The University of North Carolina at Greensboro (“the University” or “UNC Greensboro”) is committed to providing a safe and welcoming experience for minors. Faculty, staff, students, student employees, graduate assistants, contractors, and volunteers are therefore expected to hold themselves to the highest standards of conduct when interacting with minors.
This policy establishes requirements for those in the University community who work with any activities or programs for or that include minors (“Youth Programs”), including, but not limited to, camps, conferences, or outreach activities. It is incumbent on both the University community and parents or legal guardians to understand their roles and responsibilities for protecting minors on campus and during their participation in activities sponsored by or affiliated with the University.
Unless excluded below, this policy applies to all Youth Programs associated with UNC Greensboro that serve one or more youth participants, where one or more University faculty, staff, students, student employees, graduate assistants, contractors, or volunteers is knowingly supervising the youth participants or knowingly allowing an external entity to use University facilities for the purpose of operating a Youth Program.
This policy applies to all faculty, staff, students, student employees, graduate assistants, contractors, or volunteers working in Youth Programs.
Youth Programs subject to this policy may be operated on or off campus. The policy applies year-round and is not limited to Youth Programs that operate during the summer months.
Youth Programs subject to this policy include:
- Activities or programs for or that include minors that the University operates on campus or in other University facilities, including, but not limited to overnight camps, instructional programs, day camps, academic camps, and sports camps.
- Activities or programs for or that include minors that are operated, conducted, or organized by external entities but take place on campus or in University facilities, including, but not limited to, facility rentals to external entities.
- Activities or programs for or that include minors that the University operates that do not take place on campus, including, but not limited to, outreach and community service activities.
- Faculty or staff who bring minors to campus for activities or programs occurring outside of a structured activity or program where a parent, legal guardian, or other adult acting in a supervisory role (e.g., coach or teacher) is not present. This could include auditions, lessons, tutoring, tours, or activities during which minors serve as interns or volunteers, often under the mentorship or instruction of a faculty or staff member (e.g., to intern in a laboratory).
- Activities or programs operated, facilitated, or sponsored by student organizations or any other University-affiliated organization that include minors and during which members of the UNCG community are responsible for direct supervision of the minors.
The activities and programs listed in this section are not subject to the registration and compliance requirements outlined in section 4 of this policy. Except for activities and programs falling into categories “a” and “b,” such programs occurring in UNCG facilities should complete a safety registration with the University, which enables the UNC Police Department and the Office of Emergency Management to provide support in emergency situations.
- Undergraduate and graduate academic activities or programs involving a minor participant who is enrolled or who has been accepted for enrollment as a student at the University, including orientation activities.
- Normal operations of licensed childcare facilities or educational programs, such as the UNCG Child Care Education Program, the Moss Street Partnership School, and the Middle College at UNCG. These facilities and programs are subject to state laws and regulations with requirements that supersede this policy and are outside the scope of this policy. However, separate camps or programs sponsored by these programs could be subject to this policy.
- University-affiliated clinical or therapy providers delivering counseling or treatment services to minors, such as the Psychology clinic, the UNCG Speech and Hearing Center or the Vacc Counseling and Consulting Clinic.
- Research programs or grant-funded activities involving minors which are approved by the University’s Institutional Review Board (IRB).
- Student recruitment activities, including open houses and admissions visits and tours, that are scheduled to last no longer than one day and do not include an overnight stay.
- Events on campus open to the general public that minors may also attend (e.g., sporting events, theatre performances, etc.).
- Events or programs offered at or in affiliation with the University during which the minor is accompanied by a parent, legal guardian, coach, or teacher at all times.
3.Definitions and Roles and Responsibilities
- Youth Program: A “Youth Program” is any event, operation, or endeavor that is (1) operated, conducted, or organized by any unit or organization supported by or affiliated with the University or occurring in University facilities; (2) that includes minors; and (3) during which parents or legal guardians are not expected to be responsible for the care, custody, or control of the minors. A Youth Program may be University-Sponsored or sponsored by an External Entity but held on University facilities.
- University-Sponsored: A “University-Sponsored” Youth Program is any Youth Program that: (1) the university solely owns and operates; (2) the university jointly operates with another organization; or (3) the university contracts with another organization to provide. University-Sponsored Youth Programs may or may not take place in University facilities.
- External Entity Activities and Programs: “External Entity Activities or Programs” are Youth Programs that are offered by an individual or entity that is not affiliated with UNC Greensboro but take place in whole or in part in UNCG facilities. The external entity assumes full responsibility for the supervision of the minors.
- Minor: A “minor” is any person who has not reached the age of 18 years.
- Youth Participant: A “Youth Participant” is a minor attending a Youth Program at or affiliated with the University.
- Program Staff: “Program Staff” consists of both paid and unpaid individuals who have direct contact with youth participants, and may include faculty, staff, students, student employees, graduate assistants, contractors, or volunteers. Program staff are responsible for (1) planning, teaching, coordinating, and carrying out activities and/or (2) supervision of youth participants in the activities or programs. The term “Program Staff” does not include individuals who provide services that are limited in nature (such as a lecture or presentation) and who have no direct individual contact with, or oversight of, youth participants.
