REPORTING POLICY
Every CLCR staff member and/or volunteer must report:
(1) violations of the Participant Safety Handbook,
(2) misconduct as defined in CLCR’s Athlete Protection Policy, and
(3) suspicions or allegations of child physical or sexual abuse.
As a matter of policy, CLCR does not investigate suspicions or allegations of child physical or sexual abuse or attempt to evaluate the credibility or validity of such allegations as a condition for reporting to the appropriate law enforcement authorities.
Reporting Child Physical or Sexual Abuse
Child Physical or Sexual Abuse
Staff members and/or volunteers at CLCR are required to report suspicions or allegations of child sexual abuse by a colleague or co-worker, to:
(1) their immediate supervisor,
(2) a CLCR board member/administrator,
(3) a member of CLCR’s Participant Safety Committee and,
(4) where applicable, appropriate law enforcement authorities.
Grooming
Because sexual abusers “groom” children for abuse – the process used by offenders to select a child, to win the child’s trust (and the trust of the child’s parent or guardian), to manipulate the child into sexual activity and to keep the child from disclosing abuse – it is possible that a staff member and/or volunteer may witness behavior intended to groom a child for sexual abuse. All questions or concerns related to inappropriate, suspicious or suspected grooming behavior should be directed to an immediate supervisor, a CLCR administrator or a member of the CLCR Participant Safety Committee.
Peer-to-Peer Sexual Abuse
Approximately 1/3 of all child sexual abuse occurs at the hands of other children and the obligation to report extends to peer-to-peer child sexual abuse. Whether or not a sexual interaction between children constitutes child sexual abuse turns on the existence of an aggressor, the age difference between the children, and/or whether there is an imbalance of power or intellectual capabilities. If you have any concerns that an interaction between children may constitute sexual abuse, report it to the appropriate law enforcement authorities and a CLCR supervisor, a CLCR administrator or a member of CLCR’s board or coach.
Reporting Misconduct and Policy Violations
If any staff member and/or volunteer receives an allegation or observes misconduct or other inappropriate behavior, such as grooming, that is not reportable to the appropriate law enforcement authorities, it is the responsibility of each staff member and/or volunteer to report their observations to:
(1) their immediate supervisor,
(2) a CLCR administrator or
(3) a member of CLCR’s board or coach.
CLCR also encourages member parents, athletes and other sport participants to communicate violations of CLCR’s Participant Safety Handbook and/or allegations and suspicions of child physical and sexual abuse to a CLCR administrator or member of CLCR’s Participant Safety Committee. Where applicable, parents may also report to the appropriate law enforcement authorities.
REPORTING PROCEDURE
To Whom to Report
Staff members and volunteers may report to any supervisor or CLCR administrator with whom they are comfortable sharing their concerns. You may also report to any member of its Participant Safety Committee, which includes the following three designated Incident Review Officials (IROs):
- Frank Gifford, CLCR President
- Ron Cotterill, CLCR Operations Manager/Coach
- Pam Miller, CLCR Coach and Board Member
A staff member and/or volunteer may, and in many cases must, report any allegation of child physical or sexual abuse to relevant law enforcement authorities.
How to Report
CLCR will take a report in the way that is most comfortable for the person initiating a report including an anonymous, in-person, verbal or written report. Regardless of how you choose to report, it is helpful to CLCR for individuals to provide, at a minimum, (1) the name of the complainant(s); (2) the type of misconduct alleged and the name(s) of the individual(s) alleged to have committed the misconduct.
Reporting Form
Individuals reporting child physical or sexual abuse or other misconduct may create an Incident Report. Information on this report will include:
- the name(s) of the complainant(s)
- the type of misconduct alleged
- the name(s) of the individual(s) alleged to have committed the misconduct
- the approximate dates the misconduct was committed
- the names of other individuals who might have information regarding the alleged misconduct
- a summary statement of the reasons to believe that misconduct has occurred
CLCR will withhold the complainant’s name on request, to the extent permitted by law.
CONFIDENTIALITY, ANONYMOUS REPORTING AND BAD-FAITH ALLEGATIONS
Confidentiality
To the extent permitted by law, and as appropriate, CLCR will keep confidential the complainant’s name on request, not make public the names of potential victims, the accused perpetrator or the people who made a report of child physical and sexual abuse to the authorities.
