Birth registration and birth certificates: report

6. Vulnerable groups

6.1 This chapter explores barriers to birth registration and obtaining a birth certificate for vulnerable groups. The Registry has a general function to maintain and update the Register for the whole of the Victorian community under the Births, Deaths and Marriages Registration Act 1996 (Vic).[1]

6.2 As identified in earlier chapters, while the majority of the community completes birth registration in a timely manner, considerable barriers can be encountered by some, particularly disadvantaged and vulnerable groups.

6.3 The Commission heard during consultations and from submissions that the sections of the community most likely to experience difficulties with registering a birth and/or accessing a birth certificate include:

• Indigenous people, including members of the Stolen Generations

• culturally and linguistically diverse (CALD) communities

• young parents

• homeless people

• children in out-of-home care[2]

• young adults who have left care out-of-home care

• former wards of state or those who were raised in institutional care, and

• members of the community living in low socio-economic circumstances.

6.4 The particular issues faced by the Indigenous community, CALD communities, young parents and other vulnerable groups are discussed in this chapter. Issues relating to children currently in out-of-home care, young adults who have left care out-of-home care, former wards of state and those raised in institutional care were discussed in Chapter 4.

The Indigenous community

6.5 The terms of reference direct the Commission to consider barriers to birth registration specific to the Indigenous community and to identify practical solutions. As discussed in previous chapters, the origins of this project stemmed from a low rate of Indigenous birth registration in the East Gippsland area. This matter is now the subject of a three-year Australian Research Council inquiry across a number of jurisdictions.[3]

6.6 Barriers to birth registration and obtaining a birth certificate specific to the Indigenous community were raised in a number of consultations and within submissions.[4] In its submission to the Commission the Castan Centre noted that:

Aboriginal people may be experiencing problems associated with the birth registration and certification system in contrast to many others in broader society. Available information suggests that the system’s legislative and policy framework may operate to indirectly discriminate against Aboriginal people.[5]

6.7 One difficulty with identifying Indigenous-specific issues in this area is the lack of available data. As discussed in Chapter 2, the Registrar does not collect particulars of ethnic origin or Aboriginal and Torres Strait Islander status at the time of birth notification. Particulars of Indigenous status are collected at registration. But, if a child is not registered, there is currently no way of determining that child’s Indigenous status. Consequently, there is no data to support the considerable amount of anecdotal evidence that Indigenous children are over-represented among those children not registered.

The work of the Victorian Registry with the Indigenous community

6.8 Over recent years the Registry has been working to address apparently lower than average birth registration and birth certificate application by Indigenous people. In May and June 2009 Registry staff visited a number of regional locations (Mallee, Hume, Gippsland and Warrnambool) to encourage Indigenous birth registration and to assist with birth certificates.[6] This work was undertaken in conjunction with the Koori Justice Unit of the Department of Justice and the Mildura Local Indigenous Partnership Project. The Registry continued this work in other regions, developing links with community service providers in multiple regional locations, including Mildura East and Lake Tyers.[7] These are commendable initiatives.

6.9 The Indigenous Access Fund (IAF) was established in October 2010 as an initiative to encourage Indigenous people to apply for life event certificates. The IAF meets the cost of standard certificates for births, deaths and marriages, subject to the criteria being satisfied by the applicant. The establishment of the IAF, and the criteria for access to the fund, were discussed in Chapter 5.

6.10 In 2011, an initiative in the Barwon South West region involved the justice bus visiting locations across the region to promote the IAF.[8]

6.11 During consultation the Commission heard favourable comments about work undertaken in the East Gippsland region by the Registry and other local partners to encourage birth registration and obtain birth certificates for community members, particularly members of the Lake Tyers Aboriginal Trust.[9] The Castan Centre also commented positively on the work undertaken by the Registry in their submission:

We have been heartened by the positive response made by the Victorian Registry of Births, Deaths and Marriages to dealing with Indigenous communities, especially in East Gippsland where the problems faced by such groups was first publicised. The success of programs to increase registration and certification there is to be applauded.[10]

6.12 As part of this work the Registry has established an Indigenous Access Team (IAT), which aims to provide a coordinated point of contact for enquiries by members of the Indigenous community. The IAT consists of a customer service officer and a Register Data Integrity Coordinator who provide this service in addition to other Registry tasks.[11]

6.13 Although considerable work has been undertaken in this area, little public reference is made to it. The Registry website does not include information about how to apply to the IAF or for additional support with obtaining a life event certificate. As raised in the previous chapter, the Registry has informed the Commission that further information about the team as well as general information about the Registry’s work to assist Indigenous community members will be available shortly on its website.[12]

Community responses

6.14 As discussed in the previous section, while work has been undertaken by the Registry, issues raised with the Commission during consultation suggest that further work may be needed to fully meet the needs of Indigenous Victorians regarding to access to Registry services.

6.15 Submissions to the review highlighted a number of ongoing barriers birth registration for Indigenous people. The VEOHRC identified:

marginalization from mainstream services, a lack of confidence in engaging with authorities, low literacy levels and a lack of awareness of the benefits of birth registration and the requirements to give effect to it.[13]

6.16 The Castan Centre concluded that:

Rather than any single factor being the cause of comparatively low rates of Indigenous birth registration, it appears that a number of issues operate together to reduce the level of completion of birth registration and certification processes by members of the Victorian Indigenous community. Good socio-legal policy requires that these be dealt with together.[14]

6.17 Other barriers raised during consultations included:

• the cost associated with obtaining a birth certificate and/or searches of the Register[15]

• the requirement to provide additional proof of identity when applying for a birth certificate as an adult [16]

• the requirement to provide the name of the father on the birth registration statement[17]

• lack of transport and isolation preventing access to Registry services.[18]

6.18 Some of these barriers apply to a range of vulnerable groups but some have specific relevance to the Indigenous community. One such barrier includes a fear of engaging with mainstream health services.[19] Participants noted that due to past removal policies, some Indigenous parents were reluctant to register the birth of their child or engage with mainstream maternal and child health (MCH) and/or hospital services.[20] In its submission the VEOHRC, referring to earlier work by the Castan Centre, noted that:

Discredited policies that permitted Indigenous children to be removed from their parents, creating the Stolen Generations, has [sic] contributed to a hesitance of some families to register births which may trigger memories of intergenerational trauma.[21]

