1. Quick Reference: Reportable Conduct Reporting Process

This one-page guide summarises the required reporting and response process for reportable conduct matters involving WWFC workers. See the Child Safety Reporting Process page for the step-by-step guide.

Note: If there is an immediate risk to a child or criminal conduct is suspected, protect the child first and notify Queensland Police immediately. If the allegation involves the Head of Reporting Entity, report directly to the QFCC.

2. Purpose

Wynnum Wolves Football Club (WWFC) is committed to the safety, wellbeing, and best interests of every child and young person who participates in our programs, training sessions, competitions, and club activities. This policy establishes the Club’s obligations and procedures under Queensland’s Reportable Conduct Scheme (RCS), as governed by the Child Safe Organisations Act 2024 (the Act) and administered by the Queensland Family and Child Commission (QFCC).

The purpose of this policy is to ensure that:

• All workers understand what constitutes reportable conduct and their individual reporting obligations.
• All allegations or convictions of reportable conduct involving Club workers are identified, assessed, reported, and investigated in a timely, child-centred, and procedurally fair manner.
• Children, young people, families, and workers feel confident to raise concerns, knowing they will be heard and acted upon.
• The Club maintains a culture of continuous improvement in child safeguarding practices.

3. Scope

This policy applies to all workers of WWFC. Under the Act, the term “worker” is broadly defined and includes:

NOTE: This policy also applies to conduct that occurs outside of the Club environment, including conduct in a worker’s private capacity, if it meets the definition of reportable conduct under the Act.

4. Definitions

Reportable Conduct means specific behaviours or actions by a worker involving abuse or neglect of children and young people that must be reported due to their serious nature (s26(1) of the Act).

Reportable Allegation means an allegation or other information that leads a person to form a reasonable belief that a worker has committed reportable conduct or engaged in misconduct that may involve reportable conduct. This includes information about conduct that occurred before the commencement of the Scheme if the person is still a worker.

Reportable Conviction means a conviction (including a finding of guilt without a conviction being recorded) of a worker for an offence against a law of Queensland or another jurisdiction (including outside Australia) that involves reportable conduct.

Reasonable Belief means a belief based on facts and information – not suspicion, rumour, or assumption – that a fair-minded and ordinary person, with the same information, would believe the conduct may have occurred. Certainty or proof is not required. Examples:

• Direct Disclosure: A player tells a team manager that a coach has been sending them private, non-football related messages late at night.
• Observation of Pattern: A volunteer notices a staff member consistently taking a specific child into the equipment shed alone and closing the door, despite club ‘Rule of Two’ policies.
• Third-Party Report: A parent provides screenshots of social media interactions between a volunteer and a child that appear overly personal or grooming in nature.
• Physical Indicators: A coach notices unexplained bruising on a child that coincides with aggressive ‘corrective’ physical handling by another worker during training.

Head of the Reporting Entity means the person who holds the highest authority and responsibility for the Club’s compliance with the RCS. At Wynnum Wolves FC, this is the Club President (or their authorised delegate, such as the Chief Executive Officer).

Worker means any individual performing work of any kind for Wynnum Wolves FC, as described in Scope above.

QFCC means the Queensland Family and Child Commission, the independent oversight body responsible for administering the RCS.

QPS means the Queensland Police Service.

5. Reportable Conduct

5.1 Categories of Reportable Conduct

Under s26(1) of the Act, reportable conduct includes the following six categories of behaviour by a worker:

5.1.1 A Child Sexual Offence

A child sexual offence is a criminal act of a sexual nature committed against, with, or in the presence of a child. This includes, but is not limited to:

• Sexual acts by a worker with a child aged 16 or 17 who is under their care, supervision, or authority.
• Indecent treatment of a child, including taking sexual photographs, showing pornography, or fondling a child in a sexual way.
• Grooming a child under 16 (or a person who has care of a child under 16) by building trust and emotional connection with the intent to create opportunity for sexual abuse.
• Using electronic communication (including social media or messaging apps) to recruit a child under 16 to engage in a sexual act.
• Possessing, distributing, or making child exploitation material.
• Rape or sexual assault.

