•  The Willow Hill School
    Bullying Prevention and Intervention Plan 
    Priority Statement: Willow Hill School is committed to providing an environment where students, faculty and staff have the right to be free from, bullying and cyber-bullying, as well as harassment, hazing, or any form of discrimination or retaliation. These prohibitions apply to students, staff or any combination of interactions. The School will not tolerate any of the above unlawful or disruptive behaviors, in the school buildings, on school grounds, or in school-related activities.  The School will investigate promptly, all reports and complaints of bullying, cyber-bullying, harassment, hazing and retaliation and take prompt action to end that behavior and restore the target’s sense of safety.  The School will support this commitment in all aspects of the school community, including curricula, instructional programs, staff development, extracurricular activities, and parent or guardian involvement.


    Overview of the Willow Hill School 


    The Willow Hill School is a non-profit, independent co-educational day school grades 6-12 approved by the Massachusetts Department of Elementary and Secondary Education as an Approved Private Special Education School. The 67 students enrolled at Willow Hill come from 42 cities and towns. The student population served is primarily diagnosed with Attention Deficit Disorder, Aspergers Syndrome, Language Based and Non-Verbal Learning Disabilities.  The educational journey has not been easy for many of our students. Several have experienced being the target of aggressive or bullying behaviors by others. Our small, personalized, environment and low staff to student ratio promotes the fundamental skills necessary to build self-confidence. Emphasis on personal and social growth is integrated throughout the daily life at the school. Students on campus and in school-sponsored activities off campus are supervised at all times. Our class sizes are usually between 3-8 students and we have a 3-1 staff to student ratio. All students are assigned an advisor and meet with that adult every Friday morning.   Bullying is rarely experienced by our students while in the confines of our School.  


    Definitions: Harassment refers to conduct, behavior or comments that are personally offensive, degrading or threatening to others.  The following will be considered in determining if behavior constitutes harassment:


     The nature and intent of the behavior,


    • Feelings of the person at whom the behavior was directed,
    • Motivation for the behavior (i.e. religion, ethnicity),
    • Effects of the behavior on the school community, and
    • Frequency of the behavior.



    Physical Harassment includes pushing, hitting, punching, kicking, blocking a person’s ability to move freely, throwing objects intentionally at person.


    Verbal Harassment refers to threats or negative remarks based on race, gender, physical appearance, sexual orientation, religion, handicap, ethnicity, or national origin. Harassment over the Internet or through e-mail is included.  If it is determined that e-mail sent from computers off campus and after school is clearly connected to behavior or conduct in school that poses a threat or harm to an individual in school, or disrupts the activities of the school in any way, or students, the school reserves the right to impose consequences.


    Sexual Harassment includes any unwanted physical or verbal sexual attention.  Attention may include spreading sexual gossip, unwanted sexual comments, pressure for sexual activity, unwanted physical contact, displaying sexually offensive signs, clothing, pictures, or jokes.  Any complaint must include as much information as possible such as names, date, location of alleged incident, time, description of setting and description of behavior.  Any written complaints submitted to administration will be reviewed and discussed with all parties involved.  Falsely accusing another of sexual harassment will be taken very seriously.


    Hazing means any conduct used to initiate a student into any student group that willfully or recklessly endangers the physical or emotional well being of another.  Any form of hazing or coercion is prohibited and will result in disciplinary action.  If a student knows that another student is the victim of hazing, it is their responsibility to report the information to a teacher or administrator.


    Bullying means the severe or repeated use by one or more students of a written, verbal, or electronic expression, or a physical act or gesture, or any combination thereof, directed at another student that has the effect of: causing physical or emotional harm to the other student or damage to the other student’s property;  placing the other student in reasonable fear of harm to himself/herself or of damage to his/her property;  creating a hostile environment at school for the other student;  infringing on the rights of the other student at school; or  materially and substantially disrupting the education process or the orderly operation of a school.


