Table of Contents
| First created | 20 November 2014 |
| Last reviewed | 23 June 2020 |
| Review cycle | Two years |
| Approver | Senior Leadership Team |
| Owner | Projects Manager |
| Stakeholders | Board, staff |
| Child Safety | National Principles 1-4, 6, 9-10 |
Overview #
- We are committed to the fair resolution of complaints and grievances and to developing a culture based on mutual trust and respect, with procedures aimed at resolving issues in a manner that is honouring to our Lord Jesus Christ and His Word. In addition to our normal pastoral care provisions which apply for all students, international students must be given specific complaints and grievance resolution procedures. This may include a complaint or grievance that may arise as a result of action taken on disciplinary matters. This policy provides a process for international students enrolled at Rehoboth to raise a concern, complaint, or grievance.
- International students may from time to time have a complaint about a decision, behaviour, act, or omission that they feel is unacceptable. While most issues can be resolved through direct discussion with the parties involved, there may be instances in which this is not possible.
- All formal complaints and grievance processes within the College will follow a three-level framework which models the Biblical process outlined in Matthew 18.
- This policy is for international students and their families and will be used for all complaints made by:
- an international student against another staff member;
- an international student against College leadership;
- an international student about the College as a whole, or a specific department within the College; or
- an international student against the Board.
- This policy will not be relied upon in respect of:
- Child protection allegations where separate policy applies; and
- Student discipline where separate policy applies;
- Sexual harassment where separate policy applies.
Definitions #
- Complaint means an expression of dissatisfaction made to us about our services, decisions, actions, or conduct of our staff, or about the complaint management process itself. A complaint should contain sufficient detail to enable it to be addressed and recorded.
- Complainant means anyone who makes a complaint. Complaints may be made anonymously.
- Complaints and Breaches Register means the official record we keep of any complaints.
- CRICOS means the Commonwealth Register of Institutions and Courses for Overseas Students.
- Grievance generally pertains to unfair treatment or misunderstanding regarding matters pertaining to terms and conditions of employment or discrimination and harassment.
- International student means a student enrolled at Rehoboth under CRICOS provisions. This definition also extends to the student’s family.
- PRISMS means the Provider Registration and International Student Management System.
- Resolution means an outcome of a complaint that is satisfactory to both parties.
- Staff or staff member means an individual who is employed at Rehoboth Christian College.
- The role of the Director as referenced in the Guide to the Registration Standards and Other Requirements for Non-Government Schools (January 2020) as:
‘The Director General of the Department of Education is responsible for ensuring that the school observes the registration standards, including the standard about its complaints handling system. Any student, parent or community member is entitled to contact the Director General with concerns about how the school has dealt with a complaint. Information is available on the Department of Education website. While the Director General may consider whether the school has breached the registration standards, she does not have power to intervene in a complaint or override the school’s decision’.
Underlying Principles #
To ensure that complaints and grievances are addressed appropriately, we are committed to the following principles:
- Complaints and grievances will be investigated in a fair and impartial manner.
- Resolution at the local level is preferred, wherever it is appropriate to do so.
- A person facing a complaint or grievance is entitled to know detailed information about the substance of the complaint or grievance and to have the opportunity to respond.
- Procedural fairness is afforded to all parties, which is defined as:
- a hearing appropriate to the circumstances;
- lack of bias;
- evidence to support a decision; and
- inquiry into matters in dispute.
- Confidentiality will be observed.
- The complaints management process will be conducted in a manner that is respectful of all parties.
- Complaints and grievances are monitored, and their management evaluated. This is done in order to reduce the occurrence of systemic and recurring problems.
- In all matters, the safety and wellbeing of students is our first priority.
- Persons making a complaint or grievance will not be victimised.
- It is expected that complaints and grievances are made in good faith and are not frivolous, vexatious, or malicious.
- Complaints and grievances will be addressed promptly, and complainants will be advised if the matter cannot be finalised within one month.
- All persons in the Rehoboth community (including students, parents, administrators, teachers, and support staff) have a right to be treated with respect and courtesy.
