Police Check / Probity Policy

Safeguarding Framework  |  Worker Screening  |  Probity Assessment

Issued by	Ethical Hire  |  ABN 77 679 399 001
Version	2.0
Last Updated	June 2026
Replaces	Version 1.0 (March 2026)
Applies to	All Workers, Providers, Clients, Participants, Coordinators and Authorised Representatives using the Ethical Hire Platform
Next Review	June 2027 (or earlier if required by legislative or regulatory change)
Policy Owner	Compliance and Safeguarding Team

 

1. Background and Purpose

Ethical Hire is a safeguarded digital marketplace that connects Participants, Clients, Providers, and independent Workers — including disability support workers, aged care workers, nurses, allied health professionals, support coordinators, and other care and support providers.

Ethical Hire is committed to promoting the rights, safety, wellbeing, dignity, and independence of all Participants and Clients, including people with disability, older Australians, and children. We recognise our responsibility to implement effective, proportionate, and risk-based safeguards that reduce the risk of abuse, neglect, exploitation, violence, misconduct, and other harms.

This Policy sets out:

• The screening, probity, and verification requirements applicable to Workers using the Platform;
• How Ethical Hire assesses criminal history information and other compliance matters;
• The processes for suspension, restriction, or removal from the Platform; and
• How Ethical Hire handles sensitive personal information obtained through screening processes.

This Policy forms part of Ethical Hire’s broader safeguarding and risk management framework and supports compliance with applicable Australian legislation, including the National Disability Insurance Scheme Act 2013 (Cth), NDIS Practice Standards, NDIS Code of Conduct, and the Aged Care Act 2024 (Cth) and Aged Care Rules 2025.

 

Key Legislative Context From 1 November 2025, new worker screening obligations apply to all aged care workers under the Aged Care Act 2024 (Cth) and Aged Care Rules 2025. These rules require all aged care workers, including contractors and digital platform workers, to hold a valid police certificate (issued within 3 years) or NDIS Worker Screening Clearance (issued within 5 years). Ethical Hire’s requirements reflect and go beyond these minimum obligations.

2. Scope

This Policy applies to all Workers who provide, or seek to provide, Services through the Ethical Hire Platform, including:

• Disability Support Workers
• Aged Care Workers
• Registered Nurses and Enrolled Nurses
• Allied Health Professionals
• Support Coordinators and Specialist Support Coordinators
• Personal Care Workers
• Domestic Assistance Workers
• Community Access Workers
• Social Workers and Therapy Assistants
• Any other independent service provider using the Platform

This Policy applies regardless of the Worker’s employment arrangement, visa status, or engagement model, and regardless of whether services are funded through the NDIS, Home Care Packages, Support at Home, Commonwealth Home Support Programme (CHSP), private funding, or other arrangements.

3. Ethical Hire’s Responsibilities

Ethical Hire is responsible for:

• Implementing, maintaining, and communicating this Policy and associated procedures;
• Reviewing and verifying compliance documentation submitted by Workers;
• Maintaining accurate records relating to screening and verification activities;
• Conducting risk assessments where adverse screening information is identified;
• Taking reasonable steps to support Participant and Client safety through proactive compliance monitoring;
• Managing suspensions, restrictions, or removals from the Platform where safeguarding concerns arise;
• Displaying verification indicators on Worker profiles where appropriate, to assist Users in making informed engagement decisions; and
• Handling personal information in accordance with the Privacy Act 1988 (Cth), Australian Privacy Principles, and Ethical Hire’s Privacy Policy.

Consistent with Ethical Hire’s Terms and Conditions, Ethical Hire operates as a digital marketplace that facilitates connections between Users. While Ethical Hire undertakes screening and verification processes, responsibility for making final engagement decisions rests with the engaging Participant, Client, Provider, or authorised representative.

4. Zero Tolerance

Ethical Hire adopts a zero-tolerance approach to the following conduct by any Worker:

• Abuse of any kind, including physical, emotional, sexual, or financial abuse
• Neglect
• Exploitation
• Violence, including domestic and family violence
• Harassment, intimidation, or bullying
• Discrimination on any protected attribute
• Grooming behaviours
• Sexual misconduct
• Unauthorised restrictive practices
• Fraud or financial misconduct
• Any conduct inconsistent with the NDIS Code of Conduct

Workers who engage in, or are reasonably suspected of engaging in, any of the above conduct will have their Platform access immediately suspended pending investigation, and may be permanently removed from the Platform.

5. Screening Requirements for Workers

To be activated and remain active on the Ethical Hire Platform, all Workers must meet the following requirements.

5.1  Nationally Coordinated Criminal History Check (Police Certificate)

All Workers must obtain and provide Ethical Hire with a valid Nationally Coordinated Criminal History Check (NCCHC, also referred to as a National Police Check or police certificate), issued for the purpose of paid employment with children and/or vulnerable people, prior to their profile being activated on the Platform.

