Minors on Campus and in Programs
Policy Name: Minors on Campus and in Programs
Policy Number: ADM-2002
I. Policy Statement
A. Purpose and Scope
Holy Family University's Mission recognizes the essential dignity and worth of each member of our community. Accordingly, we seek to foster a safe and healthy environment built on mutual respect and trust and are committed to the conduct of operations consistent with this Mission and core values.
The following policy is intended to safeguard Minors who may participate in and/or attend activities and programs under the authority of Holy Family University or at the University or in University Facilities.
Holy Family University expects all members of its community to abide by and execute this Policy, as necessary. Failure to do so may lead to revocation of the opportunity to use University facilities and/or cancellation of programs. Employee violations of this Policy may result in disciplinary action.
B. Defined Terms Under this Policy
Minor. A non-matriculated person under the age of 18.
Authorized Adult. Any person, 18 or older, employee or volunteer, who interacts with, supervises, chaperones or otherwise oversees Minors. This includes, but is not limited to: faculty, staff, volunteers, graduate or undergraduate students, interns, employees of temporary employment agencies and independent contractors retained by the University.
Authorized Adult. also includes any person, 18 or older, employee, contractor or volunteer, of an Outside Entity who interacts with, supervises, chaperones or otherwise oversees Minors as part of their job responsibilities or volunteer activities on behalf of the Outside Entity.
Holy Family University Community. All staff, faculty, students, and volunteers employed, enrolled, and/or working in a University-specific capacity.
Holy Family Contact. An employee or volunteer of Holy Family University with whom a Program Director has primary contact to arrange an event, program, activity, class or program.
Covered Program. Any activity or program (1) sponsored or hosted by Holy Family University, regardless of where it is held, where Minors are present or (2) sponsored or hosted by an Outside Entity at the University or in University Facilities, where Minors are present.
Covered Programs do not include: (1) any University undergraduate or graduate programs in which matriculated Minors are enrolled for academic credit, (2) Visiting Student/Accepted Student/Visiting Athlete Programs/ or Admissions Programs for prospective or admitted students run by Admissions Department or Athletic Department; or (3) events on campus that are open to the general public and which Minors may attend at the discretion of their parents or guardians (hereafter “Unaffiliated Minors”).
Program Director. The Authorized Adult with overall supervisory and day to day operations responsibilities for a Covered Program.
University Facilities. Premises owned, leased, or otherwise controlled and/or maintained by Holy Family University.
Direct Contact. Contact between an Authorized Adult and one or more Minors that involves: the instruction, care, supervision, guidance or control of Minors; routine interaction defined as regular and repeated contact that is integral to the Authorized Adult’s responsibilities.
Outside Entity. Any Third Party (individual or entity) that contracts with the University to host a Covered Program.
Service Provider. Any Third Party (individual or entity) that contracts with Holy Family University to provide regular services to the Holy Family University Community, but is not affiliated with a Covered Program.
- Regular Services are services provided to Holy Family on a regular, routine, and scheduled basis. Regular Services include but are not limited to: food service, outsourced security, bookstore, transportation services, grounds keeping services. Services provided on a one-off basis are not regular services.
II. Policy Guidelines
A. MINORS ON CAMPUS – COVERED PROGRAMS
All Program Directors must satisfy the requirements of this Policy. Outside Entities that conduct or provide Covered Programs are required to comply with this Policy, and attest that the appropriate certifications and background checks have been completed (and provide written confirmation of the same to the designated Holy Family University representative). All Service Providers must satisfy the requirements of this Policy. Contracts with Outside Entities for such Covered Programs, and Contracts with Service Providers must refer to, incorporate by reference, and require compliance with this policy.
Program Directors must notify the appropriate personnel of all Covered Programs.
In the event that the Covered Program involves the housing of minors in University residence halls, Residence Life must be notified to ensure that all required forms are completed before minors are permitted to be housed in the residence halls.
