken to promote the welfare of children and protect them from harm. This encompasses protecting children from abuse and maltreatment, preventing harm to children's health or development, and ensuring children grow up with the provision of safe and effective care that enables them to have optimum life chances and enter adulthood successfully.

Guiding Principles

This Policy is underpinned by the following key principles:

1. Zero tolerance of exploitation, abuse and harassment: Mary MacKillop Today prohibits all forms of exploitation, abuse and harassment against children and adults. We recognise our duty of care to take all reasonable steps to ensure all people are kept safe from harm. The abuse, exploitation or harassment of any person, particularly children and vulnerable adults, will attract civil, criminal and disciplinary action.

2. Zero tolerance of inaction: It is mandatory for all persons within the scope of this policy to report any Safeguarding concerns or allegations or breaches of the Safeguarding policy. Reports of Safeguarding incidences often increase as people become better informed and attitudes change, as safeguards improve and as reporting procedures become more accessible and embedded. The reporting of incidents may therefore indicate that Safeguarding risks and incidents are being properly managed. Zero tolerance to inaction therefore does not mean zero reports, but rather means that every report or allegation is acted upon.

3. Strong leadership to promote Safeguarding: The leadership of Mary MacKillop Today is committed to ensuring that Safeguarding becomes central to the culture of the organization. Leaders are expected to model positive behaviours, set clear expectations for the organisation and support survivors and/or whistle-blowers to feel safe when reporting unacceptable behaviour. Mary MacKillop Today recognises the importance of a diverse and inclusive organisation in Safeguarding, especially in leadership roles. This is embedded through strong human resources policies, inclusion of Safeguarding as an agenda item at Board meetings, the appointment of Safeguarding focal points and promoting gender equality in senior roles.

4. Victim/survivor-centred approach: Any actions taken to address Safeguarding must adopt a ‘do-no-harm’ approach that prioritises the rights, wishes and needs of the victim/survivor while ensuring procedural fairness to all parties. In all actions concerning children, the best interests of the child must be the primary consideration. A survivor-centred approach means:

  • Treating the victim/survivor with dignity and respect
  • Ensuring the immediate safety and protection needs of the victim/survivor are met as far as possible
  • Involving the victim/survivor in decision making
  • Providing the victim/survivor with comprehensive information throughout any response or investigation
  • Practicing non-discrimination on the basis of gender, age, race/ethnicity, ability, sexual orientation, or other characteristics
  • Considering the need for counselling and health services to assist the victim/survivor with their recovery
  • Protecting privacy and confidentiality, and promoting fair and expedient reporting and investigation

5. Promoting gender equity, child rights and minimising power imbalances: Mary MacKillop Today recognises that where there are significant power imbalances at play (based on inequities relating to gender, age, ability, authority, social and economic status) the potential for exploitation, abuse and harassment is increased. This is particularly true where one or more drivers of inequality intersect (for example gender and disability). Mary MacKillop Today is committed to engaging with all people, particularly primary stakeholders, with respect for diversity, the promotion of gender equality, social inclusion and a commitment to ‘do-no-harm.’ Where programs work with children or vulnerable adults, spaces for participation and feedback must be built into program design.

6. Robust risk management: Mary MacKillop Today is committed to robust Safeguarding risk management. While it is not possible to eliminate all risks, Mary MacKillop Today is committed to identifying, mitigating and managing risks in all activities.

7. Safeguarding is a shared responsibility: Safeguarding is the responsibility of all staff, partners and others engaging in work or actions relating to Mary MacKillop Today. Genuine change requires collaboration, and Mary MacKillop Today is committed to working with all stakeholders to improve their capacity to prevent, report, and respond to Safeguarding concerns.

8. Strong reporting for improved accountability and transparency: Mary MacKillop Today is accountable to our primary stakeholders and their communities, our staff, partners, donors and all those who come into contact with our organisation. Strong reporting leads to better monitoring, improved understanding of risk, and improved safeguards.

Safeguarding focal points

The CEO shall appoint at least one staff member in Mary MacKillop Today’s office in Sydney and at least one staff member in our office in Dili to be the Safeguarding focal points for the organisation. If either of these focal points are at a senior management level, the CEO must appoint a second focal point. These focal points will promote this important aspect of our work through activities such as staff training, policy revision, and tool development. The Sydney office focal point/s report to the Safeguarding Committee, and the Dili focal point/s report to the Timor-Leste Country Director. The focal points have responsibility for working with staff and partners to ensure reports are responded to and managed in line with the Reporting Procedures outlined within this policy, and for maintaining records including the maintenance of the Safeguarding Incident Register. The focal points can be consulted for any clarifications or concerns related to the implementation of this Policy.

