Implementation

2.1 Review questions addressed in this chapter

This chapter responds to the following review questions:

1. Is CISS being implemented within its scope as defined by Part 6A of the Child Wellbeing and Safety Act 2005?
2. What have been the key enablers and barriers to implementation?

2.2 Is CISS being implemented within its scope as defined by Part 6A of the Child Wellbeing and Safety Act 2005?

2.2.1 Scope of CISS as defined within Part 6A of the Child Wellbeing and Safety Act 2005

The legislative framework underpinning CISS has been established and defined by Part 6A of the Act. It outlines the key principles that ISEs are required to follow in sharing confidential information in a timely and effective manner to promote the wellbeing and safety of children. These principles are that ISEs should:

• give precedence to the wellbeing and safety of a child or group of children over the right to privacy
• only share confidential information to the extent necessary to promote the wellbeing or safety of a child or group of children, consistent with the best interests of that child or those children
• work collaboratively in a manner that respects the functions and expertise of each information sharing entity and restricted information sharing entity
• seek and take into account the views of a child and the child’s relevant family members, if it is appropriate, safe and reasonable to do so
• seek to preserve and promote positive relationships between a child and the child’s family members and persons of significance to the child
• be respectful of and have regard to a child’s social, individual and cultural identity, the child’s strengths and abilities and any vulnerability relevant to the child’s safety or wellbeing
• take all reasonable steps to plan for the safety of all family members who are believed to be at risk from family violence
• promote the cultural safety and recognise the cultural rights and familial and community connections of children who are Aboriginal or Torres Strait Islander or both
• seek to maintain constructive and respectful engagement with children and their families.

Part 6A restricts information sharing under CISS to ISEs prescribed through the Regulations. CISS does not apply to all persons in Victoria. As such, CISS’ current scope is significantly determined by the Regulations.

Part 6A also outlines the threshold for sharing information under CISS, any potential offences from improper data sharing and use, protections, records management, and the relationship of CISS with other information sharing and handling acts like FVISS, the Privacy and Data Protection Act 2014 and the Health Records Act 2001.

In determining whether CISS has been implemented within its scope, this Review has focused on the extent to which implementation activities have supported:

1. prescribed professionals to share information through CISS as intended
2. the systems change envisaged by Part 6A and the Program Logic (Appendix A)
3. government oversight of CISS, including monitoring and compliance.

This Review has also discussed the activities undertaken in response to recommendations from the Two-Year Review, and areas of legislative scope which may benefit from further attention.

2.2.2 Supporting prescribed professionals to share information as intended

2.2.2.1 Training for prescribed professionals

Phase One

Phase One face-to-face training was attended by approximately 2,000 participants across 35 training sessions in 25 locations across metropolitan and regional Victoria.^{28, 29} Most attendees were from the former Department of Health and Human Services and their funded agencies (58 per cent), with the second highest being from Family Safety Victoria (23 per cent). In 2019, a further 1,058 participants across the then Department of Health and Human Services workforces participated in face-to-face training.³⁰

Additional workforce-specific training and change management was delivered by the Department of Health, the Department of Justice and Community Safety, Victoria Police and Court Services Victoria.

An online LMS for the Information Sharing and MARAM reforms was launched in December 2018. The platform contains face-to-face, webinar and eLearning training on information sharing developed by the Department as well as training packages for other departments, and it is used by prescribed ISEs.

The LMS supplements, and is complementary to, other resources and materials made available to ISEs through a variety of platforms during Phase One. These are articulated in further detail in Section 2.2.2.2 below.

Phase Two

Phase Two workforces undertook similar training and skills development activities as Phase One workforces (outlined in Section 1.4.2). These activities commenced in March 2020 ahead of the rollout from April 2021. Training and skills development activities are intended to be finalised in June 2025.

Over 2,100 individuals in education workforces attended 56 face-to-face Information Sharing Information Sessions between June 2022 and June 2023. In addition to this, 36,977 professionals accessed training online through the LMS on CISS, FVISS and MARAM. Most professionals who accessed the LMS were from the Department and their funded agencies (56 per cent), with the second highest from the Department of Health and their funded agencies (18 per cent, n=40,103).³¹

The Department also delivers activities for its funded agencies and aims to deliver training and change management activities to approximately 20,000 participants over three stages between January 2020 and June 2024.³² These training programs and modules were refined during Phase Two to focus on meeting specific education workforce needs.³³ The face-to-face and webinar training has incorporated reference to further reforms as they have commenced (e.g., the new Child Safe Standards) and has seen a reduction in duration to the minimum necessary to allow safe sharing. This has seen the length of training required reduce from 1 day, to 4.5 hours, to the current 1.5-hour duration. Workforce-specific training and change management is procured by the Department of Health, the Department of Families, Fairness and Housing, the Department of Justice and Community Safety, Victoria Police and Court Services Victoria.