- The Guide for Operating Youth Programs: The “Guide” contains detailed procedures and guidelines for operating Youth Programs at UNC Greensboro.
- University Facilities: “University Facilities” are facilities owned by or under the control of UNC Greensboro.
- Volunteer: A “volunteer” is any individual working in an unpaid capacity in a Youth Program. Volunteers are subject to the UNCG Volunteer Policy and Procedures.
- University Compliance Director: The “University Compliance Director” is the UNC Greensboro employee responsible for administering this policy. The University Compliance Director provides compliance approval for Youth Programs, certifying that Youth Programs meet the requirements of this policy and the Guide and, therefore, are approved to operate in affiliation with the University or in University facilities.
Aside from the limited exceptions noted herein, all Youth Programs will be subject to this policy and to the more detailed instructions and procedures outlined in the Guide for Operating Youth Programs (“the Guide”). All Program Staff must abide by the requirements outlined in this policy and in the Guide when working in the context of Youth Programs and are expected to comply with all relevant policies, laws, regulations and other applicable directives. Any behavior or contact between Program Staff and youth participants that violates approved program activities, established laws, this policy, the UNCG Minors on Campus: Reporting Policy, or other relevant UNCG or UNC System policies is prohibited. University personnel planning a program or activity that involves minors or may involve minors in any capacity are responsible for contacting University Compliance for review and assessment of specific program requirements.
4.1Requirements for Youth Programs
The following requirements govern participation in Youth Programs. Youth Programs must:
- Register with the University prior to the commencement of any activities involving youth participants.
- Ensure that Program Staff:
- Successfully complete background checks, reference checks, and/or student conduct checks consistent with the requirements of the UNCG Policy on Background Checks and the Guide before they are permitted to work in Youth Programs.
- Complete annual training, including child abuse awareness, prevention, and reporting, pursuant to the UNCG Minors on Campus: Reporting policy and the Guide.
- Adhere to the conduct standards set forth in Section 5 of this policy and the Guide.
- Collect and maintain, at a minimum, parental/legal guardian contact information, emergency contact information, relevant medical history, consent for emergency medical treatment, a liability waiver, and photography or media release for each youth participant in a Youth Program. The Youth Program or its associated University department shall maintain all such documents for no fewer than ten (10) years after receipt.
- Ensure appropriate supervision of youth participants at all times.
- Cooperate with official investigations should they occur.
- Establish and maintain proper controls to account for and protect the resources of the University in the operation of all Youth Programs, including money, equipment, space, supplies, data, and any other items used or accessed in the operation of a Youth Program.
- Maintain the privacy of youth participants’ individually identifiable information consistent with University requirements. Requirements for prevention and mitigation of identity theft risk are outlined in the UNCG Identity Theft Prevention Policy.
- Establish and ensure compliance with medication management procedures to meet the needs of youth participants who need to take medication during the Youth Program, including inhalers, epi-pens, and other rescue medication.
- Report any diagnosis of a communicable disease (as defined in the UNCG Communicable Disease policy) for any youth participant to the University Medical Director per the Communicable Disease policy and public health regulations.
- Obtain insurance coverage in accordance with the requirements outlined in the Guide, unless the requirements are waived by the Office of Institutional Risk Management.
- Maintain records consistent with this policy, the Guide, and the university records retention schedule.
Prior to a Program’s commencement, Youth Programs must register and receive approval from the University annually pursuant to the process outlined in the Guide. To complete the registration process, Youth Programs must provide, at a minimum, information on the person(s) in charge of the Youth Program, the dates and locations of the Youth Program, the dean, Director of Intercollegiate Athletics, or vice chancellor having supervisory authority over the Youth Program, the general nature of the activities to be undertaken, and the administrative requirements associated with the Youth Program consistent with the requirements outlined in section 4.1. Youth Programs may not occur without appropriate University approval as outlined herein. Program registration must be submitted and approved before beginning to advertise or accept youth participant registrations.
4.3External Entity Activities and Programs
In addition to the requirements listed in sections 4.1 and 4.2, external entity activities or programs are required to:
- Establish a contractual relationship with the University for the use of facilities and/or resources;
- Meet the requirements of this policy and the Guide as a term of their contract, including background checks and training of Program Staff; and
- Complete the Youth Programs registration and approval process outlined in the Guide.
4.3.2Requirements for Sponsoring Departments
University departments sponsoring Youth Programs, including external entity programs, are expected to maintain an up-to-date listing of those programs. Such lists should include each program’s dates, times, locations, number of participants, and the contact information for the person(s) in charge of the Youth Program.
All Youth Programs will be held accountable to the following conduct standards. Program Staff shall not, unless required by exigent circumstances:
- Have contact with minors in seclusion. If an activity requires any type of one-to-one interaction (tutoring, private lessons, interviews, etc.) these interactions should take place in a location that is open, observable, and interruptible and may only occur if the youth participant’s parent(s) or legal guardian(s) has been informed, has been given the option to be present, and has provided written consent.
