Child Safety and Wellbeing Policy

Five Castles Pty Ltd trading as Early Education Video Agency (EEVA)

Last updated: 11 December 2024

1. Purpose

Early Education Video Agency (EEVA) works in and around early childhood education environments. This policy sets out how we protect children and young people when we:

Visit centres, kindergartens, schools and community settings
Film and photograph children and young people
Handle, edit and store footage that includes children
Provide digital tools that may involve children's information

Our commitment is to support our clients' work with children, never to place children at additional risk.

This policy is guided by:

The National Principles for Child Safe Organisations
Victorian Child Safe Standards and equivalent child safe frameworks in other states and territories
Legal requirements for Working With Children Checks and other suitability checks for people working with children in early childhood services

2. Scope

This policy applies to:

Directors and employees of Five Castles Pty Ltd trading as Early Education Video Agency (EEVA)
Freelancers, subcontractors, camera crew, editors and other personnel engaged by EEVA
Any person representing EEVA on site at a centre, school or community setting where children are present
Any work that involves children being filmed, photographed or identified in any way
Any handling of footage or digital content that includes children

Where there is any conflict between this policy and a client's existing child safe policies or applicable law, the higher standard of protection for children will apply.

3. Our commitment to children and young people

EEVA has zero tolerance for child abuse, exploitation, neglect or any behaviour that places children at risk.

We commit to:

Prioritising the safety, wellbeing and dignity of children in every decision
Respecting the rights of children to feel safe, be heard and have a say when they are involved in filming
Valuing and respecting Aboriginal and Torres Strait Islander children, children from culturally and linguistically diverse backgrounds, children with disability and children who may be particularly vulnerable
Working in partnership with centres, schools and families to create child safe filming environments
Responding seriously and promptly to any concern or allegation related to child safety

4. Definitions

For the purpose of this policy:

Child or young person means a person under 18 years of age.
Early education environment includes early childhood education and care services, kindergartens, preschools, schools and similar settings.
Crew means any EEVA personnel or contractor who attends a site on our behalf, including camera operators, directors, sound recordists and assistants.
Client means the organisation that engages EEVA.
Parent or guardian includes a person with legal parental responsibility for the child, or other authorised carer as recognised by the client.

5. Child safe principles

EEVA's approach to child safety reflects the National Principles for Child Safe Organisations, including:

Child safety and wellbeing is embedded in leadership, governance and culture.
Children are informed about their rights, participate in decisions affecting them and are taken seriously.
Families and communities are informed and involved.
Equity is upheld, and diverse needs are respected.
People working with children are suitable, supported and skilled.
Processes to identify and manage risk are in place.
Complaints and concerns are taken seriously and responded to promptly.
Ongoing education, training and continuous improvement strengthen child safety practice.

6. Roles and responsibilities

6.1 EEVA Director and Child Safety Contact

The Director of EEVA (currently Arek Rainczuk) is responsible for:

Overall implementation of this policy
Ensuring all crew and contractors understand and follow the policy
Leading responses to any child safety concern related to EEVA's work
Reviewing and updating the policy as laws and regulations change

Contact:
Child Safety Contact
Email: [email protected]
Phone: 0467 676 205

6.2 Crew and contractors

All crew and contractors must:

Hold and maintain appropriate Working With Children or equivalent clearances where required
Follow this policy and any additional child safety rules at each site
Take reasonable steps to minimise risk to children during filming
Report any concerns about a child's safety or inappropriate behaviour to the client's nominated child safety lead and to EEVA's Child Safety Contact

7. Suitability, screening and recruitment

EEVA will:

Require all crew who attend sites where children are present to hold a valid Working With Children Check (WWCC) or equivalent clearance required in the relevant state or territory, or be exempt only where the law clearly allows it and risk has been assessed as low
Keep records of clearance numbers and expiry dates and conduct periodic checks
Consider child safe values and behaviour in recruitment and contractor selection
Provide child safe induction and clear expectations to all crew before they attend a site

If a clearance expires, is revoked or is no longer valid, that person must not attend any child-related site or be placed in child-related work until the matter is resolved.

