ECPAT NZ welcomes the opportunity to provide feedback on the Draft RSE Framework for consultation. As an organisation dedicated to preventing the sexual exploitation of children, we have reviewed the draft framework with a particular focus on aspects related to safeguarding tamariki and rangatahi. We offer the following points for consideration by the Ministry of Education:
- Emphasis on Online Safety and Child Sexual Exploitation: While online safety is mentioned, the draft framework could more explicitly and comprehensively address the risks of online child sexual exploitation and abuse. International research, time and time again, highlights that a substantial number of children and caregivers lack awareness and understanding of this issue. We recommend that the framework explicitly integrates learning objectives related to recognising, responding to, and seeking help for online sexual exploitation across different year levels, building on the foundational safety concepts introduced in Year 0-1.
- Progression of Consent Concepts: The draft framework introduces consent at Year 0-1 in the context of hearing others’ ideas. While this is a starting point, the progression of consent through the year levels needs to be more clearly articulated and built upon with increasing complexity. There should be a clear and robust progression of learning about consent in various contexts, including online interactions and intimate relationships, in line with international best practices advocated by UNESCO.
- Integration of Diverse Identities: A major area of concern is that the draft framework has entirely erased all mention of gender diversity. The draft reduces gender to two sexes – male and female – without any reference to trans people and only one acknowledgment of intersex experiences. Education about the diverse realities of sex, gender and sexuality encourage acceptance, and understanding from all young people and provides those that are vulnerable to exploitation with the tools needed to protect themselves.
- Inclusion of Diverse Family Structures: The draft framework for Year 0-1 acknowledges that there are many types of family structures. This is not mentioned again at all in the draft, and while there is a cursory nod towards diverse sexualities at year 8, there is no further acknowledgement of diverse family structures at any stage. This recognition should be consistently reinforced across all year levels, reflecting the diverse realities of tamariki and rangatahi in Aotearoa.
- Addressing Inconsistencies in RSE Delivery: This current draft was developed in response to an Education Review Office (ERO) report that found inconsistencies in what and when RSE is being taught. To do this, the new framework needs to clearly articulate how it will ensure consistent and comprehensive RSE education across all schools. This draft currently sits within the health and physical education learning area, whereas a whole-school approach would have gone some way towards this goal.
- Teacher Preparedness and Support: The draft framework should acknowledge and outline how the Ministry will support teachers in delivering the proposed content effectively and confidently, particularly in addressing sensitive topics like sexual exploitation and abuse.
- Positive Aspects of Relationships and Sexuality: There is a distinct lack of positive aspects of sex and intimacy. We believe it is important for the framework to move beyond a purely risk-based approach and include positive messaging about healthy relationships, respect, and wellbeing. The overall aim of RSE should be to equip young people with the knowledge to feel positive about themselves, and the curriculum should consider the social and emotional well-being of young people as well.
- Linkages to Mental Health and Wellbeing: There is a lack of clear links to mental health. A comprehensive RSE framework should explicitly connect relationships, sexuality, and online safety with mental health and overall wellbeing. UNESCO’s international research further emphasises the interconnectedness of education, health, and wellbeing.
- Specific Mention of Harmful Content: While online safety is mentioned in passing, the draft framework needs to be more explicit about harmful online content, including pornography and content that normalizes or promotes child sexual abuse and exploitation. Learning about identifying and avoiding such content is crucial for child protection and should be integrated appropriately across different age levels. Furthermore, ECPAT NZ have found in multiple research studies that online exploitation is an increasingly utilised method of targeting and grooming vulnerable young people. There is no mention of new technologies or methodologies in the draft curriculum at all.
- Community Consultation: The draft framework does not explicitly call for consultation with diverse community groups, including parents, whānau, iwi, and relevant organisations to ensure the curriculum is culturally responsive and meets the needs of all ākonga. Furthermore, it does not read as if it includes the youth voice or seem representative of young people in a meaningful way.
ECPAT NZ remains committed to working collaboratively with the Ministry of Education and other stakeholders to ensure that tamariki and rangatahi in Aotearoa are safe from sexual exploitation. We believe that a robust and comprehensive RSE framework, incorporating the points raised above and drawing on the previous Ministry of Education guidance, UNESCO resources, and the experiences of diverse communities, is essential to achieving this goal.
Nāku iti nei, nā
ECPAT Child Alert Trust