RESOURCES‎ > ‎

Child protection policy

EMM’s Child Protection Policy (CPP)

I. Background

    A. Theological foundation
We seek the physical, mental/emotional, and spiritual well-being of all persons associated with EMM  our workers and those whom they serve around the world, our staff, and our constituents. This also includes children. We highly value them and seek to create a welcoming, safe environment in which to care for them.

    B.  Purpose statement
The purpose of this policy is to provide protection from abuse for children and youth in our care as well as to provide protection for our staff and volunteers as they seek to care for and nurture children and youth. This policy outlines EMM’s expectations for appropriate behavior regarding the care and supervision of children and youth. Our desire is that all who participate in EMM activities know that they are in a safe environment where abusive conduct is not tolerated and where staff and volunteers are protected from false or wrongful allegations.




    C.  Definitions
1. Child: An individual under 18 years of age.
2. Child abuse1: Intentionally, knowingly, and recklessly doing any of the following:
  • Causing bodily injury to a child through any recent act or failure to act.
  • Fabricating, feigning, or intentionally exaggerating or inducing a medical symptom or disease which results in a potentially harmful medical evaluation or treatment to the child through any recent act.
  • Causing or substantially contributing to serious mental injury to a child through any act or failure to act, or a series of such acts or failures to act.
  • Causing sexual abuse or exploitation of a child through any act or failure to act.
  • Creating a reasonable likelihood of bodily injury to a child through any recent act or failure to act.
  • Creating a likelihood of sexual abuse or exploitation of a child through any recent act or failure to act.
  • Causing serious physical neglect of a child.
  • Causing the death of a child through any act or failure to act.
  • Engaging a child in a severe form of trafficking in persons or sex trafficking.

Child abuse also includes certain acts in which the act itself constitutes abuse without any resulting injury or condition. These recent acts include any of the following:
  • Kicking, biting, throwing, burning, stabbing, or cutting a child in a manner that endangers the child.
  • Unreasonably restraining or confining a child, based on consideration of the method, location, or duration of the restraint or confinement.
  • Forcefully shaking, slapping, or striking a child under one year of age.
  • Interfering with the breathing of a child.
  • Leaving a child unsupervised with an individual, other than the child's parent, who the parent knows or reasonably should have known was required to register as a sexual offender or has been determined to be a sexually violent predator or sexually violent delinquent.

    3.  Sexual abuse or exploitation2:  
Any of the following:
The employment, use, persuasion, inducement, enticement, or coercion of a child to engage in or assist another individual to engage in sexually explicit conduct, which includes, but is not limited to, the following:
  • Looking at the sexual or other intimate parts of a child or another individual for the purpose of arousing or gratifying sexual desire in any individual.
  • Participating in sexually explicit conversation either in person, by telephone, by computer, or by a computer-aided device for the purpose of sexual stimulation or gratification of any individual.
  • Actual or simulated sexual activity or nudity for the purpose of sexual stimulation or gratification of any individual.
  • Actual or simulated sexual activity for the purpose of producing visual depiction, including photographing, videotaping, computer depicting, or filming.
This paragraph does not include consensual activities between a child who is 14 years of age or older and another person who is 14 years of age or older and whose age is within four years of the child's age.

Any of the following offenses committed against a child:
  • Rape
  • Statutory sexual assault
  • Involuntary deviate sexual intercourse
  • Sexual assault
  • Institutional sexual assault
  • Aggravated indecent assault
  • Indecent assault
  • Indecent exposure
  • Incest
  • Prostitution
  • Sexual abuse
  • Unlawful contact with a minor
  • Sexual exploitation

4.  Mandated reporter: An individual (adult) paid or unpaid who, on the basis of the individual's role as an integral part of a regularly scheduled program, activity, or service, is a person responsible for the child's welfare or has direct contact with children. (Of the 16 categories of mandated reporter, this category is the most relevant for EMM purposes.)
  • Mandatory reporting means that an individual must directly report “out” to ChildLine when child abuse is suspected. In the past a person could simply report “up,” meaning they could report to their supervisor and their legal obligation would be fulfilled. All mandatory reporters could be criminally liable and considered a “perpetrator” if they fail to report “out.”

