Protection of Minors Policy

Background

Members of the University Community are required to be familiar with the System Policy on Protection of Minors (“Policy”). These processes/procedures/guidelines supplement the Policy and implement it on the Urbana-Champaign campus.

The Policy imposes four primary duties upon Members of the University Community with respect to the protection of Minors: (1) cooperate with any university, governmental, or law enforcement investigations of alleged child abuse or neglect; (2) complete and certify completion of university-approved online training; (3) report suspected child abuse and neglect to proper authorities; and (4) undergo background checks when responsible for supervision or care of children or when duties require close contact or alone time with Minors.

Processes/Procedures/Guidelines

Definitions

“Activities” means programs and activities designed to include Minors, or for which the target audience is individuals 17 years of age or younger. Activities include but are not limited to camps, summer programs, lessons, performances, and tutoring. The following programs and activities are not considered to be designed to include Minors and do not need to be reported:

1. Programs and activities intended solely for faculty, staff, and other attendees 18 years of age or older;

2. Regularly scheduled classes or activities for enrolled university students and individuals accepted for enrollment;

3. Performances or events open to the general public (such as varsity athletic competitions, theatrical performances, and concerts);

4. Externships, internships and other placements of enrolled university students with external entities for the purpose of obtaining academic credit or to satisfy other university educational requirements;

5. Research activities approved by a University of Illinois Institutional Review Board (IRB) with safety protocols in place;

6. University Laboratory High School and Primary School classroom activities;

7. Child Development Lab classroom activities; and

8. University of Illinois Extension programs and activities with approved safety protocols in place.

“Compliance Plan” means a plan that addresses the following areas, when applicable, for Activities:

1. Transportation of Minors to and from and during the Activities, whether by parents, guardians, staff or others, in compliance with university policies regarding drivers and vehicles;

2. Weather emergencies and other non-medical emergencies;

3. Adequate supervision for Minors in accordance with the American Camp Association Supervision Ratios;

4. Educating event personnel about appropriate conduct standards with and around Minors;

5. Alerting participants about how to report issues, including issues with peers, event personnel and others;

6. Collecting and maintaining appropriate permission forms, medical contact information and liability waivers. Forms should be safeguarded and readily available. Provide a blank copy of the forms to be used with the Compliance Plan; and

7. Medical emergencies.

8. Compliance Plans must also address the following additional areas for Activities with overnight stays by Minors:

a. Describe identification to be worn by staff members and participants. Staff member identification typically involves nametags displaying name, position, and Activity. Participant identification may vary depending upon the nature of the Activity;

b. Confirm that the Illinois state curfew law (720 ILCS 5/12C-60), including the times set forth in subsection (d) (1), will be followed; and

c. Code of conduct or other conduct standards for participants.

“External Entity” means an entity legally separate from the university other than a Registered Organization or a Registered Student Organization. For example, an External Entity could include a civic group, a company, an association, or the like.

“Facility Unit” means a unit of the University of Illinois that oversees a university facility to be used by an External Entity to conduct Activities.

“Registered Organizations” (ROs) and “Registered Student Organizations” (RSOs) mean organizations defined and governed by § 2-303 of the Student Code.

“University Unit” means a unit of the University of Illinois that sponsors and conducts Activities or co-sponsors Activities with a Registered Organization or Registered Student Organization.

I. Reporting of Suspected Child Abuse and Neglect. Members of the University Community must report suspected child abuse or neglect by calling both of the following numbers:

• DCFS at 1-800-25ABUSE (1-800-252-2873)

• University Police (1-217-333-1216)

II. Activities Conducted or Sponsored by University Units

1. Reporting information about proposed Activities in advance. University Units must report information about their proposed Activities at least 30 days prior to the start date using the Protection of Minors Event Form. Late submission or submission of an incomplete form could result in delay or cancellation of the Activities. The form must include the Activity dates, times, locations, estimated attendance (age range and number of participants), and contact information for two responsible individuals who will arrange for the safety of Minors and other participants in an emergency.

2. Compliance Plan:

a. Along with the Protection of Minors Event Form, the University Unit must submit a Compliance Plan for review by the Protection of Minors Compliance Specialist in the Division of Public Safety.

b. The University Unit must enforce the Compliance Plan.

