DRAFT:  UNH Policy for the Protection of Minors  (February 24, 2014)

The University of New Hampshire is committed to providing a safe environment for all persons, including but not limited to children, and to prevent and respond to abuse, neglect and crimes against children. All UNH staff (faculty, employees, students and volunteers) directly serving minors in youth programs  shall be required to attend job specific training on child safety and shall be subject to periodic criminal background records checks.

UNH shall appoint an ongoing working group to perform an annual review of industry best practices and regulations applicable to programs serving minors.  This group shall review policy, recommend changes to Cabinet, and communicate these changes to UNH Youth Program Managers to be instituted in UNH programs that serve children.   UNH will appoint a training team to develop and provide trainings to UNH Youth Programs whose departments provide programs or services to minors.   

UNH staff serving minors who have any reason to suspect abuse or neglect of a child participating in a UNH program shall follow all applicable state laws and procedures to report abuse (see Resources below).

UNH shall include child safety procedures in any contracts or agreements 1) with outside organizations that rent or use UNH facilities and services, and 2) with outside contractors and their employees who provide services on UNH property.   

Exemptions:

       The UNH Child Study and Development Center is exempted from this policy, as it meets state and federal accreditation standards for day care centers.

       Minors who are UNH students are not provided protection under this policy.

       This policy does not apply to UNH students who are placed at external institutions for the purposes of academic credit, for clinical experience or student teaching, or to participate as visiting instructors and volunteers.  UNH staff and students in these placements will follow the policies and procedures for the protection of minors in place at the hosting institution or program.

1.     Definitions

For purposes of this policy, the definitions of child abuse and neglect shall be those contained in NH RSA 169-C, as amended.

Minor- a person under the age of 18 years old (not including a UNH student) who is attending a UNH youth program

UNH youth programs with minor participants– day or overnight programs where minors participate in activities sponsored by UNH, whether accompanied by parent/guardian or supervised by UNH staff, occurring on or off campus. These programs include either:

       UNH sponsored events which are specifically intended for minors up to age 18

            or

       UNH sponsored events or facilities which are open to the general public

Sponsoring department – the UNH department or program delivering the activities to participants who are minors

UNH staff serving minors

       Employees, faculty, students and volunteers who either:

       are primarily responsible for minors at UNH programs and events when the minors are not accompanied by a parent or guardian

or

       have access to minors at UNH programs and events, when the minors are in the care of a parent, guardian, or other responsible adult

UNH Youth Program Manager

            Employees, faculty, students or volunteers who manage or direct UNH programs         designed for participation by minors. The UNH Youth Program Manager is      responsible for complying with this Policy and the UNH Procedures for the             Protection of Minors.

 

2.   Procedure for implementation of policy

            2.1 Any UNH department which sponsors programs or events that minor children could attend shall require their UNH staff to comply with this Policy and UNH Procedures for the Protection of Minors, following the minimal requirements for public UNH events and facilities where minors could be present, and where UNH staff may have access to minors who are in the care of a parent, guardian or other responsible adult.

            2.2  UNH Youth Program Managers and supervisors in UNH programs specifically intended to include minors are required to incorporate the UNH Procedures for the Protection of Minors for the recruitment, screening, training, and supervision of their employees and volunteers, the reporting of child abuse and neglect, and shall attend training on managing programs for minors at UNH.    Each program shall determine and establish program guidelines consistent with industry best practices for the type of program delivered (day program, overnight program, events where children are accompanied by adults).  

 

3       Training in Working Safely with Children

3.1   UNH Youth Program Managers shall receive training on how to instruct their UNH staff serving minors to work safely with children.

 

3.2   Training for UNH staff who are primarily responsible for minors in provision of direct services:  Any faculty or staff member or volunteer serving as a counselor, coach, program leader, Resident Assistant, teacher, etc. who has direct unsupervised responsibility for children, and is primarily responsible for children who are unaccompanied by a parent/guardian during the UNH program shall receive program-specific training on at least the following topics:

a.  Review of the UNH Policy and Procedures for the Protection of Minors

b. Youth program guidelines, specific to the population and program area, including:

1.     Coordinating safety in a multi-use UNH property

2.     Definitions of child abuse and neglect – signs to look for   

3.     How to respond to incidents or reports of abuse or neglect

4.     Ratios of children to staff

5.     Effective age-appropriate program design

6.     How to work safely with children in your program

7.     Appropriate and prohibited behaviors around children

8.     Supervision during non-structured time and transitions

 

