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Questions and Answers


General Questions
Scope of Policy
Background Checks
Authorized Adults
Reporting Issues
Questions about the Program
Working with Third Parties/Third Party Organizations

General Questions

Why did the College create these procedures?

Answer:  The College of the Holy Cross is committed to maintaining a safe environment for all members of the College community, including children who take part in our programs, on and off campus. By implementing the policy and procedures found in Policy for the Protection of Children, the College is setting forth specific standards that all departments and employees must follow to create and maintain a safe environment for children in our programs.

What age range of children does this policy apply to?

Answer:  This policy applies to any program in which any participant will be under the age of 18 during the program. Some colleges use the term “minor” when creating such child care policies, but we wanted to emphasize that even though some of our child participants may be older (15, 16, 17 years old), they are still considered to be children under the law and under this policy.

Are there any exceptions to this policy?

Answer:  Yes. This policy does not apply to children (even if under the age of 18) who are enrolled as degree-seeking students at the College. It also does not apply to those College events to which children are brought and supervised by their parents/ guardians or elementary or secondary school teachers, such as field trips, plays film, or intercollegiate athletic games. 

What does this policy require?

Answer: This policy requires that any department or employee that operates a College program with children must (a) review and comply with the policy on Policy for the Protection of Children; (b) ensure that all adults working with children satisfactorily complete a criminal background and registered sex offender check; (c) participate in the mandatory training regarding the program and child safety; (d) report actual or suspected abuse, neglect and injuries; and (e) comply with standards regarding their conduct while working with children in covered programs. We have created a checklist that includes each of these requirements.

What if you have been asked to be a Program Director? 

Answer: Please visit the Program Director Brochure  


Scope of Policy

I am developing a program for children, but it will take place off-campus. Do I need to follow the policy?

Answer: If you are developing a program in your role as a Holy Cross employee, you must follow the policy. The policy applies to any program, activity or service hosted by a College employee or department, regardless of where it takes place.

A local school is bringing their students here to watch a game / program / play. Do I have to follow this policy?

Answer:  The policy does not apply to any events in which children are brought to campus by and will be supervised by their teachers, parents or guardians.

I work for the College and I am bringing my child to campus. Do I have to follow this policy?

Answer: As the parent, you retain sole responsibility for ensuring the safety and well-being of your child. Parents/guardians must accompany minors at all times.  Unaccompanied minors are not permitted on campus or in College buildings. However, this policy does not apply.

Background Checks

Why do we require background checks?

Answer: The sole purpose of the background check is to identify evidence of past conduct that may increase the risk for children of future abuse. The ready availability of criminal history and registered sex offender status information has resulted in a significant shift in national practices within higher education to the point where obtaining this information has become a standard of care.

How much will background checks cost?

Answer:  It will vary, but each background check will cost between $75-$100.

On behalf of the College, I host a charity program for at-risk youth. This is an important resource for the Worcester community, but we don’t have many (or really, any) resources, including the funds to purchase the background checks. Can I waive this requirement?

Answer: No. The background checks are a critical component to ensuring that we vet those individuals who will be working closely with children. We recommend you connect with your Dean, Department Head or Director to see if they can provide some financial support for your program.

I recently had a background check for another program I was involved in. Can you use that background check?

Answer: We can use previous background checks conducted by the College of the Holy Cross that were completed within the last six months. However, you have an obligation to inform the College if you have been arrested or convicted of any misdemeanors or crimes since that last background check.

Do the third parties that use or rent our campus facilities have to have background checks?

Answer:  Yes, or warrant that they have a comparable background check protocol in place (and that the adults involved in the program have successfully completed such checks within a year of the program).


Authorized Adults

I have several volunteers who will be working on my program. Are they considered “Authorized Adults”? 

Answer: Yes. Anyone is an “Authorized Adult” if they will interact with, supervise, chaperone, or otherwise oversee children. This could include, but is not limited to faculty, staff, volunteers, students, interns, employees of temporary employment agencies, and independent contractors/consultants.

I have several kids under the age of 18 who will be working or volunteering in my Program. Are they “Children” or “Authorized Adults”?

Answer: Individuals under the age of 18 cannot serve as Authorized Adults. You may have children of different ages with different levels of responsibility taking part in your program, but anyone under the age of 18 is considered a child.


Reporting Obligations

What am I required to report?