If any Holy Family University Covered Program involves the transportation of a minor, the Program Director must contact the Vice President for Finance and Administration, /Risk Management for prior approval. Such authorization will include, but may not be limited to, the written permission of a parent or legal guardian.
2. Screening Requirements
Program Directors must ensure that any Authorized Adult who is expected to have Direct Contact with Minor(s) has successfully completed all required clearances in accordance with local, state and federal regulations, including the following minimum screening requirements:
- Criminal History Record - submitted through the Pennsylvania State Police
- Child Abuse History Certification - submitted through the Pennsylvania Department of Human Services
- Federal Criminal History Record (fingerprint-based) - submitted through the Pennsylvania State Police or its authorized agent. (“Minimum Screening Requirements”)
Failure to comply may result in the termination of any agreement, activity, class, event, and/or Covered Program.
In addition, all Service Providers must successfully complete all required clearances, including the Minimum Screening Requirements, for all employees, contractors, volunteers or agents who will be on University grounds or in University Facilities.
Any individual subject to screening requirements under this Policy has a continuing obligation, as long as they continue to participate in a Covered Program, to immediately disclose to the University any new felony or misdemeanor conviction or plea of nolo contendere.
Individuals who have a break in service or enrollment may be subject to re-screening in order to engage in a Covered Program if they would otherwise be subject to screening pursuant to this Policy.
Should any screening indicate a criminal record, Human Resources will determine whether the individual may participate in a Covered Program.
All screenings will be conducted, and all information and results will be used, in accordance with applicable laws, regulations, and University policies and procedures.
The University mandates that required clearances for any Covered Program be provided to, and maintained by the following personnel from the Office of Special Events, Athletics, Student Engagement, or any other department involved in a Covered Program as applicable:
- Assistant Director of Special Events, Office of Special Events;
- Assistant Director Athletics/Compliance or Athletic Director, Athletics;
- Associate Director or Coordinator, Residence Life;
- Coordinator, Student Engagement.
- Any other department involved in a Covered Program must forward required clearances to the Vice President for Finance and Administration
In lieu of providing results of the Minimum Screening to the University, it is an acceptable alternative to receive a document from an Outside Entity or Service Provider affirming that: (1) the Outside Entity or Service Provider conducted the Minimum Screening Requirements; (2) all employees, agents, or volunteers who will be on University grounds or in University Facilities have passed the Minimum Screening Requirements (with a list of names); and (3) their policies prohibit the provision of the Minimum Screening results directly to Holy Family. An Outside Entity or Service Provider will be required by contract to provide all clearances or alternative documentation under this Policy to the appropriate contact and forward this information to the Special Assistant to the President along with the contract. Failure to do so can result in the termination of the Covered Program or Service Provider contract.
The University reserves the right to take appropriate action with respect to University employees or students or Outside Entities’ employees, volunteers, or contractors, who falsify or fail to disclose information on employment or admission applications or other University documents, whether revealed as a result of screening pursuant to this Policy or otherwise, up to and including immediate termination of employment, expulsion, or rescission of permission to participate in Covered Program or come into or on University Facilities.
Any questions about the Screening Requirements can be directed to the Vice President for Finance and Administration or Human Resources.
3. Training Requirements
Training is essential to the University’s efforts to maintain a safe campus environment consistent with its mission and core values. It is the responsibility of all University employees, and those serving as Authorized Adults for the University and Outside Entities, to become informed about these matters by educating themselves.
Holy Family University will provide training materials, and will track review and acknowledgement of the policy to ensure the relevant University employees are trained annually.
All Authorized Adults must review Holy Family University’s “Protecting Minors” Presentations, provided to the Program Director.
Authorized Adults participating in any Program, event, or activity covered by this Policy shall:
- Be vigilant in protecting the well-being and safety of Minors with whom they interact on campus or elsewhere.
- Report any signs of abuse or neglect of Minors, as outlined in this Policy.