Alignment of training to the scope of CISS

Sector-specific training developed and delivered to date by each department comprehensively addresses the requirements of Part 6A of the Act, as it outlines definitions, principles and guidance for permitted information sharing under CISS for ISE workforces within their portfolios. The training materials provide information on thresholds for information sharing, who to share information with, when to seek and consider the views of a child and relevant family members, and record keeping. They are supported by relatable case studies and videos where relevant.

The approach to training has enabled key departments and agencies to develop and deliver content that is tailored for their workforces. For example, while the Department has developed WoVG training materials for use across prescribed workforces, it has also developed tailored resources for education workforces.^{34, 35, 36} This specificity has emerged as an enabler for education workforces and agencies to consolidate their understanding of CISS. A survey of the Department’s workforces rated eight of the ten information sharing courses as high on the satisfaction scale. There is an opportunity to ensure tailored training and other materials (e.g., case studies, guidance) for other workforces is made publicly available and therefore, more accessible to ISEs.

2.2.2.2 Resources to support prescribed professionals

A broad range of information about CISS is available through the Victorian Government’s “Information Sharing and MARAM reforms” webpage, including:

• Ministerial Guidelines: The Guidelines explain how prescribed ISEs should handle confidential information responsibly, safely and appropriately under CISS. The Guidelines also set out how the legislative principles of CISS are to be applied.
• Guidance materials: These include organisational readiness guidance to support ISEs to transition policies and procedures within their organisation; user guides for ISEs; tips and factsheets for engaging with children and families about information sharing; checklists for making and receiving requests; record keeping examples; and complaints processes.
• Communications materials: These include fact sheets and flyers.

This is in addition to the ISE database, hosted on a bespoke website, that identifies which entities can share or request information through CISS.

During Phase Two, there was a significant focus from the Department on improving resources available to CISS users and ISEs outside of training activities, as part of the WoVG change management strategy to respond to the findings of the Two-Year Review. Additional resources developed included:

• a Contextualised Guidance and Toolkit resource for ISEs in education and health and wellbeing workforces which complements the face-to-face training and eLearning modules. This resource has been revised into a new toolkit, through codesign with impacted workforces, that was launched in January 2024
• more factsheets developed and released iteratively, including more targeted factsheets for specific sectors, workforces and Aboriginal and Torres Strait Islander communities
• additional case studies and "bright spots" examples, to illustrate how CISS works in practice and share success stories across sectors
• video resources to target service users and build service awareness
• development of guidance on roles and responsibilities within CISS.

Some of these resources were developed through the Supporting Reform in Place project and the CISS Capacity Building Grants program, which are discussed in further detail at Sections 2.2.3.2.1 and 2.2.3.2.2.

Source: The Victorian Aboriginal Children & Young People’s Alliance, CISS Decision Making Tool.

2.2.2.3 Advice and support through the Enquiry Line and email inbox

Phase One

The Enquiry Line is a shared resource that responds to queries related to CISS, FVISS and MARAM. It has been in operation for CISS since September 2018 in line with the prescription of Phase One ISEs. It was originally operated by the Department of Families, Fairness and Housing in 2018 with operation assumed by the Department from 2019.

The Two-Year Review found that the majority of enquiries received by the Enquiry Line between January 2019 and June 2020 related to both CISS and FVISS (39 per cent) or only FVISS (29 per cent), while 11 per cent of enquiries in this time related only to CISS. Of these enquiries, 92 per cent sought to verify ISEs, seek guidance around consent and sharing confidential information, access training or resources, seek guidance around determining the threshold for information sharing, the extent of information sharing, and actions for when an information sharing request is refused.³⁷

Phase Two

The Enquiry Line continued to be operated by the Department throughout Phase Two. Since the Two-Year Review, the Department expanded the system to:

• include phone and email enquiries (to be tracked in Microsoft Excel, which was replaced by professional call tracking software in September 2021)
• extend operational hours
• enhance the data recording system.

Additionally, Enquiry Line staff were supported by an Operations Manual and a Confluence Reference Manual to refer to answers to common questions.

