Policies, Information and Resources: Introduction and Policies

POLICY, PROCEDURES, AND GUIDELINES

ON CHILD ABUSE

ARCHDIOCESE OF SAINT LOUIS

October 2009

Introduction

The following Policy and Guidelines (“Policy”) have been developed by the Archdiocese of St.

Louis (“Archdiocese”) to give guidance to employees, volunteers, religious, priests and deacons

in the Archdiocese on the subject of prevention of child abuse and the protection of children and

to address the needs of victims of child abuse. For purposes of the Policy, the Archdiocese of St.

Louis includes schools, parishes and agencies of the Archdiocese (hereafter collectively referred

to as “SPA”). The primary goal of the Archdiocese in this regard is to prevent child abuse, and

the primary method of prevention is education and care in the hiring and evaluation of

employees and volunteers. Since the possibility of child abuse has to be recognized, the Policy

also covers the investigation and reporting of incidents of child abuse, and assistance to those

affected by abuse.

Policy

The Archdiocese is committed to the prevention of child abuse and to assisting those who

are affected by incidents of child abuse. The Archdiocese is also committed to complying

with legal requirements for reporting child abuse. For purposes of this policy, child abuse

means physical injury, sexual abuse, or emotional abuse inflicted on a child, other than by

accidental means. See Appendix 11 for revised Missouri Statutes concerning Child

Protection and Reformation. All employees, volunteers, religious, priests and deacons

working in the schools, parishes, and agencies of the archdiocese are expected to support

this Policy and to comply with the Guidelines developed to implement the Policy.

I. Prevention of Abuse

I.1. Safe Environment Program

The Archdiocese has developed a Safe Environment Program to ensure the safety of our children

and youth, as required by the United States Conference of Catholic Bishops (“USCCB”)

“Charter for the Protection of Children and Young People.” This program provides a framework

for the Archdiocese to cooperate with parents, civil authorities, educators, and community

organizations to make and maintain a safe environment for children.

The Safe Environment Program has components for children/youth, parents, employees,

volunteers, religious, priests and deacons, and third party contractors doing business with the

Archdiocese. Each of these components is discussed in turn.

Effective June, 2006 implementation of the Safe Environment Program in the Archdiocese was

assumed by the newly created Safe Environment Program Office.

I.2 Safe Touch Program for Children and Youth

Students in schools, parish schools of religion and other educational programs in the Archdiocese

are to attend age-appropriate safe touch education programs, approved by the Archdiocesan

Child Safety Committee, that address child abuse and the need to report any attempted or actual

abuse to their parents, teachers, principals or other appropriate persons. Parents are welcome to

view the education materials in advance. If a parent has concerns or objections about such

material, these are to be addressed at the school and/or parish level, as appropriate. Parents will

be given the opportunity to request their children not attend these education programs. If they

do so request, parents will be given safe touch materials to present to their children at home. If

parents request that their child(ren) not attend the program, and refuse to accept the safe touch

materials, this information should be noted in the student (s)’ file. See the Opt Out form in

Appendix 10. The Safe Touch Program for Children and Youth will be coordinated and taught

by a Lead Teacher designated by the principal or pastor.

I.3. Safe Touch Program for Parents

Parents in the Archdiocese are offered safe touch education programs on signs of abuse to look

for in their children, which may alert them to a possible problem. The program must be made

available to parents but parents do not have to attend the sessions. Allowing parents to previewThe Safe Touch Program for Adults will be coordinated by a Lead Teacher designated

the Safe Touch Program can meet the standard of offering a safe touch program for

parents.

by the principal or pastor.

I.4. Safe Environment Program for Employees, Volunteers, Religious, Priests and

Deacons

The program requires that all employees, volunteers, religious, priests and deacons who work

with or near minors on a regular basis - that is someone who would be working with or near

minors three or more times a year, would be participating in an overnight program with minors,

or would be on a list of persons eligible to be working with minors, even if it is not known

whether or how often he/she would actually be scheduled - must do the following:

(1) attend the “Protecting God’s Children” program,

(2) undergo a Child Abuse / Criminal Record check upon being hired, or volunteering, and in

even numbered years thereafter, and

(3) agree to abide by the Code of Ethical Conduct.

