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Program Policies & COPPA

CONFIDENTIALITY POLICY

Big Brothers Big Sisters of El Paso respects the confidentiality of clients and volunteer records and, with the exception of situations listed below, shares information about clients and volunteers only among agency staff.

All records are considered the property of the agency and not the agency workers or clients or volunteers themselves. Records are not available for review by clients or volunteers. Information will not be released except in the following circumstances:

1. Information will be released to other individuals or non-BBBS organizations only with the client or volunteers written consent.

2. Identifying information regarding clients and volunteers may be used in agency publications or promotional materials unless the client or volunteer requests otherwise.

3. For the purpose of program evaluation, audit, or accreditation, and with prior approval of the Board of Directors, certain outside bodies such as Big Brothers Big Sisters of America may have access to client and volunteer records.

4. Members of the Board of Directors or evaluators appointed by the Board have access to client files upon authorization of the Board of Directors.

5. Information shall be provided to law enforcement officials or the courts pursuant to a valid and enforceable subpoena.

6. Information shall be provided to funders, fiscal agents, and/or partners.

7. Information shall be provided to an agency’s legal counsel in the event of litigation or potential litigation involving the agency.

8. State law mandates that suspected child abuse be reported to the appropriate authorities.

9. If an agency worker receives information indicating that a client or volunteer may be dangerous to himself or herself or to others, necessary steps may be taken to protect the appropriate party. This may include medical referral or report to the local law enforcement authorities.

10. At the time the child or volunteer is considered as a match candidate, information is shared between the prospective match parties. The information about the volunteer may include items such as: age, sex, race, religion, interest, hobbies, marriage, family status, sexual orientation, living situation, etc. Information about a client may include such items as age, sex, race, religion, interest, hobbies, family situations, etc.

COPPA PARENTAL CONSENT

Notice to Parents In compliance with the Children’s Online Privacy Protection Act (COPPA), parents (or legal guardians) of children under 13 years of age must consent to collections, uses and disclosures of the personal information of their children collected by Big Brothers Big Sisters of El Paso on Big Brothers Big Sisters of El Paso and Big Brothers Big Sisters NATIONAL websites, including bbbsep.org, bbbs.org, MatchForce (Salesforce), forms.bbbs.org, Form Assembly and formstack.io.

Your permission is required for the collection, use, or disclosure of your child’s personal information.

We will not grant your child access to any BBBS website account unless you provide us with permission. BBBS website and social media accounts provide access to BBBS content, materials, and resources relating to BBBS programs and activities.

PHOTO CONSENT AND RELEASE FORM

DIGITAL TECHNOLOGY AND SOCIAL NETWORKING POLICY

Big Brothers Big Sisters of El Paso, recognizes that online social networking (Snapchat, Facebook, MySpace, Twitter, LinkedIn, Blogs, etc.) has become a very popular communications tool and that many of our Big Brothers/Sisters and Little Brothers/Sisters use these websites. In general, personal use of social networking sites is typically for communications between peers, including friends and family. Not all social networking sites are designed to support mentoring relationships.

To protect our children and their families, we expect Volunteers, Parent/Guardian, and Child to adhere to the following BBBS affiliate Digital Technology and Social Networking Policy, to ALL guidelines defined by social media sites, and to ALL state and federal laws. BBBS affiliate reserves the right to monitor the social networking activities of Volunteers, and to request that a Volunteer delete inappropriate information from a social media site. If a Volunteer is seen using social networking in an excessively inappropriate manner, his or her relationship with BBBS could be terminated

Child Safety and Appropriate Social Networking

Child safety is our #1 priority. Volunteers choosing to engage in social media are expected to maintain an appropriate presence on social media, even if they are not “connected” with their Little through social media sites. Volunteers serve as role models for a child and the community.

• Volunteer should ensure that posts, tweets, photos and comments are appropriate and kid-friendly.

Confidentiality and Privacy

BBBS affiliate requires its Volunteers to respect the confidentiality and privacy of the children and families of Big Brothers Big Sisters in every respect, including social networking. This applies even if the Volunteer is not “connected” with their Little through social media sites. Volunteers must follow these requirements regarding confidentiality on their own and others’ social media sites.