This Review found that use of the Enquiry Line grew significantly compared to the period reviewed in the Two-Year Review, with 12,568 calls and emails managed from January 2021 to September 2023.³⁸

Analysis of the queries data provided relating to the period January 2021 to end of September 2023, reveals that the majority of queries managed by the Enquiry Line related to mandatory reporting (70 per cent), while 15 per cent related to CISS and ten per cent related to Child Link (n=12,568). This data includes enquiries that related to multiple subject areas.

Of the CISS-related enquiries, the majority related to training (74 per cent), including LMS queries, with the next most common category relating to resources, policy, guidance or other support (19 per cent).

2.2.2.4 Stakeholder engagement and communications plans and activities

Phase One

The Department developed the WoVG Integrated Stakeholder Engagement Strategy: CISS and Child Link in 2020. The Strategy describes the overarching communication and engagement approach, key messages, and engagement objectives for CISS and Child Link, with reference to FVISS and MARAM.³⁹

Due to the inter-related reforms reducing family violence and promoting child wellbeing and safety being delivered by different agencies, the Strategy is applicable for the Department, the Department of Health and the Department of Families, Fairness and Housing (including Family Safety Victoria). The Strategy is supported by Engagement Project Plans and Communications Action Plans to drive messaging to key CISS workforces.

Phase Two

The Department developed a dedicated CISS Phase Two workplan across the stakeholder engagement, communications and governance workstreams. Similar to Phase One activities, this plan included FVISS, CISS, Child Link and MARAM activities. This has been further iterated with subsequent communications action plans in 2022-23 and 2023-24, targeting education sector stakeholders.

Some sector-specific or targeted engagement and communications activities were developed through the CIS Capacity Building Grants program, which is discussed in further detail at Section 2.2.3.2.2 below.

2.2.3 Supporting systemic change

2.2.3.1 Family Safety Victoria Sector Grants Program

The Family Safety Victoria Sector Grants Program was introduced in the 2017-18 financial year and provided funding to key representative and state-wide bodies for implementation of the information sharing and MARAM reforms. The program focused on implementation of the information sharing reforms in a family violence context. In 2020-2021, grant funding of $1.5 million was allocated to projects delivering tailored initiatives to key workforces relating to all three reforms.

Grants were accessed by peak/lead bodies including the Centre for Excellence in Child and Family Welfare, Municipal Association of Victoria, Council to Homeless Persons, Victorian Alcohol and Drug Association and the Victorian Aboriginal Child Care Agency (VACCA).

2.2.3.2 CISS Change Program

In response to the Two-Year Review, the Department implemented the CISS Change Program which consists of sectoral and place-based change initiatives to support the awareness, understanding and adoption of CISS in prescribed ISEs and their workforces. The CISS Change Program was supported by a dedicated implementation strategy, funding and regular reporting to the CISSC.

2.2.3.2.1 Supporting Reform in Place project

The CIS Supporting Reform in Place project aims to embed and uplift place-based and cross-sectoral networks of ISEs to facilitate and support information sharing and practice integration around the child and family, including cohorts experiencing vulnerability and disadvantage.

The project’s key objectives include:⁴⁰

• adopting and trialling a place-based approach to embedding CISS amongst ISE workforces
• improving government understanding of CISS implementation and challenges amongst ISE workforces at a local level, across a diverse range of communities
• facilitating, embedding and uplifting cross-sectoral and place-based networks of ISEs
• enabling service system and practice integration around the child and family.

In August 2022, the Department proposed to the CISSC a total of ten implementation locations for the Supporting Reform in Place project across six metropolitan and four regional areas. These locations were chosen from an analysis conducted by the Department on ISE concentration, child vulnerability indicators and local reform activity, and a readiness assessment through consultation with local leaders to identify sites requiring further implementation support.⁴¹ Two priority locations were identified as Doveton (metropolitan) and Robinvale (regional).⁴²

Initial engagement for the Supporting Reform in Place project consisted of a voluntary half-day hybrid “Sharing Places workshop” with the local ISE community. This workshop aimed to bring geographically close ISEs together to promote child information sharing awareness, assess local CISS progress, foster community support, discuss collaboration challenges, share best practices, and establish cross-sectoral connections. This workshop was designed and delivered by VCISECS and a lead local partner, with other key project partners able to provide feedback. 36 attendees attended the Sharing Places workshop in Doveton and 24 attendees attended the Sharing Places workshop in Robinvale in March 2023.

