Policy for the Protection of Children

About

Effective Date: September 1, 2025

Policy Owner: Associate Vice President for Risk Management and Compliance

Executive Sponsor: Senior Vice President for Administration and Finance

Governing Authority: Bylaws of the College

Regulatory Reference: n/a

Applicability and Scope

1. This Policy applies to all programs, activities, services, or events involving a Child or Children when the College assumes custody and control of Child/Children, whether:
   1. On-campus or off-campus;
   2. Held in-person, virtually, or hybrid; or
   3. Is fully or partially sponsored or affiliated by the College
2. The Policy does NOT apply to:
3. College-sponsored or sanctioned events or activities in which a Child or Children attend under the continuous supervision of their parent, legal guardian, K-12 teacher, or another designated responsible adult who is not acting as College Program staff (e.g., athletic spectators, attendees at public lectures or performances);
4. Regular undergraduate academic programs, summer sessions, or continuing education courses in which an individual under 18 are formally admitted and enrolled as a College student for academic credit;
5. Official pre-enrollment recruitment activities, including but not limited to interviews, campus tours, overnight stays with other students, and sample music lessons, provided that such activities comply with departmental policies, take place in an approved location, and are logged with the relevant director, dean, or department head. [Note: the Department of Risk Management is available to consult on these activities, as desired.]
6. Individuals under the age of 18 who are employed by the College; their employment relationship is governed by College policies, any applicable contract, and applicable laws.
7. Third party organizations hosting events on campus. Any entity seeking to host a program on campus must sign the College’s Facility Use Agreement for Programs with Children. The College reserves the right to impose any requirements or restrictions as deemed necessary for the safety and security of persons on its campus.

C. External Programs

1. This policy distinguishes between College-sponsored programs and activities where the College has direct operational control, and external programs operated by third-party organizations.
2. When College students or employees participate in programs or activities involving minors at an external or third-party site (e.g., a local school, non-profit, or community center), they do so in their individual capacities and not as official agents or representatives of the College.
3. Consequently, the external, third-party organization retains primary and sole responsibility for all aspects of participant oversight. This includes, but is not limited to, conducting appropriate background screening, providing necessary training on child safety, ensuring adequate supervision, and complying with all applicable federal, state, and local laws and safety standards for working with minors.

Definitions

For the purposes of this Policy, the following definitions apply:

