Circles of Safety: Awareness to Action
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Child Sexual Abuse (CSA) Prevention Evaluation Tool for Organizations 1
| CSA Prevention Evaluation Tool for Organizations |
| Child Protection Policy & Procedures |
| Sandy K. Wurtele, Ph.D. © 2014 |
| 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 role 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. | |
| Standard 1: Safe Screening and Hiring Practices | |
| a. There are policies and procedures for recruiting personnel and volunteers and assessing their suitability to work with children. (Evidence: Copy of Recruitment Policy & Procedure) | |
| b. Agency has a standard written application form. (Evidence: application form) | |
| c. Criteria for acceptance/rejection have been identified. Lists non-negotiable minimum standards for rejection/which offenses automatically disqualify applicants. (e.g., history of CSA? violence? substance-related problems? use of child pornography? major mental disorders? prior inpatient psychiatric treatment?) | |
| d. Person(s) responsible for screening, interviewing, reference checks, hiring, etc. have been identified. | |
| e. Policies and processes for screening and selection are stated and systematically followed. | |
| f. All adults who have the opportunity for regular contact with children, or who are in positions of trust, are screened. | |
| g. Applicant signs a permission form for contacting at least 2 personal references and performing a criminal background check. | |
| h. Applicants are asked to disclose previous criminal histories of sexual offenses, violence against youth, and other criminal offenses. All candidates are asked if there has ever been any investigation or action taken against them for any ethical, moral, legal, or malpractice action. Have you ever been censured, disciplined, dismissed, expelled from, been put on probation, or been requested to resign or withdraw from any professional school, internship, volunteer program, employment, or training program? | |
| i. Reference checks are conducted, with all work/volunteer experience carefully verified. | |
| j. Verbal contact is made not only with the people listed on the application, but also people mentioned by those references. | |
| k. Criminal background checks are conducted with fingerprinting if applicable, and Sex Offender Registries are checked. | |
| l. Agency keeps the results of criminal background checks confidential (secure storage location, limited access to files). | |
| m. Informal Internet searches are conducted as a way to find additional relevant information about an applicant. | |
| n. Code of Conduct is shared with all applicants. | |
| o. Applicants’ home environments are assessed (for mentoring programs where youth meet with mentors at their homes) | |
| p. No contact with youth is allowed until applicant has been approved. | |
| q. Agency lets applicants know (verbally and in writing) that the program’s priority is the safety and well-being of children. | |
| r. There is an induction process for all staff and volunteers which includes familiarization with the child protection policy and procedures. | |
| Standard 2: Code of Conduct | |
| a. Contains input from constituents: Staff, parents, youth are consulted in developing codes of behavior. Specifies disrespectful/unsafe/harassing behaviors (i.e., makes it clear that discriminatory behavior or language in relation to any of the following is not acceptable: race, culture, age, gender, disability, religion, sexual orientation, or political views). Evidence: Code of Conduct specifically prohibits certain behaviors (hitting or physically assaulting children; having intimate, romantic, or sexual relationships with children; showing porn to children; exploiting children to meet emotional or sexual needs; asking youth to keep secrets) | |
| b. Written Code of Conduct, which provides clear guidance on acceptable/expected standards of behavior of adults toward children. (Evidence: Code of Conduct for adult-child behavior and for child-child behavior) | |
| c. Agency lists ethical conduct/appropriate behaviors (behaviors to be encouraged). (Evidence: Guidance on acceptable/appropriate behaviors) | |
| d. Agency lists unethical conduct/inappropriate behaviors or boundary violations. | |
| e. Clear statement of the need to set and maintain professional/appropriate boundaries with youth. | |
| f. Policy addresses one-on-one interactions with youth (e.g., being alone with a child in an area that cannot be seen or observed by other adults; taking children to your own home, to restaurants, or traveling alone with a child in a car) | |
| g. If applicable, policy addresses high-risk situations (e.g., bathing, changing, bathroom activities, sleep-overs) | |
| h. Policy addresses out-of-program contact restrictions (e.g., socializing with youth outside of agency-sponsored activities). | |
| i. Addresses discipline practices (that do not involve physical punishment or any other form of degrading or humiliating treatment). States responsibility of adults and children to treat one another with dignity and respect. | |
| j. Adequate adult/child ratios. Clear guidelines that specify under what circumstances–if any–staff are allowed to be alone with a child. | |
| k. Describes responsible use of the Internet | |
| l. Addresses taking photographs/videos of youth (including mobile phones with cameras) | |
| m. Provides guidelines on contacting/communicating with youth via technology (use of social media, emails, mobile phones) | |
| n. Guidelines regarding communication/language with children. (e.g., self-disclosure; personal/intimate topics; secrecy; sexual topics), and conduct (inappropriate gift giving) | |