• Written parental permission is required to post, share or tweet photos or videos of their Little. If parent consent is not given the Volunteer is prohibited from posting, sharing and/or tweeting any photos and/or videos of their Little.

• Volunteers should never post, share, tweet or tag their Little’s full name, location, city, address, school or other personal information such as where his/her parent/guardian works.

• Volunteers should not use geo-positioning applications when they are with their Little.

“Connecting” with Littles Through Social Networking

Volunteers may not initiate or accept an invitation to “connect” or “follow” his/her Little or member of the Little’s family on any social media site without written parental permission.

FIREARMS AND WEAPONS POLICY

Below is the Big Brothers Big Sisters of El Paso (BBBSEP) Firearms and Weapons policy:

1. Carrying a firearm and weapon while with your Little is not sanctioned by the agency and highly discouraged. BBBSEP explicitly prohibits all volunteers from carrying a firearm/weapon while participating in any BBBSEP activity including the match with a Little. BBBSEP explicitly prohibits volunteers from involving a Little in an activity that involves a dangerous weapon. Activities such as hunting, target shooting, paint ball games, or the use of BB or pellet guns are prohibited.

2. Volunteer will ensure that any weapons, firearms or ammunition are licensed, permitted, registered, and handled in accordance with all applicable state and federal laws.

3. Volunteers will inform BBBSEP of the ownership of any weapons or the presence of weapons in the home. BBBSEP staff will discuss the ownership of weapons during the volunteer’s interview and/or home assessment, and update that status for the life of the match. For purposes of this policy, “weapons” may include all firearms, handguns, zip guns, knives (except for kitchen knives and small pocket knives not used or intended for use as a weapon or to inflict bodily injury) and explosive devices.

4. Volunteers will ensure that weapons and ammunition are inaccessible to the child and to any other child participating in BBBSEP, while the child is under their supervision. The means of ensuring the inaccessibility will be discussed during the interview and/or home visit.

5. Volunteers will ensure that any firearms or weapons in their home will be stored with a trigger locking mechanism separately from its ammunition and keep both the ammunition and the firearm in a locked location inaccessible to their Little.

6. Volunteers will adhere to the policy that a volunteer will not carry a firearm at any time while accompanying the child assigned to them by BBBSEP or accompanying any other child participating in a BBBS activity.

7. Volunteers will understand that BBBSEP will disclose to the parent or guardian of the child assigned to you by BBBS the agency’s weapons policy and the volunteer’s admission of weapon ownership or the presence of a weapon in the home.

8. If the volunteer is a Law Enforcement Officer and required to carry a firearm at all times, it will be in their possession and inaccessible to their Little at all times while they are with their Little or accompanying any other child participating in a BBBS activity. The volunteer may be asked by BBBSEP to provide proof that they are a Law Enforcement Officer and permitted by state and federal laws to carry a firearm.

9. Volunteers will abide by any other policy or procedure that BBBSEP may put into effect regarding weapons.

ACKNOWLEDGMENT

I understand that if the volunteer violates the weapons policy, my child’s match is subject to immediate termination.

RELEASE OF LIABILITY: I, for myself and my heirs, administrators, successors and assigns, hereby release and discharge Big Brothers Big Sisters of El Paso and its directors, officers, agents employees, other volunteers, promoters, sponsors and advertisers (collectively referred to as “Releasees”) from and against any and all claims, liabilities or damages arising out of, or in connection with, my child’s participation, including any claims by, or on behalf of, me for injuries or property damage that my child may suffer during the course of, or that arise out of, my child’s participation in the Big Brothers Big Sisters program. I understand that participation creates a risk of injury and I expressly acknowledge and assume the risk of such injury. I further agree to indemnify, defend and hold harmless Releasees from any-third party suits, claims or actions arising out of, or relating to, my child’s participation in the Big Brothers Big Sisters program.

OVERNIGHT VISITS POLICY

BBBSA agencies must have a policy that prohibits overnight visits generally. Exceptions to this policy are permitted in cases where one of the following specific criteria have been met AND the required authorizations have been documented:

• There is genuine concern for the safety of a child returning to their own home (emergency circumstances).

OR

• An event is formally designated by the agency as one that (1) is of a nature to provide an exceptionally significant developmental or educational benefit to a child or youth and (2) that the event would not be possible without the Big accompanying the Little (a college visit for example).