- In some circumstances, complaints and grievances may be referred to an external authority such as the Department for Child Protection and Family Support, the Department of Communities, or the Western Australian Police Service for advice or immediate action. All referrals of this nature are to be done through the Principal of the relevant School or the CEO. The CEO is to be informed of all referrals made to external authorities.
Confidentiality #
- As far as is practicable, we will ensure the privacy, anonymity, and confidentiality of the complainant(s) and others involved in accordance with our Privacy Policy. Those involved in the process may waive their right to privacy and confidentiality if they choose to involve someone else in the process.
- Confidentiality and privacy are subject to reporting obligations. Where this is necessary, the required information will be provided to the reporting body. Information may also be disclosed where there is a legal requirement or grounds to do so.
- Anonymous complaints are accepted in accordance with the Australian Privacy Principles and the National Principals for Child Safe Organisations. These are assessed, investigated, and resolved as completely as possible using the information provided.
- In many cases, there are practical limitations as to how we can provide support to anonymous Complainants, ask for clarification, further information, or notify Complainants of any resolution. The College representative responsible for investigating the anonymous complaint will determine the extent to which the complaint will be investigated.
General Procedures #
- Where appropriate, complainants will be encouraged to communicate their complaint or grievance in a manner that will make the terms or basis of the complaint or grievance as clear as possible.
- Those involved with a complaint or grievance will have the opportunity to present their point of view.
- Complaints and grievances will be investigated according to the stages outlined below.
- All complaints and grievances will be treated seriously and investigated.
- A record of all complaints and grievances will be maintained and a report provided to the Senior Leadership Team on the number and nature of any complaints and grievances received since the previous report excluding identifying details. The record should contain the following:
- date of complaint;
- name of complainant and relationship to the College;
- subject matter of the complaint, including the name of any person complained about and his or her relationship to the College;
- name of the complaint investigator and position at the College;
- date the investigation was completed;
- whether the complaint was upheld;
- resolution agreed with or offered to the complainant;
- date of referral for review (e.g. by the Board);
- complaint reviewer and relationship to the College;
- date reviewed finalised;
- review resolution agreed with or offered to the complainant; and
- location of confidential file;
- Confidential files on all complaints and grievances should be maintained and kept together and cross-referenced with other files as necessary. The files should contain simple but clear notes of all conversations about source of dissatisfaction. This applies to friendly chats and to telephone conversations, as misunderstandings can easily arise. There should be a clear statement of what is concerning the Complainant or Grievance.
- All complainants are requested to follow the stages outlined below.
- Staff are asked not to write to the Board of the Association without first having tried to resolve the matter either informally or formally as outlined in the stages below.
Provisions for International Students #
- Throughout the processing and resolution of a complaint or grievance, international students are entitled to have their own appointed supporter.
- Grievances are to be resolved informally by supported discussion whenever possible. Should informal discussion fail to reach a resolution, the formal policy outlined here will apply.
- Upon receipt of a formal complaint or grievance we will begin an assessment within ten days of receiving the notification from the student or his or her nominee. This process is provided at no cost to the family, who will be provided with a written outcome and reasons for any decisions. Our Records Management Policy will operate over all written material.
- An international student may not have his or her enrolment cancelled while these proceedings are ongoing, and neither will any record be raised in the PRISMS system until the complaint or grievance is resolved. Should our internal process fail to achieve resolution of a matter, the student is entitled to access external conciliation. This will be facilitated within ten days after completion of the internal process.
- All formal grievance processes within Rehoboth Christian College follow a three-level framework which models the Biblical process outlined in Matthew 18:
- Stage 1: The first stage is a face to face meeting where the two parties meet at the request of the grieved party who discloses their grievance. It is hoped that within a gracious climate and with ‘active listening’ that the issue is resolved mutually.
- Stage 2: The second stage involves the appointment of a mediator to assist the parties in reaching mutual resolution.
- Stage 3: The third stage involves invoking an Independent Complaints Panel that will hear the matter and make a binding decision on all parties, which concludes the matter within the College’s jurisdiction.
