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College-wide Policies

Protection of Minors Policy (Interim)

Responsible office
Finance & Administration
Responsible party
Senior Vice President for Finance and Administration
Last revision
June 2019
Approved by
The Cabinet
Approval date
June 2019
Effective date
July 2019
Last review
June 2019
Additional references
Colorado Law 2-4-401(6) Age of Majority; CRS 19-1-103 Child Abuse & Neglect; CRS 19-3-301 Colorado Child Protection Act; CRS § 19-3-304; CRS 18-8-115 Duty to report a crime; CRS 8-12-101 Colorado Youth Employment Opportunity Act; Fair Labor Standards Act

Scope

All financial and administrative policies involving community members across campus are within the scope of this policy. If there is variance between departmental expectations and the common approach described through college policy, the college will look to the campus community to support the spirit and the objectives of college policy.

Policy

Colorado College is committed to the safety and well-being of minors visiting college facilities and/or participating in college-sponsored and hosted programs. All members of the college community are responsible for reporting abuse and/or neglect of minors involved in college-sponsored and hosted programs.  This policy applies to all college students, faculty, staff, and volunteers; campus visitors; and individuals or organizations engaging in or conducting activities or businesses associated with the college. College “facilities” include the Colorado College campus, all properties owned or leased by Colorado College, and all off-campus locations, including study abroad programs.

This policy does not apply to cases of incidental or intermittent presence of minors such as attending public events on campus, college employee activities in which children may attend, and the Colorado College Children’s Center, which is subject to state licensing requirements. These events and facilities already have procedures in place to ensure the safety and wellbeing of all participants.

Procedures

Expected Conduct

All authorized adults, employees, students, and volunteers who supervise or interact with minors on college property or in connection with college programs, events, or activities are required to conduct themselves appropriately and maintain the highest standards of professionalism, ethics, and personal behavior. Refer to “Conduct Expectation To Work with Minors” addendum.

Responsibility for Children

Colorado College is an institution of higher education. College facilities are generally not an appropriate environment for minors unless they are matriculated students or enrolled in a program specifically designed for minors and supervised by authorized adults with the proper training and credentials. However, the college recognizes that employees, students, and other adults may on occasion bring a minor to campus for a limited period.

Employees, students, and other adults who bring a minor to college facilities maintain the sole responsibility for the safety of the minor, and are accountable for the minor’s safety and behavior and adherence to college policy. Employees, students, and other adults must recognize and respect the need for a professional work and educational environment. Employees, students, and other adults are responsible for injuries or damages sustained to or by a minor with them while on college property or at college-sponsored programs or events.

The college retains the discretion to determine participation of a minor in a college-sponsored, co-sponsored, or hosted program.

Criminal Background Checks for Those Interacting with Minors

Faculty, staff, students, and volunteers who participate in college-sponsored or hosted/affiliated/third-party programs or activities directly involving minors must have a background check conducted and renewed every four (4) years. Background checks will be administered and reviewed by Human Resources.

COLLEGE PROGRAMS, EVENTS, AND ACTIVITIES

College-Sponsored Events and Activities

Colorado College sponsors a number of events in the academic units, performing arts, athletics, and other areas that are open to minors. In order to ensure their safety and that of other guests, the college requires that the guardian agree to adhere to established event guidelines and to the following conditions for the minor’s participation:

  • Colorado College is not responsible for the supervision of a minor who attends a campus event unless the event sponsor states in writing that supervision by college employees will be provided.
  • Minors must remain in the designated area where the event is located.
  • The minor’s guardian is responsible for the minor's behavior and actions and for any damages caused by the minor.

College-Sponsored or Co-Sponsored Programs

Colorado College sponsors programs specifically designed for minors. The college requires that all authorized adults interacting with minors in these programs complete the college training and any other program requirements. All programs must comply with the safety practices stated below. Any person who observes any action or inaction in violation of these practices should report the incident immediately to the program leader or their supervisor or, as necessary, to Campus Safety.

  • All program employees, students, and volunteers must follow instructions of the program and maintain professional boundaries at all times when interacting with minors in the program.
  • All program employees, students, and volunteers must complete the college-required training course. The program leader is responsible for ensuring all program employees and volunteers have completed it.
  • Guardians of minors in college-sponsored or co-sponsored programs must sign release waivers before a minor may participate in the program. Comparable releases from participating organizations may be accepted.
  • The program leader will determine and enforce the appropriate ratio of employees to minors in the program. In all cases, any ratios mandated by law must be followed.
  • Program employees must inform another program employee when they are taking minors out of the program room or area for any reason.
  • Except in an emergency or other urgent circumstances, no minor should ever be left alone or only with a single employee, student, or volunteer.
  • Program employees may take or share photographs or videos of minors in the program only for program-related purposes and only if the minor's guardian has signed an authorization form permitting photographs or videos to be taken of the minor and shared.
  • Program leaders, supervisors, or designee, must ensure that all appropriate forms, including permission forms, medical and contact information, and liability waivers, are on file and available.

