Operating Procedures for Programs Involving Minors

These operating procedures supplement the policy on Programs Involving Minors (III.A.6). Refer to the policy for applicable definitions.

Effective Date: April 1, 2023, for programs beginning on or after June 1, 2023

Table of Contents

Contacts
State-Required Reporting of Suspected Child Abuse or Neglect
Reporting Other Incidents
Program Registration, Staff Registration and Certification
Registry Checks
Education/Training
Participant Registration
Forms, Waivers and Insurance
Checklist
Facilities Use
Tools
History and Updates to These Procedures

I. Contacts

For questions regarding any of the steps outlined in these procedures, please contact:

Youth Protection in the Office of the Vice President for Ethics and Compliance (VPEC)
youthprotection@purdue.edu

II. State-Required 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, including abuse by other minors, to Child Protective Services (CPS) or local law enforcement. Such reports must be made without delay and may be made anonymously. Visit the Indiana Child Abuse and Neglect Hotline website for details.
   
   
2. If the known or suspected child abuse and/or neglect involves University faculty, staff, students, volunteers, contractors or other covered parties, or is alleged to have occurred on property owned or controlled by the University, it also must be reported to the University via one of the following options:
    
   
   1. To the campus Purdue University Police Department,
      
      
   2. To youthprotection@purdue.edu, or
      
      
   3. Anonymously through the Purdue Hotline.
      
      
3. Reporting to the University does not relieve the individual of their responsibility to notify CPS or local law enforcement as required by Indiana statute.
   
   
4. Individuals who would like to file a complaint with the University regarding child abuse and/or neglect occurring in connection with a University-Sponsored Program may do so (1) by following the Procedures for Resolving Complaints of Discrimination and Harassment, (2) by following the Procedures for Resolving Complaints of Title IX Harassment or (3) anonymously, through the Purdue Hotline.
   
   
5. Program Staff who are employees of the University may also be mandatory reporters for Title IX purposes. These individuals are required to report Title IX incidents personally observed or reported to them during the course of the Program. These incidents must be reported by completing the Incident Report form.

III. Reporting Other Incidents

Program Staff have a responsibility to the participants and other Program Staff to take appropriate action in the event an incident occurs during the Program. Program Staff must contact the campus police or local police (if off campus) if they are witness to or made aware of allegations of criminal conduct against another individual. This includes but is not limited to fondling, rape, statutory rape, sexual exploitation, assault, and robbery, as well as allegations that Program Staff is furnishing illegal drugs or alcohol to minors. These allegations must be reported to the police even if the alleged perpetrator is a minor. If Program Staff do not know whether the incident rises to the level of police involvement, they may choose to consult the Office of the VPEC.

In addition, Program Staff must notify youthprotection@purdue.edu immediately following any incident that:

1. Results or could have resulted in serious psychological harm or bodily injury to a minor or member of Program Staff, including instances of peer-to-peer abuse or injury;
   
   
2. Results or might result in a participant’s or a Program Staff’s ejection, suspension or dismissal from the Program for disciplinary reasons regardless of the duration of the suspension; or
   
   
3. Requires or involves a response by emergency personnel.

Program Directors are required to complete an incident report within the Purdue Protection of Minors Portal. Program Directors do not need to notify youthprotection@purdue.edu if they complete the incident report immediately following one of the above incidents.

IV. Program Registration, Staff Registration and Certification

1. Each Program Director must register the Program and each session with the University via the Purdue Protection of Minors Portal. The Program must be registered at least 30 days before the Program starts or 30 days before a session opens for participant registration, whichever occurs first. In the event that the Program is planned less than 30 days in advance or does not require advanced registration, the Program Director must register the program as soon as the details of the Program are known.
   
   
2. Registration of the Program includes listing all Program Staff for the purpose of recording Registry Checks and any required Program Staff training. The list must include an email address for each member of the Program Staff. The Purdue career account email address should be used for all Program Staff who are Purdue faculty, staff or students.
   
   
3. Registration of the Program includes certification that the Program Director has read policy III.A.6 and these procedures and will ensure that the requirements, including those for Registry Checks (section V) and education/training (section VI), are or will be met.
   
   
4. Registration of Custodial Programs also includes certification that the Checklist (see section IX below) will be completed prior to the start of the Program.
   
   
5. Continuously Operating Programs. Continuously operating Programs, such as childcare facilities and outreach programs, must register the Program with the University annually and whenever there is a material change in operation, management or direction.
   
