Programs for Minors Policy
MINORS IN DEPAUW UNIVERSITY PROGRAMS POLICY
This policy sets forth DePauw University’s guidelines regarding children under the age of 18 (Minors) who participate in activities and programs taking place on University property and facilities or under the authority and direction of the University at other locations. The University expects all members of its community to adhere to and act in accordance with this policy.
This policy does not apply to 1) general public events where parents/guardians are expected to provide supervision of minors, or to events where parents/guardians are explicitly required to accompany their children, 2) enrolled DePauw University students who are Minors, 3) regularly scheduled classes, Short Term Off Camups Study Programs or courses, study abroad, Education Studies observations, or other directly curriculum related programs for enrolled students, 4) co-curricular and social activities designed primarily for enrolled students of the University, or 5) patient care-related activities for Minors being served in the University Health Clinic (which are instead addressed in relevant health care policies of the contractor).
All programs which will involve non-accompanied minors (under 18 years of age and not a student at DePauw) must have a registered Program Administrator.
- All programs must be registered with the Manager of Safety and Risk Management Services at a minimum thirty (30) days prior to the program.
- The Office of Public Safety must be notified of all registered programs by the Manager of Safety and Risk Management Services.
- All overnight visitors in University owned housing and/or Greek housing who are Minors must be registered with Admissions and/or Campus Living and Community Development.
- All adults (employees, faculty, volunteers and University students) who will work with Minors in University sponsored programs on or off-campus must:
- Have a background check run for criminal conviction and sexual offender registry
- Interact with Minors only in public areas and/or in the company of a second adult
- Complete mandatory training
- Sign an agreement signifying that they understand and will abide by University rules for interaction with Minors and with the child abuse/neglect reporting procedures under the Indiana Child Abuse and Neglect Hotline.
- Immediately report any suspected child abuse/neglect to the Indiana Child Abuse and Neglect Hotline, DPU Office of Public Safety, and to the Program Administrator
- All Minor aged participants in programs or events where the University is the lead sponsor will be required to provide a written and signed parental/guardian consent form including emergency medical release and emergency contact information. Exception to this provision will be made for Admission programs (including Music and Athletics recruiting) when the Minor will be only be visiting the campus on a "day" visit and where the Minor will participate only in activities in public venues such as a guided tour, attending a class or taking a sample music lesson.
- All third-party managed programs involving Minors held on the campus will be required to sign a memorandum of agreement or contract certifying that they will follow parallel processes in the conduct of their program, will indemnify the University and will carry appropriate liability insurance coverage as identified by the University.
Please see the Minors in DePauw University Programs Procedures document for more details on implementation of this policy.
MINORS IN DEPAUW UNIVERSITY PROGRAMS PROCEDURES
Program: Any activity, program or event designed primarily to serve Minors. This includes on-going programs that occur multiple times or over multiple days, as well as one-time events or projects.
Camp and/or Clinic: Refers to any Camp and/or Clinic in which Minors participate and which is run by the University. It also refers to camps and/or clinics in which Minors participate that are not run by the University but rather by a third-party using University facilities under a contract.
Program Administrator: The Authorized Adult with overall responsibility for a Program Involving Minors. The Program Administrator is the Authorized Adult who oversees the day to day Program operations or supervises the Authorized Adults charged with directing the Program operations and is consequently responsible for preparing and submitting the Program Registration Form to the Manager of Safety and Risk Management Services prior to the commencement of the Program.
Authorized Adult: An adult who may come into contact or have interaction with a Minor as part of his or her job responsibilities or volunteer activities on behalf of the University or in a program operated in conjunction with the University. Authorized Adults are considered mandated reporters with responsibility for reporting on suspected child abuse and neglect under Indiana law and University policy.
Overnight Guest: Minor visiting campus overnight under the oversight of an Overnight Host.
Overnight Host: An individual (generally a student of the University) who agrees to host a Minor to stay overnight in University-owned or Greek housing. Hosts may or may not be acting on behalf of a University sponsored Program. Hosts of Overnight Guests can be held responsible for the behavior of their guests.