Authorization of an exception to the policy prohibiting overnight visits may be made by the agency’s CEO/Executive Director after the following steps have been taken:

• Documented confirmation that the Big/Little relationship has been in place for at least one year

• Documented professional assessment of healthy relationship development between match parties with no violations of agency policy including code of conduct

• Documented pre-approval by a parent/guardian and professional staff with the exception of an emergency circumstance (see above)

• Documented plans for privacy in: sleeping, changing clothes, bathing/showering

• Documented consideration of reasonable alternatives

• Documented professional staff monitoring for any safety concerns following the event

Policy on Overnights

Big Brothers Big Sisters El Paso strictly prohibits overnights visits. At BBBSEP our priority is to establish, support and maintain healthy and safe one to one youth mentorship. An overnight is defined as an extended period of time when parties within the match would customarily be sleeping.

BBBSEP has a zero tolerance policy with any infraction of this policy and reserves the right to close the match if any participant does not follow the agreement.

Rare exceptions to this policy may be made by either the CEO, Executive VP, or Program Director in instances where:

• There is genuine concern for the safety of a youth returning to their own home (emergency circumstances).

OR

• An event is formally designated by the agency as one that (1) is of a nature to provide an exceptionally significant developmental or educational benefit to a child or youth and (2) that the event would not be possible without the Big accompanying the Little (a college visit for example).

Program Staff requesting an exception to the policy will complete and submit the pre-overnight form to the Executive VP or Program Director. The form will include a match assessment and documentation including:

• The Big/Little relationship has been in place for at least one year

• Documentation of a healthy relationship development between match parties with no violations of agency policy, including code of conduct

• Documentation of pre-approval by parents/guardian and professional staff with the exception of an emergent circumstance (see above)

• Document plans for privacy in: sleeping, changing clothes, bathing/showering

• Document consideration of reasonable alternatives

• Documentation of the timeline for the overnight visit

• Documentation of requirement for follow up within 48 hours of overnight visit completion with all parties of the match

Executive Vice President or Program Director will review the request and notify staff of overnight visit approval or denial.

TRANSPORTATION POLICY

1) Agency Staff document in the volunteer’s file verification of appropriate licensure and insurance held by the volunteer if they will be transporting the child;

2) Documentation of verification of appropriate licensure and insurance held by Agency Staff if they will be transporting children; and

3) Safety requirements in accordance with state law (e.g. seat belt use, car seat use, prohibitions on use of cell phone, alcohol or other drugs prior to driving a child).

Policy on Driver’s License, Insurance, Driving Record and Transporting Children

Big Brothers Big Sisters Lone Star obtains a copy of a valid driver’s license or valid government issued identification on all volunteers and staff members.

If the role of the volunteer includes traveling to a school/site-based program then BBBSEP requires the volunteer to have adequate transportation (own car).

If the role of the volunteer or staff member includes transporting a child then BBBSEP requires that the CB volunteer or staff member must have:

• An acceptable driving record

• Adequate transportation (own car)

• Valid driver’s license

• Proof of the minimum car insurance required by law.

Volunteers and staff are expected to abide by safety requirements in accordance with state law, including:

• Use of seat belt

• Use of car seat use

• Prohibitions on use of cell phone while driving

• No alcohol or drug use prior to driving a child

Documentation of receipt of a copy of the driver’s license and when necessary, a copy of insurance of a Big will be noted in the volunteer’s record.

Documentation of receipt of a copy of the driver’s license and when necessary, a copy of insurance of an agency staff member will be noted in the staff member’s file maintained by Human Resources.

Exceptions to a volunteer having their own car or having a valid driver’s license can be made when public transportation or other approved transportation has been approved by the Executive VP or Program Director.

All Volunteers and Agency Staff are required to abide by the following:

• Abide by Texas State Car Seat Laws

• Texas law now requires drivers and all passengers in vehicles to be secured by a safety belt.

• The following are prohibited:

• Use of alcohol or drugs that would impair driving prior to driving a child are prohibited.

• Use of alcohol or illicit drugs by Bigs in the presence of their Little (in any setting) is grounds for closure.

• Texting or talking on cell phone while driving

• The information regarding this policy is shared with Volunteers throughout the duration of their participation in the program or employment with BBBSEP