Audit Child Protection Policies to Start the New Year

The beginning of a new year is a traditional time to make new plans. For youth organizations, it is also a good time to take a close look at child protection policies to determine which ones to keep or change going forward. Not only will the process make your program more efficient, but it will help you avoid, or at least mitigate, future problems.

Each program is unique, but be certain that your annual review covers the following areas related to child protection:

Locate old insurance policies

With more and more states extending statutes of limitation, you need to find as much information as you can about your old insurance policies. Gather whatever records you have, even if it’s only a record of paying the premium, into a handy location. Consider implementing a policy of reviewing all records for insurance information before you destroy them. If you get hit with a claim from many years ago, you will need this information, and the best time to find it is before you get the claim.

Review current insurance policies

Next, review your current insurance policies to be certain that they cover your risks. Talk to your team and colleagues about the kinds of claims that organizations in your field are facing. Work with your insurance agent or broker to be sure that your liability policy covers the claims that you are likely to face. I recommend that you ask about not only the obvious risks, such as child injury or molestation, but claims of defamation from making a mandated report to child protection authorities. Even a frivolous claim can rack up attorneys’ fees, and you don’t want to be left without insurance to cover litigation costs. Also ask about insurers that offer discounts for having child protection policies or training in place.

Audit your records

First, be certain that you have all of the information that your licensing agency or accrediting association requires in your client and staff files. Next, compare your records to your own policies. For example, if your internal policies require higher credentials or more experience for your staff than what your licensing agency requires, be sure that your staff records reflect those credentials. If you are hiring people without those qualifications, then you need consider whether you need to change your policies. At the very least, be sure the file reflects a good reason for hiring individual staff who don’t meet your internal requirements. Whether you need to improve your record-keeping or move to more realistic child protection policies, be sure that your records match your aspirations.

Finally, take time to do an in-depth review of your incident reports, parent complaints, staff reports, and whistleblower complaints. Analyze them to decide if you are seeing a pattern that indicates you need to change or adopt new policies or procedures to better protect children. Don't fall into the trap of adopting child protection policies focused on one particular risk — orienting all of your policies around your last incident won't necessarily protect you from the next one. After all, if a childcare center moves all of its teachers to watch the slides on the playground, the next child injury will be on the seesaw. Similarly, if you spend all of your resources watching for pedophiles, you may miss statistically-more-likely child-on-child abuse in your program. Analyze all of your reports and feedback with the goal of seeing if you can implement changes in your child protection policies that will work for your organization in the future.

Review your internal policies

The next step, or perhaps a part of your records audit, is to measure how well you are following your other internal child-on-child policies. The policies that you should review at least once a year include:

• Child protection, including

staff screening and supervision
adult-child boundaries
off-campus contact between adults and minors
child-child boundaries

• Document retention

• Staff training

• Staff handbooks & discipline policies

• Parent & student handbooks

A common pitfall that I see with my clients is that they let their good intentions lead them into setting unrealistic standards. For example, if licensing rules or general practice in the area requires 3 references for staff applications, an organization may decide to require 3 work references and 2 personal references. Unfortunately, the administration may find that the day-to-day pressures of running the organization don’t leave enough time for 5 references, and they fall back to the required 3. Yet, the written policy remains the same. Then when a problem occurs, the organization is held to the higher standard of its own good intentions.

So, you need to consistently review your internal policies to be sure that your organization is following them. If the standards are not negotiable, such as mandated reporting or criminal background checks, then figure out what you need to change in order to meet them. You may need to devote more manpower to the task or shift responsibilities so that person responsible actually can do the job. If your standards are aspirational, figure out whether you need to pare them back to a realistic goal given the strict limits of time, budget, and manpower.

Review your advertising

Finally, take a good look at your advertising. It can be tempting to promise parents whatever they want to hear. The problem comes when your advertising creates promises that can come back to haunt you. Do your employees, for example, meet the “highest standards in the industry” or only state licensing requirements? Is safety your “top priority” or do you run an adventure camp where children learn to manage risk as safely as possible? As with your internal policies, compare your advertising to your actual performance and change whatever needs to be changed so that the two align.

Take some time at least once a year to review all of your policies and audit your records. Whether you do that at the beginning of the year or later, be sure to do it before you are dealing with an emergency or after a serious claim.