Minors on Campus Policy

Purpose

Â鶹´«Ă˝ (“Pomona” or the “College”) strives to maintain a safe environment and is committed to the protection of all members of its community, including children. There are two over-arching and equally important aims of this “Minors on Campus Policy” (“Policy”). The first is to foster the safety and well-being of minors who are involved in College-run or Affiliated Programs or Activities as defined below and in so doing help make their experiences with the College community rewarding and enriching. The second is to provide College faculty, students, staff and volunteers with guidelines and procedures that promote sound, common-sense judgment, consistency, transparency, and care with respect to interactions with minors.

Minors on Campus Policy

Section 1: Applicability

The following individuals or entities are subject to this policy:

  • Â鶹´«Ă˝ faculty, staff and students
  • Non-Pomona faculty, students and staff from elsewhere at The Claremont Colleges if they are being compensated by the College to participate in College-run or Affiliated Programs or Activities
  • Volunteers to the extent they meet the definition of Supervising Adult or Other Covered Adult
  • Third parties renting, leasing or otherwise using College Facilities for a Covered Third-Party Use

Section 2: Policy Administration

The Human Resources Department (HR) is responsible for administering this Policy, in consultation with the Title IX Coordinator, if applicable to the issues presented. For HR to carry out this responsibility effectively, all Â鶹´«Ă˝ faculty, students, and staff are responsible for reviewing, understanding and complying with this Policy and communicating with HR about new or recurring College-run or Affiliated Programs or Activities as set forth in Section 5.A. below.

Section 3: Definitions

“College Facilities”: facilities owned by, or under the control of, the College.

“College-run or Affiliated Programs or Activities” or “Covered Program” or “Programs/Activities”: programs or activities that Â鶹´«Ă˝ operates or sponsors, using College Facilities or off-campus, that involve Minors. This definition includes activities occurring as part of course requirements.

“Covered Third-Party Use”: third-parties renting, leasing or otherwise using College Facilities to operate programs or activities for the primary benefit of Minors or where Minors play a participating role in the program or activity (for example, a sports camp or music education program for Children, as opposed to a wedding or other social event where Children may be present).

“Mandated Reporters”: persons required by law to report known or suspected abuse or neglect relating to children under the age of eighteen (18) to appropriate social service or law enforcement agencies. Under California law, mandated reporters include school officials and educators, employees whose duties require direct contact and supervision of persons under the age of 18, childcare and children’s activity providers, athletic faculty and coaches, or medical and mental health professionals. Under this Policy, all Supervising Adults are Mandated Reporters. Other Covered Adults may or may not be Mandated Reporters.

“Minor” or “Child” or “Children”: a person under the age of eighteen (18) who is not enrolled or accepted for enrollment at Pomona or another institution at The Claremont Colleges. For the purposes of this Policy, this definition does not include events or activities where parents or guardians are reasonably expected to provide supervision of Minors.

“Other Covered Adult”: any individual who is a Pomona faculty, staff, student, or volunteer or who is affiliated with a third-party engaged in Covered Third-Party Use whose job or volunteer responsibilities involve interacting with Minors, even if on an intermittent basis, but does not supervise or chaperone Minors. Examples (for illustrative purposes only):

  • Admissions Staff are Other Covered Adults because their job responsibilities involve periodic interactions with Minors, though not in a supervisory capacity.
  • Volunteer interviewers, overnight hosts and student tour guides are not Other Covered Adults.
  • Facilities and Dining Services Staff are not Other Covered Adults even if they serve food to Minors or otherwise interact with Minors on College Facilities from time to time.
  • Office of Conference and Event Planning Staff and other public programming and College event support staff are not Other Covered Adults even if they otherwise interact with Minors on College Facilities from time to time during such events.
  • A faculty member giving a guest lecture to Minors as part of a summer educational program is not an Other Covered Adult.
  • Faculty members whose interactions with Minors are limited to meeting with prospective students are not Other Covered Adults.

“Program/Activity Director”: the person responsible for directing and/or organizing and/or administering the College-run or Affiliated Program or Activity. Depending on the nature of the Program/Activity, this person may or may not have a formal title with respect to the project.

