Risk Management

Global Booking Service

Risk Management Strategy for Student Accommodation


Global Booking Service (GBS) is a homestay organisation providing student accommodation for domestic and international students over and under 18 years of age nationally.  This document is to explain our risk management strategy.

GBS also coordinates short-term group study tour programs for students who wish to visit schools, colleges and universities to enrich their educational and cultural experiences. Study tours are for primary and high school and Uni students aged 10 to 18+ years visiting Australia on a tourist visa. Study tours may include school-arranged homestay.


  • recruits, assesses, approves and engages appropriate homestay hosts
  • places national and international students in homestays and with hosts
  • is responsible for the ongoing monitoring of homestay and host placements
  • ensures appropriate arrangements for the student’s accommodation and welfare are in place
  • manages the exiting of homestay providers and hosts from the program, when required

For the purposes of the Working with Children (Risk Management and Screening) Act 2000 (‘WWC Act’) homestay providers and hosts are ‘engaged in regulated employment’. Each adult residing in the home is taken to be a volunteer ‘engaged in regulated employment’

This means that homestay providers, hosts and adult residents of the home require current Blue Cards / WWC (or exemption cards for registered teachers and police officers).

Each year GBS will review its risk management strategy (‘strategy’) about homestay hosts that:

  1. implements practices and procedures regarding the engagement of homestay providers and hosts to promote the wellbeing of children and to protect the children from harm

  2. includes:

  • a statement of commitment to the safety and wellbeing of children and the protection of children from harm
  • a code of conduct for interacting with children
  • procedures for recruiting, selecting, training and managing homestay providers and hosts
  • policies and procedures for handling disclosures or suspicions of harm
  • a plan for managing breaches of this strategy
  • policies and procedures for compliance with the blue card system
  • risk management plans for high risk activities and special events
  • strategies for communication about this strategy and support for homestay providers and student exchange hosts (e.g. training).


The purpose of this strategy is to actively support the safety, welfare and well-being of children and, in particular protecting them from child abuse in the follow ways:

  1. comply with the WWC Act

  2. to assist hosts to comply with the WWC Act

  3. to recognise that students who are under 18 years of age and in Australia without a parent to care for them are particularly vulnerable

  4. to provide an overarching framework for homestay and short term cultural exchanges which ensures students

  5. are placed into carefully selected homes where they will be safe, cared for and supported during their stay

  6. to promote the safety and wellbeing of students living with homestay providers and hosts

  7. to minimise the likelihood of harm to students living with homestay providers and hosts.


This strategy applies to:

All GBS staff

  1. whose work involves the homestay program

  2. involved in short term cultural programs organised through GBS

  3. interacting with students who are, or are applying to be living with homestay providers and hosts

  4. homestay providers and hosts

  5. residents of and visitors to the homestay and host home

  6. students living with homestay providers and hosts.

Statement of Commitment

GBS is committed to:

  1. the safety and wellbeing of children and the protection of children from harm

  2. providing safe and supportive learning environments

  3. responding when an employee, host or visitor reasonably suspects harm or a risk of harm to students

GBS will actively mitigate risks that it has the lowest tolerance for, including child and student safety.

GBS is committed to ensuring the safety and wellbeing of all children and young people in our programs. GBS demonstrates this by:

  • carefully selecting homestay providers and hosts
  • matching students with compatible homestay providers/hosts
  • ongoing monitoring of homestay/host arrangements, formally and informally

making staff, hosts and students aware of relevant:

  1. legislation
  2. this strategy
  3. policies
  4. procedures, and
  5. the process to follow to immediately report harm, risk of harm or suspicion of harm

Taking action where there has been a breach of:

  1. legislation
  2. this strategy
  3. a policy or procedure

GBS respects students as consumers and recognises that students living in a foreign country and away from their parents are particularly vulnerable. Consequently:

  • students will be treated with respect
  • students will be involved in decisions that affect them and will have their views considered
  • the safety, wellbeing and best interests of the student are paramount ..

Code of Conduct

This Code of Conduct outlines the expected behaviours of all persons interacting with students in a homestay placement.

All people involved in the homestay program

All people (including students) should act in a way that would be considered appropriate when viewed by a third party. People should not put themselves in a position where they are vulnerable to accusations of wrongdoing, for example:

  • residents of the homestay home and visitors should not be alone with a student in a bedroom or bathroom with the door closed

  • homestay students should not be alone with another person (for example, a younger child) in a bedroom or bathroom with the door closed.

