Catholic Diocese of Arlington - OPCYP

9. SAFE ENVIRONMENT POLICIES

The Catholic Diocese of Arlington is committed to providing a safe environment for children within all diocesan activities and ministries.

The safety policies must be approved by the Pastor, implemented by the Director of Religious Education, and always include consideration for participants with special needs.

The Director of Religious Education must review these policies with catechists annually.

Definitions

Adult Volunteer

• Adult volunteers are defined as those 18 years of age or older and who are no longer in high school.
• Adult volunteers may not volunteer in their parish’s youth ministry program until they reach 21 years of age if they were a participant in its youth activities as a minor.
• Students who are in high school and have not reached their 18th birthday are to be treated as minors when participating in parish or diocesan activities.
• Adult volunteers are not counselors. Their response to situations and conversations by minors may have potential legal implications, and they should, therefore, know their boundaries. The role of an adult volunteer is limited to compassionate listening.
• For the purpose of this document, all instances denoting requirements and/or guidelines for “adult volunteer(s)” are also binding for all clergy and diocesan personnel.

Chaperone/Supervisor

• A Chaperone/Supervisor is defined as an adult volunteer that has been delegated by the appropriate staff person and has oversight or supervisory authority over youth at a particular event or activity.
• All Chaperones/Supervisors must be at least 18 years of age and no longer in high school.
• Chaperones may not volunteer in their parish’s youth ministry program until they reach 21-years-of- age if they were a participant in its youth activities as a minor.
• When determining the appropriate ratio of Chaperones/Supervisors to minors for activities, a husband and wife that have direct supervision over the same group of individuals only count as one Chaperone/Supervisor

Child

• For the purposes of this Code, “children,” “child,” “minor,” “youth,” or “young person” is defined to mean any person less than 18 years of age (has not marked the 18th birthday).

It is generally not permitted for minors to participate in programs for adults unless their parents are also present, nor for adults to participate (as participants, not leaders) in programs for minors. If a parish seeks an exemption in a particular instance, the Office of Child Protection should be contacted for guidance.

I. General Safety Policies

A. Important Telephone Numbers

During the faith formation sessions, the Director of Religious Education must have easy access to the contact information for Police, Fire, Ambulance, Poison Control, and Toxic Chemical Spill centers (or 911).

The Director of Religious Education must carry a cell phone at all times during faith formation and include these numbers in his/her contact list. If the Director of Religious Education does not have a cell phone, s/he will be provided one that will be owned by the parish. Its service plan is to be covered by the parish and used for ministry purposes only.

B. Safe Volunteers

Adults must be rated compliant by successfully completing the paperwork, background check, safe environment training (currently known as Virtus) training through the Diocese of Arlington.

All volunteers are responsible for the safety of child and youth participants and must follow the safety guidelines for children as previously established by the parish. All Adult “ongoing volunteers” (e.g., classroom catechists, youth ministry volunteers) should receive annual training for facility safety guidelines, behavioral expectations, and program policies and procedures. Compliance and training must be recorded in their records.

With direct supervision from adults, those under the age of 18 may volunteer (as assistants to adults) to work with children in faith formation programs. Those under the age of 18 must receive facility safety training, written behavioral expectations, and adequate training to meet the needs of the children being served. Those under the age of 18 may not be left alone with children, nor may they escort children out of the view of adults.

Adults with CPR and First Aid training must be identified and known to volunteers.

All Directors of Religious Education must maintain current CPR and First Aid training from the Red Cross; they are encouraged to have Medicine Administration Training; the parish is to cover the cost of all safety training.

Emergency protocol and evacuation procedures must be established and reviewed annually with all employees and volunteers and practiced in all faith formation programs with minors.

Office of Child Protection and Safety

The Office of Child Protection and Safety for the Diocese of Arlington provides programs to ensure a safe environment for children within the community of the Church. These programs include a comprehensive training program for employees, volunteers, parents and children; application procedures for persons working with children, including background checks; the monitoring of child and youth activities to ensure that all contact with young people is appropriate; and outreach and support programs for victims of child abuse and their families.

All employees and volunteers of the Diocese of Arlington with substantial contact with children are required to be in full compliance with the Policy on the Protection of Children/Young People and Prevention of Sexual Misconduct and/or Child Abuse. Information for the requirements of compliance is available on the diocesan website (https://www.arlingtondiocese.org/child-protection/) .

All clearances must be updated according to the Diocesan policy. It is the responsibility of the Director of Religious Education to keep records for each employee (contractor or volunteer) in the parish and school and to renew these background checks accordingly.

Anyone working with children may not begin their ministry until all clearances are obtained.

Code of Conduct

An important tool in creating safe environments for children is a uniform Code of Conduct. The purpose of this Code of Conduct is to make clear to clergy, employees, and volunteers that certain behaviors are unacceptable and to ensure proper monitoring where youth are present.

These guidelines apply to all diocesan, parish and Catholic school activities in the Diocese of Arlington where youth are present. All adults performing work, ministry, or volunteer service within the Diocese in Arlington are expected to follow these guidelines. Violations of these guidelines are a serious matter and will be investigated and resolved in accordance with diocesan policy.

The Code of Conduct for Personnel and Volunteers in the Diocese of Arlington is available on the Diocesan website.