3. Background Checks

a. General requirement. University Units shall not allow any person who would be responsible for the supervision or care of Minors or whose duties would require close contact or alone time with Minors to participate in Activities without first clearing the person through a criminal background check and the sex-offender registry. Individuals who require background checks include directors and supervisors of Activities; individuals who will have one-on-one time with Minors; and individuals who will have overnight responsibilities with Minors.

b. Submission of names. University Units will submit the names of individuals who require a background check per this policy via the Protection of Minors Event Form. Once submitted online, the completed form will be automatically routed to the Unit Human Resources Contact named on the form. The Unit Human Resources Contact will enter the names of the individuals who require a background check into the university’s applicant tracking system. The Unit Human Resources Contact shall follow Illinois Human Resources Office procedures for submitting names for criminal background and sex-offender registry checks. Untimely or incomplete submission of information could result in delaying or cancelling the proposed Activity, or rendering those individuals who require background checks ineligible to participate in the Activity.

c. Clearance. Illinois Human Resources, in consultation with other relevant personnel, will determine eligibility of individuals to participate in Activities. Illinois Human Resources will work in conjunction with the Protection of Minors Compliance Specialist in the Division of Public Safety once names have been processed in the university’s applicant tracking system and will update the Compliance Specialist on the status of the check. Illinois Human Resources will also inform the University Unit whether the individuals whose names were submitted cleared the background check.

d. Exception. The Director of Public Safety may permit a unit to adopt alternative measures and safeguards instead of background checks. University Units must submit the request for such an exception to the Illinois Human Resources Office. That office will review the circumstances and consult with appropriate officials. The Director of Public Safety will document the decision in writing.

III. Activities Conducted by ROs and RSOs

1. An RO or RSO may conduct Activities in university facilities if they satisfy one of the two following conditions:

a. A University Unit agrees to sponsor or co-sponsor the Activities and the RSO or RO must cooperate with the University Unit in following all of the procedures set out in Section II, above; or,

b. The RSO or RO satisfies all the criteria outlined for External Entities in Section IV, below.

IV. Activities Conducted by External Entities Using University Facilities

1. External Entities may be permitted to conduct Activities using university facilities without the direct involvement of a University Unit provided:

a. The External Entity submits information about its proposed Activities, including the External Entity’s Compliance Plan, at least 30 days prior to the start date using the Protection of Minors Event Short Form. Late submission or submission of an incomplete form could result in delay or cancellation of the Activities.

b. The Facility Unit department head or designee concurs with the External Entity’s proposed event.

c. Facilities Use Agreement. The External Entity enters into a Facilities Use Agreement with the university before the event. Under the terms of the Facilities Use Agreement, the External Entity assumes all legal and financial responsibility for the conduct of its employees, agents, contractors, volunteers, and participants in connection with the Activities. The relevant Facility Unit must submit to the Contract Services Office a Facilities Use Agreement signed by the External Entity (templates available at the Contracts Office – urbanacso@uillinois.edu ) .

d. Insurance. The Facility Unit must collect from the External Entity a certificate of insurance evidencing general liability insurance coverage and specifically sexual molestation and abuse coverage with minimum limits of $1 million per occurrence. The certificate shall name the Board of Trustees of the University of Illinois as additional insured.

2. The External Entity must adhere to and enforce its Compliance Plan.

V. Procedures Applicable to all Activities

1. Maintaining documentation. The unit head or supervisor of the University Unit or Facility Unit, as the case may be, must make sure that all requirements of the Policy and these procedures are met. The University Unit or Facility Unit must maintain all required documentation in accordance with university information security policies and practices.

2. Site visits. The Division of Public Safety (“DPS”) may conduct unannounced site visits to promote compliance with these procedures. DPS personnel will complete a risk assessment checklist to verify Compliance Plans are being followed and will provide a copy of the signed compliance checklist to the University Unit or Facility Unit contact. All university employees must cooperate with site visits as required by DPS.

3. Violations. In the interest of safety or for failure to comply with applicable procedures, the Director of Public Safety may take appropriate action against University Units, ROs, RSOs, and External Entities conducting or sponsoring Activities. Such action may include, but is not limited to, any or all of the following: immediate cancellation of a planned or ongoing Activity, issuance of a verbal or written warning, directing immediate corrective action, prohibiting an individual or individuals from participating or continuing to participate in an Activity, and prohibiting the University Unit, RO, RSO, or External Entity from holding future Activities. In addition, individuals violating the Policy or these procedures will be held accountable for their actions in accordance with applicable law and university policies.

VI. Resources

1. University of Illinois Urbana Division of Public Safety Protection of Minors https://police.illinois.edu/services/protection-of-minors/

2. Compliance Plans https://police.illinois.edu/services/protection-of-minors/

3. American Camp Association https://www.acacamps.org/

4. Interacting with Minors https://police.illinois.edu/services/protection-of-minors/interacting-with-minors/

5. Risk Management Forms: liability waivers https://www.obfs.uillinois.edu/forms/risk-management/

6. Illinois 4-H Code of Conduct https://4h.extension.illinois.edu/sites/4h.extension.illinois.edu/files/events/documents/4-h-illini-summer-academies/code%20of%20conduct.pdf

 

Contact

For more information about these procedures, consult the following resources:

  • Workflow (Background Checks)
  • Frequently Asked Questions (Frequently Asked Questions)
  • Units unsure of whether or not their program or activity should be reported may contact the Division of Public Safety Protection of Minors Compliance Specialist at (217) 300-1533 or dps-aim@illinois.edu.
  • Units seeking information about the background check requirements may contact Illinois Human Resources at (217) 333-2137.