Protection of Non-Student Minors

Policy Number: 12.9
Effective Date: May 1, 2017
Revision History: January 20, 2017
Policy Contact: Director of Operations 

Purpose and Policy Statement

Georgia Gwinnett College is committed to the safety and well-being of all members of our community, including minor children.  This policy establishes requirements for College faculty, staff, students, and volunteers who work or interact with individuals under 18 years of age in College-affiliated or approved programs or activities on campus.  This policy also establishes requirements for non-College organizations and entities that operate programs or activities involving minors on campus. Non-GGC programs are required to be solely responsible for enforcing GGC rules. Failure to do so will result in stiff penalties, including forfeiture of funds and removal of the program from campus at the sole discretion of GGC.

Scope

This policy applies broadly to interactions with minors in all College-run or -approved programs or activities, either on the GGC campus or at GGC-sponsored programs at other locations. All non-College groups and all GGC students, faculty, staff, and volunteers who approve or participate in programs or activities involving minors are responsible for understanding and complying with this policy. The effective date of this policy is May 1, 2017.

This policy does not replace or supplement the following policies that pertain to minors visiting campus in different capacities or GGC faculty, staff, students, or volunteers who work with minors off-campus: 

Administrative Policy Manual 3.15 Classroom Visitors   

Administrative Policy Manual 8.2.15.51 Georgia Gwinnett College Structured Volunteer Policy  

Administrative Policy Manual 8.2.96 Visitors While at Work  

Administrative Policy Manual 9.51 Georgia Gwinnett College Library Facility Use  

Definitions

Minor: A person under the age of 18 who is not enrolled at the College, or who is not considered to be “dually enrolled” in College programs while also enrolled in elementary, middle and/or high school; also referred to as a “participant” in this policy.

College Housing: Facilities providing student living quarters that are owned by, or under the control of, the College.

Authorized Program: A program, activity, or service operated or sponsored by academic or administrative units of the College, or by non-College groups using College facilities (subject to Board of Regents Policy Manual Sections 9.10.6.2 Use of Facilities/Property by Affiliated Organizations and 9.10.6.3 Use of Facilities/Property by Unaffiliated Outside Parties), during which agents, employees or volunteers are responsible for the care, custody, or control of participating minors, rather than their parents or guardians.  For purposes of this policy, Programs do not include:

• Events that are open to the general public and that minors may attend at the sole discretion of their parents or guardians
• Field trips or events in which minors come to campus under the supervision of their school staff
• Institutional Review Board (“IRB”) supervised research activities
• Move On When Ready (“MOWR”) students or enrolled GGC students under the age of 18

Sponsoring Unit: The academic or administrative unit of the College that offers a program or gives approval for housing or use of facilities pursuant to Board of Regents Policy Manual Sections 9.10.6.2 Use of Facilities/Property by Affiliated Organizations and 9.10.6.3 Use of Facilities/Property by Unaffiliated Outside Parties.

 Non-College Group: A non-College group not associated with GGC that seeks approval for use of College facilities pursuant to 9.10.6.3 Use of Facilities/Property by Unaffiliated Outside Parties for the purpose of providing a program or activity that involves minor participants. 

Authorized Adult: Individual who is at least 18 years of age, paid or unpaid, who interacts with, supervises, chaperones, or otherwise oversees minors in program activities, or recreational, and/or residential facilities. This includes but is not limited to faculty, staff, volunteers, GGC students, interns, employees of temporary employment agencies, and independent contractors/consultants. The Authorized Adults’ roles may include but are not limited to positions as counselors, chaperones, coaches, instructors, etc.  Authorized Adults are considered to be mandatory reporters under Georgia law.

Child Abuse: Physical injury or death inflicted upon a child by a parent or caretaker thereof by other than accidental means; neglect or exploitation of a child by a parent or caretaker thereof; sexual abuse of a child; or sexual exploitation of a child. 

College Facilities: Buildings, structures and improvements of all types, outdoor areas, campus grounds, and athletic venues owned or leased by Georgia Gwinnett College. 

Mandatory Reporter: A person who is required by Georgia law to report suspected child abuse to the appropriate authorities. Mandatory Reporters include but are not limited to faculty/teachers, administrators, counselors, social workers, psychologists, law enforcement personnel, and other persons who participate in providing care, treatment, education, training, supervision, coaching, counseling, recreational programs or shelter to minors. Mandatory Reporters whose communications would otherwise be legally privileged are generally required under Georgia law to report suspected child abuse.  

