Minors and Children on Campus Policy

Gettysburg College is committed to the safety of all individuals in its community. The College has particular concern for those who are potentially vulnerable, including minor children, who require special attention and protection. The College has established this Minors and Children on Campus Policy to protect those under the age of 18 who participate in programs and activities associated with the College and to provide guidance to College students, faculty, administrators, support staff, and volunteers who are involved with such programs and activities.

Programs and activities that involve children and minors are important to Gettysburg College. From childcare services for employees to a broad range of academic, athletic, enrichment, and other programs during the summer and the academic year, the College is engaged in providing opportunities for minors. The College also allows certain outside organizations and groups to use the campus for programs that involve minors. At the core of all of these programs is a commitment to providing a safe environment and a positive experience for all participants.

II. Scope

This policy provides the guidelines that apply broadly to interactions between minors and College students, faculty, administrators, support staff and volunteers in College-run or College-affiliated programs, events or activities. This policy also establishes requirements for non-College organizations and entities that operate programs or activities involving minors on campus, and College agreements with such organizations and entities shall reflect those requirements.

The policy sets forth guidelines to help prevent the abuse or neglect of those under 18 years of age and for reporting and responding to incidents in which the safety of minors may be compromised. In addition to increasing awareness of minor abuse and neglect among all members of the College community and requiring reporting, it imposes additional requirements (training and background checks) on those who participate in programs or activities involving minors.

All Gettysburg College faculty, administrators, support staff, students, and volunteers are responsible for understanding and complying with this Policy.

III. Definitions

Child or Children refers to any person or persons under 18 years of age.

Child Abuse, for purposes of this Policy, means infliction of physical or mental harm, abuse or exploitation or negligent treatment or maltreatment of a Child. The definition includes sexual abuse of a Child.

Campus for purposes of this policy means all buildings, facilities, and properties that are owned, operated, managed, or controlled by the College. This also includes areas immediately adjacent to campus.

ChildLine is an organizational unit of the Commonwealth of Pennsylvania’ Department of Public Welfare, which operates a statewide 24-hour toll-free system for receiving reports of suspected Child Abuse and refers such reports for investigation and maintains the reports in the appropriate file. The telephone number for the ChildLine is 800-932-0313.

College employees for purposes of this policy include faculty, administrators, support staff and students who are employed by the College.

Covered programs are programs, events or activities that Gettysburg College operates in which College employees or volunteers engage through their College roles. This term does not include programs or activities in which one may engage that are unrelated to one’s status as a member of the College’s faculty, administration, support staff or student body.

Programs or services that serve Children conducted or provided by an outside entity or individual on College premises are not Covered programs under this policy. However, such entities/individuals will be required, by contract, to comply with applicable laws regarding Minors and Children.

Minor, for the purposes of this policy, means a person under the age of 18. Gettysburg College students and prospective students visiting campus who are under the age of 18 are excluded from this definition. Dual-enrolled students (i.e. student enrolled at Gettysburg as well as in a secondary school) and high school students who are auditing a course on campus are included within the definition of Minor.

Gettysburg College students who are under the age of 18 and who, in their employment or volunteer activities in Covered programs have interactions with Children, are subject to the same requirements as employees and volunteers who are 18 years of age or older.

Sponsored programs are programs that are sponsored by a member of the College community in order to be able to use College facilities without charge. Programs that lease College facilities pursuant to a Facilities Use Agreement with the College are NOT included in this definition.

Volunteers, for the purposes of this policy, are persons who are not paid for the services they provide.

IV. Guidelines and Responsibilities

College employees and volunteers in Covered programs that involve interactions with Children must:

Always be vigilant in protecting the well-being and safety of Children with whom they interact on campus and elsewhere.
Review the informational material about the signs of Child Abuse provided in Appendix A from the childwelfare.gov site.
Watch for signs of Child Abuse and promptly report suspected instances of Child Abuse, or violations of this policy or applicable law, as provided in Sections VII below.
Before engaging in any Covered program involving contact with Minors: meet the applicable requirements of this Policy relating to training (Section V) and criminal background checks (Section VI).

Any employee of the College who reasonably suspects that a Child has been abused or neglected must make reports as required by Sections VII and VIII.

To the extent College faculty, administrators, support staff, students and volunteers are participating in programs or activities run by a non-College organization or entity off campus, they should familiarize themselves with, and follow the policies of the organization relating to interactions with minors and understand their legal obligations with respect to working with minors in the program setting.

Information about the signs of Child Abuse appears in Appendix A.

V. Training for Those Participating in Programs and Activities

College employees and volunteers who participate in covered programs involving minors must complete appropriate mandatory reporter training through Vector Solutions. Enrollment for this training, Protect Children (PA), requires individual registration. Please contact lculley@gettysburg.edu for course enrollment instructions. Mandatory reporter training is valid for 3 years.

This training includes:

Recognizing the signs and types of child abuse and your reporting obligations.
Recognizing predatory behavior and avoid placing children at risk.
Report your reasonable suspicions of child abuse.

