Child Information Sharing Scheme
The Child Information Sharing Scheme (the CIS Scheme) expands the circumstances in which professionals and organisations can share information to promote the wellbeing and safety of children. The CIS Scheme was proclaimed in September 2018 under the Child Wellbeing and Safety Act 2005 to enable prescribed organisations and services (information sharing entities) to share confidential information in a timely and effective manner. The first phase of information sharing entities are specified by the Child Wellbeing and Safety (Information Sharing) Regulations 2018 and were proclaimed on 27 September 2018. Phase One is comprised of approximately 28,000 workers representing around 700 entities primarily within the secondary and tertiary sectors. Phase One information sharing entities generally had high level permissions to share information about children and families and, with exceptions such as services working predominantly with adults, the impact of extending these permissions under the CIS Scheme was expected to be minimal.
The CIS Scheme forms part of the child information sharing reforms, together with a web-based Child Link Register currently under development to streamline access to information about participation of children in government-funded programs. It is expected that these reforms will:
- improve early needs and risks identification and support for children and their families
- change a risk averse culture in relation to information sharing
- increase collaboration and integration between child and family services
- support children’s and their families’ participation in services to which they are entitled.
Ministerial Guidelines were developed to support implementation of the CIS Scheme providing more detailed information including about the legislative principles for the CIS Scheme and the threshold for determining use of the CIS Scheme.
The CIS Scheme operates alongside family violence prevention reforms introduced similarly to support effective sharing of information between authorised organisations and services. The Family Violence Information Sharing Scheme (the FVIS Scheme) enables information sharing to facilitate assessment and management of family violence risk to children and adults, and the Family Violence Multi-Agency Risk Assessment and Management (MARAM) Framework guides information sharing under both information sharing schemes where family violence is present. The majority of the Phase One information sharing entities are prescribed under both information sharing schemes and the MARAM Framework. Depending on the circumstances and authorisations, Phase One information sharing entities may use either of the schemes on their own or apply both schemes where family violence is present and there are wellbeing and other safety concerns for children.
Governance arrangements for the CIS Scheme reflects a multi-agency approach consistent with the legislative intent and responsibility for the information sharing reforms. The Department of Education and Training leads the child information sharing reforms in close partnership with Family Safety Victoria, Department of Health and Human Services, Department of Justice and Community Services and Victoria Police. In anticipation of a significantly expanded group of professionals and services with the commencement of Phase Two of the CIS Scheme in the first half of 2021, new governance arrangements provide a strengthened focus on CIS Scheme implementation.
Purpose of this review
An independent review of the operation of the CIS Scheme within two and five years of commencement is required under section 41ZN of the Child Wellbeing and Safety Act 2005. This review represents the two-year review of the CIS Scheme covering the period September 2018 to September 2020. The two-year review was required to:
- Determine to what extent the CIS Scheme has been implemented effectively.
- Identify key enablers and barriers to implementation.
- Determine to what extent the CIS Scheme is achieving its intended outcomes.
- Consider and identify any adverse impacts of the CIS Scheme.
- Assess the success of the prescription of Information Sharing Entities.
- Assess impacts on diverse and disadvantaged communities.
- Include recommendations (as necessary) on any matters addressed in the review.
The review report is structured around these key areas of inquiry.
An independent review of the FVIS Scheme overlapped with this review both in terms of timeframe and information sharing entities. The recommendations of the FVIS Scheme two-year review, tabled in Parliament in August 2020, address shared issues. The recommendations have subsequently been supported in full or in-principle by the Victorian Government.
The review commissioned by the Department of Education and Training was conducted by ACIL Allen Consulting in partnership with Wallis Market and Social Research Centre (Wallis). A program logic developed for the CIS Scheme underpinned the guiding evaluation framework and the collection of qualitative and quantitative information from a variety of new and existing sources. Data collection focused on stakeholder engagement and occurred predominantly at two points in time commencing in July 2019 with follow up in June 2020.
