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Name: Minors on Campus, Children in the Workplace, and Child Protection Policy - Interim
Responsible Office: Office of Public Safety

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff , Students , Contractors_Vendors

Policy Overview:

Issued: 02-21-2018
Next Review Date: 09-21-2019
Frequency of Reviews: Every 2 Years

St. Louis College of Pharmacy is responsible for maintaining a registry of all programs on for minors on the campus and affiliated with the College. The College hosts a wide variety of college-sponsored activities for non-enrolled minors such as camps, clinics, workshops, conferences, and other educational activities. Further, minor children or relatives of employees are often visitors in the workplace.  It is critical that minors on St. Louis College of Pharmacy’s campus are overseen in an appropriate fashion intended to keep them healthy and safe while visiting the campus. Per the details of this policy, unsupervised or unescorted minors are not permitted on St. Louis College of Pharmacy campus.

Applies to all schools, departments, offices, and other units of St. Louis College of Pharmacy, all non-STLCOP organizations that operate programs for minors in STLCOP facilities, and all members of the college community- Faculty, staff, students, and volunteers.


Definitions:

Term

Definition

Child

Any person less than fourteen (14) years of age.

Authorized Adult and/or Chaperone and/or Program Staff

Any individual, paid or unpaid, employee of the College or volunteer, who interact with, chaperone, supervise, or oversee minors in program activities affiliated with St. Louis College of Pharmacy and/or its residential facilities. Chaperones of program activities with minors must be at least eighteen (18) years of age to be considered Program Staff. This definition does not include guest speakers, presenters, or those who do not have direct contact with program participants other than short-term activities supervised by program staff.

Minor

Any person less than eighteen (18) years of age that is not enrolled in the College.

Direct contact

Providing care, supervision, guidance, or control of minors or having interaction with minors.

One-on-One contact

Personal, unsupervised interaction between any authorized adult and a minor participant without at least one other authorized adult, parent, or legal guardian being present.

Program

Any programs, activities, camps, or campus events offered by various academic or administrative departments of the College or by third-party groups using College facilities. This includes, but is not limited to, workshops, sport camps, academic camps, conferences, pre-enrollment tours, and other similar activities.

Program Administrator

An individual that is designated as the primary contact for the Program. The Program Administrator must be a St. Louis College of Pharmacy faculty or staff member and be at least twenty-one (21) years of age.

Child Abuse

Any type of cruelty visited upon a child includes physical battery, mental or emotional abuse, exploitation, neglect, and sexual abuse.

 

Missouri definition of Child Abuse

An act or failure to act that: 1. Results in imminent risk or seious harm to a child’s health and welfare due to physical, emotional, or sexual abuse; 2. Affects the child (under the age of 18 in Missouri); 3. By a parent or caregiver who is responsible for the child’s welfare.

Details:

I.     All programs and activities that involve minors in their activities will fall within the scope of this policy including, but not limited to:

a. Programs operated by the College or third-party entities, programs taking place on campus and programs under the direction and authority of the College at locations off campus.

II. Exceptions

a. Undergraduate and professional academic programs in which minors are enrolled for academic credit;
b. Other programs that are designated on a case-by-case basis, by the institutional events manager, in advance and in writing from this policy.

III. Program Rules of Conduct

a. Program Administrator, and point of contact must be determined upon program application.
b. It is the responsibility of the Program Staff to:

i. Inform program participants about safety and security procedures;
ii. St. Louis College of Pharmacy campus rules;
iii. Rules established by the Institutional Events Manager;
iv. Rules established by the Program and behavioral expectations;
v. Any additional rules set forth by the Public Safety, Facilities, or emergency management coordinator;

c. Program documentation must be submitted to the Institutional Events Manager prior to registering the event in the event management system.
d. Programs with Minors staying overnight:

i. It is the responsibility of the Program Staff to:

1. Remain on call 24 hours a day while the program is in session;
2. Maintain discipline among the participants in compliance with the College and Residence Hall rules;
3. Arranging of medical transport in all cases of illness and injury occurring during the program, and seeing that all appropriate insurance forms and information are provided;
4. Maintaining regular and open communication with St. Louis College of Pharmacy Public Safety and College Operations.

ii. Minors that are not family are never allowed to sleep in the same room overnight with an employee of the College unless the child’s parent is also in the room with the minor.
iii. Male and Female minors are never assigned nor permitted to sleep in the same room overnight unless accompanied by and with permission of parents of the minors.

e. Minors are not allowed in high-risk areas, under any circumstances including:

i. Laboratories (refer to the Minors in Laboratories policy);
ii. Shops;
iii. Mechanical rooms;
iv. Food preparation areas;
v. IDF closets or any IT equipment closet;
vi. Garage areas while unsupervised;

f. Program administrator is responsible for ensuring all Program staff have completed necessary steps as listed in Appendix A.
g. Minors are accompanied at all times and not permitted to work alone in case of emergency.

