Canadian Centre for Child Protection Public Policy on Protection from Sexual Exploitation and Abuse (“PSEA Public Policy”)

This is the Canadian Centre for Child Protection’s (C3P) policy to receive and address sexual abuse or exploitation complaints against a C3P Employee, Board Member, or any other entity or individual that is directly connected to C3P.

1. Introduction

   The Canadian Centre for Child Protection (“C3P”) is a national charity dedicated to the personal safety of all children. Our goal is to reduce the sexual abuse and sexual exploitation of children, assist in the location of missing children, and prevent child victimization through a number of programs, services and resources. A core aspect of our mission is to advocate for and increase awareness about issues related to the sexual abuse and exploitation of children.

2. Policy Scope and Application

   This policy applies to all C3P Employees, C3P Board Members, Connected Individuals, and Connected Entities, and is intended to complement the set of standards and behaviours that all C3P Employees are already required to adhere to as a condition of employment. Nothing in this policy prevents or discourages anyone from reporting incidents of sexual abuse or sexual exploitation to any other body (e.g. law enforcement, child and family services etc.).

3. Core Policy Statements

   To protect all individuals C3P interacts with and the wider public, and to ensure the integrity of C3P resources and activities:

   1. C3P will not tolerate sexual abuse or sexual exploitation against any person, adult or child, by any C3P Employee, C3P Board Member, any Connected Individual, or any officer, director, employee or volunteer of a Connected Entity. This applies whether the abusive or exploitative act occurs within or outside the C3P workplace, or within any other environment in which a C3P Employee, C3P Board Member, Connected Individual or any officer, director, employee or volunteer of a Connected Entity is providing services to the public on behalf of C3P.¹
   2. All concerns and complaints pertaining to alleged sexual abuse or sexual exploitation that come to C3P’s attention and involve any C3P Employee, C3P Board Member, Connected Individual, or any officer, director, employee or volunteer of a Connected Entity, will be promptly looked into and addressed in a manner appropriate to the situation and consistent with this policy.
   3. C3P Employees and C3P Board Members must create and maintain an environment that promotes the implementation of this policy. Senior management and management positions at C3P have particular responsibilities to support and develop systems which adhere to this policy.
   4. C3P shall make this policy publicly available and easily accessible by posting it on C3P’s primary website, www.protectchildren.ca.

4. Screening and Training Process:

   To help safeguard individuals participating in C3P’s programs and services, and reduce the incidence of sexual abuse and exploitation:

   1. C3P shall screen all prospective job candidates and prospective board members in accordance with established screening procedures, which include but are not limited to, criminal record, vulnerable sector, and child abuse registry checks. C3P shall require all C3P Employees to update these checks at least every two years throughout their employment at C3P.
   2. C3P shall ensure all C3P Employees and C3P Board Members are made aware of this policy and shall incorporate it into annual training processes.
   3. C3P shall ensure Connected Individuals and Connected Entities are also made aware of this policy, and where applicable, contractual provisions shall be included in contracts. Such provisions shall require Connected Individuals and/or Connected Entities to take appropriate measures to prevent sexual abuse and/or sexual exploitation of anyone by their employees, or any other person engaged and controlled by the individual or entity to perform any work on C3P’s behalf. The provisions shall provide that a failure to take such measures shall constitute grounds for termination of any cooperative arrangement between the Connected Individual or Connected Entity and C3P.

5. Prohibitions

   In light of the above, the following is prohibited under this policy:

   1. No C3P Employee, C3P Board Member, Connected Individual, or employee, director, officer or volunteer of any Connected Entity, shall engage in any sexual abuse or exploitation of any kind with a Recipient or Participant regardless of their age. No C3P Employee, C3P Board Member, Connected Individual, or employee, director, officer or volunteer of any Connected Entity shall have any sexual relationship of any kind with a Recipient regardless of their age. Such relationships undermine the credibility and integrity of C3P.
   2. No C3P Employee or C3P Board Member shall engage in any sexual abuse, sexual exploitation, or sexual relationship of any kind with a child, regardless of the age of majority or age of consent locally. Mistaken belief of age regarding the child is not a defense. Any such relationships undermine the credibility and integrity of C3P.
   3. No Connected Individual, and no employee, director, officer or volunteer of any Connected Entity, shall engage in any sexual abuse or sexual exploitation of any child, nor shall they engage in any sexual relationship of any kind with a child under the age of 16 years old. In addition, no Connected Individual, and no employee, director, officer or volunteer of any Connected Entity, who is in a position of trust or authority over a child, or with whom the child is in a relationship of dependence or exploitation, shall engage in any sexual abuse, sexual exploitation, or sexual relationship of any kind with such child.

6. Consequence of Policy Violation

   With respect to C3P Employees, a violation of section 5 of this policy will result in termination of employment from C3P with or without cause. With respect to C3P Board Members, a violation of section 5 this policy will result in removal from the C3P Board of Directors. Violations of the response and reporting protocols set out in section 7, or any other aspect of this policy, by an Employee may result in termination of employment with or without cause. Violations of the response and reporting protocols set out in section 7, or any other aspect of this policy, by a C3P Board Member may result in removal from the C3P Board of Directors.

