Long-term guardianship to a suitable person

A child subject to a long-term guardianship order to a suitable person is in the care of their guardian under the authority of the child protection order made by the Childrens Court. It is not a care arrangement made by Child Safety using the authority of the Child Protection Act 1999, section 82(1). 

Child Safety’s case management responsibility is limited to: 

• recording a case plan―long-term guardian/permanent guardian in Unify 
• having 12 monthly contact with the child (Child Protection Act 1999, section 51VA) and long-term guardian and deciding if a case plan review will occur
• completing a case plan review, if appropriate
• regularly providing the child with information about the charter of rights and other information line with the Child Protection Act 1999, section 74A
• providing necessary and requested support to the child or long-term guardian
• providing agreed financial supports to a guardian who was previously the child’s carer. (Refer to High support needs allowance and complex support needs allowance.) 

Create the case plan―long-term guardian/permanent guardian

When a referral is made to the DCPL to apply for a child protection order granting long-term guardianship of a child to a suitable person, prepare a case plan―long-term guardian/permanent guardian for the Childrens Court. To do this, complete the following in the child’s new ongoing intervention cycle in Unify:

• add the approved foster or kinship carer to the case (if this has not already occurred) and edit their role to long-term guardian
• record an other case note, explaining the role of approved foster or kinship carer has been edited to long-term guardian to enable the case plan―long-term guardian/permanent guardian to be created
• create and complete the case plan based on information from the child’s current case plan. Note the case plan will only address the child’s needs and not any previously identified needs for the parents
• submit the case plan to the senior team leader for approval.

Record the case plan―long-term guardian/permanent guardian

Complete all sections of the case plan―long-term guardian/permanent guardian in Unify using the instructional text in the document for guidance. (Refer to Unify case planning changes.)
Ensure the following requirements are reflected in the case plan―long-term guardian/permanent guardian:

• Child Safety will have contact with the child every 12 months (Child Protection Act 1999, section 51VA(2)).
• The proposed long-term guardian will allow Child Safety to have contact with the child (Child Protection Act 1999, section 51VA(3)).
• The proposed long-term guardian will (unless an exception has been made by the Childrens Court):
  • keep the child’s parents informed about where the child is living  
  • give the child’s parents information about the child’s care (Child Protection Act 1999, section 80(1)(a) and (b))
  • provide opportunity for contact between the child and the child’s parents and appropriate members of the child’s family as often as is appropriate in the circumstances.
• The proposed long-term guardian must, as far as practicable, ensure the care provided to the child complies with the charter of rights (Child Protection Act 1999, section 79A), including the obligation to inform the child of their right to make a complaint to Child Safety if the child considers the charter of rights is not being complied with.
• The proposed long-term guardian must notify Child Safety in writing if the child leaves their direct care at any time in the future and provide details of the child’s whereabouts, if known (Child Protection Act 1999, section 80A(2)).

The long-term guardian assumes full responsibility for meeting a child’s educational, medical or therapeutical needs unless there are specific needs and actions included in the case plan.  

The completed case plan―long-term guardian/permanent guardian is submitted to the Childrens Court. 

Give information to the child, parent and long-term guardian when the order is made

When a child protection order is made granting long-term guardianship of the child to the suitable person, give the following information to the child, their parents and the long-term guardian.

Give the child (in a developmentally appropriate way):

• written notice that the order was made, including details outlined in the Child Protection Act 1999, section 63(b). Draft a letter specifically for the individual child, depending on their age and ability to understand
• a certified copy of the order. Keep the original order on the child’s file
• verbal and written information about the charter of rights for a child in care and its effect (Child Protection Act 1999,  schedule 1)
• information in line with the Child Protection Act 1999, section 74A , about:
  • a long-term guardian’s obligations under section 79A
  • the OPG and other entities who can help the child if the child considers that the child’s long-term guardian is not complying with guardian’s obligations 
  • the child’s right to contact Child Safety if they have questions or concerns about their protection and care needs.
• the name and contact details of the CSO and CSSC with case responsibility.

Give the parents:

• verbal information about the terms and effect of the order, including how to lodge an appeal
• a completed Letter advising parents of a long-term guardianship order
• a certified copy of the order. Keep the original order on the child’s file
• the name and contact details of the CSO and CSSC with case responsibility for the child.