6.19 In earlier commentary, the Victorian Aboriginal Legal Service (VALS) noted that its clients may mistrust authority to such an extent that they do not want their details to be recorded on any formal system.[22] VALS has also noted that past government policies have led Indigenous people to conclude ‘that it is too difficult to trace their birth certificates’.[23]

Victorian implementation of recommendations emerging from the Bringing Them Home report

6.20 The national report on the Stolen Generations, Bringing Them Home[24] made a number of recommendations relevant to the experiences of Indigenous people in accessing their own records, including birth certificates. One of the recommendations of the inquiry was that each jurisdiction establish a records taskforce whose roles would include:

• the development of common access guidelines to enable Indigenous people to access their records as appropriate to the jurisdiction and in line with privacy principles

• advising government generally on access to, and use of, Indigenous records, including personal records

• advising government on the need to introduce or amend legislation to put these policies and practices into place.[25]

6.21 During consultations, one group of participants referred to the specific minimum access standards of the Bringing Them Home inquiry,[26] including the right of every person, upon proof of identity only, to view all information relating to himself, or herself, and to receive a full copy of the relevant documents. It was also noted that the inquiry had recommended that no application fee, copying fee or other charge of any kind should be imposed.[27]

6.22 Participants consulted felt that Victoria had not fully implemented the recommendations of the inquiry and that more could be done to consult with Indigenous organisations about meeting their needs in terms of access to Registry services.[28]

6.23 The Victorian response to Bringing Them Home, the Koori Records Taskforce (the Taskforce),[29] worked to develop a number of resources that would assist Indigenous people and organisations to access records.[30] The Taskforce also reported on the progress made in implementing the recommendations of the Bringing Them Home report, in the Victorian Koori Records Taskforce: Final report.[31]

6.24 The Taskforce worked to develop specific common access principles (CAPs) for Victoria, some of which reaffirmed the principles contained in Bringing Them Home. The Taskforce’s nine CAPs were included as part of a memorandum of understanding (MoU) which Taskforce partner agencies were asked to sign. The Taskforce final report noted that:

These core Common Access Principles will be fundamental to reducing barriers to better records access to Stolen Generations members across government and non-government recordkeeping agencies.[32]

6.25 The Taskforce further noted that as part of the implementation of its recommendations the government has funded Connecting Home Limited to provide further support for members of the Stolen Generations, and that:

part of the implementation of the MoU, Connecting Home anticipates that signatory agencies will formalise these access principles for Stolen Generations members, which will enable easier access to relevant records and information about themselves and their family.[33]

6.26 The Commission understands that a number of partner agencies have adopted the Taskforce’s MoU either formally or informally. The Department of Human Services (DHS) Family Information Networks & Discovery (FIND), for example, provides a no-fee service for Indigenous clients to access records.[34] The final Taskforce report noted that discussions with the Registry had concluded that requests from members of the Stolen Generations, while welcome, would be dealt with on a case-by-case basis rather than under a MoU.[35]

6.27 The Registry’s approach is different to that taken in, for example, New South Wales and South Australia. Both registries have signed up to MoUs emerging from the recommendations of the Bringing Them Home report.[36] The Commission understands that the NSW Registry MoU with Link-Up NSW includes support for members of the Stolen Generations who may not possess sufficient identity documents.[37]

6.28 The Link-Up SA website notes that the MoU with the SA Registry helps caseworkers to find records which may lead to family reunion.[38] The purpose of the MoU is to improve access to records and to reduce costs and waiting times.[39]

6.29 The Commission did not have access to the specific MoUs signed in South Australia and New South Wales, and so cannot comment on their effectiveness.

6.30 The Victorian Registry considers that section 49 of the Act,[40] which allows a discretionary fee waiver, can only be applied on a case-by-case basis and not applied to a class of people such as the Stolen Generations.[41] The interpretation of this provision was discussed in Chapter 5.

Commission’s view

6.31 The Commission notes the recent efforts made by the Registry to work cooperatively with Indigenous organisations and individuals. This includes the recent changes in Registry practice to accept a letter from Link-Up as sufficient proof of Indigeneity for applicants accessing the IAF.

6.32 The Commission notes, however, that the IAF is subject to the applicant meeting the financial criteria of possession of a health care or pensioner concession card. This means that, potentially, not all members of the Stolen Generations have access to their records without a fee being charged, as was recommended in the Bringing Them Home report.

6.33 This situation would be addressed if the Registrar developed guidelines providing for a full fee waiver for members of the Stolen Generations.

6.34 The application fee for a birth certificate is made up of two fees: one for the search, and one for the certificate. The Commission was advised by the Registry that if a first search does not reveal sufficient details for a certificate to be issued, further searches of the Register are undertaken without extra charge.[42] The Registry has indicated that a fee is only payable if the search is successful and a certificate issued.

6.35 The Commission is of the view that some of the problems people have in obtaining their birth certificate will be addressed if its recommendations in relation to a fee exemption and fee waiver are implemented. The Commission considers, however, that for the purposes of clarity and in keeping with the recommendation of the Koori Records Taskforce, an MoU between the Registry and agencies assisting Indigenous people, particularly members of the Stolen Generations, would be helpful. The MoU could outline how agencies can access Registry services and on what basis. For example, an MoU between the Registry and Link-Up Victoria could contain a protocol for Registry searches, and when and if a fee will be charged for searches and issue of certificates.

6.36 In Chapter 5 the Commission recommended that section 49 of the Act be amended to allow fee waivers to be granted to a class of people. Even without this amendment, however, the Commission believes that a MoU could still provide clarity to relationships between the Registry and organisations assisting Indigenous people to use Registry services.

Recommendation

19 The Registrar should develop Memoranda of Understanding with relevant organisations assisting members of the Stolen Generations and other Indigenous people to access their records, which cover both birth certificate applications and registry searches.

