Baseline Analysis of Best Practice Implementation of the Aboriginal and Torres Strait Islander Child Placement Principle Northern Territory April ...

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Baseline Analysis of Best Practice Implementation of the Aboriginal and Torres Strait Islander Child Placement Principle Northern Territory April ...
Baseline Analysis of Best Practice Implementation of the
Aboriginal and Torres Strait Islander Child Placement Principle
                      Northern Territory

                          April 2018

                                                                  1
Introduction
This resource presents a baseline analysis of the progress of the Northern Territory in implementing the full intent of the Aboriginal and Torres Strait Islander Child
Placement Principle (ATSICPP) with reference to the best practice approach as set out in Understanding and Applying the Aboriginal and Torres Strait Islander Child
Placement Principle – A Resource for Legislation, Policy, and Program Development.
The baseline analysis considers the alignment of the five elements of the ATSICPP – prevention, partnership, placement, participation, and connection – with five interrelated
system elements – legislation, policy, programs, processes, and practice. However, as the analysis reveals, there is significant interconnectedness and intersectionality of
both the ATISCPP and system elements. Further, piecemeal compliance with a single or even several elements does not, and cannot, lead to the full realisation of the
ATSICPP. Instead it is clear that holistic processes of reform are required to ensure full implementation and compliance with the ATSICPP’s intent to keep Aboriginal and
Torres Strait Islander children safely connected to their families, communities, cultures, and country.
It is important to note that the baseline analysis has a particular focus on child safety, protection, and family support service systems and the work of government
departments with primary responsibility for those systems, and so has some limitations to its scope. For example, the prevention element of the ATSICPP covers a broad
scope of systems and multiple departmental responsibilities for universal service provision in areas such as health, education, and disability; however, these broader support
systems are largely outside the scope of this review. Another important caveat is that the analysis is based on available documentation gathered through a desktop review
and requests to state and territories for relevant documentation. State and territory governments have had opportunity to input to each baseline as have Aboriginal and
Torres Strait Islander sector leaders.
The development of this resource – and equivalent analyses for each state and territory jurisdiction – has been guided by the work of the Aboriginal and Torres Strait
Islander Working Group established under the Third Three-Year Action Plan 2015-2018 for the National Framework for Protecting Australia’s Children 2009-2020. The
Working Group is tasked with ensuring implementation of the ATSICPP throughout the Third Action Plan and as part of this work seeks, through the current analyses, to
establish the current status of implementation in each state and territory in order to track and measure progress towards enhanced implementation.

                                                                                                                                                                          2
Overview – Northern Territory
The legislative framework for child protection in the Northern Territory recognises a range of significant principles that reflect the rights of Aboriginal and Torres Strait Islander
children to maintain cultural, family, and community connections. These include principles that require respect for culture, removal only if there is ‘no other reasonable way to
safeguard’ a child’s wellbeing, prioritisation of safe return to family, and participation of children and family members in decision-making. However, there are clear deficits in
policy commitments, programs – particularly funded Aboriginal Community Controlled Organisation (ACCO) operated programs – or enabling processes that translate these
legislative principles into practice. There is a notable lack of legislative and policy focus on preventative and early intervention measures, as well as on requirements to make
practical efforts for safe and timely reunification. In particular, there is no legislative requirement for supports to be provided to families before an order removing parental
responsibility, including a permanent care order, is made.
The underdevelopment of the Northern Territory ACCO sector is a major shortfall that cuts across every element of the Aboriginal and Torres Strait Islander Child Placement
Principle. The lack of: engagement and co-design in policy and programming; support and capacity building of the ACCO sector; and effective participation of ACCOs in child
protection decision-making and family support service provision demonstrates limited compliance with the partnership element of the ATSICPP.
It is not apparent that Aboriginal and Torres Strait Islander children and families are provided with effective and appropriate opportunities to participate in decision-making
processes. The legislatively designed mediation process does not operate in practice and does not reflect best practice in terms of being a culturally safe and appropriate
process reflective of an Aboriginal and Torres Strait Islander Family-Led Decision-Making model. A trial of Family Group Conferencing in Alice Springs in 2011-2012 which
was independently evaluated showed promise to ensure children were placed within their Aboriginal kinship networks, but has not been extended or expanded.
A further concern of current Northern Territory practice is that there is no clear requirement, commitment and resourcing of care plans that ensure connections to family,
community, culture and country. In particular, there are no specific requirements for child, family or ACCO participation in the design, implementation and monitoring of care
plans. While the Children’s Commissioner has conducted a review of a small number of care plans, there is no representative review that can demonstrate best practice
compliance at ensuring connections.
In the Northern Territory, as at June 2016 Aboriginal and Torres Strait Islander children are 11.1 times more likely than non-Indigenous children to be in out-of-home care
(OOHC). Of all the children in OOHC, 89.15 per cent are Aboriginal and Torres Strait Islander. Only 30.1 per cent of Aboriginal and Torres Strait Islander children in OOHC
are placed with Aboriginal and Torres Strait Islander kin or other family. These statistics and the underdevelopment of the ACCO sector are alarming and demonstrate that the
Northern Territory has a significant way to go to achieve compliance with the intent of the Aboriginal and Torres Strait Islander Child Placement Principle.
In this context, where the vast majority of children involved in the child protection system and residing in OOHC are Aboriginal and Torres Strait Islander, the absence of a
dedicated Commissioner for Aboriginal and Torres Strait Islander children in the Northern Territory is particularly notable.
While Territory Families (the Department) has improved transparency and accountability by recently making several key policies publically available on its website and
committing to periodically review compliance with the ATSICPP, at present there remains a lack of reporting on and monitoring of compliance with the ATSICPP by Territory
Families or any independent body.
Recent commitments to implement recommendations of the Royal Commission into the Protection and Detention of Children in the Northern Territory (NT Royal Commission)
                                                                                                                                                                           1
indicate the intention of the Northern Territory Government to address many of these issues. As set out in the Territory Families 2017 Annual Report and Strategic Plan ,
Territory Families is undertaking major reforms to its family support and child protections system, including legislative reform to be progressed through consultation; a greater
focus on prevention and early intervention; commitment to the Family Matters campaign through the signing of the Statement of Commitment which includes core principles for
working with Aboriginal people and organisations; more support to build the capacity and role of ACCOs in the child, youth and families sectors; a dual pathway system for
reports and referrals to child protection; and the transition of out of home care services to the non-government sector within seven years.
The transition of out-of-home care to the non-government sector includes plans to invest in ACCOs that can work with children in care in culturally safe and sustainable ways.
In accordance with Recommendation 33.12 of the NT Royal Commission, the outsourcing of OOHC will also incorporate an out-of-home care accreditation framework, an
outcomes and performance reporting framework and more robust oversight mechanisms. It is also directly linked to the Government’s two election commitments, to 1) ‘grow
and develop Indigenous non-government organisations focused on looking after children in out-of-home care’ and 2) that ‘Indigenous children requiring care will be supported
by extended Aboriginal families’.

