I am writing to provide feedback and seek clarifications on the reporting and investigation procedures outlined in the guidance document for incidents of peer-on-peer aggression. Additionally, I would like to offer some recommendations to enhance the effectiveness and clarity of the document.

1. Reporting Criteria and Timelines: a) The document mentions incidents that meet certain criteria should be reported to the Office of Human Rights (OHR). However, it would be beneficial to clarify whether these incidents should undergo an internal review by the provider prior to reporting. If an internal review is required, it would be helpful to provide a timeframe for conducting this review, ensuring a prompt determination of reportable incidents. b) Regarding the reporting timeframe, it is essential to clarify whether the 24-hour deadline for entering incidents into CHRIS is based on the date of discovery or the date of the provider's determination that an incident is reportable. This clarification will ensure consistency and adherence to reporting obligations.

2. Description of Incidents and Staff Names: a) The guidance document suggests including the names of provider staff members in the description of an incident if they are alleged to be involved. However, I recommend refraining from entering the names of staff members in the CHRIS system at this stage. This approach will prevent potential bias and allow for a fair investigation, ensuring that all relevant data is gathered before making a final determination. Furthermore, it will address the concerns of staff members and alleviate any unnecessary anxiety they may experience.

3. Physical and Emotional Harm: a) The document defines physical harm as evidence of open wounds, bruises, black eyes, lacerations, or broken bones. However, it is important to also consider other forms of physical harm that may not manifest in visible injuries. I recommend expanding the definition to include a broader range of physical harm to encompass all possible manifestations of harm resulting from peer-on-peer aggression. b) In regard to emotional harm, the document mentions documented changes in an individual's behavior as evidence. To provide further clarity, it would be helpful to specify that clinical documentation from a qualified professional can also serve as evidence of emotional harm. This clarification will ensure a comprehensive understanding of emotional harm and facilitate accurate assessments during investigations.

4. Reporting to Other Authorities: a) The document mentions reporting incidents to appropriate authorities in certain cases, such as sexual assault or other reportable crimes. It would be beneficial to provide further examples of incidents that require reporting to other entities, such as physical assault or exploitation, to ensure comprehensive and consistent reporting practices. Additionally, clarifying the potential for collaborative investigations with external entities, such as the police or social services, will enhance the understanding of the reporting and investigation processes.

Thank you for considering my feedback and recommendations. I believe that incorporating these clarifications and revisions will enhance the accuracy, effectiveness, and clarity of the reporting and investigation procedures outlined in the guidance document. Should you require any further information or clarification, please do not hesitate to reach out. I look forward to your response and continued collaboration.