5.  Reasonable cause to suspect child abuse: Reasonable cause is not defined in the Law. It means that someone has more than a hunch but less than certainty that child abuse has occurred. Mandated reporters are required to make a report of suspected child abuse if they have reasonable cause to suspect that a child is a victim of abuse under any of the following circumstances: Basis to Report.4 
  • A mandated reporter shall make a report of suspected child abuse or cause a report to be made if the mandated reporter has reasonable cause to suspect that a child is a victim of child abuse under any of the following circumstances:
  • The mandated reporter comes into contact with the child in the course of employment, occupation and practice of a profession or through a regularly scheduled program, activity, or service,
  • The mandated reporter is directly responsible for the care, supervision, guidance, or training of the child, or is affiliated with an agency, institution, organization, school, regularly established church or religious organization, or other entity that is directly responsible for the care, supervision, guidance, or training of the child,
  • A person makes a specific disclosure to the mandated reporter that an identifiable child is the victim of child abuse,
  • An individual 14 years of age or older makes a specific disclosure to the mandated reporter that the individual has committed child abuse.
  • Nothing in this section shall require a child to come before the mandated reporter in order for the mandated reporter to make a report of suspected child abuse,
  • Nothing in this section shall require the mandated reporter to identify the person responsible for the child abuse to make a report of suspected child abuse.
6.  Approved adult (EMM definition): Anyone age 18 years and older who has satisfied the requirements listed in Section III. C. An approved adult can be an employee or non-employee of EMM. Approved adults include any and all staff and adults who lead or assist with any and all programs and activities for infants, children, and youth (anyone from 0 to 18 years of age).




II.  Policy administration

A. This Child Protection Policy (CPP) applies to all EMM activities, no matter the location, in which children and youth participate.

B.  Administration of this Child Protection Policy involves the Human Resources Director, the Executive Vice President, and the Third Culture Kid Coach.

1. Role of the Executive Vice President (VP)
It is the responsibility of the VP to periodically review and approve revisions to the CPP and to ensure the adequacy of EMM's relevant insurance policy and coverage. It is the responsibility of the VP to support the HR Director in responding to a disclosure or an allegation of abuse. The VP will complete three hours of state-approved training. This will be refreshed every five years. Online at: reportabusepa.pitt.edu

2. Role of the Human Resources Director
The HR Director administers the CPP as it applies to hiring staff. He/she also gives oversight to the provision of training for the CPP Administrator, and coordinates the internal response to reports of suspected abuse (after it has been reported “out”). The HR director will also provide support and counsel for the CPP Administrator in situations where there are questions regarding clearance results or the appropriateness of approving an individual to work with children and youth. The HR Director will complete three hours of state-approved training. This will be refreshed every five years. Online at: reportabusepa.pitt.edu

3. Role of the Third Culture Kid Coach
The role of CPP Administrator at EMM is assigned to the Third Culture Kid Coach. Responsibilities include updating the CPP in accordance with current laws and protocol, overseeing the ongoing clearance, approval, maintenance of CPP files and records, integration, and education of all those who work in any capacity with children and youth, and ensuring that the CPP is being implemented for all child care for EMM events or activities.

The CPP Administrator will complete three hours of state-approved training. This will be refreshed every five years. Online at: reportabusepa.pitt.edu

III.  Selection and screening

A.   Keeping records:
Volunteer applications and clearance records should be submitted to the CPP Administrator. These files are either in a locked file or on the H drive of the CPP Administrator’s password protected computer.

B.  Implementation:
All EMM workers (14 years old and older), paid or volunteer, are required to obtain three background clearances: the Pennsylvania Child Abuse History Clearance, Pennsylvania State Police Criminal History Record Clearance, and FBI clearance. The FBI clearance is waived for volunteer workers who have resided in PA for the entire last ten years and who affirm in writing that the prospective volunteer is not disqualified from service due to a disqualifying offense under the Law. EMM will pay all costs connected to obtaining clearances. Download FBI waiver for volunteer workers. 

