Protecting Minors Participating in College Programs and Activities

Purpose and Scope

The purpose of this policy is to promote the health, wellness, safety and security of children who are entrusted to the College for Creative Studies’ (CCS) care, custody and control or who participate in Programs held on CCS property. The College requires all administrators, health care providers, faculty, staff, students and volunteers working with Minors in College Sponsored Programs or in Programs for Minors held on College property to comply with this policy.

All Programs and activities that involve Minors will fall within the scope of this policy including: Programs operated by the College or non-College Sponsored Programs, Programs taking place on campus, and Programs under the direction and authority of the College at locations off campus. This policy applies to such Programs and activities whether they are limited to daily activities or involve the housing of Minors in campus housing.

This policy does not apply to: (1) Minors enrolled or accepted for enrollment in a degree program at the College; (2) events on campus that are open to the general public and which Minors attend at the sole discretion of their parents or guardians; (3) youth programs whose format requires the participating Minor to be accompanied at all times by a parent, legal guardian, or other adult relative.

Definitions

A. Authorized Adult or Program Staff: Individuals, paid or unpaid, who interact with, treat, supervise, chaperone, or otherwise oversee Minors in Program activities. This includes but is not limited to faculty, staff, volunteers, graduate and undergraduate students, interns, employees of temporary employment agencies, and independent contractors/consultants. The Authorized Adult or Program Staff’s roles may include positions as counselors, chaperones, coaches, instructors, health care providers, etc. For the purposes of this policy the term “Program Staff” is also assigned this definition. This definition does not include temporary guest speakers, presenters or other individuals who have no direct contact with Program participants other than short-term activities supervised by Program Staff.

B. College Facilities: Facilities owned by or under the control of the College including housing and Program space.

C. College Sponsored Programs: Programs that are directly managed by College faculty, staff, and Sponsored Student Organizations on behalf of the College.

D. Direct Contact: Providing care, supervision, guidance or control of Minors or having routine interaction with Minors.

E. Minor: A person under 18 years of age (MCL§ 722.1(a)) who is not enrolled or accepted for enrollment in a degree program at the College. However, a person under 18 years of age who is considered to be “dually enrolled” in College Programs while also enrolled in elementary, middle or high school is considered a Minor covered by this policy.

F. Non-College Sponsored Programs: Programs that are not operated on behalf of the College or under the College’s control.

G. One-on-One Contact: Personal, unsupervised interaction between any Authorized Adult or Program Staff and a participant without at least one other Authorized Adult or Program Staff, parent or legal guardian being present.

H. Program: Programs or activities offered by various academic or administrative units of the College, or by non-College groups using College facilities where the parents or legal guardians are not responsible for the care, custody or control of their children. This includes, but is not limited to workshops, services, camps, conferences, and similar activities.

I. Program Administrator: The person(s) who has primary and direct operational responsibility for managing a Program.

Criminal Background Checks

A. Requirements

All individuals who have unsupervised access to minors at a youth program are required to submit to an initial criminal background screening (including sex offender registry check). Returning Authorized Adults or Program Staff are required to submit to a criminal background screening every two years, thereafter. Criminal background checks must be completed and evaluated before the Authorized Adult or Program Staff may begin working with Minors. The Human Resources office will administer the criminal background screening.

Program Administrators of non-CCS Sponsored Programs are required to certify that they have conducted criminal background checks and determined the fitness for all Authorized Adults and Program Staff before being allowed to use or lease College facilities.

B. Exceptions

• CCS students hosting siblings or other family members during campus events (e.g., sibling weekend) are not required to have a criminal background check.
• CCS students hosting high school students as part of a pre-enrollment visit for prospective students are not required to have a criminal background check.
• CCS students who attend a youth program in order to work or volunteer under the direct supervision of a CCS employee are not required to have a criminal background check.
• Individuals under the age of 18 who volunteer or work under the direct supervision of a CCS employee are not required to have a criminal background check.
• External organizations using CCS facilities open to the general public are not required to provide certification of criminal background checks, even if minors are present.
• Youth programs that involve large numbers of one-time volunteers are exempt from the criminal background check requirement for volunteers if the volunteers work only in public spaces and with supervision by a full-time CCS employee. Such youth programs are required to compile a list of all volunteers prior to the event, check the names of all volunteers against the Michigan sex offender registry database, and require photo identification from volunteers at the start of the program.