Safeguarding Committee

The Chairperson shall appoint two Directors to form a Committee with the CEO and the Safeguarding focal points to promote this aspect of our work. This Committee oversees the effective ongoing implementation of safeguarding practices, including the Safeguarding Policy and related procedures and practices. The Committee will oversee the response to any Safeguarding investigations and report to the Board of Directors. All committee members are provided with professional development and ongoing support in Safeguarding as required.

Safeguarding risk management

Mary MacKillop Today adopts a risk-based, proportional approach to safeguarding of children and adults. Mary MacKillop Today assesses the level of risk at the activity level through its Risk Management Tool. It then builds safeguarding risk management into its broader risk management approaches via the Risk Framework. These risks are monitored regularly to ensure risk management approaches are adequate.

Mary MacKillop Today assesses and mitigates safeguarding risks in the physical environments under its control, including offices. If Mary MacKillop Today staff are aware of any person (other than staff or others as defined in this policy’s Scope) attending any Mary MacKillop Today activities who poses a risk to children or vulnerable adults, Mary MacKillop Today will manage this risk appropriately.

Managing Risk of Sexual Exploitation, Abuse and Harassment(SEAH)of adults

All activities are assessed for potential risk of SEAH occurring. Activities considered higher risk (for example activities that require staff to travel or work remotely, or activities working with vulnerable populations) are required to have more stringent safeguards in place. As Mary MacKillop Today is a DFAT accredited agency, these safeguards must include the proportionate application of DFAT’s PSEAH minimum standards as required by the risk-level.

Managing Child Safeguarding Risk

All activities are assessed for potential Child Safeguarding risks. Programs classified as ‘contact with’ or ‘working with’ children are considered higher risk, and therefore require more stringent Safeguarding procedures. Programs that work directly with children who may have additional indicators of vulnerability including children in institutional care, children with disability, children from culturally and linguistically diverse backgrounds, Indigenous children such as those of Aboriginal and Torres Strait Islander descent, LGBTI children, children who are unable to live at home, and children in conflict or disaster affected areas should be considered higher risk. However, as children are part of every community in which we work, we are always mindful of potential risks. Risks are monitored and managed at all stages of an activity or project. As Mary MacKillop Today is a DFAT accredited agency, safeguards must include the proportionate application of DFAT’s Child Safeguarding minimum standards as required by the risk-level.


Mary MacKillop Today is committed to rigorous recruitment screening practices as outlined in the Recruitment Policy. These practices aim to recruit the safest and most suitable people to work in our programs and are extended to the appointment of suppliers and contractors, as well as all partner staff working directly on Mary MacKillop Today project activities. Any person may be prevented from working with children if they pose an unacceptable risk to children.

Employment contracts must contain provisions for the prevention of a person from working with children if they present an unacceptable risk to children; and dismissal, suspension or transfer to other duties for any employee who breaches the Safeguarding Policy and Code of Conduct.

All staff will be vetted for any sexual abuse, exploitation, and harassment or other serious misconduct in their previous role through their verbal referee checks. When recruiting for positions classified as ‘Working with Children’ or ‘Contact with Children’:

  • Interview questions must include at least two behavioural based questions that refer to the roles and responsibilities of the candidate in relation to their work with children; and
  • Verbal referee checks must include an assessment of the candidate’s suitability to be in a role where they come into contact with children.
  • The applicant will be requested to disclose if they have been charged with child exploitation offences.

Responses must be documented and filed.

Newly recruited staff with jobs classified as ‘Working with Children’ or ‘Contact with Children’ need to provide criminal checks for each country in which the respective individual has lived for 12 months or longer over the last 5 years, and for the individual’s countries of citizenship. All staff classified as ‘Working with Children’ as well as those deployed overseas, in leadership roles, and service provider roles require an annual criminal check, whereas staff classified as ‘Contact with Children’ require a criminal check on recruitment. For a comprehensive list of Mary MacKillop Today’s Child Safeguarding recruitment and staffing practices, please refer to the Child Safe Recruitment Checklist in the Human Resources Manual and the Recruitment Policy.

