Organisations, including not-for-profit organisations and schools, are on notice that the Office of the Australian Information Commissioner (OAIC) is going to take a “stronger regulatory approach” to enforcement of the Notifiable Data Breach (NDB) Scheme from 2024. The national privacy regulator announced the stronger regulatory approach is due to information security being a regulatory priority in its bi-annual report publishing statistics of reporting trends under the Scheme.

We recommend organisations prepare for this new, stronger regulatory approach from the OAIC by:

  • Understanding the types of notifications made under the NDB Scheme in 2023 – we have done this for you below
  • Considering the risks of cybercrime in Australia
  • Reviewing the determinations by the OAIC which set these higher expectations
  • Reflecting on your security vulnerabilities – consider doing a data security audit or penetration testing
  • Implementing a data breach response plan tailored to your organisation
  • Training staff to identify data breaches, report internally and implement the data breach response plan

NDB Scheme statistics from 2023

In 2023, 892 notifications were made to the OAIC under the NDB Scheme.

Health service providers made the most notifications under the NDB Scheme, making 18% of all notifications. In addition, 37% of notification involved health information being subject to the breach. This is significant, because the regulatory response and imposition of civil penalties against organisations takes into account the emotional harm caused by privacy breaches, and the breach of health data can generally have a heightened negative impact on individuals; not to mention the possibly discriminatory consequences.

Understanding types of data breaches

Cyber security incidents represented 42% of notifications:

  • 22% were compromised credentials (includes phishing and other methods)
  • 14% were cyber incidents due to social engineering or impersonation
  • 12% were from ransomware

Human error represented 28% of notifications:

  • 5% were unintended release of publications
  • 10% were emailing information to the wrong person by mistake

In July to December 2023, compromised or stolen credentials were a leading cause of all data breaches. The OAIC identifies that the large-scale data breaches in recent years have put organisations at heightened risk of cyber incidents from compromised passwords because those passwords have previously been compromised. In addition to implementing multi-factor authentication and strong password requirements (including regular changing of passwords), organisations can:

How we can help

The privacy and data security team at Moores can help you prepare for data breaches through privacy training, privacy audits and designing custom privacy and data protection procedures and internal tools for staff. We can help you respond to a data breach by assessing the breach under the Notifiable Data Breach Scheme, and helping you implement a Data Breach Response Plan.

Contact us

Please contact us for more detailed and tailored help.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

A Mutual Wills Agreement (MWA) is an agreement between two people to make their Wills in particular terms and to not alter those terms in the future.

A MWA does not arise merely by a couple executing Wills together but requires an actual agreement to limit the future alteration of the Wills. This agreement is generally set out in a separate contract or referenced in the Wills themselves. However, in the recent decision of Re Miglic the Supreme Court of Victoria found a verbal agreement made nearly 30 years prior to death constituted a binding and enforceable MWA.

Facts of Re Miglic [2024] VSC 20

  • Kurt and Marilyn Miglic were spouses from the 1960s until Kurt’s passing in 2007. Kurt had two children, Lisa and Andrea, from a prior marriage, whereas Marilyn did not have any children.
  • In 1981, Kurt made a Will that contained a life interest for Marilyn but with all his assets eventually passing to his children.
  • In 1988, Kurt made a further Will that likewise contained a life interest for Marilyn with all his assets eventually passing to his children. Marilyn also made a Will at that time that made fixed provision for her nephew and nieces (Stephen, Victoria and Louise) with the residue passing to Kurt, or his children if he was deceased.
  • In 1993, Kurt and Marilyn made new Wills that simply left everything to each other initially and then (aside from minor gifts to Stephen, Victoria and Louise) everything to Kurt’s children when they both passed.
  • Kurt died in 2007 with his entire estate passing to Marilyn pursuant to the 1993 Will.
  • Marilyn made new Wills in 2001, 2005, 2011, 2014 and 2018. It was found that Kurt had not consented to the new Wills made during his lifetime given he had advanced dementia at the time.
  • Marilyn died in 2020 and by her last Will:
    • gifted a property 1/5 each to Lisa, Andrea, Stephen, Victoria and Louise – this property was sold for $11.5M and was the major asset; and
    • apart from other minor gifts, left the balance between Andrea, Victoria and Louise.
  • Lisa and Andrea brought proceedings alleging that Kurt and Marilyn made a binding agreement in 1993 that they would not change their Wills (such that Kurt’s children would ultimately receive the majority of the survivor’s estate) without the consent of the other.

The evidence of a Mutual Wills Agreement

There was no written record of any MWA. 

In support of the MWA:

  • Lisa and Andrea gave evidence of a number of conversations from 1993 where Kurt relayed that he and Marilyn had agreed that everything would go to them when they both passed and that they could not change their Wills without the others’ consent. Marilyn had apparently been party to some of these conversations.
  • Their mother and Andrea’s ex-husband also gave supporting evidence of similar conversations with Kurt.
  • Lisa and Andrea also produced their solicitor’s notes to show that they had immediately raised the issue of a ‘family agreement’ with him when seeking advice and not invented that later when advised about the concept of a MWA.

Against the MWA:

  • The solicitor who prepared the 1993 Wills gave evidence that Kurt and Marilyn had made no mention to him of any agreement that they could not later change their Wills.
  • Stephen, Victoria and Louise argued that Lisa and Andrea’s evidence had shifted over the course of the proceedings and was not reliable.
  • Stephen, Victoria and Louise were otherwise at a disadvantage in that they could not give direct evidence on relevant discussions as they were not part of the immediate family and were not involved in those discussions.