- You must immediately report to the Director of Public Safety at any time you have reasonable cause to believe that a child under the age of 18 is suffering physical or emotional injury from abuse or neglect. This includes, but is not limited to, physical abuse, sexual abuse, sexual exploitation, human trafficking, malnutrition, or physical dependence on a drug at birth.  You may also make a direct report to the Department of Children and Families.  For further information see the policy (PDF) and Massachusetts chapter 119, section 51A.
- You must report any report of or suspicion of sexual abuse of any individual taking part in a College program to the Title IX office (consistent with your obligations under the College's Sexual Misconduct Policy. 
- You must report any crimes that take place during your program to the Department of Public Safety (consistent with our obligations under the Clery Act).
- You must report any injuries beyond those requiring basic first aid to the Department of Risk Management.

What do I do if one of the children in my program mentions previous sexual abuse or neglect?

Answer: If you have any reason to believe a child is in imminent danger, call 9-1-1. If the child is not in immediate danger, do not engage in any investigation or follow-up. But please follow the Mandatory Reporting requirements located in Section II of our policy

Are College students required to make these reports?

Answer: Yes, if they are “Authorized Adults” under this policy.

Can I get in trouble if I fail to report?

Answers: At a minimum, your failure to report these incidents may be a violation of a College policy that could result in your removal from your program and inability to take part in similar programs.  In addition, you could have professional or personal liability by your failure to report incidents of abuse. 

Someone who works in a program with children just told me of a suspected incident of child abuse. What should i do?

Answer: You should ask the person who reported it to you if they notified the Director of Public Safety. If they have not, do so yourself by calling (508) 792-2222. Then notify the Office of General Counsel at (508) 793-3759.


Questions about the Program

One of the children who has registered to take part in our program has not completed the Assumption of Risk and/or the Medical Authorization Form. What should I do?

Answer: We cannot permit students to take part in our programs until they complete these forms, especially the Medical Authorization Form.  This form enables the College to obtain appropriate medical attention for the child in the event we are unable to contact the parents.

Do we need to do anything if we will be providing transportation to the children participating in our program?

Answer:  Yes. First, you should make sure that you have written permission from each participant’s parent/guardian to provide transportation. Second, if you are renting a transportation service, please make sure to refer that contract to Risk Management or the General Counsel as early as possible to give them the opportunity to ensure that contract contains language that will protect the children and the College. Finally, if the program’s Authorized Adults will be driving the children, they must become “Authorized Drivers” through the College’s transportation program. For more information, please see:

What do we do in the event of a campus-wide emergency? 

Answer:  During a campus-wide emergency, you remain responsible for the children taking part in your program. Follow the instructions of the Office of Public Safety. Under the Policy, the Program Director should have also prepared and trained on emergency management procedures, directing how to respond in an emergency. 

What should we do if a child participating in our program engages in disruptive or abusive conduct (through their words, actions or writing)?

Answer:  If you believe anyone is in immediate danger for any reason, contact Public Safety at (508) 793-2222 or 9-1-1. Absent an emergency situation, you should try to separate that child from the other children in a safe and respectful way. Make arrangements to provide care for that child, ensuring that at least two Authorized Adults remain with that child. Then you should contact the parents/guardian and request that they pick the child up. In the event of significant and/or repeated disruption, consider dismissing the child from the program.


 Working with Third Parties / Third Party Organizations

One of our staff members / coaches / employees is using or renting our facilities to host a program that will involve minors. It’s not a Holy Cross program, however. Do they need to follow the policy?

Answer:  Yes. They will most likely be considered a third-party provider and will have to follow Section III of the policy entitled, “Third Party Requirements”.

We are permitting one of our alumnus / donors / board members to utilize our room to host a program that will involve minors. Do they have to follow the policy?

Answer:  Yes. They will most likely be considered a third-party provider and will have to follow Section III of the policy entitled, “Third Party Requirements”.

Some of our Holy Cross students have signed up with a nonprofit agency (or other third party) to work with children through that nonprofit agency. Do they have to comply with the policy?

Answer:  No. This nonprofit agency will maintain and enforce its own safety procedures. They do not have to follow our policy unless they are coming onto property owned or controlled by the College.

We want to partner with this nonprofit agency (or other third party) to bring a program to campus. Do we have to comply with the policy?

Answer:  Yes. In this case, even though we are partnering up to bring this program to campus, it is still our program and all facets of the program will need to comply with our policy and procedures.



We have been contacted by the media, who would like to do a story on our program. Is there anything I need to do? 

Answer. Great! The Vice President for Communication is responsible for the coordination of all media inquiries, including those related to our programs for children. Please contact the Vice President for Communication who will consult, guide and coordinate the appropriate response.

I have additional questions that were not addressed here. Whom may I contact for further advice?

Answer: You may contact Denielle Burl, Chief Risk and Compliance Officer at / (508) 793-2339 or Heather Como, Compliance Coordinator, at / (508) 793-2394.