“Supervising Adult”: an individual who is a Pomona faculty, staff, student, or volunteer or who is affiliated with a third-party engaged in Covered Third-Party Use and (whether paid or unpaid) supervises or chaperones Minors in Programs/Activities, including activities undertaken as part of the requirements for an academic course. Supervising Adult roles may include, but are not limited to, positions as instructors, mentors, tutors, and coaches. For example, all PAYS permanent or temporary faculty and staff are Supervising Adults. Faculty organizing course requirements involving minors are Supervising Adults.

Section 4: Scope

This policy and its appendices establish guidelines, rules and procedures for the treatment of and interactions with Minors who are participating in College-run or Affiliated Programs or Activities.

The following situations ARE NOT within the scope of this Policy:

  • Interactions between faculty, staff and others with students admitted or enrolled at Pomona or another institution at The Claremont Colleges who are under the age of eighteen (18).
  • Supervision of Minors who are involved in College research programs. This situation is addressed by Institutional Review Board Processes.
  • General public events where parents or guardians are reasonably expected to provide supervision of Minors.
  • Activities undertaken in connection with off-campus internships (paid or unpaid), summer employment, or volunteer experiences even if they were secured with the aid of the College. Instead, participating students are subject to the policies and procedures of the outside organization.
  • Activities undertaken as part of off-campus study. Instead, participating students are subject to the policies and procedures of the organization administering the program.

Section 5: Guidelines for Interacting with Minors

A. Notification to HR of Participation in College-run or Affiliated Programs or Activities and Covered Third Party Uses

Communication with HR about the existence and nature of College-run or Affiliated Programs or Activities is essential to carrying out the aims of this Policy. Such communication will allow HR to work with the Program/Activity Director or participants to ensure the requirements of this Policy are met and to coordinate compliance with obligations under applicable rental or related contracts, which may include submission of proper parental permission forms, media releases, emergency contact information, medical treatment authorization forms, background checks, etc. Therefore, Program/Activity Directors or participants, as applicable, must complete the following steps:

  • Programs/Activities: Whether or not the Program/Activity is taking place on or off campus, the Program/Activity Director shall notify HR at least fifteen (15) business days before the start of the activity by submitting the “Informational Form: ” (A sample of the Form is attached for illustrative purposes only at Appendix A.)
    • If Programs/Activities are part of academic courses, the faculty member is the Program/Activity Director responsible for filling out the Form.
    • For recurring Programs/Activities (for example, a camp that occurs every summer), the Program/Activity Director should consult with the Assistant Vice President, Human Resources to determine the most efficient way to provide updated information.
  • Covered Third-Party Use: The Pomona employee responsible for coordinating a Covered Third-Party Use shall direct the representative of any third party intending to operate a Covered Third-Party Use to submit the Informational Form as required under this Policy. Upon the third party’s execution of the required contract to operate a Covered Third-Party Use, Â鶹´«Ă˝â€™s Office of Conference and Event Planning will ensure that a copy of the executed contract is provided to HR.

B. Certification and Training

All Pomona Employees: Following the effective date of this Policy, all new Â鶹´«Ă˝ employees, regardless of whether they will interact with Minors as part of their employment, will receive a copy of this Policy and appendices as part of the onboarding process and will be required to certify that they have reviewed and understand it. Individuals who qualify as Supervising Adults or Other Covered Adults shall be required to submit the Certification for Supervising and Other Covered Adults Participating in College-run or Affiliated Programs or Activities (the “Certification”) as set forth below.

Supervising Adults: Because of their unique role with respect to Programs/Activities involving Minors, all Supervising Adults, prior to participating in a Program/Activity, must take the following steps:

  • Review this policy;
  • Review the information in Appendix B of this Policy, “Interacting with Minors: Information for Supervising or Other Covered Adults participating in College-run or Affiliated Programs or Activities.”
  • Review the information in Appendix C of this Policy, “Signs of Abuse and Neglect”
  • Obtain any required background check;
  • Review and submit the acknowledging and attesting that the individual has reviewed and understands the information in the Policy and appendices and will comply with any reporting obligations. (A sample for illustrative purposes only is available at Appendix D.)
  • Comply with any additional requirements that relate to a particular program or activity as directed by HR (for example, additional training such as an online training module).

Program/Activity Director: In addition to the Supervising Adult obligations, a Program/Activity Director is responsible for ensuring the completion and submission of Certifications from all Supervising Adults and Other Covered Adults participating in the Program/Activity no later than seven (7) business days before the start of the Program/Activity. Certifications are generally required for each discrete Program/Activity and on a recurring basis if a Program/Activity happens each year. However, for Programs/Activities with ongoing and regular activities, the Program/Activity Director should consult with the Assistant Vice President, HR to determine whether repeat certifications are necessary.