The findings of the Supreme Court of Victoria

The Supreme Court of Victoria found that Kurt and Marilyn had entered into a binding verbal MWA at the time of executing their 1993 Wills. The findings further noted:

  • A key issue was whether there was merely an expectation that the intention would be honoured or if it was intended to be legally binding. 
  • A couple making Wills together that ultimately leave their estates to the same beneficiaries is not, of itself, sufficient reason to conclude an intention that neither is able to make a new Will in the absence of the other’s consent.
  • Caution must be had in accepting evidence of verbal agreements. It is well recognised that honest people’s memories can become unreliable and the risk of that happening is very real in the context of litigation where people have a lot to lose or gain by their evidence. In this scenario, the MWA was proved by hearsay evidence of representations made by Kurt and Marilyn up to 30 years ago (with hearsay generally being inadmissible but an exception is made where the relevant person is deceased).
  • Notwithstanding the difficulties with the evidence, the standard of proof remains the ‘balance of probabilities’.  

The outcome of the finding is that Marilyn’s 2018 Will remains valid, but her estate is subject to a trust that reflects the terms of the 1993 Will. Lisa and Andrea will therefore receive the vast majority of her estate.

Key takeaways for mutual Wills

This case highlights the complexities in planning for blended families.

It also highlights the importance for a couple to be clear around whether they intend that their Wills could be changed in the future as circumstances or objectives change, or if they intend to be bound to the agreed plan. If the latter is the case, then this needs to be recorded in a written MWA. While a verbal agreement was upheld in this case, it is likely that this is the exception rather than the rule.

How we can help

For expert advice or guidance regarding Estate Planning and whether a Mutual Wills Agreement may be appropriate, contact our team.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Accepting a role as a legal personal representative of an estate (ie an executor or administrator, ‘LPR’) can be a daunting task, particularly given the risk of personal liability that goes with it. 

A key starting point to navigating the role as LPR is being aware of the timeframes which apply when administering a deceased estate.

Many of the key timeframes are outlined here, and include the following:

Notice of intention – 14 days before application for grant of representation

Before an LPR can make application for a grant of representation, they must advertise their notice of intention to do so, on the Supreme Court website1.

Where there is a valid will, this notice must include the LPR’s name and address, the date of the will to be probated and the names of the persons identified as executors in the Will.

This allows third parties a period in which to object to a grant of representation, which (in the context of a grant of probate) is typically done when somebody believes that the Will is not valid or there is a more recent Will.  

Once the 14-day period has lapsed, the LPR can file their application for a grant of representation.

In urgent matters (for instance, where a grant of representation is required to settle real estate), an LPR can be appointed without having to advertise a notice of intention, but this requires an application to the Supreme Court. 

Executor’s year – 12 months from date of death

The ‘executor’s year’ refers to the period of time that an LPR is afforded to administer an estate, without being compelled to make any distributions to beneficiaries. The principle is grounded in case law and legislation2.

However, an LPR should be aware that the principle does not mean:

  1. the administration must be complete after 12 months. Whilst 12 months is often a sufficient period in which to administer a straightforward estate, there are many reasons why an estate may take longer to finalise (including disputes or complexity).
  2. no distributions can occur within 12 months. There is often good reason to distribute an estate within 12 months from the date of death, particularly where the limitation period for a family provision claim has expired.   

Ultimately, the LPR must always ensure that they are acting promptly in the ‘due administration’ of the estate, regardless of the time period since death. 

Limitation period for family provision claims – 6 months from the grant of representation

In Victoria, an eligible person may claim further provision from an estate in circumstances where they believe that they have not been left adequate provision for their proper maintenance and support.

This claim must be made within 6 months of the grant of representation.

For this reason, LPR’s are advised not to distribute an estate within this period of time. If they do, and a successful claim is made, the LPR may be held liable if insufficient assets in the estate remain to meet the claim. 

A family provision claim can also be made outside the 6 month limitation period in certain circumstances but only where assets in the estate remain at that time. It is therefore prudent for an LPR, where feasible, to distribute an estate as soon as possible after the 6 month limitation period lapses, particularly where a potential claim exists.

Interest on a pecuniary legacy – 12 months from death

A gift of money in a will (called a pecuniary legacy) starts to attract interest3 if it has not been paid within one year after the testator dies.

Accordingly, an LPR should, where possible, seek to make payment of pecuniary legacies within this period of time, to prevent interest accruing.

How we can help

Planning is key when administering a deceased estate and knowing what timeframes apply is crucial to limiting the risk of liability. Our team of deceased estates legal experts can help you if you have any queries navigating these timeframes.

Contact us

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.


1Rule 2.03 of the Supreme Court (Administration and Probate) Rules 2014).

2Section 49 of the Administration and Probate Act.

3At the ‘legacy interest rate’ which is the rate that lies 2 per cent above the cash rate last published by the Reserve Bank of Australia: s39B(3) of the Administration and Probate Act 1958 (Vic)

It is now increasingly common for retirement village developers to present captivating promotional material to prospective residents for a village while construction is still underway. If a resident agrees to purchase or lease a unit before it is built, this is known as ‘buying off the plan’.

However, much like purchasing property off the plan, there are a number of things that buyers should keep in mind before they make their decision.

Purchasing something that you haven’t seen

One obvious consequence of entering contracts for an off the plan retirement village is that you will not have an opportunity to inspect the property before signing the contract.

Often prospective residents are left to rely on architectural drawings, designer impressions and advertising material to get a sense of what they are getting into.

Unexpected changes

But what happens when things don’t go according to plan? Whether the issue relates to changes in design, defective work, or late completion, it is important to ensure that you have the proper protections under your contract.

