Developing and implementing a child-focused complaint handling process
Putting children at the centre of protective decision-making.
16 October 2025
The content of this article was updated on 19 December 2025.
Children have the right to be heard, listened to and believed. Article 12 of the of the United Nations Convention of the Rights of the Child – which the National Quality Framework aligns with – states:
Children have the right to give their opinions freely on issues that affect them. Adults should listen and take children seriously.
Every person working in early childhood education and care (ECEC) has a legal obligation to act in the best interests of children. Children’s safety, welfare and wellbeing must remain paramount in every action and decision, embedded across all aspects of service operations and culture.
Centring children’s needs and safety is especially critical when developing complaint handling policies, processes and reporting systems.
Child-focused complaint handling – what does it mean?
A child-focused complaint handling process places children at the centre of every decision.
It is accessible, age-appropriate and culturally safe, prioritising and upholding children’s rights, voices, safety and wellbeing at every step.
Such processes foster a culture where:
- children (and families on their behalf) feel supported and empowered to raise concerns if they feel unsafe or uncomfortable, and confident that their concerns will be taken seriously and acted upon
- staff are equipped to listen to children’s voices and take action, recognising that children may express their concerns in different ways including through words, behaviour or play
- barriers that may prevent children from sharing concerns about their own or other’s safety are minimised.
Barriers to reporting
Children may be discouraged from raising concerns about their own or others’ safety if they:
- worry they won’t be believed or that adults won’t take action
- feel uncomfortable talking to adults
- don’t have a trusted adult they feel safe with
- feel scared or threatened by the person causing harm
- feel impacted by personal vulnerabilities and past experiences
- don't know who to talk to or understand what to do
- find the reporting process too confusing or adult-focused
- can’t access child friendly, culturally safe and inclusive systems.
Barriers are more likely to arise when a service prioritises organisational interests (for example, reputation management or risk avoidance) over the rights and needs of children, particularly where there is ineffective governance, poor leadership or a lack of a child safe culture.
Recognising these barriers helps services design complaint processes that are safe, inclusive, child focused and support the timely and effective resolution of any complaints, concerns or issues.
- How does your service create an environment where children feel safe, valued and empowered to speak up, specifically when they feel uncomfortable or unsafe?
- How do you support children to understand what inappropriate interactions look or feel like?
- What strategies do you use to teach children about protective behaviours?
- How are educators supported through training and supervision to build children’s confidence to speak up and help families feel safe to raise concerns?
- How do educators reflect on their own practice to ensure they are actively listening, validating and responding to children’s concerns in a timely and sensitive way?
Key legislative responsibilities
Approved providers, service leaders and all ECEC staff have a responsibility to make sure children feel safe, respected and supported to express their concerns in a way that makes sense to them.
Below are some of the key obligations under the National Quality Framework and Child Safe Standards relating to managing and responding to concerns and complaints about child abuse and harm.
Complaint handling policy and procedures
Under , approved providers are required to have a complaint handling policy and procedures in place at their service. The policy and procedures must document the service’s processes and systems for handling complaints in a child-focused way (regulation 168(2)(O)(i)) and be specific to the service’s unique context.
A service’s complaint handling policy must also include information on how complaints alleging a child is exhibiting harmful and/or sexualised behaviours will be managed.
Reporting incidents or allegations of child abuse to the NSW Early Learning Commission
Approved providers are required to notify the NSW Early Learning Commission of any incident or allegation of physical or sexual abuse to a child while they being educated or cared for by an ECEC service ().
This includes sexual offences or sexual misconduct (within the meaning of the ) committed by a person who is employed by, volunteers at or is a student who participates in a service ().
These are considered serious incidents and must be notified to the NSW Early Learning Commission within 24 hours of the incident or allegation being made or within 24 hours of becoming aware of the incident or allegation (as required under and of the National Law).
The approved provider must also notify the child’s family of the allegation and keep evidence that families have been informed.
Displaying complaint contact information
Under and , prescribed information must be displayed in an ECEC service and be clearly visible from the main entrance of the premises. This includes the service's contact details for complaints and the contact details of the regulatory authority.
