Standards for private organizations

2020 Edition

Services for Unaccompanied Children (UC) 9: Privacy Provisions

The organization provides for comfort, dignity, privacy, and safety.
NA The organization provides post-release services only.
2020 Edition




Unaccompanied Children Services support youth safety and well-being, facilitate family involvement and provide necessary supports to children seeking physical and emotional safety and legal protection.
All elements or requirements outlined in the standard are evident in practice, as indicated by full implementation of the practices outlined in the Practice Standards.
Practices are basically sound but there is room for improvement, as noted in the ratings for the Practice Standards; e.g.,
  • Minor inconsistencies and not yet fully developed practices are noted; however, these do not significantly impact service quality; or
  • Procedures need strengthening; or
  • With few exceptions, procedures are understood by staff and are being used; or
  • For the most part, established timeframes are met; or
  • Proper documentation is the norm and any issues with individual staff members are being addressed through performance evaluations and training; or
  • Active client participation occurs to a considerable extent.
Practice requires significant improvement, as noted in the ratings for the Practice Standards. Service quality or program functioning may be compromised; e.g.,
  • Procedures and/or case record documentation need significant strengthening; or
  • Procedures are not well-understood or used appropriately; or
  • Timeframes are often missed; or
  • Several client records are missing important information; or
  • Client participation is inconsistent. 
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the Practice Standards; e.g.,
  • No written procedures, or procedures are clearly inadequate or not being used; or 
  • Documentation is routinely incomplete and/or missing.      
Self-Study EvidenceOn-Site EvidenceOn-Site Activities
  • Privacy policy
  • Privacy procedures
  • Judicial order, law, or contract, as applicable (UC 9.02 b.)
  • Interviews may include:
    1. Program director
    2. Relevant personnel
    3. Children served
  • Observe facility

Fundamental Practice

UC 9.01

The organization ensures service recipients' comfort, dignity, privacy, and safety by:
  1. prohibiting the use of surveillance cameras or listening devices of persons in bedrooms;
  2. maintaining doors on sleeping areas and bathroom enclosures;
  3. providing one- or two-person rooms to service recipients who need extra sleep, protection from sleep disturbance, or extra privacy for clinical reasons; and
  4. requiring employees to knock before entering a service recipient's room unless there is an immediate health or safety concern.


When organizations are required to employ alternate practices, documentation must be provided to justify the practice. Documentation may include a judicial order, law, contract, a copy of the state's safety plan for a resident, or clear, clinical written justification for a resident.

Sensitivity should always be taken to ensure that all service recipients, especially abuse or trauma survivors and the LGBTQ population, feel safe and not violated.

Fundamental Practice

UC 9.02

Searches of children or their property are conducted in a trauma-informed manner that respects client rights, dignity, and self-determination and include, as appropriate to the frequency and invasiveness of searches: 
  1. communicating to service recipients policies for searches of individuals or their property;
  2. timely notification of required parties within the ORR network;
  3. definition and documentation of reasonable cause and assessed risk of harm to self or others;
  4. trained, qualified staff; and
  5. an administrative review process including documentation, notification, and the timetable for review.


The invasiveness of the search to be conducted has a direct impact on all aspects of search procedures. Organizations must demonstrate that more invasive searches are associated with an increased level of risk, reasonable cause, staff competence, and level of administrative review. More invasive searches should only be performed only by specially trained and qualified staff.

Fundamental Practice

UC 9.03

The organization respects the child’s privacy by only reviewing mail when a previous incident involving the child indicates that: 
  1. the mail is suspected of containing unauthorized, dangerous, or illegal material or substances, in which case it may be opened by the child in the presence of designated personnel; or
  2. receipt or sending of unopened mail is contraindicated with a clinical or legal justification.


Organizations should have electronic messaging and social networking policies, procedures, and/or protocols for staff and children and their families.


Correspondence between children and their families, friends, and other social supports should be encouraged, and not monitored nor used as a reward or punishment.
Examples: Examples of mail include: letters, packages, emails, and other forms of correspondence via electronic messaging.

Fundamental Practice

UC 9.04

All children can have private telephone conversations, and any restriction is: 
  1. based on contraindications and/or a court order;
  2. approved in advance by the program director or an appropriate designee;
  3. documented in the case record; and
  4. re-authorized weekly by the immediate supervisor of the direct service provider.