Every contract is different. Some examples of features that we have observed in retirement village contracts include:

  • a clause restricting the village owner from making changes to the plans and specifications unless they are directed to do so by a building authority, or the changes do not materially affect you;
  • a common clause which prevents the size of the unit changing by more than 5%;
  • the inclusion of a defect liability period for a short period after you become a resident;
  • a special condition which renders the contract conditional upon any sale of home that you may be relying upon to fund your entry; and
  • if the construction project is significantly delayed or the village owner lacks the finances to continue, a sunset clause allowing you to withdraw and recover any deposit that you have paid.

Staged construction

Another matter to consider is whether the retirement village will be completed in stages. Sometimes, a retirement village may offer units for purchase or lease before construction of the village as a whole is complete. In those circumstances, it will be important to keep in mind that:

  • whilst your unit may be complete, there might be several common facilities which will not be available to use at the time you move in;
  • your service fees should reflect the proportion of common facilities available.

Who covers the shortfall?

When a new village is getting started, it may take time for the owner to find residents for each unit. Whilst the owner is selling down homes, it is often the case that the village will incur a shortfall with respect to its operating account as the operating costs are greater than the service fees paid by residents. We like to see off the plan contracts include a clause that the owner will cover the shortfall until the village is fully or nearly fully occupied.

How we can help

Retirement village law is a complex and niche area. If you would like the assistance of specialist lawyers to review your documentation and help mitigate the risks outlined above, please do not hesitate to contact us.

Contact us

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Moores Senior Lawyers, Rowdy Johnson and Kate Drummond, sit down in a Moores Q&A to break down the changes to the Vacant Residential Land Tax in Victoria and what it means for owners of holiday homes.

The Albanese federal government has started the year by introducing a suite of significant workplace reforms, passing the Fair Work Legislation Amendment (Closing Loopholes No.2) Act 2023 (Cth) (Act) following robust debate. It follows the passing of the Fair Work Legislation Amendment (Closing Loopholes Act No.1) Act on 7 December 2023. Key changes made in the initial tranche included the criminalisation of intentional wage theft, broadened discrimination protections, increased workplace delegate rights (with the exception of regulated workers) and “same job, same pay” rights for labour hire workers.

The second tranche of workplace relations reforms aim to improve Australia’s workplace relations framework by addressing gaps in the current laws and includes:

The definition of employment has changed

In 2022, the majority of the High Court of Australia in CFMEU v Personnel Contracting Pty Ltd and ZG Operations v Jamsek established that when determining if a person is an employee or individual contractor, the written contract between the parties takes primacy.

The Act amends the Fair Work Act 2009 (Cth) to override this principle. New section 15AA of the Act will require the ordinary meanings of ‘employee’ and ‘employer’ be determined by reference to the ‘real substance, practical reality and true nature’ of the relationship. The ‘totality of the relationship’, including how the contract is performed in practice, must be considered when ascertaining the real substance, practical reality and true nature of a relationship.

This change will be particularly relevant to independent contractor relationships and claims that a relationship should be characterised as employment. These issues will now be subject to a broader set of considerations than the written contract between the parties and it will be more difficult for employers to rely solely, or in the main, on the terms of a written contract to the exclusion of how the relationship works in a practical sense. Employers should also keep in mind that a person may be engaged as an independent contractor at first, but then due to the conduct of the parties afterwards, be found to be an employee.

This legislative change will only be relevant for determining entitlements under the Act. Whether a person is an ‘employee’ for the purposes of taxation, superannuation and workers compensation will continue to be determined by other tests.

An interesting element of this legislative change is that contractors who earn over a ‘contractor high income threshold’ (currently $167,500), and who are already engaged at the time the Act commences, may ‘opt out’ of the amended definition of employment. However, they will have the ability to revoke that ‘opt out’ decision at any time by giving written notice.

Casual employment changes

The Act introduces two key changes in relation to casual employment.

New definition of casual employee

The reforms introduce a new definition of ‘casual employee’ as follows:

  • the employment relationship is characterised by an absence of a firm advance commitment to continuing and indefinite work; and
  • the employee is entitled under a fair work instrument or contract of employment to a casual loading or specific rate of pay for casuals.

The factors that are relevant to assessing whether there is a firm advance commitment include consideration of the real substance, practical reality and true nature of the employment relationship, whether this is verbal, written or could be inferred by conduct.

Factors which indicate the presence of a firm advance commitment include:

  • the inability of the employer to offer, or not offer, work or inability of the employee to elect to accept or reject work;
  • the reasonable likelihood of future availability of continuing work having regard to the nature of the business;
  • whether full or part time employees perform the same kind of work; and
  • whether the employee has a regular pattern of work (even if the pattern changes over time e.g. for illness, injury or recreation).

This change signals a move away from an employee’s casual status being assessed based on contract only, to being assessed having regard to what happens in practice.

The Act removes the ban on employees being both casuals and engaged under a fixed-term contract, excluding for academic university staff. 

New pathway to casual conversion

The Act removes existing casual conversion provisions and introduces an “employee choice” framework.

Under the new casual conversion framework, a casual employee will be able to give their employer a written notice if they believe their employment is no longer casual, having regard to the new definition set out above. An employee can only give this notice after 6 months of employment if they are employed by a non-small business employer, and 12 months of employment if they work for a small business employer.

This new pathway removes many of the obligations employers had under the previous casual conversion provisions. Rather than making their own assessments and offering conversion where an employee meets certain requirements, employees need to initiate the shift to permanent employment and employers will need to respond to written notifications within 21 days after they are made. Employers must respond in writing, confirming the employee’s new status and hours of work if the notification is accepted. If employers do not accept the notification, they must set out why.

The Act provides that an employer may decline the employee notification, if:

  • the employee meets the definition of a casual employee;
  • there are fair and reasonable operational grounds for declining the notification; or
  • accepting the notification would result in the employer not complying with recruitment or selection processes required by Commonwealth, State or Territory laws.

