NSW Reportable Conduct Scheme captures grooming: why child-related organisations must act early

This article discusses child grooming behaviours and safeguarding risks.

This article discusses child grooming behaviours and safeguarding risks.

Grooming is one of the most misunderstood, and potentially harmful, forms of child abuse risk.

It rarely appears overtly abusive in its early stages. Instead, it may present as friendliness, helpfulness or special attention. Because grooming behaviours can be subtle, gradual and easily misread, they are often overlooked until significant harm has occurred.

The NSW Office of the Children’s Guardian (OCG) has made clear that grooming is captured under the NSW Reportable Conduct Scheme, meaning relevant child-related organisations must recognise, record and respond to concerning behaviours appropriately.

For the early childhood education and care (ECEC) sector, the message is clear: child safety systems must focus not only on incidents of harm, but on early warning signs that may indicate escalating risk.

What grooming can look like

The OCG defines grooming as conduct where an adult builds a deceptive sense of trust with a child, or with the adults around the child, to create opportunities for future abuse.

It is often a deliberate pattern of behaviour intended to:

• gain access to a child
• lower a child’s inhibitions
• reduce the likelihood concerns will be believed
• manipulate adults around the child
• normalise boundary-crossing behaviour.

Because grooming can initially appear caring or supportive, organisations are encouraged to assess conduct through a child safety lens rather than relying on assumptions about intent.

Staff do not need to determine whether behaviour is ‘definitely grooming’. They need to recognise when conduct is concerning, inappropriate or inconsistent with professional boundaries.

Why documenting low-level concerns matters

One of the strongest messages in the OCG guidance is the importance of recording concerns early.

A single behaviour may appear minor in isolation. However, when concerns are documented over time, patterns can emerge that indicate a more serious safeguarding risk.

Examples may include:

• favouring a particular child
• giving gifts or special privileges
• seeking unnecessary one-to-one contact
• private communication outside appropriate channels
• crossing physical or emotional boundaries
• attempts to isolate a child from peers or staff.

Accurate documentation can allow leaders to identify escalating concerns and intervene before harm occurs.

What the Scheme requires

The NSW Reportable Conduct Scheme applies to relevant child-related organisations, including many education and care services.

Responsibilities may include:

• notifying reportable allegations or conduct to the OCG
• undertaking fair and timely internal investigations
• maintaining accurate records of concerns and actions
• taking risk management steps during investigations
• supporting a workplace culture where concerns are raised promptly.

The intent of the Scheme is to ensure organisations do not wait for abuse to occur before acting.

Why this matters for ECEC providers

Early childhood services are uniquely placed to notice early behavioural warning signs because educators observe daily interactions, relationships and changes in conduct over time.

However, this only works where staff feel confident raising concerns and leaders respond consistently.

Approved providers and centre managers should regularly review:

• codes of conduct
• child safe recruitment practices
• supervision arrangements
• complaints and escalation pathways
• whistleblower or speak-up systems
• staff training on boundaries and grooming indicators
• record keeping processes.

A culture of safety starts with awareness

Child safety experts continue to stress that grooming is designed to remain hidden.

By helping staff identify concerning behaviours, documenting low-level concerns and acting early, organisations strengthen child safe cultures and reduce the risk of harm.

Grooming is not always obvious, and it may not initially appear criminal.

But under the NSW Reportable Conduct Scheme, grooming behaviours can trigger serious reporting obligations.

For the ECEC sector and all child-related organisations, awareness, vigilance and early action remain essential to keeping children safe.

Access the NSW Reporting Obligations and Processes - A handbook for child-related organisations here.

Support and assistance

If this article raises concerns or distress, support is available:

• 1800RESPECT – 1800 737 732 / 1800respect.org.au
• Lifeline – 13 11 14 / lifeline.org.au
• Bravehearts – 1800 272 831 / bravehearts.org.au
• NSW Office of the Children’s Guardian – ocg.nsw.gov.au
• If a child is in immediate danger, contact Police on 000