Information gathering focused on establishing attitudes and practices of workforces of prescribed organisations and services (prescribed workforces) to information sharing, the support provided by peak/lead bodies to their respective sectors for effective implementation of information sharing reforms and the extent of change to organisational record keeping processes and systems to facilitate implementation of the CIS Scheme. Data collection methods included surveys, interviews, virtual workshops, document review and case studies.
Implementation of the Child information Sharing Scheme
Initial intensive, face-to-face training for workforces of the Phase One information sharing entities was conducted during October to December 2018. The training approach was informed by a needs analysis and the deliberations of a Child Information Sharing Working Group with membership from relevant areas of government, and consultations with a Training and Practice Advisory Group with expertise across relevant workforces. The training adopted an integrated approach covering content for both information sharing schemes and an introduction to the MARAM Framework. Training was attended by approximately 2,000 participants, 35% of whom attended regional sessions.
Lead agencies driving the reforms considered that the training had served to create an awareness of the CIS Scheme and related information sharing reforms and to inform refinement of the strategic approach to building capacity among the Phase One information sharing entities. Subsequent training developed by partner government departments was tailored to their workforces, and peak/lead bodies were supported to develop sector specific supporting materials and resources. Whole-of-Victorian Government implementation supports for the CIS Scheme are predominantly provided through a variety of platforms managed by the Department of Education and Training. These include eLearning modules, with over 6,000 enrolments to date, Ministerial Guidelines that are legally binding for information sharing entities explaining operation of the CIS Scheme and a dedicated Enquiry Line for queries related to the information sharing reforms.
Utilisation of the Enquiry Line over the 18-month period to June 2020 suggests a growing understanding of the reforms although decreased contacts may also reflect awareness about, and access to a wider range of guidance and learning resources. Approximately 60% of all queries were related to the CIS Scheme, suggesting that the Enquiry Line will be an ongoing valuable source of support for information sharing entities.
In addition, the Enquiry Line could be harnessed to provide a better understanding in ‘real time’ of the nature and proportion of enquiries related to the CIS Scheme and the category of information sharing entity seeking clarification. This information could inform monitoring of the implementation of the CIS Scheme and any gaps in understanding at workforce and service level that might warrant targeted or different support.
|Recommendation ES 1 Enquiry Line Data Collection|
|That operation of the Enquiry Line be funded to accommodate the expansion of information sharing entities under the information sharing reforms, and to facilitate the collection of ‘real time’ data to inform effective implementation of the child information sharing reforms.|
Sector Grants Program
The Family Safety Victoria Sector Grants Program introduced in 2017-18 has provided sector implementation support funding to key representative and state-wide bodies for implementation of the information sharing and MARAM reforms. The Sector Grants Program focuses on implementation of the information sharing reforms in a family violence context. Whilst the activities supported by the Grants Program have benefited operation of the CIS Scheme, peak/lead bodies have not had the resources to bring a similar focus to the CIS Scheme and its wider application. Feedback from peak/lead bodies indicates that there is continuing work to successfully embed the CIS Scheme in prescribed organisations and services.
The Sector Grants Program has demonstrated the value of supporting targeted initiatives for key workforces in promoting effective implementation of reforms. There is opportunity to better leverage the support of peak/lead bodies in complimenting other efforts to promote early intervention and prevention through improved child information sharing. This support would be especially timely in also facilitating collaboration between peak/lead bodies representing sector workforces prescribed in Phase One of the CIS Scheme and proposed for Phase Two.
|Recommendation ES 2 Sector Support|
|That support be provided to sector peak/lead bodies, similar to the Family Safety Victoria sector grants, to strengthen the response to sector-specific needs of information sharing entities in understanding and applying the CIS Scheme in a range of circumstances and to promote cross sector collaboration and consistency.|
Perspectives of prescribed workforces
Feedback in 2020 through open-ended questions in the follow up 2020 workforces survey and workshops with prescribed organisations and services, suggests that CIS Scheme training and supporting resources continues to be a priority issue for prescribed organisations and services.