   
6. Registered Student Organizations. Registered Student Organizations (RSOs) that meet the definition of a Custodial Program must register at least annually. RSOs must register individual Programs as separate events even if the RSO is registered as a Custodial Program based on its general activity.
   
   
7. Equal Access/Equal Opportunity. While a program may be targeted to a specific audience, no person may be denied participation based on a protected class covered by Purdue policies.
   
   
8. Exceptions to Registration Requirement: The following types of activities are not required to be registered with the University (but Program Staff are still subject to sections V and VI of these procedures):
   
   
   1. University departments that employ minors outside of a structured, identifiable Program for youth.
      
      
   2. College visits, open houses and admissions fairs targeted to prospective students who will matriculate in the next 24 months that do not include an overnight stay.
      
      
   3. Student recruitment activities targeted to individual prospective students, such as “Official Visits” sponsored by Purdue University Athletics or scouting trips that do not include an overnight stay.

V. Registry Checks

Program Directors must ensure that all potential Program Staff members are subject to a Registry Check within the 12-month period immediately preceding the start of the Program. Sponsors must conduct Registry Checks on anyone who will serve as Program Staff, including University faculty, staff, and students and individuals who are volunteers or contracted by a third party. The Registry Check process must be completed and recorded at least one day prior to the start of the Program and before any Program Staff may interact with any minor participants. Individuals not listed on either of the registries may serve as Program Staff.  

1. Registry Checks must be completed on the below listed websites by searching for the individual’s name in the database. A date of birth and home address can be used to differentiate between duplicate names. Be sure to keep a record of all individuals checked and the outcome of the check. See paragraphs C and D below for steps to follow if a match is found on one of the registries.
   
   
   1. Dru Sjodin National Sex Offender Public Website
      
      
   2. Indiana Sex and Violent Offender Registry
      
      
2. Sponsors may employ more thorough background check resources than those required by the University as long as they at least comply with the Registry Check requirement.
   
   
3. A valid Registry Check is performed and recorded by (1) someone other than the person being checked and (2) someone who does not report to the person being checked. A check of a Program Director may be performed by a co-director, the Office of the VPEC, or the VPEC’s designee. Programs that must be registered with the University in accordance with section IV must record Registry Check results in the Purdue Protection of Minors Portal.
   
   
4. University Sponsors. Sponsors who are units of the University must notify both careers@purdue.edu and youthprotection@purdue.edu if any potential Program Staff member’s information matches a record on one of the registries. The Offices of the VPEC and the Vice President for Human Resources (VPHR) will determine whether the individual will be allowed to participate in the Program. University Sponsorsmay not decide to exclude someone based on the outcome of a Registry Check without the direction and approval of the Offices of VPEC and VPHR.
   
   
5. Third-Party Sponsors. Third-party sponsors may decide to exclude someone from serving as a Program Staff member based on the outcome of a Registry Check. If a third-party Sponsor wishes for someone whose information matches a record on the registries to serve as Program Staff, the Sponsor must notify both careers@purdue.edu and youthprotection@purdue.edu of the match and request a determination. The individual may serve only with the direction and approval of the Offices of VPEC and VPHR.
6. Joint Sponsors. While it is not necessary for multiple Sponsors to conduct Registry Checks, efforts between the Sponsors must be coordinated to ensure all Program Staff members are subject to a Registry Check in accordance with these procedures and that the completed check is documented.
   
   
7. Volunteers as Program Staff. Units of the University who are Sponsors of Programs in which volunteers will serve as Program Staff are required to adhere to the provisions of the 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 and for annual reporting of volunteer Registry Checks. Faculty, staff and students of the University who volunteer as Program Staff, are subject to the Registry Check requirements of these procedures.
   
   
8. Continuously Operating Programs. Programs that operate continuously must conduct Registry Checks on all Program Staff prior to each staff member’s participation in the Program and at least once every 12 months thereafter.
   
   
9. Staff Hired after Program Start. Program Directors must ensure that Registry Checks are conducted on any new potential Program Staff members prior to that individual’s participation in the Program.
   