2.2.3.2.2 CIS Capacity Building Grants Program

CIS Capacity Building Grants were accessed by peak/sector bodies including Australian Childcare Alliance Victoria, Australian Primary Health Care Nurses Association, Catholic Education Commission of Victoria, Centre for Excellence in Child and Family Welfare, Centre for Mental Health Learning, Community Child Care Association Inc, Community Housing Industry Association Victoria, Early Childhood Australia (Victorian Branch), Early Learning Association Australia, Municipal Association of Victoria, United Workers Union, VACYPA (under the auspices of the Bendigo and District Aboriginal Cooperative) and Victorian Aboriginal Community Services Association Limited.

The CIS Capacity Building Grants have supported diverse activities including supporting culturally safe information sharing practices, place-based events and awareness raising, communities of practice, and networking and informational activities.

As at May 2023, this program had delivered:

• 191 information sessions to approximately 3,400 attendees
• 200 communiqués to approximately 100,000 people
• 11 sector surveys and gaps and needs analysis
• 59 other resources to support CISS implementation, including case studies, online modules, and guides.

The program also promoted cross-sectoral communities of practice to build linkages between ISEs.

Approximately $3.3 million in funding was allocated through the CISS Change Program over two years,⁴³ noting several initiatives are still in progress and funding may not all have been released or utilised at this stage.

2.2.4 Supporting government oversight of CISS

2.2.4.1 Governance

The governance model established for CISS has been described in Section 1.4.1. Activity updates and risk management are detailed and communicated regularly to key stakeholders through this governance structure. Data and information reported through the CISSC on a quarterly basis is comprehensive. The items included in the reports include (but are not limited to):

• detailed updates and tracking of actions arising from previous meetings (tracked through an action register)
• an update on CISS implementation, containing data from other key agencies (e.g., Department of Health, Department of Justice and Community Safety, Department of Families, Fairness and Housing, etc.)
• updates on implementation activities in response to the recommendations from the Two-Year Review
• a detailed risk register containing mitigation strategies.

However, any form of shared cross-departmental responsibility will always have complexity in alignment and there is still some room for enhancement in these arrangements in the areas of data collection. More information is detailed in Chapter 3.

2.2.4.2 Enforcement

Offences are dealt with in Sections 41ZK, 41ZL and 41ZM of the Act,⁴⁴ prescribing financial penalties, and in some instances, imprisonment, for instances where information is improperly used or disclosed among ISEs, or where unauthorised individuals make use of CISS.

In the implementation of CISS to date, there are limited mechanisms through which the Victorian Government conducts compliance monitoring or enforcement of the offences listed under Part 6A, Division 5 of the Act, noting these offences primarily relate to unauthorised use or disclosure of confidential information received through CISS. Offences do not relate to improper sharing of information under CISS by the original holder of the information, only by the third party with whom the information is shared.

CISS operates as a devolved model, meaning that the onus of identifying and reporting potential breaches rests with ISEs. For non-privacy related matters, complaints need to go through the respective ISE organisation and their complaints process.

Information on the Information Sharing and MARAM website indicates that children and families can make a complaint to either OVIC or HCC about how their information has been used. This is the established pathway for privacy-related complaints. However, in the OVIC’s and the HCC’s privacy guidance for individuals available online, there is limited mention of CISS and it is not clear whether these authorities can take complaints from ISEs or non-ISEs related to information shared through CISS for matters unrelated to privacy or to the individual’s own information (e.g., a professional seeking to report the misuse of information by another professional or escalate an issue about regular refusal of another ISE to share information related to the wellbeing and safety of a child). Furthermore, neither agency has reported on the number or nature of complaints received about CISS in their annual reports, indicating that either this data is not being collected or no complaints have been made that are identifiably related to CISS. Given that CISS operates alongside other schemes and regulatory bodies, the publicly available guidance on the relevant complaints pathway should be improved as the current pathway may lead people to OVIC, HCC, or the Department.

While the Department has not become aware of any instances of improper use of information through CISS to date, it is also the case that there is currently no mechanism through which potential offences can be detected by or reported to the Department. Guidance materials focus on ISE obligations to keep records about complaints and escalation pathways that can be offered to complainants through the OVIC and the HCC. The Enquiry Line’s operations manual makes explicit that they do not take complaints about the use of CISS.⁴⁵ Therefore, the extent to which any risk of improper use of CISS is materialising is unknown.

