Protecting Minors on CampusTraining The University of Montana
OVERVIEW Target Audience: This training is provided for UM employees and volunteers who work in programs, campus or conference activities that engage minors under the age of 18 years. Purpose: UM is committed to creating a safe and secure environment for minors engaged in UM sponsored youth programs or events on our campusand providing them with the best possible experience when visiting our campus. To maintain such an environment and to fulfill our obligations as mandated by law, this training is provided to guide and equip all administrators, faculty, staff, students, volunteers and others working with minors the knowledge to: • Employ strategies to plan your event and provide a safe environment for youth • Recognize the different types and signs of child abuse • Properly respond to incidents involving youth and/or report known or suspected child abuse
Section I – Recommended Strategies for Planning Your Event, Activity or Camp The following will provide a framework you can use when planning or preparing to engage in program activities involving youth. You will gain an understanding of key strategies to maintain a safe environment for those who work and participate in programs that involve youth.
I. PLANNING One of the most important tools to help you protect youth participants and staff during program activities is to have an adequate plan in place. During your planning phase consider: • Screening • Risk Assessments • Training • Policies and Procedures • Conduct Requirements
I. PLANNING - SCREENINGS • The appropriate level of Background Checks must be completed PRIOR to beginning to work with minors. • Program Directors/Leaders are responsible for tracking timely completion of background checks and screenings.
I. PLANNING – RISK ASSESSMENTS When planning your program activities proactively identify potential hazards and risks. Take time to assess and mitigate all possible risks to youth participants and staff. Some of these areas may include, but are not limited to: • The nature of the activities • Schedules • Age of participants • Any hazard that can cause an injury, illness, death, or loss • Locations • Applicable insurance coverage requirements • Participant/Staff Ratios • ADA compliance
I. PLANNING – RISK ASSESSMENTS (continued) Think About… What If’s Estimate Strategize Review Think about a variety of “what if” scenarios To get a credible Measure of how Severe a risk could become. Estimate the probability and severity of each potential risk. Think in terms of worst-case possibilities. Implement specific strategies and tools that reduce or eliminate risks and share them with all program staff. Supervise and review. Make sure everyone understands their role and the plan. Review the plan periodically to determine if any changes are needed. Determine whether adequate insurance is in place for the scope of identified program activities. Consider the use of acknowledgements of risk. Seek assistance from Legal Counsel’s Office and Risk Management if needed.
I. PLANNING - TRAINING For safety procedures to be effective, staff and volunteers must know how to put them to use. In addition to completing this training, program staff and volunteers should be trained in applicable laws and regulations, as well as, program policies, procedures and protocols BEFORE the program event begins.
I. PLANNING – POLICIES AND PROCEDURES A culture of safety can help prevent many injuries and lessen the severity of those you can’t avoid. Clear and easily understandable polices and procedures that promote a positive, safe, inclusive and welcoming environment should be developed and made available to program staff. Programs should collect signed acknowledgments of understanding of policies from all staff and volunteers prior to beginning program operations. • Roles and Responsibilities • Privacy Policies • Incident and Accident Reporting • Medications storage and disbursement procedures • Emergency & Evacuation Procedures • Missing person Procedures • Clustering of Activities by age group / gender • Transportation of participants (if applicable) • Security • Check in / out procedures • ADA Compliance • Equal opportunity policies & practices Program Staff should Know, Follow and Enforce all program policies
I. PLANNING – CONDUCT REQUIREMENTS In addition to policies, program leaders should develop written conduct requirements outlining what behaviors are acceptable and unacceptable. Conduct requirements should be clear, concise and outline expectations, rules and disciplinary measures if requirements are not followed. At a minimum conduct requirements should include, but not be limited to: • Possession / Use of alcohol, tobacco, drugs • Weapons • Bulling • Hazing • Inappropriate use of imaging devices • Harmful behaviors • Dress code • Appeals Policy Conduct requirements should be available to all staff/volunteers, as well as, program participants and parent/legal guardians. Program staff/volunteers and participants must agree to abide by the established conduct requirements prior to commencing their involvement in program activities. Establish detailed disciplinary procedures for handling violation of conduct requirements, as well as, appeals procedures that at minimum describe rules of appeal, review process, timeline, and notification procedures.