Anti-avoidance framework

The Act introduces anti-avoidance provisions to ensure casual employees are engaged properly. This includes requirements that employers must not:

  • dismiss, or threaten to dismiss, an employee to engage that individual as a casual employee to perform the same or substantially similar work; and
  • make a statement that the employer knows is false to persuade or influence the individual to enter a contract for casual employment under which the employee will perform the same or substantially similar work for the employer.

The defence to sham contracting has been narrowed

Employers who have incorrectly classified an employee as an independent contractor may be penalised for sham contracting, unless they can prove that the amended sham contracting defence applies.

Prior to the reforms, an employer needed to prove that they did not know and were not reckless as to whether the contract was an employment contract rather than one for services.

The narrowed defence provides that an employer has not contravened the sham contracting provisions if, at the time of the representation, the employer reasonably believed the contract of employment was a contract for services.

In determining whether the employer’s belief was reasonable, courts will be required to consider the size and nature of the employer’s enterprise, and will have discretion to consider any other relevant matters.

Right to Disconnect

The Act also introduces a right for employees to refuse contact from employers or third parties outside their paid working hours, unless that refusal is unreasonable.

There is a set list of matters which must be considered when deciding whether a refusal to contact is unreasonable or reasonable. This will operate in a similar way to existing provisions in the Act which relate to reasonable additional hours. In determining whether a refusal to respond is unreasonable, regard must be had to:

  • the reason for the contact or attempted contact;
  • how the contact or attempted contact is made;
  • the level of disruption the contact or attempted contact causes the employee;
  • the extent to which the employee is compensated, either to remain available during the period in which the contact or attempted contact is made or for working additional hours outside their ordinary hours;
  • the nature of the employee’s role and level of responsibility;
  • the employee’s personal circumstances including family and caring responsibilities; and
  • whether contact is required by law.

The right to refuse contact will be a ‘workplace right’ for the purposes of the Act’s general protections regime. This means that if the employer and employee cannot resolve their dispute over the right to disconnect, either party can apply to the Fair Work Commission to make an order to stop refusing contact, to stop taking certain actions, or to otherwise address the dispute.

The Fair Work Commission will be required to issue written guidelines about what is reasonable or unreasonable contact from an employer or third party, which we expect will greatly assist employers and employees to have conversations about the right to disconnect. The right to disconnect provisions will have a delayed commencement for small businesses.

Significant increase to civil penalties

The maximum civil pecuniary penalties available under the Act for breaches by body corporates of the National Employment Standards, modern awards, enterprise agreements and minimum wages will increase at least fivefold:

Nature of breachBody Corporate
Contravention$469,500
Serious contravention$4,696,000

The maximum civil penalty for a contravention of the civil remedy provisions “associated with an underpayment amount” is the higher of:

  • the ordinary civil pecuniary penalties set out above; or
  • 3 times the value of the underpayment.

These increases only apply to breaches by body corporates and do not apply where the organisation is a small business employer at the time an application for a penalty is made.

Further, there are new criminal offences for specific intentional underpayments. The criminal offence carries a maximum fine for body corporates and a term of imprisonment of up to 10 years or a fine for individuals. Where the Courts can determine the underpayment amount, the maximum fine that a Court can order against a body corporate is the greater of 3 times the underpayment amount and 5,000 penalty units (currently $1,565,000) for an individual or 25,000 penalty units (currently, $7,825,000) for a body corporate. If the Court cannot determine the underpayment amount, the maximum fine for an individual is 5,000 penalty units ($1,565,000) and for a body corporate is 25,000 penalty units ($7,825,000).

Timing

We summarise below when each change will come into operation:

ChangeWhen it commences
Definition of employment26 August 2024, or an earlier date set by the Government
Casual employment (definition and casual conversion)26 August 2024
Sham contracting27 February 2024
Right to disconnect26 August 2024 (for non-small business employers)
26 August 2025 for small business employers
Increase to civil penalties27 February 2024 for increased civil penalties for breaches of the NES, modern awards, enterprise agreements and minimum wages by companies (does not apply to small businesses).
 
For civil penalties associated with an underpayment amount, commencement will be on 1 January 2025, or an earlier date to be fixed by proclamation (does not apply to small businesses).
Criminal penalties for underpayments1 January 2025

How we can help

The reforms summarised in this article highlight the importance of employers reviewing their engagement of workers, including whether:

  • casuals, fixed-term employees, and contractors are and will be engaged lawfully (noting the changes to casual employment, limitations on fixed-term contracts and increased risks of sham contracting, and the significant implications of these reforms);
  • their expectations about the availability of workers after hours;
  • changes in policy, process and contractual arrangements are required to address the reforms.

Our Workplace Relations team can assist employers to minimise the risk of breaching the sham contracting obligations which commenced on 27 February 2024, and prepare for the commencement of other significant workplace relations reforms in August 2024.

The reforms follow previous changes to Australia’s workplace laws made by the federal government in 2022, including the Secure Jobs, Better Pay Bill and the new limits on fixed term contracts, and changes made in 2023.

Contact us

Please contact us for more detailed and tailored help.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Having a space to express breastmilk in the workplace can be a critical part of a breastfeeding parents’ transition back to work after parental leave.

Fortunately, there are laws in place to protect breastfeeding parents who need to express breastmilk in the workplace. The failure of an employer to provide a private, clean and appropriate space for expressing breastmilk can amount to unlawful discrimination. It may also be unlawful discrimination to have a rule that workers cannot take short breaks during the day, as this may disadvantage breastfeeding women who need to take breaks to express breastmilk. An employer may not dismiss an employee who breastfeeds or expresses breastmilk because of assumed health and safety risks in the workplace.

What is breastfeeding discrimination?