Note: If the Program/Activity is part of a course, students are not required to submit a Certification. Instead, the Program/Activity Director (faculty member) shall submit a acknowledging that they have, prior to the start of the Program/Activity: a) required students to read this Policy; and b) reviewed the Policy in class, including how it applies to the Program/Activity, and provided an opportunity for discussion. (The Assistant Vice President, Human Resources is available to lead or participate in this discussion if requested by the faculty member.)

Other Covered Adults: Other Covered Adults participating in a Program/Activity will be required to submit the Certification acknowledging that they have reviewed and understood the information in the Policy and appendices and will comply with any additional requirements as directed by HR.

In addition, the Vice President (or their designee) shall, on an annual basis, provide an opportunity for Other Covered Adults to review and re-familiarize themselves with the Policy (for example, by including this Policy as an agenda item for a staff meeting or in a packet of materials for volunteer interviewers). (For the avoidance of doubt, should an Other Covered Adult become a Supervising Adult, they must fulfill all requirements applicable to Supervising Adults.)

Covered Third-Party Uses: Third parties operating a Covered Third-Party Use shall provide a copy of this Policy and all appendices to all Supervising Adults and Other Covered Adults before participating in a Covered Third-Party Use. As a condition of operating a Covered Third-Party Use, the third party’s designee responsible for the Covered Third-Party Use will be required to confirm and attest that all Supervising Adults and Other Covered Adults participating in a Covered Third-Party Use understand their roles and obligations under this Policy and the appendices and will comply with any additional requirements as directed by HR and/or the Office of Conference and Event Planning.

C. Criminal Background and Sex Offender Registry Checks

Criminal Background Checks
  • Supervising Adults and Other Covered Adults: All Supervising Adults, with the exceptions noted below, are required to undergo a criminal background check. Many Â鶹´«Ă˝ staff have already undergone such a check at the time of hire. Any Supervising Adult or Other Covered Adult who has not previously undergone a criminal background check shall undergo such a check by contacting HR via email as soon as possible. Such Adults have an obligation to immediately disclose any new felony or misdemeanor convictions to the Assistant Vice President, Human Resources.
  • Exceptions to Criminal Background Check Requirement: Students participating in Programs/Activities as part of course work; student/faculty volunteers from other colleges, including but not limited to members of the Claremont Colleges, participating in Programs/Activities; volunteer prospective student interviewers/overnight hosts.
  • Timing of Criminal Background Checks: Any individual subject to the Background Check Requirement must have checks completed prior to participating in a Covered Program and having contact with Minors, and thereafter every four years. Individuals may be required to submit to additional background checks at any time based on a reasonable belief that the person is disqualified from service on grounds of a conviction or report of child abuse.
Sex Offender Registry Checks
  • Supervising Adults: All Supervising Adults, with the exception of students participating in Programs/Activities as part of course work, shall undergo a sex offender (aka “Megan’s Law”) registry check prior to participating in a Covered Program and, if such participation is ongoing, annually thereafter.
  • Other Covered Adults: Other Covered Adults who are not otherwise subject to Â鶹´«Ă˝â€™s background check requirement (for example, volunteers) shall undergo a sex offender check prior to participating in a Covered Program. All Other Covered Adults shall undergo a sex offender check every four (4) years.

Any Supervising Adult or Other Covered Adult participating in a Covered Program who has not previously undergone a sex offender registry check shall undergo such a check by contacting HR via email as soon as possible. To check if someone has one on file or any other questions, please contact HR via email.

Third parties operating a Covered Third-Party Use shall comply with the federal Fair Credit Reporting Act and any applicable state or local laws in obtaining the background checks required under this Policy, and these processes shall be conducted at their own cost. Third parties operating a Covered Third-Party Use will be required to conduct background screenings of their Supervising/Other Covered Adults in a manner that is consistent with the requirements of this Policy, and certify with the Assistant Vice President, Human Resources and/or Office of Conference and Event Planning that all requirements of this Policy have been met and understood by its Supervising/Other Covered Adults participating in a Covered Third-Party Use. The Program/Activity Director for the Covered Third-Party Use shall produce copies of all background screenings required under this Policy to the Assistant Vice President, Human Resources upon request prior to participation in any Program/Activity.