In limited circumstances it may prove impossible to obtain a reliable criminal record check a statutory declaration, or local legal equivalent, outlining efforts made to obtain a foreign police check, and disclosing any charges and spent convictions related to child exploitation, may be accepted instead.


The Safeguarding Policy and related procedures are communicated to and signed by all staff and others (as defined in this Policy’s scope) as part of their induction. Staff and others (as defined in this policy’s Scope) receive periodic refresher trainings and pre-deployment training for any person travelling overseas or to visit a Mary MacKillop Today project site. Staff classified as ‘Working with Children’ or ‘Contact with Children’ will be trained in identifying potential signs of harm and actively supporting children to raise concerns, as well as recognising the nature and indicators of child abuse, including harmful behaviours by a child towards another child, and responding and supporting those bringing forward concerns, disclosures, and allegations of child abuse.

Extension to partners

We recognise that Partners play a valuable role in consulting with communities, raising awareness of the policy and responding to complaints and concerns. Partners’ networks are also vital in establishing referral pathways for victim/survivors. Mary MacKillop Today is committed to strengthening and learning from our Partners’ Safeguarding Practices through ongoing training and capacity building.

All Mary MacKillop Today implementing partner representatives involved in the delivery of Mary MacKillop Today activities(including but not limited to the governing body, staff, volunteers and visitors) are included in the scope of this policy. Compliance with this policy and related recruitment and reporting requirements are included in all Partnership Agreements with implementing partners. A copy of this policy is provided to all partners prior to signing the Agreement.

All implementing partners are required to have an equivalent Safeguarding policy, Code of Conduct and reporting procedures that meet the standards outlined within the Mary MacKillop Today policy and that are consistent with the ACFID Code of Conduct, DFAT’s Child Protection and PSEAH Policies & Minimum Standards, and the Catholic Professional Standards. Partners may choose to have a Child Safeguarding Policy and a PSEAH Policy or combine the two policies into a Safeguarding Policy. The CEO or equivalent must appoint at least one focal point. If this focal point is in a senior management role, the CEO must appoint a second focal point. Focal points report to the implementing partner’s CEO or Director.

If Mary MacKillop Today partners or staff work with downstream partners, our partners or staff must ensure that these downstream partners have a Safeguarding Policy that aligns with the Mary MacKillop Today Policy. If they do not, our partners or staff must ensure that downstream partners sign an agreement stipulating that
staff working on any Mary MacKillop Today-funded project must adhere to Mary MacKillop Today’s Safeguarding Policy. This is a requirement within our Partnership Agreement.

Partners’ Safeguarding policies and procedures are appraised through the Organisational Capacity Assessment. Where a partner does not have equivalent policies and procedures in place, Mary MacKillop Today will work with the Partner to develop and operationalise their own documents that meet the above standards. All partner representatives working directly on the Mary MacKillop Today funded activity are required to read, sign and uphold the policy and the organisation must comply with these standards until an equivalent Partner policy can be developed.

Mary MacKillop Today undertakes a safeguarding risk assessment at the Partner level and actively monitors Partners’ compliance with the Safeguarding policy via project reports, regular monitoring visits and annual compliance assessments. Failure to respond to or correct serious or ongoing breaches of the Safeguarding policy may be cause for suspension or termination of the partnership agreement.

Communicating the Policy

All people who come into contact with our organisation, including primary stakeholders (beneficiaries), partners and staff, will be informed of the expected behaviour of Mary MacKillop Today representatives and others working on or visiting Mary MacKillop Today projects, and will be informed of how they can report suspected or alleged misconduct. This information should be in accessible formats and translated into appropriate languages. The Safeguarding Policy will be made available on the Mary MacKillop Today website.

Mary MacKillop Today understands that there are barriers that prevent children and vulnerable adults from disclosing abuse and barriers for adults recognising and/or responding to disclosures. These barriers include a fear of not being believed, concern that reporting an incident might make it worse for the child or vulnerable adult, concern about repercussions of the accused, and fear of being incorrect in the report. These barriers can be reduced by educating personnel, with particular attention to children’s cultural contexts, languages, cognitive capabilities and communication needs.

Participation of Primary Stakeholders

Mary MacKillop Today recognises that effective safeguarding requires collaboration with, and input from, primary stakeholders particularly children and vulnerable adults. We are committed to engaging with primary stakeholders in identifying and managing safeguarding risks, and in the development of safeguarding approaches.

