The National Network of Incarcerated and Formerly Incarcerated Women and Girls has today written to NSW Premier Chris Minns, raising serious concerns about proposed reforms to the Working with Children Check (WWCC) system and the dangerous narrative underpinning them.

The letter follows recent reporting suggesting the NSW Government will “crack down” on compliance and further restrict access for people with criminal records, after an audit revealed widespread failures across organisations.

But the Network says the government is targeting the wrong problem.

‘The audit did not reveal a system overrun by dangerous individuals slipping through. It revealed systemic failure by organisations, hundreds of them, to even verify checks before people started work. That is where accountability must sit,’ said Debbie Kilroy.

The Network warns that the current political framing risks expanding an already exclusionary system that locks criminalised and formerly incarcerated women out of employment, community participation, and the very sectors where their lived experience is most needed.

In our submission to the recent NSW inquiry into the WWCC system, the National Network detailed how the current framework is already causing harm, capturing women with minor or historic convictions, including those shaped by racism, poverty, coercion, and domestic and family violence, and subjecting them to opaque, inconsistent decision-making processes.

‘Criminalisation is being treated as a proxy for risk. It is not. It is a reflection of who our systems target, police and punish,’ said Debbie Kilroy.

The National Network is particularly alarmed by proposals to remove external appeal pathways, warning this would concentrate decision-making power within a single agency and strip away critical safeguards.

‘For women who have already experienced systemic injustice, independent review is not optional, it is protection against error, bias and unchecked discretion,’ said Debbie Kilroy.

The letter also challenges the fundamental contradiction at the heart of the government’s approach: investing heavily in child protection systems, while excluding the very women who hold deep, community-based knowledge of harm, survival, and safety.

‘Many of the women being locked out of this workforce are mothers, carers, and leaders in their communities. They are not abstract risks to be managed. They are people who have lived through violence, including state violence, and who are actively supporting others to do the same,’ said Tabitha Lean.

‘Child safety cannot be built on exclusion. It is built through strong communities, stable lives, and the meaningful inclusion of those who understand harm from the inside out,’ said Tabitha Lean.

The National Network has made clear it will continue to pursue this issue, including direct engagement with government, to ensure reforms do not further entrench cycles of marginalisation and poverty under the guise of protection.

‘The National Network will not stand by while ‘child safety’ is used to justify the permanent exclusion of criminalised women from community life,’ said Debbie Kilroy.

‘We are calling on the NSW Government to shift its focus, away from punitive restrictions on individuals, and toward holding organisations accountable, strengthening transparency, and meaningfully engaging with women who have lived experience of these systems,’ said Debbie Kilroy.

The National Network also call on Minister Kate Washington and Minister Jodie Harrison to support these demands. Both Ministers have attended the Keeping Women Out of Prison (KWOOP) Parliamentary Breakfasts for the last 2 years and heard firsthand from a panel of NSW criminalised women who shared how gaining employment within the community after release was one of their main barriers to becoming contributing members of the community, and the discrimination experienced in trying to gain WWCC’s, (even having acquired recognised Community Services and Welfare qualifications and having experience of working effectively with youth).

For further comment, please contact Debbie Kilroy on 0419 762 474 or Tabitha Lean on 0499 780 226