Program Administrator: The person(s) who has primary and direct operational responsibility for managing an Authorized Program.

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

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.

Registration of Programs

Any individual or group who plans to create a program in which minors will participate must register the event by contacting the Director of Operations at least 45 days before the date(s) of the program.  The Director of Operations (678.407.5414, spacemanagement@ggc.edu) will maintain a listing of all programs involving minors, educate program administrators about GGC requirements, including all relevant GGC and state policies, manage any contracts associated with programs, and hold approval authority for all proposed programs.

Parental Notification

Non-College groups will establish a procedure for the notification of the minor’s parent/legal guardian in case of an emergency, including medical or behavioral problem, natural disasters, or other significant program disruptions. Sponsoring units will follow established GGC procedures on parental notification for events and activities involving minors.  Authorized Adults with the program, as well as participants and their parents/legal guardians, must be advised of this procedure in writing prior to the participation of the minors in the program.  

Campus Emergency Notification

In the event of a campus emergency, such as severe weather or security concern, the Director of Operations or a designee will make a good faith effort to notify the program administrator of the concern.  Program staff are responsible for listening for and complying with campus security sirens and warnings.  Program staff are also responsible for monitoring for the possibility of severe weather and making decisions about program operations accordingly. 

Program Participant List

Providing units or non-College groups will provide a list of all program participants and a directory of program staff to the Director of Operations. This list will include at least participants’ names, local room assignments (if applicable), gender, age, addresses, and phone number(s) of parents or legal guardians, as well as emergency contact information.

Participant Contact

Sponsoring units or non-College groups will provide information to parents or legal guardians detailing the manner in which the participant can be contacted during the program. Information must also be collected about who may pick up or obtain information about the participant, including any safety concerns or restraining orders. Any individual authorized to pick up a participant must show identification before the participant will be released to her/him.

Medical Treatment Authorization Form

Sponsoring units or non-College groups will provide a copy of a Medical Treatment Authorization form for each participant. All Medical Treatment Forms must include the following:

1. A statement informing the parent/legal guardian that the College does not provide medical care through GGC Health Services or medical insurance to cover medical care for the minor.
2. Authorization for emergency medical treatment and emergency medical transportation.
3. An opportunity for a participant or parent to list any physical, mental or medical conditions the minor may have, including any allergies that could impact his/her participation in the program or medications that the minor may be taking.
4. At least two emergency contacts with information including name, address and phone number. 

Participant Medication

Participants’ medicines may be distributed by program staff, under the following conditions:

1. The participant’s family provides the medicine in its original pharmacy container labeled with the participant’s name, medicine name, dosage and timing of consumption. Over-the-counter medications must be provided in their manufacturers’ container.
2. The program staff member will allow the participant to self-administer the appropriate dose as shown on the container under supervision of the staff member.
3. Any non-emergency medicine must be stored and administered by a licensed healthcare professional.  Sponsoring units or non-College groups must make arrangements with a health care professional in advance of the participant’s arrival. Georgia Gwinnett College Health Services does not provide medication storage or administration to program participants.
4. Personal Epinephrine Auto-Injectors (EpiPen™) and inhalers may be carried by the participant during activities.

Emergency Medical Services

Sponsoring units or non-College groups will plan for access emergency medical services at all locations. Medical care appropriate for the nature of the events, expected attendance and other variables should be considered.

Laboratory and Research Safety

Sponsoring units or non-College groups will follow appropriate safety measures approved by the Office of Environmental Health and Safety for laboratory and research work, which can be found here.

Assessing Age Appropriateness

Sponsoring units or non-College groups will assess the age-appropriateness of all facilities that will be used during activity(ies).  When participants are minors under eight (8) years of age, special consideration should be given to facility size (e.g., whether young children can reach handrails on stairs or use toilet facilities that are designed for adults) and to child safety recommendations (e.g., eliminating access to cords on window blinds, which are a strangulation hazard). 

Accommodating Transgender Participants

Georgia Gwinnett College staff are available to advise providing units and non-College groups on accommodating transgender/gender non-conforming program participants or Authorized Adults. Requests for assistance should be directed to the Director of Residence Life.

