“Grand Valley is committed to strengthening our living, learning, and working environment by recognizing and removing the barriers to full participation and providing a safe, inclusive, vibrant community for all.”   -- Inclusiveness core value section of the University’s Strategic Plan.

Grand Valley State University is committed to being a safe and healthy environment for all.  This includes students, faculty, staff, and campus visitors, especially those who are minors.  As a public university open to everyone, the University welcomes children and teenagers on our campuses for a variety of programs and activities planned by the University or by outside organizations.  In all situations, adults are expected to be positive role models for minors, acting in a respectful and responsible manner consistent with the mission and values of the University.  To promote this vision, the University publishes and enforces policies, procedures, and guidelines that have the goal of promoting health, safety, and security for minors on our campuses. 

“Minors” are persons under the age of eighteen (18), and the term “Minor,” “Minors,” “Child,” and “Children” are used interchangeably in this policy.  Further definitions may be found below.  This policy addresses the following situations:

• A Minor will be physically present and participating in a University-sponsored program or activity, either taking place on University property or under the authority and/or direction of the University at other locations (this includes academic and sports camps);
• A Minor child will be physically present and participating in a program or activity at the University that is sponsored by a third party (this includes programs for K-12 students sponsored by a school system);
• A Minor is enrolled in one or more courses on campus, either as a matriculated student, a guest student from another institution of higher education, or a dual-enrolled student; or,
• Other events where Minors are physically present at the University, such as situations when parents/legal guardians are expected to accompany and provide supervision to Minors in their care (this includes Admissions activities and events and performances open to the public).

I.  Requirements of Programs that Involve Minors

Programs are typically workshops, sports camps, academic camps, conferences, and similar activities. Some activities that are exempt from Section I can be found in Sections III-V.

A Sponsoring Unit offering or approving a Program that involves Minors or provides University housing for Minors participating in a Program, whether utilizing University housing or not, shall abide by the following:

1. Waiver or release forms:  participation, medical treatment, use of photographs and other media:  All Minors participating in a University Program must provide a waiver or release form for participation in the program, medical treatment authorization, and use of photographs and other media by the University.  This can be one form or several, and all forms must be signed by a Parent, Legal Guardian, or Foster Parent prior to their participation in a Program. 
2. Behavior of Minors on Campus.  Minors are to be held to the same standards of behavior expected of enrolled students, as described in University policies.
3. Information maintained by Programs.  All Programs shall maintain an up-to-date list of all Program times and dates, locations, attendance information (names, ages and emergency contacts for Program Participants); list of all Authorized Adults, documentation of their training (item #5 below) and background check (item #6 below) for the Program; and a Program contact, so that in the event of an emergency, appropriate measures may be taken. All Programs must establish a procedure for the notification of a Program Participant’s Parent/Legal Guardian/Foster Parent in the case of an emergency, which might include medical or behavioral issues involving the Minor, or changes in the Program due to unforeseen and significant disruptions.  Parents/Legal Guardians/Foster Parents must also be given contact information in a manner in which the Program Participant can be contacted while the Program is in session.  All information, including release forms, shall be retained by the Sponsoring Unit for five years after the Program ends. 
4. Supervision of Minors.  All Programs must provide adequate supervision of Minors while they are on Campus. One-on-One Contact with Minors is discouraged, unless in public spaces.  In general, it is required that two or more Authorized Adult will be involved in activities where Minors are present.   Parents/Legal Guardians/Foster Parents may sign a waiver giving consent for their Child to be alone with an Authorized Adult.  (For example, if music lessons are being provided by an adult instructor.)  Exceptions in rare circumstances may also be granted (see below).
5. Training of Authorized Adults.  Each Authorized Adult, who is not the Minor’s Parent, Legal Guardian, Foster Parent or an adult designated by the Parent or Legal Guardian, who will be participating with Minors in a Program, shall complete training in the conduct and reporting requirements of this policy.  This training is given to maximize the protection of Minors from abuse of any kind.  The appropriate vice president, dean, unit head, or area director may enhance and/or supplement the required training Program to meet specific needs of the particular Program involved.  Documentation that the Authorized Adults have been trained should be maintained by a designated and identified member of the Program's Sponsoring Unit for five years.
6. Background checks of Authorized Adults.  All Authorized Adults in the Program must complete and submit the Authorization for Release of Information for Background Check form to Human Resources.  Background checks must be completed every five years.  (See also PC 10.7 Volunteers Policy, for Authorized Adults who are not University employees.)
7. Procedures for release of Minors.  All Programs must establish a procedure for the pick-up and drop-off of Program Participants, specifying times and locations.  The Authorized Adult(s) overseeing the pick-up and drop-off of Program Participants shall remain at the specified location until all Minors have been released. If a minor is not picked up, the Authorized Adult(s) will contact the parent or guardian, the program director and finally, Grand Valley Department of Public Safety if needed.

