Reflections on Safeguarding Assessments – 7 Gaps in Practice

August 18, 2022

Introducing Stephen Ratcliffe, one of Ansvar’s Senior Enterprise Risk Consultants. Stephen has a clinical background as a dietitian working in residential aged care, dementia care and disability services for over a decade, and multiple health management positions in quality improvement, strategy and risk management for 17years. Most recently Director of Strategy, Planning and Risk at The Royal Melbourne Hospital

At Ansvar, his role supports brokers and clients to improve their risk management practice, care governance and safeguarding of children and vulnerable people.  We spoke to Stephen about the importance of safeguarding to prevent abuse.

“Preventing physical or sexual abuse of vulnerable people is everyone’s business Poor practices to safeguarding children and vulnerable people can lead to concerning incidents.  Harm of a person under your care can have significant mental and physical consequences for the victims” he said.

“Many of Ansvar’s clients are organisations that serve the community – aged care, child care, education services, disability services, community groups, churches and charities. Incidents of abuse can have not only catastrophic impacts on individuals but communities as well.  Providers face considerable reputational and financial stress in the face of abuse allegations and may have to restrict or cease operations” he said.

“Ansvar is a different type of insurer, investing in specialist risk management expertise from the sectors we insure – and providing support direct to our clients. Our role is to help our clients strengthen their safeguarding practice.  Here are some of the trends of the most common gaps in safeguarding practice that we’ve seen over the last 12 months.”

Do any of these gaps apply to you?

Gap 1: Not defining what constitutes abuse – and signs it might be occurring
Reporting abuse is a mandatory requirement.  So defining the types of abuse that can occur and signs of abuse are needed to help staff and volunteers be able to identify and report abuse correctly.  This should be included in staff training and in your Protecting vulnerable people policy.

Gap 2: Not considering “non-physical contact” abuse
Sexual abuse can relate to physical contact or non-physical contact.

Oftentimes non-contact abuse is missed. Abuse of a child or vulnerable person without physical contact could include:

  • showing images or videos of sexual related content
  • inappropriate/sexualised conversation, not of a health or medical nature
  • taking photos or filming the person for sexual purposes without their consent

Gap 3: Not defining grooming and how to spot grooming behaviours
Grooming behaviours create a sense of trust that lead to an opportunity for abuse. Potential perpetrators may groom adults, co-workers, families to build a sense of trust and put themselves in a future situation to be alone with a child or vulnerable person.  Grooming behaviours may seek to persuade a vulnerable person that they have a special relationship with the perpetrator and can lead to sexual abuse.

Examples of grooming behaviours or testing boundaries include[1]:

  • Favouritism or gift-giving to a child or vulnerable person and not to others
  • Focussed attention on an individual child or vulnerable person at expense of others
  • Encouraging the child or vulnerable person to keep secrets or not talk about their relationship
  • Out-of-work contact or social media contact by a staff member or volunteer – and in the context of children, direct contact with children and not the parents
  • Supervising a child or vulnerable person undressing where supervision is not necessary or changing clothes in front of a child or vulnerable person
  • Discussing or communicating electronically about sexual feelings or intimate personal information or behaviours

[1] Adapted from: Reportable Incidents – Detailed guidance for registered NDIS providers.  2019.  NDIS Quality and Safety Commission.

Accessible online:

Mandatory reporting requires abuse to be reported when abuse is:

  • Observed
  • Disclosed by a victim or other witness to abuse
  • Reasonably suspected

A suspicion of abuse is hard to report if staff and volunteers don’t understand the types of behaviours and signs to look out for that might create a reasonable suspicion of abuse.

It is recommended that both signs of abuse and signs of grooming are clearly defined in the same policies that provide advice on mandatory reporting of abuse.  This assists staff to have all the information they need in one place and to be clear of their obligations.


Gap 4: Not including notification of an allegation of abuse to your insurance broker or insurer in your incident management procedure
Ansvar Insurance cover for Physical and Sexual Abuse is transitioning to Claims Made wording form Occurrence Wording.  The impact of this is that as soon as you are made aware of an allegation, it needs to be notified to your insurance broker or insurer

Talk to your insurance broker about the terms of your Physical and Sexual Abuse (PSA) cover and the importance of notifying within your current year policy period as soon as you are made aware of an allegation of abuse.


  • All allegations need to be taken seriously and referred to police and other statutory reporting bodies in your State.
  • An investigation does not need to be finalised to notify your insurance broker or insurer of an allegation nor does an allegation suggest it has been verified.
  • Notifications to your insurer do not affect your premium pricing.


Gap 5: Incomplete record keeping on staff training
Some organisations describe their recruitment and on-boarding practices in their recruitment procedures and others in their safeguarding from abuse procedure.

Wherever you document it, it is important to describe:

  • induction to the Code of Conduct, clearly outlining acceptable and unacceptable behaviours
  • training provided on safeguarding from abuse – including signs of abuse and grooming
  • training on how to record and report an incident
  • how training records will be kept and the frequency of refresher training


Gap 6: Incomplete record keeping on staff screening, police checks and reference checking
Almost all organisations include information about police checks and other screening programs relevant to their State, but many often forget to include the Reference Checking process.  Two referee checks are the minimum acceptable standard for positions involving vulnerable people.

Keeping track of the currency of police checks and other screening is also important. Early notification to staff of checks expiring and a temporary hold on shift allocation until updated checks are provided is required practice.


Gap 7: Conflict of interest in investigating and escalating allegations of abuse or neglect
Especially for small care providers or faith organisations, sometimes the person responsible for safeguarding from abuse has a close personal relationship with a core practitioner or has a financial interest in the business.

  • A small, in-home care provider with a sole managing director, where they are the safeguarding officer. How is conflict of interest managed with an allegation against a staff member, where an incident may result in the business closing.
  • A small church where the pastor’s partner or family member may be the safeguarding officer. How is conflict of interest managed in the event of an allegation against the Pastor

Having a secondary pathway to report abuse can help reduce any conflict of interest.  Providing information to people participating in your services on how to report abuse is good practice.  This may include references to external reporting hotlines where the participant is not comfortable with internal reporting processes.


A word about safety culture
How organisations talk about preventing abuse can give insights into the culture of the organisation and its commitment and understanding of how abuse can occur.

The following are a few examples of cultural red flags

Comment Implication
“That doesn’t happen here”


Abuse can occur in any setting.  A long history of assuming abuse “couldn’t happen here” created an environment where abuse went unnoticed or worse, noticed and unaddressed.
“But we know our volunteers”


Reference checking and mandatory screening is a critical part of preventing abuse.  This applies to paid staff or volunteers.  Tracking of currency of police checks and other screening requirements is a core part of proactively preventing abuse in your organisation.
“But we don’t provide services to children so grooming isn’t applicable to us”


Abuse can happen at any age.  Grooming is a process that creates a sense of trust and lays the foundations for a future scenario of abuse.  When a potential perpetrator has a trusting relationship, they may be in a situation where they are alone with a vulnerable person.


Further questions?
Click here to check out our Safeguarding risk alert on our website for information about critical controls along with links to videos, tools and templates.

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