Mary MacKillop Today is committed to child and youth participation. We will do this by providing opportunities for children and young people be heard and incorporate their views into our policies and programs.

In projects where Mary MacKillop Today is ‘Working with Children’ or has ‘Contact with Children’:

  • Children will be asked for their feedback about staff and services.
  • Children will be informed, through child-friendly material, about their right to be safe from abuse and who to contact if they are at risk of abuse, have concerns about a Mary MacKillop Today member of staff or another representative in the organisation, have been abused, or are concerned about another child.
  • Children will be consulted about decisions that affect them
  • Children will be consulted about what makes them feel safe and how this can be recognised by Mary MacKillop Today
  • Where appropriate and feasible within the project scope, children will be provided with age-appropriate information about safe and respectful peer relationships, including through social media
  • Where relevant, children will be provided with information, access, and/or referral to appropriate abuse prevention programs appropriate to the child’s age, development ability, and level of understanding.
Use of images / video / voice of children and vulnerable adults

Mary MacKillop Today’s Communications Policy outlines our approach to ensuring our communications do not put people at risk. Mary MacKillop Today will at all times portray children and vulnerable adults in a respectful, appropriate and consensual way. Our guidelines on the use of images are:

  • Any person appearing in photos, videos, or voice recordings should always be portrayed in a dignified and respectful manner and not in a vulnerable or submissive manner. They should be adequately clothed and not in poses that could be seen as sexually suggestive.
  • Any person appearing in photos, videos, or voice recordings must always be asked for prior informed consent for the use of their images, videos, or voice recordings. When asking for consent to use the image, video, or voice recording, details should be given as to how and where this photo, video, or voice recording will be used, noting that people who are vulnerable may be placed at risk if their story or image is shared. Adults must provide written consent, and children will provide written consent where possible. A parent or guardian must provide written consent for the use of a child’s photo, video, or voice recording.
  • People must be given the opportunity to decline the use of their image and/or decide what personal information is shared publicly.
  • Local cultural traditions should be assessed regarding restrictions for reproducing personal images.
  • When sending images electronically, file labels should not reveal identifying information.
  • All photographers will be screened for their suitability, including police checks where appropriate.
  • Images should be an honest representation of the context and the facts.
  • There should be no identifying information of children or vulnerable adults used in the publication of images, videos, or voice recordings with their location.
  • Any photos, videos, or voice recordings of children should ensure they are portrayed as part of their community.
Breach of Policy

Breaches of the Safeguarding Policy and Code of Conduct constitute gross misconduct and is grounds for termination. Depending on the nature and severity of the breach, disciplinary action for breaches of this policy include:

  • Referral to law enforcement where behaviour constitutes a criminal offence
  • Referral to the Australian Federal Police
  • Internal or external investigation
  • Suspension pending investigation
  • Performance management, formal warning and monitoring
  • Termination of employment or transfer of duties
Malicious or false reporting

This Policy protects any person who, in good faith, reports a Safeguarding incident or any person who has cooperated with a Safeguarding investigation. Malicious or false reporting of incidents with the intention of harming another person’s integrity or reputation amounts to misconduct and is subject to disciplinary action which is detailed in the Human Resources Procedures Manual. This is distinct from reports made in good faith based on the judgment and information available at the time of the report, which may not be confirmed by an investigation.

Policy Review

This Policy is reviewed every two years at a minimum or more frequently if required due to changes in relevant legislation or sector standards. Children and vulnerable adults will be consulted in the review of the Safeguarding Policy and will be asked to contribute to the Code of Conduct regarding what they consider to be appropriate and inappropriate behaviours.


Bullying: The inappropriate use of power by an individual or group, with an intent to injure either physically or emotionally. It is usually deliberate and repetitive. The bullying may be physical or psychological (verbal and non-verbal). Physical bullying includes pushing, hitting, punching, kicking or any other action causing hurt or injury. Verbal bulling includes insults, taunts, threats and ridicules. Psychological bullying includes intimidation and ostracism.

Child: In accordance with the United Nations Convention of the Rights of the Child, ‘child’ means every human being under the age of 18 unless under the law applicable to the child, maturity is attained earlier. For the purposes of this Policy, Mary MacKillop Today considers a child to be a person under the age of 18 years.