An area of continuing challenge for a number of information sharing entities has been interpretation of the concept of ‘wellbeing’ associated with use of the CIS Scheme which suggests a lack of confidence in the capacity for professional judgement in determining application of the CIS Scheme and highlights the varied familiarity of information sharing entities with child-focused practice frameworks. While universal services to be prescribed under Phase Two of the CIS Scheme are familiar with wellbeing frameworks, this is not the case for many Phase One prescribed workforces with a risk focus and adult user group. In addressing this concern, It was considered necessary to balance the original intent of the legislation regarding the importance of the breadth of circumstances relevant to wellbeing, while providing additional guidance to workforces on how they should assess and understand wellbeing for the purposes of the CIS Scheme.
|Recommendation ES 3 Assessing Threshold for ‘Wellbeing’|
|That further guidance be provided for prescribed workforces regarding expectations associated with ‘promoting child wellbeing’ under the CIS Scheme. That this further guidance be informed by an audit of state-wide and sector specific resources with the aim of identifying guidance gaps, particularly in relation to promoting a shared understanding of child wellbeing and risk thresholds, and child and family service system roles and responsibilities in relation to child wellbeing.|
|Recommendation ES 4 Strengthening capacity of phase one workforces|
|That change strategies and ongoing training of information sharing entities related to the information sharing reforms continue to develop capacity among Phase One prescribed workforces and to facilitate integration of practice between Phase One and Phase Two prescribed workforces. This could be facilitated through workforce forums developed in collaboration with peak/lead bodies, and through support for local and place-based networks across sectors and promotion of local champions.|
Embedding the CIS Scheme in policies and guidelines
Given the complexity and legislative requirement for implementation of the CIS Scheme it has been important for prescribed organisations and services to ensure that internal policies and guidelines support their workforces in the appropriate sharing of information. Among prescribed workforces surveyed in 2019 who identified that their organisations did have policies on sharing child information prior to commencement of the CIS Scheme, there was mixed perceptions of the policies’ currency and value in enabling information sharing. Change at follow up survey in 2020, however, included a larger proportion of respondents reporting that the policies were up to date (85%, an increase from 65%), were sufficiently flexible and provided clear guidance on permission to share. There was a reduction in the perception that policies sometimes hinder early identification of needs or prevention of issues.
In relation to their understanding of how to share information, there was an increase in survey respondents who considered that they were aware of their legal responsibilities (from 74% prior to commencement of the scheme to 83% at follow up in 2020) and who knew where to go for guidance on information sharing (from 67% to 85% at follow up).
While there are positive indications of an improved level of workforce understanding of, and receptiveness to information sharing, there is a continuing conservative position regarding willingness to promote information sharing where it may be of benefit. This position supports stakeholder feedback about the evolving nature of the culture change that needs to occur and the further work to be done to embed the CIS Scheme in practice.
Information sharing entity systems and processes support monitoring of implementation of the CIS Scheme
Prescribed organisations and services were expected to leverage their existing systems to meet the record keeping requirements under the CIS Scheme. A selection of prescribed organisations and services were asked about whether there had been a need to make changes to their record keeping systems in anticipation of, and subsequent to introduction of the CIS Scheme.
Nearly three-quarters (74%) of organisations (n=54) indicated that changes had been made to record keeping arrangements in response to the CIS Scheme. Some of the changes made in preparation for the CIS Scheme included developing forms, improving and updating processes, updating client management systems, improving data protection processes, and developing spreadsheets to hold new information.
The Ministerial Guidelines provide a list of required information for record keeping, which is set out in the Child Wellbeing and Safety (Information Sharing) Regulations 2018. Organisations surveyed in 2019 about their record keeping were asked about the extent to which they adhered to the list of required information in relation to each of the key activities in information sharing. Required information relating to the category of receiving a request had the highest rate of compliance with 74% of respondents reporting that all mandatory items were recorded. The remaining categories relating to information requirements for responding to a request, voluntary disclosure, and receiving and responding to a complaint, had an appreciably lower level of full compliance.