Incidental Interaction with Minors: Having interaction with Minors where the contact is always in a public setting, where there is little or no opportunity for privacy with Minors, where other adults will always be present, and where there is absolutely no one-on-one contact or physical contact with Minors.
Routine or Significant Contact with Minors: The ongoing, regular or repeated contact with Minors that is part of the responsibilities of the University employee, student, or volunteer. Includes hosting Minors that involves an overnight stay, any one-on-one contact with Minors, or any physical contact with Minors.
GENERAL PROGRAM GUIDELINES
Before engaging in any Program Involving Minors, the Program Administrator must satisfy the Program Requirements listed below.
Non-University organizations and entities that operate Programs Involving Minors in DePauw Facilities must comply with this Policy.
To the extent faculty, staff, or students participate through their University roles in a Program sponsored by a third-party operating under contract with the University on- or off-campus, they should familiarize themselves with and follow the child protection policies of the third-party organization in addition to this Policy.
All Programs covered by this Policy must meet the following requirements:
- A. Program Registration and Documentation
At least thirty (30) days prior to the beginning of a Program covered under this Policy, the Program Administrator or his/her designee shall register the Program with the Manager of Safety and Risk Management Services via the University’s registration form for Programs Involving Minors. The registration must be conducted annually. The registration will require certification by the Program Administrator that documents will be collected as required by this Policy in order to sponsor a Program Involving Minors including 1) criminal and sexual offender background checks on all Authorized Adults connected to the program and expected to have Routine or Significant Contact with Minors, 2) certifications of completion of training by all Authorized Adults connected to the program, and 3) a roster of all individuals, whether DePauw University employees, students, independent contractors, or volunteers, who will be staffing the Program.
Programs that involve only Incidental Contact with Minors should register no fewer than fourteen (14) days in advance of the anticipated Program commencement date.
- B. Required Written Agreements
Parents/guardians of Minors participating in Programs must execute a University-approved waiver of liability form and provide the waiver to the Program Administrator or his/her designee. Exception to this provision will be made for Admission programs (including Music and Athletics recruiting) when the Minor will be only be visiting the campus on a "day" visit and where the Minor will participate only in activities in public venues such as a guided tour, attending a class or taking a sample music lesson.
The Program Administrator shall be responsible for maintaining these records a minimum of three (3) years after the close of the Program and being able to make these records available to the Manager of Safety and Risk Management Services and/or designee upon request. In the case of third-party contracts, the signed contracts should be retained for ten (10) years after the close of the Program and available to the Manager of Safety and Risk Management Services and/or designee upon request.
Parent/guardians must also provide a completed Medical Treatment Authorization form. Exception to this provision will be made for Admission programs (including Music and Athletics recruiting) when the Minor will be only be visiting the campus on a "day" visit and where the Minor will participate only in activities in public venues such as a guided tour, attending a class or taking a sample music lesson. All such forms must include the following:
- A statement informing the parent/guardian that the University does not provide medical insurance to cover medical care for the Minor.
- A statement authorizing emergency treatment in case the parent/guardian cannot be reached for permission.
- Authorization to release medical information to responsible parties as needed.
- Emergency contact information including name, address, and phone number of the emergency contact.
- C. Screening Requirements
The Program Administrator will be responsible for arranging for appropriate screening, application review and personal reference checks on all Authorized Adults who are expected to have Routine or Significant Contact with Minors. University Students serving as Overnight Hosts of personal friends, family are not required to complete a screening. Arrangements for screening of employees and volunteers under third-party contractual relationships should be included in the terms of the contract.
Authorized Adults who will be expected to have Routine or Significant Contact with Minors are required to complete a Background Check Release form and to be screened for identity verification and criminal history and sexual offender status both nationally and in the county of residence. Background checks must be renewed annually. Arrangements for background checks for University staff, students, and volunteers can be arranged by the Program Administrator with the University Office of Human Resources. Third party organizations will be required under the terms of the contract to arrange for background checks for their employees and volunteers at the contractor’s own cost. University Students serving as Overnight Hosts of personal friends, family, or pre-enrollment admissions visits by High School age Minors are not required to be background checked.
