The following questions are often received by the Archdiocese of New York regarding the Safe Environment Program.
All Archdiocesan Personnel whose duties include contact with minors must complete the “Safe Environment Requirements”. This means that they must complete a Safe Environment Questionnaire and a background check, they must acknowledge that they’ve received the Archdiocesan Policy Relating to Sexual Misconduct and the appropriate Code of Conduct and abide by them; and they must complete the Safe Environment Training appropriate to their position.
At all events involving minors, there must be a minimum of two adults present, at least one of whom is 21 years of age or older, and all of whom are in full compliance with the Safe Environment Requirements. For events with both male and female minors, it is strongly encouraged to have adults of both sexes present.
Facilities where activities with minors take place are periodically reviewed to ensure that there are no conditions that pose dangers to minors.
Promoting and protecting the virtue of modesty is essential to a safe environment for minors. Therefore there must be separate facilities for males and females to ensure personal privacy, such as bathrooms, changing rooms, and showers. Adults may not share those facilities with a minor who is not their own child. Minors may only use the appropriate facility that conforms to their biological sex.
There’s no “bright line” test for every case, and administrators of Archdiocesan programs and institutions should use their best judgment. The best practice is to apply that standard broadly, and if there is any doubt to require the person to comply with the requirements. Still, we can offer some guidelines:
What is the person’s job?
Certain job descriptions should always be considered to “include contact with minors”: school administrators and administrative staff, teachers, teacher aides, school or classroom volunteers, guidance counselors, school custodians, catechists, catechist aides, music directors, youth ministers, athletic coaches and volunteers, school maintenance staff, coordinators of altar servers and youth choirs.
On the other hand, certain liturgical positions should not ordinarily be considered to have “duties that include contact with minors”, since they only have incidental contact with children during the course of the liturgy. These positions would include: lectors, Eucharistic ministers, ushers, greeters, choir members and leaders of song.
What if the person’s activities doesn’t fit into any of those categories?
The Administrator should ask the following questions about the person’s activities. If the answer to one of these questions is “yes”, then the person should be considered to have “duties that include contact with minors”:
a. Does the person’s job require them to work directly with minors (as opposed to positions that involve contact that is isolated, incidental, irregular, occasional or infrequent)?
b. Does the person’s duties frequently bring them into a school, or the location of a religious education program or youth program?
c. Does the person’s duties permit them to have private face-to-face dealings with minors?
d. Does the person have the opportunity to be with minors in private (as opposed to having contact with children always in public and under the supervision of others)?
e. Does the person ever have direct supervisory responsibility over minors?
f. Do minors typically come into the person’s private workspace?
If there is any doubt, the most prudent approach is to require them to comply with the Safe Environment requirements.
Persons who are under the age of 18 themselves may work in positions with duties that include contact with minors only if they are under the direct supervision of an adult who is in full compliance with the Safe Environment Requirements.
Persons under the age of 18 must also comply with the Safe Environment Requirements:
- Persons who are in ninth grade or above must complete a Safe Environment Questionnaire and attend a “Safer Spaces” class.
- Persons who are 16 and 17 must also submit to a background check (with parental consent).
- Persons who have not yet entered ninth grade need not submit to a background check or attend a training class, but they must be advised of the Code of Conduct.
Clergy must attend a VIRTUS “Protecting God’s Children” class.
Professional and supervisory personnel must attend a VIRTUS “Protecting God’s Children” class. This would include school administrative and educational staff (principals, assistant principals, deans, assistant deans, teachers, teachers’ aides, or guidance counselors, but not business, clerical or custodial staff), directors and coordinators of religious education (whether paid or volunteer), social workers, counselors, and youth ministers.
Other employees and volunteers may attend either a VIRTUS “Protecting God’s Children” class or a class that uses our in-house “Safer Spaces” video.
To register for a VIRTUS class, click here.
To take the Safer Spaces class online, click here.
After a person has their initial training, they do not have to re-do that class. If a person has completed the “Safer Spaces” training, but later changes their position to become a supervisor or professional employee, they must take a VIRTUS class.
In addition, our office provides periodic refresher training resources to our clergy, employees and volunteers.
Training
Training programs from other agencies, or those required by state authorities, certainly provide ample education about child abuse in general. However, they do not provide the necessary training in the Archdiocesan Code of Conduct and our reporting requirements – both of which are required by the Bishops’ Charter for the Protection of Children and Young People.
