Policies and Procedures To Help Prevent Abuse
Why are Abuse Prevention Policies and Procedures Necessary?
Policies inform your staff, volunteers, participants, parents and the community on what your organization will or will not do. Procedures map out how your organization will accomplish what the organizational policies commit to. Policies and procedures are critical because they establish the boundary lines for what are considered appropriate behaviors and what are considered inappropriate behaviors.
They:
- Control ACCESS to those in your care;
- Reduce PRIVACY with potential victims; and
- Limit CONTROL an offender might seek. (i.e., a policy that forbids gift-giving in one-on-one situations.)
This makes it easier for everyone within your organization to know what inappropriate behavior looks like and how and when to tell someone else about it.
It is important to note that policies and procedures are not written documents to be placed on a shelf and forgotten about. They are the guiding principles and standards defining how your organization will adequately address the prevention of abuse within your organization. They are living documents that define the culture of your organization and ultimately, they will be what your organization is held accountable for. One could argue that it is better to have nothing in writing at all, rather than not follow what your organization already has in writing.
Establishing a Zero Tolerance Policy
Perhaps the single most important policy within your abuse prevention program is your organizational zero tolerance policy. This is because the zero tolerance policy sets the tone for the entire organization and is the foundation on which all other policies and procedures are built. A clearly written and communicated zero tolerance policy lets everyone (including offenders) know that:
- Your organization takes participant protection seriously;
- Inappropriate behaviors are not tolerated within your organization; and
- Your organization will investigate and cooperate with law enforcement officials when responding to allegations.
Below is a quick check for how your organizational policies and procedures should look:
- Do your policies communicate a zero tolerance approach to inappropriate behaviors?
- Do your policies define appropriate and inappropriate behavior and contact?
- Do your policies communicate a strong commitment to responding to any suspicion and/or allegation of abuse?
If you answered “No” to any (or all) of these questions, you might want to consider revising your existing organizational policies and procedures.
Using Risk Assessment to Develop Abuse Prevention Procedures
How do you know what procedures your organization should have in place? Who is answering that question?
The answers to these questions are important to the overall success of your abuse prevention program. One of the best ways to answer these questions is to perform a thorough risk assessment of your organizational operations. Here are some tips to help you conduct an effective risk assessment:
- Ensure there is support from your board and leadership. This means that a directive should be published to your organization from the very highest level of leadership so that everyone knows how important this is and that their participation is required for its success.
- Don’t handle it alone. There is no possible way that one person can know everything there is to know about every operation and building in your organization. That’s why you need a risk assessment team. Your risk assessment team needs to consist of stakeholders that have a vested interest in the success of your organization as well as positions that can make changes accordingly. Risk assessment teams work best when comprised of mid and high-level management as well as people who work directly in the operational area that is being assessed. These members can rotate on and off the team as the areas of assessment change.
- Consider using external partners. Sometimes people can become blind to uncontrolled exposures and safety issues when working in a particular operation daily. That’s why a fresh set of eyes and perspective can really help when considering risks not previously recognized. Consider using a consultant or ask your insurance agent/carrier for help with this.
- Document and communicate your findings. Often in the risk management/legal world, if it didn’t get written down, it didn’t happen. Your due diligence in taking the steps to identify risks and controls for them can go a long way in demonstrating your organizational commitment to participant safety. Be proud of your efforts and communicate what you have done to make your organization safer.
- Prioritize risks through a risk assessment matrix. Once you have identified the risk exposures that are present with the change in operations, it is a good idea to grade the risks and prioritize them so that you can develop controls from the highest priority to the lowest.
- Use a hierarchy of controls. Did you know that some controls are better than others? Using a hierarchy helps to provide a systematic approach to eliminate, reduce or control the risks of different hazards. Each step is considered less effective than the one before it. It is not unusual to combine several steps to achieve an acceptable risk. The types of hazards, the severity of the hazards and the risks the hazards pose should all be considered in determining methods of hazard elimination or control.
