Hays Child & Youth Risk Management Strategy

Requirements for organisations

The Working with Children (Risk Management and Screening) Act 2000 (the Act), the Working with Children (Risk Management and Screening) Regulation 2020 and the Working with Children (Risk Management and Screening) and Other Legislation Amendment Act 2024 in Queensland require regulated organisations to develop and implement a child and youth risk management strategy (CYRMS) which aims to keep children and young people safe. The penalty for not developing and implementing a CYRMS is up to $3,338 (as at 1st July 2025). The eight mandatory requirements of a CYRMS are:

Commitment
1. A statement of commitment to the safety and wellbeing of children and the protection of children from harm
2. A code of conduct for interacting with children

Capability
3. Written procedures for recruiting, selecting, and placing temporary workers

Concerns
4. Policies and procedures for handling disclosures or suspicions of harm, including reporting guidelines
5. A plan for managing breaches of your risk management strategy
6. Risk management plans for high-risk activities and special events

Consistency
7. Policies and procedures for managing compliance with the blue card system
8. Strategies for communication and support

Whilst the requirement for a CYRMS is a requirement of the relevant Queensland laws, as a national business Hays has created its strategy to also apply to other States and Territories where relevant.

Statement of commitment of Hays Specialist Recruitment (Australia) Pty Ltd

Hays Specialist Recruitment (Australia) Pty Ltd (Hays) is a global specialist recruitment company. We are experts at recruiting qualified, professional and skilled people and operate across the private and public sectors, dealing in permanent positions, contract roles and temporary assignments. With temporary assignments, we source temporary workers who are engaged by Hays, and then on-hired to a client organisation who then supervises, directs and controls the temporary worker. The client organisation is known as the ‘host employer’. Hays is committed to ensuring the safety and wellbeing of all children and young people and is dedicated to protecting them from harm. In providing temporary workers to Hays’ clients, Hays will endeavour to provide a safe and supportive environment for children and young people by:

Obtaining a copy of the host employers child and youth risk management strategy (mandatory in QLD only), and if they do not have one, inquire as to why and escalate this to Hays QLD management
Keeping in regular contact with our clients to ensure as far as is reasonably practical the appropriate treatment of children and young people
Ensuring as far as reasonably practicable that all workers treat children and young people with respect and understanding at all times
Ensuring that those temporary workers that we place with clients and who regularly deal with children and young people undergo (unless exemptions apply) the relevant State or Territory Working with Children Check (WWC Check) and hold the relevant licence or card (WWC Card) (as an example, the Blue Card in QLD and the Ochre Card in NT)
Carefully selecting and screening temporary workers whose roles require them to have regular contact with children and young people
Ensuring Hays’s CYRMS is promoted, enforced and reviewed
Providing clear procedures for raising concerns or complaints

Code of conduct for interacting with children & young people

Who Must Comply with this Code?

All temporary workers placed by Hays with host employers that require a WWC Check
All of Hays’ internal employees that place temporary workers that require a WWC Check

Code of Conduct

For each host employer in Queensland at which Hays places temporary workers, and the host employer advises Hays that the temporary worker will directly and/or individually deal with children under the age of 18 on a regular basis (or otherwise requires the temporary worker to obtain a WWC Card), they must have a child and youth risk management strategy.

Hays’ staff and temporary workers must:

Use appropriate language when dealing with children and young people
Not make inappropriate physical contact with any children or young people
Not tolerate bullying, either amongst children and young people, or from adults towards children and young people, including within the host employer organisation
Place the safety and welfare of children and young people above all else
Report all violent and illegal acts
Set a good example for children and young people by the way you dress, speak and act

Recruitment, selection and compliance regarding temporary workers

WWC Checks are most effective when supplemented by child-focused recruitment policies. While the WWC Check process is an assessment of a person’s eligibility to work with children and young people, the recruitment and selection process is the first opportunity to ascertain a person’s suitability to work with children and young people. Our compliance processes then assist us in monitoring temporary workers.

Recruitment & selection
As the leading global recruitment agency, Hays has a robust recruitment and selection process. The goal of this process is to identify and recruit someone who has the skills and attributes to fulfil the role requirements. The selection stage allows the host employer to choose the most suitable candidate for the position. It provides an opportunity to select people who will promote and protect the rights, interests and wellbeing of children and young people. When recruiting temporary workers, any assessment should be based on the position description developed by the host employer for the role and our aim should be to recruit someone who has the skills and attributes to fulfil the role requirements.

Hays’ Critical Processes must be followed in the recruitment of temporary workers.

Compliance
The laws in each State and Territory are different, however ultimately employees who work with children and young people must hold a WWC Check (or an exemption card if applicable) if their work falls into a regulated category of employment.

