An orientation to security policies and procedures is provided for all new staff during New Staff Orientation and at least two times a year thereafter.

This Plan shall be reviewed and evaluated each year for its effectiveness, scope, performance and objectives. The review and evaluation will be conducted between March and May of each year, by a work group minimally consisting of the Director of Quality Assurance, the Director of Facilities, and the Chairpersons from each campus EOC Committee and/or their designee. The results of the review and evaluation, and related recommendations, will be reported sequentially to the campus EOC Committees and the Senior Management Team for their review and approval. Barring unforeseen and unavoidable delays, this revised Plan shall be implemented each July at the beginning of the new Program Year.

Hillcrest’s Workplace Violence policy and associated procedures are contained in Hillcrest Policies and Procedures.

While all Hillcrest employees are expected to attend to matters of safety and security, the following persons and groups are responsible for the implementation and monitoring of the Security Management Plan.
1. Agency level
At the agency level, security management is the responsibility of the agency Director of Quality Assurance and the Hillcrest Management Team.
2. Campus level
At the campus level, security management is the responsibility of the campus Program Director and their delegates (e.g., direct care Supervisors), and campus Environment of Care Committees.
At least once each month a residential campus Administrator will conduct and document an unannounced visit to and walk through of the campus during the overnight shift.

Sensitive areas include, but are not limited to:
• Areas where medications are stored.
• Areas where confidential student and client records and documents are filed.
• Areas where confidential employee records and documents are filed.
• Areas where controls for utilities can be accessed.
• Areas where money or expensive portable equipment is stored.
• Areas where potentially harmful equipment, tools and/or hazardous substances are stored.
• Campus swimming pools.
• Hillcrest computers and the computer network.
Sensitive areas will be locked at all times or constantly monitored when unlocked in order to control entry and egress. Any authorized, professional visitor to a Hillcrest campus is required to sign a Confidentiality Statement that outlines Hillcrest’s expectations for privacy and confidentiality for students, clients and student and client records.

Entry areas to campus swimming pools are locked and secured, and all pools meet or exceed local safety codes.

Access to Hillcrest computers, computerized student and client information and the Hillcrest computer network are restricted by a multi-level password system, with limited access and a firewall on the network. The Director of Information Services and the Executive Coordinator maintain copies of password lists. Access to the Internet is limited and is “filtered” according to standards set forth by the Federal Internet Protection Act. Computers used by students are not able to access the Hillcrest network. All networked computers utilize up-to-date virus software.

Key assignments are inventoried and controlled, and master keys are also inventoried, controlled and strictly limited to a small number of staff on a “need” basis.

During the overnight shift, exterior doors to all buildings are kept locked in order to limit entry to authorized personnel.

All Hillcrest work sites are small enough that almost all employees know one another. New or temporary employees are introduced to the community in brief information meetings, “Stand Ups”, which are conducted at the beginning of each shift.

All Hillcrest employees are required to wear HEC-standard photo identification at all times while working. Hillcrest maintains a database containing photos of all employees.

Visitors to any Hillcrest program site are required to sign in at the Reception area and to wear a Visitor’s Badge while on campus. All Hillcrest employees are trained to greet, confront and/or report any person who is not wearing a visitor badge and who is unknown to them or their coworkers. On residential campuses direct care supervisors make periodic sweeps of the campus during each shift, including a walk-through of each building on the campus during the overnight shift, providing additional security monitoring. Finally, student dormitories on residential campuses are monitored through the use of video camera, monitoring and taping equipment.

All Hillcrest employees are expected to report all potential or actual breaches of security or safety as soon as possible. Employees may report incidents, information and/or concerns to any supervisor or administrator at any Hillcrest site. If the security issue is not cause for immediate concern and response, employees may report the issue or concern to the campus Environment of Care Committee, or to the agency Administrator of Health, Safety & Wellness Programs, all of whom are obligated to investigate reported information and/or concerns in a thorough manner until they are appropriately resolved. Additionally, Hillcrest coordinates with local law enforcement agencies as needed.

All significant matters pertaining to security, including security-related incidents, are reported to and reviewed by campus Environment of Care Committees to insure that systemic security issues and possible patterns or trends are addressed and resolved.

Security issues at any Hillcrest campus or site are addressed by the supervisors, administrators and Environment of Care Committee at that campus, as well as by the agency Administrator of Health, Safety & Wellness Programs and Management Team. The agency has established relationships with local law enforcement agencies, and program administrators work in conjunction with local law enforcement agencies as needed. Safety and security in the environment of care, however, are shared benefits and fundamentally necessary conditions for which all employees are responsible. All Hillcrest employees are expected to be aware of and to attend to matters pertaining to safety and security in the course of their work. Employees are expected to report all potential or actual breaches of security or safety as soon as possible.

Program sites also address their unique security issues in ways best suited to their needs, campus setting and goals. For example, Hillcrest Center locks the Tetro Center at night and utilizes a call box at the entrance by which visitors can reach Supervisors on grounds.

The primary objectives of the Security Management Plan are to:
• Provide a secure and protective environment for students, clients, staff and visitors.
• Provide reasonable protection for the property of Hillcrest students, clients, staff, visitors and of the agency itself.
• Reduce the probability of harmful incidents.
• Hillcrest will accomplish these objectives in a manner compliant with regulations promulgated by the Mass. Dept. of Early Education and Care (DEEC), Mass. Department of Elementary and Secondary Education (DESE), standards established by the Joint Commission (JC), and all other applicable laws, regulations and standards.

Hillcrest Educational Centers is committed to the protection of Hillcrest students, clients, staff and visitors and to the physical property of the agency, students, clients, staff and visitors. The Security Management Plan and associated policies and procedures are intended to complement other plans, policies and procedures designed and implemented to insure a safe, secure, comfortable, and therapeutic environment of care.