(As approved by the Parish Committee, 14 August 2024)

To protect Children (and its singular “Child,” defined herein to mean all persons under the age of 18) participating in First Parish of Cohasset, including through its wholly owned nursery school, Carriage House Nursery School (“CHNS”) (herein together referred to as “First Parish”) by providing our staff and volunteers with policies to guide their conduct. These policies will also give staff and volunteers knowledge needed to interact carefully and safely with children in our programs.

Policy 1: Prohibiting the Abuse or Mistreatment of Children.

First Parish will not tolerate the mistreatment or abuse of Children in its programs. Abuse includes, but is not limited to, the following types:

• Physical abuse – injury that is intentionally inflicted upon a Child.
• Sexual abuse – any contact of a sexual nature that occurs between a Child and an adult or between two Children. This includes any activity which is meant to arouse or gratify the sexual desires of the adult or the other Child.
• Emotional abuse – Mental or emotional injury to a Child that results in an observable and material impairment in the Child’s growth, development, or psychological functioning.
• Neglect – Failure to provide for a Child’s basic needs or the failure to protect a Child from harm.

Any mistreatment or abuse by a staff member or a volunteer will result in disciplinary action, up to and including termination of employment or volunteer service.

Policy 2: Prohibiting the Abuse or Mistreatment of One Child by Another Child

First Parish is committed to providing all Children with a safe environment. First Parish will not tolerate the mistreatment or abuse of one Child by another Child.

In addition, First Parish will not tolerate any behavior that is classified under the definition of bullying, and to the extent that such actions are disruptive, we will take steps needed to eliminate such behavior.

Bullying is aggressive behavior that is intentional, is repeated over time, and involves an imbalance of power or strength. Bullying can take on various forms, including:

• Physical bullying – when one person engages in physical force against another person, such as by hitting, punching, pushing, kicking, pinching, or restraining another.
• Verbal bullying – when someone uses their words to hurt another, such as by belittling or calling another hurtful names.
• Nonverbal or relational bullying – when one person manipulates a relationship or desired relationship to harm another person. This includes social exclusion, friendship manipulation, or gossip. This type of bullying also includes intimidating another person by using gestures.
• Cyberbullying – the intentional and overt act of aggression toward another person by way of any technological tool, such as email, instant messages, text messages, digital pictures or images, or website postings (including blogs). Cyberbullying can involve:
• Sending mean, vulgar, or threatening messages or images;
• Posting sensitive, private information about another person;
• Pretending to be someone else in order to make that person look bad; and
• Intentionally excluding someone from an online group;
• Hazing – an activity expected of someone joining or participating in a group that humiliates, degrades, abuses, or endangers that person regardless of that person’s willingness to participate.
• Sexualized bullying – when bullying involves behaviors that are sexual in nature. Examples of sexualized bullying behaviors include sexting, bullying that involves exposure of private body parts, and verbal bullying involving sexualized language or innuendos.

Anyone who sees an act of bullying, and who then encourages it, is engaging in bullying. This policy applies to all Children participating in First Parish, staff and volunteers.

Policy 3: Annual Review of Child Abuse Prevention Policies

First Parish will annually review all child abuse prevention policies for relevance and will modify or rescind as appropriate. All staff will be notified no later than the next available annual training session of any changes.

Policy 4: Defining Appropriate and Inappropriate Physical Contact

First Parish’s physical contact policy promotes a positive, nurturing environment while protecting Children and staff. First Parish encourages appropriate physical contact with Children and prohibits inappropriate displays of physical contact. Any inappropriate physical contact by staff towards Children in the organizations’ programs will result in disciplinary action, up to and including termination of employment.

First Parish’s policies for appropriate and inappropriate physical interactions are:

Appropriate Physical Interactions

• Side hugs
• Shoulder-to-shoulder or “temple” hugs
• Pats on the shoulder or back
• Handshakes
• High-fives and hand slapping
• Verbal praise
• Pats on the head when culturally appropriate
• Touching hand, shoulder, and arms
• Arms around shoulders
• Holding hands (with young children in escorting situations)

Inappropriate Physical Interactions

• Full-frontal hugs*
• Kisses
• Showing affection in isolated area
• Lap sitting*
• Wrestling
• Piggyback rides
• Tickling
• Allowing a Child to cling to an employee’s or volunteer’s leg
• Any type of massage given by or to a Child
• Any form of affection that is unwanted by the Child or the staff or volunteer
• Compliments relating to physique or body development
• Touching bottom, chest, or genital areas.

*Except as might be expressly permitted under separate CHNS policy.