I.4.1

minors on a regular basis and or 18 years old and have graduated high school must attend the

“Protecting God’s Children” program. This program provides education regarding what signs to

look for in the detection of abuse, both in circumstances and events that might indicate abuse and

in the children themselves.

I.4.2

minors on a regular basis must undergo a Child Abuse / Criminal Record check prior to being

placed in a position to have contact with minors. This screening requirement is completed by the

Office of Priest Personnel for priests and the Office of Permanent Diaconate for deacons.

I.4.3

who work with or near minors on a regular basis must undergo a Child Abuse / Criminal Record

check prior to being placed in a position to have contact with minors.

As stated above, for employees and volunteers, the following guidelines are to be followed when

hiring an employee or recruiting a volunteer:

a. Utilize a standard application form developed by the Archdiocese, which

requests information regarding any history of abuse. For employees, please refer to the

Employment Application

Volunteer Application

b. Check references and other information from the application form as

appropriate to the question asked and the position being sought.

c. A Child Abuse / Criminal Records check for prior history of abuse in Missouri

should be made for each applicant. This check may be accomplished either through the Missouri

Family Care Safety Registry (FCSR) Please refer to the FCSR Memorandum and the FCSR

Worker Registration Form in Appendix 3 of this manual. Or they may use a written request to

Missouri State Highway Patrol using the Name Search Option. Please refer to the Request forform in Appendix 4 of this manual.

Child Abuse or Neglect/Criminal Record

Employees or volunteers who have resided outside of the state of Missouri any time over the

last five years will have to undergo a nationwide FBI finger print background check when they

enter the Safe Environment Program as well as the FCSR screening. Subsequent checks will be

FCSR screenings. If the only out-of-state location is Illinois, the employee or volunteer will only

have an Illinois background check in addition to the FCSR screening.

d. To ensure consistency throughout the Archdiocese, if the report from the

e. Records of persons not given positions because of concerns relating to placing

them in contact with children should be maintained for five years. Records of persons given

positions should be permanently maintained after employment has terminated.

f. In addition to the hiring and pre-employment screening process used for new

employees, there should be an ongoing evaluation of all employees who work with or near

minors on a regular basis. Every even numbered year, a Child Abuse / Criminal Records check

through the Missouri FCSR or the Missouri Highway Patrol will be conducted by the

administrator of the SPA.

I.4.4

work with or near minors on a regular basis must read the Code of Ethical Conduct and sign the

Commitment to Ethical Conduct. Please refer to the Code of Ethical Conduct for Clergy,in the Appendix 6 of this manual.

Employees and Volunteers Working with Minors

I.5. Safe Environment Program for Order Priests and Brothers and Women Religious

Serving in SPA

Priests and brothers from religious orders and women religious who are in a position to work

with or near minors on a regular basis in SPA in the Archdiocese must follow the same

compliance regulations as other adults who work or volunteer with minors. In addition these

priests and religious require a letter from their religious superior upon their arrival to the diocese

stating there is nothing in their past that would prevent them from working with children. Order

priests assigned to be pastors or associate pastors in the Archdiocese are to be cleared through

the Catholic Center.

Religious order priests who occasionally help with support ministry at parishes must have their

compliance monitored by the Office of Priest Personnel.

Religious order priests employed by high schools and agencies will be cleared according to

guidelines adopted by the respective school and agency.

I.6 Safe Environment Program for Persons Associated with Home School

Activities Conducted in Parish Facilities

Due to the unique structure of home school programs conducted in parish facilities, which by

their very nature have almost all parents participate in some form, the following persons

associated with home school programs must complete the requirements of the Safe Environment

Program of the Archdiocese of St. Louis: (1) those persons who receive monetary compensation

in connection with their efforts relating to home school programs conducted in parish facilities;

(2) those persons who have an official role in home school programs (such as “director” or

“secretary” or similar designations/representatives) and/or (3) those persons who may be in a

position to be alone with a child or children (who is not their child) in parish facilities (all three

groups collectively referred to as “Home School Agents”). The Safe Environment Program

requires that Home School Agents do the following:

(1) attend the “Protecting God’s Children” program,

(2) undergo a Child Abuse / Criminal Record check, and

(3) agree to abide by the Code of Ethical Conduct.

