Player Safety & Safeguarding Policy

Our commitment

1. Our commitment to child safety

Apex Football Group is committed to creating an environment in which children and young people:

• are treated with dignity and respect;
• feel physically and emotionally safe;
• are listened to and taken seriously;
• are able to raise concerns without fear;
• are protected from abuse, exploitation, bullying and inappropriate behaviour;
• are included and treated fairly; and
• are supported to participate positively in football.

Player welfare and safety take priority over sporting results, competition outcomes or commercial considerations.

2. Child-safe approach

Apex Football Group seeks to operate consistently with the National Principles for Child Safe Organisations.

This includes:

• embedding child safety in organisational culture;
• listening to children and young people;
• involving families in child safety;
• respecting individual and diverse needs;
• ensuring people working with children are suitable;
• maintaining child-focused complaint processes;
• supporting staff with appropriate safeguarding knowledge;
• maintaining safe physical and online environments;
• reviewing safeguarding practices; and
• documenting appropriate policies and procedures.

3. Who this policy applies to

This policy applies to people involved in Apex Super League, including:

• players;
• Apex Football Group coaches;
• employees;
• contractors;
• volunteers where applicable;
• match officials where engaged by Apex Football Group;
• photographers and videographers engaged by Apex Football Group;
• other persons engaged to work with players;
• parents and legal guardians; and
• spectators where relevant.

Anyone engaged by Apex Football Group who works with children is expected to understand and comply with the safeguarding requirements relevant to their role.

The people who work with children

4. Working with Children Checks

Apex Football Group will comply with applicable Western Australian Working with Children Check requirements.

Where a person engaged by Apex Football Group performs child-related work and is required by law to hold or have applied for a Working with Children Check, Apex Football Group will require appropriate evidence before permitting that person to undertake the relevant work, subject to any applicable lawful exemptions.

Apex Football Group may verify relevant Working with Children Check information where appropriate.

A person must not undertake child-related work for Apex Football Group where doing so would breach applicable Working with Children legislation.

A Working with Children Check is one safeguarding measure and does not replace:

• appropriate recruitment;
• supervision;
• professional boundaries;
• safeguarding policies;
• staff education;
• appropriate conduct; or
• the reporting of concerns.

5. Recruitment and suitability

When engaging people to work with children, Apex Football Group may take reasonable steps to assess suitability for the role.

Depending on the position, this may include:

• identity verification;
• Working with Children Check verification where required;
• qualifications;
• coaching experience;
• references;
• interviews;
• consideration of previous work with children; and
• agreement to applicable Apex Football Group safeguarding and conduct requirements.

Apex Football Group may decline to engage or continue engaging a person where there are reasonable child-safety or suitability concerns.

6. Professional boundaries

Apex Football Group coaches, staff and other workers must maintain appropriate professional boundaries with players.

Adults working with children must not use their position to develop inappropriate, exploitative or secret relationships with players.

Interactions should remain appropriate to:

• the person's professional role;
• the player's age;
• the football environment; and
• the legitimate purpose of the interaction.

How adults behave around players

7. Appropriate behaviour towards players

People working on behalf of Apex Football Group must treat players respectfully.

They must not engage in:

• physical abuse;
• sexual abuse or sexualised behaviour;
• emotional or psychological abuse;
• grooming;
• harassment;
• bullying;
• discriminatory abuse;
• humiliation;
• threatening behaviour;
• degrading treatment;
• coercion;
• inappropriate personal relationships; or
• conduct that creates an unreasonable risk to a child.

Coaching may be demanding and competitive, but it must remain appropriate to the player's age and development.

8. Physical contact

Football coaching may involve appropriate physical contact.

Examples may include:

• first aid;
• assisting an injured player;
• demonstrating a football movement where reasonably necessary;
• normal sporting interactions such as handshakes or high-fives; and
• intervention where immediately necessary to prevent injury.

Physical contact must:

• have a legitimate purpose;
• be reasonable and proportionate;
• be appropriate to the circumstances;
• respect the player's personal boundaries; and
• never be sexual, punitive, degrading or unnecessarily invasive.

Where practical, coaches should explain instructional physical contact before it occurs.

9. One-to-one interactions

Apex Football Group seeks to avoid situations in which an adult and a child are unnecessarily isolated from others.

Where individual coaching or discussion is required, it should, wherever reasonably practicable:

• occur in an observable environment;
• take place within view of other people;
• occur at an appropriate sporting venue or setting; and
• avoid unnecessary secrecy.