2.2.5 Progress against Two-Year Review recommendations

Critical to implementing CISS within its scope are government’s efforts to action the recommendations from the Two-Year Review. At a high level, the progress made by the Victorian Government is provided below. For further detail on the Two-Year Review’s recommendations and implementation status, please refer to Appendix D.

2.2.6 Areas of legislative scope requiring further attention

To realise intended outcomes, it is critical that CISS progresses beyond rollout to workforces (noting that there needs to be consideration of prescribing all appropriate and required workforces through further implementation, see Recommendation 13) and evolves to focus also on embedment. The rollout of CISS is a considerable and multifaceted change management task for the Victorian Government. Successful implementation of CISS is dependent on several factors but most critically, on culture change across ISEs. This relies on robust training and communication, collaboration between service providers, and collaboration between service providers and children and families.

2.2.6.1 Place-based approaches

The Victorian Government’s response to the Two-Year Review articulated a vision for dispersed, place-based leadership across ISE workforces to champion the VCIS Reform. This included promoting/supporting distributed leadership for CISS, FVISS, and MARAM, and championing reforms through place-based leaders and place-based approaches to support the Aboriginal service sector and ACCOs. There is an opportunity to develop further place-based reforms associated with CISS in a similar vein to the two place-based sites in Robinvale and Doveton.

2.2.6.2 Activity output data

In line with the design of CISS, reporting of information sharing activities is maintained at the individual ISE level. However, it should be acknowledged that the Department has implemented reporting mechanisms for partner agencies to maintain oversight of information sharing activities occurring in these agencies. As such, there is only a partial understanding of the extent to which CISS is being utilised.

2.2.6.3 Outcomes data

Further to this, the Outcome Measurement Framework is in early stages of implementation. The Outcome Measurement Framework underpins the Department’s MRF.

In 2021, the Outcome Measurement Framework was presented to the CISSC for noting and discussion on the operationalisation of the framework. In late 2021, following consultation with all departments and agencies, the CISSC endorsed the preferred option for the MRF.

In response to the Two-Year Review Recommendations, the Victorian Government committed to developing the MRF. While government has made good progress towards establishing the MRF, further efforts are required to fully develop and implement it. The Outcome Measurement Framework, while an underpinning component, remains in early stages of implementation.

While some outcomes-related data was available to be assessed as a part of this Review, government is currently limited in its ability to measure its progress against the intended medium- and long-term outcomes of CISS and demonstrate the impact of CISS on child wellbeing and safety. Refer to Chapter 3 for further discussion and analysis on progress towards the intended outcomes of CISS.

2.2.6.4 Consistency of CISS implementation activities across workforces prescribed by the Regulations

There was limited data available about efforts to target Phase One workforces in the period since the Two-Year Review. The primary proxy available is sector-specific mapping of accessing the Information Sharing and MARAM LMS, which indicated a high representation of engagement from the education sector (65 per cent of all information sharing eLearns and webinars) and comparatively limited engagement across other sectors, such as direct service health workforces prescribed in Phase Two (11 per cent), and the justice sector (which includes Victoria Police, youth justice, court services, victim services, and numerous funded justice services, who together comprised one per cent of training participants).

The comparatively limited engagement of workers outside the education, early childhood and family violence workforces with the available training resources may indicate that further work is required to increase widespread adoption of CISS. The extent to which these workforces have incorporated CISS training within their broader training and development programs is not known, as these activities are not regularly monitored by the Department or the CISSC.

2.2.7 Conclusion

The Victorian Government has made a significant investment ($97 million over four years) in CISS implementation, focusing on supporting prescribed professionals to share information through CISS as intended. Considering the ambitious nature of the VCIS Reform, activities have comprehensively addressed CISS’ current scope and scale. Some elements of the legislative scope have been prioritised during this initial transition period, which presents opportunities for further focus on monitoring and compliance activities in the future.

2.3 What have been the key enablers and barriers to reform implementation?

2.3.1 Key enablers to reform implementation

2.3.1.1 Multimodal training activities and resources

In the CISS Workforce Survey, 81 per cent (n=87) of Phase One workforces and 80 per cent of Phase Two workforces (n=243) agreed or strongly agreed that the training they received to use CISS was useful and informative. This was reiterated through consultation with both Phase One and Phase Two workforces.

Stakeholders appreciated the ability to choose and tailor training resources and activities based on their preferences and working environments. Stakeholders indicated that the training activities were convenient to access as required. For example, the website and documents helped refresh their understanding of CISS and were saved in their bookmarks bar for easy access. Some education stakeholders also expressed a preference for face-to-face training delivered by the Department which also helped build their networks to share information and noted the impact of training videos to improve understanding of CISS.

