POLICY REGARDING MINORS AT WASHINGTON UNIVERSITY OR PARTICIPATING IN WASHINGTON UNIVERSITY PROGRAMS
Purpose and Scope:
The purpose of this policy is to provide for appropriate supervision of minors (children under the age of 18) participating in activities and programs taking place on Washington University property, in University owned or managed facilities, and under the exclusive authority and direction of the University in other locations. The policy also requires immediate reporting of any instances or suspected instances of child abuse or inappropriate interactions with minors to law enforcement and to the University’s Human Resources Office. Failure to comply with this policy will be treated as a serious offense and could result in discipline, up to and including termination.
To report instances or suspected instances of child abuse or inappropriate interactions with minors, contact either the Washington University Policy Department (314-935-5514) or the Washington University School of Medicine Protective Services Department (314-362-4357) or its Human Resources office (314-362-4900), as well as the Vice Chancellor for Human Resources (314-935-7746). Reports may also be made anonymously to the Washington University Compliance Hotline (314-362-4998). You may also have a responsibility to notify the Missouri Child Abuse and Neglect Hotline at 1-800-392-3738.
Patient care activities pertaining to minors are not within the scope of this policy.
More detailed guidance regarding the application and implementation of this policy is contained in the accompanying frequently asked questions.
The person in charge of a program or activity must register the program with the appropriate University office in sufficient time to meet the applicable portions of this policy.
Programs using University facilities, such as housing or dining services may be required to execute appropriate contracts.
Criminal Background Checks
The individual in charge of the program or activity, whether sponsored by the University or a separate person or entity, will be responsible for ensuring that program staff, paid or unpaid, including but not limited to faculty, staff, students, and volunteers who work directly with minors have successfully completed a criminal background check acceptable to the Office of Human Resources.
Background checks may not be required for individuals whose only contact with minors is in the context of a discrete, occasional event that is conducted entirely in public.
The University may require background checks and/or training for other members of the University community based solely on job responsibities.
All program staff working with minors are required to complete training regarding appropriate supervision and protection of minors before beginning their work with minors.
All members of the Washington University community, including program staff, are expected to be positive role models in their interactions with minors by behaving in a caring, honest, respectful, and responsible manner and must follow these expectations to avoid behaviors that could cause harm or be misinterpreted:
- Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material (or assist in any way to provide access to such material) with minors or in the presence of minors.
- Do not engage or allow minors to engage you in conversations regarding romantic, sexual, or related matters, unless required in your professional capacity, such as resident advisor, mental health counselor, or health care provider.
- Do not engage in any 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. If restraint is necessary to protect a minor or others from harm, all incidents must be documented and disclosed to the person in charge of the program and the minor’s parent/legal guardian.
- Do not use, possess or be under the influence of alcohol or illegal drugs while on duty or when responsible for a minor’s welfare. Do not provide or in any way facilitate a minor’s access to alcohol, illegal or prescription drugs, pornography, or gambling.
- Do not contact minors outside of regular program activities, including through social media, without the express permission of the minor’s parent or guardian.
- Possession of or use of any weapon or explosive device is prohibited.
The individual in charge of each program is required to provide additional guidance regarding appropriate and inappropriate behaviors specific to the program. Examples of behaviors that should be addressed include but are not limited to, being alone with a minor, inviting minors to one’s home, communicating electronically, and transportation of minors.
Report of Alleged or Suspected Abuse or Inappropriate Activity
Every member of the University community has an obligation to immediately report instances or suspected instances of child abuse or inappropriate interactions with minors. Refer to the policy regarding Reporting Suspected Child Abuse for additional guidance on this reporting obligation.
REPORTING SUSPECTED CHILD ABUSE, NEGLECT AND INAPPROPRIATE INTERACTIONS WITH MINORS
The purpose of this policy is to provide guidance to the University community regarding required reporting of suspected child abuse, neglect or inappropriate interactions with minors under University policy and Missouri State Law.
This policy applies to all members of the University community including, but not limited to, faculty, staff, students, employees of basic service contractors and volunteers.
Every member of the University community has an obligation to immediately report instances or suspected instances of child abuse or inappropriate interactions with minors to the Washington University Police Department (314-935-5555) or Washington University School of Medicine Protective Services (314-362-4357), as appropriate, as well as the Vice Chancellor for Human Resources (314-935-7746) or School of Medicine HR Office (314-362-4900). Reports may also be made to the Washington University anonymous Compliance Hotline at (314- 362-4998). In addition, Missouri law requires that certain persons who have reasonable cause to suspect that a child has been or may be subjected to abuse or neglect or observes a child being subject to conditions or circumstances which would reasonably result in abuse or neglect must immediately make a report to the Children’s Division of the Missouri Department of Social Services (http://dss.mo.gov/cd/rptcan.htm). This reporting obligation includes information about suspected abuse, neglect, or inadequate care provided by a parent, legal guardian or custodian/caretaker. Individuals subject to this reporting obligation include, but are not limited to: Certain professionals engaged in the examination, care, treatment or research of persons, health care workers, mental health professionals, social workers, child-care providers, teachers or other school professionals, law enforcement officials, or any other person with responsibility for the care of children. For a complete list of persons subject to this reporting obligation see Mo. Rev. Stat. §210.115. http://www.moga.mo.gov/statutes/C200-299/2100000115.HTM
In addition, under Missouri law, any person who has reasonable cause to suspect child abuse or neglect may make such a report.
