Washington University in St. Louis (“University”) seeks to conduct its operations and maintain its campuses so as to provide an environment that is safe and supportive of the pursuits of its students, faculty, staff, and visitors and consistent with its mission.
The Youth Protection Policy of Minors (“Policy”) and the referenced procedures have been adopted by the University in order to protect Minors while they are on University premises or when participating in activities sponsored by the University.
This Policy applies to all Programs offered by all schools and departments of the University, recognized student groups, and by non-University organizations on University-owned property, using University facilities, or under the exclusive authority and direction of the University in other locations.
This Policy applies to all operating units of the University including faculty; other salaried and non-salaried appointees, including post-doctoral fellows, research fellows, and teaching assistants; staff, including salaried exempt workers and hourly non-exempt workers; students; volunteers; contractors, including independent contractors, external consultants, workers hired through an outside employment agency, and workers employed on campus through service vendors.
This Policy establishes:
- Minimum standards of conduct for interacting with Minors;
- Registration for Programs that interact with Minors;
- Background check screening requirements for Program Staff;
- Minimum training requirements for Program Administrators and Staff;
- Procedures for reporting, and responding to, suspicions of abuse or neglect of Minors or violations of this Policy
III. Youth Protection Oversight Committee
The Youth Protection Oversight Committee (“Committee”) is charged by the Provost, Executive Vice Chancellor for Administration, and the Vice Chancellor for Student Affairs with overseeing the compliance with and managing issues around the Policy. The Committee is also responsible for developing and delivering training related to Minors on campus, maintaining and implementing standardized forms, guidelines, and processes to support the implementation of the Policy. The Policy and Committee together form the University’s Youth Protection Program.
The work of the Committee is supported by designated Youth Protection Department Representatives. This group consists of representatives from schools and units across the University that administer Programs, and representatives from administrative units that have responsibilities under this Policy. A list of current Committee members and Department Representatives is available on the Youth Protection Program website, youthprotection.wustl.edu.
IV. Exceptions to this Policy
This Policy does not apply to the following:
- students enrolled full-time at the University or students who have accepted the University’s offer of admission by placing a deposit with the University;
- events that are open to the general public where parents, legal guardians, or school/organization chaperones are expected to provide supervision of minors in their care such as sporting events, theater performances, concerts, and carnivals;
- official University admissions-related activities for prospective students, including alumni activities or events, organized through the Department of Undergraduate Admissions and Aid. Members of the University community engaged in these types of admissions-related activities must follow the minimum standards of conduct for interacting with Minors as outlined by this Policy;
- recruitment activities for prospective student-athletes, including alumni activities or events, organized through the Department of Athletics. Members of the University community engaged in these types of recruitment-related activities must follow the minimum standards of conduct for interacting with Minors as outlined by this Policy;
- registered guests of a University student in accordance with established policies of the Department of Residential Life;
- Washington University Nursery School and the Washington University Family Learning Center which are subject to the state licensing process for child care centers;
- patient care activities involving Minors which are governed by separate standards and are not within the scope of this Policy.
V. Minimum Standards of Conduct for Interacting with Minors
All members of the University community are expected to be positive role models in their interactions with Minors by behaving in a caring, honest, respectful, and responsible manner. The University has adopted the following policies for the safety and well-being of Minors consistent with the Purpose set forth above. These guidelines are intended to provide information to prevent abuse or unfounded allegations of abuse; and identify abuse or improper behavior.
- All interactions with Minors should be in an open environment, never behind closed doors or completely out of view of others.
- Communication with Minors, including texting, the use of messaging apps, telephone calls, web conferencing, social media, or emails, is only allowed for the purpose of (i) conducting University business that is required to perform their job duties; (ii) when the content of the communication is protected by law (i.e. FERPA, HIPPA, etc); (iii) in the event of an emergency; or (iv) by Program Administrators or Program Staff who need to communicate with Minors in order to further Program-related objectives. Electronic communication and interaction that is outside the role of professional or volunteer relationship is prohibited. Email communication needs to be made using the individual’s University email or Canvas account. Web conferencing needs to be conducted using the individual’s University Zoom account. To the extent possible, communication via social media (Facebook, Twitter, etc) should be conducted using a University social media account.
- 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.
- Never photograph, film or otherwise record a Minor without the prior written consent of the Minor’s parent or legal guardian.
- Signed written permission from a parent or legal guardian, including a liability waiver and release, is required for a Minor to stay overnight on University premises and to participate in any Program.
- Any Program involving a Minor in a lab setting must adhere to the guidelines set in the Policy on Minors in Laboratories from the Office of Environmental Health and Safety and written permission from the Minor’s parent/legal guardian stating they have reviewed this policy must be on file with the Program.
- All University employees are expected to adhere to the University’s policy on Children in the Workplace included in University Employee Handbooks.
- 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.
- 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 Program Administrator and the Minor’s parent/legal guardian. This Policy extends to Minor-on-Minor behavior.
- Socializing with Minors outside the Program or inviting Minors to one’s home is not permitted unless the Minor’s parent/legal guardian, or an adult designated by the parent/legal guardian, is present.
