Best Strategies for Protecting Minors:
Shaping the Future with Lessons from the Past
Wednesday, October 16, 2013
1:00 to 2:30 pm
Ann H. Franke1
Wise Results, LLC
Washington DC
I.
Introduction
While injuries to minors have long occurred in higher education, coach Jerry Sandusky's arrest
and conviction in 2011-2012 for child molestation brought heightened attention to the problem.
Many institutions, including Penn State University, have subsequently developed or improved
policies and practices on protecting children. This paper describes a series of steps that have
proven useful in these endeavors. It uses the terms "child," "youth," and "minor" interchangeably
unless the context indicates otherwise.
Institutions typically exempt enrolled undergraduates who are minors from most provisions of
their policies protecting minors.2 An institution must, however, treat enrolled undergraduates
below the age of majority as minors for some purposes. These include (i) signing liability
releases, waivers, and contracts, (ii) consenting to medical treatment, and (iii) legally-mandated
reporting of abuse or neglect. Institutional policies may also exempt youth who are accompanied
at all times by a parent or guardian.
Colleges and universities appear to be following one of two basic routes to child protection.
Some concentrate on a limited array of elements, while others develop more comprehensive
programs. A concentrated program might require, for example, only criminal background checks
or training on reporting child abuse. Institutions following a limited route do only one or two
things and aspire to do them very well. A more comprehensive program covers many more areas
and demands greater resources and attention. Among the institutions favoring comprehensive
programs are those that have faced past child abuse problems and those affiliated with religious
denominations that have experienced these challenges.
Institutions have approached the steps to creating a program in different orders. Bear in mind that
not all the suggestions will apply to a given institution.
1
An earlier version of this paper was presented to the 2013 annual conference of the National Association of College and University Attorneys. The author welcomes suggestions and comments and can be reached at [email protected]. 2
An open question is whether an undergraduate is "enrolled" at the point of accepting admission or only upon arriving on campus to begin classes. The practical distinction is whether youth-­‐protection policies apply to summer orientation programs. 1 The paper concludes with a resource list. Note particularly the report “Preventing Child Sexual
Abuse Within Youth-Serving Organizations” from the Centers for Disease Control and
Prevention. The full text of this valuable 48-page report may be downloaded without charge.3
II.
Assemble the Right People and Information
A.
Task Force. To begin a review of child protection, the president typically appoints
a cross-functional task force. Members may be drawn from areas such as: student affairs,
athletics, admissions, community service, the legal office, human resources, risk
management, compliance, public safety, conference services, and student leadership.
Other areas with extensive interaction with youth, such as a day care center or lab school,
could be candidates for inclusion. Consider, too, faculty with special expertise in child
protection from areas including social work, psychology, or healthcare. The task force
may be a working group that develops proposals or an advisory body to vet proposals
developed by a few key people.
B.
Inventory. Under the auspices of the task force, an individual leads a process of
creating an inventory of existing programs and activities involving minors. An
institutional research officer may be a logical person to create the inventory. One
institution had good results with launching the survey from the president's cabinet. Each
cabinet member was responsible for gathering data on programs and activities within his
or her area. An on-line survey form may be useful, particularly one that can automatically
generate a report compiling the results.
The inventory should include programs sponsored by the university and also those by
outside groups that are held in university facilities or that involve university people in
their campus roles. The inventory should include not only programs held on-campus but
also ones at other locations. It should include programs sponsored by the university or by
outside groups. It should not include activities that individuals undertake in their private
capacities, unconnected to the institution. Some programs, such as camps, are highly
visible. Other activities are more informal and harder to capture. Areas easy to overlook
include:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Academic camps, e.g., robotics, writing, math
Alternate spring break, winter term, other intercession activities
Alumni interviews of applicants for admission
Alumni programs involving family members
Babysitting programs, whether regular or occasional, direct or referral
Best Buddies, for individuals with mental disabilities
Big Brother, Big Sister programs
Bridge programs
Bring Your Child to Work Day
3
The full text can be downloaded at www.cdc.gov/violenceprevention/pub/preventingchildabuse.html. The 48-­‐
page report covers (i) screening employees and volunteers; (ii) developing guidelines for behavior; (iii) monitoring behavior; (iv) creating safe environments; (v) responding to inappropriate behavior, policy violations, and suspicions of abuse; and (vi) training on child sexual abuse prevention. 2 10. Campus tours for school and scout groups
11. Clinics, e.g., speech and hearing clinic, dental clinic
12. Community service activities, both student and staff
13. Commencement
14. Competitions
15. Debate programs
16. Greek organization activities
17. High school students volunteering in labs, e.g., over winter break, summer
18. Holidays, e.g., Halloween, Christmas, Hanukah, Easter
19. Internships and externships
20. Mentoring programs
21. Music lessons
22. New-student orientation esp. w/siblings
23. Outside groups using campus facilities for weddings, religious services, sports,
camps
24. Partnerships with local K-12 schools
25. Radio or tv station events by stations affiliated with institution
26. Research involving minors (consult Institutional Review Board to find projects)
27. ROTC high school outreach or service programs, Junior ROTC
28. Science fairs
29. Special Olympics
30. Student clinical experiences in, e.g., education, psychology, healthcare
31. Student organization activities serving youth or in which youth participate
32. Student-athlete community outreach
33. Study abroad w/youth service or home stay (also domestic travel)
34. Swimming lessons
35. Theater and music productions w/child performers
36. Tutoring programs
37. Youth unaccompanied in student union, library, sports facilities, offices
At one university, the administrator responsible for compiling the initial inventory
realized, after spending several months on the project, that he had neglected to include a
university community service project in which he personally participated!
Many institutions are surprised at the extent of their youth-serving programs and
activities, which can easily number in the hundreds. The total number of youth often
exceeds the regular student enrollment.4 After creating the initial inventory, the
institution should designate someone to maintain it. If youth-serving programs and
activities must register in advance, their registration information might be used to update
the inventory.
4
Rutgers University, for example, found it had 450 affiliated programs serving about 71,000 minors. These numbers did not include campus tours for prospective students, Take Your Child to Work Day, and 4-­‐H programs. "Minors on Campus Task Force," report to University Senate Executive Committee, 2/20/13. Available at http://senate.rutgers.edu/EdwardsMemoMinorsOnCampusReport.pdf. 3 III.
Comply with Federal and State Child Protection Laws
Federal and state child protection laws establish minimum standards for the treatment of minors.
We highlight some areas of special relevance.
A.
Federal Law
1.
Child Labor. The federal Fair Labor Standards Act sets 14 as the
minimum age for most employment and regulates work hours for those under 16.