Give the long-term guardian:

• a completed Letter advising suitable persons of long-term guardianship order
• a certified or original copy of the order. Keep the original order on the child’s file

• information about their obligations in line with the Child Protection Act  1999, section 79A to (unless at the time the order was made the Childrens Court ordered that an obligation did not apply or applied to a limited extent):

  • as far as reasonably practicable, ensure the care they provide to the child complies with the charter of rights for a child in care 

  • ensure the child is provided with appropriate help in the transition from being a child in care to independence 

  • to the extent it is in the best interests of the child, preserve the child’s identity and connection to the child’s culture of origin

  • to the extent it is in the best interests of the child, help maintain the child’s relationships with the child’s parents, family members and other persons of significance to the child

• the name and contact details of the CSO with case responsibility for the child
• information and contact details for the Foster and Kinship Carer Support line. 

Give either the child or long-term guardian:

• the child’s child health passport
• the child’s Medicare card. (Give the card to the child if they are 15 years or over and listed as the cardholder.)
• an original or certified copy of the child’s birth certificate. Keep one original birth certificate on the child’s file. (Refer to Obtain a birth certificate for a child.)
• information about how to access the child’s My Health Record (Refer to Link to a child’s My Health Record.)
• the child’s tax file number, if applicable
• a certified copy of the child’s proof or confirmation of Aboriginal and/or Torres Strait Islander heritage, if applicable. Keep the original on the child’s file
• the child’s NDIS documentation, if relevant, including a copy of the current plan
• information about the Australian Government’s Transition to Independent Living Allowance (TILA) funding, if the child is 15 years or older. (Refer to Assist the young person to access Transition to Independent Living Allowance.)

Amend the carer’s details in Unify

When a carer is granted long-term guardianship of a child, update the following details in the care arrangement case in Unify:

• record the start date as the day the order was granted 
• record the scheduled expiry date as the order expiry date.

Have contact with the child and long-term guardian

Child Safety must have contact with the child at least every 12 months and the long-term guardian must allow this to occur (Child Protection Act 1999, section 51VA). Contact with the long-term guardian will also occur every 12 months.

Contact with the child and long-term guardian may occur more regularly if this is requested by the child or long-term guardian or it is considered necessary by Child Safety. 

Check the details of the specific order made by the Childrens Court for any modifications made to the obligations listed in the Child Protection Act 1999 , section 79A. 

Make a suitable time at an appropriate location to visit the child and long-term guardian.

Record the contact made using the Contact report - long-term guardian in the ongoing intervention cycle in Unify.

Contact with the child

At the visit talk to the child about their belonging, safety and wellbeing. Invite conversation on any matters they wish to discuss. Ensure Child Safety meets the obligations to regularly provide the information about the child’s rights, guardian’s obligations, Child Safety support options and how they can ask questions or raise concerns about their protection and care needs in line with the Child Protection Act 1999, section 74A. This includes: 

• the charter of rights 
• case plan reviews
• referrals to community support services
• changes in their circumstances
• cultural and identity needs
• family contact arrangements. 

Record the contact in the Contact report - long-term guardian in the ongoing intervention cycle in Unify. If the decision is made to review the case plan as part of the contact, refer to Review a case plan—long-term guardianship to suitable person.

Contact with the long-term guardian

During the 12 monthly contact with the long-term guardian:

• Confirm the child is still residing in their direct care.
• Ask if they would like to have the child’s case plan reviewed (Child Protection Act 1999, section 51VA). 
• Provide them with a written copy of the Charter of Rights for a child in care .
• Inform them that support can be provided without the need to review the child’s case plan.
• Discuss any changing needs or circumstances that may require additional support to the child or long-term guardian.
• Ensure the long-term guardian is continuing to meet their obligations (as listed in the Child Protection Act 1999, section 79A or as modified in the specific child’s order:
  • ensure the care they provide to the child complies with the charter of rights for a child in care (as far as reasonably practicable)
  • ensure the child is provided with appropriate help in the transition from being a child in care to independence 
  • tell the child’s parents where the child is living and provide them with information about the child’s care facilitate contact between the child, parents, family members and other significant people (Child Protection Act 1999, section 80). 
    as far  as reasonably practicable, ensure the care they provide to the child complies with the charter of rights for a child in care
  • ensure the child is provided with appropriate help in the transition from being a child in care to independence 
  • tell the child’s parents where the child is living
  • give the parents information about the child’s care
  • facilitate contact between the child, parents, family members and other significant people (Child Protection Act 1999, section 80).
• Facilitate referrals to services in the community, if requested.
• Discuss how the long-term guardian is meeting the child’s cultural connection needs.
• Discuss the ongoing provision of financial assistance and record any approval by the financial delegate in the case plan.
• Remind the long-term guardian of their legal responsibility to notify the chief executive in writing if the child leaves their direct care and to provide information about where the child is living (if known) (Child Protection Act 1999, section 80A).

