Waves Resilience Policies
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Child Safety Policy
Waves Resilience
Reviewed: October 2026
Scheduled for Review: October 2027
Child Safety Policy
PURPOSE
At Waves Resilience we believe that every child regardless of gender, race, country of origin, socio-economic status, or religious belief, has the right to be safe, be respected, be protected, be valued, be seen, and be heard. Our policy guides staff, volunteers and students on how to honour and fulfil these beliefs and rights with children and youth connected to our business.
Waves Resilience is committed to encouraging Workers, Volunteers, Children, Carers or Community Members to raise any concerns or provide their views on the well-being of children engaged with Waves Resilience including any perceived risks to a child's safety or signs of abuse or harm.
1.1 AIMS
The Policy aims to ensure Waves Resilience is a child safe business by:
providing a safe, inclusive and respectful environment for all children involved in our programs
proactively preventing child abuse
ensuring all parties are aware of their responsibilities in protecting children from harm
providing guidance to staff/volunteers/contractors as to interventions required when abuse is suspected within or outside the business
1.2 DEFINITIONS
Child means a person below the age of 18.
Child protection means any responsibility, measure or activity undertaken to safeguard children from harm.
Child Abuse and Neglect is maltreatment of a person under the age of 18 years. It is the result of action or inaction on the part of a person who has responsibility to care for a child resulting in harm or injury to the child. The harm may include delayed physical and/or intellectual development. The maltreatment experienced is normally described in five categories. Each category of maltreatment is described by a range of indicators.
Physical abuse ‐ occurs when a child has experienced severe and/or persistent ill‐treatment. It can include, but is not limited by injuries such as cuts, bruises, burns and fractures caused by a range or acts including beating, shaking, illicit administration of alcohol and other drugs, attempted suffocation, excessive discipline or physical punishment.
Emotional abuse is a sustained, repetitive, inappropriate, ill treatment of a child or young person through behaviours including threatening, belittling, teasing, humiliating, bullying, confusing, ignoring and inappropriate encouragement. Children who have been emotionally abused are likely to have a reduced capacity to experience a range of emotions, to express emotion appropriately and to modulate their emotional experience. Children who have been emotionally abused are likely to be fearful, withdrawn and/or resentful, distressed and despairing.
Sexual abuse covers a wide range of behaviour or activities that expose or subject a child to sexual activity that is exploitative and/or inappropriate to his/her age and developmental level. These behaviours include observation or involvement with inappropriate fondling of a child’s body, making a child touch an adult’s genitalia, showing pornographic material or sexual acts to a child, and sexual penetration of the child. Harm from sexual abuse may include significant emotional trauma, physical injury, infections and impaired emotional and psychological development.
Psychological abuse is the sustained, repetitive, inappropriate, ill treatment of a child or young person through behaviours including threatening, isolating, neglecting, discrediting, misleading, disregarding, ignoring and inappropriate encouragement. This abuse damages a child’s intellectual faculties and processes, including intelligence, memory, recognition, perception, attention, imagination and moral development. Children are likely to feel worthless, flawed, unloved, unwanted, endangered or only of value in meeting another’s needs.
Neglect is the failure of a parent/caregiver to provide a child with the basic necessities of life. These include adequate supervision, adequate food or shelter, suitable clothing, effective medical, therapeutic or remedial care and emotional security. Neglect can be acute, chronic or episodic, and can result in detrimental effects on the child or young person’s social psychological, educational or physical development and/or physical injury. Neglect should be considered in the context of physical, emotional or psychological abuse.
Cultural Safety is an environment that is safe for people: where there is no assault, challenge or denial of their identity, of who they are and what they need. It is about shared respect, shared meaning, shared knowledge and experience, of learning, living and working together with dignity and truly listening.
Staff means anyone who works or volunteers for the Business: be they contractor, regular or otherwise.
1.3 SCOPE OF THE POLICY
This policy applies to all members of the Waves Resilience Community. This includes all staff of Waves Resilience, volunteers, work experience students, individual contractors and consultants, supporters, partners and sponsors. It covers information about the process of recognising and reporting child abuse, sexual abuse or neglect.
Waves Resilience is currently operated by a sole trader (the Team Leader). Provisions in this policy that refer to staff, volunteers, contractors or work experience students apply whenever other people are engaged. Young people who take part in the program as Assistants, as a pathway to leadership, are children and young people under this policy and are protected by it in the same way as all other participants. Assistants may occasionally receive a small honorarium for a task; their parents or carers sign for it.
Part 2: POLICY
2.1 CHILD SAFE COMMITMENT, RECRUITMENT, SELECTION AND STAFF SUPERVISION
Waves Resilience is committed to encouraging Workers, Volunteers, Children and Carers to raise any concerns or provide their views on the well-being of children engaged with Waves Resilience including any perceived risks to a child's safety or signs of abuse or harm.
Waves Resilience will:
regularly survey and talk to children and carers about child-safety matters including informing children about relevant government and non-government services available to them
provide a copy of our Child Safe Policy and Framework upon request by external community members
provide Carers with a contact from Waves Resilience who is available to speak with them or to facilitate speaking with their children at any time during the operating hours of the business
2.1A In the event that Waves Resilience is recruiting via job advertisements:
2.1A.1 All job advertisements will refer to Waves Resilience’s commitment to safeguarding children and young people and reference this policy.
2.1A.2 All recruited staff will be required to read, agree to and sign the Child Safe Code of Conduct and other related Policies.
2.1A.3 All potentially successful applicants (staff and volunteers) will be asked whether they have ever been a subject of an employer investigation or been charged with a criminal offence involving children, violence, drug dealing or dishonesty.
2.1A.4 A minimum of two reference checks are to be conducted for all applications who are being considered for employment before they are contracted. These should not be written references. Referees should be contacted via telephone. The results of these are to be documented and evaluated prior to any employment voluntary or paid.
2.2 WORKING WITH CHILDREN CHECK & POLICE CLEARANCE
It is a legal requirement under the Child Protection (Working With Children) Act 2012 that any person working with children must have a WWCC Clearance.
All employees and volunteers whose roles involve direct contact with children and/or young people as part of their role with Waves Resilience are required to obtain a Working With Children Check (WWCC). If for any reason a WWCC Clearance number has been refused, the individual cannot work with children and/or young people and will be removed from all roles at Waves Resilience that require direct contact with children and young people.
It is the responsibility of the individual to ensure that their WWCC is valid and renewed when necessary.
The status of current staff’s Working With Children Checks will be monitored annually by the Team Leader.
The Team Leader’s own Working With Children Check is also recorded and its expiry date is diarised, so that it is renewed before it lapses. Assistants who are under 18 are not required to hold a Working With Children Check; they take part as young people in the program and are supported by the Team Leader.
Waves Resilience will maintain a database of all employees and volunteers who work directly with children and young people. The information held on the database will include the individual’s full name, aliases, date of birth, WWCC Clearance number, WWCC date of expiry, information provided in statutory declarations, and any other relevant information. This information will be stored confidentially in line with privacy requirements.
Prior to commencing employment, all Waves Resilience employees are required to provide a current Working with Children Check in accordance with the Working With Children legislation, as well as a National Police Clearance issued within three months.
Exclusions from employment findings on a police check may include criminal histories of:
child abuse
child/adult sexual abuse or assault
violence
child pornography or internet offences involving children
an undeclared criminal record of any sort
misleading or dishonest information
Other areas of concern may be:
substance abuse
major dishonesty
An applicant should not be automatically excluded from a position on the basis of having a criminal record. They may include charges for criminal activities that do not necessarily pose a risk to children eg shoplifting. Important factors to take into account are:
the nature of the offence in relation to the nature of the position being offered
the length of time since the offence took place, as well as the age at which it was committed
whether there is evidence of an extended criminal history
severity of punishment imposed ie whether they were convicted, found guilty etc
An applicant should have the opportunity to present a case as to their suitability regarding the above.
2.3 INDUCTION
All new staff and contractors are to participate in formal induction within 30 days of their appointment and are provided with access to documentation outlining Waves Resilience’s policies and operating procedures including this Policy as well as the Waves Resilience Child Safe Code of Conduct.
All new staff members and volunteers, during their induction, are also made aware of the risk of child abuse, indicators of child abuse and mandatory notification obligations and responsibilities.
The Team Leader will refresh their own child protection and mandatory reporting knowledge each year when this Policy is reviewed, and will keep a record of the training completed.
2.4 PROFESSIONAL STANDARDS
Whilst employed, engaged or representing Waves Resilience, all individuals will adhere to these principles:
Treat all children and young people with respect regardless of race, skin colour, sex, language, disability, religion, political or other opinion, national, ethnic or social origin, property, birth or other status.
Provide a welcoming, inclusive and safe environment for all children, young people, parents/guardians, community members, personnel, associates and representatives of Waves Resilience.
Report all concerns and issues to the Team Leader.
Communicate clearly and undertake all tasks in an honest and transparent manner.
Exercise caution in using institutional authority. Positions of authority are not to be used for abusive, exploitative, intimidating, or manipulative purposes.
Maintain professional relationships and clear social boundaries with children and young people.
Abide by the Waves Resilience Child Safe Code of Conduct (Attachment 1)
2.5 CONFIDENTIALITY
Waves Resilience staff who have access to information regarding suspected or disclosed child abuse have a clear obligation to observe appropriate confidentiality in relation to the entire matter and an obligation to ensure that this information is kept secure and not communicated beyond mandatory reporting and staff reporting processes.
2.6 PROTOCOLS
It should be noted that it is the policy of Waves Resilience that:
Staff members do not contact students directly on their personal mobile devices or other direct communication channels without the knowledge and permission of the child’s parent/guardian and this communication must be strictly restricted to practical elements of Waves Resilience programs i.e. asking whether the child/young person wants to attend a Waves Resilience training session, relaying times, what to bring, how to download their app etc. This communication should also be made with parents/guardians at the same time.
Staff members do not use their private vehicles to transport participants without the permission of the child’s parent/guardian
Staff members do not invite children into their homes
Staff members do not visit children inside their homes without the permission of the child’s parent/guardian
2.7 DIGITAL, PRIVACY AND INFORMATION SAFETY
Waves Resilience will:
only take, keep or share photos, video or audio recordings of children with the informed consent of the child and their parent/guardian, and only for the purposes explained to them
not publish identifying information about a child (such as full name, school or where they live) without the consent of the child and their parent/guardian
communicate with children by phone or online only in line with section 2.6 and the Child Safe Code of Conduct
keep information about children (including enrolment, health, incident and evaluation information) secure, share it only with people who need it or where the law requires, and keep only what is needed
explain to children and their parents/guardians how information collected for program evaluation or funding reports will be used, and respect their choice about taking part
act promptly if information about a child is lost or shared by mistake, including telling the people affected
2.8 CULTURAL SAFETY AND INCLUSION
Waves Resilience is committed to the cultural safety of Aboriginal and Torres Strait Islander children and young people, and to a program that is welcoming and inclusive of every child, including children from diverse backgrounds and children with disability. Waves Resilience will:
respect and support each child’s connection to family, community and culture
seek advice from local Aboriginal community members and organisations about cultural safety in the program, and review that advice each year
welcome families, carers and community members to take part in activities
make reasonable adjustments so that children with disability or additional needs can take part safely
Part 3: PROCEDURES (These are also documented in the Child Safety Framework, which contains more detail and should be read and implemented together with this policy.)
