Education and Training Reform Regulations Review Attn: Strategic Policy Division

30 January 2017

Education and Training Reform Regulations Review Attn: Strategic Policy Division

Department of Education and Training GPO Box 4367 Melbourne 3001

SUBMISSION ON THE DRAFT EDUCATION AND TRAINING REFORM REGULATIONS 2017

I am writing to let you know of my concerns regarding the Draft Education and Training Regulations that was released on 21 December 2016.

I believe that if these concerns are not properly addressed, it will be detrimental to children who are experiencing bullying as well as children with anxiety difficulties, psychological or emotional problems and those with special needs, in addition to any other child deemed at- risk.

Although reports say that bullying in Australian schools is falling, it still remains 'unacceptably high' (Sydney Morning Herald, 1 July 2016). I had to withdraw one of my children from school because of bullying which resulted in anxiety. I have since been home schooling and have kept in touch with the home schooling community here in Victoria. I was informed of the Draft Education Regulations through regular contact with this community.

It is extremely frustrating to know that the home schooling community's concerns were totally ignored by the Department of Education and Training, after some deliberations with the Home Education Network, who act as our representatives.

Personally, the proposals are a problem for me because of the following points:

Rights of Parents and Children

·  It will remove a parent's right to promptly remove their child from school even if the child is in danger. The problem with this is that it can cause emotional and mental anguish to children. I know this firsthand because it happened to my child. I believe that children should not be forced to stay in a dangerous environment.

The government supports individuals to leave an inhumane condition or obtain a restraining order in cases of family violence, harassment at work or in cases of women in abusive relationships. Shouldn't it be right therefore that children in unsafe school environments also be granted this privilege? The quickest and most logical way of removing a child from harm is pulling them out of school.

From the Human Rights website, I gathered: "ICCPR (International Covenant on Civil and Political Rights) Article 24 states: 1. Every child shall have, without any discrimination as to race, colour, sex, language, religion, national or social origin, property or birth, the right to such measures of protection as are required by his status as a minor, on the part of his family, society and the State (https://www.humanrights.gov.au/rights-parents-and-children)."

Approval Prior to Removal

·  It will trap a child in school until the department's decision to accept or reject the home schooling application (re: Regulation 74 (2)(d) "The notice must be given within 28 days after the Authority receives an application in accordance with regulation 72."). This means that a child who is experiencing trauma at school will be trapped while waiting for the outcome. How will the government protect children from harm when their failure in the school system has been the motivation behind the home schooling decision of families?

According to reports published on the Kidspot website, "children who are bullied are three times more likely to show depressive symptoms and children who were bullied were up to nine times more likely to have suicidal thoughts (Facts and figures about bullying, Fiona Baker, Kidspot).” A news article also stated that "Suicide rates among young Australians are at their highest level in ten years, despite a range of prevention strategies and investment from government... (Suicide rates for young Australians highest in 10 years, researchers call for new prevention strategies, Jessica Longbottom, ABC News, 30 Nov 2016)" Are we going to make matters worse with this new regulation approved because of our failure to protect these children?

Increased Power for the VRQA

·  Potentially the Draft Education and Training Regulations will be open to abuse by the VRQA because there are a lot of grey areas in the proposed regulations. It seems to me that the department can have unlimited power and can change the requirements or definitions anytime.

Plans and Support

·  Training and support for school teachers are consistently being organised. However, home schooling parents, are asked to show plans with no training or support whatsoever. When I had to pull my child out of school, the school authorities tried to bully my family. Can't the department support the home schooling parents by working with them to improve their plight seeing that they are already in distress of having to pull out their child from school?

It seems to me that school authorities are more concerned about the SRS funding amount they get. Home schooling parents are working very hard to educate their children at no cost to the government, in most cases.

I believe that the draft education regulations are exceedingly harsh to home schooling parents or parents who wish to home school. If the government is sincere about 'light touch' regulation, then I suggest the draft presented should be changed, starting with a genuine deliberation with the home schooling community to build a workable regulatory rule, which limits the power of the Department over home schooling parents. We should avoid biases by deciding on this matter with the help of those who have a lot more home schooling experience and there are many in the home schooling community.

I sincerely hope that we can all work together and support each other for the benefit of our community, our families and most importantly our children, who are the future of this country.