School Policies

Purpose

This policy describes University Senior College’s practices for staff and student use of information and communication technologies (ICTs).

Background

University Senior College is committed to ensuring that the use of ICTs does not place staff and students at risk and that the wellbeing and safety of staff and students is protected.

The College’s computer network, internet access facilities, computers and other College Information, Communication and Technologies bring great benefits to the teaching and learning programs and the effective operation of University Senior College.

The overall goal of the College is to create and maintain a safe cyber security environment, which is in-keeping with the values of the College, and legislative and professional obligations.

The computer network is provided by University Senior College in conjunction with the University of Adelaide, and all College IT equipment/devices, are for educational purposes appropriate to the College environment. Staff and students may also use College IT equipment/devices for teaching and learning and personal use which is both reasonable and appropriate to the College environment.

This applies whether the equipment/devices are owned or leased by the College or the University of Adelaide.  It applies to the use of devices and the network, both on or off site.

Guiding Principles

In alignment with the Australian Student Wellbeing Framework, University Senior College is committed to:

• Visible leadership to inspire positive school communities;
• An inclusive and connected school culture;
• Authentic student participation;
• Effective family and community partnerships; and
• Providing support for wellbeing and positive behaviour.

This policy is to be read in conjunction with the following USC policies that are relevant to IT use.  This list is not intended to be exhaustive, but is a quick reference to the main policies that are relevant to IT use and include:

• USC Staff IT user agreement
• USC Staff Computer and Network Policy
• USC Cyber Security Policy
• Critical Cyber Security Breach Response Plan
• Data Breach Response Plan
• IT User Agreement for University Senior College Students
• USC Anti-Harassment Policy
• USC Staff Code of Ethics
• USC WHS Policy
• USC Collaborative Practices Policy
• USC Teaching & Learning Policy

USC also adheres to the IT policies and procedures outlined by the University of Adelaide, including:

• Cyber Security Incident Management Framework
• IT Acceptable Use and Security Policy
• IT Acceptable Use Procedures
• IT Security Procedures
• CSF Security Incident Management Standard
• Security Incident Management Standard (UofA Cyber Security Framework)

ICT Definition

ICT is defined, for the purpose of these guidelines, as:

• School-wide and local area networks (both wired and wireless) including wiring, hubs, routers, transmitters/receivers, and other devices;
• On-premise and cloud servers and application software packages or services;
• Devices (desktop and laptop computers, mobile phones and tablets) and equipment (printers/copiers, projectors, speakers, headsets, and other peripherals);
• Digital resources, learning resource management systems, and distance learning systems; and
• Telephone systems including primary systems, conferencing and integrated voice response management systems, and automatic dialling systems and video capturing, broadcast, receiving, and distribution systems.

Acceptable and Unacceptable Use of ICTs

Acceptable Use of ICTs includes:

• IT facilities are provided to support the College's teaching and learning, administrative and business activities.
• Sending and receiving emails using an appropriate school email account; and
• Using the internet in connection with teaching and learning along guidelines established by the school.

Unacceptable actions or intent may include (but are not limited to):

• Excessive personal use, or personal use that breaches the USC IT User Agreement;
• Using ICT resources for defamation purposes;
• Copyright infringement;
• Illegal or unlawful use, including but not limited to:
  • Accessing or distributing child exploitation materials;
  • Accessing or distributing defamatory material;
  • Accessing or distributing material that could constitute racial or religious vilification, or unlawfully discriminatory material;
  • Stalking;
  • Blackmail and threats;
  • Breach of copyright laws; and/or
  • Breaches of any other legislation.
• Accessing or distributing offensive or inappropriate material;
• Mass distribution of malware and/or spam.
• deliberate, unauthorised corruption or destruction of IT facilities (including deliberate introduction or propagation of computer viruses)
• deliberate, unauthorised access to IT facilities
• unauthorised use of data or information obtained from the use of IT facilities
• transmission or use of material which infringes copyright held by another person or the University of Adelaide
• violation of software licensing agreements
• use of IT facilities to transmit unsolicited commercial or advertising material
• deliberate impersonation of another individual by the use of their login credentials, e-mail address or other means
• violation of the privacy of personal information relating to other individuals
• unauthorised disclosure of confidential information
• use of IT facilities to harass or threaten other individuals
• unauthorised attempts to identify or exploit weaknesses in IT facilities
• use which deliberately and significantly degrades the performance of IT facilities for other users
• use of hardware and /or software to bully, harass, intimidate or threaten a third party.

Internet Use

University Senior College is committed to ensuring that internet use and access is appropriate. Regarding the safety and privacy of students, staff, and other internet users, University Senior College will implement strategies to protect these groups.

University Senior College has established Staff & Student user agreements which outlines the expected standards for internet use and the consequences of breaches of this code.

In circumstances where inappropriate material is sent or received via the internet, University Senior College will take appropriate action to address and mitigate any issues.

University Senior College will implement the following strategies to ensure that the school’s network is appropriately protected from viruses and other malicious software:

Email Use

When using email communication, staff and students of University Senior College should be aware of the following:

• Whilst reasonable care is taken, a school cannot guarantee the confidentiality of online communication by users of the school’s network;
• The email system is monitored by the school, emails are traceable, and may also be recovered;
• Defamatory, sexually explicit, harassing, insulting, or offensive material must not be sent to others, and staff and students must not solicit such materials to be sent;
• Emails may be sent to the wrong destination and cannot always be recalled;
• Any email sent from a school’s network is the property of the school and will necessarily reflect on the school; and
• Email correspondence is no different from paper documents and can be requested by parents or other parties.

User Accounts and Passwords

• All user accounts must have one person nominated as the person responsible for that account.
• Users are responsible for all activity initiated from their accounts, unless it is established that the activity was done by another person who gained access to the user's account through no fault of the user.
• Users must select passwords that cannot be easily guessed and they must not divulge passwords to others, including other staff and students.
• Users must not attempt to determine another user's password.
• If the security of a password is compromised, it must be changed immediately.  USC IT staff and ITDS must be notified immediately.
• Users are not permitted to authorise others to login using their account.
• Users are prohibited from using another user's account.

Social Media

Staff members are expected to exercise discretion, professionalism, and good judgment when engaging in social media activities. Personal social media accounts should be separate from professional ones, and staff should be mindful of their representation of the College in both personal and professional contexts.

To maintain the integrity and confidentiality of University Senior College and the University of Adelaide, staff members are advised to refrain from posting any reference to the College or the University on personal social media accounts. This includes any content that could be perceived as representing the official stance or opinion of the College. Staff members are also requested to confirm and regularly check that privacy settings on their personal social media accounts are appropriately set.

While refraining from direct references to the College, staff members are encouraged to share information regarding school activities and achievements with the Director of Marketing and Community Partnerships. This collaboration ensures that positive news and updates about the College can be appropriately shared through official channels.