Adequate Supervision

Providing units or non-College groups will ensure adequate supervision of minors while they are on College property. All activities involving minors must be supervised by at least two or more Authorized Adults or by their parent(s) or legal guardian(s) at all times. No one-on-one supervision is allowed. No group will ever be supervised by a single Authorized Adult.  Some of the factors to consider in determining “adequate supervision” are the number and age of participants, the activity(ies) involved, type of housing if applicable, and age and experience of the counselors. See also, item 12.9.17 below.

1. When there are high school students, including prospective athletes, participating in pre-enrollment visitation, the requirement for two Authorized Adults will be waived.
2. All supervised participants in a College program or a program taking place on College property are permitted in the general use facilities (e.g. 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.

Rules and Discipline Measures

Sponsoring units or non-College groups will develop and make available to participants the rules and discipline measures applicable to the program. Program participants and staff must abide by all College regulations, including the GGC’s Non-Discrimination and Harassment policy, which can be found in the Administrative Policy Manual 4.1.2.  Program participants and staff may be removed from the program for non-compliance with regulations and rules. The following must be included in program rules and will be enforced by the unit/program:

1. The possession or use of alcohol and other drugs, fireworks, guns, and other weapons is prohibited.
2. The parking of staff and participant vehicles must be in accordance with College parking regulations.
3. Rules and procedures governing when and under what circumstances participants may leave College property during the program.
4. No violence, including sexual abuse or harassment, will be tolerated.
5. Hazing of any kind is prohibited. Bullying, including verbal, physical, and cyber bullying are prohibited.
6. No use of tobacco products will be tolerated.  All tobacco and e-cigarette use is prohibited on campus, both indoors and outdoors.
7. Misuse or damage of College property is prohibited. Charges will be assessed against those participants who are responsible for damage or misusing College property.
8. 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 Releases

Sponsoring units or non-College groups will obtain all media and liability releases as part of the program registration process. All data gathered is subject to records retention guidelines, and will not be disclosed, except as provided by law.

Age of Camp Staff

Sponsoring units or non-College groups will assign at least one staff member who is at least 21 years of age to be accessible to participants. The staff member(s) must reside in the housing unit, if applicable. Additional Authorized Adults will be assigned to ensure one-on-one contact with minors does not occur and that appropriate levels of supervision are implemented. See also 12.9.19 below.

1. When there are high school students, including prospective athletes, participating in pre-enrollment visitation, the hosting GGC student(s) will not be required to be at least 21 years of age and the requirement for two Authorized Adults will also be waived.

Background Checks

All non-College groups must perform background checks on all Authorized Adults who will have direct contact with minors.  All GGC-run camps must have background checks completed in accordance with Administrative Policy Manual 8.2.99 Background Investigations Policy.

1. When there are high school students, including prospective athletes, participating in pre-enrollment visitation, the hosting GGC student(s) will not be required to undergo a background check.
2. New GGC hires will be required to complete the College background check process at the time of hire.
3. All other GGC faculty/staff, students and volunteers, paid or unpaid, must complete the College background check process 
4. Program staff must notify the Director of Operations within 24 hours if any Authorized Adult is arrested during the duration of the camp.
5. The costs associated with background checks are to be borne by the non-College group. 
6. Each Authorized Adult must undergo a background investigation at least once every three years. 

Supervision of Minors in College Housing

If applicable, sponsoring units or non-College groups will adopt and implement rules and regulations for proper supervision of minors in College housing. The following must be included:

1. Written permission signed by the parent/guardian for the minor to reside in College housing.
2. A curfew time which is age-appropriate for the participants.
3. Guests of participants (other than a parent/legal guardian and other program participants) are restricted to visitation in the residence hall lobby and/or floor meeting areas, and only during approved hours specified by the program.
4. The program must comply with all security measures and procedures specified by GGC’s Departments of Residential Life and Public Safety.
5. Pre-enrollment visit programs for high school students housed overnight in residence halls must be registered with the Office of Residential Life.
6. Parents/guardians are not required to have separate accommodations from their participating child.  Separate accommodations for all other adults and minors are required.

