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Section 1: Developing Policies and Procedures for Child Protection

Youth serving organizations come in many shapes and sizes – public and private schools, Boys and Girls Clubs, Scouts, mentoring programs, YMCAs, after school programs, child care centers, municipal sports organizations, Big Brothers and Big Sisters, day and overnight camps, and studios and clubs for dance, arts and crafts, drama, music, acrobatics, and the martial arts to name a few. No matter how large or small, or the services they provide, all YSOs have at least one thing in common – they want to keep their children and youth safe from harm. An organization’s policies and procedures for child safety and abuse prevention are the backbone of its efforts to protect children and youth, and provide an overarching framework that should present, first and foremost, its commitment to the safety and well-being of the children and youth entrusted to its care. It is upon this foundation that all other elements will rest, and from which the safety components and strategies described throughout this report will draw their meaning and credibility.

Child protection policies must be developed with the organization’s mission and circumstances in mind. For example, an organization that provides youth mentoring may need to adopt prevention strategies for one-on-one activities between youth and staff/volunteers that would differ from those adopted for team sports activities in which most activities take place in a group. Similarly, prevention strategies for a studio with a single, storefront location will likely differ from those of a statewide agency with multiple dedicated sites and scores of programs. Well-written policies, procedures and/or guidelines provide the means for any YSO to clearly express, in a public way, a commitment to its parents, to its community and to the children and youth it serves by outlining the steps it takes to protect children and youth from sexual and other forms of abuse; the type of environment it strives to build and maintain; and the safeguards it employs to ensure that all staff, employees and volunteers are properly vetted and trained to recognize and respond to inappropriate and/or harmful behaviors. Thus, effective policies focus both on the creation and maintenance of safe, preventive environments for children and youth, as well as on the responsible management of incidents or alleged incidents of abuse.

Policies for Massachusetts YSOs should clearly identify the duties and responsibilities of all staff, reflect both Federal and Massachusetts abuse reporting laws, provide direction to employees, staff, and volunteers who wish to make a report, and define the internal mechanisms to be followed when a case of child abuse or neglect is suspected and/or being reported. When a crisis occurs, having a clearly defined and recognized set of policies and procedures will make the process of reporting go more smoothly, thus helping to reduce the anxiety and reluctance of staff, and protecting the children and youth more effectively. The figure below ¹ illustrates the values that should guide the creation of a child protection policy.

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Values that Guide a Child Protection Policy

The best interests of the child are primary

All children, girls and boys, of all abilities and backgrounds have equal rights to safety in all settings and locations.

Violence and abuse against children are never acceptable in any form, location or setting.

Children are vulnerable to violence and abuse due to their size, age, physical and psychological maturity, dependence and lack of power. While all children may be vulnerable, in some settings, some children may have a heightened risk of abuse and violence.

Violence against children has damaging and often long-lasting repercussions for children, their families and their communities.

All organizations and adults are responsible to provide safety for the children in their care.

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The Centers for Disease Control (CDC) ² also suggests that implementing a child sexual abuse prevention policy and making the changes necessary to protect youth from child sexual abuse in organizations are not easy tasks, but that organizations should take on as many individual strategies to prevent child sexual abuse as they can. They also offer several steps for organizations to take to effectively create, implement and measure their child sexual abuse prevention strategies (See Appendix 7 for more detail).

The Task Force suggests that the attitudes of leadership towards abuse prevention policies can and will have a direct effect on how the policies are viewed by the YSO as a whole – particularly if the policies are being implemented for the first time. Introducing any kind of change in an organization’s way of doing business – particularly one that is trying to effect behavioral change in its managers, staff, volunteers and clients – is more of a process than a single event, and that process takes place over time and requires buy-in from the people whom the policy affects (See more on this in the section on Implementation and Oversight). Strong leadership within the YSO that emphasizes regularly the importance of child abuse prevention can help make some of the challenges more manageable. Leadership must make the case for the policy and then either lead and coordinate the effort – or delegate it to an individual or a small internal group who will be responsible for its creation and implementation. In the latter case, it is critical that YSO leadership remains involved, visible and engaged on a regular basis to reinforce their commitment to the effort and its goals.