Mandatory Reporting Laws

A mandatory reporter is any individual, including both paid (staff) and unpaid (volunteer), who has an integral part of a regularly scheduled program, activity, or service, and accepts responsibility for a child. Additionally, anyone who is supervised or managed by a mandated reporter is also a mandated reporter. A child is defined as an individual under the age of eighteen. To be clear, Directors of Religious Education, Lay Faith Formation Ministers (including Adult, Youth, etc.), Catechists (and classroom aides), Coaches, etc. are mandatory reporters.

If any issues or allegations of a legal nature arise with respect to a student, teacher, or other individual associated with a catechetical program, the Director of Religious Education should advise the Pastor immediately, and one or both should contact the diocesan Office of General Counsel as soon as practically possible.

Limited Controlled Access to the Religious Education Program for Parents Identified as Sexual Offenders

Parishes are to follow the guidelines developed by the Office for the Protection of Children/Young People regarding the presence of parents/guardians identified as sexual offenders.

C. Student Privacy

The Director of Religious Education or designated officials have the right to protect the health, welfare, and safety of parishioners against drugs, weapons, unauthorized publications, and other contraband materials.

The search of a child's person and/or personal property (e.g. bags, etc.) while on parish property or at parish activities may be conducted by the clergy, Director of Religious Education, or other designated officials. The search must have reasonable cause and be related to the parish rights in these regards. Searches of property should be done in the presence of another adult witness (e.g. catechist or parent), whenever possible. Searches of persons must be done in the presence of another adult witness.

The failure of a child to voluntarily submit to a search shall be presumptive evidence of the existence of contraband and grounds for appropriate disciplinary action.

D. Secure Entry (Buildings)

Every Religious Education Program will have secured entry and exit. An adult monitor will be stationed there during faith formation times for children, e.g., 15 minutes before class until the last child is picked up. No child is to be left unattended, including in a classroom.

Parents who fail to pick up their children in a timely manner must be telephoned. If contact cannot be made, the emergency contact is to be called. No child is to be left alone with one adult.

E. Classroom Attendance

For every class, catechists must take attendance.

Parents may either:

• drop off and pick up in the classroom, or
• when there is an unexpected absence, the parent must be notified.

Catechists must be notified of all authorized persons who will pick up each child (and also who is not authorized to pick up the child).

Suggestions:

• Verification of identification should be attained until the adult picking up the child is recognized by the catechist;
• A sign-in and sign-out page may be implemented.

F. Traffic/Pedestrian/Bus Safety

Adult monitors shall be assigned to ensure the safety of children and youth at drop-off and dismissal.

G. Orientation/Drills

Religious Education classes must offer an orientation of emergency procedures for all students at the beginning of the year; see Chapter 10 for Emergency Policies and Plans.

This student orientation should include:

• Evacuation of Building/Fire Drill (to an on-site location, e.g. parking lot), and
• Lock-down drill (in the building).

Catechists should be trained in:

• Evacuation of Building/Fire Drill (to an on-site location, e.g. parking lot), and
• Lock-down drill (in the building).
• Lock-out evacuation drills (to an off-site location designated for emergency pick-up). Note: This information must also be included in the Religious Education Handbook.

H. Inclement Weather Policy/Class Cancellations

Parish Religious Education Programs will follow the local school district for class and event cancellations. Weekend events may be made independently, and the decision rests with the Pastor of the parish. All class cancellations (for any reason) should be posted on parish/Religious Education voicemail and websites.

Parish Religious Education Program schedules should accommodate two inclement weather dates.

I. Discipline

In all areas of learning, discipline must be considered in the development of children. Discipline must be based on the Gospel message of Jesus. Discipline encourages and nourishes growth in self-discipline, responsibility for Catholic moral values, and loving respect for the rights of all persons. To achieve these ends, parents, catechists, and students work together to create a Catholic learning environment.

Each Director of Religious Education shall formulate a set of rules and regulations regarding discipline during faith formation programs consistent with Diocesan policies, guidelines, and regulations. These rules and regulations, after prior review and approval by the Pastor, shall be distributed annually in writing as part of the Student Code of Conduct. It may be included in the Parish Faith Formation Handbook. It must be signed by both the parent and the child, returned, and added to the student’s file.

The basic components include:

• Catechists have the right to teach. No student must be allowed to stop the catechist from teaching;
• Students have the right to learn. No student must be allowed to stop another student from learning.

Based upon the Catholic moral values and loving respect for others taught by Jesus, students will:

• Be honest and committed to integrity;
• Be respectful and courteous toward all teachers and adults;
• Refrain from harassment of any kind;
• Use appropriate language;
• Speak respectfully to and about others;
• Complete all assignments and participate fully in class;
• Respect all parish and personal property;
• Refrain from any deliberate disruption in the faith formation program;
• Adhere to the faith formation program’s cell phone policy;
• Comply with the internet acceptable use policy;
• Play only in parish playground areas with good sportsmanship and cooperation;
• Be present for all required activities unless officially excused by the Director of Religious Education;
• Adhere to the dress code;
• Not give or receive unauthorized assistance on tests, quizzes or assignments;
• Not leave parish grounds during the religious education sessions for any reason;
• Not bring to parish any real or toy knives, guns or any facsimiles thereof, sharp objects that may be used as a weapon, matches, lighters, laser devices, or sparklers (which may result in suspension or expulsion);
• Maintain and support others who maintain a safe and drug-free environment at the parish with the understanding that possession or distribution of alcohol, drugs, tobacco or any other substance that may be harmful or dangerous and forbidden will result in suspension or expulsion from the faith formation program;
• Not engage in any physical or verbal contact with another student which could be interpreted to be an inappropriate display of affection; such conduct is prohibited on parish grounds or at parish-sponsored activities; and
• At all times, whether at the parish or in the community, conduct themselves in a manner, which reflects the Catholic values and principles of the parish.

