Baby Bloom — Childcare Professional Code of Conduct

Introduction

This Code of Conduct sets out the community standards expected of all Childcare Professionals on the Baby Bloom platform. Compliance with these standards is a condition of platform access. Baby Bloom is a platform facilitator — not your employer — and enforces these standards by moderating platform access, not by exercising employer discipline. A breach of this Code may result in restrictions to your platform access (such as suspension of matching or babysitting features, or account termination), but does not create an employment relationship or employment consequences (such as disciplinary proceedings, performance management, or withholding of pay).

1. Confidentiality & Digital Presence

Your Obligation: You must keep all information about Clients, their households, and their children strictly confidential. This is essential for client safety and privacy, and is a legal requirement under privacy and family law.

Definition of “Confidential Information”:

Confidential information includes (but is not limited to):

• Children's names, ages, photos, or identifying characteristics.
• Family addresses, routines, or household details.
• Payment terms or rates.
• Family contact information.
• Medical or developmental information about children.
• Any information discussed in private during care arrangements.

What You Must Not Do (Without Explicit Written Consent from Client):

You must not disclose, post, share, or discuss any confidential information:

• On personal social media (Facebook, Instagram, TikTok, LinkedIn, Twitter, etc.).
• On external platforms or websites.
• In public forums, messaging groups, or community discussions.
• To anyone outside the immediate care arrangement (family members, friends, colleagues).

You MAY discuss your work in general terms (e.g., “I am working as a nanny with young children in Sydney”) BUT NOT identifying details.

Definition of Different Breach Types:

A breach occurs when you disclose confidential information intentionally, recklessly, or through negligence.

1. Minor Breach (Negligent Disclosure): Unintentional or careless disclosure that does not involve sensitive information. Example: mentioning a Client's first name and suburb in casual conversation; leaving a care plan visible where someone could see it.
2. Moderate Breach (Intentional Disclosure of Non-Sensitive Information): Deliberate but non-malicious disclosure. Example: posting a photo of your workplace (not the Client's home) on Instagram; mentioning babysitting details without naming the Client.
3. Serious Breach (Disclosure of Identifying or Sensitive Information): Deliberate disclosure of identifying or sensitive information. Example: posting the Client's address or children's photos on Facebook; sharing Client's medical information.
4. Severe Breach (Malicious Disclosure Causing Harm): Disclosure intended to harass, endanger, or harm the family. Example: posting identifying information with intent to stalk or harass; sharing information that directly causes financial or safety harm.

Consequences for Breaches (Proportionate & Fair):

These consequences restrict your platform access and are applied by Baby Bloom as a platform moderator enforcing community standards, not as employment discipline.

Minor Breach:

• First instance: Written warning and mandatory confidentiality training.
• Second instance (within 12 months): Temporary restriction of matching and babysitting features (7-14 days) + retraining.

Moderate Breach:

• Temporary restriction of matching and babysitting features (1-4 weeks) + mandatory confidentiality training + written apology to Client (facilitated by Baby Bloom).

Serious Breach:

• Extended restriction of matching and babysitting features (1-3 months) + mandatory confidentiality training + written apology to Client (facilitated by Baby Bloom).
• OR immediate account termination (if disclosure involves children's identifying photos or addresses, or if there is a history of prior breaches).

Severe Breach (Malicious Disclosure):

• Immediate account termination.
• Baby Bloom may refer the matter to law enforcement if the breach constitutes harassment, stalking, defamation, or endangerment.

Appeals & Mitigating Factors:

You may appeal any confidentiality consequence by contacting compliance@babybloomsydney.com.au within 14 days, providing:

• Explanation of mitigating circumstances.
• Evidence of your intent (if you claim it was accidental).
• Commitment to prevent future breaches (e.g., agreed to privacy training).

Exceptions (You Are NOT Breaching Confidentiality If):

You are not breaching confidentiality if you disclose information:

• To comply with mandatory reporting obligations (see Section 6) — you MUST report child safety concerns to NSW DCJ at 132 111.
• To law enforcement or government agencies with proper legal authority (warrant, court order, subpoena).
• To a lawyer or counselor for your own legal advice or mental health support (and they are bound by professional confidentiality).
• With explicit written consent from the Client.