Overall, the breadth of available training and resources combined with the ability for ISEs to access those activities and resources that were most relevant to them, enabled an increase in their understanding of CISS. In turn, this increased understanding enabled CISS’ implementation. However, some ISEs experienced barriers when training and resources were designed to be sector-specific (see Section 2.3.1.2 below).

2.3.1.2 Sector-specific tailoring of training and guidance materials

Implementation activities were enabled by delivery of tailored and targeted measures (e.g., guidance specific to the mainstream education and early childhood sector, CIS Capacity Building Grants Program, and CIS Reform in Place Project) to promote organisational awareness and tailored implementation of the reforms. However, this approach created barriers to understanding and using CISS for stakeholders in different contexts.

The Department developed and delivered sector-specific training materials for education professionals. Eighty-eight per cent of education workforces either agreed or strongly agreed that the training they had received was useful and informative (n=133). However, one education professional (Phase Two) observed that current training and guidance is targeted at larger mainstream schools in a metropolitan context, which made it less applicable to rural, small, or specialist schools. Consequently, this professional reported a low-level understanding of CISS and its application within their school’s context.

Seven per cent (n=87) of all respondents from Phase One workforces and eight per cent (n=243) of all respondents from Phase Two workforces disagreed or strongly disagreed that the training received was useful and informative. The information within training materials is high-level and brief which impacts understanding for some professionals. Peak body and education sector stakeholders said that information at the “principle level was good but could be improved at the detail level”.

“The information needs to literally be that target audience. If you’re talking to kindergartens, it must have a kindergarten example. If you’re talking to out of school care, it needs have an out of school care programme context and an example.” – Phase Two education peak body.

The Enquiry Line, CIS Supporting Reform in Place Project and the CIS Capacity Grants are available to support more detailed and contextualised understandings of CISS and tailored implementation in relation to specific work environments and cohort-based needs.

Education stakeholders in the CISS Workforce Survey indicated that if there are knowledge gaps, they are more likely to consult with their peers rather than access additional training materials from the Department. This further indicates that training materials and activities could be more tailored and relevant to deepen understanding of CISS. Advice from the stakeholder consultations, particularly from non-education stakeholders, was that those who did not understand how CISS should be applied in their specific circumstances are less likely to use CISS.

Overall, similar to the findings of the Two-Year Review, tailored and targeted training and guidance enabled some professional groups to implement CISS more effectively, but these same products created barriers for professionals that could not access materials more relevant to their workplace and context. There is an opportunity to ensure tailored materials developed by all departments and agencies is easily accessible (e.g., made available online) for ISEs across different sectors and that a place-based approach to developing local ISE understanding of CISS is adopted more widely.

2.3.1.3 Dedicated resourcing within the Department of Education

Implementation activities have been enabled by dedicated resourcing from VCISECS. This dedicated team has ensured that WoVG implementation activities for CISS have been delivered as communicated and with the appropriate funding and resources. The ability to dedicate resources to the implementation of CISS has resulted in success; 76 per cent of respondents to the CISS Workforce Survey who were asked about their confidence in their understanding of CISS indicated that they feel confident (n=330). This ability to understand CISS and engage as intended can be attributed to the WoVG support provided by the Department.

2.3.1.4 Cultural shift towards information sharing

A clear theme emerging from stakeholder feedback was there has been a cultural shift towards information sharing. However, culture and behaviour towards information sharing varies within and between service sectors. This variability is to be expected and, in many cases is linked to established professional practice and norms within each sector.

In the CISS Workforce Survey, the majority of respondents (64 per cent, n=330) either agreed or strongly agreed that there is more communication and collaboration between service providers through their organisation’s use of CISS.

An enabler to more open and collaborative culture of information between professionals is the strong adoption and use of training materials and resources delivered during implementation. This was more apparent for education professionals in Phase Two who had engaged more with the Department’s training materials and had access to more sector-specific guidance. These professionals are more open and willing to share information under CISS in alignment with intended outcomes. For example, one Phase Two education peak body said: “the training materials have helped professionals think differently about how we engage with families (irrespective of whether it sits under CISS or FVISS).” This appears to reflect a shift in how ISEs in education conceptualise sharing information towards viewing it as one accessible concept facilitated by multiple tools that can positively impact their relationships with children and families.

