PSA

Prevention of Sexual Abuse (PSA)

Unaccompanied Children Sexual Abuse and Harassment Zero Tolerance Policy Training

All children in our care have the right to be free from sexual abuse and harassment

YouthCare aims to cultivate an environment for Unaccompanied Children residents that provides for their emotional and physical safety that strictly prohibits any staff member, grantee, contractor, or volunteer conduct that is abusive or neglectful of the youth in our care. YouthCare has a zero tolerance toward resident sexual abuse and sexual harassment.

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This Zero Tolerance policy aims to Prevent, Detect and Assess any action or omission that is considered as Sexual Abuse or Sexual Harassment under the Standards To Prevent, Detect, and Respond to Sexual Abuse and Sexual Harassment Involving Unaccompanied Children; Washington State residential services policies; Washington State Child Protective Services legislation; and Washington State criminal law codes.

Definitions

Unaccompanied Child (UC) means a child:

• (1) Who has no lawful immigration status in the United States;
• (2) Who has not attained 18 years of age; and
• (3) With respect to whom there is no parent or legal guardian in the United States or there is no parent or legal guardian in the United States available to provide care and physical custody.

Sexual Abuse under ORR

Sexual abuse of a UC by a staff member, grantee, contractor, or volunteer.

Sexual abuse of a UC by another UC

Sexual Abuse

Sexual Abuse of a minor by ANOTHER minor includes the following acts:

• The employment, use, persuasion, inducement, enticement, or coercion of a child to engage in, or assist another person to engage in, (2) or (3) below or the rape, molestation, prostitution, or other form of sexual exploitation of children, or incest with children;

• Actual or simulated sexual intercourse, including sexual contact in the manner of genital-genital, oral-genital, anal-genital, or oral-anal contact, whether between persons of the same or opposite sex;

• Intentional touching, either directly or through the clothing, of the genitalia, anus, groin, breast, inner thigh, or the buttocks of another person, excluding contact incidental to a physical altercation;

• Penetration of the anal or genital opening of another person, however slight, by a hand, finger, object, or other instrument; Bestiality; Masturbation; Lascivious exhibition of the genitals or pubic area of a person or animal; Sadistic or masochistic abuse; or Child pornography or child prostitution.

Sexual Abuse

...of a UC by a staff member, grantee, contractor, or volunteer.

Includes any of the following acts, with or without the consent of the UC:

• The employment, use, persuasion, inducement, enticement, or coercion of a child to engage in, or assist another person to engage in, (2) or (3) below or the rape, molestation, prostitution, or other form of sexual exploitation of children, or incest with children;

• Actual or simulated sexual intercourse, including sexual contact in the manner of genital-genital, oral-genital, anal-genital, or oral-anal contact, whether between persons of the same or opposite sex;

• Intentional touching, either directly or through the clothing, of the genitalia, anus, groin, breast, inner thigh, or the buttocks that is unrelated to official duties or where the staff member, grantee, contractor, or volunteer has the intent to abuse, arouse, or gratify sexual desire;
• Contact between the mouth and any body part where the staff member, grantee, contractor, or volunteer has the intent to abuse, arouse, or gratify sexual desire.

Sexual Abuse

... of a UC by a staff member, grantee, contractor, or volunteer.

Includes any of the following acts, with or without the consent of the UC:

• Any display by a staff member, grantee, contractor, or volunteer of his or her uncovered buttocks or breast in the presence of a child; Bestiality; Masturbation;

• Lascivious exhibition of the genitals or pubic area of a person or animal; Sadistic or masochistic abuse; Child pornography or child prostitution; or Voyeurism by a staff member, grantee, contractor, or volunteer

• Penetration of the anal or genital opening of another person, however slight, by a hand, finger, object, or other instrument that is unrelated to official duties or where the staff member, grantee, contractor, or volunteer has the intent to abuse, arouse, or gratify sexual desire;

• Any attempt, threat, or request by a staff member, grantee, contractor, or volunteer to engage in activities (1) through (5) above

Sexual Abuse

What DO I REPORT?

