Policy Manual

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Protection of Minors

Policy Statement:

Georgia College & State University (“Georgia College” or “GC”) periodically conducts, sponsors, or hosts programs designed to serve minors who are not enrolled as students, including but not limited to camps, clinics, after school programs and activities.  This Policy sets forth operational requirements to safely conduct and enhance programs serving minors on campus or otherwise affiliated with the University.  Program Administrators, authorized staff and volunteers must be appropriately pre-screen and trained to enhance the protection of minors. 

Definitions:

Authorized Adult/Program Staff/Volunteer: A person, paid or unpaid, who may have direct contact or interact with, treat, supervise, chaperone, and otherwise oversee minors. This definition does not include temporary guest speakers, presenters, or other individuals who have no direct contact with program participants other than short-term activities supervised by program staff; or individuals whose only role is as a participant in the education, services, or programs offered.

Authorized Program:  A program, activity, or service operated or sponsored by Georgia College or by a non-GC entity using Institution Facilities during which agents, employees or volunteers of Georgia College or the non-GC entity are responsible for the care, custody, or control of participating minors, rather than their parents or guardians.  For purposes of these procedures, Authorized Programs do not include events that are open to the general public and that minors may attend at the sole discretion of their parents or guardians; Institutional Review Board (“IRB”) supervised research activities; school field trips, campus visits, or other events where minors remain under the care or control of another entity such as parents, teachers, coaches, or guardians; campus orientations for admitted students and campus tours for potential students; or other programs as may be designated from time-to-time by the appropriate institution official as exempted from these procedures or specific provision(s) of these procedures after approval has been obtained in advance and in writing from the USG Office of Internal Audit and Compliance.

Child Abuse: An injury or pattern of injuries to a minor that is non-accidental.  Child abuse includes, but is not limited to, sexual abuse, physical injury, and neglect.

Direct Contact: Adult employees or volunteers who are reasonably anticipated to have direct interaction with minors through a youth program. Generally, speakers, presenters, exhibitors, registration/logistics volunteers, exam proctors, scorekeepers, clock operators, competition judges, campus tour guides, and admission interviewers/admission events do not have care, custody or control of minors and therefore are not considered to have direct contact with minors.

Institution Facilities: Buildings, structures and improvements of all types, outdoor areas, campus grounds, and athletic venues owned or leased by Georgia College.

Mandatory Reporter: Mandatory reporters are those that are required by law to report suspected abuse or neglect of minors to the appropriate authorities. Under Georgia state law, Georgia College employees and volunteers are considered mandatory reporters. Those whose communications may otherwise be privileged or confidential by law are also considered mandatory reporters and must report child abuse under Georgia state law (e.g., licensed professional and pastoral counselors).

Minor: Any person under the age of 18 and for purposes of these procedures, who is not enrolled as a student at Georgia College and who is not employed at Georgia College.

Program Administrator: The person(s) who has primary and direct operational responsibility for the overall content, management, and execution of an Authorized Program and who serves as the primary point of contact.

Volunteer: A person participating on an unpaid basis and with a set scope of duties in a Georgia College structured volunteer program.

Keywords:

Minors

Protection

 

Reason for the Policy:

The purpose of this Policy is to provide guidelines for those individuals and organizations that interact with minors. This process will ensure all programs are operating in compliance with established guidelines.  Georgia College & State University is committed to providing a safe environment for minors that visit or participate in programs held on campus.

Proposed Outcome:

The Policy seeks to establish guidelines for programs that involve minors.

Applicability of the Policy:

This policy applies to all employees and volunteers involved in programs that involve minors, as well as third-party youth programs hosted on the Georgia College campus. This policy does not apply to:

  • events that are open to the general public and that minors may attend at the sole discretion of their parents or guardians;
  • Institutional Review Board (“IRB”) supervised research activities;
  • school field trips, campus visits, or other events where minors remain under the care or control of another entity such as parents, teachers, coaches, or guardians;
  • campus orientations for admitted students and campus tours for potential students;
  • or other programs as may be designated from time-to-time by the appropriate institution official as exempted from these procedures or specific provision(s) of these procedures after approval has been obtained in advance and in writing from the USG Office of Internal Audit and Compliance.  

Related Policies:

University System of Georgia policy on Programs Serving Minors

 

Procedures:

Guidelines and Responsibilities

Georgia College has established the following administrative procedures that address the safety of minors on campus. These procedures provide the minimum responsibilities of all Authorized Programs. Each Authorized Program may have procedures which are more stringent than the following:

 

Program Registration

Georgia College, through the Academic Affairs Office, maintains a registry of Authorized Programs for minors.  This registry includes pertinent information about each Authorized Program, including the name of the program, the name of the Program Administrator, the dates and times of the program, whether participants reside overnight, and a description of the program.   This information is required on all internal and external programs. Programs are required to register on an annual basis.

Internal (Georgia College managed) programs require additional information to the registry, including the staff to student ratio.  For Georgia College programs, there should never be less than 2 Authorized Adults/Staff/Volunteers per program.  The minimum staff to student ratio is 1 to 18. Specific programs and camps may require smaller ratios based on best practice recommendations for the program type.

External or Third-Party programs who rent or use Georgia College facilities and maintain custody of minors are also required to be listed in the registry.  For the registration of these third-party or external programs, the Program Administrator must attest to use the approved Facility Use Agreement (MOU), as detailed in the Facility Use Agreement section below. 