It restricts young workers from hazardous tasks such as climbing ladders or
operating food slicers. Every state also regulates child labor.5
2.
Child Pornography. More than a few colleges and universities have
discovered child pornography in their IT systems. The creation, distribution,
possession, or receipt of images of individuals under 18 engaged in sexually
explicit conduct is a federal crime. If child pornography is found on an institutionowned computer, a report may be made to the National Center for Missing and
Exploited Children, which will forward it to appropriate law enforcement
authorities. (The National Center can be reached at www.cybertipline.com or 1800-843-5678.) The institution may also report the matter directly to federal,
state, or local law enforcement.6
3.
Clery Act. A crime against a minor should be treated the same way as a
crime against an adult under the Clery Act. Obligations include timely warning of
certain threats and statistical reporting.
4.
COPPA. The Federal Trade Commission enforces the Children's Online
Privacy Protection Act of 1998. COPPA imposes certain obligations on websites
that collect information on children under age 13. If a website directed to a
general audience has actual knowledge that some users are under 13, it must
comply with the act.7 COPPA exempts non-profit organizations.
5.
FERPA. FERPA rights transfer from the parent to the student upon age 18
or enrollment in higher education, whichever comes first. Students under 18 who
are concurrently enrolled in high school and college have FERPA rights in both
settings. The two schools may share information without consent of either the
parents or student.8 Parents may inspect the high school records, including any
from the college that the high school may possess. The college may disclose
records to the parents under the exception for tax dependents or if the student
gives consent. The college could include a FERPA consent form in its registration
5
See www.dol.gov/dol/topic/youthlabor 6
United States Department of Justice Child Exploitation and Obscenity Section. See www.justice.gov/criminal/ceos/subjectareas/childporn.html 7
FTC Bureau of Consumer Protection, COPPA resources. www.business.ftc.gov/privacy-­‐and-­‐security/childrens-­‐privacy 8
34 C.F.R. § 99.34(b). 4 materials. The college may not, however, condition the student's participation in
its program on the student's granting consent for parental disclosure.
6.
HIPAA. Issues with minors may have implications under HIPAA.
Consider, for example, a student health service that treats non-students, such a
child attending summer camp, and sends a bill electronically to the camper's
health insurer. A university child development clinic that works with children
from the community may, depending on its billing practices, have implications for
HIPAA coverage.9 In addition, the HIPAA privacy regulations address the
recognition of personal representatives of emancipated and unemancipated
minors.10
7.
Research. Human subject research must meet special standards if it
involves children or other vulnerable populations.11 For research supported by the
Department of Health and Human Services and many other federal agencies,
regulations require parental permission and, if feasible, assent from the child.
Additional safeguards apply to research with greater potential for harm to child
subjects.12 Some institutions apply the HHS child protection requirements to all
research involving children, whatever the funding source.13 The HHS regulations
appear to contemplate only harm from the research procedures, not potential
abuse by the researcher. In a state having a law on a minor's capacity to consent
to medical treatment, legal counsel should examine the application of the state
law to participation in research. Research involving school children comes under
the Protection of Pupil Rights Amendment, enforced by the Department of
Education.14
8.
Broadcasting. Another way in which colleges and universities interact
with children is through their television and radio stations. Under the Children's
Television Act, licensed tv stations must meet standards for the amount and
content of children's programming and advertising. TV and radio stations operate
under constraints on airing obscene or indecent content.15
9
Melissa Bianchi and Nina Lavoie, "Deconstructing HIPAA: The Basics and Beyond," NACUA annual conference, June 29, 2012. 10
45 C.F.R. § 164.502(g)(2) and (3). 11
Marilyn Field and Richard Berman, eds., The Ethical Conduct of Research Involving Children, National Academies Press (2004). Full text (448 pp.) available without charge at www.nap.edu/catalog.php?record_id=10958 12
45 CFR § 46, Subpart D. 13
E.g., Cornell University, Office of Research Integrity and Assurance, Human Research Participant Protection Program, SOP 11: Informed Consent, Enrollment, and Other Considerations for Research Involving Children (10/1/2010). www.irb.cornell.edu/documents/SOP%2011%20-­‐%20Children.pdf 14
www2.ed.gov/policy/gen/guid/fpco/ppra/index.html 15
In 1975, the FCC fined radio station WXPN, affiliated with the University of Pennsylvania, $2,000 for airing obscene and indecent language during a call-­‐in program titled "The Vegetable Report." A father listening to the program in the car with his son complained to the Commission. Board of Trustees, University of Pennsylvania (WXPN-­‐FM), 57 FCC 2d 782 (1975) and 57 FCC 2d 793 (1976). 5 B.
State Law. It would be difficult to exaggerate the role that state law plays in child
protection. As a foundational matter, the issue of who is legally a minor requires a stateby-state answer. While most states use 18 as the age of majority, a handful use 19 or 21.16
In some states, a minor may become emancipated, i.e., legally an adult, with certain life
events such as marriage or military service.
The child protection topics covered in state law are nearly endless. States regulate day
care centers and primary and secondary schools. Each state criminalizes child abuse and
neglect and creates mandatory reporting obligations concerning child abuse. States may
regulate camps and the transportation of children. State legislatures have addressed
criminal background checks. The legal effect of waivers and releases varies by state, as
does a minor's capacity to consent to medical treatment.17 Counties and cities may pass
local laws and regulations supplementing state requirements. We address here some key
areas.
1.
Child Abuse Reporting. Most states designate certain categories of people
as mandatory reporters of child abuse or neglect. The categories typically include,
for example, social workers, healthcare providers and K-12 school personnel.
Less common categories include substance abuse counselors, film processors, and
computer technicians. (It is doubtful that campus IT staff in Alaska, Illinois,
Missouri, North Dakota, Oklahoma, and South Carolina understand that state law
makes them mandatory reporters of suspected child abuse.) A state may require
mandatory reporters to complete periodic training. Recent amendments in some
states have added coaches and higher education personnel to their lists of
mandatory reporters.
About 18 states take a wider approach, requiring anyone to report child abuse or
neglect to government authorities. Institutions should address in their own
policies and training not only state laws on mandatory reporting but whether, and
if so how, they want people to make reports within the institution of suspected or
known abuse or neglect that they encounter in their institutional roles. Consider,
too, whether outside groups using campus facilities should make a report within
the institution. If so, include the expectations in their contracts.
