Policy

Colorado College is committed to the safety and well-being of minors visiting college facilities and/or participating in college-sponsored or college-hosted programs. All members of the college community are responsible for reporting abuse and/or neglect of minors involved in college-sponsored or college-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.

Procedures

Expected Conduct

All Authorized Adults, college or program employees, students, and volunteers who supervise or interact with Children/Minors on college property or in connection with College-Sponsored, Co-Sponsored, or Hosted Programs, Events, or Activities are required to conduct themselves appropriately and to maintain the highest standards of professionalism, ethics, and personal behavior.  All such individuals are required to comply with the “Conduct Expectation To Work with Children/Minors” addendum to this policy.

Responsibility for Children/Minors

Colorado College is an institution of higher education. College facilities are generally not an appropriate environment for Children/Minors unless they are matriculated students or are enrolled in a College Sponsored, Co-Sponsored, or Hosted Program, Event, or Activity specifically designed for Children/Minors and supervised by Authorized Adults with the proper training and credentials. However, the college recognizes that college or program employees, students, and other adults may on occasion bring a Child/Minor to campus for a limited period.

College or program employees, students, and other adults who bring a Child/Minor to college facilities are responsible for the safety of the Child and are accountable for the Child’s safety and behavior, and adherence to college policy. College and program employees, students, volunteers, and other adults must recognize and respect the need for a professional work and educational environment. College and program employees, students, volunteers, and other adults are responsible for injuries or damages sustained to or by a Child/Minor with them while on College property or at College-Sponsored, Co-Sponsored, or Hosted Programs, Events, or Activities.

The College retains the discretion to restrict or permit the participation of a Child/Minor in any College-Sponsored, Co-Sponsored, or Hosted Program, Event, or Activity, and to exclude or permit Children/Minors from being on campus or in college facilities, even when accompanied by a parent, Guardian, or another legal custodian.

 

Criminal Background Checks for Those Interacting with Children/Minors

College and program employees, students, and volunteers who participate in College-Sponsored, Co-Sponsored, or Hosted Affiliated Third-Party Programs, Events, or Activities involving Children/Minors must have passed a criminal background check within the previous four (4) years. Background checks for the college will be administered, authorized, reviewed, or approved in scope by Human Resources.

COLLEGE PROGRAMS, EVENTS, AND ACTIVITIES

College-Sponsored or Co-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 Children/Minors to attend. In order to ensure their safety and that of other guests, the college requires that the Child/Minor’s Guardian agree to adhere to established event guidelines and to the following conditions for the Child/Minor’s participation:

• Colorado College is not responsible for the supervision of a Child/Minor who attends a College-Sponsored or Co-Sponsored event unless the event sponsor states in writing that supervision by College Employees will be provided.
• Children/Minors must remain in the designated area where the event is located.
• The Child/Minor’s Guardian is responsible for the Child's safety, behavior, and actions and for any damages caused by the Child.

College-Sponsored or Co-Sponsored Programs

Colorado College sponsors programs specifically designed for Children/Minors. The College requires that all Authorized Adults who are to or who might interact with Children/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, to the Program Leader’s supervisor. or, as necessary, to Campus Safety.

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

College-Hosted or Affiliated Third-Party Programs, Events, or Activities

Colorado College approves selected outside individuals and entities to use college facilities for programs, events, or activities specifically designed for or including Children/Minors. Through the agreement process, the college requires the sponsoring entity to provide proof that Authorized Adults, Program Leaders, and program employees have passed appropriate criminal background checks within the past 4 years, and 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

College employees, volunteers, and students engage in off-campus activities involving Children/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 must comply with college policies in the same manner and extent as for 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.

College-Sponsored Trips and Study Abroad

College employees, volunteers, and students must consult with the Center for Global Education and Field Study in advance regarding any Child/Minor’s participation in trips or other activities associated with college-sponsored trips or study abroad programs and must comply with established sponsored trips and study abroad procedures. All College participants in such programs must comply with college policies in the same manner and extent as for programs conducted on campus. The college has the discretion to restrict or permit participation by any Child/Minor in such a program.

