Policy for Programs Involving Minors

This policy incorporates, where applicable, specific obligations that were developed as part of this policy initiative:  the Standards of Behavior with Minors, the Rules and Procedures for Minors in Research Facilities and the Roles and Responsibilities for Chaperones

Responsible Executives:
Dean of the Faculty and the Executive Vice President
Responsible Office(s):
Conference and Event Services with support from the Minors Oversight Committee
Contact(s):
Conference and Event Services Director, 609-258-3371 or minors@princeton.edu

Effective Date: 9/3/2019

I.    Policy Statement

Princeton University is dedicated to the welfare and safety of all individuals who participate in its programs and activities. The University has particular concern for Minors, defined as any individuals under the age of 18 years old, who are not matriculated college students at Princeton University or elsewhere. Princeton University expects that all faculty, staff, students and volunteers who interact with Minors on campus, and/or who are participating in Princeton activities, will foster and maintain an appropriate and secure environment. This policy provides the framework that programs are required to follow in order to facilitate successful and safe programming. It establishes standards, procedures for reporting suspected abuse or neglect of Minors, and obligations for the operation of Covered Programs, defined below, which include registration, background checks and training. 

Princeton University expects parents/guardians or Chaperones to provide appropriate supervision over Minors unless they are participants in a Covered Program. 

II.    Who Is Affected By This Policy 

This policy applies broadly to all University faculty, staff, students and volunteers who interact with Minors on campus or under a Covered Program. Some examples include, but are not limited to, private lessons or tutoring, athletic camps, and research and educational internships.

III.    Definitions

A.  Adult: For purposes of this policy and corresponding requirements, an Adult is an individual who is 18 years old or older, or a matriculated college student at Princeton University or elsewhere. 
B.  Care, custody and control:  The responsibility level when an Adult, who is not the parent/guardian, is present and has supervisory responsibility for one or more Minors as well as the knowledge of the general location (particularly when leaving the building) of each Minor at any given point throughout a Covered Program.
C.  Chaperone:  An individual(s), such as a teacher during an academic program, who is not a Princeton University faculty or staff member, student, volunteer, or a parent/guardian, but is responsible for the care, custody and control of one or more Minors. For additional information, please see the Roles and Responsibilities for Chaperones. 
D.  Covered Program: Any program or activity operated or conducted by the University, whether on or off campus, including overnight or daytime stays, where the care, custody and control of Minors is the responsibility of University faculty, staff, students or volunteers. Covered Programs include but are not limited to outreach and community service activities.

Covered Programs do not include the following. See Section VII for specific requirements and policies related to the following:

i.    Events or activities that are open to the general public, and/or where parents/guardians are expected to provide supervision;
ii.    Events or activities where parents/guardians or Chaperones are explicitly required to accompany Minors; 
iii.    Institutional Review Board-approved research that involves Minor participants; 
iv.    Employment of 16- and 17-year-olds through Human Resources; and/or
v.    Admitted or prospective student programs.

E.  Minor: For purposes of this policy, a Minor is defined as any individual under the age of 18 years old, who is not a matriculated college student at Princeton University or elsewhere. 
F.  Minors Oversight Committee: A subcommittee of the Environmental Safety and Risk Management Committee (ESRM), which will monitor the administration of this policy and provide annual reports to the ESRM. 
G.  Program Staff: University faculty, staff, students and/or volunteers who are responsible for, supervise or otherwise oversee the care, custody and control of Minors in Covered Programs. 
H.  Research Facility: Any facility used for conducting research and/or experiments. For the purposes of this policy, a Research Facility may include or be adjacent to hazardous operations, hazardous equipment and/or materials, machinery or field research. For additional information, please see Section IV. (D) and the Rules and Procedures for Minors in Research Facilities.

IV.    Policy

A.    Standards of Behavior with Minors
Adults must follow the Standards of Behavior with Minors when interacting with Minors under a Covered Program.

B.    Reporting Obligations under State Law
All faculty, staff, students and volunteers who have reasonable cause to believe that a Minor has been subjected to child abuse or acts of child abuse are required under New Jersey law to report the situation to: 

  1. The New Jersey Division of Youth and Family Services and
  2. Under this policy, to the Princeton University Department of Public Safety (DPS). 

For any other crimes or in emergencies, contact 911 or 609-258-3333 for DPS. 