Development and implementation of a policy is best done as a collaborative effort. A policy will be effective only if people are aware of it, feel some sense of ownership towards it, and have the opportunity to express their views on how it will, should, or will not work. Thus, whether creating a set of child safety policies for the first time, or reviewing and updating one that already exists, input from a range of stakeholders is important to consider. Managers, front-line staff, volunteers, parents, children and youth representatives can be invited to participate as an internal “consulting team” and will have a range of experiences to offer. Consultation with local social service agencies, law enforcement, legal counsel, risk managers, faith-based groups, and other YSOs that have already enacted child safety policies can offer professional expertise and experience with policy development and implementation that can help to avoid pitfalls and move the process along more efficiently.

Once the team is formed, YSO leadership and the consulting team can use the sections of this report and the sample policies, mission statements, codes of conduct, procedural guidance and other documents provided to construct a draft document for the group to consider. There is no one size or form that is better than any other. If the “master” document gets large, YSOs can extract and consolidate the most important points into a set of “abbreviated” policies or “pocket version” policies that address specific populations like volunteers and other “front-line” staff who may be less concerned with the legal, managerial and supervisory aspects of the policies than with issues like “What is child abuse?”; “How can I recognize it?”; and “What am I supposed to do, and who am I supposed to tell if I see it?”

Once the policy is drafted, it can be sent around for internal and external review, and the consultant team can be convened to present their opinions, reactions, and suggestions. If there are differing views expressed at the consultations, document how leadership determined what would be included in the policy and why. The document can then be revised and sent to all stakeholders for review and comment. Provide a date for comment and allow enough time for people to provide them. Then review the comments and finalize the policy. Have the policy approved by the organization’s governing body and make it publicly available (e.g. by distributing it, posting it on bulletin boards, putting it online, making copies available, etc.).  Implement the policy and set a future review date. Policies should be considered “living” rather than static documents. They should be reviewed (and updated if necessary) every two to three years to see what is working, what isn’t working as expected, and what aspects might need to be strengthened. Between publication and review, think about the kinds of information and data that should be collected that will help answer these questions (See section on Analysis, Review and Self-Audit).

An effective set of abuse policies for youth-serving organizations should:

• Clearly establish leadership’s commitment to building and maintaining an environment and culture in which children and youth are safe and their best interests are primary.
• Codify the safety framework of the organization.
• Communicate to all managers, supervisors, employees, and volunteers (and have them acknowledge) their legal and ethical obligations to protect children and youth from harm, abuse and exploitation.
• Clearly identify and detail Massachusetts state laws regarding the reporting of suspected, observed or disclosed cases of child abuse and neglect to the Department of Children and Families (DCF), and provide the state-specific definitions of the types of child abuse and neglect.
  • Include step-by-step instructions with a flow chart including names, telephone numbers, the sequence of events, and the information needed, with a report form attached. Also identify the emergency, after-hours procedures for reporting (See Appendix 11 for Samples).
• Identify who in the YSO is expected/required to report and in what timeframes.
• Describe the organization’s internal reporting protocol and identify the office, person, or designated persons to whom suspicions, observations or disclosures of child abuse should be reported
  • Ensure that parents and children/youth are also aware of the protocol and know whom to contact and how.
• If appropriate, describe the various individuals, teams, organizational departments or functions dedicated to abuse prevention and investigation and define their roles and responsibilities – particularly how they may differ when an allegation of suspected abuse is made against a current or past member (or client) of the organization.
  • Clearly describe the investigation process that takes place when an allegation of child abuse or neglect is made.
• Announce and detail the existence of pre-employment/volunteer screening and background check procedures as mandatory.
• Identify the initial and follow-up training requirements for all stakeholders: those working directly with children/youth; those working indirectly with children/youth; managers, supervisors, employees, volunteers, interns, parents and, in some cases, the children/youth themselves.
  • Ensure that training includes instruction for a trauma-informed, victim-centered response to all children and youth who disclose incidents of child sexual abuse.
• Establish the procedures and standards for physical access to, and for the safety and maintenance of the organization’s buildings and grounds.
• Establish Codes of Conduct containing the guidelines and standards for interpersonal behavior, professional boundaries, and on-site and on-line interaction among staff and between staff and children/youth.
  • Outline responsibilities for monitoring behaviors and define the lines of communication and reporting when problematic behaviors are suspected, observed, or disclosed.
• Identify the tools and ongoing requirements for record-keeping, information security, measurement, self-audit, periodic assessment, and continuous improvement of child safety policies and procedures.
• Identify plans and requirements for both internal and external communication and partnerships.
• Introduce child protection organizational values and Policies and Procedures with all new staff upon hire as part of staff orientation, and review and update this information with all staff on an annual basis.