I.6.1

This program provides education regarding what signs to look for in the detection of abuse, both

in circumstances and events that might indicate abuse and in the children themselves.

I.6.2

Criminal Record check prior to being permitted to participate in Home School Programs in

parish facilities.

A Child Abuse / Criminal Records check for prior history of abuse in Missouri should be made

for each Home School Agent.

This check may be accomplished either through a written request to Missouri State Highway

Patrol using the Name Search Option (please refer to the Request for Child Abuse orform in Appendix 3 of this manual) or through the Missouri Family(please refer to the FCSR Memorandum and the FCSRin Appendix 4 of this manual). This check will provide

Neglect/Criminal Record

Care Safety Registry (“FCSR”)

Worker Registration Form

information from open records from the Missouri Criminal Record Repository and information

from the Missouri Division of Family Services’ Central Registry.

If the Home School Agent currently resides or recently resided in another state, a records check

should also be made with the comparable agency for that state. If deemed appropriate, based on

information received from the application process, a records check should also be made with the

comparable agency for all states in which the applicant has resided in the last five years (see

Appendix 5 of this manual).

I.6.3

and sign the Commitment to Ethical Conduct (please refer to the Code of Ethical Conduct forin the Appendix 6 of this manual).

Clergy, Employees and Volunteers Working with Minors

The Code of Ethical Conduct must be balanced with the fact that some of those who sign the

Code are also parents of students in the program and in this context, the provisions of the Code

should be interpreted broadly to accommodate the parental relationship.

I.6.4

the parish safety coordinator to ensure that the Home School Agents have completed the Safe

Environment Program requirements.

I.7 Safe Environment Program for Contractors

Contractors are those individuals who work in schools, parishes or agencies who are in a position

to have contact with children but who are not directly employed by the school, parish or agency.

These individuals could be working for a company or group contracted to provide specific

services. Examples include individuals working for a cafeteria service, bus company,

maintenance firm, or latch key program.

I.7.1

to any past history of child abuse. The responsibility for such screening rests with the. The administrator is

employer, not with the administrator of the school, parish or agency

only responsible to determine that the contracted firm undertakes the screening at the appropriate

time. Administrators should require evidence that such an evaluation has occurred. For

example, firms could be asked to supply a copy of the employee’s screening form from the State

of Missouri. If a firm does not cooperate in this screening effort, another firm should be sought.

a. A records check for prior history of child abuse in Missouri should be made for new

independent contractor personnel who will have contact with children at a school or parish of the

Archdiocese by the firm employing the individual. The Archdiocese of St. Louis, not the State

of Missouri, requires this check. This check is accomplished through a written request to

Missouri State Highway Patrol or through the Missouri Family Care Safety Registry.

b. If the individual currently resides in another state a records check should also be made

with the comparable agency for that state. If deemed appropriate based on information received

from the application process, a records check should also be made with the comparable agency

for all states in which the individual has resided in the past five years. See State Centralin Appendix 5 of this manual).

Repository

c. The administrator should request verification each year from the employer of the

independent contractor personnel working at the school, parish or agency that all new employees

have been screened. New employees should be evaluated immediately upon hire and prior to the

employee being assigned to the school, parish or agency.

d. In addition to the hiring and pre-employment screening process used in hiring new

employees there should be an ongoing evaluation of independent contractor personnel who are

working with or who are in a position to have contact with children. Every even numbered year

the employer should send a written request to the Missouri State Highway Patrol or the Missouri

Family Care Safety Registry.

I.7.2

contractors working with the Archdiocese who may have contact with minors sign a Code of

Ethical Conduct (please refer to the Code of Ethical Conduct for Employees of Companies,in Appendix 9 of this manual). Good

Contractors, Vendors, Consultants and Any Other Entity Providing Goods or Services to

the Archdiocese of St. Louis and any of its Members

judgment should be the rule. Certain types of Contractors are exempted, while others are not.