All social media posts related to University Senior College must be authorised by the Director of Marketing and Community Partnerships and/or the Principal, or their designated delegates. This includes but is not limited to posts about events, achievements, and official announcements.

Personal or private information regarding students should not be published on any social media site. Student, parent or staff likeness, images, voice recordings, performances or creative work will not be shared on social media without previously obtaining a signed consent form. Once the College has obtained the appropriate permissions and has complied with child protection obligations, photos and videos can be posted, news can be shared, and announcements can be made on social media.

Students and staff should be aware of the following expectations in considering their use of their personal social networking sites/accounts:

• Consideration has been given to the information and images of them available on their sites and they are confident that these represent them appropriately; and
• Comments on their site about their school, friends, or staff, if published, would not cause hurt or embarrassment to others, risk claims of libel, or harm the reputation of their school, their friends, or staff.

Non-Compliance and Breach of Policy

Adherence to University Senior College’s Acceptable Use of ICTs Policy for Staff and Students is a condition of staff employment and student enrolment. Non-compliance with the Policy will be regarded as a serious matter and appropriate action will be taken. Depending on the nature of the inappropriate use of ICT resources, non-compliance with the University Senior College’s Acceptable Use of ICTs Policy may constitute:

• A breach of employment obligations;
• A breach of school enrolment obligations;
• A criminal offence;
• A threat to the security of the school;
• An infringement of the privacy of other persons;
• Exposure to legal liability;
• Sexual harassment;
• Serious misconduct; and/or
• Unlawful discrimination.

Where there is a reasonable belief that illegal activity may have occurred, this will be reported to the South Australian Police (SAPOL).

Sanctions for failing to comply with this Policy may include:

• immediate withdrawal of access to IT facilities, with or without prior notice.
• the Principal may enforce a range of disciplinary measures, including but not limited to a written warning. The Principal holds the authority to consider additional or further actions, such as dismissal from employment.
• Likewise, students found in violation may face consequences, including the potential withdrawal of their enrolment.
• criminal or other penalties imposed by State or Commonwealth legislation.
• financial compensation may be sought by University Senior College and/or the University of Adelaide.

Legal Liability

Staff and students can be held personally liable for any commentary deemed to be defamatory, obscene, proprietary, or libellous. Caution should be exercised with regards to exaggeration, obscenity, copyrighted materials, legal conclusions, and derogatory remarks or characterisations. Staff and students should appreciate that no matter what protections they place around access to their personal sites, their digital postings are still at risk of reaching an unintended audience and being used in ways that were unintended.

Legislative Context

• Education and Early Childhood Services (Registration and Standards) Act 2011 (SA)
• Children and Young People (Safety) Act 2017 (SA)
• Copyright Act 1968 (Cth)
• Equal Opportunity Act 1984 (SA)
• Privacy Act 1988 (Cth)
• Sex Discrimination Act 1984 (Cth)

Relevant Standards and Frameworks

• Australian Student Wellbeing Framework
• Child Protection Curriculum – Information for Educators
• Protective Practices for Staff in Their Interactions with Children and Young People (SA)

This policy assists the College to achieve Aspiration 2 of the USC Strategic Plan.

Principles

All members of the USC community have a right to be safe at College.

USC’s commitment to mutual respect ensures that the College is not a place of harassment or bullying.  All members of the College community are committed to ensure we work in a safe and caring environment, which promotes respect, excellence and positive relationships for all.

It is everyone’s responsibility not to take part in harassment and bullying in any form. This policy is directed at students and is applicable to parents and staff.

It is everyone’s responsibility to inform teachers and leadership staff about harassment or bullying incidents.

An individual who experiences bullying does not have to handle the problem alone.

Definitions

Harassment is

• Unwanted actions or words that annoy, alarm, abuse or demean another person.
• Can be a one-off incident or a repetitive behaviour.
• It may be intentional or unintentional.

Bullying is

• When an individual or group repeatedly misuses power to intimidate, hurt or exclude others.
• Intentional behaviour that can cause psychological, physical or social harm. 
• Undertaken in person
• Manipulating others to take part or through the use of social media such as email, text messaging Snapchat, Instagram or chat rooms.  This type of bullying is referred to as cyberbullying.

Guidelines for how to address harassment and bullying situations

Individuals are encouraged to report incidents of harassment or bullying to a staff member, teacher, Mentor, Counsellor and Wellbeing Coordinator, a Dean of Student Experience, or any other member of leadership.

If students do not feel confident in reporting incidents, parents are requested to contact a Dean of Student Experience, Counsellor(s), Psychologist or Principal.

Parents may inform the staff member of the incident(s), people involved etc. Information about the harassment will be dealt with sensitively.

Staff are to inform the Principal if they are the victim of bullying or harassment. If the claim is against the Principal, staff are to inform the Council Chair.

Parents and students are requested not to take matters into their own hands by making contact with the student who they believe has been the perpetrator of the bullying.

​​​​​​​Parents and victims of harassment/bullying are to be informed about possible procedures and consequences.

At University Senior College we are committed to preparing students for success at the senior secondary level and tertiary study.  We aim to promote a cooperative environment that fosters the development of knowledge, skills, attitudes, self-reliance and a sense of self-worth that will enable students to maximize their personal potential and become independent learners.  We recognise that this involves not only the development of the students’ academic skills but also helps prepare students to accept responsibility as young adults for their choices and their actions.

Behaviour Codes

A Student Charter is developed by students each year.  The Charter is used as a reference guide when addressing behaviour issues.

Staff and students at University Senior College expected to:

• treat each individual with respect.
• create a safe, secure and supportive learning environment.
• follow a code of behaviour based on mutual respect.
• encourage effective communication.
• provide an environment that celebrates success.
• Use IT appropriately and not as a tool for bullying, harassment, humiliation or intimidation of others.

Everyone at University Senior College has the right to:

• be provided with every opportunity for intellectual and emotional growth.
• be treated with respect and take responsibility for treating others with respect.
• privacy and confidentiality, consistent with safety and legal responsibilities.
• feel valued and be treated with equity according to need.
• feel safe and cared for, and be free from verbal, physical, racial, sexual or emotional abuse.
• seek and to receive help, support or advice when needed.

Everyone at University Senior College has the responsibility to:

• show courtesy and consideration.
• adhere to College policies.
• treat their own and others’ property with care and respect.
• respect other people and tolerate different viewpoints and perspectives.
• consider consequences and accept responsibility for choices.
• monitor their own behaviour as a group member.

Irresponsible Behaviour

Behaviour that is disruptive and disrespectful is unacceptable.  All members of the College community are expected to behave in a respectful manner.  Students who behave in a disrespectful and unsatisfactory manner will be asked to meet with:

• a staff member
• Dean of Student Experience
• Counsellor(s) or Psychologist
• Principal or Principal’s delegate

where an agreed Behaviour Plan will be discussed. 

Continual inappropriate behaviour will affect the student’s enrolment.

Consequences for all behaviours

Responsible behaviours increase students’ range of future opportunities whereas irresponsible behaviour decreases those options and may result in termination of enrolment.