• Access: Refers to the opportunity for interaction (physical, virtual/electronic) with Children in connection with a Program covered by this Policy. Individuals who have Access may be subject to screening, training, and documentation requirements based on their role and the nature of the interaction.
• Authorized Adult: Any individual, aged 18 or older, whether paid or unpaid (employee, volunteer, student, contractor), who is designated by a Program and authorized by the College to interact with, supervise, chaperone, or otherwise oversee Children in Program settings. This includes having Direct Contact with Children. Authorized Adults must meet all screening and training requirements outlined in this Policy.
• Camp: Any program called a “camp” or otherwise meeting the definition of a "recreational camp for children" as defined by the Commonwealth of Massachusetts under 105 CMR 430.000 (Minimum Standards for Recreational Camps for Children - State Sanitary Code, Chapter IV).
• Child/Children: Any person under the age of eighteen (18) who is not enrolled, formally accepted for enrollment in credit-bearing academic courses in, or employed by the College. The terms "minor" and "Child/Children" are used interchangeably within this Policy. In addition, for the purposes of this Policy, and any other College policy or procedure that references "Minors" in the context of protection, supervision, transporting, or programming, etc.. the definition provided here shall apply.
• College Facilities: Any building, structure, outdoor space, or property owned, leased, licensed, or otherwise controlled by the College.
• College-Affiliated Program or Activity: Any program or activity in which the College, through its employees, volunteers, students, or designated representatives, is formally designated to provide care, custody, or control of a participating Child or Children through this process. Examples include, but are not limited to, College-sponsored camps, clinics, academic enrichment programs, mentorship activities, and community service initiatives.
• Communication: Includes any communication or interaction in any manner or media, whether currently existing or developed in the future, including, but not limited to, telephone, written correspondence, text messaging, voice notes, social media platforms, in-game chats, private chat functions within virtual meetings, email.
• Direct Contact: Providing care, supervision, guidance, instruction, or control over Child or Children, or having routine interaction with a Child or Children, whether in-person or through virtual means, as part of a Program.
• External Program: An organized program or activity involving a Child or Children that is operated by a third-party organization or entity not sponsored, controlled, or supervised by the College.
  • For External Programs, any Child or Children are typically under the care, custody, and control of the external entity.
  • Screening and training of the external entity's staff and volunteers are the responsibility of that entity according to its own policies.
  • External Programs utilizing College Facilities must comply with College requirements, including executing a Facility Use Agreement that may stipulate adherence to relevant aspects of this Policy.
  • Examples: Programs operated by Big Brothers Big Sisters on campus; off-campus placements for volunteer work in K-12 schools (excluding formal teacher preparation programs).
• Program: Any organized event, activity, camp, clinic, conference, workshop, or service offered or sponsored by the College, or hosted in College Facilities that involves one or more Children who are participating without the direct, continuous supervision of their own parent, legal guardian, or teacher throughout the activity. This includes virtual programs hosted by the College and hybrid programs.
  • Exclusions: This definition excludes large public events where one or more Children attend and are supervised by their parents/guardians (e.g., athletic games, performances, museum visits), field trips supervised by K-12 school personnel, and regular College academic courses enrolling matriculated students under 18.
• Program Director: The College employee (or approved lead volunteer/student for specific programs) who holds primary operational responsibility for a specific Program. Responsibilities include planning, administration, staff/volunteer oversight, ensuring compliance with this Policy, managing logistics, and serving as the primary contact. Each Program must have a designated Program Director who is an Authorized Adult.
• Rule-of-Three: A fundamental safeguarding principle requiring that interactions involving a Child or Children must occur in the presence of at least two Authorized Adults, so that a single Authorized Adult is never left alone with a single Child in an unobservable or private setting.
• With or in the Presence of a Child or Children: Refers to any interaction, communication, conduct, or activity occurring directly with a Child or Children, or in proximity where Children are present and may observe or be affected by the conduct. This applies across all modalities (in-person, virtual, written, etc.).

Policy Statement

The College of the Holy Cross (the “College") is fundamentally committed to providing a safe and supportive environment for all Children participating in College-affiliated or sponsored Programs and activities. This Policy is generally designed to protect the safety and well-being of Children who engage in College Programs as further outlined below.

Its objectives are to:

1. Define requirements, roles, and protocols necessary for the safe operation of Programs involving Children.
2. Foster an institutional culture where the proactive reporting of safety concerns is expected, supported, and managed appropriately.
3. Mandate the registration of all Programs falling within the scope of this Policy.
4. Facilitate appropriate screening, training, and credentialing for all proposed Authorized Adults before interacting with Children.

Procedures

I. Mandated Reporters

These policy obligations are in addition to any responsibilities Authorized Adults may hold under Massachusetts General Laws Chapter 119, Section 51A. However, per College protocol, all reports of suspected physical or sexual abuse or neglect of a Child within Programs must be made to the Department of Public Safety, which serves as the College’s designated reporter to the Department of Children and Families (DCF).

II. Reporting Obligations

• All College employees must report suspected child abuse or neglect in a College Program to the College’s Department of Public Safety.
• Authorized Adults must report:
  1. Suspected child abuse or neglect (physical, sexual, emotional, neglect) to the Department of Public Safety at (508.793.2222) and the Associate Director of Risk Management (508-793-2520)
  2. Actually or potentially harmful and/or sexual interactions between Children to Department of Public Safety (508.793.2222) and the Associate Director of Risk Management (508-793-2520)
  3. Suspected or actual violations of this Policy to the Associate Director of Risk Management (508-793-2520)
  4. Inappropriate or boundary-crossing behavior by an adult towards a Child the Associate Director of Risk Management (508-793-2520)
  5. Any situation causing concern for a Child's safety, even if details are unclear to the Associate Director of Risk Management (508-793-2520)
• Privacy: Reports will be handled with discretion, and information shared only on a need-to-know basis for assessment, investigation, and resolution, consistent with College policy and legal requirements.