Beginning with a risk assessment presents a structured approach to addressing the risks associated with your organizational operations. It is important to include members of your internal team in your risk assessment to benefit from other perspectives and experience/knowledge. This also helps to create “buy-in” from all staff and volunteer members.
Risk assessments should include both table-top discussions of potential risks and physical walkthroughs of the facility to identify physical risks. Examples of risks for consideration include:
Physical Risks
- Slip/Trip/Fall hazards
- Securement of furniture and other heavy items that could fall over.
- Securement of areas of the building not in use.
- Isolated areas not visible to staff
- Increased sanitation of play areas and surfaces following CDC standards.
- Electrical safety
- Crisis response plan in place
- Bathroom procedures
- Safe food handling measures; consideration of food allergies
- Maintaining building emergency egress routes
- Medication procedures
- Maintain proper child-to-staff ratios and supervise children at all times.
Tabletop Discussion
- Compliance with local/state health codes
- Prioritization of children of healthcare workers
- Adherence to state and federal mandates
- Adequate training of all new staff/volunteers and training of staff/volunteers in new roles
- Parent pick-up/drop-off procedures
- Physical security vulnerability assessment
- Proper screening of new staff and volunteers – Careful consideration of staff/volunteers in identified “at-risk” people.
- Appropriate age grouping
- Third-party risk transfer measures if needed
- Sick child response protocols and isolation procedures. Infectious disease safe practices and child screenings in place.
Below are some operational areas that your organization should consider developing plans/procedures for if the operations are present:
SAMPLE Local Field Trips
The following is a model local travel policy provided to assist organizations in developing their own policies. Any policy developed by an organization should include the mandatory components.
Mandatory Components
Covered organizations must include components a and b. Local travel consists of travel to training, practice and competition that occurs locally and does not include coordinated overnight stay(s).- Application. This policy shall apply to:
- Adult members who have regular contact with amateur athletes who are minors;
- Any adult authorized by a covered organization to have regular contact with or authority over an amateur athlete who is a minor; and
- Adult staff and board members at a covered organization. (Collectively “applicable adult” for the purposes of this policy.)
- Transportation. An applicable adult who is not also acting as a legal guardian shall not ride in a vehicle alone with an unrelated minor athlete, absent emergency circumstances, and must have at least two minor athletes or another adult present at all times unless otherwise agreed to in writing by the minor athlete’s parent/legal guardian in advance of each local travel.
- Application. This policy shall apply to:
Recommended Components
Covered organizations may include the following components:- Shared or carpool travel arrangement. We encourage parents/legal guardians to pick up their minor athlete first and drop off their minor athlete last in any shared or carpool travel arrangement.
- Parents/Legal guardians receive education concerning child abuse prevention before providing consent for their minor athlete to travel alone with an applicable adult who is subject to these policies.
SAMPLE Overnight Trips
The following is a model travel policy, provided to assist covered organizations in developing their own policies. Any policy developed by a covered organization must include the mandatory components. If a covered organization does not create a team travel policy, the mandatory components will become the default team travel policy for that organization.
Mandatory Components
Covered organizations must include components a through d. Team travel is travel to a competition or other team activity that the organization plans and supervises.- Application. This policy shall apply to:
- Adult members who have regular contact with amateur athletes who are minors;
- Any adult authorized by a covered organization to have regular contact with or authority over an amateur athlete who is a minor; and
- Adult staff and/or board members at a covered organization. (Collectively “applicable adult” for the purposes of this policy.)
- Team/Competition travel. When only one applicable adult and one minor athlete travel to a competition, the minor athlete must have his/her legal guardian’s written permission in advance and for each competition to travel alone with said applicable adult.