Students who wilfully damage property are invoiced for the repairs and enrolment will be reviewed.

Responsible behaviour in teaching and learning areas (including study areas)

• Respecting the right of students to learn and teacher to teach.
• Interacting positively with the members of the College community.
• Caring for the College’s facilities and resources (i.e. keep areas clean and tidy);
• Acknowledging that all actions lead to consequences.

Learning Etiquette

In classrooms and laboratories, students are expected to:

• Be seated and ready to begin a few minutes before official starting time.
• Place their mobile phone on silent.
• Bring only water to class.

In lectures, students are expected to:

• Record their cards on the card reader or sign the card – otherwise a text message is sent home to indicate non-attendance.
• Fill up seats from the front to maximize concentration and engagement.
• Participate as an active listener and ask questions as appropriate.
• Ask permission from the lecturer if they wish to record a lecture.

Study Rooms

• All students have a right to a quiet study area where they can work without interruptions and distractions.  Study areas are available to students for quiet study during lesson time in both the Jordan Building and Gawler Place. Students are also encouraged to make use of facilities such as the Barr-Smith Library, the University Hub and the State Library.

Student Exclusion or Suspension

Suspension or exclusions from the College are the responsibility of the Principal (or Principal’s delegate).  Suspensions recommended by a Dean of Student Experience or Counsellor(s) are ratified by the Principal.  The Principal directs all contact with parents and makes the final decision.  The Principal keeps documentation in confidence. Relevant information is distributed to the relevant Dean of Student Experience and, Mentor & Counsellor(s).

Social Events

While the College acknowledges that its duty of care for students does not extend outside of College hours or College organised functions, many parents often request some guidelines regarding social events.  The following is provided to assist parents when requested:

• During term time, parties should not be held during the week and social activities should be kept to a minimum, as study is a priority.
• Responsible male and female adults are present to supervise.
• Neighbours and local police notified, if there are events held over the weekend.
• A formal guest list and gate security are both recommended.
• The College will not endorse any social functions organised by parents or students.

It is an offence for adults to provide minors with alcohol, vapes even in private homes and private functions to underage people.

This policy and associated practices assist the College to achieve the Graduate Attributes and all Aspirations of the USC Strategic Plan.

Statement of Intent

USC holds the care, safety and wellbeing of young people as a central and fundamental responsibility of our College. This policy describes University Senior College’s Child Protection practices. University Senior College acknowledges that every child and young person has the right to be always safe from harm. Staff at USC are expected to work within the USC Values of mutual respect, integrity and diversity at all times.

Child Protection is paramount to USC as a safe environment for all students. Maintaining a safe environment for students is a shared responsibility and assists the College to be student focused in all aspects.

The Child protection policy includes a Mandatory Notification policy and procedures, Keeping Them Safe policy and procedures and Protective Practices.

Purpose

University Senior College is committed to adhering to the Child safe environments. We

• Take a preventative, proactive and participatory stance on child protection issues where the safety and wellbeing of children is the paramount when we develop activities, policies and management practices.
• value and embrace the opinions and views of our students and have a strong focus on our adult learning environment and student agency.
• Encourage and assist students to build skills that will assist them to participate in society; and
• Take action to protect children from physical, sexual, emotional, and psychological abuse and neglect.

Legal Obligations

University Senior College is committed to promoting the safety, wellbeing and participation of children and young people. This includes:

• Supporting mandatory notifiers to report and respond to children and young people at risk of harm as outlined in the mandatory notification section.
• Ensuring a safe environment for children and young people is maintained; and
• lodging a Child Safe Environments Compliance Statement with the SA Department of Human Services.

Responsibilities

Various staff members of University Senior College will have different responsibilities regarding Child Protection, including requirements relating to mandatory reporting.

The Principal

The Principal is responsible for the overall running of the College and in relation to Child Protection this includes the following:

• promoting Child Protection wherever possible and ensuring that Child Protection is included regularly in staff training.
• ensuring that Child Protection is included in the College’s curriculum, which in the case of USC, is the mentoring program.
• when a mandatory report has been made, assisting staff to complete site documentation, and then sign the mandatory notification record and ensure this is stored correctly and confidentially.
• ensuring that students and staff receive adequate support if involved in a child abuse situation or are at risk of harm.      
• ensuring that staff are supported when making a mandatory report and police report; and
• ensuring that staff and volunteers have completed Working with Children Checks and RAN-EC/RRHAN-EC training, and that third parties have completed Working with Children Checks where required.

Staff

All staff of University Senior College are responsible in ensuring the College is a safe environment and for the following:

• reporting any suspected risk of harm or abuse to the Child Abuse Report Line (CARL) on 13 14 78 and a police report as required.

• advising the Principal when a report is being/has been made (unless the report involves the Principal in which case it should be reported to the Chair of the College Council).
• when concerning behaviour has been observed, the staff member who witnessed it must alert an appropriate senior staff member; and act if children and young people have disclosed information about inappropriate behaviours of other adults. Recent changes to legislation require staff to make a police report about concerns related to a staff member, whether they have proof or not.

Code of Conduct, Professional Boundaries and Expectations of Staff and Volunteers

University Senior College has developed a Staff Code of Conduct to specify standards of conduct and care, professional boundaries, ethical behaviour and unacceptable behaviour when working and interacting with children and young people.

The Code of Conduct applies to all staff and breaches of the Code may result in disciplinary action or, in the case of serious breaches, dismissal.

Compulsory behaviour

• Staff and volunteers must comply with the College’s Child Protection Policy.
• Staff and volunteers must behave as a positive role model to students.
• Staff and volunteers must promote the safety, welfare and wellbeing of students.
• Staff and volunteers must promote the safety, participation and empowerment of students with a disability.
• Suspicions of risk of harm, harm or abuse to a child must be reported to the Child Abuse Report Line (CARL – 13 14 78) and to the Principal, or to Chair of the College Council if the situation involves the Principal.
• Concerning behaviour or breaches of the Child Protection Policy must be reported to the Principal. or to the Chair of the College Council if the breach concerns the Principal. The Principal (or other delegated person) will be responsible for developing an appropriate plan of action and ensuring it is followed.
• Students must be treated with respect and encouraged to speak up and participate.
• Actions must be undertaken transparently and with the knowledge and consent of the Principal.
• When working one-on-one with children and young people, actions must be:
  • Public – ensure the environment is visible, public and busy. Use the College’s authorised ICT systems.
  • Authorised – parents must be informed and have given consent and the activity must be authorised by the Principal.
  • Timely – the activity must be a legitimate part of the staff member’s role, support must be provided within normal work hours where possible, and sessions should be concise and not unnecessarily prolonged; and
  • Purposeful – the activity should address or be linked to an identified wellbeing and/or learning need of the child or young person.
• Manage challenging behaviour through non-physical intervention, such as directing other children and young people to move away from the situation, talking to the child, directing the child or young person to a safe place, and directing other children to a safe place. Physical restraint should only be used as a last resort and must only be used when the safety of a child or young person or adult is threatened. Physical restraint must not be used as a response to property destruction, disruption to the education or care activity, refusal to comply, verbal threats, leaving an education care setting, or a need to maintain good order unless someone’s safety is clearly threatened.
• Become as familiar as possible with the values of various cultural groups enrolled at the College.
• Ensure that the privacy of students is respected, and that personal information is managed in accordance with the College’s Privacy Policy.

