630 Youth Program Protection Policy - OU Administrative Policies and Procedures

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SUBJECT:	YOUTH PROGRAM PROTECTION POLICY
NUMBER:	630
AUTHORIZING BODY:	VICE PRESIDENT FOR FINANCE AND ADMINISTRATION
RESPONSIBLE OFFICE:	OFFICE OF THE CHIEF OF POLICE
DATE ISSUED:	SEPTEMBER 2019
LAST UPDATE:	JUNE 2021
RATIONALE: To provide for the appropriate supervision and protection of Youth participating in programs and events, whether in-person or virtual, offered by or at Oakland University (University).
POLICY: All University employees are responsible for the protection of Youths hosted on campus or participating in events or programs under the direction of the University at other geographic locations. Failure to comply with this policy may lead to disciplinary action and/or the revocation of the opportunity to use university facilities or representing the University.
SCOPE AND APPLICABILITY: This policy applies to all units and programs of the University. All academic programs, camps, athletic camps, pre-college programs, tutoring, the Lowry Center, and similar activities intended for Youths and meet the definition of Youth Programs are within the scope of this policy whether they are limited to daily activities or involve the housing of Youths in residence halls and whether they occur virtually, in University facilities, or other geographic locations. This policy applies to University employees who conduct Youth Programs at University Facilities through a separate business entity such as a corporation, limited liability corporation, partnership or sole proprietorship. This policy does not apply to enrolled University students who are Youths or high school students and Youths covered under Policy 718 “Employment of High School Students and Youths.”
DEFINITIONS: Authorized Adult - Individuals, age 18 and older, who interact with, supervise, chaperone, or otherwise oversee Youths in program activities, or recreational, and/or residential facilities. This includes but is not limited to faculty, staff, volunteers, graduate and undergraduate students, interns, employees of temporary employment agencies, and independent contractors/consultants. This does not include invited speakers or presenters at events where the speaker or presenter will not have any one-on-one Contact with a Youth. One-on-one Contact - Unsupervised interaction between a Youth and any adult who is not the Youth's parent, guardian, school teacher, and/or chaperone. One-on-one contact limitations do not include situations in which more than one Youth or faculty, staff, or Authorized Adult is present. Sponsoring Unit - The academic, non-academic, administrative or auxiliary unit of the University, or entity deemed by the University to be subject to this policy, which offers a Youth Program. Tutoring - A one-to-one or small group activity where a person who is knowledgeable and has expertise in a specific content area or discipline provides guidance, help, or clarification to one or more who do not. University Facilities - Facilities owned by, or under the control of, the University with the exception of the Student Health Center, which will follow separate policies that reflect the unique activities that occur in this location. Youth - A person under the age of eighteen (18) who is not enrolled or accepted for enrollment at the University. Students who are “dually enrolled” in University programs while also enrolled in elementary, middle and/or high school are not included in this policy unless such enrollment includes overnight housing in University facilities. Youth Program - Any class, camp, program, or other activity that includes participation by Youths, whether virtually or in-person. This includes but is not limited to lessons, Lowry Center, workshops, sports camps and/or clinics, academic camps, pre-college programs, conferences, pre-enrollment visits, or other programs and similar activities. The term “Youth Program” does not include (1) private, personal events (e.g. birthday parties, weddings) that occur at University Facilities, or (2) events open to the general public (e.g., intercollegiate athletic events, and concerts), or (3) activities during which parents, guardians, school teachers, and/or chaperones are expected to be responsible for the care, custody, or control of the Youths, or (4) activities which are part of a University student’s academic pursuit, curricula, or University required community engagement activities such as service learning programs, clinical rotations or similar activity. Youth Program Administrator - A University employee who is responsible for the administration of the Youth Program. Youth Protection/Clery Compliance Coordinator – The University employee responsible for overseeing all University policies involving youth protection.