                                                                                                                                                                                   3
The NT Government has announced its in-principle support to NT Royal Commission recommendations 40.1 and 40.2 to replace the Children’s Commissioner with a
Commission for Children and Young People, with jurisdiction for all children and young people in the Northern Territory, and two Commissioners, one of whom will be an
Aboriginal person.
NOTE: The materials reviewed for this analysis were compiled throughout 2017 prior to the NT Government releasing its response to the NT Royal Commission on 1 March
2018. As such, it does not fully reflect emerging policy directions in response to the NT Royal Commission. It is expected that the next stage of measuring progress against the
baseline will reflect implementation of the broad agenda for reform emerging from the NT Royal Commission.

                                                                                                                                                                            4
LEGISLATION
                                                           Refers to the Care and Protection of Children Act 2007 (NT) unless otherwise stated
            PREVENTION                                PARTNERSHIP                              PLACEMENT                            PARTICIPATION                                CONNECTION
Northern Territory legislation             Northern Territory legislation         Section 12 aligns with some             Generally, decisions ‘should’ be           The Act contains several strong
contains relatively strong principles      recognises Aboriginal self-            important aspects of best practice,     made with the ‘informed                    principles that recognise a child’s
regarding the primary role or              determination (s12(1)), however,       however, is limited by the use of       participation’ of the child, family        right to family, culture, and contact
‘responsibility’ of family for the         does not go on to effectively enable the qualifier ‘as far as practicable’,    and other persons who are                  – right to be brought up in
care, upbringing and development           independent or representative          and includes no requirement for         significant in the child’s life (s9(2)).   language, tradition, and culture
of a child (s8(1)), a child and            participation. While section 12(2)     ACCO participation in decision          Section 11 lists enablers for              (ss8(2), 9(2)(b), 10(g)(h)), and
family’s right for a child to be           provides that a representative         making. The section provides that       informed child participation,              presumption that for a child in
brought up in language, tradition,         organisation or community of           ‘as far as practicable’, an Aboriginal including opportunity to express            OOHC, ‘as far as practicable’ and
and culture (ss8(2), 9(2)(b),              Aboriginal people nominated by         child ‘should’ be placed with – in      views that are taken into account          consistent with best interests,
10(g)(h) – the latter being a best         family ‘should be able to              this order – ‘a member of the           having regard to maturity and              contact with family should be
interest consideration) and the            participate’ in decision making,       child’s family’, ‘an Aboriginal         understanding.                             encouraged and supported, and
‘responsibility’ of the State to           there are no enabling provisions       person in the child’s community in      In relation to judicial decision-          the child should ‘eventually’ be
support families (s7).                     defining ‘representative               accordance with local community         making, the court must consider            returned to family (s8(4)).
Further, s8(3) states that a child         organisation’, mandating               practice’, ‘any other Aboriginal        the wishes of the child, parents,          There are express provisions
may only be removed from family if         participation or even attempts at      person’, or a non-Indigenous            person proposed to be given daily          allowing the court to restrict contact
there is ‘no other reasonable way’         participation before decisions are     person who in the Department’s          care and control (DCC) or parental         and regulate it by supervision on an
to safeguard wellbeing. Section            made, or requiring a                   opinion is ‘sensitive to the child’s    responsibility, and any other person       interim order on adjournment or a
8(4) goes on to state that ‘as far as      recommendation of an Aboriginal        needs and capable of promoting          with a direct and significant interest     protection order (ss123(2),
practicable’ and consistent with           person or agency regarding             the child’s ongoing affiliation with    (interest) in the child’s wellbeing        139(1)(d), 139(5)), however, there
best interests, if a child is removed,     permanent care order decisions.        culture (and if possible ongoing        (s130(1)(b) re protection orders,          are no express provisions for
contact with family should be              In relation to mediation               contact with family)’. Further, ‘as far s137H re permanent care orders).           directions or orders that would
encouraged and supported, and              conferences – which may be             as practicable’, a child ‘should’ be    A child is necessarily a party to          allow or require contact. Where a
the child should eventually be             initiated by the Department (with      placed in close proximity to the        court proceedings (ss94(1)(a),             protection order gives daily care
returned to family.                        the agreement of parents) or court     child’s family and community.           125(2)(a)) and may be provided             and control or parental
The Act provides an inclusive              ordered (ss49, 127) – the              The section does state that kin, a      with a legal representative if in their    responsibility to the Department, it
definition of ‘relative’ and ‘family’ as   Regulations instruct that the          representative organisation or          best interests (s143A). It is              ‘must provide opportunity’ for
including persons related by way of        convenor must have regard to           community ‘should be able to            presumed that a child 10 years and         contact with parents and other
customary law or tradition, or             section 12(2) (above) when             participate’ in decision-making,        older is able to provide direct            family ‘as often as is reasonable
contemporary custom or practice            determining who to invite to a         however, this is not mandated and       instructions, otherwise, will be           and appropriate’ (s135(1)(b)).
(ss18, 19).                                conference (regulation 5 Care and      there are no systems in place to        represented on a best interests            Decisions about contact must be
The Act contains a relatively weak         Protection of Children (Mediation      ensure that this is implemented at      basis (s143B).                             set out in the child’s care plan
safeguards against giving a non-           Conferences) Regulations 2010          an operational level (see               Parents are necessarily parties to         (s70(2)(c)(ii)).
parent parental responsibility under       (NT)).                                 ‘Participation’).                       proceedings (though not in relation        In relation to permanent care
a long-term parental responsibility        While section 303 allows for                                                   to permanent care orders: s137D)           orders, section 137F expressly
direction (a direction in a protection     delegation of the functions and                                                and other persons may be parties if        prohibits the making of any
order allocating parental                  powers of the CEO of the                                                       it is proposed that they hold DCC          direction other than one that
responsibility for more than 2             Department, it is not apparent that                                            or parental responsibility, or if they     authorises overseas travel without
years) – that such a direction             this has been designed to delegate                                             have an interest in the child’s            parental consent. This means no
cannot be made unless the court is         functions and powers to Aboriginal                                             wellbeing (ss94, 125). The court           contact can be ordered on a
satisfied that the transfer of             and Torres Strait Islander                                                     must, as far as practicable, ensure        permanent care order and no other
responsibility is ‘the best means’ of      organisations.                                                                 each party understands the                 requirements for maintenance of
safeguarding wellbeing, and ‘there                                                                                        proceedings – and may direct that          child’s family or cultural
is no one else who is better suited’                                                                                      services such as an interpreter be         connections can be imposed.
to be given the responsibility                                                                                            provided (s98). A party has a right        Despite the principle that a child