Unacceptable behaviour

• Failure to act when an allegation of harm or abuse is made, including failure to report the allegation may result in disciplinary action, dismissal and / other government sanctions.
• Failure to intervene in situations where sexual harassment is occurring.
• Inappropriate comments about a child or young person’s appearance, including excessive flattering comments.
• Inappropriate comments, conversations or enquiries of a sexual nature.
• Use of inappropriate nicknames.
• Obscene gestures and/or language.
• Jokes or innuendo of a sexual nature.
• Facilitating/permitting access to pornographic material.
• Facilitating/permitting access to sexually explicit material that is not part of an endorsed curriculum.
• Correspondence of a personal nature via any medium (including phone, text message, letters, email, social media, internet posts) that is unrelated to the staff member’s role. This does not include class cards or bereavement cards.
• Discussing personal lifestyle details or your opinions, other staff or children and young people unless directly relevant to the learning topic and with the individual’s consent.
• Corporal punishment (for example, physical discipline or smacking)
• Inappropriate use of physical restraint/restrictive practices.
• Unwarranted or unwanted touching of a child or young person personally or with objects (for example, pencil or ruler)
• Initiating, permitting or requesting inappropriate or unnecessary physical contact with a child or young person (for example, massage, kisses, tickling games) or facilitating situations that unnecessarily result in close physical contact with a child or young person.
• Inviting/allowing/encouraging children and young people to attend the staff member’s home.
• Attending children and young people’s homes or their social gatherings.
• Being alone with a child or young person outside a staff member’s responsibilities.
• Entering toilets occupied by children or young people when supervision is not required or appropriate.
• Transporting a child or young person unaccompanied.
• Using toilet facilities allocated to children and young people.
• Undressing using facilities allocated to children and young people, or in their presence.
• Tutoring (outside the College’s directions or knowledge)
• Giving personal gifts or special favours.
• Singling the same children and young people out for special duties and responsibilities.
• Privately giving money and/or gifts to individual children/young people.
• Photographing, audio recording or filming children or young people via any medium when not authorised by the site leader to do so and without required parental consent.
• Using personal rather than College equipment for approved activities, unless authorised by the site leader to do so.
• Correspondence or communication (via any medium) to or from children and young people where a violation of professional boundaries is indicated and where the correspondence has not been provided to the Principal or their delegate via the staff member.
• Still/moving images or audio recordings of children and young people on personal equipment or kept in personal locations such as car or home that have not been authorised by the Principal.
• Uploading or publishing still/moving images or audio recordings of children and young people to any location, without parental and site leader’s consent.
• Creating or using private chat rooms; and
• Filming/recording students for the use of behaviour training/modification without obtaining prior permission from the Principal and parents.

Recruitment, Selection, Screening and Background Checks

University Senior College will ensure that all employees and volunteers have a current Working with Children Check, and that these are updated every 5 years. University Senior College does not employ a person or allow someone to volunteer unless a Working with Children Check has been conducted in the preceding 5 years. University Senior College is registered with the Department of Human Services (DHS) Screening Unit and will verify the accuracy of WWCCs for all potential and current employees in the DHS Screening Unit online portal.  University Senior College will advise the Screening Unit when we become aware of certain information regarding any person involved with our organisation, including any serious criminal offence, child protection information, or disciplinary or misconduct information.

To thoroughly screen and assess potential employees and volunteers, University Senior College will also conduct background checks and risk assessments. This will involve:

• undertaking face-to-face interviews.
• confirming educational status.
• requesting referee reports and obtaining reference checks.

It may also include:

• conducting criminal history assessments; and/or
• undertaking other background checks (for example, psychological testing, or on the job observation).

Mandatory Reporting

Any person who, while in the course of their work or volunteering, suspects that a child is being or has been harmed, abused or is at risk of harm, must report their suspicion to the Child Abuse Report Line (CARL). This includes all persons who are not mandated to report suspected child abuse or neglect under the legislation. 000 should always be called in an emergency situation.

All serious concerns of suspected child harm abuse or neglect must be reported via CARL by phoning 13 14 78. The telephone line is available 24 hours a day. Serious concerns include the suspicion that a child is in imminent or immediate danger of serious harm or serious injury or is experiencing chronic neglect. The following information is required to be provided when making a report to CARL:

• the child’s name, age, date of birth and address.
• a description of the injury, abuse and/or neglect (current and previous)
• the child’s current situation.
• the location of the child, parent or caregiver and alleged perpetrator; and
• when and how you found out about the abuse.

Non-serious concerns can be reported via eCARL, which is the online Child Protection reporting system.

All adult works (even if not a mandated notifier) have a legal obligation to report child sexual abuse to the police and to protect a child from sexual abuse.  Failure to meet these obligations may be considered a criminal offence.

University Senior College will maintain records of all mandated reports made. All written documentation is to be provided to the Principal and kept secure by the Principal. Any report related to the Principal is to be provided to and kept by the Chair of the College Council.

University Senior College will ensure that adequate support is provided to the student involved. The support provided to the student includes access to Student Counsellors and or any member of the Leadership team and a safe space in the College.

It is a requirement that employees and volunteers inform the Principal of any mandatory notifications made. This will ensure that the Principal can put in place the appropriate action to support the child. If the concerns or allegations raised in the notification involve the Principal, then the Chair of the College Council must be informed instead.

Homestay

Homestay arrangements attract several regulatory requirements because of their interrelationship with migration law and requirements relating to overseas students. In situations involving homestay students, University Senior College is committed to a safe environment for students who require access and employ Australian Homestay Network who:

• Ensure all adults residing at any homestay have a current Working with Children Check, including all WWCCs in the DHS Screening Unit portal.

• Conduct regular visits and assessments of the homestay with access to all areas of the premises, for the purposes of checking compliance with legislative requirements and homestay standards. This includes:
  • A safe, private and secure bedroom for the student’s sole use with suitable storage space for clothes, personal items and study materials, and a suitable area in which to study including a desk, chair and adequate lighting.
  • A clean home with appropriate furnishings suitable for a family and students.
  • Access to a shared or private bathroom, with reasonable time allowed for showers.
  • Access to the kitchen, living areas, laundry facilities and shared areas of the home.
  • Access to heating in winter and cooling in summer if required.
  • Household facilities and appliances which comply with government regulations regarding safety standards;
  • Provision of keys, alarms or passwords required to have free access to the homestay residence.
• Ensure host families have an appropriate insurance policy to cover students residing in their home.
• Ensure there is regular training of host families, particularly those hosting students under 18 years of age.
• Ensure that there is a 24-hour emergency contact number that is known to students, the host family and the education provider; and
• Maintain regular contact with host families, students and College staff as required.