The classroom catechist should view well-prepared and well-conducted classes as the first step toward good classroom discipline. The classroom catechist should first manage the discipline problems of his/her classroom and should enlist the help of the Director of Religious Education only in cases involving serious or repeated misbehavior.

Whatever disciplinary action is taken must be deserved and appropriate to the offense. Disciplinary measures must not be excessive, arbitrary, inflict bodily harm, or intended to subject the student to ridicule or defamation. Corporal punishment is expressly forbidden, regardless of parental consent.

The decision to place one’s hands on a child for the purpose of restraint should only be made in situations where a child has become an imminent danger to himself or another person. Any means of restraint must not intentionally cause any harm, injury, or pain to the child. Restraint should not include any device or instruments as the means to restrain. Physical restraint should never be the first alternative to correcting a child’s behavior.

J. Retreats and Field Trips

Retreats and Field Trips may be planned to enhance the catechetical program and expand the religious experiences of the child.

A permission form signed by the child’s parent(s) or (parent with legal custody) or guardian(s) is obtained prior to the child’s participation in a field trip.

Each event must be adequately supervised.

Whenever possible, bus transportation should be used. The carrier must be listed on the Diocesan Vendor Insurance List. (See diocesan website for current list.)

If automobiles or vehicles of Church personnel, youth, or parents are utilized to transport children on field trips, the drivers or the vehicle owners must provide copies of current liability, medical, and uninsured motorist insurance coverage.

Overnight events, such as retreats and lock-ins, may be scheduled only with the permission of both the Pastor and the Director of Religious Education. These events must have adequate supervision, and all supervisors (even volunteers) must comply with policies established by the Office of Child Protection. Parents have the right to opt-out of overnight events, and a suitable alternative for faith formation requirements must be provided.

Planning overnight events must take into consideration the following policies:

• Any interaction between an adult and a youth may not be held within the sleeping quarters;
• Adults should not be alone with a child in a sleeping facility, restroom, dressing facility, or other closed room or isolated area that is inappropriate for a ministry relationship. If any adult volunteer must enter a sleeping area with young people, a second adult volunteer must be present;
• Under no circumstances shall an unrelated adult share a bed with a child. If an adult must stay in a hotel or other sleeping room with children, the adult must sleep in his or her own bed, using a rollaway, cot or other bedding materials if necessary;
• During overnight activities, Chaperones/Supervisors are responsible for establishing and enforcing a curfew;
• Chaperones/Supervisors must check rooms on a regular basis after curfew to ensure that young people are located within and remain in their rooms; and
• A Chaperone must be available and on-watch in a designated location throughout the night. This adult is also responsible for monitoring sleeping arrangements in which adults are also present with minors throughout the night.

K. Guidelines for Chaperones/Supervisors of Children at Group Activities

When sponsored programs occur off-campus, chaperones/supervisors will be provided information to review with all youth participants to help familiarize them with the program schedule and facility layout where event activities will take place.

All adults should ensure that young people understand important safety information.

A specific location must be designated where minors will be able to locate their chaperone or supervisor or where the group will meet at an agreed-upon time.

In planning for chaperons/supervisors of children at group activities, the following guides must be considered and implemented:

• Chaperones/Supervisors are responsible for reviewing the Diocese of Arlington Code of Conduct and all related guidelines;
• Two or more adult volunteers must be present for events involving children;
• In the event that a sufficient number of chaperones/supervisors are not available, the event must be canceled;
• The required minimum ratio for chaperones/supervisors to children for a day trip:

Preschool          1:4

Grades K–5      1:6

Grades 6–8      1:8

Grades 9–12    1:10;

• The required minimum ratio for chaperones/supervisors to children for events lasting more than 12 hours is 1:7;
• If there is only one adult volunteer driver to transport youth, at least two youth must always be present;
• Clothing must always be in keeping with modesty and Christian values;
• Young people will be assigned to a specific chaperone/supervisor who will monitor and supervise their behavior throughout the event or trip; and
• Both adults and youth are expected to attend activities with the entire group.

L. Medical Treatment during off-site Events and Activities

• For off-site events and activities, one of the adults must have Medical Administration Training certification (see General Safety above) if there is a child who needs medicine administered.
• Adults may not administer medication of any kind without authorized, written parental permission.
• Parental permission must be obtained, including a signed medical treatment form, before taking children to any activities off of the parish/school property or event location, even when students are delivered directly to the location.
• A copy of the parental permission and medical form for each young person is to be “in-hand” by a chaperone/supervisor for all off-site events. An additional copy is to remain at the parish along with a list of all participants at the event.
• A good faith effort should be made to provide the appropriate care or assistance to any ill or injured young person in a life-threatening emergency situation (§8.01-225 (A)(1), Code of the Commonwealth of Virginia).

M. Guidelines for Nurseries during Mass or Religious Education

While a nursery room for parents/caregivers to attend Mass/teach religious education falls under the Virginia Department of Social Service religious exemption, using the Department of Social Service’s ratio parameters is encouraged. The state ratio is one adult volunteer to every four children (1:4), when there are any children less than 2 years of age and 1:10 for ages 2–4. In order to maintain the religious exemption, parents must not leave Church property without their children at any time.