2. Communication & Punctuality

Baby Bloom expects professional standards of communication:

• Respond to messages and connection requests within 24 hours.
• If you accept a booking or introduction, follow through with the commitment.
• If you need to cancel, communicate as early as possible (minimum 7 days' notice for confirmed bookings, where feasible).
• “Ghosting” — accepting a booking or introduction and then failing to show or respond without notice — is a serious breach.

Definitions:

• “Reasonable timeframe”: 24 hours for non-urgent messages; 2 hours for booking requests.
• “Ghosting”: Failing to respond to a Client within 24 hours after confirming a booking or introduction, or failing to appear for a confirmed booking without notice or valid reason.
• “Valid reason for late cancellation”: Medical emergency, family emergency, or unexpected illness (with evidence if requested).

Consequences (Platform Access Restrictions):

• First instance: Written warning. Baby Bloom may restrict your ability to accept new bookings for 7 days.
• Repeated ghosting (2+ instances in 12 months): Temporary restriction of babysitting features for 1 week.
• Serious/habitual ghosting (3+ instances in 12 months): Account termination under Section 3.

Appeal: You may appeal any restriction within 14 days by contacting compliance@babybloomsydney.com.au with explanation of any mitigating circumstances.

3. Babysitting Cancellation Rules and Consequences

Why This Matters: When you accept a babysitting booking, the Client is depending on you to provide care. Cancellations create hardship for families and undermine trust in the platform. However, we also recognize that legitimate emergencies happen. These rules are designed to distinguish between avoidable cancellations and genuine emergencies, and to impose proportionate consequences.

Tracking Cancellations:

Baby Bloom tracks babysitting cancellations within a rolling 12-month period.

Types of Cancellations (And Whether They Count):

Legitimate Cancellations (Do NOT Count Toward Limit):

• Medical emergency or sudden serious illness (with medical certificate or family member testimony).
• Death or serious illness of an immediate family member (with death notice or family testimony).
• Childcare provider emergency affecting your ability to work (e.g., unexpected illness of your own child).
• Natural disaster or government-ordered emergency (flood, fire, lockdown).
• Court-ordered appearance or legal emergency.

If you cancel due to a legitimate emergency, contact Baby Bloom immediately with evidence. This cancellation will NOT count toward the 3-cancellation limit.

Avoidable Cancellations (Count Toward Limit):

A cancellation counts toward your limit if you accept a babysitting job and then cancel without a legitimate emergency reason.

Cancellations are counted based on notice period:

• With 24+ hours' notice: 1 cancellation point.
• With less than 24 hours' notice: 2 cancellation points.
• No notice (ghosting — no response for 24 hours after confirming): 3 cancellation points.

Example: Cancelling 1 job with 48 hours' notice = 1 point. Cancelling 1 job with no notice = 3 points.

Consequences for Avoidable Cancellations (Platform Access Restrictions):

Example: If you cancel 1 job with 24+ hours' notice (1 point) and later cancel another with no notice (3 points), you have 4 points total and face a temporary suspension.

Your Right to Appeal:

You may appeal any consequence by contacting compliance@babybloomsydney.com.au within 14 days of receiving the notice.

To Appeal:

1. Provide details of each cancellation that contributed to the consequence:
   • Date of cancellation.
   • Reason for cancellation (if you dispute the categorisation as “avoidable”).
   • Any supporting documentation (medical certificates, death notices, communication logs, etc.).
2. Baby Bloom will appoint a senior staff member (not involved in the original decision) to review your appeal.
3. The reviewer will consider:
   • The circumstances of each cancellation (distinguishing between emergencies and avoidable cancellations).
   • Your history on the platform (overall reliability, tenure, past behavior).
   • Any mitigating factors you have provided.
4. Baby Bloom will provide a written decision within 7 business days, explaining:
   • Whether the consequence is upheld, reduced, or lifted.
   • Specific reasons for the decision.
   • Any conditions for reinstatement (e.g., “you must not cancel for 4 consecutive bookings”).
5. If you disagree with the appeal decision, you can escalate to another senior staff member within 7 days.

Lifting Restrictions Early:

After serving a restriction period, you can request early reinstatement if you:

• Complete a professionalism or communication skills training module.
• Demonstrate commitment to reliability (e.g., accepting and completing 5 consecutive babysitting jobs without cancellation).