Complaints Process #
Step 1. Raise the Matter with the Person Concerned
Where an International Student feels aggrieved by any perceived injustice or wrong it is their responsibility to raise the matter directly with the person concerned. An exception is a case of perceived harassment for which a separate policy exists for all students (See Discrimination and Harassment Policy). The aggrieved student may take one other person (for example parent, guardian, friend or student) with them to the meeting for support.
Step 2. Interview with the Principal
If a face to face meeting fails to produce a mutual resolution the student seeks an interview with the Principal to report the matter. The Principal may interview any person who attended the “face to face” step. The Principal will advise the Deputy Principal and the International Student Liaison Officer and/or the school counsellor/psychologist of the complaint and a mediator will be appointed with a view to facilitate a mutual resolution.
Step 3. Interview with the CEO
Should the Principal and the Student Coordinator fail to resolve the issue, the matter shall be referred to the CEO, who will attempt to resolve the issue, having considered all the information provided by the parties above.
Step 4. Interview with a Panel Established for this Purpose
If mediation fails to produce a mutual resolution, the CEO will convene a panel of 3-5 people to hear the matter and determine an outcome which is binding on the parties. The panel is convened from impartial parties and comprises at minimum:
- The head of an affiliated school as Chair
- An approved Minister of Religion
- A Board member who has played no role in the matter.
The panel may interview any person directly involved in the preceding steps and seek other information and advice. The student’s supporter continues in their supportive role outlined above.
Step 5. If Unresolved, Contact the International Student Conciliator
In the event a dispute is not resolved to the satisfaction of either the Association or the student, an independent conciliator will be engaged by either the Association or by the student to assist in bringing amicable resolution to a complaint. The student or Association may also engage the service of the Conciliator located at the Department of Education Services. Details for contacting this service are provided in Section 9 below.
Step 6. Family and College Agree to Appoint an Independent Complaints and Appeals Body
Should the College or the family of the International Student not be satisfied with the outcome, the parties may agree to appoint an Independent Artbiter, who is separate from the College and the Association, and is not related or acquainted with the family. Terms of reference for the Complaints and Appeals Body will be made in accordance with Standard 10 of the ESOS National Code 2018.
Should the internal or external complaint handling or appeal process result in a decision that supports the student, the College will immediately implement any decision and/or corrective action required. The decision of the Independent Complaints and Appeals body shall be binding and final and the parent/student will be informed of the Independent Complaints and Appeals Body’s decision in writing.
International Students Ombudsman #
- The International Student Ombudsman acts as an Independent Conciliator for the purposes of resolving complaints or grievances affecting international students. This service replaces mediation formerly provided by the Federal Government and is a free service. The contact details appear at the end of this policy. The International Students Ombudsman has information sheets in many community languages available and can provide copies of a large print information booklet.
- The Independent Conciliator will attend to matters relating to:
- services and facilities;
- content and standard of education services;
- amount of refunds paid to students;
- quality of instruction;
- academic progress of students;
- conduct of international students;
- welfare services;
- information concerning part time employment opportunities;
- suspension and expulsion of international students; and
- any other matters as the Independent Conciliator sees fit.
- Subject to the provisions of consent and privacy laws, this information may be made available to other Government agencies both at State and Federal levels.
- International students may contact the International Student Ombudsman:
Online: https://www.ombudsman.gov.au
By phone: 1300 362 072 - Individuals wanting to make a complaint in relation to the VET FEE-HELP scheme or VET Student Loans program should first consider the information here before lodging a complaint with our office.
- Private Health Insurance advice can be found at PrivateHealth.gov.au.
- Services available to assist students to make a complaint:
- Translation and interpretation services for non-English speaking people: Translating and Interpreter Service – 131 450.
- Deaf/hearing impaired or speech impairment: National Relay Service
- TTY users phone 133 677 then ask for 1300 362 072
- Speak and Listen users phone 1300 555 727 then ask for 1300 362 072
- Internet Relay users connect to the National Relay Service then ask for 1300 362 072
Other Support Services #
- The Department for Child Protection is the State Government department responsible for issues specifically related to the protection of children, including the handling of abuse and neglect cases. Its website contains some excellent material for professionals, and parents and friends.