PROCEDURES: Program Registration The University requires that all University-sponsored Youth Programs be registered annually. Youth Program Administrators are responsible for ensuring all information is current for their Youth Program Registration, which is expected to be completed no later than 60 days before the program or event start date. The Registration link can be found at https://forms.oakland.edu. If you have any questions, contact the Youth Protection/Cleary Act Coordinator at (248) 370-3867 or OUPD at (248) 370-3000. Background Checks The University requires that all Authorized Adults be subject to a criminal background check as specified by the University. All background checks must be completed and evaluated annually at the Sponsoring Unit’s expense through the University approved vendor (unless required to be conducted through the State of Michigan) before an Authorized Adult can instruct, supervise, chaperone, oversee or otherwise interact with Youths in Youth Programs. The University requires a minimum of two weeks prior to the commencement of the program to complete background checks. If a criminal record history is found, the Youth Protection/Clery Compliance Coordinator will evaluate and make a determination regarding the ability of an Authorized Adult to participate in a Youth Program. Standards of Behavior Authorized Adults are responsible for familiarizing themselves with this policy, the Youth Protection website and these standards of behavior. The following standards of behavior are expected to be adhered to in order to prevent harm to Youths or behaviors that could 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 Youths. Do not be alone with a Youth. If one-on-one Contact is required, meet in an open, well-illuminated space or room with windows observable by other adults from the Youth Program, unless the one-on-one Contact expressly authorized by the Youth Program Administrator, dean, and department chair or is being undertaken by a healthcare provider. Do not meet with Youths outside of established times for Youth Program activities. Do not invite individual Youths to your home. Any exceptions require written authorization by the Youth Program Administrator and written authorization by a parent/guardian. Do not engage or allow Youths to engage you in romantic or sexual conversations, or related matters, unless required in the role of resident advisors, counselors, or health care providers. Do not engage or communicate with Youths through email, text messages, social networking websites, internet chat rooms, or other forms of social media at any time except and unless there is an educational or programmatic purpose and the content of the communication is consistent with the mission of the Youth Program and the University. Do not touch Youths in a manner that a reasonable person could interpret as inappropriate. Touching should generally only be in the open and in response to the Youth’s needs, for a purpose that is consistent with the Youth Program’s mission and culture, and/or for a clear educational, developmental, or health related (i.e. treatment of an injury) purpose. Any resistance from the Youth should be respected. Do not engage in any abusive conduct of any kind toward, or in the presence of, a Youth, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. If restraint is necessary to protect a Youth or other Youths from harm, all incidents must be documented and disclosed to the Youth Program Administrator, Youth Policy/Clery Compliance Coordinator, and the Youth’s parent/guardian. Do not use, possess or be under the influence of alcohol or illegal drugs while on duty or when responsible for a Youth’s welfare. Possession of or use of any type of weapon or explosive device is prohibited. Report Allegation(s) of Inappropriate Behavior “See Something, Say Something, Do Something.” Every member of the University community has an obligation to immediately report instances or suspected instances of abuse of or inappropriate interactions with Youths to the Youth Protection/Clery Compliance Coordinator, OUPD and to the Youth Program Administrator. Individuals violating this policy will be subject to disciplinary action up to and including expulsion or termination. Responsibilities: Authorized Adults Authorized Adults must adhere to the Standards of Behaviors set forth in this policy. Consent to the background check conducted by University. Complete training as mandated by the University. Youth Program Administrator Coordinate completion of background checks with all Authorized Adults affiliated with the Youth Program in accordance with this policy. Provide Authorized Adults with the OUPD and Youth Protection/Cleary Compliance Coordinator contact information to report potential abuse. Supervise and enforce Standards of Behavior for Authorized Adults as outlined in this policy. Complete training as mandated by the University and ensure all Authorized Adults have completed the training mandated by the University. Youth Protection/Clery Compliance Coordinator Receive, review and confirm registration for all Youth Programs and confirm that background checks are completed in accordance with this policy. Review background checks and make final determination as to whether an Authorized Adult is allowed to take part in a Youth Program. Conduct periodic audits to ensure all Authorized Adults have had a background check and completed training mandated by the University. All Persons Report to Youth Protection/Cleary Compliance Coordinator, OUPD and Youth Program Administrator any instance when child abuse, sexual abuse, or neglect has been witnessed, alleged, or when there is information that a Youth faces a threat of child abuse, sexual abuse, or neglect. Cooperate with OUPD officers investigating alleged abuse or neglect. Training Youth Program Administrators are responsible for ensuring that all required training has been completed prior to commencement of the Youth Program. Training is valid for one year from date of completion and must be renewed annually. Youth Program Administrators should retain all successful training completion emails sent by the system in order to confirm appropriate retraining dates.
RELATED POLICIES AND FORMS: Policy 718: Employment of High School Students and Minors Policy 870 - Software Regulations
APPENDIX: Youth Protection Website: https://www.oakland.edu/youth