A one-to-one conversation may sometimes be necessary for legitimate coaching, welfare or safeguarding reasons.

The circumstances should remain appropriate and professional.

10. Communication with players

For junior players, administrative and operational communication should ordinarily occur through the player's parent or legal guardian or through an approved Apex Football Group system.

Apex Football Group workers must not engage in inappropriate secret or highly personal communication with junior players.

Communication should relate to legitimate matters such as:

• football;
• training;
• matches;
• player development;
• scheduling;
• player welfare; or
• other appropriate Apex Super League matters.

Where direct communication with an older junior player is reasonably appropriate, professional boundaries must still be maintained.

11. Social media and private messaging

Apex Football Group workers must not use social media or private messaging to:

• groom a player;
• pursue an inappropriate personal relationship;
• send sexual or otherwise inappropriate material;
• ask a player to keep communications secret from their parent or legal guardian;
• bully or humiliate a player; or
• communicate in a manner inconsistent with their professional role.

Apex Football Group may establish approved communication channels for team or competition purposes.

12. Changing rooms, toilets and private areas

Players are entitled to privacy in changing rooms, toilets, showers and similar areas.

Apex Football Group workers must not unnecessarily enter a private changing area occupied by junior players.

Where access is reasonably necessary because of an emergency, safety issue or legitimate supervisory requirement, appropriate care must be taken to preserve player privacy.

Photography and videography are prohibited in:

• toilets;
• showers;
• changing areas while players are changing; and
• other locations where a child would reasonably expect privacy.

This restriction applies regardless of any media permission provided under the Media & Recording Policy.

13. Photography and videography

Photography and videography relating to Apex Super League are governed by the Media & Recording Policy.

Media permission does not override child-safety requirements.

Apex Football Group will not knowingly create or use media that:

• sexualises a child;
• humiliates or degrades a child;
• unnecessarily exposes a child in a vulnerable state;
• reveals sensitive personal information without an appropriate reason; or
• creates an unreasonable safeguarding risk.

Player safety takes priority over creating promotional or commercial content.

14. Player dignity during media activities

Even where a parent or legal guardian has provided the required media permission, children should be treated respectfully during photography or videography.

A player should not be unnecessarily forced or pressured into an individual staged photograph, interview or similar promotional activity where they are clearly uncomfortable.

This does not prevent ordinary match, training, event or group recording carried out in accordance with the Media & Recording Policy.

Respect, inclusion and being heard

15. Bullying

Bullying is not accepted within Apex Super League.

Bullying may include repeated:

• verbal abuse;
• intimidation;
• threats;
• deliberate exclusion;
• physical behaviour;
• online harassment;
• humiliation; or
• other behaviour intended to harm or control another person.

Players should report bullying to an Apex Football Group coach, staff member, parent, legal guardian or the designated safeguarding contact.

Apex Football Group will consider reported bullying and take appropriate action having regard to the circumstances.

16. Discrimination and inclusion

Apex Football Group seeks to provide an environment in which players are treated fairly and respectfully.

Discriminatory abuse, harassment or vilification is not accepted.

Apex Football Group will seek to reasonably consider the individual needs of players, including where relevant to:

• disability;
• language;
• cultural background;
• family circumstances; or
• other needs affecting safe and meaningful participation.

17. Player voice

Players should feel able to speak up where something makes them:

• uncomfortable;
• worried;
• frightened;
• unsafe;
• confused; or
• concerned about another person.

A player who raises a genuine concern should be listened to seriously and treated respectfully.

Children and young people should not be punished or disadvantaged merely for raising a safeguarding concern in good faith.

18. Parents and legal guardians

Parents and legal guardians play an important role in maintaining a safe environment.

Parents and legal guardians are encouraged to:

• discuss safety with their child;
• make Apex Football Group aware of relevant welfare concerns;
• keep emergency and medical information current;
• raise inappropriate behaviour promptly;
• encourage their child to speak up when uncomfortable;
• comply with the Apex Super League Code of Conduct; and
• respect reasonable safeguarding procedures.

Supervision, collection and medical care

19. Supervision

Apex Football Group will take reasonable steps to provide appropriate supervision during organised Apex Super League activities.

The level of supervision may depend on:

• player ages;
• the number of players;
• the activity;
• the venue;
• environmental conditions; and
• the particular risks involved.

Parents and legal guardians remain responsible for complying with applicable drop-off, pick-up and attendance arrangements communicated by Apex Football Group.

