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Policies

Please find a full list of Immanuel College policies below.

Child Safety Policy & Code of Conduct

CHILD SAFETY POLICY

Under the Children and Young People (Safety) Act 2017 (SA) (the Act), a child or young person is considered to be “at risk” if:

  • the child or young person has suffered harm
  • there is a likelihood that the child or young person will suffer harm
  • there is a likelihood that the child will be removed from the State for the purposes of an unlawful medical or other procedure (including female genital mutilation), child marriage or an activity or action that would be a criminal offence, if it occurred in the state
  • their parents or guardians are unable or unwilling to care for them, have abandoned them, or cannot be found or are dead
  • they are persistently absent from school with no explanation; or
  • they have no fixed address.

In the Act a child or young person is defined as a person who is under 18 years of age.
Harm is defined in the Act as a term used to be a reference to physical harm or psychological harm (caused by act or omission) and includes harm caused by sexual, physical, mental or emotional abuse or neglect.
While grooming behaviour is not recognised under South Australian law as a form of abuse, it can lead to a child or young person being at risk of harm and is a crime under section 63 of the Criminal Law Consolidation Act 1935 (SA).

Immanuel College has zero tolerance for child abuse and is committed to the protection of all children from all forms of abuse, grooming and neglect.

“In the Lutheran school the gospel is to inform all programs, relationships and activities” (LCA and School statement). The love of God in Jesus Christ is to govern all that is done, in response to this love, people in the school community are directed to their fellow human beings. Where they love others, they love him. Christ’s promise is that whatever is done for others is done for him. Informed and transformed by God’s creative, redemptive and sanctifying love, God’s people are concerned with the total needs of their fellow human beings. The Child Safe program in place at Immanuel College defines power as the capacity to set and care for boundaries. Boundaries are the structures which support human development within community; boundaries may be personal, communal, spiritual, psychological or physical. In Christ, there is an empowerment by the gospel to recognise boundaries and prevent their destructive crossing and to care for those who have been violated. Our responsibility of leadership is to care for professional boundaries through the establishment of structures that protect them. Structures provide for support, examination, and action to ensure that school leaders, staff and students act according to boundaries that help, protect and uphold the dignity, worth and safety of each individual. (Valuing Safe Communities: Statement of values)”

This Child Protection Program is made up of work systems, practices, policies and procedures designed to maintain a child safe environment and to embed an organisational culture of child safety within the College. The Program deals specifically with child protection issues and is designed to ensure compliance with the South Australian requirements for a child safe environment as prescribed by the Act.

Policy Objectives
This Policy provides the framework for:

  • the development of work systems, practices, policies and procedures that promote child protection within the College
  • the creation of a positive and robust child protection culture
  • the promotion and open discussion of child protection issues within the College
  • complying with all laws, regulations and standards relevant to child protection in South Australia.

Statement of Commitment to Child Safety
Immanuel College is committed to the safety and wellbeing of all children and young people at the College. We support the rights of the child and will act without hesitation to ensure a child safe environment is maintained at all times. We also support the rights and wellbeing of our staff and Volunteers, and encourage their active participation in creating and maintaining a child safe environment for all members of the College.

Our Child Safe Values and Principles
Immanuel College’s commitment to child safety is based on the following overarching principles that guide the development and regular review of our work systems, practices, policies and procedures to protect children from abuse, grooming and neglect.

1. All children have the right to be safe.
2. The welfare and best interests of the child are paramount.
3. The views of the child are taken into consideration with a view to respecting privacy.
4. Clear expectations for appropriate behaviour with children are established in our Child Safe Code of Conduct and Staff and Student Professional Boundaries Policy.
5. The safety of children is dependent upon the existence of a child safe culture.
6. Child safety awareness is promoted and openly discussed within our College.
7. Procedures are in place to screen the Principal, College Council members, members of the Executive Team , all staff, Volunteers, Contractors and External Education Providers who have direct contact with students.
8. Child safety and protection is everyone’s responsibility.
9. Child protection training is mandatory for all College Council members, staff, Direct Contact Contractors and Volunteers.
10. Procedures for responding to alleged or suspected incidents of child abuse, grooming or neglect are simple and accessible for all members of the College.
11. Children from culturally or linguistically-diverse backgrounds have the right to special care and support including those who identify as Aboriginal or Torres Strait Islander.
12. Children who have any kind of disability have the right to special care and support.