- Hotel rooms. Applicable adults shall not share a hotel room or other sleeping arrangement with a minor athlete (unless the applicable adult is the legal guardian, sibling or is otherwise related to the minor athlete). However, a parent/legal guardian may consent to such an arrangement in advance and in writing. Furthermore, a parent/legal guardian may consent in advance and in writing to the minor athlete sharing a hotel room or other sleeping arrangement with an adult athlete.
- Meetings shall be conducted consistent with the organization’s policy for one-on-one interactions (i.e., any such meeting shall be observable and interruptible).
- Application. This policy shall apply to:
Recommended Components
Covered organizations may include the following components:- Team travel policies must be signed and agreed to by all minor athletes, parents, and applicable adults traveling with the organization.
- Applicable adults who travel with the organization must successfully pass a criminal background check and other screening requirements consistent with the organization’s policies.
- During team travel, when doing room checks, attending team meetings and/or other activities, two-deep leadership (two applicable adults should be present) and observable and interruptible environments should be maintained.
- Meetings should not be conducted in a hotel room.
- Parents/legal guardians receive education concerning child abuse prevention before providing consent for their minor athlete to travel alone with an applicable adult who is subject to these policies.
SAMPLE Bathroom Procedures
The following is a model locker room and changing area policy provided to assist covered organizations in developing their own policies. Any policy developed by a covered organization must include the mandatory components. If a covered organization does not create a locker room and changing area policy, the mandatory components will become the default policy for that organization.
Mandatory Components
Covered organizations must include components a through f.- Application. This policy shall apply to:
- Adult members at a facility that is either partially or fully under the jurisdiction of a covered organization;
- Adult members who have regular contact with amateur athletes who are minors;
- Any adult authorized by a covered organization to have regular contact with or authority over an amateur athlete who is a minor; and
- Adult staff and board members of a covered organization. (Collectively “applicable adult” for purposes of this policy.)
- Non-exclusive facility. If our organization uses a facility not fully under our jurisdiction (for, e.g., training or competition or similar events) and the facility is used by multiple constituents, applicable adults in categories 1 through 4 are nonetheless required to adhere to the rules set forth herein.
- Use of recording devices. Use of any device’s (including a cell phone’s) recording capabilities, including voice recording, still cameras and video cameras in locker rooms, changing areas, or similar spaces at a facility under our organization’s jurisdiction is prohibited. Exceptions may be made for media and championship celebrations, provided that such exceptions are approved by the covered organization or the LAO and two or more applicable adults are present.
- Undress. Under no circumstances shall an unrelated applicable adult at a facility under our organization’s jurisdiction intentionally expose his or her breasts, buttocks, groin or genitals to a minor athlete.
- One-on-one interactions
- Except for athletes on the same team, at no time are unrelated applicable adults permitted to be alone with a minor athlete in a locker room or changing area when at a facility under our partial or full jurisdiction, except under emergency circumstances.
- If our organization is using a facility that only has a single locker room or changing area, we will designate separate times for use by applicable adults, if any.
- Except for athletes on the same team, at no time are unrelated applicable adults permitted to be alone with a minor athlete in a locker room or changing area when at a facility under our partial or full jurisdiction, except under emergency circumstances.
- Monitoring our organization regularly and randomly monitors the use of locker rooms and changing areas at facilities under our jurisdiction to ensure compliance with these policies.
- Application. This policy shall apply to:
Recommended Components
Covered organizations may include the following components:- Under no circumstances shall an unrelated applicable adult at a facility under our organization’s jurisdiction expose his or her breasts, buttocks, groin or genitals to a minor athlete.
- To minimize the risk of bullying and hazing, our organization uses locker room monitors to ensure that minor athletes are not left unsupervised in locker rooms and changing areas.
- Applicable adults make every effort to recognize when a minor athlete goes to the locker room or changing area during practice and competition and, if they do not return in a timely fashion, will check on the minor athlete’s whereabouts.