An adverse result in a criminal background or sex offender check will not automatically disqualify someone from participating in College-run or Affiliated Programs or Activities. Rather, the Assistant Vice President, Human Resources will analyze the specific facts associated with the adverse result to evaluate whether it warrants exclusion of the individual from participating in the College-run or Affiliated Programs. The College may request any additional information it deems necessary to meet the requirements of this Policy.

D. Procedures for Addressing and Reporting Potential Harm to Minors

Emergencies

In case of an emergency involving a child, immediately call 911. Immediately thereafter, notify Campus Safety at 909-621-8170 or 909-607-2000, your supervisor, and the Assistant Vice President, Human Resources [pomonaHR@pomona.edu] and, if applicable to the nature of the emergency, the Title IX Coordinator [titleix@pomona.edu] (in cases of alleged/suspected sexual harassment/sexual misconduct).

Mandated Reporting of Known or Suspected Child Abuse or Neglect

Under California law, Mandated Reporters have an individual legal obligation to report known or, if there is a reasonable basis, suspected abuse or neglect relating to children.

It is not the job of the mandated reporter to determine whether the allegations are valid. If child abuse or neglect is reasonably suspected or if a student shares information with a mandated reporter leading them to believe abuse or neglect has taken place, the report must be made. No supervisor or administrator can impede or inhibit a report or subject the reporting person to any sanction.

Under this Policy, Supervising Adults are Mandated Reporters as are Other Covered Adults whose duties bring the individual into contact with children on a regular basis. (Any questions about any individual’s status as a Mandated Reporter should be directed to the Assistant Vice President, Human Resources.)

Child abuse and neglect, as defined under the Child Abuse and Neglect Reporting Act (“CANRA”), California Penal Code Sections 11161-11174.3, includes:

  • Physical injury or death inflicted by other than accidental means upon a child by another person;
  • Sexual abuse, meaning sexual assault or sexual exploitation of a child;
  • Neglect, meaning negligent treatment of the maltreatment of a child by a person responsible for the child’s welfare under circumstances indicating harm or threatened harm to the child’s health or welfare, including both acts and omissions on the part of the responsible person;
  • Willful harming or injuring of a child or the endangering of the person or health of a child, meaning a situation in which any person willfully causes or permits any child to suffer, or inflicts thereon, unjustifiable physical pain or mental suffering, or having the care or custody of any child, willfully causes or permits the person or health of the child to be placed in a situation in which the child’s person or health is endangered;
  • Unlawful corporal punishment or injury of a child, meaning a situation where any person willfully inflicts upon any child any cruel or inhuman corporal punishment or injury resulting in a traumatic condition.

Child Abuse and/or Child Neglect Can Be Any of the Following:

  • A physical injury inflicted on a child by another person other than by accidental means.
  • The sexual abuse, assault, or exploitation of a child.
  • The negligent treatment or maltreatment of a child by a person responsible for the child’s welfare under circumstances indicating harm or threatened harm to the child’s health or welfare. This is whether the harm or threatened harm is from acts or omissions on the part of the responsible person.
  • The willful harming or endangerment of the person or health of a child, any cruel or inhumane corporal punishment or any injury resulting in a traumatic condition.

One does not have to be physically present or witness the abuse to identify suspected cases of abuse, or even have definite proof that a child may be subject to child abuse or neglect. Rather, the law requires that a person have a “reasonable suspicion” that a child has been the subject of child abuse or neglect. Under the law, this means that it is reasonable for a person to entertain a suspicion of child abuse or neglect, based upon facts that could cause a reasonable person, in a like position, drawing, when appropriate, on their training and experience, to suspect child abuse or neglect.

Red flags for abuse and neglect are often identified by observing a child’s behavior at school, recognizing physical signs, and observations of dynamics during routine interactions with certain adults. While the following signs are not proof that a child is the subject of abuse or neglect, they should prompt one to look further.