    Cyber-bullying means bullying through the use of technology or any electronic means, such as telephones, cell phones, computers, and the Internet.  It includes, but is not limited to, email, instant messages, text messages, and Internet postings.  See M.G.L. c. 71, § 37O for the legal definition of cyber-bullying.


    Hostile Environment, as defined in M.G.L. c. 71, § 37O, means a situation in which bullying causes the school environment to permeate with intimidation, ridicule or insult that is sufficiently severe or pervasive to alter the conditions of the student’s education and create an abusive school environment.


    Retaliation is any form of intimidation, reprisal, or harassment directed against a student who reports bullying, provides information during an investigation of bullying, or witnesses or has reliable information about bullying.

    Aggressor means the student who engages in bullying, cyber-bullying, harassment, hazing, discrimination or retaliation.


    Target means the student against whom bullying, cyber-bullying, harassment, discrimination  or retaliation has been perpetrated.


    I.  Leadership


    A. Public involvement in developing the plan


    The plan will be developed in consultation with various constituencies. This involvement will include:


    The Willow Hill School’s administrative staff, teachers, professional support staff, students and parents;


    Consultation will include notice and a public comment period prior to adoption.


    B. Assessing needs and resources


    The Head of School with input from parents and staff will assess the adequacy of current programs. This may include:


    Review of current policies and procedures;


    Assessments of initial and periodic needs, by surveying students, staff and parents/guardians on school climate and school safety issues.


    C. Planning and oversight


    The Director of Education will be responsible for the following tasks under the Plan:


    Receiving reports on bullying;


    1. Creating a process for recording and tracking reports;
    2. Identifying and recommending supports that will respond to the needs of targets and aggressors.



    The Head of School will be responsible for the following tasks:


    Amending student and staff handbooks and codes of conduct;



      1. Updating the Plan annually or more frequently;


      1. Leading the parent engagement efforts;


      1. Developing new or revised policies and protocols under the Plan.



    II.  Training and Professional Development


    Annual staff training: Annual training for all Willow Hill School staff includes staff duties, an overview of the steps that the Head of School or designee will follow upon receipt of a report of bullying or retaliation, and an overview of the bullying prevention curricula to be offered at all grades throughout the School.  Staff members hired after the start of the school year are required to participate in school-based training during the school year in which they are hired, unless they can demonstrate participation in an acceptable and comparable program within the last two years.  Training may be conducted by a staff member who is part of the “Train the Trainer” program through MARC at Bridgewater State University.


    Ongoing professional development: The goal of professional development is to establish a common understanding of tools necessary for staff to create a school climate that promotes safety, civil communication, and respect for differences.  Professional development will build the skills of staff members to prevent, identify, and respond to bullying.  The content of school wide professional development will be informed by research and will include information on:


    (i)   developmentally (or age-) appropriate strategies to prevent bullying;


    (ii)  developmentally (or age-) appropriate strategies for immediate, effective  


          interventions to stop bullying incidents;


    (iii) information regarding the complex interaction and power differential that can take


          place between and among an aggressor, target, and witnesses to the bullying;


    (iv) research findings on bullying, including information about specific categories of


          students who have been shown to be particularly at risk for bullying in the school




    (v)  information on the incidence and nature of cyber-bullying; and


    (vi) Internet safety issues as they relate to cyber-bullying. 


    Professional development will also address ways to prevent and respond to bullying or retaliation for students with disabilities.  This will include a particular focus on the needs of students with autism or students whose disability affects social skills development.


    Written notice to staff: The School will provide all staff with an annual written notice of the Plan by publishing information about it, including sections related to staff duties and the code of conduct.  This information is available in the Willow Hill Faculty and Staff Handbook and is updated annually, as needed. 


