Safeguarding policy framework: FA, OCG, MPIO, mandatory reporting

This is the reference article — the legal and policy framework that sits behind safeguarding work in NSW community football. Read this once so you understand the system; refer back when you need definitions. Don't read this during an active concern; go to the escalation workflow instead.

Three frameworks govern child safety in NSW community football:

1. Football Australia National Member Protection Framework

The sport-wide policy that defines:

• The MPIO role (Member Protection Information Officer).
• Member protection obligations of clubs and individuals.
• Conduct standards for registered participants (players, coaches, staff, volunteers).
• The processes for handling complaints and concerns.

Linked from the Football Australia About → Policies page. Football NSW publishes implementation guidance specific to NSW.

2. Children's Guardian Act 2019 (NSW) and the Reportable Conduct Scheme

The state-level legal framework. Defines what is reportable conduct and the obligations on heads of "child-related entities" (your club is one). Reports go to the NSW Office of the Children's Guardian.

3. Child Protection (Working with Children) Act 2012 (NSW)

The WWC framework that gates who can work with children at all in a child-related role. Anyone in a coaching, medical or other child-related role at your club must hold a current WWC. See Working With Children Check basics.

MPIO (Member Protection Information Officer)

• The designated club member responsible for receiving and triaging child protection / member protection concerns.
• Typically a senior club member who is not also a head coach or physio (avoids conflicts of interest).
• Holds appropriate WWC and FA-recognised MPIO training.
• The first internal point of contact for any safeguarding escalation.

Head of entity

• Typically the club president.
• The legally-named "head of the entity" under the Children's Guardian Act.
• Responsible for notifying the OCG when reportable conduct is identified.
• Works with the MPIO on case management.

Mandatory reporters

• Defined classes of professionals (under NSW law) who are legally obliged to report current concerns about risk of significant harm to FACS.
• Includes: registered medical practitioners, registered nurses, registered psychologists, registered teachers, and registered physiotherapists.
• The mandatory reporter must make the report personally — the MPIO can support but not substitute.

You as a physio

• If you're a registered physio, you're a mandatory reporter for current concerns about risk of significant harm.
• For all concerns (mandatory-reporter threshold or not), your role is: document factually, escalate to MPIO immediately, do not investigate.

A safeguarding concern is the broad category — anything that worries you about a child's welfare in the football context.

Reportable conduct is a defined set of behaviours by an employee or volunteer of a child-related organisation (under the Children's Guardian Act):

• Sexual misconduct against, with, or in the presence of a child.
• Sexual offence against a child.
• Behaviour that causes significant emotional or psychological harm.
• Significant neglect.
• Ill-treatment.
• Physical assault.

If a safeguarding concern involves an adult in the football environment behaving in any of those ways, it is reportable conduct and the OCG must be notified by the head of entity (the club president, supported by the MPIO).

Your role as physio is the same in either case: document factually and escalate to the MPIO immediately. The classification is the MPIO's and the head of entity's job.

These are not mutually exclusive. A single incident can require all four reports.

Safeguarding cases are medical-group + MPIO visibility only. This is enforced in the data model — the case rows are RLS-gated so coaches, family, and other admins cannot read them.

You may discuss the case with:

• Your MPIO and back-up MPIO.
• Your head of entity.
• The relevant external agency (FACS, OCG, police).
• An external clinical supervisor for your own welfare (case details anonymised).

You may not discuss the case with:

• The family (until and unless the MPIO advises).
• The coach or other team staff.
• Other parents or club members.
• Anyone outside the necessary professional circle.

You are protected under the Children's Guardian Act 2019 (NSW) when you raise concerns in good faith, regardless of whether they are ultimately substantiated. Mandatory reporters are similarly protected when reporting under the Children and Young Persons (Care and Protection) Act 1998.

Speak to your MPIO. Ambiguity is the MPIO's job to triage, not yours. There is no penalty for raising a concern that turns out not to meet a reporting threshold; there are significant consequences for failing to escalate.

• NSW Office of the Children's Guardian — Reportable Conduct Scheme
• Football Australia — National Member Protection Framework (via the FA About → Policies page)
• NSW DCJ — Mandatory Reporter Guide
• Football NSW — Member Protection page