Vulnerable Students

University Senior College acknowledges that there are vulnerable students who may be at a higher risk of experiencing harm, abuse and neglect due to their circumstances. These students may struggle with advocating for themselves or communicating their experiences to other people. Vulnerable students include students with disability, students in care and new arrival students. University Senior College will ensure that:

• College staff will consult with a student with disability, their parent and/or other associates (such as external allied health professionals). During consultation, staff will discuss the impact of the disability to assess the student’s ability to advocate for themselves.
• Staff will be mindful of the individual circumstances of vulnerable students and will be mindful of the potential signs of child abuse or neglect that vulnerable students may exhibit; and
• Individual student needs and circumstances will be considered when teaching the Child Protection curriculum. This includes being mindful of and sensitive to cultural differences.

Curriculum

University Senior College recognises the importance of addressing matters raised in the Keeping Safe: Child Protection Curriculum (KS:CPC). The two main themes of the KS:CPC are ‘we all have the right to be safe’ and ‘we can help ourselves to be safe by talking to people we trust’.

The keeping children safe themes are implemented in the mentoring program within the topics of consent and sexual health, particularly at Year 10 and are revisited in the Consent program at Years 11 and 12.

University Senior College is committed to ensuring that the curriculum addresses student agency where children and young people are informed about their rights, participate in decisions affecting them and are taken seriously. University Senior College will address this in the development of the student charter, within the Consent program and during the O Week activities.

Online Safety

University Senior College acknowledges and accepts its responsibility to ensure that children are protected from harm when participating online.

University Senior College is committed to creating a safer online environment by ensuring students and parents understand the USC IT Agreement upon enrolment.

University Senior College has developed Acceptable Use of Information and Communication Technologies for Staff/Students Policies, and a Student Anti-Bullying and Harassment Policy. These documents also address online safety.

Policy Review

University Senior College’s Child Protection Policy and Procedures will be reviewed and updated every 2 years. The Child Protection Policy and Procedures will also be reviewed and updated when the College:

• Expands the services it offers to children and young people;
• Undergoes a substantial change to the responsible or managing authority; or
• Experiences an event or incident where children or young people were or could have been at risk of harm.

When changes are made to the Child Protection Policy, University Senior College will lodge a new Compliance Statement with the SA Department of Human Services.

 

Legislative Context

• Child Safety (Prohibited Persons) Act 2016
• Children and Young people (Safety) Act 2017)
• Statutes Amendment (Child Sexual Abuse) Act 2021
• Criminal Law Consolidation Act 1935 (SA)
• Equal Opportunity Act 1984 (SA)
• Sex Discrimination Act 1984 (Cth)
• Teacher Registration and Standards Act 2004 (SA)
• Education and Early Childhood Services (Registration and Standards) Act 2011(SA)
• Education Act 2013 (Cth)
• Education Services for Overseas Students Act 2000 (including National Code of Practice for Providers of Education and Training to Overseas Students 2018)
• Disability Discrimination Act 1992 (Cth)

Relevant Conventions

• National Principles for Child Safe Organisations
• The United Nations Conventions of the Rights of the Child

Relevant Standards and Frameworks

• Australian Student Wellbeing Framework
• National Quality Framework
• Safe & Supported: The National Framework for Protecting Australia’s Children 2021 - 2031
• Child Safe Organisations National Principles
• Disability Standards for Education 2005
• Homestay Standards

Relevant Cross Sector Guidelines

• Protective Practices for staff in their interactions with children and young people
• Managing allegations of sexual misconduct in SA education and care settings
• Responding to problem sexual behaviour in children and young people
• Suicide Postvention Guidelines

The Complaints Policy and Grievance Procedure apply to all members of the USC community, students, parents and staff. USC is committed to the delivery of a high-quality learning pathway and having structures in place to ensure every member of the College community feels safe and supported. It is recognised that, from time to time, grievances may arise, and the following procedures are designed to assist in reaching a satisfactory resolution for students, parents/caregivers and staff. USC staff will work alongside members of the community to reach agreement on a suitable action plan for resolving issues or concerns.

If you wish to arrange a time to speak with someone about a grievance, it is a good idea to inform them of the issue in advance so that they are better able to provide information when the meeting takes place. If at any stage of these procedures you would like to have a support person present as an observer, it is important to negotiate such an arrangement prior to a meeting.

There are some grievances of a very serious nature, where a member of the College community may need to approach the Principal directly and immediately, but most grievances in a College can be resolved before taking such a step. A student or parent/caregiver can raise a concern or complaint if they think that the College or a member of the College community has:

• Acted unfairly or impolitely.
• Acted improperly.
• Failed to do something that was assured or anticipated.

Under such circumstances your concern or complaint may be about:

• Issues related to teaching and learning.
• The behaviour, comments and decisions of staff often related to student conduct.
• A policy, procedure, or practice.
• Bullying and harassment.
• Work, health, and safety.

At University Senior College:

• We support students to reach their personal best.

• Our values of mutual respect, trust and integrity, diversity and inclusivity underpin all we do.

• We value the involvement of our community and see parents and guardians as integral to our success. 
• We promote and support an adult learning environment where relationships are based on mutual respect.
• We encourage the resolution of complaints when they arise at the College level, wherever possible.
• We support the rights of students, parents, guardians and staff to have their complaints listened to, taken seriously, in good faith and to be addressed and resolved expeditiously, fairly and reasonably. The outcome will be communicated to all parties involved once a resolution has been reached.
• We comply with all relevant statutory and legal requirements. These include but are not limited to antidiscrimination and vilification laws, child protection laws and family court orders.

Guiding Principles

Parents, guardians and students are entitled to lodge a bona fide complaint with the College. This means that complaints should be lodged in good faith.

Some points to consider if you wish to lodge a concern or complaint:

• Raise the concern or complaint as soon as possible and maintain confidentiality.
• Clearly identify the issue and communicate what outcome you seek.
• Provide in writing the key points of your concern or complaint.
• Focus on the facts or details of what has taken place and avoid personal or inflammatory comments.
• Act in good faith to achieve an outcome acceptable to all parties.
• In the first instance only discuss your concern or complaint with the people directly involved.
• Have realistic and reasonable expectations about what course of action is required to resolve the concern or complaint satisfactorily.

Please note:

Neither the Minister for Education nor the Department for Education have any power to directly intervene in any complaints relating to the operations of a non-government College.

Grievance Procedure

 

This policy assists the College to achieve Aspirations 1 and 2 of the USC Strategic Plan.

Principles and rationale

The principles of natural justice and procedural fairness will apply in the management of suspected drug-related incidents.

Overarching policy statement

USC is committed to maintaining a safe, secure and supportive environment for its community.  This policy is part of our Whole College Drug Strategy that includes a range of curriculum; policies and procedures; and positive College environment initiatives.  USC takes action to prevent drug use by students and to intervene if it occurs by taking a whole of College approach.  The use, possession and/or distribution of illicit drugs and the unsanctioned use and distribution of drugs such as alcohol, tobacco and prescription drugs, are not accepted.

Intervention related to drugs and alcohol

The consumption of alcohol, tobacco, vapes or illicit drugs on The University of Adelaide campus or in the vicinity of or in the College is prohibited.  It is also prohibited at College functions.  Breaches of this policy will result in a meeting with the appropriate leadership staff where consequences will be outlined.  The Principal will determine in consultation with parents/guardian, the nature of consequences, which may include termination of enrolment.

Authority

This policy is consistent with The Department of Education Intervention matters: A policy statement and procedural framework for the management of suspected drug-related incidents in schools.  This policy was developed by our Drug Strategy Core Team and endorsed by the staff and Council.  To ensure continuous improvement, College procedures will be reviewed after every drug-related incident, whilst the policy will be reviewed at least every two years.

Student Agreement

During enrolment interviews, all students sign the following agreement.

I understand that during school hours whilst on or near the College campus, or when involved with any official College activity, I am not permitted to:

• Smoke and/or possess tobacco products, including using or possessing a Vape.
• Consume and/or possess alcohol.
• Possess and/or use pharmaceutical drugs for non-medical purposes.
• Possess and/or use illegal drugs, possess and/or use drug-related equipment, such as bongs, pipes or syringes (except for medical purposes).

The limit of the campus is defined as any space bounded by and including Grenfell Street, King William Street, River Torrens and Frome Road.

During the time a student is enrolled at USC, access and use of the Uni Bar for any reason is not permitted.  

Students understand that if they engage in any of the above activities, they jeopardize enrolment at University Senior College.

If suspected drug-related incidents occur and drug issues arise, they will be managed and responded to in ways that:

• minimise the harm to all members of the College community.
• ensure the wellbeing, educational careers and ongoing support for the students involved.

are both firm and fair.

The University Senior College community works collectively to achieve its Vision and Mission. Good communication is a vital ingredient to a high performing College.  The College’s main value mutual respect is critical when communicating and the College expects staff, students and parents to communicate in a respectful manner.

USC uses a range of platforms to communicate with the community. Parents may expect to access College information via the website, on the College’s Facebook or Instagram page. Important information is also made available via email from the Principal, Deans of Student Experience, or individual staff members.

Staff will respond to parent and student emails in a reasonable timeframe, and during the working week, this will usually be within 24 to 36 hours during the working week. Part-time staff will respond to emails when they are on duty. Staff are not required to respond to emails over the weekend, College holiday periods, or after hours, in line with the Right to Disconnect legislation.

If a parent or student believes their issue is an emergency and the matter requires attention within 24 hours, they are encouraged to contact the Principal.

Regular attendance at all mentoring sessions, classes, tutorials and lectures is fundamental to student success, achievement and positive wellbeing.

Regular attendance supports students to develop positive relationships with their peers and with USC staff.

Regular attendance assists in student academic achievement.

At University Senior College full attendance is expected, in both mentoring and academic programs (classes, tutorials and lectures), unless there are significant extenuating circumstances. Extenuating circumstances may include the following:

• Occasional illness verified by a parent
• Occasional illness verified by a medical practitioner when an assessment item falls at the same time as the absence.
• Ongoing illness verified by a medical practitioner.
• Ongoing mental wellbeing concerns verified by an appropriate medical practitioner.
• Family occasion, which is approved by the Principal and is less than 1 month.
• Family occasion, which is approved by the CE of AISSA and is more than 1 month.

If a student has ongoing absences, the student and parent will be required to meet with the Dean of Student Experience, and/or another member of the leadership team to discuss the absence and determine steps forward to support the student to return to full attendance.

Student Responsibility

• A student is required to attend all timetabled lessons punctually. Should the student be delayed, we request that the College be advised on +61 8 8313 4988 as soon as possible.

Parent/Caregiver Responsibility

The College has an Attendance Policy which explicitly states that full attendance is expected of all students, unless verified by a medical practitioner, or in the case of extended absence, supported by the Principal or CEO of AISSA. Students and parents sign this policy upon enrolment.

If, due to illness or other legitimate reason, a student is unable to attend College, a parent/caregiver is requested to contact the USC Reception by email uscabsentees@adelaide.edu.au or 8313 4988, preferably before the students class begins. In case of illness, a medical certificate is required.

Occasionally parents wish to take students out of College for an extended period for reasons other than illness. Generally, these students may be travelling to play competitive sport or on a family holiday. If it is for holidays, the College does not condone students taking time out for vacation, unless it is exceptional circumstances. If a student is under 17 there is an Exemption Form to be completed and returned to the Principal for approval. If a student or parent informs a mentor or subject teacher a student will be absent for a period longer than a week, they will need to complete the Exemption form. The form should go to the Dean of Student Experience for checking and then to the Principal for approval. The form is in Shared files/forms/student.

If a parent wishes to take a student out for more than a month, approval must be sought from the CEO of Independent Colleges SA.

Teacher Responsibility

All teaching staff are expected to complete their class roll within the first 25 minutes of class. An automatic SMS is sent to parents of students who have an unexplained absence at the 30-minute mark of the lesson. Rolls must altered to show students who have arrived late to assist in accurate information being sent to parents. ESOs will also telephone parents to inform them of student absences. When absences continue, the Deans of Student Experience will hold meetings with the student concerned and their parents.

For Year 10, 11 and Year 12 tutorials/ classes, teachers are expected to record the attendance at every lesson by logging on to https://synweb.usc.adelaide.edu.au/ , using their staff ID and password. If a staff member is supervising a class for another teacher, they are requested to log on to Synweb and select the staff member’s class they are covering to record absences; via Students/Attendance Maintenance/Staff Code.

For Year 12 Lectures, there is an electronic proximity card system. Card readers can be collected from the Jordan Reception and should be returned there as soon as possible after the lecture. The teacher must swipe his or her ID card first and students can then follow. For those students who do not have their cards, a paper sign-in form is included with the scanner.

 Accurate attendance records are important. These records are legal documents which have on occasions been required in court. This is a very important part of our duty of care to the students.

In cases of repeated absence or lateness, in the first instance the teacher should discuss this with the student and notify the student’s Mentor and the relevant Dean of Student Experience. The mentor or Dean may refer the concern to the College Counsellor, or Principal.

This policy assists the College to achieve Aspiration 1 and 2 of the USC Strategic Plan.

Legislative requirements

From 1 July 2019, Colleges which are bodies corporate (companies limited by guarantee, incorporated associations or body corporates under any law) are required to observe the provisions of the Corporations Act which relate to whistleblowing.  For large proprietary companies, there is also a requirement to have a whistleblower policy which applies from 1 January 2020.

Registration requirements

For College registration, the South Australian Education Standards Board requires that Colleges have in place and implement, policies and procedures for managing complaints and grievances from students, parents, caregivers and the community. These requirements are set out in the Education and Early Childhood Services (Registration and Standards) Act 2011 (SA).

1. INTRODUCTION

1.1 Purpose and scope

This policy applies University Senior College Inc.  in protecting eligible whistleblowers and managing qualifying disclosures made regarding misconduct in relation to the College.

This policy can be accessed in Shared files in the College network and is made available to Council members and employees.

1.2 Related policies

• Complaints or allegations of staff misconduct that do not meet the criteria of a whistleblowing disclosure will be addressed in accordance with the College’s Code of Ethics, Child Protection Policy, Anti-Harassment and Anti-Bullying Policy, Grievance Policy, Resolving Workplace Bullying Policy and the Work Health and Safety Policy.
• Disclosures about reportable conduct will be addressed in accordance with the College’s policies outlined above.
• Disclosures regarding a grievance between staff members about work matters, including work relationships and decisions made by other staff members which impact on their work, may be addressed in accordance with the Code of Ethics, Grievance Policy and Resolving Workplace Bullying Policy.
• Unlawful discrimination, harassment or bullying complaints may be addressed in accordance with the College’s policies as they relate to the concern raised.

2. What is a qualifying disclosure?

A qualifying disclosure occurs when an eligible whistleblower makes a disclosure to an eligible recipient, and the eligible whistleblower has reasonable grounds to suspect that the information concerns a disclosable matter.

3. Who can make a qualifying disclosure?

3.1 Eligible whistleblowers

An eligible whistleblower is an individual who is or has been any of the following, in relation to the College:

• a Council member
• an employee
• a person who supplies goods or services (paid or unpaid)
• an employee of a person who supplies goods or services (paid or unpaid)
• an individual who is an associate of the College (as defined in the Corporations Act); and
• a relative or dependent (or dependents of a spouse) of any individual described above.

3.2  Anonymous disclosures

A disclosure can be made anonymously. However, this may make it difficult to investigate the reported matter. University Senior College encourages disclosers to provide their names.  If a discloser wishes to disclose anonymously, the discloser should provide sufficient information to allow the matter to be properly investigated and disclosers are asked to provide an anonymous email address through which additional questions can be asked and information provided.

4. Disclosable matters that qualify for protection

4.1 Disclosable matters

A disclosable matter is a disclosure of information where the eligible whistleblower has reasonable grounds to suspect that the information relating to the College or a related company concerns such as:

• misconduct
• an improper state of affairs or circumstances.
• illegal activity (including conduct of officers and employees) – meaning activity in breach of the Corporations Act or specified financial services legislation, or an offence against any law of the Commonwealth punishable by imprisonment of 12 months or more; or
• conduct (including conduct of officers and employees) that represents a danger to the public or financial system.

This may include any conduct in relation to the operation of the College that involves:

• fraudulent activity.
• unlawful or corrupt use of College funds.
• improper accounting or financial reporting practices.
• systemic practices that pose a serious risk to the health and safety of any person on College premises or during College activities.

4.2  Reasonable grounds to suspect

A discloser would have ‘reasonable grounds to suspect’ if the discloser has a suspicion that could reasonably be formed based on the facts and information available to them.

If a disclosure is made without 'reasonable grounds to suspect’ (e.g. where the disclosure is unfounded), the disclosure will not be a qualifying disclosure and the discloser will not have the protections provided for under this policy and the Corporations Act.

4.3  Personal work-related grievances

Generally, disclosures that concern personal work-related grievances do not qualify for protection.  

A disclosure will concern a personal work-related grievance of the discloser if the information:

• concerns a grievance about any matter in relation to the discloser's employment, or former employment, having or tending to have implications for the discloser personally; and
• does not have significant implications for the College that do not relate to the discloser; and
• does not concern conduct that is:
  • an alleged contravention of the Corporations Act and specified financial services laws; or
  • an offence against another law of the Commonwealth, which is punishable by imprisonment of 12 months or more; or
  • a danger to the public or financial system.

Examples of disclosures regarding personal work-related grievances that may not qualify for protection include:

• an interpersonal conflict between the discloser and another employee
• a decision relating to the engagement, transfer or promotion of the discloser
• a decision relating to the terms and conditions of engagement of the discloser
• a decision to suspend or terminate the engagement of the discloser, or otherwise discipline the discloser.

These matters will be addressed in accordance with the College’s Code of Ethics, Promotion Policy and Grievance Policy.

A disclosure could qualify for protection if it concerns a personal work-related grievance and also concerns alleged detriment (or a threat of detriment) to the discloser.

5. Who can receive a qualifying disclosure?

5.1 Eligible recipients

An eligible recipient is an individual who occupies any of the following roles, in relation to the College or a related company:

• a Council member or a member of Executive Leadership (Principal, Director School Operations, Director Academic Programs or Finance Manager).
• an auditor, or member of an audit team of the College or a related company.
• an actuary of the College or a related company.

5.2 Making a qualifying disclosure

While an eligible whistleblower can make a disclosure to any eligible recipient, the College encourages them to make a disclosure in writing to the Principal via email at anita.zocchi@adelaide.edu.au

If it is not appropriate for the disclosure to be made to the Principal, the eligible whistleblower is encouraged to make the disclosure, in writing, to the Chair of the Council, via email at paul@pauldalby.com

Where a disclosure is made to an eligible recipient who is not the Principal, then subject to the confidentiality protections set out at Section 7 below, it will generally be passed onto the Principal and dealt with in accordance with Section 6 below. 

5.3 External disclosures

Disclosures may also qualify for protection if they are made to ASIC, APRA or a prescribed Commonwealth authority, or if an eligible whistleblower makes a disclosure to a legal practitioner to obtain advice about the operation of the whistleblower provisions.

Public interest disclosures

An eligible whistleblower can disclose to a member of Parliament or a journalist where:

• at least 90 days has passed since the whistleblower made the disclosure to ASIC, APRA or another Commonwealth body prescribed by regulation.
• the whistleblower does not have reasonable grounds to believe that action is being, or has been taken, in relation to their disclosure.
• the whistleblower has reasonable grounds to believe that making a further disclosure of the information is in the public interest; and
• before making the public interest disclosure the whistleblower has given written notice to the College that includes sufficient information to identify the previous disclosure and states that the whistleblower intends to make a public interest disclosure.

Emergency disclosures

An eligible whistleblower can disclose to a Member of Parliament or a journalist only if:
the whistleblower has previously disclosed the information to ASIC, APRA or a prescribed Commonwealth authority, and:

• the whistleblower has reasonable grounds to believe that there is an imminent risk of serious harm or danger to public health or safety, or to the financial system, if the information is not acted on immediately; and
• a reasonable period has passed since the disclosure was made; and
• after the end of the reasonable period, the whistleblower gives the body to which the disclosure was made a written notification that includes sufficient information to identify the previous disclosure and states that he or she intends to make an emergency disclosure.

