Policy on Activities Involving Minors

Event Form

Download the Activities Involving Minors Event Form.

1. Purpose and Policy:

   Southern Illinois University Carbondale (“University”), as a part of its public engagement mission, has many activities that include minors. The protection and safety of minors in these activities is a high priority of the University and of the organization administering these activities. The University is committed to providing a safe and enjoyable environment for minors when they are using campus facilities or interacting with campus units and staff. This comprehensive policy is set forth to provide reasonable safeguards and steps to be taken, ensuring activities involving minors are carried out in accordance with all applicable laws, policies, and regulations and afford the greatest protection to minors when they are engaging in activities at the University.

   All faculty, staff, and other members of the University community are expected to be familiar and comply with the requirements of this Policy and any other applicable laws, regulations, policies, or procedures, including but not limited to the Illinois Abused and Neglected Child Reporting Act (ANCRA), 325 ILCS 5/et. seq. Therefore, all faculty, staff, and other members of the University community shall complete the training, reporting, and background check requirements required herein or otherwise by the University prior to engaging in any activity involving minors.
   
   Any non-University organizations and/or entities that operate any activities involving minors on University property shall ensure that the organization or entity and all of their staff, agents, volunteers or other persons comply with the requirements of this Policy. Further, all individuals involved in an activity involving minors shall take appropriate precautions to protect the minors participating in or attending any program or activity at the University.
   
   These definitions do not include the placement of enrolled students receiving academic credit and/or clinical or student teaching requirements, with external entities. Rather, when schools and/or programs place students at external entities for such purposes, students must be informed of their obligation to comply with the external entity’s own policies and procedures, including those regarding background checks and working with minors.
2. Definitions:
   1. Minor:  A child or minor for the purposes of these provisions shall be any person under the age of eighteen (18).  This definition may not capture certain circumstances in which minors are present on campus, and further consideration will be given as to whether they fall within the scope of the policy.
   2. Activities:  The term “activities” includes ongoing or planned events that are designed to include minors such as camps, lessons, workshops, clubs, teams, projects, practices, tours, or open-houses. Activities do not include commercial performances or events open to the general public that are not targeted toward children (such as University athletic competitions, plays, concerts), regularly scheduled classes, or activities designed primarily for enrolled students who are age 17 and above.
   3. Child Abuse and Neglect: Child Abuse and/or Neglect is defined by the Illinois Abused and Neglected Child Reporting Act. That Act provides that the maltreatment of a child under the age of 18 by a parent, immediate family member, any person responsible for the child’s welfare, individual residing in the same home, at the time of the alleged abuse, or any person who came to know the child through an official capacity or position of trust is required to report such maltreatment. Child abuse can be physical abuse, sexual abuse, and/or neglect.
      
      Physical abuse occurs when a parent or a person responsible for the child’s welfare by other than accidental means inflicts, caused to be inflicted, or allowed to be inflicted a physical injury; created a substantial risk of physical injury; commits an act of torture; inflicts excessive corporal punishment; allows the use of alcohol and/or drugs.
      
      Sexual abuse occurs when a parent responsible for the child’s welfare commits or allows to be committed any of the following: transmission of a sexual disease; sexual penetration; sexual molestation; sexual exploitation and/or places a minor at risk of sexual harm. (Abused and Neglected Child Reporting Act)
      
      Neglect occurs when a parent or a person responsible for the child deprives or fails to provide the child with adequate food, clothing, shelter, or needed medical care.
   4. University Facilities: University facilities mean any facilities or property owned or controlled by the University.
3. Procedures:

   1.  A. Duty to Cooperate: All faculty, staff, and other members of the University community shall cooperate with investigations of alleged Child Abuse or Neglect, including but not limited to investigations conducted by the Department of Children and Family Services (DCFS), law enforcement, or other internal or external investigations. Further, all faculty, staff, and other members of the University community shall cooperate with investigations of alleged violations of this policy or any other applicable University policies or procedures.

   2. Training Requirements:
      1. Upon hire, all faculty, staff, and other employees shall complete the approved DCFS training and sign a certificate acknowledging their understanding of reporting responsibilities. Further, all University employees who will be interacting with minors as part of their activities or responsibilities at the University must complete the approved protection of minors training and submit any required documentation as established by the University.
      2. All University contractors, volunteers, or others that will be interacting with minors as part of their activities at the University must complete the approved protection of minors training and submit any required documentation as established by the University.
      3. All faculty, staff, and other employees shall complete any recertification training as required by the ANCRA as required by law or the University. All University employees who interact with minors as part of their activities or responsibilities at the University must complete the approved protection of minors training annually at a minimum and submit any required documentation as established by the University.
   3. Duty to Report: All faculty, staff, or other University employees shall report any suspected crimes, including but not limited to suspected Child Abuse or Neglect as required by ANCRA. These obligations include:
      1. Reporting any suspected child abuse or neglect immediately to the SIUC Department of Public Safety at 911 for emergency situations or at (618) 453-3771.
      2. If faculty, staff, or other University employees have reasonable cause to believe that a minor known to them in their professional or official capacity at the University may be an abused or neglected child, reporting immediately to DCFS. If the report is for a non-life threatening or non-emergency incident of abuse or neglect, an on-line report may be submitted to: https://dcfsonlinereporting.dcfs.illinois.gov. If the reporting party believes the abuse or neglect requires immediate action, the party must call the DCFS Child Abuse and Neglect Hotline at 1-800-25-ABUSE (1-800-252-2873) as soon as abuse or neglect is suspected. In addition to making a report to DCFS, the reporting party must follow any additional directions given by DCFS to complete the report.
      3. If a faculty, staff, or other University employee has reasonable cause to suspect that a minor has died as a result of abuse or neglect, reporting immediately any such suspicion to the appropriate medical examiner or coroner.
      4. University students, contractors, volunteers, or other designated individuals are encouraged to report in the same manner.
4. Requirements for any Activity involving Minors.
   The following provisions apply to all activities and programs serving minors when the activity takes place on University property or is provided as part of a University program or activity.
   
