Programs and Activities with Minor Participants

As part of its educational mission, Lourdes University is committed to fostering a welcoming and inclusive educational environment for all members and guests by sponsoring many programs and activities that are specifically for minor children or in which minor children participate. The University also makes its facilities available to outside groups and organizations that conduct programs directed towards or that include minor children. Because minor children are a particularly vulnerable population, the University is committed to providing a safe environment for all members of the University community, including its visitors, as well as appropriate supervision of minors who are involved in programs and activities that are either held at University facilities or are sponsored by the University.

Definitions

Authorized Adult: Individuals, age 18 and older, paid or unpaid, who interact with, supervise, chaperone, or otherwise oversee minors in program activities, recreational and/or residential facilities. This includes but is not limited to faculty, staff, volunteers, graduate and undergraduate students, interns, employees from temporary employment agencies and independent contractors/consultants. Authorized Adults may also include positions such as counselors, chaperones, coaches, instructors, program leaders, etc. Authorized Adults are considered to be mandatory reporters under Lourdes University policy and in some cases, Ohio law, which requires the reporting of any suspected child abuse/neglect involving a minor (under the age of 18). Further guidance for reporting child abuse can be located in the Title IX Sexual Misconduct Policy.

Care, Custody, and Control: When an Authorized Adult is present and has primary responsibility for supervision of minors at any given point throughout the program or activity involving minors. At least one Authorized Adult must have care, custody, or control of minors at all times during covered programs.

 Child: A person under the age of eighteen (18) who is not a student enrolled at Lourdes University. We use the term “minors” interchangeably with “children.”

Covered Programs: Programs or activities operated or organized by various academic or administrative units of the University (or the University’s contractor), or by non-University groups using University facilities that (i) includes minors and (ii) during which parents/guardians are not expected to be responsible for the care, custody, or control of the minors. This includes but is not limited to workshops, sports camps, academic camps, conferences, retreats, pre-enrollment visits and similar activities.

Direct Contact: Positions with the possibility of care, supervision, guidance, or control of children or routine interaction with children.

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

Sponsoring Unit: The academic or administrative unit or registered student organization of the University that offers the program or provides approval for use of facilities or housing.

Third-Party Contractor: A non-University entity contracting for the use of University facilities to host events involving minors.

University Facilities: Facilities owned by, or under control of, the University with the exception of the Sisters of St. Francis areas (including, but not limited to, Regina Hall and Conference Room, Madonna Hall and Conference Room, Umbria Square Conference Room and the 1^st and 2^nd Floors of Umbria Hall, All Good Things, Rosary Care Center, Our Lady of Grace, Convent Park Apartments, and Sophia Center), which may follow separate policies that reflect unique activities in those locations.

 

Policy Scope

This policy applies to Covered Programs specifically designed for participation by minors, and all participants, employees, students, and volunteers who exercise direct supervision, chaperone, or otherwise oversee minors in the course of their duties in covered programs. This includes, but is not limited to, the following:

1. The University’s Covered Programs operated on campus or in University facilities, including but not limited to overnight camps, instructional programs, day camps, academic camps, and sports camps.
2. The University’s Covered Programs that do not take place on campus, including but not limited to outreach and community service activities.
3. Covered Programs operated, conducted, or organized by Third-Party Contractors that take place on campus or in university facilities.

Exceptions

This policy does not apply to the following:

1. Individuals under the age of eighteen who have been accepted for enrollment and the undergraduate and graduate academic programs in which they are enrolled.
2. Events on campus that are open to the general public, which minors attend at the sole discretion of their parents/guardians, but the University is not accepting care, custody, or control for the minor.
3. Enrolled students when hosting high school students, including prospective athletes, participating in pre-enrollment visitation.
4. Minors working for the university as employees or interns.
5. Employees or volunteers who may have incidental contact with minors but do not work directly with minors within a program or activity.
6. Covered programs granted a specific exemption from part or all of the policy in advance of the event taking place, after a written request has been reviewed and approved by legal counsel and the University President.

