“The IEUA has previously been on the record and re-asserts in this submission that it would support a nationally consistent information exchange system to protect children and young persons within and between Australian jurisdictions.
“The IEUA argues, however, that the information exchange should relate specifically to child sexual abuse matters and that ’threshold’ triggers need careful discussion and consideration. For instance, the IEUA would reject information sharing of ‘rumour and innuendo’.
“Further, the IEUA would reject a nationally consistent notification arrangement that sought to include ‘other disciplinary matters’ that are collected and overseen by some teacher licensing authorities .
“In relation to the authority in each jurisdiction that might have responsibility for management of the data repository on child sexual abuse, the IEUA does not support the notion that a possible appropriate authority would be the teacher registration/licensing authority (variously known as teacher colleges, institutes or boards).
“The IEUA rejects such a proposition for a number of reasons, most significantly being that these authorities, paid for by registered teachers, are not equipped to deal with the task and the resources to undertake such work would increase the costs of these bodies which would inevitably be borne by our members. This community service responsibility of managing the repository is correctly a responsibility of and financial function of the state.
“Further, many staff working in schools are not members of the teacher registration/licensing authority by virtue of the nature of their employment and therefore a separate and alternate arrangement would need to be made for these staff. The IEUA is concerned about the number and type of prescribed bodies that would have access to the repository and would argue strongly for a strict limit on the number of appropriate and necessary prescribed bodies.
“Further, the type of information shared needs to be limited to information that is specific to the welfare of the child at risk. Accordingly, further consultation and discussion will be required in relation to this element.
“The IEUA notes that children’s commissioners or ombudsman exist in jurisdictions and that these bodies could be more appropriately charged with the responsibility of management of the repository.
“The IEUA also believes that any nationally consistent information exchange system should not be any more onerous than current arrangements. Structural proposals will necessarily require further consultation with key stakeholders.
“It is the responsibility of the IEUA to protect our members’ welfare, employment, reputation and careers. Accordingly any nationally consistent approach will require inbuilt review and appeals’ processes.
“Further, the IEUA believes that access to the repository should be limited and that prescribed bodies need to be clearly and carefully defined and restricted only to those responsible for the working with children check at the point of employment.
“As there are currently variations in this process in jurisdictions at present, a considered review and likely further consultative process will be required to capture the appropriate bodies.”