Christchurch United Football Club June 2025

Background

The Chief Review Officer has the authority to carry out reviews (which may be general or in relation to particular matters) of the provision of a safe physical and emotional environment that supports learning for students accommodated in hostels under section 470 of the Education and Training Act 2020. This function is delegated to review officers who have the powers to enter and carry out review of hostels under section 472 of the Act.

Context

The Christchurch United Football Club (CUFC) provides stand-alone boarding facilities in a hostel for up to 10 male students who have been selected for the club’s Residential Boarding Programme. The hostel neighbours the CUFC football grounds and training facilities. It opened in January 2024. This is the first ERO review of the hostel.

Academic education is provided for boarders through partnerships with two Christchurch schools: Ao Tawhiti Unlimited Discovery and St Thomas of Canterbury College. These partnerships are formalised through a Memorandum of Understanding between CUFC and each school as required by the special condition on the hostel’s licence. Each memorandum was signed in February 2025, and they are due to expire in February 2028.

There are three buildings and a large outdoor area on the site where the licensed hostel is located. CUFC considers that two of the buildings are not licensed parts of the hostel. However, the current use of the two adjacent buildings is such that they require to be licensed.

The licensed hostel is a recently renovated house consisting of four dormitories/bedrooms, each shared by a pair of boarders. This building also contains two bathrooms, a room for quiet study, laundry facilities and an open plan kitchen/dining/living area of sufficient size for all boarders to gather. Meals are prepared and served in this building. This licensed building currently houses 8 boarders.

The following are the non-licensed buildings and their current use:

• a sleeping quarters for the hostel manager and an isolation space, when needed, for a boarder who is unwell
• a building that has three dormitories/bedrooms, currently occupied by three boarders and an adult who is neither enrolled in a school nor a hostel employee. This building also has bathroom and laundry facilities and an open-plan kitchen and living space with recreation equipment. This kitchen is used by these boarders to prepare and eat breakfast.

Findings

The hostel manager and the hostel owner has attested in the Hostel Assurance Statement that they meet the requirements of the Hostel Regulations 2005.

The review of the hostel identified that CUFC has a suite of appropriate policies which address the Hostel Regulations. ERO has significant concerns that CUFC governance lacks understanding of the Hostel Regulations 2005 and the implementation of expected quality procedures and practices. In particular: 

• The hostel exceeds its licensed maximum number of boarders.
• Unlicensed areas are used for accommodating boarders, including with an adult who is not a hostel employee.
• Overnight supervision and security are inadequate. Hostel staff cannot know if people enter or exit the hostel overnight.
• No process is in place for visitors to sign into and out of the hostel.
• There is insufficient staffing for the expected supervision of boarders. Boarders remaining at the hostel are unsupervised while hostel staff accompany other boarders on optional excursions.
• There is a lack of formalised and documented risk assessment and management systems for excursions.
• Records need to be kept of all instances when medication or first aid has been administered to boarders.
• Boarders are responsible for laundering their own bedding and towels. This is not well monitored for hygiene.
• Practices do not satisfy all requirements of a fire evacuation scheme for all buildings onsite.
• There are no emergency procedures for earthquakes or lockdown/shelter in place.
• Food is prepared and served without a Food Control Plan in place.
• Not all boarders are New Zealand citizens or hold a residence class visa; the memoranda with schools are insufficient for adhering to the Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021 established under section 534 of the Education and Training Act 2020.
• Building warrants of fitness have not been obtained.

Meetings between hostel staff and boarders are held weekly. The boarders ERO interviewed reported that they enjoyed the Residential Boarding Programme including the football training and excursions organised by the club and hostel staff. Boarders said they felt well supported in the hostel and valued the degree of independence provided.

Actions for Compliance

ERO identified non-compliance in relation to:

• The hostel must at no time accommodate more than a specified maximum permitted number of boarders. 
  [Reg. 22 Hostel Regulations 2005]
• Insufficient procedures and monitoring of laundering, including sheets and bath towels. 
  [Reg. 46 Hostel Regulations 2005]
• All hostel staff must be trained in earthquake drills, and in other emergency procedures 
  [Reg. 48 (c) Hostel Regulations 2005]
• Practices do not satisfy all requirements imposed by or under the Fire and Emergency New Zealand Act 2017 for a fire evacuation scheme for the buildings concerned. 
  [Reg. 49 (b) Hostel Regulations 2005; Fire and Emergency New Zealand Act 2017; Fire and Emergency New Zealand (Fire Safety, Evacuation Procedures, and Evacuation Schemes) Regulations 2018.]
• Safety and hygiene of premises, equipment, etc needs to be compliant 
  [Reg. 50 Hostel Regulations 2005]
• First-aid equipment and supplies are not sufficient to meet all reasonably foreseeable first-aid needs of the boarders are provided at the hostel, maintained, and ready for immediate use. 
  [Reg. 52 (1) (a) Hostel Regulations 2005]
• The owner of a hostel must ensure that boarders are not accommodated in unlicensed premises. 
  [Reg. 53 Hostel Regulations 2005]
• The owner of a hostel must ensure that the hostel is managed in accordance with written policies, and written operating procedures, maintained by the owner. 
  [Reg. 54 (1) Hostel Regulations 2005]
• Procedures must specify how recreational and other associated activities (such as transport to and from venues) are to be assessed to identify any risks involved, and how arrangements are to be made to manage those risks. 
  [Reg. 56 (2) (e) Hostel Regulations 2005]
• Records must be kept of details of all medicines of any kind administered by hostel staff to the boarder while at the hostel, the occasions on which they were administered, and by whose authority they were administered. 
  [Reg. 59 (f) Hostel Regulations 2005]
• Every person not employed or engaged by the hostel who has regular access to the hostel or unsupervised contact with boarders must be subject to a suitability check (including Police vetting). [Reg. 61 (2) (da) (ii) Hostel Regulations 2005]
• Security measures must be used to prevent unauthorised access to the hostel’s premises. 
  [Reg. 61(2) (f) Hostel Regulations 2005]
• CUFC must ensure that the hostel is at all times staffed with a ratio of staff to boarders present at the hostel that ensures the safety of those boarders having regards to the number of them and their ages and needs; the nature (including the locations and times of day) of their activities; the training and qualifications of the staff or other adults concerned. 
  [Reg. 61 (3) Hostel Regulations 2005]
• The hostel owner must ensure that food is, when stored, prepared, and served, free of, and adequately protected against, contamination and register a Food Control Plan (FCP) under the Food Act 2014. 
  [Reg. 63 (b) Hostel Regulations 2005; Food Act 2014]
• Annual building warrants of fitness must be obtained, displayed and supplied to the territorial authority. 
  [Section 108 Building Act 2004]

In order to address this, the board of trustees must:

• conduct an urgent and thorough review of policies, procedures and practices to ensure alignment with the application for licensing, Hostel Regulations 2005 and other guiding legislation for operation.

The hostel owner/Manager has taken steps to address the areas of non-compliance identified.

Sharon Kelly
Director of Schools (Acting)

4 June 2025

About the Hostel