ACADEMICS, RESIDENTIAL LIFE, AND EMPLOYMENT

Child/Minor Students in Classes and Labs

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

Children/Minors Who Live on Campus

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

Employment of Children/Minors

Occasionally, Colorado College may hire a Child/Minor to fill an employment position or student work position. The Student Financial Aid Office authorizes the hiring 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 Children/Minors. In the event the college hires a Child/Minor, the Human Resources Office will inform the supervisor that the employee is under the age of 18 and will assist the supervisor in determining whether any particular steps or limitations are necessary because of the employee's age. Children/Minors are not to be assigned to work alone or without close supervision by an Authorized Adult without the written approval of the Human Resources Office.

DAY AND OVERNIGHT VISITS INVOLVING CHILDREN/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 from and submit it to the housing and conferences manager prior to the guest's overnight stay. Campus Safety will be informed of any overnight guest, who is a Child/Minor, prior to the overnight 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 by the Colorado College Admission Office. Prospective students who plan to stay overnight and who are Children/Minors must 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 to serve as a 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 must obtain training from the Admission Office, and, where feasible, the student host will remain with the student during the overnight visit. Otherwise, the student host will always know the whereabouts of the prospective student during the overnight visit. Campus Safety will be informed of any prospective student who is a Child/Minor staying overnight prior to the overnight stay.

Camps and Conferences with Overnight Guests

The rules regarding overnight stays by Children/Minors in College camps and conferences will be determined by the Program Leaders of the camps and conferences involved, in agreement with the college. Children/Minors who are not registered for these activities are not allowed to stay overnight as a guest without written permission by the camp or conference Program Leaders and the Child/Minor’s Guardian. 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 employees, students, and volunteers who participate in College-Sponsored, Co-Sponsored, or Hosted or Affiliated Programs, Events, or Activities involving Children/Minors must complete the college’s online training.  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 Children/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 CHILD ABUSE OR NEGLECT

Mandatory Reports of Child Abuse or Neglect

Any college employee and any person employed by a private sports organization or program, who has reasonable cause to suspect that a Child/Minor has been subjected to Child Abuse or Neglect (as defined above) or who has observed a Child/Minor in circumstances that would reasonably result in Child Abuse or Neglect, must immediately report the facts to the county department of health and human services, local law enforcement, or through the child abuse reporting hotline.  See C.R.S. § 19-3-304. 

The Colorado Springs Police Department  Resource Officer assigned to Colorado College may be reached at (719) 389-6707. 

The College’s Campus Safety Department is staffed 24 hours a day year-round by trained professionals employed to serve the college community.

Information on El Paso Country Human Services is located at https://humanservices.elpasoco.com. 

The Colorado Child Abuse and Neglect Hotline; 1-844-264-5437; is open 24 hours a day.

Notification to College administrators or Program Leaders does NOT satisfy the reporting requirement in this paragraph.

For the oral report, the reporting person should be prepared to provide as much information as possible about:

• The name, address, age, sex, and race of the Child/Minor;
• The name and address of the person responsible for the suspected Child Abuse or Neglect, if known;
• The nature and extent of the Child/Minor’s injuries, including any evidence of previous cases of known or suspected abuse or neglect of the Child or the Child’s siblings;
• The family composition;
• The reporting person’s name, address, and occupation;
• Any action taken by the reporting person;
• Any other information that may be helpful.

An oral report should be followed by a written report.  The written report should provide as much information as possible in the same categories set out above, plus, if known and if the individual responsible for the suspected abuse or neglect is a member of the armed forces or is a significant other or family member living in the home of a member of the armed forces, any military affiliation of the individual.

