When Boundaries Blur: Lessons in Maintaining Professional Boundaries
On 24 March 2025, the Victorian Institute of Teaching (VIT) handed down a decision in relation to a serious breach of professional boundaries by former teacher at Carey Baptist Grammar (the School), Eleanor Yorke (Ms Yorke). The full decision can be found here (Decision).
This Decision serves as a reminder to all educational organisations of the importance of maintaining professional boundaries, particularly in student–teacher relationships, and the importance of ensuring that clear policies and accountability systems are in place.
Background
Ms. Yorke began teaching at Carey Baptist Grammar in 2017 and, during the COVID-19 lockdowns, taught a 17-year-old Year 12 student online. What began as academic support through Microsoft Teams developed into regular, personal exchanges.
Over time, the communication deepened, with approximately 35,000 messages sent between Ms. Yorke and the student. These messages became increasingly personal and emotional, far beyond what would be considered professional contact.
After the student graduated in 2021, Ms. Yorke entered into a sexual relationship with him. When the School became aware of the relationship in 2023, it reported the matter to the VIT. The VIT’s Disciplinary Panel (the Panel) found that Ms. Yorke had failed to maintain professional boundaries while teaching the student and engaged in a sexual relationship with a former student within two years of graduation, breaching the VIT Code of Conduct.
Ms. Yorke made admissions in relation to the allegations and expressed remorse. However, the Panel described her actions as a “deliberate rejection of professional standards”, noting that the power imbalance between teacher and student continued even after graduation. Her teaching registration was cancelled, and she was disqualified from teaching for three years, until March 2028.
Why Professional Boundaries Matter
Professional boundaries exist to protect both students and teachers. They ensure teaching relationships remain focused on learning, safety and wellbeing, and that power imbalances between students and teachers are not exploited.
The VIT Code of Conduct makes this duty explicit. Teachers must:
Maintain professional relationships with students;
Avoid conduct that could be perceived as favouritism, over-familiarity, or emotional dependency; and
Not enter into romantic or sexual relationships with former students within two years of graduation.
In this case, those boundaries were crossed when daily online communication blurred the line between teacher and friend. The later sexual relationship aggravated the breach, showing how easily a professional connection can become personal when safeguards are not observed.
These standards exist to preserve trust: trust between teacher and student, and trust between the public and the education profession.
What This Decision Means for Educational Organisations
This Decision is a reminder that breaches of professional boundaries can have serious personal and organisational consequences and sends a clear message to all education providers. Safeguarding professional boundaries requires active management, and not just good intentions. Maintaining professional boundaries isn’t just about discouraging connection, it’s about ensuring those connections stay safe, appropriate, and consistent with the trust that families place in schools.
Digital communication, remote learning, and social media have made it easier for boundaries to blur. Without clear guidance and strong organisational systems, even well-meaning staff can find themselves in risky territory. To prevent similar breaches, organisations should:
Have clear Codes of Conduct and policies around professional boundaries that set explicit expectations around communication, both in person and online;
Provide regular safeguarding and professional boundary training so that staff understand what appropriate behaviour involves;
Ensure reporting procedures are in place so concerns can be raised early and handled sensitively; and
Review and update policies regularly to stay aligned with current legislation and best practice.
How Can Safe Space Legal Help?
At Safe Space Legal, we have extensive experience working with organisations in the educational sector to strengthen their safeguarding frameworks and promote safer, more accountable environments.
Our services include:
Conducting independent investigations into allegations of misconduct, which are trauma- informed and legally compliant;
Providing expert legal advice on risk management;
Auditing and drafting safeguarding policy suites, including Codes of Conduct, complaint handling, and professional boundaries policies; and
Delivering tailored safeguarding and professional boundaries training to ensure staff understand their obligations and how to uphold them in practice.
If your organisation would like support to strengthen its safeguards and give your team confidence in managing professional boundaries, contact office@safespacelegal.com.au or call (03) 9124 7321 to organise a complementary discussion in relation to your organisation’s child safety and safeguarding needs.
Contact us for a 30-minute consultation to discuss your organisation’s safeguarding needs
Patrice Fitzgerald is the Principal Lawyer and Director of Safe Space Legal. Patrice has over 20 years of experience working in the legal sector, predominantly in safeguarding and child protection.
Patrice has extensive expertise supporting organisations to comply with their safeguarding obligations. Alongside her role at Safe Space Legal, Patrice is also a Member of the Victorian Civil & Administrative Tribunal in the Review and Regulation List (Child Welfare).