Authorized Adults participating in any Program, event, or activity covered by this Policy, and any individual affiliated with a Service Provider, shall not:
- Be alone with a Minor. If one-on-one is required, it is necessary for this interaction to take place in an area visible to others.
- Have any direct social media or electronic contact with Minors, unless related to the Program and another Authorized Adult shall be included in the communication. This provision does not apply to any University recruitment-related communication. All communication with Minors is expected to be done through a parent or guardian.
- Have contact with a Minor outside of the Program.
- Enter a facility in use by a Minor, such as a bathroom, residence hall room, or similar area without another Authorized Adult present.
- Engage in abusive conduct of any kind toward, or in the presence, of a Minor.
- Physically assault, hit, or inappropriately touch Minors.
- Engage in sexual behavior with a Minor.
- 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, or otherwise commit any form of emotional abuse.
- Transport Minors to and from their homes to Program activities.
- Provide alcohol or illegal drugs to any Minor or facilitate a Minor’s presence at an event where there is underage consumption of alcohol or use of illegal drugs.
- 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, unless the Program Director has obtained written consent from the minor’s parent or guardian (See #13 below).
- It is incumbent upon the Program Director to ensure prior written consent is obtained for any photographs, video recordings or any other type of image capture that may be posted on social media or any other means by the Holy Family University Community or Outside Entity. Written consent provided by a parent or guardian must be obtained by a Program Director or Authorized Adult prior to any Program participation by a Minor.
B. MINORS ON CAMPUS - UNAFFILIATED MINORS
1. Residence Halls
Minors who are not participating in a Covered Program, including siblings, relatives, and friends, who visit with a matriculated university student in a residence hall must abide by all University rules and regulations including the Minor Guest Policy in the Student Handbook.
2. Minors in the Workplace
In very rare instances will Minors be allowed in the workplace. Any Minor in the workplace is subject to advanced approval by the supervisor, and as long as the Minor’s presence is not in a confidential or information sensitive area. This practice should only be utilized as an absolute last resort. The Minor must not be left unattended.
3. Minors in Classrooms
Minors are not allowed in classrooms while classes are in session unless permission is granted by the faculty member. In such cases, a Minor is allowed in the classroom under the supervision of the parent or guardian.
The faculty member must also get advanced approval from their supervisor.
This practice should only be utilized as an absolute last resort and in rare instances, and if there are no other options available. Alternatives, such as a student arranging to record a particular session, should be considered.
Students cannot bring Minors to classrooms on days of examinations, and Minors are not permitted to participate in field trips, internships, or retreats or any event off campus.
III. Procedure for Dissemination and Confirmation of Compliance with Policy Requirements
The Policy will be disseminated to University Personnel and Outside Entity Personnel as outlined below.
- University Personnel
- This policy will be disseminated each academic year via a learning management system, for review and acknowledgement.
- The Policy will be listed on the University website under University Policies and University Policy Library, as well as in the University Employment Policy Handbook
- Outside Entity and Service Provider Personnel
- The Office of Special Events, Athletics, Student Engagement, or any other department involved in a Covered Program, will disseminate the Policy and companion Training Overview as part of the contracting process with Outside Entities.
- The Office of Special Events, Athletics, Student Engagement, or any other department involved with a Covered Program will maintain records of confirmation of receipt and understanding in regard to Policy dissemination and review by Program Directors and confirmation that all Authorized Adults have complied with the Minimum Screening Requirements and reviewed the Protecting Minors Presentations as set forth above.
- The University will disseminate the Policy to all Service Providers as part of the Contracting Process with Service Providers. The Vice President for Finance and Administration will maintain records of confirmation of receipt and understanding in regard to Policy dissemination and review and confirmation that all Service Provider Personnel have complied with the Minimum Screening Requirements and reviewed the Protecting Minors Presentations as set forth above.
IV. Reporting Allegations of Abuse Involving Minors
All employees of the University are required to promptly report all suspected child abuse of Minors to Public Safety and the Title IX Coordinator.
