[NFBOH-Cleveland] Youth Program Participant Protection Policy - affiliate template

[Richard Payne]

Dear leaders and members,

You will find attached and in the body of this message the Youth Program
Participant Protection Policy which was sent to us from the national and
adopted by the state board of directors. 

If you have any questions please contact me or the national president off
list.

	National Federation of the Blind of [AFFILIATE] Youth Program
Participant Protection Policy 

Purpose
The National Federation of the Blind (NFB) understands the importance of
protecting all individuals especially minors that participate in programs
controlled by the national organization or state affiliate. This includes
any program directly managed by a Federation employee or by a Federation
leader with authorization to commit resources. These programs may take place
at a variety of locations utilized by the program. This policy affirms our
commitment to taking the necessary steps to provide a safe and secure
environment for program participants. 

Definitions
Youth program participants (participants) - minors seventeen years of age or
younger, and other vulnerable individuals (as defined by relevant laws and
regulations) who participate in our programs and events. 
Program workers (workers) - volunteers (members and non-members), employees,
and contractors who are directed by the program coordinator to interact with
our youth program participants.
Program coordinator - the affiliate staff lead or designated Federation
leader who is responsible for the oversight and coordination of program
workers and program-related activities.
Grooming - the process used by an abuser to select a child, win the child's
trust (and the trust of the child's parent or 'gatekeeper'), manipulate the
child into sexual activity, and keep the child from disclosing the abuse. 

Screening Program Workers
Background Checks
All program workers will be screened in accordance with this policy prior to
being eligible to serve. Screening will include at least the following: 
.	An internal conflict review will be conducted to discover
circumstances that would exclude a potential program worker from the program
due to investigations or violations related to the organization's code of
conduct. 
.	Criminal background checks will be conducted for all potential
program workers after they've completed an application. The background
checks will comply with applicable federal and state regulations governing
programs. Applicants will not be considered for positions when checks show
evidence of convictions for an offense involving children, violence, or any
other conduct contrary to the mission of the NFB. 
.	The affiliate will use a well-known reputable third party service to
conduct a screening and criminal background check that allows the
performance of monthly updates to the extent permitted by law. The
information obtained will be stored on a secured server, and only made
accessible to authorized NFB personnel. 

Personal Interview
A personal interview will be conducted with the applicant by a designated
affiliate leader or authorized designee to discuss the position and the
applicant's talents, qualifications, and abilities. Multiple and/or group
interviews may be conducted as appropriate. Individuals who have previously
passed this screening process may not be required by the affiliate to be
personally interviewed again unless they have not worked in an NFB program
for three or more years.

References
All applicants must provide at least three references. References may be
personal or professional and presented in written form or by providing phone
and email contact information. All references will be confirmed by
appropriate program workers and documented in the applicant's file. At least
one reference will be from a personal contact if available.

Training and Education
In addition to specific training related to the particular goals and
objectives of the program, all program workers will receive an orientation
training that includes: 
.	Review of NFB Code of Conduct
.	Anti-discrimination
.	How to recognize consent problems and create appropriate
interventions 
.	Mandatory reporting responsibilities 
.	Emergency procedures 
Program worker trainings and orientations will be updated and refreshed each
year.
The affiliate will offer the training and orientation through workshops,
programs, and the use of Braille, print, and/or audiovisual resources. 

Supervision
Supervision of youth program participants, programs, facilities, and program
workers will be designed to protect program participants and program workers
at all times. Practices to ensure a safe and caring environment will
include: 
.	A minimum of two program workers should be assigned to each program
and program location. 
.	Program workers will never be alone with an individual program
participant where they are not observable by others. 
.	Classroom doors should remain open unless there is a window in the
door or a side window beside it. Doors should never be locked while persons
are inside the room unless there are emergent safety needs or imminently
threatening health demands. 
.	There will be access to a telephone at all program locations during
operating hours. 
.	Program participants will never be left unsupervised.
.	Program workers will never release program participants to anyone
other than the authorized parent(s), guardian(s), or an individual
authorized by parents in writing or verified by phone. 
.	Program workers will utilize constructive methods for maintaining
group control and managing program participants' behavior. 
.	Program workers will appear and behave in a manner consistent with
the mission and values of NFB at all times; including electronic, written,
and verbal communications. 

Parent/Guardian Communications
The affiliate will inform parents of our youth program participant
protection strategies. All parents will be provided with a link to the
current NFB Code of Conduct and any other relevant policies.
Parents will be introduced to the program workers and will receive regular
communication about the program's content and schedules and feedback
regarding their child's participation in the program, including behavior and
general health. 
Parents or guardians will be allowed to observe the program as deemed
appropriate by the program coordinator without disruption to the program.

Reporting Requirements
For purposes of this policy, "child abuse" is any action (or lack of action)
that endangers or harms a child's physical, psychological, or emotional
health and development. All NFB program workers are recognized as mandated
reporters. The affiliate will follow current regulations and guidelines for
the reporting of abuse. 
Categories of Abuse & Neglect
Some categories of child abuse and neglect are: 
.	Physical - non-accidental physical injury inflicted by another
person with the intent of hurting the child. 
.	Sexual - when an adult uses a child for sexual stimulation or
gratification. 
.	Neglect - the negligent treatment, lack of treatment, or the
maltreatment of a child by a person responsible for the child's welfare.
There are two levels of neglect that must be reported: general and severe. 
.	Willful harm or injury - harming, injuring, or endangering a child. 
.	Unlawful corporal punishment - willfully inflicting unlawful
corporal punishment on a child and resulting in a traumatic condition. 
.	Abuse or neglect in out-of-home care - when a licensee,
administrator, or employee of any facility licensed to care for children, or
an administrator or employee of a public or private school or other
institution or agency, physically, sexually, or emotionally abuses a child
or neglects a child.
.	Grooming - We recognize that sexual abusers groom children for
abuse, thus, we ask all program workers to be aware of behaviors intended to
groom a child for sexual abuse.  

Program workers will follow an internal chain of command for the reporting
of abuse and may report directly to local authorities if appropriate.
If an incident of abuse or neglect is alleged to have occurred at or during
NFB programs or activities, the following procedure shall be followed: 
.	The parent or guardian of the child will be notified.
.	The appropriate authorities will be notified, consistent with local,
state, and/or federal regulations.
.	The affiliate will cooperate with any investigation of the incident
by state or local authorities. In the event there is no investigation of the
incident by state or local authorities, a management team will be formed to
investigate the circumstances of the incident. 
.	The alleged perpetrator of the abuse or misconduct will immediately
be separated from the group, will be placed on leave pending an
investigation, and consequences will be administered which are consistent
with the Federation's policies and practices related to the Code of Conduct
.	An incident report will be completed. 
.	As deemed appropriate by the program coordinator and the affiliate
board of directors, other program workers, participants, and families of
participants will be notified of the incident and resulting actions taken.
.	The incident will be filed in a timely fashion through the NFB's
Code of Conduct process.

Monitoring
This policy will be reviewed and updated as needed by the National
Federation of the Blind of [affiliate] Board of Directors or its designee on
an annual basis. 
Adopted on [month and day], [year], by the National Federation of the Blind
of [affiliate] Board of Directors. 

By signing below, I acknowledge that I have read, understood, and agree to
comply with the policy and procedures listed above.
Date:
Name:
Signature:
  
Your message is ready to be sent with the following file or link
attachments:

Youth Program Participant Protection Policy - affiliate template


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