I. General Definitions
For the purposes of this policy, the following terms are defined as follows:
A. Authorized Adult
“Authorized Adult” means all individuals or employees, paid or unpaid, who may interact with, supervise, chaperone, or otherwise oversee minors in program or recreational activities, and/or residential facilities. This includes but is not limited to faculty, staff, volunteers, graduate and undergraduate students, interns, and alumni.
“Minor” is any individual under the age of 18.
“Program” is defined in this policy as any activity, event, lesson, or class involving a minor, including programs sponsored or operated in whole or in part by the College, on or off campus where a College employee exerts some level of control over the event.
D. Program Sponsor
Each Program must identify a College employee to serve as a liaison for the group.
Authorized Adults who interact with, and have access to, minors are classified in these policies as having high or low access:
Individuals with high access with minors.
Authorized Adults with high access to minors include any individual who:
- is involved with or supervises the care, supervision, guidance or control of minors; or
- has routine interaction with minors; or
- works with or around minors on a program(s) that meets regularly or involves multiple interactions; or
- has the potential for unsupervised access with one minor; or
- is responsible for supervising minors; or
- is a consistent and regular volunteer for programs involving minors; or
- interacts with minors on a frequent basis.
Examples of individuals with high contact with minors may include:
- instructors, mentors, tutors, counselors, coaches and their assistants;
- individuals who regularly engage in volunteer opportunities on behalf of the College that involve minors;
- individuals who transport minors (on campus or on field trips);
- individuals who supervise overnight programs (on or off campus).
(b) Individuals with low contact with minors.
Authorized Adults with low access to minors include any individual who:
- works with or around minors for a one-time program (but not programs that meet regularly or involve multiple interactions); or
- is always supervised by another adult when interacting with minors.
Examples of individuals with low contact with minors may include:
- one-time campus tour guides, who remain with a group (i.e., more than 3 or more individuals) at all times; or
- one-time volunteers, such as students, involved in service learning or club projects who remain with a group (i.e., more than 3 or more individuals) at all times.
F. Types of Abuse
The College has zero tolerance for abuse. Child abuse exists when there is endangerment of a minor’s physical or mental health due to injury by act or omission, including acts of sexual abuse. Please refer to
https://dcf.wisconsin.gov/cps/signs for more detailed information regarding our state’s statutory definitions of child abuse and child neglect.
This policy will be implemented and strictly enforced by the Human Resources Department. Failure to comply will result in corrective action, up to and including dismissal from the College. Violations may also lead to civil or criminal proceedings.
III. Screening and Selection
All programs must adhere to screening and selection criteria required by the College. All steps must be completed before an Authorized Adult is approved to work with minors in a paid or unpaid position. The College reserves the right to repeatedly conduct background screening any time after employment or volunteer services has begun.
Screening and selection of individuals will include the following:
A standard application designed to screen for abuse
Signed College Code of Conduct;
A multi-state criminal background check that includes county-level information;
A national sex offender registry check;
Screening and selection of Individuals for positions that have access to minors may include the following:
Face-to-face interviews using behaviorally-based standardized questions designed to assess for potential risk to abuse; and
A minimum of three references, using behaviorally-based questions that assess abuse risk.
IV. Background Checks
Regardless of a staff member’s access to minors or prior screening, the College will conduct the following searches on all existing employees, every four years:
As a condition of employment, a College employee must notify his/her supervisor within five calendar days if arrested for or convicted of a crime or violation which may be related to the employee’s job. The college will not discriminate based upon a criminal record or pending charge; however, it is not discrimination to decline hire or terminate employment based upon a person’s arrest or conviction record if the arrest or conviction is substantially related to the circumstances of the particular job.
For any child abuse prevention policy to be effective, the Authorized Adults providing services to minors must have adequate education and training. All Authorized Adults must annually complete College-approved child abuse prevention and mandatory reporting training courses.
The training must cover, at a minimum: how offenders operate, how abuse happens on campus, the impact of abuse, how to protect youth from abuse, how to prevent false allegations of abuse, how to manage high risk situations, and how to respond and report a range of concerns (including inappropriate behaviors and policy violations, suspected child abuse and neglect, and youth-to-youth sexual behaviors and abuse) internally and externally as appropriate. No Authorized Adult required to take the training will be allowed to conduct or participate in a program involving minors until the training is accomplished and documentation is submitted to Human Resources.
Completion of all training requirements is required annually at a minimum.
VI. Appropriate Interactions with and Supervision of Minors
Adults should serve as positive role models for minors, and act in a caring, honest, respectful, and responsible manner that is consistent with the mission and guiding principles of the College. The behavior of all members of the College community is expected to align at all times with the
College Code of Ethics
It is expected that Authorized Adults will exhibit exemplary behavior at all times. The Guide to Working with Minors listed in Appendix A denotes behavioral guidelines for Authorized Adults as we strive to accomplish our mission together.
VII. Recognizing, Responding, and Reporting
The College is dedicated to maintaining zero tolerance for abuse. As such, it is imperative that everyone actively participate in the protection of minors and be alert to safeguard the safety of minors on and off campus.
Every member of the College community should respond and internally notify the College of violations of this policy, violations of the College Code of Ethics, inappropriate or suspicious behaviors that may not rise to the level of abuse, minor-to-minor sexualized behaviors and abuse, and suspected child abuse and neglect. Notifications to the College can be made to Human Resources or Campus Security. All reports will be investigated.
