NQS

QUALITY AREA 2:  CHILDREN’S HEALTH AND SAFETY

QUALITY AREA 7:  GOVERNANCE AND LEADERSHIP

National Regulations

RELATED LEGISLATION

• Child Care Subsidy Secretary’s Rules 2017

• Family Law Act 1975

• A New Tax System (Family Assistance) Act 1999

• Privacy Act 1988 (the Act)

• Family Assistance Law – Incorporating all related legislation as identified within the Child Care Provider Handbook

RELATED POLICIES

Purpose

Children’s safety and wellbeing is paramount and our Service has the responsibility to provide and maintain a safe and secure working and learning environment for staff, children, visitors and contractors, including online environments. We aim to create and maintain a positive digital safe culture that works in conjunction with our Service philosophy, and privacy and legislative requirements to ensure the safety of enrolled children, educators and families.

The use of Close Circuit Television (CCTV) installed at the Service aims to address crime prevention strategies to reduce concerns, deal with complaints and support investigations. Our Service adheres to the Privacy Act 1988 (Privacy Act) and comply with the Australian Privacy Principles.

Scope

This policy applies to children, families, staff, educators, management, approved provider, nominated supervisor, students, volunteers and visitors of the Service.

Terminology

Source: Glossary to NQF Child Safe Culture and Online Safety Guides- ACECQA 2025

Implementation

Our Service uses digital technology and electronic devices as a tool for learning with children, documenting their learning and development, communicating with families and the wider community, supporting program planning and administration tasks and enhancing safety and security through systems such as sign in/out platforms and CCTV monitoring. Our educators are diligent in ensuring children are only able to access age-appropriate technology on a Service issued device.

Digital Technology and Electronic Devices used at the Service

Our Service follows the National Model Code and Guidelines for taking images or videos of children.

The approved provider will inform staff, educators, visitors, volunteers and family members that the use of personal electronic devices used to take photos, record audio or capture video of children who are being educated and cared for at the Service is strictly prohibited. This includes items such as tablets, phones, digital cameras, smart watches with a camera, META sunglasses and personal storage and file transfer media (such as SD cards, USB drives, hard drives and cloud storage). These devices should not be in the possession of staff or Educators while working directly with children.

Staff and educators are advised that electronic devices belonging to the Service must not be removed from the premises as they may contain personal details of staff or children, including photos or videos. Except where required for operational activities, for example excursions or transportation.

The approved provider will inform staff, educators and visitors of exemptions that may warrant a person to use or be in possession of a personal electronic device that can be used to take images or videos. Staff, educators or visitors with an exemption must not use the personal device to take images or videos of children. For an exemption an Educator will fill out a service “Phone Permission” form and provide this to Nominated Supervisor to approve. Exemptions need to be provided for in writing by the Nominated Supervisor, or Responsible Person, and may include:

•        Emergency communication during incidents such as a lost child, injury, lockdown, or evacuation

•        Personal health needs requiring device use (e.g. heart or blood sugar monitoring)

•        Disability related communication needs

•        Urgent family matters (e.g. critically ill or dying family member)

•        Local emergency event to receive alerts (e.g. government bushfire or evacuation notifications)

Children enrolled at our Service are not permitted to bring electronic devices to the Service, unless an exception has been discussed with the approved provider or nominated supervisor where the device may be required to support a diagnosed medical condition or disability. If a child brings an electronic device to the Service, it will be switched off and stored in a location which is inaccessible to children.

Images and Videos

The approved provider is responsible for determining who is authorised to take, use, store and destroy images and videos of children using Service issued digital devices. Images and videos will be stored securely with password protection, with access limited to authorised personnel only. Images and videos of children must only be taken and used in accordance with Service policies, and careful consideration given to the purpose of the image or video. Educators will engage in discussions that consider the intent, appropriateness, context and consent involved in capturing and using the images and videos, ensuring the process aligns with children’s learning, wellbeing and right to privacy. 