You must report touching as sexual abuse when...

“Lascivious exhibition of the genitals or pubic area”

What else should be reported as sexual abuse?

Opening of bathroom doors

Sexual Harassment

is a repeated behavior that is sexual in nature

Of a minor by an ADULT includes:

Of a minor by another MINOR includes:

• Repeated verbal comments,
• Gestures, phone calls, emails, texts social media messages, pictures sent or shown, or other electronic communication of a sexual nature to a child by a staff member, grantee, contractor, or volunteer, including demeaning references to gender,

• Sexually suggestive or derogatory comments about body or clothing, or obscene language or gestures.

• Repeated and unwelcome sexual advances
• Requests for sexual favors, or verbal comments,
• Gestures, phone calls, emails, texts, social media messages, pictures sent or shown, other electronic communication,
• Or actions of a derogatory or offensive sexual nature.

Examples

Innapropriate Sexual Behavior

Any other type of incident that is sexual in nature but does not fall under the definition of sexual abuse or sexual harassment.

*Examples:

• Minor A blowing kisses at another minor one.
• Minor drew a picture of a penis on his desk and laughed about it.

*These types of incidents must go on SA SIR and categorized as inappropriate sexual behavior

Code of Conduct Violation

Code of conduct violations should be reported on SA/SIRs unless the violation meets the definition of sexual abuse or sexual harassment.

All code of conduct violations should be sent to PSAC (Prevention of Sexual Abuse Coordinator)

Examples of Code of Conduct Violations

Voyeurism

Is an invasion of privacy of a child by a staff member, grantee, contractor, or volunteer for reasons unrelated to official duties. Examples include inappropriately viewing a child perform bodily functions or bathing; or requiring a child to expose his or her buttocks, genitals, or breasts; or recording images of all or part of a child’s naked body or part of a child performing bodily functions.

Neglect

Is considered as the violation of responsibilities to report or document abuse, and performs job responsibilities that may have contributed to an incident or retaliation of an UC. The omission for reporting the knowledge or the sustained suspicion of Sexual Abuse and Sexual Harassment of a UC under the previous definitions, YouthCare will take disciplinary action.

Examples

Prevention Strategies

Background Check

In accordance to ORR standards

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Trainings

• PSA training, refresher every 6 months
• Compliace Manager

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Applicants Screening

Is a key part of identifying qualified and safe staff.

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Prevention Strategies

Unannounced room checks

Adhering to the no-touch policy

Maintaining proper line-of-sight

Prevention Strategies

One-on-One Supervision

Casa will not use the Risk Assessment to place a client on one-on-one supervision unless there are exigent circumstances related to a threat to safety that require it to keep the client, other clients, or staff safe.

Casa will never involuntarily segregate clients solely because of their gender expression, sexual orientation, or gender identity. During the meetings with the Mental Health Therapist, the risk assessment will be updated to determine when the one-on-one supervision may be removed

If there is an exigent need, Casa will only place the client on one-on-one supervision until an alternative solution is established. During this time, the client will meet daily with the Mental Health Therapist.

Prevention Strategies

Basic Boundary Guidelines

Strong and healthy boundaries are important in keeping the minors in care safe.

YouthCare Boundary Guidelines

1. It is not appropriate, under any circumstances, to have sexual relations with current or former YouthCare clients. This activity is grounds for criminal prosecution and/or disciplinary action.
2. A youth’s connection to YouthCare is confidential for their entire lives.
3. Do not talk about the youth outside of professional conversations.
4. Do not tell one youth information about another youth such as “she’s not here” or “he went to the library” (depending on programs)

YouthCare Boundary Guidelines

• If you see a youth out in public, do not acknowledge or approach them. If they address you, you can reciprocate.

• Do not give youth rides or meet with them off-site.

• Outings with clients should be planned and approved by supervisors and occur during hours of regularly scheduled work in a public venue.

• Do not socialize with clients, including former clients.
• Do not confide in or disclose personal information to clients.

• They are not there to meet your needs. Use self-disclosure only when it is clearly related to therapeutic interest of clients. When in doubt, don’t self-disclose.