Every adult volunteer (age 18+) must be OPCYP compliant. If volunteers are under the age of 18, they should not be in a supervisory position in the nursery but should assist the adult volunteers. There should be no less than 3 adult volunteers at one time in the nursery, in case one adult volunteer needs to leave for any reason.

Consider whether the nursery will be equipped to handle diapering and bathroom breaks for the children. If not, let the parents know that they will be contacted (even during Mass) to come and assist their child.

Sign In/Sign Out procedures must be communicated to all parents using the nursery and be used consistently:

• A sign in and sign out page where the parent lists his/her name and a cell phone number, the child’s name, date and time signed-in, and time signed-out, as well as any allergy conditions of the child if food is present;
• Name tags must be provided for the children to be completed by the parent upon arrival (ideally two for each child - one for their front, and one for their back); and
• A matching system of some sort should be considered for use, where the parent receives a numbered card that matches the number on the child’s name tag. This will make sure the correct parent and child are matched at pick-up.

Parish Nursery Programs should have procedures on:

• How to contact parents during the Mass if he/she needs to return to the nursery if their child becomes ill or very upset;
• Snacks be offered (and handling allergens);
• Nursery rules for the children to follow (e.g., soft voices, no hitting, no running, etc.);
• An emergency plan, including an emergency evacuation plan. Let parents know where the designated meeting place would be in case of evacuation, and post the plan in the nursery;
• Childproofing the nursery; and
• Room maintenance and sanitation of surfaces and toys.

N. SPRED (Special Religious Development) Safety Guides

Recognizing that SPRED is a ministry to the most vulnerable population, safety and protection are primary elements. Specific measures to meet the spiritual and safety needs of SPRED participants and volunteers must be enforced.

The group leader and at least one additional volunteer must be aware of and must be able to follow all guidelines.

i. Safe Facilities for SPRED

The facilities used for SPRED must meet or exceed expected safety standards, designed to keep children and adults safe from physical injury, unauthorized entry or exit, or other harm. Therefore:

• Leaders must be proactive with accident prevention by conducting periodic facility safety inspections and identifying any hazards;
  • Volunteers must immediately report a problem with facility or safety standards to the parish staff;
  • A problematic situation must be handled proactively by the parish staff for the safety of all involved in the program;
  • Doors must be opened/locked at specific times to facilitate entry/exit by authorized persons;
  • Doors that lead to the exterior must be locked when not in use to prevent possible unauthorized entry/exit; and
  • The group leader or designee must maintain keys to doors while children are present.

ii. Guidelines for SPRED Safety

To reduce the risk of danger or abuse, and promote health and safety, these basic guidelines must be followed:

• All volunteers must complete written applications and receive training in safety guidelines, behavioral expectations, and program policies and procedures;
  • Adults with CPR and First Aid training must be identified and known to volunteers;
  • Emergency protocol and evacuation procedures must be established and reviewed monthly;
  • Emergency phone numbers must be posted and clearly visible in all rooms used by volunteers. The phones numbers should include emergency 911, non-emergency police, parish office, and rectory;
  • Behavior and safety expectations for children, youth, and adults, must be clearly defined;
  • Reports of injury, incidents, or accidents must be documented and kept on file;
  • Volunteers must wear identifying name badges while in the building;
  • Volunteers may keep cell phones on their person, with contact phone numbers available in the event of an emergency;
  • Conversations must be limited to essential information when children are present, in order to focus on the needs and behaviors of participants;
  • Children must be escorted in the hallways using positive control during all transitions or movements (visual or physical contact at all times);
  • Volunteers must have visual or physical awareness of children at all times;
  • Any distress or concerns with specific children must be identified and addressed by the religious education team and parents as soon as possible;
  • Parents must be informed as soon as possible of any behavioral incidents or problems acted out by their child; and
  • Physical restraint for the safety and best interest of a child may be used when necessary and must be conducted in accordance with diocesan guidelines (sensible restraint for the safety and best interest of the child).

II. Health and Medical Safety

All faith formation staff and volunteers must be aware of proper procedures in case of a medical emergency.

At least one person with current First Aid and CPR certification must be present during children’s faith formation programs.

In the event of a serious injury or medical emergency: Call 911 and provide the address.

• Identify the location (specific floor, classroom, etc.).
• Describe the medical emergency by stating what happened and the type of injury.
• Obtain or provide on-site first aid.
• Alert other employees/catechists (when appropriate) that an emergency is occurring.
• Designate an employee/catechist to meet the EMTs and show them where the injured person is located.
• Notify parents or guardians immediately. Siblings may be gathered for early dismissal if convenient for the parent in these situations.

A. Communicable Disease

Children excluded from regular school attendance should not participate in regular parish faith formation programs. Special accommodations must be sought.

B. Medical Conditions

Parents must inform the Director of Religious Education in writing if a medical condition prevents their child from participating in any activity, if their child has severe food allergies, or if any classroom instruction modifications must be accommodated (IEP/ISP).

The Director of Religious Education, in turn, must provide the classroom catechist with appropriate information. However, catechists are not to administer any medications, including over-the-counter products.

C. First Aid and Universal Precautions

First aid refers to the initial and reasonable care given in response to an illness, accident, or injury. Universal precautions refer to the avoidance of contact with another’s bodily fluids.

D. Accidents

The Director of Religious Education is notified immediately in case of an accident during a faith formation function.

Parents are notified of the accident or injury as soon as possible.

Basic first aid is administered when appropriate.