   
10. Registered Student Organizations. When a Registered Student Organization (RSO) meets the definition of a Custodial Program, the RSO’s chair/president must conduct Registry Checks on all members age 18 or older. A Registry Check of the chair/president may be done by the Office of the VPEC, or the VPEC’s designee. Checks must be done upon each adult member’s admittance to the RSO and at least once every 12 months thereafter. All other RSOs that are the Sponsor or co-Sponsor of a specific Program or event targeted to minors, such as a philanthropy event involving children, must conduct Registry Checks on all members who will be in attendance at the event. Any RSO that finds a match during a Registry Check must comply with paragraph D above.
    
    
11. Exceptions. Program Directors are not required to conduct Registry Checks on potential Program Staff for virtual (online) Noncustodial Programs who will not be expected to interact directly with minor participants.

VI. Education/Training

1. Program Directors
   
   Except as provided in paragraph 3 below, all individuals who will serve as a Program Director must complete training on leading youth programs. This training is in addition to the training required for Program Staff (described below) and must be completed within the 24-month period immediately preceding the start of the Program. Program Directors who provide services for more than one Program need only complete the training once in a 24-month period.
   
   The University provides training that fulfills this requirement. Follow these instructions for accessing the training.
   
   
   1. Sponsors may provide their own training to Program Directors, as long as the training addresses adequate screening of staff and volunteers, recognition of signs of predatory behavior, strategies for preventing child sexual abuse, and age appropriate staffing ratios. In these instances, the Program Director must maintain files of documented proof of completed training for all directors and record/upload the information in the Purdue Protection of Minors Portal.
      
      
   2. Registered Student Organizations(RSOs). If the RSO meets the definition of a Custodial Program, the president/chair of the RSO and the RSO’s advisor are subject to the requirements of this section. When an RSO is a Sponsor or co-Sponsor of a Program or event targeted to minors, such as a philanthropy event involving children, the president/chair of the RSO and anyone else serving as a Program Director for the event are subject to this section.
      
      
   3. Exceptions. Program Directors for the following Programs and activities do not need to complete training on leading youth programs:
      1. Programs for which the University has no Operational Responsibility.
      2. Programs that are overseen by a state or federal licensing board (such as schools, childcare facilities, etc.).
      3. Noncustodial Programs where Program Staff are not expected to interact with the minor participants.
         
         
2. Program Staff
   
   Except as provided in paragraph 5 below, all individuals who will serve as Program Staff must complete training on youth safety and Indiana’s requirements for reporting of suspected child abuse or neglect. Youth safety training must include information about appropriate interactions and communication, bullying intervention, and prohibited conduct. 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 need only complete the training once in a 24-month period.
   
   The University provides training that fulfills the above requirements. Follow these instructions for accessing the training.
   
   
   1. A Sponsor may provide its own training to Program Staff as long as it covers, at minimum, youth safety and Indiana’s requirements for reporting suspected child abuse or neglect. In these instances, the Program Director must maintain files of documented proof of completed training for all Program Staff and record/upload the information in the Purdue Protection of Minors Portal.
      
      
   2. Continuously Operating Programs. Programs that operate continuously must ensure all Program Staff are trained in accordance with these procedures in the 24-month period immediately preceding each staff member’s participation in the Program and at least every 24 months thereafter.
      
      
   3. Staff Hired after Program Start. Program Directors must ensure that any member of Program Staff who joins the Program after its start is trained in accordance with these procedures prior to the staff member interacting with minor participants of the Program if the staff member has not already completed training within the last 24 months.
      
      
   4. Registered Student Organizations (RSOs). RSOs that meet the definition of a Custodial Program must ensure that all members of the organization age 18 or older complete training as described above. When an RSO is the Sponsor or co-Sponsor of a specific Program or event targeting minors, such as a philanthropy event involving children, all members of the organization who will be in attendance at the event must complete the training described above.
      
      
   5. Exceptions:
      
      
      1. Large Festivals. Volunteers serving as Program Staff for large, single day or single weekend festival-like events do not need to complete training on youth safety if they are always accompanied and supervised by a member of Program Staff who has completed training on youth safety as described above. These individuals are referred to as supervised volunteers. The Program Director must still inform these volunteers of conduct prohibited by the University and of Indiana’s reporting requirements for suspected child abuse and/or neglect, and the Program Director must conduct a Registry Check for these volunteers in accordance with the University policy on Volunteers (VI.B.2).
         
         
      2. Noncustodial Programs. Program Directors must inform Program Staff of Indiana’s reporting requirements for suspected child abuse and/or neglect and conduct prohibited by the University, but Program Staff for Noncustodial Programs do not need to complete any formal training on youth safety.
         