| o. Prohibits the display or distribution of sexually suggestive or pornographic material | |
| p. Policy regarding transporting students/youth. | |
| q. Policy outlaws use, possession, or distribution of illegal or unauthorized drugs. Furnishing or encouraging minors to use, possess or unlawfully distribute alcohol, tobacco, illegal or unauthorized drugs. | |
| r. Code contains guidelines relating to adult-child physical contact. | |
| s. Code outlines Sanctions for Breaching: (e.g., Contains a statement “I have read and understand the Policy and agree to be bound by the provisions contained within. I understand that violations involving sexual relations with a student, sexual abuse of a student, or communication with a student of a sexual or romantic nature, shall result in dismissal, prompt notification of law enforcement and social services if required by state law, and in the case of an employee or volunteer licensed by a Board of Professional Licensing, the initiation of a complaint against the license.”) | |
| t. Applicant signs/dates statement “I agree to abide by/adhere to Code of Conduct”. | |
| u. Arrangements are in place to monitor compliance with child protection policies and procedures. | |
| Standard 3: Implementation and Monitoring a. Written plan showing what steps will be taken to keep children safe, who is responsible for implementing these measures, and when/how often monitoring will occur. (Evidence: Copy of the Child Protection Plan) | |
| b. Defines roles and responsibilities for implementing Plan and for monitoring both implementation and interactions between youth and adults. | |
| c. Audit procedures are in place for monitoring the extent to which policies and procedures and all training programs are being implemented (method of demonstrating accountability and transparency). | |
| d. Documentation that monitoring has occurred (using written records). | |
| e. Uses formal supervision including periodic evaluations (e.g., annual appraisal of staff, review of volunteers) | |
| f. Uses informal supervision (random observations) | |
| g. Institutional climate encourages professionals and volunteers to keep their eyes open for potentially problematic adult-youth interactions and share their concerns with and confront a colleague about those concerns. | |
| h. Agency provides therapeutic supervision (i.e., encourage and support the recognition of personal needs like loneliness and how they may be affecting professional relationships; acknowledging emotional/sexual feelings toward clients; climate of trust in which staff feel free to disclose feelings and experiences to their supervisors) | |
| i. Agency provides multiple opportunities for youth and staff to give/obtain feedback and seek support (e.g., peer mentoring) | |
| j. All incidents, allegations of abuse and complaints are recorded and monitored. (Evidence: Summary of number of incidents of abuse and number of complaints) | |
| Standard 4: Ensuring Safe Environments | |
| a. Ensure spaces are open and visible (windows in doors; “no-closed door” policy) | |
| b. Provide youth with privacy when toileting, showering, changing clothes. | |
| c. Install surveillance cameras in difficult-to-supervise public areas. | |
| d. Parents are allowed/encouraged to visit the agency unannounced at any time | |
| e. Policies in place for field trips/off-site activities. | |
| f. Transportation policies established and monitored. | |
| g. Zero-tolerance/abuse-free/anti-bullying policies are advertised throughout environment. Youth safety is priority. | |
| h. Child protection policy is openly displayed and available to everyone, and is included in staff handbooks along with student and parent handbooks. | |
| i. Children are aware of their right to be safe from abuse and who to speak to if they have worries or concerns. | |
| j. Agency creates a climate that encourages guardians/staff to question concerning or confusing behaviors or practices. | |
| Standard 5: Investigating & Reporting Concerns, Disclosures, Allegations | |
| a. Purpose: Provides clear guidance on what to do when a child protection concern arises. | |
| b. Goal: to respond quickly and appropriately to 1) inappropriate or harmful behavior, 2) violations of any policies, and 3) allegations and suspicions of harassment and sexual misconduct. | |
| c. All employees and adult volunteers are aware of their obligation to report suspected abuse or neglect. (e.g., Priests are clear that the Seal of Confession does not apply to disclosures of abuse or abusive behavior.) | |
| d. All employees and adult volunteers are trained in recognizing obvious signs and symptoms of abuse but also more subtle signs (crossing boundaries; grooming behaviors) | |
| e. All adults are trained in how to respond to a child who discloses abuse or questionable behavior. (List of do’s and don’ts) | |
| f. Staff, parents, and youth know how to report concerns, suspicions, and allegations about unacceptable behavior. | |
| g. Youth have opportunities to report/describe concerning behavior directly and indirectly (e.g., a suggestion box to make complaints). Children are provided with information on where to go to for help and advice in relation to abuse, harassment and bullying. (Evidence: Copies of information for children about sources of support) | |
| h. Clear written procedures provide step-by-step guidance on what action to take if there are concerns, allegations, suspicions, or disclosures of abuse (historic or current). | |
| i. There is a designated person/person(s)/officer (Designated Officer and Deputy Officer if possible) (key point of contact) with clearly defined role and responsibilities for receiving complaints, reports, suspicions, or concerns. | |