The Director of Religious Education must keep a written record of the circumstances of all accidents (e.g., date, time, injured party, immediate cause, involved parties, supervisory volunteer or staff, and treatment or action taken) if the child requires professional medical attention or if the severity of the incident warrants documentation. The written record is kept on file for the calendar year and may be placed in the student’s file.

E. Substance Abuse

The parish recognizes all federal, state, and local laws regarding the use of drugs and alcohol.

Participants in faith formation programs (child or adult) may not possess, use, transmit or be under the influence of drugs or alcohol on the parish grounds, activity bus, or at any parish related activity.

Any participant in a parish faith formation program who consumes, possesses, buys, or sells drugs or alcohol, or is suspected of such activities on parish property or at a parish-sponsored function shall be referred immediately to the Director of Religious Education for action.

In such cases, a witness ought to be present during the confrontation.

Parents must be notified, and when appropriate, the proper law enforcement agency is contacted.

The parish may recommend opportunities for guidance and counseling if desired by the parents.

F. Pandemic Response Plan for Influenza or Other Heath Crisis

Introduction:

This plan provides guidance to parents, students, employees and volunteers in the event normal faith formation activities are suspended due to a pandemic flu or other health-related crisis. A decision to implement this plan will be based on the best available information supplied by the appropriate federal, state, and local governmental agencies, and by the Diocese of Arlington in cooperation with the Office of Catholic Schools. This plan is intended to be fluid in nature and will be modified at the direction of the Episcopal Vicar of Faith Formation, to respond to the circumstances dictated by a particular health crisis.

Guidance to Directors of Religious Education:

• Communicate with catechists the appropriate strategies to prevent or reduce the spread of a virus. Instruct catechists to review these strategies with students (for example, covering sneeze or cough, hand washing, and telling parents or teacher of flu related symptoms). Send home instructions taught in class.
• Ensure that maintenance staff, catechists, and all employees are trained in infection control and disinfection procedures. Classrooms are to be cleaned after every session (tables, chairs, and surfaces used are to be wiped down with disinfectant).
• Identify students most vulnerable to a health crisis because of a compromised immune system or chronic illness. Encourage their families to homeschool during the pandemic.
• Maintaining in the classroom an adequate supply of materials (tissues, ant-bacterial wipes or hand sanitizer) to prevent the spread of a virus.
• Keep parents and catechists informed of relevant information supplied by Federal, state or local agencies and the Office of Faith Formation.
• Create a contingency plan for employee/volunteer absences. Identify substitute catechists and alternate procedures in support of essential operations.
• In the event of school closure:
  • Immediately activate the school emergency communications system to provide information on the closure. Notify other news agencies of the closure as appropriate and necessary;
  • Update the parish website to provide the most recent and relevant information to parents and the community relating to a school closure;
  • Establish a symptom free protocol for the return of students.
• In the event that Religious Education must be closed for an extended period of time:
  • The Director of Religious Education is to develop and maintain a contingency education plan. Provide a good learning atmosphere during the closure, taking into account the effects the crisis is having on students’ families;
  • Catechists are to prepare resources that can be supplied to parents and students by the most appropriate form of communication. These materials should include grade-appropriate lesson plans and devotions;
  • Maintain communication with catechists to ensure that a learning environment is provided that takes into account the nature and magnitude of the health crisis, offering support and assistance as needed;
  • Catechists may utilize appropriate learning tools (for example, educational websites, such as Google Classrooms, Meet, etc., and educational television channels, EWTN); follow the policies and guidelines for online education platforms (see Ch 8, D, I – p. 6, Ch 9, I, C,I, pp. 4-7ff)
  • Encourage catechists to communicate on a weekly basis with the parents on homework assignments or other learning activities, copying in the Director of Religious Education in all correspondence.
  • Ensure that the school is properly cleaned and disinfected prior to the resumption of any in-school activities; and,
  • Ensure parents know how they will receive communication for updates, and announcements of re-opening. Remind parents to continually monitor the parish website for updates, and to check email accounts.

III. Safe Communications and Technology

A. Safe Communications

Parish public relations deal with the communication of relevant materials to explain and interpret the policies and activities of the faith formation programs for such purposes as establishing and maintaining goodwill, inviting attention to the goals of faith formation, seeking parishioners' support, and gaining volunteers. Those to whom such communications need to be directed include the Pastor and clergy, the pastoral council, parents, and parishioners.

When feasible and with the approval of the Pastor, media releases may be made concerning the activities of the parish faith formation programs to the public at large.

i. Electronic Communication with Minors (up to and including age 17)

Permission of the parent must be obtained, in writing, in order for an adult to communicate with minors via telephone, cell phone, text messaging, e-mail, social networks, or other electronic means. The respective parish office (e.g., Youth Ministry, Religious Education) should be copied in on the communication, as well as the parent. Only ministry-related communications are appropriate.

ii. Online Educational Platforms

a. Privacy

Protecting Privacy

Parish Religious Education programs may find online education platforms and video conferencing capability to be useful and effective means for accomplishing instruction and maintaining/building community. Some educators have expressed concern about privacy (especially of minors) when these tools are used, a concern that comes from reports that the interest that tech companies have in data collection will compromise participant privacy.

Google for Education and Zoom Features

• Both platforms offer end-to-end encryption, with some exceptions
  • Calls to actual phones may not be encrypted if the telephone provider can’t provide that functionality
    • If a user is using a third-party add on, like special hardware in a conference room, the video might not be encrypted onto that hardware/application. This would be an unusual circumstance for WFH – Distance Learning
• Both platforms allow for
  • Controls over who can record video, so that only the organizer can start videos
    • Chat or audio only meetings
    • Participants in the meeting have control over their audio and video settings so they can choose to self-mute or not show video

Additional information relative to the mentioned platforms as well as other platforms can be found below.