- 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 provider.
- 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.
- Any member of the University community who witnesses a violation of this Policy are required to immediately report the violation in accordance with procedures including in the incident reporting section of this Policy.
Occasionally, a Program Administrator may find it necessary to provide additional guidance regarding appropriate and inappropriate behaviors specific to the Program. In such case, the Program Administrator should contact the Committee for assistance in formulating additional guidance under this Policy.
VI. Program Registration
Registration for all Programs is required annually and must be completed in sufficient time to meet the applicable portions of this Policy. Registration procedures can be accessed via the Youth Protection Program website, youthprotection.wustl.edu. A registry of Programs is maintained by the Committee.
In addition to Program registration, all non-University organizations wishing to use University owned facilities to host Programs must comply with facility usage requirements including providing certificates of insurance and confirming compliance with all Policy requirements. All contracts between University departments and non-University organizations must be reviewed by General Counsel and certificates of insurance reviewed by Office of Insurance and Risk Management.
Any Program registration defined as an internship, research or shadowing experience, either paid/unpaid, must be reviewed by Human Resources to ensure compliance with city, state, and federal employment laws. Programs that involve lab work may also be subject to review by the Office of Environmental Health and Safety based on guidelines included in the Policy on Minors in Laboratories.
VII. Background Check Screening Requirements
All Program Staff must successfully complete a criminal background check within the 12 months immediately preceding their work with Minors. Criminal records shall include at minimum a criminal background check of state and national criminal records and applicable sex offender registries.
Program Staff whose criminal records check include a conviction, or pending charges, for a sex-related offense or crime against a Minor, or who appear on applicable sex offender registries will not be permitted to participate in any Program subject to this Policy. The offenses that may serve to disqualify someone from working with Minors are not limited to sex offenses and crimes against Minors.
Background check procedures can be accessed via the Youth Protection Program website, youthprotection.wustl.edu. A registry of Program Staff who have undergone criminal record checks is maintained by the Committee.
Screening for contractors or other individuals employed or otherwise affiliated with non-University organizations shall be handled by such non-University organizations. The non-University organization must certify to the University in writing what screens, compliant with the Policy, were completed.
Certain discrete or occasional Programs for which a large number of Program Staff are essential may adopt reasonable measures and safeguards, other than criminal records checks for such individuals, to protect Minors participating in such Programs. The Program Administrator of such a Program should contact the Committee for guidance.
The University may require background checks for other members of the University community based solely on job responsibilities.
VIII. Minimum Training Requirements
All Program Staff are required to complete a training program regarding appropriate supervision and protection of Minors before beginning their work with Minors. Training provides helpful information on preventing and reporting suspected child abuse, steps that should be taken to protect the wellbeing of Minors, duties as mandatory reporters, and appropriate supervision of minors.
Additional information regarding training can be accessed on the Youth Protection Program website, youthprotection.wustl.edu. A registry of Program Staff who have completed training is maintained by the Committee.
Training for Program Staff employed or otherwise affiliated with non-University organizations shall be handled by such non-University organizations. The non-University organization must certify to the University in writing that Program Staff have received training that meets or exceeds the minimum requirements of this Policy.
The University may require training for other members of the University community based solely on job responsibilities.
IX. Incident Reporting
Any member of the University community who witnesses a violation of this Policy are required to immediately report the violation to their supervisor or the Program Administrator in accordance with the Youth Protection Incident Reporting Chart in Appendix A. Reports may also be made to the Washington University anonymous Compliance Hotline (314-362-4998).
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 Department of Human Resources.
Mandatory Reporting of Child Abuse
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=.
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.
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.
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.
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.
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, contact the Vice Chancellor for Human Resources.
Individuals who fail to comply with this Policy and the procedures associated with it may be subject to disciplinary action, up to and including termination of employment from the University.
XI. Key Definitions
- Minor: A Minor, as defined by this Policy, is any person under the age of 18.
- Program: Any organized event or activity that includes participants who are Minors offered by an academic or administrative unit of the University or recognized student organization whether on University-owned property, using University owned or managed facilities, or under the exclusive authority and direction of the University in other locations. This includes virtual and online events or activities. Programs also include events or activities offered by non-University organizations using campus facilities. Programs include, but are not limited to: academic programs, coursework, or camps (both credit and noncredit); athletic camps or clinics; skill-based or enrichment camps and programs; tutoring or mentorship programs; internships (paid or unpaid), shadowing or research experiences; events not open to the general public (either one time or reoccurring).
- Program Administrator: An individual aged 18 or older, designated as the primary contact for the Program and is responsible for Program administration and ensuring compliance with the Policy. The Program Administrator must be a University affiliated individual (student, staff, or faculty).
- Program Staff: Any individual aged 18 or older who works, paid or unpaid, in a Program where the individual may have one-on-one contact with a Minor, or contact with a group of Minors, in a non-public setting without a parent, legal guardian, or school/organization chaperone present.
A full copy of the Youth Protection Policy is available to download here.