Two excellent online resources facilitate research on state child abuse laws. First,
the federal child welfare gateway has a "state statute search function." It provides
ready information on state laws on child abuse and neglect, as well as child
welfare and adoption.18 The website offers fact sheets that are clearly written,
16
As of January 2012, states and U.S. possessions using an older age were: Alabama (19), Mississippi (21), Nebraska (19), Pennsylvania (21), and Puerto Rico (21). "Age of Majority by State and United States Possession, Department of Defense Financial Management Regulations, DoD 14.7000.14-­‐R, vol. 7B appendix H. Full text available at http://comptroller.defense.gov/fmr/current/07b/07b_appendix_h.pdf. 17
The volume The Ethical Conduct of Research Involving Children, cited above in note 11, contains in Appendix B some useful state-­‐by-­‐state charts on emancipation of minors (p. 345) age of consent for medical care (p. 347), and age of consent for treatment of certain medical conditions (p. 354). Prepared in 2004, the charts contain statutory references. www.nap.edu/openbook.php?record_id=10958&page=347#p2000a7b49960347001 18
www.childwelfare.gov/systemwide/laws_policies/state/index.cfm 6 show their date of preparation, and cite to state statutes. The second online
resource is maintained by the National Conference of State Legislatures.19 It
tracks bills introduced in state legislatures around the country on child abuse and
other key topics. It provides bill numbers, a summary, and the bill's status as
pending, enacted, or failed.
2.
Camps. Most states regulate camps in some fashion. Many require a
license or permit to operate a camp, with the definitions of camp varying by state.
New Hampshire, for example, requires a license for a youth recreation camp,
defined as
a program that operates for at least 10 days per license year for the
purpose of providing recreational opportunities, or a combination of
recreation and instruction, to 10 or more youth per day, at a place which is
continuously or periodically used for such purposes. The term includes
residence camps and seasonal and year-round day camps.
California regulates "organized camps," defined as "a site with program and
facilities established for the primary purposes of providing an outdoor group
living experience with social, spiritual, educational, or recreational objectives, for
five days or more during one or more seasons of the year." Regulation in
California is through county health departments. Florida and Washington are
among the states that do not require camps to obtain licenses.
State law may address camp staff background checks, driver record checks,
wages, meal breaks, and overtime. The American Camp Association maintains a
useful website with state-by-state information on camp regulations.20 Institutions
sponsoring or hosting camps should check the state requirements.
3.
Criminal Background Checks. States may limit the use of criminal
backgrounds in employment decisions. They may also limit the availability of
digital fingerprint checks from the FBI. For further discussion, see the section
below on Screening and Selection.
4.
Transportation. Motor vehicle crashes are the leading cause of death in the
United States for children ages 1 to 19. States address this problem through
various means. Five states require seat belts on all buses: California, Florida,
Louisiana New Jersey, and New York. Texas requires seat belts on buses
purchased after September 2010.21 State law may prohibit transporting children in
19
www.ncsl.org/issues-­‐research/human-­‐services.aspx?tabs=858,51,19 20
www.acacamps.org/publicpolicy/regulations/print 21
Governors Highway Safety Association, Child Passenger Safety Laws (May 2013). http://ghsa.org/html/stateinfo/laws/childsafety_laws.html 7 15-passenger vans or in the back of pickup trucks.22 All 50 states require child
safety restraints for infants and small children. Every state except Florida and
South Dakota requires booster seats or similar restraints for children of specified
sizes.
5.
Summary. Know important state requirements that apply to youth-serving
programs and activities. Help the institution's youth-serving programs meet their
obligations and require facility renters to do likewise. If youth will be traveling
out-of-state, understand the laws in the states or countries they will visit. Key
requirements, and sources to begin researching them, include:
a. Age of majority
http://comptroller.defense.gov/fmr/current/07b/07b_appendix_h.pdf
b. Who must report child abuse and neglect and how to make a report
www.childwelfare.gov/systemwide/laws_policies/statutes/manda.pdf#Pag
e=2&view=Fit
c. Requirements for operating camps
www.acacamps.org/publicpolicy/regulations/print
d. Child transportation restrictions
www.nasdpts.org/documents/vanssurveyfeb04.pdf
http://ghsa.org/html/stateinfo/laws/childsafety_laws.html
IV. Develop Screening and Selection Policies
A.
Introduction. Each youth-serving program in a higher education institution may
have its own method, whether formal or informal, for recruiting students, staff, faculty,
and volunteers. A one-day activity for local kids might welcome any volunteer who
shows up on the morning of the event. In contrast, a college student seeking to tutor
children in a public elementary school may undergo a rigorous selection and background
check process.
Many higher education institutions are working to create more consistent standards for
selection and screening across all of their youth-serving programs. Some use a tiered
system for selection processes. They apply the most stringent standards to individuals
who bear the greatest responsibility for serving youth or who, by virtue of their positions,
pose the greatest potential risk to youth. Other institutions apply identical standards for
screening and selection to all individuals who may interact with youth in any way.
In the public's mind, criminal background checks are the best method for selecting people
to work with children. Yet only 3 to 4% of child abusers have a criminal background.
22
In 2004, the National Association of State Directors of Pupil Transportation Services conducted a state-­‐by-­‐state survey of laws on vans. www.nasdpts.org/documents/vanssurveyfeb04.pdf 8 B.
Basic Screening. The United States Department of Justice has long regarded
written applications, interviews, and reference checks as key elements of screening those
working with minors or incapacitated adults.23 A written application might reveal, for
example, gaps in employment that the candidate cannot convincingly explain. An
interview presents an opportunity to ask behavioral questions: What would you do if you
saw an adult wrestle with a child? Go off alone with a child? Give a gift to a teen? From
reference checks, one can gauge how others assess the individual.
Traditional screening methods offer insight on a person's common sense, degree of
responsibility, and willingness to hold others accountable. A criminal background check
does none of this. Consider screening processes appropriate for volunteers, students, and
staff across a range of activities.24 For a large youth-serving event held over a short
period, the basic three-part screening may be unrealistic. Consider alternatives such as a
registration form rather than an application. A registration form can elicit a volunteer's
address, phone, and email information, as well as the name and details of an emergency
contact. In screening students, review of disciplinary and academic records may, at least
sometimes, substitute for written applications, interviews, and reference checks.25
C.
Criminal Background Checks. Criminal background checks have become
necessary, although not sufficient, for screening adults working with minors. Many
institutions already check the criminal backgrounds of new hires. For those institutions,
the issue becomes whether and, if so, how to conduct background checks on students,
incumbent employees, and volunteers. Institutions using the common application form
for student admission have already elicited information from students on whether they
have "ever been adjudicated guilty or convicted of a misdemeanor, felony, or other
crime." If the outcome was sealed, expunged, or otherwise confidential, the applicant
need not answer affirmatively.