Our Service will regularly review how digital data, including images and videos of children, is stored. Back ups of all digital data will be stored either through the use of Kinderloop (service App) or through data storage on Dropbox. Digital data stored at the Service will be destroyed in accordance with the Record Keeping and Retention Policy and procedure. The approved provider will ensure staff, educators, visitors and volunteers do not transfer images or videos from Service issued devices to personal devices, unauthorised transferring of digital data may result in disciplinary action.

Physical Environment and Active Supervision 

The approved provider, nominated supervisor, management and educators will:

• ensure children are always supervised and never left unattended whilst an electronic device is connected to the internet

• provide a child safe environment to children- reminding them if they encounter anything unexpected that makes them feel uncomfortable, scared or upset, they can seek support from staff

• reflect on our Service’s physical environment, layout and design to ensure it supports child safe practices when children are engaged in using technology

  • perform regular audits to identify risks to children’s safety and changes in room set-ups that can indicate areas of higher-risk and become supervision ‘blind spots’

  • display supervision plans within children’s environments which includes areas where higher levels of supervision are required

  • ensure location of digital technology/equipment allows educators to remain in line-of-sight of other staff members when working with children

  • only permit children to use devices in open areas where educators can monitor children’s use

  • be aware of high-risk behaviours for children online, including uploading private information or images, engaging with inappropriate content (inadvertently or purposefully), making in-app purchases, and interacting with unsafe individuals

  • ensure all visitors and volunteers are supervised at all times

  • ensure all devices are password protected with access for staff only

• where digital devices are used during transportation and excursions, they must be used in accordance with practices outlined within this policy and associated procedure.

Software Programs and APPS

Our Service uses a range of secure software programs and apps on Service-issued devices to support the educational program and administration of the Service. All apps used by staff, educators, visitors and children are carefully selected, regularly checked and kept up to date with the latest available system updates. Access to software programs and apps are password protected to ensure the privacy of children, families and staff. Each user is required to create their own user account and ensure log in, and password information is not shared.

The approved provider will ensure programs which require additional background checks, such as CCS Software, are only accessed by authorised staff who have completed necessary screening processes in accordance with Family Assistance Law. Our educational program software is used by educators to share observations, photos, videos, daily reports, and learning portfolios with families in a secure, closed platform – currently or service uses Kinderloop. In addition, our Service may use accounting and payroll software such as Xero, HR systems, and compliance tools. These platforms assist in managing the Service’s financial, staffing, and operational requirements.

Confidential and Privacy Guidelines

All staff, educators, and visitors must ensure that any information, images, or digital content related to children, families, and the Service is collected, stored, used, and shared in accordance with privacy legislation and Service procedures, to maintain confidentiality and protect the safety and wellbeing of children. The nominated supervisor will advise the approved provider as soon as possible regarding any potential threat to security information and access to data sensitive information.

The approved provider will notify the Office of the Australian Information Commissioner (OAIC) in the event of a possible data breach by using the online Notifiable Data Breach Form. This could include:

• a device containing personal information about children and/or families is lost or stolen (parent names and phone numbers, dates of birth, allergies, parent phone numbers)

• a data base with personal information about children and/or families is hacked

• personal information about a child is mistakenly given to the wrong person (portfolios, child developmental report)

• this applies to any possible breach within the Service or if the device is left behind whilst on an excursion

• ensure educators are aware of their mandatory reporting requirements and report any concerns related to child safety including inappropriate use of digital technology to the approved provider or nominated supervisor.

Identification and Reporting Of Online Abuse and Safety Concerns

Our Service will implement measures to keep children safe whilst using digital technology and accessing online environments.