It should be noted that all professionals, including those in sectors where organisational or cultural barriers existed, reported they either agreed or strongly agreed that they understand when they could share information for child wellbeing and safety (84 per cent, n=330).

Overall, organisational culture remains a key factor in either enabling or tempering effective engagement with the CISS rollout and is likely to continue to impact the adoption of CISS.

2.3.1.5 Child Link implementation

Part 7A of the Act provides for the establishment of Child Link, a digital tool that consolidates and displays information about every child in Victoria, to promote the wellbeing and safety of children. Child Link is an enabler of CISS and operates as one component of the VCIS Reform; however, it can be used with or without CISS. That is, Child Link can be used to access high-level information about a child to facilitate information sharing activities under CISS or for other professional purposes. Child Link became operational in December 2021, with authorised professionals gradually onboarded from 2022.

Many CISS professionals in child protection, maternal and child health, early childhood, and education workforces will be able to access Child Link following their completion of mandatory training. Professions captured under both Child Link and CISS include child protection workers, maternal and child health nurses, early childhood teachers and staff members in school education settings.

The information displayed in Child Link is likely to be a key enabler for CISS amongst professionals who can access both schemes, as Child Link can help users to identify other services engaged in supporting a child that may hold relevant additional information that could be shared under CISS. For example, a professional accessing Child Link could identify that a child in their care is under a child protection order or the details of other services they are accessing, such as their registered school or a Maternal and Child Health service. Another Phase Two education peak body said, “it would really help an educator to proactively share information.”

2.3.2 Key barriers to reform implementation

2.3.2.1 The scale and diversity of CISS workforces

As CISS has been rolled out to more than 8,000 ISEs across multiple service sectors, there are many individual professionals prescribed under CISS providing a wide range of services. The distribution of ISEs according to which department or entity oversees their activities is reflected in Table 2.1 below. The 2020 Regulatory Impact Statement indicated that there were approximately 121,000 prescribed professionals in education workforces, and 108,000 prescribed healthcare professionals.⁴⁸

Table 2.1: Number of ISEs prescribed under CISS

Source: Department of Education

The scale and diversity of the workforces prescribed under CISS has contributed to the complexity involved in implementing CISS. This complexity posed a challenge to implementation.

There is significant complexity involved in harmonising information sharing practices with sector-specific frameworks across a multitude of organisations. The requisite systems-level change relies on process-level changes in each organisation, as well as widespread cultural change. While CISS was introduced with the objective of complementing the practices prescribed in FVISS and MARAM, many CISS practitioners are also subject to other frameworks. Examples of these frameworks include the Key Ages and Stages framework for Victorian Maternal and Child Health services, and the Framework for Improving Student Outcomes for Victorian schools. Services develop their own internal processes and policies outlining the activities their workforces must undertake to comply with these frameworks. These processes could be adapted to incorporate information sharing practices, leading to embedment of CISS across services.

To add to this complexity, significant turnover across all prescribed workforces presents a further challenge for the Department in both rollout and embedment of CISS. For example, in January 2022, the child protection workforce saw 19 per cent turnover.⁴⁹

2.3.2.2 Trust between workforces

A barrier to implementation and adoption of CISS in some workforces was continued perception of tension between CISS and historical privacy-based information sharing schemes. This was particularly apparent in Phase One secondary and tertiary workforces that operate in a more risk-averse environment and the Phase Two healthcare professionals, who have strong competing professional obligations regarding patient confidentiality.

Professionals in child protection, family services, and justice noted they are less likely to consider proactively sharing information for children’s wellbeing and safety. One Phase One child and family safety peak body said: “there’s a bit of reluctance from the change of previous legislation. Service providers are concerned that the information they share could harm the child, compromise the child’s relationship or even be used negatively”.

This may pose a risk to the extent of CISS’ use in these sectors compared to professionals with fewer cultural tensions and sensitivities. One Phase Two health peak body noted that culture change to share information under CISS is “maturing” and “slow”. However, this may ultimately be in accordance with CISS’ intended outcomes, as stakeholders primarily expressed concerns about sharing information where it may not promote the child’s wellbeing or safety (see Section 3.3.9.2 for further detail on culture change).

2.3.2.3 COVID-19

COVID-19 and associated restrictions to manage the transmission of the virus in Victoria coincided with the Two-Year Review’s final round of data collection. The impact of COVID-19 on the community and service providers has been profound, affecting service delivery and placing significant pressure on many of the secondary and tertiary services involved in CISS. This caused disruption to planned implementation initiatives while other priorities required attention. Only 58 per cent of prescribed workforces surveyed in 2020 responded that there had been no change to child information sharing as a result of COVID-19, pointing to a significant proportion of Phase One workforces who reported a change.