20. Arrival and collection of players

Parents and legal guardians are responsible for ensuring that appropriate arrangements are in place for players to arrive at and leave Apex Super League activities safely.

Apex Football Group should be notified where an issue is likely to materially affect a child's collection or welfare.

A coach should not knowingly leave a young child unattended at a venue because a parent or legal guardian is late.

Where a player has not been collected as expected, Apex Football Group may attempt to contact:

• the parent or legal guardian;
• nominated emergency contacts; or
• an appropriate authority where reasonably necessary for the child's safety.

21. Transport

Apex Football Group does not ordinarily provide individual transport for players to or from Apex Super League activities unless a specific transport arrangement has been expressly organised.

Apex Football Group workers should not routinely transport a junior player alone in a private vehicle without an appropriate reason and parent or guardian knowledge.

Where transport is specifically arranged, reasonable safeguarding and safety measures should be followed.

22. First aid and injuries

Where reasonably practicable, Apex Football Group will maintain appropriate arrangements for responding to injuries during organised activities.

Where a player is injured, reasonable steps may include:

• stopping or modifying participation;
• providing first aid within the responder's competence;
• contacting the parent or legal guardian;
• contacting an emergency contact; and
• contacting emergency services where appropriate.

Apex Football Group coaches and staff are not expected to provide medical treatment beyond their qualifications and competence.

23. Medical emergencies

Where Apex Football Group reasonably believes a child requires urgent medical assistance, player safety takes priority.

Apex Football Group may contact emergency services without waiting for parental approval where delay could place the child at risk.

Parents or legal guardians will be contacted as soon as reasonably practicable.

Recognising and reporting a concern

24. Recognising safeguarding concerns

Safeguarding concerns can arise in many ways.

Examples may include:

• a child disclosing abuse;
• unexplained or concerning injuries;
• significant changes in behaviour;
• inappropriate adult-child boundaries;
• grooming behaviour;
• bullying;
• sexualised conduct;
• concerning online communication;
• allegations regarding a coach or worker;
• unsafe supervision;
• inappropriate physical contact; or
• another circumstance suggesting that a child may be at risk of harm.

No person is expected to personally investigate suspected abuse before reporting a genuine concern.

25. Responding when a child discloses a concern

Where a child raises a safeguarding concern, the person receiving the disclosure should, as appropriate:

• listen calmly;
• take the child seriously;
• avoid blaming the child;
• avoid making promises that the information will remain completely secret;
• avoid unnecessarily interrogating the child;
• record relevant information accurately as soon as reasonably possible;
• report the concern through the appropriate safeguarding process; and
• take immediate action where necessary to protect the child from further harm.

The role of an Apex Football Group worker is not to conduct their own criminal investigation.

26. Reporting safeguarding concerns

A player, parent, legal guardian, worker or other person may raise a safeguarding concern with Apex Football Group.

Concerns should be reported as soon as reasonably possible to the Apex Football Group Safeguarding Contact:

• Vinny, Director
• Email: [email protected]
• Phone: 0468 335 010

A concern may also be raised with an Apex Football Group coach or appropriate staff member, who should escalate it through the applicable safeguarding process.

27. Immediate danger

Where a child is in immediate danger or urgent assistance is required, contact 000.

Apex Football Group may also contact police, child-protection authorities, emergency services or another appropriate authority where reasonably necessary or required by law.

Safeguarding concerns do not need to be resolved internally before urgent external assistance is sought.

28. Concerns involving an Apex Football Group worker

Where an allegation or concern relates to an Apex Football Group coach, employee, contractor or other worker, Apex Football Group will consider appropriate protective action.

Depending on the circumstances, this may include:

• changing duties;
• restricting contact with players;
• additional supervision;
• temporary suspension from relevant activities;
• an internal review;
• obtaining professional advice;
• referring the matter to an appropriate authority; or
• terminating the person's engagement where appropriate and lawful.

A person who is the subject of a safeguarding allegation should not be solely responsible for deciding how that allegation is handled.

How a concern is handled

29. Confidentiality

Safeguarding concerns will be handled with appropriate sensitivity.

Information may be shared with people who reasonably need it for purposes such as:

• protecting a child;
• assessing a safeguarding concern;
• obtaining professional advice;
• managing an allegation;
• complying with legal obligations;
• communicating with authorities; or
• ensuring procedural fairness.

Apex Football Group cannot promise absolute confidentiality where information needs to be disclosed to protect a child or comply with law.

