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UWEC 625.A, Protecting Youth

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Procedure #: UWEC 625.A

Intent

This purpose of the practice directive is to establish minimum standards for the protection of minors engaged in covered activities at UW-Eau Claire. This procedure supports practice directive UWEC 625, Youth Protection and Compliance.

Scope

The scope of this procedure is limited to youth participants in covered activities. The policy only applies to events which are targeted towards youth participants in covered activities. Activities that are exempt from this policy include:

  1. Events open to the general public,
  2. For-credit courses,
  3. Medical care provided to minors in in-patient or out-patient settings,
  4. Institutional Review Board-approved research,
  5. Daycare and preschool services operating under the direction of a licensed daycare or healthcare provider,
  6. Private events, or
  7. Minors participating in pre-enrollment visitation or recruiting activities governed by the NCAA.

Children brought into a campus workplace by an employee are covered under practice directive UWEC 239, Children in the Workplace.

Definitions

Terms included in this procedure are consistent with definitions included in SYS 625, Youth Protection and Compliance, and are defined for purposes of this procedure and may not be consistent with definitions used in other settings.

Procedures

  • Requirements
  • Complete the Youth Activity Registration e-Form.
  • Register staff who will be working at the Youth Activity.
  • Register all youth who will be attending the Youth Activity.
  • Ensure all staff are properly screened before the start date of the Youth Activity.
  • Ensure all staff have completed the necessary training before the start of the Youth Activity.
  • Ensure staff and participants are aware of behavioral standards and expectations.
  • Meet the required supervision ratios for staff and minors.
  • Prepare and distribute a Safety & Emergency Plan with all staff before the start of the Youth Activity.
  • Ensure staff are prepared to report incidents of abuse and neglect.

Requirements

These requirements are intended to align with SYS 625, Youth Protection and Compliance.

Institutional Oversight

The Office of Risk Management, Safety and Sustainability has the responsibility and authority to oversee and ensure that covered activities are conducted pursuant to SYS 625, Youth Protection and Compliance and applicable UW-Eau Claire practice directives, procedures and policies.

The Director of Risk Management, Safety & Sustainability will designate a youth protection liaison to be the main point of contact with UW System for SYS 625, Youth Protection and Compliance.

Institutional Sponsor

All Covered Activities that are organized, sponsored, and/or operated by UW-Eau Claire must have a designated Institutional Sponsor (also known as a Sponsoring Unit).

Registration

Covered activities must register annually with the Office of Risk Management, Safety & Sustainability.

Covered activities providing custodial care which are organized, sponsored, and/or operated by UW-Eau Claire must have a designated Institutional Sponsor and require registration of youth participants. Registration information collected must include:

  • Name
  • Contact information, including emergency contact information

The Office of Risk Management, Safety & Sustainability must be granted access to Third Party contracts for covered activities upon request.

Screening

All designated individuals serving in covered activities through which UW-Eau Claire offers custodial care, regardless of employment status, must be screened through a reference check process in alignment with the minimum standards found in SYS 1275, Recruitment Policies.

All applicable data management and record retention policies must be followed for purposes of retaining this information.

Training

Prior to interaction with youth participants in Covered Activities, authorized adults must be trained on reporting responsibilities, including EO54 Mandated Reporting and sexual harassment/sexual violence reporting.

Prior to interaction with youth participants in Covered Activities, designated individuals must be trained on the following content:

  • Institutional youth protection best practices; and
  • Reporting responsibilities, including EO54 Mandated Reporting and sexual harassment/sexual violence reporting.

The Office of Risk Management, Safety & Sustainability may require additional training based on the individual’s role or level of risk associated with the covered activity (e.g., duration of program, type of activities) and applicable legal requirements.