The approved provider, nominated supervisor and management will:

• ensure all staff, educators, students and volunteers are aware of their mandatory reporting obligations and promptly report any concerns related to child safety, including inappropriate use of digital technology, to the approved provider or nominated supervisor [See Child Protection Policy]

• support educators to:

  • encourage children to seek support if they encounter anything unexpected that makes them feel uncomfortable, scared or upset

  • listen sensitively and respond appropriately to any disclosures children may make relating to unsafe online interactions or exposure to inappropriate content, adhering to the Child Protection Policy and reporting procedures

  • respond to and report any breaches and incidents of inappropriate use of digital devices and online services to management

• ensure all concerns are documented and responded to promptly and appropriately, with support provided to the child and their family as required

• report any suspected cases of online abuse to the relevant authorities, including the eSafety Commissioner and Police, in accordance with legal requirements and child protection procedures

• notify the regulatory authority within 24 hours, via NQAITS, if a child is involved in a serious incident, including any unsafe online interactions, exposure to inappropriate content, or suspected online abuse. 

Use of Closed-Circuit Television (CCTV) Monitoring 

Our Service uses Closed-Circuit Television (CCTV) to monitor the physical environment. Our Service will regularly review guidance on the use of surveillance devices, including information provided by the Office of the Australian Information Commissioner. Families are informed the Service uses CCTV as a surveillance method during enrolment and orientation to the Service – and this information is displayed on entry to the service.

Cameras are not installed in private areas such as bathrooms or shower areas (for adults or children). All cameras are clearly visible.

Access to CCTV footage at the Service is strictly controlled and protected by secure, password-protected systems. Only authorised personnel are permitted to access the footage, in accordance with privacy laws and Service policies. The approved provider is responsible for determining who is authorised to access CCTV footage. CCTV footage will not be accessible to external parties (e.g., staff members or families) without appropriate authorisation. Any requests to view CCTV footage will be managed in accordance with Australian Law. 

Access to the recordings will only be disclosed to:

1. the Ombudsman NSW to assist with investigations on ‘child protection’ (e.g., risk of harm, abuse, neglect and ill treatment).

2. to a member or officer of a law enforcement agency e.g., Police for use in assisting with investigations.

3. the approved provider or nominated supervisor to investigate situations that may have occurred.

 THE APPROVED PROVIDER/NOMINATED SUPERVISOR/MANAGEMENT WILL ENSURE:

• that obligations under the Education and Care Services National Law and National Regulations are met

• educators, staff, students, visitors and volunteers have knowledge of and adhere to this policy and associated procedure

• new employees, students and volunteers are provided with a copy of the Safe Use of Digital Technologies and Online Environments Policy and procedure as part of their induction, Via the QR code within the foyer

• all staff, educators, volunteers and students are aware of current child protection law, National Principles for Child Safe Organisations and their duty of care to ensure that reasonable steps are taken to prevent harm to children

• families are aware of this Safe Use of Digital Technologies and Online Environments Policy and procedure and are advised on how and where the policy can be accessed

• they promote and support a child safe environment, ensuring adherence to the Child Safe Environment and Child Protection Policies, including mandatory reporting obligations

• the National Principles for Child Safe Organisations is embedded into the organisational structure and operations

• professional learning is provided to educators and staff relating to the safe use of digital technologies and online environments, included within our annual Child Protection training

• appropriate ratios and adequate supervision are maintained for children at all times including when using digital technology and accessing online environments

• students, volunteers and/or visitors are never left alone with a child whilst at the Service under any circumstances

• all staff, educators, volunteers and students are aware of the National Model Code and Guidelines and adhere to these recommendations for taking images or video of children including:

  • personal electronic devices or personal storage devices, that can take images or videos, are not used by educators, staff, visitors or volunteers when working directly with children

  • staff and educators only use electronic devices issued by the Service for taking images or videos of children enrolled at the Service

  • Service issued devices are securely configured, monitored and maintained to prevent unauthorised access 

  • visitors who are supporting children at the Service (NDIS funded support professionals, Inclusion Support Professionals) obtain written authorisation from parents/guardians to capture images or video of a child for observation/documentation purposes only. (See ECIP Confidentiality Agreement)

• children, educators and parents are aware of our Service’s complaints handling process to raise any concerns they may have about the use of digital technologies or any other matter (see: Grievances and Complaints Policy)

• the Service Privacy and Confidentiality Policy is adhered to at all times by staff, educators, families, visitors, volunteers and students

