Policy

The purpose of this policy is to provide for appropriate supervision of children under the age of 18 (referred to herein as “minors” or “youths”) participating in activities and programs taking place on Washington University property, in University owned or managed facilities, or under the exclusive authority and direction of the University in other locations.

A full copy of the Youth Protection Policy is available to download here.

Scope

This policy applies to programs and activities offered by all schools and departments of the University, student groups, and by non-University groups on University-owned property or using University facilities. Programs covered under this policy include, but are not limited to, academic programs, athletic camps, mentorship or internship opportunities, and other programs and activities intended for minors, regardless of the frequency or duration of program activities, and regardless of whether the program involves the housing of minors in University housing.

This Policy does not apply to academic programs exclusively offered to students enrolled full-time as undergraduates at Washington University (or students who have accepted the University’s offer of admission by placing a deposit with the University), even if some of the academic program participants are minors. Additionally, the Policy does not apply to events that are open to the general public (such as theater performances, sporting events, or carnivals) where parents or guardians are expected to provide supervision of minors in their care.  Finally, patient care activities involving minors are governed by separate standards and are not within the scope of this policy.

The University’s Youth Protection Policy is contained in three parts, consisting of (i) safety requirements, (ii) program registration, background check and training requirements, and (iii) reporting requirements.

I. Safety and Well-Being of Minors:

1. One-on-one contact between adults and minor youths is prohibited. In situations requiring a personal conference, the meeting is to be conducted with the knowledge and in view of other adults and/or youths.
2. No one-on-one contact between adults and minor youths includes telephonic/digital communications.
   1. Social Media: Program Staff may not engage with minor youths through private online gaming or privately on any form of social media. For purposes of this policy, the term “social media” means websites and applications that enable users to create and share content of any kind, type or quality (except texting/messaging which is addressed below), or to participate in social networking through online interactions. Nothing herein prohibits the use of social media in public or group interactions.
   2. Texting: Texting or messaging apps (including Snapchat, WeChat, WhatsApp, Facebook Messenger and similar instant messaging apps) may not be utilized to communicate one-on-one with minor youths; provided, however, that such applications may be used for one-on-one communications (i) in the event of an emergency; or (ii) by Program Directors or other University employees (or their delegees) who need to communicate with minor youths in order to perform the essential functions of their jobs.
   3. Emails: Emailing one-on-one with minor youths is prohibited except (i) when the content of the email is protected by law (i.e. – FERPA, HIPAA, etc.); or (ii) by Program Directors or other University employees (or their delegees) who need to communicate with minor youths in order to perform the essential functions of their jobs.  All other email communications with minor youths shall be copied to either a parent or other adult Program Staff member or University employee.
   4. Telephone: Private telephone conversations with minor youths are prohibited except (i) in the event of an emergency; (ii) by Program Directors or other University employees (or their delegees) who have a need to communicate with minor youths in order to perform the essential functions of their jobs.
3. Inappropriate use of smart phones, cameras, imaging, or digital devices is prohibited. The use of any device capable of recording or transmitting visual images in or near showers, restrooms, or other areas where privacy is expected is inappropriate.  Recording visual images in or around such areas is prohibited.
4. No hazing. Hazing and initiations are prohibited and may not be included as part of any university or student sponsored activity or on university property.
5. No bullying/abusive behavior. Engaging in any abusive conduct of any kind toward or in the presence of a minor, including but not limited to verbal abuse, cyberbullying, striking, hitting, punching, poking, spanking, or restraining is prohibited. If restraint is necessary to protect a minor or others from harm, all incidents must be documented and immediately disclosed to the person in charge of the program and the minor’s parent/legal guardia This policy extends to youth-on-youth behavior.
6. Socializing. Socializing with minor program participants outside the program or inviting minors to one’s home is not permitted. Engaging in any sexual activity, making sexual comments, telling sexual jokes, or sharing sexually explicit material (or assist in any way to provide access to such material) with minors or in the presence of minors is prohibited.  Additionally, engaging in or allowing minors to engage you in conversations regarding romantic, sexual, or related matters, is prohibited unless required in your professional capacity, such as resident advisor, mental health counselor, or health care provide
7. Drugs, Alcohol & Tobacco Products; Other Prohibited Behaviors. Using, possessing, or acting/working under the influence of alcohol, tobacco products or illegal drugs while on duty or when responsible for a minor’s welfare is not permitted. Do not provide or in any way facilitate a minor’s access to alcohol, tobacco products or illegal or prescription drugs, pornography, or gambling.

Occasionally, an individual in charge of a program may find it necessary to provide additional guidance regarding appropriate and inappropriate behaviors specific to the program. In such case, the program supervisor should contact the Youth Protection Committee for assistance in formulating additional guidance under this policy.