Contact compliance@babybloomsydney.com.au to request early reinstatement. Baby Bloom will respond within 5 business days.

Reset of Rolling Count:

The 12-month rolling period is calculated from the date of each cancellation. Once 12 months have passed from any cancellation, it drops off your count.

Example: If you had cancellations on Jan 1 (1 point), Feb 15 (3 points), and Mar 30 (2 points) in Year 1, you have 6 points total (suspension triggered). On Jan 2 of Year 2, the Jan 1 cancellation drops off, leaving you with 5 points. On Feb 16, the Feb 15 cancellation drops off, leaving you with 2 points. This allows you to “reset” if you improve your reliability.

4. Safe Care Standards

When providing care, you must:

• Maintain appropriate hygiene and cleanliness standards
• Actively supervise children at all times
• Follow the Legal Guardian's household rules, routines, and care instructions
• Respect any screen time limits set by the family
• Not transport children in a vehicle unless expressly authorised by the Legal Guardian and you hold a valid driver's licence and vehicle insurance

5. Platform Integrity

• Use the Baby Bloom platform for its intended purpose only
• Do not solicit Clients for services unrelated to childcare
• Do not attempt to circumvent platform features, verification requirements, or connection processes

6. Mandatory Reporting

You have legal obligations under two NSW frameworks:

1. Children and Young Persons (Care and Protection) Act 1998 (NSW):

If you become aware of any situation involving Risk of Significant Harm (ROSH) to a child (such as abuse, neglect, or exposure to domestic violence), you must report it to the NSW Department of Communities and Justice (DCJ) Child Protection Helpline:

NSW DCJ Child Protection Helpline: 132 111 (available 24/7)

2. Disability Inclusion Act 2014 (NSW) — If Applicable:

If you provide childcare to a child with a disability and become aware of abuse or misconduct involving that child, you may also have obligations under the Disability Inclusion Act 2014 (NSW). Contact the NSW Office of the Ombudsman if you are unsure:

NSW Ombudsman: 1800 451 524

Important:

• Logging an incident on Baby Bloom does not replace your legal duty to report to government authorities.
• You must report to the authorities listed above, even if you also report to Baby Bloom.
• You are protected by law from reprisal when reporting in good faith.
• For more information on mandatory reporting: www.dcj.nsw.gov.au/children-and-families/protecting-children-and-young-people/mandatory-reporters

7. Online Safety

Baby Bloom complies with the Online Safety Act 2021 (Cth). You must not post, upload, or share harmful, abusive, or threatening content on the Platform. If you encounter harmful content, report it through the Platform's reporting mechanism.

8. Anti-Discrimination

You must not discriminate against any Client or family based on race, colour, national or ethnic origin, age, sex, sexual orientation, gender identity, disability, religion, or any other protected attribute under the Anti-Discrimination Act 1977 (NSW).

9. Consequences and Disciplinary Procedures

Baby Bloom uses a graduated, proportionate response to Code of Conduct breaches. Consequences vary depending on the severity of the breach, your history, and mitigating circumstances. We follow principles of fairness and natural justice, inspired by the ACCC v Mable Technologies decision (which emphasised graduated consequences, transparency, and proportionality in platform enforcement).

Graduated Consequences Structure

These consequences restrict your platform access and are applied by Baby Bloom as a community standards moderator, not as employment discipline.

Level 1 — Warning (Minor or First Breach):

• First violation of communication standards, minor platform misuse, or first confidentiality concern that does not involve disclosure of sensitive information.
• Minor failure to follow Code of Conduct (e.g., unprofessional communication, one avoidable cancellation).
• Action: Written warning identifying:
  • The specific issue and which Code of Conduct section was violated.
  • The expected standard going forward.
  • Timeframe to correct (typically 7-14 days).
  • How to contact Baby Bloom if you need help complying.
• Duration: No restriction of platform services. The warning remains on your account record for 12 months.
• Note: If you receive 2+ warnings within 6 months, further breaches may trigger Level 2 restriction.