YouthCare Boundary Guideliness

• Do not talk about your social life (especially use of substances) with or in the presence of youth.
• Do not check your personal email in the presence of youth.
• Do not give youth money or gifts, or accept money or gifts from youth.
• Do not buy or bring food for clients without supervisor approval
• No smoking in the presence of youth.

• Do not store personal property for a young person. This puts both you and the young person at risk of theft or loss of property or accusations of theft or loss of property.
• Do not use affectionate nicknames to refer to youth. For example flaquito, gordito, flaca, gordi, gorda,negra/o, negrita/o etc.
• Do not become Facebook friends or be linked on other social media platforms.

• Do not give clients your phone number, address, or other contact/personal information even if they are primary clients. Only staff can call staff. Clients need to communicate through on-duty staff.
• Do not give clients the phone number, address, or other contact/personal information of any other staff. (Check with supervisor for specific program rules and exceptions).

Some boundaries "red flags"...

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Staff fails to hold a minor accountable for a rule infraction

01

Staff is in a middle of a personal Crisis

02

Staff does personal favors or shows favoritism for a particular minor

The minor knows personal things about the staff

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04

Increased personal and/or private conversations

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Staff has contact with minors at unusual times

Guidelines and Best Practices for Emotional and Physical Boundaries

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Avoiding Personal Opinions

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Avoiding Staff Splitting

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Maintaining Personal Boundaries

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Avoiding Favoritism and Inconsistency

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Avoiding inappropriate self-disclosure

Boundaries Quiz!

Question 1/5

Boundary quiz

1. The program knows that a recently arrived female client is pregnant. One night, the client tells a staff member that she is the only person the client trusts in the program and she requests the staff member’s advice. The client discloses she is struggling to decide to have the baby or to have an abortion. You overhear the staff member counseling her to have an abortion because she will have more opportunities in the U.S. Is this a boundary violation?

No

Yes

Question 2/5

Lorem ipsum quiz

A client gets a splinter in her finger and requests staff’s assistance in getting it out. You see the staff member assist her. Is this a boundary violation?

No

Yes

Question 3/5

Boundary quiz

A client shares with you that her father (in home country) is an angry person, drinks a lot, and often would yell at the client. For this example, assume that you (as the staff member) have a similar life experience and relationship with your own father. You believe that sharing this information will help the client to feel less alone and normalize her experience, so you share it. Is this a boundary violation?

No

Yes

Question 4/5

Boundary quiz

A staff tells a client not to share that the staff allowed them to do something against the rules... is this a boundary violation?

No

Yes

Question 5/5

Boundary quiz

You are at a store and you see a shirt that "you know" a client is going to like. You buy it, bring it to program and give it to the client.Is this a boundary violation?

No

Yes

Question 6/6

Boundary quiz

You overhear a staff telling clients the type of music that they like. You also hear the staff sharing they like to hike in their free time.Is this a boundary violation?

No

Yes

Signs of abuse

Accordingly to the National Childhood Traumatic Stress Center, the following may be signs of sexual abuse:

• Depression
• Not wanting to be alone
• Sexual knowledge inappropriate for the child's age

• Increase in nightmares
• Withdrawn behaviors
• Angry outbursts
• Anxiety
• Withdrawn behaviors

Signs of Abuse

"Although many children who have experienced sexual abuse show behavioral and emotional changes, many others do not. It is therefore critical to focus not only on detection, but on prevention and communication—by teaching children about body safety and healthy body boundaries, and by encouraging open communication about sexual matters."

Long Term Effects

"Research has repeatedly shown that child sexual abuse can have a very serious impact on physical and mental health, as well as later sexual adjustment. Depending on the severity of and number of traumas experienced, child sexual abuse can have wide-reaching and long-lasting effects. Those who have suffered multiple traumas and received little parental support may develop post-traumatic stress disorder, depression, and anxiety. Their ability to trust adults to take care of them may also be jeopardized."

