Presbyterian Ladies’ College (PLC) strives for excellent standards in all areas of its operations and is committed to child safety and wellbeing. To achieve this, all staff are expected to comply with this Code of Conduct including in their physical and online interactions with children and young people under the age of 18 years.
For the purpose of this document only, ‘staff’ are defined as:
- All paid and unpaid employees (including boarding staff)
- Governing body members
- Practicum students
- Volunteers; and
Compliance with all College Policies, Procedures, and Requirements
Staff are required to observe, support and comply with all College policies and procedures during the course of their employment/engagement with PLC. It is the responsibility of all staff to understand College policies and procedures and to remain abreast of changes to such documents. The College will provide notification of changes and updates as and when they occur.
Staff are expected to take an active part in the general life of the College by supporting policies, procedures, aims and objectives in order to facilitate the day‑to‑day operation and promote a high quality of education and service delivery.
Child Safety and Wellbeing
All PLC staff have a common law ‘duty of care’ and statutory obligations regarding the safety and wellbeing of children. The use of any form of child abuse, corporal punishment or other degrading punishment is explicitly forbidden.
Four forms of child abuse are covered by Western Australian law:
- Physical abuse occurs when a child is severely and/or persistently hurt or injured by an adult or a child’s caregiver
- Sexual abuse, in relation to a child, includes sexual behaviour in circumstances where:
(a) the child is the subject of bribery, coercion, a threat, exploitation or violence
(b) the child has less power than another person involved in the behaviour; or
(c) there is a significant disparity in the developmental function or maturity of the child and another person involved in the behaviour.
- Emotional abuse including:
(a) psychological abuse; and
(b) being exposed to an act of family and domestic violence.
- Neglect including failure by a child’s parents to provide, arrange or allow the provision of:
(a) adequate care for the child; or
(b) effective medical, therapeutic or remedial treatment for the child.
Grooming is also forbidden. Grooming is considered a form of sexual abuse and is defined as: the use of a variety of manipulative and controlling techniques with a vulnerable subject in order to establish trust or normalise sexually harmful behaviour with the overall aim of facilitating exploitation and/or prohibiting exposure.
All Staff are required to report any of the above forms of child abuse to the Principal or one of the College Child Protection Officers.
PLC will at all times respond appropriately to reportable incidents and allegations:
- In the best interests of students, children and young people
- In accordance with the law; and
- In accordance with College policies and procedures.
Staff and Student Professional Boundaries
Staff are expected to observe professional boundaries including emotional, relationship, power, communication and physical boundaries. Refer to the Child Protection Policy for more information on staff expectations and on reporting abuse.
The following statements are not an exhaustive list, rather they provide Staff with examples of inappropriate interactions with students.
Staff must 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 they are working with for a purpose unrelated to PLC’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 the staff member is required to do so by law or in accordance with PLC’s policy and procedures on reporting
- Use inappropriate language in the presence of any child, or show or provide a child 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
- Engage in any form of inappropriate behaviour towards students or expose students to such behaviour
- Use prejudice, oppressive behaviour or inappropriate language with students
- Express personal views on cultures, race or sexuality in the presence of students or discriminate against any student based on culture, race, ethnicity or disability
- Engage in open discussions of an adult nature in the presence of students
- Engage in any form of sexual conduct with a student including making sexually suggestive comments and sharing sexually suggestive material
- Engage in inappropriate or unnecessary physical conduct or behaviours including doing things of a personal nature that a student can do for themselves, such as toileting or changing clothes; or
- Engage in contact with students through social media or technology that is not of a work-related matter.
The two following questions may be useful in determining if your conduct should be altered in any way:
- Would I modify my behaviour if a colleague was present?
- How would I feel about explaining my actions at a staff meeting?
Boundaries are not always clear. There are “grey areas”. Actions often have the potential to be perceived by others in unintended ways. Staff working with children have the power. It is ultimately the staff member’s responsibility not to misuse it. If in doubt, staff members must always err on the side of caution and seek advice from their line leader.
- Act in accordance with PLC’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 at PLC
- Demonstrate appropriate personal and professional boundaries
- Consider and respect the diverse backgrounds and needs of all children at PLC
- 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 PLC’s policies, discussions, learning and reviews about child safety and wellbeing
- Identify and mitigate risks to children’s safety and wellbeing as required by PLC’s risk assessment and management process
- Respond to any concerns or complaints of child harm or abuse promptly and in line with PLC’s policy and procedure for receiving and responding to complaints
- Report all suspected or disclosed child harm or abuse as required by law and in accordance with PLC’s policy and procedures on internal and external reporting
- Comply with PLC’s protocols on communicating with all children at PLC; and
- Comply with PLC’s policies and procedures on record keeping and information sharing.