5.1.2 Sexual Misconduct Committed in Relation to, or in the Presence of, a Child

Sexual misconduct includes sexualised behaviour that is inappropriate but may not reach the threshold of a criminal act. This includes:

• Inappropriate touching (e.g., massaging a child’s shoulders or placing a child on one’s lap when not required by the role).
• Voyeurism (e.g., watching a child undress).
• Use of sexual language without a legitimate reason (e.g., making sexual jokes or comments in the presence of a child, or discussing personal sexual experiences with a child).
• Sending or requesting sexual messages or images from a child.

5.1.3 Ill-Treatment of a Child

Ill-treatment means conduct towards a child that is unreasonable and seriously inappropriate, improper, inhumane, or cruel. This includes:

• Making excessive or degrading demands of a child.
• A pattern of hostile, humiliating, or degrading comments or behaviour directed at a child.
• Using inappropriate forms of behaviour management, such as pulling a child’s hair, grabbing a child’s arm to force compliance, or yelling at a child as a means of control.
• Engaging in discriminatory or degrading treatment on the basis of race, disability, religion, gender identity, or other personal characteristics where the conduct causes harm or distress.

5.1.4 Significant Neglect of a Child

A serious departure from the standard of care that should be provided to a child, which has caused, or creates a real risk of causing, significant harm to the child’s health, safety, or wellbeing. This may be a single significant incident or a pattern of persistent neglect. This includes:

• Supervisory neglect: Leaving a child without appropriate supervision, failing to respond to a child in clear distress, or failing to act when witnessing a child being harmed.
• Physical neglect: Deliberately failing to provide adequate food, appropriate clothing, or physical hygiene.
• Emotional neglect: Repeatedly belittling, shaming, isolating, or ignoring a child’s emotional needs.
• Educational neglect: Preventing a child from accessing required learning supports.

The threshold is met when neglect is chronic or repeated, or creates a real risk of serious harm, even if harm has not yet occurred.

5.1.5 Physical Violence Committed in Relation to, or in the Presence of, a Child

Physical violence means the intentional or reckless application of physical force to a person without lawful justification, or an act that causes a person to anticipate immediate and unlawful violence. This includes:

• Hitting, striking, punching, pushing, dragging, kicking, or spitting on a child.
• Using an object to hit or strike a child.
• Using restraint or excessive force that is inappropriate to the situation.
• Throwing objects or behaving aggressively in a way that exposes children to physical intimidation.

This does not include trivial, negligible, or insignificant physical force, or force that is reasonably applied to protect a person from harm (e.g., lawful self-defence or approved safety holds consistent with a behaviour support plan).

5.1.6 Behaviour that Causes Significant Emotional or Psychological Harm

This means conduct that has serious and/or ongoing detrimental effects on a child’s emotional or psychological wellbeing and/or development. There must be a clear causal link between the worker’s conduct and observable harm to the child. This includes:

• Persistently bullying, taunting, or ridiculing a child, resulting in withdrawal, distress, or self-harm.
• Repeatedly rejecting, ignoring, or emotionally withholding support from a child.
• Subjecting a child to racist or discriminatory behaviour that harms their sense of identity, belonging, or emotional safety.
• Intentionally intimidating or threatening a child to force compliance, creating ongoing fear or anxiety.

5.2 What is NOT Reportable Conduct

The following behaviours are NOT considered reportable conduct under the Act (s26(4)):

• Reasonable behaviour management consistent with the Club’s Code of Conduct (e.g., a coach briefly raising their voice to get the attention of a group without targeting or distressing any individual child).
• Minor accidents or incidents where no neglect or recklessness is involved (e.g., a child grazes their knee during training and the worker responds with appropriate first aid).
• Brief corrective feedback delivered respectfully and without shaming or threatening the child.
• Reasonable restrictive practices or safety holds used in accordance with an approved behaviour support plan.

Workers are encouraged to discuss any uncertainty about whether conduct is reportable with the Club President or Child Safety Officer.