                                                                                                                                                                                                          5
LEGISLATION
                                            Refers to the Care and Protection of Children Act 2007 (NT) unless otherwise stated
            PREVENTION                   PARTNERSHIP                           PLACEMENT                             PARTICIPATION                           CONNECTION
(s130(2)). There is no requirement                                                                        of legal representation and the        should be eventually returned to
for a demonstration of any or                                                                             court may adjourn to provide a         family (see above), the Act does
reasonable efforts at reunification.                                                                      reasonable opportunity for this        not contain any safeguards
In a similar way, the only real                                                                           (s101). However, in certain            protecting against the making of
safeguard against the making of a                                                                         circumstances, the court may           long-term orders without attempts
permanent care order is that the                                                                          proceed and make an order in the       at reunification (protection order
court must be satisfied that a child                                                                      absence of the parents (ss105(5),      with a long-term parental
is in need of protection, the order is                                                                    126(1), including in relation to       responsibility direction (s130(2),
the best means to safeguard                                                                               permanent care orders: s137E)          permanent care order: s137G)).
wellbeing, and the proposed                                                                               despite section 100 requiring          There are also no specific
permanent carer has demonstrated                                                                          attendance of parents.                 requirements for demonstrated
their suitability (s137G).                                                                                The court may also hear                commitment of carers to the
While section 44 provides that the                                                                        submissions from a non-party, such     maintenance and development of a
Department may provide and fund                                                                           as a family member, and these          child’s cultural connections before
child-related services (defined as a                                                                      persons may have a legal               these orders are made.
range of social services by s13),                                                                         representative make these              Care plans are required for all
there is no provision requiring or                                                                        submissions on their behalf (s148).    children in the Department’s care
even encouraging referral to family                                                                       Mediation conferences may be           (s70). The plan must identify the
support services.                                                                                         initiated by the Department (if the    child’s needs, outline measures to
                                                                                                          parents agree) to address concerns     meet those needs, and set out
                                                                                                          about a child’s wellbeing, or by       decisions regarding matters such
                                                                                                          court order (ss49, 127). The Act       as placement and contact (s70(2)).
                                                                                                          and Regulations assume the             Requirements for 6 monthly review
                                                                                                          participation of the child, parents,   or plans are provided (s74) and for
                                                                                                          and ‘appropriate’ family members.      having regard to the views of the
                                                                                                          A child may also participate in the    child, parents, carer and other
                                                                                                          development of a care plan (wishes     significant persons in creating
                                                                                                          taken into account: s72) and a         plans (s72,74). There is no specific
                                                                                                          child, parent, carer, and other        reference to addressing cultural
                                                                                                          person with an interest may            connections or needs in case
                                                                                                          participate in the review of a care    plans.
                                                                                                          plan (regard had to views: s74(4)).