   1. Use of University Property for activities involving minors: Prior to scheduling an activity involving minors, a unit or outside entity shall contact University Events and Outreach to receive required training. Outside entities are also required to complete a facility use agreement with the University. Outside entities are required to comply with this Policy.
   2. Activity Information: Units or outside entities sponsoring activities that include minors and University facilities that are used by activities including minors must maintain an up-to-date list of activities and submit that list to Events and Outreach and the Department of Public Safety. The list shall include each program’s dates, times, locations, attendance (age range and number of participants), an activity contact, any issues or safety measures taken based concerning the presence of minors, and the appropriate course of action to address the minors’ health and safety. The responsible University unit or outside entity must also submit (original) this information to the Director of Public Safety by completing the Activity with Minors Event Form and sending a copy to the University official responsible for compliance with the Policy as identified in Section V. Updates to the information should be provided to the Director of Public Safety and Events and Outreach as soon as possible.
   3. Activity Logistics: Activities that include or serve minors shall create, enforce, and make available policies that address the following areas, if they are applicable to the activity. These policies must be kept on file by the respective department:
      1. Transportation: Including the method(s) for the transportation of minors at the beginning and end of the activity, to and from the activity, and within the activity, whether by parents, guardians, staff, or others. University activities must comply with University policies regarding drivers and vehicles.
      2. Procedures in the event of an emergency, including but not limited to weather, large scale disaster, and first aid.
      3. Appropriate levels of access to and supervision of minors. Proper ratio of supervisors per group size of minors.
      4. Appropriate level of physical contact and communication by personnel with minors based on the age of the minors and the nature of the activities.
      5. Statement to participants about avenues for reporting issues.
      6. Appropriate forms including permission forms, medical contact information, and liability waivers. Forms should be safeguarded and readily available.
   4. Activities including overnight stays by minors shall have the following additional policies:
      1. Identification to be worn by staff members and participants, if appropriate.
      2. Curfews.
      3. A Code of Conduct for participants.
      4. Contractual agreements concerning personnel, facilities, or housing related to activities including minors must include compliance with this policy as a term of the contract. When appropriate, such contracts shall also include an indemnification provision in which Southern Illinois University is held harmless for the acts or omissions of other activity participants or third-party employees or agents.
      5. The program/school coordinator/director or supervisor who oversees the unit hosting or sponsoring the activity with minors is responsible for ensuring that the activities are in compliance with this policy.
   5. Background Checks:
      1. Units or entities sponsoring or hosting activities with minors shall take all reasonable steps to ensure that all individual, including but not limited to faculty, staff, students, volunteers, or other personnel, who will work with minors have been subject to a background check which includes a check of the Illinois sex offender registry prior to the date of the activity. The Illinois Sex Offender Registry is available at https://isp.illinois.gov/Sor/Disclaimer. A record of the sex offender registry check must be maintained by the sponsoring University unit.
      2. If an individual appears on the Illinois sex offender registry, the Unit shall contact the Department of Public Safety to confirm the results. The unit shall contact Human Resources (HR) to complete the review of the information and take all appropriate steps as required by HR. The unit or entity shall not allow program activity participation by faculty, staff, student, volunteer, or other person whose sex offender registry check includes a record of sexually based offenses or crimes against minors.
      3. The University official responsible for compliance with the Policy as identified in Section V, in consultation with the Director of Public Safety, may approve an exception to these requirements if the Unit has adopted appropriate measures and safeguards. This exception process may only be used for one-time events or events that are not operated or sponsored by the University. The Unit shall maintain records of such approvals and the measures and safeguards used.
5. Violations of the Policy/Retaliation prohibition
   The Vice Chancellor or Director of the area through which the activity involving minors are taking place are responsible for ensuring compliance with this Policy. Failure to comply with the provisions of this Policy and/or any other relevant University policies or procedures may result in cancellation of the activity and/or disciplinary action against the employee(s) who failed to comply. Knowingly making false statements or intentionally providing misleading information during an investigation may also result in disciplinary action discipline of the employee(s). Discipline of any employee for a violation of this policy shall be in accordance with University policies or the relevant collective bargaining agreement and may include appropriate sanctions, up to, and including termination of employment. This Policy does not protect against external entities from pursuing other criminal charges or legal remedies.
   
   The University strictly prohibits any retaliation against anyone making a good faith report or complaint under this Policy or who cooperates with any investigation of any report of Child Abuse or Neglect. Retaliation in violation of this prohibition may also result in disciplinary action discipline in accordance with University policies or the relevant collective bargaining agreement, up to, and including termination of employment.