Required information for record keeping provides information sharing entities with an important source of internal monitoring of effective implementation of the CIS Scheme and an ability to assess any improved outcomes for children and their families. If capacity allows, the information collected by information sharing entities could potentially be aggregated by government to enable measurement of the contribution of the CIS Scheme to the intended outcomes, such as earlier intervention and prevention.
|Recommendation ES 5 Compliance with record keeping requirements|
|That CIS Scheme partner government departments work with information sharing entities in their respective sectors to promote compliance with the legislated record keeping obligations under the CIS Scheme, as explained in the Ministerial Guidelines.|
More recent feedback from prescribed organisation and services highlights ongoing refinement of processes and tools to support the information sharing entity’s commitment to taking responsibility for children. This has included amendment to intake forms for services that deal predominantly with adults to record any involvement of children and consent forms that raise client awareness of information sharing schemes.
A consistent conversation across services to ensure that service users are aware of and understand the information sharing reforms is important to effective implementation of the CIS Scheme and the ongoing process of engagement with service users and consumers (individuals, families and communities) more broadly.
|Recommendation ES 6 Service User Awareness|
|That training modules and templates identify information sharing entity responsibility for, and provide resources to support a consistent approach to service user awareness of the information sharing reforms and ensuring they understand their implications, the obligations of information sharing entities and the service user’s rights.|
There was little change reported by workforces in their perception of the level of effort needed to align their organisation’s practices, procedures and systems to the CIS Scheme over the period of the two workforces surveys. The average ranking of level of effort was 6.2 at baseline and 6.4 at follow up (0=very little effort and 10=extremely high level of effort; n=194). This result supports qualitative feedback from stakeholders that adjusting systems to the CIS Scheme has been ongoing in the period since commencement of the CIS Scheme, and that for many organisations, this has not been an inconsiderable effort.
Enablers and barriers to implementation
A wide range of enablers to effective implementation of the CIS Scheme through ensuring workforce skills and knowledge were cited by information sharing entities. These included:
- building workforce understanding of the legislative basis for information sharing to improve confidence in applying the CIS Scheme
- having an identified person with responsibility for implementation of the CIS Scheme
- translation of policy into practice including alignment with other policies, frameworks and guiding principles
- promotion of ongoing (experiential) learning through communities of practice.
Insights into barriers to effective implementation of the CIS Scheme because of a lack of workforce capability are provided by workforces surveyed in 2020 about the main reason for not requesting information. This largely derives from insufficient knowledge of the CIS Scheme. Other challenges experienced included:
- lack of practice in applying a child-focus
- lack of familiarity with the culture of other organisations
- privacy perceptions.
Activities delivered by information sharing entities to enable practice change
A range of innovative approaches have been developed by prescribed organisations and services to support practice change among their workforces. This has involved embedding training in relevant existing training programs, making the language around the CIS Scheme more accessible, enabling awareness of children in their work, and identifying professionals/leaders available for secondary consultations.
There should be a process for capturing and disseminating examples of approaches to supporting workforce practice change, such as the potential for proactive sharing. At a minimum, this could be demonstrated through a series of case studies that have regard for the structure, size and location of organisations and services.
|Recommendation ES 7 Disseminating approaches to practice change|
|That good practice case studies across a range of contexts be identified and shared through a variety of media, including through innovation workshops and published material.|
Achievement of intended outcomes
A number of positive outcomes were achieved in the implementation of the CIS Scheme. These included a perception among workforces that legal restrictions and organisational policies that inhibited information sharing had decreased, and that they were less likely to refuse a request for information after the introduction of the CIS Scheme. Privacy was also less likely to be cited as a reason to be used for refusing requests for information.
There were also early signs of cultural shift among workforces towards early intervention and prevention. Evidence provided by stakeholders indicated a greater willingness of their workforce to consider information sharing in cases which would have been perceived as not of sufficient concern to warrant information sharing prior to the CIS Scheme. Workforces were also beginning to look beyond their traditional sources of information to consider how other sources of information could supplement their case assessment and planning. However, these efforts were sometimes curtailed by the fact that workforces were not necessarily aware of who to seek information from, or with which services it would be appropriate to share information.