In rare circumstances, strict adherence to this policy’s requirements may not always be feasible or be the best practice for managing risk. If a Program can justify an exception in consultation with and with approval from Human Resources, or, when appropriate, obtain written consent by the Parent/Legal Guardian/Foster Parent for the parameters applicable to the Program, certain requirements under this policy may be waived. Such waivers will be considered on a case-by-case basis.

II.  Conduct Requirements of Authorized Adults

All Authorized Adults, participating in Programs and activities covered by this policy, should be positive role models and act in a caring, honest, respectful, and responsible manner.  They are required to comply with all applicable laws and University policy.  In addition, at all times, they shall:

1. In general, avoid One-on-One Contact with Minors, unless in public spaces. Two or more Authorized Adults must be involved in Programs where Minors are present unless a waiver has been signed or an exception has been granted.
2. Have separate accommodations from the Minors.  An Authorized Adult should not have One-on-One Contact by entering a Minor’s room, bathroom facility, or similar area without another Authorized Adult in attendance.
3. Not take photographs or digital images of Minors other than specified in the waiver for photography (see Section I.1).
4. Not engage in private communication not pertaining to Program matters with a Minor by email, telephone, text message, social media, or any other method at any time, except when there is a clear educational purpose and the communication is consistent with the mission of the University.
5. Not meet with Minors outside of established times for Program activities. Any exceptions require written Parent/Legal Guardian/Foster Parent authorization and must include more than one Authorized Adult from the Program.
6. In the presence of a Minor or during any University Program, not engage in any sexual activity or romantic conversations, or sexually explicit comments.
7. Not possess, have within reach and/or share sexually-oriented printed or computerized or portable materials (magazines, cards, videos, films, clothing, smartphones, etc.) in any form available to Minors participating in Programs or activities covered by this policy or assist them in any way in gaining access to such materials.  The one exception would be legitimate sexual education Programs in which the Minor’s Parent/Legal Guardian/Foster Parent have given prior written consent.
8. Not engage in abusive conduct of any kind toward, or in the presence of, a Minor.  For example, no Authorized Adult shall strike, hit, administer corporal punishment or touch in an abusive or illegal manner any Minor.  If necessary, touching should only be in the open, in response to the Minor’s immediate physical needs, for a purpose that is consistent with the Program’s mission and culture, or for a clear educational, development, safety, or health-related purpose (i.e., treatment of an injury).
9. Not possess fireworks, firearms, knives, or other weapons, unless being used for an officially sanctioned and approved instructional Program.  (See also the Weapons policy [ PC 6.27].)
10. Not transport Minors, except as specifically authorized in writing by the Minor’s Parent/Legal Guardian/Foster Parent, or in the case of an emergency.
11. Not engage in the use of alcohol or illegal drugs, or be under the influence of alcohol or illegal drugs, during such Programs or activities.  (See also the Alcohol and Other Drugs policy [ PC 5.1].)
12. Respect and adhere to any resistance from the Minor unless it is a life- threatening emergency.
13. Not continue to participate in Programs or activities if an allegation of prohibited or illegal conduct has been made against an Authorized Adult covered by this Policy until such allegation has been satisfactorily resolved and future participation in Programs is permitted by the University.
14. Not engage in any activity that violates the policies of the University ( www.gvsu.edu/policies).  This includes the harassment policies [ PC 9.1], the Sexual Misconduct policy [ PC 9.1], and the Religious Inclusion policy [ PC 9.6].

Those who do not meet the prescribed standards of behavior may be asked to leave the Campus and/or Program and may be subject to expulsion from the Program, suspension of attendance, being issued a “no-trespass” order by Public Safety, or disciplinary action up to and including termination of employment.  (See also Section VII of this policy.)

The behavioral requirements in this policy are not meant to preclude enrolled University students from developing appropriate friendships with Minors who are close in age to the enrolled student; rather, the requirements are meant to protect Minors from abusive or illegal contact and inappropriate relationships. 

III.  Third Party Programs Held on University Property

Third Parties using University facilities for events that involve Minors shall operate within all policies and requirements to use University facilities.  In addition, adults who interact with Minors in these activities shall conform to the conduct requirements in Section II of this policy. 

IV.  Minors Enrolled in Courses

Minors who are matriculated students of the University, guest students from other institutions, or dual-enrolled students are subject to all university policies.  Adults who interact with Minor students (e.g. faculty teaching courses, academic advisors) are also subject to all university policies and shall conform to the conduct requirements in Section II of this policy.  The requirements of Section I of this policy do not apply.

V.  Minors at the University Who Are Not Participating in a Program

1. Minors brought to Campus by an employee, student, or visitor, and who are not participating in a Program by a Sponsoring Unit, are the sole responsibility of the employee, student, or visitor.  The person bringing the child to Campus is responsible for all aspects of the Minor’s behavior including the Minor’s safety and is financially responsible for any damages caused by the Minor.
2. Minors are permitted at events and venues open to the public.  However, the University reserves the right to determine, in its sole discretion, whether selected events or venues are appropriate for unescorted or unsupervised Minors.
3. In the event a Minor is on Campus and 1) is unsupervised by an adult, 2) they are not a Participant in a University Program, and 3) they are not a Participant in a Third Party Program (Section III), they may be required to leave the Campus.