 

Mandatory Reporting

Any Authorized Adult or Program Staff or other Mandatory Reporter under Georgia law who has reasonable cause to believe that suspected child abuse has occurred, shall immediately report the suspected abuse to the Georgia College Public Safety and the appropriate supervisor or Program Administrator who can take immediate action. (It is further expected that any other Georgia College employee, whether a Mandatory Reporter or not, will also appropriately report suspected child abuse.) Georgia College Public Safety will ensure that the Division of Family and Children Services is notified of the suspected abuse immediately and in no case later than 24 hours after the Authorized Adult or Program Staff (or other reporter) first had reasonable cause to suspect the abuse.

 

Background Investigations & Screening

Georgia College shall conduct background investigations and appropriate screening of all Authorized Adults or Program Staff participating in GC-sponsored Authorized Programs in accordance with USG Human Resources Administrative Practice Manual: Background Investigation. In addition, Georgia College employees working with minors under the age of 13 will be subject to pre-employment and random drug testing. Employees may not begin work until cleared by Human Resources. Each Authorized Adult or Program Staff must undergo a background investigation as specified in the Human Resources Administrative Practice (HRAP) Manual.  Procedures for appropriate background investigations are found in the Human Resources Administrative Practice Manual: Background Investigation. Non-GC entities using Institutional Facilities for Authorized Programs are required to certify in an approved MOU that they have conducted criminal history background checks, including the National Sex Offender Registry, on all employees, volunteers, counselors, chaperones, and others who are reasonably anticipated to have direct contact or interaction with minor program participants. The cost of the screening and background investigations are to be borne by the non-GC entity.

 

Training

The Georgia College Program Administrator is responsible for providing appropriate training to all Authorized Adults and Program Staff. Training topics include, but are not limited to, safety, security, job duties and expectations, codes of conduct, appearance, parent/guardian pick-up policies, emergency procedures, and mandatory reporting requirements and procedures. Each program may add additional training opportunities specific to the individual Authorized Program. Mandated Reporter and Code of Conduct training is included in the annual refresher training course.

 

Code of Conduct

Georgia College has established a code of conduct for Authorized Adults or Program Staff that addresses appropriate behavior and prohibited conduct when interacting with minors. This Code of Conduct is given at the time of hire and reviewed annually in the required Georgia College Annual Refresher Training. Authorized Adults or Program Staff should be positive role models for minors and act in a responsible manner that is consistent with the mission of the institution. A copy of the Code of Conduct form for internal use is located on the website.

 

Facility Use Agreements

At times, Georgia College enters into agreements licensing, leasing, or allowing the use of Institutional Facilities by non-GC entities for Authorized Programs. These agreements include language in a binding written agreement requiring the non-GC entity to comply with these procedures and to identify Authorized Adults or Program Staff (including certification that each has been the subject of an appropriate criminal background check with satisfactory results and that each has been properly trained). In accordance with Board of Regents Policy 6.14.2, the form used for such agreements must be USG-approved.  All agreements will be routed for the necessary approvals according to the current Georgia College policy and procedures for contracts, service agreements, and MOUs.  Legal Affairs will review all agreements to ensure appropriate language is included.

 

Participant Requirements

Parents or legal guardians of minors must submit required forms before minors will be allowed to participate in Authorized Programs. These forms will include (if applicable) but are not limited to a registration form, waivers of liability (including a photo and media release) authorization for child pick-up, medical information, advisement of non-licensed program, participant code of conduct, and an authorization to administer medicine (if applicable).  Approved forms for University use may be found on the Minors on Campus website.

 

Other Requirements

Prior to the operation of any Authorized Program on campus, other requirements must be addressed and documented by the Program Administrator. Such requirements may include, but are not limited to:

  • Appropriate staffing and supervision ratios are maintained with consideration of age and activity;
  • Safety and security planning;
  • Risks associated with specific activities are identified and addressed to include water safety, special events, trips, competitions, etc.  
  • Requirement of constant supervision and maintaining attendance logs;
  • Check-in & check-out procedures are in place;
  • There is a lost child protocol in place;
  • Guest visitation rules are in place;
  • Prescription and other medication procedures are in place;
  • Arrangements for required transportation needs;
  • Housing and food services needs;
  • Response protocols for injuries or illnesses;
  • Response protocols for accusations of misconduct;
  • Insurance requirements;
  • Licensing or exemption therefrom by the applicable government agency(ies).

 

Records Retention

Records associated with the program should be maintained by the Program Administrator for a period of 3 years after the minor reaches 18. A comprehensive listing of the records retention guidelines can be found under Special Program Student Records in the student records section of the records age retention schedule on the USG website.

The Program Administrator will be responsible for maintaining these records. 

 

Review and Compliance

The Campus Coordinator for the Protection of Minors on Campus will make periodic and/or ongoing reviews of programs on campus to ensure the policy and procedures are being followed.  Compliance reviews will be conducted by the Office of Legal Affairs.  There may also be audits/reviews the Georgia Department of Early Care and Learning (DECAL).

 

Non-Compliance

Failure to comply with these procedures may result in disciplinary actions, up to and including termination. In the case of employees, non-compliance may prevent a program from becoming Authorized; and/or may terminate the relationship or take other appropriate actions against non-University entities.

 

Creation Date:  1/23/2017

Revision Date:07/2023

Last Reviewed Date: 3/2023

Responsible Department:  School of Continuing and Professional Studies

Cabinet Approval Date: N/A

Effective Date: 4/1/2019