Screening in Faith Policy

Diocese of Ontario Screening in Faith Policy

Section 1

1.1 Theological Foundation

The Diocese of Ontario is committed to ensuring that our Church is a holy place where the love of Christ can be modeled and learned. Our Baptismal Covenant identifies that we are to seek and serve Christ in all persons, loving our neighbour as ourselves (Book of Alternative Services, p. 159). A fundamental obligation, therefore, is to look after the welfare of all members of our community but especially those who are vulnerable through age, infirmity or particular circumstances of dependency. This is a sacred trust which must be responsibly and safely managed.

In company with the bishops, clergy and people of the Anglican Communion, the Diocese of Ontario “affirms that every human is created in the image of God who has made us for loving, covenant relationships with our Creator, others and the world. We believe that our peace arises out of right relationships. Our personal dignity, freedom and bodily integrity are ensured by faithfulness to just covenants of mutual trust, care and respect. Such covenants undergird the moral framework of our communal life, responsibilities and entitlements.” Lambeth Conference Report, 1988

Ministry is a privilege. Through our baptism we are all called to ministry using our varied and different gifts. (BAS pp. 158-160) The process of matching an individual’s gifts with the Church’s needs requires Church leaders use gifts of discernment, insight, courage and to speak the truth in love. From time to time, some individuals may feel a stronger call to a ministry than the Church is able to affirm. However, only those who are perceived to have the appropriate gifts for the position will be permitted to minister. This principle is important to ensure that the recipients of the ministry, the individual who feels called to the ministry and the Church are safe from harm.

Those who offer themselves for ministry must have an attitude of servanthood and be willing to be trained, mentored and possibly reassigned, as needs dictate.

1.2 Rationale for the Policy

This Screening in Faith policy is the means by which the Diocese of Ontario responds to our call to offer our best to those we serve. It is necessary, therefore, that we discern gifts and determine a person’s suitability to a ministry position.

The Diocese of Ontario is abundantly blessed with gifted and committed clergy, employees and volunteers who offer their talents in full recognition of their obligations. In fact, the Church could not operate without the work of thousands of individuals throughout the Diocese who exercise a variety of ministries to persons within the Church community and beyond.

It is critical, therefore, to ensure that those we place in positions of power and trust be selected, trained and supported so that their ministry may be life-giving. In this way our Christian values are consistent with the legal concept of “duty of care.” Duty of care arises out of legal doctrines dealing with negligence. Everyone has a general obligation to conduct themselves in a manner which does not cause damage to other people or their property. The duty of care is most obvious where a relationship of dependence exists.

1.3 Application

The policy applies to: all lay and ordained people under the jurisdiction of the Bishop of Ontario, that by virtue of their ministry or work are in positions of trust.

It is a requirement that this policy be implemented in all parishes, ministries or other organizations which:

(a) are funded, in whole or in part, by the Diocese of Ontario;

(b) function on behalf of the Church (whether on or off its premises);

(c) operate on Church premises.

This Screening in Faith policy establishes minimum standards for the screening of staff and volunteers. Any parish or organization may develop more comprehensive policies of its own to reflect its own circumstances provided such policies at least meet the minimum standard of protection for children and vulnerable adults, and physical, spiritual and financial responsibilities contained in this policy. Screening standards must be consistently applied to all appropriate ministries.

1.4 Responsibilities

It is the responsibility of the organizational leadership (bishop, churchwardens, director, incumbent, priest-in-charge) to ensure that screening standards are implemented in the parish or organization. If the leadership does not comply with this policy, it could jeopardize insurance coverage. It could also result in disciplinary proceedings. The Bishop of Ontario serves as the supervisor of the clergy. For the purposes of this policy, the churchwardens are mutually accountable regarding all screening issues.

1.5 Definition of Vulnerable Person

The term “vulnerable person” includes not only people typically recognized as vulnerable, such as children, youth, some of the elderly, hospital patients, the mentally and physically disabled, but also to those otherwise healthy adults who become vulnerable because of personal circumstances. Such circumstances might include, but are not limited to, those grieving the death of a loved one, those experiencing job loss or career difficulties, those facing illness in themselves or others, and those facing other uncertainties. It is important to recognize that all people are vulnerable to varying degrees at different stages in their lives.

Section 2:

Screening Steps:

• Step 1: List all the ministry activities and positions.
• Step 2: List all the duties and responsibilities for each ministry activity or position.
• Step 3: Assess the risk for potential harm.
• Step 4: Reduce the risk for potential harm.
• Step 5: Assign appropriate screening standards for each ministry position.
• Step 6: Finalize the ministry descriptions.
• Step 7: Establish appropriate training and supervision.
• Step 8: Apply the screening standards.
• Step 9: Make a selection decision based on the screening information.
• Step 10: Evaluate and enforce the screening standards.