Each of these points will be discussed in more detail in the sections below. It is important to remember that a set of child safety policies and procedures sets the standard for each individual and for the YSO as a whole. Whether a YSO is evaluating an existing policy or creating a new one, a convenient Child Sexual Abuse Prevention (CSA) Evaluation Tool for Organizations ³ is provided below. The complete evaluation tool is provided in the Resources section. Also, see Appendix 7 for a listing of sample and model policies from both small and large YSOs.

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CSA PREVENTION EVALUATION TOOL FOR ORGANIZATIONS

CHILD PROTECTION POLICIES AND PROCEDURES

General Standards	Yes
a. Policy is written in a clear and easily understood way. (Evidence: Copy of policy)
b. Policy contains definitions of key terms. (e.g., Sexual Abuse; Minor)
c. Policy is publicized, openly displayed, promoted and distributed to everyone involved with an organization. (Evidence: Circulation list to show distribution)
d. States Purpose: Agency’s commitment to create safe environments for children and protect them from harm. (welfare/safety of youth is paramount; values children, youth)
e. States Principles underlying standards: (e.g., all children have the right to protection and safety; equal rights to protection from harm; to an environment free from violence, abuse, harassment, and discrimination; treat each other with respect; Everyone has a responsibility to support the care and protection of children)
f. Abuse-free, non-sexualized work environment. Zero tolerance for any form of abuse of youth, whether emotional, physical, or sexual.
g. Policy is approved and endorsed by relevant management/oversight body. (Evidence: signed statement of approval; excerpt from minutes of relevant meeting to show approval)
h. Policy specifies to whom standards apply. (e.g., mandatory for staff and volunteers)
i. Developed in collaboration with many stakeholders. (e.g., children, parents, law enforcement, legal counsel, experts, child protective services)
j. Encourages collaboration between parents and program staff to keep children safe.
k. Policy is reviewed/updated on regular basis. (e.g., every three years or whenever there is a major change in the organization or relevant legislation) (Evidence: Timetable for review)
l. Processes/mechanisms are in place to consult children and parents as part of the review of safeguarding policies and practices. Steps are taken to seek users’ views on policies and procedures and how they are working.
m. Identifies personnel with clearly defined roles and responsibilities in relation to child protection. Person(s) responsible for implementing/reviewing policy and procedures.
n. Information about where to go for help and contact details for designated contact person, local social services department, police, and emergency medical help are readily available.

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¹ Ten Steps to Creating Safe Environments for Children and Youth: A Risk Management Road Map to Prevent Violence & Abuse. Canadian Red Cross.

² Paul J, Audage NC. Preventing Child Sexual Abuse Within Youth-serving Organizations: Getting Started on Policies and Procedures. Atlanta (GA): Centers for Disease Control and Prevention, National Center for Injury Prevention and Control; 2007.

³ Wurtele, Sandy K. (2014). CSA Prevention Evaluation Tool for Organizations: Child Protection Policies and Procedures. Reproduced with author’s permission (https://www.canconferenceuofm.org/wp-content/uploads/handouts/2015-can-conference-uofm-D-6-Wurtele.pdf).