Policy 5: Defining Appropriate and Inappropriate Verbal Interactions

Staff and volunteers are prohibited from speaking to Children in a way that is or could be construed by any observer, as harsh, coercive, threatening, intimidating, shaming, derogatory, demeaning, or humiliating.

Staff and volunteers must not initiate sexually oriented conversations with Children, except in the context of an established curriculum. Staff and volunteers are not permitted to discuss their own sexual activities with Children.

First Parish’s policies for appropriate and inappropriate verbal interactions are:

Appropriate Verbal Interactions

• Positive reinforcement
• Appropriate jokes
• Encouragement
• Praise

Inappropriate Verbal Interactions

• Name-calling
• Discussing sexual encounters or in any way involving Children in the personal problems or issues of staff and volunteers
• Secrets
• Cursing
• Off-color or sexual jokes
• Shaming
• Belittling
• Derogatory remarks
• Harsh language that may frighten, threaten, or humiliate Children
• Derogatory remarks about the Child or his/her/their family

Policy 6: Managing the Risk When One Staff Member Is Alone with One Child

It is First Parish policy that staff and volunteers should generally not have one-on-one interaction with Children. However, In those situations where one-on-one interactions are approved, staff and volunteers should observe the following additional guidelines to manage the risk of abuse or false allegations of abuse:

Additional Guidelines for One-on-One Interactions

• When meeting one-on-one with a Child, always do so in a public place where you are in full view of others
• Avoid physical affection that can be misinterpreted.  Limit affection to pats on the shoulder, high-fives, and handshakes
• If meeting in a room or office, leave the door open or move to an area that can be easily observed by others passing by
• Inform other staff and volunteers that you are alone with a Child and ask them to randomly drop in
• Document and immediately report any unusual incidents, including disclosures of abuse or maltreatment behavior problems, and how they were handled, injuries, or any interactions.

Tutoring/Private Coaching

One-on-one situations, such as tutoring and private coaching sessions, introduce additional risks for false allegations. Staff and volunteers should be aware of our policies regarding tutoring and private coaching:

1. Staff and volunteers must have supervisor approval for any tutoring or private coaching sessions.
2. Tutoring and coaching sessions with First Parish’s Children may not occur outside of the organization.
3. Supervisors must keep a schedule of private tutoring and coaching sessions, which should include times, Children involved, and location of sessions.

Policy 7: Managing Interactions Between Staff and Children Outside of Regularly Scheduled Program Activities

Many cases of organizational abuse occur off-site and outside of regularly scheduled activities. This contact outside of regularly scheduled activities may put staff, volunteers, and First Parish at increased risk.

First Parish strongly recommends that staff and volunteers do not have outside contact with Children from the organization. However, if off-site contacts are unavoidable, First Parish has determined that the following forms of outside contact are appropriate and inappropriate:

Appropriate Outside Contact

• Taking groups of Children on an outing
• Attending sporting activities with groups of Children
• Attending functions at a Children’s home, with parents present
• Other functions approved by the staff or volunteer’s supervisor

Inappropriate Outside Contact

• Taking one Child on an outing without the parents’ written permission
• Visiting one Child in the Child’s home, without a parent present
• Entertaining one Child in the home of staff or volunteers
• A lone Child spending the night with staff or volunteers

In addition, when outside contact is unavoidable, ensure that the following steps are followed:

1. Supervisors should identify for staff and volunteers what types of outside contact are appropriate and inappropriate.
2. Ensure that staff or volunteers have the parents’ permission to engage in outside contact with the Child.  Consider requiring the parents to sign a release-of-liability statement.

Policy 8: Governing Electronic Communications Between Staff and Children

Any private electronic communication between staff and Children, including the use of social networking websites like – Facebook, Instagram, Snapchat, instant messaging, texting, etc. is prohibited.

All communication between staff and Children must be transparent.  The following are examples of appropriate and inappropriate electronic communication:

Appropriate Electronic Communication

• Sending and replying to emails and text messages from Children ONLY when copying in a supervisor or the Child’s parent
• Communicating through “organization group pages” on Facebook or other approved public forums
• “Private” profiles for staff and volunteers which Children cannot access

Inappropriate Electronic Communication

• Harsh, coercive, threatening, intimidating, shaming, derogatory demeaning or humiliating comments
• Sexually oriented conversations
• Private messages between staff and volunteers with Children
• Posting pictures of organization participants on social media sites
• Posting inappropriate comments on pictures
• “Friending” participants on social networking sites

In addition, provide this information to the Children’s  parents so that they know what is appropriate and inappropriate from staff and volunteers.

