For CSU’s Protection of Minors Policy please see the policy.

The purpose of this policy is to establish criteria that welcome Minors to the University, minimize the risk of injury, and promote an environment conducive to accomplishment of the University’s mission. The CSU policy provides for minimum standards for all university programs that serve minors. State rules and regulations governing child care programs may apply.

There are many different programs and interactions with minors on campus, and in the community. In recognition of the wide scope and variety of interaction with minors, RMI has compiled general guidance (RMI Guidance) and best practices.

If you consider that your program or interaction is unique, or is not addressed in this guidance, or if you have any questions, please contact Sally Alexander, Director of RMI.

Online/Virtual Programs with Minor Participants

As a result of COVID-19 many youth programs are exploring online or virtual opportunities.

For RMI Guidance and requirements

Background Checks

RMI Guidance and best practices

For CSU’s Background Checks Policy please see the policy.

Section III of the Protection of Minors Policy requires that the program leader ensures that program staff whether paid or unpaid, (this includes faculty, staff, students, and volunteers) successfully complete a criminal background check, including checking the National Sex Offender Registry.

Best practices: background checks are required for anyone who works “directly with Minors.” Program leaders are expected to perform reference checks on employees and volunteers, prior their starting work in the program.

Section III of the policy does provide circumstances where a background check may be waived by RMI.

RMI Guidance: RMI recognizes that it is best practice for all individuals who interact with minors to have successfully completed a background check. The waiver of a background check can only be provided by RMI, provided sufficient information is provided, and certain criteria are met. RMI will always err on the side of caution.

Convenience and expense will never be a reason not to require a background check.

The following factors may be taken into account when waiving a background check: –

•The program or activity is a discrete, occasional event that is operated entirely in public

•The individuals concerned are one time/ once- off assignments, and the conducting of a background check is unreasonable

•Examples of a background check being unreasonable include – where the individual is in fact the parent/ legal guardian of the minor/s supervised; where the discrete event, or one time activity is unexpected provided other best practices are followed, or where individuals can show that they have already successfully completed a background check.

•Other factors that RMI may take into account in waiving this requirement include – the level of intimacy (where one to one interactions are low or non existent), where individuals would be working in public places, and where individuals would be directly supervised by a person who has undergone a background check.

The waiver for a background check must be requested by the program leader, and must clearly explain why the check is unreasonable, and clearly describe what other best practices will be followed.

Please note that third party programs are required to attest that their employees, staff and volunteers have all successfully completed a background check.

One to one Interactions

We recommend limited one to one interactions between employees, volunteers and youth but we do know that sometimes these situations are unavoidable.

RMI Guidance and best practices

Please ensure that one or more of following best practices are followed (as appropriate): –

•Have another employee randomly drop in

•Only meet with youth/ minor while in full view of other employees – for example doors are open and windows are uncovered

•Inform other staff members/ responsible individuals that you are having a one to one session.

•Ensure that you document any unusual incidents, including behavioral problems and how they were handled.

Minors & Social Media

RMI Guidance and best practices

In order to prevent incidents of abuse and false accusations we recommend the following best practices (as applicable) where programs involves minors and social media:

•Create an official “public page” on social media so that employees and volunteers can communicate with youths/ minors in a public and monitored forum. See CSU’s Social Media policy.

•Prohibit employees and volunteers from interacting with youths/ minors privately on social media sites. This includes direct, and indirect messaging.

•If employees or volunteers must text or email youths, please ensure that they copy in a supervisor or a parent in any communication.

Adult to child ratio

For programs involving minors, the policy recommends an adult to minor ratio of 1:12 with a higher ratio of adults for younger children.

RMI Guidance and best practices

Please remember that programs such as licensed child care centers must comply with applicable state regulations.

This guidance does not apply to counseling or therapy conducted by licensed psychologists. Depending on the age, and the activities consider the gender distribution of participants when planning supervision.

For ages 4-8 years; adult to child ratio of between 1:5 and 1:8 is acceptable. For ages 8-14 years, ratio between 1:8 and 1:11 is acceptable. For ages 15 – 17 years, ratio 1:12 is acceptable.

Program Plans

Section V of the policy requires that programs sponsored by a college, department or unit that involve minors coming to campus, or interactions with minor off campus are required to have a program plan.

The program plan must be approved by Director, Department Head or Higher Authority.

RMI Guidance and best practices

The policy references a sample plan. While, there is no prescribed format that the program plan has to follow, we recommend that you use the sample plan (docx).

An acceptable program plan (in any format) must include at least the following:

•A health and safety plan. (Where applicable discuss medical treatment authorization, media release, liability waivers, parental/ legal guardian/ emergency contact information, treatment procedures – incident report/ health log, adequate supervision (ratio), inclement weather plan, emergency response, missing/ runaway participant procedures)

•Enrollment materials that include appropriate disclosures of the nature of the Program, including requirements for participation.

•Reliable methods of ensuring adequate supervision of Minors at all times. (This references discussion on adult to child ratio, and other interactions.)

 •Documents such as participation agreements, incident report forms, parental permission agreements, emergency contact information, medical release forms, and waivers from the Office of Risk Management or CSU Extension.

•Appropriate training of Program staff (including familiarity with this policy).

•Any liability waivers collected by the Program should be retained for two years after the end of the Program.

•Adult: child supervision ratios within an age- and activity-appropriate range (generally, not less than one adult for every 12 Minors, with a higher ratio of adults for younger children). If any of these sections are not applicable, please include a brief description.

Other areas to include where appropriate include conduct expectations and consequences, housing specifics program/ event staff/ volunteers, programming risks and any departmental specific plan requirements.

Additional Resources

National Sex Offender Public Website (external link)

CO4kids (external link) (Public awareness, and education.)

CSU Tell Someone

Managing the Risks of Minors on Campus, Gallagher (PDF)

RMI Sample Documents

 Sample Photography Consent Form (PDF)

Sample Parent Consent Emergency Contact (PDF)

Sample Health Log (PDF)