Youth Protection Policy
Originally Approved by AdAB: October 29, 2019
Effective Date: November 26, 2019
I. Policy Statement
Hope College strives to provide a safe and enjoyable educational environment for all campus community members, including youth attending programs on campus. To introduce youth to higher education and to specific areas of knowledge, members of the college community may take part in programs or activities that Hope operates or sponsors involving minors (more fully defined below as Hope Covered Programs). In furtherance of these objectives, Non-College organizations also may use Hope Facilities for programs and activities involving minors that are not sponsored by Hope (more fully defined below as Non-Hope Covered Programs).
Hope is committed to protecting the safety and well-being of youth who participate in both Hope Covered Programs and Non-Hope Covered Programs, which requires an increased level of attention and supervision, as well as an expectation that members of the college community and Non-college organizations will conduct themselves in a responsible and appropriate manner in the presence of youth.
This policy applies to programs and activities in which minors will be physically present and participating, either taking place on the college campus or under the authority and/or direction of the College at other locations.
This policy also applies to visitors or guests using College facilities who must provide to the sponsoring College unit satisfactory evidence of compliance with all of the requirements of this policy prior to the scheduled program or activity, and must maintain compliance throughout the duration of their use of the College facilities. Those who do not meet the proscribed standards may be asked to leave the Campus.
All College faculty, administrators, support staff, students, program staff, and volunteers are responsible for understanding and complying with this Policy. Any exceptions to this policy must be in writing and approved by the Office of the President.
III. Reason for Policy
The aim of this policy is to restrict the interactions of youth with adults on this campus in a prudent manner with the hope that this policy, together with campus attention and awareness, will maintain an environment where children’s safety is maximized and their risk of injury on campus is minimized.
IV. Entities Affected by this Policy
This policy applies to all youth serving programs and the employees, students, visitors, volunteers and third party contractors who are working with these programs.
The policy does NOT apply to the following:
- College credit-bearing academic courses with students under the age of 18 enrolled, including on-campus, distance education, and/or independent study experiences;
- Minors employed by Hope College. (Note: Minors who are under the age of 18 and who, in their employment or volunteer activities have interactions with children, are subject to the same requirements as employees and volunteers who are 18 years of age or older.);
- Minors as guests of family members;
- Minors participating in private or public events accompanied by parents/legal guardians or adults designated as responsible for their care by parents/legal guardians;
- Performances or events open to the general public;
- Minors who are subjects of Institutional Review Board-supervised research (Research conduct is addressed in the policies and procedures of Hope’s Institutional Review Board, known as the Human Subjects Review Board (HSRB).);or
- Contact with minors through external internship programs.
- Authorized Adult: The paid employee(s) primarily responsible for oversight of the Hope Covered Program or with responsibility to the contracts for the Non-Hope Covered Programs.
- Campus: All buildings, facilities, and properties owned, operated, managed, or controlled by the college. This also includes areas immediately adjacent to campus.
- Hope Covered Program: Includes any program or activity that Hope operates or sponsors involving youth,
including programs and activities sponsored by student organizations, or programs
and activities offered by any academic, administrative or athletic unit of the College
(including, but not limited to, formalized courses of study; academic camps; mentoring
activities; academic enrichment programs; internships or other activities in laboratories;
athletics activities; and recreational programs).
Hope Covered Programs do not include: (i) public events and other activities at or sponsored by Hope at which parents or other guardians are expected to provide supervision of minors in their care; and (ii) supervision of minors who are College research subjects, which is addressed in the policies and procedures of Hope’s Institutional Review Board, known as the Human Subjects Review Board (HSRB).
- Mandated Reporters: The College defines all employees as “mandatory reporters” for the purpose of filing Clery statistics, meaning all college employees must inform Campus Safety if they are made aware of a crime that has occurred on campus. For the purpose of this policy, all employees would also be considered Mandated Reporters as it relates to reporting child abuse or neglect to the State under Michigan Child Protection Law.
- Minor/Youth: For purposes of this Policy, a minor/youth is a person under the age of eighteen (18), participating in a Hope Covered Program or Non-Hope Covered Program, who is not enrolled in or accepted for enrollment in a degree-granting program at Hope. Students who are dually enrolled in Hope credit-granting courses while also enrolled in elementary, middle and/or high school are not considered Minors for purposes of this Policy. College students who are under the age of 18 are excluded from this definition. Prospective students, under the age of 18, who are on campus for the purposes of exploring admission to the College are also excluded from this definition.
