Community Standards & Policies

Abuse & Molestation Prevention and Response Policy

Organization: The Tactical Reintegration Project

Effective Date: January 1st, 2026
Approved By: The TRP Board & All its Executive Directors
Applies To: All employees, volunteers, interns, contractors, board members, and third‑party program partners (“Member Personnel”)
Reviewed/Updated: [02/25/2026] (at least annually)

1) Purpose & Commitment

The Tactical Reintegration Project (“The TRP”) maintains a zero‑tolerancepolicy for abuse, neglect, or exploitation of any program participant, client, or beneficiary—especially children, youth, and vulnerable adults. We prioritize prevention, swift reporting, coordination with authorities, fair investigations, and appropriate corrective action, including suspension or termination, to protect those we serve and uphold our mission and legal/ethical obligations.

2) Scope

This policy applies to all programs, activities, events, and services operated or sponsored by the Organization, whether on‑site, off‑site, in transit, or virtual/online, and to all Personnel regardless of role or tenure.

3) Definitions

• Abuse: Physical, sexual, emotional/psychological harm; neglect; financial exploitation; grooming; and any conduct that places a participant at risk of harm.
• Sexual Abuse/Molestation: Any sexual contact/activity with a minor or vulnerable person; non‑contact sexual acts (e.g., exposure, pornography, voyeurism); grooming; boundary violations (e.g., excessive one‑on‑one time, secret communications).
• Neglect: Failure to provide necessary care or supervision.
• Vulnerable Person: A minor (under the age of majority) or adult with physical, mental, or cognitive limitations.

4) Roles & Responsibilities

• Board/Executive Leadership: Approves policy; ensures resources, oversight, and annual review.
• Program Leadership: Implements training, supervision, staffing plans, reporting culture, and environment design.
• Supervisors/Managers: Enforce policy, monitor compliance, ensure mandatory reporting, and coordinate response.
• All TRP Board Personnel: Complete training; maintain boundaries; report concerns immediately; cooperate in investigations.
• All TRP Member Personnel: Maintain boundaries; adhere to community code of conduct, report concerns immediately; cooperate in investigations.
• Designated Safeguarding Lead (“DSL”)/Compliance Officer: Central point for internal coordination, documentation, and insurer/regulatory interactions
• TRP Member Management Committee: Administers pre-membership/ Volunteer screening interviews, administers corrective actions, and handles volunteer relations.
• Risk/Insurance Contact: Notifies insurance broker/insurer per-policy conditions and preserves evidence.

5) Prevention Measures

5.1 Safe Recruitment & Screening

• Applications & Interviews tailored to roles working with minors/vulnerable adults.
• Background Checks appropriate to jurisdiction and role in organization (e.g., CORI/SORI or equivalent, sex offender registry, reference checks) before start.
• Document and retain screening outcomes; re‑check eligibility if concerns arise.

5.2 Training & Acknowledgments

• Initial and annual training for all Personnel on:
  • Recognizing indicators of abuse, grooming, and boundary violations
  • Mandatory reporting obligations and procedures
  • Supervision protocols and ratios
  • Digital safety and social media boundaries
  • Transportation and off‑site supervision
• Written Policy Acknowledgment collected at onboarding and annually.

5.3 Supervision, Ratios & Environment

• Enforce two‑adult rule where feasible; avoid isolated one‑on‑one situations; maintain open/visible environments (windows in doors, no covered windows, open‑door offices).
• Maintain age/setting‑appropriate staff‑to‑participant ratios.
• Pre‑approve and document off‑site activities and transportationplans; parent/guardian consents required.

5.4 Behavioral Standards & Boundaries

• No secret gifts or coercion, quid-pro-quo , private texting/DMs, or personal social media connections with minors
• No physical discipline; only approved, trained de‑escalation techniques.
• Physical contact must be limited, appropriate, brief, and for a clear purpose and consent (e.g., during training purposes, first aid).
• No one‑on‑one remote sessions without supervisor approval, recorded scheduling, and visibility controls (e.g., glass office, virtual waiting room, co‑monitor).