- For sexual abuse reports, the Mandatory Reporting Service must be contacted through one of the following means:
By phone 1800 708 704
By email mrs@dcp.wa.gov.au
By fax 1800 610 614
By post PO Box 8146 Perth Business Centre WA 6849
This unit is available 24 hours a day, 7 days a week for make a report or to raise concerns.
Details regarding mandatory reporting can be obtained through the mandatory reporting website.
To contact DCP for assistance with a specific case that does not involve sexual abuse, the school will need to speak to the Duty Officer at the local office, available during office hours. All offices are listed in the White Pages or on the website. - After hours:
Child Abuse Services WA
By phone 9223 1111 / 1800 199 008
Crisis Care (24 hour phone service for people in crisis and needing urgent help)
By phone 9223 1111 / 1800 199 008
WA Police Service Child Abuse Investigation Unit
For urgent matters 000
If you are a victim 131 444
Reporting child abuse to the
Child Protection Squad 9492 5444
child.abuse.investigation@police.wa.gov.au
Crime Stoppers 1800 333 000
Or visit your local Police Station
WA Police Cyber Predator Team
By phone 9492 5444
To lodge complaints www.police.wa.gov.au - Other sources of information:
www.acma.gov.au
www.constablecare.org.au
www.cybersmartkids.com.au
www.netalert.net.au
www.virtualglobaltaskforce.comThese websites contain information on cyber predators for parents, teachers, and students to use.
- The National Association of the Prevention of Child Abuse and Neglect (NAPCAN)
NAPCAN is an Australian organisation that seeks to resource and network child welfare professionals and practitioners working to prevent child abuse and neglect from happening before it starts, through the provision of parenting brochures, training, support networks and information. - Protective Behaviours WA Inc. – 9356 0514 / pbwainc@hotmail.com
This is a preventative life skills program that assists people of all ages to develop the skills to help them deal with difficult or hostile situations. The program has a voluntary committee made up of representatives from government and non-government agencies as well as interested members of the community. AISWA is a group member of Protective Behaviours and is able to purchase resources at a discount for interested schools. - Prime Corporate Psychology Services – 9492 8900 / 1800 674 188
This is a support service available for staff at schools who may experience personal issues resulting from making a report. They offer an employee assistance program including counselling, management and referrals. - The following services and organisations can provide help, advice, and support to the College, parents, or children who are affected by abuse and to prevent abuse from recurring:
Department for Child Protection (see above for contact information)
Parenting Line
By phone 9272 1466 / 1800 654 432
Family Helpline – 9223 1100 / 1800 643 000
This is a free confidential telephone counselling and information service for families with relationship difficulties.
Men’s Domestic Violence Helpline – 9223 1199 / 1800 000 599
This service provides free telephone, referral, and counselling for men to help them change their violent behaviour toward female partners.
Women’s Domestic Violence Helpline – 9223 1188 / 1800 007 339
This service provides free 24 hour telephone support and counselling for women experiencing family and domestic violence.
Child Health and Community Health Services
Refer to the White Pages for contact details of local Child Health Centres
Child and Adolescent Mental Health Services – 1800 220 400
24-hour mental health advice line
Perth Children’s Hospital – 6456 2222
State Child Development Centre – 9481 2203
Disability Services Commission – 9426 9200 / 1800 998 214
Kids Helpline – 1800 551 800
This is a free and confidential telephone counselling service for 5 to 25 year olds in Australia available 24 hours a day, 7 days a week.
Sexual Assault Resource Centre Counselling Line
This service offers free, 24-hour emergency services for people aged 13 or over who have been sexually assaulted or sexually abused recently (within the last two weeks).
Lifeline Australia – 13 11 14
This service operates 24 hours a day, 7 days a week and can provide information about other support services, if required. - The following sites can provide a wide range of background information on child abuse for schools that are interested:
http://www.aifs.gov.au/nch/afsapubs.html
This site lists recent publications relating to information on child abuse that have been updated on the web site of the National Child Protection Clearinghouse.
http://www.aic.gov.au/publications
This is the Australian Institute of Criminology site and has links to the criminal aspect of child abuse.
Flowchart #
