Utilize Policies and Procedures To Help Prevent Abuse

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Policies and Procedures

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.

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:

  1. Do your policies communicate a zero tolerance approach to inappropriate behaviors?
  2. Do your policies define appropriate and inappropriate behavior and contact?
  3. 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 procedures:

  1. How do you know what procedures your organization should have in place?
  2. 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:

  1. 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. Don’t make it a requirement. Instead, make it an opportunity to participate in some important work.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.

Operational Management Checklist Booklet

Use this tool to conduct your own risk assessment.

ACCESS THE CHECKLIST

Below are some operational areas that your organization should consider developing plans/procedures for if the operations are present:








For additional Loss Control guidance, please visit the Plan & Protect safety hub.

Resources

Training and Reporting to Prevent Abuse | U.S. Center for SafeSport

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