As a result, professional and supervisory personnel in Archdiocesan schools (principals, assistant principals, deans, assistant deans, teachers, teachers’ aides, or guidance counselors, but not business, clerical or custodial staff) must still attend the VIRTUS “Protecting God’s Children” training class, even if they have already had the New York State child abuse awareness training class.
Other Archdiocesan employees can satisfy their training requirement by attending a class that uses our in-house “Safer Spaces” video.
Background Check
Even if you’ve already had a background check from another agency or program, we still require everyone to submit to a background check with us. The reason is that our standards are different from other agencies, and we have to make sure that everyone satisfies those standards.
They still have to comply with our Safe Environment requirements. Here’s how:
Employees of local school districts – If they have current proof that they have passed a background check and had training in child abuse from their district, they should be given written copies of the Archdiocesan Code of Conduct and our reporting requirements.
Other contractors (e.g., regular school maintenance staff, but not contractors who are in the building for a limited time on a discrete job, such as plumbers, electricians, etc.) – They must submit to a background check and attend a “Safer Spaces” class.
There are lots of people who are in contact with minors in programs or activities that are not sponsored or conducted by an Archdiocesan institution. Instead, they just use or rent facilities of a parish or school (e.g., community sports program that play games at the school gym). They are not Archdiocesan personnel, and are not required to comply with the Safe Environment requirements.
For volunteers with Boy Scout and Cub Scout troops sponsored by Archdiocesan institutions, their Safe Environment Requirements are satisfied if they have taken the Boy Scout Youth Protection Training Course, are up to date with their Boy Scout Youth Protection certification, and have had a background check (including criminal record and state sexual offender registry checks) within the previous three years. The Troop or Pack leader should make sure that these requirements are fulfilled. If the volunteer is participating in an activity besides scouting, then they still have to take the Safer Spaces training.
Your background check is good as long as you stay in the same parish or school. But we’re asking everyone to have a new background check every time they begin work at a new institution. This will ensure that we have current and accurate information about all our personnel.
For example, if you’re a teacher at a parish elementary school, and start volunteering as a catechist in a different parish, we ask that you submit to another background check; if, on the other hand, if you start volunteering in the same parish, you do not have to have a new background check when you start.
We do not, however, ask that people have another training program, so long as they have the appropriate level of training for their new position. Remember, clergy and employees must have completed a VIRTUS “Protecting God’s Children”; volunteers can satisfy the training requirement by attending a “Safer Spaces” class or a VIRTUS “Protecting God’s Children” class.
So, for example, if you previously were a volunteer and completed a “Safer Spaces” program, you will have to attend a VIRTUS “Protecting God’s Children” class if your new position is as an employee. On the other hand, if you were an employee and completed a VIRTUS “Protecting God’s Children” program, you won’t have to have new training to volunteer in another parish.
These people should be deleted from your parish or program rosters. We will maintain their information in our archives in case they begin work at another institution in the future.
We verify a person’s identity and background based on their name, date of birth, and social security number. We also check to see if there is any relevant information in the agency’s database of criminal records and in state sexual offender registries. To do this, we use a credit agency that has access to this kind of information. Don’t be alarmed at the use of the word “credit”. We do not ask for any financial information about you.
If you obtain your own credit report, it will note that the Archdiocese or the credit check agency has “obtained a copy” of your credit report. Again, we never ask for any financial information — the agency is required by law to note any time your information has been accessed, even if it was only to verify your identity. However, the credit agency does not reveal to potential lenders that your information has been accessed — it will only appear on your copy of your credit report.
You can dispute information in your background check in several ways. You can certainly submit information to us, and we will take it into account in evaluating your background check. You can also file a dispute directly with the credit check agency, or with the source of the information. For information on how to do this, check out the website of the Federal Trade Commission.
Yes. We still have to verify their identity and check their background. If a person does not have a valid Social Security number, have them complete the background check authorization form, leaving the line for Social Security number blank. The pastor, principal or DRE should verify their identity with some form of official government photo identification (e.g., a driver’s license, a passport, etc.). The pastor, principal or DRE should then send our Office the authorization form, along with a copy of the identification document, or with a notation that they have verified the person’s identity.
All active staff are enrolled in a continual monitoring system that provides us with real-time updates if a person has a negative event such as a criminal conviction.