• Compliance
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Considerations for Conducting Virtual Camps

Heather Salko, Esq.
May 2021
Recommendations to increase safety and reduce liability

Many institutions are converting traditional on-campus camps to “virtual” or online camps to provide more options for participation. However, if you are implementing this shift, consider the following practices for managing the safety and liability risks of running virtual camps.

Online Platforms and Security

The platform you choose to host your online camp should be appropriate for campers and camp activities and have robust security features. After choosing, understanding and configuring the platform’s security features, implement another layer of security by requiring all camp sessions to use:

  • A unique password
  • A “waiting room” for campers to wait, sequestered, before each session begins
  • A sign-in displaying only the camper’s first name and last initial to protect the camper’s identity
  • Virtual backgrounds, to allow for more privacy for counselors and campers
  • Limits on screen captures and screen sharing
  • A disabled chat feature, or limited chatting between the camper and the counselors/moderators only
  • A default so all campers are on “mute,” with campers un-muted individually by the counselor when there are questions or discussion comments

Train counselors/online moderators on these security features. Require at least two counselors be live in a session before allowing campers in from the waiting room. Train multiple counselors to be prepared to close the session in the event of inappropriate camper behavior or so-called “Zoom bombing” (infiltration by an unauthorized outsider). Most importantly, require counselors to practice these skills and discuss situations that may arise requiring the moderator to act.

Policy Review and Revision

A virtual space requires a review and possible revision of your camp policies to ensure they apply in an online environment and to address issues that can arise from the use or misuse of technology. You may already have policies for other online programs, and these policies are resources to reference as you review camp policies.

Camper Rules and Parent Handbooks

Ensure your policies pertaining to campers address cyberharassment, online bullying, and other inappropriate behavior. The virtual environment may require you to update your reporting or complaint procedures, as well as discipline options.

Explain expectations for parental behavior and involvement in the camp, especially if you are enrolling younger campers who may be unable to work independently.

Policies should prohibit sharing meeting links and passwords with other campers or children not enrolled in a camp session. Consider having parents, and possibly campers (depending on their age), electronically sign an acknowledgment that they have read and agree to your policies.

Employees

Because your workforce will be virtual, review your employee handbook to ensure online behavior guidelines are incorporated. Conducting your camp online instead of on campus shouldn’t allow counselors to behave informally during camper or parent interactions.

Explain that your social media and other information technology (IT) policies still apply. Policies should expressly prohibit one-on-one interactions between counselors and campers and prohibit counselors from “friending” or direct messaging campers. Copy a parent and another counselor (or supervisor) on any communication with a camper outside of a camp session.

Require employees to acknowledge that they have reviewed and agreed to abide by your employment policies.

Other Policies

This is a good opportunity to review your institution’s separate protecting minors policies to ensure the policies apply to a virtual environment. You also may wish to review your social media and IT use policies to account for working entirely in a virtual space, including the archiving of session materials and communications.

Training

Continue training employees on camp policies and practices but use virtual or remote-friendly training tactics. For example, explore options for online group training or use individual online training modules that each employee can complete separately.

More topics to consider training on for the virtual environment:

  • Safe online interactions
  • Boundary setting
  • IT safety
  • Security features of your platform (you also may consider training campers and parents on internet safety and your platform’s security features)

To prepare counselors to respond appropriately, if possible, practice real-life scenarios in your training.

Forms

You may need to revise standard camp forms to account for your new camp “location.” Work with your institution’s counsel to review and update these forms as necessary:

  • Waivers
  • Photography/video releases
  • Permission/consent forms for certain activities
  • Acknowledgment of receipt and review of policies

Laws

Depending on your location, different laws may impact virtual camps. Work with counsel to determine if different or additional laws apply to virtual rather than physical camps. Laws to consider include:

  • Children’s Online Privacy Protection Rule ( COPPA)
  • Privacy/recording limitations
  • Accessibility requirements and tools

Carefully note whether your registered campers live in other states and how that may impact your legal obligations.

Other Considerations

Moving to a virtual camp during the pandemic can create additional challenges:

  • Staff hiring. Hiring and screening new staff may take place entirely online. Conduct thorough interviews and leave adequate time for staff screening and background checks. These may be delayed, especially fingerprinting, as many jurisdictions do not have physical locations open to fingerprint during the pandemic.
  • Meeting and activity ratios. If all activities are virtual, it may be tempting to reduce staff to save money. However, consider the size of your camp sessions and keep your counselor-to-camper ratios the same or similar. Depending on how your online platform displays participants, you may need at least one staff member to look for camper questions and monitor participation or inappropriate behavior.
  • Equipment. Depending on the type of camp, some activities may require special equipment or supplies. Determine how to provide these. Will campers purchase them through your camp, on their own, or through a predetermined third-party supplier? Consistency may be important to assure the equipment meets relevant safety standards.
  • Safety practices and insurance. In addition to online safety practices, consider if other safety practices are necessary. These may vary from session to session or activity to activity. For example, sports skills camp may require reminding campers to check for safety hazards prior to beginning an activity. A STEM camp session may mean reminding campers to use safety goggles or other protective equipment.
  • Supervising counselors. Determine how you will monitor counselor work performance, provide feedback, and correct behavior.
  • Communications. Receive and respond to communications through designated camp channels. Do not provide personal email addresses or phone numbers of counselors or camp staff.
  • Behavior management and discipline. Campers must be held to appropriate behavioral standards. Determine how your staff will remotely manage inappropriate or unsafe camper behavior and impose appropriate discipline.
  • Parent involvement or participation. Younger campers may require parental assistance or participation in certain activities. Explain the expected level of parental involvement and consider whether you will need a separate waiver for parents participating in camp activities.
  • Intellectual property. Consider whether your materials contain music or other media that may be subject to copyright law. Work with counsel to get necessary clearances.

While there is a lot to consider in setting up a virtual camp, these enterprises can be run successfully with preparation and consideration.

 

More From UE

Educator Sexual Misconduct at K-12 Schools Resource Collection

Checklist for Camps on Campus

Minors and the Use of Releases

Protecting Children Course Collection for K-12

Address Accessibility in Your EIT Vendor Contracts

Data Security Course Collection

Additional Resources

University of Texas at Austin: Youth Protection Program

Virtual Training for Camp Staff Video

American Camp Association: Virtual Program Resources Page

American Camp Association: Considerations for Youth Protection in a Virtual World

University of Central Florida: Youth Protection Program Online Participation Agreement and Waiver Form

Praesidium: Electronic Communications with Youth in Challenging Times

Zoom: Best Practices for Securing Your Virtual Classroom

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