Awareness-raising activities with the Indigenous community, including operation of, and access to, the IAF

6.37 A number of submissions commented specifically about collaborative action the Registry could initiate to raise awareness among the Indigenous community about birth registration. VEOHRC, for example, submitted that:

The Registrar should collaboratively develop strategies with the Aboriginal community to ensure that families within the Aboriginal community are aware of the benefits associated with registering a birth and being issued with a certificate. The Registrar should consult with the Aboriginal community to develop or expand culturally appropriate solutions to non-certification, for example, supporting birth registration units within regional Aboriginal communities, employing Aboriginal staff, and mobile units regularly accessing remote areas.[43]

6.38 Liberty Victoria recommended that:

The Registrar of Births, Deaths and Marriages should develop strategies and initiatives to communicate with relevant Aboriginal and other communities to ensure that individuals are aware of the benefits of registering a birth and receiving a birth certificate, and to promote and facilitate the registration process.[44]

6.39 The Commission heard of examples of community-based initiatives, including the development of Koori liaison posts in hospitals. For example, the Koori Liaison officer based at the Latrobe Regional Hospital helps new mothers with filling in forms after the birth.[45] Consultation participants felt that this approach had been successful due to the culturally appropriate and non-judgmental way it was done.[46]

6.40 In consultation, one young Koori mother commented that the local Koori Liaison Officer had visited her in hospital after the birth of her child and helped with the paperwork, which she found very helpful.[47]

6.41 The Gippsland and East Gippsland Aboriginal Co-operative (GEGAC) was also cited in consultation for its work assisting Indigenous families to obtain birth certificates.[48] It was noted that young Koori mothers are more likely to go to the local co-op than use mainstream services.[49]

6.42 The Commission notes the Victorian Government initiative Balert Boorron: The Victorian Plan for Aboriginal Children and Young People (2010–2020).[50] The plan aims to improve outcomes for Indigenous children and young people within a human rights framework.[51]

6.43 The ‘Welcome Baby to Country Project’, a joint initiative of Barengi Gadjin Land Council, Delkaia Aboriginal Best Start and Horsham Rural City Council, invites new Indigenous parents to a ceremony of welcome near their home that focuses attention on children’s needs and achievement, and also acknowledges the role of carers and families in their growth and development.[52]

6.44 The project was reported to be successful in increasing the engagement of carers and families with relevant support services. It also provided an opportunity to supply information, resources and assistance on children’s needs and health and wellbeing issues.[53] It has also been reported that the program encourages and facilitates Aboriginal and Torres Strait Islander birth registration.[54]

6.45 During consultations specific issues were raised in relation to the operation and awareness of the IAF. The history and outline of the fund were discussed in Chapter 5.

6.46 A number of consultation participants, both Indigenous and non-Indigenous, were not aware of the IAF.[55] For example, in a consultation with a local Boorai Group (Indigenous new parents/baby group) participants said that they had not heard of the IAF.[56]

6.47 Staff from one justice service centre noted that they had received a number of IAF applications, but suggested that this was most likely due to a former member of staff having moved to the local Rumbalara Aboriginal Co-operative.[57] Another regional justice service centre expressed a similar sentiment, noting a transfer of a staff member to the Mildura Aboriginal Co-operative had resulted in a greater awareness of the IAF.[58]

6.48 The Commission heard that not all justice service officers routinely raise the availability of the IAF, as staff reported they wished to be sensitive about making assumptions about a person’s identity.[59] The Mildura justice service centre, however, noted that its staff will always inquire in a sensitive manner whether the applicant wishes to use the IAF, and then discuss eligibility.[60]

6.49 The role of the Registry in promoting awareness of the IAF was raised in submissions and consultations. The LIV, for example, discussed some of the positive awareness-raising activities the Registry has undertaken with Indigenous communities to date.[61] Some health professionals informed the Commission that they had heard about the IAF through word-of-mouth.[62]

6.50 The NSW Registry has an Indigenous Access Program, promoting the value of birth registration and offering registry services by Indigenous staff members on request. Of particular note is the NSW Registry’s information on dealing with identification issues for members of the Stolen Generations and the ability to apply for a fee waiver.[63]

Commission’s view

6.51 While acknowledging the valuable work already undertaken by the Registry, the Commission is of the view that there is scope for further work to be done to make services more accessible for the Indigenous community. The Registry should continue to build on connections already made in the community through previous awareness-raising activities.

6.52 In light of the forthcoming changes to the Registry website and inclusion of publicly available information about the Registry’s Indigenous Access Program, the Commission makes no recommendations at this time. It appears that the changes proposed will go some way in addressing the issues raised with the Commission in consultations and submissions.

Birth registration work with the Indigenous community in other jurisdictions: The Minimbah School project

6.53 Recent work has been undertaken in Armidale, New South Wales examining the issue of birth registration and birth certificates at a local primary school.

6.54 The Minimbah School project had its origins in a financial literacy project run by teaching students at the University of New England (UNE), working in the Students in Free Enterprise (SIFE) program.[64] SIFE students worked with students at Minimbah School to open their own bank accounts, to promote money management skills. During this process SIFE students discovered that a number of the Minimbah students did not have the requisite primary identification, such as a birth certificate, to open a bank account.[65]

6.55 Further research identified approximately 300 local children who had not had their birth registered or did not have a birth certificate. Many of these children were Indigenous. UNE and community partners have now run two registration drives, the first in 2011 and the second in 2012 (across a number of local schools in the region), aimed at ensuring all students have their births registered and have birth certificates.[66]

6.56 Legal Aid NSW referred to the Minimbah School project in its submission:

[i]deally this kind of service would be provided not just in cases where communities have been able to raise funding privately or through ad hoc applications to government, but government would facilitate a low-cost (or no cost) means of providing birth documentation to people in communities across the country.[67]

6.57 A delegation from the project has met with Commonwealth ministers to advocate for birth certificates to be issued free of charge upon registration.[68] On invitation from the federal Member for New England, the delegation visited Canberra in February 2013 to advocate for a National Partnership Agreement between all states and territories at the Council of Australian Governments.[69]

6.58 The Commission notes the Attorney-General for Australia, The Hon Mark Dreyfus QC, recently indicated his intention to raise the profile of the issue, stating that in his view:

states and territories should look at the possibility of having a fee waiver for people that can’t afford a birth certificate, can’t afford the fee.[70]

6.59 With regard to the proposed fee waiver issue, the Attorney-General noted his intention to raise the issue at the Standing Council on Law and Justice in April 2013.[71] No further information from the meeting has been made publicly available in a communiqué.

Culturally and linguistically diverse communities

6.60 Victoria has a diverse population, with many ethnic backgrounds and language groups represented. At the 2011 Australian Bureau of Statistics Census, 26.2 per cent of Victoria’s population were born overseas[72] and 46.8 per cent of Victorians were either born overseas, or have a parent who was born overseas.[73] Victorians come from more than 200 countries, speak more than 230 languages and dialects and follow more than 130 religious faiths.[74] Culturally and linguistically diverse (CALD) communities have a high ratio of young families compared to the general population and many of these families have migrated to Australia in the last 10–15 years.