Programs and Events on Campus Sponsored by Other Entities

Colorado College approves selected outside individuals and entities to use college facilities for programs/events specifically designed for or including minors. Through the agreement process, the college requires the sponsoring entity to maintain specified insurance coverage, including sexual abuse/molestation liability insurance coverage. Program sponsors will be responsible for ensuring that the college-approved facility use agreement, verification of required insurance coverage, and other necessary documents have been completed by the outside entity and are on file with the appropriate college office.

OFF-CAMPUS COLLEGE- SPONSORED AND CO-SPONSORED PROGRAMS AND TRIPS

General

Employees and students engage in off-campus activities involving minors through Colorado College's community-based learning, community engagement, internships, field trips, student teaching, and other programs. All college employees and volunteers in these programs will be required to comply with college policies in the same manner and extent to programs conducted on campus. If the off-campus program host or sponsor organization has additional requirements, the college participants will be responsible for knowing and complying with those requirements as well.

Sponsored Trips and Study Abroad

Students and employees must consult with the Center for Global Education and Field Study in advance regarding their child(ren)’s participation in trips or other activities associated with sponsored trips or study abroad programs and must comply with established sponsored trips and study abroad procedures. All college participants in such programs will be required to comply with college policies in the same manner and extent to programs conducted on campus. The college has the discretion to determine if participation by a minor in such a program is appropriate.

ACADEMICS, RESIDENTIAL LIFE, AND EMPLOYMENT

Minor Students in Classes and Labs

Some students in college classes or laboratories may be minors. Minors who take courses and/or participate in college programs are expected to follow course requirements and comply with the college’s standards, policies, and behavioral expectations. Minors and their guardians should be aware that college courses are not specifically designed for minors and may include activities, conversations, or topics not normally presented to minors. Pre-College Summer Program informs all faculty who have minors in their classes as part of the acceptance process and faculty have the opportunity to deny the minors’ participation in their course. Faculty who have questions about the participation of minors in their classes or out-of-classroom events and programs should contact the program leader or sponsoring department.

Minors Who Live on Campus

Because some matriculated students start school before they have attained the age of 18, Colorado College sometimes has minors living in residence halls. Minors living in residence halls are expected to follow the same rules as all other college students. Before minors move into a residence hall, the residential hall staff will be informed of the student’s status as a minor and birth date. The residential hall staff shall be mindful of the minor status and consider whether any special measures or precautions are necessary with respect to such students.

Employment of Minors

Occasionally, Colorado College may hire a minor to fill an employment position or student work position. The Student Financial Aid Office authorizes the hire of student workers while the Human Resources Office authorizes the hiring of all non-student employees. The college complies with applicable law with respect to the employment of minors. In the event the college hires a minor, the Human Resources Office will inform the supervisor that the employee is under age 18 and will assist the supervisor in determining whether any particular steps or limitations are necessary because of the employee's age. Minors are not to be assigned to work alone or without close supervision without written approval of the Human Resources Office.

DAY AND OVERNIGHT VISITS INVOLVING MINORS

General Rules

Students residing in college-owned housing are welcome to host overnight guests provided they comply with the College Residential Life and Housing Guest Policy. All guests (including guests under the age of 18) must agree to abide by applicable rules related to campus guest policies. In addition, the guardian of guests under the age of 18 must sign a campus visit permission and waiver form and submit it to the housing and conferences manager prior to the guest's overnight stay. Campus Safety will be informed of the overnight guest prior to the stay.

Overnight Visits by Prospective Students

Colorado College sometimes arranges for prospective students to visit the campus for an overnight stay. All visits by prospective students should comply with the college’s Student Honor and Community Standards policy and be approved with the Colorado College Admission Office. Prospective students who are staying overnight will be required to have their guardian sign a campus visit form and submit it to the housing and conferences manager and the Admission Office. The Admission Office will assign a college student in the residence hall to be available as needed to provide assistance and serve as host to the prospective student during the overnight visit. Students serving as a host to an overnight visitor are required to comply with the College Student Honor and Community Standards policy and obtain training from the Admission Office, and where feasible, the student host will remain with the student during the overnight visit. Otherwise, the host student will always know the whereabouts of the prospective student during the overnight visit. Campus Safety will be informed of the prospective student prior to the overnight stay.