FERPA and COPPA Compliance

Google and Meet offer FERPA and COPPA compliant security and have reasonable strong end-to-end encryption in place for security. They offer many settings that would allow end users to opt-out of participating in videos, and both platforms allow for recording meetings, which should be required in most situations. Security is only as strong as the user.

Google

• Meet and Hangouts are covered under the security policies as the rest of the GSuite, which is FERPA compliant.
  • GSuite administrators can set some security settings as default, such as only allowing meetings with members with a school email address. Good to keep participants inside the school, problematic if they want to use this platform with parents.
  • Google administrators can see chat and Hangout logs through the admin dashboard.

Zoom

The Diocese is exploring whether they are going to apply their FERPA standards to basic accounts opened by educators. They know which ones are educators’ accounts, which is how they unlock the accounts for unlimited meeting length. But right now, you have to assume they are applying Basic security standards to these accounts.

Zoom for Education

Zoom for Education has full FERPA and COPPA compliance. The problem is that it is unlikely any school has this; this is expensive.

• The platform allows for more security settings, including setting password for meeting, adding more encryption choices, etc.
  • Meeting organizers can dismiss individual participants from the meetings. Google Meet doesn’t have this control.

Summation

• Both platforms have a strong level of encryption
  • Only Google for Education accounts have stated FERPA/COPPA compliance.
  • Zoom’s documentation says it is compliant, but is vague about which account types that applies to
• Most of the compliance issues have to do with
  • Making sure that participants know they are being recorded
    • Have the right and ability to opt-out
    • Both platforms have this ability

In addition

Look at what other applications your teachers are using right now that have audio/video recording. There have been so many applications that are offering free upgraded version right now. Many of the Best Practices for Zoom, Meet, etc. would apply to these. 

These other applications might not be as secure as Zoom and Meet.

b. Online Education Platforms - Best Practices

There are best practices for these kinds of instructional and meeting uses that should be followed when using this technology.

When Setting up Conferences

The following procedures should be followed when setting up conferences with students and parents and can be adapted for different age groups as appropriate:

• Receive parent permission prior to scheduling any conference (keep a copy on file for the full school year)
  • Include parents in email communication and invite them to participate in the meeting itself, especially with younger children
  • The parish office of ministry (e.g. Faith Formation, Youth Ministry, etc.) is to be copied in on all email correspondence
  • Include a second teacher, aide or parent who is an adult (18+ years old) on the conference
  • Record the conference
• If you can’t record a conference do the following
  • Two adults must be on the conference
    • Take roll
    • Record start and end time

Conference Moderation - Settings

The following controls are available through the technology and should be used to moderate the conference:

• Disable “Join Before Host” so people can’t join and begin before you arrive
  • Disable “File Transfer” so there’s no malicious file sharing between computers
  • Disable “Allow Removed Participants to Rejoin” so removed/rejected attendees cannot come back in
  • Do not post the Zoom conference link in any public profile, website, link, etc.

Conference Moderation - Recording

• Best Practices for these platforms for our educators to use in every meeting to apply the strongest security possible.
  • Every session, at least as far as classroom meetings, should be recorded.
    • These recordings need to be stored where the parish can control them. (Particularly if a parent asks that the recording be deleted, within their rights under the applicable FERPA/COPPA rules.)
    • Recordings are published in a way that keeps the content private within the school/classroom. Teachers shouldn’t be posting content up on public YouTube channels, etc.
    • Parents should be aware when recordings happen and what their rights are as far as letting their students opt-out of live recordings.
    • Students should be reminded that recording from their end is expressly forbidden.
    • Monitoring and communicating with teachers about security issues will need to be ongoing.
    • Limit platform choices to one or two.

iii. Social Media

• Social Media is defined as any form of electronic communication through which a user creates, utilizes, accesses, retrieves, and/or visits online communities or systems to share information, ideas, personal messages, and other content.
  • Social Media encompasses, but is not limited to, all of the following: email, texting, chat rooms, instant messaging, social networks, video messaging, on-line message boards, gaming systems, landline and mobile telephones, online voice communications, etc.
  • In accordance with diocesan policy, as stated in 8.1 and 8.2 of the Information Security Policy, version 12 (for the full policy, see Diocesan website):

8.1 All information and messages that are created, sent, received or stored using diocesan communication assets are the sole property of the Diocese, and no user has any ownership interest or expectation of privacy in such communications. The Diocese retains the right, in its sole discretion, to review all information or communications sent, received, stored, or posted using Diocesan communication assets. The Diocese also retains the right to track Internet site, chat room, and newsgroup visits, as well as file downloads, for compliance with diocesan policies, and for other business reasons. The Diocese has the right to conduct such review without prior notice to the employee. The user consents to allow IS and CDA Management access to, and review of, all materials created, stored, sent or received, by the user through any CDA network or Internet connection. Employees may not intercept or disclose, or assist in intercepting or disclosing, electronic communications.