6.61 At present the Act does not require ethnicity particulars to be included on the birth notification or registration. The Births, Deaths and Marriages Registration Regulations 2008 (Vic) (the Regulations) require that a parent’s Indigenous status be included in the birth registration particulars, but no other details of ethnicity are required.[75] It is therefore difficult to conclude, definitively, whether CALD groups are over-represented in unregistered births, are less likely to obtain a birth certificate at the same time as registration, or have difficulty obtaining a certificate at a later date.[76]

6.62 The submission from the Royal Women’s Hospital, the largest Australian provider of specialist services to women and newborns, notes that every year ‘[The hospital] provide 200,000 occasions of care for women from 65 different countries who speak 81 languages and follow 42 religious faiths’.[77] The submission from the hospital states that:

the health literacy of culturally and linguistically diverse (CALD) women is typically relatively low because of language and cultural barriers to receiving and exchanging health information.[78]

6.63 During consultations the Commission met with service providers, organisations and individuals who serve members of the community from CALD backgrounds, and/or are from a CALD background themselves. Specific issues with regard to accessing health and government services, including the registration of births, were raised. These are discussed further below.

Services currently provided to people from CALD backgrounds

6.64 At present the birth registration statement and birth certificate application forms are available in English, with access to interpreting and translating services highlighted on the back page of both forms in English. The current birth registration statement form (Appendix C) notes:

If you require access to a translation or interpreter service to complete this form, please call the Translating and Interpreting Service (TIS) on 13 14 50 and ask them to contact the Registry on 1300 369 367.[79]

6.65 This form provides a translation of the above information in Arabic, Chinese (Traditional), Polish, Russian, Spanish, Turkish and Vietnamese.[80] The birth certificate application form notes the contact number for TIS, but the information is not provided in any other languages.[81]

6.66 The Registry website also includes information about the availability of interpreting services for assistance with translating website content. To the Commission’s knowledge no Registry material is provided in languages other than English and no Registry programs currently exist that specifically target CALD communities.

6.67 Justice service centres that provide Registry services also have access to the TIS.[82] The Department of Justice has recently produced a guide to justice services for newly arrived communities. While the guide lists the Registry’s number under useful information,[83] it does not discuss the requirement to register the birth of a child.

6.68 More broadly, the Victorian government’s maternal and child health (MCH) enhanced services, as discussed in Chapter 3, prioritise access to health services and early intervention for vulnerable families (including CALD and Indigenous mothers).[84] During consultations the Commission heard an example of one enhanced MCH practitioner who had attended the Registry office with a client from a CALD background to help her to register the birth of her baby.[85]

6.69 General MCH services provide support for mothers and babies by facilitating new parent groups. The MCH program includes an optional unit for parents from CALD backgrounds. This unit provides information on support resources for parents from CALD backgrounds.[86]

Community responses

6.70 The consultation paper asked the community what barriers people from CALD backgrounds may encounter when registering the birth of their child or applying for a birth certificate. The paper also sought community views on practical solutions to help overcome any identified barriers.

6.71 The Commission received a number of submissions that identified issues specific to CALD communities. Community consultation also provided an insight into the difficulties members of CALD communities may have in navigating the birth registration process.

6.72 The Commission notes that during consultation it became apparent that significant diversity exists within, and between, CALD communities. This was particularly apparent with regard to knowledge and understanding of the birth registration process, as well as level of English, literacy and the ability to complete a birth registration statement without assistance. The issues identified are discussed below.

Language and literacy

6.73 Language barriers were cited as one of the key issues affecting successful birth registration for people in CALD communities.[87] During consultation, language was often raised in conjunction with issues about literacy and general understanding, and awareness of bureaucratic processes and the rights and responsibilities of Victorian citizens.[88] Community and government agencies working with CALD communities, as well as midwives, commented that help with completing forms is often requested, noting that it is sometimes very difficult for members of the CALD community to complete the forms independently.[89]

6.74 The Spectrum Migrant Resource Centre informed the Commission that people from a CALD background, particularly refugees, can have difficulties navigating government agencies and processes.[90] The centre suggested that providing forms and guides in several community languages would help remove linguistic barriers.[91]

6.75 Consultation participants noted that information about translation and interpreting services was on the back page of the birth registration statement. Some suggested that it would be more accessible to people from CALD backgrounds if this information was on the front of the form.[92] Often a person from a CALD background will take a friend or relative to the justice service centre to help them.

6.76 Staff from two justice service centres noted that they often rely on informal networks (friends or relatives of the applicant) or use local agencies such as the Ethnic Council of Shepparton in Hume and the Sunraysia Mildura Ethnic Council in Mildura to assist.[93]

6.77 In one outer metropolitan justice service centre, staff noted they have limited scope to help people who present to the counter with language barriers, due to time limitations and resource constraints. Justice service centre staff use the TIS service when this occurs.[94]

6.78 Agencies who work with people from CALD backgrounds noted that people often prefer to seek assistance from family members or friends rather than call a telephone interpreting service.[95] Hospitals consulted confirmed this approach. The Royal Women’s Hospital and Dandenong Hospital informed the Commission that they rely on a core group of on-site interpreters to meet most of the demand. [96]

6.79 The Commission consulted with new parents from CALD backgrounds about language difficulties encountered. In consultation with a group of Vietnamese-speaking new parents, participants noted that poor English-language skills were the main barrier in registering the birth of their child. No parent consulted had used the interpreting services offered by the Registry, preferring to speak with someone they knew or other, unspecified, interpreting services.[97]

6.80 Consultation participants suggested a number of ways in which services for people from CALD backgrounds could be improved with regard to language difficulties, including:

• greater on-site assistance for people from CALD backgrounds completing registration documents[98]

• translation of forms, or explanatory notes, in languages other than English[99] (for example it was noted that Corrections Victoria offers information about services in other languages),[100] and

• amendment to the current birth registration statement to include instructions in other languages in text boxes beside the questions.[101]

Commission’s view

6.81 The Commission appreciates the resourcing considerations of producing publications, requiring frequent updates, in multiple languages. Therefore, it is the Commission’s view that the birth registration statement should remain a publication in English.

6.82 However, more information about the requirement to register a birth and how to do so could be made available in a variety of languages. This general information as well as answers to frequently asked questions could be made available on the Registry’s website.

6.83 The Registry could also offer links to a range of agencies that could provide the assistance required to members of the CALD community. For some communities, lack of literacy skills in their own language is also a barrier.