The University expects parents/guardians to provide supervision over minors on campus unless the minors are involved in a Covered Program. Parents or guardians should not leave minors unsupervised on University property.

 

Policy Compliance

A Sponsoring Unit of any University Covered Program or Third-Party Contractor hosting a Covered Program involving minors in any capacity shall:

• Register annually with the appropriate Lourdes University official using the Children on Campus Program Registration Form (Available Here). Program Administrators must ensure all information is current for their program at least 60 days in advance of the program. Third-Party Contractors must register as well, with assistance from the University entity facilitating the contract.
• Provide the sponsoring unit satisfactory evidence of compliance with all the requirements of this policy at least sixty (60) days prior to the scheduled use of University facilities, and for Third-Party Contractors, sign an approved agreement for use of University facilities.
• Demonstrate compliance with the Program Planning Checklist, which includes procedures for necessary program consent and release forms, training, medical issues, supervision, transportation, safety and security, and discipline.
• Warrant that background checks are completed and cleared for all Authorized Adults, including employees, students, and volunteers, involved in University Covered Programs, including BCI (Ohio) checks a minimum of every 4 years. If an individual has not resided in Ohio for five consecutive years must have a BCI and FBI background check completed.
• Ensure appropriate supervision of minors in accordance with the guidelines below and follow the mandatory reporting guidelines.
• Sponsoring Units and individuals must cooperate with any investigations that may occur and must retain records demonstrating compliance with this Policy.

 

Violation and Accountability

Individuals, entities, programs, or Sponsoring Units that violate this policy will be held accountable for their actions under the applicable program’s standards of behavior and expectations, University policies and rules, and applicable law, including but not limited to the following:

1. Volunteers are subject to reprimand or loss of volunteer status. Volunteers who lose status may be barred from campus in the future.
2. Students are subject to the Student Code of Conduct.
3. Employees, including student employees, who fail to comply with this policy, are subject to disciplinary action up to and including termination in accordance with the applicable Employee Handbook.
4. Suspension or termination of the use of University facilities for a program or activity.
5. Criminal investigation and prosecution, where warranted.

 

Supervision

Adequate supervision of minors must be established while they are on University property. All activities involving minors must be supervised by at least two or more Authorized Adults or by their parent(s)/legal guardian(s) at all times, in accordance with the Program Supervision Standards listed below.

 

Authorized Adult Guidelines

• Authorized Adults are strictly prohibited from :

1. Abusive conduct of any kind toward, or in the presence of, a minor is strictly prohibited. This includes any striking, hitting, pushing, pulling, administering corporal punishment, making sexual advances, or touching in any inappropriate or illegal manner.
2. Providing tobacco products, alcohol, or unauthorized/illegal drugs to any minor. Authorized Adults shall not provide prescription drugs or any medication to any minor unless specifically authorized in writing by the parent/legal guardian as being required for the minor’s care or the minor’s emergency treatment. Program staff, following conditions outlined in parental permission, may distribute participants’ medicines and directions form.
3. Providing materials containing sexual content in any form to minors participating in programs or activities covered by this policy. Authorized Adults may not view such material in the presence of minors nor assist them in any way in gaining such access to such materials.
4. Having One-on-One contact with minors, except in music/dance programs involving private instruction, clinical programs, or similar programs in which the parent/guardian has been informed and given written consent to the One-on-One contact (or has the opportunity to be present). The prohibition against One-on-One contact extends to all interactions and communications, including those by telephone, mail, email, texting, or any other means or medium. Any communication by an Authorized Adult with a minor shall include a second Authorized Adult or the parent/guardian of the minor as a party to the communication, and shall be strictly limited to those with an educational or programmatic purpose consistent with the mission of the University. Authorized Adults shall not be alone in vehicles with minor participants other than their own child.
5. Entering a minor’s room, bathroom facility, or similar area unless accompanied by another Authorized Adult.
6. Sharing a room with a minor; Separate accommodations for adults and minors are required, other than the minor’s parent/guardian.