Warning Signs of Emotional Abuse in Children
  • Excessively withdrawn, fearful, or anxious about doing something wrong.
  • Shows extremes in behavior (extremely compliant or extremely demanding; extremely passive or extremely aggressive).
  • In younger children, displaying a lack of attachment/closeness with parents or caregivers, and in older adults, seeming distant from their parents or caregivers or having a strong need for affection from other adults.
  • Acts either inappropriately adult-like (taking care of other children) or inappropriately infantile (rocking, thumb-sucking, throwing tantrums).
  • Showing extreme lags in development or dramatic behavioral changes.
  • Being socially isolated.
Warning Signs of Physical Abuse in Children
  • Frequent injuries or unexplained bruises, welts, or cuts.
  • Is always watchful and “on alert” as if waiting for something bad to happen.
  • Injuries appear to have a pattern such as marks from a hand or belt.
  • Shies away from touch, flinches at sudden movements, or seems afraid to go home.
  • Wears inappropriate clothing to cover up injuries, such as long-sleeved shirts on hot days.
Warning Signs of Neglect in Children
  • Clothes are ill-fitting, filthy, or inappropriate for the weather.
  • Hygiene is consistently bad (unbathed, matted and unwashed hair, noticeable body odor).
  • Untreated illnesses and physical injuries.
  • Is frequently unsupervised or left alone or allowed to play in unsafe situations and environments.
  • Is frequently late or missing from school.
  • Malnutrition or dehydration, which may indicate a child is not provided with adequate food or water.
Warning Signs of Sexual Abuse in Children
  • Trouble walking or sitting.
  • Actual bruising or bleeding around the genitals, or persistent pain while using the bathroom.
  • Displays knowledge or interest in sexual acts or concepts inappropriate to or unusual for the child’s age, or even seductive behavior.
  • Sudden or unexplained fear or anxiety around certain people, places or things, or making strong efforts to avoid a specific person, without an obvious reason.
  • Discomfort when asked to remove clothes, even while changing, taking a bath, or using the toilet.
  • Unexplained health problems, including headaches, stomach aches, or loss of appetite.
  • Problems sleeping, such as nightmares, bedwetting, or a fear of going to sleep
  • Distraction or anxiety, which may appear as a loss of interest in things the child previously enjoyed like school, organized group activities, or time with friends
  • Feelings of anger, fear, or insecurity; unexplained emotional outbursts or unstable moods
  • Negative self-thought, especially about their own body
  • Unexpected new cash or possessions, like clothes, electronics, or toys
  • New relationship with an older person that seems secretive or overly intimate.
  • A sexually transmitted infection (STI) or pregnancy, especially under the age of fourteen.
  • Runs away from home.

For specific definitions of what conduct meets the definition of abuse or neglect under , see California Penal Code Section 11165.1-11165.6.

Child abuse and neglect does not include a fight between minors, or an injury caused by reasonable and necessary force used by a peace officer acting within the course and scope of their employment as a peace officer. The pregnancy of a minor does not, in and of itself, constitute a basis for a reasonable suspicion of sexual abuse.

A reasonable basis for a report of suspected abuse or neglect may be based on information confided in the Mandated Reporter by the minor, by someone else about the minor, or based on an individual’s own observations or suspicions (e.g., social media, rumor, etc.). A reasonable suspicion of child abuse or neglect means that it is objectively reasonable for a person to entertain a suspicion, based upon facts that could cause a reasonable person in a similar position, based on that person’s training and experience, to suspect child abuse or neglect. Actual evidence of abuse is not necessary to trigger this requirement. No one should investigate the matter on their own. Any doubt about whether or not to report should be resolved in favor of making the report to ensure that appropriate child protective services are engaged to assess the situation and evaluate the safety of the child.

Any Mandated Reporter who knows of or reasonably suspects abuse or neglect of a Minor must immediately report the matter as required by law. If there is an imminent threat to health or safety, contact 911. Otherwise, any Mandatory Reporter who knows of or reasonably suspects child abuse or neglect must immediately proceed as follows:

  • The immediate report by the Mandated Reporter to the local county child protective or law enforcement agency. In Los Angeles County, the initial report may be made by calling the Los Angeles County Department of Children and Family Services’ (DCFS) 24-hour Child Protection Hotline at (800) 540-4000 (toll-free within California), (213) 639-4500 (from outside California), or (800) 272-6699 (TDD), or directly to a police or sheriff's station.
  • Immediately following a report to DCFS, and within no more than 24 hours, submit notice to Â鶹´«Ă˝â€™s Human Resources and Title IX Offices by completing the .
  • Within 36 hours of the initial telephone report, file a written report with DCFS by completing and submitting (Suspected Child Abuse Report or “SCAR”) by mail, fax, or other electronic means as indicated during the initial call with DCFS. (See Page 2 on Form SS8572 for instructions on how to complete and submit that Form.)