The widely-held belief that juvenile criminal records are sealed is not entirely accurate, as
state law may provide otherwise. If a juvenile's crime involved a traffic offense,
reportable sex offense, or use of a weapon, in some states the conviction must remain
public. If a juvenile is tried as an adult, the record remains open. Some states will seal a
juvenile record only if the minor makes an application, and not all minors initiate the
process.26
23
"Guidelines for the Screening of Persons Working with Children, the Elderly, and Individuals with Disabilities in Need of Support," United States Department of Justice, Office of Juvenile Justice and Delinquency Prevention at p. iii. (1998). The Guidelines support the use of a tiered approach that applies different screening criteria to different groups based on levels of risk. The full text available at www.ncjrs.gov/pdffiles/167248.pdf. 24
For a sample volunteer application form, see “Managing the Risk of Minors on Campus,” Arthur J. Gallagher & Co. (2012) at page 42. www.ajgrms.com/portal/server.pt/gateway/PTARGS_0_28406_581934_0_0_18/ManagingRiskMinorsPaper_6-­‐14-­‐
12_final.pdf 25
Under the Family Educational Rights and Privacy Act, a college employee with a legitimate educational interest may view student education records. 26
Even sealed records, including juvenile arrests, may be available through FBI digital fingerprint background checks. For a state-­‐by-­‐state tool on juvenile records, visit the website of the Catholic Immigration Network, Inc. 9 1. Sex Offender Registry. There are different ways to check an individual's
criminal history. The federal government maintains a national sex offender public
website. The website consolidates records from federal, state, territory, and tribal
governments. Anyone can enter a name into the website to see whether the
individual is a registered sex offender. The site's limitations include mistaken
identities due to similar names, information on offenses that may be incomplete or
outdated, and variations among the states in their definitions of sex offenses.27
Despite these limitations, the website offers fast and free searches of convicted,
registered sex offenders. It is located at www.nsopw.gov.
2. Name and Fingerprint Checks. Beyond the online sex offender registry,
criminal background checks can be based on name and Social Security number or
on fingerprints.28 These often, but not always, yield similar results. They differ,
however, in their capacity to detect identity theft. If an employer bases its
criminal background checks on name and Social Security number, a candidate
may supply false information. There is no guarantee that "John Smith, SSN 12345-6789" is actually John Smith rather than an imposter who stole the identity.
Fingerprint checks eliminate that risk but may pose greater privacy intrusion,
administrative burden, and cost. FBI digital fingerprint checks are available only
if state authorities have a specified agreement with the FBI. 29
3. Legal Requirements. A human resources office already conducting criminal
background checks can offer advice on expanding the process into youth-serving
programs. The EEOC has issued guidance on avoiding employment
discrimination in checking criminal backgrounds.30 Reliance on a third-party
vendor to check criminal backgrounds of job applicants and employees triggers
the federal Fair Credit Reporting Act. Application of the FCRA to recruiting
volunteers is legally unclear.31 State laws may also apply to criminal background
checks.
http://cliniclegal.org/state-­‐state-­‐juvenile-­‐records-­‐update See also the National Center for Juvenile Justice www.ncjj.org 27
Commercial criminal background check companies are often strongly critical of the federal database. 28
A useful resource is “Criminal Background Checks: Background Information and Guidance for Camps,” American Camp Association. Full text available at www.acacamps.org/sites/default/files/images/publicpolicy/documents/CBC_Education_7_2011.pdf. 29
See "FBI Criminal History Checks for Employment and Licensing." www.fbi.gov/about-­‐us/cjis/criminal-­‐history-­‐summary-­‐checks/backgroundchk 30
"Questions and Answers About the EEOC's Enforcement Guidance on the Consideration of Arrest and Conviction Records in Employment Decisions under Title VII." Full text available at www1.eeoc.gov/laws/guidance/qa_arrest_conviction.cfm?renderforprint=1 31 If an institution uses volunteers to replace staff, the argument for FCRA applicability is stronger. See Federal Trade Commission, "Forty Years of Experience with the Fair Credit Reporting Act: An FTC Staff Report with Summary of Interpretations," July 2011, at page 32. ("Because the term 'employment purposes' is interpreted liberally to effectuate the broad remedial purpose of the FCRA, it may apply to situations where an entity uses individuals who are not technically employees to perform duties. Thus, it includes…a nonprofit organization staffed in whole or in part by volunteers." Footnote with citations omitted.) 10 4. Details on Criminal Background Checks. Among the details to be resolved in
requiring criminal background checks are how many years the check should cover
(7 to 10 years is typical) and who bears the cost, which can quickly become a
political question. Individuals who undergo a criminal background check should
have a continuing duty to notify the institution within 72 hours (or similar period)
of any subsequent arrests or convictions.32 Criminal background checks might be
repeated periodically, for example annually or every three or four years.
5. Outside Groups. What about requirements for outside groups that rent
facilities? They might be held to the same standards for screening and selection as
institution-affiliated groups. Alternatively, more rigorous standards might apply to
outside groups, on the theory that the institution has no existing relationship with
the staff and volunteers of external programs.
Athletic camps run by the university's coaches may present special considerations.
Are these internal or external camps? Or do they fall somewhere in the middle?
Many institutions consider coach-run camps to be outside groups yet make
accommodations when applying criminal background checks to them, such as a
phase-in period or cost sharing. With all third parties, including athletic camps,
the institution should establish the right to review any background checks that
show any criminal history and to bar from its premises, at its discretion, anyone
with an unsuitable criminal history.
6. Resources. Many useful resources exist on criminal background checks. For a
start, NACUA members can access the Legal Reference Service resource page
titled "Background Check Resources and Links."33
V.
Develop Policies on Event Registration and Staffing Requirements
Given that youth-serving activities can sprout like weeds, many institutions are implementing
controls. This section will discuss event registration and staffing requirements.
A.
Event Registration. Procedures for advance registration and approval are
becoming more common. Duke University, for example, requires the director of a youthserving event to register the program and complete an application form. Staff from
corporate risk management and from conferences services oversee the process, which is
entirely online.34 It also includes criminal background checks and online training. In
developing a registration system for youth-serving events, registration of student parties
might be a useful analogy.
32
Penn State's form for notifying the university of subsequent arrests and convictions is available online. http://guru.psu.edu/policies/OHR/Self_Disclosure_Form.pdf 33
www.nacua.org/lrs/NACUA_Resources_Page/BackgrndChecks.asp (members only) 34
http://events.duke.edu/event_planning/minors/index.php 11 B.
