A complaint about a breach may be raised by anyone.

1. The Church Board is responsible for developing and approving policies to handle complaints. They are responsible for handling major breaches and critical complaints.
2. The Ministry Leader is responsible in the first instance for receiving complaints and handling minor complaints.
3. The Safeguarding Coordinator and Team is responsible for assisting with handling minor complaints.
4. All Staff and Volunteers are responsible for reporting any breaches they become aware of.

Anyone may make a complaint or pass on information that relates to a breach of the Code of Conduct or Vulnerable Persons Safeguarding Policy by Staff or Volunteers of the Church.

Complaints can be reported to the Church Board, a Ministry Leader, a Safeguarding Team member or any Staff or Volunteer. Complaints may be received verbally; however, written outlines of the complaint should be encouraged.

Any complaints received are to be reported to:

• The Ministry Leader, in the first instance. If this is not possible or the complaint is about the Ministry Leader, then report to the Safeguarding Coordinator or Team Member or a member of the Church’s Board.
• The QB Safe Spaces Coordinator and Professional Standards Officer are available to assist churches in the complaints process, or if someone feels uncomfortable making a complaint within the church.

Level 1 Complaints – Minor
Some complaints are minor in nature. Examples of minor breaches include:

• Using inappropriate language or behaviour around Children, Young People or Vulnerable Adults.
• Showing a lack of respect.
• Breaking confidentiality.
• Minor breaches of physical touch (eg: getting caught up in the moment and hugging a hesitant Child or Young Person).
• Initiating or maintaining direct and personal contact on social media.

Level 2 Complaints – Major

Some complaints may be classed as major breaches. Some examples of these include:

• Any allegations of abuse, bullying or harassment by a staff or volunteer.
• Complaints of near misses due to inappropriate behaviour (eg: leader driving unsafe with Children, Young Person or Vulnerable Adults in the car).
• Deliberately disregarding the Ministry Leader’s instructions.
• Repeated complaints of minor breaches.

Level 3 Complaints – Critical

Some complaints may be classed as a critical breach. Critical breaches include anything that
must be reported to Government authorities or may have legal, media or insurance implications.
Some examples of these may include:

• Any child sexual offence complaint against a staff or volunteer.
• Any child protection concern complaint against a staff or volunteer (as per the definition in the Procedure for responding to Child Protection Concerns).
• Engaging in unlawful activities.
• Causing significant harm (eg: death or serious injury) due to negligence.

Procedure for Handling Level 1: Minor Complaints

Any complaint about a Staff or Volunteer which is considered a minor breach of the Safe Spaces Code of Conduct or Safeguarding Policy should be reported and dealt with by the Ministry Leader and the Safe Spaces Team by undertaking the following steps:

Step 1 – Assess the Complaint

On receipt of a complaint the Ministry Leader and Vulnerable Persons Team member must meet to
discuss the complaint, process that will be followed and possible outcomes.

Step 2 – Investigate the Complaint

The Ministry Leader and member from the Safe Spaces Team member will advise the Respondent
about the complaint received against them and request a meeting. An offer will be extended for
them to bring a support person to this meeting if desired.

Step 3 – Communication of Outcome

The Ministry Leader and member from the Vulnerable Persons will meet with the Respondent to
discuss the complaint. In this discussion, they may choose to:

• Re-address policies and procedures regarding the breach.
• Repeat the Church’s approved Vulnerable Persons Training.
• Assign a probationary period for the Staff or Volunteer to correct their behaviour.
• Assign a shadow-leader to assist in mentoring in the correct behaviour.
• Take another course of action deemed appropriate under the given circumstances.

Step 4 – Document the Process

After the meeting, the Ministry Leader and Safeguarding Team member must document the discussions had and corrective actions taken in an Incident Report Form. A copy of this should be given to the Staff or Volunteer, the Church Board and QB Safe Spaces Coordinator -safespaces@qb.org.au.

Because of the seriousness of these matters, Churches are strongly encouraged to contact the QB Safe Spaces Coordinator or QB Professional Standards Officer for assistance and support.

Any complaint about a Staff or Volunteer which is considered a major or critical breach of the Code of Conduct or Safeguarding Policy must be reported to the Church Board (including the Senior Pastor). The Church Governance Group, the Ministry Leader and the Safeguarding Team together will decide on the appropriate course of action which may include:

• Notifying the QB Professional Standards Officer if the complaint received involves a Queensland Baptist Registered Pastor or Recognised Ministry Worker.
• Following the Procedure for Responding to Child Protection Concerns in addition to this
• procedure if the complaint relates to a child protection concern.
• Reporting to the police any knowledge about any criminal activity.

Step 1 – Risk Assessment

In addition to considering or making a report to the relevant authorities, a risk assessment must be undertaken to assess the safety of and risk of further harm to the complainant or any other Children, Young People or Vulnerable adult and identify any reasonable safeguards that need to be implemented to minimise those risks.

The Church must be careful not to prejudice ongoing or any potential future criminal investigations and so may need to implement their risk management strategy and investigation without alerting the person subject to the complaint. Guidance should be sought from the relevant authorities (Government or Police) in these instances.

Subject to the advice of the relevant authorities (Government or Police), if the Church has received a plausible complaint (ie: not clearly false or vexatious) of serious Child Protection Concerns against a staff member or volunteer, then the Church must suspend that person from such duties while the complaint is considered.