Counselor Ratios, Training, and Tasks

Sponsoring units or non-College groups will require the program to provide and supervise trained counselors (also considered to be Authorized Adults) who must be at least 18 years of age, in accordance with the following:

1. The ratio of counselors to program participants must meet the minimum state ratio requirements, reflect the gender distribution of the participants, and should meet the recommendations of the American Camp Association for staff member-to-camper ratio. 
2. Training for the counselors must include, at a minimum, information about responsibilities and expectations; policies, procedures, and enforcement; appropriate crisis/emergency responses; safety and security precautions, including any specialty equipment or circumstances; confidentiality issues involving minors; and College responsibility/liability. Counselors must know how to request local emergency services and how to report suspected child abuse.
3. Tasks of the counselors must include, at a minimum, informing program participants about safety and security procedures, College rules, rules established by the program, and behavioral expectations. Counselors are responsible for following and enforcing all rules.  They must be able to provide information to program participants and to respond to emergencies.

Mandatory Training

Sponsoring units or non-College groups will attend annual mandatory training, provided either by GGC or a third party provider, training on the conduct requirements of this policy, on protecting participants from abusive emotional and physical treatment, and on appropriate or required reporting of incidents of improper conduct to the proper authorities including, but not limited to, appropriate law enforcement authorities.

Reporting Disclosed or Suspected Abuse

Sponsoring units or non-College groups will report any disclosed or suspected assault or abuse experienced by a program participant, at any time previously or during the program.  The Authorized Adult, as a mandatory reporter under Georgia Law, must inform the Program Administrator, the GGC Public Safety (678.407.5333), and the Office of Diversity, Institutional Equity, and Title IX Program Administration (678.407.5921).

Authorized Adult Behavior

Authorized Adults participating in programs and activities covered by this Policy will not:

1. Have one-on-one contact with minors; there must be two or more Authorized Adults present during activities where minors are present. Authorized Adults also will not have any direct electronic contact with minors without another Authorized Adult being included in the communication.
2. Enter a minor’s room, bathroom facility, or similar area without another Authorized Adult in attendance, consistent with the policy of not having one-on-one contact with minors.  Staffing should be sufficient to allow two Authorized Adults to address any issues in these facilities without leaving other participants unattended.
3. Engage in abusive conduct of any kind toward, or in the presence of, a minor.
4. Strike, hit, administer corporal punishment to, or touch in an inappropriate or illegal manner any minor.
5. Pick up minors from or drop off minors at their homes, other than the driver’s child(ren), except as specifically authorized in writing by the minor’s parent or legal guardian.
6. Provide alcohol or illegal drugs to any minor. Authorized Adults will not provide prescription drugs or any medication to any minor unless specifically authorized in writing by the parent or legal guardian as being required for the minor’s care or the minor’s emergency treatment. Participants’ medicines may be distributed by program staff, following the conditions outlined in this document.
7. Make sexual materials 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.

Allegations of Inappropriate Conduct

If an allegation of inappropriate conduct has been made against an Authorized Adult participating in a program, she/he will discontinue any further participation in programs and activities covered by this policy until such allegation has been satisfactorily resolved.

Compliance

Sponsoring programs and non-College groups must provide evidence of compliance with all of the requirements of this policy at least thirty (30) days prior to the scheduled use of College facilities.  Any college or non-College group required under Georgia law to be licensed to operate must provide a copy of the license or exemption as part of their registration.  A University System of Georgia approved agreement for use of College Facilities, if applicable, must be signed at least thirty (30) days prior to the scheduled use of College facilities. Failure to comply with any provision of this policy may result in Georgia Gwinnett College officials terminating the program. Additional needs of Authorized Programs may need to be addressed in the program approval process to ensure the safety of minor participants and program staff.  These include but are not limited to:

• Safety and security planning;
• Arrangements for required transportation needs;
• Housing needs;
• Response protocols for injuries or illnesses;
• Insurance requirements;

Related Regulations, Statutes, and Policies

GGC Environmental Health and Safety regulations

GGC Parking Regulations

American Camp Association staff member-to-counselor recommended ratios

Institutional Review Board procedures

Georgia Mandated Reporter Law

Board of Regents Policy Manual Sections 9.10.6.2 Use of Facilities/Property by Affiliated Organizations

Board of Regents Policy Manual Section 9.10.6.3 Use of Facilities/Property by Unaffiliated Outside Parties