No one is prohibited from making a report whether or not an individual is a Mandated Reporter. If you are unsure about your individual obligations or have any questions, contact the Assistant Vice President, Human Resources.

Reporting Other Serious Concerns and Violations Relating to Minors

Any other serious concerns or violations relating to Minors not rising to the level of child abuse and neglect should be reported as soon as possible, and within no more than 24 hours after becoming aware of the original concern by completing the .

The reporting requirements detailed in this Policy do not supersede or exempt individuals from other College or legal reporting obligations, including the requirement to report prohibited conduct (as defined in the College’s relevant sexual harassment/sexual misconduct/Title IX policies) to the College’s Title IX Office. Sexual misconduct, discrimination, and/or harassment against minors, whether perpetrated by College employees, volunteers, third-party contractors, or students, is a form of discrimination covered by Title IX, the federal statute prohibiting discrimination on the basis of sex at educational institutions receiving federal funds. In these cases, the Title IX Coordinator must be notified directly by any responsible employee. If there are any doubts as to whether conduct should be reported to the Title IX Coordinator, please consult with your supervisor.


 

Section 6: Enforcement

Sanctions for violating this policy will depend on the circumstances and nature of the violation, but may include the full range of available sanctions, such as suspension, termination, and exclusion from campus. The College may also take interim measures before determining whether a violation has occurred. The College may terminate relationships or take other appropriate actions against third parties that violate this policy.

Section 7: Policy Implementation and Modification

If anyone has any questions about the interpretation or application of this Policy, contact the Assistant Vice President, Human Resources. The Assistant Vice President, Human Resources will review the Policy annually and make any necessary updates to the Information Form (Appendix A), the Signs of Abuse and Neglect (Appendix B), and the Certification forms (Appendix C). The Assistant Vice President, Human Resources shall recommend modifications to any other sections of the Policy to Executive Staff as necessary, including the reflection of changes in the law or standards relating to the protection of minors, or College processes.

Section 8: Exhibit(s)

Section 8: Exhibit(s)

Appendix A: “Sample: Informational Form-Programs/Activities and Covered Third-Party Uses Involving Minors”; Appendix B: Interacting with Minors: Information for Supervising or Other Covered Adults participating in Programs/Activities involving Minors; Appendix C: Signs of Child Abuse and Neglect; and

Appendix D: Sample Certification for Supervising and Other Covered Adults Participating in College-run or Affiliated Programs or Activities.

Appendix A

Note: This sample is for illustrative purpose only. To access and submit the most up-to-date version of this form, please go to Informational Form - .

Sample: Informational Form-Programs/Activities and Covered Third-Party Uses Involving Minors

Instructions:

  • The Program/Activity Director is responsible for filling out this form. This includes faculty directing Programs/Activities as part of course work.
  • Please complete this form at least 15 business days before the start of the Program/Activity or Covered Third-Party Use involving Minors.
  • If you are submitting this form in connection with a Â鶹´«Ă˝-run or Affiliated Program or Activity and have any questions about this form, including how it applies to recurring Programs/Activities, please contact the Assistant Vice President, Human Resources 909-607-1686 or email HR.

· If you are submitting this form in connection with a Covered Third-Party Use (third parties renting, leasing or otherwise using facilities owned by, or under the control of, Â鶹´«Ă˝ to operate programs or activities for the primary benefit of Minors or where Minors play a participating role in the program or activity) and have any questions about this form, please email Â鶹´«Ă˝â€™s Office of Conference and Event Planning at 909-607-2241 or via email.

Name/title/email:

Name of Program/Activity:

Is the Program/Activity operating under a Covered Third-Party Use? Yes or No.

Describe your role in the Program/Activity:

General Description of Program/Activity:

Program/Activity Dates (note if Program/Activity is ongoing or recurs annually):

Program/Activity Venue:

Age of Minor Participants (give range if applicable):

Is there an overnight component to the Program/Activity? Yes or No. If yes, please describe.

Identify all others who will be involved in the Program/Activity, including whether they will be paid or unpaid and nature of role. For example: Anne Smith, Pomona student, paid, tutor; John Seymour, Pomona faculty, paid, instructor; Isabelle Sherman, CMC student, volunteer, mentor.

Will Pomona be responsible for driving participating Minors to/from the Program/Activity or to/from field trips or other program activities? Yes or No. If yes, please describe.

