Child Sexual Abuse and Exploitation (CSAE) Policy and Reporting Procedure
The Miles Foundation, Inc. dba Best Place for Students!®
Effective Date: April 14, 2025
1. Zero-Tolerance Policy
Best Place for Students! maintains a zero-tolerance policy toward all forms of Child Sexual Abuse and Exploitation (CSAE), including the production, possession, or distribution of Child Sexual Abuse Material (CSAM). This policy is grounded in our commitment to safeguarding the dignity and safety of minors and is enforced across all content and communications involving our website, www.BestPlace4Students.com (the “Site”).
Any conduct, communication, or content that promotes or facilitates CSAE or CSAM is strictly prohibited and will be reported to the appropriate authorities.
2. Prohibited Conduct
Users are strictly prohibited from engaging in or facilitating any of the following on or through the Site:
- Possessing, producing, distributing, or linking to child pornography or any depiction of minors in sexually explicit conduct, as defined in 18 U.S.C. § 2256.
- Sharing or soliciting personal information from minors for inappropriate or exploitative purposes.
- Uploading content that sexualizes minors or depicts them in a manner that is harmful, predatory, or coercive.
- Transmitting messages or engaging in activities that harass, victimize, or intimidate minors.
Any attempt to bypass these restrictions or obscure abusive behavior will be treated as a violation of this policy.
3. Reporting Suspected CSAE or CSAM
We urge any user who suspects the presence of CSAE-related content or behavior to report it immediately. Reports can be made by contacting:
Sara Redington
Chief Philanthropy Officer
The Miles Foundation
Email: sredington@milesfdn.org
Reports are treated with the highest level of confidentiality and urgency.
4. Internal Response Procedure
Upon receiving a report of suspected CSAE or CSAM, the following steps will be taken by designated TMF staff:
A. Verification
Trained personnel will review the reported content to determine whether it qualifies as CSAM or CSAE under applicable laws. This verification process ensures accurate identification and compliance.
B. Immediate Action
If confirmed, the content will be immediately removed from the Site. The user associated with the content will be permanently banned, and relevant data preserved.
C. Reporting to Authorities
Confirmed CSAM will be reported promptly and without delay to the National Center for Missing and Exploited Children (NCMEC) via the CyberTipline, in accordance with the PROTECT Act (18 U.S.C. § 2258A). The report will include:
- Nature and location of the content
- Time of discovery
- Relevant user information (e.g., email, IP address)
- Contextual details of the incident
Law enforcement cooperation will be extended as necessary.
5. Recordkeeping and Confidentiality
We maintain secure records of all CSAE/CSAM reports, reviews, and actions taken. These records:
- Are kept for a minimum of five (5) years, or longer if required by law
- Are stored securely in compliance with data protection regulations
- Are accessible only to authorized personnel
- Will not be disclosed except as required by law or in cooperation with law enforcement
6. Ongoing Training and Policy Review
TMF personnel involved in content moderation or site management will receive initial and annual CSAE/CSAM training covering legal obligations, reporting procedures, and responsible handling practices.
This policy will be reviewed and updated annually, or as necessary to ensure continued alignment with evolving laws and best practices for child protection.
7. Legal Compliance
We comply fully with all applicable federal and state laws regarding CSAE, including:
- The PROTECT Act (18 U.S.C. § 2258A)
- 18 U.S.C. § 2256 (definitions of CSAM and child pornography)
- Any additional laws or regulations imposed by federal or local authorities
Violators may be subject to civil and criminal penalties.
If you have questions or need to report CSAE-related concerns, please contact us directly at sredington@milesfdn.org.