Unacceptable behaviour includes:

  • domestic and family violence
  • aggression, intimidation, abuse, name calling and swearing
  • inappropriate comments or behaviour related to a person’s race, religion, disability, gender or sexuality (including racist or sexist jokes)
  • sexual harassment (for example, suggestive comments or jokes)
  • inappropriate or unwanted physical contact (hugging can be unwanted)
  • child abuse
  • criminal offences

Homestay providers and hosts will

  • maintain a ‘professional’ relationship with the student (it is important to maintain appropriate boundaries and not blur the lines between ‘student’ and ‘friend’ or ‘romantic interest’)
  • understand there are differences in what people perceive as ‘appropriate’ due to age, maturity and cultural background
  • ensure all physical contact would be considered appropriate by a reasonable third party
  • ensure alcohol use by residents and visitors does not pose a risk to the student’s safety or wellbeing (students must not drink alcohol)
  • do not use or permit the use of illegal drugs in the home
  • seek support to manage cultural issues from the school, if required
  • treat students with respect and to listen to their concerns
  • are alert to any unsocial or improper behaviour by a homestay student
  • refer to the GBS Student Protection guidelines for information about student protection matters, including student sexualised behaviour, unlawful sexual relationships between children under 16 years of age, harm caused by another student and student self-harm
  • refer all issues of student misbehaviour to the school or the nominated program organiser for an GBS short term cultural program (students must not be subjected to verbal abuse or physical punishment)
  • contact the 24-hour emergency telephone number for the school, or the nominated program organiser for an GBS program, for immediate support outside school hours.


  • ensure age-appropriate supervision and care for students outside of school hours, with extra precautions when visitors are in the house and if there is use of alcohol on the premises
  • never leave a student unsupervised overnight, if they are aged over 18 seek agreement from student and notify GBS before hand – providing emergency contact numbers for the student.
  • contact the school as soon as possible in advance if you cannot supervise the student (for example, if you have to travel and the homestay student cannot travel with you)
  • monitor the student’s outside of school hours activities to ensure they are safe.


  • ensure first aid is administered (if an appropriately qualified person is available) if a student is injured (seek permission from the student, where possible and parent if required)
  • document any first aid given for future reference
  • arrange medical assistance for the student when required (for study tours, contact the tour escort first, where possible unless a medical emergency when 000 should be called)
  • Be aware and how to assist with any ongoing medical situation (student required to notify on application and information to be passed on to host by GBS)
  • ensure appropriate care and supervision of a student who is sick or injured
  • report all injuries and illnesses to the school, or for short term cultural programs report to the nominated Services program organiser, as soon as practicable.
  • If student is intoxicated you need to assess the situation to identify if it is an emergency and an ambulance is required. You need to notify GBS as soon as possible of the situation so that guardians and parents can be made aware.  There are little steps that can be taken to help an intoxicated individual avoid serious health consequences as a result of too much alcohol. You can help by:
  • Continually monitoring the person who is drunk. If you do not know the drunk person, you can ask if you can call anyone to come and get them. If inside commercial premises (e.g. a restaurant or bar), ensure any staff are aware that the person is drunk;
  • Check and monitor the breathing of the person who is drunk;
  • Make sure the intoxicated person does not slip from sleeping to unconsciousness by waking them often. The blood alcohol concentration (BAC) can rise even when someone has stopped drinking alcohol – this means that “sleeping it off” is not safe;
  • Ensure the intoxicated individual is sleeping on their side with a pillow behind them to prevent them from rolling on their back. This will prevent them from choking on their vomit.
  • Never let one drunk person look after another drunk person.
  • Never allow an intoxicated individual drive a car, swim or ride a bike.
  • If the intoxicated individual vomits continually, displays irregular slow breathing, cool pale skin or loses consciousness, it becomes an emergency situation and an ambulance should be called immediately.
  • Emergency Situation: It is important to understand that Alcohol is a toxin and, if drunk in excess in a single occasion, it can lead to alcohol poisoning. Alcohol poisoning can be life-threatening and is an emergency situation that requires help from medical professionals. An ambulance should be called if a person is displaying symptoms of alcohol poisoning. Symptoms of alcohol poisoning include:
    • Mental confusion;
    • Stupor or coma;
    • Vomiting;
    • Seizures;
    • Slow breathing (fewer than eight breaths per minute);
    • Irregular breathing (10 seconds or more between breaths);
    • Hypothermia; and
    • Bluish skin colour and paleness.

In extreme cases of nervous system depression, complete respiratory support may be necessary. Once an ambulance has been called, first aid will optimise health outcomes for the intoxicated individual.