- We discourage parents from entering locker rooms and changing areas unless it is truly necessary. In those instances, it should only be a same-sex parent when other minor athletes are changing in the same locker room or changing area. If this is necessary, parents should let a coach or administrator know about this in advance.
SAMPLE 1-on-1 Procedures
The following is a model locker room and changing area policy provided to assist covered organizations in developing their own policies. Any policy developed by a covered organization must include the mandatory components. If a covered organization does not create a locker room and changing area policy, the mandatory components will become the default policy for that organization.
Mandatory Components
Covered organizations must include components a through e.- Application. This policy shall apply to:
- Adult members at a facility that is either partially or fully under the jurisdiction of a covered organization;
- Adult members who have regular contact with amateur athletes who are minors;
- Any adult authorized by a covered organization to have regular contact with or authority over an amateur athlete who is a minor; and
- Adult staff and board members of a covered organization. (Collectively “applicable adult” for the purposes of this policy.)
- Observable and interruptible.
- One-on-one interactions between a minor athlete and an applicable adult (who is not the minor’s legal guardian) at a facility partially or fully under our jurisdiction are permitted if they occur at an observable and interruptible distance by another adult.
- One-on-one interactions between minor athletes and an applicable adult (who is not the minor’s legal guardian) at a facility partially or fully under our jurisdiction are prohibited, except in the circumstances described in subpart d of this section and under emergency circumstances.
- Meetings
- Meetings between applicable adults and minor athletes at a facility partially or fully under our jurisdiction may only occur if another adult is present, except under emergency circumstances. Such meetings must occur where interactions can be easily observed and at an interruptible distance from another adult.
- If a one-on-one meeting takes place in an office at a facility partially or fully under our jurisdiction, the door to the office must remain unlocked and open. If available, it will occur in an office that has windows, with the windows, blinds and/or curtains remaining open during the meeting.
- Meetings with mental health care professionals and health care providers If a mental health care professional and/or health care provider meets with minor athletes at a facility partially or fully under our jurisdiction, a closed-door meeting may be permitted to protect patient privacy provided that:
- the door remains unlocked;
- Another adult is present at the facility;
- The other adult is advised that a closed-door meeting is occurring; and
- Written legal guardian consent is obtained in advance by the mental health care professional and/or health care provider, with a copy provided to our organization.
- Individual training sessions. Individual training sessions between applicable adults and minor athletes are permitted at a facility partially or fully under our jurisdiction if the training session is observable and interruptible by another adult. It is the responsibility of the applicable adult to obtain the written permission of the minor’s legal guardian in advance of the individual training session if the individual training session is not observable and interruptible by another adult. Permission for individual training sessions must be obtained at least every six months. Parents, guardians and other caretakers must be allowed to observe the training session.
Recommended Components
Covered organizations may include the following components:- Monitoring. When one-on-one interactions between applicable adults and minor athletes occur at a facility partially or fully under our jurisdiction, applicable adults will monitor these interactions. Monitoring includes knowing that the one-on-one interaction is occurring, the approximate planned duration of the interaction, and randomly dropping in on the one-on-one.
- Out-of-program contacts. Applicable adults are prohibited from interacting one-on-one with unrelated minor athletes in settings outside of the program that are not observable and interruptible (including, but not limited to, one’s home and individual transportation), unless parent/legal guardian consent is provided for each out-of-program contact. Nonetheless, such arrangements are strongly discouraged.
- Application. This policy shall apply to:
SAMPLE Parent Pick-up/Drop-off Procedures
Drop-off Time
Checking in and out must be done daily for security and bookkeeping purposes. Licensing requirements mandate that children are signed in and out of the center each day.
Arrival and departure times are the very busiest hours of the day. For safety purposes, please hold your child’s hand in the parking lot and do not allow them to run or move away from you in the hallways. Do not enter the playground using the front or rear playground gates to pick up or drop off your child.
We ask that all children are dropped off at the center by 10:00 a.m.