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)

In addition to reporting to the county, law enforcement, or the hotline, any college employee with information concerning Child Abuse or Neglect must notify the Program Leader for the program, event or activity with which the Child/Minor is associated, if known, and the Sexual Assault Response Coordinator, identified below.  Notification to the Sexual Assault Response Coordinator or other college administrators or Program Leaders does NOT satisfy the mandatory reporting requirement identified above.

Immunity

Under C.R.S. § 19-3-309, any person who reports Child Abuse or Neglect is immune from liability or termination of employment that otherwise might result from the report, unless a court determines that the report was willful, wanton, and malicious.  A reporting person's good faith is presumed.

RETALIATION

The College does not retaliate against college or program employees, students, volunteers, or others because the person has made a report pursuant to this Policy, has made a good faith report to government authorities, has cooperated in an investigation of a report under this Policy, or has cooperated in an investigation by law enforcement or government authorities.

Improper retaliation could take many forms depending on the positions and circumstances of the people involved.  In the context of college employees, retaliation might involve adverse personnel action that is causally connected to the report of Child Abuse or Neglect or to the cooperation in an investigation.  For other persons, improper retaliation might involve exclusion from activities for having made a report of Child Abuse or Neglect or for cooperating in an investigation.

If a member of the college community believes that they have experienced retaliation by any person for making a report pursuant to this Policy, making a good faith report to government authorities, cooperating in an investigation of a report under this Policy, or cooperating in an investigation by law enforcement or government authorities, the person should make a report immediately to the Risk Management Administrator or Title IX Coordinator, identified below.

CONSEQUENCES FOR VIOLATIONS OF POLICY

College and program employees, students, and volunteers who violate the conduct standards or engage in other violations of this Policy may be subject to disciplinary action at the discretion of the college.  College and program employees, students, and volunteers who fail to make timely reports of suspected Child Abuse or Neglect may be subject to disciplinary action at the discretion of the college.

Disciplinary action may include, but is not limited to, a warning or reprimand; corrective action and/or suspension of the perpetrator’s employment, volunteer work, affiliation, or other College activity; termination of the perpetrator’s employment, volunteer work, affiliation, or other college activity; and/or a ban on the perpetrator’s presence on campus, on other College facilities, or at College-Sponsored, Co-Sponsored, or Hosted Programs, Events, or Activities.

CONTACT INFORMATION

Interim Title IX Coordinator, Josh Isringhausen, jisringhausen@coloradocollege.edu, 719-389-6886

Campus Advocate, Cassie Luna, Office (719) 227-8101, on-call advocate 719-602-0960, sarc@coloradocollege.edu or cluna@coloradocollege.edu

Director, Campus Safety and Emergency Management, Cathy Buckley, cbuckley@coloradocollege.edu,  (719) 389-6707

Risk Management Administrator, Ryan Hammes, rhammes@coloradocollege.edu 719-389-6791

 

Conduct Expectations to Work with Children/Minors

 Do

• Maintain a high standard of personal and professional behavior when interacting with Children/Minors. Treat them consistently, fairly, and with consideration, respect, and dignity; listen and provide positive reinforcement.
• Maintain appropriate professional physical boundaries; only touch Children/Minors when necessary and only in ways that are non-sexual and appropriate in any setting. Be aware of how others might perceive or misinterpret your actions or intentions.
• Maintain discipline and discourage inappropriate language or touching behavior by or between Children/Minors.
• Be highly aware of your words and tone of your voice in the presence of Children/Minors (e.g. profanity, adult topics, sexual innuendo, risqué humor, stereotyping comments, etc.).
• Use good judgment about physical closeness and take particular care when touching Children/Minors. Proactively avoid touching that may be considered or that might appear unwanted/inappropriate (e.g. give side hugs, when initiated by the Child, rather than frontal; do not seat a Child on your lap or between your legs).
• Consult with an Authorized Adult when uncertain about a situation or when you need help with misbehaving Children/Minors.
• Comply with mandatory reporting laws and cooperate fully in any investigation of Child Abuse or Neglect.
• Maintain a safe and healthy physical environment for Children/Minors. Ensure that physical needs are met (e.g. easy access to water), avoid potential hazards (e.g. overheating, food or environmental allergies), and be sure the physical space is safe.