3.3   Training for UNH Staff with unsupervised access to minors-

Any UNH employee or volunteer serving the public at any UNH property where minors may be present shall receive training from their Program Managers on at least the following topics:

a.      Review of the UNH Policy and Procedures for the Protection of Minors

b.     How to work safely around children

c.      How to respond to and report suspected child abuse or neglect

d.     Appropriate behaviors around children

 

4.  Supervision of UNH Staff in programs serving minors

4.1       UNH Youth Program Managers shall provide regular supervision to all UNH staff with unsupervised primary responsibility for minors, and shall manage all program details appropriate for the age of the participants, following best practices for the type of youth program being delivered.   Responsibilities of the UNH Youth Program Manager or designee include at minimum:

a.      Instituting child sign in and sign out procedures;  monitoring when children arrive and depart from UNH programs

b.     Ensuring adequate staff-to-children ratios for the ages and populations  served

c.      Recruiting, training and supervising all UNH staff serving minors

d.     Managing periodic criminal record background checks of all staff with primary responsibility for minors attending UNH youth programs

e.      Overseeing program facilities

f.      Assure supervision of minors at all times by a responsible adult, when untrained adults are present

g.     Performing periodic unannounced visits to program sites to observe activities

h.     Promptly responding to any suspicious or improper activity and report to authorities if needed

i.       Overseeing all communication with parents/guardians

j.       Assuring compliance with COPPA and UNH IT policies regarding children’s privacy

k.     Conducting observations and monitoring staff performance

5.  Non-UNH Employee Procedures

5.1   For Non-UNH groups serving minors that use UNH Facilities or attend UNH-sponsored events:

5.1.1   UNH contracts shall specify that, while the University acts as landlord for the event, the sponsoring organization is responsible for safety of minor children attending their program. The sponsoring organization is required to obtain their own insurance, including coverage with no exclusions or sub-limits for incidents arising from sexual misconduct (including, but not limited to, sexual molestation, sexual assault, sexual harassment, dating violence and stalking). 

5.1.2   The sponsoring organization shall confirm that they follow internal child       safety policies according to best practices for their type of program. 

5.2   For outside contractors and their employees who provide services to UNH programs and facilities where minor children may be present:

5.2.1  UNH contracts shall specify that the vendor will follow the same standards as detailed in the UNH Policy for the Protection of Minors for the screening, training and supervision of their employees who work at UNH where minor children may be present.

5.3   UNH Programs serving minors who engage untrained and unscreened guest speakers, instructors, or volunteers to work with minors in the course of the UNH program shall provide continuous supervision for the duration of the program from UNH Youth Program staff who have been trained in compliance with this Policy and the Procedures for the Protection of Minors.

At no time shall minor children attending a UNH program be left under the supervision of an outside consultant who has not attended UNH Youth Program training and has not completed a criminal background check. 

6.  Resources –

            UNH Webpage for Youth Programs, including Procedures for the Protection of Minors and training information (link)

Emergency Response Procedures for Reporting Abuse:

               UNH Police Department: 911 or (603) 862-1427

               NH DCYF Central Intake Office 1-800-894-5533 or 603-271-6556.

                        After regular business hours, child abuse emergencies are referred to the local law enforcement agency.

Durham, NH Police Department: 911 or 603-868-2324

Manchester, NH Police Department: 911 or

NH Statewide Sexual Violence Hotline: 1-800-277-5070

NH Statewide Domestic Violence Hotline: 1-886-644-3574

           

Ongoing Support:

Strafford County NH Child Advocacy Center: 603-516-8100

Community Partners Mental Health 603-335-6470

Seacoast Mental Health 603-436-6703

UNH SHARPP 24/7 Helpline - (603) 862-SAFE (7233) or (888) 271-7233

                                       Office: (603) 862-3494

UNH Affirmative Action and Equity Office: 603-862-2930

UNH Counseling Center: 603-862-2090

UNH Health Services: 603-862-1530

UNH Human Resources 603-862-0500

NH Department of Environmental Safety- for regulations regarding youth camps

http://des.nh.gov/organization/divisions/water/dwgb/youthcamps/index.htm

 

NH 2013- law requiring background checks for staff at Youth Skills Camps

http://www.gencourt.state.nh.us/legislation/2013/HB0295.html

(add administrative rules when available).

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