For organisations captured by Queensland’s Reportable Conduct Scheme, the Head of Entity plays a critical role in ensuring allegations involving children are managed appropriately.
The position carries significant responsibility for overseeing the organisation’s response, protecting children, ensuring procedural fairness and meeting legislative obligations.
While many operational aspects of an investigation may be delegated to appropriately qualified staff or an independent investigator, responsibility for ensuring the organisation responds appropriately ultimately rests with the Head of Entity.
Understanding this role is essential for schools, childcare providers, disability service providers, sporting organisations, religious organisations and other entities working with children.
Who Is the Head of Entity?
The Head of Entity is the individual who has overall responsibility for the management of the organisation.
Depending on the organisation, this may include:
the Chief Executive Officer;
Managing Director;
Principal;
Executive Director;
Secretary;
Commissioner;
Chief Executive;
Board-appointed Executive Officer; or
another person prescribed under the relevant legislation.
Although the title may differ between organisations, the responsibilities under the Reportable Conduct Scheme remain broadly the same.
Responsibility Cannot Simply Be Delegated Away
While the Head of Entity may appoint others to assist with managing an allegation, accountability for ensuring the organisation responds appropriately cannot simply be transferred.
This includes ensuring that:
child safety is prioritised;
allegations are assessed promptly;
appropriate risk management measures are implemented;
procedural fairness is maintained;
investigations are conducted professionally;
legislative obligations are met; and
appropriate records are maintained.
Delegation of administrative tasks does not remove executive responsibility.
The Initial Response Is Critical
When an allegation is received, the Head of Entity should ensure that the organisation responds promptly and proportionately.
Early considerations may include:
whether any child remains at immediate risk;
whether interim protective measures are required;
whether police or another agency should be notified;
whether evidence needs to be preserved;
whether the respondent’s duties should be modified pending investigation;
whether the matter falls within the Reportable Conduct Scheme; and
whether an independent investigator should be appointed.
Early decisions often have a significant impact on the integrity of the investigation.
Supporting an Independent Investigation
One of the Head of Entity’s most important responsibilities is ensuring the investigation can proceed independently and without interference.
This includes ensuring that investigators have:
access to relevant documents;
access to witnesses;
sufficient authority to conduct the investigation;
appropriate administrative support;
protection from organisational influence; and
adequate time to complete the investigation properly.
Attempts to influence witnesses or investigators may undermine confidence in the investigation and expose the organisation to additional risk.
Maintaining Procedural Fairness
While child safety remains the highest priority, the organisation must also ensure procedural fairness for the person who is the subject of the allegations.
The Head of Entity should ensure that the respondent:
understands the substance of the allegations;
has a genuine opportunity to respond;
is treated respectfully throughout the investigation; and
is not subject to predetermined conclusions.
Fair processes protect both individuals and the organisation.
Maintaining Confidentiality
Reportable Conduct investigations frequently involve highly sensitive information.
The Head of Entity should ensure that information is only disclosed to those who have a legitimate need to know.
Maintaining confidentiality helps:
protect children;
protect witnesses;
protect the respondent;
preserve evidence;
maintain procedural fairness; and
safeguard the integrity of the investigation.
Poor confidentiality can significantly affect both the investigation and public confidence in the organisation.
Governance Responsibilities
A Reportable Conduct investigation is not simply an operational issue.
It is also an important governance matter.
The Head of Entity should ensure that the organisation:
follows its policies and procedures;
complies with legislative requirements;
documents decisions appropriately;
identifies any systemic issues;
considers organisational improvements; and
responds appropriately to identified risks.
Strong governance extends beyond resolving the immediate allegation.
It also involves preventing similar issues from occurring in the future.
Receiving the Investigation Report
Once the investigation is complete, the Head of Entity should carefully consider the investigator’s report.
A professional investigation report should clearly explain:
the allegations investigated;
the evidence considered;
the investigation process;
procedural fairness provided;
findings reached;
reasons supporting those findings; and
any recommendations arising from the investigation.
The Head of Entity remains responsible for determining any organisational response following receipt of the report.
Learning From Every Investigation
Every investigation presents an opportunity for organisational improvement.
Following completion of the investigation, organisations should consider whether changes are required to:
child safety practices;
supervision arrangements;
policies;
staff training;
reporting pathways;
recruitment practices;
risk management systems; or
organisational culture.
A proactive approach helps strengthen child safety while improving governance and accountability.
When Should an Independent Investigator Be Appointed?
The Head of Entity should carefully consider appointing an independent investigator where:
the allegations are serious;
the matter involves a child or vulnerable person;
senior employees are involved;
there is an actual or perceived conflict of interest;
criminal conduct may be alleged;
the investigation is likely to attract regulatory scrutiny;
multiple witnesses require interviewing; or
maintaining public confidence in the investigation is important.
An independent investigation provides confidence that findings have been reached objectively and without organisational influence.
How Regional Queensland Investigations Can Assist
Regional Queensland Investigations conducts independent Reportable Conduct investigations throughout Queensland.
We regularly assist Heads of Entity by providing:
independent investigations;
investigation planning;
evidence preservation;
witness interviews;
procedural fairness management;
evidence analysis;
comprehensive investigation reports; and
practical recommendations to strengthen governance and child safety.
Our investigators undertaking relevant child-related investigations hold current Queensland Blue Cards and understand the obligations imposed on organisations working with children.
We work with schools, childcare providers, sporting organisations, disability service providers, government agencies, religious organisations and not-for-profit organisations throughout Queensland.
Our objective is to establish the facts through impartial, professional and defensible investigations that support informed decision-making.
Contact Regional Queensland Investigations
If your organisation requires independent assistance in responding to a Reportable Conduct matter, Regional Queensland Investigations can assist.
Regional Queensland Investigations
Phone: 1300 870 923
Email: admin@rqinv.com.au
Website: www.rqinv.com.au
Jason King is the Director of Regional Queensland Investigations Pty Ltd. He has a background in law enforcement, compliance, workplace investigations and corporate investigations, assisting businesses and organisations across regional Queensland and the Northern Territory.