The purpose of this policy is to provide for appropriate supervision of children under the age of 18 (referred to herein as “minors” or “youths”) 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.
This policy applies to programs and activities offered by all schools and departments of the University, and by non-University groups on University-owned property or using University facilities. Programs covered under this policy include, but are not limited to, academic programs, athletic camps, 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.
This Policy does not apply to academic programs exclusively offered to students enrolled full-time as undergraduates at Washington University (or students who have accepted the University’s offer of admission by placing a deposit with the University), even if some of the academic program participants are minors. Additionally, the Policy does 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. Finally, patient care activities involving minors are governed by separate standards and are not within the scope of this policy.
All members of the Washington University community, including students, faculty and staff, are expected to be positive role models in their interactions with minors by behaving in a caring, honest, respectful, and responsible manner. The University has adopted the following policies for the safety and well-being of minors on campus. While these policies primarily protect minors, they also serve to protect adult members of the University community who work with minors.
- One-on-one contact between adults and youths is prohibited. In situations requiring a personal conference, the meeting is to be conducted with the knowledge and in view of other adults and/or youths.
- No one-on-one contact between adults and youths includes telephonic/digital communications.
A. Social Media: Program Staff may not engage with minor youths through private online gaming or any form of social media, including but not limited to Instagram, Twitter, Facebook, Tumblr, YouTube, LinkedIn, and any other interactive social media platforms. For purposes of this policy, the term “social media” means websites and applications that enable users to create and share content of any kind, type or quality (except texting which is addressed below), or to participate in social networking through online interactions.
B. Texting: Under no circumstances may texting apps (such as SnapChat, WeChat, WhatsApp, Facebook Messenger and similar instant messaging apps) be utilized to communicate one-on-one with minor youths during the program; provided, however, that such applications may be used to communicate with international students temporarily until such students acquire a U.S. mobile phone or U.S. compatible SIM card. Additionally, texting (SMS/MMS or through an app for international students) one-on-one with minor youths is prohibited except in the event of an emergency.
C. Emails: Emailing one-on-one with minor youths is prohibited except (i) when the content of the email is protected by law (i.e.- FERPA, HIPAA, etc.); (ii) by Program Directors (or their delegee) who need to communicate with minor youths as part of the program application and acceptance process. All other email communications with minor youths shall be copied to either a parent or other adult Program Staff member.
D. Telephone: Private telephone conversations with minor youths are prohibited except (a) in the event of an emergency or (b) by Program Directors (or their delegee) who need to communicate with minor youths (i) as part of the program application and acceptance process; or (ii) to communicate programmatic information that the minor youth needs to know in order to participate in the program.
- Inappropriate use of smart phones, cameras, imaging, or digital devices is prohibited. The use of any device capable of recording or transmitting visual images in or near showers, restrooms, or other areas where privacy is expected is inappropriate. Recording visual images in or around such areas is prohibited.
- No hazing. Hazing and initiations are prohibited and may not be included as part of any university sponsored activity or on university property.
- No bullying/abusive behavior. Engaging in any abusive conduct of any kind toward or in the presence of a minor, including but not limited to verbal abuse, cyberbullying, striking, hitting, punching, poking, spanking, or restraining is prohibited. If restraint is necessary to protect a minor or others from harm, all incidents must be documented and immediately disclosed to the person in charge of the program and the minor’s parent/legal guardian. This policy extends to youth-on-youth behavior.
- Socializing. Socializing with minor program participants outside the program or inviting minors to one’s home is not permitted. Engaging in any sexual activity, making sexual comments, telling sexual jokes, or sharing sexually explicit material (or assist in any way to provide access to such material) with minors or in the presence of minors is prohibited. Additionally, engaging in or allowing minors to engage you in conversations regarding romantic, sexual, or related matters, is prohibited unless required in your professional capacity, such as resident advisor, mental health counselor, or health care provider.
- Drugs, Alcohol & Tobacco Products; Other Prohibited Behaviors. Using, possessing, or acting/working under the influence of alcohol, tobacco products or illegal drugs while on duty or when responsible for a minor’s welfare is not permitted. Do not provide or in any way facilitate a minor’s access to alcohol, tobacco products or illegal or prescription drugs, pornography, or gambling.
Occasionally, an individual in charge of a program may find it necessary to provide additional guidance regarding appropriate and inappropriate behaviors specific to the program. In such case, the program supervisor should contact the Manager of Campus Card Services for assistance in formulating additional guidance under this policy.