8. Code of conduct for interacting with children

When working in settings where children are present or involved, EEVA crew must:

Treat children with respect, listen to them and take their views seriously
Use appropriate, positive and professional language at all times
Maintain appropriate physical boundaries and avoid unnecessary physical contact
Never be alone with a child in a closed or isolated space
Never transport children in personal or company vehicles
Never engage in private communication with a child, including on social media or by direct message
Not give personal gifts, food or money directly to children unless this is part of an agreed centre activity and supervised by staff
Not take or keep personal photographs or videos of children on personal devices
Not engage in any behaviour that could be interpreted as favouritism, grooming, bullying or exploitation

If a child becomes upset, distressed or behaves in a way that affects filming, crew must seek assistance from the educator or staff member. It is never the role of EEVA crew to discipline or manage children's behaviour.

9. Planning and risk management for filming

Before any filming involving children, EEVA will:

1. Consult with the client

Confirm the centre's child safe policies and photography rules, including any phone or device restrictions brought in under recent child safety reforms.
Confirm who is responsible for supervising children during filming.
Confirm any children who must not be filmed or identified.

2. Complete a project-specific risk assessment

Identify potential risks to children related to location, layout, crew size, timing and planned activities.
Plan to minimise crowding, confusion and disruption to established routines.
Confirm emergency procedures and who to contact if an incident occurs.

3. Clarify supervision arrangements

Ensure a responsible educator, staff member or guardian is present at all times when children are being filmed or could be filmed.
Ensure crew understand that they must not be the sole adult responsible for children in any space.

4. Brief all crew

Provide a clear pre-shoot briefing on child safe expectations, local rules at the site and any specific restrictions on filming or photography.

10. Consent to film or photograph children

EEVA will only film or photograph children where appropriate consent has been obtained and documented by the client.

10.1 Responsibility for obtaining consent

The client is responsible for collecting and maintaining parent and guardian consent for filming and photography at their service.
EEVA will request written confirmation from the client that appropriate consent is in place and that a list or visual marker is provided for any children who must not be filmed or identified.

10.2 What consent should cover

Consent arrangements should clearly explain:

The purpose of the filming or photography
The types of images and footage that may be captured
The intended uses (for example website, social media, internal training, print materials)
How long the images may be used
Whether footage may be used for EEVA's portfolio and showreel
The right of parents and guardians to withdraw consent, and how this will be managed

EEVA can provide template consent forms on request, but centres should check these against their own legal and regulatory duties.

10.3 Respecting children's participation

Even where parental consent exists, children have a right to:

Decline to be filmed or photographed
Step out of a shot or activity
Ask questions about what is happening

If a child indicates they do not wish to participate, crew will respect this, and the educator or staff member will be informed so they can support the child.

11. Filming and photography practice

When filming in early education settings, EEVA crew will:

Follow all local rules on devices, photography and CCTV that form part of the centre's compliance with child safety reforms and the National Law
Use only approved professional cameras and equipment, not personal phones or private devices, unless explicitly authorised and supervised
Avoid capturing identifying details (such as name tags, school logos, street signs) where parents have not consented to public release
Take particular care around bathrooms, change areas, rest spaces and any other sensitive locations, which will not be filmed
Stop filming immediately if a child shows distress, discomfort or confusion, or if staff request a pause
Avoid staged situations that place children in unsafe positions, on unstable equipment or in risky environments

If children are actively performing, acting or being directed for a commercial production, EEVA will work with the client to determine whether child employment laws and permits apply, and ensure any required permits or approvals are obtained before the shoot.

12. Use of personal devices and social media

EEVA crew must:

Not use personal devices to record, store or share images or footage of children
Not post images or behind-the-scenes content involving children on their personal social media accounts
Only share content involving children in line with the written agreement with the client and obtained consents
Not tag, identify or contact children or young people through social media

Any approved behind-the-scenes content will be captured and published only in line with the centre's policies and explicit written consent.

13. Storage, security and retention of child-related footage

EEVA recognises that video and photographs of children are sensitive information and must be protected.