  • If a child is demonstrating violent behaviour notify both GBS and the school immediately for assistance by a professional.


  • permit safe travel arrangements, for example, in registered and roadworthy vehicles with appropriate insurance
  • seek specific permission from the school and student’s parent before allowing the student to travel in a vehicle operated by a provisional licence holder (“P-plates”) (note: study tour students are not permitted to travel in a vehicle operated by a P-plate driver, unless the P-plate holder is 25 years of age and above)
  • do not permit the student to travel in a vehicle operated by a learner licence holder (“L-plates”)
  • ensure use of public transport is safe and age appropriate (with appropriate arrangements to and from the bus stop/train station etc.)
  • All transportation for excursions or airport transfers (drivers) must hold appropriate certification to transport children in a commercial vehicle if not being transported by the host family.


  • respect the privacy of the student while exercising appropriate supervision (for example, knock and wait for permission before entering the bedroom and bathroom)
  • get consent before taking the student’s photograph or making a video recording (students must be appropriately clothed)
  • get consent before sharing information about the student (e.g. posting photos or comments about them on social media).
  • No identifying information should be included with posted photos. This would include first and last name combination, name of school and class.
  • Only those photos shared with GBS will be stored for marketing purposes, no personal identifying information of the students is stored with the photos. Photos are stored with password protection.
  • To avoid reproduction of photos a watermark is added to all uploaded photos
  • Students are required to
  • respect the household rules, household property and residents of the home
  • show consideration and courtesy to all residents of the home
  • ensure their homestay provider/host knows where they are and can contact them at all times

respect the privacy of your homestay/host family, for example:

  • knock and wait for permission before entering a bedroom, bathroom or toilet;
  • get consent before taking photographs or making video recordings of the residents of the home (persons must be appropriately clothed)
  • seek permission before posting any information about the family or the home on social media
  • be respectful in any social media posts or public comments
  • use the internet and social media appropriately, following homestay/host family rules and complying with Australian laws
  • comply with Australian laws and the conditions of their visa
  • do not drink alcohol, smoke, misuse prescription medication or use illegal drugs
  • do not do anything that endangers their safety or the safety of other people
  • do not do anything that may bring their Queensland school or the student program into disrepute.

GBS staff

must comply with:

  • GBS policies and procedures
  • the law

Homestay Recruitment, Screening and Training

GBS’s relevant policies and procedures align with the code of conduct for interacting with children and young people. Hosts are required to read and acknowledge our terms and conditions, orientation and privacy policies before commencement of hosting. This material is updated regularly and always available for hosts to review.

  • All residents over 18 must have their Bluecard’s revalidated prior to the arrival of a student under 18 if less than 3 months since last validation.
  • Properties are inspected every 6 months or, prior to the placement of an Under 18 student into that property, whichever comes first.
  • A record of each property insection is documented in our CRM for reporting purposes.

Procedures for handling disclosures and suspicions of harm

If you become aware or suspect that a student has been harmed or is at risk of harm you must take immediate action.

assess, report https://secure.communities.qld.gov.au/cbir/home/ChildSafety#

GBS employees:

  • follow the Student Protection procedure and comply with mandatory reporting obligations.
  • For allegations against employees, follow the Allegations against employees in the area of student protection procedure.

Homestay providers:

  • inform the school (student coordinator or school principal) and the police
  • and/or Child Safety Services, where relevant.
  • Hosts: notify the nominated program organiser and the police and/or
  • Child Safety Services, where relevant.


  • inform your school (for example, the student coordinator or the school principal) and the police and/or Child Safety Services, where relevant.

What is ‘harm’?

  • Harm is defined as is any detrimental effect of a significant nature on the child’s physical, psychological or emotional wellbeing. It is immaterial how the harm is caused and may include physical, psychological or emotional abuse, neglect and sexual abuse or exploitation. Harm can be caused by a single act, omission or circumstance or a series or combination of acts, omissions or circumstances.

Identifying harm

Indicators of harm may include:

  • demanding or aggressive behaviour
  • sleeping difficulties, often being tired and/or falling asleep
  • low self-esteem
  • difficulty relating to adults and peers
  • abusing alcohol or drugs
  • being unable to explain an injury, or providing explanations that are inconsistent, vague or unbelievable
  • feeling suicidal or attempting suicide
  • having difficulty concentrating
  • being withdrawn or overly obedient
  • being reluctant to go home
  • creating stories, poems or artwork about abuse.