    III. Access to Resources and Services


    Resources and Counseling and other Services:  Willow Hill School has a full-time licensed School Counselor who provides programs in Social Skills and Transitional Planning, which includes lessons on bullying, to all students.  This person is also the liaison between the School and student’s outside therapists and is able to provide individual counseling, on an as needed basis.  Additional services and resources are coordinated with the referring school districts. Willow Hill also has an ongoing relationship with Dr. Scott McLeod and Dot Lucci, from YouthCare, which is affiliated with Mass General Hospital.  Referrals to outside agencies are also channeled through parents and the home school district.


    IV. Academic and Non-Academic Activities 


    Specific prevention approaches:  Social Skills is an ongoing aspect of the Willow Hill curriculum.  It is addressed more specifically in the Social Skills and Transitional Planning classes, using a variety of materials and discussions.  Information about the Plan is included in the Student/Parent Handbook.  Approaches to bullying prevention may include:



      • using scripts and role plays to develop skills;


      • empowering students to take action by knowing what to do when they witness other students engaged in acts of bullying or retaliation, including seeking adult assistance;


      • helping students understand the dynamics of bullying and cyber-bullying, including the underlying power imbalance;


      • emphasizing cyber-safety, including safe and appropriate use of electronic communication technologies;


      • enhancing students’ skills for engaging in healthy relationships and respectful communications; and


      • engaging  students in a safe, supportive school environment that is respectful of diversity and difference.



    Approaches to support bullying prevention efforts:   The following approaches are integral to establishing a safe and supportive school environment.  They underscore the importance of bullying intervention and prevention initiatives:



      • setting clear expectations for students and establishing school and classroom routines;


      • creating safe school and classroom environments for all students, including those students with disabilities, those who may be lesbian, gay, bisexual, transgender or homeless students;


      • using appropriate and positive responses and reinforcement, even when students require discipline;


      • using positive behavioral supports;


      • encouraging adults to develop positive relationships with students;


      • modeling, teaching, and rewarding pro-social, healthy, and respectful behaviors;


      • using positive approaches to behavioral health, including collaborative problem-solving, conflict resolution training, teamwork, and positive behavioral supports that aid in social and emotional development;


      • using the Internet safely; and


      • supporting students’ interest and participation in non-academic and extracurricular activities, particularly in their areas of strength.



    V.  Procedures for Reporting and Responding


    Reporting bullying or retaliation: Reports of bullying or retaliation may be made by staff, students, parents or guardians, or others, and may be oral or written.  Oral reports made by or to a staff member shall then be recorded in writing.  A school staff member is required to immediately report to the Head of School or designee any instance of probable bullying or retaliation the staff member becomes aware of or witnesses.  The School will make a variety of reporting resources available to the school community including, but not limited to, an Incident Reporting Form, (see attached).


    Use of an Incident Reporting Form is not required as a condition of making a report.  The School will include a copy of the Incident Reporting Form in the Faculty and Staff Handbook, as well as in the Parent and Student Handbook.  It will also be available in the School’s main office, the office of the Head of School, the office of the Director of Education, the counseling office, and other locations determined by the Head of School or designee. The form will, additionally be posted on the School’s website.  The Incident Reporting Form will be made available in the most prevalent language(s) of origin of students and parents or guardians. 


    At the beginning of each school year, the School will provide the school community, including administrators, staff, students, and parents or guardians, with written notice of its policies for reporting acts of bullying and retaliation.  A description of the  reporting procedures and resources, including the name and contact information of the Head of School or designee, will be incorporated in student and staff handbooks, on the school website, and in information about the Plan that is made available to parents or guardians.  All parents and students will be required to sign-off, acknowledging that they have read and will adhere to the Plan.


    A staff member will immediately report to the Head of School or designee when he/she witnesses or becomes aware of conduct that has the probability of bullying or retaliation.  The requirement to report to the Head of School or designee does not limit the authority of the staff member to respond to behavioral or disciplinary incidents consistent with school or district policies and procedures for behavior management and discipline.


