PRK Anti-Bullying Policy

Please read and understand these policies and procedures thoroughly before registering your child for any Keegan PLAY-RAH-KA activities. If you have concerns or questions about any of these items, please email

Objectives and Purpose

To facilitate our mission, Keegan PLAY-RAH-KA (PRK) has established this bullying prevention policy. This policy protects the dignity and safety of the Keegan PRK community and describes Keegan PRK’s prevention strategies to identify and prevent incidents. Keegan PRK will promptly report and investigate all incidents of bullying, harassment and intimidation and provide appropriate remedies for victims of an incident.

This policy serves as Keegan PRK’s bullying prevention plan.


Keegan PRK defines bullying as any severe, pervasive, or persistent act or conduct whether physical, electronic, or verbal that:

  1. May be based on a youth’s actual or perceived race, color, ethnicity, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, intellectual ability, familial status, family responsibilities, matriculation, political affiliation, genetic information, disability, source of income, status as a victim of an intrafamily offense, place or residence or business, or any other distinguishing characteristic, or on a youth’s association with a person, or group with any person, with one or more of the actual or perceived foregoing characteristics; and
  2. Can reasonably be predicted to:
    1. Place the youth in reasonable fear of physical harm to their person or property;
    2. Cause a substantial detrimental effect on the youth’s physical or mental health;
    3. Substantially interfere with the youth’s academic performance or attendance; or
    4. Substantially interfere with the youth’s ability to participate in or benefit from the services, activities, or privileges provided by an agency, educational institution, or grantee.
Prohibition Against Bullying

Acts of bullying, including cyberbullying, whether by youth, volunteers, or staff, are prohibited:

  1. On Keegan PRK grounds and immediately adjacent property, at Keegan PRK-sponsored or related events on and off Keegan PRK grounds, in any vehicle used for Keegan PRK business, at any transit stop at which youth wait to be transported to Keegan PRK business, or through the use of any electronic devices owned by Keegan PRK, leased by Keegan PRK or used for Keegan PRK business; and
  2. At a location or function unrelated to Keegan PRK, through the use of any electronic devices, including those not owned or leased by Keegan PRK, if the acts of bullying or cyberbullying create a hostile environment at the agency for the victim or witnesses, infringe on their rights at Keegan PRK, or materially and substantially disrupt the orderly operation of Keegan PRK.

Retaliation against a youth, volunteer or staff member who reports bullying, provides information about an act of bullying, or witnesses an act of bullying is also prohibited.

Policy Development
Publication and Contact Information

This policy will be made available on Keegan PRK’s website. Keegan PRK emphasizes that the policy applies to participation in functions sponsored by Keegan PRK. Additionally, this policy will be included in all publications of agency rules, regulations, and solicitations and agreements for contracts and grants.

Keegan PRK’s Director of Education is responsible for coordinating Keegan PRK’s bullying prevention efforts. All questions, comments and concerns about the bullying policy and Keegan PRK prevention efforts should be directed to the Director of Education at

Prevention Leadership

Responsibility for the implementation and execution of this policy is vested with the Director of Education who shall have responsibility for:

  1. Planning and organizing the prevention plan’s professional development activities and coordinating these activities with the Artistic and Managing Directors of Keegan Theatre;
  2. Receiving and recording incidents of bullying;
  3. Responding to incidents of bullying and addressing the needs of victims and bullies;
  4. Managing the data collaboration and collection process;
  5. Regularly reviewing and updating the policy and any procedures developed as part of it.

If the Director of Education chooses to delegate responsibility for any of these areas, it must be done in consultation with Keegan’s Managing Director.

Policy Evaluation

Keegan PRK will annually review and update this policy.

Primary Prevention Strategies
Create Positive Agency Atmosphere

Keegan PRK will establish a culture of respect and safety. As part of this commitment, Keegan PRK will incorporate bullying prevention messages and efforts into all aspects of its operations that serve youth or that support youth serving operations.

Staff must be committed to creating a positive and respectful environment. 

Code of Conduct

Keegan PRK expects youth to behave in a way that supports Keegan PRK’s objective to provide a safe and welcoming environment for other youth, Keegan PRK staff, and community members. Youth who are part of the Keegan PRK community are expected to:

  1. Treat all members of the Keegan PRK community with respect;
  2. Respect the property of Keegan PRK, its staff, and other youth connected to Keegan PRK; 
  3. Respond appropriately to instructions from Keegan PRK staff.
Training and Professional Development

Keegan PRK will provide to all personnel whose duties consistently bring them into contact with youth by design or incident, training on Keegan PRK’s prevention curriculum, as well as the procedures for responding to and reporting an incident of bullying. Staff will also learn to engage with each other and youth reflectively to build an agency-wide atmosphere of respect. Staff will have the appropriate background checks needed to ensure they are allowed to work with children.