C.    Obligations for Covered Programs
Covered Programs have an obligation to protect the safety of participants in programs involving Minors. Program Staff must follow this policy, including the procedures established in Section V below and any others established by the Minors Oversight Committee.

Covered Programs must: 

  1. Provide care, custody and control.  At least one Adult must have care, custody and control of the Minors during a Covered Program.
  2. Register. All Covered Programs must register with the University. 
  3. Perform Background Checks. All Program Staff must successfully complete University-provided background checks prior to working on Covered Programs.
  4. Train. All Program Staff must complete University-provided training, which includes the obligation to review and agree to abide by the Standards of Behavior with Minors. 

D.    Minors in Research Facilities
Minors, including dependents of faculty, staff or students, are prohibited from entering Research Facilities except as outlined in the Rules and Procedures for Minors in Research Facilities. Faculty, staff and students must follow the Rules and Procedures for Minors in Research Facilities.

V.    Procedures for Covered Programs 

Registration, background checks and training must be completed before a Covered Program begins.  

A.    Registration

It is expected that 60 days prior to the start of the program, Program Staff shall register the Covered Program, when possible. In order for the University to know when and where Minors are being hosted on or off campus, Program Staff must provide the information requested.  All registered programs will be provided with additional information to help host a successful program. A description of the program, expected age range and estimated attendee count are examples of the types of information that the University requires at the time of registration. 

B.    Background checks

Prior to a Covered Program commencing, all Program Staff are required to successfully complete a University-provided, confidential background check. Minimum background check requirements include:

1.    Completion before each Program Staff member joins a Covered Program; 
2.    Multi-state and county criminal checks including checks of the National Sex Offender Registry; and
3.    Performance on at least an annual basis.

C.    Training

All new Program Staff must complete University-provided training prior to the program start date.  Previously-trained Program Staff are required to complete refresher training in subsequent years as determined by the Minors Oversight Committee.  At a minimum, the training must include:

i.    Responsibilities of Program Staff and protocols in place in case of an injured Minor and/or emergency situations;
ii.    Recognizing the basic signs of physical, emotional, sexual abuse and neglect;
iii.    Reporting suspected child abuse and neglect including who must report, when to report and protection for good-faith reporting;
iv.    How to help prevent child abuse;
v.    Appropriate ratio of Adults to Minors; 
vi.    The Standards of Behavior with Minors; and
vii.    All the requirements of this policy.

VI.     Exemption

Program Staff may request that their program be granted a specific exemption from part or all of this policy in advance of the Covered Program taking place. A written request and justification must be sent to the Minors Oversight Committee (minors@princeton.edu) more than 60 days prior to the commencement of the Covered Program. All exemption requests must be approved by the Minors Oversight Committee.

VII.    Other

A.    Hiring. For employment of 16- and 17-year-olds, follow the HR Employment of Minors Policy and the Rules and Procedures for Minors in Research Facilities.  
B.    Admitted or prospective student programs. The Admission Office staff member responsible for programs for admitted or prospective students and the Athletics Department staff member responsible for prospective student-athlete visits, must:

a.    register with the University; 
b.    distribute the Standards of Behavior with Minors to all Princeton student hosts; and, 
c.    notify the Department of Public Safety by providing lists of all overnight locations.

C.    Chaperoned programs. Programs where Chaperones are expected to provide care, custody and control should be registered with the University and Chaperones should review and comply with the Roles and Responsibilities for Chaperones. Events open to the public do not need to register.

VIII.     Accountability 

All University faculty, staff, students or volunteers who interact with Minors must report potential violations of this policy to one or more of the offices of Human Resources, Dean of the Faculty, the Minors Oversight Committee, or to the University Hotline (reports to the Hotline can be made anonymously). Faculty, staff, students or volunteers who fail to comply with this policy may have their program canceled and reported to the appropriate University department. Faculty, staff, students or volunteers may face additional repercussions related to their reporting obligations under federal, state and local laws as well as University policy.

The Minors Oversight Committee will guide and monitor the University’s implementation of this policy. The Minors Oversight Committee will submit an annual report to the ESRM Committee.    

IX.     Related Policies and Resources 

Rights, Rules, Responsibilities Section 1.2.6

Employment of Minors – HR Policy 2.1.3
Standards of Behavior with Minors  
Rules and Procedures for Minors in Research Facilities 
Roles and Responsibilities for Chaperones 
Website for Programs Involving Minors

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