Robust attestation, registration and police vetting


Both the Ministerial Inquiry and the Parker Report commented on the lack of robustness in processes associated with making decisions about a teacher being of ‘good character and fit to be a teacher’. One way for schools to be confident about whether a person is of good character is through police vetting. Registered teachers are police vetted when they apply for registration or are renewing their practising certificate. Applicants for limited authority to teach are police vetted at the time they apply which may be every one, two or three years depending on the role they are employed for.[22]

LegislationThe Education Act places restrictions on the appointments and continued employment of teachers. Section 120B(2) states that No employer shall continue to employ in any teaching position any person who holds neither a practising certificate nor an authorisation, if that person is not under the general supervision of a person who holds a practising certificate.[23] All teachers seeking to gain and maintain a practising certificate with full registration are required to meet the Registered Teacher Criteria. Practising certificates are renewed every third year. Principals recommend beginning teachers for initial full registration and attest that teachers applying for renewal of their practising certificate meet the criteria. Observations, discussions, and documentary sources are used as evidence in the judgement that a teacher has met the criteria.

Attestation that teachers meet the required Collective Agreements’ professional standards,[24] including justifying the annual increment, is undertaken by principals.

The Ministry Circular Number 2010/09[25] states that the following people need to be police vetted:

  • every person who is appointed to a position at a school, who is not a registered teacher or holder of a limited authority to teach, and who works at the school during normal school hours
  • every contractor or employee of a contractor, who has or is likely to have unsupervised access to students at the school during normal school hours, must be police vetted.

All vetting must be repeated at least every three years unless the person concerned is no longer in a role that requires them to be vetted. Schools may choose to police vet other adults who could have unsupervised access to students. For example, they may choose to have police vetting carried out on volunteers or parent helpers in the classroom or attending a school camp.

What ERO evaluated

ERO evaluated whether a school had robust employment practices beyond the appointment that emphasise student safety. ERO focused specifically on:

  • how well employment policies and procedures reflected the importance of student safety
  • the way the trustees, principal, teachers carried out registration, attestation and police vetting of non-teaching staff
  • the situations where the police vetting had not been thorough or the school had identified a teacher of concern.

What ERO found

Key findings

  • Just over half of the schools had robust processes for both teacher attestation and registration. There was a strong relationship between the rigor of attestation and registration processes and the quality of appraisal processes.
  • There was confusion by some schools about the purpose of, and when and how to use, the Registered Teacher Criteria, and the relevant Collective Agreement professional standards.
  • Some schools were not aware of the requirement for three-yearly police vetting of non-teaching staff.

School policies and procedures for teacher registration and attestation

The appraisal policies in 90 percent of schools surveyed included statements signalling that processes were in place to assure the board that teachers are meeting relevant professional standards. In 83 percent of schools, principals said the school provided guidelines for teachers to link their appraisal goals to the Registered Teacher Criteria. Eighty-two percent of primary school principals said their appraisal documentation linked to relevant Collective Agreement professional standards, whereas only 54 percent of secondary principals said their guidelines had such a link.

School practices for teacher registration and attestation

ERO evaluated the robustness of systems for registration and attestation by taking into account:

  • the clarity of process and whether this process was actually followed
  • the quality of the observation, mentoring, and documentation to support the registration application and attestation
  • whether there was a system for knowing when registrations are due.

Forty-nine percent of primary schools and 59 percent of secondary schools were judged as having robust processes for both attestation and registration. In most of these schools the processes were embedded in the appraisal system, so there was a strong relationship between the quality of the appraisal system and the robustness of decisions about registration and attestation. The schools that did not have robust processes to support registration and attestation decisions did not link these decisions to appraisal.

Teacher and principal appraisal intends to:

  • support the improvement of individual capability
  • support the school to meet its goals
  • provide accountability about quality to the wider education sector.

This ERO report focuses on accountability. Schools use of appraisal to promote improvement is discussed in other ERO reports.

Approximately 80 percent of principals surveyed felt the school’s appraisal system was either effective or very effective in determining whether both sets of teaching standards (Registered Teacher Criteria and Collective Agreement professional standards), were being met. Secondary principals were more confident about the processes associated with provisionally registered teachers than primary principals were.

How did schools use both the Registered Teacher Criteria and the Professional Standards?

Many principals said the confusion about the purposes of the Registered Teacher Criteria and Collective Agreement professional standards hindered the appraisal process’s effectiveness. These principals talked about the large range of criteria as each set is quite large in itself, the different time periods that each set of teaching standards is applied to, and the different language used in the two sets of teaching standards.

Principals surveyed were asked about their training in using either the Registered Teacher Criteria or the Collective Agreement professional standards. Leaders in 45 percent of schools had training about the Collective Agreement professional standards, 56 percent about the Registered Teacher Criteria and 42 percent in both. More secondary schools than primary schools had undertaken training about the Registered Teacher Criteria.

Who has responsibility for ensuring registrations are up to date?

It is the principal’s responsibility to attest that teachers meet the Registered Teacher Criteria. Boards often delegated the responsibility for ensuring all teacher registrations were up to date to the principal or a senior manager.

