Operating Procedures for Programs Involving Minors

Effective Date: January 1, 2015, for programs that start on or after May 1, 2015

  1. Introduction
    Purdue University encourages programs and activities that enhance learning and stimulate creativity in youth. The success of these programs depends on careful planning that makes safety the highest priority. These procedures reinforce the safety of minors by requiring all programs that include minors as participants to be registered with the University. Registration includes certification by the sponsor of the program that all steps outlined in these procedures have been completed.

    Sponsors of programs are not limited by these procedures from developing more stringent requirements for their program staff. Similarly, units of the University that serve other units and third parties in facilitating programs (e.g., Purdue Extended Campus, IPFW Division of Continuing Studies, Intercollegiate Athletics) may supplement these procedures with additional requirements.

  2. Contacts
    1. For questions regarding the interpretation of these procedures, please contact:

      Office of the Vice President for Ethics and Compliance
      vpec@purdue.edu
      765-494-5830
    2. For questions related to the registration form, please contact:

      Risk Management
      RiskMgmt@purdue.edu
      765-494-7695

  3. Application
    These procedures apply to any camp, clinic, conference, workshop, program or other activity that involves participation of minors who are not registered students of Purdue University and where the Sponsor or co-Sponsor is:

    1. A college, school, department, office, organization or other unit of the University, regardless of the program location, or
    2. A third party who is hosting or conducting the program on University-owned property.

  4. Exclusions
    These procedures do not apply to (1) performances or events open to the general public and not targeted to minors (e.g., varsity athletic events, concerts, plays, etc.), (2) regularly scheduled classes, including dual-credit courses, or activities designed primarily for enrolled students of the University, (3) student recruitment activities, including open houses and admissions visits and tours, that are scheduled to last no longer than one day and do not include an overnight stay (4) national tests offered by a University testing center, (5) programs for which a Recognized Student Organization is the Sponsor or (6) University research involving minors as human subjects.

  5. Definitions
    All defined terms are capitalized throughout the document. Additional defined terms may be found in the central Policy Glossary.

    1. Sponsor: Any group, department, school, college, organization or individual involved in supporting a program, operationally and/or financially, whether a unit of the University or a third party.
    2. Program Director: The primary person acting on behalf of the Sponsor(s) who is responsible for the organization and execution of the program, including adherence to these procedures. The Program Director is also considered part of the Program Staff for the purposes of these procedures.
    3. Program Staff: Any individual, paid or unpaid, who is expected to interact with, supervise, chaperone or otherwise oversee minors in his/her role during a program. Such individuals may be faculty, staff, students, volunteers, employees or contractors of the University or of a third party.

  6. Mandatory Reporting of Suspected Child Abuse or Neglect
    1. Anyone 18 years of age or older is required by Indiana law to report known or suspected child abuse or neglect to Child Protective Services (CPS) or local law enforcement. Reports may be made anonymously.
    2. Complaints of child abuse or neglect involving University faculty, staff, students, volunteers, contractors or other covered parties may be made (1) by following the Procedures for Resolving Complaints of Discrimination or Harassment or (2) anonymously, through the University Hotline. Doing so does not relieve the individual filing the complaint from notifying CPS or local law enforcement.

  7. Registration and Certification
    1. Each Program Director must register the program with the University before the activity commences using the Programs for Minors Registration Form.
    2. Registration of the event includes certification that all Program Staff have passed minimum background check requirements (see section VI below) and have received training within the 24-month period preceding the start of the program (see section VII below).
    3. Registration also includes certification that the Checklist (see section VIII below) has been completed.

  8. Background Checks
    All Program Staff must pass, at minimum, a sex and violent offender registry check, which is verification that the individual is not listed as having any convictions of certain sex and violent crimes on the Dru Sjodin National Sex Offender Public Website nor the Indiana Sex and Violent Offender Registry, nor any other national or state registry that may become available. The registry check must have been performed within the 12-month period immediately preceding start of the program.

    1. Purdue University Colleges, Schools, Departments, Offices and Organizations as Sponsors
      1. It is the practice of Purdue University to regularly conduct registry checks on all faculty, staff and students. As such, units of the University do not need to conduct registry checks on faculty, staff or students of the University who will serve as Program Staff.
      2. A unit of the University who is a Sponsor of a program in which volunteers who are not faculty, staff or students of the University will serve as Program Staff are required to adhere to the provisions of the University policy on Volunteers (VI.B.2). The policy and its associated Administrative Manual on University Volunteers outline all requirements for using the services of volunteers, as well as detailed steps on conducting and documenting registry checks.
      3. If a unit of the University will be paying or contracting with outside individuals or a third party to serve on the Program Staff, a background check must be performed on each individual (see section VI.B.2 below), and only those individuals not listed on any of the registries may serve as Program Staff.
    2. Third Parties as Sponsors
      1. Third parties (those not acting on behalf of Purdue University) that are a Sponsor of a program on University-owned property must conduct registry checks on anyone who will serve as Program Staff. Only those individuals who are not listed on any of the registries named above may serve as Program Staff.
      2. Registry checks are done online by searching for the individual’s name. A date of birth and home address can be used to differentiate between duplicate names. Links to the required registries are below.
    3. Joint Sponsors
      1. If a program is sponsored by both a unit of the University and a third party, a combination of the above processes to verify that no one on the Program Staff is listed on a sex or violent offender registry may be used. Efforts between the Sponsors must be coordinated to ensure all Program Staff pass the background check.