SECTION II – RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE This section provides you with recommended Best Practices and Strategies to prevent child abuse and neglect. The recommendations outline in this section are primarily for the protection of participants; however, they also serve to protect the program staff and volunteers from false accusations of child abuse.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE A) SUPERVISION & RATIOS Program leaders should make certain that activities are coordinated in a way that will ensure that appropriate staff-to-participants ratios are in place at all times. It is important to understand that appropriate staff-to-participant ratios are dependent on several factors. At a minimum consider the following: The risk of activities involved The location of activities and the type of housing (if applicable) The number and age of participants The age and experience of the counselors and staff
II. RECOMMENDED STRAGETIES TO KEEP YOUTH SAFEA) SUPERVISION AND RATIOS (CONTINUED) Program leaders should make certain that activities are coordinated in a way that will ensure that appropriate staff-to-participant ratios are in place at all times. Listed below are staff-to-participant ratios recommended by the American Camp Association.
II. RECOMMENDED STRAGETIES TO KEEP YOUTH SAFEA) SUPERVISION AND RATIOS (CONTINUED) BE AWARE SCAN ADJUST MONITOR Be aware of the environment and event participants and adjust supervision accordingly. Frequently scan the area, take count of youth, ensure areas not visible are supervised by another staff member. Make sure you adjust supervision for different ages and abilities, activities, and environments. Events involving more risk or younger children require more supervision. When supervision is adjusted, staff must be aware of participants location at all times. Monitor your own behavior, as well as, the behavior of other staff and volunteers. It is important that everyone take responsibility for monitoring program activities, reporting issues, working on correcting safety concerns, and intervening if the need arises.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFEB) INTERACTIONS ONE-ON-ONE INTERACTIONS Program staff should avoid private one-on-one interactions with youth. Have another adult observer present during all interactions with youth participants (including when transportation is needed). In situations that require personal conferences, the meeting is to be conducted in view of other adults and campers. If a camper approaches you when you are alone, move quickly to an area where there are others or ask the camper to meet you somewhere else (in a public area) in a few minutes. TWO-DEEP LEADERSHIP IN VIEW OF OTHERS
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFEB) INTERACTIONS (CONTINUED) REMEMBER… Appropriate adult leadership must be present for all overnight activities; coed overnight activities-even those including parent and youth-require male and female adult leaders, one of whom is 21 years of age or older. Two adult employees or one employee and a parent of a participant, or other adult, one of whom is 21 years of age or older, should be required during all event activities. The event director is responsible for ensuring that sufficient leadership is provided for all participant activities.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFEC) SEPARATE ACCOMMODATIONS If you are hosting an overnight event, require separate accommodations for adults and participants. Youth are not to be permitted to sleep in the room of an adult other than his or her own parent or guardian. If possible, programs should have separate shower and bathroom facilities for males and females. If separate facilities are not available schedule separate times for male and female use. Likewise, youth and adults must shower at different times. For co-ed overnight, at least one adult of each sex needs to be in attendance. Adequate supervisory ratios must be in place at all times.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE D) PRIVACY Adults must respect the privacy of participants in situations such as changing clothes, taking showers, and other areas where privacy is expected, intruding only to the extent that health and safety require. Adults must protect their own privacy in similar situations. While most participants and leaders use cameras and other imaging devices responsibly, it has become very easy to invade the privacy of individuals. It is inappropriate to use any device capable of recording or transmitting visual images in shower houses, restrooms, or other areas where privacy is expected by participants. Be aware of and follow established privacy policies. Participants information must be handled in a secure and confidential manner. The amended Children’s Online Privacy Protection Act (COPPA) considers photos, videos and audio recordings that contain a child’s image or voice to be personal information. Please obtain written consent prior to the collection or use of photos. RESPECT PRIVACY USE OF DIGITAL DEVICES POLICIES PHOTOS/VIDEOS /AUDIO RECORDINGS