   With respect to a Connected Individual or Connected Entity, a violation of this policy may result in termination of the relevant contract, agreement, or association between C3P and the Connected Individual and/or Connected Entity, or such other action as solely determined by C3P, having regard to the existing laws and contracts that may apply to the individual or entity.

7. Reporting and Response Protocols

   1. C3P provides a safe, confidential and publicly accessible mechanism and procedure for personnel, stakeholders, Recipients, Participants, and the public to report sexual abuse and sexual exploitation allegations against a C3P Employee, a C3P Board Member, a Connected Individual, or any employee, director, officer or volunteer of any Connected Entity:

      1. C3P Employees may report such information directly to the member of C3P senior management to whom that C3P Employee reports, or the Director of Finance & Administration, or the Associate Executive Director. The Executive Director of C3P shall next be alerted and direct next steps in terms of follow up and action. If the allegation involves the Executive Director, the obligation shall be to alert the Chair of the Board of Directors, who shall then be responsible for directing next steps.
      2. C3P Board Members may report such information directly to the Chair of the Board of Directors, who shall be responsible for follow up and action. If the allegation involves the Chair of the Board of Directors, the obligation shall be to alert one or both of the Vice Chair(s) of the Board of Directors who shall then be responsible for directing next steps.
      3. Members of the public may report confidentially through a contact form on the website that will go to a secure C3P email, or by phone to a secure number. The email/phone will only be accessible to those responsible for handling these types of reports.

   2. C3P shall, properly, and without delay, follow up on all alleged concerns or complaints. The manner in which such follow up shall occur shall vary based on the information provided. For example:

      1. C3P may refer the matter as appropriate to an investigative body with jurisdiction to investigate, particularly if the alleged perpetrator is a Connected Individual or affiliated with a Connected Entity.
      2. Any information received that may support a finding that the alleged act is criminal, or has put, or may result in putting, a child in need of protection, C3P shall pass the reported information on to national or provincial authorities as appropriate and permitted by law.

      Concerns or complaints that, upon follow up or based on other reliable information, is determined by C3P, acting reasonably, to be false, vexatious, malicious, or made in bad faith will not be further actioned.

   3. In addition to the above, and only with consent from the potential survivor or parent/guardian, C3P shall promptly refer potential survivors of sexual abuse or sexual exploitation to available accessible services based on their needs.

8. Confidentiality

   Throughout the process of reporting and follow up, care will be taken to respect the confidentiality and privacy of the individual reporting. C3P will not disclose the name of the complainant to any person except where (a) it is necessary to follow up on the report or take corrective action with respect to the report or (b) it is required by law.

9. Knowingly False, Vexatious, or Malicious Reports

   Reports made in circumstances that are knowingly false, vexatious, malicious, or made in bad faith are not permitted. Any C3P Employee who knowingly makes a false report, or makes a report that is deemed by C3P, acting reasonably, to be vexatious or malicious, will be disciplined, which may include termination of employment.

10. Definitions:

    For the purpose of the present policy, the following terms shall have the meaning ascribed to them as set forth below:

    “child(ren)”

    refers to any person under the age of 18 years old and can include a Recipient or Participant.

    “C3P Board Member(s)”

    refers to all persons who are members of C3P’s Board of Directors.

    “C3P Employee(s)”

    refers to all persons who currently have a paid employment contract with C3P.

    “Connected Individual(s) and/or Connected Entity(ies)”

    includes anyone engaged by C3P to perform certain work for C3P and who have direct contact with members of the public on behalf of C3P. It includes independent contractors, sub-contractors, and volunteers.

    “Recipient”

    means a recipient of services from C3P, or a beneficiary of C3P’s assistance. A Recipient can be an adult or a child.

    “Participant”

    means any person who participates in educational or other events hosted by C3P. A Participant can be an adult or a child.

    “senior management”

    refers to any C3P Employee whose employment title includes the word “Director” as well as General Counsel for C3P.

    “sexual abuse”

    means any actual, threatened or attempted physical intrusion of a sexual nature, whether by force or under unequal, unwanted, or coercive conditions.

    “sexual exploitation”

    means any actual, threatened or attempted act against another person for a sexual purpose that in the view of C3P constitutes abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not kimited to, profiting monetarily, socially or politically from the sexual exploitation of another. It includes the exchange of money, employment, goods, or services for sex, including sexual favours or other forms of exploitative or harmful behaviour.

1. 1 Environments where C3P Employees, C3P Board Members, Connected Individuals, or any officer, director, employee or volunteer of a Connected Entity provide services includes (but is not limited to) environments such as public and private schools, universities, C3P conferences and events, and external conferences and events. ↩

Report Form

Our privacy commitment to you: Any information you choose to share is kept confidential and only shared with those directly involved in assessing and responding to your report. All information provided by you will be treated in accordance with sections 7 (Reporting and Response Protocols) and 8 (Confidentiality) of this policy. We will not share your information without your consent, except in limited circumstances as explained in our Privacy Policy. For example, if we have reason to believe that a child is in need of protection we are required by law to report that information. For more information, please see our Privacy Policy.