Approved by:	The President
History:	Issued	-- June 1, 2017
	Revised	-- August 2, 2017
	Last Reviewed -- July 31, 2019
Related Policies:	Crime Reporting and Response Policy; Drug and Alcohol Abuse Policy (staff and faculty); Sexual Offenses Policy (student); Serving of Alcoholic Beverages on Academic Occasions Policy; Student Alcohol and Other Drug Abuse Policy; Visitation in the Residence Halls Policy
Additional References:	American Camp Association; Camp Documents, Forms, and Training; Standards of Conduct for Interacting with Minors; Protection of Minors Training
Responsible Official:	Associate Vice President and Chief Human Resources Officer tel. (202) 319-5050

I. Policy Statement

 

The Catholic University of America is committed to creating a safe and welcoming environment for all members of its community, including Minors (defined below). This policy establishes guidelines and procedures to promote the protection of Minors.

Compliance with this policy is the responsibility of all University employees (staff and faculty), students, volunteers, contractors, vendors, and other individuals or entities that contract with the University.

Except for the reporting of abuse or neglect in Section III, this policy does not apply to Minors walking through the Campus without entering a University facility or participating in a University sanctioned event or activity. Such individuals enter the University's Campus at their own risk and are not the responsibility of the University.

II. Definitions

 

A. Campus means all buildings, facilities, and other property owned or controlled by the University, including but not limited to lecture halls, residence halls, administrative buildings, parking lots, athletics fields and facilities, and vehicles.

B. Campus Visit means a Minor's temporary presence on Campus as part of a University recruitment event or community outreach activity. Examples include visits by prospective students/student athletes, clinics, and school field trips.

C. Minor means an individual who is under the age of 18 who is not a matriculated University student.

D. Program means a University sanctioned event or activity that provides educational/instructional, recreational, cultural or athletic activities primarily developed to serve Minors, such as but not limited to camps. Programs may be limited to daily activities or may involve overnight housing. Programs may be organized or sponsored by the University or by external entities. The term "Program" does not include:

1. A University sponsored event or activity that requires a Minor to be accompanied by a parent or guardian;
2. A University sponsored event or activity that is open to the general public and which Minors attend at the sole discretion of their parents or guardians;
3. Minors serving as participants in Institutional Review Board approved research studies;
4. A Campus Visit; or
5. An event or activity that is exempted from these requirements by the University Department of Environmental Health and Safety on a case-by-case determination.

III. Reporting Abuse or Neglect

 

A. Reports to the University

 

Every member of the University community or any individual participating in a Program that knows or suspects that a Minor has been abused or neglected, or who has other concerns about the safety of Minors must report that information to the University.

Where to Report

On-Campus: Reports should be made to a University Public Safety officer, to the Public Safety dispatcher in Leahy Hall, or by calling (202) 319-5111. Any of the emergency telephones located throughout campus may be used as well. After notifying DPS, immediately notify the Program sponsor, if any.

Off Campus: Reports should be made to the Metropolitan Police Department (MPD) at 911. After notifying local policy, immediately notify DPS and the Program sponsor, if any.

See the Crime Reporting and Response Policy for further details.

B. Mandatory Reporting to Law Enforcement

The District of Columbia requires that any person over 18 years of age report known or suspected sexual abuse of an individual less than 16 years of age to the D.C. Child and Family Services Agency at tel. (202) 671-7233 or to MPD at 911.

The District of Columbia also requires that persons in certain occupations and professions report known or suspected mental or physical abuse or neglect of an individual under the age of 18 years of age. The professions are called Mandatory Reporters and include but are not limited to the following: teacher/faculty member, athletic coach, physician, psychologist, registered nurse, licensed practical nurse, person involved in the care and treatment of patients, law-enforcement officer, school official, social service worker, day care worker, and mental health professional. Mandatory Reporters must report information of neglect or abuse learned in their official or professional capacity including whether the child is in immediate danger of such abuse or neglect. Reports must be made to the D.C. Child and Family Services Agency at (202) 671-7233 or to the Metropolitan Police Department (MPD) at 911.

Priests are required to report sexual assault or abuse of a minor in accordance with the Archdiocese of Washington Child Protection Policy.

Any employee who is unsure or unclear of the responsibilities or legal obligations under this section should contact the Office of General Counsel for advice at (202) 319-5142.

IV. General Requirements

 

The University reserves the right, at its discretion, to condition, restrict or deny access by Minors to Campus or a Program. Minors are subject to all University policies, must follow directions from authorized University personnel, and may be asked to leave Campus or the event or activity if they are unable or unwilling to comply with such directions.

Parents or guardians are responsible for understanding the risks associated with allowing a Minor onto Campus or permitting a Minor to participate in a Program. The University is not responsible for unsupervised Minors.

A. Supervision

 

Unless a Minor is participating in a Program, Campus Visit, or an Institutional Review Board approved research study, the Minor's parent(s), or guardian(s), (along with the individuals(s) that brought the Minor to Campus, if different) are responsible for supervision of the Minor. Those individuals are responsible for the safety, security, and well-being of the Minor, and are responsible for any injuries to persons or damage to University property caused by the Minor.