Our Child Protection Program
Immanuel College has developed procedures and standards to support our overarching Child Safe Policy, through our Child Protection Program. Our Child Protection Program relates to all aspects of protecting children from abuse, grooming and neglect and establishes work systems, practices, policies and procedures to protect children from abuse. It includes:

  • clear information as to what constitutes child abuse and associated key risk indicators
  • clear procedures for responding to and reporting allegations of child abuse
  • strategies to support, encourage and enable staff, Volunteers, Third Party Contractors, External Education Providers, parents/guardians and students to understand, identify, discuss and report child protection matters
  • procedures for recruiting and screening College Council members, staff, Direct Contact Contractors and Volunteers
  • pastoral care strategies designed to empower students and keep them safe
  • policies with respect to cultural diversity and students with disabilities
  • a child protection training program
  • information regarding the steps to take after a disclosure of abuse to protect, support and assist children
  • guidelines with respect to record keeping and confidentiality
  • policies to ensure compliance with all relevant laws, regulations and standards (including the requirements for a child safe environment)
  • a system for continuous improvement and review.

Responsibilities
Child protection is everyone’s responsibility. At Immanuel College all members of the Council and staff, Volunteers, Third Party Contractors and External Education Providers have a shared responsibility for contributing to the safety and protection of children. Specific responsibilities include:

College Council
Each member of the College Council is required to ensure that appropriate resources are made available to allow the College’s Child Safe Policy and the Child Protection Program to be effectively implemented within the College and is responsible for holding the Principal and Executive Team accountable for effective implementation.

The Principal
The Principal is responsible, and will be accountable, for taking all practical measures to ensure that this Child Safe Policy and the College’s Child Protection Program are implemented effectively and that a strong and sustainable child protection culture is maintained within the College. The Principal is also the College’s Child Safety Officer and has an important role in the promotion and maintenance of a child safe environment at the College.

The College’s Child Safety Contact Officers
A number of Staff are nominated as the College’s Child Safety Contact Officers. Along with the Principal our Child Safety Contact Officers are the first point of contact for raising child protection concerns within the College. They are also responsible for championing child protection within the College and assisting in coordinating responses to child protection incidents.

Staff Members
All staff are required to comply with our Child Protection Program and their legal obligations with respect to the reporting of child abuse. Each current and new staff member is required to sign a written statement indicating that they have read and acknowledged the College’s Child Safe Policy and Child Safe Code of Conduct. It is each individual’s responsibility to be aware of key risk indicators of child abuse, to be observant, and to raise any concerns they may have relating to child abuse with the Principal. Staff, as a condition of employment at the College, must adhere to the College’s Child Safe Code of Conduct and Staff and Student Professional Boundaries Policy.

Volunteers
All Volunteers are required to comply with our Child Protection Program and their legal obligations with respect to the reporting of child abuse. Each Volunteer is required to sign a written statement indicating that they have read and acknowledged the College’s Child Safe Policy and Child Safe Code of Conduct. It is each individual’s responsibility to be aware of key risk indicators of child abuse, to be observant, and to raise any concerns they may have relating to child abuse with the Principal.

Contractors
All Contractors engaged by the College are responsible for contributing to the safety and protection of children in the College environment. Contractors include, for example, maintenance and building personnel, consultants, casual teachers, tutors, sports coaches and College cleaners. This also includes peripatetic music teachers and other extra-curricular teachers and instructors who are engaged by students and their families directly, rather than the College, but have an agreement with the College to use the College’s facilities.