Don’t

• Be alone with a Child/Minor or spend time alone with a Child/Minor out of view of others. Do ensure there is at least one other Authorized Adult present and in sight at all times during all program activities.
• Enter a Child/Minor’s room, bathroom facility, changing area, shower area, or similar area without another Authorized Adult present. Children/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 Children/Minors. Separate accommodations for CC students and Children are required for all overnight trips.  Children/Minors should be placed in accommodations such that the Child may lock a door between themselves and program employees.
• Engage in unsupervised communications with Children/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 Children/Minor’s Guardian (e.g. all emails and texts must be sent to the Guardian, not the Child/Minor). For prospective student communication, the admission or pre-college representative is to be copied.
• Provide prescriptions or over-the-counter medication to any Children/Minor unless specifically authorized in writing by the Child’s Guardian as required for the Child’s care or emergency treatment.
• Visit or have contact with a Child/Minor outside of the program (e.g., babysitting, home visits). Do not arrange to meet a Child/Minor outside the presence of the Child’s Guardian or another Authorized Adult..
• Provide transportation to a Child/Minor participating in the program unless it is a component of a program acknowledged by the Child’s Guardian and another Authorized Adult is present. Children/Minors may be transported by Campus Safety in college vehicles and via ambulance if necessary. Program staff may drive their own 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 Children/Minors. Do not provide alcohol, marijuana, or illegal drugs to any minor. Note: being “hung over” counts as being under the influence, and is equally unacceptable. 
• Engage in horseplay or any conduct with a Child/Minor that might cause bodily injury, including bruising, bleeding, burns, broken bones, hematoma, soft tissue swelling, substantial pain, or other impairment. Athletic activities with proper, trained supervision, and a release signed by the Child’s Guardian are appropriate.
• Use force of any kind against a Child/Minor, unless the force is reasonable and justifiable for example, to remove the Child from a dangerous situation, to prevent self-harm, for defense of yourself or others under imminent threat of serious physical harm, or to obtain possession of a weapon.
• Cause or encourage the Child/Minor to engage in actual or pretended infliction of pain or discomfort or to simulate being or actually to be restrained or bound.
• Engage in abusive conduct of any kind toward, or in the presence of, a Child/Minor. This includes but is not limited to striking, hitting, punishing, or touching in an inappropriate or illegal manner.
• Engage in any romantic, dating or sexual relationship with a Child/Minor.
• Make sexual materials in any form available to Children/Minors or assist them in any way to gain access to such materials.
• Behave in a manner that is sexually suggestive, provocative.
• Engage in sexual contact with a Child/Minor, including but not limited to sex-related communications, sexually explicit language, showing sexually explicit or suggestive images, commenting on the Child’s sexuality or sexual characteristics, inciting the Child to expose the Child’s or another’s genitals or to touch the Child’s or another’s genitals, Exposing your own genitals to a Child (including by smart phone or computer network), touching the Child’s genitals or the clothing over the genitals, engaging in any form of self stimulation in the presence of a Child, and engaging in any conduct that provides you sexual gratification or that is intended to arouse the Child.
• Take photos or videos of a Child/Minor with personal cell phones or cameras unless directed by an Authorized Adult and for program use only and authorized by the Guardian.
• Take, create, possess, publish, or arrange to publish an image of a Child/Minor, or cause the Child to pose for, or to make or send images of the Child, with genitalia or sensitive areas exposed.
• Give gifts to Children/Minors except for gifts provided by the program. Do not accept gifts from any Child/Minor in the program. Actively avoid the appearance of favoring one Child more than another. 
• Tell Children/Minors anything that encourages the Children 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 intimate displays of affection towards others in the presence of Children/Minors, Guardians, or other program staff, including engaging in sexually provocative behavior, making sexual jokes or innuendos. or using sexual material in the presence of Children/Minors.
• Use cruel, threatening, or excessively harsh language toward a Child/Minor or engage in any other form of emotional, verbal, or psychological abuse of the Child.
• Provide shelter to a Child without consent of the Child’s Guardian, except for momentary shelter in the event of an emergency.