Decide whether to review a case plan―long-term guardian/permanent guardian

A review of the case plan is required, in line with the Child Protection Act 1999, section 51VA:

• if requested by the child or long-term guardian at the 12-monthly contact and if Child Safety agrees to the review
• at any point in time if requested by the child or long-term guardian and Child Safety agrees to the review
• if Child Safety considers it necessary.

In addition, Child Safety will review the case plan in any of the following circumstances:

• The long-term guardian is not fulfilling their legal obligations.
• A review is needed to assess the current care arrangement and appropriateness of the order.
• A priority response on the long-term guardian has been finalised, and it is assessed the child has experienced harm and is at unacceptable risk of harm.
• The child is no longer residing in the direct care of the long-term guardian.
• The child or the long-term guardian needs time-limited intensive case work:
  • the long-term guardian makes a request for high support needs allowance or
  • the high support needs allowance has continued for more than 12 months and this request cannot be approved through casework.
• The long-term guardian or the child is receiving child related cost payments that have continued for more than 12 months.

Child Safety may decide to review the case plan if an assessment on the long-term guardian has been finalised with the outcome Substantiated—ongoing intervention continues and the child is not at unacceptable risk of harm.

Decide not to review a case plan 

If the child or long-term guardian requests a case plan review, there may be exceptional circumstances where Child Safety can determine this review is unnecessary and decide not to review the case plan. This is a reviewable decision, in accordance with the Child Protection Act 1999, schedule 2.

When a child’s case plan is not being reviewed:

• explain the decision to the child and long-term guardian of the reason for the decision and how to have the decision reviewed
• complete a Letter re: Decision not to review the case plan for the long-term guardian and provide it to them
• write an age and developmentally appropriate letter to the child explaining the decision and how they may request the decision reviewed
• attach a copy of each letter to the ongoing intervention cycle in Unify.

If this decision was made in the course of making contact with the child and long-term guardian, record this contact in a contact report - long-term guardian in the ongoing intervention cycle in Unify.

The senior team leader or CSSC manager is responsible for ensuring compliance with the legislative requirement to provide written notice of the decision to not review the child’s case plan. 

Review a case plan—long-term guardian/permanent guardian

Provide opportunity for the child and the long-term guardian to participate in the case plan review (note—their participation is not a requirement). Decide how the review process will occur considering the specific circumstances and the child’s best interest. (Refer to Decide the process for a case plan review.)

Complete the review report—long-term guardian

Record a case plan review using the Review report―long-term guardian in the ongoing intervention cycle in Unify. 

Submit the report to the senior team leader for approval. 

Develop a revised case plan

In the revised case plan―long-term guardian/permanent guardian form, record the support needs and actions required to ensure the child’s protection and care needs, including: 

• new or existing support needs and actions yet to be achieved 
• ongoing supports to be provided to the child and their long-term guardian 
• family contact arrangements (refer to Family contact) 
• arrangements for maintaining and supporting the child’s cultural identity. 

Family contact

The long-term guardian is responsible for providing the opportunity for ongoing contact between the child and the child’s parents and appropriate members of the child’s family, as often as is appropriate in the circumstances, unless otherwise ordered by the Childrens Court.

If issues or circumstances arise that prevent or impact on a child’s ongoing contact with their parents and appropriate members of their family offer assistance by:  

• discussing options for resolving the issues and encourage the long-term guardian and family members to attempt to address the issues independently
• negotiating with the long-term guardian for a Child Safety practitioner to contact the family members directly to help resolve the matter (if the long-term guardian and family members are not able to resolve the matter independently).

Review the case plan if it is identified that family contact needs to be supervised or restricted.

