Government response to the Child Information Sharing Scheme 5-Year Review

Establish a mechanism to capture data that enables an accurate picture of the use of CISS to be developed over time.

Government response: support in part

The Victorian Government acknowledges the importance of gaining an accurate picture of the use of the Child Information Sharing Scheme (CISS) over time.

The Victorian Government is continually improving data reporting from central agencies to key governance committees and will consider opportunities for additional data collection for measuring and understanding the impact of the scheme against short-, medium- and long-term reform outcomes as these relate to child wellbeing and safety. Additional data capture may include, for example, existing systems data or data reported by Information Sharing Entities (ISEs) directly or through rotating consultations with ISEs and their peak representative organisations.

Any such data collection activities will be considered having regard to the impact on services which may detract from the utilisation of CISS and detract from their capacity to provide core services. The Victorian Government does not support adding significant administrative burden on ISEs, for example by introducing mandatory reporting requirements for the scheme.

Prioritise the continued improvement and full rollout of the Outcome Measurement Framework including an accompanying data collection and analysis approach that will improve understanding of the impact of CISS on child wellbeing and safety, which will in turn guide CISS improvement.

Government response: support in principle

The Victorian Government acknowledges the importance of ongoing reform monitoring to assess the impact of CISS over time.

The Department of Education (DE) has developed and implemented an approach to measuring reform outcomes that has minimal impact on workforces. Government will prioritise the work of improving and implementing the Outcome Measurement Framework and strengthen the method of measuring and understanding the impact of the scheme against short-, medium- and long-term reform outcomes as these relate to child wellbeing and safety.

The Victorian Government will consider the approach to additional data collection to inform reform monitoring while having regard to the impact on services and workforces, which may detract from the utilisation of CISS and detract from their capacity to provide core services.

Ensure every ISE has appropriate representative(s) who have undertaken up-to-date CISS training.

Government response: support in principle

The Victorian Government recognises the need to support and empower ISEs to train professionals in information sharing practices and has supported over 47,000 staff to be trained to date.

The Victorian Government will consider ways to further support ISEs to train staff and implement localised approaches, policies and procedures that will enable and enhance information sharing activities, in recognition of the diversity of organisations and service delivery needs.

The Victorian Government will examine the feasibility of supporting ISEs and service sectors to nominate ‘CISS champions’ who can support best practice reform implementation locally, such as through refresher training and improved contact details on the digital ISE listing directory.

With consideration of the permissive nature of the reform which supports localised implementation approaches for information sharing and reducing the potential burden on ISEs, the Victorian Government does not support additional administrative burden on ISEs.

ISEs maintain a CISS training register to ensure information about trained individuals is available to the Department upon request.

Government response: support in principle

The Victorian Government acknowledges the benefits of every ISE having appropriately trained staff to implement CISS within their organisation and notes the active participation of ISE workforces in training to date.

The Victorian Government will consider improvements to the Learning Management System (LMS) and to providing additional refresher training. The Victorian Government will also explore good practice approaches for embedding training into staff induction and onboarding, and whether to further expand the LMS to more workforces. ISE contact information available in the digital ISE listing directory will be refreshed, and consideration will be given to strengthening support through the Enquiry Line which currently assists staff in ISEs with related queries.

With consideration of the permissive nature of the reform which supports localised implementation approaches to support information sharing and reducing the potential burden on ISEs, the Victorian Government does not support additional administrative burden on ISEs.

Strengthen support available to ISEs through implementation activities such as training (mandatory/refresher), support services and communication to ensure all ISEs understand their obligations to report potential breaches of the Act and/or misuse of information.

Government response: support in principle

The Victorian Government acknowledges the importance of supporting staff in ISEs to understand their obligations under the scheme.

The Victorian Government will consider options for strengthening supports available to ISEs, including through communications and the Enquiry Line. The Victorian Government will also consider the feasibility of developing additional resources to support ISEs, including refresher training for workforces.

The Victorian Government acknowledges that CISS is implemented in a devolved manner and that ISEs are best placed to determine their workforce needs regarding localised policies, procedures, and training needs. 

Clarify the CISS complaints process for ISEs wishing to raise concerns or make complaints about non-privacy related matters.

Government response: support in full

The Victorian Government acknowledges the importance of readily available and clear information related to the complaints process for ISEs.

DE currently provides advice to ISEs on the operation of CISS through the Enquiry Line. This includes providing general advice that the complaints process related to non-privacy related matters is devolved and that any complaints may be directed to the respective ISE organisation to be handled in accordance with their complaints processes.

The Victorian Government will review current practice guidance to provide further clarity on existing avenues for complaints regarding non-privacy related matters.

Adopt a place-based approach to change management and supporting ISEs with meeting their CISS obligations and opportunities for information sharing, including providing support to ACCOs and services directly from the Department of Education and partner agencies.

Government response: support in principle

The Victorian Government acknowledges the importance of supporting ISEs in their ongoing implementation of CISS, including ensuring that ISEs have a fulsome understanding of their opportunities for information sharing and obligations under the scheme.