Unsurprisingly COVID-19 hindered the rollout and uptake of CISS for both Phase One and Phase Two ISEs. While the rollout of CISS to Phase Two workforces was planned for September 2020, the Department was required to shift rollout to April 2021. In particular, the healthcare workforce who were at the forefront of the COVID-19 response were most impacted. However, there were impacts to other CISS workforces such as the education workforce who were required to shift to remote and virtual learning and the police workforce who were tasked with enforcement of public health measures. While there was alignment in the rollout of CISS and FVISS to their respective Phase Two workforces, the rollout of multiple legislative frameworks and the new Child Safe Standards in 2022 created significant demand on overstretched and under-resourced workforces.

While COVID-19 did not significantly delay CISS implementation activities, as many were designed to be delivered remotely or were able to be rolled out as COVID-19 restrictions and disruptions eased (e.g., CISS Change Program), it did impact services’ capacity to engage with, learn about and implement CISS.

As the COVID-19 response is no longer a focus, the Department must now work with partner agencies and ISEs to refresh training and communication across both Phase One and Phase Two workforces. Phase Two ISEs noted some additional training would be useful as a refresher given their initial training was rolled out during the stressful and distracting period affected by COVID-19. Further, given the turnover across CISS workforces is high, the current training model is unlikely to be sufficient in supporting building awareness and understanding, and embedment and application of CISS in the long-term. A further shift towards a more place-based approach to understanding and using CISS (through all available tools) is likely to be needed.

2.3.3 Conclusion

Several key enablers have facilitated the implementation of CISS, which include the provision of training and resources tailored to workforce sectors and locations. The establishment of Child Link allowed some CISS users to identify other services or individuals supporting a child in a timely manner. Additionally, the dedicated resourcing for CISS implementation within the Department has played a crucial role. Some sectors benefitted from an organisational culture that promotes trust, communication and collaboration within and between different workforces, fostering more timely and proactive child information sharing. A significant challenge in CISS’ implementation arose from the scale and diversity of prescribed workforces, characterised by varied functions, roles and workplaces. COVID-19 further exacerbated these hurdles, causing delays and restrictions in the delivery of specific implementation initiatives, particularly affecting Phase One workforces.

Notes

28 ACIL Allen Consulting, Child Information Sharing Scheme Two-Year Review (December 2020).

29 Ibid.

30 Department of Education.

31 Provided by the Department.

32 Department Training Plan provided by the Department.

33 Ibid.

34 Victorian Government, Child Information Sharing: information for families, carers, children and young people, vic.gov.au (11 November 2022)

35 Victorian Government, Child Information Sharing: caring for all Koorie children in Victoria, vic.gov.au, (15 November 2022)

36 Victorian Government, Hear from the champions of the Child Information Sharing Scheme, vic.gov.au, (18 January 2023)

37 ACIL Allen Consulting, Child Information Sharing Scheme Two-Year Review (December 2020).

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38 Provided by the Department.

39 Victorian Government, Whole-of-Victorian Government Integrated Stakeholder Engagement Strategy: CISS and Child Link.

40 Victorian Government, Whole-of-Victorian Government Integrated Stakeholder Engagement Strategy: CISS and Child Link.

41 Department of Education, Supporting Reform in Place – Initial Implementation Strategy (2022).

42 Ibid.

43 Provided by the Department.

44 Section 41ZK of the Act prescribes penalties relating to the unauthorised use and disclosure of confidential information. Section 41ZL of the Act prescribes penalties (including possible imprisonment) relating to intentional or reckless use and disclosure of confidential information. Section 41ZM of the Act prescribes penalties relating to the false claim that a person is or represents an information sharing entity or restricted information sharing entity.

45 Department of Education, Information Sharing and MARAM Enquiry Line and Inbox: Operations Manual (version July 2023), 22.

46 Department of Education, Child Information Sharing – Caring for all children in Victoria Fact Sheet (2022)

47 Department of Education, Child Information Sharing Flyer (2022).

48 Victorian Government, Regulatory Impact Statement – Child Wellbeing and Safety (Information Sharing) Amendment Regulations 2020 (2019), 78.

49 Victorian Auditor-General’s Office, Quality of Child Protection Data (2022).