2.1 List All the Ministry Activities and Positions

Each parish or organization shall make a list of all positions associated with the Church or organization, whether short-term, long-term, formally or informally established, paid or volunteer, involving laity or the ordained, taking place on Sunday or during the week, on Church premises or off-site.

2.2 List All the Duties and Responsibilities for Each Activity or Position

List all the tasks, duties and responsibilities for each ministry positions listed in 2.1 above. These preliminary lists will be used to assess the risks of each ministry activity and to establish proper screening standards.

2.3 Assess Risk for Potential Harm

Assess the level of power, authority and control of those who minister, the level of vulnerability of those being ministered to, and the risk that harm could be committed by sexual harassment, exploitation, assault, emotional, verbal, physical, spiritual or financial abuse. Determine the risk level and assign a low, medium or high rating. Retain the worksheet, if used, as documentation of the decision-making process for assessing risk. A ministry can shift from medium to high risk depending on the specific setting, activity and leadership arrangement of a particular event. The highest risk activity within a given ministry will determine its risk rating. It is the nature of the position, not the person holding the position that determines the potential for risk.

Low Risk Ministries

Ministry duties and responsibilities that do not permit a person to be alone with a child or vulnerable adult, or do not permit access to financial resources or confidential information. Such ministries do not require a significant level of authority or trust.

Examples: arranger of coffee fellowship, audio-visual controller, bulletin folder, flower arranger, greeter, reader, some committee and group members

Medium Risk Ministries

Ministry duties and responsibilities that permit few chances for a person to be alone with a child or vulnerable adult or permit some access to moderate amounts of financial resources or confidential information. People in these ministries are in a position of authority or trust. Examples: adult Bible study leader, advisory board member, chairperson, lay eucharistic administrator, team collection counter, team nursing home visitor

High Risk Ministries

Ministry duties and responsibilities that permit opportunities for a person to be alone with a child or vulnerable adult or permit access to significant amounts of financial resources or sensitive and confidential information. These ministries are positions of authority or the positions that allows a person to establish long-term relationships of trust. All residential or off-site ministries with children or vulnerable adults are always ranked high risk.

Examples: camp leader, Christian education coordinator, church musician, churchwarden, clergy, counselor, home visitor, most parish employees, parish nurse, server instructor, Sunday school teacher, youth leader.

2.4 Reduce the Risk for Potential Harm

Whenever possible, the risk associated with any ministry should be lessened or eliminated. This can be accomplished by changing the size of a group being ministered to, the number of leaders required, the location and visibility of the ministry, the level of supervision or the degree of authority associated with the position. It is much easier, and ultimately safer, to reduce the risks associated with any ministry than to apply a higher level of screening.

2.5 Assign Appropriate Screening Standards to each Ministry Position

Low Risk Ministries

It is recommended that all people in these ministries:

1. Fill out an Application Form which does not require a list of references.
2. Receive a Ministry Description of the position.
3. Be trained for the ministry.
4. Meet regularly with a supervisor who will provide support, feedback, mentoring and information about the nature and duties of the ministry.

Medium Risk Ministries

It is required that all people in these ministries:

1. Be known to the organization or a regular Church attendee for at least 12 months or have a good reference from another parish before they are assigned to the ministry. (This may not be an appropriate requirement for paid employees.)
2. Fill out an Application Form which does not require a list of references.
3. Receive a Ministry Description for the position.
4. Be interviewed by the senior person responsible for the ministry to discern suitability. The discussion should include a review of the ministry description, the norms of the faith community and expected behaviour and attitudes required for the position.
5. Be trained for the ministry.
6. Attend a sexual misconduct policy training session at the beginning of the ministry and every three years thereafter. The person responsible for the ministry will ensure the person’s attendance is recorded and kept on file for an indefinite period of time.
7. Receive a copy of the Guidelines appropriate for their type of ministry.
8. Meet regularly with a supervisor who will provide support, feedback and mentoring.