• parents/guardians are informed of how the Service will take, use, store and destroy images and videos of children enrolled at the Service during enrolment and orientation

• written authorisation is requested from families to take, use, store and destroy digital documentation including images and videos of children

• images or videos of children are not taken, used or stored without prior parent/guardian authorisation

• written authorisation is obtained from parents/guardians for children to use electronic devices, as part of the enrolment process

• written authorisation is obtained from parents/guardians to collect and share personal information, images or videos of their children online (Website, Facebook, Instagram or Kinderloop)

• families are informed to withdraw authorisation, a written request is required

• images and videos for individual children are deleted or destroyed and removed from storage when authorisation has been revoked from the parent/guardian

• they review how images and videos are stored on a regular basis and ensure new educators and staff have access to relevant folders and files, if required, in accordance with their role

• digital data is stored securely via password protected Dropbox account, or stored via Kinderloop

• images and videos are deleted or destroyed and removed from storage devices in accordance with the Record Keeping and Retention Policy, images and videos used for documenting children’s learning and development must be held for 3 years after the child’s last day of attendance

• external agencies or specialists are consulted if concerns are identified relating to online abuse, cyberbullying or digital safety risks

• policies and procedures reflect a commitment to equity and diversity, protect children’s privacy, and empower children to be independent

• collaboration with relevant professionals, as required, to support equitable access to digital technologies for all children

• they remain informed of privacy legislation through monitoring of updated from relevant government authorities such as the Office of the Australian Information Commissioner (OAIC)

• a risk assessment is conducted regarding the use of digital technologies by staff and children at the Service, including accessing online environments

• risk assessments for digital technology and online environments are reviewed annually or as soon as possible after becoming aware of any circumstances that may affect the safety, health or wellbeing of children

• policies and procedures are reviewed following an identification of risks following the review of risk assessments relating to the use of digital technologies and online environments

• staff, educators, families and children are informed of updates to policies, procedures or legislation relating to digital technologies and online environments

• a review of practices is conducted following an incident involving digital technologies or online environments, including an assessment of areas for improvement 

• educators are informed of, and adhere to recommended timeframes for ‘screen time’ according to Munch and Move Guidelines:

  • children birth to one year should not spend any time in front of a screen

  • children 2 to 5 years of age should be limited to less than one hour per day

  • children 5-12 years of age should limit screen time for entertainment to no more than 2 hours a day.

• they share information to families about recommended screen time limits based on Australia’s Physical Activity and Sedentary Behaviour Guidelines.

EDUCATORS WILL:

• adhere to the Safe Use of Digital Technologies and Online Environments Policy and associated procedure 

• ensure they are aware of current child protection law, National Principles for Child Safe Organisations and their duty of care to ensure that reasonable steps are taken to prevent harm to children

• ensure they promote and support a child safe environment, ensuring adherence to the Child Safe Environment and Child Protection Policies, including mandatory reporting obligations

• participate in practical training related to digital safety, privacy protection and responsible use of technology

• understand the critical importance of implementing active supervision strategies when children are accessing online environments to keep children safe

• promote and contribute to a culture of child safety and wellbeing in all aspects of our Service’s operations, including when accessing digital technologies and online learning environments

• not use, or have access to, any personal electronic devices, including mobile phones or smart watches used to take images or video of children at the Service, access social media (Facebook, Instagram or other) or breach children and families’ privacy

• keep passwords confidential and log out of computers and software programs after each use

• ask permission before taking photos of children on any device and explain to children how photos of them will be used and where they may be published

• ensure children’s personal information where children can be identified such as name, address, age, date of birth etc. is not shared online

• ensure that screen time is NOT used as a reward or to manage challenging behaviours under any circumstances

• introduce concepts to children about online safety at age-appropriate levels

• support children’s understanding of online safety by providing age-appropriate guidance, discussions and activities that help them to recognise safe and unsafe online behaviours

• consult with children about matters that impact them, including the use of digital technologies and online environments, to ensure their voices are heard and respected in a meaningful way.