         
      3. Event Presenters, Lecturers, etc. Individuals who serve a specific, limited role or perform a certain task in a Program (see examples below) and are always in the presence of the Program Staff are not required to complete any formal training on youth safety. Program Directors must inform these individuals of Indiana’s reporting requirements for suspected child abuse or neglect and conduct prohibited by the University. Examples may include, but are not limited to, a surgeon performing a procedure for the participants to observe, sideline judges for competitions, a singer who performs for the participants, and tour guides.
         
         
      4. Departments that Employ Minors. When units of the University employ minors outside of an identifiable Program, the unit supervisor must ensure that all faculty and staff who work with the minor(s) are notified of conduct prohibited by the University and of Indiana’s reporting requirements for suspected child abuse or neglect.

VII. Participant Registration

1. Except as provided in Paragraph 4 below, the following types of Programs must register all participants via the BoilerBase registration portal.
   
   
   1. University-Sponsored Custodial Programs that include increased risk for physical injury, such as athletic camps, interaction with animals, ropes courses, swimming, etc.
      
      
   2. University-Sponsored Custodial Programs that include a meal, regardless of whether the food is provided by the participant or the Program.
      
      
   3. University-Sponsored Custodial Programs that include an overnight stay.
      
      
   4. Exceptions. The following types of Programs are excluded from the participant registration requirement:
      
      
      1. Noncustodial Programs;
         
         
      2. Programs that do not ask participants to register in advance;
         
         
      3. Programs that are not required to complete Program registration as outlined in Section IV;
         
         
      4. Programs for which the University has no Operational Responsibility;
         
         
      5. Programs that grant the Office of the VPEC full access to their own participant registration system and obtain an exception for this requirement in writing from the Office of the VPEC, or the VPEC’s designee;
         
         
      6. Programs that fall under the oversight of a state or federal licensing board, such as schools and daycares; and
         
         
      7. Student recruitment activities targeted to individual prospective students, such as “Official Visits” sponsored by Purdue University Athletics or scouting trips when a parent or guardian accompanies the minor.
         
         
2. Participant registration must include, at a minimum, demographic information and emergency contact information.
   
   
3. Program Directors must ensure each participant has completed registration prior to each individual being checked-in to the Program. For Programs involving an overnight stay, this verification must occur prior to the individual being given a room key and prior to the departure of the parent/guardian. No individual shall be permitted to check in if a required registration is incomplete.
   
   
4. Other Programs may utilize the BoilerBase registration portal for form management, incident reporting, or participant registration by sending a request to youthprotection@purdue.edu.

VIII. Forms, Waivers and Insurance

1. RM29 Form
   
   
   1. All Custodial Programs must require parents or guardians of minor participants to complete the RM29 form or another equivalent liability waiver as approved by Risk Management.
      
      
   2. Noncustodial Programs may need to require parents or guardians of minor participants to complete the RM29 form or another equivalent liability waiver as approved by Risk Management if an activity during the Program presents a higher than ordinary level of risk.
      
      
2. Medical Authorization Form
   
   Custodial Programs must require parents or guardians of minor participants to complete the Medical Authorization Form for any Program lasting more than four hours or where parents or legal guardians are not expected to be reasonably accessible during the Program.
   
   
3. Media Release Forms
   
   Any Program that is not required to fill out the RM29 form noted above and plans to take photos or videos of the Program participants and/or Program Staff must obtain media release forms from the subjects if the photo or video (1) is taken in a nonpublic location; (2) depicts a minor; and/or (3) will be used for promotion of the Program, in Program materials, and/or posted to an online platform that is not restricted to the Program Staff and participants only. Photos and videos include recordings and images captured during virtual meetings.
   
   
4. SAM Insurance for Third Party Sponsors
   
   
   1. Except as provided below, Sponsors that are not units of the University are required to carry at least $1M of Sexual Abuse and Molestation Liability Insurance ("SAM”) coverage and list the Trustees of Purdue University as an additional insured. The Sponsor must provide a certificate of insurance demonstrating that this requirement is satisfied at the time of Program registration and upload the certificate into the registration form. Third parties who are co-Sponsors of an event with a unit of the University must provide a certificate of insurance as described in this paragraph.
      
      
      1. Exceptions. Sponsors that do not exercise any Operational Responsibility over a Program and Sponsors that are government offices or agencies or K-12 institutions are not required to carry SAM and do not need to provide certificates of insurance.