Since a temporary worker would be considered an ‘employee’ of Hays, even though we do not supervise, direct or control temporary workers whilst they are with a host employer, where the host employer advises Hays that the temporary worker is required to have a WWC Check, Hays will ensure the temporary worker holds a WWC Card regarding each temporary worker.

Depending on the State/Territory, temporary workers who require a WWC Check can commence regulated child-related work once their application has been lodged and while their application is being processed.

Penalties apply for employing someone in regulated employment without a WWC Card.

Temporary workers who do not undergo a WWC Check or hold a WWC Card will not be permitted to deal with children or young people. If a temporary worker’s application for a WWC Check is refused, Hays has the duty to refuse that person’s placement at a client’s site that relates to children and young people.

If a temporary worker’s WWC Check is about to expire whilst on a current assignment with a host employer through Hays, or a temporary worker who is about to commence regulated employment approaches Hays to complete a WWC Check application, in certain States/Territories, Hays may need to complete the application form as the ‘organisation’.

Examples of when WWCC is NOT required (Note: Tasmania is unclear)

State	Yes/No	Details
NSW	No	No check required if you are: A tradesperson who may incidentally come into contact with children but is not working with the children.
WA	No	Ineligible to apply – not in ‘child-related work’: Under section 6 of the Working with Children (Criminal Record Checking) Act 2004: work is ‘child-related work’ if the usual duties of the work involve, or are likely to involve, contact with a child in connection with any of the categories listed in this factsheet UNLESS an exemption applies. Contact includes any form of physical contact, oral communication (e.g. telephone) and electronic communication (e.g. email or internet) but does not include contact between employers, workplace supervisors or volunteer co-ordinators of children and workers whose fellow workers are children (unless they otherwise engage in child-related work). If a person’s only contact with a child is as an employer of a child or as a fellow employee, then that person is not considered to be in child-related work.
QLD	No	A tradesperson who enters school grounds to do work (eg an electrician replacing a light, a plumber fixing pipes or a glazier repairing a window) does not need a blue card, because the work they are doing is for the school, rather than the students. However, if a tradesperson will do any of the above work (or similar) while children are present (eg outside of school hours care, early learning or child care centre), they may need a blue card.
VIC	No	Worker does not need a Check: because the contact with children is incidental to their work. Section 9 of the Working with Children Act 2005 defines child-related work as work in any of the occupational fields, involving contact with a child that is direct and not incidental to the work.
ACT	No	Not all positions in an organisation involving contact with vulnerable people require a Working with Vulnerable People (WWVP) registration. Only those persons who have more than incidental contact in regulated activities or services with vulnerable people need to be registered. *Incidental contact: When a person works in the same building as a vulnerable person but does not have any physical or face to face communication with the vulnerable person. *Regulated activity: activity, service or support provided to vulnerable people in child education services, child accommodation services, child protection services, childcare services, etc etc.
TAS	Possibly	Consumer, building & occupational services: You may need to apply for registration if you: would be expected to have more than incidental contact with children as a normal part of your duties. TAS Dept of Education website: All Department of Education employees, volunteers (including the School Association Committee), contractors and external providers are required to maintain a current Tasmanian Registration to Work with Vulnerable People (RWVP).
SA	No	Using the screening guide on the Dept for Education SA website. Contractors/third party providers to the Dept for Education include: Electricians IT technicians Cleaners, etc Will you be providing contracted services that involve: having contact with or working in close proximity to children on a regular basis supervision or management of people in such positions having access to records of an education or childcare service No screening is required unless otherwise required in the relevant contract or agreement.
NT	No	Dept of Education website: If it is not readily apparent whether a worker may perform child-related work, and the worker does not fall within one of the above categories, the manager must determine the need for an Ochre Card (working with children clearance) taking into account the following if the worker will have any form of physical contact with children if the worker will have any form of verbal contact with children, either face to face or by other means if the worker will have any form of written communication with children Situations must be assessed on a case-by-case basis, always ensuring the wellbeing of children is the paramount consideration.
SA	Compulsory

Online process – all states & territories

Regardless of the state or territory, where are candidate requires a WWC Check or requires verification of their existing WWC Check, this can be achieved via the Service Delivery, Background Checks team.

Consultants should complete the request template, which can be found on FreshService portal here and send to the Background Checks team for processing. The Background Checks team will provide an update as to the progress of the application and update the relevant task in OneTouch with the applicable status.

Where the online process is unable to be followed, please refer to the manual process for each state or territory below.