Appendix B

Interacting with Minors: Information for Supervising or Other Covered Adults participating in Programs/Activities involving Minors

If you are working with minors, you have a key role to play in maintaining their safety and well-being and in helping to make the activity in which they are participating a rewarding and enriching experience. The College adopted its Minors on Campus Policy to foster this goal and equally importantly to protect College faculty, students, staff and volunteers by developing a set of guidelines and procedures that promote sound, common-sense judgment, consistency and uniformity, transparency, and care with respect to interactions with minors.

Supervising and Other Covered Adults (as defined in the Policy) must observe the following common-sense “dos” and “don’ts.” They are meant to help the College community adhere to a core set of standards when working with minors including maintaining appropriate physical and emotional boundaries; treating all children fairly and consistently; and demonstrating respect for their overarching welfare.

Do:
  • Treat minors with respect at all times, regardless of their actions or behavior.
  • Listen to, interact with minors, and provide appropriate praise and positive reinforcement.
  • Maintain discipline and respond calmly and respectfully when minors use inappropriate language or engage in disrespectful behavior by letting them know that everyone deserves respect, even when they are angry, and consult with supervisors as needed for help.
  • Avoid unnecessary one-on-one interactions with minors and interaction with minors in enclosed spaces or behind closed doors and follow “open door” practices by always keeping the door ajar when working with minors. If such interactions are necessary (such as tutoring, advising, private lessons or other academic support), it is best to hold such sessions in a public place; in a room where the interaction can be observed; or in room with the door left open and another staff member notified of the meeting. Please note that this does not mean you cannot take a child aside for a brief confidential discussion of a matter such as their behavior, but conduct any necessary one-one-one interactions with minors in a public environment where you can be observed.
  • Be aware of how your actions and intentions might be perceived and could be misinterpreted, keeping in mind that physical contact with children can be misconstrued not only by the recipient but also by others observing it and that different people have a different sense of personal space. For example, while some contact such as patting a child on the back or gently touching a child’s arm to get attention may be appropriate, you should not touch children against their will or engage in highly physical contact such as picking them up, giving them back rubs, or tickling or roughhousing.
  • Again, because actions can be misinterpreted, do not engage in inappropriate touching or have physical contact with a minor in private locations. The following types of physical contact between non-related adults and minors may be permitted: handshakes, high-fives and hand slapping, pats on the shoulder or back, side hugs (with the minor’s advance consent), holding hands while escorting children (e.g., helping with street crossing), other brief contact intended to comfort distressed children below the age of twelve so long as another adult is witnessing it, teaching a physical technique that literally requires hands-on instruction, such as finger placement on a musical instrument or positioning for an athletic activity, so long as it is either conducted in the open or in an interior space with doors and windows open and in a building open to the public at the time of contact, contact to aid an injured minor or a minor in imminent danger of physical harm (such as a struggling swimmer), separating minors involved in an altercation, and assisting disabled minors who need assistance with a major life function, so long as at least one other adult is present and observing.
  • Use discretion and consider the age of the child when communicating with the child. This includes communicating with children in a manner that is consistent with your position as role model, including avoiding sharing information about your private life, discussing intimate matters with children such as relationships or sexual orientation, relating to minors as if they were peers, or taking on the role of “confidant.”
  • Use good judgment when accompanying young children on a bathroom trip, including not going into the stall with a child. Best practice is to bring more than one child at a time to the bathroom, but if that is not possible, maintain an appropriate distance from the stall.
  • If you will be driving minors, familiarize yourself with relevant safety laws and inform parents or guardians in advance if their minor will be driven somewhere, and obtain advance written permission by parents or guardians to transport their minor. Avoid driving alone with a single child.
  • Use staff-only bathrooms, if available. If no staff-only bathrooms are available, adults should use bathrooms when no minors are present. If you must use a bathroom when a minor is present, ensure that at least one other adult or minor is also present.
  • Consult with supervisors, program/activity directors or colleagues if you feel uncertain about how to handle a situation.
¶Ů´Ç˛Ô’t:
  • Spend significant time alone with just one minor outside of a group setting, and avoid being alone with a minor in the minor’s room or in your room. Never sleep in a minor’s room or allow a minor to sleep in your room.
  • Engage in inappropriate touching (including striking or hitting a minor) or have any physical contact with a minor in private locations. The following types of physical contact between non-related adults and minors is not permitted: frontal hugs, kisses, lap sitting, massages or rubs, piggyback rides, tickling, touches on the buttocks, chest, or groin (except when changing diapers), wrestling, or any intended affection unwanted by the minor.
  • Berate, intimidate, or belittle a child. Use words with care, and while giving praise is appropriate, use discretion when complimenting minors and do not get too personal.
  • Strike or hit a minor, or use corporal punishment or other punishment involving physical pain, discomfort, or humiliation.
  • Give personal gifts to, or do special favors for a minor or otherwise engage in conduct that could be perceived as favoring one child over others.
  • Share information with minors about your private lift or have informal or purely social contact with minors outside of Programs or Activities. In general, private meetings and telephonic or electronic communications with minors outside of the Program’s normal activities are discouraged unless they are necessary as part of the Program.
  • Approach or engage with minors on social media, and avoid responding to text messages, e-mails, and social media posts sent by minors to your personal device.
  • Give personal gifts. Whenever possible, also do not accept personal gifts. If rejecting a personal gift is not possible, be thoughtful about handling the situation – for example, if feasible consider sharing the gift with your colleagues or informing your supervisor.
  • Provide alcohol, cigarettes (including smokeless cigarettes or vaporizers) or narcotics to minors or use them in the presence of minors.
  • Take pictures of children unless their parents or guardians have signed a waiver allowing the use of photography for Program-related purposes.
  • Use inappropriate language, profanity, tell risquĂ© jokes, or make sexually suggestive comments (even if minors themselves are doing so).
  • Make comments about other peoples’ bodies.
  • Show pornography or sexual materials to minors or involve minors in pornographic activities.
  • Date or become romantically or sexually involved with a minor.
  • Relate to minors as if they were peers, conduct private correspondence, or take on the role of “confidant” outside of a professional counseling relationship.
  • Tell a child “This is between the two of us” or use other similar language, or otherwise encourage a child to keep secrets from parents or guardians.
  • Drive alone with a single child, and do not drive any children in your personal vehicle without advance, written parental permission.
  • Change clothing or shower in locker rooms at the same time as minors, or watch minors undress or shower. While minors shower, at least one adult in charge of the Activity should stand within earshot of the minors to ensure that no adults are showering with them and that the minors are respectful of one another.