C. Criminal Background Check and Sex Offender Registry Results

The following types of convictions will render an individual ineligible to work or volunteer for the College’s youth programs:

• Drug distribution activity or felony drug possession
• Sexual offenses
• Crimes of violence involving physical injury to another person
• Child abuse, molestation or other crimes involving child endangerment
• Murder
• Kidnapping
• Any other crime involving moral turpitude

Operational Requirements

A. Program Handbook

An office/department sponsoring a youth program must develop and distribute a program handbook to participants and their parents/legal guardians. The program handbook must include the following information:

1. Procedures for notifying a minor’s parent/legal guardian in case of emergency, including medical or behavioral situations.
2. Information for parents/legal guardians on how to contact the participant during the program.
3. Program rules, including conduct expectations, for participants in the program, including the fact that participants must abide by all College regulations and may be removed from the program for violation of such rules. Program rules must include the following:
   • Prohibition against the possession or use of alcohol, tobacco, drugs, fireworks, guns, and other weapons.
   • Rules about when participants may leave campus during the program.
   • Statement that no violence of any kind will be tolerated.
   • Statement that sexual harassment, sexual abuse, and other sexually inappropriate conduct will not be tolerated. (Title IX Policy)
   • Statement that harassment in violation of the CCS Non-Discrimination Policy will not be tolerated.
   • Statement that hazing and bullying (physical, verbal, or cyber-bullying) will not be tolerated.
   • Statement that misuse or damage of College property is prohibited and participants may be financially responsible for damage or misuse of CCS property.
   • Prohibition against cameras and other digital recording devices in showers, restrooms, locker rooms, and other areas where privacy is expected by participants.
4. A description of the process to be followed if a participant, group leader, or other individual associated with a youth program is alleged to have violated College policies or conduct rules of the program, including the process for dismissal and removal from the program.
5. A description of the process to be utilized for the parent, legal guardian, or other responsible adult to pick up the participant if he/she is dismissed from the program early.
6. Housing specific policies, if applicable, addressing:
   1. Curfew time that is age-appropriate for participants;
   2. In-room visitation by participants of the opposite gender;
   3. Visitation by non-participant guests; and
   4. Whether separate accommodations are provided for adults and minors.
7. Statements describing how requests for accommodation may be made for participants with disabilities.

B. Program Requirements

Offices/Departments are expected to adhere to the following program requirements when conducting youth programs:

• Utilize the standard medical treatment authorization form for all participants.
• Utilize the standard media release and parent/guardian consent form for all program participants as part of the registration process.
• Provide adequate supervision for minors during the program. In determining the appropriate level of supervision, the program will consider the number and age of participants, the activities involved, and the age and experience of staff / volunteers.

C. Annual Staff Training

Youth programs are expected to provide annual training to program staff and volunteers that addresses the following topics:

• Program responsibilities and expectations
• Protecting Minors Participating in College Programs or Activities
• Authorized Adult or Program Staff Conduct Rules
• Sexual Misconduct Policy (Title IX)
• Transportation of Minors
• What to do in the event of a criseis or emergency
• Safety and security precautions
• Prohibited harassment and reporting obligations
• College reporting protocols for suspected child abuse, sexual assault, or child pornography

D. Conduct Rules for Authorized Adults (Youth Program Staff and Volunteers)

Authorized Adults or Program Staff should be positive role models for Minors, and act in a caring, honest, respectful and responsible manner that is consistent with the mission of the College. Authorized Adults or Program Staff are required to comply with all applicable laws and College policy. Authorized Adults or Program Staff working in Programs covered by this policy must follow these expectations to avoid conduct that could cause harm or be misinterpreted:

• Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material with Minors or assist in any way to provide access to such material to Minors.
• Do not engage or allow Minors to engage you in romantic or sexual conversations, or related matters, unless required in the role of resident advisors, counselors, or health care providers.
• Do not touch Minors in a manner that a reasonable person could interpret as inappropriate. Touching should generally only be in the open and in response to the Minor’s needs, for a purpose that is consistent with the Program’s mission and culture, or for a clear educational, developmental, or health related purpose (i.e., treatment of an injury). Any resistance from the Minor should be respected.
• Do not use profanity, vulgarity, or harassing language.
• Do not be alone with a single Minor. If One-on-One interaction is required, meet in open, well illuminated spaces or rooms with windows observable by other Authorized Adult or Program Staff, unless the One-on-One interaction is expressly authorized by the Program Administrator or is being undertaken by a health care provider.
• Do not meet with Minors outside of established times for Program activities. Any exceptions require written parental authorization and must include more than one Authorized Adult or Program Staff.
• Do not invite Minors to your home or other private locations.
• Do not provide gifts to Minors or their families independent of items provided by the Program.
• Do not engage or communicate with Minors through email, text messages, social networking websites, phone, internet chat rooms, multiplayer online games, or other forms of social media at any ?time except and unless there is an educational or Programmatic purpose and the content of the communication is consistent with the mission of the Program and the College.
• Do not engage in any abusive conduct of any kind toward, or in the presence of, a Minor, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. If restraint is necessary to protect a Minor or other Minors from harm, all incidents must be documented and disclosed to the Program Administrator and the Minor’s parent/guardian.
• Do not use, possess or be under the influence of alcohol or illegal drugs while on duty, or in the presence of Minors involved in a Program, or when responsible for a Minor’s welfare.
• Do not provide alcohol or illegal drugs to a Minor.
• Do not provide medication to a Minor unless authorized by the Program’s medication management guidelines.
• Do not possess any type of weapon or explosive device.

E. Reporting Protocols

Youth program staff, volunteers, and other individuals associated with a youth program must report child abuse, sexual assault, and child pornography.

All members of the College community are encouraged to report the presence of unaccompanied minors on campus, as well as any inappropriate conduct by a minor and an accompanying adult to CCS Campus Safety [Tel: 313.664.7444 (Ford Campus) or 313.664.1444 (Taubman Center)].

All employees serving as Authorized Adults in CCS sponsored Programs should be aware that they are “mandatory reporters” under Michigan’s Child Protection Law, MCL §722.621, et seq., and must report to the Michigan Department of Health and Human Services (855-444-3911) all instances where they have reasonable cause to believe a child is suffering child abuse or child neglect, as defined in the Child Protection Law. All such employees should contact the Vice President for Enrollment and Student Services immediately at 313-664-7494 or 734-634-6258 (cell) in the event they become aware of or concerned about such abuse or neglect for assistance in making all required reports under Michigan law.

In addition, all employees serving as Authorized Adults in CCS-sponsored programs are “Campus Security Authorities” under the College’s Policy on the reporting of crimes pursuant to the Jeanne Clery Disclosure and Campus Security Policy and Campus Crime Statistics Act (the “Clery Act”) and should review the CCS Policy on Crime reporting found at https://campus.collegeforcreativestudies.edu/policy/reporting-criminal-and-other-serious-incidents/.

F. Transportation of Minors

College employees should not transport minors except in the case of emergency and only if the following requirements are met:

• College employees and volunteers that transport minors must have been subject to a Michigan driver records check within the last twelve months and must have zero points on their driving record.
• Although the use of private vehicles for transporting minors should be avoided, when private vehicles must be used, drivers must have automobile liability insurance.
• More than one adult must be present in the vehicle.