FAMILIES WILL:

• adhere to the Safe Use of Digital Technologies and Online Environments Policy and associated procedure

• not use personal electronic devices, such as mobile phones, smart watches or META sunglasses, to take photos, record audio, or capture video of children being educated and cared for at the Service

• be aware that sometimes other children in the Service may feature in the same photos, videos, and/or observations as their children. In these cases, families are never to duplicate or upload them to the internet/social networking sites or share them with anyone other than family members.

VISITORS AND VOLUNTEERS WILL:

• adhere to the Safe Use of Digital Technologies and Online Environments Policy and associated procedure whilst visiting the Service

• not use personal electronic devices, such as mobile phones smart watches or META sunglasses, to take photos, record audio, or capture video of children being educated and cared for at the Service

• report any concerns related to child safety, including inappropriate use of digital technology, to the approved provider or nominated supervisor

• obtain written authorisation from parents/guardians to capture images or video of a child for observation/documentation purposes only. This applies to visitors who are supporting children at the Service (NDIS funded support professionals, Inclusion Support professionals) (See ECIP Confidentiality Agreement).

Breach of Policy

Staff members or educators who fail to adhere to this policy may be in breach of their terms of employment and may face disciplinary action. Visitors or volunteers who fail to comply to this policy may face termination of their engagement. Family members who do not comply with this policy may place their child’s enrolment at risk and limit the family members access to the Service.

Resources

• Australian Children’s Education & Care Quality Authority. National Model for Early Childhood Education and Care.

• Australian Government Office of the eSafety commission 

• eSafety Early Years Program for educators

• eSafety Early Years Program checklist

• eSmart Alannah & Madeline foundation 

• Family Tech Agreement. eSafety Early Years Online safety for under 5s

• Kiddle is a child-friendly search engine for children that filters information and websites with deceptive or explicit content: https://www.kiddle.co/

• Office of the Australian Information Commissioner (OAIC)

Continuous Improvement/Reflection

Our Safe Use of Digital Technologies and Online Environments Policy will be reviewed on an annual basis in consultation with children, families, staff, educators and management. Families will be notified of changes to policies within 14 days to ensure they remain informed and can provide feedback or ask questions as needed.

Childcare Centre Desktop - Related Resources

Sources

• Australian Children’s Education & Care Quality Authority. (2025). Guide to the National Quality Framework

• Australian Children’s Education & Care Quality Authority. (2023). Embedding the National Child Safe Principles

• Australian Children’s Education & Care Quality Authority. (2024). Taking Images and Video of Children While Providing Early Childhood Education and Care. Guidelines For The National Model Code.

• Australian Children’s Education & Care Quality Authority. (2025). NQF Online Safety Guide

• Australian Government eSafety Commission (2020) www.esafety.gov.au

• Australian Government Department of Education.(2025). Child Care Provider Handbook  

• Australian Government. eSafety Commissioner Early Years program for educators

• Australian Government, Office of the Australian Information Commissioner. (2019). Australian Privacy Principles:  https://www.oaic.gov.au/privacy/australian-privacy-principles-guidelines/

• Australian Government Department of Health and Aged Care. (2021). Australia’s Physical Activity and Sedentary Behaviour Guidelines

• Australian Human Rights Commission (2020). Child Safe Organisations.  https://childsafe.humanrights.gov.au/

• Early Childhood Australia Code of Ethics. (2016).

• Education and Care Services National Law Act 2010. (Amended 2023).

• Education and Care Services National Regulations. (Amended 2023).    

• Office of the Australian Information Commissioner (OAIC)

• Privacy Act 1988.

• Western Australian Legislation Education and Care Services National Law (WA) Act 2012

• Western Australian Legislation Education and Care Services National Regulations (WA) Act 2012 

Date:

18.8.2025

Next Review:

18.8.2026

Version:

1

Last amended by:

Laura Clarke  

Position:

Nominated Supervisor

Modification:

• New policy developed following changes to National Regulations effective from 1 September 2025

• Merger of the following policies: Technology Policy, Cyber Safety Policy and CCTV Policy