Considerations for Youth Protection in a Virtual World

April 28, 2020
girl waving at computer screen

While shelter-in-place orders affect camps’ ability to host in-person gatherings across the country, some have turned to online programming until we are allowed to meet in person once again. While some youth safety practices from in-person programming transfer over to the online world, there are a number of additional safety precautions to consider. 

The following questions intend to help camps plan for safe online program experiences. 

Disclaimer: This list is not intended to be exhaustive, nor a replacement for legal counsel. Instead, this list should provide a starting point for camps that are considering virtual programming. Think about your answers to these questions, and make sure to discuss your decisions with your insurance carrier and legal counsel. 

Program

  • What will your virtual program include? Be specific. 
  • When are you running the virtual program? 
  • What revenue and payroll are anticipated for this virtual program/activity? 

Supervision and Training

  • What are your staff screening requirements and process for the virtual program/activity? 
  • How many participants will be served daily? What are the age levels of participants being served? 
  • Who and how will you staff* for the program/activity?   
  • How many staff do you anticipate utilizing for this program?   
  • What is the plan to train, observe, and supervise the staff delivering the program/activity?  
  • What is your plan for ensuring youth protection in a virtual setting? (i.e. “rule of three,” mandated reporting, etc.) 

Risk Considerations 

  • What safety and risk management guidelines will be in place? 
  • What technology risk management controls will be in place? 
  • What acknowledgement of risks, waivers, and releases will be used? 
  • What behavioral controls will be implemented? 

General Practices

  • How are you going to address potential technical issues participants and/or staff have? 
  • What adjustments to your personnel policies/staff handbook need to be addressed for a virtual setting? 
  • What policies and procedures will be needed to ensure consistent program delivery by staff? 
  • Do you need to revisit your existing participant code of conduct and information provided to parents/guardians?  
  • Do social media policies need to be revised for considerations related to the program/activity? 
  • What expectations will you set for parent/guardian supervision and involvement? 
  • What parent/guardian education needs to be in place for your participants for use of a virtual platform? (i.e., Are children aware of online safety? Do children know who to talk to if they have concerns? What about children with little to no online experience?) 
  • Have you considered the implications of Children’s Online Privacy Protection Act (COPPA) regulations? 
  • Have you discussed with your legal counsel the possible need for recording all interactions with campers in the event of an accusation of abuse or other claim and how that fits within COPPA regulations? 


A special thank you to Darrow Milgrim of Arthur J. Gallagher & Co. for his contributions to this article.