The Boys' and Girls' Clubs Association of Hong Kong (BGCA) is guided by the goal of "Nurture the Young, Create the Future" and is committed to creating a socially-conducive environment for the healthy growth of children and youth. In addressing the issue of child abuse, BGCA upholds a zero-tolerance policy and supports legislation, as we believe that children should not be subject to any form or degree of harm during their development. Children often find it difficult to express their feelings verbally, nor can they actively avoid risks on their own. As stakeholders in this society, it is even more important that we adopt a child-centred approach and work together in our respective roles to create a safe environment for children to grow in. The Legislative Council is currently reviewing the Mandatory Reporting of Child Abuse Bill and the Mandatory Reporting Guide. BGCA has the following comments:

1. The social welfare, education and healthcare sectors have different expertise and foci when it comes to child protection. BGCA appreciates the effort of the three professional advisory groups to establish a cross-sector collaboration framework in the guide and jointly promote child protection.
2. BGCA is pleased to see that the Labour and Welfare Bureau and the Social Welfare Department have adopted the sector's suggestion to include a schedule to the bill that outlines the elements that constitute "serious harm", which will help increase the certainty of the reporting threshold. The guide also introduced a reporting flowchart, analytical framework and case scenario examples to help mandatory reporters assess the severity and risk of suspected child abuse cases, and make more comprehensive, objective and accurate judgments. Since the current guide is still a draft, we hope that after the first version has been written, the authorities will invite mandatory reporters from various sectors to attend a briefing session and collect feedback from frontline staff to further improve the guide.
3. Regarding the reporting format, BGCA recommends the establishment of an interactive online platform in addition to written reports. This platform can integrate the reporting flowcharts and analytical framework, so as to help mandatory reporters systematically follow the guide, from assessing the severity and risk of suspected child abuse cases to inputting the necessary and supplementary information, letting them complete both assessment and reporting in one go.
4. BGCA also recommends that the guide provide suggestions on follow-up actions and services to help mandatory reporters complete statutory reporting. This can further protect children suspected of being abused, safeguard the best interests of children, and avoid secondary harm. We also recommend that the authorities provide a simple written response to mandatory reporters regarding the investigation results within a specified timeframe, so as to alleviate their concerns about long-term follow-up after reporting suspected abuse cases.
5. The Social Welfare Department currently publishes the Child Protection Registry Statistical Report annually, which shows the overall situation of child abuse in Hong Kong by sharing cases of child protection and children at risk of abuse reported to the system. BGCA recommends that in the future, the government should compile, publish and discuss data on mandatory reporting of suspected child abuse cases every year. After removing all personal information, the data should be made available to scholars and researchers for further analysis. This will help improve understanding of the characteristics and background of these cases, improve the definition, process and reporting decision-making tools of mandatory reporting, facilitate the planning and development of child protection services, evaluate the effectiveness of child protection work and more.

The Bills Committee has started reviewing the provisions and the reporting guide is also under preparation. To facilitate the effective implementation of the legislation, the government must provide the sector with adequate training and supporting resources as soon as possible. This will help frontline staff master the knowledge and skills for early identification and early intervention, familiarise themselves with the reporting mechanism, enforcement procedures and reporting decision-making tools, and develop the confidence to fulfil their statutory duties and provide professional services. Mandatory reporting is only one part of child protection. Protecting children from harm is a shared responsibility of all stakeholders in society. We hope that the government will continue to prioritise children's interest, invest resources, and jointly promote child protection work.