• Authorized Adults facing allegations of inappropriate conduct must discontinue any further participation in programs and activities covered by this policy until such allegation has been satisfactorily resolved.
• When the University is hosting High School students, including prospective athletes, participating in pre-enrollment visitation, the requirement for two Authorized Adults will be waived. The requirement also does not apply to Sophia Center providing psychological and counseling services to minors.

 

Participant Guidelines

• All participants in a University Covered Program are generally permitted in the general use facilities (athletic fields, public spaces, academic buildings) but may be restricted from certain areas of the facilities (e.g. storage rooms, equipment rooms, athletic training rooms, staff/faculty offices) or from utilizing certain equipment.
• Program Participants must abide by all Lourdes University Student Conduct policies, as well as any disciplinary rules applicable to the program. Program participants, staff, and Authorized Adults may be removed from the program for non-compliance with rules. The following University rules specifically apply to all Covered Programs and everyone involved in the Covered Program:

1. Possession or use of alcohol and other drugs, tobacco products (including vapes), fireworks, guns and other weapons is prohibited.
2. Operation of motor vehicles by minors is prohibited while attending and participating in the program.
3. The parking of staff and participant vehicles must be in accordance with University parking regulations.
4. Rules and regulations must be established that govern when and under what circumstances participants may leave University property during the program.
5. No violence, sexual misconduct including sexual abuse or harassment, will be tolerated. All participants and Authorized Adults are subject to the Lourdes University Title IX Sexual Misconduct Policy.
6. Hazing, threatening, or bullying of any kind is prohibited whether verbal, physical, or cyber.
7. No theft of property (regardless of owner) or criminal activity will be tolerated.
8. Misuse or damage of University property is prohibited. Both the responsible participant and the hosting program will be responsible for costs associated with damage or misuse of University property.
9. The inappropriate use of cameras, imaging and digital devices is prohibited, including use of such devices in showers, restrooms, or other areas where privacy is expected by participants.

• Media and liability releases must be obtained as part of the program registration process and Covered Programs must provide the release to participants with all program registration forms. All data gathered shall be confidential, is subject to records retention guidelines, and shall not be disclosed, except as provided by law.

 

Program Supervision Standards

 The program will be required to provide trained Authorized Adults who must be at least 18 years of age, using the following guidelines:

Residential Camps/Programs:

• No participants aged 0-9 may reside in University residence halls.
• One Authorized Adult for every eight participants ages 10 to 14
• One Authorized Adult for every ten participants ages 15 to 17
• No group may participate unless there are a minimum of TWO Authorized Adults or Parents/Guardians available.
• No group may have participants under the age of 4 participating in Covered Programs.

Non-Residential Camps/Programs:

• One Authorized Adult for every six participants ages 4 and 5
• One Authorized Adult for every eight participants ages 6 to 8
• One Authorized Adult for every ten participants ages 9 to 14
• One Authorized Adult for every twelve participants ages 15 to 17
• No group may participate unless there are a minimum of TWO Authorized Adults or Parents/Guardians available.

Training for Program Leaders and all Authorized Adults must include at a minimum:

• Information about responsibilities and expectations under this policy and any Program requirements.
• Policies, procedures, guidelines, and enforcement of same.
• Appropriate crisis/emergency responses.
• Safety and security precautions.
• Confidentiality issues involving minors.
• Mandatory reporting.
• University responsibility/liability and responsible employees.
• Must know how to contact local emergency services and how to report suspected child abuse.

 

Responsibilities of the Program Leader and any Authorized Adults must include at a minimum:

• Informing program participants about safety and security procedures.
• Informing program participants about University rules.
• Establishing in and informing participants about program rules and behavioral expectations
• Collecting all signed release and waiver forms from participants and Authorized Adults.
• Facilitating background checks of all Authorized Adults, including parent/guardian volunteers.
• Program leaders are responsible for following and enforcing all rules, must be able to provide information to program participants, and must be able to respond to emergencies.

 

How to Make a Report

All University community members must act immediately when criminal activity involving children is taking place, is alleged, or suspected.