The Background Checks team can be contacted via raising a FreshService ticket or at 07 3243 3088

Manual process - state & territory specific

Queensland

Hays as an Organisation is not involved in the application process for a QLD Blue Card Registration. The following steps must be followed by Hays when a candidate supplies a QLD Blue Card Registration:

The following steps must be followed by Hays when a candidate supplies their own Blue Card:

Check the card and verify that the name and signature match the candidate’s identification documents
Validate their card online using this link. Please note that once a card’s validity has been determined, the candidate still needs to be linked to Hays as an Organisation
Once a card has been verified and the consultant has confirmed for the card to be linked to Hays. Link the card by using this link

Outcome	Meaning	Outcome
Application pending	Applicant has verified identity but has not submitted an application	Person cannot work with children
Application in progress	Blue or exemption card application is in progress	Person cannot work with children (unless applying for an exemption card)
Valid card + application in progress	Card holder has a valid card and has submitted a renewal application	Person can work with children
Valid card	Blue or exemption card issued and is active	Person can work with children
Valid clearance	Blue or exemption card issued but the card	Person can work with children
No valid card - contact BCS	Person does not have an application in progress, or a valid card	Person cannot work with children
Negative notice	Person has a current negative notice	Person cannot work with children
Disqualified person	Person is disqualified	Person cannot work with children
Card suspended	Blue or exemption card has been suspended	Person cannot work with children

Western Australia

The following steps must be followed by Hays when a candidate is applying for a WWC Check:

The candidate must collect the application form from an Australia Post outlet then bring that application to Hays
An authorised representative will need to complete Parts 5 and 6 and sign the ‘Employer, volunteer organisation or education provider declaration’ of the candidate’s application form
From here the candidate must submit the application in person, along with their identification, to an Australia Post outlet
Request a copy of the application receipt as confirmation and enter this information into the WWC log for Western Australia and upload to their Compliance Portal

The following steps must be followed by Hays when a candidate supplies their own WWC Card:

Request a copy of the candidate’s card
Validate the card online here
Upload to their Compliance Portal

South Australia

The following steps must be followed by Hays when a candidate is applying for a DCSI Check:

The consultant will submit a FreshService request to the Background Checks team
From here the candidate must action the application online
If a candidate requests their identification be validated by the Requesting Organisation the approved Hays Manager must site, the candidate’s original identify documents that add up to at least 100 points and is required to declare that:
- They have sighted and confirmed the applicant's original or certified true copy personal identity documents, and that verification has been achieved using the 100-point check
- They are satisfied as to the correctness of the applicant's identity
- They are qualified to act as a verifying officer

The following steps must be followed by Hays when a candidate supplies a DCSI Check:

Request a copy of the candidate’s check for our records
Raise a FreshService ticket with the copy of the DCSI check to the Background Checks team to validate online here

New South Wales

Hays as an Organisation is not involved in the application process for a NSW WWC Check. The following steps must be followed by Hays when a candidate supplies a WWC Check:

Raise a FreshService ticket with a copy of the WWC Check to the Background Checks team to validate online here

Victoria

Hays as an Organisation is not involved in the application process for a VIC WWC Card. The following steps must be followed by Hays when a candidate supplies a VIC WWC Card:

Request a copy of the candidate’s card for our records
Validate the candidate’s card online here
Remind the candidate that they must add Hays to their list of Organisation on their My Check online account

Australian Capital Territory

Hays as an Organisation is not involved in the application process for an ACT WWVP Registration. The following steps must be followed by Hays when a candidate supplies an ACT WWVP Registration Card:

Request a copy of the candidate’s card for our records
Validate the candidate’s card here

Tasmania

Hays as an Organisation is not involved in the application process for a TAS WWC Registration. The following steps must be followed by Hays when a candidate supplies a TAS WWC Registration:

Request a copy of the candidate’s card for our records
Validate the candidate’s card online here
It is at this point that you can check if the candidate has added Hays as an Organisation. If they have not done so, it can be added on their behalf

Northern Territory

Hays as an Organisation is not involved in the application process for a NT Ochre Card. The following steps must be followed by Hays when a candidate supplies a NT Ochre Card:

Request a copy of the candidate’s card for our records
Validate the candidate’s card online here

Implementing the Policy

All temporary workers who work with children and young people are to receive a copy of the policy upon its adoption and are expected to familiarise themselves with the document.

Monitoring compliance

Compliance with this policy will be monitored by each State/Territory’s management team via regular liaison with temporary workers and Hays’ clients.

Breaches

Hays will review any allegations of breaches of this policy and will take steps to minimise the risk of any further breaches. Penalties can be imposed on Hays with regard to any breaches of the relevant working with children laws in each State/Territory.