Data Collection
Incident Database

Keegan PRK will create a dataset of all incident and service measures designated in this policy. This data will not include any identifying information about the bully, victim, or witnesses. Given the sensitive nature of information contained in this database, only the Director of Education will have access to individualizing information in the database.

Incident Measures

Keegan PRK will collect the following pieces of information about reported incidents of bullying: 

  1. Name(s) of the victim, bully, and any witnesses
    1. Reliable contact information for the victim, bully and any witnesses
  2. Relevant attributes about the victim, bully and any witnesses including:
    1. Any prior incidents involving either the victim or bully
    2. Connection of the victim, bully, and any witnesses to the incident (i.e. are they students, staff, volunteers, etc.)
  3. The nature of the bullying incident
    1. Where the incident took place
    2. What time the incident took place
    3. What type(s) of bullying it was (physical, verbal, cyber, relational, etc.?)
    4. What factors drove the incident of bullying (social status, personal appearance, race, sexual orientation, etc.)
    5. What adult supervision was in place
    6. Context of the incident

Keegan PRK will only attempt to collect this information insofar as it does not jeopardize the safety of the victim and witness(es) and allows non-staff reports of bullying to be made anonymously.

Keegan PRK will take every possible measure to ensure the privacy and confidentiality of all parties in an incident. To ensure confidentiality, reports provided to outside agencies will not include identifying information about the parties involved in an incident, and will report data only in the aggregate.

Secondary Prevention Strategies
Identifying At-Risk Groups

All staff at Keegan PRK will actively seek out youth who are at risk of being victims or bullies to proactively remedy incidents of bullying before they occur. In determining whether a youth is at risk of being a victim of aggression, staff will consider the following risk factors:

  1. Individual factors
    1. Cautious, sensitive, insecure personality
    2. Difficulty asserting themselves among peers
    3. Physical weakness, particularly in boys
  2. Parental factors
    1.  Possible overprotective parents
  3. Peer risk factors
    1. Lack of close friends.

Risk factors for being a bully in an incident include:

  1. Individual factors
    1. Impulsive, hot-headed, dominant personality lacking empathy
    2. Difficulty conforming to rules and low frustration tolerance
    3. Positive attitudes toward violence
    4. Gradually decreasing interest in school or academic achievement
  2. Parental factors
    1. Lack of parental warmth and involvement
    2. Overly-permissive or excessively harsh discipline/physical punishment by parents
    3. Lack of parental supervision
  3. Peer risk factors
    1. Friends/peers with positive attitudes towards violence
    2. Exposure to models of bullying
Controlling At-Risk Areas

If a location on Keegan PRK premises is identified by Keegan PRK’s data collection efforts as being particularly prone to hosting incidents of bullying, the prevention specialist will take steps to improve the safety and security of that location for Keegan PRK youth. These steps will include:

  1. Reducing youth traffic to these areas by altering schedules or activities;
  2. Reducing the number of youth of different ages or activity groups in an at-risk area by altering schedules or activities;
  3. Increasing supervision in these areas, and training supervising staff in the identification of bullying behaviors particularly common in that place.

Keegan PRK will take measures to address an at-risk location no more than one month after receiving information on the presence of such an area on Keegan PRK premises.

Tertiary Prevention Strategies
Reporting Incidents of Bullying or Retaliation

Keegan PRK expects all staff members and volunteers to report incidents of bullying or retaliation they witness or are made aware of. Staff members should immediately report all such incidents to the Director of Education who will create a written report of a bullying incident and include the incident in Keegan PRK reports of bullying incidents to the citywide coordinator.

Youth, parents, guardians, and community members are encouraged by Keegan PRK to report any incidents of bullying that they witness or become aware of. Reports of bullying may be made to; 1742 Church St. NW, Washington, DC 20036, Director of Education Jared Graham at (202) 265-3767. An anonymous reporting form can also be found here:

Reports of bullying by youth, parents, guardians and community members may be made anonymously, but disciplinary action cannot be taken by Keegan PRK solely on the basis of an anonymous report, though such a report may trigger an investigation that will provide actionable information. All oral reports received as part of this process will be transcribed into writing and included in Keegan PRK’s bullying database.

The Director of Education is available to assist in reporting incidents of bullying and can be reached at (202) 265-3767.

Reports of bullying not received by the Director of Education will be transmitted to them within one day of their receipt or creation by the staff member who reported the initial incident.

Investigating Incidents of Bullying

Prior to the investigation of an incident, the Director of Education will take steps to ensure the safety of the alleged victim referenced in a reported bullying incident. These steps will be designed to restore a sense of safety to the victim and to protect them from further incidents if necessary. Once an investigation is concluded, further steps will be taken as needed to assure the continued safety of the victim from additional incidents of bullying or retaliation.

Once a report of bullying has been received, the following groups will be notified as needed by the Director of Education, so long as, in the absence of legal imperative, the parent or guardian’s written consent is obtained prior to notification.