Additional requirements:

• The NCCHC must be issued within the previous 3 years (consistent with aged care requirements under the Aged Care Rules 2025);
• Workers must renew their NCCHC every 3 years, or more frequently if required by law, regulatory direction, or at Ethical Hire’s reasonable request;
• Ethical Hire reserves the right to request an updated NCCHC at any time where concerns arise regarding Participant safety, regulatory compliance, or safeguarding risks; and
• Workers who have lived or worked overseas after the age of 16 may be required to provide additional international criminal history documentation or statutory declarations in accordance with applicable requirements.

Note: Police Certificate vs NDIS Worker Screening Clearance Workers who hold a current NDIS Worker Screening Clearance are not required to also hold a police certificate for the purposes of aged care obligations under the Aged Care Rules 2025. However, Ethical Hire may still require a police certificate for risk management and NDIS compliance purposes. Please contact the Compliance Team if you believe this exemption applies to you.

 

5.2  NDIS Worker Screening Check

Workers delivering NDIS-funded supports must obtain and maintain a valid NDIS Worker Screening Check where required under applicable legislation or NDIS Practice Standards. The NDIS Worker Screening Check:

• Is valid for 5 years from the date of issue;
• Is a nationally recognised clearance administered by state and territory worker screening units;
• Includes real-time monitoring — all linked employers (including Ethical Hire) can monitor a Worker’s clearance status in real time; and
• Is not required for Workers delivering exclusively non-NDIS supports, unless required by Ethical Hire or the engaging Provider.

Workers must link their NDIS Worker Screening Check to Ethical Hire’s registration to enable ongoing compliance monitoring.

5.3  Working with Children Check (WWCC)

Workers who provide, or wish to provide, services to children under the age of 18 must hold a current Working with Children Check (WWCC) relevant to their state or territory of work. A WWCC cannot be accepted as a substitute for a police certificate.

WWCC requirements by state and territory:

State/Territory	Responsible Body	Valid For	Notes
NSW	Office of the Children’s Guardian	5 years	Mandatory for child-related employment
VIC	Working with Children Check Victoria	5 years	Mandatory for child-related work
QLD	Blue Card Services	3 years	Blue Card required
SA	Department of Human Services	5 years	Screening clearance required
WA	Department of Communities	3 years	WWC Card required
TAS	Consumer, Building & Occupational Services	5 years	Registration to Work with Vulnerable People
NT	NT Government	2 years	Ochre Card / clearance required
ACT	ACT Government	3 years	Registration required

5.4  Working with Vulnerable People (WWVP) Card

Workers based in Tasmania or the ACT must hold a valid Working with Vulnerable People (WWVP) Registration as required by local legislation.

5.5  AHPRA Registration

Workers who are registered health practitioners (including nurses, physiotherapists, occupational therapists, psychologists, and others regulated under the Health Practitioner Regulation National Law) must maintain current AHPRA registration. Workers must:

• Provide Ethical Hire with evidence of current registration before activation;
• Ensure registration is renewed in accordance with AHPRA requirements; and
• Immediately notify Ethical Hire of any AHPRA investigation, restriction, suspension, or cancellation.

5.6  First Aid Qualification

All Workers are required to hold a current First Aid certificate from an Australian Registered Training Organisation (RTO) prior to profile activation. First Aid certificates must be kept current and renewed as required.

5.7  Other Licences, Registrations, and Insurance

Workers must maintain all licences, registrations, qualifications, and insurances relevant to the services they provide, including but not limited to:

• Relevant professional registrations and qualifications;
• Public liability and professional indemnity insurance (where required); and
• Any state-based licences or clearances applicable to their services.

6. Obtaining Required Checks

Nationally Coordinated Criminal History Checks (NCCHC) must be obtained through an ACIC-accredited provider approved by Ethical Hire, or through a provider accepted by Ethical Hire’s compliance requirements. Ethical Hire will advise Workers of the preferred or approved providers through the Platform’s onboarding process.

Workers must upload valid compliance documentation through the Ethical Hire Platform. Documentation is verified by Ethical Hire or a trusted third-party verification partner (such as Cited or equivalent) prior to profile activation. Verification may take 24–72 hours.

7. Ongoing Obligations and Notifications

Workers must immediately notify Ethical Hire — and in any event within 24 hours of becoming aware — of any of the following:

• Any criminal charge, summons, arrest, or conviction;
• Any suspension, revocation, cancellation, or restriction of their NDIS Worker Screening Clearance, WWCC, WWVP, or AHPRA registration;
• Any safeguarding investigation, reportable incident allegation, or worker screening investigation involving the Worker;
• Any regulatory proceeding, compliance action, or disciplinary action commenced by the NDIS Commission, AHPRA, a Professional Registration Board, the Aged Care Quality and Safety Commission, or any other regulatory body;
• Any conduct that may be inconsistent with the NDIS Code of Conduct or Ethical Hire’s Code of Conduct; or
• Any change in circumstances that may affect the Worker’s suitability to provide services.

