Youth Program Participant Protection Policy 

Purpose 

The National Federation of the Blind (NFB) understands the importance of protecting all individuals, especially minors, that participate in programs controlled by the national organization. This includes any program directly managed by a Federation employee or by a Federation leader with authorization to commit resources. These programs may take place at the NFB Jernigan Institute or other locations utilized by the program. This policy affirms our commitment to taking the necessary steps to provide a safe and secure environment for program participants.

Definitions

Youth program participants (participants): minors seventeen years of age or younger, and other vulnerable individuals (as defined by relevant laws and regulations) who participate in our programs and events.

Program workers (workers): volunteers (members and non-members), employees, and contractors who are directed by the program coordinator to interact with our youth program participants.

Program coordinator: the NFB staff lead or designated Federation leader who is responsible for the oversight and coordination of program workers and program-related activities.

Screening Program Workers 

Background Checks

All program workers will be screened in accordance with this policy prior to being eligible to serve. Screening will include at least the following:

  • An internal conflict review will be conducted by designated NFB staff to discover circumstances that would exclude a potential program worker from the program due to investigations or violations related to the organization’s code of conduct.
  • Criminal background checks will be conducted for all potential program workers after they’ve completed an application. The background checks will comply with applicable federal and state regulations governing programs. Applicants will not be considered for positions when checks show evidence of convictions for an offense involving children, violence, or any other conduct contrary to the mission of the NFB.

The NFB will use a well-known reputable third-party service to conduct a screening and criminal background check that allows the performance of monthly updates to the extent permitted by law. The information obtained will be stored on a secured server and only made accessible to authorized NFB personnel.

Personal Interview 

A personal interview will be conducted with the applicant by an NFB staff member or authorized designee to discuss the position and the applicant’s talents, qualifications, and abilities. Multiple and/or group interviews may be conducted as appropriate. Individuals who have previously passed NFB’s screening process may not be required by NFB to be personally interviewed again unless they have not worked in an NFB program for three or more years.

References 

All applicants must provide at least three references. References may be personal or professional and presented in written form or by providing phone and email contact information. All references will be confirmed by appropriate program workers and documented in the applicant’s file. At least one reference will be from a personal contact if available.

Training and Education 

In addition to specific training related to the particular goals and objectives of the program, all program workers will receive an orientation training that includes:

  • NFB Code of Conduct review
  • Anti-discrimination
  • Consent problem recognition and creating appropriate interventions
  • Mandatory reporting responsibilities
  • Emergency procedures

Program-worker trainings and orientations will be updated and refreshed each year.
The NFB will offer the training and orientation through workshops, programs, and the use of Braille, print, and/or audiovisual resources.

Supervision 

Supervision of youth program participants, programs, facilities, and program workers will be designed to protect program participants and program workers at all times. Practices to ensure a safe and caring environment will include:

  • A minimum of two program workers should be assigned to each program and program location.
  • Program workers will never be alone with an individual program participant where they are not observable by others.
  • Classroom doors should remain open unless there is a window in the door or a side window beside it. Doors should never be locked while persons are inside the room unless there are emergent safety needs or imminently threatening health demands.
  • There will be access to a telephone at all program locations during operating hours.
  • Program participants will never be left unsupervised.
  • Program workers will never release program participants to anyone other than the authorized parent(s), guardian(s), or an individual authorized by parents in writing or verified by phone.
  • Program workers will utilize constructive methods for maintaining group control and managing program participants’ behavior.
  • Program workers will appear and behave in a manner consistent with the mission and values of NFB at all times; including electronic, written, and verbal communications.

Parent/Guardian Communications 

The NFB will inform parents of our youth program participant protection strategies. All parents will be provided with a link to the current NFB Code of Conduct and a link to the current NFB Sexual Abuse and Molestation (SAM) policy.

Parents will be introduced to the program workers and will receive regular communication about the program’s content and schedules, as well as feedback regarding their child's participation in the program, including behavior and general health.

Parents or guardians will be allowed to observe the program as deemed appropriate by the program coordinator without disruption to the program.

Reporting Requirements 

For purposes of this policy, “child abuse” is any action (or lack of action) that endangers or harms a child’s physical, psychological, or emotional health and development. All NFB program workers are recognized as mandated reporters. The NFB will follow current regulations and guidelines for the reporting of abuse.

Categories of Abuse and Neglect

Some categories of child abuse and neglect are:

  • Physical: non-accidental physical injury inflicted by another person with the intent of hurting the child.
  • Sexual: when an adult uses a child for sexual stimulation or gratification.
  • Neglect: the negligent treatment, lack of treatment, or the maltreatment of a child by a person responsible for the child's welfare. There are two levels of neglect that must be reported: general and severe.
  • Willful harm or injury: harming, injuring, or endangering a child.
  • Unlawful corporal punishment: willfully inflicting unlawful corporal punishment on a child and resulting in a traumatic condition.
  • Abuse or neglect in out-of-home care: when a licensee, administrator, or employee of any facility licensed to care for children or an administrator or employee of a public or private school or other institution or agency physically, sexually, emotionally abuses, or neglects a child.
  • Grooming: the process used by an abuser to select a child, win the child’s trust (and the trust of the child’s parent or ‘gatekeeper’), manipulate the child into sexual activity, and keep the child from disclosing the abuse.

We recognize that sexual abusers groom children for abuse, thus, we ask all program workers to be aware of behaviors intended to groom a child for sexual abuse.  

Program workers will follow an internal chain of command for the reporting of abuse and may report directly to local authorities if appropriate.

If an incident of abuse or neglect is alleged to have occurred at or during NFB programs or activities, the following procedure shall be followed:

  • The parent or guardian of the child will be notified.
  • The appropriate authorities will be notified, consistent with local, state, and/or federal regulations.
  • The NFB will cooperate with any investigation of the incident by state or local authorities. In the event there is no investigation of the incident by state or local authorities, a management team will be formed to investigate the circumstances of the incident.
  • The alleged perpetrator of the abuse or misconduct will immediately be separated from the group, will be placed on leave from the NFB pending an investigation, and consequences will be administered which are consistent with the Federation’s policies and practices related to the Code of Conduct.
  • An incident report will be completed.
  • As deemed appropriate by the program coordinator and NFB Board of Directors, other program workers, participants, and families of participants will be notified of the incident and resulting actions taken.

Monitoring 

This policy will be reviewed and updated as needed by the National Federation of the Blind Board of Directors or its designee on an annual basis.

Adopted on June 20, 2023, by the National Federation of the Blind Board of Directors.