Breastfeeding discrimination can arise where:

  • a person is treated unfairly because of their need to breastfeed or express breastmilk (direct discrimination); or
  • imposes a requirement, condition or practice that has the effect of disadvantaging women who breastfeed, and it is not reasonable (indirect discrimination)

A recent case involving breastfeeding discrimination

In one of the first reported anti-discrimination cases involving breastfeeding parents, the ACT Civil and Administrative Tribunal (Tribunal) recently found that a KFC franchisee indirectly discriminated against a worker by failing to provide an adequate solution for one of its workers to express breastmilk.

The Respondent in this case was a large private KFC franchise owner in Australia. The Applicant was a woman who started working for the Respondent when she was 14 years old in 2015 and worked her way up to the position of store manager. She gave birth to her daughter in June 2021 and was excited to return to work in November 2021.

The Applicant had a lengthy and, at times difficult, negotiation process with the Respondent’s management about a suitable return to work arrangement to accommodate her need to express breastmilk at work.

In November 2021, the Respondent allowed the Applicant to use a fridge to store her breastmilk and use the wash sink, but otherwise:

  • refused the Applicant’s request for a private room and comfortable chair, as they considered it impractical and too costly;
  • refused the Applicant’s request to leave the store to express breastmilk at a nearby mall with a parent room, as she was sometimes the only manager on site and the Respondent couldn’t guarantee there would be another manager certified in OH&S available during her shifts; and
  • suggested the Applicant transition to becoming a casual worker, which was a demotion.

The Applicant then lodged a complaint with the ACT Human Rights Commission.

Eventually, a flexible work arrangement was approved, which included a pop-up tent and foldout chair in the storeroom. However, after the Applicant returned to work, the Applicant found this solution to be unsuitable. Due to the thin walls, the sounds of expressing milk were audible to staff and as there was no door, any staff member could walk in at any time.

The Applicant instead proposed to take unpaid meal breaks during her shift to express breastmilk, but this request was denied. From time-to-time, the Applicant left the store to express milk at the parent room in the nearby mall, but as there was frequently no other manager on site, she had to express at a much later time which caused her physical pain and discomfort.

The Applicant claimed that she suffered significant mental harm and a reduced capacity to work because of the Respondent’s failure to accommodate an arrangement which allowed her to express breastmilk at work.

What did the Tribunal decide?

The Tribunal found the Respondent indirectly discriminated against the Applicant by imposing a condition requiring managers to remain on site unless another manager was available on site who is certified in OH&S. This condition disadvantaged workers who breastfeed and express breastmilk (a protected attribute) and was not reasonable in the circumstances.

The Tribunal found that the Applicant had no choice but to accept a demotion or express before or after her shifts, disadvantaging her. The tent inside a doorless storeroom that was eventually provided was not even a ‘pass’ level solution, causing embarrassment and discomfort, which was also a form of disadvantage.

To address the Applicant’s request, the Respondent had multiple options to consider, such as adding a storeroom door, transferring the Applicant to a nearby store with a private, appropriate space to express breastmilk or providing junior workers with OH&S training so they could act in her place during the brief periods she left the store to express.

Lessons for employers and other duty holders

Employers and other duty holders are required to make suitable arrangements to support workers transitioning back to work after parental leave or to accommodate breastfeeding, and a failure to do so may amount to unlawful discrimination.

Requests from breastfeeding workers to cater for their need to express breastmilk are a normal part of the modern workplace, and so employers may wish to proactively consider how to accommodate such requests in a positive and appropriate manner. Other duty holders such as councils, sporting organisations, educational institutional and service providers should also take steps to reasonably accommodate people to breastfeed.

The Tribunal in this case was also critical of the process the Applicant had to go through to request her return to work arrangement. At only 20 years old, she was interviewed on her own by two senior men who questioned her in detail about the breastfeeding process and made her feel uncomfortable. The suggestion by a senior female manager that the Applicant express in the toilet was also criticised as not being a modern solution for breastfeeding parents at work. Employers may consider developing a clear policy and process for how to address such requests, to avoid an unnecessarily complicated or intimidating process.

How we can help

Moores assists clients by:

  • developing best practice policies and procedures on equal employment opportunity, flexible work arrangements, and reasonable adjustments and accommodations;
  • providing advice on how organisations can support their staff to transition back to work after parental leave;
  • advising on complex discrimination issues;
  • assisting organisations to prevent and respond to discrimination as far as possible; and
  • providing training about unlawful behaviours in the workplace.

If a discrimination issue arises, we can support you in your response and investigation.

Contact us

Please contact us for more detailed and tailored help.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

In the case of Kaplan v State of Victoria (No 8) [2023] FCA 1092, five Jewish former students at Melbourne’s Brighton Secondary College (College) received compensation of $435,000 after the Federal Court found they had been subjected to anti-Semitic bullying and harassment, and that the State of Victoria and the Principal of the College breached the Racial Discrimination Act 1975 (Cth) (Act) by failing to properly address anti-Semitism at the College. This case highlights the significant discrimination and child safety implications of a school’s failure to proactively address discriminatory bullying and harassment against its students on an individual and systemic level.

Background of the case

The applicants, five former students from the College, filed a claim against the State of Victoria, the Principal of the College, and two teachers from the College. The claim alleged:

  • contraventions of s 9(1) of the Act, which makes racial discrimination unlawful;
  • contraventions of s 18C of the Act, which makes it unlawful for a person to do an act that is reasonably likely, in all the circumstances, to offend, insult, humiliate or intimidate another person or a group of people because of the race, colour, national or ethnic origin of the person (anti vilification provisions); and
  • negligence.