6. Reporting Obligations

6.1 Obligation of All Workers

Under s33(2) of the Act, every worker of Wynnum Wolves FC who becomes aware of a reportable allegation or reportable conviction involving another worker must report the matter as soon as possible to the Head of the Reporting Entity (Club President or Child Safety Officer).

If the allegation involves the Head of the Reporting Entity, the worker must report the matter directly to the QFCC. Workers may also report directly to the QFCC at any time (s33(4)).

Workers do not need to determine whether the behaviour definitively meets the reportable allegation threshold before making a report. If unsure, workers should still report, as individual behaviours may be part of a broader pattern that only becomes apparent when information is considered collectively.

The obligation to report does not apply if the worker reasonably believes the matter has already been reported by another person (s33(3)).

6.2 Obligations of the Head of the Reporting Entity

The Head of the Reporting Entity (Club President or authorised delegate) is responsible for the Club’s compliance with the RCS. Upon receiving a report of a potential reportable allegation or conviction, the Head must:

Note: Failure to notify and provide reports to the QFCC is an offence under the Act and may result in a financial penalty of 100 penalty units.

6.3 Reporting when the Head of Reporting Entity is the Subject

If an allegation involves the Club President or their authorised delegate, any person may notify the QFCC directly. The Club will designate a senior, independent officer (e.g., the Vice-President or a Management Committee member who is not subject to the authority of the person under allegation) to manage the matter internally before escalation to the QFCC. This alternative reporting pathway will be clearly communicated to all workers.

7. Immediate Risk Assessment and Management

Upon receiving a report of a potential reportable allegation or conviction, the Head of the Reporting Entity must immediately assess all available information to identify and manage risks to:

• The child or children involved.
• Other children or young people at the Club.
• The worker subject to the allegation.
• Families and carers.
• Adult witnesses.
• The integrity of any concurrent investigation.

Immediate risk management actions may include:

• Increased supervision of the worker.
• Modification of the worker’s duties or relocation within the Club.
• Removal of the worker’s access to digital systems, personal information, or CCTV.
• Restricting the worker’s contact with children, families, or witnesses.
• Suspension of the worker (where proportionate to the assessed risk).
• Securing relevant evidence (records, CCTV footage, devices).
• Notifying the Department of Families, Seniors, Disability Services and Child Safety if there is a reasonable suspicion that a child is in need of protection.

All risk management actions taken must be documented and included in the Initial Report to the QFCC. Risk management must also consider the wellbeing of the worker subject to the allegation, including access to appropriate support such as counselling. The worker’s privacy must be protected in accordance with relevant privacy laws.

8. Reporting to the QFCC

8.1 Initial Report (within 3 business days)

The Initial Report to the QFCC must include, at minimum (s35(1) of the Act):

• Details of the reportable allegation or conviction.
• The name (including any former name or alias) and date of birth (if known) of the worker subject to the allegation or conviction.
• The name of the Head of the Reporting Entity.
• Whether the QPS or a sector regulator has been notified.
• The Club’s contact details (name, address, telephone number).
• Any risk management action taken in response to the allegation or conviction, including immediate steps taken to prevent the worker from having contact with children and any disciplinary action taken or proposed.

8.2 Interim Report (within 30 business days)

If the investigation is not complete within 30 business days, an Interim Report must be provided to the QFCC. This report must include (s35(2) of the Act):

• The facts and circumstances of the allegation or conviction, to the extent available.
• An update on all actions taken, including risk management actions.
• A copy of any written submissions made by the worker in relation to the allegation or conviction.

8.3 Final Report (as soon as practicable after completion)

The Final Report must include (s37 of the Act):

• Information about the facts and circumstances of the allegation or conviction.
• The findings made after completing the investigation, including whether the worker engaged in reportable conduct.
• The reasons for the findings.
• Copies of all documents relied upon in making the findings (e.g., witness statements, submissions).
• Whether the matter has been referred to another entity and the details of that entity.
• Any risk management action taken in response to the findings, including steps taken to prevent the worker from having contact with children and any disciplinary action taken or proposed.
• Any actions taken or proposed to improve the Club’s ability to identify, report, and investigate reportable conduct.
• If no action is to be taken under the above two points, the reasons why.