The toll free number for the Child Abuse and Neglect Hotline Unit is 1-800-392-3738.
Persons calling from outside Missouri should dial 573-751-3448.
Protection of Rights:
The University will not tolerate retaliation against persons who report suspected child abuse or neglect. Any such retaliation, or encouragement of another to retaliate, is a serious violation of University policy, independent of whether the particular report is substantiated, and could result in discipline, up to and including termination. If you believe you have been subjected to retaliation in violation of this rule, you should contact the Vice Chancellor for Human Resources or School of Medicine HR Office.
Reports of suspected child abuse or neglect must be made in good faith and not out of malice or ill-will. Knowingly making a false or fictitious allegation of child abuse or neglect will be treated as a serious offense and could result in discipline, up to and including termination. If you believe you have been the subject of such a report, you should contact the Vice Chancellor for Human Resources or School of Medicine HR Office.
Under Missouri law, any person making a report to the Department of Social Services in good faith shall have immunity from any civil or criminal liability for making the report.
Any person who knowingly makes a false report or who makes a report in bad faith or with ill intent shall not have immunity.
Policies Regarding Minors at Washington University or Participating in Washington University Programs and Requirements Regarding Reporting Suspected Child Abuse, Neglect, and Inappropriate Interactions with Minors
Frequently Asked Questions
Q #1: Why is the University establishing these new policies?
A: Like many other institutions across the country, Washington University is taking additional steps to protect minors who visit our campuses and to provide training for those faculty, staff, students, and volunteers who interact with minors while on University property or in the course of a program conducted by the University or University group.
Q #2: What does the policy regarding minors require?
A: This policy requires (a) that programs that bring minors to campus be registered with the University; (b) that program leaders, staff, and volunteers who may have close, one-on-one contact with minors participate in training programs; and (c) that these individuals also complete a criminal background check. The policy also includes behavioral expectations for all members of the University community who interact with minors on campus or in University programs or activities.
Q #3: Is the Policy Regarding Minors at Washington University or Participating in Washington University Programs University-wide Policy?
A: Yes. This policy applies to programs and activities offered by all schools and departments of the University, and by non-University groups using University facilities. Programs covered under this policy include, but are not limited to, athletic camps, academic programs, mentorship or internship opportunities, and other programs and activities intended for minors, regardless of the frequency or duration of program activities, and regardless of whether the program involves the housing of minors in University housing. Please review all of these FAQs to determine how the policy applies to a particular program.
Q #4: Are there programs and activities that are not covered by the Policy Regarding Minors at Washington University or Participating in Washington University Programs?
A: This registration, background check and training sections of the policy do not apply to programs exclusively offered to enrolled WUSTL students, even if some of the participants are minors. Those requirements do not apply to events that are open to the general public (such as theater performances, sporting events, or carnivals) where parents or guardians are expected to provide supervision of minors in their care.
Patient care activities involving minors are governed by separate standards and are not within the scope of this policy.
Q #5: What’s the definition of a minor?
A: A minor is considered to be anyone under the age of 18.
Q #6: What about programs that involve interaction with minors off-campus or away from the University?
A: If you are participating in a University sponsored or endorsed program that involves interaction with minors away from campus or other University-owned property, you may be subject to these requirements or to similar requirements imposed by the agency or organization where the activity is being held. Check with your program leader/director if you are unsure.
Q #7: What types of programs need to be registered and how do I complete a registration?
A:Programs that involve repeated interactions with minors, or any opportunity for one-on-one interactions with minors who either come to the University or participate in a University Program must be registered. This does not include short visits to campus where the minor remains under the supervision of a parent, guardian, teacher or other responsible adult.
If you are participating in a student-sponsored program, contact the Community Service Office.
If your program requires minors to stay overnight in University facilities, contact the Summer Conferences and Programs Office. All other programs held on or sponsored by those on the Danforth Campus should contact the Campus Card Services Office.
If the program is sponsored by the School of Medicine or located on the School of Medicine campus, contact the Medical School’s Office of Human Resources.
Q #8: What type of training is required?
A: All program staff and volunteers must complete an online training program. Additional information regarding the online training will be posted on http://card.wustl.edu or, at the School of Medicine, at http://medschoolhr.wustl.edu. The training provides helpful information on preventing and reporting suspected child abuse and steps that should be taken to protect the wellbeing of minors.
Q #9: When is a criminal background check required?
A:Individuals who work with minors in programs that involve repeated interaction with minors and /or who may interact with minors in non-public spaces must successfully complete a criminal background check. Examples of such programs include, but are not limited to:
- Athletic Camps
- Academic programs and workshops
- Individualized internship or mentorship opportunities
- Other settings where one-on-one, unobserved or unsupervised contact with minors can occur
Q #10: How do I get a criminal background check?