The following types of convictions will render an individual ineligible to work at a Program in a paid or volunteer capacity:
a. Sexual offenses, including stalking
b. Crimes of violence involving physical injury to another person
c. Dependent abuse, endangerment, molestation, child pornography
f. Listing on any sexual offender registry
Authorized Adults are required under this policy to notify the appropriate Human Resources representative (in the case of employees and volunteers) or the Program Administrator (in the case of University students and third-party program staff) of an arrest (charged with a misdemeanor or felony) or conviction within 72 hours of knowledge of the arrest or conviction. This includes any arrests or convictions that occur either between the date the background check release form was submitted and the date work begins, or during the conducting of the Program Involving Minors.
- D. Behavioral Expectations for Authorized Adults
Authorized Adults and Overnight Hosts participating in any Program covered by this Policy:
- Shall participate in and complete the mandatory youth protection training on signs of abuse and neglect of Minors.
- Shall watch for signs of Minor abuse or neglect and promptly report suspected instances of abuse or neglect.
- Shall limit physical contact with Minors to the following: side hugs; shoulder-to-shoulder or “temple” hugs; pats on the shoulder or back; handshakes, high-fives, hand-slapping, fist-bumping; verbal praise; pats on the head when culturally appropriate; touching hands, shoulders and arms; arms around the shoulders; lifting young children when necessary; holding hands (with young children in escorting situations).
- Shall not engage in full-frontal hugs; kisses; showing affection in isolated areas; lap sitting; wrestling; piggyback rides; tickling; allowing a Minor to cling to the program staff person’s leg; any type of massage given by or to a Minor; any form of affection that is unwanted by the Minor or program staff; compliments relating to physique or body development; touching bottom, chest or genital areas.
- Shall not have contact with a Minor outside of the Program without parent arrangement and permission.
- Shall not pick up Minors from or drop off Minors at their homes or transport them to and from off-campus activities. Authorized Adults MAY transport High School age Minors in conjunction with recruiting visits. As much as practically possible, Authorized Adults should avoid transporting such Minors alone and in all cases should do so only with the written permission of the parent/legal guardian. In addition, Minors may be transported by Public Safety with or without prior authorization by the parent/legal guardian as needed for emergency medical treatment.
- Shall not tell Minors “this is just between the two of us” or use similar language that encourages children to keep secrets from their parent/guardian.
- Shall not engage in inappropriate conversations with Minors that are sexual in nature (“inappropriate” meaning any conversation which the Authorized Adult would not feel comfortable having in the presence of the parent/guardian of the Minor).
- Shall not engage in abusive conduct of any kind toward, or in the presence of, a Minor.
- Shall not 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 perpetuate any form of emotional abuse.
- Shall not provide alcohol or illegal drugs to any Minor or facilitate the Minor’s presence at an event where there is underage consumption of alcohol or use of illegal drugs.
- Shall not make any sexual materials in any form available to Minors or assist them in any way in gaining access to such materials.
- Shall not give gifts to Minors or their parent/guardian independent of gifts provided by the Program.
- Shall not take photos or videos of a Minor with personal cell phones, cameras or similar devices in showers, locker rooms, restrooms, or other areas where privacy is expected
- Shall not have any direct electronic and/or social media contact with Minors, unless it is related to the Program AND another Authorized Adult is included in the communication (This provision shall not apply to Admission (including Music and Athletics) recruiting).
- Shall not violate any other provisions of DePauw University policy or any federal/state/local laws or regulations.
Authorized Adults (but not University Students serving as Overnight Hosts of personal friends, family, or pre-enrollment admissions visits by High School age Minors) participating in any Program covered by this Policy:
- Shall not invite individual Minors to their home or place of residence. Any exceptions will require authorization by the Program Administrator and written authorization by the parent/guardian.