Anyone participating in a Covered Program who knows, suspects or receives information indicating that a child has been abused, neglected, or who has other concerns about the safety of children MUST immediately inform University Public Safety (419-574-3861) and the local Sylvania police department (911 for emergencies, or 419-255-8443 for non-emergencies). In addition, the Program Leader and Sponsoring Unit should be notified when it is safe and appropriate to do so.

Ohio’s child protection law, Ohio Revised Code §2151.421 designates individuals in certain occupations and professions as mandated reporters, including school officials, as well as volunteers. Mandated reporters must immediately report known or suspected mental or physical abuse or neglect of a child made known to them in their professional or official capacity directly to the Notify Lucas County Children Services to report abuse or neglect: (419) 213-CARE (2273) (24 hours a day, 7 days a week).  Even those who are not mandated reporters may report known or reasonably suspected child abuse to Lucas County Children Services.

If you are making a report of child abuse or neglect, follow these steps:

1. If the child is in immediate danger, contact police at 911to obtain immediate protection for the child.
2. Notify Lucas County Children Services to Report Abuse or Neglect: (419) 213-CARE (2273) (24 hours a day, 7 days a week)
3. Notify Lourdes University Public Safety Department 419-574-3861(24 hours a day, 7 days a week)

 

University Housing

Programs involving placement in University housing require an Authorized Adult, ideally a Lourdes University community member, to reside in the housing unit.  Sufficient adults must be present to ensure One-on-One contact with minors does not occur and that appropriate levels of supervision are implemented.

• University housing is not available to children aged 0 – 9 years old unless they are staying with a parent or guardian. Children ages 10 and up may spend the night in University housing.
• For residential programs at University facilities, a list of all program participants and a directory of program staff must be provided to the Director of Public Safety and the Director of Residence Life. This list shall include participant’s name, room assignment (if applicable), gender, age, address, and phone number(s) of parent/legal guardian, as well as emergency contact information.
• When high school students are participating in pre-enrollment visitation, including prospective athletes, the University will waive the requirement for two Authorized Adults to be present. Residence Life must have advance notice of any pre-enrollment visits by high school students if they involve an overnight stay in residence halls.

Third-Party Contractors must ensure proper supervision of minors in University housing, including the following:

1. Written permission signed by the parent/guardian for the minor to reside in University housing.
2. A curfew time that is age-appropriate for the participants, but in no case shall it be later than midnight.
3. In-room visitation to be restricted to participants of the same gender.
4. Guests of participants (other than parent/legal guardian and other program participants) are restricted to visitation in the building lobby/hallway area or designated public area set by the program and limited to the approved hours specified by the program.
5. The program must comply with all security measures and procedures specified by Residence Life and Public Safety.

 

Medical

Covered Programs must provide Medical Authorization containing at a minimum the following:

1. A statement informing the parent/legal guardian that the University (does or does not, as applicable) provide medical insurance to cover medical care for the minor.
2. A statement authorizing the release of medical information (HIPAA) and emergency treatment in case the parent/legal guardian/emergency contact cannot be reached for permission.
3. A list of any physical, mental or medical conditions the minor may have, including any allergies that could impact his/her participation in the program.
4. All emergency contact information including name, address, and phone number of the emergency contact.
5. A list of Over the Counter (“OTC”) medication and self-administered prescription medication.
6. Agreement to follow guidance from the University concerning communicable diseases.

 

Background Checks

All Covered Programs must warrant that Authorized Adults who have direct contact with minors have submitted to and successfully cleared an Ohio BCI background check, including the National Sex Offender Registry, at a minimum every four years. If an individual has not resided in Ohio for five consecutive years, the individual must have both a BCI and a FBI background check completed. A BCI/FBI background check can be obtained locally by visiting the Sylvania Police Department Monday-Friday between the hours of 8:00am-4:00pm.

Authorized Adults are required to notify the Program Administrator of an arrest (charged with Misdemeanor or Felony) or conviction for an offense within 48 hours of knowledge of the arrest or conviction.