Barriers to Reporting

Youth reluctance to report

Lack of staff training

Lack of youth education about reporting

Inadequate protocols

Unprofessional staff relationships

Awareness and Reporting

• Clients are informed about the Zero-Tolerance Policies upon entry to the program.
• Posters around the facilities, pamphlets in rooms, covered at weekly meetings, discussed in Risk Assessment with Mental Health Therapist every 30 days
• Emergency Phone in Casa Uno's game room and by the client's bathroom at Casa Dos

ORR Sexual Abuse Hotline

Consulates

Resources

Harborview Abuse and Trauma Center

CPS

Awareness and Reporting

• Clients are encouraged to report in whichever way they are most comfortable. They can also use the grievance box to report anonymously.
• Staff are required to report even the suspicion of sexual abuse, harassment, or inappropriate sexual behavior.

• Must report to Supervisor, CPS, and ORR via SIR.
• For Sexual Abuse, SIR must be forwarded to the FBI and the local police must be contacted in addition to the notifications above.

• For clients below 14, parents/guardians and their lawyers (KIND) must be contacted. Information from these calls is reported on the SA/SIR. If above 14, the client’s wishes to report or not will be followed, and their decision will be documented.

Awareness and Reporting

• Information following a report is shared on a need-to-know basis. This is in accordance with policy, and to protect the victim's welfare and for law enforcement and prosecutorial purposes.
• Within the program, any documentation related to a SA incident is password protected.

• If a staff member is accused of any of these behaviors, they will be placed on administrative leave while an investigation is conducted.
• Per ORR, the staff member may not return to work until CPS closes the investigation.

Awareness and Reporting

• Initial reporting via Sexual Abuse/SIR must be completed immediately.
• The specific timeline for reporting depends on the type of event. Specifically for incidents of sexual abuse the report must be submitted no later than 4 hours.
• For incidents of sexual harassment, inappropriate sexual behavior, and code of conduct violations reports must be made within 24 hours.
• Addendums should be created anytime there is new or updated information.
• Addendums must be completed within 24 hours of learning of new information.

Protection Against Retaliation

Anyone who reports is protected from retaliation.

For example the following may be monitored:

• Behavioral reports or SIRs
• Client housing or service changes
• Negative staff performance reviews
• Reassignments of staff

Healthy Reporting Culture

Staff youth are willing to report sexual abuse and harassment

Staff and youth trust the reporting and follow-up process

At Casa and YouthCare, we strive to create and maintain a healthy reporting culture. This means:

Staff know how to report allegations

Staff and youth are confident there will be no retaliation

Communication and interactions between staff and from staff to youth are respectful and professional

Pat Down Searches

YouthCare strictly prohibits any type pat-down search. We are a hands-off agency.

External Resources

Harborview Abuse and Trauma Center (HATC)

• Crisis Hotline 24/7: 206-744-1600 (English)
• Crisis Hotline 24/7: 206-744-1616 (Spanish)

HATC provide physical exams, advocacy, trauma-informed therapy, sexual abuse evaluations, and telephone consultation

King County Sexual Assault Center (KCSARC)

• 24/7 Crisis line: 888-99-VOICE

May provide victim and legal advocates, trauma therapy, case management, safety planning, legal support for immigration, and crisis response.

Responder Duties

Emotional Support

Contact Emergency

Acceptance

Preserve and protect

Separate people involved

Avoid Blame

Preserve Forensic evidence

Neutrality

Communicate

Cooperate with authorities

Set up forensic exam for the victim

Ask only what is needed

Priority: Safety

Sensitivity – LGBTQI

• Changes to a housing plan may be made based on the result of a sexual abuse/harassment incident, or based on their LGBTQI identity.
• Be aware that youth within the LGBTQI populations may have been targeted in COO for their sexual orientation. Situations that happen in program may be triggering, even if they do not rise to meet the definition of sexual abuse/harassment.

• It is required that we respond effectively and professionally to all children. Special emphasis is placed on children who identify as lesbian, gay, bisexual, transgender, questioning, or intersex (LGBTQI).
• Do not discuss a client’s sexual orientation in front of other clients.
• Ask which pronouns a client wishes to use, and ask if their pronoun can be used in front of other clients, or with their sponsor.