                                                                                                                                                                                    6
POLICY
            PREVENTION                             PARTNERSHIP                             PLACEMENT                            PARTICIPATION                            CONNECTION
A relevant prevention focused          For a long time, there were no         Preference for placement within a      Northern Territory policy               There are no publically available
policy is the Northern Territory’s     publically available policy            child’s immediate or extended          documents state that families are       overarching policy documents that
consideration of Aboriginal child      documents that reference or            family (for all children) and          integral to decision making about       emphasise the importance of
                                                                                                                                    13
health outcomes, endorsed by the       commit to partnership in any of the    compliance with the legislated         their children. However, there is       maintaining and developing
Northern Territory Aboriginal Health   identified best practice ways – this   placement hierarchy of the             no policy commitment or provision       connections to family, community,
Forum – What are the Key               included no commitment to co-          ATSICPP is emphasised in several       for family participation through        culture and country, beyond those
                                                                                            11
Services needed to Improve             design by ACCOs or a peak body,        documents. In relation to all          mediation or other conferencing         already noted in relation to
Aboriginal Child Health Outcomes       no support or prioritisation of        children, the Annual Report 2015-      means supported by ACCOs such           placement. However, recognition of
                               2
– Progress and Possibilities.          ACCO case management or ACCO           2016 states that ‘the search for       as Aboriginal and Torres Strait         the importance of these
The Department has published a         custody or guardianship, and no        suitable placement options within      Islander Family Led Decision-           connections may be inferred to
Family Intervention Framework,         support for ACCO capacity building     the child’s immediate and extended     Making.                                 some extent from policy documents
which briefly defines services to      for participation and service          family occurs until all options have                                           that promote family contact, sibling
                                                                                                  12
reduce child protection involvement    delivery.                              been exhausted’.                       Recent commitments to implement         co-placement, reunification, and
                                                                                                                                                                          14
and prevent children entering and      The only reference to community        Otherwise, there is no other policy    recommendations of the NT Royal         care plans.
remaining in OOHC and how those        participation was found in the         reference or emphasis on               Commission indicate the intention       In relation to care plans, the
                         3
services are targeted. In the past,    Standards of Professional              reviewing lower-priority               of the Northern Territory               Standards of Professional Practice
                                                 8
the Department noted only briefly in   Practice. This is a relatively weak    placements, participation of family    Government to address these             go further than legislation to specify
its Annual Report that part of its     position that echoes the legislative   and ACCOs in placement decision-       issues, including the introduction of   that such plans are to identify how
                                                                                                                                                                                         15
budget and work includes support       allowance (not requirement) that an    making, or ACCOs’ role in kinship      a Family Group Conferencing             cultural needs will be met. The
to prevent child protection            Aboriginal organisation ‘is able’ to   carer and other placement              model into child protection practice,   only reference to family
              4
involvement. The Department has        participate in child protection        identification, assessment, and        designed in partnership with            participation in the development of
published policies describing the      decision making, with the added        support.                               ACCOs and children and families.        these plans is noted in the
operation of Parent and Family         qualifier of ‘if they have been                                                                                       Department’s Annual Report 2015-
                                                                                                                                                                    16
Support Services and its internal      selected to do so by the child’s       In 2017 the Department provided                                                2016. Otherwise, there is no
casework support approach,             family’.                               some funding to SNAICC –                                                       invitation or encouragement of
                           5
Strengthening Families. However,       While the Northern Territory child     National Voice for our Children and                                            family or ACCO participation in the
these policies are more related to     and family welfare ACCO sector is      APO NT to develop an Aboriginal                                                development, implementation, or
service operation than systemic        clearly under-resourced and under-     OOHC Strategy to create and build                                              review of these plans.
commitment to prevention and           valued, including the disbanding of    Aboriginal-led and managed OOHC                                                The Standards and Policy –
early intervention (see ‘Programs’).   the peak body, there is significant    services in the Northern Territory.                                            Reunification repeat the legislative
There is some acknowledgement of       current capacity within the            This will include drafting a service                                           principle prioritising safe
                                                                                                                                                                             17
Aboriginal kinship and child rearing   Aboriginal health sector to provide    model and strategy for establishing                                            reunification.
practices, but this is found in        family support services, parenting     an Aboriginal OOHC service sector                                              Though it has not yet significantly
process documents, and is not set      programs, identification and           that among other things, prioritises                                           progressed, the Northern Territory
out as a clear policy position (see    support for Aboriginal kinship         the placement of Aboriginal                                                    Government’s commitment to the
‘Processes’ below).                    carers, and child                      children with Aboriginal kinship and                                           transfer for OOHC case
It is promising that the Northern      health/development assessments         foster carers.                                                                 management to NGOs is also
                                                                                                                                                                              18
Territory Government has recently      etc. The ACCO health sector have                                                                                      relevant here.
developed an early childhood           been involved in promising
strategy, with some                    discussions with the Department
acknowledgement and actions            regarding initiatives, including a
targeted at Aboriginal children and    review of cases of Aboriginal
          6
families.                              children on long-term orders with a
Further, Territory Families now        view to support for family
more clearly commits to prevention     reunification, and development of a
                                       process for referral of ‘low-risk’

                                                                                                                                                                                                  7
POLICY
           PREVENTION                           PARTNERSHIP                 PLACEMENT   PARTICIPATION   CONNECTION
and early intervention approaches   matters to health services.
               7
and programs.                       The Aboriginal Peak Organisations
                                    NT (APO NT) have developed a set
                                    of Partnership Principles designed
                                    to guide the development of
                                    partnerships for non-Aboriginal
                                    organisations to engage in the
                                    delivery of services or development
                                    initiatives in Aboriginal communities
                                                               9
                                    in the Northern Territory. The
                                    adoption, commitment, and
                                    implementation of these principles
                                    by the Department and government
                                    represents a good first step to
                                    genuine partnership.
                                    Another recent promising shift
                                    towards partnership and self-
                                    determination is the Northern
                                    Territory’s commitment to ACCO
                                    capacity building and transfer of
                                                                 10
                                    OOHC case management.
                                    The Minister for Children and
                                    Families’ signing of the Family
                                    Matters Statement of Commitment
                                    is another promising step, though
                                    the commitments and principles
                                    relating to genuine partnership and
                                    self-determination need to be
                                    realised.