In summary, the applicants alleged that:

  • they were subjected to anti-Semitic bullying and harassment by individuals and groups of students at the College between 2013 and 2020, including verbal taunts and physical attacks;
  • they were exposed to a considerable volume of offensive graffiti, namely hundreds of swastikas drawn in classrooms, books and across the school grounds;
  • the above conduct made them fearful for their safety at School;
  • despite repeated complaints, staff at the school failed to take action in response to the anti-Semitic conduct;
  • the College failed to prevent or take disciplinary action in relation to the anti-Semitic behaviour at the College;
  • unlike treatment of other vulnerable minority student groups, inadequate steps were taken by the Principal and others at the College to address treatment of the applicants and protect Jewish students;
  • the Principal and staff at the College failed to take proactive or systemic steps to discourage the graffiti, educate students about its impact on vulnerable groups of students, or facilitate behavioural changes at the College.

Finally, the applicants alleged that the Principal contravened the anti-vilification provisions of the Act in respect of at least one speech he gave to a full school assembly, where the applicants allege he made remarks that offended, insulted, humiliated or intimidated Jewish students and were offensive more generally to Jewish people.

Each of the five applicants left the school as a result of the above.

The decision by the Court

The Court upheld the applicants allegations in part, and found that State of Victoria was vicariously liable for the Principal’s failure to adequately respond to anti-Semitic bullying and harassment by students.

The applicants succeeded on some of their claims under section 9(1) of the Act and negligence claims. Specifically, the Court found that:

  • the Principal engaged in unlawful discrimination contrary to the Act against four students by his failure to:
    • take systemic and co-ordinated action to address anti-Semitic bullying and swastika graffiti at the College;
    • enforce the College’s policies on racial harassment.
  • another employee engaged in unlawful discrimination under section 9(1) of the Act against one applicant by greeting him in Hebrew in front of his class, despite being told that the conduct was unwelcome and singled the applicant out.

The Court accepted the applicants’ claim that the Principal failed to address anti-Semitic bullying and harassment in a systemic and proactive way using recognised and established approaches in Australian secondary schools and approaches that were used at the College for other vulnerable students.

The Court found that the Principal contravened s 9 of the Act by failing to take reasonable and appropriate steps to discourage swastika graffiti and the anti-Semitic bullying and harassment of students. Appropriate and reasonable steps could have included taking disciplinary action against students who engaged in bullying and harassment, and taking systemic approaches to address the issue through school-wide campaigns. The Court found that at a leadership and systemic level the Principal took a different, and less favourable, approach to anti-Semitic bullying and harassment of Jewish students than he took, or would have taken, to the bullying and harassment of other vulnerable minority student groups. As a result, this different and less favourable approach to anti-Semitism was also adopted by College staff.

The Court observed an inexplicable and unusual tolerance for anti-Semitic graffiti and a preparedness to ignore, downplay and take less seriously the complaints made by Jewish students and their families. There was also a disinclination to adopt any systemic, school-wide steps to address anti-Semitic student behaviour, despite this having been done, appropriately, to protect LGBTQIA+ students and to encourage tolerance and acceptance of students who identified in that way or who were exploring their identity.

In relation to the claims made in negligence, the Court upheld the negligence claims made by four of the five applicants.

Damages and compensation orders were made against the State totalling approximately $435,000.

In its orders, the Court also provided a declaration to be made outlining the above findings of discrimination. The Court also prescribed some steps to be taken between the parties to negotiate a form of apology from the State of Victoria that is compatible with the Court’s reasons.

Key takeaways for organisations to help address discriminatory bullying and harassment

  • Anti-Semitism in schools must not be tolerated, and schools should take proactive steps to protect the safety and wellbeing of Jewish students when incidents of anti-Semitic bullying and harassment arise.
  • Schools should ensure they have a policy, procedure and code of conduct that sets out:
    • acceptable and unacceptable behaviours by and against all students;
    • how the school will prevent and respond to bullying, harassment and discrimination, regardless of the protected attribute. Appropriate proactive steps should be taken to support students subjected to discrimination and deter the discriminatory behaviour.
  • Schools should adopt a consistent approach to allegations of bullying, harassment and discrimination, regardless of the protected attribute (e.g. race, religious belief, gender, sex and disability). That said, the actions taken to deter harmful behaviour may be appropriately tailored to the relevant vulnerable cohort, in consultation with appropriate stakeholders.
  • Schools in Victoria must also ensure that their policies and procedures to protect students from bullying, harassment and discrimination align with the Victorian Child Safe Standards and Ministerial Order 1359, which requires Schools to ensure that equity is upheld and the diverse needs of students be respected in policy and practice.
  • There are different thresholds for reportable conduct between jurisdictions. However, discriminatory bullying and harassment may also cause significant psychological and emotional harm, and a failure to address this could in some circumstances constitute significant neglect in the form of supervisory neglect. Depending on the circumstances, this may constitute reportable conduct under a reportable conduct scheme, which may need to be reported and investigated.  

How we can help

Our safeguarding team has expertise in both child safety and discrimination matters. We are well placed to assist with incidents raising either or both of these issues and can provide peace of mind in navigating any allegations or investigations that may arise.

Contact us

Please contact us for more detailed and tailored help.

Subscribe to our email updates and receive our articles directly in your inbox.

Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

As you would likely be aware from the popular media, there are some significant changes to the Victorian land tax landscape in 2024. Unfortunately, the complexity of the legislation and the messaging coming from the Government and Opposition can mean it’s difficult to work out what those changes mean in a practical sense.

We cut through the confusion and explain (in simple terms) the things you need to have on your radar going into the new year.

1. Expansion of VRLT across Victoria

The vacant residential land tax (VRLT) regime is being expanded to apply throughout Victoria. 