Some individuals are also required by law to externally report suspected child abuse and neglect. For purposes of this policy, the terms child abuse and neglect include, but are not limited to, the following: physical abuse, verbal abuse, sexual abuse, emotional abuse, neglect, and economic exploitation. Refer to
https://dcf.wisconsin.gov/cps/mandatedreporters for state statutory definitions, a list of mandated reporters, and mandated reporting requirements. Refer also to the Child Welfare Gateway:
https://www.childwelfare.gov/topics/systemwide/laws-policies/state/ for additional state specific resources and information.
The reporting requirements listed above are for purposes of this policy and do not absolve any individuals from any reporting obligations they may have under state law. Failure of an employee to make an internal or external report under this policy may result in disciplinary actions up to and including termination.
No hardship, loss, penalty or benefit may be imposed on an individual in response to:
Filing or responding to a bona fide complaint of discrimination or harassment
Appearing as a witness in the investigation of a complaint
Serving as an investigator of a complaint
VIII. Investigation and Resolution
The College’s investigation and resolution procedures will be strictly followed to ensure that the rights of all those involved are protected. The safety and well-being of the minor is the key consideration when deciding what interim safety measure(s) to initiate and maintain.
IX. Facility Rentals and Non-College Sponsored Events
Facility rentals and non-College sponsored events occurring on campus should include standardized written documents that require:
A. An agreement to defend, indemnify and hold harmless the College and its Governing Board from and against any and all claims, causes of action, losses, liabilities, damage or judgments directly or indirectly related to sexual misconduct or child abuse or neglect.
B. An agreement to name the College as an additional insured by endorsement on any applicable insurance policies, including a sexual abuse and molestation policy.
C. Confirmation that all adults responsible for minors on campus have cleared some minimal screening (which can include a national criminal background check and national sex offender registry check).
D. Confirmation that adults responsible for minors on campus have received some minimal abuse prevention training (which can include the identification, prevention, and reporting of sexual abuse of consumers).
E. Defined supervision procedures in place for monitoring their program participants (i.e., adult-to-consumer ratios and management of high-risk times and high-risk activities). For joint events, clearly delineate supervision responsibilities between the organizations.
F. Report incidents or allegations of sexual misconduct (involving adults or minors) back to the institution.
Appendix A: Conduct with Minors
The following guidelines are intended to assist employees and volunteers in making decisions about interactions with minors. For clarification of any guideline, or to inquire about behaviors not addressed here, contact Human Resources.
Our organization provides minors with the highest quality services available. We are committed to creating an environment for minors that is safe, nurturing, empowering, and that promotes growth and success.
No form of abuse will be tolerated, and confirmed abuse will result in immediate dismissal from our organization. Our organization will fully cooperate with authorities if allegations of abuse are made that require investigation.
The Conduct with Minors outlines specific expectations of the employees and volunteers as we strive to accomplish our mission together.
i. Minors will be treated with respect at all times.
ii. Minors will be treated fairly regardless of race, sex, age, religion, gender, or sexual orientation.
iii. Employees and volunteers will adhere to uniform best practices of displaying affection.
iv. Employees and volunteers will avoid affection with minors that cannot be observed by others.
v. Employees and volunteers will adhere to best practices of appropriate and inappropriate verbal interactions with minors.
vi. Employees and volunteers will not stare at or comment on minors’ bodies.
vii. Employees and volunteers will not date or become romantically involved with minors.
viii. Employees and volunteers will not use or be under the influence of alcohol or illegal drugs in the presence of minors.
ix. Employees and volunteers will not have sexually oriented materials, including printed or online pornography, on College property.
x. Employees and volunteers will not have secrets with or give/receive gifts with minors.
xi. Employees and volunteers will avoid interactions with minors outside our programs.
xii. Employees and volunteers will not engage in inappropriate electronic communication or social media with minors.
xiii. Employees and volunteers will avoid working one-on-one with minors in a private setting.
xiv. Employees and volunteers will not abuse children in anyway.
xv. Our organization will not tolerate the mistreatment or abuse of one child by another child. In addition, our organization will not tolerate any behavior that is classified under the definition of bullying, and to the extent that such actions are disruptive, we will take steps needed to eliminate such behavior.
Bullying is aggressive behavior that is intentional, is repeated over time, and involves an imbalance of power or strength. Bullying can take on various forms, including:
Physical bullying – when one person engages in physical force against another person, such as by hitting, punching, pushing, kicking, pinching, or restraining another.
Verbal bullying – when someone uses their words to hurt another, such as by belittling or calling another hurtful names.
Nonverbal or relational bullying – when one person manipulates a relationship or desired relationship to harm another person. This includes social exclusion, friendship manipulation, or gossip. This type of bullying also includes intimidating another person by using gestures.
Cyberbullying – the intentional and overt act of aggression toward another person by way of any technological tool, such as email, instant messages, text messages, digital pictures or images, or website postings (including blogs). Cyberbullying can involve:
i. Sending mean, vulgar, or threatening messages or images;
ii. Posting sensitive, private information about another person;
iii. Pretending to be someone else in order to make that person look bad; and
iv. Intentionally excluding someone from an online group.
v. Hazing – an activity expected of someone joining or participating in a group that humiliates, degrades, abuses, or endangers that person regardless of that person’s willingness to participate.
vi. Sexualized bullying – when bullying involves behaviors that are sexual in nature. Examples of sexualized bullying behaviors include sexting, bullying that involves exposures of private body parts, and verbal bullying involving sexualized language or innuendos.
Anyone who sees an act of bullying, and who then encourages it, is engaging in bullying. This policy applies to all children, employees and volunteers.
xvi. Employees and volunteers will report concerns or complaints about other employees and volunteers, other adults, or children to a supervisor or Human Resources.
xvii. Employees and volunteers will report allegations or incidents of child abuse and neglect to the proper state authority.