Additional Policy Requirements:
1. Program Registration
Any programs that involve 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 with the Campus Card Services Office. 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 Gephardt Institute.
If the program is sponsored by the School of Medicine or located on the School of Medicine campus, contact the Employee Relations Manager in the Medical School’s Office of Human Resources.
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.
2. Criminal Background Checks
All individuals who work with minors in University 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. The University requires a fingerprint based criminal background check of state and national criminal records and sexual offender registries.
It is the responsibility of the program supervisor to ensure that all program staff, paid or unpaid, including but not limited to faculty, staff, students, volunteers or other third parties who work directly with minors have successfully completed a criminal background check acceptable to the University’s Office of Human Resources.
For those programs on the Danforth Campus, North Campus, West Campus, South Campus and Tyson Research Center, the Campus Card Services Office is responsible for administering the required fingerprint based criminal background check. Contact Campus Card Services (314–935–8800) for the required paperwork and to arrange for payment of the background check fee.
For programs within the School of Medicine, contact the Employee Relations Manager in the Medical School’s Office of Human Resources.
The University may require background checks and/or training for other members of the University community based solely on job responsibilities.
3. Required Training
On an annual basis, all program staff and volunteers who work with minors are required to complete a 45-minute online training program regarding appropriate supervision and protection of minors before beginning their work with minors. In addition to the online training program, Program Directors are required to attend a 1-hour classroom training annually. Additional information regarding the training is posted on http://card.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.
There are two types of Youth Protection–related reporting procedures that program staff and volunteers must follow:
- When you witness or suspect any child has been abused or neglected – See “Mandatory Report of Child Abuse” below.
- When you witness a violation of the University’s Youth Protection Policy – See “Reporting Violations of Washington University’s Youth Protection Policy” below.
1. Mandatory Reporting of Child Abuse
- A. 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 immediately make a report to the Children’s Division of the Missouri Department of Social Services (http://dss.mo.gov/cd/can.htm). 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, principal or other school official; minister; 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. §210.115.1. http://www.moga.mo.gov/mostatutes/stathtml/21000001151.HTML.
- B. 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.
- C. 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. Mo. Rev. Stat. §210.135.1.
- D. In addition to mandatory reporters specified by Missouri law, any other person who has reasonable cause to suspect child abuse or neglect may make such a report to the Children’s Division of the Missouri Department of Social Services.
- E. Any person reporting an instance or suspected instance of child abuse or neglect to the Children’s Division of the Missouri Department of Social Services should also report the incident to his or her immediate supervisor at the University.
2. Reporting Violations of Washington University’s Youth Protection Policies
- A. Any member of the University community who witnesses a violation of the University’s Youth Protection Policy are required to immediately report the violation to their supervisor or the Program Director, as appropriate, as well as to the Vice Chancellor for Human Resources or School of Medicine HR Office (as applicable). Reports may also be made to the Washington University anonymous Compliance Hotline.
- B. 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 IS A CLASS A MISDEMEANOR UNDER MISSOURI LAW. ADDITIONALLY, A FALSE OR FICTITIOUS ALLEGATION OF CHILD ABUSE OR NEGLECT WILL BE TREATED AS A SERIOUS OFFENSE BY THE UNIVERSITY AND MAY 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.
Frequently Asked Questions
Q #1: What’s the definition of a minor?
A: A minor is any person under the age of 18.
Q #2: 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 remain subject to these requirements and may also be subject to requirements imposed by the agency or organization where the activity is being held. Check with your program leader/director if you are unsure about how the University policy affects your off-campus interaction with minors.
Q #4: 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 the required fingerprint based criminal background check. Contact the 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 #5: 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 #6: 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 #7: 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 #8: 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, do not need to complete a criminal background check. Examples of such programs include, but are not limited to:
● Field trips 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 where there is no opportunity for one-on-one contact with a minor
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
Q #9: What should I do if I am not sure whether a criminal background check is required?
A: You should evaluate your program and, if you require additional guidance, contact the Manager of Campus Card Services for assistance.
- Campus Card Services Manager: (314) 935-7626
- Gephardt Institute for Civic and Community Engagement: (314) 935-5599
- Employee Relations Manager, WUSM Office of Human Resources: (314) 362-8278
- Washington University Compliance hotline: (314) 362-4998
- Vice Chancellor for Human Resources: (314) 935-7746
- Missouri Children’s Division Child Abuse and Neglect Hotline Unit: (800) 392-3738