                                                                                                                     8
PROGRAMS
              PREVENTION                              PARTNERSHIP                           PLACEMENT                             PARTICIPATION                           CONNECTION
The Family Intervention Framework         There are no Department funded or    The Department’s Foster Carer            In terms of child, family and         There are no government funded
consists of four service                  supported programs for ACCO          Attraction, Recruitment and              community participation, although     programs (ACCO operated or
components – child safety                 participation in child protection    Retention Strategy 2015-2016             legislation provides for mediation    otherwise) that enable family and
intervention, intensive family            decision making. While there could   seeks to support foster carers,          conferences, these do not operate     community to participate in care
preservation, reunification support,      be an opportunity for ACCOs to       including Aboriginal carers, and to      in practice (see ‘Practice’ section   planning or implement contact
and relative and kinship carer            participate through legislatively    recruit Aboriginal kinship and other     below). In any case, these            arrangements or care/cultural
          19
support. Policy – Family and              provided mediation conferences,      carers through ‘talking posters’ and     conferences were not designed as      plans. There is no ACCO case
                                                                                                                   27
Parent Support Services sets out          these are not designed as ACCO-      radio advertisements in language.        ACCO-operated ATSIFLDM or             management or custody and
                                 20
Department support services.              operated Aboriginal and Torres       The Nothern Territory Government-        similar.                              guardianship. Family support
Intensive family preservation             Strait Islander Aboriginal and       run Carer Community website              General legal services and            programs, including those focused
services have been tendered to            Torres Strait Islander Family Led    provides information about financial     Aboriginal and Torres Strait          on achieving reunification, are run
external providers, however this          Decision-Making (ATSIFLDM) and       support, training, and other support     Islander legal services, including    by several ACCOs in Central
                              21
includes only one ACCO.                   in fact are not occurring in         for kinship and other carers. The        family violence prevention and        Australia.
                                                   26
The Department also has also              practice – see further               Department provides training for         legal services may provide            The Department does highlight one
supported a Targeted Family               ‘Participation – Practice’ below.    carers that ‘includes an introduction    government-funded legal advice        promising program/service – the
                                                                                                      28
Support Program, however again            There are no funded ACCO-led or      to Aboriginal culture’.                  and representation to children,       Community Based Children’s Care
                                    22
only one program is ACCO-run. It          operated programs such as            There are no other Department            parents and family members in         Service in Tennant Creek. This
appears however that this service         ATSIFLDM, case management,           programs and no ACCO-led                 child protection matters.             service allows children in the local
was defunded at the end of the            custody and guardianship, peak       programs that provide kinship and                                              region to remain in Tennant Creek,
2015-2016 financial year when the         body involvement in system design,   family scoping, placement                                                      ‘close to family connections’, while
Department opted to fund an               sector representation and sector     identification, assessment and                                                 foster or kinship carers are found.
alternate service model that does         development, or even ACCO            support, ATSIFLDM or similar, or                                               While this service aims to ensure
not require the same level of highly      training and review of mainstream    reconnection efforts to place                                                  children maintain family and
skilled staff.                            service’s cultural competency.       children back with family and                                                  community connections, it is run by
The Remote Family Support                                                      community.                                                                     a mainstream service – Lifestyle
                                                                                                                                                                         29
Service, funded by the                                                         A recent promising shift has been                                              Solutions.
Commonwealth Government,                                                       the Department’s expanded
operates in 18 remote communities                                              funding to Tangentyere Council, an
and while is not ACCO-run, does                                                ACCO in Central Australia, to find
employ local Aboriginal people who                                             suitable kinship care placements
are ‘fluent in both culture and                                                for Aboriginal children, and to
             23
language’. However, difficulties in                                            attract, engage, retain and support
engagement are common and                                                      Aboriginal carers.
likely given this service is run by
Territory Families.
The Commonwealth Government
also funds Intensive Family
Support Services (IFSS) for
families with a risk of recurring child
neglect, aiming to ‘help families
keep children in their homes, in
their communities and out of the
child protection system’. There are
several ACCOs delivering IFSS.
Eligibility is closely tied to

                                                                                                                                                                                                 9
PROGRAMS
            PREVENTION                 PARTNERSHIP   PLACEMENT   PARTICIPATION   CONNECTION
concurrent referral to child
protection income management
and preferencing of families
already subject to this.
Where an assessment has
determined that future harm to a
child is a low or moderate risk, the
child protection case may be
closed and a Strengthening
Families case opened (with the
consent of the parents). Ongoing
Strengthening Families case
management includes identification
                      24
of supports required.
While not a specific program, the
Department operates a system of
‘preventative family care payments’
to reduce the risk of harm and
subsequent likelihood of removal
into OOHC. These payments are
                               25
described as a casework tool.

