Legacy Haven Academy Child Protection and Safeguarding Policy

Policy Number:  
LHA-SEC-002
Version:  
1.0
Effective Date:  
October 12, 2025
Review Date:  
October 1, 2026
Last Updated:  
October 12, 2025
Functional Area Manager:  
Director of Security

1. Introduction

Legacy Haven Academy Foundation (the "Academy") is committed to creating a safe, nurturing environment for vulnerable youth, particularly orphans and homeless individuals aged 10-18, as outlined in its mission to foster lifelong learning, character development, and whole-person wellness through hands-on education, mentorship, and community engagement (Legacy Haven Academy, n.d.). This Child Protection and Safeguarding Policy establishes comprehensive standards to prevent abuse, neglect, and harm while promoting the well-being of all participants. The policy aligns with Arizona Department of Child Safety (DCS) guidelines for vulnerable youth in educational and out-of-home care settings, which emphasize educational stability, trauma-informed care, and preparation for adulthood (Arizona Department of Child Safety [DCS], 2024a; DCS, 2024b). It incorporates Applied Suicide Intervention Skills Training (ASIST) principles for suicide prevention, recognizing the heightened mental health risks among vulnerable youth (LivingWorks, 2023; Substance Abuse and Mental Health Services Administration [SAMHSA], 2025).

As the Academy pursues 501(c)(3) tax-exempt status under the Internal Revenue Code, this policy demonstrates adherence to federal requirements for charitable organizations serving children, including risk mitigation and ethical operations (Internal Revenue Service [IRS], 2025a; Venable LLP, 2024). Compliance with Arizona Revised Statutes (A.R.S.) Title 8 (Child Safety) and Title 13 (Criminal Code), as well as Mohave County oversight through DCS regional offices, ensures alignment with state and local mandates (Arizona Legislature, 2024a; DCS, 2024c). This policy applies to all staff, volunteers, contractors, board members, and visitors interacting with youth.

2. Scope

This policy covers all Academy programs, including academic instruction, mentorship, outdoor adventures, wellness activities, and residential care elements. It addresses physical, emotional, sexual, and neglectful abuse, as well as self-harm risks. Vulnerable youth are defined per DCS as those in out-of-home care, experiencing homelessness, or facing trauma, with tailored supports for educational continuity and transition to adulthood (DCS, 2024b; Child Welfare Information Gateway, 2024a).

3. Definitions

  • Abuse: Physical injury, sexual exploitation, emotional harm, or neglect endangering a minor's health or welfare (A.R.S. § 8-201; DCS, 2024d).
  • Mandatory Reporter: Any Academy personnel, per A.R.S. § 13-3620, required to report suspected abuse (Arizona Attorney General's Office, n.d.; Child Welfare Information Gateway, 2024b).
  • Vulnerable Youth: Minors aged 10-18 at elevated risk due to orphan status, homelessness, or prior trauma (DCS, 2024a).
  • Safeguarding: Proactive measures to prevent harm, including screening, training, and response protocols (Safe Kids Thrive, n.d.a; Venable LLP, 2024).

4. Background Checks and Screening

All individuals interacting with youth must undergo rigorous screening prior to engagement and renewed every five years, per Arizona Department of Education and DCS requirements (Arizona Department of Economic Security [DES], n.d.; DCS, 2020). This includes:

  • Fingerprint Clearance Card
    • Frequency: Initial and every 5 years
    • Responsible Party: HR/Academy Director
    • Compliance Reference: A.R.S. § 41-1758.07 (Arizona Legislature, 2024b)
  • Central Registry Check
    • Frequency: Initial and every 5 years
    • Responsible Party: DCS Liaison
    • Compliance Reference: DCS Policy (DCS, 2020)
  • Reference & Interview
    • Frequency: Initial
    • Responsible Party: Selection Committee
    • Compliance Reference: Best Practices (Safe Kids Thrive, n.d.b)
  • Annual Volunteer Check
    • Frequency: Annually
    • Responsible Party: Volunteer Coordinator
    • Compliance Reference: DES Guidelines (DES, n.d.)

Additional screening includes reference checks, self-disclosure forms, and interviews assessing prior experience with youth. Volunteers require annual verified background checks via third-party services (Lutheran Social Services of the Southwest, n.d.). Immediate disqualification applies for convictions of child-related offenses; conditional approval for minor infractions requires DCS review. The Academy will maintain confidential records in a secure system, ensuring compliance with IRS governance standards for risk management in youth-serving nonprofits (IRS, 2025b; Venable LLP, 2024). Mohave County DCS will be consulted for local applicability in educational/residential contexts (DCS, 2024c).

