Revised Policy Proposed: August 31, 2016
Effective Date: September 30, 2016
PROTECTING STUDENT AND NON-STUDENT MINORS ON CAMPUS
Middle Georgia State University (MGA) offers a variety of camps, clinics and activities that bring student and non-student minors onto campus. These include but are not limited to athletic camps, after school programs, science camps, aviation camps, music camps, and other enrichment programs. Moreover, through dual-enrollment including the Georgia Academy of Arts, Mathematics, Engineering & Sciences, the MGA student body includes minors who participate in both academic programs and co-curricular activities, such as Registered Student Organizations and International Programs. These programs are of great educational value and serve to benefit both the institution and the larger community. This policy, which is structured by the guidelines set forth in the Board of Regents policy Protecting Non-Student Minors on Campus, includes minors who are MGA students as well as visiting minors. It seeks to promote the safety and welfare of all minors on our campuses.
This Policy applies broadly to interactions between all minors and institution faculty, staff, students and volunteers in Authorized Programs, as defined herein, on property owned or leased MGA or in MGA sponsored programs at other locations. This policy also establishes requirements for non-MGA entities that operate such programs for minors at MGA campuses or on behalf of the university.
- Authorized Adult or Program Staff: A person, paid or unpaid, who may have direct contact, interact with, treat, supervise, chaperone, or 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 a participant in the education, services, or programs offered.
- Authorized Program: A program, activity, or service operated or sponsored by MGA or by a non-MGA entity using MGA facilities during which agents, employees or volunteers of MGA or non-MGA entity are responsible for the care, custody, or control of participating minors, rather than their parents or guardians. For the purpose of this policy, 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; supervised research activities; or other programs that may be designated from time-to-time by the appropriate institution official as exempted from this policy, or specific provision(s) thereof, after approval has been obtained in advance and in writing from the MGA offices of Auxiliary Services and Risk Management.
- Child Abuse: Physical injury or death inflicted upon a child by a parent or caretaker thereof by other than accidental means; neglect or exploitation of a child by a parent or caretaker thereof; sexual abuse of a child; or sexual exploitation of a child.
- Institutional Facilities: Buildings, structures and improvements of all types, outdoor areas, campus grounds, and athletic venues owned or leased by MGA.
- Mandatory Reporter: A person who is required by Georgia law to report suspected child abuse to the appropriate authorities. Mandatory Reporters include but are not limited to faculty/teachers, administrators, counselors, social workers, psychologists, law enforcement personnel, and other persons who participate in providing care, treatment, education, training, supervision, coaching, counseling, recreational programs or shelter to minors. Mandatory Reporters whose communications would otherwise be legally privileged are generally required under Georgia law to report suspected child abuse.
- Minor: for purposes of this policy means any person under the age of 18, whether or not enrolled as a student of MGA.
- Signs of Childhood Abuse and Neglect: National guidelines for reports and substantiations of child maltreatment are described in Appendix A.
REPORTING HARM TO MINORS
Any Authorized Adult Program Staff or any 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 campus police department and the appropriate supervisor or Program Administrator who can take immediate action. It is further expected that any other MGA employee, whether a Mandatory Reporter or not, will also appropriately report suspected child abuse. MGA 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.
Emergencies: In case of an emergency, one should immediately call the University Police at Main Switchboard 478-934-3002.
All Other Reports of Known or Suspected Abuse or Neglect of Minors: Anyone participating in a University run or affiliated program or activity involving minors or a non-University program or activity operating on campus involving minors who knows, suspects, or receives information indicating that a minor has been abused or neglected, or has other concerns about the safety of minors MUST inform the Office of Risk Management at 478-471-2506 and they will contact appropriate officials/departments they deem necessary.
GUIDELINES & RESPONSIBILITIES
MGA has established administrative policies and procedures that address the safety of minors on campus including:
Code of Conduct: MGA shall develop a code of conduct for Authorized Adults or Program Staff that addresses appropriate behavior and prohibited conduct when interacting with minors, based on Appendix B hereto, no later than May 1, 2017. The Code of Conduct will include a general prohibition against being alone with minors. 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 MGA.
Program Registration: MGA is responsible for establishing and maintaining a registry of Authorized Programs for minors. The registry will include pertinent information about each of the Authorized Programs such as name of its Program Administrator, the number of participants, whether participants reside overnight, and the number of Authorized Adults or Program staff. Programs will be registered annually, at least 30 days in advance of program start date, with the Office of Auxiliary Services.
Program Requirements: The following important considerations must be addressed prior to approval by MGA of an Authorized Program:
- Training requirements;
- Proper screening and background checks for volunteers;
- Appropriate staffing and supervision ratios.