Child abuse: Includes physical, sexual, emotional, neglect, bullying, child labour and domestic violence. Abuse happens to male and female children of all ages, ethnicity and social backgrounds, abilities, sexual orientation, religious beliefs and political persuasion. In some cases, professionals and other adults working with children in a position of trust also abuse children.

Child and young person: Regarded to be any person under the age of 18 years, unless a nation’s laws recognise adulthood earlier.

Child-Sex Tourism: ECPAT International defines child-sex tourism as:‘...the commercial sexual exploitation of children by men or women who travel from one place to another, usually from a richer country to one that is less developed, and there engage in sexual acts with children, defined as anyone aged under 18 years of age.’ (ECPAT International, 2006).

Child exploitation: The use of the child in work or other activities for the benefit of others that are to the detriment of the child’s well-being. It includes, but is not limited to, child labour, child trafficking, child slavery, and child sexual exploitation.

Child safeguarding: Actions, policies and procedures that create and maintain protective environments for children to protect them from exploitation and abuse of all kinds (from ACFID Child Safeguarding definition)

Contact with children: Working on an activity or in a position that involves or may involve contact with children, either under the job description or due to the nature of the work environment.

Domestic violence: Occurs when children and young people witness or experience the chronic domination, coercion, intimidation and victimisation of one person by another by physical, sexual or emotional means within intimate relationships (adapted from the Australian Medical Association definition).

Downstream partners: Suppliers, individuals and organisations who are engaged by a Partner or work with a Partner to implement Mary MacKillop Today projects.

Duty of care: A common law concept that refers to the responsibility of the organisation to provide children with an adequate level of protection against harm. It is the duty of the organisation to protect children from all reasonably foreseeable risks of injury.

Emotional abuse: This occurs when a child is repeatedly rejected or frightened by threats. This may involve name-calling, being put down or continual coldness from parent or caregiver, to the extent that it affects the child’s physical and emotional growth.

Fraternisation: Any relationship that involves, or appears to involve, partiality, preferential treatment or improper use of rank or position including but not limited to voluntary sexual behaviour. It could include sexual behaviour not amounting to intercourse, a close and emotional relationship involving public displays of affection or private intimacy and the public expression of intimate relations.

Grant Funded Activity: Any activity or project that is funded through an external funding partner with contractual compliance standards including the Department of Foreign Affairs & Trade (DFAT).Neglect: The persistent failure or the deliberate denial to provide the child with clean water, food, shelter, sanitation or supervision or care to the extent that the child’s health and development are placed at risk.

Partner: Any organisation with which Mary MacKillop Today enters into an agreement to deliver its programs.

Perpetrator: A person (or group of persons) who commits an act of Sexual Exploitation, Abuse and Harassment (SEAH) or other type of crime or offence.

Physical abuse: Occurs when a person purposefully injures or threatens to injure a child or young person. This may take the form of slapping, punching, shaking, kicking, burning, shoving or grabbing. The injury may take the form of bruises, cuts, burns or fractures.

Safeguarding: Actions, policies and procedures that create and maintain protective environments to protect people from exploitation, harm and abuse of all kinds. This encompasses protecting children and vulnerable adults from abuse and maltreatment, preventing harm to children or vulnerable adults’ health or development, and ensuring children grow up with the provision of safe and effective care that enables them to have optimum life chances.

Senior management: Any member of staff who fills the role of the most senior staff member in an office or the organisation.

Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions, for the sexual stimulation or gratification of the perpetrator. It covers sexual offences including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent is considered to be sexual abuse. This is regardless of the age of majority or age of consent locally. These can be contact or non-contact acts, including threats and exposure to pornography.

Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.

Sexual Harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favours, or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated. Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff and personnel.

Transactional sex: The exchange of money, employment, goods or services for sex, including sexual favours.

Victim/Survivor: A person who is, or has been, sexually exploited, harassed or abused.

Vulnerable adults: Those aged over 18 years who, due to their gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or as a result of disasters and conflicts or any other factors, are deemed to be at risk. It also includes adults placed in a situation of vulnerability due to power imbalances, such as organisational hierarchies or partnerships.

Working with Children: Being engaged in an activity with a child where the contact would reasonably be expected as a normal part of the activity and the contact is not incidental to the activity (adapted from DFAT definition). If in doubt, see DFAT Child Safeguarding Risk Assessment Tool.

Incident Report Form

To report a safeguarding incident or concern, click here to complete the Safeguarding Incident Report Form.