5. Training Requirements

All personnel must complete mandatory training within 30 days of onboarding and annually thereafter, aligning with DCS educational supports for foster/vulnerable youth (DCS, 2024a; Arizona Health Care Cost Containment System [AHCCCS], 2021).

  • Core Training: 4-hour module on recognizing abuse signs, mandatory reporting, and trauma-informed care (DCS, 2024d; Child Welfare Information Gateway, 2024b).
  • ASIST Integration: Two-day ASIST certification for all staff, focusing on suicide risk identification, intervention, and safety planning—critical for vulnerable youth with mental health vulnerabilities (SAMHSA, 2025; LivingWorks, 2023; AHCCCS, n.d.).
  • Specialized Modules: For mentors and residential staff, include boundary-setting, cultural sensitivity, and emergency response (Safe Kids Thrive, n.d.a; Venable LLP, 2024).
  • Documentation: Training records tracked via learning management system; non-compliance results in suspension.

This exceeds IRS expectations for operational integrity in child-focused organizations (IRS, 2025a).

6. Abuse Reporting Procedures

The Academy enforces zero tolerance for abuse, mandating immediate reporting per A.R.S. § 13-3620(A), which requires oral reports within 24 hours and written follow-up within 48 hours to DCS or law enforcement (Arizona Legislature, 2024c; Maricopa County Attorney's Office, n.d.).

  • Internal Protocol: Suspected incidents reported confidentially to the Designated Safeguarding Officer (DSO) via hotline (928-XXX-XXXX) or secure form. DSO assesses urgency and notifies DCS Child Abuse Hotline (1-888-SOS-CHILD) if imminent danger exists.
  • External Reporting: Direct DCS contact for all allegations; no internal investigation precedes external report to avoid conflicts (DCS, 2024d; Child Welfare Information Gateway, 2024b).
  • Anonymous Reporting: Encouraged for youth/staff; whistleblower protections per IRS nonprofit governance (IRS, 2025b).
  • Mohave County Coordination: Reports routed through local DCS office for expedited response in rural settings (DCS, 2024c).

Failure to report is a Class 1 misdemeanor (A.R.S. § 13-3620(B)).

7. Prevention Measures

Proactive strategies mitigate risks, per best practices for youth academies (National Council of Youth Sports [NCYS], 2021; Centers for Disease Control and Prevention [CDC], n.d.):

  • Supervision Ratios: 1:8 staff-to-youth in activities; two-deep leadership (no single adult with child).
  • Physical Environment: Secure facilities with cameras in common areas; private reporting spaces.
  • Youth Empowerment: Age-appropriate education on rights, boundaries, and ASIST-informed self-advocacy (LivingWorks, 2023; DCS, 2024b).
  • Monitoring: Annual audits and anonymous surveys to identify concerns.

8. Response to Allegations

Upon report:

  1. Ensure youth safety (e.g., temporary separation).
  2. Notify DCS/law enforcement within 24 hours.
  3. Cooperate with investigations; suspend accused pending outcome.
  4. Provide support services (counseling, educational continuity) per DCS standards (DCS, 2024a).
  5. Document and review for policy improvements.

Aligns with IRS risk management for 501(c)(3) applicants (Venable LLP, 2024).

9. Record Keeping and Confidentiality

Records maintained securely for 7 years (or until age 21 for youth), accessible only to authorized parties. Breaches reported to DCS (A.R.S. § 8-807; DES, n.d.).

10. Policy Review and Compliance

Annual review by Board/DSO, with input from DCS and ASIST trainers. Violations subject to disciplinary action, up to termination. The Academy will seek DCS licensing as a child welfare agency upon 501(c)(3) approval (Arizona Administrative Code Title 21, Chapter 7; DCS, 2024e).