All NSW ECEC services, including outside school hours care services, are required to implement the Child Safe Standards under the . The standards outline clear expectations and actions organisations must take to create and maintain environments and cultures where children feel safe, valued and heard.
Under Standard 6, child-related organisations must:
- establish a child-focused complaint handling system that is understood by children, staff, volunteers and families
- maintain clear and effective complaint handling policy and procedures, including defined roles and responsibilities, and steps for responding to different types of complaints and concerns
- ensure all complaints are taken seriously and responded to in a timely and thorough manner, while meeting all relevant legal obligations around reporting, privacy and employment.
- How does your service’s complaints handling policy actively support a child-focused reporting process and help children feel safe, heard and empowered to raise concerns?
- Do staff fully understand their responsibilities under the policy, including supporting children and meeting mandatory reporting requirements in a timely and appropriate way?
- How does your service ensure complaint handling and reporting policies and procedures prioritise children’s safety and best interests at all times?
- What processes are in place to keep reporting and complaint policies and procedures up to date with legislative requirement and regulatory guidance?
- How do you support staff to understand and implement complaint handling and reporting policies and procedures effectively, including their legal obligations to report complaints and disclosures of child abuse to all relevant authorities?
- How does your service monitor compliance with complaint handling policies and procedures, and ensure all complaints are responded to promptly, thoroughly and in line with legal obligations?
Developing and implementing a child-focused complaint handling process
Creating a safe environment where children feel confident to speak up is essential to child safety. By developing and embedding child-focused, transparent and responsive complaint and reporting systems into daily practice, educators and service leaders can create a culture where advocacy, protection and respect for children is actively promoted, modelled and upheld by everyone in the service.
- Regularly invite children's input. Consistently use age-appropriate opportunities such as group discussions, daily check-ins or story time prompts to encourage children to share their thoughts and feelings.
- Reinforce that children’s voices matter. Remind children that they will be believed and supported if they express concerns or disclose discomfort or harm. This helps build trust and strengthens their sense of belonging.
- Celebrate speaking up. Acknowledge and affirm children's efforts to express themselves, reinforcing that it is always okay to ask for help, raise an issue, voice their needs, or share positive or negative feedback.
- Involve children in system design. Engage children in co-designing complaint processes, forms or guides to ensure accessibility and understanding.
- Engage families. Educate families about complaint procedures and their role in supporting children to raise concerns safely.
- Offer children age-appropriate ways to raise concerns. These can include verbal, written, anonymous, visual or digital methods to meet different communication needs, preferences and comfort levels. Prominently display resources, such as the , to support children to recognise if something or someone has made them feel uncomfortable or worried and who they can go to for help.
- Provide ongoing professional learning. Ensure all staff, volunteers and students understand the service's complaint and reporting procedures and are trained in responding to disclosures of harm or abuse. Training should cover:
- recognising direct and indirect disclosures, including verbal, behavioural and non-verbal cues
- applying trauma-informed practices to respond sensitively
- understanding legal and organisational responsibilities under mandatory reporting and child protection laws
- completing the national child safety training, which will be mandatory for all ECEC staff, volunteers and students from early 2026.
- Create a supportive team culture. Encourage open communication and provide regular opportunities to discuss real scenarios, share learnings, and reflect on and strengthen practices related to child safety and complaint handling.
- Embed a child safe culture. Make child safety a core part of everyday practice, decision-making and relationships. Ensure policies, procedures and training are actively applied in daily operations, empowering staff to act confidently and responsibly and reinforcing a culture where children feel safe, valued and heard.
- Use daily check-ins. Establish routines such as morning circles, emotion charts or guided discussions where children are encouraged to talk about how they feel.
- Teach protective behaviours. Integrate learning experiences that build children's understanding of personal safety, body autonomy, respectful relationships and recognising unsafe situations.
- Model safe, respectful conduct. Consistently demonstrate positive, respectful interactions, setting a clear example of what safe adult behaviour looks like.