II. Registration, Background Checks and Training

1. Program Registration
   Any programs or activities that involve interactions with minors who either come to the University or participate in a University programs or activities must be registered. The person in charge of a program or activity must register the program or activity with the appropriate University office in sufficient time to meet the applicable portions of this policy. This Youth Protection Policy applies to all student programs and events involving minors. Student programs involving minors must register with WUGO. Upon registration, a representative from the Youth Protection Committee will contact the event sponsor to discuss the requirements of this policy. If the program is sponsored by the School of Medicine or located on the School of Medicine campus, contact the Office of Human Resources (Employee Relations) at EmployeeRelations@wustl.edu. A designated member of Employee Relations will follow up as necessary. The registration requirement does not pertain to programs/events open to the public where the minor remains under the supervision of a parent, guardian, teacher or other third party adult.
2. Criminal Background Checks
   All individuals who work with minors in University or student programs or activities that involve interaction with minors in spaces that are generally not open to the public must successfully complete a criminal background check. The University requires a fingerprint based criminal background check of state and national criminal records and sexual offender registries. The background check requirement does not pertain to individuals interacting with minors in programs/events open to the public where the minor remains under the supervision of a parent, guardian, teacher or other third party adult. When background checks are required, it is the responsibility of the program supervisor to ensure that all program staff, paid or unpaid, including but not limited to faculty, staff, students, volunteers or other third parties who work directly with minors have successfully completed a criminal background check acceptable to the University’s Office of Human Resources. For those programs on the Danforth Campus, North Campus, West Campus, South Campus and Tyson Research Center, the Campus Card Services Office is responsible for administering the required fingerprint based criminal background check. Contact Campus Card Services (314-935-8800) for the required paperwork and to arrange for payment of the background check fee. For programs within the School of Medicine, contact the Office of Human Resources (Employee Relations) at EmployeeRelations@wustl.edu. A designated member of Employee Relations will follow up as necessary. The University may require background checks and/or training for other members of the University community based solely on job responsibilities.
3. Required Training
   On an annual basis, all program staff and volunteers who work with minors are required to complete a 45-minute online training program regarding appropriate supervision and protection of minors before beginning their work with minors. In addition to the online training program, Program Directors are required to attend a 1-hour classroom training annually. The training provides helpful information on preventing and reporting suspected child abuse and steps that should be taken to protect the wellbeing of minors.

III. Reporting

There are two types of youth protection–related reporting procedures that program staff and volunteers must follow:

• When you witness or suspect any child has been abused or neglected – See “Mandatory Report of Child Abuse” below.
• When you witness a violation of the University’s Youth Protection Policy – See “Reporting Violations of Washington University’s Youth Protection Policy” below.

1. Mandatory Reporting of Child Abuse
   1. Missouri law requires that certain persons who have reasonable cause to suspect that a child has been or may be subjected to abuse or neglect or observes a child being subject to conditions or circumstances which would reasonably result in abuse or neglect immediately make a report to the Children’s Division of the Missouri Department of Social Services. Individuals subject to this reporting obligation include, but are not limited to: Certain professionals engaged in the examination, care, treatment or research of persons; health care workers; mental health professionals; social workers; child-care providers; teachers, principal or other school official; minister; law enforcement officials; or any other person with responsibility for the care of children. For a complete list of persons subject to this reporting obligation and other legal requirements pertaining to mandatory reporting, see Mo. Rev. Stat. §210.115 https://revisor.mo.gov/main/OneSection.aspx?section=210.115&bid=35615&hl=.
   2. The Children’s Division of the Missouri Department of Social Services toll free number for the Child Abuse and Neglect Hotline Unit is 1-800-392-3738. Persons calling from outside Missouri should dial 573-751-3448. Online reporting may also be available for non-emergencies through http://dss.mo.gov/cd/can.htm.
   3. Under Missouri law, any person making a report to the Department of Social Services in good faith shall have immunity from any civil or criminal liability for making the report. Any person who knowingly makes a false report or who makes a report in bad faith or with ill intent shall not have immunity. Mo. Rev. Stat. §210.135.1.
   4. In addition to mandatory reporters specified by Missouri law, any other person who has reasonable cause to suspect child abuse or neglect may make such a report to the Children’s Division of the Missouri Department of Social Services.
   5. Any person reporting an instance or suspected instance of child abuse or neglect to the Children’s Division of the Missouri Department of Social Services should also report the incident to his or her immediate supervisor at the University.
2. Reporting Violations of Washington University’s Youth Protection Policies
   1. Any member of the University community who witnesses a violation of the University’s Youth Protection Policy are required to immediately report the violation to their supervisor or the Program Director in accordance with the Youth Protection Incident Reporting Chart (PDF) (Appendix A). Reports may also be made to the Washington University anonymous Compliance Hotline.
   2. The University will not tolerate retaliation against persons who report suspected child abuse or neglect. Any such retaliation, or encouragement of another to retaliate, is a serious violation of University policy, independent of whether the particular report is substantiated, and could result in discipline, up to and including termination. If you believe you have been subjected to retaliation in violation of this rule, you should contact the Vice Chancellor for Human Resources or School of Medicine HR Office.

REPORTS OF SUSPECTED CHILD ABUSE OR NEGLECT MUST BE MADE IN GOOD FAITH AND NOT OUT OF MALICE OR ILL-WILL. KNOWINGLY MAKING A FALSE OR FICTITIOUS ALLEGATION OF CHILD ABUSE OR NEGLECT IS A CLASS A MISDEMEANOR UNDER MISSOURI LAW.  ADDITIONALLY, A FALSE OR FICTITIOUS ALLEGATION OF CHILD ABUSE OR NEGLECT WILL BE TREATED AS A SERIOUS OFFENSE BY THE UNIVERSITY AND MAY RESULT IN DISCIPLINE, UP TO AND INCLUDING TERMINATION. IF YOU BELIEVE YOU HAVE BEEN THE SUBJECT OF SUCH A REPORT, YOU SHOULD CONTACT THE VICE CHANCELLOR FOR HUMAN RESOURCES OR SCHOOL OF MEDICINE HR OFFICE.