CRIS Digital Device Management
PEAK FDC bodies aligned regarding Digital Device Management public consultation submission.
With the Hon. Jason Clare MP due to release a statement later today regarding Child Safety Review and the Consultation Regulation Impact Statement (CSRIS), May 2025, outcomes, it’s timely to highlight the importance of today’s Ministerial safeguarding meeting with particular respect to the united front PEAK FDC bodies held in June 2025 during the public consultation period. Three key sector PEAK bodies, Family Day Care Australia, Family Day Care Australia NSW and Family Day Care Queensland shared a common consensus that any changes to Digital Device Management was “it is imperative… [they] respond to the unique FDC setting and context of service delivery” (National Child Safety Review (2025) FDCQ p4).
CAPTION: The original positions that three organisations took in their June 2025 submissions to the National Child Safety Review (CRIS).
Blanket changes to the management of digital devices without considerations for FDC nuances could result in an array of significant consequential impacts on the home-based care sector. At a glance, this is how the sector’s leading PEAK bodies positioned themselves for their members and the sustainable interests of home-based care in June.
| Organisation | Position on digital devices (for FDC) |
| FDCQ | Support Option 1 (status quo) for FDC, unless a tailored hybrid of Options 2 & 3 can be applied specifically to home-based care “FDCQ supports Option 1—maintaining the status quo for FDC services—unless a hybrid approach combining Options 2 and 3 can be applied across the home-based care sector.” |
| NSWFDCA | Support Option 1. Say Options 2 or 3 would severely impact the FDC sector “The NSWFDCA supports Option 1. The implementation of regulatory Options 2 or 3 would have a severe negative impact on the FDC sector.” |
| FDCA | Support Option 1 (policy-led approach); oppose Options 2 & 3 as unsuitable for FDC “Policy-led, adaptable and proportionate to risk… Options 2 and 3 do not meet these standards in a family day care context.” |
Key arguments supporting each submission
FDCQ
- Home-based realities and cost/feasibility for sole operators.
- Risks can be managed via policy (consents, upload-and-delete, defined exceptions).
FDCANSW
- Educators must have a working phone for emergencies; strict bans create safety and viability issues.
- Services can uphold child safety with permissions, codes of conduct and training.
FDCA
- Options 2/3 are designed for centres, not FDC; risk is better addressed through proportionate policy.
- Significant cost and operational burdens for FDC services without proven safety gain.
Read the full submissions
- FDCQ (PDF) — FDCQ CSRIS submission June 2025
- NSWFDCA (PDF) — NSWFDCA CSRIS submission June
- FDCA (PDF) — FDCA CSRIS submission June 2025
FAQ
- What is “Option 1 (status quo)”?
Keep the current approach (as at June 2025) but require clear service policies for digital devices (Reg 168) — covering capture, storage, deletion, and children’s privacy. - Why not Options 2 or 3 for FDC?
They can be costly and impractical in home-based settings and may not improve safety compared to strong, enforceable policies. - Does this apply to centres?
This page summarises FDC positions. Centre-based contexts differ and may support different options.
About this page
This article summarises submissions lodged in June 2025 to the Child Safety Review CRIS. It records the positions held at that time.