For guidance please refer to Guidance Regarding Contractors Signing the Code of Ethicalin Appendix 9 of this manual.

Conduct

I.7.3

under the age of 18, or who are still in high school, who work or volunteer with or near minors

as part of a high school service project or any other parish program or activity must sign the

Code of Ethical Conduct for Student Volunteers working with Minors

must also sign this form. See Appendix 8 of this manual.

I.8. Minimum Age for Lead Chaperones for Events involving Minors:

For purposes of compliance, someone who is 18 years old and out of high school is considered

an adult. However, when someone is serving as the lead chaperone for an event involving minors

he/she must be at least 21 years old, and his/her fitness must be determined by the SPA

sponsoring the youth event.

I.9. Background Evaluations For Undocumented Volunteers:

Undocumented volunteers, who by the nature of their presence in this archdiocese cannot be

subject to the same Safe Environment Program-required background checks performed on other

adults in this archdiocese, must adhere to the following guidelines if they want to volunteer

around children:

Every effort must be made to ensure there is no documentation for the individual. If the

individual claims to have no documentation when he/she really does, he/she must stop

volunteering immediately.

There must be a waiting period of six months after the initial request to volunteer before the

individual can begin to volunteer

The volunteer service must be performed in tandem with another adult who is in full compliance

with the Safe Environment Program

There must be two or more local character references, not from the same family.

Both other components of Safe Environment Program compliance – the Protecting God’s

Children workshop and the reading and signing of the Code of Ethical Conduct – must be

completed. This policy will be reviewed in April, 2010..10. Policies for Registered Sex OffendersGuidelines for registered sex offender participation at Mass

I

I.10.1

Certainly no one should ever be denied participation in liturgy but a few precautions are in order.

The registered sex offender should attend the same Mass each Sunday and ideally attend a

service that is not a crowded, family Mass. Also the individual must sit in the same area every

Sunday. An usher should be alerted to his or her presence.

The person may not participate in any special role in the Mass or in any parish ministry. Such

participation would likely result in the ability for the sex offender to have contact with minors

and/or could put the sex offender in a position where he or she could develop a relationship of

trust with minors.

I.10.2

A person who is a registered sex offender or who is otherwise known as a sex offender and has a

close relative ( e.g. child, step-child, grandchild, sibling, niece or nephew) in a Catholic school or

Catholic parish-related program may be allowed to attend activities or programs for that close

relative if he/she complies with the following guidelines. These activities could be, but are not

limited to, such things as a school play, an athletic event, etc. These guidelines also apply to

individuals who are non-Catholic. The first line of responsibility for enforcement of these

guidelines should be between the sex offender’s family and the pastor.

The individual may not hold a volunteer or employee position but may participate as a member

of the assembly for religious events, or as a spectator for athletic events, etc.

The individual must make him/herself known to the parish pastor, and to the head of the ministry

whose activity it is he or she may want to attend, e.g. school principal, PSR director, athletic

director,

Guidelines for registered sex offender participation at parish events involving minors.. Parents or guardiansCode of Ethical Conduct for Student Volunteers or Working with Minors: Young peopleCode of Ethical Conduct: The Safe Environment Program also requires that allScreening: It is important to make sure that these individuals are screened with regardReporting: Each Director of the home school program for each parish must work withCode of Ethical Conduct: Home School Agents must read the Code of Ethical ConductScreening Home School Agents: Home School Agents must undergo a Child Abuse /Training: Home School Agents must attend the “Protecting God’s Children” program.Code of Ethical Conduct: Employees, volunteers, religious, priests and deacons who 

FCSR or the Missouri Highway Patrol is returned with information related to a past

offense allegedly committed by an applicant, employee or volunteer, please contact Ms.

Terry Edelmann, the coordinator of the Safe Environment Program at 314.792.7271 or

terryedelmann@archstl.org for guidance.

in Appendix 2 of this manual.in Appendix 1 of this manual. For volunteers, please refer to theScreening Employees, Volunteers and Religious: Employees, volunteers and religiousScreening Archdiocesan Priests and Deacons: Priests and deacons who work with or nearTraining: Employees, volunteers, religious, priests and deacons who work with or near