| j. Chain of Reporting clearly described. Includes Designated Officer passes information on to Civil authorities. Contact details for local social services and police are included. (Evidence: Flow chart) | |
| k. Designated Officer consults with Child Protective Services/Law Enforcement about all allegations/disclosures. | |
| l. Process for recording all incidents, allegations, concerns, suspicions and referrals and storing these securely and maintaining confidentiality. (Evidence: Child Protection Recording Form; General Incident Reporting Form) | |
| m. Process for dealing with complaints made by parents and children about unacceptable and/or abusive behavior, with clear time tables for resolving the complaint. | |
| n. There is guidance on confidentiality and information-sharing which makes clear that the protection of the child is the most important consideration. | |
| o. Clearly stated guidelines for conducting an internal evaluation of complaint (of limited scope). Delineates what behaviors the agency will respond to internally and what behaviors require reporting to authorities. | |
| p. Maintain Records: Every referral should be documented, and a file should include a log of actions, events and information received. Any information/observations in connection with the case should be documented and included in the personnel file. | |
| q. Identifies who has responsibility for contacting the family of alleged victim and describes if, how, when, and by whom all families are notified. | |
| r. Provides guidance on how to respond to a child who is suspected to have been abused. | |
| s. Arrangements for providing supervision and support to staff and volunteers during and following an incident or allegation. Provides information and support to individuals both during and following an incident or allegation of abuse. Provides referrals, reimbursement for counseling, restorative justice, a list of professionals and organizations that provide assistance. (Evidence: List of contacts for advice, information, therapy) | |
| t. Clear guidance for responding to media/press. | |
| u. Clear plan for making public apologies. | |
| Standard 6: Training/Educational Programs | |
| a. Agency has developed and implemented educational programs specifically designed for youth, parents, professionals in training, and staff/administrators and volunteers who have significant contact with children. (Evidence: Copy of training plans/programs) | |
| b. All groups are educated about all forms of child maltreatment and in-depth coverage on sexual exploitation (causes, signs and symptoms, debunk myths about offenders, consequences of abuse, grooming behavior) | |
| c. Training includes discussion of need for and guidance in how to establish and maintain professional boundaries with youth. (Almost all serious ethical infractions emerge from a context of escalating boundary violations.) | |
| d. Training of professionals includes discussion of how personal problems, needs, deficits, can result in over-involvement (boundary violations) with needy youth. Acknowledge power differential between adults and youth. | |
| e. Provides guidance in spelling out/setting boundaries and limits with youth. Trainees have opportunities to discuss and role play risky situations. | |
| f. Discussions about how sexual misconduct can have its beginnings in good intentions (need to save a child from pain, risk of taking on the role of various or parent surrogate), easy to cross boundaries. Help trainees recognize ethical conflicts and provide practice in responding to sexual behaviors of youth. | |
| g. Opportunities for careful self-examination/training in recognizing when personal needs or unresolved problems are affecting work (e.g., addictions, pressures of work/home, loneliness, need for physical contact, for belonging, adoration, connecting) | |
| h. Recognizing the rationalizations/cognitive distortions adults use to construe deepening involvement as something other than sexual misconduct (e.g., good for the child). Victim sensitization approaches can make it difficult for trainees to deny the harmful effects that sexual relationships have on clients/mentees. | |
| i. Provide candid testimonials from respected faculty/administrators who have encountered strong (sexual) feelings for their clients (serve as models for how to engage in an open, professional discussion of sexual issues) | |
| j. Discuss the need to prevent sexual feelings from evolving into ethical infractions. (Draw the line between feelings and actions) | |
| k. Help staff recognize and intervene when they observe a co-worker crossing professional boundaries (e.g., taking a student to lunch or dinner, giving gifts). | |
| l. All groups are informed about duty to report sexual misconduct. | |
| m. Training includes a means of confirming participation and completion. | |
| n. Training is given before interactions with children begin, and is repeated every _ years. |
Contact information: Sandy K. Wurtele, Ph.D.
University of Colorado, Colorado Springs
Phone: (719) 255-4150; E-mail: swurtele@uccs.edu
OTHER COMPREHENSIVE RESOURCES
“Preventing Child Sexual Abuse Resources” (2020). The National Sexual Violence Resource Center. This collection of online resources provides information and tools for caretakers, organizations and communities assuming the responsibility of preventing child sexual abuse. (https://www.nsvrc.org/preventing-child-sexual-abuse-resources).
“Safe-Child Standards Resource Bank” (2013). New Jersey Department of Children and Families.(http://www.nj.gov/dcf/about/divisions/dfcp/safe.child.standards.NJ.Resource.Bank.pdf).
1 Reproduced in this Report with Author’s permission
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