Eligible whistleblowers who make a 'public interest disclosure' or an 'emergency disclosure' also qualify for protection.

6. Investigating a qualifying disclosure

6.1 Receiving a disclosure

Upon receiving a disclosure, the recipient (generally the Principal or Chair of the Council) will assess the disclosure to determine whether it qualifies for protection under the Corporations Act and is to be managed in accordance with this policy (qualifying disclosure) or the disclosure concerns matters that should managed in accordance with related policies (see section 1.2).

6.2 Investigating a qualifying disclosure

How University Senior College investigates a qualifying disclosure will depend on the nature of the disclosure.

An investigation will generally involve the making of inquiries or collection of evidence for the purpose of assessing the disclosure made by the whistleblower.

External professionals may be engaged to assist or conduct the investigation process.

In instances where the College reports the allegations within the disclosure to a third party, such as South Australian Police, Australian Federal Police or Australian Securities and Investments Commission (ASIC), the investigation procedures of the relevant third party will generally take precedence.

The timing of an investigation will depend on the circumstances of the matter and whether the College is the primary investigator of the disclosure.

Employees about whom disclosures are made will generally be given an opportunity to respond to the relevant allegations made in the qualifying disclosure. 

An eligible whistleblower and the relevant parties that the disclosure is about may choose to have an appropriate support person present at any meeting with representatives of the College.

The College may not be able to undertake an investigation if it is not able to contact the whistleblower (e.g., if the disclosure is made anonymously and the whistleblower has not provided contact details).

​​​​​​​6.3 Investigation of findings

The findings from an investigation will be documented and reported to those responsible for oversight of this Policy. 

A determination will then be made as to providing those findings in written format to the whistleblower. There may however be instances where it may not be appropriate to provide details of the outcome to the whistleblower.

​​​​​​​6.4 Review of findings

A whistleblower may lodge a complaint with a regulator, such as ASIC, APRA or the ATO, if they are not satisfied with the outcome of the College’s investigation.

7. Confidentiality and records

Under the Corporations Act, the identity of the discloser of a qualifying disclosure and information which is likely to lead to the identification of the discloser must be kept confidential.

Exceptions to this are disclosures to ASIC, the Australian Federal Police, a legal practitioner for the purpose of obtaining advice about the application of the whistleblower protections or made with the consent of the discloser.

The discloser's identity and information which is likely to lead to the identification of the discloser can also be provided to any Commonwealth or State authority for the purpose of assisting the authority in the performance of its functions or duties. This could include SAPOL, the SA Ombudsman, Education Standards Board or the SA Department for Education.

It is also permissible to disclose information which could lead to the identification of the discloser if the disclosure is reasonably necessary for the purpose of investigating the matter, if all reasonable steps are taken to reduce the risk that the discloser will be identified as a result of the information being disclosed.   

Breach of these confidentiality protections regarding the discloser's identity and information likely to lead to the identification of the discloser is a criminal offence and may be the subject of criminal, civil and disciplinary proceedings.

Confidentiality must be observed in relation to handling and storing records.

8. Whistleblower protections

Eligible whistleblowers making a qualifying disclosure are protected by the requirement that their identity, and information that may lead to their identification, should be kept confidential, subject to relevant exceptions as set out in section 7 above.

Eligible whistleblowers making a qualifying disclosure cannot be subject to any civil, criminal or administrative liability (including disciplinary action) for making the disclosure. No contractual or other remedy or right will be enforced or exercised against the person on the basis of the disclosure.

Whistleblowers who make some types of qualifying disclosures (generally external to the College) are also provided immunities to ensure that information they disclose is not admissible in evidence against them in criminal proceedings or in proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information.

These immunities do not prevent an eligible whistleblower being subject to criminal, civil or other liability for conduct that is revealed by the whistleblower, only that the information the person has disclosed is not admissible in certain proceedings against them. 

Eligible whistleblowers are also protected from victimisation - suffering any detriment by reason of the qualifying disclosure. It is unlawful for a person to engage in conduct against another person that causes, or will cause detriment, where the person believes or suspects that the other person or a third person made, may have made, proposes to make or could make a qualifying disclosure.

Threats of detriment are also unlawful.

Detriment has a very broad meaning and includes dismissal of an employee, injuring an employee in their employment, alteration of an employee's position or duties to their disadvantage; discrimination between an employee and other employees; victimisation of a dependent of the discloser, harassment or intimidation of a person or harm or injury to a person, including psychological harassment; damage to a person's property, reputation or business or financial position.

Remedies for being subjected to detriment could include:

• compensation
• injunctions and apologies
• reinstatement of a person whose employment is terminated
• exemplary damages

Colleges and individuals may face significant civil and criminal penalties for failing to comply with confidentiality and detrimental conduct provisions.

If an eligible whistleblower believes they are being subjected to a detriment or a threat of detriment, this should immediately be reported in writing to the Principal via email

If it is not appropriate for the report to be made to the Principal, the eligible whistleblower should report the matter, in writing, to the Chair of the Council via email at paul@pauldalby.com

9. Additional support for eligible whistleblowers and other employees

The College's employee assistance program (EAP) or equivalent will be available to all eligible whistleblowers and other employees affected by the disclosure, should they require that support. 

10. Contact

If you have any queries about this policy, you should contact Anita Zocchi, Principal or Karen Boyd, Finance Manager ​​​​​​​for advice.

This policy assists the College to achieve all Aspirations of the USC Strategic Plan.

University Senior College at Adelaide University Incorporated (“University Senior College” or “the College”) recognises the importance of proper management of work health and safety. The most valuable asset to the College is its employees, whose health and safety ranks equally with all other financial and operational considerations.

It is the responsibility and aim of University Senior College to minimise the risk of injury and disease to employees, students and other persons, by adopting a planned and systematic approach to the management of work health and safety and providing the resources for its successful implementation and continuous improvement.

University Senior College endeavours, through the regular review of its systems, to strive for continuous improvement to bring about an ongoing improvement of work health and safety performance, with the aim of eliminating all unwanted work-related hazards and work-related injuries.

The College will endeavour to ensure compliance with the Work Health and Safety Act 2012 (SA) and the Work Health and Safety Regulations 2012 (SA) and any approved Codes of Practice, together with the Return to Work Act 2014 (SA).

Everyone who works at University Senior College has responsibilities for observing work health and safety requirements and to take care to protect their own health and safety and to avoid adversely affecting the health and safety of any other person.

For USC to meet the WHS regulations, staff are to ensure they do not attend the workplace under the influence of drugs or alcohol. Additionally, if a staff member suspects that another staff member is under the influence of drugs and/or alcohol and has reported to work, or an official school event, the Principal must be notified. Any staff member who attends USC or a school related function, under the influence of drugs and/or alcohol, is subject to disciplinary action.