                                                                                              10
PROCESSES
            PREVENTION                             PARTNERSHIP                               PLACEMENT                            PARTICIPATION                             CONNECTION
While the Care and Protection           There are no process or practice         While a Policy – Placements            The Practice Framework and              There are no process or practice
Policy and Procedures Manual is         documents that require or enable         document exists to guide the           Standards of Professional Practice      documents that provide guidance
not publically available, some          community or ACCO participation          Standards of Professional Practice,    state the intention to involve          on assessing and meeting cultural
understanding of processes can be       in child protection decision making.     it provides no specific processes to   families in decision-making and to      needs. However, incidentally
gained from the Department’s            As set out above in ‘Policy’, there is   ensure legislative and policy          ensure they have the information        through other policy documents,
Standards of Professional Practice,     only a passing reference in the          commitments to the placement           and support, such as interpreters,      some guidance can be found –
                                                                                                     34
Practice Framework and other            Standards of Professional Practice       hierarchy are met. It merely           they require to understand and          care plans must document family
                   30
policy documents.                       that Aboriginal organisations are        restates the hierarchy and premise     participate – ‘this includes            contact arrangements and these
The Standards state that ‘where         able to participate if selected by the   that all placement options within      information about legal processes       must be reviewed on a regular
                                                       33                                                                                                37
appropriate, families are referred to   child’s family. This does not            family are to be exhausted – it does   and access to representation’.          basis as part of the case review
relevant services to receive            require timely or informed               not set out how this is to be done,    This also involves ‘encouraging’ the    process or if a significant event
                                                                                                                                                                         39
ongoing assistance and/or               participation in any decision            that it should be done with            child, parents, and significant         occurs. The importance of sibling
specialised services’ and this is to    making, let alone all significant        culturally appropriate assessment      others to participate, with             relationships and preference of
be recorded on the case file.           decision making, starting at             methods, that it should be recorded    ‘continued attempts’ to be made         placing siblings together in care is
                                                                                                                                                                        40
There is some recognition of            notification.                            or that lower-level placements are     when individuals are reluctant or       noted. For carers, very limited
                                                                                                                                            38
culture that may lead to more           There are no other references or         to be regularly reviewed with a goal   refuse to engage.                       guidance is provided to keep
appropriate risk assessment and         requirements in any available            to reconnect with a prioritised        The Standards provide specific          children connected with family and
safety planning. While not              documents that otherwise set out         placement.                             guidance regarding child                culture. The Department’s Carer
expressly referencing these             processes that align with best           In terms of guidance on kinship        participation, setting out that where   Community website lists suggested
processes, the Tune into Little         practice – there are no processes        structures and care practices, there   a child is required or wishes to        activities and then refers carers to
Ones resource recognises and            that require recording outcomes of       is only passing reference to the       attend court, the child is to be        the allocated case worker,
values Aboriginal kinship and care      participation or require participation   importance of kinship networks and     assisted to attend and understand       Aboriginal Community Worker, or
                                                                                                                                                                                        41
systems, instructing workers to         in court proceedings. There are no       cultural strengths in child rearing    matters by the Department.              other cultural advisor.
learn and understand these              guidelines for ACCO case                 practices in the Practice              Further, the Department must            In terms of reunification, it is set out
           31                                                                                 35
practices, and the Practice             management or delegation of              Framework. There is no guidance        assist the child’s legal                that contact increases the
                                                                                                                                                                                                    42
Framework describes culture as a        custody and guardianship to              on how this acknowledgment             representative by providing             likelihood of family reunification,
source of strength and resilience,      ACCOs.                                   informs placement decision-            necessary information and               the reunification process begins as
recognising the importance of           A recent promising shift to build        making. Similarly, the resource        assisting with arranging meetings.      soon as a child is placed in OOHC
extended kinship networks and           relationships on the ground and          Tune into Little Ones discusses        However, there are no processes         but it ends if reunification is
cultural strengths in child rearing     work more closely with members of        kinship and care systems but does      that detail culturally safe and         determined to be no longer
           32                                                                                                                                                           43
practices.                              the local community is the               not expressly guide decision-          supported participation such as         viable. The reunification policy
                                                                                                      36
                                        Department’s support for the Mikan       making or practice.                    through ATSIFLDM, guidance on           document sets out that family
                                        Child Protection Reference Group         There are no processes that enable     consulting children in a culturally     members should be provided with
                                        in East Arnhem. Mikan was started        family or ACCO participation in        safe manner, or requirements to         accurate information about the
                                        in February 2017 to provide a link       placement decision-making.             record and detail consideration of      reunification process, timeframes
                                        between Territory Families, the                                                 views.                                  and expectations must be
                                        communities, and Mala (clans) in                                                                                        communicated in appropriate
                                        the Nhulunbuy region, and to build                                                                                      language and style, and they must
                                        constructive relationships. The                                                                                         be engaged in case planning in
                                        group shares information and                                                                                            order to develop a realistic
                                        promotes child protection                                                                                               understanding of the possibility of
                                        awareness within the communities                                                                                        reunification. The document states
                                        and discusses high risk cases to                                                                                        that ‘parents and extended family
                                        work together as a group to make                                                                                        should have access to appropriate
                                        safe plans for the child. This                                                                                          and timely services necessary to
                                        encourages participation in                                                                                             facilitate … sustainable

                                                                                                                                                                                                       11
PROCESSES
PREVENTION              PARTNERSHIP               PLACEMENT   PARTICIPATION              CONNECTION
             decision-making and aims to keep                                 reunification’. The document also
             children in community and diverted                               states that consideration will be
             away from the child protection                                   given to the ATSICPP and other
             system.                                                          specific language and cultural
                                                                              needs of the child and family.
                                                                              For permanent care orders, there is
                                                                              instruction that for Aboriginal
                                                                              children to be considered for an
                                                                              order, they must have their needs
                                                                              and proposed care arrangements
                                                                              assessed under the ATSICPP and
                                                                              the decision-making process must
                                                                                                         44
                                                                              be documented in detail. A
                                                                              Permanent Care Order Panel must
                                                                              endorse an application before the
                                                                              Department proceeds to make an
                                                                              application for an order to the court.
                                                                              While there is a reference to
                                                                              ‘cultural advisors’ on the panel, this
                                                                              is not specified as a representative
                                                                                                               45
                                                                              Aboriginal community member.

                                                                                                                   12
PRACTICE
            PREVENTION                             PARTNERSHIP                            PLACEMENT                              PARTICIPATION                            CONNECTION
The proportion of Northern Territory   Very limited government funding is     The proportion of Northern Territory    Mediation conferences as                There is no reporting on the
spending on intensive family           provided to the ACCO sector in the     Aboriginal and Torres Strait            envisaged by Northern Territory         completion, quality, implementation
support services and family support    Northern Territory. As set out         Islander children placed with           legislation – either initiated by the   or review of cultural care plans.
services in relation to total child    above in ‘Policy’, there is no         Aboriginal or Torres Strait Islander    Department or court-ordered – do        While the Department states that
                                                                                                                                                 55
protection spending has increased      recognition, commitment or             kin or other family, or an Aboriginal   not operate in practice. This           throughout 2015-2016, 800
significantly from 2.43% in 2011-      prioritisation for ACCO capacity,      or Torres Strait Islander home-         means there is no effective             approved care plans were
                                  46
2012 to 22.46% in 2015-2016.           service design and/or delivery, or     based carer has fallen from 38.1%       program or process through which        maintained while other plans cycled
                                                                                                                                                                                58
However, this is significantly less    participation in decision-making.      as at 30 June 2012 to 36.2% as at       children and families can               through review, there is no
                                                                                              52
than the 50% relative percentage       There are no available measures of     30 June 2016.                           participate in non-judicial child       breakdown of whether these care
investment recommended by the          partnership practice, however, it is   However, in terms of the first          protection decision-making, and to      plans were for Aboriginal and
2010 Inquiry into the child            clear from the lack of strong          preferred placement, as at 30 June      some extent judicial decision           Torres Strait Islander children or
                    47
protection system.                     legislation, policy, programs and      2016, only 30.1% of children were       making. The Department does not         appropriately addressed cultural
There is no available data on the      processes that practice is poor.       placed with Aboriginal and Torres       reference any commitment to             support needs.
proportion of Aboriginal and Torres    Further, there is no apparent          Strait Islander kin or other family,    initiate mediation conferences or       The Children’s Commissioner for
Strait Islander children in the NT     practice review of ATSICPP             an increase from 27.8% at 30 June       more culturally safe processes          the Northern Territory conducted a
                                                                                     53
commencing intensive family            implementation.                        2012.                                   such as ATSIFLDM. This is despite       care plan review of a random
support services since 2014-2015.                                             There are no available measures of      a promising trial – funded by the       sample of cases, finding that 80%
This is reported because ‘the NT                                              whether high-priority placements        Department – of family group            of Aboriginal children had a plan
did not fund services that met the                                            are maintained through kinship          conferencing in Alice Springs in        that adequately addressed their
                                                                                                                                   56                                          59
definition of prevention or                                                   care supports, all placement            2011-2012.                              cultural needs. The review
                         48
reunification services’. There is                                             options are exhausted in order of       While Aboriginal and Torres Strait      considered a total sample of 105
no other data available on access                                             hierarchy, or there is regular review   Islander legal services exist to        cases – 10% of all cases – and 97
to family support services for                                                of lower-level placements with          assist children and families,           of these cases were of Aboriginal
Aboriginal and Torres Strait                                                  higher-level placements made as         underfunding of these services, late    children. It is unclear what criteria
Islander children and families.                                               soon as possible.                       referral to these services by the       was used to determine adequacy of
In the NT, Aboriginal and Torres                                              The Children’s Commissioner for         Department and underfunding of          addressing cultural needs.
Strait Islander children represented                                          the Northern Territory has reported     interpreter services weakens the        The Department does not report on
89.15% of all children in OOHC as                                             a trend in complaints regarding         effective participation of children     contact or reconnection, and in
at 30 June 2016, an increase from                                             inadequate and/or inappropriate         and families in judicial decision       relation to reunification only stated
                               49                                                                                              57
81.86% as at 30 June 2012.                                                    kinship placements for children in      making.                                 that the ‘vast majority’ of the 304
                                                                                             54
Aboriginal and Torres Strait                                                  remote areas.                                                                   children leaving care in 2015-2016
                                                                                                                                                                                    60
Islander children were 11.1 times                                                                                                                             returned to family. The Children’s
more likely than non-Indigenous                                                                                                                               Commissioner reported the
children to be in OOHC at 30 June                                                                                                                             Department’s figure as 195 cases
2016, an increase from 6.1 times                                                                                                                              that were closed with return to
                            50
as likely at 30 June 2012. As at                                                                                                                              family – there is no breakdown as
30 June 2016, 3.45% of all                                                                                                                                    to whether these cases involved
Aboriginal and Torres Strait                                                                                                                                  Aboriginal and Torres Strait
                                                                                                                                                                                   61
Islander children in the NT were in                                                                                                                           Islander children. Considering
OOHC, an increase from 2.15% at                                                                                                                               that as at 30 June 2016, there were
                 51
30 June 2012.                                                                                                                                                 1,032 in OOHC, this reunification
                                                                                                                                                              percentage is not insubstantial.
                                                                                                                                                              In relation to contact, the Children’s
                                                                                                                                                              Commissioner reported a trend in
                                                                                                                                                              complaints regarding inadequate

                                                                                                                                                                                                   13
contact between children in OOHC,
                                                                                                                                                                      and family and significant others.
                                                                                                                                                                      No permanent care orders were
                                                                                                                                                                      made in the Northern Territory as
                                                                                                                                                                      at 1 July 2016, despite ‘a level of
                                                                                                                                                                      interest’ received by the
                                                                                                                                                                                    62
                                                                                                                                                                      Department. Since then, the
                                                                                                                                                                      Department reports that one
                                                                                                                                                                      permanent care order has been
                                                                                                                                                                      made in 2016-2017, though it is not
                                                                                                                                                                      specified whether this is in relation
                                                                                                                                                                      to an Aboriginal and Torres Strait
                                                                                                                                                                                      63
                                                                                                                                                                      Islander child.

1
  Territory Families, Northern Territory Government, Annual Report 2016-2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/452521/territory-families-annual-report-2016-17-
web.pdf; Territory Families, Northern Territory Government, Strategic Plan 2017-2020, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/449572/Territory-Families-Strategic-Plan-2017-
2020.pdf
2
  Northern Territory Aboriginal Health Forum (AMSANT, NTG), What are the Key Services needed to Improve Aboriginal Child Health Outcomes – Progress and Possibilities, April 2016, available at
http://www.amsant.org.au/wp-content/uploads/2017/08/What-Are-the-Key-Core-Services-Needed-to-Improve-Aboriginal-Childhood-Outcomes-in-the-NT-Report-FINAL.pdf
3
  See https://childrenandfamilies.nt.gov.au/__data/assets/pdf_file/0003/234066/Family-intervention-framework-specifications.pdf
4
  Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
5
  Territory Families, Northern Territory Government, Policy – Parent and Family Support Services, January 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0009/434763/family-and-
parent-support-policy.pdf; Territory Families, Northern Territory Government, Policy – Strengthening Families, June 2017, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0011/434765/strengthening-families-policy.pdf
6
  Northern Territory Government, Great Start, Great Future – Northern Territory Early Years Strategic Plan 2016-2020, available at
https://education.nt.gov.au/__data/assets/pdf_file/0006/275901/DoE_Strategic-Plan.pdf
7
  Territory Families, Northern Territory Government, Annual Report 2016-2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/452521/territory-families-annual-report-2016-17-
web.pdf; Territory Families, Northern Territory Government, Strategic Plan 2017-2020, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/449572/Territory-Families-Strategic-Plan-2017-
2020.pdf
8
  Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf
9
  See http://www.amsant.org.au/apont/wp-content/uploads/2015/02/21070504-APO-NT-Partnership-Principles-Updated-version.pdf
10
   Territory Families, Northern Territory Government, Annual Report 2016-2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/452521/territory-families-annual-report-2016-17-
web.pdf; Territory Families, Northern Territory Government, Strategic Plan 2017-2020, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/449572/Territory-Families-Strategic-Plan-2017-
2020.pdf
11
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf; Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf; Territory Families, Northern Territory Government, Policy – Placement, February 2017, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0011/425756/placements-policy.pdf
12
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
13
   Department of Children and Families, Northern Territory Government, Practice Framework, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0018/234045/practice-framework.pdf
14
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf; Territory Families, Northern Territory Government, Policy – Family Contact Arrangements, July
2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0008/425744/family-contact-arrangements-policy.pdf; Territory Families, Northern Territory Government, Policy – Sibling Groups in
Care, February 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0006/425760/sibling-groups-in-care-policy.pdf; Territory Families, Northern Territory Government, Policy –
Reunification, February 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/425758/reunification-policy.pdf

                                                                                                                                                                                                             14
15
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf
16
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
17
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf; Territory Families, Northern Territory Government, Policy – Reunification, February 2017, available
at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/425758/reunification-policy.pdf
18
   Territory Families, Northern Territory Government, Annual Report 2016-2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/452521/territory-families-annual-report-2016-17-
web.pdf; Territory Families, Northern Territory Government, Strategic Plan 2017-2020, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0004/449572/Territory-Families-Strategic-Plan-2017-
2020.pdf
19
   See https://childrenandfamilies.nt.gov.au/__data/assets/pdf_file/0003/234066/Family-intervention-framework-specifications.pdf
20
   Territory Families, Northern Territory Government, Policy – Parent and Family Support Services, January 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0009/434763/family-and-
parent-support-policy.pdf
21
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
22
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
23
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
24
   Territory Families, Northern Territory Government, Policy – Strengthening Families, June 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0011/434765/strengthening-families-
policy.pdf
25
   Territory Families, Northern Territory Government, Policy – Financial Support for Children and Families, February 2017, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/425746/financial-support-child-family-policy.pdf
26
   APO NT, Submission to the Royal Commission into the Protection and Detention of Children in the Northern Territory, July 2017, available at
https://childdetentionnt.royalcommission.gov.au/submissions/Documents/submissions/Aboriginal-Peak-Organisations-Northern-Territory-July-2017.pdf
27
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
28
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
29
   Department of Children and Families, Northern Territory Government, Annual Report 2015-2016, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0010/379594/Department-of-Children-
and-Families-annual-report-2015-16.pdf
30
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf; Department of Children and Families, Northern Territory Government, Practice Framework,
available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0018/234045/practice-framework.pdf
31
   See https://territoryfamilies.nt.gov.au/children-and-families/tune-in-to-little-ones
32
   Department of Children and Families, Northern Territory Government, Practice Framework, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0018/234045/practice-framework.pdf
33
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf
34
   See Territory Families, Northern Territory Government, Policy – Placement, February 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0011/425756/placements-policy.pdf;
Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf
35
   Department of Children and Families, Northern Territory Government, Practice Framework, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0018/234045/practice-framework.pdf
36
   See https://territoryfamilies.nt.gov.au/children-and-families/tune-in-to-little-ones
37
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf; Department of Children and Families, Northern Territory Government, Practice Framework,
available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0018/234045/practice-framework.pdf
38
   Department of Children and Families, Northern Territory Government, Standards of Professional Practice, March 2014, available at
https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0019/234046/standards-of-professional-practice.pdf
39
   Territory Families, Northern Territory Government, Policy – Family Contact Arrangements, July 2017, available at https://territoryfamilies.nt.gov.au/__data/assets/pdf_file/0008/425744/family-contact-
arrangements-policy.pdf

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