    The School expects students, parents or guardians, and others who witness or become aware of an instance of probable bullying or retaliation involving a student, to report it to the Head of School or designee.   Students, parents or guardians, and others may request assistance from a staff member to complete a written report.  Students will be provided practical, safe, private and age-appropriate ways to report and discuss an incident of bullying with a staff member or with the Head of School or designee.


    Responding to a report of the probability of bullying or retaliation:  Before fully investigating the allegations of bullying or retaliation, the Head of School or designee will take steps to assess the need to restore a sense of safety to the alleged target and/or to protect the alleged target from possible further incidents.  Responses to promote safety may include, but not be limited to, creating a personal safety plan; pre-determining seating arrangements for the target and/or the aggressor in the classroom, at lunch, or on the bus; identifying a staff member who will act as a “safe person” for the target; and altering the aggressor’s schedule and access to the target.  The Head of School or designee will take additional steps to promote safety during the course of and after the investigation, as necessary.


    The Head of School or designee will implement appropriate strategies for protecting from bullying or retaliation a student who has reported bullying or retaliation, a student who has witnessed bullying or retaliation, a student who provides information during an investigation, or a student who has reliable information about a reported act of bullying or retaliation.  Retaliation against anyone that has filed a complaint will not be tolerated.  Acts of retaliation may result in disciplinary action up to and including suspension, termination or expulsion.


    Upon determining that bullying or retaliation has occurred, the Head of School or designee will promptly, within 24 hours, notify the parents or guardians of the target and the aggressor, that an incident has occurred  and of the procedures for responding to it.  There may be circumstances in which the Head of School or designee contacts parents or guardians prior to any investigation.  Notice will be consistent with state regulations at 603 CMR 49.00.


    If the reported incident involves students from more than one school district, charter school, non-public school, approved private special education day or residential school, or collaborative school, the Head of School of Willow Hill or designee first informed of the incident will promptly notify, by telephone, the Head of School, principal or designee of the other school(s), so that each school may take appropriate action.  All communications will be in accordance with state and federal privacy laws and regulations, and 603 CMR 49.00.


    At any point after receiving a report of bullying or retaliation, including after an investigation, if the Head of School or designee has a reasonable basis to believe that criminal charges may be pursued against the aggressor, the Head of School will notify the local law enforcement agency.  Notice will be consistent with the requirements of 603 CMR 49.00 and locally established agreements with the local law enforcement agency.  Also, if an incident occurs on school grounds and involves a former student under the age of 21 who is no longer enrolled in school, the Head of School or designee shall contact the local law enforcement agency if he or she has a reasonable basis to believe that criminal charges may be pursued against the aggressor.


    In making this determination, the Head of School will, consistent with the Plan and with applicable school or district policies and procedures, consult with the school resource officer, if any, and other individuals the Head of School or designee deems appropriate. 


    Investigation:  The Head of School or designee will investigate, within 24 hours, all reports of bullying or retaliation and, in doing so, will consider all available information known, including the nature of the allegation(s) and the ages of the students involved. 


    During the investigation the Head of School or designee will, among other things, interview students, staff, witnesses, parents or guardians, and others as necessary. The Head of School or designee will remind the alleged aggressor, target, and witnesses that retaliation is strictly prohibited and will result in disciplinary action. 


    Interviews may be conducted by the Head of School or designee, other staff members as determined by the Head of School or designee, and in consultation with the school counselor, as appropriate.  To the extent practicable, and given his/her obligation to investigate and address the matter, the Head of School or designee will maintain confidentiality during the investigative process. The Head of School or designee will maintain a written record of the investigation. 


    Procedures for investigating reports of bullying and retaliation will be consistent with school or district policies and procedures for investigations.  If necessary, the Head of School or designee will consult with legal counsel about the investigation.


    Determinations:  The Head of School or designee will make a determination based upon all of the facts and circumstances.  If, after investigation, bullying or retaliation is substantiated, the Head of School or designee will take steps reasonably calculated to prevent recurrence and to ensure that the target is not restricted in participating in school or in benefiting from school activities.  The Head of School or designee will determine what remedial action is required, if any, and what responsive actions and/or disciplinary action is necessary.


    Depending upon the circumstances, the Head of School or designee may choose to consult with the students’ teacher(s) and/or school counselor, and the target’s or aggressor’s parents or guardians, to identify any underlying social or emotional issue(s) that may have contributed to the bullying behavior and to assess the level of need for additional social skills development.


    The Head of School or designee will notify the parents or guardians of the target and the aggressor about the results of the investigation, within 24 hours of completion of the investigation, and, if bullying or retaliation is found, what action is being taken to prevent further acts of bullying or retaliation.  All notice to parents must comply with applicable state and federal privacy laws and regulations.  Because of the legal requirements regarding the confidentiality of student records, the Head of School or designee cannot report specific information to the target’s parent or guardian about the disciplinary action taken, against the aggressor, unless it involves a “stay away” order or other directive that the target must be aware of in order to report any further violations.


    Responses to Bullying:  Upon the Head of School or designee determining that bullying or retaliation has occurred, the law requires that the School use a range of responses that balance the need for accountability with the need to teach appropriate behavior.  M.G.L. c. 71, § 37O(d)(v).  Skill-building approaches that the Head of School or designee may consider include but are not limited to:



      • offering individualized skill-building sessions based on the school’s anti-bullying curricula


      •  providing relevant educational activities for individual students or groups of students, in consultation with guidance counselors and other appropriate school personnel;


      •  implementing a range of academic and nonacademic positive behavioral supports to help students understand pro-social ways to achieve their goals;


      •  meeting with parents and guardians to engage parental support and to reinforce the anti-bullying curricula and social skills building activities at home;


      • adopting behavioral plans to include a focus on developing specific social skills;


      • make a referral for evaluation.



    If the Head of School or designee decides that disciplinary action is appropriate, the disciplinary action will be determined on the basis of facts found by the Head of School or designee, including the nature of the conduct, the age of the student(s) involved, and the need to balance accountability with the teaching of appropriate behavior.  Discipline will be consistent with the Plan and with the school’s code of conduct, which is available in the Parent and Student Handbook.


    Discipline procedures for students with disabilities are governed by the federal Individuals with Disabilities Education Improvement Act (IDEA), which should be read in cooperation with state laws regarding student discipline. 


    If the Head of School or designee determines that a student knowingly made a false allegation of bullying or retaliation, that student may be subject to disciplinary action.


    The Head of School or designee will consider what adjustments, if any, are needed in the school environment to enhance the target's sense of safety and that of others as well.  One strategy that the Head of School or designee may use is to increase adult supervision at transition times and in locations where bullying is known to have occurred or is likely to occur. 


    Within a reasonable period of time, not more than 2 weeks, following the determination and the ordering of remedial and/or disciplinary action, the Head of School or designee will contact the target to determine whether there has been a recurrence of the prohibited conduct and whether additional supportive measures are needed.  If so, the Head of School or designee will work with appropriate school staff to implement them immediately.


    Collaboration with Families


    Willow Hill will offer education programs for parents and guardians that are focused on the parental components of the anti-bullying curricula and any social competency curricula used by the district or school.  The programs will be offered in collaboration with the WHPA. In the past programs on internet use and safety, encompassing cyber-bullying, have been offered through the Sudbury Police and these may be offered again.  Other programs may be offered through YouthCare, an affiliate of Mass. General Hospital.


    Each year the school will inform parents or guardians of enrolled students about the anti-bullying curricula that are being used. This notice will include information about the dynamics of bullying, including cyber-bullying and online safety.  The school will send parents written notice each year about the student-related sections of the Plan and the school's Internet safety policy.   Parents and students are required to sign-off that they have read and agree to the terms of the Internet safety policy.  All notices and information made available to parents or guardians will be in hard copy and electronic formats, and will be available in the language(s) most prevalent among parents or guardians.  The School will also post the Plan and related information on its website.  