• Mental Health Therapists complete a risk assessment within 72 hours to assess if there are any heightened needs or precautions that need to be taken with a particular client. This information is updated every 30 days.

Sensitivity -Cultural Competency

• Be aware of potential language barriers – especially for youth who speak an indigenous language. Clients may be conversational in everyday Spanish, but could prefer an interpreter for more serious or difficult conversations.
• Always offer the client the use of a translator if they speak a language other than Spanish as their first language.

• Treatment for sexually transmitted diseases, or emergency contraception, can carry a stigma in Central America (for both religious and cultural reasons). Be aware that a client could express ambivalence to seeking medical treatment for this reason.

• Always offer validation and empathy when speaking with the youth regarding a difficult event.

• When holding discussions with the youth around sexual abuse or sexual harassment incidents be aware of the following:
• These are often a taboo topic in Central America. Clients may feel uncomfortable or ashamed. Emphasize their role as the victim/survivor. They are not the ones at fault.

• Sexual abuse/assault in COO is often a contributing factor when youth (especially females) decide to migrate to the U.S. Keep a youth’s potential trauma history in mind when discussing the event. Situations that happen in the program may be triggering for the client.

• The age range that Casa serves is 12-17 year old; however, the educational attainment is usually around 2nd-3rd grade. Keep this is mind when discussing events. Use vocabulary that the youth will understand.

Sensitivity -Cultural Competency

• Keep in mind that the youth is in a new country, with new laws, and a new culture. Youth will benefit from having policies and options explained in a variety of ways, across time. For example, educating the clients on the Zero Tolerance Policy at intake is not sufficient for them to process the information. For that reason, it is reviewed regularly with both the supervisor and therapist.
• Keep in mind that prior to the Casa program, the youth were in immigration detention. There may be a valid and warranted distrust of those in authority in the U.S. Keep in mind that trust and rapport-building take time.

Sensitivity

Be mindful of the client's emotional state when discussing the incident

Be mindful of gender dynamics.

Allow the client to take breaks as they need.

If the client becomes emotionally dysregulated offer the client cold water or hot tea. Allow the client to take a break.

Ask the client if there is a particular staff member they would like to have join the conversation.

Sensitivity, a general reminder...

Incidents that may not rise to the definition of sexual abuse, can still be extremely traumatic for our clients as they remind they of incidents from home country.

When discussing incidents, use the anatomically correct names for the genitals involved.

Honor and respect a client's self-identified sexual orientation and gender identity.

Be aware of the stigma associated with sexual abuse, especially for males, for those who identify as LGBTQ.

Remember never to discuss a client's reunification or legal case while discussing these incidents.

Remember to emphasize the client's role as the VICTIM and that they did nothing wrong.

Be mindful of body language and facial expressions.

Offer options (as appropriate).

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A QUIZZ!

Question 1/5

Quiz

1. Clients are playing soccer. One trips and falls into a girl and touches her breast. The victim reports that the other client fell on purpose just to touch her. Staff saw the incident and believe it to be an accident.

None

Sexual Abuse

Innapropriate Sexual Behavior

Sexual Harrasment

Question 2/5

Quiz

2. A client reports he believes a staff member is looking at his butt.

None

Sexual Abuse

Innapropriate Sexual Behavior

Sexual Harrasment

Question 3/5

Quiz

3. Two clients are reported to be in love and kissed on the lips

None

Sexual Abuse

Innapropriate Sexual Behavior

Sexual Harrasment

Question 4/5

Quiz

4. Two clients reported to be in love and kissed while touching each other's butts.

None

Sexual Abuse

Innapropriate Sexual Behavior

Sexual Harrasment

Question 5/5

Quiz

5. A client intentionally grabs a client's breasts while she walks by.

Innapropriate Sexual Behavior

Sexual Harrasment

None

Sexual Abuse

Question 6/6

Quiz

6. A client made a sexual comment to another client, this is the first time happening/reported.

None

Sexual Abuse

Sexual Harrasment

Innapropriate Sexual Behavior