5.5 Facilities & Technology Safeguards

• Cameras in public/common areas (never in bathrooms/changing areas), locked records, least‑privilege data access.
• Written rules on photo/video consent, storage, and public posting.

6) Reporting & Response Procedures

Immediate action is required for any suspicion, allegation, disclosure, or observed indicators of abuse. Staff do not investigate; they report.

6.1 If Someone is in Immediate Danger

1. Call 911 (or local emergency number).
2. Provide first aid/medical attention as needed.
3. Secure the area to ensure safety of all participants.

6.2 Mandatory & External Reporting (Jurisdiction‑Specific)

• Mandated Reporter obligations apply per state law (e.g., in Massachusetts, many roles must file a 51A report to the Department of Children & Families (DCF) immediately upon reasonable suspicion; oral report at once and written/online report within statutory timeframes).
• Report to law enforcement immediately if criminal conduct is suspected.
• Where applicable, notify licensing/regulatory authorities, contracting agencies, and funder(s) per contract or regulation.
• Do not promise confidentiality to the reporter or alleged victim; explain reporting obligations.

Section 51A. (a) A mandated reporter who, in his professional capacity, has reasonable cause to believe that a child is suffering physical or emotional injury resulting from: (i) abuse inflicted upon him which causes harm or substantial risk of harm to the child’s health or welfare, including sexual abuse; (ii) neglect, including malnutrition; (iii) physical dependence upon an addictive drug at birth, shall immediately communicate with the department orally and, within 48 hours, shall file a written report with the department detailing the suspected abuse or neglect; or (iv) being a sexually exploited child; or (v) being a human trafficking victim as defined by section 20M of chapter 233.

6.3 Internal Notification (Concurrent with External)

• Notify your Supervisor and the Designated Safeguarding Lead (DSL)immediately.
• If the allegation involves your supervisor or DSL, report directly to TRP Members Committee or Executive Leadership (skip‑level option).
• DSL triggers the Incident Response Protocol below.

6.4 Incident Response Protocol (Internal)

1. Safety Measures
   • Remove alleged victim and alleged perpetrator from contact; ensure safe supervision for all.
   • Administrative leave or temporary reassignment of the alleged perpetrator pending investigation (paid/unpaid per policy/contract/union).
2. Preservation of Evidence
   • Do not destroy or alter records. Secure CCTV, access logs, messages, emails, device logs, sign‑in sheets, duty rosters.
   • Maintain chain‑of‑custody logs for physical/digital evidence.
3. Notifications
   • DSL/Insurance Contact notifies the insurance broker/insurerpromptly in accordance with policy conditions (Abuse/Molestation coverage, EPLI, GL).
   • Notify legal counsel.
   • Notify Board Chair/Executive Leader per materiality thresholds.
4. Communication Plan
   • All external communications are centralized (DSL/Executive/Legal).
   • Respect confidentiality and victim privacy; no unauthorized statements to media or on social media.
   • Coordinate with authorities before any family/guardian/community updates.
5. Internal Administrative Investigation (parallel to but not interfering with official investigations)
   • Led by TRP Membership Committee or qualified third party, following trauma‑informed practices.
   • Collect statements, documents, rosters, training records, and access logs.
   • Maintain neutrality and due process; no retaliation against reporters or witnesses.
6. Findings & Corrective Action
   • Based on evidence, determine policy violations and apply corrective actions (see Section 8).
   • Address programmatic controls, supervision, training gaps, and environment changes.
7. Documentation
   • Complete Incident Report (Appendix A).
   • Maintain secure records per retention schedule and legal holds.

7) Confidentiality & Non‑Retaliation

• Protect the privacy of the alleged victim, reporter, and witnesses to the maximum extent permitted by law and consistent with safety and due process.
• Strictly prohibit retaliation (discipline up to termination) against any individual who reports in good faith or participates in an investigation.