IV. Program Evaluation

a. All existing and recurring programs should evaluate the structure of the Program and the suitability of the environment in which the Program operates or will operate to determine if all steps have been taken to ensure the safety and wellness of minors involved. In addition, the Program’s plans to respond to emergency situations should be addressed. A risk assessment worksheet, required to be submitted to the emergency management coordinator with sample risk factors to consider can be found at the end of this policy in Appendix B.

V. Child Protection

a. All children have the right to be safe and protected from harm in any and all environments. St. Louis College of Pharmacy embraces this right to safety and is dedicated to promoting and ensuring the protection of all children. The College will take reasonable steps to create a safe environment for children and young people, to prevent their physical abuse, sexual abuse and neglect. It is the expectation of the College that all persons covered under this policy comply with the provisions stated in this policy.
b. All Program staff are responsible for completing all the necessary programs with minor’s components prior to the start date of the program as defined in Appendix A. All Program staff of programs with minors, regardless of if they have direct contact with minors or not, are responsible for completing and accessing the “Protecting Children: Shine A Light” MOODLE lesson located on Emergency Management for Faculty and Staff.
c. Media, Photo, and Video of Youth Programs

i. Faculty, staff and students are prohibited from capturing photos, videos and all other forms of media that may feature minors attending College-affiliated programs.
ii. When capturing media for promotional purposes, it is the responsibility of the individual creating the media to obtain a photo/video release and maintain release records in accordance with the College’s record retention policies.
iii. Interested parties should, with the Office of Marketing and Communications, obtain photography and videography services during College-affiliated programs.
iv. When the media constitutes a business need or opportunity aligned with the College marketing objectives, the Office of Marketing and Communications may produce the media. In other cases, the office will assist program administrators in securing and negotiating freelance services at the cost of the program.
v. Official, external marketing and advertising for College-affiliated programs must be coordinated through the Office of Marketing and Communications. 

d. Code of Conduct

i. Authorized adults and Program staff are prohibited from the following in connection with programs involving minors on campus:

1. Encouraging minors to keep secrets from their parents;
2. Having one-on-one contact with minors outside the presence of others;
3. Individual music or athletic lessons without the presence of the minor’s legal guardian;
4. Sharing the same sleeping bag or room as a minor without the presence of the minor’s parent or legal guardian;
5. Showering, bathing, or undressing with or in the presence of minors;
6. Engaging in abusive conduct toward a minor, including but not limited to striking, hitting, punching, poking, spanking, restraining, verbal abuse, or any acts intended to cause humiliation or degradation;
7. Touching in an inappropriate or illegal manner any minor;
8. Use of a personal vehicle to pick up or drop off minor participating in the program unless the parent or legal guardian of the minor has provided written permission;
9. Coercing minors into inappropriate acts, pranks, or jokes of any kind;
10. Hazing or bullying of any kind including verbal, physical, and cyber bullying;
11. Engaging in the use of alcohol or substances, or being under the influence of alcohol or drugs during Programs;
12. Making any form of pornography available to minors or assisting them in gaining access or allowing access to pornographic material;
13. Engaging in intimate displays of affection toward others in the presence of minors;
14. Taking any photos or videos of minors and posting on a digital, electronic, hosted media, or web-based service or any other medium without first obtaining a release from the Minor’s parent or legal guardian;
15. Failing to report abuse, harassment, or exploitation of minors in the Program that you are made aware of.

VI. Mandatory Reporting of Child Abuse

a. Program staff are required to report any confirmed or suspected child abuse of minors involved in College programs. It is not required that program staff have proof that abuse has occurred. Any program staff with reasonable cause to suspect that a child has been or may be subjected to abuse or neglect or observes such conditions or circumstances that would reasonably result in abuse or neglect are mandated to report it to officials. Reasonable cause to suspect means a standard of reasonable suspicion, rather than conclusive proof. When a person is required to report in an official capacity as a staff member, the person in charge shall be notified. That person in charge becomes responsible for immediately making or causing a report to be made. No supervisor or program administrator may impede or inhibit any reporting.
b. If you suspect child abuse, immediately notify STLCOP Public Safety at 314-446-7233 (SAFE) who will then notify the Missouri Division of Family Services.
c. If the minor is in imminent danger, immediately contact 911.
d. Any St. Louis College of Pharmacy employee making a report shall be subject to any sanction, including any adverse employment action, for making such report.
e. Any St. Louis College of Pharmacy employee who willfully fails to report a case of suspected child abuse is subject to disciplinary action, up to and including, dismissal and is subject to penalty of a Class A Misdemeanor under Missouri State Law.