Prohibited Behaviors

All UW-Eau Claire employees and students are responsible for identifying, monitoring and reporting prohibited behaviors. Prohibited behaviors include, but is not limited to, the following:

  • Conduct that violates the law (e.g., child abuse, child sexual abuse, protected class discrimination, emotional abuse, hazing, indecent exposure, child pornography, neglect, physical abuse, sexual abuse, and sexual harassment);
  • Conduct that violates UW System policies;
  • Actions that are found to constitute bullying or grooming;
  • Infringement on privacy of Youth Participants in situations where they are changing clothes or taking showers except in situations where health and safety require;
  • Adults showering, bathing, or undressing with or in the presence of youth participants;
  • Use of such devices capable of recording or transmitting visual images in shower houses, restrooms, or other areas where privacy is expected by participants; and
  • Use of alcohol when engaged in covered activities.
Measures to Maintain adequate Supervision of Youth Participants

Supervision ratios in covered activities must meet the minimum standards set through ATCP 78.18(1) and ATCP 78.18(5), with the exception of classroom settings, which allow for a 1:18 Adult to Youth Participant ratio. A minimum of two adults is required for all field trips. Designated individual status is required for all adults serving in supervision ratios.

One-on-one interactions between adults and youth participants is prohibited, unless the adult is a designated individual in a setting where one-on-one instruction occurs. In such settings, activities must be observable and interruptible.

The Office of Risk Management, Safety & Sustainability will review and may approve exceptions to supervision requirements, including where a familial relationship exists.

Overnight Covered Activities

Designated individual status is required to directly supervise youth in overnight covered activities.

Designated individuals must not enter the youth participant’s room, bathroom facility, or similar area without another designated individual in attendance except in emergency situations.

Designated individuals may not share a bed or sleeping bag with a youth participant during overnight covered activities.

Emergency Preparedness

All covered activities must document minimum emergency preparedness protocols based on the covered activity’s level of risk and as advised by the Office of Risk Management, Safety & Sustainability.

Insurance Coverage

All covered activities must be covered by Camps and Clinics Blanket Accident Insurance or other insurance product(s) as applicable and approved by the Office of Risk Management, Safety & Sustainability.

Reporting Obligations

Adults covered under this practice directive must immediately report any suspected physical abuse, neglect or sexual abuse of a minor pursuant to UW-Eau Claire’s Mandatory Reporting of Child Abuse and Neglect policy.

Adults covered under this practice directive must report the following incidents that occur within a covered activity to the Office of Risk Management, Safety & Sustainability:

The Office of Risk Management, Safety & Sustainability may identify additional reportable incidents.

The Office of Risk Management, Safety & Sustainability will publish an Escalation Matrix to guide decision-making around incidents that violate policy or trigger a reporting obligation.

Retaliation

Retaliatory actions against the following is prohibited:

  • Anyone acting in good faith to report a concern about possible violations of System or UW-Eau Claire policy or practice directive;
  • Individuals involved in investigating or responding to concerns; and
  • Anyone involved in enforcement of youth protection policy.
Consequences for Noncompliance

Violations of this practice directive and/or associated policies, protocols, practice directives or procedures may be subject to program termination, and/or disciplinary action, including removal from the role or authorization to work with minors, in accordance with UW-Eau Claire policies, practice directives and procedures.

Third Parties

Third Parties engaged in Covered Activities must sign a contract that includes, at minimum, the following:

  • Clear allocation of responsibility for risks posed by the Covered Activity to the Third Party;
  • Representation that Third Parties engaged in Covered Activities meet the minimum requirements outlined in Sections 4 through 12 of this practice directive. Third Parties are also required to maintain event data equivalent to that outlined in Sections 3.a and 3.b.
  • Requirement to submit a list of names and dates of birth of all authorized adults and youth participants who participated in the Covered Activity to the Office of Risk Management, Safety & Sustainability within thirty (30) days of the end date identified in the contract.
  • Inform Third Parties that audits on requirements in this section may occur at any time within seven (7) years following the conclusion of the event.
Data Retention

Covered Activities must store protected health information and other confidential and sensitive data according to Regent Policy Document 25-5, Information Technology: Information Security.

Complete the Activity Registration e-Form

Provide general information on the Youth Activity (dates, locations, staff, participants, activities, logistics, etc.)

StepAction
1.Review Youth Protection Program webpage here.
2.Gather information on the Youth Activity (participant/staff numbers, locations, activities, days, etc.).
3.Register the Youth Activity here.
4.Await feedback and respond to follow-up questions (if needed).
5.Once the Activity is approved, await further instruction regarding the next steps for compliance.