There was also evidence that workforces from different sectors were collaborating and coordinating better as a result of the CIS Scheme. Collaborative activities were evidenced at a broad range of levels, including between peak/lead bodies, leadership of individual prescribed organisations and services, and among individual workers.
It will be important to continue to enable Phase One secondary and tertiary services to actively seek opportunities to participate in child information sharing for purposes of promoting child wellbeing and safety. The implementation of Phase Two of the CIS Scheme should include strategies to strengthen existing and new efforts to leverage from the engagement with families and children of secondary and tertiary services, to optimise the extended support that might be available for shared clients.
|Recommendation ES 8 Role Clarity in collaborative practice|
|That the implementation of Phase Two of the CIS Scheme includes strategies to strengthen collaboration between universal, secondary and tertiary services (that is, Phase One and Phase Two information sharing entities) around a child, to optimise benefits for the child, and to reinforce the contribution of Phase One prescribed workforces.|
In relation to the level of information sharing activity, as there is no systematic reporting of information sharing activity, and there are numerous informal ways to share information, it was not possible to conclude at this time whether the implementation of the CIS Scheme had made an impact on the level of information sharing.
In relation to individual child outcomes, it was too early to say whether the CIS Scheme had made a significant impact. While there were some examples of good practice, the data available did not provide a clear indication of positive outcomes for individual children. However, stakeholders felt confident that the CIS Scheme provides a strong foundation for improved outcomes for child wellbeing and safety.
While the achievement of some early outcomes is promising, stakeholders also provided feedback that the CIS Scheme is not a simple implementation of a policy or program, but rather requires a paradigm shift in the way services consider the needs of the child in their everyday practice. Continued support and education will be necessary to achieve this cultural shift and embed child-focused practice across all sectors of service delivery.
Unintended adverse impacts
Stakeholders who participated in the data gathering activities occasionally raised unintended impacts of the CIS Scheme, which were predominantly either positive or neutral. There were a small number of unintended adverse impacts that relate to perceived disruption to previous workable arrangements for information sharing. Generally, however, the perceived impacts could be considered short term disruption to pathways for information sharing with a view to enhancing the quality and extent of information sharing through a more rigorous and transparent process.
Most stakeholders appreciated that the CIS Scheme augments the information sharing capabilities of information sharing entities. However, the fact that the CIS Scheme augments, rather than replaces, any existing information sharing processes or standards (such as the Child Safe Standards, Mandatory Reporting Requirements or Reportable Conduct Scheme) should continue to be reinforced through ongoing education and communications.
|Recommendation ES 9 Clarifying relationships to other legislation and standards|
|That consideration be given to providing material to reinforce how the CIS Scheme interacts with other existing legislation and standards, such as the Child Safe Standards, Mandatory Reporting Requirements and Reportable Conduct Scheme, and how these relate to information sharing entities in different sectors, to ensure adherence to the intent of mechanisms available to facilitate child information sharing. Such an approach can highlight where the CIS Scheme provides additional information sharing powers over existing legislation and standards, providing clarity on when and how to use the CIS Scheme.|
While the potential for inappropriate use of the CIS Scheme was a concern raised by stakeholders at commencement of the CIS Scheme, there were no examples of inappropriate use or complaints arising out of implementation of the CIS Scheme encountered during the data collection for this Review. Nonetheless, this continues to remain a risk and the potential for inappropriate use should be actively monitored at organisational and state-wide levels.
Success of prescription of information sharing entities
In considering the impact of the proposed information sharing reforms, it was intended that the phased implementation of the CIS Scheme would involve both government and non-government organisations and align to implementation of the FVIS Scheme to reduce any confusion amongst the workforce and community. The significant overlap of workforces prescribed under both information sharing schemes has provided a logical framework for integrated training but has also highlighted practices that can be strengthened to ensure the successful implementation of the CIS Scheme. Lessons identified by respondents to the follow up workforces survey include reinforcing the importance of routinely gathering accurate information, formalising standards for information collection and developing processes for documenting information sharing occasions and outcomes. Some respondents indicated that they would have liked prescription of information sharing entities to be broader to widen the opportunities for earlier intervention and prevention, however, there was recognition of the increased level of effort that would have been required and the potential for other barriers to have been created to effective implementation.