- Shall not share sleeping quarters with Minors. Separate accommodations for Authorized Adults and Minors are required other than in the case of the Minor’s own parent/guardian or sibling. Minors should be placed in accommodations that allow for a locked door between themselves and program staff. Program staff should not enter the sleeping quarters of a Minor without another Authorized Adult present.
- Shall not enter a facility used by a Minor such as a bathroom, locker room, residence hall room, or similar area without another Authorized Adult present.
- Shall not shower, bathe, or undress within the presence of Minors.
- Shall not be alone with a Minor. If one-on-one interaction is necessary, the interaction must take place in an area in plain sight of passersby or witnesses, such as a dining hall or café, or in an office or other unlocked space with a) doors and windows uncovered and providing unobstructed view from outside of the office and b) in a building open to the public at the time of the interaction.
- E. Youth Protection Training for Authorized Adults
All Authorized Adults who participate in Programs involving Minors must complete youth protection training annually, prior to the commencement of the Program. Youth protection training must include a review of:
- Basic warning signs of abuse or neglect of Minors
- Guidelines for protecting Minors from emotional and physical abuse and neglect
- Requirements and procedures for reporting incidents of suspected abuse, neglect or improper conduct
- All requirements in this Policy
All third-party organizations operating Programs involving Minors in DePauw facilities must provide youth protection training to their Authorized Adults that covers the basic warning signs of abuse or neglect of Minors; offers guidelines for protecting Minors from emotional and physical abuse and neglect; and imposes requirements and procedures for reporting incidents of suspected abuse, neglect, or improper conduct.
- F. Staffing Ratios and Requirements
Each Program must meet the following minimum ratios of Authorized Adults to Minors:
AGES RATIO FOR OVERNIGHT PROGRAMS RATIO FOR DAY PROGRAMS
6 to 8 1:6 1:8
9 to 14 1:8 1:10
15 to 17 1:10 1:12
For purposes of the staffing ratios, the Authorized Adults must be at least 18 years of age and have completed required youth protection training before interacting with Minors.
If, however, a Minor’s parent/guardian supervises the Minor at all times during the Program, the required minimum staffing ratios do not apply to that Minor. The parent/guardian of a Minor participating in the Program shall not supervise other Minors without qualifying as a volunteer or employee of the Program.
The Program Administrator shall assign a supervisory Authorized Adult to be on-site and available to Minors at all times. For overnight programs, the supervisory Authorized Adult must reside in the housing unit. For Overnight Guests, their Host must be responsible for their guest at all time.
- G. Emergency and Safety Protocols for Programs Involving Minors
Each Program Administrator shall:
- Establish a procedure for notifying the Minor’s parent/guardian in case of an emergency, including medical or behavioral problems, natural disasters, or other significant disruptions. The Program Administrator shall provide written information on the notification procedure to Authorized Adults involved in the Program, parents/guardians of Minors, if age appropriate - the Minor, and the Manager of Safety and Risk Management Services (who will, in turn, provide it to the Office of Public Safety).
- For overnight Programs and Overnight Guests, provide a roster of all Minors participating in the Program to the Manager of Safety and Risk Management Services (who will, in turn, provide to the Office of Public Safety). The roster shall include each Minor’s name, sex, age, and home address; local room assignment; phone number of parent/guardian; and emergency contact information.
- Provide information to the parent/guardian detailing the manner in which the Minor can be contacted during the Program.
- Provide the Manager of Safety and Risk Management Services (who will, in turn, provide to the Office of Public Safety) with a roster of Program staff and contact information, including information on the Program Administrator.
- For overnight Programs, distribute to all Program staff the Public Safety Emergency Procedures Guide and, for Minors, distribute a summary of the Emergency Procedures Guide. Review the information in the guide with them upon arrival or as soon as practical thereafter, but prior to their first night on campus.
- Program staff may distribute medications to Minors only under the following conditions:
- The Minor’s parent/guardian must provide the medicine in its original pharmacy container labeled with the Minor’s name, medicine name, dosage, and timing of consumption. Over-the-counter medications must be provided in the manufacturer’s container and labeled with the Minor’s name, dosage, and timing of consumption.