6.84 The Department of Education and Early Childhood Development website provides information about a variety of MCH resources for CALD communities. Resources available for download and links to source documents in community languages include ‘Safe sleeping’, ‘SunSmart information’, ‘Kindergarten information sheets’ and ‘ Healthy Eating and Play for Toddlers’.[102] The Victorian Electoral Commission also produces enrolment forms in a range of community languages.[103]

6.85 By way of further example, the Office of the Public Advocate (Victoria) website makes available online facts sheets in a number of community languages. The fact sheets outline law and policy concerning issues specific to the Office of the Public Advocate.[104]

Recommendation

20 The Registrar should consider:

• moving the information about the translation and interpreter service at the back of the birth registration statement to the front of the form, and

• making information about the requirement to register a birth and how to fill in the birth registration statement in a range of community languages available in brochures and on its website.

Awareness and understanding

6.86 Closely related to language and literacy issues were general barriers relating to awareness and understanding in CALD communities about the birth registration process.

6.87 In its submission, the VEOHRC suggested that people from CALD backgrounds may be less aware of the rights and benefits provided by registration and having a birth certificate than other members of the community.[105] The Commission also heard some cultures may not attach as much importance to documentation, and may be fearful of authority and bureaucratic systems.[106]

6.88 A number of innovative suggestions were proposed for developing better understanding in the CALD community, particularly among newly arrived migrants and refugees.

6.89 One group of consultation participants suggested that volunteers, based in community health centres, could help new parents to fill in forms. Participants referred to an existing program run by the Jesuit Social Services in Collingwood that helps those with limited English and literacy to fill in forms and engage in general English conversation.[107]

6.90 It was also suggested that, along with provision of information in community languages, the Registry could take a more proactive approach to engaging with new refugee groups, and CALD groups more generally.[108] For example, the Registry could provide more information about issues that may arise if the parent/s do not register their child.[109]

6.91 Understanding and awareness also affect decisions with regard to birth certificates. As discussed in Chapter 4, it was noted that some members of the CALD community prefer to purchase commemorative birth certificates, and were likely to do so without fully understanding that a commemorative certificate cannot be used for official purposes.[110]

Cultural awareness

6.92 Cultural practices of some CALD communities were also noted during consultation. One group identified naming conventions (such as the order of names on the certificate) or conflict over the child’s name as a potential barrier to birth registration.[111] The Commission notes that the birth registration statement states that ‘Parents from multicultural backgrounds can follow traditional rules when naming their child. However, the name provided on this form must be written in English.’[112]

6.93 Some specific cultural practices can also mean that there is a delay in registering the birth of a child, for example where there is a need to consult a religious adviser before a name is chosen,[113] as discussed in Chapter 3.

6.94 In consultation with one new parents group, the Commission was informed that in some cultures a confinement period is normal for new mothers after the birth of a child. When the parent/s also need help with completing the form, this may make it difficult to complete the registration within the 60-day time limit.[114]

6.95 It was suggested that employing a specific CALD contact at the Registry or providing more specific cultural training for Registry staff could help in dealing with more complicated cases.

Commission’s view

6.96 While the Commission acknowledges the concerns raised in consultations, it is the Commission’s view that the current requirement to register a birth within 60 days is appropriate.

6.97 The Commission agrees that cultural awareness training is an important component of service delivery when dealing with the community. The Commission is aware that the Department of Justice provides cultural competency training opportunities for its business units and staff[115] and that Registry staff have opportunities to undertake the training offered. In addition, an inclusive guide to employment of people from CALD backgrounds is available.[116]

6.98 The Commission makes no recommendation in relation to the provision of additional training for Registry staff or a specific CALD contact. This consultation feedback has been included to help the Registry plan for its provision of services to CALD communities.

Young parents and other vulnerable groups

6.99 The Commission consulted with a number of new parents groups as part of the review,[117] including with teenage parents.[118] The Commission heard that young parents are more likely than other parent groups to be from a low socio-economic background, to have a history of family disruption or time in care, and to be raising a child as a single parent.[119]

6.100 Young parents are more likely to encounter difficulties in registering the birth of their child due to a number of factors:

• lack of understanding of the importance of birth registration [120]

• not knowing who the father is, or difficulties in locating the father, in order to sign the birth registration statement [121]

• the often chaotic nature of their lives, with interaction with a number of agencies and support services, family disruption and/or drug and alcohol dependency [122]

• the fee for the birth certificate may be prohibitive [123]

• no credit card or cheque book to pay the fee.[124]

6.101 Several groups consulted[125] suggested that the most significant barriers faced by young parents in registering the birth of their child were:

• the lack of understanding of the importance of birth registration

• the requirement to provide the father’s details, and

• the requirement to obtain the father’s signature for part 4 of the birth registration statement.

6.102 It was suggested that more information, for example a pamphlet outlining the importance and process of birth registration, could be included in the Parent Pack provided at the hospital.[126] Access and awareness are discussed further in Chapter 7.

6.103 During consultation, participants raised concern about barriers faced by other vulnerable groups in registering a birth or obtaining a birth certificate. These groups include people with disabilities, people experiencing homelessness and other young adults.

6.104 For example in one consultation, participants noted that the complexity of the birth registration statement and birth certificate application form can create a barrier for people who are sight-impaired or have a cognitive impairment.[127] Further, VEOHRC recommended that ‘the Registrar should review the birth registration and certification process to ensure that the system is accessible to people with disabilities, including people with intellectual disability’.[128]

6.105 One consultation described the difficult situation faced by a client in registering the birth of her child. The client, who had an intellectual disability and low literacy skills, was advised to pursue a DNA parentage test to determine the father of the child. Neither possible father wished to acknowledge paternity. It was reported that the client struggled with the registration process and probably would not have pursued the registration without the assistance of the justice service centre officers and other support services.[129]

6.106 Mental health issues, such as postnatal depression, were also cited as a possible barrier to registration. One young mother informed the Commission that she had not registered her now two-year-old, as she had suffered from severe postnatal depression.[130]

6.107 Finally, VEOHRC identified homelessness as a potential barrier to birth registration and obtaining a birth certificate. VEOHRC noted that issues surrounding obtaining identity documents to support applications and the costs involved in making applications would likely be significant barriers to homeless people because of their situation.[131]

Commission’s view

6.108 The Commission recognises that young parents and other vulnerable groups such as people with disabilities, homeless people and young adults in general may encounter specific barriers to the registration of a birth or to obtaining a birth certificate.

6.109 A greater focus on awareness-raising among the community, and service delivery agencies and health professionals should help these groups.