3.1 RECOGNITION AND SUSPICION OF ABUSE OR NEGLECT
A child or young person may disclose information about abuse or neglect, either privately or publicly. A staff member/volunteer may perceive there is a concern or believe they have evidence of abuse or neglect.
The staff member/volunteer may confidentially consult with another staff member/volunteer before they make the formal notification to the Team Leader
Confidentiality is paramount, and the staff member/volunteer must not investigate child abuse or neglect matters.
3.2 REPORTING ABUSE OR NEGLECT
3.2.1 A staff member/volunteer who observes or becomes aware through a child’s disclosure of physical, emotional or psychological abuse or neglect must report concerns to the Team Leader.
3.2.2 A young person or child who becomes aware of physical, emotional or psychological abuse or neglect of a child must report to a staff member or volunteer who will then report the concerns to the Team Leader.
3.2.3 Where there are reasonable grounds to suspect that a child is at risk of significant harm, the Team Leader reports the matter to the Department of Communities and Justice (DCJ) Child Protection Helpline on 132 111 (or by eReport) under the Children and Young Persons (Care and Protection) Act 1998 (NSW). The NSW Mandatory Reporter Guide (reporter.childstory.nsw.gov.au) is used to help decide whether a report is required.
3.2.4 Under section 316A of the Crimes Act 1900 (NSW), any adult who knows, believes or reasonably ought to know that a child abuse offence has been committed against a child must report that information to NSW Police as soon as practicable, unless they have a reasonable excuse. Section 43B of the Crimes Act also requires a person in authority in an organisation that engages workers in child-related work to act to reduce or remove a known serious risk that a worker will commit a child abuse offence. If a child is in immediate danger, call 000.
3.3 DISCLOSURE IN PRIVATE
3.3.1 If a child or young person discloses a situation of abuse to a staff member/volunteer, their role is to reassure and support the child or young person in their decision to disclose. They must assure the child or young person that they have a right to feel safe.
3.4 DISCLOSURE IN PUBLIC – PROTECTIVE INTERRUPTION
It is possible that a child or young person may start to disclose in a class or with a group of other students. If disclosure begins in a public arena, it is important to use the strategy of protective interrupting.
3.5 ALLEGATION AGAINST A STAFF MEMBER OR VOLUNTEER
In the event that allegations are made against a Waves Resilience staff member or volunteer, the business is required to immediately suspend that person from all activities involving the direct supervision of, and/ or direct contact with, children and young people.
Reinstatement of a staff member or volunteer may only occur after any and all allegations against that person have been dismissed or cleared to the satisfaction of the Team Leader of Waves Resilience and any authorised interveners involved in investigations.
In the event that the allegations are made against the Team Leader, all activities of the Business will cease. Consultation will be made with the Supervisory Group of Waves Resilience who can, if necessary, manage any necessary communications and procedures at their expert discretion.
The Supervisory Group is made up of experienced workers who have agreed to take the above responsibilities and to manage communications if the business owner is incapacitated. This group is made up of between 2 and 3 person’s experienced in working with children in child focused services. The make up of the Supervisory Group may change from time to time. The names of the Supervisory Group are published on the Waves Resilience website.
3.6 REPORTING FOLLOWING A DISCLOSURE
Once disclosure has been made, the staff member/volunteer needs to determine the child or young person’s immediate need for safety and to consider the emotional state of the child or young person. The staff member needs to:
Ensure the child is safe in the immediate future
Refer the matter to the Team Leader as soon as possible
4 DOCUMENTATION
4.1 At the earliest opportunity (within 24 hours) the staff member/volunteer must fill out a Child Safety Incident Report (see attachment 2) about the incident including dates, the nature of the indications or disclosure, and action taken. These should be placed in a sealed envelope marked “Confidential ‐ Child Protection.” The Team Leader will ensure that any records made while waiting for initial concerns or suspicions to be supported, remain confidential.
4.2 DOCUMENTATION Responsibilities
4.2.1 Team Leader responsibility:
Once the staff member/volunteer has reported the situation further action rests with the Team Leader who will:
Assess the report, obtained from the staff member, volunteer or external party and gather correct and concise information and statements from staff. The NSW Mandatory Reporter Guide (reporter.childstory.nsw.gov.au) is used to help determine whether a report to DCJ is required and the next steps.
Contact Department of Communities and Justice (DCJ) Contact parent or parents, (if advised by the Department) Place the report in a secure place.
Adhere to appropriate record keeping:
Ensure records relating to child abuse, alleged abuse and child safety incidents are archived in a safe and secure location (paper and electronic) for at least 45 years from the date the record was created, or longer where the law requires.
Ensure that processes have been adhered to in an honest and transparent manner, while also providing protection to all involved in the process.
If allegations of reportable conduct arise, the allegation and actions taken need to be documented in detail. It is necessary to always be mindful of confidentiality and privacy requirements and only disclose the information to relevant authorised persons.
All information is to be documented accurately and in an objective manner. All documents need to be signed and dated.
5 DEBRIEFING
5.1 It is imperative for staff member/volunteer’s well‐being that after a disclosure, she or he seeks an opportunity to talk to somebody as soon as possible. The Team Leader is the most suitable person, however, if staff prefer to debrief with someone else, they must be mindful that the issues of confidentiality are paramount to protect the child or young person.
6 MANAGEMENT OF EXTERNAL PARTIES
6.1 It is extremely important that staff or volunteers are mindful of the damage that can be caused through gossip and innuendo.
6.2.1 Waves Resilience staff members/volunteers are advised to not inform parents that their child/ren have been maltreated. It is recommended that officers of the DCJ undertake this task as they are trained and experienced in dealing with these situations and any questions the family may have.
6.2.2. Details which would identify the alleged perpetrator, or the children and young people involved in allegations, should not be disclosed to parents of other children attending Waves Resilience activities. Discuss any plans to advise parents of these concerns with DCJ before you take this action.
6.2.3. Staff who are not immediately involved in the allegation may need to be informed that an allegation has been made. Unless staff are briefed, they will not be aware what procedures Waves Resilience is implementing and will not be able to respond appropriately to parent concerns and other issues as they arise.
6.2.4. Staff directly involved in the supervision of the person or involved in providing care to the child/ren affected by the maltreatment may need additional information to enable them to fulfil their duties.
6.2.5. The decisions of what to tell staff and when to tell them needs careful consideration to ensure confidentiality is maintained and any investigations are not compromised. Staff should consult with the Supervisory Group, if it is involved in the investigation, before providing information to staff.
6.2.6. Children and young people who have been maltreated may be traumatised or develop behaviours that require additional support. It is important that staff are aware of these issues and monitor the children’s behaviour. The DCJ can assist Waves Resilience staff attend to the needs of these individual children and young people.
6.2.7. Allegations of maltreatment against a staff member of a service will normally cause strong responses from other staff members. These may include:
Loyalty to the colleague who is the alleged perpetrator.
Disbelief and/or anger towards the child and/or the investigating authorities.
Disgust at the idea that a child in their care could be maltreated.
Confusion and mixed loyalties to the child/ren and the staff member.
Fear that an accusation could be made against them.
Sense of failure for not protecting children in their care.
It is important that during and after an investigation of maltreatment, staff have an opportunity to be debriefed to enable them to deal with these emotions.
6.2.8. Allegations of maltreatment in a children’s service are contentious and extremely emotional and may attract media attention. The Supervisory Group will advise and assist at their professional discretion.
7 INDICATORS OF POSSIBLE CHILD ABUSE AND NEGLECT- Refer to Waves Resilience Child Safety Framework Document
8 MONITORING OF POLICY
This Child Safety Policy is evaluated on annual basis by the Business owner/Team Leader. Staff are advised of revisions and updates to the policy and it is their responsibility to be aware of all changes.
We are guided by legislation, standards and principles including:
The 10 Child Safe Standards under the Children’s Guardian Act 2019 (NSW), as set out by the NSW Government Office of the Children’s Guardian and informed by the Royal Commission into Institutional Responses to Child Sexual Abuse, drawing on its findings, research and consultation about what makes business’s child safe.
The 10 National Principles for Child Safe Organisations, which are adopted under the Commonwealth Child Safe Framework and apply to Commonwealth-funded activities through the child safety obligations in our funding arrangements (the National Principles are listed in the Child Safety Framework).
As a provider of recreational programs for children in NSW, Waves Resilience implements the NSW Child Safe Standards through this Policy, the Child Safety Framework, the Child Safe Code of Conduct, the Complaints Handling Policy and section 11 and the Risk Register, and reviews them annually.
Waves Resilience welcomes feedback on its policies and practice and will ensure feedback is analysed to inform continuous improvement.
Waves Resilience Policies including the Child Safety Policy are available on the Waves Resilience website at https://www.coequal.com.au/waves-policies.
9 BREACH OF POLICY
If staff members or volunteers breach this policy they may be subject to disciplinary actions.
10. Risk Management
10.1 Review Child Safety Risks annually via reviewing this policy and it’s implementation.
10.2 Contact with children is to be conducted in visible places, usually at the beach and in open public places.
10.3 Some Waves Resilience activities involve the Team Leader driving a child or young person alone in the Team Leader’s vehicle, and some support sessions are one-to-one. This is part of how the program works and is managed as follows:
10.3.1 Parents and carers give written permission at enrolment for children to travel in the vehicles of Waves Resilience staff to and from sessions, and parents and carers are aware when a session is one-to-one.
10.3.2 Trips outside usual Waves Resilience activities (for example court, medical or other service appointments) are discussed with the parent or carer beforehand, and a record is kept.
10.3.3 Trips and one-to-one sessions take place at, or on the way to, public or service locations where other people are usually present.
10.3.4 The Team Leader keeps a trip log recording who was in the vehicle and which sessions or supports they attended.
10.3.5 Children use a seatbelt or appropriate restraint.
10.3.6 Children and families are told they can raise any concern with the Team Leader or through the Complaints Handling Policy, including by contacting the Supervisory Group.
10.4 Children can be accompanied by parents or guardians at anytime and this is welcomed and parents/guardians can also participate in Waves Resilience activities and counselling/mentoring sessions.
10.5 The Risk Register records, for each risk, existing controls, the residual risk rating, planned treatments, the risk owner, the treatment due date and the review date. Child safety risks are grouped under six areas: people and workforce safety; reporting and response; program supervision and practice; physical and environmental safety; digital, privacy and information safety; and cultural safety, inclusion and governance.
10.6. Refer to Waves Resilience Risk Register for more risk management connected to the program.
11. COMPLAINTS AND CONCERNS
11.1 Waves Resilience has a Complaints Handling Policy, which, with the other Waves Resilience policies and procedures, is available at https://www.coequal.com.au/waves-policies and sets out how complaints are made and handled, including timeframes. In summary, anyone, including a child, young person, Assistant, parent, carer, worker or community member, can raise a concern or make a complaint about the safety of a child or the conduct of anyone connected with Waves Resilience. Concerns can be raised in person, by phone, by message or in writing, with the Team Leader, using the contact details published on the Waves Resilience website and provided to families. A child does not need an adult to raise a concern for them, and may bring a support person. Parents, carers and participants are directed to these policies and procedures on the website through the permission form and in verbal and written introductions to Waves Resilience.
11.2 Concerns and complaints are taken seriously, handled promptly and kept confidential. The person raising the concern will be listened to without blame, will not be pressured, and will be told what happens next and what is being done, unless that would put someone at risk or interfere with an investigation. Complaints are handled in a way that puts the child’s safety and wellbeing first.