GBS staff managing and recording a disclosure of harm

Reporting requirements and supporting resources are available at:

If a student voluntarily discloses information, the staff member should listen and document the disclosure, as soon as possible, using the student’s own words. If the student makes a disclosure in a public setting and it is inappropriate to continue the conversation immediately, the student should be given an opportunity to finish their disclosure in a more private setting with little delay.

The quality and type of information a student shares can be influenced by the questions or statements posed. If it is necessary to ask questions to clarify information or circumstances, the questions should be open ended, non-leading and carefully worded to encourage students to share information in their own words.

A clear and accurate record should be kept of what questions were asked and the student’s responses. Where possible, the record should reflect the student’s own words and include relevant dates, times and locations.

Homestay providers and hosts managing and recording a disclosure of harm should;

  • remain calm and listen attentively, actively and non-judgementally
  • ensure there is a private place to talk
  • encourage the student to talk in their own words and ensure just enough open-ended questions are asked to act protectively (e.g. ‘Can you tell me what happened’…or ‘Can you tell me more about that’).
  • reassure the student they have done the right thing by telling you
  • advise the student that you need to tell someone else who can help the child
  • Document the disclosure clearly and accurately, including a detailed description of:
  • the relevant dates, times, locations and who was present
  • exactly what the person disclosing said, using “I said,” “they said,” statements
  • the questions you asked
  • any comments you made, and
  • your actions following the disclosure
  • not attempt to investigate or mediate an outcome.

Reporting harm

If you suspect or are told a student has been harmed: do not conduct an investigation – report it immediately.

Homestay providers report to the school’s international student coordinator or school principal and to the Police Service or the Department of Communities, Child Safety and Disability Services (Child Safety Services), where appropriate.

Hosts report to the nominated program organiser and to the Police Service or Child Safety Services, where appropriate.

GBS employees follow GBS procedures and comply with mandatory reporting obligations.

Any person has the right to make a report directly to Child Safety or the Police Service.

Managing breaches of the Risk Management Strategy

A person breaches this strategy if they fail to comply with the Code of Conduct or any of their responsibilities, provided above. Specifically, any action or inaction which compromises student safety is a breach of this strategy and will be dealt with as set out below.

Who manages the breach?

Breaches will generally be managed by the managing director at GBS or the Operations Manager in line with Code of Conduct.

Breach by homestay providers and hosts

Breaches will be managed under the following procedures:

  • Ongoing monitoring of homestay providers and placements – GBS
  • Ongoing monitoring of homestay providers and placements – GBS Study Tours
  • Ongoing monitoring of hosts and placements – GBS

Breach may result in:

  • removal of the student from your residence
  • termination of your participation in the homestay/host program
  • reports to the police or Child Safety Services, if warranted.


Breach may result in:

  • removal from the homestay/host home
  • cancelling your participation in the homestay program
  • suspension or cancellation of enrolment (for study tours this means removal from the school program).

GBS staff

Employee breaches of this strategy will be managed in accordance with processes associated with breaches of the Code of Conduct and the Standard of Practice


Breach by a visitor, volunteer or other person will be managed by Managing Director and the action taken will depend on the circumstances of the breach.

For further information about blue card requirements and processes refer to the Queensland Government Blue Card Services website or the appropriate WWC website in the relevant state or territory.

Risk Management Plans – GBS does not undertake any high risk activities with students.

Strategies for Communication and Support

This strategy is available on the GBS website at:


Students, parents and education agents are advised to access this strategy electronically, on the GBS website.

Hosts are given a copy of this strategy online when they are engaged to host a student. Information about this strategy is provided during orientation for homestay providers and hosts.

GBS staff are provided with regular training, including information about this strategy, throughout each school year. Newsletters and emails are used to inform staff about updates to the strategy.

Related documents

This strategy should be read in conjunction with:

  • any contract between the educator and the homestay provider/host
  • Code of Conduct
  • GBS Terms and Conditions
  • GBS Orientation

(GBS employees only)

  • Working with Children (Risk Management and Screening) Regulation 2011
  • Working With Children Check – Blue Cards
  • GBS Critical Incident procedure


GBS International Student Programs

Telephone: 61 7 30624553

Email: Contact@homestaybookings.com.au


Regular reviews will:

  • incorporate feedback from stakeholders
  • check the strategy reflects current legislation and current GBS policies and procedures
  • check the strategy continues to be effective in addressing risks of harm to students and children
  • incorporate learnings from any critical incidents or reports of harm

last review 20.04.2018