    Prohibition against Bullying and Retaliation


    Acts of bullying, which include cyberbullying, harassment, hazing or discrimination and retaliation, are prohibited on school grounds and property immediately adjacent to school grounds; at a school-sponsored or school-­related activity, function, or program whether on or off school grounds; at a school bus stop; on a school bus or other vehicle owned, leased, or used by a school district or school; or through the use of technology or an electronic device owned, leased, or used by the school. 


    The above acts are also prohibited at a location, activity, function, or program that is not school-­related but is conducted through the use of technology or an electronic device that is not owned, leased, or used by a school district or school, if the acts create a hostile environment at school for the target or witnesses, infringe on their rights at school, or materially and substantially disrupt the education process or the orderly operation of a school. 


    Retaliation against a person who reports bullying, provides information during an investigation of bullying, or witnesses or has reliable information about bullying is also prohibited.*


    *Parts of this Plan have been modeled on and duplicated from the Massachusetts Department of Elementary and Secondary Education’s August 2010 Model Bullying Prevention and Intervention Plan.


    Revised: December 13, 2010



    Willow Hill School


    Bullying Prevention/Intervention


    Reporting Form




    1.      Name of the Reporter/Person Filing the Report ______________________________




    2.      Check whether you are the: Target of the behavior   Reporter (not the target)




    3.      Check whether you are a: Student  Staff member (specify role)___________


                                                             Parent   Administrator Other (specify) ________




    4.      Information about the Incident:




         Name of Target (of behavior): _______________________________________


         Name of Aggressor (person who engaged in the behavior): ________________


         Date(s) of Incident(s): _____________________________________________


         Time When Incident(s) Occurred: ___________________________________


         Location of Incident(s) (Be as specific as possible): ______________________








    5.      Witnesses (List people who saw the incident or have information about it):




         Name: ________________________________  Student   Staff   Other


         Name: ________________________________  Student   Staff   Other


         Name: ________________________________  Student   Staff   Other




    6.      Describe the details of the incident (Including names of people involved, what occurred, and what each person did and said, including specific words used).  Please use additional space on back if necessary.




    (Please use additional paper and attach to this document as needed)












    7.      Signature of Person Filing this Report: _____________________Date: ______


    8.      Form given to: ____________________  Position: _______ Date: __________




    Signature: ________________________________ Date Received: __________










    1.      Investigator(s): _____________________________ Position(s) _____________




    2.      Interviews:


              Interviewed aggressor    Name: ______________________Date:________


           Interviewed target           Name: ______________________ Date:________


                □ Interviewed witnesses   Name: ______________________Date:_________


                                                               Name: ______________________ Date:_________




    3.      Any prior documented incidents by the aggressor?  Yes     No


    If yes, have incidents involved target or target group previously? Yes  No


    Any previous incidents with findings of Bullying, Retaliation         Yes  No


    Summary of Investigation:










    (Please use additional paper and attach to this document as needed)










    1.  Finding of bullying or retaliation:   Yes     No




         Bullying                    Incident documented as ________________________


         Retaliation                 Discipline referral only __________________________


    2. Contacts:


        Target’s parent/guardian        Date: ______________


        Aggressor’s parent/guardian Date: _______________


    3. Action Taken:


         Loss of Privileges   Detention   Suspension


         Community Service  Education  Other ___________________________ 


    4.      Describe Safety Planning:_______________________________________________


    Follow-up with Target: scheduled for _______ Initial and date when completed: ______


    Follow-up with Aggressor: scheduled for ____ Initial and date when completed: _____


    Report forwarded to Head of School: Date _______(if Head of School was not the investigator)


    Signature and Title: ______________________________________ Date: _________