6.110 The Registry’s commitment to reviewing the way in which it delivers services is also a positive step in making this vital service accessible to all members of the Victorian community, including the most vulnerable. Chapter 7 contains further discussion as to how birth registration and birth certificate issues could be better conveyed to the community, as well as to how the Registry might play a more proactive role in raising awareness and increasing access to services. As such, the Commission makes no specific

recommendation here.


  1. Births, Deaths and Marriages Registration Act 1996 (Vic) s 3.

  2. A child who is currently subject to a child protection order and is either in the custody or guardianship of the state.

  3. This was discussed in Chapter 1.

  4. Submissions 5 (The International Commission of Jurists—Victoria); 6 (Law Institute of Victoria); 7 (VEOHRC); 9 (Legal Aid NSW); 10 (Castan Centre for Human Rights Law—Monash University); 12 (Liberty Victoria). Consultations 2 (Boorai Group, Victorian Aboriginal Health Service); 6 (Ovens and King community health workers & co, Wangaratta); 12 (DEECD); 14 (Mildura Base Hospital); 15 (Mildura Justice Service Centre); 23 (MCH Team Meeting, Bairnsdale); 26 (Gippsland East Aboriginal Driver Education Program); 31 (The Royal Women’s Hospital); 32 (Mercy Hospital for Women); 33 (Link-Up Victoria).

  5. Submission 10 (Castan Centre for Human Rights Law—Monash University).

  6. Sixteen sessions were held across regional Victoria in towns including Mildura, Swan Hill, Shepparton, Sale, Bairnsdale, Heywood and Warrnambool. As a result of this outreach work the Registry received 300 applications for birth certificates, and 53 Indigenous births were registered: Department of Justice (Victoria), Annual Report 2008–09 (2009) 175.

  7. Department of Justice (Victoria), Annual Report 2010–11 (2011) 48.

  8. Ibid.

  9. Consultation 26 (Gippsland East Aboriginal Driver Education Program). This work was undertaken in 2009. According to consultation participants, there has been no further work focusing solely on the Gippsland region since the initial partnership with local organisations to encourage birth registrations and access to birth certificates for Indigenous people.

  10. Submission 10 (Castan Centre for Human Right Law—Monash University).

  11. Letter from Erin Keleher, Victorian Registrar of Births, Deaths and Marriages to the Hon P.D. Cummins, Chair, Victorian Law Reform Commission, 21 February 2013.

  12. Ibid.

  13. Submission 7 (VEOHRC).

  14. Submission 10 (Castan Centre for Human Rights Law—Monash University).

  15. Submissions 9 (Legal Aid NSW); 10 (Castan Centre for Human Rights Law—Monash University). See also Consultations 12 (DEECD); 14 (Mildura Base Hospital); 23 (MCH Team Meeting, Bairnsdale).

  16. Consultation 2 (Boorai Group, Victorian Aboriginal Health Service). See also Submissions 5 (The International Commission of Jurists—Victoria); 7 (VEOHRC); 10 (Castan Centre for Human Rights Law—Monash University).

  17. Consultation 32 (Mercy Hospital for Women).

  18. Submission 9 (Legal Aid NSW). See also Consultation 6 (Ovens and King health and community workers & co, Wangaratta).

  19. One participant noted that she had not attended postnatal services as in her experience as an Indigenous woman she was fearful of what they were: Consultation 6 (Ovens and King health and community workers & co, Wangaratta).

  20. Submissions 5 (The International Commission of Jurists—Victoria); 10 (Castan Centre for Human Rights Law—Monash University). Consultation 6 (Ovens and King health and community workers & co, Wangaratta).

  21. Submission 7 (VEOHRC) citing Castan Centre for Human Rights Law—Monash University, Report to the UN Committee on the Rights on the Child regarding Australia’s Compliance with Article 7 of the Convention on the Rights of the Child (2011) 2, 3, <http://www2.ohchr.org>.

  22. Victorian Aboriginal Legal Service Co-operative, Presentation by Frank Guivarra at Castan Centre for Human Rights Law—Monash University Symposium on Indigenous Birth Registration and Birth Certificates— Potential Legal Solutions (1 December 2009) 1,

    <http://www.law.monash.edu.au/castancentre>.

  23. Ibid.

  24. Human Rights and Equal Opportunity Commission, Bringing Them Home: Report of the National Inquiry into the Separation of Aboriginal and Torres Strait Islander Children from Their Families (1997) (‘Bringing Them Home’) contained 54 recommendations.

  25. Ibid 301––302 [recommendation 23].

  26. Consultation 33 (Link-Up Victoria).

  27. Consultation 33 (Link-Up Victoria). Bringing Them Home, above n 24, 304 [recommendation 25(-1—–2)].

  28. Consultation 33 (Link-Up Victoria).

  29. The Taskforce was established in 2001 as a major initiative of the Victorian Government’s response to the Bringing Them Home report which recommended each state and territory establish Records Taskforces to help members of the Stolen Generations in tracing their families: Public Record Office Victoria, Victorian Koori Records Taskforce (2013) <http://prov.vic.gov.au>.

  30. Victorian Koori Records Taskforce, Finding Your Story: A Resource Manual to the Records of the Stolen Generations in Victoria (2005). To help Stolen Generations members find information on the locations of their records. The Taskforce also published the Wilam naling…Knowing who you are…Improving Access to records of the Stolen Generations Report (2006).

  31. Victorian Koori Records Taskforce, Victorian Koori Records Taskforce: Final Report (2012).

  32. Ibid 6.

  33. Ibid 23.

  34. Ibid 7.

  35. Ibid 23.

  36. Bringing Them Home, above n 24, 301–4 [recommendations 23–25].

  37. NSW Registry of Births, Deaths and Marriages, Aboriginal and Torres Strait Islander <http://www.bdm.nsw.gov.au>.

  38. South Australia Link-Up, Links (2005) <http://www.salinkup.com.au>.

  39. South Australia Link-Up, SA Link-Up (2005) <http://www.salinkup.com.au>.

  40. Births, Deaths and Marriages Registration Act 1996 (Vic) s 49.

  41. Letter from Erin Keleher, above n 11.

  42. Meeting of Erin Keleher, Victorian Registrar Births, Deaths and Marriages and Andrew Jackomos, Director, Koori Justice Unit,

    Department of Justice with the Hon P.D Cummins, Chair, Victorian Law Reform Commission, 12 March 2013.