- Non-Hope Covered Program: Non-College organizations using Hope facilities for programs and activities involving minors that are not sponsored by Hope. Non-Hope Covered Programs do not include public events and other activities at which parents or other guardians are expected to provide supervision of minors in their care.
- One-on-One: Interactions between one adult and one minor that is not in a public space or in the presence of other Program Staff, participants or a parent; in an office/space alone where not visible to others.
- Program Staff: Anyone working or volunteering with a Hope Covered Program.
A. Code of Conduct for Program Staff
The Authorized Adult and/or Program Staff member is expected to notify additional Program Staff and volunteers of applicable program rules, including conduct expectations. Program Staff and volunteers must minimally abide by all College policies and regulations and may be removed from the program for violation of such rules. Program Staff may not do any of the following:
- Engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material with minors or assist minors to access such materials, unless in the role of a provider of health care or counseling, or faculty academically addressing materials of a sexual nature as an established part of the curriculum of a course, training, research or classroom experience.
- Engage or allow minors to engage them in romantic or sexual conversations or related matters unless required in the role of resident advisors, counselors, or health care providers.
- Engage or communicate with minors through email, text messages, social networking websites, phone, internet chat rooms, multiplayer online games, or other forms of social media at any time except in the case of an emergency. Upon request, the college may authorize such communication if there is an educational or programmatic purpose for the communication and the content of the communication is consistent with the mission of the program and the college.
- Touch minors in a manner that a reasonable person could interpret as inappropriate. If necessary, touching should only be in the open, in response to the minor’s immediate physical needs, for a purpose that is consistent with the program’s mission and culture, or for a clear educational, developmental, or health-related purpose (i.e., treatment of an injury). Respect and adhere to any resistance from the minor unless it is a life-threatening emergency.
- Take pictures of minors or post information about minors to social media sites without written permission from a parent/guardian.
- Meet with minors outside of established times for program activities. Any exceptions require written parental authorization and must include more than one Program Staff.
- Invite individual minors to your home or other private locations. Any exceptions require authorization by the Authorized Adult and the College and written authorization by a parent/legal guardian.
- Provide gifts to minors or their families independent of items provided by the program.
- Use profanity, vulgarity, or harassing language, or language that would violate the college Equal Opportunity, Harassment and Nondiscrimination policy.
- Engage in abusive conduct of any kind toward, or in the presence of, a minor, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. No Program Staff shall strike, hit, administer corporal punishment or touch in an inappropriate or illegal manner, any minor. If restraint is necessary to protect a minor or other minors from harm, all incidents must be documented and disclosed to college, the Program Administrator, and the minor's parent/legal guardian.
- Use, possess, or be under the influence of alcohol, marijuana or illegal drugs while on duty or while in the presence of minors involved in a program.
- Provide alcohol, marijuana or illegal drugs to a minor.
- Provide medication to a minor unless explicitly authorized in writing by a parent/guardian.
- Carry a firearm or other weapon at any time during the youth program.
- Program Staff must make reasonable efforts to limit one-on-one contact between adults
and minors. This includes:
- Reasonable efforts to have two or more adults present during activities where only one minor is present
- Reasonable efforts to involve more than one adult in any direct electronic contact with a minor
- Reasonable efforts of Program Staff to have another Program Staff present when addressing a minor in private areas (e.g.: restrooms, bed-rooms, study lounges)
- If handling an emergency when only one minor is present, the adult responding should make reasonable efforts to contact another adult to come and assist immediately
- Staff expected to contact single minors for official academic or programmatic reasons/recruitment may do so as long as the content of the communication is consistent with the mission of the program and the college.
- If meeting One-on-One is required and there is a window on the door of the room, the window must remain uncovered. If there is no window, the door should remain slightly ajar or propped open. Additionally, parents will be made aware of circumstances when One-on-One interaction may be possible.