Appendix C

Signs of Child Abuse and Neglect

Source:

What are the common signs of child abuse?

REPEATED INJURIES: Bruises, welts, burns. Parents may seem unconcerned, deny that anything is wrong, or give unlikely explanations for the injuries.

NEGLECTED APPEARANCE: Children often are badly nourished, inadequately clothed, are left alone or are wandering at all hours, always seem as if nobody cares. (Sometimes, though, over-neatness may be a sign of abuse.)

DISRUPTIVE BEHAVIOR: Constantly repeated, very aggressive, negative behavior can be a sign of abuse and signal a desperate need for attention and help.

PASSIVE WITHDRAWN BEHAVIOR: When children are excessively shy and friendless, it may indicate that there are serious problems at home.

FAMILIES THAT ARE EXTREMELY ISOLATED: Parents who do not share in school or community activities and resent friendly contacts may be distrustful of people and afraid to seek help.

Use caution and good sense in identifying child abuse. Every parent makes errors in judgment, but when the errors become a pattern, or are close to becoming one, then it is time for help.

Appendix D

Please note: This sample is for illustrative purpose only and is subject to change. To access and submit the most up-to-date version of this form, please go to .

Sample Certification for Supervising and Other Covered Adults Participating in College-run or Affiliated Programs or Activities

I hereby certify that I have read and understand the Minors on Campus Policy, including accompanying appendices. I have had an opportunity to ask any questions I have about the information included in the Policy, including relating to whether I am a mandated reporter and, if so, my obligations under California law and the Policy.

Printed Name:

Title:

Signature:

Date:

Name of Program/Activity (if applicable):

Name of Program/Activity Director:

Program/Activity Director’s Email Address (required for Program/Activity Director to receive a copy of this Certification):

Sample Additional Certification for Faculty Directing Course Requirements

I am overseeing a Program/Activity involving minors as part of a class I am teaching, _____________ (fill in course name), _____________ (fill in semester and year). I certify that I have required my students to read the Minors on Campus Policy, have reviewed the Policy in class, including how the Policy applies to the course requirements, and have provided an opportunity for discussion and questions.

Printed Name:

Title:

Signature:

Date: