AACS represents the interests of member schools on a range of issues that impact on the delivery of authentic Christian education in Australia. At the core of our work is conveying our views and lobbying for change in relation to legislation, educational policies, budget initiatives and the administration of government programmes. Our work involves visits to politicians and bureaucrats, submissions to parliamentary inquiries, appearances before parliamentary committee hearings as well as negotiations with peak bodies.
Provided below are a summary of recent inquiries and submissions made by AACS on behalf of member schools.
Last month, Executive Officer Vanessa Cheng was involved in a robust virtual roundtable discussion with other governing bodies of independent schools where significant concerns were raised with Cheryl Vardon, who is leading the review, about the implementation of the current accreditation framework for non-state schools in Queensland.
Following the discussion, AACS provided further feedback to the Review, expanding upon the concerns provided at the roundtable.
The Non-State Schools Accreditation Framework should recognise that parents have a high regard for genuine educational choice and ensure the accreditation framework facilitates and encourages the expression of diverse educational paradigms within the education sector rather than restrict it.
The current accreditation process involves a rigorous evaluation of each school's compliance with the standards by NSSAB, including a review of policies, procedures, and documentation, as well as on-site inspections and interviews with staff and students as part of the school’s cyclical review.
Our member schools have experienced inconsistencies in the implementation of the accreditation framework across different regions and assessors. This can lead to schools being assessed differently based on the assessor they are assigned, which undermines the integrity of the accreditation process.
AACS opposes increasing or strengthening the powers of NSSAB. Rather, AACS recommends further checks and balances are put in place to ensure the accreditation framework sufficiently recognizes the diversity of non-state schools in Queensland.
Christian schools should be able to demonstrate their compliance with the standards in a way that reflects their Christian ethos. There is an increasing tendency to make ‘guidelines’ mandatory expectations, diminishing one of the key obligations of the NSSAB which is to support choice in education. Mandating outcomes and expectations limit parental choice.
AACS appreciate the opportunity to provide feedback on this issue and look forward to working with the Queensland Government to ensure that the accreditation framework is fair, transparent, and fit for purpose.
Executive Officer, Vanessa Cheng has submitted a Response to Department of Employment and Workplace Relations (DEWR) Consultation Paper “Updating the Fair Work Act 2009 to provide stronger protections for workers against discrimination”
The DEWR Consultation Paper includes commentary regarding ‘Options for reform – Anti-discrimination measures’ noting the extensive range of laws dealing with discrimination in employment areas across the Commonwealth and state and territory laws.
AACS agrees that this array of laws and overlap ‘results in a complex and fragmented scheme that is confusing and difficult for both employers and employees to understand and navigate.’
AACS have indicated in their submission that it is premature for the Government to introduce amendments to the anti-discrimination framework of the Fair Work Act until the ALRC review has handed its final report to the Government at the end of the year.
AACS requested that any proposed changes to the FW Act be accompanied by extensive public consultation following the Government’s response to the final ALRC report.
The Department of the Attorney-General and Justice released the draft Anti?Discrimination Amendment Bill 2022 for public consultation ('Exposure Draft Bill') in June. The Exposure Draft Bill contains a number of proposed reforms to the Anti-Discrimination Act 1992 (the Act), which are the result of a comprehensive review by the Department in 2017?2018. The Department called for submissions to be made by 12 August 2022.
Following a referral by the Attorney-General, the Queensland Human Rights Commission (QHRC) conducted a wholesale review into the Anti-Discrimination Act 1991 (Qld). The QHRC released a Discussion Paper in November 2021 and called for submissions to be made by March 2022. AACS made a submission in March 2022.
This reform proposal considers options for responding to recommendations made by the ACT Law Reform Advisory Council (LRAC) in its 2015 review of the Discrimination Act 1991 (ACT) ('Act'). Most of the LRAC recommendations for change to the Act have already been implemented. However, recommendations in the areas of coverage, exceptions and positive duty remain outstanding. The Justice and Community Safety Directorate released a Discussion Paper in October 2021, to which we have responded.
At the instruction of the WA Attorney-General, the Law Reform Commission of WA is conducting a review of the Equal Opportunity Act 1984 (WA). The Attorney's instruction specifically referenced the exceptions that Christian Schools rely on to build faith-based communities for our children. The Law Reform Commission has provided a Discussion Paper to which AACS made a submission.
AACS provided feedback to ACARA about the proposed revisions to the Australian Curriculum. Christian school teachers were also encouraged by AACS to provide their own feedback about specific subject areas on the proposed curriculum revisions through an online survey.
AACS welcomed the opportunity to provide a submission in response to the Tasmanian Law Reform Institute’s (TLRI) community consultation into ‘sexual orientation and gender identity’ (SOGI) conversion practices. where we outlined our significant concerns about the practical implications of the recent introduction of conversion practice laws in Qld, ACT and currently under consideration by the Victorian Parliament for our staff and parents.
The South Australian Government indicated its intention to amend the Equal Opportunity Act 1984 so that Christian schools will be prevented from relying on the religious exception to anti-discrimination laws, although they have an existing separate exception specifically relating to hiring practices. AACS provided a submission to the consultation.
Christian schools are committed to educating all students wanting a Christian education, including those with disabilities. To meet this challenge and successfully support students with disabilities we recommend the Government consider how it might increase resources for training and support of staff in this area. AACS provided a joint submission along with Christian Schools Australia and Adventist Schools Australia into the 2020 Review of the Standards which you can read below.
The introduction of Mark Latham's Anti-Discrimination Amendment (Religious Freedoms and Equality) Bill 2020 aims to protect religious freedoms in New South Wales through amendments to the Anti-Discrimination Act 1977 (NSW). AACS strongly supports this bill because in the current climate of antipathy towards people of faith we believe a greater level of legal protection for freedom of belief and religion is required. Freedom of belief in a society means having a broad range of educational options through which such beliefs can be expressed. Choice in schooling provides parents with the opportunity to choose a school that is religiously motivated or one that is not. As an association of schools that operate within a multicultural and pluralist society AACS is committed to ensuring that all communities have the freedom to express themselves and live according to their beliefs.
In our submission to the Senate Education and Employment Legislation Committee’s inquiry into funding models, AACS reiterated our desire for a consistent, needs-based, sector-blind school funding model for Australian students and their families. We are grateful that the school funding model is well on the way toward a more detailed collection and analysis of parental income through the first iteration of the Direct Measure of Income (DMI) model to determine Capacity to Contribute (CTC) scores.
AACS commends the Government on its improvements to the Religious Discrimination Bill in response to feedback provided in consultation with the Australian community. It is a step towards our main priority: ensuring that parents retain the ability to educate their children at schools that accord with their faith. The Bill provides that there is no religious discrimination where a religious school engages in good faith in conduct that is in accordance with the beliefs and teachings of their religion. This allows us to maintain our schools’ distinctive culture, ethos and pedagogy. The AACS submissions are below:
AACS submission on the 2nd exposure draft
AACS collaborated with Adventist Schools Australia (ASA), the Associated Christian Schools (ACS) group and Christian Schools Australia (CSA) to lodge a submission to the Queensland Parliament’s Health, Communities, Disability Services and Domestic and Family Violence Prevention Committee. Our submission makes it clear that our groups consider a bill whereby the government mandates a school counsellor’s response to a particular student, regardless of their clinical opinion and under the guise of banning vaguely defined ‘conversion therapy’ – is dangerous and unjustified.
On 22 November 2017, the then Prime Minister, the Hon Malcolm Turnbull, announced the appointment of an Expert Panel to examine whether Australian law adequately protects the human right to freedom of religion. The Panel received more than 15,500 submissions to the Religious Freedom Review. In our submission, AACS requested that the common understandings of religious freedom protection within human rights law be re-affirmed, that areas of ambiguity be clarified, and that more substantive religious and associational freedoms protection be afforded to all religious schools.
In its submission to the Department of Attorney-General and Justice of the Northern Territory in response to its Discussion Paper ‘Modernisation of Anti-Discrimination Act’ (September 2017) argued strongly against the proposals which would lead to the removal of religious and associational freedom presently enjoyed by educational facilities, students and their parents in the Northern Territory.
AACS encourages school leaders to cultivate a positive relationship with their political representatives to ensure they experience the character of our schools and know the contribution they make to the intellectual, economic, social, cultural, moral and spiritual capital of the nation. Local members and senators are open to invitations to visit schools in their electorate and provide an opportunity to highlight the distinctives of Christian education, the importance of parental choice and any local issues. AACS is available to brief school leaders on current issues that you may like to raise with your representatives and prepare you for hosting a school visit or a meeting in Canberra. You can find the contact detilas of your local Member of Parliament here.
School visits to the Nation's Capital provide many rich learning opportunities for students, including a tour of Parliament House, and AACS can assist with advice and support to set up meetings with your local member while you are in here. The Australian Parliament's School Visit Program provides a unique opportunity for primary and secondary schools to gain a first hand appreciation of law-making and democracy in Australia.