III. Addressing Reports under this Policy

The College will respond promptly to all reports received under this Policy including the following:

• Initial Assessment: Upon receipt of a report, the designated College office (DPS for immediate safety/abuse concerns, the Office of Title IX and Equal Opportunity for conduct alleged to violate conduct prohibitions of the Sexual Misconduct Policy or Equal Opportunity Policy, DPS for alleged violations of criminal law, and Risk Management for other concerns under this Policy) will conduct an initial assessment. This includes evaluating the need for immediate action with respect to the safety of individuals involved and the community (e.g., interim restrictions, increased supervision).
• Referral to Law Enforcement/DCF: Reports alleging potential criminal conduct, including child abuse or neglect, will be promptly reported by DPS to appropriate external agencies (law enforcement and/or DCF) as required by law and College protocol.
• Internal Investigation:
  • The College has the right to conduct its own internal investigation into any alleged violation of College policy or applicable law, pursuant to the applicable policy, as appropriate based on the nature of the allegation and the individuals involved.
  • The College's internal investigation may proceed concurrently with external investigations but may be paused if requested by law enforcement. The College will cooperate fully with external agency investigations.
• Violations of this Policy. Any violation of this Policy may result in disciplinary action, up to and including termination of employment, dismissal from the College, revocation of volunteer status, or permanent exclusion from participating in Programs involving Children. Individuals may also face separate criminal charges or civil liability based on external investigations.
• Interim Measures. Risk Management may implement interim measures, at its sole discretion, to protect the interests of any individual or child as deemed necessary. These measures do not constitute a finding of responsibility and are not meant to be punitive.

IV. Standards of Conduct for Interactions with Children

All individuals interacting with a Child or Children must conduct themselves in accordance with the standards set forth in this policy and other College policies. Including, but not limited to, identifying their Program Director, completing screening requirements, using sound judgment, acting professionally, prioritizing child safety, maintaining appropriate boundaries, and serving as positive role models and observing all specific conduct requirements and prohibitions set forth herein. These requirements apply in all settings, including in-person and virtual interactions.

• Program Director Responsibilities: Each Program Director is responsible for Policy compliance in connection with the Program. Key areas include:
  • Program Context: Clearly communicating program goals, schedules, participant demographics (age, needs), and relevant medical/behavioral information.
  • Guidance & Training: Verify that all Authorized Adults have received appropriate training. Provide clear guidance on, at minimum: their roles and responsibilities as an Authorized Adult under this Policy and any Program-specific procedures; Provide their direct contact information and offer themselves as a resource for Authorized Adults for issues that might arise during a Program.
  • Supervision & Safety: Assigning oversight responsibility for all conduct standards listed below, and responsibility for oversight of supervision requirements (including Rule-of-Three), implementing safety protocols (check-in/out, medical administration, emergency plans), training, support and reporting and addressing incidents appropriately.
  • Logistics & Support: Managing daily operations (schedules, meals, transitions, transportation), ensuring facility appropriateness, overseeing restroom/hygiene protocols, and facilitating communication.
• Specific Conduct Standards and Prohibited Behaviors: The following list is not exhaustive but outlines key requirements and prohibitions:
  • One-on-One Contact in an unobservable area:
    • Prohibited: Any interaction between an Authorized Adult and a single Child that occurs without at least one other Authorized Adult, parent, or legal guardian being present and able to observe and hear the interaction. This includes interactions in physical, virtual, or electronic environments. Interactions are considered unobservable if sightlines are obstructed or continuous visual/auditory monitoring is not possible. One-on-One Contact is strictly prohibited unless explicitly permitted under specific, documented exceptions defined within this Policy.
    • Prohibited: Leaving a child or children alone or unsupervised during the program, including during transitions, breaks, or while awaiting pick-up.
    • Required: Adhere to the Rule-of-Three in all settings, physical, electronic, and/or virtual. Breakout rooms must be supervised according to ratio guidelines (see Section IX) and ideally have more than one Child per room.
  • Communication:
    • Prohibited: Engaging in private Communication with a Child outside of official Program channels or without involving another Authorized Adult or parent/guardian.
    • Required: All Communication with a Child or Children must be professional, transparent, Program-related, and conducted through Holy Cross official channels or with appropriate oversight (e.g., copying another Authorized Adult or parent).
    • Exceptions: (1) College students hosting prospective student-athletes may follow specific NCAA/Athletics Department communication protocols.