Failure to notify Ethical Hire as required may result in immediate suspension and removal from the Platform, in addition to any other action Ethical Hire considers appropriate.

8. Precluding and Disqualifying Offences

Certain criminal history information will result in automatic preclusion from the Platform. The following categories of offences are treated as precluding offences consistent with requirements under the Aged Care Rules 2025, NDIS Worker Screening Rules, and applicable state and territory legislation:

Category	Examples of Precluding or Serious Offences
Offences against persons	Murder, manslaughter, assault causing serious harm, kidnapping, stalking, threats
Sexual offences	Sexual assault, rape, indecent assault, child sexual abuse, production/possession of child exploitation material
Child-related offences	Any offence involving the abuse, exploitation, grooming, or trafficking of a child
Offences against vulnerable persons	Abuse, neglect, exploitation, or financial abuse of a person with disability or older person
Financial / dishonesty offences	Fraud, theft, embezzlement, money laundering, serious dishonesty offences
Drug trafficking	Drug trafficking resulting in a term of imprisonment
Weapon offences	Unlawful possession or use of firearms or dangerous weapons

Workers with precluding offences will not be approved for access to the Platform. Where a precluding offence is identified after profile activation, the Worker’s access will be immediately suspended and the account closed.

Note on Aged Care Specific Precluding Offences Under the Aged Care Rules 2025, certain offences automatically preclude a person from aged care work, including: conviction for any offence involving the death of a person; and conviction and imprisonment for 1 year or longer within the past 5 years for a sex-related offence, certain assault offences, or offences involving dishonesty or harm to a child. Ethical Hire applies these requirements to all Workers delivering aged care services through the Platform.

9. Assessment of Non-Precluding Disclosable Court Outcomes

Where a Worker’s police certificate discloses court outcomes that do not constitute precluding offences, Ethical Hire will conduct a fair, transparent, and risk-based assessment of those outcomes to determine suitability for Platform access.

Ethical Hire will not unlawfully discriminate on the basis of criminal history. However, Ethical Hire may determine that a person is unsuitable to provide services through the Platform where identified risks are inconsistent with Participant safety, safeguarding obligations, or the inherent requirements of care and support work.

Factors considered in the assessment include:

• The safety and wellbeing of Participants and Clients, which is the primary consideration in all assessments;
• The unsupervised nature of many support environments;
• The nature, seriousness, and circumstances of the offence;
• Whether the offence involved a child, person with disability, older person, or other vulnerable individual;
• Whether the offence involved an abuse of trust, authority, or a position of care;
• Whether the offence involved financial exploitation, fraud, or dishonesty;
• The relevance of the offence to the services being provided;
• Any pattern of offending behaviour;
• The age of the Worker at the time of the offence;
• The time elapsed since the offence;
• Evidence of rehabilitation, including any professional conduct history;
• Employment, professional, and character history;
• Findings from worker screening units, AHPRA, professional registration boards, or other regulatory bodies;
• Findings arising from safeguarding investigations or reportable incident processes; and
• NDIS Commission compliance actions or Aged Care Quality and Safety Commission findings.

Where adverse disclosable outcomes are identified, Ethical Hire may contact the Worker to seek additional information prior to making a determination. Workers will be given an opportunity to provide relevant context where it is appropriate to do so.

10. Suspension and Safeguarding Action

Ethical Hire may immediately suspend, restrict, or remove a Worker’s access to the Platform where:

• An NDIS Worker Screening Clearance is suspended, revoked, cancelled, or subject to an exclusion;
• A Working with Children Check is suspended, revoked, or restricted;
• An AHPRA registration is suspended, cancelled, or subject to conditions relevant to safeguarding;
• A serious criminal charge is laid against the Worker;
• A safeguarding investigation, reportable incident allegation, or worker screening investigation is underway;
• Regulatory or compliance action is commenced by a government authority; or
• Ethical Hire reasonably believes that continued access to the Platform may present a risk to the safety of Participants, Clients, Workers, or the broader community.

Such action may be taken on an interim basis while investigations are ongoing and is not a final determination of unsuitability. Ethical Hire will communicate with affected Workers regarding the outcome of any investigation, to the extent permitted by law and consistent with Ethical Hire’s privacy obligations.

11. Record Keeping

Ethical Hire maintains records relating to screening and verification activities in accordance with applicable privacy legislation and the following minimum retention periods:

• Records relating to aged care workers (including police certificates and NDIS Worker Screening Clearance details): minimum 7 years, including after the Worker leaves the Platform — consistent with the Aged Care Rules 2025;
• Records relating to NDIS workers: as required by NDIS Practice Standards and applicable legislation; and
• Other screening records: minimum 7 years, or as otherwise required by applicable law.