- The parent/guardian must provide written authorization before Program staff may distribute any medication to a Minor.
- Program staff shall keep the medication in a secure location and, at the appropriate time of distribution, meet with the Minor in the presence of another Authorized Adult.
- The Program staff member shall allow the Minor to self-administer the appropriate dose as shown on the container.
- For medicine that the Minor cannot self-administer, the parent/guardian must make arrangements with a third-party health care professional unaffiliated with the University in advance of the Minor’s arrival. In no event will a University health care professional be responsible for such administration.
- Minor may carry personal “epi” pens and inhalers during activities for self-administration.
- H. Rules and Disciplinary Measures for Programs Involving Minors
Each Program Administrator shall develop and make available to participants and their parent/guardian the rules and disciplinary measures applicable to the Program. Program participants and staff must abide by all applicable University policies and regulations and may be removed from the Program for non-compliance. Program rules must include the following:
- The possession or use of alcohol and other drugs, fireworks, guns, or other weapons is prohibited.
- The operation of a motor vehicle by Minors is prohibited while participating in a Program.
- Staff and participants must park vehicles in accordance with University parking regulations.
- Minors may leave University property during the Program only under stated conditions.
- No theft or violence, including sexual abuse or harassment, will be tolerated.
- Hazing of any kind is prohibited.
- Bullying, including verbal, physical, and cyber bullying, is prohibited.
- In compliance with the University Smoking policy as well as Greencastle city ordinance, no smoking is allowed within University buildings (or within 40 feet of those buildings), in University vehicles or at University outdoor facilities.
- Misuse or damage of University property is prohibited. Charges will be assessed against those responsible for damaging or misusing University property.
- The inappropriate use of cell phones, cameras, imaging, and digital devices is prohibited including use of such devices in showers, restrooms, or other areas where privacy is expected.
- The Program must adopt and implement rules and regulations for proper supervision of Minors in University housing.
- The Program must comply with all security measures and procedures specified by the Office of Campus Living and Community Development and the Office of Public Safety.
- Overnight Guests are expected to follow University rules and guidelines. Hosts of Overnight Guests can be held responsible for the behavior of their guests.
- I. Reporting Suspected Abuse and Responding to Allegations of Inappropriate Conduct
All Authorized Adults who suspect or know of child abuse or neglect must report this information immediately to the Indiana Child Abuse and Neglect Hotline (800-800-5556), the Program Administrator, and the Office of Public Safety. If the situation involves an emergency and/or the victim is in imminent danger, place the call to 911.
If an allegation of inappropriate conduct has been made against an Authorized Adult participating in a Program, he or she shall discontinue any further participation in the Program until such allegation has been resolved to the University’s satisfaction. It is the Program Administrator’s responsibility to ensure that the Authorized Adult’s participation in the Program ceases as soon as the Program Administrator becomes aware of such an allegation.
- J. Transporting Minors
When transporting Minors by motor vehicle:
- Program Administrators must be notified of all transportation activities to initiate standard travel procedures.
- Minors must never be transported without written permission from a parent/guardian in the form of a Release of Liability associated with the Program.
- Drivers must be in compliance with the University’s Transportation and Vehicle Use Policy.
- K. Third Party Contractor Requirements
Contracts with non-University organizations bringing Minors onto the campus for an overnight stay or for consecutive day (or longer) visits must include the following provisions:
- Language making it clear that the non-University organization has been provided with a copy of or link to this Policy and will abide by the requirements contained within, along with a notification that failure to abide by the Policy may constitute grounds for termination of the activity.
- An indemnification clause in which the non-University organization agrees to indemnify the University for claims, lawsuits, or other actions that arise as a result of the non-University organization’s use of campus facilities.
- General Liability insurance limits of $2 million per occurrence and $2 million aggregate with the University shown as additional insured.
- Effective with the 2016-2017 academic year, Sexual Misconduct (also known as Abuse and Molestation) Liability insurance with limits of $2 million per occurrence and $2 million aggregate with the University shown as additional insured is required.