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.

Child Safety Review national public consultation and FDC implications

FDCQ is urging all Family Day Care services and educators to have their voices heard in the national Child Safety Review consultation currently underway. This important review proposes significant changes to the National Law and Regulations that could have particular implications for the Family Day Care sector.

About the Review

The Australian Government, in partnership with state and territory governments, has engaged Deloitte Access Economics to undertake a Regulatory Impact Analysis (RIA) on proposed changes aimed at improving child safety arrangements in education and care services across Australia. These proposed policy options address recommendations from the Review of Child Safety Arrangements under the National Quality Framework.

Public consultation period

The consultation period is open now and closes on 11 June 2025. This is a critical opportunity for Family Day Care services and educators to provide feedback that will directly inform decisions about regulatory changes that may affect your day-to-day operations.

Key topics under review

The review focuses on 6 key areas, several of which have specific implications for Family Day Care.

1. Management of digital devices

Proposals include restricting the use of personal devices for taking images or videos of children, potentially requiring only service-issued devices to be used. This has particular implications for Family Day Care educators who often use personal devices for both business operations and documentation of children's learning.

2. Child Safety Training

Proposed changes aim to strengthen child protection provisions and introduce nationally consistent mandatory child safety training for all educators and staff.

3. Responding to Educator conduct

Includes making inappropriate conduct an offence, enhancing information sharing about prohibition notices, and expanding regulatory responses to educator conduct.

4. Working with children checks

Proposals seek to provide more nationally consistent approaches to WWCC requirements, including requiring valid checks before commencing roles and reporting changes in status.

5. Physical service environment safety

This includes proposals that would significantly impact Family Day Care services, such as:

Assessing formal boundaries between FDC service premises and the rest of the residence/property
Expanding authorised officers' powers to access all areas of FDC residences and properties
This could particularly affect rural and remote FDC services where properties may be extensive with structures located far from children's play areas

6. Additional recommendations

Includes changes to how Regulatory Authorities identify and monitor related providers, extending limitation periods for proceedings, and improving information sharing with recruitment agencies.

FDCQ's response

FDCQ has formed a working party to review the proposals and prepare a comprehensive submission. However, to ensure our response truly represents the views of our members, we need your input.

Don’t delay, have your say

Your professional expertise and firsthand experience are invaluable to this process. We encourage all Family Day Care services and educators to:

Visit the official consultation website: https://content.deloitte.com.au/ChildSafetyReview
Review the 6 key topic areas and consider how proposed changes might affect your service
Share your thoughts with FDCQ through our anonymous feedback form so your perspectives can be incorporated into our submission
Complete the relevant survey on the CSR website:
- Education and Care workforce survey (for educators)
- Approved Providers, PMCs or nominated supervisors survey

Your feedback will help us develop a submission that accurately represents the Family Day Care sector and advocates for sensible regulation that enhances child safety while acknowledging the unique characteristics of Family Day Care environments.

Deadline reminder

FDCQ’s feedback form will close Friday, 30 May, to allow our Working Group enough time to collate all your feedback and ensure it is incorporated in our final submission.

All responses must be submitted by 11 June 2025. Don't miss this important opportunity to shape regulations that will affect your service.

For questions about the review or FDCQ's response, please contact mailto:enquires@fdcq.au.