A: For those programs on the Danforth Campus, the Campus Card Services Office is responsible for administering a required fingerprint based criminal background check. Contact this office at (314-935-8800) for the required paperwork and to arrange for payment of the required fee.
For programs within the School of Medicine, please contact the Medical School’s Office of Human Resources.
Q #11: Who will have access to any information learned as a result of the criminal background check?
A: Criminal background check information is confidential. Only the Campus Card Services Manager or a representative of the Medical School Office of Human Resources will receive the information unless there is something that may be considered serious enough to prevent participation in a program with minors. In that case, the University’s Vice Chancellor for Human Resources will be consulted and will determine whether or not an individual’s potential interaction with minors should be limited or prohibited. Issues ongoing in the School of Medicine will be reviewed by the HR Office there.
Q #12: What if I already had a criminal background check for another reason?
A: The University requires a fingerprint based criminal background check of state and national criminal records and sexual offender registries. If you have had a criminal background check within the past twelve months and provide a copy of that report to the appropriate office above, and it provides information required by the University, you will not be required to have another criminal background check conducted at this time.
Q #13: Once I have the required criminal background check, will I have to do it again every year?
A: If you have been continuously employed by Washington University or are a continuing student, and are involved in an on-going event or program, a criminal background check will be required every three years. If you are not a Washington University employee or student, then annual criminal background checks are required.
Q #14: When isn’t a criminal background check required?
A: Individuals who work with minors in the context of discrete, occasional programs that do not include one-on-one interaction in private settings or whose only contact with minors will occur in a group setting like a classroom, research lab, etc., do not need to complete a criminal background check. Examples of such programs include, but are not limited to:
- Field days for elementary children who are accompanied by a teacher, parent, or other responsible adult
- Tutoring or advising in group settings
- Mentorship or internship opportunities based in visible clinic or research lab settings
Individuals who interact with minors in the context of a program organized and supervised by another entity do not need to complete a WUSTL criminal background check. Individuals participating in such programs are expected to meet all screening and training requirements imposed by that entity. Examples of such programs include, but are not limited to:
- Programs conducted in local schools
- Children’s Hospital Summer camp
Individuals working at events that are open to the general public, where parents, guardians, or school teachers are expected to provide supervision of minors in their care do not need to complete a criminal background check. Examples of such programs include, but are not limited to:
- Thurtene Carnival
- Sporting events
- Theater or musical performances
- Mini Med School series
Individuals working with minors who are enrolled as full-time Washington University students or students who have accepted the University’s offer of admission by placing a deposit with the University are not required to complete a criminal background check.
In summary, a criminal background check will not be required if:
- The program is a discrete event entirely conducted in public (this excludes programs with overnight stays or use of locker rooms).
- The program involves WUSTL personnel at an off-campus location that is organized and implemented by an outside entity with its own requirements regarding interactions with minors. Then the WU personnel involved must meet the requirements of the outside entity.
- It is a program where the only contact with minors is in a group setting, such as in a classroom, research lab, etc.
- The minors in the program are all WUSTL enrolled students or students who have accepted WUSTL’s offer of admission by placing a deposit with WUSTL.
- The program is open to the general public, where parents, guardians, or other caretakers such as teachers are expected to supervise minors in attendance, such as sporting events, lectures, carnivals, etc.
Q #14: What should I do if I am not sure whether a criminal background check is required?
A: You should evaluate your program in light of the explanations included in this Q&A. If you require additional guidance, contact Vice Chancellor for Human Resources, Legail Chandler at firstname.lastname@example.org (314-935-7746). Questions about activities at the School of Medicine should be directed to Apryle Cotton, Assistant Vice Chancellor for Human Resources, at email@example.com.
Q #15: Are there things I can do to make it less likely for child abuse to occur?
A: Yes, there are several precautions you can take, and these are covered in the required training program. For example, if you must have one-on-one contact with minors, try to do so in a public space rather than in a closed, private environment. Limit your contact with minors to professional interactions. Don’t do anything to compromise your position as an adult role model.
Q #16: Who is required to complete training?
Any program leader, staff or volunteer who is involved in an activity, program or event involving a minor.
Q #17: What if I see or suspect a case of child abuse, neglect or inappropriate interactions with minors?
A: The University’s policy regarding Reporting Suspected Child Abuse, Neglect, and Inappropriate Interactions with Minors states that every member of the University community has an obligation to immediately report instances or suspected instances of child abuse or inappropriate interactions with minors to either the Washington University Police Department (314-935-5514) or the Washington University School of Medicine Protective Services Department (314-362-4357) or its Human Resources office (314-362-4900), as well as the Vice Chancellor for Human Resources (314-935-7746). Reports may also be made anonymously to the Washington University Compliance Hotline (314-362-4998). You may also have a responsibility to notify the Missouri Child Abuse and Neglect Hotline at 1-800-392-3738. The University’s policy can be reviewed at (http://hr.wustl.edu/policies/Pages/PoliciesRegardingMinors.aspx).
If you see something that you think may be inappropriate, or if you are unsure that a minor may be involved, report it, and let the University follow-up.