VII. Children in the Workplace

a. St. Louis College of Pharmacy values its employees and strives to support them through employment policies and benefit programs. STLCOP also strives to provide an environment open to work and family balance.
b. St. Louis College of Pharmacy is a diverse environment of classrooms, offices, laboratories, recreation and other common areas. Visitors, including children are welcome; however, appropriate precautions and limitations on visitation are necessary to protect health and safety and to maintain productivity and regulatory compliance. Safety is a primary concern, and the majority of our facilities are not designed for occupancy by children. Generally, the presence of children in the workplace during a parent’s workday is inappropriate and should be avoided. If it is necessary to bring a child to work, this policy is established to reduce job disruption, property liability and to preserve the College’s professional work environment. Please observe the following guidelines when children visit our campus:

i. Employees must always obtain supervisor approval to bring children into the workplace;
ii. Children are not to be brought to work on a regular basis in lieu of childcare;
iii. Children may be brought to work only occasionally, for the convenience of the employee or due to a family emergency;
iv. Parent or guardian must provide supervision at all times;
v. Children should not be left unattended or with other employees;
vi. Children should not interfere with workplace activities;

c. If it is necessary to bring a child to work, the supervisor will consider the age of the child, how long the child must be present, the employee’s work environment and potential disruption. Ill children should not be brought into the workplace, and the supervisor may ask that the child leave at his/her discretion.
d. Exceptions may be granted to the above restrictions at the discretion of the requesting employee’s supervisor, Human Resources, or Director, Public Safety.


Procedures:

The following policy procedures apply to any program administrator, sponsoring department offering or approving a program which involves minors or provides university housing for minors participating in a program, whether utilizing College housing or not.

I. Participant Registration

a. Program administrators are responsible for registering their event with the Institutional Events Manager at least 8 weeks before the start date of the Program.
b. Prior to registering the event in the St. Louis College of Pharmacy Event Management System, program administrators are responsible for completing and returning forms found in Appendices B-D to the emergency management coordinator.
c. A Program Administrator, and point of contact must be determined upon program application.
d. Additional participant information may be needed, such as medical treatment authorization, participant agreement/waiver forms, medical disclosure forms depending on the characteristics and duration of the Program. A waiver form can be referenced in Appendix E of this policy. Program staff must keep a file of any medical disclosure forms or copies of Appendix E on file for the duration of the program. Due to sensitive information that may be included on a program participant’s medical disclosure form, forms must be kept in a secure location in which only the Program Administrator has access.

II. Program Staff and Administrator Responsibilities

a. Any program participant who has been convicted, found guilty, or plead guilty or no contest to a crime involving child abuse or a sex related offense must disclose such information to the Program Administrator. The Program Administrator will review the Missouri Family Care Safety Registry and Missouri Sex Offender Registry for all program staff as part of the screening process. Any positive reports will be shared with the College’s Director of Human Resources and Director of Public Safety who shall immediately take the necessary steps to restrict the program staff member’s participation in the program until a full review can be completed.
b. Criminal background checks are required for all program staff with programs involving minors.
c. Background checks can be obtained through the Office of Human Resources and must be renewed on an annual basis. Background checks must be paid for by the program administrator, their department, or by the hosting organization if program staff includes non-STLCOP employees using College facilities.
d. Criminal background checks for programs involving minors are required when:

i. Minors attend camp and are not accompanied by an adult or chaperone
ii. Minors stay overnight with program staff
iii. Non-STLCOP staff of programs using STLCOP facilities

III. “Protecting Children: Shine a Light” MOODLE Training

a. Training for program staff is available through United Educators and can be found on MOODLE under Emergency Management for Faculty and Staff.
b. Once program staff have completed the training, the training certificate must then be saved and uploaded onto MOODLE under “Shine a Light: certificate turn-in”. Training will not be complete without turning in the certificate.

IV. Emergency Procedures and Medical Plan

a. Program administrators are responsible for completing the plan found in Appendix B for responding to emergency events, including communication to participants, parents/guardians, and College personnel, and shall understand how emergency situations at the Program level interface with the College emergency plans.

V. Program Staff to Participant Ratio

a. The following illustrates the mandatory staff-to-participant ratio.
b. Ratios should be maintained at all times:

i. One adult chaperone for every 5 participants ages under Six (6);
ii. One adult chaperone for every 10 participants ages 6-11;
iii. One adult chaperone for every 15 participants ages 12 and older;
iv. One adult chaperone for every 15 overnight participants 14 and older;

Responsibilities:

Position/Office/Department

Responsibility

Program Administrators

Completing and returning all forms located in the appendices of this Policy to the Emergency management coordinator. Program administrators are also responsible for registering their event in the college event management system at least 8 weeks prior to the start of their event. Program administrators are responsible for completing the risk assessment plan found in the appendix of this policy and returning it to the emergency management coordinator.

Program Staff

All program staff are responsible for informing program participants about safety and security procedures, St. Louis College of Pharmacy campus rules, rules established by the Institutional Events Manager, rules established by the Program and behavioral expectations, and any additional rules set forth by the Public Safety, Facilities, or emergency management coordinator.

 

Program Administrators and Program Staff

All those affiliated with the program involving minors are responsible for completing the necessary training available on the Emergency Management for Faculty and Staff MOODLE page titled “Protecting Children: Shine a Light”.

Resources:

Minors in Laboratories Policy