Supervision. The American Camp Association has set minimum standards for
adult-to-camper ratios in day and overnight programs.
Ages 4 to 5 6 to 8 9 to 14 15 to 17 Staff-­‐to-­‐Camper Ratio for Overnight Programs 1:5 1:6 1:8 1:10 Staff-­‐to-­‐Camper Ratio for Day Programs 1:6 1:8 1:10 1:12 ACA also recommends that “80 percent or more of the counseling/program staff be at
least 18 years old. Staff must be at least 16 years old and be at least two years older than
the campers with whom they work. In special needs camps, 100 percent of the
counseling/program staff must be at least 18 years old.”35
Some institutions have adopted ratios identical or similar to those of the ACA, while
others require programs to develop ratios appropriate to their own circumstances.36 Some
institutions do not address overall ratios of adults to youth. Most, however, require two
adults to be present at all times, avoiding one-on-one interactions between adults and
youth.
C.
Behavioral Standards. A comprehensive youth-protection program includes
behavioral standards for those interacting with youth. Villanova University uses these
standards:37
DO:
•
•
•
•
•
•
•
Maintain the highest standards of personal behavior at all times when interacting
with minors.
Listen to and interact with minors and provide appropriate praise and positive
reinforcement.
Treat all minors in a group consistently and fairly, and with respect and dignity.
Be friendly with minors within the context of the formal program or activity while
maintaining appropriate boundaries.
Maintain discipline and discourage inappropriate behavior by minors, consulting
with your supervisors if you need help with misbehaving youth.
Be aware of how others might perceive or misinterpret your actions and
intentions.
Consult with other adult supervisors or colleagues when you feel uncertain about
a situation.
35
www.campparents.org/safetytips 36
Institutions adopting the ACA or similar ratios include: Bucknell University, Penn State, and Villanova University. Institutions leaving programs to develop their own ratios include Iowa State University and Rutgers University. 37
"Guidelines for Working with Minors," Villanova University, at page 19. www1.villanova.edu/content/dam/villanova/finance/documents/insurance/Minors_in_VillanovaUniversity_Progra
ms_Policy.pdf 12 DON’T:
• Be alone with a minor. If one-on-one interaction is necessary, the interaction must
take place in an area visible to others to ensure there is no opportunity for privacy.
• Have any direct electronic and/or social media contact with minors, unless it is
related to the program and another adult is included in the communication. (Does
not apply to Athletic recruiting.)
• Have contact with a minor outside of the program (e.g., babysitting, home visits).
• Enter a facility in use by a minor such as a bathroom, locker room, residence hall
room (if applicable), or similar area without another adult present, consistent with
the policy of avoiding one-on-one contact with minors.
• Sleep in the same accommodations with a minor, unless you are a parent or
guardian of the minor.
• Engage in abusive conduct of any kind toward, or in the presence of, a minor.
• Hit, physically assault, or inappropriately touch minors; use language, make
suggestions, or offer advice which is inappropriate, offensive or abusive; behave
in a manner that is sexually provocative; act in ways intended to shame,
humiliate, belittle or degrade minors; or otherwise perpetrate any form of
emotional abuse.
• Drive with a minor in a University or personal vehicle (e.g. pick up minors from
or drop off minors at their homes or transport them to and from off campus
activities). Note Minors may be transported by Public Safety in University
vehicles and via ambulance as needed.
• Provide alcohol or illegal drugs to any minor. Adults shall not provide
prescription or over-the counter medication to any minor unless specifically
authorized in writing by the parent or legal guardian as being required for the
minor’s care or the minor’s emergency treatment.
• Make sexual materials in any form available to minors or assist them in any way
in gaining access to such materials.
• Take photos or videos of a minor with personal cell phones or cameras in
showers, restrooms or other areas where privacy is expected.
• Give gifts to minors independent of gifts provided by the Program.
Behavioral standards should be easy to find, distributed widely, and covered in training
programs.
VI.
Establish Reporting and Response Protocols for Child Abuse or Neglect
State law on reporting child abuse to government authorities provides the foundation for
institutional reporting policies. Many states allow a report to be made either to the child welfare
agency or law enforcement. The federal Child Welfare Information Gateway maintains a list of
all state child abuse hotline phone numbers and the websites of state child protection agencies.38
38
www.childwelfare.gov/responding/reporting.cfm 13 If campus public safety officers have police powers, a report made to them may (or may not)
satisfy state reporting requirements.39
A.
Suspicion of Abuse in the Family. Consider the possibility that a child might
reveal evidence of abuse within the family or another non-university setting. This would
trigger a mandatory reporting obligation. If the family resides in another state, consider
reporting both to the institution's home state and the family's home state. The list of child
abuse hotline phone numbers can prove particularly handy in situations involving more
than one state.
B.
Mandated Internal Reporting. Many institutions complement state-mandated
reporting with internal reporting requirements. They develop mechanisms for receiving
and investigating reports. An anonymous reporting route is useful, to protect the
complainant from potential repercussions. The policy might note that the institution's
ability to investigate an anonymous report may be limited. Consider expanding the scope
of the fraud/ethics hotline to cover child abuse or neglect complaints. (Other topics such
as hazing, discrimination, harassment, and student sexual assault could also be added to
the hotline.)
Auburn University provides clear standards for reporting known or suspected abuse: 40
If you know or suspect that a child is a victim of child abuse or neglect, you must
act. In deciding whether or not to report an incident or situation of suspected child
abuse or neglect, it is not required that the university personnel have proof that
abuse has occurred. Any uncertainty in deciding to report suspected abuse must
be resolved in favor of making a report.
In making a report, your actions should be as follows:
First, immediately report the information to local law enforcement authorities. If a
child is in imminent danger, the employee must contact police at 911 to obtain
immediate protection for the child. The non-emergency number for the City of
Auburn Police Department is 334-501-3100.
When contacting local law enforcement you should include all available
information regarding the known or suspected abuse or neglect, including, but not
limited to, the name of the child, his whereabouts, the names and addresses of the
parents, guardian, or caretaker and the character and extent of the injuries. The
report should also contain, if known, any evidence of previous injuries to said
child and any other pertinent information that might establish the cause of such
injury or injuries, and the identity of the person or persons responsible for the
same.
39
If an allegation involves a high-­‐profile administrator, involvement of non-­‐campus state law enforcement or the government child welfare agency may be preferable. 40
Child Protection and Reporting of Child Abuse Policy, https://sites.auburn.edu/admin/universitypolicies/Policies/ChildProtectionandReportingofChildAbusePolicy.pdf 14 Do not delay making a report in order to gather evidence; the law enforcement
agency to whom you make the report will determine whether such an
investigation is warranted. It is acceptable to quickly collect additional
information that is readily available (such as talking to coworkers who also
interact with that child) or to verify that the information learned meets criteria for
reporting, but this must be done very promptly. It is better to report without all
relevant information than to delay a report to collect information.