Most of the principals in schools where registrations and attestations were up to date reported this information to boards. In a few cases boards were pro-active and asked for assurance that all teachers working with students were registered. In the schools where the policy and procedures for registration and attestation were not followed there was no accountability system to check that the processes were carried out.

Good practice

Robust processes for registration generally included the following within an appraisal system:

  • opportunities for reflection and self assessment about practice
  • targeted observations and feedback
  • goals and evidence linked to the Registered Teacher Criteria
  • a formal discussion about the evidence/documentation that the Registered Teacher Criteria were being met.

The following two examples show robust final sign-off processes.

A Self-Assessment Tool encourages self analysis and reflection against a set of professional learning goals. One of the goals is based on an inquiry into current teaching practice, and the other on the Registered Teacher Criteria. There is professional learning evidence, including from teaching as inquiry. At least four lessons are observed. Records of professional reflection are considered with a mentor/appraiser. The principal interviews all teachers at this stage. (Secondary school)

Team leaders do appraisals of teachers in their team. They discuss the findings with the principal and put forward recommendations for attestation. The principal reads the file and makes the final decision. (Primary school)

Schools with robust systems understood the purpose of both sets of teaching standards and connected them in ways that linked accountability with improved teacher capability and improved school outcomes within the appraisal system, as shown in the two examples below.

The school integrated the Registered Teacher Criteria and the Collective Agreement professional standards for secondary teachers into a single document which makes the process of deciding whether to attest or not easier. (Secondary school)

The principal, with senior leaders and teachers, has developed a matrix that aligns Registered Teacher Criteria, Collective Agreement professional standards and Catholic Character dimensions in one document. Each dimension has an overarching reflective question for teachers to self reflect and discuss with their appraiser (the principal). (Primary school)

The schools that had robust systems for attestation and registration also kept a register, and actively monitored teacher registration status.

How did schools identify teachers of concern?

The principals of schools with robust systems did not attest that the teaching standards had been met for teachers of concern. Poor practices, and practices that put students’ safety at risk, were noticed in a variety of ways including, but not limited to, the appraisal process. ERO was told by some principals that concerns about teacher practices were more often raised by other teachers, teacher aides, parents or students, and that these concerns were followed up.

The school raises safety issues for discussion with staff each term. They stress the importance of maintaining trust and for all staff to be vigilant with their observations of each other. They encourage staff to notify others of any impropriety they observe or are concerned about. This approach is used to promote staff awareness of student safety, and their own safety, when dealing with vulnerable students.(Primary school)

In some schools, it was students who identified the inappropriate behaviour. For example:

One teacher in the school is working with a team leader to improve her relationships and interactions with students. This support was implemented after a concerned student captured inappropriate interactions on their cell phone video and shared it with parents. (Primary school)

What did robust processes for initial registration look like?

Robust processes to support provisionally registered teachers to become fully registered included:

  • well-designed provisionally registered teacher programmes with regular meetings, discussion, reflection, and mentoring
  • observations focused on particular aspects of classroom practice agreed in advance and feedback provided
  • provisionally registered teachers feeling well supported with opportunities to raise concerns.

Many schools that had robust systems for initial registration did not have equivalently robust systems for the ongoing registrations.

School practices for police vetting of non-teaching staff and school volunteers

School policies, procedures and practices need to reflect the regulations around the ongoing need for police vetting of non-teaching staff or contractors. There was some confusion about who needed initial and ongoing police vets (some schools were unaware that they needed to police vet all non-teaching staff), when the ongoing police vets needed to be undertaken, who was responsible for them, and what the actual process was to obtain them.

Sometimes when the non-teaching person belonged to another organisation schools were unsure about who was responsible for the ongoing police vetting, as illustrated below.

A tutor working in the school has not been police vetted – he works in several schools and it is believed he has been vetted elsewhere. (Primary school)

There is a disconnect between the parish and the school. Some parish members have been on the school site without formal checks. Also a tutor has just arrived at the school to teach French (part time) and the principal is not sure what organisation he is attached to. No police checks were made. (Primary school)

In most schools a particular person was delegated the responsibility of renewing police vets, but in some of the larger schools the delegation was not clear to everyone. Delegated responsibility needs to be detailed in the appointment process of non‑teaching staff. The example below illustrates how one large school assures that all non-teaching staff were police vetted.

The Executive Officer has the contracts for all coaches, technical support and grounds people. She also checks and signs off police vets. She said she often needs to remind teaching staff about the process. (Secondary school)

Many schools that did not have robust systems around student safety, or effective systems for renewal of teacher registration, were those that needed to ensure all non‑teaching staff members are police vetted every three years.

Schools need to decide whether volunteers for particular roles need police vets. It appears many do not request this vetting. If volunteers are not police vetted, the board must assure the community that students will not be put in risky situations. This may mean schools need guidelines about the roles of non-teaching staff and volunteers in their student safety and personnel policies and procedures.


ERO recommends that schools develop rigorous and effective performance management practices around the use of the Registered Teacher Criteria to ensure the safety of their students.

ERO recommends schools review the risks associated with their range of volunteers who support school activities, and make active decisions about which roles need to be police vetted.