Ongoing change management work is informed by a place-based approach and the Victorian Government will consider options related to how services, including Aboriginal Community-Controlled Organisations (ACCOs), may be supported in future to achieve further embedding of the reform over time.

The Victorian Government will consider how best to support continued implementation of CISS in the Aboriginal service sector in the context of the findings of the ongoing Yoorrook Justice Commission and Treaty negotiations.

To ensure that CISS is embedded to benefit Aboriginal children and their families, the Department should collaborate with Victorian Aboriginal communities to inform how the principles of Indigenous Data Sovereignty and Data Governance can be embedded and understood through CISS, enabling ACCOs and communities to make self-determining decisions about their data.

Government response: support in principle

CISS empowers Aboriginal services to access information and the scheme’s permissive nature allows for the exercise of professional judgement when sharing relevant information in line with the scheme’s requirements. The Victorian Government has, in partnership with the Aboriginal service sector, developed resources to support services in building community confidence related to CISS and determining how their knowledge may be shared.

The Victorian Government acknowledges the importance of a shared understanding of Indigenous Data Sovereignty (Aboriginal Data Sovereignty in Victoria) and pathway for progression of Aboriginal ownership and management of data. The Victorian Government will continue to drive these goals through the national Aboriginal and Torres Strait Islander Health Collaboration and Roundtable as well as through the Victorian Aboriginal Health and Wellbeing Partnership Forum, both of which have a focus on progressing Data Sovereignty.

The Victorian Government acknowledges the importance of aligning reform implementation to the findings and recommendations of the ongoing Yoorrook Justice Commission and to ongoing Treaty negotiations. The Victorian Government recognises the work by the Yoorrook Justice Commission relating to the principles of Indigenous Data Sovereignty and governance and will work towards agreed outcomes from the commission and Treaty negotiations.

The Victorian Government will consider how best to support continued embedding of CISS in the Aboriginal service sector in this context, ensuring that Aboriginal children and their families can further benefit from the scheme.

Develop a program of work (as a monitoring activity within the Outcome Measurement Framework) to better understand the impact of CISS on diverse communities and communities experiencing disadvantage including how any positive impacts of information sharing can be enhanced with any unintended consequences identified. 

Government response: support in full

The Victorian Government acknowledges the importance of engaging with diverse communities and communities experiencing disadvantage to identify any specific implications and to enhance positive impacts for these communities, arising from the implementation of CISS.

The Victorian Government will consider options to improve understanding of impacts on these communities through more targeted activity. Any such data collection activities will be considered having regard to the impact on services which may detract from the utilisation of CISS and detract from their capacity to provide core services. The Victorian Government does not support adding significant administrative burden on ISEs.

Improve ISE confidence and capability in engaging with children and their parents or carers about the benefits of information being shared to promote the wellbeing and safety of children.

Government response: support in full

The Victorian Government is committed to supporting ISEs in developing their confidence and capability in engaging with families in relation to CISS.

To this end, resources, including within the Ministerial Guidelines, to support professionals in engaging with children and families have been developed and are available online to support services prescribed under CISS.

The Victorian Government will consider options for development of further resources for families and children and activities to improve ISE confidence and capability in this area of engagement. 

Include non-government organisations in the CISS governance model, recognising that CISS is designed to extend well beyond Victorian Government entities in its scope.

Government response: support in full

The Victorian Government is committed to continued close engagement with non-government organisations that are implementing or supporting the implementation of CISS.

DE will investigate opportunities to include non-government organisations in the CISS governance model in an advisory capacity.

Work with other governments (particularly New South Wales, South Australia, and the Commonwealth) to enhance information sharing, particularly to promote child wellbeing and safety in border communities.

Government response: support in full

The Victorian Government recognises the value of national and cross-border approaches to information sharing to promote child wellbeing and safety.

Legislative and/or regulatory change would be required to enact cross-border or national child information sharing. Victoria will continue to advocate for national child information sharing reforms to the Commonwealth and at national forums.

The Victorian Government will consider, through its change management strategy and place-based activities, the possibility of continuing its current work to support information sharing in cross-border communities, as well as examine options for legislative and regulatory change.

Determine the appropriate scope for further CISS expansion to remaining sectors that have high involvement with children and families.

Government response: support in full

The Victorian Government acknowledges that CISS currently does not include some workforces that work with vulnerable children and their families, including disability workforces, and private mental health practitioners.

Regulatory change would be required to prescribe additional ISEs under CISS, and appropriate support for those workforces would need to be provided.

The Victorian Government will consider options for future CISS reform implementation, including the possible prescription of additional workforces through legislative and regulatory change.

Consider implementing the improvement opportunities identified by the above recommendations, to further strengthen CISS and support any expansion of ISEs.

Government response: support in principle

The Victorian Government acknowledges the importance of continuous improvement in supporting reform implementation.

The Victorian Government will consider options for providing appropriate support to current and possibly additionally prescribed services, including through appropriately implementing the government response to the recommendations of the 5-year review of CISS.