All Contractors engaged by the College are required to comply with our Child Protection Program and their legal obligations with respect to the reporting of child abuse, grooming and neglect. Each Contractor is required to sign a written statement indicating that they have read and acknowledged the College’s Child Safe Policy and Child Safe Code of Conduct. The College may include this requirement in the written agreement between it and the Contractor.

External Education Providers
An External Education Provider is any organisation that the College has arranged to deliver a specified course of study that is part of the curriculum to a student or students enrolled at the College. The delivery of such a course may take place on College premises or elsewhere. All External Education Providers engaged by the College are responsible for contributing to the safety and protection of children in the College environment. All External Education providers engaged by the College are required to comply with our Child Protection Program and their legal obligations with respect to the reporting of child abuse, grooming and neglect. Each External Education Provider is required to have appropriate child protection policies and procedures within their organisation. Immanuel College may include this requirement in the written agreement between it and the External Education Provider.

Reporting Concerns
Our Child Protection Program provides detailed guidance for all members of the College as to how to identify key risk indicators of child abuse, grooming or neglect and how to report child protection concerns. It also contains detailed procedures with respect to the reporting of child abuse, grooming or neglect incidents to relevant external authorities. Staff, Contractors, External Education Providers, Volunteers, students, parents/guardians and other community members who have concerns that a child may be subject to abuse, grooming or neglect or at risk of significant harm and have queries about how to make a report are asked to contact the College’s Principal or a Child Safety Contact Officer.

All communications will be treated confidentially on a ‘need to know basis’ and without threat of punishment or victimisation. Please be aware that consulting with the Principal or a Child Safety Contact Officer does not change any obligation you have under legislation to report to an external authority.

Whenever there are concerns that a child is in immediate danger the Police should be called on 000.

If you have any questions regarding the College’s Child Safe Policy, and how it applies to you, please contact the Principal.

Policy and Child Protection Program Review
Immanuel College is committed to the continuous improvement of our Child Protection Program. The Program is regularly reviewed for overall effectiveness, in response to a significant change at the College and to ensure compliance with all child protection related laws, regulations and standards.

Approval Authority: Immanuel College Council
Responsible Officer: Principal
Approval Date: November 2019
Review Date* November 2022

* Unless otherwise indicated, this policy will still apply beyond the review date. This policy will also be updated as required as per Policy and Child Protection Program Review above.  

CHILD SAFETY CODE OF CONDUCT

A Child Safe Code of Conduct lists behaviours that are acceptable and those that are unacceptable. It provides a high-level statement of professional boundaries, ethical behaviour and acceptable and unacceptable relationships. For more detailed guidance refer to our  Staff and Student Professional Boundaries Policy. When individuals are clear about behavioural expectations, they are much more likely to act appropriately with each other and with children. When everyone is educated about the Code of Conduct and the reasons it is so important to uphold, the College environment becomes much more transparent and people are accountable for their behaviour. Above all, a Child Safe Code of Conduct helps to protect children from harm. This Code applies to:

  • all staff members, including non-teaching staff and temporary or casual staff
  • students
  • volunteers
  • parents and guardians
  • contractors and service providers (including External Education Providers)
  • members of the College Council
  • teaching students on placement at the College
  • visitors.

This Code is made available on our public website. The College has also developed a Student Code of Conduct.

The College Council has approved and endorsed this Child Safety Code of Conduct.