- To better assist us with staffing needs and lunch counts, you must call in by 9:00 a.m. if your child will be arriving after the 10:00 a.m. drop-off time.
- Please note that from 11:30 a.m. and 2:00 p.m., children are preparing for naptime and resting. Dropping your child off during this time is strongly discouraged. This not only disrupts other children who are trying to rest, but it may also upset your own child if they have to lie down for a nap as soon as they arrive.
Door Codes
Some of our centers have locked doors that require a code to enter. Each person on a child’s pick-up/drop-off list is given a security code at the time of enrollment. There is a note posted by the keypad with specific instructions on how to enter the code. There is also a call button to notify someone in the office if you are having difficulty with this process. Visitors or anyone without a door code may use the call button to speak with someone in the front office. They will have to be given approval and buzzed into the building. The phone number to the center is also posted outside in case there are any issues reaching someone in the center with the call button. We are working diligently to get this feature added to all of our centers.
Clock In/Out Keypad
Upon entering or exiting the building, parents/guardians must check-in/out by entering their code on the keypad that is located near the front entrance. This keypad is attached to our childcare computer operating system.
It is important that each person uses their own assigned code. Sharing codes is strictly forbidden. Also, please do not allow your child to operate any of the keypads, as this will allow us to better monitor the proper use of the systems so that there are fewer problems and maintenance issues.
Physically Escorting In/Out
It is very important for security, policy and licensing regulations that all children are always with an adult. After children have been checked-in, it is mandatory that the parent/guardian physically escorts each child to their classroom and properly transfers care to their teacher. Likewise, checking-out any child requires that a parent/guardian physically escorts each child out once care has transferred back to that authorized person.
Photo IDs and Pick-Up List
Anyone picking up a child will be asked for a photo ID until that adult becomes familiar to the staff. If there is a change or substitution in staff and they are not familiar with a parent/guardian, they are required to ask for a photo ID.
Individuals taking children from the classroom must be at least 18 years of age.
A safe, functioning car or booster, appropriate for the child’s age must be in every vehicle a child is leaving our center in. We are mandated by the state to report to DHS or law enforcement officials if we believe a child is being driven around without proper safety restraints.
If a parent needs to authorize a person who is not on the pick-up list to temporarily pick up their child, advanced notice must be given in writing and will be approved at the director’s discretion. If there is an emergency and a note has not been left, someone on the list of contacts must call and speak with the office. They will be asked to verify their identity by answering questions about the child. It is then at the director’s discretion to confirm the information and allow the temporary guardian to pick up the child. A photocopy of their photo ID will be made.
If at any time during the program year, the parent wishes to change who is on their pick-up list, they may do so by coming to the center and changing the information in their child’s file. For safety reasons, we request that these changes are kept to a minimum.
Late Pick-Up
Children must be picked up no later than 6:00pm. If a child is still in the center after closing time, a late fee of $1.00 per minute per child will be charged to your account. Time is always determined by the center’s clock. Excessive violation of this policy may lead to your child being dropped from the program.
If a child has not been picked up at closing time and the center has not been contacted regarding the parent/guardian’s delay then the following procedures will be followed:
- Parent/Guardian will be called on their personal phone. If we are unable to contact you on your personal phone, we will attempt to contact you through your place of employment.
- If we are still unable to reach you, the emergency contact person listed on your application will be notified to pick up the child.
- At 30 minutes past the closing hour, if no contact has been made by parents or someone authorized to act on the child’s behalf, DHS or local law enforcement will be contacted.
- When a parent/guardian fails to contact the center regarding delays in picking up their children, it is considered neglect and is something that we do not take lightly.
Abuse Prevention: Plan. Protect. Respond.
Learn practical ways to help stop abuse in your community.
Resources
Training and Reporting to Prevent Abuse | U.S. Center for SafeSport
Mandatory Components
Covered organizations must include components a through d.
Recommended Components
Covered organizations may include the following components: