Some additional thoughts:
in point 3:
The elders do not
shield any perpetrator of child abuse from the authorities.
Sure, they take no positive action to shield abusers, but isn't the very fact that they consult the branch office to find out if they're legally required to report the abuser (instead of, you know, just reporting the abuser...) to authorities a form of shielding the abuser? They'll first shield the organization from potential legal problems by complying with law, but if that's not an issue, then they shield the abuser by refusing to report them. All this statement is really saying is that if the authorities subpoena their records about an abuser they'll provide them. Oh, wait, no they won't even do that - they'll fight a legal battle to prevent providing their records on abusers to the point of paying millions of dollars of donated money to avoid it. I guess really all this is saying is that if police bust into a kingdom hall to arrest the abuser, they won't try to stop them.
In all cases, victims and their parents have the right to report an accusation of child abuse to
the authorities. Therefore, victims, their parents, or anyone else who reports such an accusation to the
elders are clearly informed by the elders that they have the right to report the matter to the authorities.
Elders do not criticize anyone who chooses to make such a report
Riiiiiiight. I'll believe that when I see it. Even if I'd grant that elders wouldn't criticize someone that reports child abuse, the culture of not reporting anything to the authorities when legal troubles arise between JWs is so strong that it's virtually guaranteed that someone (probably many) in the congregation will criticize the reporter of abuse, and they will very likely be somewhat ostracized as a result. To make matters worse, this fact is absolutely present in the mind of anyone that's been a JW for any length of time, which makes it less likely that abuse will be reported. And just like their claim that they don't shield abusers, this statement is likely only true if interpreted very narrowly. Maybe elders won't "discourage" reporting the abuse, and maybe they won't "criticize" someone that does, but it's been well documented that they will generally "provide a warning" that reporting abuse could result in them being brought before a JC on charges of slander.
in point 5:
If the alleged abuser is one of the victim’s parents, the elders will inform the
Let's just think for a moment about why a child might be reporting one of their parents' abuse to the elders. Could it be that 1) they already told their other parent and were met with skepticism, punishment, or an ineffective attempt to end the abuse or 2) that they fear telling the parent will result in option 1? In either of those two cases, which are unfortunately all too common in the world at large (and I suspect even more common in situations where people believe themselves and the abuser to be among the 0.1% most virtuous people in the world, as is the case with JWs) it seems that the action to take should be to first inform the authorities, then the other parent.
Their policy of informing the other parent of the abuse reminds me of their policy to send replies to letters from individuals to their elders. This reflects the authoritarian, pyramid-shaped, power structure that they're all to eager to reinforce because it's the very core of how the cult (indeed any cult) is run and sustained.
Elsewhere in point 5:
Even if the elders have no legal duty to report an accusation to the authorities, the branch office of Jehovah’s Witnesses will instruct the elders to report the matter if a minor is still in danger of abuse
Isn't it just so heartening to know that it will be one or more elders, men completely uneducated in the fields of social services, child protection, or criminal psychology will be the ones to make the determination of whether a minor is still in danger from the accused abuser. Why would you ever want impartial authorities to make that decision? (sarcasm)
in point 8:
and their families may decide to consult a mental-health professional. This is a personal decision.
Again, while this is technically true, the culture in JW-land is explicitly opposed to seeking help from mental-health professionals. The reason for this goes directly to statements in their own literature that comes from the top. So while it's "a personal decision" it's one that has been preemptively explicitly discouraged. They presume that it's acceptable that they don't discourage it in connection with their policy on child abuse, but considering the fact that they explicitly discourage it for any problem (preferring to recommend, instead, that people rectify the problem with prayer and deeper involvement in the cult) this should not exonerate them in the slightest.
Beginning of point 9:
Elders never require victims of child abuse to present their accusation in the presence of the
This represents a policy change and considering the fact that there was a recent lawsuit over this very behavior, this point would be more honest if it started with the words "Going forward" or "In the future" but of course they are loathe to admit (especially in view of their adherents) that they've ever made a mistake and therefore present it as if this has never happened in the past.
In point 10:
member of the congregation who is an unrepentant child abuser is expelled from the congregation and
is no longer considered one of Jehovah’s Witnesses.
What they fail to mention is that in many (perhaps most) cases they will fail to establish someone as being an abuser with sufficient evidence for them to actually take any action. Which leads to:
If it is determined that one guilty of child sexual abuse is repentant and will remain in the
congregation, restrictions are imposed on the individual’s congregation activities. The individual will
be specifically admonished by the elders not to be alone in the company of children, not to cultivate
friendships with children, or display any affection for children. In addition, elders will inform parents
of minors within the congregation of the need to monitor their children’s interaction with the individual.
So when someone is determined by 3 janitors (with absolutely no experience in the field of criminal psychology) to be "repentant" they place primary trust in that person's self-monitoring of their own activities? The naivety of this policy is incomprehensible. Then they state that they will inform parents in the congregation to keep their kids away from this abuser - again, when reading this it seems to be necessary to keep in mind that any point that they make should be taken as narrowly as possible, and it appears to be pretty reliable to assume that any point that they fail to make is indeed false. Viewing the statement that they'll inform parents in that light, one can assume with reasonable confidence that they won't inform the congregation at large. So, what about babysitters, aunts and uncles or grandparents. If the parents decide to take a weekend vacation and the grandparents take the kids to the meeting, will they remember to pass along a list of all the abusers in the congregation to the grandparents? Either way, it's not the elders' problem! They informed the parents and told the abuser to stop abusing kids so their hands are clean. (sarcasm)
Furthermore what this point fails to explicitly say (and thus we can assume with high probability that it is not the case), following on from point 10, is that they will inform parents in the congregation of an accusation of abuse that they could not establish with enough evidence (i.e. they didn't confess and there weren't 2 witnesses, both wildly unlikely scenarios) to actually take action by the cult's rules. This would include cases where the case was reported to the authorities and the person was convicted in criminal court of the crime. So if someone manages to escape a judicial hearing because only one victim reported them and they didn't confess and then is convicted, serves their time, and returns to the congregation the elders won't mention to anyone that this person is a known child abuser.
Perhaps the saddest thing in all of this is that even with the above glaring flaws, this policy document actually represents an improvement over the previous status quo. It remains to be seen if some of these improvements are actually put into practice or if elders will stick to their old habits.