and

8.2 CDA retains the right to monitor the content of electronic communications. The content of electronic communications and the usage of electronic communications systems will be monitored to support operational, maintenance, auditing, security, investigative activities, and for other business reasons. IS staff will not review the content of an individual user’s communications out of personal curiosity or at the request of individuals who have not gone through the proper approval process. A report of misconduct is to be sent to the Chancellor or the Moderator of the Curia to have email messages or Internet activity reviewed or monitored. The Chancellor or Moderator of the Curia will authorize or deny monitoring. If authorized, the Chancellor or Moderator of the Curia will contact the IS Director to initiate the review/monitoring. The results will be returned to the Chancellor or the Moderator of the Curia.

a. Communication and Social Media Policy

• The responsibility for parish faith formation public relations rests ultimately with the Pastor.
  • Matters that concern public relations should first be brought to the attention of the Pastor. As circumstances suggest, other diocesan offices may be involved, principally the Office of Communications.

iv. General Guidelines for Social Media

The parish retains the right to discipline students for their actions, regardless of when or where they occur, when those actions negatively impact the parish’s image, reputation, and/or the safety and well-being of the Church community. This covers inappropriate behavior in cyberspace including but not limited to messages, chat room commentary, comments/pictures, postings on social networking sites, blogs, wikis, gaming chats, digital transmissions, and other technology-related social activity.

• All ministry social networks and communication should be open and transparent;
  • All clergy and employees must always identify themselves with the appropriate title in their username and/or profile;
  • Clergy/employee social media accounts are always to be presumed to be ministry accounts and thus to be open and transparent;
  • Personal social media accounts may not be used for ministry communication with minors;
  • Each ministry that communicates with minors should establish a dedicated account that is used exclusively for ministerial purposes and that may be accessed, monitored and used by more than one unrelated adult volunteer;
  • Use of social media communication for private one-on-one contact with minors is not permitted. In the rare event that these activities occur, the communication must be kept on file and at the organization location in an easily accessible format;
  • Written permission from their parent(s) or the legal guardian is necessary prior to any electronic communication with a minor that cannot be openly seen by the parents and unrelated adults;
  • All text-based communications sent to or received from young people must be copied to their parent(s) or the legal guardian or an additional adult volunteer. These communications must be kept on file and at the organization location in an easily accessible format;
  • Communication with minors via electronic means is to be restricted to the hours that are appropriate for a phone call to the residence, except in the event of an emergency or to communicate time-sensitive information;
  • The “tagging” of a minor in a picture or video is prohibited;
  • If an electronic photograph or video is posted on any ministry site, all names related to minors must be removed; and
  • Further advancements in technology may require periodic updates and addendums to this section of the Code of Conduct. The universal principles provided for above are to be applied prudently and judiciously in the event an update has not occurred.

B. Parish/School Technology

i. Educational Purpose and Appropriate Use

Technology may be used to enhance student learning (e.g., computers, online textbook supplementation resources, etc.). Students must not access social networking sites or gaming sites, except for educational purposes and under teacher supervision.

ii. Electronic and Mobile Devices, Cell/Smart Phones and Tablets

Users must adhere to the local parish religious education policy, as found in their handbook. If a particular mobile device is to be used for an educational purpose, the catechist will provide parameters for this use.

iii. Responsibilities for the Use of Parish Facilities for the Internet and Email

When using networks or computing resources of other organizations, students must observe the rules of that organization regarding such use.

• Users should not reveal their personal addresses or phone number(s), and shall not reveal the personal address or phone number(s) of others without their authorization/permission;
  • Users are reminded that electronic mail (e-mail) is not guaranteed to be private. Operators of the network/system have access to all mail. Messages relating to or in support of illegal activities may be reported to the authorities;
  • Catechists and students shall immediately notify the Director of Religious Education if they suspect that a security problem with the system and/or the Internet exists; and
  • Any attempt to log onto the Internet or the school’s network/system as a systems administrator, by someone other than the systems administrator, will result in loss of user privileges at the parish. Any user identified as a security risk by the parish administration/systems administrator due to a history of actual or suspected unauthorized access to other computer(s), network(s) or system(s) may be denied access to the parish’s computers, networks, and/or systems.

Examples of Unacceptable Use

Users are not permitted to:

• Use technology in sexting or cyber-bullying: to harass, threaten, deceive, intimidate, offend, embarrass, or annoy any individual;
  • Post, publish, or display any defamatory, inaccurate, violent, abusive profane or sexually-oriented material. Users must not use obscene, profane, lewd, vulgar, rude, or threatening language. Users must not knowingly or recklessly post false information about persons, students, staff, or any other organization;
  • Use a photograph, image, video, or likeness of any student or employee without expressed permission of the individual, individual’s parent, and the Director of Religious Education;
  • Attempt to circumvent system security;
  • Deliberately visit a site known for unacceptable material or any material that is not in support of educational objectives;
  • Violate license agreements, copy disks, CD-ROMs or other protected media;
  • Use technology for any illegal activity. Use of the Internet for commercial gains or profits is not allowed from an educational site;
  • Breach confidentiality obligations of parish or school employees;
  • Harm the goodwill and reputation of the parish or school employees; and
  • Transmit any material in violation of any local, state, or federal law, including copyrighted material, licensed material, and threatening or obscene material.

iv. Reporting

Users must immediately report damage or change to the parish or school’s hardware and/or software.

v. Administrative Rights

The Director of Religious Education has the right to monitor student use of all school equipment, including computers, computer accessed content, and social media. Social media refers to activities that integrate technology, telecommunications, and social interaction through the use of words, images, video, or audio tools. Examples include, but are not limited to, social websites, blogs, message boards, wikis, podcasts, image–video-sharing sites, live webcasting, and real-time communities. Because this is a constantly evolving area, this policy applies to all new social media platforms whether or not they are specifically mentioned in this policy.

vi. Policy Violations

Violation of the above policy will be dealt with by the Director of Religious Education. Violation of this policy may result in any or all of the following:

• Loss of use of the parish/school network, computers, and software including Internet access; and
  • Disciplinary action including, but not limited to, dismissal and/or legal action by the parish/school, civil authorities, or other involved parties.