  9. Education/Training
    All individuals who will serve as Program Staff must complete training on youth safety and the requirements for mandatory reporting in Indiana. Training must be completed within the 24-month period immediately preceding the start of the program. Program Staff who provide services for more than one program only need to complete the training once in a 24-month period. A certificate of completion should be filed with the Program Director as proof of completed training.

    1. Faculty, staff and students of the University may access online training offered through the Office of the Vice President for Ethics and Compliance. Follow the instructions for completing the training and certification quiz on Child Sexual Abuse: Prevention and Response.
    2. Purdue Extended Campus provides training for individuals not employed by or enrolled at the University on Youth Safety and Reporting Child Sexual Abuse. After viewing the online training material, individuals should follow the instructions to get certified.
    3. A Sponsor may provide its own training to Program Staff so long as it covers, at minimum, the topics noted above.

  10. Checklist
    The following safeguards must be in place prior to or at the start of the program.

    1. The Sponsor has a list of all program participants (for programs where registration of participants is required) and Program Staff, including current emergency contact information, and has a plan in place for notifying parents or legal guardians in the event of an emergency. Please note that the Purdue University Risk Management Office must be notified following an emergency.
    2. All appropriate permission forms, liability waivers, media releases and medical treatment authorization forms for minors participating in the program have been obtained and are on file with the Sponsor. These forms should be safeguarded and readily available. (See Tools section for examples.)
    3. Arrangements have been made to ensure all activities involving minors will be supervised by the child’s parent or legal guardian or an appropriate ratio of Program Staff at all times. If they are staying in University housing, a plan for supervision of minors while in University housing has been approved by the applicable campus housing authority.

  11. Facilities Use
    Units of the University with administrative responsibility over the University facility that will be used during a program must obtain from the Sponsor, prior to the program, a use of facilities or booking agreement that is in form and substance satisfactory to the University’s Office of Legal Counsel.

  12. Applicable University Policies
    Conduct that constitutes harassment or violent behavior, including sexual abuse, sexual assault, hazing or bullying, is not tolerated:

    1. Anti-Harassment (III.C.1)
    2. Violent Behavior (IV.A.3)
    3. Access to program activities must be made available to all participants with accommodations provided as appropriate: Equal Opportunity, Equal Access and Affirmative Action (III.C.2).
    4. The possession or use of alcohol and other drugs (including medical marijuana), is prohibited: Alcohol- and Drug-Free Campus and Workplace Policy (C-44).
    5. The possession or use of fireworks and any type of firearm or dangerous weapon is prohibited: Regulations Governing the Use and Assignment of University Facilities (IV.B.1).
    6. Misuse or damage of Purdue University property and theft of property, regardless of owner, will not be tolerated: Regulations Governing the Use and Assignment of University Facilities (IV.B.1).
    7. Smoking is prohibited in any University building. Further prohibitions on the use of tobacco products are stated in each campus’s policy:
      1. Calumet: Smoke Free Campus Policy (PDF)
      2. Fort Wayne: Tobacco and Smoke-free Campus Policy
      3. North Central: PNC Smoke/Tobacco Free Policy (PDF)
      4. West Lafayette: Smoke Free West Lafayette Campus (WL-5)
    8. Anyone operating a vehicle in conjunction with a program sponsored by a unit of the University must be an Authorized Driver in accordance with the policy on Use of Vehicles for University Business (IV.A.1).

  13. Tools
    1. Programs for Minors Registration Form
    2. Online sex and violent offender registries:
      1. Dru Sjodin National Sex Offender Public Website
      2. Indiana Sex and Violent Offender Registry
    3. Sample forms:
      1. Risk Management Website
      2. Purdue Extended Campus Website
    4. Templates for booking agreements for use by third party Sponsors and letters of agreement for use by colleges, schools, offices, organizations or other units of the University may be obtained by contacting the following:

      Special Counsel, Procurement Contracting and Risk Management
      Phone: 765-494-0534

    5. FAQs for Programs Involving Minors
    6. Parking information for each campus:
      1. Calumet
      2. Fort Wayne
      3. North Central
      4. West Lafayette

  14. History and Updates to These Procedures

    • May 14, 2015: Hyperlinks updated in section IX.A&B.
    • January 1, 2015: Procedures established and effective in support of the University’s policies on Equal Opportunity, Equal Access and Affirmative Action (III.C.2), Anti-Harassment (III.C.1), and Regulations Governing the Use and Assignment of University Facilities (IV.B.1).

Contact Information
Ernest C. Young Hall, 10th Floor
155 S. Grant Street
West Lafayette, IN 47907-2114
Phone: 765-494-5830
Fax: 765-494-1295
E-mail: vpec@purdue.edu 

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