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFEE) SAFETY AND SECURITY BULLYING/HAZING Bullying or Hazing of any kind is strictly Prohibited. Program staff and participants are expected to conduct themselves in a manner that respects the rights of others including staff, faculty, participants and the general public APPROPRIATE ATTIRE Be aware of the dress code for your program. Ensure that all participants and staff/volunteers have appropriate attire and safety equipment for all program activities. RELEASING CAMPERS Adequate security protocols should be in place. Program participants should only be released to their parent or legal guardian or someone authorized by them, as indicated in writing. CONTROL ACCESS TO YOUTH Limit contact between youth participants and individuals not associated with the program. Monitor the comings and goings of all youth and adults who enter and leave the facility. Be particularly alert to opportunities that are presented when activities occur in public spaces. Have procedures for signing in and out.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFEF) FIELD TRIPS/TRANSPORTATION If your event involves the transportation of youth participants, all applicable laws must be observed at all times. Consider the following: RULES – Establish rules for transportation. • Authorized Drivers • Authorized Vehicles PARENTAL/GUARDIAN CONSENT - Obtain written consent from parents/guardians so as to permit program participants to partake in any trips associated with the event. ADEQUATE RATIOS – Remember to maintain appropriate staff-to-participant ratios during travel time. Observe the two deep leadership rule. VEHICLE SAFETY – Inspect vehicles to ensure they are capable of safely completing the trip and to provide the highest levels of safety. INSURANCE - Make sure evidence of proper insurance is obtained. LAWS - Observe current Child Passenger Safety Laws and Highway Safety Laws. ALTERNATIVE PLAN - Have an alternative method of transportation in case of emergency.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE G) APPROPRIATE COMMUNICATION Out-of-program Communication Contact between employees/volunteers and youth participants should be limited to sanctioned activities and programs and/or certain locations, such as activities within your organizations building. This includes contact via social media, telephone, and meetings outside of scheduled activities and official program communication.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE G) APPROPRIATE COMMUNICATION (CONTINUED) ONLINE COMMUNICATION • To help ensure that all online communication between program staff and participants remains positive and safe these channels must be public. • The “two deep” leadership approach used during in person program activities also applies to online interaction. Avoid private messages and one-on-one direct online contact including, but not limited to, text messages, e-mail, social media websites (e.g. Facebook, Twitter, etc.) chats, instant messaging (Google Messenger, AIM, etc.), or other similar messaging features. • All communication between adults and youth should take place in a public forum (e.g. the Facebook wall), or at a bare minimum, electronic communication between adults and youth should always include one or more authorized adults openly “copied” (included) on the message or message thread.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE1)REAL LIFE SCENARIOS The following slides outline scenarios that could very well take place during a youth program. After reading the scenarios, take a moment to reflect on the situations and then answer the corresponding questions. Do you consider this scenario acceptable? John (an 18 year old program staff member) takes Bill (a 17 year old program participant) on a walk alone during the program. Since John had a cell phone and could be reached at any time, he did not ask another program staff/volunteer to join them for the walk.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE1)REAL LIFE SCENARIOS (cont.) If you did not consider the scenario outlines in the previous slide to be acceptable, you are Correct. This situation is NOT considered acceptable. Program staff/volunteers must avoid private one-on-one interactions with youth and should have another adult observer present during all interactions with youth participants (including when transportation is needed). Also, contact between employees/volunteers and youth participants should be limited to sanctioned activities and programs and/or to certain locations, such as activities within your organization’s building.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE2)REAL LIFE SCENARIOS Jill is a volunteer for a mentoring program for high school students. During a regular scheduled program session, Jill was approached by Dan (a 17 year old program participant) who requested to speak with her about a private matter. Jill asked Dan to meet her at a work station that was away from others but that was still in an open area that was observable by other volunteers and participants. Do you consider this scenario acceptable?
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE2)REAL LIFE SCENARIOS If you considered the scenario outlined in the previous slide to be acceptable, you are CORRECT. One-on one interactions with youth should be avoided. In situations that require personal conferences, the meeting is to be conducted in view of other adults and campers (the meeting should be observable and interruptible). If a participant approaches you when you are alone, move quickly to an area where there are others or ask the camper to meet you somewhere else (in a public area) in a few minutes.
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE3)REAL LIFE SCENARIOS Jeff is a 19 year old student who is a volunteer at a summer day camp. He recently learned that a long-time family friend’s 16 year old daughter (Betty) was attending the camp. On the first day of camp, Jeff told Betty to let him know if she needs anything and he provided her with his personal phone number and e-mail address. Betty began texting Jeff regarding non-program related topics, such as an upcoming family gathering and how she is looking forward to her senior year of High School. Jeff and Betty begin to interact in one-on-one conversations like this on a frequent basis. Do you consider this scenario acceptable?