C.  Approved adult:
An approved adult is someone who has met the following requirements:
  1. Is 18 years of age or older.
  2. Completes and signs an Application to work with children and youth. This application must be approved by the CPP Administrator. EMM will also review background check (see #3 below) results before approving staff and volunteers to work with children. References will be checked by the CPP Administrator. No one who is known to have committed sexual abuse, has a felony drug offense, is identified in the statewide database as the perpetrator of a founded report of abuse within the previous five years, who is listed as a perpetrator of indicated reports of child abuse, or is the subject of a founded report of child abuse will be approved as a child/youth worker.
  3. Has received a Pennsylvania Child Abuse History Clearance (www.dhs.pa.gov), a PA State Police Criminal History Record Clearance (epatch.state.pa.us), and a FBI clearance (pa.cogentid.com).
    Copies of clearances completed in the past five (5) years are acceptable. People holding current clearances will submit copies of the clearances to the CPP Administrator.
    If applicants are not PA residents, they will be required to submit a State Child Abuse History Clearance and Criminal History Record from the state(s) in which they lived.
  4. All clearances will need to be repeated every five years.
    A permission form for release of information will be signed if EMM submits the request for the PA State Police Criminal History Record Clearance.
    EMM will pay all costs connected to obtaining clearances.
    Staff and volunteers must provide written notice to EMM if they are arrested for or convicted of an offense that would constitute grounds for denying employment or participation in a program, activity or service, or are named as a perpetrator in a founded or indicated report of child abuse. Such written notice must be provided within 72 hours of the staff person’s or volunteer’s arrest, conviction, or notification that s/he has been listed as a perpetrator in the statewide database.
  5. Has received orientation, training, and updates on the EMM Child Protection Policy and has signed the EMM Child Protection Policy Covenant Statement.

D. Orientation and training (this is not a state-approved training):
All EMM workers, paid or volunteer, are required to receive child protection training before working with children. Initial training includes review of this Child Protection Policy, completing clearances, and signing the EMM CPP Covenant Statement stating they understand and agree to follow the EMM CPP.

When the CPP is updated or revised, all workers will be asked to review and sign the EMM CPP Covenant Statement.



IV.  General guidelines
It is the policy of EMM to provide adequate supervisory control of all adult staff and volunteers working with children and youth who are participating in any company programs and activities, including temporary child care programs. The following requirements apply to any workers who have contact with children and youth while participating in any company programs. These requirements are designed to protect both the children and youth and the adults who work with them.

A.  Protection and safety:
It is recommended that two persons be present in each room during any EMM-sponsored program, activity, or event involving children of kindergarten age or younger.

Windows in doors:
All doors into children's rooms and youth rooms should have windows in them. If there is no window, or whenever two workers are not in the room, doors should be left open.

B. Bathroom and diapering:
Encourage children to use the bathroom before coming to class. If you need to take a child to the bathroom, wait outside the bathroom stall. If assistance is required, leave the stall door open.

When feasible, two persons should be present when clothes or diapers are changed.

C. Expressions of affection:
Use appropriate expressions of affection. Positive reinforcement (verbal praise and encouragement) is the preferred method used to foster appropriate child/youth behavior. True expressions of affection contribute to a warm, healthy relationship  don't stop loving and touching children. Always respect a child/youth's refusal of affection and don’t make them feel uncomfortable. Ask permission before giving a hug. Be aware of hand placement as it could be misinterpreted. Note that body-to-body embraces and touching private areas (areas covered by a bathing suit) are inappropriate.

D. Discipline:
No humiliation, verbal abuse, or physical discipline should be administered at any time.

E.  Parental permission:
Any off-site activity/field trip that is part of a children or youth program requires that the parent/guardian sign a consent form. The consent shall include:
parental permission to seek or provide emergency medical treatment as necessary, and parental permission to use photographs for social media posts or company publication. Download the form here.

F. Transportation rule:
When children/youth are transported for EMM activities, they will be transported by drivers who are 18 years of age or older. Drivers must have a valid driver's license and obey all traffic laws. They should read and sign a Vehicle Authorization Form, which will be kept on file. It is preferable that an EMM vehicle is used. If this is not possible and a driver uses their personal vehicle, they must provide proof of current insurance for their vehicle.

G. Incident report:
In the event that a child/youth is injured during EMM activities, a report of the injury should be made using the Incident Report Form. The report will be filed by the CPP Administrator.



V.  Reporting alleged abuse
In the event of suspected child abuse, the following steps will be taken.

A. Response of the individual reporter:
  1. Secure the immediate safety of the child/youth involved. If the child is in imminent danger or needs immediate medical attention, call 911.
  2. The preferred method of reporting out is to file a report online on the Child Welfare Portal at compass.state.pa.us/cwis. Note: Before a report can be made, the person must pre-register on the portal. After you pre-register, you can file a report directly through the portal. There is no follow-up report needed if you file electronically and receive confirmation that the Department has received your report.
  3. After making an electronic report (or calling ChildLine at 1-800-932-0313) to report the suspected abuse, the individual should immediately notify the CPP Administrator or the HR Director.
  4. Maintain confidentiality. A mandated reporter should not discuss the report he/she has made with anyone else who is not involved in the situation.
  5. Any person who, in good faith, makes a report of suspected child abuse will be free from discrimination, retaliation, and civil or criminal liability related to this action.

B. Response of EMM:
    1. The CPP Administrator will notify the HR director.
    2. The HR director:
    • Will file the completed form in a secure location.
    • Will notify the VP, the president, and the director of Advancement.
    • Will notify the insurance company that the alleged abuse has been reported.
    • Addresses initial and ongoing support in the process for the child and the child’s family through communication with the County Children and Youth Agency and attorneys. Provides counseling and resources as appropriate. Reports findings to the VP, the CPP Administrator, and others involved.
    • Addresses initial and ongoing support in the process for the Alleged Perpetrator and his/her family. Provides counseling options and resources as appropriate. Reports findings to the VP, the CPP Administrator, and others involved.
    • Will document all contacts and conversations.
    • Temporarily removes the Alleged Perpetrator from any environment where children/ youth are involved while the investigation is in process.
3. Director of Advancement:
Will serve as the point person for all inquiries by the constituency or the media.
4. Documentation:
All conversations and meetings/contacts with individuals or groups will be documented and kept in a secure file.


VI. Response to the alleged/actual victim and family

EMM's first priority in such circumstances is to ensure that the CPP is followed for the safety of the children/youth and for the preservation of EMM as a secure place. Support and resources will be offered as needed for alleged/actual victim and family.


VII. Response to the alleged/actual perpetrator

EMM attempts to show Christlike love to all staff and volunteers. While acknowledging the need to minister to and support the Alleged/Actual Perpetrator, EMM’s first priority is to ensure that the CPP is followed for the safety of the children/youth.

A. Positions and responsibilities held:
An individual accused of child abuse will be removed from all positions and responsibilities while the investigation takes place.

B. Releasing information:
In releasing information about allegations, pending cases, determinations by law enforcement officials, and determinations by the courts, EMM will carefully attend to concerns about both transparency and confidentiality. If an EMM staff member or worker is found guilty of child abuse by the courts, their name will be disclosed to EMM personnel.

C. Allegations founded or unfounded:
  1. If allegations are determined to be unfounded, every effort will be made to exonerate, reconcile, and restore the Alleged Perpetrator. He/she will be reinstated to any position from which he/she was removed due to the allegation.
  2. If allegations are determined to be unfounded, but the information reported remains a cause for reasonable concern, the individual will be removed from environments where children or youth are involved for a stated period of time.
  3. If allegations are determined to be founded, the Perpetrator’s employment with EMM will be terminated.

1Taken from Child Protective Services Law (CPSL) section 6303
2
Taken from CPSL section 6303
3Taken from CPSL section 6311 (a) (7)
4Taken from CPSL section 6311 (b)