C. Photography and Video Policy

Parental permission is necessary for the photographing or filming of Religious Education students. Without expressed written permission, photos and/or videos may not be taken of their child (individually or with others, including in a liturgical setting).

The Director of Religious Education is to obtain annual written permission for each student and keep it on file for the entire school year. Before taking pictures or videotaping students, the catechist must check that parental permission has been granted. The Director of Religious Education must include this form in the parish Faith Formation Handbook.

• Photographs/videos of single or specific children may not be taken without the knowledge and permission of a parent or guardian;
• Parental permission granted for the photographs or videos of minors must be done so in writing prior to the event and renewed each year;
• Adults may never take photographs of children while they are unclothed or dressing.
• Parental permission must be granted for the publishing of a minor’s name and done so in writing prior to publication and
• Copies of photographs must be readily available to parents and guardians immediately upon request.
• Photographs taken during Sacramental Celebrations may not be sold, but freely given.

D. Guidelines and Policies for Copyrighted Materials

Many materials on the internet are copyrighted; permission must be granted for use, and oftentimes fees must be paid. For example, photographs/videos from new stories, poems, blog entries, YouTube videos, etc. are often copyrighted. These materials must not be re-posted to parish websites or social media accounts without permission. Refrain from posting all materials from unknown sources.

Many religious images (e.g., paintings) are “public domain,” but the copies of the religious images are not. Photographs and electronic images of the art are owned and copyrighted.

If downloading materials, such as lesson plans or classroom materials (even for a fee), strictly follow the copyright and licensing regulations.

The following information is offered to assist religious educators in obeying copyright laws.

Fair Use

Fair Use is the right to use copyrighted materials in a reasonable manner without the consent of the author. This limitation permits teachers, librarians, researchers, scholars, and others to use copyrighted works without paying the copyright owner. What constitutes fair use is expressed in the form of guidelines rather than explicit rules. When determining whether the use made of a work in a particular case is a fair use, the factors to be considered include:

• The purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes;
• The nature of the copyrighted work, with special consideration given to the distinction between creative work and informational work;
• The amount and substantiality of the portion used in relation to the copyrighted work as a whole; and
• The effect of the use on the potential market or value of the copyrighted work.

i. Policy: Printed Matter (paper or electronic, e.g., Websites/social media)

A teacher may:

• make a single copy for use in scholarly research, or in teaching, or in preparation for teaching a class of the following:
  • a chapter from a book;
    • an article from a periodical or newspaper;
    • a short story, short essay or short poem, whether or not from a collected work;
    • a chart, graph, diagram, drawing, cartoon, or picture from a book, periodical or newspaper;
• make multiple copies for classroom use only, and not to exceed one per student in the class, of the following:
  • a complete poem, if less than 250 words and printed on not more than two pages;
    • an excerpt of fewer than 250 words from a longer poem;
    • a complete article, story or essay, if it is less than 2,500 words;
    • an excerpt of fewer than 1,000 words or 10% of the work, whichever is less, from prose;
    • one chart, graph, diagram, cartoon, or picture per book or periodical.
• A teacher may not:
  • make multiple copies for classroom use if the document has already been copied for another class in the same institution;
    • make multiple copies of a short poem, article, story, or essay from the same author more than once in a class term, or from the same collective work or periodical more than three times in a class term;
    • make multiple copies of works more than nine times in the same class term;
    • make a copy of works to take the place of an anthology or substitute for the purchase of books, reprints, or periodicals;
    • make a copy of "consumable" materials such as workbooks.

ii. Policy: Electronic Media

Any duplication or copying of copyrighted material is illegal. This would apply even to the making of an archival copy or transferring from one format to another.

Use of legally acquired copyrighted material (through purchase or rental) in classrooms or similar places of instruction as part of face-to-face teaching is allowed. The use must be directly related to the instructional program (e.g., a purchased video on the Sacraments may be used to teach a class).

A public performance license is required for all use of copyrighted materials for non- instructional purposes such as rewards, extended day programs, during assemblies, or any showing via closed circuit. However, schools do not need a license to use copyrighted materials for "face-to-face" instruction, i.e., when a movie is related to the subject being taught.

Building library/copyrighted collections through contributions or purchase of illegally copied material is a violation of the copyright law, and therefore, illegal.

Electronic media made for educational purposes from TV programs may be kept for 45 days only. During the first ten days, a teacher may use the copy once in a day and one more, if needed, for review. For the remaining thirty-five days, teachers may use the copy for evaluation purposes only.

iii. Policy: Computer Software

Copying computer programs is generally illegal unless permission to make copies is included in the purchase or rental agreement. The owner of the computer program has the right to copy if, and only if, (1) such a copy is "an essential step in the utilization of the program in conjunction with a machine," or (2) the copy is for archival purposes only, i.e., to serve as a back-up in case the original is lost or destroyed.

A license is generally needed to multiple load one disk into many machines.

It is generally a violation of the copyright law to download a program to a number of computers through a networking system unless you have a network license for that software.