Activities for which this Section V of the policy is relevant include:

• Events or performances on Campus that are open to the general public (e.g., athletic competitions, plays, concerts);
• Pre-enrollment visits such as admission, recruiting, and orientation events;
• Services provided by the Campus Health Center or other similar On-Campus clinical services during which a Minor is under the supervision of a Parent/Guardian/Foster Parent or a clinical provider;
• Non-residential field trips to Campus supervised by a Minor’s school or organization;
• Private, personal events (e.g., birthday parties, weddings) for which the user has a separate, signed agreement with the University to use space on Campus.

The following activities are exempt from this policy:  Off-campus clinical, practicum, internships, student teaching, or similar experiences in which (1) University students (undergraduate or graduate) interact with Minors as part of the experience and (2) are supervised by a third party.  This also includes Off-Campus events in which registered student organizations participate with third-party organizations.

VI.  Reporting Requirements

Reporting requirements of suspected child abuse or other illegal conduct towards a Minor shall be in accordance with applicable federal, state and local laws.  In particular, see:

• State of Michigan Department of Health and Human Services rules on reporting abuse and neglect.  (This page includes indicators of child abuse and/or neglect and the State of Michigan’s definition of “Mandatory Reporters”.)

Individuals who witness or suspect child abuse should not conduct an investigation or delay in notifying the appropriate authorities via 911.  Such actions could taint any appropriate criminal or administrative investigation and render evidence inadmissible.

In addition, the University’s Police Department/Public Safety site provides up-to-date definitions of unlawful behavior:  https://www.gvsu.edu/gvpd/title-ix-and-campus-security-authority-report-141.htm

VII.  Additional Considerations

1. When an Authorized Adult or other person has been alleged to engage in inappropriate conduct with a Minor, that individual must discontinue any further participation in Programs covered by this policy until such allegation has been satisfactorily resolved and the individual has been given written permission by the University to participate again in Programs.  Resolution of the allegation will involve appropriate investigatory steps, and any written permission to continue participation (or participate in the future) in a Program covered by this policy must be coordinated with Human Resources.
2. Any person that requires accommodations due to a disability, while visiting campus must inform the Sponsoring Unit of their needs.

VIII.  Interaction with Other Standards, Practices, and Requirements

Nothing in this policy is meant to supersede or replace the standards of practice of other entities in responding to child abuse, suspected incidents of child abuse or threats of child abuse.   Satisfying the requirements of this policy does not relieve a person from any obligation to follow the protocols of another entity that may apply to the particular incident. Individual University units maintain the discretion to impose safety measures beyond those required by this policy on University Programs they sponsor or oversee.  Additionally, all state and federal requirements must be followed.

Human Resources may develop forms and guidelines to assist Programs that wish to work with Minors on Campus.  In addition, Human Resources will conduct random audits annually to ensure compliance with this policy.

Definitions

1.         “Authorized Adult” is an individual, age 18 and older, paid or unpaid, who supervises, chaperones, or otherwise works with Minors in Program activities, or recreational, and/or residential facilities.  This includes but is not limited to faculty, employees, student employees, staff, volunteers, graduate and undergraduate students, interns, teachers, employees provided by temporary agencies, third-party hosts, and independent contractors/consultants.  The role of Authorized Adult may include positions such as counselors, chaperones, coaches, instructors, and other similarly situated persons.  Temporary guest speakers, presenters and other individuals who have no direct contact or only incidental contact with Program Participants, other than as short-term activities supervised by Program staff, are not considered Authorized Adults but are still expected to conform to the conduct requirements in Section II of this policy.

2.         “Campus” includes all domestic real property owned or leased by the University and can include any of its campuses.

3.         “Parent” is the natural Parent or adoptive Parent as recognized under the law, of a Minor child whose parental rights and responsibilities have not been terminated under applicable law.  “Legal Guardian” is any person appointed under applicable law to have the care and management of the person, the estate, or both of a Minor.  “Foster Parent” is a person appointed by the court to temporarily provide the care and management of the minor child.

4.         “One-on-One Contact” is personal, unsupervised interaction between any Authorized Adult and a single Program Participant Minor without at least one other Authorized Adult, Parent or Legal Guardian being present. Unless in public spaces, such contact is to be avoided by all adults on Campus, whether considered an Authorized Adult under this policy or not.

5.         “Program” or “Programs” are programs and activities offered by various academic or administrative units of the University, whether on University property or not, that potentially will include Minors as Program Participants. This includes but is not limited to workshops, sports camps, academic camps, conferences, and similar activities.

6.         “Program Participants” are Minors who are involved in University-sponsored Programs both on and off Campus.

7.         “Sponsoring Unit” is the academic or administrative unit of the University that offers a Program or gives approval for housing or other use of facilities.

Much of the text of this policy was adopted with permission from a similar policy at the University of Dayton.