30. Record keeping

Apex Football Group may maintain appropriate records relating to safeguarding incidents, allegations, reports and actions taken.

Records should be:

• accurate;
• appropriately secured;
• accessible only to people with a legitimate need for access; and
• retained having regard to safeguarding, legal, insurance and operational requirements.

Personal information will also be handled in accordance with the Privacy Policy.

31. Reporting to authorities

Apex Football Group will comply with applicable legal reporting obligations.

Where circumstances warrant, safeguarding matters may be referred to organisations including:

• Western Australia Police;
• the Western Australian Department of Communities;
• the Working with Children Screening Unit;
• emergency services; or
• another regulator or authority with responsibility for the matter.

Whether a particular concern must or should be reported externally will depend on the nature of the concern and applicable law.

32. Working with Children Check concerns

If Apex Football Group becomes aware of information affecting a person's eligibility to engage in child-related work, Apex Football Group will take appropriate steps consistent with applicable Working with Children legislation.

A person who is legally prohibited from undertaking child-related work must not be permitted to undertake that work for Apex Football Group.

33. No retaliation

A person should not be subjected to retaliation merely because they raise a genuine child-safety concern in good faith.

This includes players, parents, legal guardians and workers.

This protection does not prevent reasonable action where a person knowingly makes a deliberately false or malicious allegation.

34. Procedural fairness

Safeguarding allegations will be treated seriously.

At the same time, Apex Football Group will seek to act fairly towards all people involved.

Where appropriate and consistent with child safety, a person who is the subject of an allegation may be informed of the substance of the concern and provided an opportunity to respond.

Immediate protective measures may be taken before an allegation is finally determined where reasonably necessary to protect children.

Protective action does not necessarily mean that an allegation has been proven.

Online safety

35. Online safety

Apex Football Group seeks to maintain safe digital environments as well as safe physical environments.

Online safeguarding may include appropriate management of:

• Parent Portal access;
• team communications;
• direct messaging;
• photography and video;
• player information;
• social-media interaction;
• digital accounts; and
• online publication of information concerning children.

Personal information concerning children should only be shared in accordance with legitimate Apex Football Group purposes and applicable policies.

36. Parent Portal safety

Parent Portal accounts are intended for authorised users.

Users must not:

• access another family's private information without authority;
• share another child's private information inappropriately;
• misuse photographs or video obtained through the portal;
• use portal information to bully or harass another participant; or
• interfere with the security of the system.

Apex Football Group may restrict access where reasonably necessary to protect player safety, privacy or system security.

37. Safeguarding and media

The Media & Recording Policy operates subject to this Player Safety & Safeguarding Policy.

Where a media, advertising or promotional objective conflicts with the safety or welfare of a child, the child's safety and welfare take priority.

Conduct, breaches and review

38. Code of Conduct

Players, parents, legal guardians, spectators, coaches and relevant workers must comply with the Apex Super League Code of Conduct.

Behaviour that breaches the Code of Conduct may also constitute a safeguarding issue where it affects the safety or wellbeing of a child.

39. Breaches of this policy

A breach of this policy may result in action including:

• education or guidance;
• a warning;
• increased supervision;
• behavioural conditions;
• removal from a particular activity;
• suspension;
• spectator restrictions;
• termination of a worker's engagement;
• removal from Apex Super League; or
• referral to an external authority.

The action taken will depend on the nature and seriousness of the circumstances.

40. Safeguarding education

Apex Football Group may provide or require safeguarding information, education or training for coaches, staff or other relevant workers.

Safeguarding expectations should be communicated as part of onboarding and reinforced where appropriate.

41. Review and continuous improvement

Apex Football Group may review safeguarding practices periodically and following significant incidents or changes in law or operations.

Apex Football Group may update:

• policies;
• procedures;
• staff guidance;
• risk controls;
• digital practices; and
• training

where reasonably necessary to strengthen child safety.

42. Changes to this policy

Apex Football Group may update this Player Safety & Safeguarding Policy to reflect:

• changes in law;
• updated child-safety guidance;
• operational changes;
• lessons identified through safeguarding incidents;
• changes in technology; or
• improvements to Apex Football Group safeguarding practices.

Material changes affecting existing participants may be communicated where reasonably appropriate.

43. Contact

Safeguarding concerns or questions about this policy may be directed to:

• Apex Football Group
• ABN 34 672 323 867
• Safeguarding Contact: Vinny, Director
• Email: [email protected]
• Phone: 0468 335 010