Unpaid Internship Policy

Policy Name: Unpaid Internship Policy

Policy Number: HR-5001

Effective: 2021/08/23

Revised: Not applicable

Policy Statement

This policy provides general guidance and specific procedures pertaining to Unpaid Interns.

Definition of an Internship

According to the National Association of College Employers, an internship is “A form of experiential learning that integrates knowledge and theory learned in the classroom with practical application and skills development in a professional setting. Internships give students the opportunity to gain valuable applied experience and make connections in professional fields they are considering for career paths; and give employers the opportunity to guide and evaluate talent.”

What Constitutes an Unpaid Internship?

Students who wish to volunteer for the purposes of educational or professional interest as part of a formal or informal educational program must be assessed under the following factors from the Department of Labor to determine whether an Unpaid Internship status exists:

  1. The extent to which the intern and the employer clearly understand that there is no expectation of compensation. Any promise of compensation, expressed or implied, suggests that the intern is an employee-and vice versa.
  2. The extent to which the internship provides training that would be similar to that which would be given in an educational environment, including the clinical and other other hands-on training provided by educational institutions.
  3. The extent to which the internship is tied to the intern's formal education program by integrated coursework or the receipt of academic credit.
  4. The extent to which the internship accommodates the intern's academic commitments by corresponding to the academic calendar.
  5. The extent to which the internship's duration is limited to the period in which the internship provides the intern with beneficial learning.
  6. The extent to which the intern's work complements, rather than displaces, the work of paid employees while providing significant educational benefits to the intern.
  7. The extent to which the intern and the employer understand that the internship is conducted without entitlement to a paid job at the conclusion of the internship.

If the factors listed above are met, an employment relationship typically does not exist under the FLSA, and the Act's minimum wage and overtime provisions do not apply to the Unpaid Intern. Further, the individual is not eligible for any Holy Family University benefits, including unemployment or workers' compensation.


  • A college student who volunteers their time to increase their knowledge and skills through hands-on training when a part-time paid position or independent study (for credit) are not options.
  • A high school student interested in learning about or researching a project for which they are receiving class credit at their school or are learning more about a role because they have an interest in it as a career field.
  • A graduate student who volunteers their time as part of a course requirement to obtain specialized knowledge, experience or study.

Requirements and Responsibilities Pertaining to Unpaid Interns

Unpaid Interns are subject to and must abide by all applicable University, policies, procedures and rules, including but not limited to those relating to health and safety, confidentiality, intellectual property, protected health information, non-discrimination, computer use, ethics, conflict of interest, criminal background check, drug use and anti-violence. It is the responsibility of the sponsoring supervisor to review these with the Unpaid Intern.

Safe Environment Policy

Unpaid Interns who have direct contact with a Minor that involves the care, supervision, guidance or control of a Minor and has routine interaction with a Minor must have completed the full set of background check clearances before they arrive on campus. Routine interaction (which is part of the definition of “direct contact”) is “regular and repeated contact that is integral to a person’s intern responsibilities”.

All Interns must successfully complete the following clearances: (i) Pennsylvania State Police Criminal Record Check; (ii) Pennsylvania Child Abuse History Clearance; and (iii) FBI fingerprint based national criminal records check.

To complete the clearances, please follow these steps:

As an unpaid Intern, you are able to complete the clearances under the purpose of “Volunteer”. There may be no cost associated for these clearances. Please see below for instructions on initiating these checks. If you have completed clearances for another purpose, within the previous 12 months, those results may be acceptable.

(i) The Pennsylvania State Police Criminal Record Check

This clearance can be obtained by logging on to https://epatch.state.pa.us . Select “Submit a New Record Check” and complete the required information. Submit a copy of your printed certificate form displaying the results to the Office of Human Resources upon completion.

(ii) Pennsylvania Child Abuse History Clearance

Submit an application online by creating a Child Welfare Account and completing the information electronically through the Child Welfare Portal at http://www.compass.state.pa.us/CWIS. Submit a copy of your printed certificate form displaying the results to the Office of Human Resources upon completion.

(iii) FBI Federal Criminal History Record

To complete the FBI Fingerprinting, go to https://uenroll.identogo.com to register. Enter code 1KG6ZJ. On the next screen choose “schedule an appointment”. To finish the registration process, complete the required information. Once registration is completed, you will receive a confirmation email. IdentoGO is the service provider for federal background checks/fingerprinting services. As part of the registration process, you will schedule an appointment at one of their locations. Once you receive the results of the fingerprinting, please send your completed results to the Office of Human Resources.

Prohibited Activities

Unpaid Interns cannot replace or be substituted for current employees or perform work that would otherwise require another individual to be employed. Volunteer services are generally limited to educational training.

Unpaid Interns are also prohibited from performing the following activities:

  • Operating heavy equipment, including vehicles
  • Working with stored energy (e.g. steam, electricity, hydraulics)
  • Activity considered inappropriate for any employee
  • Entering into any contract on behalf of the University
  • Being present in a clinical setting or working with Protected Health Information (PHI), except in accordance with the specific internship agreement and Holy Family University confidentiality policies and procedures, as applicable

Unpaid Interns must satisfactorily complete all applicable training and orientation appropriate to the role prior to commencing activities. Depending on the nature of the service, training may include HIPAA requirements, FERPA requirements, health and safety precautions, lab protocols, compliance or customer service requirements.


Unpaid Interns are expected to conduct themselves consistent with standards of professional behavior common to all University and departmental staff. Unpaid Intern opportunities approved under this policy may be terminated at any time without cause or prior notice.

Email accounts, keys, ID badges and other equipment issued to an Unpaid Intern remain the property of Holy Family University and must be returned upon termination.

Additional Policies Governing Unpaid Interns

Unpaid Interns who wish to seek reasonable accommodations for a disability should contact the Holy Family University Section 504/ADA Coordinator.

Procedures for Unpaid Internships

It is the department's responsibility to be certain the individual has adequate experience, qualifications, orientation, training and supervision appropriate to intern role or task they will be expected to perform.

Unpaid Interns:

  1. Each potential Unpaid Intern must sign an Unpaid Intern Agreement and successfully complete the University background check and child abuse clearance requirement. This process must be coordinated through Holy Family University Human Resources.
  2. If the individual is returning or starting a new assignment, and, if a break in assignment is 6 months or more, all forms and processes set forth above must be completed or updated.

Sponsoring Manager:

  1. Sponsoring Managers must review any Internship Agreement and Objectives of Study with the Vice President for Finance & Administration prior to agreeing to the Unpaid Internship.
  2. Sponsoring Manager or designee will be responsible initiating IT Onboarding/Offboarding, in order to obtain access to email and other IT related technology/software.
  3. Sponsoring Managers are prohibited from providing Unpaid Interns physical files or shared drive access to electronic files containing PHI. Unpaid Interns should only have access to de-identified or non-sensitive information through a sponsored guest account.
  4. Sponsoring Managers will ensure that the Unpaid Intern is properly trained on all required policies, procedures, safety equipment, and that the Unpaid Intern is following/using them. Department specific policies and procedures will be addressed as appropriate.
  5. Sponsoring Managers will ensure that the Unpaid Intern's activities are monitored at all times.
  6. Sponsoring Managers will be responsible for initiating an IT Offboarding form, and collecting the Unpaid Intern's ID badge and other Holy Family University property by the end of the last day in the workplace.
  7. The supervisor and/or department will be responsible for retaining all forms and documents for a period of three years from the date the volunteer ends the assignment, and providing a copy of all forms to the Office of Human Resources.