  43. Submission 7 (VEOHRC).

  44. Submission 12 (Liberty Victoria).

  45. Consultation 22 (MCH Team Meeting, Traralgon).

  46. Ibid.

  47. Consultation 30 (New Mothers Group, Connect Ed, Horsham College).

  48. Consultations 23 (MCH Team Meeting, Bairnsdale); 24 (Bairnsdale and Morwell Justice Service Centres).

  49. Consultation 25 (Young, Pregnant and Parenting Group, Lakes Entrance).

  50. Victorian Government, Balert Boorron: The Victorian Plan for Aboriginal Children and Young People (2010–2020) (2010) ii (‘Balert Boorron’).

  51. Victorian Government, Victorian Indigenous Affairs Framework (2006).

  52. Balert Boorron, above n 50, 18.

  53. Ibid.

  54. Victorian Aboriginal Legal Service Co-operative, above n 22, 5.

  55. Consultations 9 (MCH Team Meeting, Wangaratta); 13 (New Parents Group, Mildura South).

  56. Consultation 2 (Boorai Group, Victorian Aboriginal Health Service).

  57. Consultation 4 (Shepparton Justice Service Centre). Rumbalara Aboriginal Co-operative is a community centre in Shepparton providing services including health, family, housing, finance and administration, aged care and disability services and justice programs: Rumbalara Aboriginal Co-operative, Welcome to Rumbalara <http://www.rumbalara.org.au>.

  58. Consultation 15 (Mildura Justice Service Centre).

  59. Consultation 24 (Bairnsdale and Morwell Justice Service Centre).

  60. Consultation 15 (Mildura Justice Service Centre).

  61. Submission 6 (Law Institute of Victoria).

  62. Consultation 14 (Mildura Base Hospital).

  63. NSW Registry of Births, Deaths and Marriages, Aboriginal & Torres Strait Islander <http://www.bdm.nsw.gov.au>.

  64. Enactus University of New England, Minimbah Banking Change Project <http://blog.une.edu.au>.

  65. Ibid.

  66. Representatives from the University of New England and Community Mutual Group, ‘Minimbah BDM Sampler’ (3 May 2012) <http://vimeo.com/41475275>; Submission 9 (Legal Aid NSW). The second drive extended to 3 primary schools in the area and ran from 6–8 November 2012.

  67. Submission 9 (Legal Aid NSW).

  68. The delegation is also supported by Armidale businesses and community groups and Monash University: The Armidale Express, ‘Armidale delegation launches birth certificate campaign’ The Armidale Express (Armidale, New South Wales), 12 February 2013.

  69. Ibid. Tony Windsor MP, ‘Armidale delegation launches national campaign for free birth certificates’ (Media Release, 12 February 2013); The Northern Daily Leader, ‘Armidale delegation wants free birth certificates for every child’ The Northern Daily Leader, (Tamworth, New South Wales), 12 February 2013.

  70. Attorney-General and Minister for Emergency Management, The Hon Mark Dreyfus QC MP, Media conference – Darwin (4 April 2013) <http://www.attorneygeneral.gov.au>.

  71. Ibid.

  72. This figure does not include the 5.2% of Victorians who did not state their country of birth: Australian Bureau of Statistics, 2011 Census Quick Stats (30 October 2012) <http://www.censusdata.abs.gov.au>. See also Victorian Multicultural Commission, 2011 Census: A Snapshot of our Diversity (7 January 2013) <http://www.multicultural.vic.gov.au>.

  73. This figure does not include the 5.6% of Australians who did not state their country of birth: Australian Bureau of Statistics, 2011 Census Quick Stats (30 October 2012) <http://www.censusdata.abs.gov.au>. See also Victorian Multicultural Commission, 2011 Census: A Snapshot of our Diversity (7 January 2013) <http://www.multicultural.vic.gov.au>.

  74. Victorian Multicultural Commission, 2011 Census: A Snapshot of our Diversity (7 January 2013) <http://www.multicultural.vic.gov.au>.

  75. Birth, Deaths and Marriages Registration Regulations 2008 (Vic) reg 7(m).

  76. The Department of Justice (Victoria), Cultural Diversity Plan 2012–2016 (2013) recognises that stronger responses are required to key issues, including the need for better data collection processes to improve service delivery for individuals and groups in CALD communities (‘Cultural Diversity Plan’).

  77. The Royal Women’s Hospital, Submission to the Inquiry into Multiculturalism in Australia, Parliament of Australia, Joint Standing Committee on Migration, Submission 89, 1.

  78. Ibid 2.

  79. The TIS is provided by the Department of Immigration and Citizenship (Commonwealth) and used by all state and territory registries. The TIS provides a service for people who do not speak English and for English-speakers who need to communicate with them: Department of Immigration and Citizenship (Commonwealth), About TIS National <http://www.immi.gov.au>.

  80. Victorian Registry of Births, Deaths and Marriages, Birth Registration Statement (November 2012).

  81. Victorian Registry of Births, Deaths and Marriages, Application for a Victorian Birth Certificate (November 2012).

  82. Justice service centres are managed by the same unit that is responsible for the justice bus service. The Department of Justice (DoJ) has a Language Services Policy and a minimum standard for the provision of language services which requires that DoJ clients be given access to professional interpreting and translating services when they have to make significant decisions about their lives; or when they need essential information to inform decision making: Department of Justice (Victoria), Language Services Policy and Guidelines for working with Interpreters and Translators (2006) 6. The Cultural Diversity Plan 2012–2016 (CDP) has been developed to ensure individuals and communities from CALD backgrounds can access mainstream justice services. The CDP applies to all DoJ business units and regions, and important goals include access to justice information, goods, services, programs and facilities with the intention to deliver a justice system that is accessible to CALD communities. The CDP encourages DoJ business units to ensure people receive the information they need in the way they like to receive it. The CDP further states that DoJ respects diversity and will continue to provide CALD communities with information on how to participate in justice services and how to exercise their rights and responsibilities as residents of Victoria: Department of Justice (Victoria), Cultural Diversity Plan, above n 76, 11, 13.

  83. Department of Justice (Victoria), Living in Victoria: A Guide to the Law for Newly Arrived Communities (2013) 18.

  84. Department of Human Services (Victoria), Enhanced Maternal and Child Health Services Guidelines 2003–2004 (2003). As of 27 August 2007 this document is managed by DEECD.