Camps and Conferences with Overnight Guests

The rules regarding overnight stays by minors in college camps and conferences will be determined by the leaders of the camps and conferences involved. Minors who are not registered for these activities will not be allowed to stay overnight as a guest without written permission by the camp or conference leaders. Outside entities hosting camps and conferences on campus must follow the conduct standards outlined in this policy with respect to overnight stays.

TRAINING REQUIREMENTS

Colorado College faculty, staff, students, and volunteers who participate in college-run or affiliated programs and activities involving minors must complete the college’s online training offered by United Educators.  Additional training may be required depending on the program or activity and the person’s role in the program or activity.

Authorized adults with third-party entities that host a minors’ event or program on campus must also satisfy the training requirement.  However, some of these entities may already have training and protocols similar to the college’s training. To determine if their training meets the college’s training requirements, contact the program leader.

REPORTING POTENTIAL HARM TO MINORS  

Any member of the college community who knows, suspects, or receives information that a minor on campus or in a sponsored/co-sponsored program or on-campus event has been abused or neglected or who is concerned about the safety of the minor, must contact the Colorado Child Abuse and Neglect Hotline; (844) 264-5437; open 24 hours a day.  The Campus Safety/CSPD Resource Officer is the on-campus resource; (719) 389-6707. In all circumstances, the program leader/supervisor must be notified.

Colorado Revised Statute 18-8-115 states that it is the duty of every person who has reasonable grounds to believe that a crime has been committed to report promptly the suspected crime to law enforcement authorities. When acting in good faith, a person is immune from any civil liability for reporting.  In addition, Colorado Revised Statute 19-3-304 requires “public and private school officials or employees” to report to county child welfare or local law enforcement:  (a) circumstances when a person has reasonable cause to know or suspect child abuse has occurred; and (b) circumstances when a person has observed a child being subjected to conditions that would reasonably result in abuse.

The college’s Campus Safety Department is staffed 24 hours a day year-round by trained professionals employed to serve the college community. In life-threatening emergencies, or when there is a need for immediate police, fire, or medical assistance, make the following calls:

  • 911
  • (719) 389-6911 (Campus Safety)

CONTACT INFORMATION

Risk Management Administrator, Barbara Wilson, bwilson@coloradocollege.edu, (719) 389-6791

Title IX Coordinator, Heather Kissack, hkissack@coloradocollege.edu, (719)389-6202

Sexual Assault Response Coordinator, Anna Thompson, Office (719) 227-8101, on-call advocate (719) 602-0960, sarc@coloradocollege.edu or amthompson@coloradocollege.edu

Director of Campus Safety and Emergency Management, Maggie Santos, maggie.santos@coloradocollege.edu, (719) 389-6707

Conduct Expectations to Work with Minors

Do

  • Maintain a high standard of personal and professional behavior when interacting with minors. Treat them consistently, fairly, and with consideration, respect, and dignity; listen and provide positive reinforcement.
  • Maintain appropriate professional physical boundaries; only touch minors when necessary and only in ways that are appropriate in public and non-sexual. Be aware how others might perceive or misinterpret your actions or intentions.
  • Maintain discipline and discourage inappropriate language or touching behavior by minors.
  • Be highly aware of your words and tone of your voice in the presence of minors (e.g. profanity, adult topics, sexual innuendo, risqué humor, stereotyping comments, etc.).
  • Use good judgement about physical closeness and take particular care when touching minors. Proactively avoid touching that may be considered unwanted/inappropriate (e.g. give side hugs rather than frontal).
  • Consult with an authorized adult when uncertain about a situation or need help with misbehaving minors.
  • Comply with mandatory reporting laws and cooperate fully in any investigation of abuse of minors.
  • Maintain a safe and healthy physical environment for minors. Ensure that physical needs are met (e.g. easy access to water), avoid potential hazards (e.g. overheating, food or environmental allergies), and the physical space is safe.