Step 2 – Providing Support

The Church must ensure that appropriate support is provided to both the Complainant and the Respondent, which may include:

• Providing them with a contact person to whom they can direct enquiries about the progress
  of the complaint.
• Offering them a support person (of their choosing).
• Providing them with access to counselling or other support services

Step 3 – Appointing an Investigator

The Church Governance Group must appoint a person (or group) to investigate the complaint
(the Investigator) who is free of conflicts of interest.

For any matters relating to any form of harm or abuse of a Child, Young Person or Vulnerable Adult, the Investigator should be external to the Church.

Step 4 – Investigating the Complaint

The Church Governance Group should contact the QB Professional Standards Officer for
assistance and advice in the investigation process.

In investigating the complaint, the Investigator must:

• Act in good faith, without bias and without reasonable delay.
• Collect and document evidence, including conducting trauma informed interviews and taking
  statements from the complainant and other witnesses.
• Maintain a record of all relevant evidence obtained and steps taken in the investigation.

Putting the complaint to the Respondent

The Investigator must put the complaint in writing to the Respondent for their consideration.
In doing so, the Investigator must:

• Set out the complaint with sufficient detail for the Respondent to understand the complaint;
• State the part of the Code of Conduct or Safe Spaces Safeguarding Policy that is alleged
  to have been breached;
• Set out the potential adverse outcomes for the Respondent if there is a finding that the
  Respondent has breached the Code of Conduct; and
• Provide the Respondent with an opportunity to respond to the complaint in writing and
  within a stated timeframe not exceeding 2 weeks.

If, during the investigation, further adverse information is brought forward in relation to the
Respondent, the Investigator will:

• Advise the Respondent in writing of the further adverse information; and
• Provide the Respondent the opportunity to respond to the information.

Writing an investigation report
At the conclusion of the investigation, the investigator must provide a written report which set
out:

• The details of the complaint / allegation.
• The part of the Code of Conduct that is alleged to have been breached.
• The finding of the investigation.
• The evidence relied upon to make the finding, including the response of the Respondent (if
  any) to the complaint.
• A finding about whether the complaint is sustained or not sustained, using the “balance of
  probabilities” as the standard of proof.
• Possible outcomes or consequences that the Church Governance Group may consider
  implementing.

The Investigator’s Report will be provided to:

• The Church Governance Group.
• QB Safe Spaces Coordinator (safespaces@qb.org.au) and Professional Standards Officer
  (pso@qb.org.au).

A summary of the Investigator’s report (considering both confidentiality and procedural fairness)
will be provided to the Respondent with:

• An invitation to respond in writing to the Church Governance Group within a defined timeframe
• Written notice of the possible consequences if the Investigator’s report is accepted by Church Governance Group. This may include suspension, termination from duties for volunteers, termination of employment/appointment for staff. It may also require notice to Police and/or Department of Child Safety, Seniors and Disability Services which may impact Blue Card status.

Determination of Complaint and Outcomes
The Church Governance Group is to consider the Investigation findings and recommendations as presented in the report giving due consideration to all the relevant material available.

If the Church Governance Group decides that a complaint is sustained and the Code of Conduct
has been breached, they are to determine an outcome for the Respondent, which may include,
but is not limited to:

• Termination of the employment/appointment.
• Suspension from the employment/appointment for a period.
• Imposing conditions on the employment/appointment.

If the Church Governance Group does not accept the Investigator’s findings, they should decide whether there is another available finding based on the evidence presented to it, and document their reasons for departing from the Investigator’s finding (and if relevant, propose an alternative outcome for the respondent as above).

Communication of Outcome

The respondent will be informed in writing of the:

• Determination of the complaint.
• Any consequences arising from the determination.
• The reasons for the decision.

The Complainant will be informed of the outcome of the complaint.

The QB Safe Spaces Coordinator and/or Professional Standards Officer will be informed of the
outcome of the investigation.

Record Keeping:
For record keeping requirements, please refer to the requirements detailed in section 7 – Procedure for Record Keeping.

Natural Justice:
Everyone has the right to

• expect justice and to be treated fairly;
• the presumption of innocence until proven otherwise;
• be heard and be taken seriously;
• seek clarification;

No one has the right to

• demand forgiveness.

Duty of Care:
Our duty of care includes

• the safety, care and support of victims, particularly where is a risk of ongoing harm.
• the gentle and loving care of all the parties involved (including secondary parties who may be
  impacted), knowing that these situations increase the level of vulnerability of those involved.
• offering access to a support person for all parties during the process,declaring any conflicts of interest whether personal or professional,
• ensuring that all involved in deliberations are free from any influence that might compromise their independence,
• considering all matters with fairness, impartiality, in good faith and with seriousness,
• dealing with matters in a timely manner,
• awareness of the broad impact of our words, statements, decisions, process and any outcome we may decide on,
• seeking to establish the known facts,
• being honest, telling the truth and being above reproach in all our dealings,
• considering what would Jesus do and what would our church and broader community expect
  from us. We will always seek to represent Christ and his church well,
• seeking reconciliation and/or restoration where possible, but recognising this may be
  improbable, impossible or unwise in certain circumstances (e.g. where there has been abuse).
• maintaining confidentiality of information gained, unless there is a legal requirement to share
  this information. This includes secure storage of any information and reports,
• accurate and adequate record keeping and reporting to QB, government authorities and
  insurance.

Humanity:
We will be mindful that

• there is a difference between remorse (the expression of regret, pain, sorrow or shame)
  and repentance (the slow and deeply personal process of accepting responsibility for the
  consequences of actions).
• every person has the right to be treated with respect, value and dignity regardless of ethnicity,
  gender, sexuality, age, beliefs and social, political or economic status. This is implicit in how
  we believe God views all people.