For Camps, ratios of staff to participants will be as required for accreditation by the American Camp Association:
- 5 years & younger 1 staff for each 5 overnight campers and 1 staff for each 6 day campers
- 6–8 years 1:6 for overnight, and 1:8 for day
- 9–14 years 1:8 for overnight and 1:10 for day
- 15–18 years 1:10 for overnight and 1:12 for day
- Safety and security planning;
- Arrangements for transportation;
- Response protocols for injuries or illnesses;
- Response protocols for accusations of misconduct;
- Transportation needs;
- Housing needs;
- Participation requirement forms;
- Insurance requirements; and
- Licensing or exemption therefrom by the applicable government agency(ies).
Participant Requirements: Parents or legal guardians of minors must sign and submit required forms before minors will be allowed to participate in Authorized Programs. These forms may include but are not limited to:
- registration form;
- participation agreement including Code of Conduct and Program Policies and Procedures;
- health information, including short term medication and/or first aid health record log (if applicable);
- emergency contact information;
- authorized pickup information;
- proof of medical insurance and medical release;
- release of claims/waiver of liability; and
- media/photo/video release.
See Appendix C for sample forms developed for Junior Knights summer camp.
Training: MGA shall develop and maintain a training program, and all Authorized Adults or Program Staff must receive appropriate periodic training on safety, security, and mandatory reporting requirements and procedures. Additional training may be required depending upon the role of the staff member or volunteer. MGA employees can visit the Risk Management website training page to get information on training requirements and where to find the training links and other useful pertinent information that meets or exceeds the minimal requirements set by the Board of Regents.
Screening & Background Investigations: MGA shall conduct background investigations and appropriate screening of all Authorized Adults or Program Staff participating in MGA-sponsored Authorized Programs in accordance with the USG Human Resources Administrative Practice Manual: Background Investigation. Each Authorized Adult or Program Staff must undergo a background investigation at least once every three years. Procedures for appropriate background investigations are found in the USG Human Resources Administrative Practice Manual: Background Investigations.
MGA Personnel. Staff and volunteers, including MGA students engaged in experiential learning through Knowledge@Work, will undergo a GCIC statewide background check conducted by University Police at a minimum. If the unit sponsoring or hosting the program wishes to conduct a nationwide check, it will incur the costs of doing so through the MGA Office of Human Resources.
Third Parties. Non-MGA entities using Institutional Facilities for Authorized Programs are required to certify that they have conducted appropriate screening and background investigations and that the results and methods are sufficient to meet institutional standards prior to the start of the Authorized Program. The cost of the screening and background investigations are to be borne by the non-MGA entity.
Facility Use & License Agreements: MGA requires that all non-MGA Authorized Programs enter into binding written Facility Use & License Agreements which include language requiring the non-MGA entity to comply with this policy 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 220.127.116.11, the form used for such agreements must be USG-approved.
CHILDREN OF EMPLOYEES AND STUDENTS
Children are welcome on campus when the purpose of their visit is to attend classes or to participate in activities specifically scheduled and designed for their benefit.
Except as described above, MGA strongly discourages employees and students from bringing their children to the workplace/campus because of the potential disruption of work/schoolwork, health and safety concerns, and liability to the University.
In unique cases where the employee or student has a special need to bring a child to work/campus, they must first get permission from their department head and Human Resources (if an employee) or the classroom professor/Student Affairs (if a student). Employees and students will not be allowed to bring their child on a regular basis for any reason.
Children of employees and students are not allowed in any high risk areas such as: laboratories, shops, studios, mechanical rooms, power plants, garages, hangars, food prep areas, or any other area containing power tools or machinery with exposed moving parts or be allowed to drive or be a passenger in any state owned vehicles including golf carts.
During authorized visits, children must not be left unattended or with other employees, visitors, or students. Employees and students are responsible for all aspects of their child’s behavior, safety and are financially responsible for any damages the child may cause.
The department head or Human Resources may direct an employee, and Student Affairs or University Police may direct a student, to remove the child from the workplace at any time if the department head/HR or Student Affairs/University Police determines that this policy has been violated or that the child’s presence negatively impacts the University interests.
Sanctions for violations of this policy will depend on the circumstances and the nature of the violation, but may include a full range of available University sanctions applicable to the individual including suspension, dismissal, termination, prosecution, and where appropriate, exclusion from campus. The University may also take necessary interim actions before determining whether a violation has occurred. The University may terminate relationships or take other appropriate actions against non-University entities that violate this policy.
APPENDIX A: Signs of Childhood Abuse and Neglect
Nationally, most reports and substantiations of child maltreatment are neglect, followed by physical abuse and sexual abuse.
Neglect occurs when parents or caretakers do not provide proper supervision, control, subsistence, education as required by law, or other care necessary for healthy development.