Don’t

  • Be alone with a minor or spend time alone with a minor out of view of others. Ensure there is at least one other authorized adult present and in sight at all times during all program activities.
  • Enter a minor’s room, bathroom facility, changing area, shower area, or similar area without another authorized adult present. Minors should use a “buddy system” or otherwise be encouraged to stay together when going to the bathroom, on field trips, or when leaving the program area.
  • Share sleeping quarters (bed or sleeping bag) with minors. Separate accommodations for CC students and minors are required for all overnight trips. Minors should be placed in accommodations that have a locked door between themselves and program employees.
  • Engage in unsupervised communications with minors. This includes but is not limited to Facebook, Twitter, email, text, phone communication, or other social media. All communication outside of designated program times and program purposes must be with the minor’s guardian (e.g. all emails and texts must be sent to the guardian, not the minor).
  • Have contact with a minor outside of the program (e.g., babysitting, home visits).
  • Provide transportation to a minor participating in the program unless it is an acknowledged component of a program. Minors may be transported by Campus Safety in college vehicles and via ambulance if necessary. Program staff may drive their child(ren) in the program.
  • Smoke, use tobacco products, possess or be under the influence of alcohol, marijuana, or illegal drugs at any time while working with minors; provide alcohol, marijuana, or illegal drugs to any minor. Note: being “hung over” counts as being under the influence, and is equally unacceptable.
  • Provide prescriptions or over-the-counter medication to any minor unless specifically authorized in writing by the guardian as required for the minor’s care or the minor’s emergency treatment.
  • Make sexual materials in any form available to minors or assist them in any way to gain access to such materials.
  • Behave in a manner that is sexually provocative.
  • Give gifts to minors except for gifts provided by the program. Do not accept gifts from any minor in the program. Actively avoid the appearance of favoring one minor more than another. 
  • Take photos or videos of a minor with personal cell phones or cameras unless directed by an authorized adult and for program use only and authorized by the guardian.
  • Never tell minors anything that encourages minors to keep secrets from their guardians, (e.g. “this is just between the two of us”) even if it is about something as innocuous as sharing candy.
  • Engage in abusive conduct of any kind toward, or in the presence of, a minor. This includes but is not limited to striking, hitting, punishing, or touching in an inappropriate or illegal manner.
  • Engage in intimate displays of affection towards others in the presence of minors, guardians, and other program staff, including engaging in sexually provocative behavior or using sexual material in the presence of minors.

Transportation and Field Trips

  • Unless authorized by the program leader, do not use a personal vehicle to transport a minor.
  • When possible, at least two authorized adults should be in any CC vehicle transporting minors.
  • Never pick up minors from or drop off minors at their homes, by foot or by car.
  • Never drop minors off at a location where there is neither an authorized adult nor an identified guardian to take custody of the minor.
  • Due to the heightened risk involved in programs in which transportation is involved, program supervisors and employees are responsible for working with guardians to ensure that a guardian consent form is on file for each participant.
    • The consent form must include, at a minimum, a description of the program/activity; dates, times, and locations of activities; contact information for program staff responsible for activity; and any special risks associated with the program/activity. The form must be kept current.
    • Authorized adults are responsible for having copies in their possession at all times; emergency medical staff cannot provide care for a minor without a release, even in life-threatening situations.

High-Risk Areas

In general, minors are not permitted in high-risk safety areas. Examples of high-risk safety areas generally include, but are not limited to:

  • Power plants, shops, mechanical rooms, confined spaces, food preparation areas
  • Any areas, indoors or out, containing power tools or machinery with exposed moving parts or rotating equipment
  • College vehicles, low-speed vehicles, heavy-duty or other motorized equipment
  • Laboratories or specialized work areas that include chemical hazards, biological hazards, radioactive hazards, flammables, explosives, compressed gasses, sharp objects, lasers, research animals, hazardous wastes, or other environmental hazards
  • Basements, closets, stairwells, bathrooms, lockers, rooms without windows, and underground tunnels
  • Any other high-risk areas (rooftops, construction zones, etc.)

Direct supervision is required at all times in workplace areas with high-risk safety and/or confidentiality factors. Visits for non-CC student minors may be authorized for guided tours, experiential learning programs, or other reasons based on review by an appropriate responsible college authority and always with authorized adults present. 

 

 

Definitions

Child/Minor:  A person under the age of 18

Guardian:  A parent or legal guardian who has responsibility for a minor. 

Authorized Adult (employed by the college or sponsoring organization): Students, employees, volunteers, and third parties who have had a background check conducted and have been approved to supervise or otherwise interact with minors. 

Program Leader:  The individual or individuals with primary responsibility for the program, event, or activity, who has had a background check conducted and who has the authority to make decisions concerning the program, event, or activity, including placement and removal of employees.

Employees:  Faculty, staff, and students employed by the college and involved in programs, events, or activities that include minors. 

Sponsored and Co-Sponsored Programs, Events, or Activities:  Administered in full or in part by the college wherein minors are in the care, custody, and control of the college during the program’s operations. 

Hosted/Affiliated/Third-Party:  Programs, events, or activities conducted on campus or other college-owned or operated facilities and administered by a non-college entity. Examples include external groups holding workshops, sports camps, and conferences.