B. Prohibited Areas

 

Minors are prohibited from the following areas unless part of a University-sponsored event or activity and are accompanied by a University employee:

1. Laboratories, laboratory preparation areas, and scientific work areas
2. Workshops, maintenance areas, and technical work areas
3. Fitness facilities (e.g. pools, locker rooms, and weight rooms)
4. Residence Halls (unless the Minor lives in a Residence Hall with a parent or guardian)
5. Construction Sites

C. Minors in the Workplace

 

University employees may bring Minor(s) to work in the following limited situations:

1. University-sanctioned event or activity in which the presence of Minors is welcomed, provided that the employee retains supervision of the Minor(s) at all times;
2. If the employee is a campus resident;
3. Brief visits that do not interfere with the employee or his or her colleagues' work, provided that the employee's supervisor approves this visit and the employee supervises the Minor(s) at all times;
4. In the event of an emergency, and if there are no other alternatives, provided that the employee's supervisor approves, the employee supervises the Minor(s) at all times, and the Minor(s) do not interfere with the employee or his or her colleagues' work.

D. Minors in the Classroom

 

In an occasional emergency situation, a Minor child may be brought to class provided that the situation does not interfere with students' educational experiences and only with permission of the instructor (in the case of a student bringing a Minor to class) or Dean (in the event of the instructor bringing a Minor to class). If permission is not granted or if the Minor interferes with the educational experience of University students, the parent or guardian must remove the Minor child.

E. Standards of Conduct for Interacting with Minors

 

All individuals on Campus or participating in a Program must adhere to the University's Standards of Conduct for Interacting with Minors.

F. Alcohol

 

All individuals on Campus or participating in a Program must adhere to the University's alcohol policies: Drug and Alcohol Abuse Policy (staff and faculty); Serving of Alcoholic Beverages on Academic Occasions Policy; Student Alcohol and Other Drug Abuse Policy.

IV. Additional Requirements for Programs

 

The University is committed to the safety and well-being of all Minors who participate in Programs. Accordingly, additional requirements regarding background investigations, trainings, and supervision and interaction with Minors are imposed as set forth below and at Camp Documents and Forms.

A. Forms

 

University-Sponsored or Organized Programs: The Minors and their parents or guardians must submit required University forms before Minors are allowed to participate in a University organized or sponsored Program.

Externally-Sponsored or Organized Programs: External organizers or sponsors of Programs must sign and return a University-approved Agreement before the start of any Program involving Minors.

B. Background Checks

 

University-Sponsored or Organized Programs: Individuals who are responsible for the supervision or care of Minors, or whose duties would require close contact with Minors must successfully complete a criminal background check prior to working with Minors, and every three years thereafter. The cost of the background investigation is the responsibility of the University organizer or sponsor. Background investigations are coordinated through the Office of Human Resources in accordance with the University's Background Investigation Policy.

Individuals with unsatisfactory background check results may be excluded from participation in the Program at the University's discretion.

Externally-Sponsored or Organized Programs: External organizers or sponsors must conduct criminal background checks for their personnel who are responsible for the supervision or care of Minors, or whose duties would require close contact with Minors, and must determine that those individuals have satisfactorily completed a criminal background check before the start of the Program.

Individuals with unsatisfactory background check results must be reported to the University. Those individuals may be excluded from participation in any Program at the University's discretion.

C. Training

 

University-Sponsored or Organized Programs: Individuals who are responsible for the supervision or care of Minors, or whose duties would require close contact with Minors must complete annual mandatory Protecting Minors Training prior to interacting with Minors. Contact EHS-CUA@CUA.EDU for information about mandatory training.

Externally Sponsored or Organized Programs: External organizers or sponsors are responsible for abiding by best practices when selecting and training personnel who will be interacting with or supervising Minors.

D. Supervision and Interaction with Minors

 

University-Sponsored or Organized Programs: When interacting with Minors, all employees and students must adhere to the University's Standards of Conduct for Interacting with Minors and provide sufficient adult supervision for all Minor participants.

Externally-Sponsored or Organized Programs: External organizers or sponsors are required to provide sufficient adult supervision for all Minor participants. Such personnel must:

• Serve as a liaison between University staff and the Minor participants in the event of discipline, noise and/or destructive behavior;
• Accompany and supervise Minor participants at all times as they travel from area to area on campus or off Campus;
• Be responsible for the behavior of Minors, and actively enforce University policy governing behavior in residence halls; and
• Respond to any and all emergencies.

Personnel interacting with Minors must abide by best practices when interacting with Minors.

External organizers or sponsors should use adults in ratios that at a minimum meet a chaperone-to-Minor ratio as recommended by the American Camp Association standards, or in accordance with a successor organization or regulatory body.

VI. Violations

 

Any violation of this policy should be immediately reported to the Department of Public Safety at (202) 319-5111.

Violations of this policy may lead to removal of a Minor from Campus or termination of the event or activity. Violations may also lead to University sanctions that will be forwarded to the Office of Human Resources (for staff), the Office of the Provost (for faculty) or the Office of the Dean of Students (for students), as applicable, for appropriate disciplinary action up to and including termination from the University.

Suspected violation of law may be referred to law enforcement authorities and may result in criminal prosecution.