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HR-POL-04 – Child Safety Code of Conduct

Posted
Updated
ByAlexander Mueller
Effective Date: September 2026 Review Date: September 2027
Document Status: PUBLISHED Original Version: 2026.1
Authorised by: Chief Executive Officer Document Owner: Alexander Mueller

WARNING! – UNCONTROLLED WHEN PRINTED! – THE ORIGINAL/LATEST/CURRENT VERSION OF THIS DOCUMENT IS KEPT ON THE STAFF PORTAL OF THE INTELLIGENT TRAINING SOLUTIONS WEBSITE

01. Objective

To set out the expected behaviour of adults engaged in child-connected work at Intelligent Training Solutions (ITS, RTO 22570), so as to protect the safety and wellbeing of secondary school students and other students under 18 enrolled in ITS’s nationally accredited training and assessment.

To meet ITS’s obligations under the Victorian Child Safe Standards (Child Wellbeing and Safety Act 2005 (Vic)) and the National Principles for Child Safe Organisations, and under Outcome Standards 2.5 and 2.6 of the Standards for Registered Training Organisations 2025.

02. Scope

This Code applies to all ITS employees, driving instructors, TAE40116-qualified trainers and assessors, subcontracted training providers, work placement hosts, and any other adult engaged in child-connected work on ITS’s behalf.

This Code applies to all physical and online environments used by ITS students, including training rooms, on-road driving lessons, work placements and excursions, and online learning environments such as staff.its.edu.au and any learning management system used by ITS. It applies during and outside standard business hours wherever the interaction relates to a student’s enrolment with ITS.

ITS is registered with ASQA only (RTO 22570) and is not registered with the Victorian Registration and Qualifications Authority (VRQA). ITS’s Victorian operations are therefore subject to the Child Safe Standards directly through the Social Services Regulator, which regulates the Child Safe Standards for organisations without a sector-specific co-regulator.

This Code should be read in conjunction with ITS’s Working with Children Check Policy (HR-POL-05) and ITS’s Complaints, Grievances and Appeals, and Privacy policies and procedures.

03. Definitions

  • Child / young person: a person under the age of 18 years.
  • Child-connected work: work that involves, or is likely to involve, regular direct contact with a student under 18.
  • Direct contact: physical, oral, written, electronic or face-to-face contact, or being within eyeshot of a student — including during a driving lesson.
  • Regulator: the Social Services Regulator, which administers the Working with Children Check, the Reportable Conduct Scheme, and the Child Safe Standards for organisations without a sector-specific co-regulator.
  • Personnel: ITS employees, contractors, driving instructors, trainers, assessors and volunteers engaged in child-connected work.

04. Policy Statement

Promoted and expected behaviours — all ITS personnel engaged in child-connected work must:

  • Take all reasonable steps to protect students from abuse or harm, including during one-on-one contact such as practical driving lessons and work placements.
  • Take disclosures of harm or abuse made by a student seriously, and respond in line with ITS’s reporting procedure (see Procedure, below).
  • Raise child safety concerns promptly with Alexander Mueller (CEO/Director) or Cameron Gutterson (General Manager/Director).
  • Complete compulsory child safety induction and refresher training, including any training required under ITS’s Working with Children Check Policy.
  • Treat all students with respect, regardless of race, sex, gender identity, sexual orientation, language, religion, disability, cultural background or other characteristics.
  • Consider the individual learning, wellbeing and support needs of each student, consistent with Outcome Standards 2.5 and 2.6 of the Standards for RTOs 2025.
  • Support Aboriginal and Torres Strait Islander students and families to feel safe, included and able to express their culture and identity, and promote inclusion for students from culturally and linguistically diverse backgrounds.
  • Maintain clear professional boundaries at all times, including during one-on-one practical training and driving lessons.
  • Obtain documented parent or guardian consent before transporting a secondary school student for driving instruction, assessment or an excursion.
  • Report any conflict of interest that may affect a person’s ability to safely perform their role, and respect the privacy of students and their families.
  • Uphold the rights of the child or young person and always prioritise their needs.

Unacceptable behaviours — all ITS personnel must not:

  • Condone or participate in illegal, unsafe, abusive or harmful behaviour towards a student — including physical violence, sexual abuse, emotional or psychological abuse, grooming, neglect or sexual misconduct.
  • Ignore or disregard any concern, suspicion or disclosure of harm or abuse, or fail to report it.
  • Use hurtful, discriminatory or offensive language or behaviour with a student, or touch a student in a way that is unnecessary or unsuitable.
  • Show a student pornographic or sexually explicit material, use sexual language or gestures in the presence of a student, or share details of sexual experiences with a student.
  • Develop a ‘special’ relationship with, or show favouritism towards, a particular student, including through gifts or unnecessary or unsuitable attention.
  • Have unauthorised contact with a student online, on social media, or by phone, or take, screenshot or share images of a student that are not authorised by ITS.
  • Be alone with a student where there is no professional reason to do so, including a driving lesson conducted outside the scheduled route, time or venue without this being logged and authorised.
  • Engage in tutoring, mentoring, private driving lessons or other one-on-one contact with an ITS student outside of work hours without managerial approval.

05. Eligibility Criteria

This Code applies to all personnel described in Scope above. There are no exemptions or eligibility exclusions.

06. Procedure

  1. Where a breach of this Code is suspected, personnel must act to prioritise the best interests of the student and promptly take steps to ensure the student is safe.
  2. As soon as possible, the incident or concern must be reported to Alexander Mueller (CEO/Director) or Cameron Gutterson (General Manager/Director).
  3. The privacy of those involved must be maintained, consistent with ITS’s record-keeping, privacy and information-sharing obligations.
  4. Some breaches may need to be reported to Victoria Police, the Social Services Regulator, or, in respect of ITS’s RTO registration, to ASQA. Staff, contractors and families who report a child safety concern in good faith are protected from retaliation or victimisation. All reports will be treated seriously, confidentially, and investigated promptly.
  5. All new starters engaged in child-connected work must read and acknowledge this Code before commencing that work. ITS records acknowledgements through its staff induction and on-boarding course.
  6. Personnel who breach this Code may be subject to disciplinary action, up to and including termination of employment or engagement, and may also face police investigation, a report to the Social Services Regulator, and/or action affecting their Working with Children Check or ITS’s RTO registration.

07. Responsibility

Alexander Mueller (Chief Executive Officer/Director) and Cameron Gutterson (General Manager/Director) are jointly responsible for the effective implementation of this Code, for receiving and acting on child safety concerns and disclosures, and for ensuring ITS’s compliance with the Child Safe Standards.

All ITS personnel engaged in child-connected work are responsible for following this Code and for reporting any concern or suspected breach without delay.

08. Procedure Notes and Explanations

If a person in a position of authority at ITS becomes aware of a substantial risk that a student may become the victim of a sexual offence committed by an adult associated with ITS (for example, an employee, contractor, driving instructor or subcontracted trainer), and that person has the power or responsibility to reduce or remove the risk, they must take all reasonable steps to do so. A person in authority who negligently fails to take appropriate action may commit the criminal offence of ‘failing to protect’ under the Crimes Act 1958 (Vic) and may face imprisonment.

If an adult reasonably believes a sexual offence has been committed by an adult against a child under 16, they must report it to Victoria Police by calling 000 or attending their local police station. Failing to disclose this information may itself be a criminal offence under the Crimes Act 1958 (Vic).

Legislative and regulatory context:

  • Child Wellbeing and Safety Act 2005 (Vic) — Child Safe Standards
  • Crimes Act 1958 (Vic) — mandatory reporting, failure to disclose and failure to protect offences
  • Worker Screening Act 2020 (Vic) — see ITS’s Working with Children Check Policy (HR-POL-05)
  • Standards for Registered Training Organisations 2025 (Outcome Standards 2.5 and 2.6)
  • National Principles for Child Safe Organisations

09. Policy Approval and Publication

This policy has been approved for publication by the Company Directors, Alexander Mueller (Chief Executive Officer) and Cameron Gutterson (General Manager).

Signed: Alexander Mueller & Cameron Gutterson    Date: 03/09/2026

Revision History

POLICY DOCUMENT REGISTER

REVISION DATE DOCUMENT VERSION DESCRIPTION OF MODIFICATION OR AMENDMENT
1 September 2026 2026.1 Original document created
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