B. Reporting Requirements
All Authorized Adults and Program Staff of Hope Covered and Non-Hope Covered Programs
are required promptly report any crime (including sexual misconduct) they are made
aware of that happened on (or immediately adjacent to) campus property or during a
Hope sponsored event or program off campus, unless the employee is designated as a
confidential resource person for sexual misconduct. Program Staff should contact Campus
Safety for most reports, though cases of sexual misconduct may be reported directly
to the Title IX Coordinator.
Michigan Child Protection Law requires certain professionals to report their suspicions of child abuse or neglect to Children's Protective Services (CPS) at the Department of Human Services (DHS), including school administrators and teachers. These professionals are referred to as Mandated Reporters. Mandated Reporters are required to make an immediate verbal report to CPS and a written report within 72 hours when they suspect child abuse or neglect. Mandated Reporters must also notify the head of their organization of the report. The verbal report can be completed by calling 855.444.3911.
The individual who had contact with the child must complete the call and provide as much detail as possible about the following information:
- The child's primary caretaker, including name and address.
- Names and birth dates for all members of the household.
- Name and birth date of the alleged perpetrator(s).
- Whether the alleged perpetrator lives with the child.
- Address where the alleged abuse or neglect occurred.
- What makes the mandated reporter suspect the child is being abused or neglected.
The Child Protection Law requires that the written report include the following information:
- Name of child.
- Description of abuse or neglect.
- Names and addresses of child's parents/guardians.
- The persons with whom the child resides.
- Child's age.
- Other information available to the reporting person that might establish the cause of the abuse or neglect, and the manner in which the abuse or neglect occurred.
DHS encourages the use of the Report of Actual or Suspected Child Abuse or Neglect (DHS-3200) form when filing the written report, which includes all the information required under the law. If more than one mandated reporter suspects child abuse or neglect based upon the same incident, they may submit just one DHS-3200 form.
The college prohibits retaliation against any member of the college community for making a good faith report of suspected child abuse or neglect or for acting as a witness in any investigation or proceeding concerning a report of child abuse or neglect. Similarly, individuals making a good faith report are protected from civil and criminal prosecution and cannot be penalized for making the report or cooperating with a CPS investigation.
C. Background Checks
All Authorized Adults and Program Staff (18 years or older) who have unsupervised access to minors at a Hope Covered Program must have been subject to a criminal background check (including sex offender registry check) through the Human Resources Department within the last three years.
An external organization sponsoring a Non-Hope Covered program on campus must certify that all Program Staff have been subject to a criminal background check (including sex offender registry check) within the past three years.
Youth programs that involve large numbers of one-time volunteers are exempt from the criminal background check requirement for volunteers if the volunteers work only in public spaces and with supervision by a College employee.
- Hope students hosting high school students as part of a pre-enrollment visit for prospective students are not required to have a criminal background check, but will be checked through campus conduct records with the Dean of Students office.
- Hope students who attend a youth program in order to work or volunteer under the direct supervision of a Hope employee are not required to have a criminal background check.
- Individuals under the age of 18 who volunteer or work under the direct supervision of a Hope employee are not required to have a criminal background check.
- External organizations using Hope facilities open to the general public are not required to provide certification of criminal background checks, even if minors are present.
3. Criminal Background Check and Sex Offender Registry Results
The types of convictions that will normally render an individual ineligible to work or volunteer at a College youth program include, but are not limited to:
- Drug distribution activity or felony drug possession
- Sexual offenses
- Crimes of violence involving physical injury to another person
- Child abuse, molestation or other crimes involving child endangerment
- Any other felony or crime involving moral turpitude
Individuals who have unsupervised access to minors at a youth program may generally not be listed on any sex offender registry.
Individuals who do not have satisfactory criminal background check results will be provided with an opportunity to explain the results and give clarifying information to Human Resources before a final decision regarding eligibility is made.