(2) Athletic coaches may engage in direct communication with recruits/prospective student-athletes using official College platforms (e.g., College email, approved messaging systems like ARMS), provided such communications are logged as required by Athletics Department policy.

• Housing, Hygiene, and Restrooms:
  • Prohibited: Using restrooms, locker rooms, showers, or changing facilities simultaneously with a Child or Children. Undressing, showering, or bathing with or in the presence of a Child or Children. Sharing sleeping accommodations (room, bed, tent) with any Child or Children. (Children 12 and under are prohibited from overnight residential programs).
  • Required: Program Directors must plan for appropriate facility use. Use designated staff/adult restrooms where available. Implement staggered schedules for shared facilities. Utilize group restroom breaks with appropriate supervision (e.g., "buddy system" with multiple Children, supervised by Authorized Adults waiting outside or positioned for auditory/partial visual monitoring without entering fully – e.g., door ajar, foot in hall). Ensure appropriate privacy is respected.
• Personal Boundaries & Interactions:
  • Prohibited: Engaging in grooming behaviors (actions designed to create a sense of dependency or dismantle a Child’s boundaries). Meeting privately with a Child or Children outside of scheduled Program activities. Sharing personal, intimate, or inappropriate information (e.g., relationship details, gossip). Using vulgar language, swearing, or engaging in sexually suggestive conversations or jokes. Giving personal gifts or money to a Child or Children (Program-provided items distributed equitably are acceptable). In virtual settings, directing a Child to end the session immediately if they take the device into a private space (e.g., bathroom, bedroom).
  • Required: Maintain professional demeanor. Interactions should be Program-focused. Respect each Child's personal space and boundaries.
• Abuse, Discipline, and Behavior Management:
  • Prohibited: Engaging in any form of abuse (physical, sexual, emotional, verbal, neglect). Using humiliation, threats, hazing, or ridicule. Employing physical punishment (striking, spanking, hitting, corporal punishment). Depriving basic needs (food, water, restroom access) as discipline. Using inappropriate language (swearing, name-calling).
  • Required: Use positive behavior management techniques appropriate for the age group. Establish clear expectations and rules. Address misbehavior calmly and respectfully. Follow program-specific discipline protocols. Report significant behavioral issues to the Program Director.
• Physical Contact:
  • Prohibited: All unnecessary physical contact. Children cannot consent to physical contact in a Program setting; the responsibility for maintaining appropriate boundaries rests solely with the Authorized Adult. Prohibited contact includes, but is not limited to: tickling, kissing, full-frontal hugging, lap sitting, wrestling, piggyback rides, massaging, inappropriate touching (e.g., bottom, chest, genital areas), and physical restraint unless necessary for safety.
  • Permitted/Required: Physical contact should be minimal, public, initiated for clear safety or instructional purposes, and respectful. Examples: brief celebratory high-five, guiding a hand during an activity, applying a bandage, assisting with safety equipment, athletic skills demonstration. Always explain contact beforehand if possible and be sensitive to a Child's reaction.
• Medical Care / Administration of Medicine
  • Prohibited: Authorized Adults are strictly prohibited from distributing, administering, or supplying any form of medication to minors. This includes, but is not limited to, over-the-counter medications, prescription drugs, controlled substances, herbal supplements, and alcohol.
  • Required: In the event a Child requires medical attention or is in need of medication, Authorized Adults must immediately contact the Department of Public Safety (and/or Sports Medicine, for Athletics-events), which will coordinate appropriate medical care in accordance with the College’s emergency management procedures.
  • Self-Administration: A Child or Children may carry and self-administer inhalers, EpiPens, or insulin if: (a) the child is capable of self-administration; and (b) the parent/guardian has signed the self-administration release form. 
  • Additional Doses: If an attendee requires a second dose of medication (e.g., medication for attention deficit disorder), the parent/guardian must coordinate with the Program Director to return to campus and administer it at a mutually agreed-upon time.
• Transportation:
  • Prohibited: Transporting any Child or Children in personal vehicles or any vehicle without prior, explicit authorization from the Program Director and the Department of Risk Management and Compliance.
• Content and Media:
  • Prohibited: Exposing a Child or Children to sexually explicit, violent, or otherwise inappropriate materials in any manner or media (e.g., images, videos, websites, literature). Assisting a Child or Children to access such materials. Taking photos, videos, or audio recordings of a Child or Children without explicit, prior written consent from the parent/legal guardian via a College-approved release form, specifying the intended use (for Program purposes only). Sending, receiving, creating, or requesting inappropriate images or media involving a Child or Children, whether through existing or future technologies and platforms (including but not limited to phones, computers, social media, cloud services, virtual, weareable technology: such as smart glasses, smart watches, rings or or augmented reality, and artificial intelligence tools. Recording virtual sessions without prior written consent from the parent/guardian of every Child who may appear or be heard in the recording.
  • Required: Ensure all media/content used is age-appropriate and serves a legitimate Program purpose. Obtain necessary consents before any recording or photography.
• Child Release/Pick-Up:
  • Prohibited: Releasing a Child to anyone other than a parent, legal guardian, or pre-authorized individual specified in writing by the parent/guardian or any such releasing without verifying identity.
  • Required: Maintain an accurate, up-to-date list of individuals authorized for pick-up for each Child. Verify identity (e.g., government-issued photo ID) before releasing a Child. Follow Program-specific check-out procedures diligently. Supervision must be continuous and comply with the Rule-of-Three until the child is released in accordance with program procedures and this Policy.

