Protection of Minors Policy
Owner: Director of Finance & Operations (DFO) – with input from all Directors Audience: All OWL staff and any working partners who work directly with children.
Purpose
Open Way Learning is committed to maintaining a safe and supportive environment for all individuals, including minors (under age 18), especially in the context of school-based partnerships, student exhibitions, or community-engaged learning. This policy outlines OWL's procedures and expectations for protecting minors from abuse, neglect, or harm during OWL-affiliated activities.
Scope
This policy applies to all OWL staff, fellows, contractors, and volunteers who may, through their work, interact directly or indirectly with minors in either physical or virtual environments.
Code of Conduct for Interacting with Minors
All OWL-affiliated adults are expected to:
Maintain professional, respectful boundaries at all times.
Avoid being alone with a minor unless in a public, observable space (“observable and interruptible”).
Not share personal contact information or communicate with minors outside of professional channels.
Avoid transporting minors in personal vehicles or hosting them in personal residences.
Obtain written parental/guardian permission before photographing or recording minors.
Avoid behavior or language that could be perceived as abusive, sexual, or discriminatory.
Prohibited Behaviors
OWL strictly prohibits:
Physical, emotional, or sexual abuse or harassment of any minor.
Use of inappropriate, suggestive, or discriminatory language or jokes in the presence of minors.
Giving alcohol, drugs, or inappropriate materials to minors.
Photographing minors on personal devices for non-OWL purposes.
Retaliation against any individual who reports suspected misconduct or abuse in good faith.
Mandatory Reporting Requirements
All OWL-affiliated adults are mandated reporters. If you suspect that a minor is being abused, neglected, or is the victim of a violent or sexual offense, you must:
Immediately:
Contact 911 if the child is in immediate danger.
Report the concern to the Department of Social Services (DSS) in the county where the child resides or is physically located.
Notify an OWL director (e.g., Director of Outreach & Programs), who will document the report and ensure organizational compliance.
Note that you are not responsible for investigating - only reporting in good faith. Reasonable suspicion is enough. North Carolina law provides immunity for good-faith reporters (G.S. § 7B-309).
Background Check Requirements
To protect minors and ensure trust with partner organizations, OWL requires background checks for:
Employees, OWL Fellows, or contractors expected to have direct, non-incidental contact with minors.
Volunteers who may be present in unsupervised or extended contact roles.
Anyone assigned to OWL-led events involving youth interaction outside of immediate school staff supervision.
Process Overview
Trigger Point: The Director of Outreach or Program Manager identifies individuals requiring a check based on their project role.
Consent: The individual completes a standard background check consent form (provided by OWL).
Vendor Screening: OWL uses Sterling Volunteers, a nonprofit-friendly background check service with strong experience supporting small education nonprofits.
Review & Recordkeeping: A designated OWL director securely reviews results and logs only the clearance status (no sensitive data stored).
Renewal Schedule: Background checks are valid for three years for staff and one year for short-term contractors or volunteers.
Background checks include identity verification, sex offender registry screening, and criminal history review. Additional DMV checks may be conducted when travel with minors is involved.
Training & Certification
All OWL-affiliated individuals who may work with minors must:
Complete OWL's annual Protection of Minors Training (30–45 minutes).
Sign an annual Acknowledgment Form affirming understanding of the policy and reporting obligations.
Training Includes:
Overview of this policy
Recognizing signs of abuse and neglect (emotional, physical, sexual, neglect)
Dos and Don'ts for adult-minor interactions
Bullying and peer-on-peer abuse awareness
Reporting steps and emergency response
Scenario-based reflection questions
Partnership & On-Site Alignment
OWL-affiliated personnel are also expected to adhere to any child safety policies of the partner schools or organizations where programming occurs. This may include sign-ins, escort policies, mandatory ID badges, or other supervision protocols.
OWL defers to these host site procedures while ensuring this internal policy remains the minimum baseline standard for all engagements involving minors.
Refer to forms in the Templates & Resources section for the PROTECTION OF MINORS ACKNOWLEDGEMENT FORM and the CONSENT TO BACKGROUND CHECK FORM.
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