D. Addressing Reports of Abuse or Neglect
Whenever the college receives a report of alleged Child Abuse, the Title IX Coordinator, Director of Human Resources and/or Department of Public Safety will:
- Take immediate steps to prevent further harm to the alleged victim or other children, including, where appropriate, removing the alleged abuser from the program or activity or limiting his or her contact with children pending resolution of the matter
- Determine whether Michigan CPS has already been notified and, if not, make such notification and ensure the local police department is notified as appropriate
- If the parents or legal guardians of the alleged victim have not been notified and are not the alleged abusers, notify the parents or legal guardians of the child involved as determined by CPS and the local police
- Investigate the report and resolve the matter in a way that safeguards children, protects the interests of victims and reporters, affords fundamental fairness to an accused member of the community, and meets relevant legal requirements
- If an allegation of inappropriate conduct has been made against Program Staff, the suspected individual shall immediately discontinue any further participation in any covered programs until such allegation has been resolved
- Facilitate the college’s cooperation with any investigation conducted by the police department or other governmental agency. The college will try to avoid conflict with any criminal investigation into a reported incident. The college’s investigative process is separate from any active criminal investigation.
- The college’s department of public safety should be in ongoing contact with the police department or other investigating authority to establish the right timing for the college’s follow-up. Typically, the college would defer to law enforcement authorities for a period of 7–10 business days allowing law enforcement the opportunity for a criminal fact finding stage without any potential interference by a simultaneous administrative process.
Sanctions for violations of this Policy will depend on the circumstances and the nature of the violation, but may include the full range of available college sanctions including suspension, dismissal, termination, and, where appropriate, exclusion from campus. The college may also, in its discretion, take interim actions before determining whether a violation has occurred. The college may terminate the relationships or take other appropriate actions against entities that violate this Policy.
A. Program Requirements
All Hope Covered programs (as defined above) must be registered annually with the college, no later than 30 days before the program start date. Student organizations which sponsor youth programs must have a sponsoring faculty or staff member who has reviewed and approved their compliance with these requirements.
Authorized Adults must complete the Youth Program Registration form online through the Events and Conferences Office; a blank print out of this form is included as an appendix to this Policy. Note that registration must be completed with sufficient advance notice so that any applicable policy requirements such as background checks can be requested and determined to be acceptable prior to the beginning of the program.
Any third party program at the College that will involve Minors must provide a statement in its contract that ensures its adherence to this policy.
Registry provides information that programs are addressing youth safety in their planning and a commitment to meet the requirements of this policy. Hope Covered Programs are required to address the topics in the Hope Covered Programs - Youth Protection Handbook as part of their planning and evaluation of registered programs. Planning records should be available for immediate review upon request of those responsible for this policy. (The College will provide guidance/samples in each area.) Under certain circumstances, Hope Covered Program registration requirements may be waived or modified through joint approval between the Director of Public Engagement, Events and Conferences and the relevant Vice President or Dean.
The following information must be managed by both Hope Covered and Non-Hope Covered Programs:
- Selection and screening of faculty, staff, students and volunteers, including criminal background checks as required
- Training provided for all Authorized Adults/Program Staff covering Hope College Emergency Procedures and State and Campus mandatory reporting requirements
- Participation requirement forms including liability, medical treatment, and transportation policies
- Insurance requirements
B. Concussion Awareness
Units operating a youth athletic activity must comply with the requirements of the State of Michigan Sports Concussion law. A detailed description of the Michigan sports concussion law and a compliance checklist can be found online.
Requests for accommodations received by any program or activity operating on the Hope College campus involving minors must be considered within the expectations of the Americans with Disabilities Act. If you are unsure about how to manage an accommodation request, you are welcome to reach out to Sara Dorer, Equal Opportunity and Compliance Coordinator. Before ever denying a request for an accommodation, please contact Sara to discuss the situation. She can be reached by email (firstname.lastname@example.org) or at 616.395.6816.
VIII. Related Documents
- Background Check Policy
- Institutional Research Policies and Procedures (HSRB)
- Waiver of Liability Agreement
- Vehicle Usage Policy
- Youth Program Registration Form
IX. Authority and Amendment
Questions about the interpretation or application of this policy can be directed to:
- Susan Ipri-Brown, Director of ExploreHope
- Sara Dorer, Equal Opportunity and Compliance Coordinator
- Derek Emerson, Director of Public Engagement, Events and Conferences
The college reserves the right to edit the procedures as needed. Policy updates may need to be considered at times to reflect changes in the law, standards relating to the protection of minors, College processes, or as otherwise necessary as part of a standard review.
Sections of this policy have been modified from publicly available materials from the Centers for Disease Control and Prevention, Marsh Risk Consulting, Michigan State University, University of Michigan, University of Scranton, Grand Valley State University, Purdue University, and New York University.
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