Level 2 — Temporary Restriction (Repeated or Moderate Breach):

• Repeated minor breaches (2+ within 6 months despite prior warnings).
• First significant breach: repeated ghosting (2+ instances in 12 months), moderate confidentiality lapse, or violation of safe care standards.
• Failure to comply with a Level 1 warning within the specified timeframe.
• Action: Restriction of matching and babysitting features (access to EdTech and professional profile remains).
• Duration: 1-4 weeks, proportionate to breach severity and your history.
• Notice: Written notice identifying:
  • The specific breach(es) and Code of Conduct section(s) violated.
  • The restriction period and effective date.
  • Your right to respond and appeal (see Procedural Protections below).

Level 3 — Termination (Serious Misconduct):

• Child safety violations (mandatory reporting breach, recklessness in care, endangering a child).
• Fraud or identity falsification (knowingly or intentionally lying on application, submitting fake credentials, falsifying documents, misrepresenting identity, or deceiving Baby Bloom or Clients about material facts).
• Illegal activity (criminal conduct, grooming, harassment, assault, stalking, cyberbullying).
• Serious confidentiality breach (intentional disclosure of child's identifying information or photo with malicious intent).
• Habitual misconduct (3+ Level 2 restrictions in 12 months, or continued breaches after multiple warnings).
• Action: Immediate account termination (in urgent child safety situations) or account termination after due process (see Procedural Protections).
• Notice: Written explanation of serious misconduct provided within 48 hours (or immediately in child safety emergencies).

Procedural Protections (Fairness and Natural Justice)

Baby Bloom believes in fair processes. Except in urgent child safety situations, you will have the opportunity to respond before any action is taken against your account.

For Level 1 & 2 Actions (unless child safety emergency):

1. Right to written notice: You will receive a written notice identifying:
   • The specific breach(es) and which Code of Conduct section(s) were violated.
   • The factual basis for the allegation (e.g., dates, screenshots, or details of the breach).
   • The proposed consequence and duration.
   • Your right to respond and appeal.
2. Right to respond: You have 7 calendar days to respond to the allegation in writing. Your response should address:
   • Whether you dispute the allegation and why.
   • Any mitigating circumstances (misunderstanding, medical emergency, technical issue, etc.).
   • Any supporting documentation (evidence, witness statements, etc.).
3. Right to be heard: Baby Bloom will carefully consider your response before finalising the decision. You will receive a written decision explaining:
   • Whether the allegation is upheld or dismissed.
   • The specific reasons for the decision.
   • The consequence applied (if any), including the duration and effective date.
   • Your right to appeal.
   • Contact information for the compliance team.
4. Right to appeal: You may appeal any Level 1 warning or Level 2 restriction within 14 days of receiving the notice by contacting compliance@babybloomsydney.com.au. Your appeal should include:
   • New evidence or circumstances not previously considered.
   • Explanation of how the consequence is disproportionate to the breach.
   • Any change in circumstances since the original decision.
   • Any procedural fairness concerns (e.g., whether the process was impartial or sufficient).

   A senior staff member (not involved in the original decision) will review your appeal independently and provide a final written decision within 10 business days.

For Level 3 (Termination for Serious Misconduct):

1. Immediate Termination is ONLY permitted if:
   • There is an immediate, serious child safety risk that requires urgent action (e.g., credible evidence of active abuse, grooming, or imminent harm to a child).
   • Even in urgent situations, Baby Bloom will provide written explanation within 48 hours of termination.
2. If Immediate Termination is NOT Required:
   • You will receive written notice of the serious misconduct allegation, the evidence, and the proposed termination.
   • You have 7 calendar days (or longer, at Baby Bloom's discretion, if you request more time) to respond in writing.
   • Your response can address:
     • Whether you dispute the allegation.
     • Mitigating circumstances or explanations.
     • Any supporting evidence or witnesses.
     • Any compelling reasons why termination is disproportionate.
   • Baby Bloom will consider your full response before finalising termination.
3. Right to Appeal Termination: You may appeal a Level 3 termination within 14 days of the termination notice. Your appeal can address:
   • Procedural fairness: Did Baby Bloom follow fair procedures? Was the process conducted impartially?
   • New evidence: Do you have new evidence that contradicts or materially changes the allegation?
   • Proportionality: Is termination proportionate to the breach?