11.3 If a concern involves suspected abuse or a risk of significant harm to a child, the reporting process in Part 3 and the Child Safety Framework applies, including reports to the DCJ Child Protection Helpline and NSW Police where required.
11.4 If the complaint is about the Team Leader, or the person does not want to raise it with the Team Leader, they may contact the Supervisory Group (names published on the Waves Resilience website) or an external body: the NSW Office of the Children’s Guardian (ocg.nsw.gov.au); the DCJ Child Protection Helpline (132 111); NSW Police (Police Assistance Line 131 444, or 000 in an emergency); or Kids Helpline (1800 55 1800), which children can call for free at any time.
11.5 Concerns, complaints and the action taken are recorded and kept securely in line with section 4.2.1, and are reviewed each year to improve how Waves Resilience keeps children safe.
Attachment 1
Waves Resilience | CHILD SAFE CODE OF CONDUCT
All paid and unpaid staff, including volunteers, interns or trainees of Waves Resilience are responsible for the safety and wellbeing of children and young people who engage with Waves Resilience. All paid and unpaid staff are expected to act in accordance with this Code of Conduct in their physical and online interactions with children and young people under the age of 18 years.
I will:
Act in accordance with Waves Resilience’s child safety and wellbeing policies and procedures at all times.
Behave respectfully, courteously and ethically towards children and their families and towards other staff.
Listen and respond to the views and concerns of children, particularly if they communicate (verbally or non-verbally) that they do not feel safe or well.
Promote the human rights, safety and wellbeing of all children in Waves Resilience.
Demonstrate appropriate personal and professional boundaries.
Consider and respect the diverse backgrounds and needs of children.
Create an environment that promotes and enables children’s participation and is welcoming, culturally safe and inclusive for all children and their families.
Involve children in making decisions about activities, policies and processes that concern them wherever possible.
Contribute, where appropriate, to Waves Resilience policies, discussions, learning and reviews about child safety and wellbeing.
Identify and mitigate risks to children’s safety and wellbeing as required by Waves Resilience’s risk assessment and management policy or process.
Respond to any concerns or complaints of child harm or abuse promptly and in line with Waves Resilience’s policy and procedure for receiving and responding to complaints.
Report all suspected or disclosed child harm or abuse as required by New South Wales and federal legislation and by Waves Resilience’s policy and procedure on internal and external reporting.
Comply with Waves Resilience’s protocols on communicating with children.
Comply with state and federal legislation and Waves Resilience’s policies and procedures on record keeping and information sharing.
I will NOT:
Engage in any unlawful activity with or in relation to a child.
Engage in any activity that is likely to physically, sexually or emotionally harm a child.
Unlawfully discriminate against any child or their family members.
Be alone with a child unnecessarily.
Arrange personal contact, including online contact, with children I am working with for a purpose unrelated to Waves Resilience’s activities.
Disclose personal or sensitive information about a child, including images of a child, unless the child and their parent or legal guardian consent or unless I am required to do so by Waves Resilience’s policy and procedure on reporting.
Use inappropriate language in the presence of children, or show or provide children with access to inappropriate images or material.
Work with children while under the influence of alcohol or prohibited drugs.
Ignore or disregard any suspected or disclosed child harm or abuse.
If I think this Code of Conduct has been breached by another person at Waves Resilience I will:
Act to prioritise the best interests of children.
Take actions promptly to ensure that children are safe.
Promptly report any concerns to the Team Leader at Waves Resilience.
Follow Waves Resilience’s policies and procedures for receiving and responding to complaints and concerns.
Comply with state and federal legislation if relevant, and with Waves Resilience’s policy and procedure on internal and external reporting.
I agree to abide by this Code of Conduct during my employment with
Waves Resilience.I understand that breaches of this Code of Conduct may lead to disciplinary action or termination of my employment with
Waves Resilience..........................................................................
Signature.........................................................................
Full Name.............................................
Date
Attachment 2
Waves Resilience | CHILD SAFETY INCIDENT REPORT
Complete within 24 hours of the incident, disclosure or concern. Record facts only, in the child’s own words where possible, without interpretation. Place the report in a sealed envelope marked “Confidential – Child Protection” and give it to the Team Leader.
Date and time of incident, disclosure or concern
Location
Report completed by (name and role)
Child’s name and age
Parent/carer name and contact (if known)
What was seen, heard or disclosed (child’s own words where possible; facts only)
Who else was present or may know about it
Action taken to keep the child safe
Reported to (Team Leader; DCJ Child Protection Helpline 132 111; NSW Police; other) – date, time and reference number
Parent/carer informed? (only if advised by DCJ or Police) – who, when
Follow-up needed and by whom
Signature and date
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Child Safety Framework
Waves Resilience
Reviewed: October 2026
Scheduled for Review October 2027
CHILD SAFETY FRAMEWORK
Waves Resilience
Waves Resilience is committed to encouraging workers, volunteers, children, young people, carers or community members to raise any concerns or provide their views on the well-being of children engaged with Waves Resilience including any perceived risks to a child's safety or signs of abuse or harm.
This document outlines a framework for Waves Resilience’s Child Safety Policy requirements and provides guidance for its implementation.
The purpose is to protect children and young people from the risk of harm and abuse, and support Waves Resilience staff and volunteers in their work with children and young people to understand and implement due diligence in situations that involve identifying and/or reporting child safety concerns.
Waves Resilience is currently operated by a sole trader (the Team Leader). References in this Framework to staff, volunteers and contractors apply whenever other people are engaged.
1. RECOGNITION OR SUSPICION OF CHILD SAFETY CONCERNS
All incidents disclosures or suspicions of harm are to Waves Resilience are taken seriously and actioned immediately.
A disclosure or suspicion can often arouse strong feelings in the person to whom the disclosure or observation is being made. Such reactions may include shock, anger and helplessness. It is important for the staff member/volunteer to be aware and in control of these feelings and ensure that they are dealt with following the disclosure.
A staff member/volunteer is never responsible for investigating his or her suspicions or the child or young person’s disclosure and the minimum amount of information is to be collected. Other agencies or individuals have this responsibility.
If a child or young person discloses harm, only ask open questions to confirm the need to report the matter. Waves Resilience employees/volunteers should avoid asking probing questions as this could cause distress, confusion and interfere with any later enquiries.
For instance, Waves Resilience employees/contractors/volunteers should ask non-leading questions such as “What happened then?” or “Can you tell me about that?”, as opposed to leading questions such as “Did X touch you?”
1.1 DISCLOSURE IN PRIVATE
If a child or young person discloses a situation of abuse to a staff member/volunteer, their role is to reassure and support the child or young person in their decision to disclose. They must assure the child or young person that they have a right to feel safe.
It is not easy for a child or young person to disclose abuse or neglect as they may previously have been coerced, bribed or threatened into secrecy. They may need repeated reassurance that they are believed and that it was right to tell.
Sometimes a child or young person will try to elicit a promise that the staff member/volunteer not tell anyone about the disclosure. Do not make this promise. If this happens it is important to explain that you have concerns about their safety and that you have to take action to ensure that they will be protected from further abuse.
1.2 DISCLOSURE IN PUBLIC – PROTECTIVE INTERRUPTION
It is possible that a child or young person may start to disclose in a class or with a group of other students. If disclosure begins in a public arena it is important to use the strategy of protective interrupting:
acknowledge that you have heard the child or young person and stop them disclosing any further, be supportive and gently indicate that they may want to talk to you about it in a more private situation
quietly arrange to see the child or young person as soon as possible, away from other students
do not allow other children or adults to ask questions or make judgments
A staff member/volunteer’s role is to listen actively to what the child or young person is saying but not push for details.
1.3 SUSPICIONS OF CHILD SAFETY CONCERNS
Waves Resilience employee/volunteers may have ‘reasonable grounds’ to suspect harm if:
Someone else, for example, another child or young person, a parent, or a staff member, tells Waves Resilience employees/volunteers that harm has occurred or is likely to occur
A child or young person informs Waves Resilience employees/volunteers they know someone who has been harmed. (It is possible the child may be referring to themselves)
Waves Resilience employees/volunteers are concerned at significant changes in the behaviour of a child or young person, or the presence of new unexplained and suspicious injuries, and/or
Waves Resilience employees/volunteers witness the harm occurring. If this is the case, intervene immediately, provided it is safe to do so. If it is unsafe, call the police.
1.4 INDICATORS OF POSSIBLE CHILD ABUSE OR NEGLECT
The following list of indicators of child abuse and neglect should be used as a guide only and are not exhaustive but contain those indicators which will be of most use to Waves Resilience staff members/volunteers. Indicators need to be considered in the context of their consistency with a child's developmental stage, medical history and social context. Any of these indicators may suggest that a child is being or has been abused or neglected. Some indicators may also suggest other emotional trauma. With young children their play or drawings often represent the trauma they are experiencing, and they do not always have the language to express themselves. They may not be aware that what is happening is not normal.
Sexual Abuse
Physical Indicators
- Genital or anal bleeding
- Signs of pain or discomfort in the genital or anal areas
- Pregnancy
- Unexplained difficulty in walking or sittingBehavioural Indicators
- Disclosure of involvement in sexual activity
- Inappropriate interest or knowledge of sexual matters
- Reports of sexual assault or inappropriate sexual behaviour to a staff member- Changes in academic performance
Physical Abuse
Physical Indicators
- Unexplained bruises and welts, particularly on face, lips, mouth, back, torso or on several different body parts
- Shaped or linear bruising- Unexplained burns shaped or linear
- Unexplained fractures
- Injuries in various stages of healingBehavioural Indicators
- Fear of adults, particularly parents
- Startled reflex, cringes when sudden movement by adult
- Behavioural extremes, withdrawn or aggressive
- Afraid to go home
- Reports of injury from child
- Changes in academic performanceEmotional Abuse
Physical Indicators
- Speech disorders
- Failure to thrive
- Lags in physical developmentBehavioural Indicators
- Habit behaviours not consistent with developmental stage
- Conduct disorders, destructive, violent
- Behavioural extremes
- Changes in academic performanceNeglect
Physical Indicators
- Consistent hunger
- Unattended physical or medical problems- Inadequate clothing
- AbandonmentBehavioural Indicators
- Constant fatigue
- Developmental delays
- Changes in academic performance2. PROCESS FOR REPORTING FOLLOWING A DISCLOSURE OR SUSPICION
Waves Resilience requires all employees and volunteers to inform the Team Leader (Sole Trader) of any concerns that they may have about a child or young person. The Team Leader should be informed of any serious concerns, particularly where a child is considered to be at significant risk of harm. Where the threshold for significant risk of harm is reached, the Team Leader is required under the Children and Young Persons (Care and Protection) Act 1998 (NSW) to report the matter to the Department of Communities and Justice (NSW). Where the threshold for significant harm is not met, advice should be obtained from the Team Leader in order to take appropriate action to most effectively assist the child.
The Team Leader uses the NSW Mandatory Reporter Guide (reporter.childstory.nsw.gov.au) to help decide whether a report is required, and reports to the DCJ Child Protection Helpline on 132 111 (or by eReport).
Under section 316A of the Crimes Act 1900 (NSW), any adult who knows, believes or reasonably ought to know that a child abuse offence has been committed against a child must also report that information to NSW Police as soon as practicable, unless they have a reasonable excuse. If a child is in immediate danger, call 000.
2.1 SAFETY OF CHILD OR YOUNG PERSON
Once disclosure has been made or suspicion has been observed, the staff member/volunteer needs to determine the child or young person’s immediate need for safety and to consider the emotional state of the child or young person.
The staff member needs to:
• Ensure the child is safe in the immediate future
• Refer the matter to the Team Leader as soon as possible
2.2 DOCUMENTATION
2.2.1 STAFF/ VOLUNTEER RESPONSIBILITY:
At the earliest opportunity (within 24 hours) the staff member/volunteer must fill out a Child Safety Incident Report about the incident including dates, the nature of the indications or disclosure, and action taken.
These should be placed in a sealed envelope marked “Confidential.” The Team Leader will ensure that any records made while waiting for initial concerns or suspicions to be supported, remain confidential.
2.2.2 TEAM LEADER RESPONSIBILITY:
Once the staff member/volunteer has reported the situation further action rests with the Team Leader), who will:
Assess the report, obtained from the staff member, volunteer or external party and gather correct and concise information and statements from staff.
Contact Department of Communities and Justice (DCJ) Contact parent or parents, (if advised by the Department) Place the report in a secure place.
Adhere to appropriate record keeping:
Ensure records relating to child abuse, alleged abuse and child safety incidents are archived in a safe and secure location (paper and electronic) for at least 45 years from the date the record was created, or longer where the law requires.
Ensure that processes have been adhered to in an honest and transparent manner, while also providing protection to all involved in the process.
If allegations of reportable conduct arise, the allegation and actions taken need to be documented in detail. It is necessary to always be mindful of confidentiality and privacy requirements and only disclose the information to relevant authorised persons.
All information is to be documented accurately and in an objective manner. All documents need to be signed and dated.
2.3 DEBRIEFING
It is imperative for staff member/volunteer’s well‐being that after a disclosure, she or he seeks an opportunity to talk to somebody as soon as possible. The Team Leader is the most suitable person, however, if staff prefer to debrief with someone else, they must be mindful that the issues of confidentiality are paramount to protect the child or young person.
3. MANAGEMENT OF EXTERNAL PARTIES
It is extremely important that staff or volunteers are mindful of the damage that can be caused through gossip and innuendo.
3.1 SAFETY OF PARENTS, CARERS OR GUARDIANS
Waves Resilience staff members/volunteers are advised not to inform parents, carers or guardians that their child/ren have been maltreated. It is recommended that officers of the DCJ undertake this task as they are trained and experienced in dealing with these situations and any questions the family may have.
Details which would identify the alleged perpetrator, or the children and young people involved in allegations, should not be disclosed to parents of other children attending Waves Resilience activities.
Discuss any plans to advise parents of these concerns with the Team Leader and/or the DCJ before you take this action.
3.2 SAFETY OF STAFF
Staff who are not immediately involved in the allegation may need to be informed that an allegation has been made. Unless staff are briefed, they will not be aware what procedures Waves Resilience is implementing and will not be able to respond appropriately to parent concerns and other issues as they arise.
Staff directly involved in the supervision of the person or involved in providing care to the child/ren affected by the maltreatment may need additional information to enable them to fulfil their duties.
The decisions of what to tell staff and when to tell them needs careful consideration to ensure confidentiality is maintained and any investigations are not compromised. Staff should consult with the Supervisory Group, if it is involved in the investigation, before providing information to other staff members.
Children and young people who have been maltreated may be traumatised or develop behaviours that require additional support. It is important that staff are aware of these issues and monitor the children’s behaviour. The DCJ can assist Waves Resilience staff attend to the needs of these individual children and young people.
It is important that during and after an investigation of maltreatment, staff have an opportunity to be debriefed to enable them to deal with these emotions.
4. RISK MANAGEMENT
Waves Resilience personnel will undertake risk assessments on all programs and activities that have contact with children. The assessments should identify risks, classify any high risk activities, and implement steps to reduce or remove these risks.
Among our risk management we adhere to legislation, standards and principles including:
The 10 Child Safe Standards under the Children’s Guardian Act 2019 (NSW), as set out by the NSW Government Office of the Children’s Guardian and informed by the Royal Commission into Institutional Responses to Child Sexual Abuse, drawing on its findings, research and consultation about what makes organisations child safe.
1. Child safety is embedded in organisational leadership, governance and culture
2. Children participate in decisions affecting them and are taken seriously
3. Families and communities are informed and involved
4. Equity is upheld, and diverse needs are taken in to account
5. People working with children are suitable and supported
6. Processes to respond to complaints of child abuse are child focused
7. Staff are equipped with the knowledge, skills and awareness to keep children safe through continual education and training
8. Physical and online environments minimise the opportunity for abuse to occur
9. Implementation of the Child Safe Standards is continuously reviewed and improved
10. Policies and procedures document how the organisation is child safe
The 10 National Principles for Child Safe Organisations, adopted under the Commonwealth Child Safe Framework and applied to Commonwealth-funded activities through child safety obligations in funding arrangements:
1. Child safety and wellbeing is embedded in organisational leadership, governance and culture
2. Children and young people are informed about their rights, participate in decisions affecting them, and are taken seriously
3. Families and communities are informed and involved in promoting child safety and wellbeing
4. Equity is upheld and diverse needs respected in policy and practice
5. People working with children and young people are suitable and supported to reflect child safety and wellbeing values in practice
6. Processes for complaints and concerns are child focused
7. Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training
8. Physical and online environments promote safety and wellbeing, while minimising the opportunity for children and young people to be harmed
9. Implementation of the national child safe principles is regularly reviewed and improved
10. Policies and procedures document how the organisation is safe for children.
Waves Resilience also takes account of the Commonwealth Child Safe Framework and the child safety obligations in its funding arrangements. As a provider of recreational programs for children in NSW, it implements the NSW Child Safe Standards through the Child Safety Policy, this Framework, the Child Safe Code of Conduct and the Risk Register.
The Waves Resilience Risk Register is reviewed annually. It records existing controls, residual risk ratings, planned treatments, risk owners, treatment due dates and review dates, and groups child safety risks under six areas: people and workforce safety; reporting and response; program supervision and practice; physical and environmental safety; digital, privacy and information safety; and cultural safety, inclusion and governance.
5. COMPLAINTS AND CONCERNS
Concerns and complaints from children, young people, families, carers and others are handled under the Waves Resilience Complaints Handling Policy and section 11 of the Child Safety Policy. Where a concern involves suspected abuse or a risk of significant harm, the reporting process in section 2 of this Framework also applies.
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Waves Resilience Privacy Policy
Waves Resilience is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers.
This Personal Information is obtained in many ways including [permission forms, interviews, correspondence, by telephone and facsimile, by email, via our website, via our apps,] and from third parties. We don’t guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Waves Resilience will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Policy Updates
This Policy may change from time to time.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy please contact us at:
Waves Resilience
Phil@coequal.com
0427697173 -
COMPLAINTS HANDLING POLICY – Waves Resilience
Reviewed: October 2026
Scheduled for Review: October 2027
DEFINITIONS
Worker means any person that performs work for Waves Resilience including but not limited to:
Business Owner/Team Leader
employees (permanent and casual)
volunteers
contractors and sub-contractors
work experience students/interns/secondments/student placements.
Child means a person under the age of 18.
Complaint means an expression of dissatisfaction (including by a Child or Carer or anyone on their behalf) about Waves Resilience's Workers or practices where a response or resolution is explicitly or implicitly expected or legally required and is to be distinguished from:
• feedback about Waves Resilience’s practices or Workers where a response is not explicitly or implicitly expected or legally required
• reports of problems or wrongdoing merely intended to bring an issue to Waves Resilience's notice with no expectation of a response.
SCOPE
This Policy applies to all Complaints about Waves Resilience's Workers or practices.
This Policy applies to Complaints made by or on behalf of Children, Carers, community members and Workers. Waves Resilience is currently operated by a sole trader (the Team Leader); provisions about Workers apply whenever other people are engaged. It operates together with the Waves Resilience Child Safety Policy and Child Safety Framework, which apply to any concern or Complaint involving the safety of a Child.
PURPOSE
Waves Resilience is strongly committed to the safety and well-being of all Children that it engages with by creating and maintaining a Child-safe environment.
Waves Resilience is committed to ensuring that all Complaints made about its Workers and practices, including in relation to Complaints involving Children, are dealt with fairly, efficiently and effectively in order to:
protect the welfare and safety of Children that Waves Resilience engages with
ensure public confidence in Waves Resilience’s Workers and practices
assist Waves Resilience to improve the quality of its Workers and practices.
POLICY
Organisational commitment
Waves Resilience is committed to fair, effective and efficient Complaint handling while at the same time recognising:
its responsibilities to perform its core functions in the most effective and efficient way possible
the importance of the health, safety and security of its Workers
the need to allocate resources fairly across multiple Complaints.
Waves Resilience expects that the Team Leader will promote a culture that values Complaints and their effective resolution including where appropriate by:
providing a copy of this policy to anyone who requests it, and making it available at https://www.coequal.com.au/waves-policies.
keeping records on Waves Resilience’s Complaint handling and reporting publicly if required.
providing adequate support and direction to any staff responsible for Complaint handling
regularly reviewing reports about Complaint trends and issues arising from Complaints
encouraging Workers to be alert to Complaints and assist those responsible for handling Complaints to resolve them promptly
encouraging Workers to make recommendations for system improvements and acting upon those recommendations
recognising and rewarding good Complaint handling.
Waves Resilience expects that all Workers will understand and comply with Waves Resilience’s Complaint Handling Policy and Procedure including where appropriate by:
treating complainants with respect
assisting people to make a Complaint, if needed
being alert to Complaints and assisting Workers handling Complaints to resolve Complaints promptly
providing feedback to management on issues arising from Complaints and/or ways to improve Waves Resilience's Complaints Handling Procedure
implementing changes arising from Complaints as required.
Guiding principles
Waves Resilience is committed to facilitating the making of Complaints by:
making information available about its Complaint handling process and how Complaints can be made, including anonymously
respecting complainants and ensuring they do not suffer detriment by reason of having made a Complaint or having had one made on their behalf
protecting the identity of complainants where this is practical and appropriate.
Waves Resilience is committed to responding to Complaints in an appropriate manner by:
promptly acknowledging receipt of Complaints
assessing and prioritising Complaints in accordance with the urgency and/or seriousness of the issues raised
managing expectations by informing complainants of the Complaint Handling Procedure including expected time frames, the progress of the Complaint and reasons for any delay, the complainant's likely involvement in the process where appropriate, the possible or likely outcome and, if Waves Resilience is unable to deal with any part of the Complaint, providing advice about alternative avenues of redress
addressing each Complaint in a fair, objective and unbiased manner
adopting a flexible approach to Complaint handling
resolving Complaints in a timely manner
providing complainants or their representatives with information regarding the outcome of a Complaint.
Waves Resilience is committed to managing the parties to a Complaint by:
where a Complaint is made about Waves Resilience's practices or Workers and an external organisation (such as a Complaint involving a contractor), working with the other organisations where possible, to ensure proper communication with the complainant and/or their representative subject to privacy and confidentiality considerations
where similar Complaints are made by multiple parties establishing a representative of the group with whom to communicate, where possible
where Waves Resilience considers that a Complaint is not genuine or where a complainant has acted unreasonably, by taking proactive and decisive action to manage such conduct and to protect its Workers.
HOW TO MAKE A COMPLAINT
Anyone can make a Complaint, including a Child, Carer, community member or Worker. A Complaint can be made in person, by phone, by message, by email or in writing, anonymously, or through someone who speaks for the person, such as a support person, family member or advocate. A Child does not need an adult’s permission or help to make a Complaint and may bring a support person of their choice. Contact details for the Team Leader are provided to families.
TIMEFRAMES
Waves Resilience aims to:
acknowledge every Complaint within 2 working days (immediately, if it involves the safety of a Child)
give the complainant the outcome, or a progress update and the reason for any delay, within 20 working days
tell the complainant what will happen next, unless doing so would put someone at risk or interfere with an investigation.
COMPLAINTS INVOLVING THE SAFETY OF A CHILD
Any Complaint that involves abuse, harm or a risk of harm to a Child, or the conduct of a Worker towards a Child, is dealt with immediately under the Child Safety Policy and Child Safety Framework. This includes making a report to the Department of Communities and Justice Child Protection Helpline (132 111) and/or NSW Police where required. The matter is not delayed until the Complaint process is finished, and Waves Resilience does not investigate alleged abuse itself; that is for the authorities. A Worker who is the subject of an allegation is removed from contact with Children while the matter is dealt with (Child Safety Policy, section 3.5).
Complaints from Children are handled in a child-focused way. The Child is listened to, taken seriously, not blamed, and supported. They are told in age-appropriate language what will happen next.
IF THE COMPLAINANT IS NOT SATISFIED, OR DOES NOT WANT TO COMPLAIN TO THE TEAM LEADER
A complainant may contact the Supervisory Group (see below) or an external organisation:
NSW Office of the Children’s Guardian – ocg.nsw.gov.au
DCJ Child Protection Helpline – 132 111 (24 hours)
NSW Police – Police Assistance Line 131 444, or 000 in an emergency
Kids Helpline – 1800 55 1800 (free, 24 hours, for children and young people).
RECORDS
Complaints, the action taken and the outcome are recorded and kept securely and confidentially. Records of Complaints involving Children, including allegations of abuse or harm, are kept for at least 45 years (Child Safety Policy, section 4.2.1). Records are reviewed at least annually to identify trends and improvements.
PERSON RESPONSIBLE
The Team Leader of Waves Resilience will be responsible for management of Waves Resilience’s Complaint Handling Procedure. If the Complaint is about the Team Leader and it is not appropriate for them to handle the Complaint, the complaint will be referred to the Supervisory Group of Waves Resilience (the names of its members are published on the Waves Resilience website). To contact the Supervisory Group directly, please email: ed.u.playillawarra@gmail.com
POLICY REVIEW PROCESS
This Policy will be reviewed annually and the Team Leader will undertake to incorporate feedback from Children, Carers and Workers.
USEFUL CONTACTS
Anyone can contact these services at any time, including to raise a concern about Waves Resilience:
Emergency (police, fire, ambulance): call 000.
NSW Police, non-urgent: Police Assistance Line 131 444, or report online at portal.police.nsw.gov.au. Crime Stoppers (to give information anonymously): 1800 333 000.
Child Protection Helpline (NSW Department of Communities and Justice): 132 111, open 24 hours a day, 7 days a week (TTY 1800 212 936). Use this to report a child at risk of significant harm.
NSW Office of the Children’s Guardian: (02) 8219 3600, Monday to Friday, 9:00am to 4:50pm. Website: ocg.nsw.gov.au (online contact form at ocg.nsw.gov.au/contact-us). Postal address: Locked Bag 5100, Strawberry Hills NSW 2012.
Kids Helpline (for children and young people aged 5 to 25): 1800 55 1800, free, 24 hours a day, 7 days a week. WebChat at kidshelpline.com.au.
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Waves Resilience - Workplace, Health and Safety Policy
Purpose
The Workplace, Health and Safety Policy (WHS) supports the health and safety management system at Waves Resilience? and describes the relevant responsibilities and accountabilities under this system to ensure compliance with the Work Health and Safety Act 2011 (NSW) (the Act).
Scope
This policy applies to all staff, affiliates and contractors (hereafter 'workers'), participants, officers of the organisation and visitors to the organisation when undertaking work, activities and or function at, or on behalf of Waves Resilience (or 'the organisation’).
The Business Owner (Team Leader) is the Safety Officer of the organisation, for the purpose of this policy.
Principles
Waves Resilience is committed to ensuring the health, safety and wellbeing of its workers, participants and visitors in line with its values and strategy.
Waves Resilience will manage risk to prevent serious injury that impacts the health, safety and wellbeing of staff, participants or individuals.
Workers, participants and visitors have a collective and individual responsibility to adhere to safe work and study practices to prevent injuries and illnesses and act in compliance with the Act. The success of the organisation's health and safety management system depends on the commitment, cooperation and input of all those under the scope of this policy.
Waves Resilience recognises its responsibilities to comply with the requirements of the Act and aims to ensure, so far as is reasonably practicable, the health and safety of workers, participants and visitors by:
complying with all applicable legislation
integrating health and safety risk management practices into its operations, and functions with a focus on continuous improvement
ensuring that effective consultation and communication mechanisms are implemented, monitored and improved to ensure general understanding of the health and safety management system
providing a safe environment for work and study (including safe plant, structures and safe systems of work)
ensuring the safe use, handling and storage of plant, structures and substances
providing adequate facilities for the health and safety at work of workers, students and visitors
monitoring the health of workers and the conditions at the workplace as part of an illness and injury prevention strategy
providing relevant information, training, instruction or supervision to workers and where appropriate, students, affiliates and visitor
managing any accidents and incidents that occur, in order to minimise harm and prevent recurrences
allocating appropriate resources to facilitate the fulfilment of the organisation's health and safety responsibilities.
Policy statements
The Act sets out the broad responsibilities for the Person Conducting Business or Undertaking (PCBU) (henceforth 'the organisation'). Whilst tasks related to fulfilling these responsibilities may be performed by others, the responsibilities themselves cannot be delegated, transferred or contracted out.
Officers of the organisation must exercise due diligence (defined in section 27(5) of the Act) to ensure the organisation complies with its duties or obligations.
Workplace Health and safety responsibilities
Risk Management Officer (Team Leader)
The Risk Management Officer has primary responsibility for overseeing, delegating, facilitating and coordinating the workplace health and safety management tasks and protocols, which includes:
supporting staff and contractors in meeting their health and safety objectives
referring to external bodies (such as the Safe Work NSW and NSW Health) in the fields of work health and safety, and risk management
providing a workplace injury management and return to work program that assists staff to promptly return to safe and durable work following injury or illness
managing the organisation's workers' compensation insurance strategy and procedures
monitoring compliance through the regular auditing of equipment and facilities
providing information and training resources to assist colleagues and contractors
advice and guidance to key stakeholders to strengthen awareness of the compliance requirements of Waves Resilience's health and safety procedures.
ensuring that appropriate resources and processes are allocated to eliminate or minimise risks to health and safety that may arise as part of the organisation's operations
ensuring that the organisation has appropriate processes for receiving and considering information regarding incidents, hazards and risks and responding in a timely way to that information
ensuring that the organisation has processes for complying with any duty or obligation under the Act such as:
reporting notifiable incidents
consulting with workers and affiliates
ensuring compliance with notices issued under the Act
ensuring the provision of training and instruction to workers about work health and safety.
Workers
In taking responsibility for health and safety at Waves Resilience, workers (including contractors and casuals) must:
take reasonable care of, and cooperate with actions taken to protect, the health and safety of both themselves and others
follow safe work practices as provided by the Risk Management Officer, including the proper use of any personal protective equipment supplied
seek information or advice before performing new or unfamiliar tasks
report all health and safety accidents, incidents and hazards to the Risk Management Officer as soon as is practicable
comply with workplace injury management and return to work programs
follow the emergency evacuation procedures and any instructions given by emergency personnel
Visitors or participants
In taking responsibility for health and safety at Waves Resilience, visitors and participants must:
undertake the necessary health and safety induction training when coming onto an activity location
take reasonable care of, and cooperate with actions taken to protect, the health and safety of both themselves and others
report all health and safety accidents, incidents and hazards to a staff member as soon as is practicable
follow the emergency evacuation procedures and any instructions given by emergency personnel.
6. Definitions
The following definitions apply for this policy:
Officers are as defined by section 9 of the Corporations Act 2001 (Cwlth) as persons who make, or participate in making, decisions that affect the whole or a substantial part of the business.
Participant means any member of the public undertaking an activity with Waves Resilience? workers.
PCBU is defined as 'persons conducting a business or undertaking' as defined in section 5 of the Work Health and Safety Act 2011 (NSW). In this policy, the organisation (Waves Resilience?) is the PCBU.
Plant includes any machinery, equipment, appliance, container, implement and tool, and any component of any of those things, and anything fitted or connected to any of those things.
Risk management is defined as the identification, evaluation, and prioritisation of risks followed by coordinated and economical application of resources to minimise, monitor, and control the probability or impact of unfortunate events or to maximize the realization of opportunities. For the specific purposes of this policy, in includes the 'coordinated activities to direct and control an organization with regard to risk' (Australian/New Zealand Standard AS/NZS ISO 31000:2018 Risk management — Guidelines).
Reasonably practicable is as defined in section 18 of the Work Health and Safety Act 2011 (NSW) as ' …that which is or was at a particular time, reasonably able to be done in relation to ensuring health and safety, taking into account and weighing up all relevant matters including:
the likelihood of the hazard or risk concerned occurring, and
the degree of harm that might result from the hazard or risk, and
what the person concerned knows or ought reasonably to know about the hazards and risks and ways of eliminating or minimising those risks, and
the availability and suitability of ways to eliminate those risks, and
after assessing the extent of the risks and the availability of ways of eliminating or minimising those risks, the costs associated with available ways of eliminating or minimising those risks, including whether the costs are grossly disproportionate to the risk’.
Structures means anything that is constructed, whether fixed or movable, temporary or permanent, and includes components of a structure and any part of a structure.
Visitor means any member of the public visiting or transiting the campus.
Worker is as defined in section 7 of the Work Health and Safety Act 2011 (NSW), and includes people carrying out work in any capacity for UTS, including UTS staff, contractors/subcontractors and their employees, employees of labour hire companies who have been assigned to work at UTS, outworkers, apprentices, trainees, work experience students at UTS, and volunteers (including members of the UTS Peer Network).
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Nikke Gladwin
Honora Jenkins
Jenny Briscoe-Hough
-
See below
How risks are rated
Each risk is rated after existing controls are in place (the residual rating) by combining the Consequence and the Likelihood using the matrix below. Planned treatments are actions that would reduce the rating or strengthen controls further.
| Consequence \ Likelihood | Rare | Unlikely | Possible | Likely |
|---|---|---|---|---|
| Minor | Low | Medium | Medium | Medium |
| Moderate | Low | Medium | High | High |
| Major | Medium | Medium | High | High |
| Critical | Medium | Medium | High | High |
Consequence levels
- Minor – first aid only; no lasting harm.
- Moderate – medical treatment or short-term harm to a child, or a breach of privacy or obligations.
- Major – serious injury or harm to a child, or a serious breach of obligations.
- Critical – death, permanent disability, or abuse of a child.
Likelihood levels
- Rare – may occur only in exceptional circumstances.
- Unlikely – could occur at some time, but not expected.
- Possible – might occur at some time.
- Likely – expected to occur in most circumstances.
People and workforce safety (3)
65Team Leader’s Working With Children Check lapses or is not renewedMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Expiry date not tracked; renewal overlooked
- Consequences
- Team Leader unable to lawfully work with children; program suspended; breach of funding and legal obligations.
- Existing controls
- Current Working With Children Check held by the Team Leader; expiry date recorded and diarised (Policy 2.2); status verified annually through the Office of the Children’s Guardian.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Yearly check and three month alert for WWC expiry
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Checked. Expiry is 6/12/2028
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
66Unsuitable adult engaged to work with children (if other adults are engaged in future)Medium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Screening, reference checks and induction not completed before an adult starts
- Consequences
- Child harmed by a person who should not have been engaged.
- Existing controls
- Waves Resilience is currently run by a sole trader and no other adults are engaged. Policy 2.1A and 2.2 require, before any adult is engaged: Working With Children Check, National Police Clearance, two telephone reference checks, signed Child Safe Code of Conduct, and induction within 30 days. The Team Leader’s plan is to review this register before engaging anyone.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Rare
- Planned treatments
- Review this register and complete all checks before any other adult is engaged to work with children. No adults are currently engaged.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Before any adult is engaged
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
67Assistants (under 18) given inappropriate responsibility or inadequate supportMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Assistant role (a pathway to leadership, not a formal job) not clearly bounded; Assistants left to supervise other children
- Consequences
- Assistant (a child) placed at risk, or other children supervised by someone who is not an adult; confusion about the Assistant’s role.
- Existing controls
- Assistants are young people under 18 and are protected by the Child Safety Policy as children (Policy 1.3). They do not need a Working With Children Check, take part under the direct supervision of the Team Leader, and do not supervise other children alone. Parents/guardians are welcome at any time. Assistants are briefed as all participants on what to do in the unlikely event that the Team Leader is incapacitated.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Assistants’ parents sign an invoice when they perform this role and receive the honorarium for the task.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
Reporting and response (5)
64Child ProtectionMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Poor recruitment, screening or supervision; non-compliance with, or poor implementation of, the Child Safety Policy
- Consequences
- A participant is abused or harmed while involved in a Waves Resilience session, or a child is not protected when action could have been taken in line with the NSW Child Safe Standards and the National Principles for Child Safe Organisations.
- Existing controls
- Child Safety Policy, Framework and Child Safe Code of Conduct reviewed annually by the Team Leader. Team Leader holds a current Working With Children Check (expiry diarised). Contact with children takes place in visible, open public places with a maximum of two participants; parents/guardians are welcome at any time. Phone/online contact only for practical matters and with the parent/guardian’s knowledge; transport only with parent/guardian permission. Allegations against the Team Leader are referred to the Supervisory Group. Complaints Handling Policy in place. Reporting to DCJ and NSW Police as required. See also child safety risks 65–79.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
68Disclosure or suspicion of harm not recognised, or not reportedMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Lack of knowledge of indicators or reporting thresholds; reluctance to act
- Consequences
- Child remains at risk; legal obligations not met.
- Existing controls
- Child Safety Policy Part 3 and Framework Sections 1–2 set out recognising and responding to disclosures. The Team Leader uses the NSW Mandatory Reporter Guide and the DCJ Child Protection Helpline (132 111) and reports to NSW Police where required (Crimes Act 1900 (NSW) s316A).
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Team Leader to refresh child protection and mandatory reporting knowledge each year when the Policy is reviewed (Policy 2.3), and record it.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Annually, at Policy review (next: October 2027)
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
69Allegation made against the Team Leader is not handled independentlyMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Sole trader is the only decision-maker
- Consequences
- Allegation not investigated independently; child or Team Leader unprotected.
- Existing controls
- Policy 3.5: all activities cease and the Supervisory Group (2–3 experienced workers, names published on the website) manages communications and procedures.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Confirm that Supervisory Group members are current, willing and contactable, and that the website list is up to date.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- 30 November 2026
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
70Records of disclosures, incidents or concerns lost, insecure or destroyed too earlyMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Records not stored securely; no retention date set
- Consequences
- Child or family unable to access records later; evidence lost; privacy breach.
- Existing controls
- Child Safety Incident Report completed within 24 hours and stored confidentially (Policy 4.1); records kept for at least 45 years (Policy 4.2.1, Royal Commission recommendation).
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Confirm secure storage location (paper and electronic, with back-up) that will last 45 years.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- 31 January 2027
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
71Concern or complaint from a child, parent or carer not raised or not handled wellMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Children and families do not know whom to tell or how
- Consequences
- Concerns not heard; harm continues; loss of trust.
- Existing controls
- Waves Resilience Complaints Handling Policy (how to complain, including anonymously; acknowledgement within 2 working days; outcome within 20 working days; child-focused handling; external contacts) and Child Safety Policy section 11; Team Leader contact details available to carers at all times during operating hours (Policy 2.1); external contacts listed (Office of the Children’s Guardian, DCJ Helpline, NSW Police, Kids Helpline).
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- Parents, carers and participants are directed to the Waves Resilience policies and procedures at https://www.coequal.com.au/waves-policies through the permission form and in verbal and written introductions.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
Program supervision and practice (32)
27Pre-existing Illness, Allergy or Medical ConditionHigh
- Residual risk rating
- High
- Risk category
- People
- Causes
- Inadequate screening of Participants prior to starting a lesson
- Consequences
- Participant having an episode in the water endangering themselves or others, requiring medical attention.
- Existing controls
- Establish fitness level and swimming competency of participants prior to lesson. Determine any significant health concerns through enrolment process, disclosure form and waiver. Ensure adequate first aid facilities are available to offer assistance for person experiencing seizure. Ask all participants at the beginning of session: Can everyone swim? Does anyone have a health condition which I need to be aware of?
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
28Surfer's Myelopathy - Neck and spinal injuryHigh
- Residual risk rating
- High
- Risk category
- People
- Causes
- Neck and spinal injury resulting from falling from board impacting water or striking head on sand bar
- Consequences
- Neck and spinal injury resulting from falling from board impacting water or striking head on sand bar
- Existing controls
- Inspect and select surf zone away from obvious sand bars likely to attract 'dumping' conditions. Advise participants of whereabouts of sand bars. Advise participants of duck-diving and board handling techniques (i.e. No nose diving). Advise participants of falling 'flat' technique rather than diving when falling from board.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
29Lost person - Participant lost or unaccounted forMedium
- Residual risk rating
- Medium
- Risk category
- People
- Causes
- Lost person during lesson, who is unaccounted for at the end of the lesson
- Consequences
- Danger to participant
- Existing controls
- Highly unlikely in Waves sessions because there are only two Participants. Commence search procedures immediately. Contact lifeguards and emergency services. Implement buddy system on rough days to ensure pairs monitor each other.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
30Intoxication - participant or staff participating in surf lesson while intoxicated.Medium
- Residual risk rating
- Medium
- Risk category
- People
- Causes
- Inadequate screening of Participants prior to starting a lesson
- Consequences
- Drowning resulted from intoxicated participant participating in surf school lesson
- Existing controls
- Observe participants to enforce no participants under the influence of drug or alcohol. Remind participants of no surfing while under the influence if suspicions of participants intoxicated.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
33Violence - Instructor assaulted by other surfer without provocationLow
- Residual risk rating
- Low
- Risk category
- People
- Causes
- May be unprovoked. Crowded surf zones, surf rage.
- Consequences
- Danger to staff and Participants resulting in injury requiring first aid attention.
- Existing controls
- Initiate emergency procedures to protect self and people in your care. Contact emergency services and lifeguards on duty.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
34FatigueMedium
- Residual risk rating
- Medium
- Risk category
- People
- Causes
- Participant suffers from fatigue during surf lesson because they are unfit, over exert themselves or excess time in the sun.
- Consequences
- Poor concentration. Loss of coordination.
- Existing controls
- Establish fitness level and swimming competency of participants prior to lesson. Determine any significant health concerns through enrolment process, disclosure form and waiver. Ensure adequate first aid facilities are available to offer assistance for person experiencing fatigue.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
35SeizureHigh
- Residual risk rating
- High
- Risk category
- People
- Causes
- Participant suffers a seizure during lesson while in water
- Consequences
- Participant could lose consciousness in the water or on the beach, which could lead to serious long term effects including brain damage.
- Existing controls
- Establish fitness level and swimming competency of participants prior to lesson. Determine any significant health concerns through enrolment process, disclosure form and waiver. Ensure adequate first aid facilities are available to offer assistance for person experiencing seizure.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
36Heart attackMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Pre-existing heart condition. Over exertion of participant while participating in surfing lessons.
- Consequences
- Participant suffers heart attack during lesson while in water
- Existing controls
- Ask all participants at the beginning of session: Can everyone swim? Does anyone have a health condition which I need to be aware of? Establish fitness level and swimming competency of participants prior to session. Determine any significant health concerns through enrolment process, disclosure form and waiver. Ensure adequate first aid facilities are available to offer assistance for a person experiencing a heart attack.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
37Lack of fitness or poor swimming abilityHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Fitness level and swimming ability not correctly assessed prior to lesson beginning.
- Consequences
- Drowning from participant being unable to swim after breaking leg rope
- Existing controls
- Ensure daily checking of all safety equipment. Do not enter water above waist deep for beginners * Ensure all participants have basic swimming ability through disclosure/enrolment form. Ensure rescue board in close proximity for non-patrolled beaches. Notify lifeguards for assistance if participant in trouble from lost leg rope. Provide rescue assistance if participant loses board from broken leg rope. Provide clear instruction to participant on use of leg rope. Encourage participants to hold board if falling rather than jumping clear. Provide instruction to participants on what to do if leg rope breaks
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
38Rash - caused by abrasion between the surfboard and the participant's skinLow
- Residual risk rating
- Low
- Risk category
- Health & Safety
- Causes
- Poor provision of equipment and preventative measures by staff and coaches; excessively abrasive surfboards; Failure to adhere to SOP policies
- Consequences
- Participants suffer increasingly sensitive rash to their body which over time makes it impossible to surf without excessive pain. Negative impact on lesson; poor feedback; substandard experience
- Existing controls
- Ensure all Participants wear wetsuits or rash-vests. Store and offer Vaseline jelly or tape to any participant already suffering from a board rash. Advise inappropriately attired participant's of the risk of a rash and the action they need to take to avoid it.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
39HarassmentHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Sexual harassment of staff or participant while in care of surf school
- Consequences
- Participant or staff put in an uncomfortable or unsafe position.
- Existing controls
- When instructing on board handling and riding techniques, avoid touching of participant. Brief children on child safety. Monitor participants for inappropriate comments or touching. Take all reports of inappropriate behaviour seriously. Refer to Child Safety Policy and Framework. Sessions are held in open public places with a maximum of two participants; parents/guardians are welcome at any time; the Child Safe Code of Conduct applies.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
40Tsunami warningMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Tsunami warning issued by lifeguards during lesson
- Consequences
- Immediate water evacuation. Lesson cancellation.
- Existing controls
- Brief participants on safety and emergency instructions including beach evacuation. Monitor evacuation alarms/siren from lifeguards. Monitor shore line for sudden receding of water levels. Do not commence session in the event of known earth tremors/earthquakes reported in region
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
41Depth of waterMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Participants paddle out further than they can stand. Leg rope coming off while surfing a wave.
- Consequences
- Drowning from getting into deep water after leg rope breaks
- Existing controls
- Advise participants of whereabouts of possible deep sections. Advise participants of evasive action to take if caught in deep water. Instruct beginners to stay in waist deep water only. Inspect surf conditions prior to each session. Inspect fitness levels of participants. Team Leader to maintain close supervision of all participants. Inspect all equipment prior to session beginning.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
42Shallow holesMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Shallow holes in water
- Consequences
- Sprained ankle in shallow hole while wading in water
- Existing controls
- Inspect surf conditions prior to each session. Instruct participants safe water entering procedures including walk only. Advise participants of possible hazard from holes and care required when stepping from board.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
43Salt/Sand SprayLow
- Residual risk rating
- Low
- Risk category
- Health & Safety
- Causes
- Strong winds or swell causing salt/sand spray
- Consequences
- Sore and bloodshot eyes after salt spray, sun and wind
- Existing controls
- Inspect weather conditions prior to each session. Ensure first aid kit is readily available for all lessons (carry first aid kit for non-patrolled beaches). Designate person responsible to maintain first aid kit supplies. Stock first aid kits with saline solutions for eye wash.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
44Shore BreakHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Dumping waves on the shore break.
- Consequences
- Neck injury sustained from being dumped in shore break during lesson
- Existing controls
- Inspect and select surf zone for appropriate surf entry conditions. Do not enter water if conditions are unsafe. Instruct participants on safe entry points for entering water, timing of entry between sets, correct water exit techniques. Instruct participants to not ride waves into shore line.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
45TidesMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Daily changes in tides
- Consequences
- High tides causing challenging conditions in the water
- Existing controls
- Time sessions around the low tide if possible, except for more experienced participants.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
46Sand barHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Shallow depth of water
- Consequences
- Neck and spinal injury resulting from falling from board and striking head on sand bar
- Existing controls
- Inspect and select surf zone away from obvious sand bars likely to attract 'dumping' conditions. Ensure rescue board is available if non-patrolled locations in case of spinal injuries. Advise participants of whereabouts of sand bars. Advise participants of duck-diving and board handling techniques. Advise participants of falling 'flat' technique rather than diving when falling from board.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
47Surf - Unsafe conditionsHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Sudden change in surf conditions
- Consequences
- Participants endangered, possible collisions in the water, getting stuck in rips, losing boards.
- Existing controls
- Inspect and select surf zone for safest conditions. Instruct safe board handling instructions. Advise participants of correct board handling methods including holding board vertical to wave, catch broken waves only. Advise of entering waist deep water only. Advise participants they may be held under in some unforeseen circumstances
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
48Surf - SwellHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Rising swell conditions creating dumping waves and stronger rip conditions
- Consequences
- Rising swell conditions creating dumping waves and stronger rip conditions resulting in possible spinal injuries
- Existing controls
- Inspect and select surf zone away from obvious rips. Conduct sessions around low tide when possible. Select lesson times appropriate to the skill level of the participant. Ensure rescue board is on beach if non-patrolled locations. Implement one- on-one time in the water when conditions call for it. Instruct safe board handling instructions
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
49Rips and UndertowHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Strong water flow back out to sea.
- Consequences
- Drowning as a result of being caught in a rip or undertow
- Existing controls
- Inspect and select surf zone away from obvious rips. Conduct lessons around low tide when possible. Select lesson times appropriate to the skill level of the participant. Ensure rescue board is on beach if non-patrolled locations. Implement one- on-one time in the water when conditions call for it.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
50Water temperatureMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Low water temps or sudden change in water temps
- Consequences
- Cold water temperature affecting some participants with hypothermia
- Existing controls
- Consider delaying or cancelling session if weather conditions deteriorate. Participants and staff to wear appropriate wetsuits
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
51Pedestrian struckHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Pedestrian crossing the road without looking. Driver not concentrating while driving.
- Consequences
- Waves participant struck by car while crossing road to beach for lesson
- Existing controls
- Identify high risk locations specific to Waves Resilience Training operations
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
52Motor Vehicle AccidentHigh
- Residual risk rating
- High
- Risk category
- Vehicular
- Causes
- Poor concentration while driving. Other drivers on the road could also be negligent.
- Consequences
- Motor vehicle accident resulting in serious injury while on way to surf school lesson site
- Existing controls
- Define appropriate surf locations accessible by on-road vehicles. Ensure competency of all drivers/Team Leader. Ensure mobile telephone carried at all times and that Team Leader do not operate in remote locations where no mobile phone coverage. Maintain all vehicles to high standards. Ensure all vehicles carry comprehensive motor vehicle insurance and all staff are covered under workers compensation insurance.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
53FogMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Low cloud and fog caused by storms
- Consequences
- Loss of visibility from sea fog causing cancellation of lesson/s
- Existing controls
- Inspect visibility prior to lesson. Cancel lesson/s in the event of poor visibility. Monitor visibility on foggy days to ensure public supervision is not compromised.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
54Smog/Dust/SmokeMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Excessive smog/dust/smoke in the air at time of lesson
- Consequences
- Excessive smog/dust/smoke conditions creating respiratory problems for participant during lesson
- Existing controls
- Check with all participants prior to lesson for pre- existing medical conditions. Cancel lessons where significant smog, dust or smoke may affect public health. Monitor weather forecasts and weather-related health alerts.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
60SunburnMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Excessive exposure to sun during the day.
- Consequences
- Sunburn from excessive exposure to face, arms and other unprotected body parts
- Existing controls
- Provide sunscreen for all Team Leader and participants. Participants to wear appropriate wet suits and other equipment. Provide shade shaded area (under tree) for talk sessions.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
61Sun - DehydrationMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Excessive exposure to sun during the day.
- Consequences
- Dehydration from hot days without adequate fluids
- Existing controls
- Encourage drinking of water before starting session on hot days. Provide drinking water to all participants and staff. Remind people of dehydration hazard and encourage to drink water. Allow the carrying of drinking water to surf zone if appropriate.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
62Spinal/Neck Injury - sustained from being dumped in the shore-break during a lesson, or from falling from board and striking head on sand barHigh
- Residual risk rating
- High
- Risk category
- Health & Safety
- Causes
- Poor lesson supervision by surf coaches; Unsuitable session location; Failure to identify a heightened risk during the Venue Analysis; Failure to adhere to SOP policies
- Consequences
- Participant can suffer pain and/or intense stinging sensation; loss of movement; loss of sensation. Paraplegia. Reputation impact; Liability claims.
- Existing controls
- Assess conditions during the Safety Review Talk. Continue to monitor conditions throughout lesson and remove Participants if risk becomes too high. Select surf zone away from obvious sand bars likely to attract 'dumping' conditions. Rescue board is kept on the beach. Instruct participants on safe entry points for entering water, correct take-off technique, action on wipeout, correct water exit techniques. Instruct participants to not ride waves into shore line.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
63Thermos Hot Water BurnMedium
- Residual risk rating
- Medium
- Risk category
- Health & Safety
- Causes
- Poor supervision and instruction about safe handling of thermos.
- Consequences
- Participant could suffer burn from near boiling water.
- Existing controls
- Best practice is Team Leader to pour from thermos unless instruction is given to participants about safe ways to handle thermos.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
72Team Leader alone with a child in a one-to-one situationMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Counselling, mentoring or coaching involving one child
- Consequences
- Child exposed to abuse or to a false allegation.
- Existing controls
- Contact takes place in visible places, usually the beach and open public places (Policy 10.2); sessions involve a maximum of two participants; parents/guardians welcome at any time, including in counselling/mentoring sessions (Policy 10.4); parents/carers are aware when a session is one-to-one; trip log kept (Policy 10.3); Code of Conduct prohibits being alone with a child unnecessarily.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
73Child transported alone in a vehicleMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Child driven alone by the Team Leader to or from a session, or to an appointment (including court or another service)
- Consequences
- Child alone with an adult in a private space.
- Existing controls
- Written parent/guardian permission at enrolment to travel in staff vehicles (Policy 2.6, 10.3); parents/carers aware when a session is one-to-one; trips outside usual activities discussed with the parent/carer beforehand and a record kept; trips and sessions go to public or service locations where other people are usually present; trip log of who was in the vehicle and which sessions or supports they attended; seatbelt or appropriate restraint; children and families told how to raise a concern (Complaints Handling Policy, Policy 11).
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
Physical and environmental safety (26)
1BarnaclesMedium
- Residual risk rating
- Medium
- Risk category
- Animals
- Causes
- Inadequate Venue Analysis
- Consequences
- Participants suffer immediate and sometimes severe pain due to laceration; negative impact on session; potential reputation impact.
- Existing controls
- Sufficient Venue Analysis identifying appropriate entry points for Participants skill level, advise Participants of risks of surfing near rocks which may be covered in barnacles.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
2Marine Bites & StingsMedium
- Residual risk rating
- Medium
- Risk category
- Animals
- Causes
- Inadequate Venue Analysis identifying stingers in the water.
- Consequences
- Participants suffer stings or bites to their body which can cause significant pain and in some cases an allergic reaction. Negative impact on session.
- Existing controls
- Monitor surf conditions for stingers during venue analysis. Ensure all Participants wear wetsuits. Ensure access to first aid treatment is readily available to treat stings.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
4Sea UrchinMedium
- Residual risk rating
- Medium
- Risk category
- Animals
- Causes
- Failure to adequately advise participants of appropriate entry into water from rocks. Failure to correctly identify participants skill level for entering the water at reef/rock breaks.
- Consequences
- Participants suffer immediate and sometimes severe pain due to sea urchin spines entering skin; negative impact on lesson; potential reputation impact.
- Existing controls
- Sufficient Venue Analysis identifying appropriate entry points for Participants skill level, advise Participants of risks of surfing near rocks which may be covered in urchins. Avoid walking across rock areas in bare feet (if possible). Reef surfing for advanced surfers only. Wear booties if rock walking is required to walk to or from surf location. Ensure first aid kit is available.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
9Shark attack - Participant gets attacked by shark during the lesson.Medium
- Residual risk rating
- Medium
- Risk category
- Animals
- Causes
- Not staying abreast of ocean alerts. Not doing location specific assessments and communicating these to participants.
- Consequences
- Minor injury through to death of participant due to severity of shark attack.
- Existing controls
- Instruct all participants on emergency water evacuation procedures prior to entering the water. Take immediate action in the event of shark attack: Calmly implement water evacuation procedures. Account for all participants. Call Ambulance. Carry out first aid procedures as necessary. Notify lifeguards. Do not enter water if there are reports of shark sighting. Watch for schools of fish or gathering birds which could indicate a possible school where sharks may be attracted.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
11Polluted water - Heavily polluted water causes health problems for staff and Participants causing diarrhoea and vomitingMedium
- Residual risk rating
- Medium
- Risk category
- Chemical
- Causes
- Severe storms causing excessive runoff into the ocean.
- Consequences
- Team Leader, Staff and Participants swallowing contaminated water which may cause illness including diarrhoea, vomiting and ear infections.
- Existing controls
- Inspect surf conditions for pollution levels (particularly after heavy rain). Apply relevant first aid measures if illness occurs. Report to health authorities if obvious link between health complaints and pollution.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
12Underwater kelp, reef or rock - Drowning resultingMedium
- Residual risk rating
- Medium
- Risk category
- Coastline
- Causes
- Leg rope getting caught under
- Consequences
- Drowning resulting from leg rope
- Existing controls
- Avoid surfing in reef, kelp or rock areas if unsafe. Trainers need to always be close to participants. Instruction given about removing leg ropes in safety briefings
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
13Reefs - Heavy lacerations to back sustained due to striking reef while in surf lessonMedium
- Residual risk rating
- Medium
- Risk category
- Coastline
- Causes
- Shallow water levels causing surfer to hit the reef on impact.
- Consequences
- Varying injury and lacerations due to reef cuts, which may cause infection and time out of the water.
- Existing controls
- It is unlikely we will be surfing near any reefs during Resilience Training. We will stay in sandy areas. In case there are experienced surfers who participate then...encourage the wearing of booties and wetsuits when surfing in reef areas. Avoid reef areas if unsafe. Reef surfing for intermediate and advanced surfers only (conditions permitting). Provide appropriate warning and care required if surfing near reef locations.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
14Rocks - Slip and fall onto rocksMedium
- Residual risk rating
- Medium
- Risk category
- Coastline
- Causes
- Team Leader and Participants may slip while walking across the rocks.
- Consequences
- Injury to Staff or participants requiring first aid attention. Damage to equipment.
- Existing controls
- Provide appropriate warning and care required if surfing or walking in reef locations. Encourage Team Leader and participants to wear booties if available. Inspect reef conditions before entering water. Check competency of surfers before session.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
15Slippery surfaces - Slip and fall on slippery surfacesMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Team Leader and Participants may slip while walking across slippery surfaces.
- Consequences
- Injury to instructor or participant requiring first aid attention. Damage to equipment.
- Existing controls
- Provide appropriate warning and care required if surfing or walking in reef locations. Encourage Team Leader and participants to wear booties if available. Inspect reef conditions before entering water. Check competency of surfers before session.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
16Car parks - Danger to staff and Participants while arriving and leaving Waves Sessions.High
- Residual risk rating
- High
- Risk category
- Environmental
- Causes
- Staff and Participants can be unseen by drivers arriving and leaving the Car Park area.
- Consequences
- Pedestrian impact injuring those involved.
- Existing controls
- Provide adequate warning to all Participants the need to be mindful of cars and pedestrians while arriving and leaving the Car Parks.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
17Floating objects - unknown objects/materials floating into the surf zoneMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Small - large piece of hazardous material floating into surf zone
- Consequences
- Injury sustained from striking log or other large piece of hazardous material floating into surf zone
- Existing controls
- Inspect surf conditions prior to each session. Inspect fitness levels of participants. Instructor to maintain close supervision of all participants Advise participants of whereabouts of possible deep sections. Advise participants of evasive action to take if caught in deep water.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
18Submerged obstacles - large unknown objects striking Participants/staffMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Large unknown objects striking Participants/staff
- Consequences
- Injury sustained from striking log or other large piece of hazardous material floating into surf zone
- Existing controls
- Inspect surf conditions prior to each session. Inspect fitness levels of participants. Instructor to maintain close supervision of all participants Advise participants of whereabouts of possible deep sections. Advise participants of evasive action to take if caught in deep water.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
19Surf Board - Manual handling - Manual handling injury from carrying surfboardMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Carrying too many boards at one time. Participants inappropriately carrying/dragging boards.
- Consequences
- Inappropriate carrying of boards causing injury to self and to equipment. Muscle injury and strain to staff / Participants requiring first aid treatment or ongoing therapy. Damage to equipment.
- Existing controls
- Limit number of surfboards carried by Team Leader in dispatching and collecting equipment. Demonstrate to Participants the most appropriate way to carry the surfboard based on their size. Provide appropriate first aid response in the event of injury. Review work practices and ensure workflow is best suited to minimising physical carrying of weight. Match physical capability of individuals with tasks requiring manual handling. Use light weight soft boards.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
20Surf Board - struck in face - Facial injury after being struck by board in rough seasHigh
- Residual risk rating
- High
- Risk category
- Environmental
- Causes
- Surfer bailing board in the water.
- Consequences
- Board impact to self or other surfer leading to facial injury requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Instruct safe board handling instructions. Consider modifying session time if weather conditions deteriorate. Provide appropriate first aid response in the event of injury. Use light weight soft boards only. Instructions about keeping boards towards the sand... not in front of you.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
21Surf Board - Run down by board - Running over the top of other surfers causing lacerationsHigh
- Residual risk rating
- High
- Risk category
- Environmental
- Causes
- Participant surfing over the top of another participant or beach goer
- Consequences
- Board impact to self or other surfer leading to injury requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Instruct safe board handling instructions. Consider modifying session time if weather conditions deteriorate. Provide appropriate first aid response in the event of injury. Use light weight soft boards only. Use rubber protected fins.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
22Collisions - Impact between 2 or more surfers/swimmers in the waterHigh
- Residual risk rating
- High
- Risk category
- Environmental
- Causes
- Participant surfing into other surfer or swimmers
- Consequences
- Board impact leading to injury requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Instruct safe board handling instructions. Advise Participants to be aware of other surfers / swimmers in the water. Consider modifying session time if weather conditions deteriorate. Provide appropriate first aid response in the event of injury. Use light weight soft boards only and runner protected fins.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
23Surf Board - Leg rope - Being struck in face by recoiling boardHigh
- Residual risk rating
- High
- Risk category
- Environmental
- Causes
- Leg rope too short for the board.
- Consequences
- Board impact leading to injury requiring first aid attention.
- Existing controls
- Attach longer leg ropes on larger boards. Regularly check all equipment for damage Instruct participants to check tension of leg ropes before surfacing and how to protect themselves against recoiling boards.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
24Jet ski - Struck and badly injured by jet ski who fails to see surf lesson in surf zoneMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Jet ski riding in surf zone. Inappropriate selection of surf zone
- Consequences
- Serious injury to surfers requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Consider modifying session time if watercraft appear in surf zone mid-session. Provide appropriate first aid response in the event of injury. Report unsafe jet ski activity to local authorities or lifeguards on patrolled beaches.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
25Other Water Crafts - Struck and badly injured by other water crafts who fail to see surf lesson in surf zoneMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Other beach users fail to see surf lesson in surf zone
- Consequences
- Serious injury to surfers requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Consider modifying session time if watercraft appear in surf zone mid-session. Provide appropriate first aid response in the event of injury. Report unsafe water craft activity to local authorities or lifeguards on patrolled beaches.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
26Power boats - Struck and badly injured by other power boats who fail to see surf lesson in surf zoneMedium
- Residual risk rating
- Medium
- Risk category
- Environmental
- Causes
- Other beach users fail to see surf lesson in surf zone
- Consequences
- Serious injury to surfers requiring first aid attention.
- Existing controls
- Inspect and select surf zone for safest conditions. Consider modifying session time if watercraft appear in surf zone mid-session. Provide appropriate first aid response in the event of injury. Report unsafe power boat activity to local authorities or lifeguards on patrolled beaches.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Rare
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
55Air temperatureMedium
- Residual risk rating
- Medium
- Risk category
- Conditions
- Causes
- Sudden drop in air temperature affecting all surfers in lesson
- Consequences
- Participants or staff become cold and no longer enjoy their time in the water
- Existing controls
- Consider delaying or cancelling session if weather conditions deteriorate. Participants and staff to wear appropriate wetsuits
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
56Strong Winds - offshore/onshoreMedium
- Residual risk rating
- Medium
- Risk category
- Conditions
- Causes
- Substantial wind storm occurs during lesson.
- Consequences
- Lesson delay or cancellation
- Existing controls
- Consider delaying or cancelling session if weather conditions deteriorate. Inspect surf conditions prior to each session. Consult weather and surf conditions forecast.
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
57Excessive wind - board carryingMedium
- Residual risk rating
- Medium
- Risk category
- Conditions
- Causes
- Substantial wind storm occurs during lesson.
- Consequences
- Substantial wind storm occurs during lesson and unable to return to safe location for one hour (i.e. Car, surf school) to wait for the storm to pass.
- Existing controls
- Consider delaying or cancelling session if weather conditions deteriorate. Participants to wear appropriate wetsuits
- Consequence (after controls)
- Minor
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
58Excessive wind - sandHigh
- Residual risk rating
- High
- Risk category
- Conditions
- Causes
- Strong winds during lesson
- Consequences
- Substantial wind storm occurs during lesson causing sand into eyes of participants.
- Existing controls
- Cancel lesson if too windy. Advise participants of hazards of wind in eyes. Encourage the wearing of sunglasses when walking to surf zone if appropriate.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Possible
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
59LightningMedium
- Residual risk rating
- Medium
- Risk category
- Conditions
- Causes
- Lightning storm occurs in the middle of lesson
- Consequences
- Lesson delay or cancellation
- Existing controls
- Cancelling session if weather conditions deteriorate and evacuate beach to indoor/undercover location. Consult weather and surf conditions forecast prior to lesson beginning.
- Consequence (after controls)
- Critical
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment required; existing controls reapplied at each session (venue and conditions check before every session).
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
74Children unsupervised or unaccounted for before and after sessions, or at changing and toilet facilities at public venuesMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Children arriving or leaving alone; shared public facilities
- Consequences
- Child exposed to harm from members of the public or others; child unaccounted for.
- Existing controls
- Sessions held in open public places with parents/guardians welcome; participants wear wetsuits or rash vests; only two participants per session so each child is always accounted for; arrival and departure details communicated with parents/guardians.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
Digital, privacy and information safety (3)
75Photos, video or audio of a child taken, shared or stored without consentMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Recording or posting without informed consent from child and parent/guardian
- Consequences
- Child identified or exposed; privacy breach.
- Existing controls
- Code of Conduct prohibits disclosing information or images of a child without consent (Attachment 1); Policy 2.7 requires informed consent of the child and parent/guardian. This is included in Consent form.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
76Inappropriate personal contact with a child by phone, online or social mediaMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Direct messaging of children; personal accounts used
- Consequences
- Grooming or inappropriate relationship.
- Existing controls
- Policy 2.6: contact only with the parent/guardian’s knowledge, restricted to practical matters and copied to parents/guardians; Code of Conduct prohibits personal contact unrelated to program activities.
- Consequence (after controls)
- Major
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
77Personal, health or incident information about a child lost, disclosed or kept too longMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Insecure storage; unclear access; information (including evaluation or app data) shared without consent
- Consequences
- Privacy breach; harm to child or family.
- Existing controls
- Confidentiality provisions (Policy 2.5 and 2.7); information shared only with people who need it or where required by law.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
Cultural safety, inclusion and governance (2)
78Aboriginal and Torres Strait Islander children do not feel culturally safeMedium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Program not culturally safe or informed by local community; cultural identity not respected
- Consequences
- Child feels unsafe or excluded; harm to identity and wellbeing; reputational damage.
- Existing controls
- Cultural safety is defined in the Child Safety Policy; Code of Conduct requires a culturally safe and inclusive environment; Policy 2.8 commits to seeking advice from local Aboriginal community members and organisations each year and to welcoming families.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027
79No independent oversight of child safety (sole decision-maker)Medium
- Residual risk rating
- Medium
- Risk category
- Child Safety
- Causes
- Business run by one person; funding compliance relies on one person
- Consequences
- Weaknesses in child safety go unnoticed; funding obligations not met.
- Existing controls
- Supervisory Group of 2–3 experienced workers; annual review of the Child Safety Policy, Framework and this register by the Team Leader; annual child safety statement of compliance to the funder.
- Consequence (after controls)
- Moderate
- Likelihood (after controls)
- Unlikely
- Planned treatments
- No further treatment planned.
- Risk owner
- Team Leader (Phillip Crawford)
- Treatment due date
- Ongoing
- Last reviewed
- 27 October 2026
- Next review
- 27 October 2027