High Risk Ministries

It is required that all people in these ministries:

1. Be known to the organization and a regular attender for at least 12 months or have a good reference from another parish before they are assigned to the ministry. (This may not be appropriate for paid employees.)
2. Fill out an Application Form and provide a list of three references. Sign a release on the Application Form allowing for reference checks. The senior person responsible for the ministry will ensure the reference checks are completed.
3. Receive a Ministry Description of the position.
4. Be interviewed by the senior person responsible for the ministry to discern suitability. The discussion should include a review of the ministry description, the norms of the faith community and expected behaviour and attitudes required for the position.
5. Be trained for the ministry.
6. Attend a sexual misconduct policy training session at the beginning of the ministry and every three years thereafter. The person responsible for the ministry will ensure the person’s attendance is recorded and keep on file for an indefinite period of time.
7. Receive a copy of the Guidelines appropriate for their type of ministry.
8. Document all one-on-one visits or meetings that occur with children or vulnerable adults.
9. All off-site activities involving children under the age of 16 shall require a parental consent form signed by parents or legal guardians.
10. Meet regularly with a supervisor who will provide support, feedback and mentoring.
11. Send a current background check (no more than one year old) from their local police department to the Diocesan Registrar.

2.6 Finalize Ministry Descriptions

The parish or organization will provide a Ministry Description for all medium and high risk ministries. The ministry descriptions will include the title, length of term, responsibilities, skills required, qualifications needed, limits of the position, reporting relationship, benefits and opportunities and screening requirements.

2.7 Establish Training and Supervision

Clear lines of supervision must be established for all ministry positions. All individuals ministering in positions of authority should have regularly scheduled meetings with a supervisor in order to discuss the ministry, ensure that their actions remain appropriate, and that participants are benefiting from the ministry. When an individual is in doubt about appropriate or inappropriate courses of action, or is in doubt about the vulnerability of a particular group or individual, or when he or she believes a boundary may have been crossed in the course of ministry, he or she must report the situation to the supervisor and seek advice on how to proceed. If the supervisory person is unable, unwilling or unavailable to assist, advice should be sought from another qualified individual. It is important that the supervisory or advisory person be identified in advance so that there is no question about whom to contact should it become necessary.

2.8 Apply the Screening Standards

All screening standards must be applied equitably and consistently. Do not lower the standards and do not skip steps. It is the nature of the position not the nature of the person holding the position which determines the standard. It is the responsibility of the organizational leadership (bishop, churchwardens, director, incumbent, priest-in-charge) to ensure that screening standards are implemented in the parish or organization.

2.9 Make a Selection Decision Based on the Screening Information

To make the selection decision:

1. Review the documented material.
2. List the screening standards and where concerns were raised, if any.
3. Obtain more information, if needed, e.g. a second interview.
4. Assess the information based on the nature of the ministry, services and activities provided; the degree of vulnerability of the participant; the relevant ethical and spiritual principles associated with the ministry and the potential risk for harm.
5. Assess the information objectively and consistently.
6. Determine suitability by exercising “best judgment.”

If the information obtained through the screening procedures does not raise any concerns then the applicant can be accepted into the ministry position. If a decision is made not to accept the person for a ministry position, they must be informed. Those implementing the screening process and making the selection decisions may be the Churchwardens, incumbent, organizational leader or individual who directly oversees the ministry. The selection decision is not communicated to the individual being screened until the incumbent or organizational leader ratifies the decision and signs the Screening Checklist. If there are concerns raised in the screening process, then the incumbent or organizational leader should be consulted.

The signing of the Screening Checklist is the responsibility of the incumbent or organizational leader. The incumbent or organizational leader may delegate all other screening responsibilities to another person(s) as long as the governing advisory board or committee ratifies this appointment.

2.10 Evaluate and Enforce the Screening Standards

The screening process does not stop when the individual is accepted for a ministry. Ongoing training, supervision and evaluation will be required. This policy is designed to assist parishes and organizations to implement a screening program appropriate to their context.

Section 3

3.1 Police Records Checks

The police records checks are only required for high-risk positions where the level of risk cannot be reduced through other methods. It is considered a prudent measure and is widely used by most volunteer agencies serving children and vulnerable adults. The police records check only provides limited information and so it must never be the most relied-upon screening standard.

A records check is required for all ordained ministry and normally for paid employee positions where there is a level of trust inherent in these positions of ministry/work and a lack of daily, structured supervision. An original records check, no older than one (1) year, is required at the beginning of a ministry.

The procedures for obtaining a police check varies among police departments in Ontario. However, the common practice is for the individual to fill out an application form obtained from the police department responsible for the area of the individual’s home address. The parish or organization will likely have to provide the individual with a copy of the Ministry Description to be included with the application form. Parish or organizational leaders may be contacted by the police department and asked to provide information about the ministry responsibilities. The police department then sends the individual the police record check.