DO:

  • Behave as a positive role model to students.
  • Promote the safety, welfare and wellbeing of students.
  • Be vigilant and proactive with regard to student safety and child protection issues.
  • Provide age appropriate supervision for students.
  • Comply with guidelines published by the College with respect to child safety and protection.
  • Comply with the SA Protective Practices Guidelines as modified from time to time.
  • Treat all members of the College with dignity, respect, sensitivity and fairness.
  • Promote the safety, participation and empowerment of students with a disability.
  • Promote the cultural safety, participation and empowerment of linguistically and culturally-diverse students.
  • Use positive and affirming language toward students.
  • Encourage students to ‘have a say’ and then listen to them with respect.
  • Respect cultural, religious and political differences.
  • Help provide an open, safe and supportive environment for all students to interact and socialise.
  • Intervene when students are engaging in inappropriate bullying behaviour towards others or acting in a humiliating or vilifying way.
  • Report any breaches of this Child Safety Code of Conduct.
  • Report concerns about child safety to the Principal or a Child Safety Contact Officer and ensure that your legal obligations to report allegations externally are met.
  • Where an allegation of child abuse is made, ensure as quickly as possible that the student involved is safe.
  • Call the Police on 000 if you have immediate concerns for a student’s safety.
  • Respect the privacy of students and their families and only disclose information to people who have a need to know.

DO NOT:

  • Engage in any form of inappropriate behaviour towards students or expose students to such behaviour including high-risk behaviours such as bullying or harassment of a child.
  • Use prejudice, oppressive behaviour or inappropriate language with students.
  • Express personal views on cultures, race or sexuality in the presence of students or discriminate against any student based on culture, race, sexuality, ethnicity or disability.
  • Engage in open discussions of an adult nature in the presence of students.
  • Engage in any form of sexual conduct with a student including making sexually suggestive comments and sharing sexually suggestive material.
  • Engage in inappropriate or unnecessary physical conduct or behaviours including unwarranted and/or inappropriate touching of a child or doing things of a personal nature that a student can do for themselves, such as toileting or changing clothes.
  • Engage in any form of physical violence towards a student including inappropriately rough physical play.
  • Use physical means or corporal punishment to discipline or control a student.
  • Engage in any form of behaviour that has the potential to cause a student serious emotional or psychological harm.
  • Develop ‘special relationships’ with students that could be seen as favouritism (for example, the offering of gifts or special treatment for specific students).
  • Engage in undisclosed private meetings with a student who is not your own child.
  • Engage in meetings with a student who is not your child, outside of school hours and without permission from the College and the child’s parent.
  • Engage in inappropriate personal communications with a student through any medium, including any online contact or interactions with a student.
  • Publish (including online) photos, movies or recordings of a student without parental/guardian consent.
  • Post online any information about a student that may identify them such as their full name, age, e-mail address, telephone number, residence, school, or details of a club or group they may attend.
  • Ignore or disregard any suspected or disclosed child abuse, grooming or neglect.

Our Child Protection Program includes a Staff and Student Professional Boundaries Policy that provides detailed guidance for all staff and Volunteers on how to maintain professional boundaries between students and adults at Immanuel College.

Report Any Child Protection Concerns
Staff, Contractors, External Education Providers, Volunteers, parents/guardians, students and other community members who have concerns that a child may be subject to abuse, grooming or neglect or at risk of significant harm and have queries about how to make a report or that there has been a breach, or potential breach, of the Child Safe Code of Conduct are asked to contact the College’s Principal or a Child Safety Contact Officer. Please be aware that consulting with the Principal or a Child Safety Contact Officer does not change any obligation you have under legislation to report to an external authority. All communications will be treated confidentially on a ‘need to know basis’ and without threat of punishment or victimisation.

Whenever there are concerns that a child is in immediate danger the Police should be called on 000.

If you have any questions regarding the College’s Child Safe Code of Conduct, and how it applies to you, please contact the Principal.

Disciplinary Procedures
Where a staff member breaches the Code, Immanuel College may take disciplinary action, including in the case of serious breaches, dismissal (where appropriate). Where any other member of the College breaches any obligation, duty or responsibility within the Code, Immanuel College will take appropriate action. For example, the services of Volunteers may no longer be required by the College.

Approval Authority: Immanuel College Council
Responsible Officer: Principal
Approval Date: November 2019
Review Date* November 2022

* Unless otherwise indicated, this policy will still apply beyond the review date. This policy will also be updated as required as per Policy and Child Protection Program Review above.  