V. Virtual Programming - Additional Safety Precautions

In addition to all other applicable standards, Programs conducted partially or wholly online must implement the following:

• Platform Security: Use only College-approved virtual platforms (e.g., Zoom, Google Meet) unless specific written permission is granted by the Chief Information Officer and the Associate Vice President for Risk Management and Compliance.
• Access Control: Distribute login credentials only to registered participants (Children, parents/guardians) and Authorized Adults. Utilize features like waiting rooms and password protection to prevent unauthorized access.
• Session Management: Disable participant screen sharing by default. Disable private chat features between participants. Consider disabling private chat between participants and hosts unless essential and monitored.
• Identification: Instruct participants to use first name and last initial, or another agreed-upon non-identifying format. Discourage inappropriate or distracting virtual backgrounds.
• Supervision: Ensure at least two Authorized Adults are present in the main virtual room throughout the session. Maintain required staffing ratios (see Section IX) if using breakout rooms, with at least two Children per breakout room whenever possible.
• Registration: Verify all participants are properly registered before admitting them to sessions.

VI. Staffing Ratios

All Programs must meet or exceed the following minimum Authorized Adult-to-Child ratios at all times and across all activities and locations within the Program. The Rule-of-Three must always be maintained, meaning no fewer than two Authorized Adults should be supervising any group, even if the ratio allows for one.

• Minimum Staffing: Every Program must have at least one (1) designated Program Director and a minimum of three (3) Authorized Adults present whenever participants are under the Program's care, regardless of group size (unless group size is exceptionally small and specific alternative supervision plans are approved by Risk Management).

• Planning Considerations: The Department of Risk Management reserves the right to require higher staffing levels for various factors, including but not limited to specific needs (e.g. disabilities) of participants; the nature and risk of activities (e.g. swimming, residential program); physical layout of the area (e.g. multiple rooms or areas on campus); and the need for coverage for transitions and/or emergencies.

VII. Background Checks

The College requires background checks for designated individuals.

• Who Requires Checks: All individuals seeking to serve as Authorized Adults who will have Direct Contact or potential unsupervised Access to Children in Programs.
• Frequency of Required Checks: At a minimum, every three (3) years (or more frequently as required by law).
• Authorized Adults must complete the following, with results satisfactory to the College:
  1. A Massachusetts Criminal Offender Record Information (CORI) check.
  2. A National Sex Offender Registry check (SORI / NSOPW).
  3. A multi-jurisdictional criminal background check that includes county/state of residence and known previous residences.
• Internal Conduct Review: As part of the screening process, Authorized Adults must consent to an internal review of relevant College records. This requires authorizing Human Resources, the Office of Title IX and Equal Opportunity and the Division of Student Development to disclose any documented findings of responsibility for any violation(s) of a College policy, including, but not limited to, the Sexual Misconduct Policy and the Community Standards to the Department of Risk Management for review.
• Timing and Cost: Background checks must be completed and reviewed before an individual begins serving as an Authorized Adult. The cost of required background checks (beyond standard employee pre-hire checks) is the responsibility of the sponsoring Program or department and must be budgeted accordingly.
• Ongoing Checks: The College reserves the right to conduct background checks on any Authorized Adult at any time during their affiliation with a Program.

VII. Arrest or Conviction Notification Requirement

The following notification obligations apply:

• Self-Disclosure Obligation: Individuals serving as Authorized Adults must notify the College’s Department of Public Safety (DPS) within 72 hours of any arrest or criminal conviction occurring within three years after their initial background check.
• Review Process: Upon notification, DPS will immediately consult with the Associate Vice President for Risk Management and Compliance and/or the Office of General Counsel to assess the situation and determine appropriate action, which may include temporary suspension or permanent removal from duties involving Children, pending further review or investigation.

VIII. Training Requirements

Training as described below is mandatory for all Authorized Adults.

• Frequency: Training must be completed annually, unless otherwise specified . Completion is required prior to interacting with Children in a Program.
• Required Components
  1. Training Modules: Successful completion of all College-mandated training modules related to child protection, recognizing and reporting abuse/neglect, and the behavioral expectations outlined in this Policy is required. Specific required courses include:
     • College-specific training on institutional policies and procedures for working with children
     • Protecting Children: Identifying and Reporting Sexual Misconduct
     • Protecting Children: Shine a Light
  2. Documentation: Submission of signed acknowledgments and agreements annually, including:
     • Authorized Adult Code of Conduct Acknowledgment form
     • Background Check Authorization required at a minimum every three years, or more frequently as required by law and returned with satisfactory results.
  3. Program-Specific Training: Program Directors are responsible for providing orientation and ongoing training specific to their Program’s activities, logistics, emergency procedures, and participant population. RM&C may offer supplemental in-person or tailored training sessions upon request.

IX. Program Registration and Compliance

All Programs must be registered and adhere to all requirements of this Policy. Programs may not operate without completing required steps and receiving confirmation of approval.

• College-Affiliated Programs:
  • Registration: Each Program Director must register their Program with the Department of Risk Management and Compliance at least 30 days prior to the Program start date using the designated process. Late registrations risk non-approval.
  • Compliance: Prior to the program beginning, Program Directors must:
    • Identify all potential individuals who will have access to any Child in the Program.
    • Verify that all Authorized Adults have completed required background checks with results satisfactory to the College, training, and documentation before the program begins.
    • Develop and document program-specific operating procedures, safety plans, and emergency protocols consistent with this Policy and as required by applicable law.
    • Maintain records of participant information (including emergency contacts and necessary consents/releases).
    • Adhere to staffing ratios and conduct standards throughout the program.
    • Complete any other requirements outlined in checklists or guidance provided by RM&C.
  • Compliance Verification: RM&C may verify compliance before and during Program operation. Programs found non-compliant may be suspended or terminated.

X. Massachusetts Camp Regulations

Programs that meet the definition of a "recreational camp for children" under 105 CMR 430.000 must comply with all applicable Massachusetts state laws and regulations in addition to this Policy.

• Identification: Program Directors must determine if their program qualifies as a state-regulated camp. For more information, please see this state guide, Does Your Program Qualify as a Recreational Camp?
• Additional regulations: If a Program meets the definition of a camp, the Program Director is also responsible for following the Massachusetts State Camp Regulations, which will require additional time to meet state legal obligations. For information on the most current year’s regulations, please see camp-related resources on the Massachusetts Department of Public Health website: State of MA Camp Overview.
• Strictest Standard Applies: Where College policy and state regulations differ, the stricter standard must be followed. Staffing ratios must meet or exceed both the requirements of this Policy (Section IX) and state camp regulations/American Camp Association (ACA) guidelines, where applicable.

XII. Non-Retaliation

The College’s Whistleblower Policy prohibits retaliation against any individual who, in good faith, reports a concern or suspected violation of this Policy or applicable law, or who participates in an investigation related to such a report. Please see that Policy for more information.

XIII. Record Retention and Audit

Maintaining accurate records is essential for compliance and accountability.

• Responsibility: Each Program Director is responsible for collecting and maintaining required documentation related to their Program, including participant information (rosters, consents, emergency contacts), Authorized Adult records (training completion, signed forms – copies may suffice if originals held centrally), program schedules, safety plans, and incident reports. Copies of key compliance documents (e.g., registration forms, lists of cleared Authorized Adults) must be provided to the Department of Risk Management and Compliance as requested or required by established procedures.
• Retention Period: Program-related records, including participant and Authorized Adult documentation pertinent to this Policy, must be retained by the sponsoring department/Program Director for a period of thirty five (35) years following the conclusion of the Program year, unless a longer period is required by law or other College policies. RM&C will retain oversight and audit-related documentation according to its retention schedule.
• Audit: The Department of Risk Management and Compliance will conduct periodic reviews and audits of Programs to assess compliance with this Policy. Program Directors, Authorized Adults, and sponsoring departments are expected to cooperate fully with audit requests.

Policy Enforcement

Any violation of this Policy may result in disciplinary action, up to and including termination of employment, dismissal from the College, revocation of volunteer status, or permanent exclusion from participating in Programs involving Children. Individuals may also face separate criminal charges or civil liability based on external investigations.

Version History

2019 - Policy for the Protection of Children

Appendix A

Reporting & Review Matrix

Notes

• Authorized Adults are required to report suspected abuse and neglect and violations of the policy—even if they are unsure whether it meets the legal threshold.
• Department of Public Safety (DPS): DPS serves as the College’s designated reporter to the Department of Children and Families and emergency response
• Immediate Safety Concerns: Always reported to DPS, especially if there’s any potential abuse or harm involved, Contact for medical emergency.
• Human Resources will be notified when a complaint involves employee conduct or may result in employee discipline, coaching, or remediation.
• Risk Management Role: Risk Management is involved in reviewing patterns, ensuring policy compliance, and determining whether an individual may continue participation. RM&C will consult with other departments as needed. Risk Management also reviews reports submitted through incident & Accident reporting for handling .
• Title IX and Equal Opportunity: There are mandatory reports of any conduct falling within the definitions of prohibited conduct in the Sexual Misconduct Policy, including, but not limited to alleged sexual misconduct.
• Student Development/ Community Standards will be engaged if the alleged misconduct involves students and may implicate the Student Code.

Appendix B

Resources and Forms