The Diocesan Office will receive and store all information from police checks. In order to protect the privacy of information in the document the police record will be stored centrally at the Diocesan Centre and not in the parish. All information associated with this process will be handled in a confidential manner consistent with Provincial and Federal Privacy Standards.

Certain classes of convictions will automatically preclude an individual from filling a ministry position of trust with children or vulnerable adults (e.g. violent or sex-related crimes). In some cases the existence of an official pardon will be taken into consideration. An individual with a criminal history may be accepted into a ministry position so long as the convictions are not related to the tasks of that position.

3.2 Records Keeping

The minimum records that must be sent to The Diocesan Office are:

1. A copy of the Screening Checklist for all ministry positions ranked as High Risk.
2. The police background records check for those ministering in positions ranked as High Risk.

All screening documents (excluding the police background records check) should be stored in a locked filing cabinet in the parish for an indefinite period of time. Access to the filing cabinet shall be limited to the incumbent and the parish administrator or director. Those who have access to the files have a moral obligation to do everything within their power to maintain confidentiality. The location of the locked filing cabinet may or may not be at the parish.

However, if it is not at the parish, it must be in a location mutually agreed upon by those who have access to the files. Files must never be left out in the open or in a readily accessible location. People being screened should know who has access to their file. Only documentation that is necessary to the screening process should be kept on file. Although this type of record keeping and storage may be a difficult adjustment for some congregations, maintaining appropriate documentation is key to a meaningful screening program and is required as proof of implementation of the screening practices.

3.3 Individuals Holding Multiple Positions within the Parish

Individuals who hold more than one position within a parish or organization are to be screened in a manner consistent with the position that holds the highest level of risk and has the most stringent screening requirements.

3.4 Elected Positions within the Parish or Organization

There are a number of elected positions in most parishes and organizations. These positions are subject to the same screening procedures as all other positions. It should be made clear to both the elected individual and to the parish at large that following the election the individual will have to meet the requirements of the screening process before serving in the elected position. When possible, screening requirements should be addressed with nominees, prior to election in order to avoid potential confusion and/or embarrassment.

3.5 Sexual Offenders

Persons who have been found in a criminal proceeding to have committed sexual abuse of a child shall under no circumstances be given duties where they may be in contact with children.

According to the Ontario Child and Family Services Act, the parish will ensure all reasonable suspicions of sexual offence against children and vulnerable adults are reported to the police and Children’s Aid Society.

3.6 Changing Relationships

From time to time, relationships between parishioners and their families may move from ministry to friendship. In many cases this is to be celebrated, since an important role of the Church is building communities of friendship that reveal Christ’s love. Unfortunately, sexual offenders also attempt to form relationships that serve their own purposes and harm the most vulnerable. It is important to inform the incumbent and to be sensitive to responsible boundaries in any relationship of trust.

3.7 Compliance With Policy

This policy and a specific plan for its implementation were approved at the May 27, 2008 meeting of Synod Council. A target date of October 2008 has been established for all high risk ministries.

3.8 Outside Groups Using Church Property

While the Church or organization is not directly responsible for screening leaders of other organizations that use the Church’s property, it could be named in a legal action and held vicariously liable should there be charges of negligence or abuse. It is therefore necessary that the Church inquire into the screening procedure of the groups using the facilities. Where the screening procedures of an outside organization do not meet the standards outlined in this policy, a discussion should take place between the churchwardens and the user organization to determine an appropriate course of action. If the user group ministers to vulnerable people and is unable or unwilling to undertake proper precautions in terms of risk-reduction and/or screening procedures the Church must consider terminating the relationship for safety reasons.

3.9 Screening Standards for Parish Employees

Many of our Church employees are given authority, by virtue of their position, and perform their work/ministry with little supervision in places where they could have access to children and vulnerable adults. Therefore, normally, all paid positions in the Church will be ranked as a High Risk Ministry and the screening standards of this risk level are to be applied to it. Exceptions to this norm should be documented and kept with the ministry description for this position.

3.10 Screening Standards for Ordained Ministry

Ordained ministry takes place in a variety of contexts, some of which are unsupervised and demanding and where there is a highly visible public role. The ordained person must work with the vulnerable of society in such a manner that trust and pastoral integrity is never compromised. It is essential, therefore, that the Diocese make every effort to ensure the people who are called to ordained ministry are able to cope with this responsibility and trust. Ordained ministry is ranked as a High Risk Ministry and the screening standards of this risk level are to be applied to it. Ordained persons may also have to participate in additional screening activities such as a psychosexual assessment and attend a psychosexual education workshop at the beginning of ministry.