Anonymous Reporting
CLCR recognizes it can be difficult for an athlete, teammate, friend or family member to report an allegation of misconduct and strives to remove as many barriers to reporting as possible. Anonymous reports may be made without the formality of completing an Incident Report:
- by completing creation of an incident report without including their name
- by expressing concerns verbally to a CLCR administrator or a member of CLCR or coach
- through email, texts or notes left for a CLCR administrator or a member of CLCR or coach
However, anonymous reporting may make it difficult for CLCR to investigate or properly address allegations.
All suspicions of child physical or sexual abuse will be reported to the appropriate law enforcement authorities.
“Whistleblower” Protection
Regardless of outcome, CLCR will support the complainant(s) and his or her right to express concerns in good faith. CLCR will not encourage, allow or tolerate attempts from any individual to retaliate, punish, allow or in any way harm any individual(s) who reports a concern in good faith. Such actions against a complainant will be considered a violation of our Participant Safety Handbook and grounds for disciplinary action.
Bad-Faith Allegations
A report of abuse, misconduct or policy violations that is malicious, frivolous or made in bad faith is prohibited. Such reports will be considered a violation of our Participant Safety Handbook and grounds for disciplinary action. Depending on the nature of the allegation, a person making a malicious, frivolous or bad-faith report may also be subject to civil or criminal proceedings.
HOW REPORTS ARE HANDLED
Suspicions or Allegations of Child Physical or Sexual Abuse
Reporting to Law Enforcement and/or Child Protective Services
An independent investigation can harm youth and/or interfere with the legal investigative process. CLCR, its staff members and/or volunteers do not attempt to evaluate the credibility or validity of child physical or sexual abuse as a condition for reporting to appropriate law enforcement authorities. As necessary, however, CLCR may ask a few clarifying questions of the minor or person making the report to adequately report the suspicion or allegation to law enforcement authorities.
For mandatory reporting laws, visit www.childwelfare.gov.
Immediate Suspension or Termination
When an allegation of child physical or sexual abuse is made against a staff member, youth and/or volunteer, CLCR may immediately remove that individual from contact with any children in the program until the allegation has been investigated by an official agency. As necessary, CLCR may suspend or change the assignment of a staff member and/or volunteer.
In those cases where the Ted Stevens Act may apply, the accused individual will be offered a hearing. A hearing under the Ted Stevens Act will not necessarily affect CLCR’s ability to immediately suspend or terminate the accused individual from employment or performing services for organization.
A staff member or volunteer’s failure to report to a supervisor, a CLCR administrator or member of the Participant Safety Committee is a violation of this policy and grounds for termination of a staff member and/or dismissal of a volunteer.
Misconduct and Policy Violations
CLCR addresses internally alleged policy violations and misconduct – bullying, harassment, hazing, emotional, physical and sexual – that are not reportable under relevant state or federal law. Staff members and/or volunteer must report policy violations and misconduct to an immediate supervisor, CLCR administrator or member of CLCR’s Participant Safety Committee.
CLCR may also investigate allegations of child physical or sexual abuse that are reportable, if such investigation does not interfere with any ongoing criminal investigation or prosecution for abuse. Such allegations may include:
- Emotional abuse
- Abuse reported outside the relevant statutes of limitation
- Allegations of abuse that were reported to authorities, but: (a) legal authorities did not press criminal charges; (b) criminal charges were filed, but not pursued to trial; or (c) the alleged offender was acquitted at trial
NOTIFICATION
Following CLCR’s notice of a credible allegation that results in the removal of an employee, coach or other volunteer, CLCR may consider the circumstances in which it will notify other parents of athletes with whom the accused individual may have had contact. In CLCR’s discretion, as appropriate, and after consultation with counsel, CLCR may notify its staff members, contractors, volunteers, parents, and/or athletes of any allegation of child physical or sexual abuse or other criminal behavior that (1) law enforcement authorities are actively investigating; or (2) that CLCR is investigating internally. Advising others of an allegation may lead to additional reports of child physical or sexual abuse and other misconduct.