Evaluation & review

This policy will be reviewed annually, in line with Hays’s review of its entire Child Protection Risk Management Strategy. The policy will be reviewed with regard given to any aspects of the document that require changes. This review will be carried out by Background Checks, legal and with input from each State/Territory management team.

Induction & training

Any temporary workers that have been successfully recruited and screened and require a WWC Check will be provided a copy of this CYRMS.

Handling disclosures & suspicions of harm

Receiving a disclosure

When Hays’ internal employees or temporary workers are confronted with disclosures of harm or suspect harm to children and young people, they will respond professionally and in the best interests of the child or young person subjected to the alleged harm. Complaints will be dealt with promptly, seriously, sensitively and confidentially. Any Hays internal employee or temporary worker confronted with disclosures of harm will:

Not react in a shocked or critical way
Reassure the child or young person that they have done the right thing in notifying
Say they need to tell someone else who can help the child or young person
Reassure the child or young person that they will only tell someone who will make them safe
Ultimately believe the child or young person and assume that they are telling the truth
Ask only non-leading questions
Only ask the child or young person enough questions to determine the need to report the matter to the Police Service or the relevant Government Department

Dealing with a disclosure

Following a disclosure of harm from a child or young person, the temporary worker must notify the host employer and Hays, and Hays and or the host employer will investigate whether the allegation should be reported to the relevant Police Service or Government Department. If the incident(s) are serious or criminal in nature, Hays’ response should be immediate. All other allegations should be actioned as soon as possible, preferably within 24 hours. For allegations of a serious or criminal nature, Hays will follow these guidelines:

If the allegation involves a child at risk of harm, the incident should immediately be reported to the Police and/or the relevant Government Department
Hays will contact the relevant Government Department for advice if there is any doubt whether the complaint should be reported
If the child’s parent(s) or guardian are suspected of committing the abuse, Hays will report the allegation to the Police or the relevant Government Department immediately

Strict confidentiality, impartiality, fairness and due process must be maintained at all times. Under no circumstances will Hays conduct its own investigations into any serious allegations or allegations of a criminal nature.

Managing breaches of the risk management strategy

Hays will review any allegations of breaches of the CYRMS and will take steps to minimise the risk of any further breaches.

High risk activities and special events

In a labour hire arrangement, Hays as the labour hire company does not have control over the temporary worker or their workplace and the host employer is responsible for supervising, directing and controlling the temporary worker. Therefore, it is important that Hays confirms with the host employer that they have a child protection risk management strategy (in Queensland) and otherwise has relevant procedures in place regarding the protection of children.

Compliance with Legislation

Hays will comply with relevant legislation by ensuring that all relevant temporary workers undergo the WWC Check and obtain proof of their ability to work with children and/or vulnerable people (where exemptions do not apply). Hays will respect the confidentiality of information relating to applications for WWC Checks and will maintain appropriate systems to protect the privacy of applicants.

Employee register
Hays will implement and maintain an employee register that outlines all relevant temporary workers in states where this is a legislative requirement. This must include particulars of:

WWC Card holders or applicants, and
Exemption card holders or applicants

Hays will track all candidates in all states who have provided working with children and/vulnerable people clearance in their system ensuring they have valid registration at all times while engaged with Hays in a temporary work capacity.

Reporting requirements
Hays must advise the relevant WWC government agency if a temporary worker advises us that they have had a change in their police or disciplinary information during the application process or after a WWC Check has been issued.

Hays must not continue to employ the person in regulated, child-related employment until we have submitted a Change in police information notification form. As a listed employer in certain States, the relevant agency will notify us of any suspension or cancellation of the person's WWC Card.

In addition, in Queensland, Hays must advise Blue Card Services if the temporary worker stops working through Hays. Therefore, once a Hays consultant becomes aware that a temporary worker is no longer engaged through Hays, they must notify the Compliance team who will submit a ‘no longer with organisation’ form and update the employee register.

Cancellation or suspension of a WWC Check

If a temporary worker has had a WWC Check cancelled or suspended or receives a negative notice after a change in police information, Hays must:

Ensure the person does not continue to undertake regulated child-related work through Hays, and
If Hays continues to engage the person to perform work that is not child-related, ensure that appropriate policies and procedures are in place to manage any risks of harm to children and young people that may arise as a result of the person's ongoing engagement through the organisation

Strategies for communication and support

Copies of this CYRMS will be made available on the Hays Intranet under the Compliance section and a copy will be provided to Hays consultants who place workers that require WWC Checks and to the associated temporary workers. This will ensure that all of Hays’ relevant consultants and temporary workers understand what is expected of them with regard to providing a safe and friendly environment for children and young people.