II. RECOMMENDED STRATEGIES TO KEEP YOUTH SAFE3)REAL LIFE SCENARIOS If you did not consider the scenario outline in the previous slide to be acceptable, you are Correct. This situation is NOT considered acceptable The “two deep” leadership approach used during in person program activities also applies to online interaction. Avoid private messages and one-on-one direct online contact including, but not limited to, text messages, e-mail, social media websites (e.g. Google Messenger, AIM, etc.), or other similar messaging features. Limit your contact with minors to professional interactions. All communications between adults and youth should take place in a public forum (e.g. Facebook wall), or at a bare minimum, electronic communication between adults and youth should always include one or more authorized adults openly “copied” (included) on the message or message thread.
III. TYPES AND SIGNS OF CHILD ABUSE The first step in helping abused or neglected youth is learning to recognize the signs of child abuse and neglect. During this section you will become familiar with the different types of child abuse and some of the common warning signs of child abuse or neglect. Remember to Stay Vigilant
III. TYPES AND SIGNS OF CHILD ABUSE Child Abuse may take several Forms, including: Physical Emotional Sexual Neglect National Child Abuse Statistics, Childhelp, http://www.childhelp.org/pages/statistics#5
III. TYPES AND SIGNS OF CHILD ABUSE DEFINITIONS CHILD OR YOUTH Any person under 18 yeas of age. §41-3-102, MCA ABUSE or NEGLECT means: • actual physical or psychological harm to a child; includes actual physical or psychological harm to a child or substantial risk of physical or psychological harm to a child by the acts or omissions of a person responsible for the child’s welfare; • Substantial risk of physical or psychological harm to a child; or • Abandonment.§41-3-102, MCA HARM “Harm” to a child’s health or welfare can occur when any person responsible for the child’s welfare: a)Inflicts or allows to be inflicted upon the child physical or psychological abuse or neglect; b) commits or allows sexual abuse or exploitation of the child; c) causes malnutrition or a failure to thrive or otherwise fails to supply the child with adequate food, clothing, shelter, education or adequate health care, though financially able to do so d) exposes or allows the child to be exposed to unreasonable risk to child health or welfare by failing to intervene or eliminate the risk; or e) abandons the child§41-3-102, MCA
III. TYPES AND SIGNS OF CHILD ABUSECHILD MOLESTATION Child Molestation is a type of child abuse. Abuse more broadly covers impairment of a child’s physical or mental welfare. Child neglectis the passive failure to nurture a child, such as through inadequate supervision. While child molestation typically occurs in family settings, it also arises in youth serving programs. Some molestation is perpetrated by children on other children rather than adults. Whether adult or child, a molester may target victims from underprivileged circumstances or who have mental impairments. Who is a “typical” child molester? • Most pedophiles are not strangers, rather they are known to, and liked by, their victims. • Can be a man or woman, married or single. • Can b a child, adolescent, or adult • Can be of any race, religious belief, and have any sexual preference • Can be a teacher, tutor, camp counselor, parent, stepparent, relative, family friend, clergy, babysitter (anyone who comes in contact with children). • Can appear charming, trustworthy, and generous
III. TYPES AND SIGNS OF CHILD ABUSECHILD MOLESTATION (cont.) Three conditions that encourage child molestation: • Access to children College Campuses offer many opportunities for adults to interact with minors in the many youth serving programs and summer camps that are provided for the community youth. Remember there may be a few of those adults who have ill willed motives. • Privacy The molester seeks opportunities to be alone with a child. Eliminate the opportunity for any one-on-one situations. • Control Child molesters are master manipulators, both with children and adults. They systematically engage in a “grooming” process to gain trust, establish secrecy, and testing the child’s reaction to increasing physical contact. The molester may make threats to the child against the child’s family members or pets. They may ‘groom’ adults to overlook or excuse their inappropriate behavior when crossing boundaries.
III. TYPES AND SIGNS OF CHILD ABUSE Often times a youth may not report abuse; therefore, it is vital that you are aware of the common signs of child abuse or neglect. While there is no single set of behaviors that is characteristic of children who have been abused and/or neglected, the U.S. Department of Health and Human Services has documented several emotional and psychological effects that are commonly associated with children who have been victimized. Listed are signs that may suddenly appear in victims of child abuse. Low Self-esteem Depression and anxiety Post-traumatic stress disorder (PTSD) Attachment difficulties Attention Disorders Eating disorders Poor peer relations Self-injurious behaviors (e.g., suicide attempts) Lower academic achievement Bruises in areas not usually bruised in normal childhood activities Please Note: The presence of a single sign is not proof that a youth has been abused, but a closer look at the situation may be warranted when these signs appear repeatedly or in combination.