Introduced at the start of 2018, the VRLT regime originally only applied to properties in inner and middle Melbourne (ie. properties in certain specified local government areas within a ring around the CBD). The tax is payable for a calendar year when the property was vacant for more than 6 months in the previous calendar year.  Owners have a positive obligation to notify the State Revenue Office if that is the case.

From 1 January 2025, the catchment area for VRLT has been expanded to the whole of Victoria. This means that the way the property is used throughout 2024 will determine whether VRLT is payable for the 2025 year. 

The exemptions from VRLT can be highly technical, and care should be taken in relying upon general advice or media summaries. The main exemptions are:

  • The holiday home exemption, which is now available for properties used and occupied by any of the following as their holiday home for at least four weeks in a calendar year:
    • the owner or a relative of the owner (if the owner is an individual); or
    • a vested beneficiary or a relative of the vested beneficiary (if the owner is a trust).
      It is important to note that this exemption is not currently available for properties owned by an organisation or association (or trusts without a vested beneficiary) – so if you hold your holiday home in a company or trust, be aware that VRLT could apply from next year. The Government has flagged that there may be some change forthcoming in this area later this year, but as there is no specific detail of what is planned or when, owners would be wise to make their plans on the basis of the current laws.
  • The work accommodation exemption, which is available for properties used and occupied by the owner (or if the owner is a trust, by a vested beneficiary) at least 140 days (whether continuous or aggregate) in a calendar year for the purpose of attending their workplace or conducting business. Note that this exemption is also not available for properties held in a company structure.
  • The change of ownership exemption, which applies to any property which changed ownership (ie. title was transferred) during the previous calendar year.
  • The new residential land exemption, which can now be available for a period of up to three years after the land first becomes residential in nature (subject to certain requirements).

Action to take: If you own a residential property which is currently vacant or used for less than six months cumulatively each year, consider whether it could qualify for any of the exemptions. If not, you may wish to look at the options to ensure that it is occupied for more than six months this year – for example, by leasing it to a residential tenant.

2. Increase in the VRLT rate

From 1 January 2025, a new, progressive, rate of VRLT will apply based on the number of consecutive tax years the land has been liable for VRLT. 

Previously, VRLT was fixed at 1% of the property’s capital improved value (CIV). Under the new rules, VRLT will be calculated on a progressive rate:

YearVRLT Rate
First year which the land is liable for VRLT1% of CIV
Second consecutive year which the land is liable for VRLT2% of CIV
Third and subsequent consecutive years which the land is liable for VRLT3% of CIV

By way of illustration, Tom inherited a home in Daylesford from his mother, who died 4 years ago. The CIV shown on the council rates notice is $850,000. Tom occasionally visits the property for a weekend to tend to the garden and do some maintenance on the home, but it is otherwise empty while he decides whether he wants to live there in his retirement.

If Tom continues this pattern of use, then in 2025 he will be liable for VRLT of $8,500 on the home. This will increase to $17,000 in 2026, and $25,500 from 2027 onwards.

Action to take: If you own any unoccupied residential property (whether in your own name, or through a company or trust), consider the possible financial implications of the changes.  Check the CIV on your current council rates assessment – use this figure to calculate your potential VRLT liability and help inform your decision-making about how you will deal with the property this year and future years.

3. Extension of VRLT to capture unimproved residential land

Previously, VRLT only applied to land with a residence constructed on it. From 1 January 2026, however, the tax will extend to some unimproved residential land, ie. residential land without any residence on it.

VRLT will apply to vacant land which:

  • is located in metropolitan Melbourne;
  • has remained undeveloped for at least five years; and
  • is capable of residential development.

The rationale given for this change is to encourage development (and discourage land banking), with a view to increasing housing supply in metropolitan Melbourne.

Action to take: If you own vacant land which is unlikely to be developed in the next two years, consider whether a sale is appropriate and if not, factor in the potential VRLT liability from 2026.

4. No more apportionment of land tax when purchasing real estate

Vendors are prohibited from apportioning land tax to a purchaser under contracts of sale entered into from 1 January 2024. This is a significant change to the standard practice of apportioning land tax along with other periodic statutory outgoings such as council rates and water rates – previously, the vendor would bear outgoings only up to the day of settlement. Now the vendor must pay the land tax for the whole year. 

There is no contracting out of this provision – it is now an offence for a vendor to enter into a contract of sale that purports to require the purchaser to pay an amount for, or towards, the vendor’s land tax. However, it is open to vendors to seek to recover the difference through a higher asking price.

The prohibition does not apply to contracts where the consideration is $10 million or more (noting that this amount is subject to indexation).

Action to take: If you’re entering into a contract for the sale or purchase of a property, ensure that it doesn’t include a provision apportioning land tax between vendor and purchaser.

5. New exemption – Trust for Nature conservation covenants

From 1 January 2024, land which is subject to “conservation covenant” is entitled to an exemption from land tax. To qualify for exemption, the landowner must have entered into a covenant with Trust for Nature (Victoria) for the conservation of the land under the Victorian Conservation Trust Act 1972 (known as a “Trust for Nature” covenant). The exemption is available only upon application and can apply to part of a land parcel if only part is subject to the covenant.  

Action to take: If you own land which is subject to a Trust for Nature covenant or are considering purchasing such land, submit a land tax exemption application.

How we can help

The property team at Moores has extensive experience in land tax matters and can provide strategic advice tailored to your specific property ownership situation, giving you a road map through the confusion.

If you would like to explore your options in this regard, please get in touch with us and we’ll help you work out a solid plan.

Contact us

Please contact us for more detailed and tailored help.

Subscribe to our email updates and receive our articles directly in your inbox.

Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

As you would likely be aware from the popular media, there are some significant changes to the Victorian land tax landscape in 2024. Unfortunately, the complexity of the legislation and the messaging coming from the Government and Opposition can mean it’s difficult to work out what those changes mean in a practical sense.