Second, do not directly question or solicit information from the child or from the
person suspected of improper behavior. That is not your role; the role of
investigation lies with city, county, and state officials.
Third, in addition to making a report with local law enforcement, within 24 hours
after making the foregoing report, an employee shall report the information to
his/her immediate supervisor and to the Auburn University Executive Director of
Public Safety & Security. It shall be the responsibility of the Executive Director
of Public Safety & Security to notify university officials of the suspected child
abuse and to coordinate the investigation with local law enforcement. University
officials include, at a minimum, the President, Executive Vice President, Provost,
General Counsel and Executive Director of Risk Management & Safety. It shall
be the responsibility of the university President to notify the Board of Trustees of
the incident.
Further, it shall be the responsibility of the Executive Director of Public Safety &
Security to either report the incident to the State of Alabama Department of
Human Resources or to ensure that the local law enforcement agency has made
the report. The Executive Director of Public Safety & Security shall advise the
reporter that such report has been made. Finally, the Executive Director of Public
Safety & Security shall be responsible for maintaining all records and reports
related to the incident and to brief university officials as needed.
Like Auburn University, Penn State University expands on state law and requires all universityaffiliated people to report child abuse both externally and internally. Penn State has adopted a
similarly clear, and somewhat different, protocol for reporting.41
Whether an institution has a legal duty, as opposed to a moral duty, to receive and investigate
reports of child sexual abuse may hinge on the status of the child and the institution's
interpretation of Title IX.42
41
Policy AD39, Minors Involved in University-­‐Sponsored Programs or Programs Held at The University and /or Housed in University Facilities. http://guru.psu.edu/policies/ad39.html 42
The Department of Education interprets Title IX as applying to sexual violence against third parties, arguably including non-­‐enrolled minors participating in enrichment programs, camps, and similar activities. An institution might resist this interpretation if, for example, the youth had no formal affiliation with the institution, the program leader was a student or lower-­‐level staff member, and key institutional officials played little or no role in overseeing the program. Relevant authorities include the Dear Colleague Letter, April 4, 2011, at 15 C.
Reporting Information for Parents. Parents also need information on how to raise
concerns or make a report. Consider including this in program materials, on posters, and
elsewhere. Parents are among the people to be contacted about suspected or known
abuse, unless they are the alleged perpetrators.
D.
Pending Investigation. While an investigation is pending, provide support to the
complainant and remove the alleged perpetrator from contact with children. St.
Bonaventure University has a thoughtful list of actions to take while a child sexual abuse
investigation is pending.43
E.
Years-Old Complaint. At least two institutions have faced the issue of whether to
report to government authorities a complaint from an adult that he was abused years
earlier. Having complained to the institution, the adult in one instance declined to report
the problem to the state and objected to the institution's doing so.
In situations of child sexual abuse, a report is mandatory. In situations of adult sexual
abuse, the best practice is to leave to the complainant the decision whether to report to
law enforcement. The adult reporting past child abuse presents a hybrid situation. State
law may provide an answer.44 If not, consider balancing multiple factors with the
assistance of a cross-functional team. Steps in the analysis include:
1. Evaluate known facts on whether the alleged perpetrator may have continuing
access to children. The presence or absence of children in the home is not
conclusive, given the likely presence of children in the neighborhood or in
religious or community organizations in which the adult may be active. Consider,
too, access to children through Internet chat rooms. The alleged perpetrator would
have no access to children only in very limited circumstances, such as
institutionalization, incarceration, or death.
2. Work with the victim over a period of time to evaluate the pros and cons of
reporting.
3. Refer the victim to a counseling or victim support organization and then discuss
the reporting issue at a time suggested by the ally.
4. Evaluate state mandatory reporting laws.
5. Analyze relevant institutional policies, if any.
4 n.11, www2.ed.gov/about/offices/list/ocr/letters/colleague-­‐201104.pdf and the definition of "program" in 20 U.S.C. § 1687(2)(A). 43
www.sbu.edu/uploadedFiles/image_gallery/protection_of_minors_policy(1).pdf 44
In 1993, the Maryland Attorney General concluded in an opinion that a report was still required if the child abuse victim is now an adult or if the alleged abuser is deceased. 78 Op. Att'y Gen. 189, 12/3/1993. www.oag.state.md.us/Opinions/1993/78oag189.pdf 16 6. Evaluate any rules on confidentiality and reporting applicable to the context in
which the victim disclosed the information, for example an attorney-client
relationship, a counseling relationship, or a similar special relationship.
7. Estimate the harm that the victim might experience, such as significant emotional
distress, if the institution made a report over his or her objection. Sexual assault
victims have, among other vulnerabilities, a heightened risk of suicide.
8. Make a preliminary telephone call to the relevant agency to discuss its protocols
and confidentiality protections. Explain these to the victim.
9. Consider the feasibility, and advisability, of making a report that names the
alleged perpetrator but not the victim.
10. Have the institution make the report by speaker phone with the victim and an ally
listening in the room.
11. Come to a written understanding with the adult victim on the course of action.
12. If agreement cannot be reached, at least notify the victim in writing of his or her
options and the institution's planned course of action, rationale, and timetable.
This list is not exhaustive. An administrator involved in the decision making should document
the various matters considered and the final outcome. Close cases are best resolved in favor of
reporting, to protect other children from future victimization. The report should be made in the
jurisdiction in which the alleged perpetrator lives.
VII.
Conduct Training
Distribution of a policy is a good first step in applying standards across an academic institution,
but it is hardly sufficient. Training and monitoring are generally also necessary.
Over the past two years, many colleges and universities have launched training programs on
child protection. Their target audiences vary. One of the most extensive training programs is that
of The Citadel, located in South Carolina. It is requiring every student, employee, and trustee to
complete an in-person three-hour program on recognizing and responding to child sexual abuse.
The Citadel is partnering with a nearby child protection group, Darkness-to-Light, that also trains
many YMCA employees nationwide.
Georgetown University requires all adults working with children to review annually basic written
information covering warning signs of child abuse and neglect, guidelines for protecting
children, and procedures for reporting problems. The adults must sign and return a statement
certifying that they have reviewed the information. Those having more extensive involvement
with minors must complete a one-hour online training program.