8) Corrective Action (Up to and Including Termination)

Depending on the severity and findings (and without waiting for criminal disposition when safety requires), the Organization may take any of the following:

• Immediate suspension pending investigation.
• Reassignment to non‑contact duties.
• Written warning, final warning, mandatory retraining.
• Termination of employment/volunteer/contractor relationship.
• Permanent bar from future participation.
• Referral to law enforcement/regulators and cooperation with prosecution.
• Contractual remedies with third‑party vendors/partners (including termination for cause).

9) Third‑Party Providers, Partners & Sites

• All third‑party partners providing services to participants must agree in writing to equal or stricter safeguarding standards, background checks, training, supervision, incident reporting, and insurance (including Abuse/Molestation coverage) and to immediate notification of any allegation associated with services rendered to the Organization.
• Contracts will include indemnification, additional insured, primary & non‑contributory, waiver of subrogation, and prompt noticerequirements.

10) Insurance Coordination

• Notify insurer promptly of any incident, claim, or circumstance that could give rise to a claim, following all notice requirements and cooperation clauses.
• Retain training rosters, screening files, supervision plans, and policy acknowledgments as supporting risk controls.

11) Recordkeeping & Retention

• Maintain all screening, training, supervision, incident, and investigation records securely with limited access.
• Apply legal hold instructions upon notice of a claim, litigation, or investigation.
• Follow jurisdictional and funding/contract retention requirements (often ≥ 7 years)

12) Auditing, Quality Improvement & Annual Review

• Conduct periodic spot checks of supervision practices, environment visibility, and documentation.
• Review incident trends to improve controls.
• Annually review and re‑approve this policy; update training and procedures accordingly.

13) Acknowledgment

All Personnel must sign the annual acknowledgment confirming they have read, understand, and agree to comply with this policy and reporting obligations.

Appendix A — Incident Report (Template)

Complete immediately after ensuring safety and required external reports. Submit to Supervisor and DSL.

1. Reporter Information
   • Name, role, contact, date/time of report
2. Subject(s) Involved
   • Alleged victim: name/ID, age, program, guardian contact (if applicable)
   • Alleged perpetrator: name/role/relationship
   • Witnesses: names/roles/contact
3. Incident Details
   • Date/time, location, program/activity
   • Detailed factual description (what happened, by whom, sequence of events)
   • Visible injuries/behaviors; first aid/medical attention provided
   • Environmental factors (visibility, supervision, ratios)
4. Immediate Actions Taken
   • Safety measures, separation, notifications made (911, DCF/APS, police case #, licensing/regulator, guardians) with timestamps
   • Preservation of evidence steps
5. Internal Notifications
   • Supervisor/DSL/HR/Executive notified (names, times)
   • Insurance notified (policy #, broker/insurer contact, claim # if assigned)
6. Attachments/Evidence
   • Photos (if permitted), logs, rosters, training records, messages, CCTV references

Appendix C — Quick‑Reference: Mandatory Reporting (Fill with Local Details)

• State Hotline / Portal: [e.g., MA DCF 51A Hotline & link]
  • MA.gov SafeLink 1-877-785-2020
  • 844-878-MOVA or mass.gov/askMOVA.
• Mandated Reporter Categories: [Youth Coaches, or Administrators]
• Timeframes: [Immediate oral; written within 48 hours/2 days]
• Local Police: [The town/ City the offense/ crime was committed]

Appendix D — Massachusetts Quick‑Reference

Emergencies: 911 (then follow applicable pathway)
Children (<18): DCF Child‑At‑Risk Hotline 24/7: 1‑800‑792‑5200.Written 51A due within 48 hours. (Report to the DCF area office serving the child’s town.)
Elders (60+ in the community): Elder Abuse Hotline 24/7: 1‑800‑922‑2275 or report online (EPS).
Adults with disabilities (18–59) dependent for daily living needs: DPPC 24/7: 1‑800‑426‑9009 (online option; standard = “reasonable cause to believe”).
Long‑term care/hospital staff‑on‑patient abuse: DPH 1‑800‑462‑5540(in addition to age/disability pathway).
Sexual assault (medical provider duty): Anonymous PSCR to EOPSS + local PD (regardless of victim’s police reporting status).
Confidentiality of sexual assault/DV police reports: M.G.L. c.41 §97D.