Respond to a request for support

A child or long-term guardian may contact Child Safety to request practical or financial support. The CSO with case responsibility will respond to such requests by:

• discussing the request with the senior team leader
• facilitating the provision of appropriate support
• seeking approval for any financial support from the delegated officer.

Refer to the policy Support for children in the care of long-term and permanent guardians.

Child related costs

Requests by a long-term guardian for reimbursement of child related costs (that are not approved within the child’s case plan) may be approved if the costs are considered significant or ongoing.

In addition, a long-term guardian will have access to financial support from Child Safety for services to meet the child’s health, education, therapeutic, cultural and transition to adulthood needs, if the supports are not available in the community. (Refer to the policy Child related costs.)

High support needs allowance and complex support needs allowance

The high support needs allowance and complex support needs allowance may be paid to a long-term guardian, if:

• the child was assessed and approved for the high or complex support needs allowance before the order was made
  or
• the child has developed or presents with previously unforeseen special needs (short-term or ongoing in nature) that were unknown or not present at the time the order was made.  

Refer to the policy High support needs allowance, the procedure High support needs allowance, the policy Complex support needs allowance and the procedure Complex support needs allowance. 

Special payments (including ex-gratia payments)

A long-term guardian is able to claim for a special payment, for example, if they have suffered a loss or property damage caused by a Child Safety client. This is subject to the policy Special Payments (including Ex-gratia), in the Financial management practice manual. 

Short breaks

A long-term guardian of a child:

• can access ‘emergent’ short breaks for the child, in line with the policy Dual payment of carer allowances, only if an emergency arises (or a situation arises that temporarily impacts the long term guardian’s ability to provide direct care) and there is no alternative option available within their existing safety and support network. In this circumstance, the child may be placed with an approved foster carer if the long-term guardian provides written consent using the Short break agreement

• is not eligible for ‘planned’ short breaks for the child. If the child has a disability, they may be able to access respite support through the National Disability Insurance Scheme. (Refer to Respond to a child's disability needs.)

Evolve

As the long-term guardian is responsible for meeting the child’s emotional and behavioural needs, the child is not eligible for Evolve therapeutic services (Evolve). If the child needs a mental health or counselling service, provide the long-term guardian with information about appropriate services.

Transition from care into adulthood

A young person subject to a long-term guardianship order to a suitable person:

• can apply for the Australian Government’s Transition to Independent Living (TILA) allowance
• may be eligible for child related costs. (Refer to Child related costs.)
• can receive case work support to help them make the transition to adulthood if they are no longer living with the long-term guardian. (Refer to Respond when the child is no longer in the long-term guardian's direct care.) 

Provide case work for emergent issues

If circumstances arise that are likely to impact on the stability of the care arrangement, Child Safety may provide 3 months of intensive case work. For example, if:

• the long-term guardian is unwilling or unable to meet their guardianship responsibilities such as caring for the child
• the long-term guardian is diagnosed with a terminal illness.

To facilitate case work, review and develop a case plan for the child. (Refer to Review a case plan—long-term guardianship to suitable person.)  

The CSSC manager may extend the period of case work if progress has been made and a further period of case work is likely to resolve the identified issues. It would not be appropriate for case work to extend past 6 months, unless there were exceptional circumstances.

If, after case work has been provided, the circumstances remain unchanged, the CSSC manager will consult with the OCFOS lawyer and decide whether to make a referral to DCPL to apply to vary the child protection order and seek long-term guardianship to the chief executive. In making this decision, the CSSC manager will:

• consider the views of the child, the long-term guardian and the child’s family
• with the consent of the child and family, arrange for an independent person to assist an Aboriginal or Torres Strait Islander child and their family to participate in the decision-making process.

Refer to a family support service

If a long-term guardian seeks support and it is assessed that the required support is able to be provided by an intensive family support service or Aboriginal and Torres Strait Islander family wellbeing service, and case work support is not currently being provided for emergent issues:

• Discuss the referral with the senior team leader.
• Discuss the referral with the child and long-term guardian and obtain their consent to refer.
• Complete the referral to:
  • an Intensive Family Support Service. (Refer to Procedure 1 Referral to family support.)
    or
  • an Aboriginal and Torres Strait Islander Family Wellbeing Service. (Refer to Procedure 4 Refer a family to an Aboriginal and Torres Strait Islander Family Wellbeing Service.)
• Attach the completed referral to the ongoing intervention cycle in Unify.
• Contact the service to discuss the referral.

Offer a support service

A support service may be opened for a young person who has turned 18 and who was previously subject to a long-term guardianship order to a suitable person. (Refer to Procedure 4 Support service case with a young person.)

Provide information about the Foster and Kinship Carer Support line

Make sure the long-term guardian is aware that they may access the Foster and Kinship Carer Support line on 1300 729 309. The support line operates Monday to Friday 5pm to 11.30pm and weekends 7am to 11.30pm. (Refer to Procedure 6 Provide support to the carer.)

Access to counselling services for a long-term guardian

If a long-term guardian requires support due to a traumatic event relating to the child in their guardianship, and they are an approved foster or kinship carer for another child, in the first instance, they should receive support from their foster and kinship care service.

If they require intensive support that can only be provided by a professional counsellor or psychologist (such as counselling or therapy) and they were an approved foster or kinship carer before being granted long-term guardianship of the child, then the CSSC manager may approve child related costs on a case-by-case basis. (Refer to the policy Child related costs.)

In deciding whether to approve financial expenditure for counselling, the CSSC manager will consider:

• contextual information about the need for the service, including whether it specifically relates to trauma experienced in relation to the child subject to the guardianship order
• whether the long-term guardian has accessed support from their foster and kinship care service, if applicable
• the length of time counselling may be required
• whether the long-term guardian is able to access a Medicare rebate for the services of a psychologist or other allied mental health professional.

Training

Tell the long-term guardian they are eligible to participate in carer training if wish to do so to support the care arrangement. (Refer to Foster carer training.)

Child support

If the long-term guardian is a relative of the child in their guardianship, advise them that they may be eligible for child support. Refer to the Child Support website or call the Child Support Agency on 131 272.

Regulation of care requirements

Unless a long-term guardian plans to provide care to a child in the custody or guardianship of the chief executive, they are not:

• required to hold a current blue card or a certificate of approval as a foster or kinship carer
• subject to the policy Responding to concerns about the standards of care. Respond to concerns regarding their care of the child in line with usual intake processes. (Refer to Procedure 1 Receive and respond at intake.)

Other issues that may arise for a long-term guardian

Separation or divorce of long-term guardians

If long-term guardians separate or divorce, both continue to hold guardianship responsibility for the child subject to the order. They will need to negotiate plans for the child’s daily care, taking into consideration:

• the child’s views
• the circumstances of the separation or divorce.

If the long-term guardians have been receiving the fortnightly caring allowance, only one of them can continue to receive the allowance after the separation or divorce. If the child’s daily care is to be shared, the long-term guardians will need to decide who will receive the allowance. The long-term guardian who receives the allowance may (but is not obligated to) pay part of the allowance to the other long-term guardian.

If a long-term guardian subsequently re-partners or remarries, there is no legal requirement for the new partner to be assessed or approved to provide care for the child subject to the long-term guardianship order. If concerns arise about the new partner, decide whether:

• to request a meeting with the long-term guardian to discuss relevant issues
  or
• the concerns meet the threshold for recording a notification. (Refer to Procedure 1 Receive and respond at intake.)

Succession planning for the child

A sole long-term guardian or long-term guardian couple may document details of a nominated person or of people they wish to be considered as the child’s guardian in the event of their death. While their wishes are not legally binding, by informing Child Safety or recording their wishes in a will, they enable Child Safety (should it be required) to consider inviting a nominated person to apply to become an approved carer for the child.

If a long-term guardian (either a sole guardian or part of a long-term guardian couple) is diagnosed with a terminal illness, and they wish to secure the child’s legal status before their death, consult OCFOS about making a referral to the DCPL for an application to the Childrens Court to:

• vary the order granting long-term guardianship to a suitable person
  and
• seek an order granting long-term guardianship to the chief executive.

This may occur if:

• the terminally ill long-term guardian (or both long-term guardians) state they cannot continue to fulfil their role as guardian for the child during the course of the illness
• the other long-term guardian indicates they will not be able to fulfil their guardianship responsibility after their partner’s death.

The long-term guardian seeks alternative arrangements for the child’s care

If a long-term guardian does give the daily care of the child to another person (or nominates someone to take over the child’s daily care) and it appears that the arrangement is in the child’s best interest and is the most appropriate arrangement for meeting the child’s emotional and physical needs:

• Consult with the senior team leader and the OCFOS lawyer about a referral to the DCPL to vary the child protection order and seek an order granting long-term guardianship to the chief executive.
• Invite the person caring for the child to apply to become an approved carer. To ensure continuity of care for the child, facilitate a provisional approval of the carer applicant. (Refer to Procedure 6 Complete the provisional assessment.)

If a long-term guardian advises that they are no longer able and willing to meet their responsibilities as the child’s long-term guardian, including providing daily care for the child:

• Obtain and genuinely consider the child’s views before deciding the best way to proceed.
• Review the case plan and explore all options available to the child.
• Consult with the senior team leader and OCFOS lawyer to consider whether it is in the child’s best interest to make a referral to the DCPL for an application:
  • to vary the child protection order
    and
  • seek an order granting long-term guardianship to the chief executive or another suitable person.

Respond when the child is no longer in the long-term guardian’s direct care

If the long-term guardian advises that the child is no longer in their direct care:

• Seek information from them to confirm the child’s current whereabouts and the circumstances leading to the change.
• Have direct contact with the child (if their whereabouts are known) as soon as practicable after receiving the advice, to assess their immediate safety and wellbeing and determine whether a review of the case plan is required.
• Review the child’s needs for safety, belonging and wellbeing, and take any further action considered appropriate (Child Protection Act 1999, section 80A).
• Assess whether the long-term guardian is prepared to resume direct care of the child and if the child is prepared to return to the direct care of the long-term guardian, if Child Safety provides a period of time-limited case work aimed at addressing the factors leading to the change in circumstances. (Refer to Respond to a request for support.)
• Advise the long-term guardian that the fortnightly caring allowance and other financial supports will cease if the child is not in their direct care, but payments will recommence if the child returns to their care.
• Determine if the fortnightly caring allowance and other financial supports need to cease, based on the circumstances. (Refer to the policy Expenses—fortnightly caring allowance and inter-state foster payments and the policy High support needs allowance.)
• Inform the long-term guardian of their responsibility to advise Centrelink that the child’s care arrangement has ended, if applicable.
• Update the child’s placement details and location in their person record on Unify.

If the child’s whereabouts are unknown, make reasonable attempts to locate them, by contacting:

• the child’s long-term guardian to discuss possible places the child may be
• the child’s school or educational facility
• the child’s parents, siblings or other family members
• the child’s friends
• professionals or agencies currently or recently in contact with the child
• Centrelink, if considered appropriate in the circumstances. (Refer to Procedure 2 Take action if a child and family cannot be located.)

After assessing the child’s safety and wellbeing, consult the senior team leader about:  

• assisting the child and long-term guardian to resolve issues contributing to the young person leaving and to enable their return to the long-term guardian’s care
• the appropriateness of the order in meeting the child’s ongoing care and protection needs and whether to consult the OCFOS lawyer about making a referral to the DCPL for an application to the Childrens Court to:
  • vary the order granting long-term guardianship to a suitable person
    and
  • seek an order granting long-term guardianship to the chief executive.

Consider if the order needs to be varied

Consult with the senior team leader and OCFOS lawyer about a referral to the DCPL to vary the child protection order and seek an order granting guardianship to the chief executive if:

• the long-term guardian is no longer able and willing to be the child’s long-term guardian and fulfil their obligations under the Child Protection Act 1999, section 80
• the long-term guardian can no longer fulfil guardianship responsibilities but wants to continue caring for the child. The long-term guardian could be assessed as a kinship carer for the child, and if approved, continue to care for the child while they are in the chief executive’s custody or guardianship
• an assessment has been finalised with a child in need of protection  outcome, and it is assessed that the child is at unacceptable risk of harm, and the long-term guardian is not willing to work with Child Safety to address the concerns.

In all these circumstances, meet with the child, long-term guardian, family and other relevant people to review the case plan. (Refer to Review a case plan―long-term guardian/permanent guardian.)   

If an application to vary the order is made to the Childrens Court, while the application is proceeding:

• The long-term guardian will:
  • continue to have guardianship rights and responsibilities for the child
  • be treated by the court as a parent and afforded the same appeal rights
  • be a respondent in the proceedings.
• The child’s parents will:
  • have appeal rights
  • be respondents in the proceedings.