Register staff who will be working at the Activity

Provide names, email addresses, and information on their relationship to UWEC.

StepAction
1.Fill out the Authorized Adults List by including all faculty, staff, students, and volunteers.
2.Include names, email addresses, roles, and employment status of all adults.
3.Send Authorized Adults List via email to Andrew Suralski at suralsaw@uwec.edu.

Register all youth who will be attending the Activity

This information will promote safer outcomes for minors involved in Activities at UWEC.

StepAction
1.Communicate practice directive UWEC 625, Youth Protection and Compliance with parents and/or guardians, including participant registration.
2.Create a profile for the Youth Activity via CampWise.
3.Ask parents and/or guardians to register youth for the Youth Activity via CampWise.
4.Ensure all youth participants have been registered prior to the start of the Youth Activity.

Ensure all staff are properly screened before the start date of the Activity

Criminal Background Checks (CBCs) are required for all Activity Staff who will be interacting with minors.

StepAction
1.Complete Affiliate Request eform (via HR) for non-university volunteer staff (if applicable).
2.Activity Director will receive a shared document showing the status of staff CBCs and online training.
3.Review shared document regularly and stay in contact with Andrew Suralski at suralsaw@uwec.edu if there are changes.
4.Using shared document, ensure all staff have been screened prior to the start of the Activity.

Ensure all staff have completed the necessary training before the start of the Activity

A 12-minute online course is required for all Activity Staff.

StepAction
1.Wait for confirmation that staff have been entered into Vector Safe Colleges to begin online training.
2.Notify staff to respond to Vector emails in order to confirm account creation.
3.Remind staff to complete “Camps on Campus” online training prior to the start of the Activity.
4.Using shared document, ensure all staff have completed training prior to the start of the Activity.

Ensure staff and participants are aware of behavioral standards and expectations

Staff must review and sign a waiver before working at the Youth Activity.

StepAction
1.Ask your staff to review and sign the Behavioral Expectations for Authorized Adults waiver.
2.Keep all waivers for your records (RMSS may ask for these records to verify compliance).

Meet the required supervision ratios for staff and minors

Activity Directors must provide the appropriate number of Activity Staff to stay within the ratio.

StepAction
1.Review SYS 625, Youth Protection and Compliance section 6.G, Measures to Maintain adequate Supervision of Youth Participants.
2.Confirm that your staff numbers are in line with the supervision ratio requirement set by the policy.

Prepare and distribute a Safety & Emergency Plan with all staff before the start of the Activity

This plan is meant to be a go-to resource for Activity Staff in the event of an emergency.

StepAction
1.Find a copy of all relevant emergency maps for your Activity.
2.Starting from a provided template, fill out the Safety & Emergency Plan with input from your staff.
3.Share the Safety & Emergency Plan and emergency maps with your staff.
4.Communicate the important takeaways from these resources with your staff prior to the Activity.

Ensure staff are prepared to report incidents of abuse and neglect

Activity Directors should communicate the process with Activity Staff prior to the beginning of the Activity.

StepAction
1.Include emergency contact phone number for Activity Director in the Safety & Emergency Plan.
2.Include 911 in Safety & Emergency Plan (this number is for emergencies only).
3.Include (715) 839-4972 In Safety & Emergency Plan (for urgent but non-emergency responses).

Resources

Practice Directive UWEC 625, Youth Protection and Compliance

Practice Directive UWEC 239, Children in the Workplace

Procedure UWEC 239.A, Bringing Children to Work

UW-Eau Claire Youth Protection Program website

UW System Youth Protection website

Youth Activity Registration Form

Procedure Administration

Version NumberV1.0
Approval AuthorityVice Chancellor for Finance & Administration
Approval DateMarch 1, 2023
Next Review DateMarch 1, 2024
DivisionFinance & Administration
DepartmentRisk Management, Safety & Sustainability
ContactDirector of Risk Management, Safety & Sustainability | safety@uwec.edu

Revision History

VersionRevision DateDescription of ChangeAuthor(s)
1.0March 1, 2023Initial issuanceAndrew Suralski

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