Parents and guardians: Keegan PRK will notify the parents or guardians of victims, bullies, and if appropriate, witnesses to an incident of bullying behavior about the nature of the incident and the procedures and steps in place for responding to it. The prevention specialist will determine if parents or guardians should be informed prior to or after the investigation of an incident.

Schools: Keegan PRK will notify the schools of all victims and bullies in an incident of bullying to ensure that youth are not victimized across agencies and that comprehensive service and protection can be provided to bullies and victims.

Law enforcement agencies: If Keegan PRK determines that the reported incident may involve criminal activity or the basis for criminal charges, information about the incident must be conveyed to the appropriate law enforcement authorities. As part of making this determination the prevention specialist may wish to consult with either a law enforcement officer or legal counsel. Law enforcement shall only be contacted if all other available remedies have been exhausted.

Keegan PRK will notify these groups of incidents of bullying only to the extent allowed by law. Notification will be undertaken solely to ensure that services are provided to victims and bullies and to protect victims from further or sustained victimization. Keegan PRK will make every effort to protect the confidentiality of those who report bullying incidents.

The Director of Education is responsible for investigating reports of bullying and can be reached at An investigation of an incident will be initiated no more than one day after the Director of Education receives a report of bullying and will conclude no later than 30 days after the receipt of such a report. As part of the investigation the Director of Education will interview any involved or relevant parties including alleged victims, bullies, witnesses, staff, parents or guardians.

The Director of Education will provide confidentiality as far as possible to relevant parties as part of the investigation, and inform all relevant parties that retaliation for reporting acts of bullying is prohibited. Written records of the investigation process should be maintained and may be included in the prevention database to generate a more accurate picture of bullying behaviors at Keegan PRK. Where necessary, provisions will be made to include the advice of legal counsel.

In investigating an incident of bullying, the Director of Education will seek to ensure that the reported incident is one of victimization, a sign of bullying, rather than of conflict. 

The Director of Education is charged with making determinations as to whether a reported incident constitutes a case of bullying. These determinations will be made in consideration of the totality of the facts and the circumstances surrounding the incident. If the Director of Education determines that an incident of bullying has occurred, they should take the response steps enumerated in Keegan PRK’s tertiary prevention plan to prevent the recurrence of an incident and restore the safety of a victim.

If the Director of Education determines that additional support is needed to conduct a thorough and equitable investigation they will contact the citywide prevention coordinator.

Sanctions and Remedies for Bullying

Keegan PRK recognizes that for sanctions to be an effective component of a bullying prevention plan, they must be applied consistently, fairly, and equitably. To this end, Keegan PRK shall ensure that staff follow these guidelines as closely as possible, while allowing for flexibility to adapt sanctions to individual contexts. Furthermore, to ensure equitability in applying sanctions, measures will be applied on a graduated basis determined by the nature of the offense, the disciplinary history of the youth involved, and the age and developmental status of the youth involved. Responses to incidents of bullying may include, but are not limited to:

  • Reprimand
  • Deprivation of Keegan PRK privileges
  • Bans on participating in optional Keegan PRK activities
  • Deprivation of Keegan PRK services
  • Ban or suspension from Keegan PRK facilities

Sanctions will be applied within two business days of the determination that an incident of bullying has occurred, unless an appeal of the incident by the bully has been received in that time as described in the Appeals section of this policy.

Keegan PRK does not endorse the use of punitive strategies associated with “zero-tolerance” policies when applying sanctions to an incident of bullying.

Keegan PRK shall communicate to youth in contact with Keegan PRK, the consequences that youth can expect for participating in bullying behavior.

Rewards for Third Party Prevention

Keegan PRK encourages third party reporting of bullying and constructive intervention in incidents, and recognizes that it may take considerable courage for a youth to intervene in an act of bullying in a way that does not exacerbate the situation. Therefore, Keegan PRK may choose to recognize and/ or reward youth who make a positive contribution to the Keegan PRK climate by intervening in an act of bullying. Examples of such rewards include, but are not limited to praise, granting of special or additional privileges at Keegan PRK or rewards. Provided public recognition will not create harm for the youth, rewards may be provided in a public forum to serve as a positive example and encourage other youth who might be encouraged to intervene in a bullying incident and to further promote a positive agency atmosphere.


Parties dissatisfied by the outcome of a bullying investigation may appeal the determination of the Director of Education to the Keegan Theatre Managing Director. This appeal should be submitted no later than 30 days after the initial determination. Upon receipt of an appeal, the Keegan PRK director must conduct a secondary investigation within 30 days of the receipt of an appeal. This 30 days may be extended by up to an additional 15 days if the Keegan Theatre Managing Director sets forth in writing the reasons why more time is needed to conduct an investigation. Additionally, upon the receipt of an appeal, the Keegan Theatre Managing Director must inform the party making the submission of their ability to seek additional redress under the DC Human Rights Act.

If you have concerns or questions about any of these items, please email