It could be expected that initial engagement of Phase One information sharing entities in the CIS Scheme will ensure that these services, acutely aware of how unsustainable downstream support is and the impact of entrenched and intergenerational disadvantage, can champion prevention and earlier intervention initially within secondary and tertiary services and ultimately among services operating across the continuum of care. Further support and time is required to ensure that Phase One information sharing entities fully operationalise the CIS Scheme and can work effectively with an expanded CIS Scheme to improve equity of outcomes for children and young people.
Impacts of the CIS Scheme on diverse and disadvantaged communities
The CIS Scheme forms part of a larger toolkit available to information sharing entities to promote the wellbeing and safety of all children in Victoria, with an emphasis on targeted supports for disadvantaged populations. There are a wide range of Commonwealth and Victorian policies, guidelines and frameworks that support the design of services, including workforce knowledge and skills, to respond to the needs of diverse populations with a view to improving access to specialist and mainstream services. Change through service provider policies and practices aims to reduce discrimination, embed cultural responsiveness, foster social inclusive practices, offer healing and trauma informed care and access to language services. It could be expected that the extent of the impact of the CIS Scheme on diverse and disadvantaged communities will be in part a measure of how well the CIS Scheme is utilised and in part reflective of how well services are engaging with diverse communities. The ability to monitor and evaluate the impact of the CIS Scheme on outcomes for diverse and disadvantaged communities will require a more rigorous approach to data collection.
|Recommendation ES 10 Measuring contribution of the cis scheme in responding to the needs of diverse and disadvantaged communities|
|That CIS Scheme partner government departments consider the adequacy of the current minimum record keeping requirements of the CIS Scheme, including as they inform the role of the CIS Scheme in responding to the needs of diverse population groups.|
|Recommendation ES 11 Engaging diverse and disadvantaged communities|
|That CIS Scheme partner government departments engage diverse and disadvantaged groups through sector and advocacy peak bodies and information sharing entities, to understand any specific barriers to the implementation of the CIS Scheme and use these findings to assist information sharing entities to overcome these barriers.|
Implementing the CIS Scheme for Aboriginal and Torres Strait Islander communities
While Aboriginal stakeholders consulted as part of this project broadly expressed support for the CIS Scheme, a key issue reported in the successful implementation of the scheme for Aboriginal community controlled organisations (ACCOs) has been barriers related to lack of trust among community members because of the legacy and abiding harm of past experiences relating to child services. There is a need, therefore, to continually educate and reassure families and communities on the objectives and intended outcomes of the CIS Scheme. However, this requires a significant investment of time and effort from the ground up, beginning with the development of culturally appropriate resources for the CIS Scheme.
While stakeholders were cautious about the pace of implementation of the CIS Scheme among Aboriginal organisations and service providers, they were also confident that the CIS Scheme will lead to better outcomes for Aboriginal women and children.
|Recommendation ES 12 Cultural safety|
|That CIS Scheme partner government departments continue to work with and support the Aboriginal service sector to provide community engagement to ensure Aboriginal communities have a good understanding of the CIS Scheme, and to ensure that cultural safety is taken into account at all stages of using the CIS Scheme.|
|Recommendation ES 13 Culturally appropriate resources to support implementation of the CIS scheme in Aboriginal communities|
|That CIS Scheme partner government departments work with Aboriginal lead bodies to develop culturally appropriate training and support materials for the effective implementation of the CIS Scheme in Aboriginal communities, both by Aboriginal-specific and mainstream information sharing entities.|
 Aboriginal and Torres Strait Islander people may be also referred to in this report as Aboriginal people
Reviewed 30 March 2021