- Engage in abusive conduct of any kind toward, or in the presence of, a minor.
- Strike, hit, administer corporal punishment to, or touch any minor in an inappropriate or illegal manner.
- Be under the influence of, use, or possess, alcohol or illegal drugs at any time while working with minors.
- Provide or knowingly allow minors to possess or consume alcohol, tobacco or illegal drugs. Program Staff also must not provide prescription drugs or any medication to a minor unless specifically authorized in writing by the parent or legal guardian as being required for the minor’s care. In case of emergency, individuals must call 9-1-1.
- Give gifts to minors without the knowledge of their parents or legal guardians.
- Invite minors to a private location or home, accept their invitations for the same, or meet with minors outside of the established program locations or outside of established times without written authorization from the minor’s parent or legal guardian.
- Use profane, vulgar, sexual, or harassing language in the presence of a minor, or otherwise speak in an inappropriate manner in the presence of a minor, including but not limited to, engaging in romantic or sexual conversations with a minor, making inappropriate or sexual comments, and telling inappropriate or sexual jokes.
- Expose minors to inappropriate or sexually explicit materials.
- With the exception of minors’ parents or legal guardians as it relates to their own children, Program Staff shall not: (1) share accommodations with minors; (2) use a personal vehicle to transport a minor; or (3) use personal text, email, internet chat, online games, phone, or other forms of social media to communicate privately with minors.
Youth Programs may be granted an exemption from specific policy requirements based on unusual circumstances. Requests for an exemption must be: (1) communicated annually in writing in advance of the commencement of the Youth Program; (2) approved by the dean, Director of Intercollegiate Athletics, or vice chancellor having supervisory authority over the program; and (3) submitted to and approved by the University Compliance Director. The University Compliance Director will issue a written response to all requests for exemptions.
7.Duty to Report Allegations of Inappropriate Conduct
Consistent with North Carolina law, all persons, including Program Staff, have a duty to immediately report allegations of inappropriate conduct involving minors pursuant to the UNCG Minors on Campus: Reporting Policy. Failure to report such allegations may result in criminal penalties under North Carolina law and University sanctions as outlined in section 9 of this policy.
Any person who makes a good faith report of child abuse or neglect shall not be subjected to retaliation. Further, no one making a good faith report of suspected abuse or neglect will be retaliated against in the terms and conditions of employment or participation in the educational program. Individuals reporting inappropriate conduct or suspected inappropriate conduct in good faith are protected under North Carolina law from criminal and civil liability for making the report.
Youth Programs must discontinue the participation of any employee or volunteer when an allegation of inappropriate conduct has been made against them, until such allegation has been satisfactorily resolved or disciplinary action is taken.
8.Statement of Nondiscrimination
UNCG prohibits unlawful discrimination based on the following protected classes: race/ethnicity, color, genetic information, national origin, religion, sex (including pregnancy and pregnancy related conditions), sexual orientation, gender identity, age, disability, political affiliation, and veteran status.
9.Compliance and Enforcement
Compliance with this policy and the Guide is required as a condition of operating Youth Programs at or affiliated with UNCG. Failure to comply with the requirements of this policy or the requirements further outlined in the Guide can result in the loss of program privileges, including but not limited to, revocation of the opportunity to use university facilities, issuance of a no-trespass notice, and/or suspension or termination of the Youth Program. Other sanctions may include the following:
- Volunteers are subject to reprimand or loss of volunteer status.;
- Students are subject to disciplinary action under the Student Code of Conduct.
- Faculty, staff and student employees are subject to corrective and/or disciplinary action up to and including termination.
- Applicable unit-level sanctions.
- External entities are subject to punitive actions under the terms of their contract agreement, up to and including termination of the contract.
The University Compliance Director is charged with monitoring compliance with this policy and presenting training on best practices. Youth Programs may be subject to announced and unannounced compliance site visits. Findings of noncompliance will be reported to the person in charge of the Youth Program and may also be escalated to the vice chancellor, Director of Intercollegiate Athletics, or dean having supervisory authority over the Youth Program, and to other University officials as needed.
Any suspected violation of approved program guidelines or University policy will be subject to investigation by the appropriate University officials. Colleges, units, and individuals must cooperate with investigations when they occur.
10.2Related Policies and Resources
- UNC Greensboro Guide for Operating Youth Programs
- Youth Programs Website
- Minors on Campus: Reporting Policy
- Minors in Research Laboratories Policy
- Policy on Background Checks
- Volunteer Policy and Procedures
- Facility Use Policy
- Communicable Disease Policy
- Identity Theft Prevention Policy
- The Code and UNC Policy Manual: 1300.10 Policy on Protection of Minors on Campus
10.4Contacts for Additional Information and Reporting
Responsible Administrator: University Compliance Director; firstname.lastname@example.org.
Responsible Executive: Associate Vice Chancellor for Strategy and Policy
|Revision Date||Revision Summary|
|02/10/2020||This policy underwent non-substantive revisions to identify the University Compliance Director as the responsible administrator of the policy. It was also updated to reflect a recent change in state law, which imposes criminal penalties for failure to report allegations of certain crimes against minors.|