17 Training may be live or delivered via written material, online tutorial, or video. Combinations of
these modes may prove useful. One need not start from scratch in developing a training program
on youth protection and child sexual abuse. Many free and low-cost resources exist, and other
institutions may grant permission to adapt their materials.45 See Selected Resources on
Protecting Minors, below, for links to sample campus programs.
Outside groups renting campus facilities may be contractually required to train their staff and
volunteers on subjects covered in the institution's training.
Training on child protection is not a one-time event. It must be repeated over and over, reaching
new generations of students, employees, and volunteers and reinforcing the importance of child
protection to long-serving individuals.
VIII.
Work in Partnership with Parents
In undergraduate education, many institutions struggle to manage what they perceive as
excessive parental involvement with their children. In youth-serving programs, aim to threat
parents instead as allies. Parents and guardians benefit from having:
An awareness of program schedules, activities, and staff
An understanding of behavioral expectations for children, program staff, and themselves
Opportunities to observe the program
Information on the potential risks of activities
Advice on how to raise an informal concern and how to file a complaint
An understanding of the institution's child protection program
Notice of suspected abuse (unless the parent is the alleged perpetrator)
Prompt information on major developments occurring in the program
An understanding of emergency protocols, including medical emergencies and missing
children
Contact information for the program director, campus public safety, reporting hotline,
and other resources
Consider including a tab "For Parents and Families" on a child protection website. Address
relevant items there and also in written materials shared with parents.
IX.
Develop Robust Administrative Practices
This section covers some major issues in running an effective child protection program.
A.
Point Person. With youth-serving activities spread widely across most institutions,
it becomes important to designate one "go to" person. The role provides coordination for
prevention, response, and administration. Some institutions are appointing a half-time
45
See "Free and Low-­‐Cost Training Resources on Child Sexual Abuse Suitable for Use in Colleges and Universities," by Ann Franke (2012). Available to NACUA members on the Legal Resource Page "Minors on Campus" in the NACUA online Legal Reference Service. www.nacua.org/documents/ResourcesOnChildSexualAbuse.pdf 18 Child Protection Officer or Youth Safety Coordinator. This may require new resources
rather than an increase in the duties of an existing employee.
Responsibilities might include:
Maintaining the inventory of youth-serving programs and activities
Overseeing compliance with policy elements such as screening and selection,
background checks, and training
Coordinating compliance with outside groups renting campus facilities
Developing and maintaining contacts with internal and external subject-matter
experts on child protection
Delivering presentations and special programs on child protection (query whether
the role should include conducting extensive front-line training)
Investigating and resolving problems, or coordinating those efforts
Monitoring the overall child protection program and, as needed, recommending
changes in policies and procedures
Overseeing record retention
The individual should be comfortable interacting on sensitive subjects with a wide range
of people in various roles including senior administrators, faculty, coaches, law
enforcement and child welfare authorities, school personnel, outside groups, parents, and
children of all ages. He or she should have, or develop, credibility across the institution.
If the position requires conducting investigations, that skill would be important. The
position might reside in the compliance office, human resources, diversity and equity,
risk management, or general counsel.
B.
Record Retention. A comprehensive child protection policy will generate many
records. These include, among others, signed parental permission forms, staff screening
and selection documents, training certifications, agreements with outside parties,
complaints, and results of investigations. State statutes of limitations on civil and criminal
claims of child abuse tend to be very long. Some states have no limit and, in others, the
limitations period begins to run only when the individual reaches the age of majority. If a
6-year old child suffers abuse in an institution-affiliated program, for example, the
institution may first learn of the claim several decades later. Against this backdrop,
record retention becomes very significant. The documents noted above should be stored
for a stated time period tied to the state statute of limitations. Additional documents for
retention include rosters of staff and youth, institutional insurance policies, and proof of
insurance for outside parties. It is unrealistic to believe that each youth-serving activity
can independently retain documents for decades and retrieve them upon request. Central
coordination of records appears imperative.
C.
Oversight or Advisory Council. It may be useful to appoint an oversight or
advisory council to consult with the Child Protection Officer. It might meet semiannually or quarterly. The Council could usefully include representatives from the same
areas that consulted on the original Task Force that developed the policy. Consider
including a subject-matter expert from the community, such as a local pediatrician or the
director of a nonprofit child protection organization. One or more parents with children
19 who have participated in campus programs could also add valuable perspectives. (Parents
without other tie to the institution might be the best choice.) Rotate membership on the
Council.
D.
Monitoring. Too often institutions adopt policies and then become lax about
enforcement. People who work with children and youth should have impeccable
judgment. If they violate known behavioral standards, such as not being along with a
child, they should face consequences. Similarly, program requirements such as ratios of
youth to adults require occasional monitoring or auditing. Does the tennis camp or the
arts camp actually have on duty the required number of adults? Are the adults attentive to
the youth or distracted by their own conversations or electronic devices? Consider
including in contracts with outside parties the right to audit their records on, for example,
background checks and training and their operations for compliance with stated rules.
X.
Conclusion
Higher education institutions generously share ideas and resources with one another. Take
advantage of that generosity in implementing or refining child protection policies. Be prepared,
in turn, to share your best ideas and setbacks for the benefit of children and youth.
20 SELECTED RESOURCES ON PROTECTING MINORS
An excellent starting place for research is the Minors on Campus resource page in the NACUA
Legal Reference Service. See also the resource page Background Check Resources and Links.
Available only to NACUA members.
www.nacua.org/lrs/NACUA_Resources_Page/MinorsOnCampus.asp
STATE LAWS AND RESOURCES
State Statute Search Function
www.childwelfare.gov/systemwide/laws_policies/state/index.cfm
A convenient finding tool to search by jurisdiction and topic on laws addressing child abuse,
child neglect, child welfare, and adoption.
Mandatory Reporters of Child Abuse and Neglect: Summary of State Laws (August 2012)
www.childwelfare.gov/systemwide/laws_policies/statutes/manda.pdf
State-by-state summaries and comparative analyses of who must report child abuse, standards
and procedures for making a report, disclosure of reporter's identity, and related issues.
