2. No follow through to ensure compliance.

• Gap: The Board ensured that policies and procedures were written, but there has never been a policy audit to confirm that the policies are being adhered to. 
• Our Recommendation: An audit should be requested by Senior Leadership and/or the Board on an annual basis to ensure policies are actually being followed. 

• Gap: Only those working with Children and Youth are screened, or screening is limited to only a criminal record check. 
• Our Recommendation: We now recommend that all staff, volunteers, Board, support and care staff, and hall monitors are screened. Screening should include: 6 month waiting period (where applicable), applications, interviews, reference checks, criminal record checks (Vulnerable Sector Checks) and training. 

4. Documentation is not being kept permanently.  

• Gap: Documentation, personnel records, attendance records, registration forms and consent forms are being destroyed.
• Our Recommendation: As there is no statute of limitations on child abuse in Canada and many States in the US, insurance companies and legal counsel recommends that documentation be kept permanently. 

5. Reporting guidelines conflict with legislation.

• Gap: If you require your staff or volunteers to report abuse to Senior Leadership, instead of reporting it to Child Protection Agencies, you are conflicting with the laws in Canada and many of the States in the US 
• Our Recommendation: All Canadians are mandatory reporters and this should be reflected in your policies. In the US some have a professional duty to report, while everyone else is encouraged to report a child that is in need of protection. Reports must be made directly. 

6. Reporting guidelines that delay a report. 

• Gap: If you require your staff or volunteers to first report to leadership in order for an investigation to be conducted, or for a decision to be made as to whether a report is necessary, this could delay or interfere with the reporting process, placing a child in greater risk of harm or abuse, and it conflicts with legislation.
• Our Recommendation: The report MUST be made immediately - this should be reflected in your policies.

7. Training is not being conducted by knowledgeable trainers. 

• Gap: We have heard some excellent trainers, but we have heard many trainers who are teaching content incorrectly. Content that incorrectly communicates legislation, and insurance standards could place your organization at great risk. Training that is uninspiring and contributes to a negative perspective of abuse prevention and/or Plan to Protect®. 
• Our Recommendation: We have researched and invested hours specializing in abuse prevention, and we have a team of experts both on staff and on our Advisory Council. We are committed to professional development - our Train the Trainer certification course equips trainers appropriately. 

8. Refresher training is not being required annually.  

• Gap: Organizational policy does not require training or if it does, it is not being enforced.
• Our Recommendation: Refresher training provides opportunity to review gaps, areas of the policy that are not being followed, new changes with Plan to Protect®, etc. This is a requirement of most insurance companies. 

9. Inadequate abuse coverage in place.  

• Gap: Abuse coverage is often excluded from most insurance policies. 
• Our Recommendation: To qualify for abuse coverage, you must meet the requirements of your insurance company. We recommend you secure a minimum of $2M, preferably $5M of insurance. Plan to Protect® incorporates insurance standards.

10. Missing operational procedures that give parameters on interaction between minors and program leaders. 

• Gap: Today most of your staff and volunteers have cell phones, technology at their fingertips, and access to students is 24/7 via social media. Policies that have not been updated in the last few years are often missing important operational procedures that will set parameters on engagement with the vulnerable sector. 
• Our Recommendation: Update policies to include appropriate interactions between staff/volunteers and the vulnerable sector outside of scheduled program time.

Are your polices up-to-date? Do your policies have any of these gaps? At Plan to Protect® we believe there is always room for improvement and we should collectively continue to strive for the Highest Standard of protection.

If you would like more information about how we can help you fix any of these gaps we would be happy to assist. Would you like to see how your policies measure up? Take our FREE online assessment here.