Transportation and Field Trips

• Unless authorized by the program leader, do not use a personal vehicle to transport a Child/Minor.
• When possible, at least two Authorized Adults should be in any CC vehicle transporting Children/Minors.
• Never pick up Children/Minors from or drop off Children at their homes, by foot or by car.
• Never drop Children/Minors off at a location where there is neither an Authorized Adult nor an identified Guardian to take custody of the Child.
• Due to the heightened risk involved in programs in which transportation is involved, Program Leaders and employees are responsible for working with Guardians to ensure that a Guardian consent form is on file for each Child/Minor 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 of consent forms and medical releases in their possession at all times; emergency medical staff cannot provide care for a Child/Minor without a release, even in life-threatening situations.

High-Risk Areas

In general, Children/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
• 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 Children/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

Authorized Adult (employed by the College or sponsoring organization): Students, employees, volunteers, and third parties who have been approved to supervise or otherwise interact with Children/Minors.  No person may be approved to supervise or otherwise interact with Children/Minors unless person has passed a background check conducted or authorized by the College or sponsoring organization.

Child/Minor:  A person under the age of 18   

Child Abuse or Neglect:  An act or omission that threatens the health or welfare of a Child/Minor AND that meets any of the following:

(I) The Child/Minor exhibits evidence of skin bruising, bleeding, malnutrition, failure to thrive, burns, fracture of any bone, subdural hematoma, soft tissue swelling, or death and either: (a) the condition or death is not justifiably explained; (b) the history given concerning the condition is at variance with the degree or type of the injury or death; or (c) the circumstances indicate that the condition may not be the product of an accident;

(II)  The Child/Minor is subjected to sexual assault, unlawful sexual contact, enticement, incest, human trafficking, sexual exploitation or procurement for sexual exploitation, indecent exposure, prostration, soliciting for prostitution, pandering. obscenity, internet luring, public indecency, invasion of privacy, kidnapping, or unlawful electronic communication; (for details see C.R.S. § 16-22-102 (9));

(III)  The Child/Minor's parents, Guardian, or custodian fails to take the actions to provide adequate food, clothing, shelter, medical care, or supervision that a prudent parent would take;

(IV)  The Child/Minor is subjected to an identifiable and substantial impairment of the Child's intellectual or psychological functioning or development or a substantial risk of such impairment;

(V)  (a) A parent, Guardian, or legal custodian has abandoned the Child/Minor, has subjected the Child to mistreatment or abuse, or has allowed another person to mistreat or abuse the Child and the parent, Guardian, or legal custodian does not take lawful means to stop such mistreatment or abuse and prevent it from recurring;  (b) The Child lacks proper parental care through the actions or omissions of the parent, Guardian, or legal custodian; or (c) The Child's environment is injurious to the Child’s welfare;

(VI)  A controlled substance is manufactured or attempted to be manufactured, in the presence of a Child/Minor, or on the premises where a Child is found, or where a Child resides;

(VII)  The Child/Minor tests positive at birth for a controlled substance, unless the positive test is a result of the mother's lawful intake of such substance as prescribed; or

(VIII) The Child/Minor is subjected to human trafficking for involuntary servitude.

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

College Sponsored and Co-Sponsored Programs, Events, or Activities:  Programs, events, or activities administered in full or in part by the College in which Children/Minors are in the care and/or custody of the College during the program, event, or activity. 

Guardian:  A parent or legal guardian who has responsibility for a Child/Minor.

Program Leader:  The individual or individuals with primary responsibility for the program, event, or activity and who has (have) the authority to make decisions concerning the program, event, or activity, including placement and removal of employees.  All such individuals must have passed a background check conducted or authorized by the College or sponsoring organization.