IV. CHILD PROTECTION LAWS This section will briefly review some of the laws to consider when working with minors. Note: Programs are responsible for becoming familiar with and following all applicable Federal and State laws.
IV. CHILD PROTECTION LAWS A) REPORTING Mandatory Reporters:(MCA §41-3-201) health care providers, clergy, school teachers and officials, social workers, foster care and residential providers, peace officers, guardian ad litem, court appointed advocates. Permissible Reporting: Even if you are not a mandatory reporter, you may report suspected child abuse and neglect to the DPHHS, Child and Protective Services Division.
IV. CHILD PROTECTION LAWSB) SCREENING University Policy • University policy (No. 401.2) requires criminal background investigations prior to employing permanent staff members, contract administrators, contract professionals, all faculty members, individuals on Letters of Appointment, and designated temporary staff members. Permissible background checks (Best Practices) • Employment reference checks and application questions • Background checks may be requested from Montana DPHHS, Child & Family Services Division. • Instructions about how to request the background checks are located at: http://www.dphhs.mt.gov/cfsd/backgroundchecks.shtml • Montana Department of Justice Sexual Violent Offender Registry • https://app.doj.mt.gov/apps/svow/
IV. CHILD PROTECTION LAWSC) PRIVACY Children’s information must be handled with extreme care at all times. Programs must establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children. Programs collecting information related to children 13 and under must comply with the Children’s Online Privacy Protection Act (COPPA). The primary goal of the Children’s Online Privacy Protection Act (COPPA) is to give parents/guardians control over what information is collected from their children online and how such information may be used. Please Note: Never provide personally identifiable information through the University of Montana websites without an approved written consent from a parent or guardian.
V. REPORTING Programs should have clear guidance on what to do when an incident involving the safety of minors arises. Develop clear procedures and step-by-step guidance to encourage a prompt response to concerns about a youth participant’s safety or welfare. Explain and distribute procedures to all staff, volunteers, and other individuals working directly with youth. Create a process for documenting incidents and/or concerns, and storing these securely, so that confidential information remains private. Create a process for informing appropriate University officials about incidents. Make sure that emergency and parental contact information is readily available to supervisors at all times.
V. REPORTING In the event of an emergency or if you see a crime in progress on campus, immediately contact UMPD at 406-243-4000; off campus report to local law enforcement. If you are a mandatory reporter and have reason to believe that a child is a victim of abuse, report it immediately to the Department of Public Health and Human Services. One of the four methods below can be used to report to MT DPHHS. Telephone: 1-(866) 820-5437 Regional office: 1-(406)523-4100 Fax: 1-(406)523-4150 On-line: www.dphhs.mt.gov
V. REPORTING If youth inform you of abuse or you suspect child abuse: • Do • Believe the youth • Provide a safe environment • Tell the youth participant it was • not his/her fault • Listen carefully • Document the exact quotes • Be supportive, not judgmental • Know your limits • Tell the truth and make no • promises • Report the abuse to the Montana • Department of Health and Human • Services • Do Not • Investigate to determine • if the reported abuse is true • Ask leading questions • (e.g., “That man touched you, • didn’t he?”) • Make promises • Notify the accused individual
V. REPORTING - SCENARIOS While at the program, a youth participant informs you that she “thinks” one of her roommates was physically abused by someone during the program. She did not have any additional information and indicated that she was not “entirely sure” that anything harmful happened. Since you cannot confirm the report of the abuse is true and you do not have complete information, should you wait until you have enough evidence or information?
V. REPORTING - SCENARIOS If you answered “NO” to the question in the previous slide, you are CORRECT. If someone reports a case of known or suspected child abuse to you, TAKE IMMEDIATE ACTION. Remove child from immediate harm and report the incident even if you cannot confirm the report of abuse is true or even if all of the requested information is not available at the time of the report.
CONCLUSION Thank you for participating in this very important training. The University of Montana is committed to creating a safe and secure environment for all minors engaged in any UM and UM-Affiliated youth programs or events. We hope this course has provided you with the necessary information to carry out this commitment on behalf of the institution, including: • Strategies for providing a safe environment for youth • Recognizing different types and signs of child abuse • Properly responding to incidents involving youth and/or reporting known or suspected child abuse