- Ensure your policies and procedures comply with recent child safety reforms. Legislative changes recently came into effect in NSW, strengthening protections for every child in ECEC services. This includes updates to regulation 168(2)(h), which requires services to specifically address how they will provide a child safe environment in their documented policies and procedures.
- Develop clear, child safe policies and procedures. These should include steps that empower everyone – especially children – to speak up if something is wrong, along with safe and supportive processes for managing serious concerns, including problematic and/or harmful sexual behaviours. For practical guidance on developing compliant-handling systems that prioritise child safety and participation, refer to the National Office for Child Safety’s .
- Review regularly. Treat policies as living documents, reviewing them routinely and immediately after any critical incident to ensure they align with current best practice, legal requirements, regulatory guidance and service risk assessments.
- Make policies visible and accessible to all. Share your complaints policy in plain language with families, staff and children (using child-friendly formats). Ensure everyone knows how to access it and who they can speak to if they have a concern.
- How does your service ensure policies and procedures are child safe, accessible and aligned with legislative requirements and best practice?
- What processes and systems have you implemented at your service to make it easier for children, families and others to raise concerns or complaints about children’s safety? Can people share their concerns in different ways, like talking to someone, writing it down or doing it anonymously?
- How do you support children to understand processes for raising concerns about their safety?
- How do you ensure all children, including those from culturally and/or linguistically diverse backgrounds and children with disability and/or additional needs, can express when something is wrong?
- How are families supported and encouraged to raise or report concerns within the service?
- How do educators observe and reflect on children’s behaviour and emotional responses to staff? What might changes in these behaviours indicate about a child's sense of safety or comfort?
Responding to disclosures or allegations of abuse
When concerns are not addressed promptly, appropriately and effectively, there is a real risk that harm, including abuse or neglect, may go unnoticed or unchallenged. If children’s voices are dismissed or overlooked, they may feel powerless and unsafe, increasing their vulnerability.
Approved providers must ensure their services have clear, child-focused processes for responding to disclosures and allegations of abuse. This includes making sure all educators, staff and volunteers understand both their legislative responsibilities and their role in supporting children sensitively and appropriately.
- Listen carefully and calmly. Allow the child to share their concerns in their own way, without interruption or judgement.
- Validate the child. Reassure them that they did the right thing by speaking up and that you take their concern seriously.
- Respond with care. Acknowledge what has been shared and focus on ensuring the child feels safe.
- Report all concerns in accordance with your service’s policies and mandatory reporting obligations. This involves notifying the appropriate service leaders or management (such as the nominated supervisor), documenting the disclosure or concern accurately and promptly, and ensuring reports are made to the relevant authorities. These may include the NSW Department of Communities and Justice (DCJ) via the , NSW Early Learning Commission, the NSW Office of the Children’s Guardian (OCG) and NSW Police.
The specific circumstances of the concern or allegation will determine which agencies must be notified. The primary purpose of making a report is to ensure the child or children at risk are protected, safe and supported.
The OCG's includes helpful guidance on responding to disclosures or allegations made by children.
- How can your service strengthen staff confidence and competence in listening and responding effectively and in a trauma-informed way when someone – including children, families and colleagues – speaks up about harm to children?
- How well are staff prepared to recognise and respond to children’s verbal and non-verbal cues that may indicate they have something important or concerning to share?
- What systems and supports are in place to ensure all staff respond supportively, appropriately and consistently to disclosures in line with mandatory reporting requirements?
- How does your service reinforce understanding of legislative responsibilities and the role of each staff member in protecting children?
- How does your service monitor and reflect on staff responses to disclosures to ensure they are child-focused, safe and aligned with policy and legal requirements?
Resources
- NQF Child Safe Culture Guide, including
- Implementing the Child Safe Standards resources developed by the OCG for the NSW ECEC sector, including:
- Modules 3 and 4, focusing on child safe reporting for staff and leaders
- Episode 3 – Reporting in an ECEC context of the
- NSW Early Learning Commission
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