  85. Consultation 10 (MCH Team Meeting, Flemington).

  86. Department of Human Services (Victoria), First Time Parent Group Resource and Facilitation Guide for Maternal and Child Health Nurses (2001). As of 27 August 2007 this document is managed by DEECD. Birth registration and birth certificates are absent from suggested support resources in this manual. A variety of other Maternal and Child Health resources for parents from CALD backgrounds are available in a number of community languages on the DEECD website: Department of Education and Early Childhood Development (Victoria), Additional Resources (13 February 2013) <http://www.education.vic.gov.au>.

  87. Submissions 4 (North Melbourne Legal Service); 7 (VEOHRC). Consultations 1 (Spectrum Migrant Resource Centre); 4 (Shepparton Justice Service Centre); 14 (Mildura Base Hospital); 19 (Vietnamese New Parents Group, Springvale); 20 (Dandenong Hospital); 21 (MCH Team Meeting, Warragul); 27 (Dandenong Justice Service Centre); 32 (Mercy Hospital for Women).

  88. Submission 4 (North Melbourne Legal Service); 7 (VEOHRC). Consultations 1 (Spectrum Migrant Resource Centre); 4 (Shepparton Justice Service Centre); 19 (Vietnamese New Parents Group, Springvale); 20 (Dandenong Hospital); 21 (MCH Team Meeting, Warragul); 37 (Dandenong Justice Service Centre).

  89. Submission 5 (North Melbourne Legal Service). Consultations 11 (Sue Smythe, Robinvale Resource Centre); 4 (Shepparton Justice Service Centre); 14 (Mildura Base Hospital); 15 (Mildura Base Hospital); 20 (Dandenong Hospital).

  90. Consultation 1 (Spectrum Migrant Resource Centre).

  91. Ibid.

  92. Consultations 10 (MCH Team Meeting, Flemington); 27 (Dandenong Justice Service Centre).

  93. Consultations 4 (Shepparton Justice Service Centre); 15 (Mildura Justice Service Centre).

  94. Consultation 27 (Dandenong Justice Service Centre).

  95. Consultations 1 (Spectrum Migrant Resource Centre); 19 (Vietnamese New Parents Group, Springvale).

  96. Consultations 20 (Dandenong Hospital); 31 (The Royal Women’s Hospital).

  97. Consultation 19 (Vietnamese New Parents Group, Springvale).

  98. Consultation 27 (Dandenong Justice Service Centre).

  99. Consultations 1 (Spectrum Migrant Resource Centre); 19 (Vietnamese New Parents Group, Springvale).

  100. Consultation 27 (Dandenong Justice Service Centre). For example, Corrections Victoria, operator of Community Corrections Services, produces a resource for prisoners exiting prison which is translated into Vietnamese: VACRO (Victorian Association for the Care and Resettlement of Offenders) and Department of Justice (Corrections Victoria), Getting Started: A Guide to Getting Out—Vietnamese (2011).

  101. Consultation 27 (Dandenong Justice Service Centre).

  102. Department of Education and Early Childhood Development (Victoria), CALD Resources (4 April 2013) <http://www.education.vic.gov.au>.

  103. Victorian Electoral Commission, Aids and Assistance for Voters <https://www.vec.vic.gov.au>.

  104. See, for eg, Office of the Public Advocate (Victoria), Vietnamese (20 Dec 2010) <http://www.publicadvocate.vic.gov.au>. Key fact sheets are available in Arabic, Chinese, Croatian, Greek, Italian, Polish, Russian, Serbian, Spanish, Turkish, Vietnamese and Macedonian.

  105. Submission 7 (VEOHRC).

  106. Consultation 20 (Dandenong Hospital).

  107. Consultation 10 (MCH Team Meeting, Flemington).

  108. Consultations 20 (Dandenong Hospital); 31 (The Royal Women’s Hospital).

  109. Consultation 20 (Dandenong Hospital).

  110. Consultations 1 (Spectrum Migrant Resource Centre); 10 (MCH Team Meeting, Flemington); 19 (Vietnamese New Parents Group, Springvale).

  111. Consultation 1 (Spectrum Migrant Resource Centre).

  112. See ‘Naming your child’ Appendix C.

  113. Consultations 6 (Ovens and King health and community workers & co, Wangaratta); 10 (MCH Team Meeting, Flemington); 17 (Immunisation session, Flemington); 19 (Vietnamese New Parents Group, Springvale).

  114. Consultations 10 (MCH Team Meeting, Flemington); 19 (Vietnamese New Parents Group, Springvale).

  115. Department of Justice (Victoria), Cultural Competency Training @ DoJ Information Sheet (2010).

  116. Department of Justice (Victoria), Inclusive employment @ DoJ (January 2011).

  117. Consultations 3 (New Parents Group, Mooroopna); 8 (New Parents Group, Wangaratta); 13 (New Parents Group, Mildura South); 17 (Immunisation session, Flemington); 18 (New Parents Group, Dandenong North; 19 (Vietnamese New Parents Group, Springvale).

  118. Consultations 25 (Young, Pregnant and Parenting Group, Lakes Entrance); 30 (New Mothers Group, Connect Ed, Horsham College).

  119. Consultations 5 (MCH Team Meeting, Shepparton); 30 (New Mothers Group, Connect Ed, Horsham College).

  120. Consultations 9 (MCH Team Meeting, Wangaratta); 24 (Bairnsdale and Morwell Justice Service Centres); 25 (Young, Pregnant and Parenting Group, Lakes Entrance).

  121. Consultations 5 (MCH Team Meeting, Shepparton); 25 (Young, Pregnant and Parenting Group, Lakes Entrance); 30 (New Mother Group, Connect Ed, Horsham College).

  122. Consultation 5 (MCH Team Meeting, Shepparton).

  123. Consultation 9 (MCH Team Meeting, Wangaratta).

  124. Consultation 10 (MCH Team Meeting, Flemington).

  125. Consultations 9 (MCH Team Meeting, Wangaratta); 24 (Bairnsdale and Morwell Justice Service Centres); 25 (Young, Pregnant and Parenting Group, Lakes Entrance).

  126. Consultations 12 (DEECD); 20 (Dandenong Hospital).

  127. Consultation 4 (Shepparton Justice Service Centre).

  128. Submission 7 (VEOHRC).

  129. Consultation 29 (Horsham Justice Service Centre).

  130. Consultation 30 (New Mothers Group, Connect Ed, Horsham College).

  131. Submission 7 (VEOHRC). VANISH also provided an example of a homeless client who encountered the issue of having to produce documentation to the Registry to establish his current address: Submission 11 (VANISH).