Physical signs may include:
- Poor hygiene.
- Inappropriate or ill-fitting clothes.
- Being left alone or with people unstable to provide proper supervision.
- Obvious lack of necessary medical treatment.
Behavioral signs may include:
- Chronic hunger or sleepiness.
- Delayed language development.
- Clinging behavior or development of indiscriminate attachments.
- Frequent complaints of feeling unwell.
- Frequent tardiness or absence from school.
Physical Abuse is a non-accidental injury of a child by a parent or caretaker.
Physical signs may include:
- Bruises, welts, or swelling.
- Sprains or broken bones.
- Lacerations or abrasions.
- Bite marks.
- Unexplained or repeated injuries.
Behavioral signs may include:
- Attempts to hide injuries.
- Difficulty sitting or walking.
- Wariness of physical contact with adults.
- Reluctance to go home.
- Depression or self-mutilation.
- Fear of parent(s) or caregiver(s).
Sexual abuse is exploitation of a child for the sexual gratification of an adult or older child.
Physical signs may include:
- Difficulty walking or sitting.
- Torn, stained, or bloody clothing.
- Genital pain or itching.
- Sexually transmitted diseases.
Behavioral signs may include:
- Precocious sexual knowledge or behavior.
- Extremes-hostile and aggressive or fearful and withdrawn.
- Substance abuse.
- Running away.
APPENDIX B: Guidelines for Working with Minors
Those associated with programs or activities involving minors should observe the following “do’s and don’ts” in order to maintain a safe and positive experience for program participants, encourage parental confidence, and avoid mistaken allegations.
- Maintain the highest standards of personal behavior at all times when interacting with minors. Whenever possible, try to have another adult present when you are working with minors in an unsupervised setting.
- Conduct necessary one-on-one interactions with minors in a public environment where you can be observed.
- Listen to and interact with minors and provide appropriate praise and positive reinforcement. Treat all minors in a group consistently and fairly, and with respect and dignity.
- Be friendly with minors within the context of the formal program or activity while maintaining appropriate boundaries.
- Maintain discipline and discourage inappropriate behavior by minors.
- Consult your supervisor if you need help with misbehaving youth.
- Be aware of how your actions and intentions might be perceived and could be misinterpreted. Consult with other adult supervisors or colleagues when you feel uncertain about a situation.
- Don’t spend a significant time alone with one minor away from the group or conduct private interactions with minors in enclosed spaces or behind closed doors.
- Don’t engage in inappropriate touching or have any physical contact with a minor in private locations.
- Don’t use inappropriate language, tell risqué jokes, or make sexually suggestive comments around minors, even if minors themselves are doing so.
- Don’t give personal gifts to, or do special favors for, a minor or do things that may be seen as favoring one minor over others.
- Don’t share personal information with minors about your private life or have informal or purely social contact with minor program participants outside of program activities.
- Don’t strike or hit a minor, or use corporal punishment or other punishment involving physical pain or discomfort.
- Don’t relate to minors as if they were peers, conduct private correspondence or take on the role of “confidant” (outside of a professional counseling relationship).
- Don’t date or become romantically or sexually involved with a minor. Don’t show pornography to minors or involve minors in pornographic activities.
- Don’t email, text, or engage with minors through social networking media unless there is an important educational or programmatic reason to do so and you are communicating consistently to all minors of the program.
APPENDIX C: Sample Forms
Units planning camps or other activities involving minors on campus are encouraged to review, modify as needed, and adopt the following sample documentation collected for the Junior Knights Summer Camp hosted at MGA from June 27 – July 1, 2016, which included:
- Online Volunteer Form for MGA Students and faculty members wanting to participate in some capacity.This form stipulates that all volunteers are subject to a background check. Participating student will receive experiential learning credits (based on the amount of volunteer hours completed); faculty members can add this to their portfolio as service to the institution/community.
- Parents are required to read the Policy and Procedures document, which addresses camp guidelines as well as the weekly meal plan.
- Code of Conduct addresses the issue of acceptable and non-acceptable behavior.
- Detailed online-registration form (created in Google Forms, allowing for reports with full list of registrants), requesting all the pertinent information needed about the camper. This includes location option, dietary needs, medical information, and insurance information. Registration also included several consents for parents/guardians to approve: Photo Release, Liability, and Emergency Medical Treatment.
- If any of the campers is on medication, the parent would have to complete a fillable short-term medication form and submit it the first day of camp.
- The nurse onsite keeps a first aid record log (sample attached) in case we have any medical emergencies.
- Online payment portal created through the MGA Conference Center for parents to pay electronically. Once parents create an account, they can select their options and pay for all at one time.
- Consider adding a webpage that gives the parents an idea of what a typical day looks like.