Privacy Policy

In the course of Immanuel College’s activities, we manage and protect personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles (APPs). Our policy outlines the circumstances in which we obtain personal information, how we use and disclose that information, and how we manage requests to access and/or change that information. Below is a summary of the key areas of our Privacy Policy:

What is personal information and how do we collect it?

Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as a student, contractor, volunteer, stakeholder, job applicant, alumni, visitors or others that come into contact with the school. In the course of providing services we may collect and hold:
– Personal Information
– Sensitive Information
– Health Information

Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).

How we collect personal information

The collection of personal information depends on the circumstances in which Immanuel College is collecting it. 

Solicited Information

– We collect personal information via forms (e.g. an Enrolment Form), as well as email, letters, notes, via our website, over the telephone, in face-to-face meetings, through financial transactions and through surveillance activities such as CCTV or email monitoring.
– We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources.
– We collect information website data via “cookies’’ and other data collection methods to improve our website and marketing. We do not use this information to personally identify individuals.  

Unsolicited information

We may be provided with personal information without having sought it through our normal means of collection, such as misdirected postal mail and email and employment applications sent to us that are not in response to an advertised vacancy.

Collection and use of sensitive information 

We only collect sensitive information if it is:
– reasonably necessary for our functions, and we have the individual’s consent 
– necessary to lessen or prevent a serious threat to life, health or safety
– another permitted general or health situation.

How do we use personal information?

We only use personal information that is reasonably necessary for our functions or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented including, but are not limited to:
– providing education, pastoral care, extra-curricular and health services
– satisfying our legal obligations including our duty of care and child protection obligations
– keeping parents informed as to school community matters through correspondence, newsletters and magazines
– marketing, promotional and fundraising activities
– supporting the activities of school associations such as Immanuel College Old Scholars Association and Immanuel College Parents and Friends Association
– supporting the activities of the College foundation
– supporting community based causes and activities, charities and other causes in connection with the school’s functions or activities
– helping us to improve our day-to-day operations including training our staff
– systems development; developing new programs and services; undertaking planning, research and statistical analysis
– school administration including for insurance purposes
– the employment of staff and the engagement of volunteers.

How do we store your information and keep it secure?

We store personal information in a variety of formats and takes all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:
– Restricting access and user privilege of information by staff depending on their role and responsibilities.
– Ensuring staff do not share personal passwords.
– Ensuring hard copy files are stored in lockable filing cabinets in lockable rooms.  
– Ensuring access to Immanuel College’s premises are secured at all times.
– Implementing physical security measures around the school buildings and grounds to prevent break-ins.
– Ensuring our IT and cyber security systems, policies and procedures are implemented and up to date.
– Ensuring staff comply with internal policies and procedures when handling the information. 
– Undertaking due diligence with respect to third party service providers who may have access to personal information to ensure as far as practicable that they are compliant with the APPs or a similar privacy regime. 
– The destruction, deletion or de-identification of personal information we hold that is no longer needed, or required to be retained by any other laws.

Immanuel College will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC). If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.

Disclosure of personal information

Personal information is used for the purposes for which it was given to Immanuel College, or for purposes which are directly related to one or more of our functions or activities. Personal information may be disclosed, if the individual:
– Has given consent; or 
– Would reasonably expect the personal information to be disclosed in that manner.

Immanuel College may disclose personal information without consent or in a manner which an individual would reasonably expect if:
– We are required to do so by law.
– The disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety.
– Another permitted general situation applies.
– Disclosure is reasonably necessary for a law enforcement related activity.
– Another permitted health situation exists.

Disclosure of your personal information to overseas recipients

Personal information about an individual may be disclosed to an overseas organisation in the course of providing our services, for example when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

– we have the individual’s consent (which may be implied);
– we have satisfied ourselves that the overseas recipient is compliant with the APPs, or a similar privacy regime;
– we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or 
– we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.

The quality of personal information

We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information. If Immanuel College becomes aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.