National Conference of State Legislatures
www.ncsl.org/issues-research/human-services.aspx?tabs=858,51,19
Tracks bills introduced around the country on child abuse, with frequent updates. Includes
summary of pending bills by state.
www.ncsl.org/issues-research/human-services/mandatory-rprtg-of-child-abuse-and-neglect2013.aspx
Child Welfare Hotlines by State
List of state toll-free phone numbers for reporting suspected abuse or neglect. Also includes
related websites and some additional resource people and organizations. (2011)
www.childwelfare.gov/responding/reporting.cfm
American Camp Association
State-by-state legal requirements for operating camps.
www.acacamps.org/publicpolicy/regulations/print
GENERAL GUIDES
"Managing the Risk of Minors on Campus,” Arthur J. Gallagher & Co. (2012)
Volunteer application form at p. 42
www.ajgrms.com/portal/server.pt/gateway/PTARGS_0_28406_581934_0_0_18/ManagingRisk
MinorsPaper_6-14-12_final.pdf
"Preventing Child Sexual Abuse Within Youth-Serving Organizations," Division of Violence
Prevention, Centers for Disease Control and Prevention, U.S. Department of Health and Human
Services (2007)
21 Excellent 48-page guide with chapters on prevention, overcoming challenges, developing
processes, and implementing training. Hard copies currently out-of-print. Full text available at
www.cdc.gov/violenceprevention/pub/preventingchildabuse.html.
Child Welfare Information Gateway
U.S. Department of Health and Human Services
Great website with information and resources on a wide range of child-centered issues. Topics
include preventing, and responding to, child abuse and neglect.
www.childwelfare.gov
"The Best Practices for Managing Minors on Campus," Marsh Risk Consulting
Covers topics including bringing children to work or class and employment of minors. (2011)
www.ucop.edu/risk-services/_files/pubs/appendix_a.pdf
CRIMINAL BACKGROUND CHECKS
State laws are a critical source on guidance on conducting and using criminal background
checks, so be sure to check your state law. For employees, the Fair Credit Reporting Act is
relevant.
Conducting Criminal Background Checks: Why Do It and What the Law Allows
U.S. Small Business Administration
www.sba.gov/community/blogs/community-blogs/business-law-advisor/conducting-employeebackground-checks-%E2%80%93-why-do-#
FBI criminal background checks from digital fingerprints
www.fbi.gov/about-us/cjis/background-checks
Fair Credit Reporting Act
Resources on the FCRA from the Federal Trade Commission, which enforces the act.
www.ftc.gov/os/statutes/fcrajump.shtm
“Guidelines for the Screening of Persons Working with Children, the Elderly, and Individuals
with Disabilities in Need of Support,” U.S. Department of Justice (1998)
www.ncjrs.gov/pdffiles/167248.pdf
National Sex Offender Search
Named in memory of a sexual assault victim, the Dru Sjodin National Sex Offender Public
website is free and easy. It allows searches by location or by name of convicted assailant.
Covers states, U.S. territories, and Indian country.
www.nsopw.gov/?AspxAutoDetectCookieSupport=1
22 TRAINING MATERIALS
Overview
Free and Low-Cost Training Resources on Child Sexual Abuse Suitable for Use in Colleges and
Universities, Ann H. Franke (2012).Available to NACUA members on the Legal Resource Page
"Minors on Campus" in the NACUA online Legal Reference Service.
www.nacua.org/documents/ResourcesOnChildSexualAbuse.pdf
Videos and Narrated PowerPoints
University of South Florida
http://usfweb2.usf.edu/human-resources/TalentManagement/onlinetrng/hrprocess/ChildAbuseReporting/ChildAbuseReporting.htm
University of Alabama
http://policies.ua.edu/UA%20Employee%20Training%20Academy%20Instructions%20for%20C
hild%20Protection%20Policy%20Training.pdf
University of Southern California
www.usc.edu/dept/hr/equity_diversity/i-protecting_minors.html
Other Formats
Information packet - Georgetown University
www.protectionofminors.georgetown.edu
Workbook - Duke University
www.hr.duke.edu/policies/expectations/minors.php
Brochure - Edison State College
www.edison.edu/docs/E%20140814%20ESC-2PRINTPROTECTING%20CHILDREN%20BROCHURE.pdf
Quiz - Baylor University
www.baylor.edu/content/services/document.php/173526.pdf
SAMPLE CAMPUS POLICIES AND REPORTS
Auburn University
Website collecting university's policies on minors on campus
https://cws.auburn.edu/rms/minorsOnCampus.aspx
Comprehensive ad hoc committee report, 103-pages, includes survey of 19 other institutions
www.auburn.edu/academic/provost/pdf/Final%20Report%20Committee%20to%20Review%20and%20Establish%20University%20Policies%20Regardi
ng%20Minors%20on%20Campus.pdf
Dartmouth College
Poster on reporting child abuse
www.dartmouth.edu/~legal/pdfs/child_abuse_reporting_12_07_11.pdf
23 Georgetown University
Website explaining university's policies on protecting minors including FAQ and information for
parents and families
http://protectionofminors.georgetown.edu
Indiana University
Website with interim policy (2012) and links to related policies such as minors in hazardous
work areas
http://policies.iu.edu/policies/categories/administration-operations/public-safety-institutionalassurance/PS-01.shtml
Minnesota State Colleges and Universities
Report from general counsel's office on legal considerations when hosting minors
www.ogc.mnscu.edu/Documents/HANDBOOK%20Minors%20on%20C.pdf
Penn State University
Comprehensive policy covering not only abuse but medical needs, transportation, and other
topics. Many links to forms and related policies
http://guru.psu.edu/policies/ad39.html
Rutgers University
Policy covers measures to prevent abuse, adequately supervise minors, and handle emergencies
http://senate.rutgers.edu/MinorsOnCampusTaskForceReport.pdf
St. Bonaventure University
Policy addresses services to victims and lists responsibilities of various campus offices
www.sbu.edu/uploadedFiles/image_gallery/protection_of_minors_policy(1).pdf
Temple University
Includes anonymous reporting
http://news.temple.edu/news/2013-01-14/temple-adopts-new-policies-minors-who-come-campus Tufts University
Policy addresses contacting parents and interim safety measures for victims. Flow charts of
university reporting requirements and investigative process
http://hr.tufts.edu/wp-content/uploads/EMP_Minors_Policy-.pdf
24 University of Florida
Office of Youth Conference Services
Under Educational Resources, see policy on minors in labs, clinics, and animal care facilities
https://oycs.ufsa.ufl.edu
University of Oklahoma
Policy includes handy checklists on event planning, housing, and first aid
www.ou.edu/content/eoo/links/jcr%3Acontent/mid_par/download_3/file.res/Minors%20Best%2
0Practice%205-8cl.pdf
University of Southern California
Prohibits students from babysitting in their rooms, including relatives. Prohibits children in class.
Applies same requirements to university-affiliated programs and outside groups
http://policies.usc.edu/p2admOpBus/protecting_minors.html
Villanova University
Comprehensive policy
www1.villanova.edu/content/dam/villanova/finance/documents/insurance/Minors_in_Villanova
University_Programs_Policy.pdf
25