IX. Checklist

For Custodial Programs, the following safeguards must be in place prior to or at the start of the Program (RSOs that meet the definition of a Custodial Program are exempt from this requirement, unless serving as the Sponsor or Co-Sponsor of a specific event targeted to minors that is a Custodial Program).

1. The Sponsor has designated at least one Program Director to be on site and available to the Program Staff and participants for most of the Program’s duration and at least one Program Director to be reachable and within a reasonable travel distance to the Program location when not on site.
   
   
2. The Program has a plan for participant check-in and check-out that ensures participants are only released to their parent or legal guardian or another adult designated in writing in advance by the participant’s parent or legal guardian.
   
   
3. The Program has a policy in place to eliminate private, one-to-one interactions, including electronic interactions, between a participant and Program Staff.
   
   
4. When the Program is open to participants of any age, the Program Director has a plan in place for ensuring that unaccompanied minor participants are separated from adult participants (e.g., separate classrooms, different time slots, etc.).
   
   
5. The Program has a plan in place for notifying parents or legal guardians in the event of a medical, behavioral, or other emergency. The plan must also include notifying youthprotection@purdue.edu.
   
   
6. The Program has a plan in place for addressing concerns that an individual has violated University policy or Program rules, including a process for dismissal and removal from the Program. The plan must also include notifying youthprotection@purdue.edu.
   
   
7. Arrangements have been made to ensure all activities involving minors will be supervised by an appropriate ratio of Program Staff at all times, including use of locker rooms, escorts to restrooms, transportation, etc. Refer to the American Camp Association recommendations listed on the Guidance for Youth Programs webpage.
   
   
8. If staying in University housing, the applicable campus housing authority has approved the plan for supervision of minors while in University housing.
   
   
9. When the Program includes an overnight stay:
   
   
   1. Consideration of participant’s ages is made when assigning roommates.
      
      
   2. Program Staff and adults are assigned separate rooms from minor participants when accommodations are private or semi-private rooms. A parent or guardian may share a room with their own child if no other minors are in the same room.
      
      
10. The Sponsor has the following records safeguarded and readily available by the start of the Program or, for continuously operating Programs, by the start of each Program session (electronic records and documentation in the Purdue Protection of Minors Portal are sufficient):
    
    
    1. Records cataloging the date on which each individual who will serve as Program Staff was screened according to the Registry Check requirements of these procedures (see section V above).
       
       
    2. Documentation for each individual who will serve as Program Staff certifying that the individual has completed the training requirements of these procedures (see section VI above) within the 24-month period preceding the start of the Program.
       
       
    3. All appropriate permission forms, liability waivers, media releases and medical treatment authorization forms for minors participating in the Program.
       
       
    4. A list of all Program participants (for Programs where registration of participants is required) and Program Staff, including current emergency contact information.

X. 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 start of the Program, a use of facilities or booking agreement that is in form and substance satisfactory to the University’s Office of Legal Counsel.

XI. Tools

1. Youth Protection website
2. Purdue Protection of Minors Portal
3. Incident Report form for reporting Harassment, Discrimination, and Title IX concerns.
4. Online sex and violent offender registries:
   1. Dru Sjodin National Sex Offender Public Website
   2. Indiana Sex and Violent Offender Registry
5. Templates for booking agreements with 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 Office of Legal Counsel
6. Parking information for each campus:
   1. Fort Wayne
   2. Northwest
   3. West Lafayette

XII. History and Updates to These Procedures

April 1, 2023: Updated reporting requirement language in sections II and III. In section IV, added deadline for registration, noted requirement to register Program Staff, and included equal access statement. In section V, added deadline for completing Registry Checks and clarified who can perform a Registry Check on a Program Director. In section VI, noted requirement to record/upload training documentation to the portal and added training exception for individuals who serve certain roles. Revised section VII.A (who must register participants). Expanded section IX to include Program Director availability, separation of minors and adults, and overnight stay requirements. Tweaked language throughout to align with current Program registration process.

January 15, 2022: Policy language moved to new policy on Programs Involving Minors (III.A.6). Broadened the scope of procedures to include training and/or Registry Checks for certain Programs where registration is not required. Included requirements for notification of certain events. Added training requirements for Program Directors. Added sections on Forms, Waivers and Insurance and on Program Staff and Participant Registration. Expanded the Checklist section.

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).