Records maintained for each Worker include name, date of birth, address, type and reference number of each clearance, issue and expiry dates, verification details, and any statutory declarations.

 

12. Confidentiality and Privacy

Ethical Hire handles all screening and compliance information in accordance with the Privacy Act 1988 (Cth), Australian Privacy Principles (APPs), applicable state and territory privacy legislation, and Ethical Hire’s Privacy Policy.

Information obtained through NCCHCs, NDIS Worker Screening Checks, WWCCs, and other compliance documentation will only be used for legitimate screening, compliance, safeguarding, and risk management purposes.

Ethical Hire may engage trusted third-party verification providers to assist with compliance checks and document verification. Where appropriate, Ethical Hire may display verification status indicators (such as ‘Verified’ badges) on Worker profiles to assist Users in making informed engagement decisions, without disclosing the content of underlying screening information.

13. Relationship to the NDIS Code of Conduct

All Workers using the Ethical Hire Platform are expected to conduct themselves in a manner consistent with the NDIS Code of Conduct. Workers must:

• Act with respect for individual rights, autonomy, dignity, and self-determination;
• Respect the privacy and confidentiality of Participants and Clients;
• Deliver supports and services safely and competently, with appropriate care and skill;
• Act with honesty, integrity, and transparency;
• Take all reasonable steps to prevent and respond to violence, abuse, neglect, exploitation, discrimination, harassment, and sexual misconduct;
• Promptly report concerns relating to Participant safety where required by law; and
• Comply with all applicable legal, professional, and regulatory obligations.

14. Relevant Regulatory Findings

When assessing a Worker’s suitability to access or remain on the Platform, Ethical Hire may consider findings and actions from the following bodies:

• NDIS Quality and Safeguards Commission (including investigations, findings, and compliance actions);
• State and Territory Worker Screening Units (including screening decisions and exclusions);
• AHPRA and professional registration boards (including conditions, suspensions, and cancellations);
• Aged Care Quality and Safety Commission;
• State and Territory safeguarding bodies;
• Reportable incident investigation outcomes;
• Tribunal and court findings relevant to safeguarding or professional conduct; and
• Other relevant regulatory or professional oversight bodies.

15. Definitions

Term	Definition
NCCHC / Police Certificate	A Nationally Coordinated Criminal History Check issued by the AFP, a state/territory police service, the ACIC, or an ACIC-accredited organisation.
NDIS Worker Screening Check	A nationally recognised assessment used to determine whether a person poses a risk to people with disability, administered by state and territory worker screening units.
NDIS Participant	A person who receives supports funded under the National Disability Insurance Scheme.
Precluding Offence	A criminal conviction that automatically disqualifies a person from working in aged care or as an NDIS worker under applicable legislation.
Reportable Incident	An incident that must be reported under the NDIS Incident Management and Reportable Incidents Rules or Aged Care legislation.
Safeguarding Investigation	An investigation conducted by a regulatory body, employer, or Ethical Hire into conduct that may constitute a safeguarding concern.
Worker Screening Exclusion	A decision by an authorised worker screening body that prevents an individual from performing NDIS risk-assessed roles.
WWCC	Working with Children Check — a state or territory-based check required for workers engaged in child-related work.
WWVP	Working with Vulnerable People registration — required in Tasmania and the ACT for workers in care and support roles.

17. Related Documents and Legislation

Internal Documents

• Ethical Hire Terms and Conditions
• Ethical Hire Privacy Policy
• Ethical Hire Code of Conduct
• Ethical Hire Safeguarding and Risk Management Framework
• Ethical Hire Incident Management Policy

Legislation and Regulatory Frameworks

• Privacy Act 1988 (Cth) and Australian Privacy Principles
• Crimes Act 1914 (Cth)
• National Disability Insurance Scheme Act 2013 (Cth)
• NDIS Code of Conduct
• NDIS Practice Standards
• NDIS Worker Screening Rules
• NDIS Incident Management and Reportable Incidents Rules
• Disability Discrimination Act 1992 (Cth)
• Australian Human Rights Commission Act 1986 (Cth)
• Aged Care Act 2024 (Cth)
• Aged Care Rules 2025
• Aged Care Quality Standards
• Health Practitioner Regulation National Law

18. Feedback and Policy Review

This Policy will be reviewed at least annually, and more frequently where required due to legislative, regulatory, operational, or safeguarding changes.

Ethical Hire welcomes feedback from Participants, Clients, Workers, Providers, Coordinators, and other stakeholders to support continuous improvement of its safeguarding and compliance framework.

Questions or feedback regarding this Policy may be directed to:

Compliance and Safeguarding Team

Ethical Hire  |  ABN 77 679 399 001