Appendix A: References

AHCCCS. (n.d.). Suicide prevention training for schools. Arizona Health Care Cost Containment System. https://www.azahcccs.gov/Members/BehavioralHealthServices/suicideprevention/training_for_schools.html

AHCCCS. (2021). Trauma-informed approach [PDF]. https://www.azahcccs.gov/AHCCCS/Downloads/TraumaInformedRec24.pdf

Arizona Attorney General's Office. (n.d.). Arizona's mandatory reporting laws [PDF]. https://dcs.az.gov/sites/default/files/documents/files/MandatedReporterTraining-Education-overview_0.pdf

Arizona Department of Child Safety. (2020). Employee central registry check policy [PDF]. https://dcs.az.gov/sites/default/files/documents/files/EmployeeCentralRegistryCheckPolicy_.pdf

Arizona Department of Child Safety. (2024a). Student education services. https://dcs.az.gov/Education

Arizona Department of Child Safety. (2024b). Services and supports to prepare youth for adulthood. https://extranet.azdcs.gov/DCSPolicy/Content/Program%2520Policy/05-Child_Permanency/05%2520Transition%2520to%2520Adulthood/CH5_S31%2520Services%2520Supports%2520to%2520Prepare%2520Youth%2520for%2520Adulthood.htm

Arizona Department of Child Safety. (2024c). Mohave County. https://dcs.az.gov/counties/mohave

Arizona Department of Child Safety. (2024d). DCS laws, rules, and policies. https://dcs.az.gov/about/policy

Arizona Department of Child Safety. (2024e). Welcome to DCS program policy. https://extranet.azdcs.gov/DCSPolicy/Content/Program%2520Policy/Program_Policy.htm

Arizona Department of Economic Security. (n.d.). Background check requirements for child care staff [PDF]. https://des.az.gov/sites/default/files/dl/CCA-1301A.pdf

Arizona Legislature. (2024a). Title 8 - Child safety. https://www.azleg.gov/arsDetail/?title=8

Arizona Legislature. (2024b). A.R.S. § 41-1758.07. https://www.azleg.gov/ars/41/01758-07.htm

Arizona Legislature. (2024c). 13-3620 - Duty to report abuse, physical injury, neglect and denial or deprivation of medical or surgical care or nutritional intervention. https://www.azleg.gov/ars/13/03620.htm

Centers for Disease Control and Prevention. (n.d.). Preventing child sexual abuse within youth-serving organizations [PDF]. https://www.cdc.gov/child-abuse-neglect/communication-resources/PreventingChildSexualAbuse-a.pdf

Child Welfare Information Gateway. (2024a). Educational supports for youth in foster care - Arizona. https://www.childwelfare.gov/resources/educational-supports-youth-foster-care-arizona/

Child Welfare Information Gateway. (2024b). Mandatory reporting of child abuse and neglect - Arizona. https://www.childwelfare.gov/resources/mandatory-reporting-child-abuse-and-neglect-arizona/

GoodHire. (2024, February 20). Arizona background checks. https://www.goodhire.com/background-checks/arizona/

Internal Revenue Service. (2025a). Exemption requirements - 501(c)(3) organizations. https://www.irs.gov/charities-non-profits/charitable-organizations/exemption-requirements-501c3-organizations

Internal Revenue Service. (2025b). Publication 557 (Rev. January 2025) [PDF]. https://www.irs.gov/pub/irs-pdf/p557.pdf

Legacy Haven Academy. (n.d.). Legacy Haven Academy. https://legacyhavenacademy.org/

LivingWorks. (2023). Trainee experiences, recommendations, and post-training behavior [PDF]. https://livingworks.net/wp-content/uploads/2023/09/ASIST-Experiences-and-Recommendations.pdf

Lutheran Social Services of the Southwest. (n.d.). Volunteer background clearance guidelines. https://www.lss-sw.org/background-clearance

Maricopa County Attorney's Office. (n.d.). Mandatory reporting. https://maricopacountyattorney.org/544/Mandatory-Reporting

National Council of Youth Sports. (2021). Best practices and guidelines [PDF]. https://www.ncys.org/wp-content/uploads/2021/07/NCYS_Guidelines-Final-1.pdf

Safe Kids Thrive. (n.d.a). Best practices in training to prevent child sexual abuse. https://safekidsthrive.org/prevention-topics/training/training-best-practices/

Safe Kids Thrive. (n.d.b). Preventing child abuse - Screening & background checks. https://safekidsthrive.org/the-report/key-sections/section-2-screening-and-background-checks-for-selecting-employees-and-volunteers/

Substance Abuse and Mental Health Services Administration. (2025, February 21). Applied suicide intervention skills training (ASIST). https://www.samhsa.gov/resource/dbhis/applied-suicide-intervention-skills-training-asist

Venable LLP. (2024, April 11). Nonprofits managing risk for youth programs: Ten key compliance considerations. https://www.venable.com/insights/publications/2024/04/nonprofits-managing-risk-for-youth-programs