We cut through the confusion and explain (in simple terms) the things you need to have on your radar going into the new year.

1. No more apportionment of land tax when purchasing real estate

Vendors are prohibited from apportioning land tax to a purchaser under contracts of sale entered into from 1 January 2024.  There is no contracting out of this provision – it is now an offence for a vendor to enter into a contract of sale that purports to require the purchaser to pay an amount for, or towards, the vendor’s land tax if the consideration for the property is under $10 million (noting that this amount is subject to indexation). 

This is a significant change to the standard practice of apportioning land tax along with other periodic statutory outgoings such as council rates and water rates, and is welcome news for charitable organisations purchasing property – they will no longer have to contribute to the vendor’s land tax.

Action to take: If your organisation is purchasing property, ensure the contract doesn’t include a provision apportioning land tax between vendor and purchaser. In addition, consider seeking advice about any exemptions which could apply once your organisation owns the property.

2. Expansion of VRLT across Victoria

The vacant residential land tax (VRLT) regime is being expanded to apply throughout Victoria. 

Introduced at the start of 2018, the VRLT regime originally only applied to properties in inner and middle Melbourne (ie. properties in certain specified local government areas within a ring around the CBD). The tax is payable for a calendar year when the property was vacant for more than 6 months in the previous calendar year. Owners have a positive obligation to notify the State Revenue Office if that is the case.

From 1 January 2025, the catchment area for VRLT has been expanded to the whole of Victoria. This means that the way the property is used throughout 2024 will determine whether VRLT is payable for the 2025 year.

The exemptions from VRLT can be highly technical, and care should be taken in relying upon general advice or media summaries. The main exemptions are:

  • The holiday home exemption, which is now available for properties used and occupied by any of the following as their holiday home for at least four weeks in a calendar year:
    • the owner or a relative of the owner (if the owner is an individual); or
    • a vested beneficiary or a relative of the vested beneficiary (if the owner is a trust).
      Importantly, organisations (companies, associations etc) cannot make use of the holiday home exemption. The Government has flagged that there may be some change forthcoming in this area later this year, but as there is no specific detail of what is planned or when, organisations would be wise to make their plans on the basis of the current laws.
  • The work accommodation exemption, which is available for properties used and occupied by the owner (or if the owner is a trust, by a vested beneficiary) at least 140 days (whether continuous or aggregate) in a calendar year for the purpose of attending their workplace or conducting business. Note that this exemption is also not available for properties owned by an organisation.
  • The change of ownership exemption, which applies to any property which changed ownership (ie. title was transferred) during the previous calendar year.
  • The new residential land exemption, which can now be available for a period of up to 3 years after the land first becomes residential in nature (subject to certain requirements).

Action to take: If your organisation owns a residential property which is currently vacant or used for less than 6 months cumulatively each year, consider renting it out or seek legal advice about whether the property could qualify for any of the exemptions. 

3. Increase in the VRLT rate

From 1 January 2025, a new, progressive, rate of VRLT will apply based on the number of consecutive tax years the land has been liable for VRLT. 

Previously, VRLT was fixed at 1% of the property’s capital improved value (CIV). Under the new rules, VRLT will be calculated on a progressive rate:

YearVRLT Rate
First year which the land is liable for VRLT1% of CIV
Second consecutive year which the land is liable for VRLT2% of CIV
Third and subsequent consecutive years which the land is liable for VRLT3% of CIV

By way of illustration, Do Good Ltd purchased a residential property in Daylesford last year with a view to potentially setting up a retreat for ill children and their families. The CIV shown on the council rates notice is $850,000. The Board is undecided about plans for future use at this stage and for now, the property is sitting vacant with staff visiting occasionally for maintenance purposes or for weekend breaks.

If Do Good Ltd continues this pattern of use, then in 2025 it will be liable for VRLT of $8,500 on the property. This will increase to $17,000 in 2026, and $25,500 from 2027 onwards.

Action to take: Consider unoccupied residential property you might own and the budget implications.  Check the CIV on your current council rates assessment– use this figure to calculate the potential VRLT liability and help inform your Board’s decision-making about how you will deal with the property this year and future years.

4. Extension of VRLT to capture unimproved residential land

Previously, VRLT only applied to land with a residence constructed on it. From 1 January 2026, however, the tax will extend to some unimproved residential land, ie. residential land without any residence on it.

VRLT will apply to vacant land which:

  • is located in metropolitan Melbourne;
  • has remained undeveloped for at least five years; and
  • is capable of residential development.

The rationale given for this change is to encourage development (and discourage land banking), with a view to increasing housing supply in metropolitan Melbourne.

Action to take: If your organisation holds vacant land, consider the likely time frame for development and factor in the potential VRLT liability if development is unlikely to take place within the next 2 years.

5. New exemption – Trust for Nature conservation covenants

From 1 January 2024, land which is subject to “conservation covenant” is entitled to an exemption from land tax. To qualify for exemption, the landowner must have entered into a covenant with Trust for Nature (Victoria) for the conservation of the land under the Victorian Conservation Trust Act 1972 (known as a “Trust for Nature” covenant). The exemption is available only upon application and can apply to part of a land parcel if only part is subject to the covenant.  

Action to take: If your organisation owns land which is subject to a Trust for Nature covenant or is considering purchasing such land, ensure that a land tax exemption application is submitted for the property.

How we can help

The property team at Moores has extensive experience in land tax matters and can provide strategic advice tailored to your specific property ownership situation, giving you a road map through the confusion.

If you would like to explore your options in this regard, please get in touch with us and we’ll help you work out a solid plan.

Contact us

Please contact us for more detailed and tailored help.

Subscribe to our email updates and receive our articles directly in your inbox.

Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.