We will:

Store footage and images containing children on secure systems with appropriate access controls and technical safeguards
Limit access to child-related footage to staff and contractors who need it to perform their role
Use encrypted transfer methods where possible when sharing footage with clients or editors
Retain footage only for as long as is reasonably necessary for the agreed project, legal or insurance purposes, and any additional period agreed in writing with the client
Delete or de-identify child-related material when it is no longer required, or earlier if the client requests deletion and there is no legal reason to retain it

Where footage is held in cloud services or third party platforms, EEVA will take reasonable steps to select reputable providers and configure services to protect confidentiality and security.

EEVA will cooperate with clients to ensure compliance with the Privacy Act 1988 (Cth) and relevant state based privacy and child protection laws, including any obligations that arise when publishing images or recordings of children online.

14. Portfolio and promotional use of children's images

EEVA sometimes uses finished client work in its portfolio, on its website or in professional presentations.

Where children are identifiable in such material, this will only occur when:

The client has confirmed that appropriate parent or guardian consent includes use in EEVA's portfolio or
Specific additional written consent has been obtained for this purpose

If, at any time, a client requests removal of a portfolio piece that identifies a child, EEVA will review the request promptly and remove or edit the material where reasonably practicable.

15. Digital safety in EEVA software and online tools

EEVA provides digital tools that are used by early education providers to support enrolments, communications and related functions.

In these contexts:

EEVA's platform is designed for use by centre staff and parents or guardians, not by children directly
EEVA will configure systems to minimise unnecessary collection of children's personal information
Access controls and user permissions will be set to limit who can see child-related data
EEVA will not use child-related data from the platform for its own independent marketing to parents or children
Any analytics or reporting will use aggregated or de-identified data wherever possible

Centres remain responsible for their own compliance with child safety and privacy obligations when using EEVA's tools. EEVA will cooperate with clients to support safe use of the platform.

16. Reporting concerns, complaints or incidents

16.1 Immediate safety

If any EEVA crew member believes a child is in immediate danger, they must:

Prioritise the child's safety
Alert the nearest staff member or centre leader
Follow the centre's emergency procedures
Notify EEVA's Child Safety Contact as soon as it is safe to do so

16.2 Concerns about child safety

Any EEVA crew member who:

Observes behaviour of an adult or child that raises concerns
Receives a disclosure from a child
Notices an issue with the way filming is being conducted that may compromise child safety

must report this as soon as possible to:

The client's nominated child safety leader or person in charge at the site, and
EEVA's Child Safety Contact

We will document the concern, support the client's processes, and cooperate with any investigation in line with relevant legislation and the client's reporting obligations, including recent reforms that tighten reporting timeframes for incidents in early childhood services.

16.3 Complaints about EEVA

Children, families, staff or community members who have a concern or complaint about EEVA's behaviour or content can:

Raise it through the service directly, which can then contact EEVA, or
Contact EEVA's Child Safety Contact using the details in section 6.1

All complaints and concerns related to child safety will be treated seriously, handled sensitively and recorded securely.

17. Training, communication and awareness

EEVA will:

Provide induction on this policy to all new staff and contractors who may work in child-related settings
Periodically refresh training, particularly when laws or sector standards change
Include child safety expectations in pre-shoot briefings and call sheets
Make this policy accessible on our website and provide a copy to clients on request

We encourage clients to share relevant parts of this policy with their staff, and to brief us on any additional local requirements before filming.

18. Continuous improvement and review

In line with the requirement that child safe policies are documented, implemented and regularly improved, we will:

Review this policy at least every two years, or earlier if there are significant changes to law, regulation or sector standards
Seek feedback from clients on how filming practices can better support child safety
Update procedures, templates and training in light of experience, new guidance and reforms

The updated version of this policy will be published on our website and made available to existing clients.

19. Related documents

This policy should be read alongside:

EEVA Privacy Policy
EEVA Website Terms and Policies
EEVA Project Agreements and Filming Agreements
Client's own Child Safety and Wellbeing Policy
Client's Privacy Policy and Photography / Electronic Devices Policy

20. Disclaimer

This policy describes how EEVA intends to operate as a child safe organisation. It does not replace the legal obligations on early childhood services, schools or other clients, nor does it provide legal advice.

We strongly encourage clients and partners to obtain their own legal advice to ensure their child safety and privacy obligations are fully met in their jurisdiction.

Questions or concerns?
Contact our Child Safety Contact at [email protected] or 0467 676 205