Policy 9: Addressing Staff Cell Phone Use During Program Hours

While assigned to work with Children, staff and volunteers are not permitted* to use electronic communications devices except during approved breaks and emergency situations. Internet use, text messaging and/or emailing pictures while assigned to work with Children is strictly prohibited regardless of the type of device used and whether for business or personal reasons. Employees need to ensure that friends and family members are aware of this policy.

Use of personal electronic communication devices to contact (via voice, text, or pictures/video) organization members and/or program participants for inappropriate reasons shall be grounds for discipline up to and including termination of employment.

*Except as might be expressly permitted under separate CHNS policy.

Acceptable Use of Cell Phones During Program Hours

There are occasions in which staff will need to use personal or organizational issued electronic communication devices.  In these cases, staff will have explicit direction from supervisors governing use.  Situations which may require use of organizational issued or personal electronic communication devices include:

1. Field Trips
2. Off-site Programs
3. Emergencies

Policy 10: Every Allegation of Abuse Taken Seriously and There Is Cooperation with Authorities

All reports of suspicious or inappropriate behavior with Children or allegation of abuse will be taken seriously. The First Parish will fully cooperate with authorities if allegations of abuse are made and investigated.

Policy 11: Mandatory Reporting Requirements

Staff should be trained to be aware of and understand their legal and ethical obligation to recognize and report suspicions of mistreatment and abuse. Staff will:

1. Be familiar with the symptoms of child abuse and neglect, including physical, sexual, verbal, and emotional abuse;
2. Know and follow organization policies and procedures that protect Children against abuse;
3. Report suspected child abuse or neglect to the appropriate authorities as required by state mandated reporter laws as soon as possible, in no event later than 24 hours; and
4. Follow up to ensure that appropriate action has been taken.

Policy 12: Criminal Background Checks – Employees

Because we are a Child-serving organization and the safety of children is of the utmost importance, First Parish requires a criminal background check for all full-time, part-time and temporary employees** upon hire, once a conditional offer of employment has been extended. Thereafter these employees will receive the screening every other year. These criminal background checks will be conducted in accordance with applicable law.

First Parish shall ask applicants and employees to complete a Criminal Offender Record Information (“CORI”) consent* form authorizing it to conduct a criminal background check. Applicants and employees are required to complete the authorization as a condition of continued consideration for a position or continued employment with First Parish.

A criminal record will not automatically disqualify an applicant from employment or an employee from continued employment with First Parish. A variety of factors, such as the nature of the conviction, the relevance of the crime to the position, and the time that has elapsed since the conviction, will be taken in consideration.

If an applicant attempts to withhold information or falsify information pertaining to previous convictions, the applicant will be disqualified from further employment consideration with First Parish due to falsification of an application.

An offer of employment may be extended to an applicant prior to the completion of the criminal background check. However, the applicant’s first day of work in the position cannot begin prior to the satisfactory completion of the criminal background check.

**Excludes temporary employees represented by an agency. All employees responsible for contracting with temporary employee agencies shall ensure that the contract requires that a criminal background check has been completed on the temporary employee within the last two years prior to the temporary employee beginning work with First Parish.

Policy 13: Criminal Background Checks – Volunteers

Volunteers working directly with Children will be required to have passed a CORI check prior to participating in the program. The term “Volunteers” in this instance does not include those who come in contact with Children in a public location for a limited period of time, as long as First Parish approved safeguards are in place for ensuring these individuals are never left alone with Children.

Policy 14: Child Abuse Prevention Training

First Parish requires all First Parish employees take certain child abuse awareness and prevention training within 30 days of hire. First Parish may require additional child abuse prevention and reporting training of some or all staff from time to time.  Refusal or failure to take such training shall lead to disciplinary action up to termination of employment.

Policy 15: Massachusetts Requirements

Anything in the previous policies notwithstanding, the following Massachusetts mandated requirements shall apply to CHNS:

1. All staff are mandated reporters to the Commonwealth of Massachusetts.
2. Reports are to be made to the Department of Children and Families (“DCF”) by phone to 1-781-331-6600, or such other number as DCF shall specify.
3. All staff must be instructed in the signs of child abuse as listed by DCF.
4. Staff will document suspected child abuse, consult the DCF information and the Director of CHNS (the “Director”) for assistance.
5. The Director will notify DCF of such filing within 48 hours of any suspected abuse or neglect.
6. The Director will notify the Massachusetts Department of Early Education and Care (“DEEC”) immediately of any suspected abuse or neglect made against any staff member.

In the event staff is involved in abuse, the Director will remove said staff from having any contact with Children, contact the CHNS Advisory Board immediately, and file any necessary paperwork with DEEC immediately. The Director will cooperate fully in all investigations involving abuse and/or neglect by a staff member. All staff are made aware of these policies through their inclusion in the Employee Handbook.