Mandatory Reporting Obligations
Commencing from January 2009, teachers and boarding supervisors are required by law to make a mandatory report of child sexual abuse when a belief, based on reasonable grounds, is formed that sexual abuse is occurring or has occurred. This applies to staff working in a paid or unpaid capacity as a teacher, school nurse and/or boarding staff.
Staff who are not teachers, school nurses or boarding supervisors must report all forms of abuse to the school Principal or, if the Principal is named in the allegation, to the Chair of Council. Sexual abuse that occurred before 1 January 2009 is not considered a mandatory report but must be reported to the Principal.
In the case where a former student (still under the age of 18), or the parent or guardian of a former student, makes an allegation about child sexual abuse at the College occurring before 2009, the Department of Communities – Child Protection Service is to be informed immediately. An allegation involving a former student who is now aged 18 or over is reportable to the police. In either case, the Principal must be informed and submit a critical incident report to the Director General (Department of Education) and where required notify the Teacher Registration Board of Western Australia.
Professional Conduct and Expectations
Personal and professional behaviour must conform to the standards that could reasonably be expected of such persons employed by or associated with PLC.
- Staff are required to follow any lawful and reasonable direction made by College or its representatives
- Staff are expected to report any breach of the Code of Conduct they witness to thePrincipal or a member of the Senior Leadership Team as soon as reasonably practicable; and
- Contractors must be aware of and comply with the Contractor Acceptable Standards of Behaviour at PLC.
Interactions with Students and their Families
In accordance with the College’s Mission, Vision and Values, staff will:
- Provide a supportive, stimulating and effective environment that empowers and encourages students to reach their potential
- Treat students with respect, impartiality, courtesy and sensitivity and, wherever possible, involve them in decisions that affect them
- Provide accurate, timely and useful information to students in relation to their course of study, co-curricular activities, policies and processes
- Provide an environment free from discrimination and harassment in which students, staff and parents feel safe and comfortable
- Provide a clear statement of acceptable academic requirements and behaviours by students
- Be committed to the ethical values of honesty, trust, fairness, respect and responsibility in their interactions with students
- Support the contribution of students and their families to the life of the College
- Remain abreast of current knowledge and trends in education and specific subjects through participation in relevant professional development activities and membership of professional organisations; and
- The College recognises psychologists and nursing staff are subject to additional professional codes which may override parts of this Code.
Respect and Support
Staff must treat each other, students, and other individuals in the PLC community in a fair, respectful and equitable manner.
Examples of behaviour that are unacceptable include but are not limited to:
- Communication in offensive or aggressive tones
- Rude or insulting behaviour
- Discriminatory or sarcastic comments
- Making decisions based on favouritism; or
- Misuse of power through positions held to disadvantage or inhibit other staff members in fulfilling their duties.
Staff must ensure they contribute positively to an environment free of discrimination and harassment. This requires the implementation of fair and transparent practices of decision making, not influenced by irrelevant and unlawful attributes, as prescribed by anti-discrimination, anti-harassment and anti-bullying legislation.
Conflicts of Interest and Outside Activities
Staff should avoid situations where personal interest conflicts with the best interests of the College. This may involve outside employment or a business that a Staff member, family members or friends engage in that involves PLC, a student or another Staff member. It may involve a competitor of PLC or one of its suppliers.
Employment or professional activities, other than those undertaken as part of a Staff member’s role at PLC, must not negatively impact their ability to perform their College duties or undermine, compromise or create a conflict of interest with obligations, duties and values of College. Outside employment must be discussed with and approved by the Principal on every occasion as per the Exclusivity of Employment Policy.
Corrupt, Improper and Criminal Conduct
Staff must discharge their duties with honesty and integrity and refrain from any corrupt, improper or criminal conduct. Staff must report known and suspected instances of corrupt, improper or criminal conduct to their line leader, to a member of the Senior Leadership Team or through other appropriate reporting mechanisms.
Staff must advise the Principal if they are charged with a criminal offence.
Staff must use all PLC resources, both physical and online, in line with appropriate College policies and avoid any waste of resources. They must safeguard, properly use, protect and care for PLC resources, both physical and online, at all times.
The Principal, or their delegate, is the spokesperson for the College. Unless authorised specifically to do so, Staff must not make public comment on behalf of PLC or in a context where a comment could be interpreted as a statement on behalf of PLC.
All documents must be prepared and presented in a professional format, in accordance with the PLC Style Guide, and accurate spelling, grammar and punctuation must be maintained.
The PLC logo and letterhead must not be used for any non-school related documents and must not be used for written references without the Principal’s permission.
Public communications must be approved by the Principal.
Social Media and Technology
Social media includes any form of computer-based technology used for communication including websites, social networking, online communities, electronic messaging services including but not limited to emails, group or individual chat services and content sharing sites.
Whether using social media for work or in a private capacity, staff must not do or say anything that may adversely affect their standing as an employee of PLC. Use of social media and technology must not negatively impact the reputation of other staff or bring PLC into disrepute.
Staff must only ever engage with students through technology or social media for work-related purposes. Refer to the Child Protection section of this code for more information.
Privacy and Security
Staff must not make improper use of information gained by being a staff member. They must ensure that personal information, including data relating to other staff, students or members of the PLC community, is collected, held, used and disclosed in accordance with the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and PLC policies and procedures, including records management practices.
Staff are required to change their password on a regular basis and as requested by Management. Passwords must be kept confidential and never shared.
Staff are required to retain the confidentiality of all PLC information and take appropriate steps to prevent unauthorised disclosure. These obligations apply equally to other people’s confidential information (be they students, other staff, suppliers or family members) that is provided as a result of their employment.
Engagement with Partners and Communities
In interacting with any external party, staff will do so in the knowledge that they are a representative of PLC and their personal and professional behaviour will conform to the standards that could be reasonably expected of employees of College in such situations. Staff conduct will at all times demonstrate regard to the College’s interests.
Communication in the workplace, whether verbal or written must conform to acceptable standards of behaviour at all times. It must not harm or damage the College or an individual’s reputation or standing with staff, students or the PLC Community.
Examples of unacceptable behaviour are statements, either written or verbal, that deride, insult, denigrate or are discriminatory in any form.
Staff acknowledge their responsibilities and obligations under occupational safety and health (OSH) legislation and agree to take reasonable care to ensure their own safety and health at work and to avoid adversely affecting the safety or health of others through any act or omission at work. Staff agree to take practicable precautions to prevent, report and manage any hazards, risks and injuries to ensure a safe working environment.
Staff are required to:
- Uphold OSH responsibilities in line with their position requirements
- Perform all duties in accordance with relevant OSH laws, College policies and procedures and instruction given by PLC for the safety or health of others
- Consult with stakeholders including staff, students and contractors as applicable on any OSH matter
- Support colleagues in return to work endeavours
- Report all hazards, risks, injuries or harm to health which arises in the course of or in connection with employment/engagement at PLC and take reasonably practical steps to protect themselves and others
- Ensure that they do not adversely affect their work performance or cause any risk to health and safety through the consumption of alcohol or use of other drugs; and
- Cooperate with PLC in adhering to safety and health obligations imposed by OSH legislation.
Copyright and Intellectual property
The materials/programmes developed that relate to employment with PLC, whether created on campus, at home, or another venue, are the intellectual property of the College. Staff cannot give away or assign the College’s intellectual property without the written approval of the Principal. Staff must ensure the intellectual property rights of others are not infringed.
Breach of Code of Conduct
If staff think this Code of Conduct has been breached by another person at PLC, they must:
- Act to prioritise the best interests of children
- Take actions promptly to ensure that children are safe
- Promptly report any concerns or objectively observable behaviour, other than those subject to mandatory reporting obligations, to the Principal, one of the designated Child Safety Officers or the PLC Chair of Council
- Follow the College Complaints policy and procedures or the Internal Grievance Policy and Procedures (accessible through Complispace) as appropriate; and
- Comply with legislative requirements on reporting, if relevant, and with the College policies and procedures on internal and external reporting.
Any person making a report in good faith will be protected from victimisation or other adverse consequences.
Consequences relating to the Code of Conduct will vary depending on the nature and scale of the breach. Please refer to the Performance Counselling, Discipline and Termination Policy for more information. Staff are required to report all objectively observable breaches of this Code of Conduct to the Principal or, where the breach observed was committed by the Principal, to the Chair of Council.
Approved by Council: Monday 23 November 2020
To be reviewed by: Thursday 31 December 2021