Access and correction of personal information

You may submit a request to us to access the personal information we hold, or request that we change the personal information. We will take steps to verify your identity before granting access or correcting the information. 

Personal information of students

The Privacy Act does not differentiate between adults and children and does not specify an age after which individuals can make their own decisions with respect to their personal information.

We take a common sense approach to dealing with a student’s personal information and generally will refer any requests for personal information to a student’s parents/carers. We will treat notices provided to parents/carers as notices provided to students and we will treat consents provided by parents/carers as consents provided by a student.

We are however cognisant of the fact that children do have rights under the Privacy Act, and that in certain circumstances (especially when dealing with older students and especially when dealing with sensitive information), it will be appropriate to seek and obtain consents directly from students. We also acknowledge that there may be occasions where a student may give or withhold consent with respect to the use of their personal information independently from their parents/carers.

There may also be occasions where parents/carers are denied access to information with respect to their children, because to provide such information would have an unreasonable impact on the privacy of others, or result in a breach of the school’s duty of care to the student.

Complaints

You can make a complaint about how Immanuel College manages personal information, including a breach of the APPs, by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response. Immanuel College does not charge a fee for the handling of complaints. If you are not satisfied with our response, you may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.

How to contact us about our Privacy Policy

If practical, you can contact us anonymously or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do. 

Download a copy of the full Privacy Policy here

Whistleblower Policy

Download a copy of the full Whistleblower Policy here

Complaints Handling Policy


Immanuel College recognises that from time to time, there might be instances where individuals or organisations may disagree with the way the College has handled matters, and may wish to lodge a complaint. Such individuals may include parents, students, suppliers, local residents, and other external bodies with whom the College has dealings.

The College acknowledges that complaints present an opportunity to improve and is fully committed to resolving complaints in an efficient, fair and timely manner. The College recognises that its complaints handling procedures must be fair to the complainant as well as the person about whom the complaint is made. Accordingly, the College will:

  • document all formal discussion and processes involving a complaint
  • acknowledge receipt of the complaint within two working days
  • treat all parties with sensitivity, respect and courtesy
  • investigate matters impartially and fairly
  • provide all parties with a response within 14 days, or provide interim information if a response is not yet available
  • provide clear reasons as to why any actions have been taken or are proposed to be taken
  • keep matters confidential
  • monitor the effectiveness of outcomes
  • provide a right of appeal to the Principal and Chair of the College Council if the College’s response to the complaint is not satisfactory.

Making a Complaint

We ask that, where appropriate, you first raise the matter directly with the relevant staff member. If that is not appropriate or the issue was not addressed to your satisfaction, please contact the Director of Community Relations on 08 8375 1700 or at immanuel@immanuel.sa.edu.au

Complaints Relating to Child Protection Incidents

There may, at times, be concerns or complaints relating to the College’s Child Protection Program, for example regarding the College’s management of a child protection incident. When a child protection-related complaint is made, the College will first consider whether the complaint raises any concerns about unreported abuse and/or risk of abuse at the College. If concerns of this nature are raised by the complainant, the College’s Procedures for Responding to and Reporting Child Protection Incidents should be followed.

Child protection complaints that do not raise concerns of unreported abuse, or a risk of abuse at the College will be managed in the same manner as other complaints received by the College. The complaints will be recorded to ensure that any further developments relating to the same incident or issue are monitored.

Note that neither the Minister for Education and Child Development nor the Department for Education and Child Development has any power to directly intervene in any complaints relating to the operations of the College.

If you have any questions or require clarification on anything, please reach out to us through one of the following channels.


Contact Information:

Address: 32 Morphett Road, Novar Gardens, South Australia 5040
Phone: 08 8375 1700
Fax: 08 8294 2658
Email: immanuel@immanuel.sa.edu.au

Office Hours:

Monday – Friday: 8.00am – 4.30pm during school terms
Monday – Friday: 8.00am – 4.00pm during school holidays