The Danger of Inadequate Child Protection Policies
Policies reveal an organization’s priorities. Non-existent or inadequate policies indicate a lack of interest or engagement, while careful and thorough policies demonstrate investment. Robust policies show that the issue at hand is important to the organization.
Child protection policies have a stated goal of protecting children from harm. Too often, child protection policies serve a different purpose: protecting a church from liability and assuaging parental concerns. Inadequate child protection policies are often more dangerous than the absence of a policy because nominal policies allow church members to believe that they are safe when they are actually in grave danger.
There are many excellent resources and examples of child protection policies available to churches, but we’ll highlight two resources in this piece: The Child Safeguarding Policy Guide for Churches and Ministries from GRACE and Let the Children Come: Preparing Faith Communities to End Child Abuse and Neglect by Jeannette Harder.
These two publications provide a framework for evaluating good child protection policies. We are grateful to R.L. Stollar for this helpful summary of the two resources:
According to Harder, the four qualities every child protection policy should exhibit are: visible, agreed to, comprehensive, and implemented.
Visible means community members and outsiders considering joining the community should be able to easily find and access the policy. It should be posted online and in your facilities.
Agreed to means everyone in the community (children included!) needs to buy into the policy. At least once a year, everyone should receive a copy and review it.
Comprehensive means the policy should cover all aspects of your community, both formal and informal gatherings. It also should address all forms of child abuse, not just sexual abuse.
And finally, implemented means the policy has to be something lived out in daily life. A child protection policy is not something you create once, post online, and then forget about. You have to review and assess and update it annually and actually implement it in your interactions with children.
According to GRACE, the five elements every child protection policy should entail are: foundational principles, protective measures, rules and procedures for responding to policy violations and abuse allegations, survivor support, and mechanisms for implementing the policy.
The foundational principles would be things like a statement about why your community cares about child protection, definitions of abuse, lists of indicators that a child has experienced abuse, information about the long-term impacts of abuse, information about polyvictimization, and so forth.
Protective measures would include screening people who work with children, for instance with background checks, as well as requiring safe behaviors like having two adults always present whenever children are also present.
Rules and procedures for responding to policy violations and abuse allegations should involve details such as who specifically is responsible for reporting violations and abuse allegations to whom and when they must report it by.
Survivor support encompasses both how you will handle disclosures of abuse (how you will care for the victim in the short-term and keep them safe) and how you commit to care for all survivors on an ongoing basis (for example, support groups, help with therapy costs, etc.).
And lastly, mechanisms for implementing the policy would establish how often your community distributes the policy and trains everyone on it, how often your community plans to evaluate and update the policy, and who will be responsible for ensuring all this actually happens.
CFC’s Child Sexual Abuse Prevention Training offers a prime case study for examining elements of a dangerous policy that provides an illusion of safety while leaving children unprotected. This document is undated, but according to CFC’s Board of Trustees minutes, several church leaders and board members worked on the CSAP policy in 2020 and 2021.
The policy appears to be a mash-up of several existing policies with duplicate sections and conflicting definitions. It is telling that this policy wasn't important enough to warrant even basic editing.
The title page of the document raises the first question: Why does this policy say “Madrid and Potsdam”? Do the other three congregations lack children? Is this a typo or are CFC Canton, CFC Moira, and North Country Christian Fellowship covered under different—or perhaps nonexistent—policies?
The policy introduction states: “Our goal in establishing a Child Sexual Abuse Prevention Strategy is to safeguard children, their families, and the church from the devastating consequences of Child Sexual Abuse. Additionally, the education and training in Child Sexual Abuse Prevention provided by the church will benefit families in safeguarding their children while they are at home and in the community.” The intended dual nature of the policy ostensibly explains why the training seems geared toward ministry volunteers but includes a section for parents titled "Tell your child that."
The insertion of a section for parents is particularly interesting because it directly contradicts several key CFC teachings. A child who is spanked by a parent learns that their body is not their own. The child learns that it is perfectly acceptable for an authority figure to override the child’s natural protective instinct, ignore their “no,” and inflict pain on their (sometimes bare) buttocks.
CFC seems to accept predators with a history of child sexual abuse for ministries that do not involve children. Allowing an abuser to serve in a ministry provides the church’s stamp of approval, whether or not that is the intended impact. People who are unaware of the abuser’s past will likely give them access to children outside the church setting because the church appears to approve of them.
The policy sections on reporting and responding to allegations of Child Sexual Abuse are particularly disturbing. All staff members and church members are “urged” to report CSA concerns, but the policy does not indicate where the report should be made. Ministry staff and volunteers are asked to report to church leadership, which leaves any other reader with the sense that they should also report to church leadership instead of going to the appropriate authorities.
The Response to Allegations section clarifies the process. Reports go to a Senior Pastor, Elder, or Ministry Head, not CPS. The CFC leaders will do their own internal investigation, consult with a lawyer, and only then will they decide if a call to CPS or other authorities is warranted.
When we examine the CFC CSAP policy in light of the recommendations from experts, it falls short on almost every level:
Is this policy easy to find and access online and in CFC buildings? No.
Does everyone (including children) get a copy to review annually? No.
Does this policy address all types of gatherings, including CFA events, Life Group, mothers’ meetings, and more? No.
Is this policy reviewed and updated regularly? Unclear.
Is the policy followed when allegations arise? No (at least in the case of Sean Ferguson).
Compared with the GRACE recommendations, the CFC policy does include some information about definitions of abuse (though those definitions are not consistent), abuse indicators, and information about the long-term impacts of abuse. CFC’s policy is most consistent with expert recommendations when it comes to protective measures, like screening volunteers and requiring safe behaviors.
CFC’s policy is also woefully inadequate in the area of policy violations and response to abuse allegations, as noted above. In fact, the policy implicitly discourages people from reporting allegations to the proper authorities.
CFC’s policy section on survivor support reflects their approach in practice: the support is non-existent. Survivors at CFC are slandered and demonized, not supported.
This CSAP policy highlights the fact that children are not safe at CFC. Parents should carefully evaluate whether they want their children to participate in activities and events in such a dangerous environment.
Unfortunately, this inadequate approach to child protection is far too common in ministry and church communities. Administrative neglect and leadership failure leave everyone vulnerable: from the leaders who must scramble to respond to situations for which they are ill-equipped and poorly trained to congregants who learn to normalize secrecy and unwarranted trust in omnicompetent leaders. Most importantly, it ensures that children and other vulnerable people will suffer both because churches failed to protect them and, when abuse occurs, instead compounded harm with an inadequate response. Churches and the people who entrust themselves to them deserve better.