   However, appeals are not a re-trial. If Baby Bloom found you breached mandatory reporting obligations or endangered a child, the appeal cannot overturn that finding unless you have compelling new evidence that the original finding was factually wrong.

   A senior staff member (different from those involved in the original decision) will review your appeal independently and provide a final written decision within 10 business days.

4. Interim Access: During your appeal of a Level 3 termination, your account remains terminated, but you retain access to:
   • Your account data and EdTech records (for export and backup).
   • The appeal process and communications with Baby Bloom.
   • Any refunds due under the SaaS Refund Policy.

Refunds Upon Termination

In all cases where Baby Bloom terminates your account (Level 3), any unused EdTech SaaS subscription fees will be refunded on a pro-rata basis. (See SaaS Refund Policy, Section 6.)

Notice and Communication

Baby Bloom will notify you of any action taken against your account via:

• Email to your registered email address.
• In-app notification.
• SMS (optional, if you have opted in).

Disputes and Questions

If you have questions about a warning, restriction, or termination decision, contact:

• Compliance team: compliance@babybloomsydney.com.au
• Phone: Monday-Friday 9am-5pm AEST

Baby Bloom aims to respond to all inquiries and appeals within 10 business days.

Definitions

“Serious breach”: A violation that poses a risk to child safety, involves dishonesty, or is a repeated violation of a rule after prior warning. Examples include: breach of mandatory reporting obligations, physical harm to a child, gross negligence in supervision, deliberate deception about qualifications or identity, reckless conduct that endangers a child, or criminal conduct.

“Fraud”: Knowingly or intentionally deceiving Baby Bloom or Clients about material facts, including: submitting false or fraudulent identity documents, lying on your application about WWCC status or qualifications, impersonating another person, creating a fake account to evade consequences, misrepresenting your experience or capabilities, or any other dishonest conduct intended to obtain benefit or deceive.

“Ghosting”: Failing to respond to a Client within 24 hours after confirming a booking, or failing to appear for a confirmed booking without notice or valid reason.

“Emergency”: A genuine and unexpected event that prevents you from providing care, such as hospitalisation, serious illness with medical evidence, or death of a family member.

“Risk of Significant Harm (ROSH)”: As defined under NSW law: a situation where a child is at serious risk of significant harm due to abuse, neglect, or exposure to domestic violence.

ACCC v Mable Technologies Compliance Statement

This Code of Conduct has been designed with reference to the Australian Competition and Consumer Commission (ACCC) enforcement action against Mable Technologies (June 2025), which established important legal principles about fair platform enforcement:

1. Graduated Consequences: We impose graduated, proportionate consequences rather than automatic termination. Serious breaches alone do not warrant immediate termination without due process (except urgent child safety situations).
2. Proportionality: Consequences must be proportionate to the breach. A 3-month babysitting suspension for minor cancellations is not proportionate; we cap maximum restrictions at 4 weeks with opportunity for appeal and early reinstatement.
3. Procedural Fairness: We follow principles of natural justice, including: written notice of allegations, right to respond, right to be heard, independent appeal review, and transparent reasoning.
4. Clear Standards: We clearly define breaches and consequences in advance, rather than using vague or discretionary language. “Zero tolerance” rules are avoided in favor of proportionate, context-sensitive responses.
5. Platform Moderation, Not Employment Discipline: As a digital facilitator, Baby Bloom enforces this Code through platform access restrictions (not employment consequences). We do not act as an employer imposing discipline; we manage community standards.

Baby Bloom is committed to fair, transparent, and proportionate enforcement of this Code.

Contact Us

Baby Bloom, Sydney
ABN: 17 463 812 867
Address: 19 St Neot Avenue, Sydney NSW 2011
General: contact@babybloomsydney.com.au
Support: support@babybloomsydney.com.au
Compliance: compliance@babybloomsydney.com.au
Phone: Monday-Friday 9am-5pm AEST
Website: https://babybloomsydney.com.au
Legal: https://babybloomsydney.com.au/legal

Mandatory Reporting:
NSW DCJ Child Protection Helpline: 132 111 (available 24/7)
NSW Ombudsman: 1800 451 524 (Monday-Friday 9am-5pm)

This document should be reviewed by a qualified legal professional before publication.