University employees must report child abuse that they witness or have reasonable cause to suspect. It is not required that the employee have proof that abuse occurred, and any uncertainty in deciding to report suspected abuse should be resolved in favor of making a report.
In making a report, an employee shall immediately:
- If a Minor is in imminent danger call 911. Immediately after reporting to the police, contact Public Safety at 267-341-3333 to report the incident.
- Make a direct report of suspected child abuse to the Pennsylvania Department of Human services via ChildLine at 1.800.932.0313 or via the approved on-line form at compass.state.pa.us/cwis. Contact Public Safety at 267-341-3333 for assistance.
- After (or in conjunction with) reporting to the Pennsylvania Department of Human Services, call Public Safety at 267-341-3333 Public Safety will work with the reporter to ensure the reporter has satisfied his/her obligations under Pennsylvania Law.
- Within 48 hours of an oral report to ChildLine, the reporter must also submit a written report to the department or county agency assigned to the case (This step is not required if the child abuse report is filed electronically),
- All persons making a report will be required to assist the University, to extent deemed necessary, in gathering factual information related to the report.
The Public Safety Officer who receives a report of suspected child abuse will contact the Director of Public Safety and Title IX Coordinator. The Director of Public Safety will notify the Vice President for Finance and Administration/CFO, or their designee.
The Director of Public Safety, Title IX Coordinator, and/or the Vice President for Finance and Administration/CFO will confirm that all necessary steps have been taken to report the suspected child abuse inside and outside of the University, and ensure a thorough investigation of the incident.
The University will not retaliate against any person who makes a good faith effort under this reporting requirement.
Pursuant to Law, a mandated reporter who willfully fails to report a case of suspected child abuse or make a referral to the appropriate authorities or campus officials may be the subject to disciplinary action.
MINORS ON CAMPUS AND IN PROGRAM POLICY
A Guide for the Program Director
The following steps will help to ensure that all Covered Programs sponsored by Holy Family University and its affiliates, on or off campus, or by Outside Entities using University Facilities (or relationships with Service Providers), are conducted in such a manner as to provide for a safe and secure environment for all participants. Additionally, these steps will ensure that the Covered Program will be in compliance with the Pennsylvania Child Protective Services Laws and Holy Family University’s Minors on Campus and in Programs Policy.
Note: All of these steps may not apply to your particular situation and are not necessarily in any chronological order.
□ Read the Holy Family University Minors on Campus and in Programs Policy.
□ Contact the appropriate Holy Family University Compliance person to discuss your Covered Programs.
- Special Events Manager, Office of Special Events;
- AD-Compliance or Athletic Director, Athletics;
- Director or Coordinator, Residence Life;
- Coordinator, Student Engagement
The Vice President for Finance and Administration will oversee the administration of this Program and should be consulted by other departments, as needed.
□ Ensure that all Authorized Adults associated with the Covered Program have successfully completed the Minimum Screening Requirements, and provide the required information to Holy Family University.
□ Contact the Vice President for Finance and Administration, or Human Resources with questions regarding the Minimum Screening Requirements/Background Checks procedures.
□ Ensure that all Authorized Adults associated with the Covered Program have reviewed the Holy Family University “Protecting Minors” Presentations and are aware of their responsibilities as a Mandated Reporter of Child Abuse under State Law and Holy Family University Policy.
□ Ensure receipt of the sign off sheet indicating Authorized Adults have received, reviewed and agree to comply with the Protecting Minors Policy.
□ Ensure that the facilities used for the Covered Program are appropriate for Minors.
□ When planning your Covered Program, consider the following areas that may need to be addressed for your particular situation:
□ Appropriate physical contact and communication by personnel with children based on the age of children and the nature of the Covered Program activities;
□ Appropriate forms including permission forms, medical contact information and liability waivers have been completed and are readily available;
□ Parental/Guardian permission to use media images obtained from the Covered Program;
□ Internet Access and Social Media exposure, for staff and participants of the Covered Program.