PROCEDURES FOR POSITIVE CRC/VSC SCREENINGS RECEIVED

If the Centre receives the CRC results or an OD from a conditionally hired employee or existing staff member; Or if the individual’s criminal history come to the attention of Kids Come First through social media or the News and the results reveal

• that the employee has been either charged with/convicted of an offence under the Criminal Code involving sexual conduct and minors, or
• which indicates that a child may be at risk of harm or injury,

the Executive Director or Designate will:

1. Put the staff of immediate paid leave of absence
2. Inform the Centre’s Board of Director’s Executive – Committee. If it is a Director or Officer, a committee will be formed by the remaining members.
3. Pursuant to the Early Childhood Educators Act, Kids Come First will promptly report this information in writing to the College of Early Childhood Educators, if applicable.
4. Request written particulars from the candidate regarding the information referenced in the Screening results.
5. Review the written documentation with the Board of Director’s Executive Committee in order to assess eligibility for employment, continued employment or volunteering with the Centre. An assessment shall include consideration of the following factors which shall assist the Committee in determining if the candidate, employee or volunteer is considered a high risk with respect to having direct contact with children:

• Requirements of the position;
• Nature of the offence(s);
• Sentencing received (if any);
• Date of the offence; and
• Rehabilitation efforts made by the candidate (if any)
• Candidates or volunteers with certain convictions under the Criminal Code that have not been pardoned such as sexual interference, child pornography, duty of persons to provide necessaries, murder and infanticide will not be considered. Current employees or volunteers who receive any of the foregoing convictions may be disciplined, up to and including termination from employment.

1. Prepare a recommendation on the candidate’s eligibility for employment at the Centre for review and approval by the Centre’s Board of Directors.
2. The Executive Director will carefully document all discussion.
3. Advise the applicant of the decision in writing.

The final decision on eligibility for employment with the Centre will depend on the Board of Director’s opinion on whether the candidate would be considered a high risk to have direct contact with the children at the Centre.

Where the immediate health and safety of the children are a concern (e.g. a PRC, OD or attestation reveals that an individual has been convicted of child pornography), the licensee or designate will:

• follow the serious occurrence policies and procedures;
• notify the local Children’s Aid Society immediately in accordance with “duty to report” obligations under the Child and Family Services Act or subsequent legislation; and
• notify other authorities (e.g., College of Early Childhood Educators, Consolidated Municipal Service Manager/District Social Services Administration Board, local police service, local public health, etc.), as applicable.

Glossary

Attestation: A written declaration provided for an ‘other person’ who provides child care or other services to children in a child care centre, completed by the person’s employer or the person or entity who retained the person’s services (e.g. a parent/guardian of a child). See the Attestations section of this policy for information on what needs to be included in an attestation.

Break in a Relationship with the Licensee: The ending of a relationship between the licensee and an individual from whom a VSC is required (i.e. employee, student or volunteer) that is later restarted. Examples of breaks in relationship include, but are not limited to:

• The end of an employee’s contract and the start of a new contract after a period of time has passed.

• A student’s placement ends and the student is hired as an employee the following week.

• A volunteer completes their volunteer hours and starts volunteering again after a period of time has passed.

Breaks in relationship do not include vacations, parental leaves or sick leaves where the person intends to return to their position after a period of time.

Police Record Check: A document concerning an individual that was prepared by a police service or service from national data on the Canadian Police Information Centre system and contains information concerning the individual’s personal criminal history. There are three types of police record checks: (1) Criminal Record Checks (2) Criminal Records and Judicial Matters Checks (3) Vulnerable Sector Checks.

• Criminal Record Check (CRC): A basic type of police record check that is not intended for people who are seeking positions working with vulnerable persons.

• Criminal Records and Judicial Matters Check: A type of police record check that may include criminal convictions, findings of guilt under the Youth Criminal Justice Act (Canada), outstanding charges, warrants and judicial orders, absolute discharges, conditional discharges and other records as authorized by the Criminal Records Act (Canada). This check is not intended for people who are seeking positions with vulnerable persons and cannot take the place of a vulnerable sector check.

• Vulnerable Sector Check (VSC): An enhanced type of criminal record check for persons who may hold positions of trust or authority over vulnerable persons, that is performed at the request of an organization responsible for the well-being of a child or vulnerable person to protect children and vulnerable persons, as governed by section 6.3(3) of the Criminal Records Act (Canada). A VSC verifies whether an individual has a criminal record and any record suspensions for sexual offences and local police records for information relevant to the VSC.

Interacting: To be or become involved in communication, social activity or work with somebody else or one another (Source: Encarta Dictionary). Examples of interactions with children include conversing, playing, directing, intervening, supervising or assisting in fulfilling their needs (e.g. food/drink consumption, toilet use).

Offence Declaration (OD): A written declaration signed by an individual that lists all of their convictions for offences under the Criminal Code (Canada), if any, during the period stated in the declaration.

Other person providing child care or other services to children at the child care centre (‘other person’): Any person who provides child care or other services to a child who receives child care at the child care centre, other than an employee, student or volunteer (e.g. resource teachers, nurses, occupational therapists, speech pathologists, entertainers, sport/activity instructors, etc.). This would not include Ministry of Education program advisors, fire/health inspectors, CAS investigators, quality assurance analysts or other inspectors.

Student: An individual who is on an educational placement with the child care centre and interacts with children in care.

Volunteer: An individual who participates in the child care program and interacts with children in care but is not paid by the licensee (e.g. parents assisting on an occasional or recurring basis with child care programming, such as excursions, field trips, etc.).

Vulnerable Person: A person who, because of his or her age, disability or other circumstances, whether temporary or permanent is:

1. in a position of dependency on others; or

2. is otherwise at a greater risk than the general population of being harmed by a person in a position of trust or authority towards them.

Revised: July 1, 2026

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Page updated September 2026