VI. Criminal Background Checks

Certain College employees and volunteers will be required to clear criminal background checks prior to participation in Covered programs College-run or College-affiliated activities involving Minors. The categories of individuals who must undergo background checks are listed in Appendix C.

If the criminal background check reveals adverse information or unfavorable results, the College will conduct an individualized assessment using relevant considerations designed to identify potential risk to Minors.

The existence of a criminal conviction does not automatically disqualify an individual from employment or volunteer work. Relevant considerations may include, but are not limited to: the individual’s age at the time of the offense; the nature and seriousness of the offense; the amount of time that has elapsed since the offense; any information provided by the individual regarding his/her rehabilitation or good conduct; the duties and responsibilities of the position sought or held by the individual, and the effect of the conviction on the individual's ability to perform these duties. EEOC guidelines (http://www.eeoc.gov/laws/guidance/arrest_conviction.cfm) provide specific instructions about fair application of a criminal background check.

Within the confidential process of their decision making, the Co-Director of Human Resources and the Hiring Manager should explicitly determine that the criminal record is judged to be correct, that the elapsed time since the conviction is short enough that the crime is still relevant, that the nature and gravity of the offense make it relevant for employment purposes, that the crime did not involve exercise of free speech, and that disparate impact of the criminal justice system on minorities is not an issue in this case.

Except as otherwise required by law, criminal background checks of College employees and volunteers that are conducted pursuant to this Policy will be used only for purposes consistent with this Policy and will otherwise be kept confidential. Records of background checks will be maintained separately from an individual’s personnel or student file.

Sponsored programs that operate programs or activities on campus involving Minors must conduct criminal background checks of their employees and volunteers and must provide copies of the background checks to the College, if requested. The College may request any additional information it deems necessary to meet the requirements of this Policy. If the sponsor is a Gettysburg College employee, they must go through the College’s background check process if the program involves minors and lasts for two or more days. All sponsored programs with minors, must notify minors_on_campus@gettysburg.edu.

Specific requirements and procedures for background checks appear in Appendix C.

VII. Reporting Potential Harm to Children

1. Emergencies

In case of an emergency, one should immediately call Gettysburg College’s Department of Public Safety at (717) 337-6911 or Gettysburg Police at 911.

2. All Other Reports of Known or Suspected Abuse or Neglect of Children

All employees of the College and anyone participating in a Covered program that has reasonable cause to suspect that a Child is a victim of Child Abuse MUST immediately make a report of suspected abuse by calling the Commonwealth of Pennsylvania’s ChildLine at (800)-932-0313.

Immediately after ChildLine has been notified, inform the Gettysburg Police Department at either 911 or (717) 334-8101; then inform Gettysburg College’s Department of Public Safety. (717) 337-6911. Under Pennsylvania law, most persons are required to submit a written report, within 48 hours, of making a call to ChildLine.

The Department of Public Safety (DPS) will be responsible for notifying Gettysburg College’s Executive Vice President, the Title IX Coordinator and the respective Program Director of the suspected Child Abuse, assault or neglect unless the Department of Public Safety believes that the Program Director is involved with the alleged abuse. DPS will cooperate and assist local and State authorities in any subsequent investigation.

The College prohibits retaliation against any person who in good faith makes or participates in making a report of Child Abuse under this Policy. The College also prohibits the intentional filing of a false report of Child Abuse.

3. Questions

Questions about one’s obligations or what one should do in a situation that makes one uncomfortable should be raised with the Title IX Coordinator and Director of Civil Rights Compliance and Education, the Associate Provost for Faculty Affairs, or the Executive Director of Human Resources.

Title IX Coordinator and Director of Civil Rights Compliance and Education: Amanda Blaugher
Second Floor, College Union Building,
ablaughe@gettysburg.edu
717.337.6907

Associate Provost for Faculty Affairs: Michelle Schmidt
Third Floor, Pennsylvania Hall
mschmidt@gettysburg.edu717-337-6840

Executive Director of Human Resources: Jen Lucas
First Floor, Pennsylvania Hall
jlucas@gettysburg.edu
717.337.6211

VIII. Addressing reports of Abuse or Neglect

A. Whenever the College receives a report of alleged Child Abuse:

The Title IX Coordinator, Executive Vice President and/or Department of Public Safety will:

a. Take immediate steps to prevent further harm to the alleged victim or other Children, including, where appropriate, removing the alleged abuser from the program or activity or limiting his or her contact with Children pending resolution of the matter.

b. Determine whether ChildLine has already been notified and, if not, make such notification. Ensure the Gettysburg Police Department (GPD) is notified as appropriate.

c. If the parents or guardians of the alleged victim have not been notified and are not the alleged abusers, notify the parents or guardians of the Child involved – as determined by ChildLine and the local police.

d. Investigate the report and resolve the matter in a way that safeguards Children, protects the interests of victims and reporters, affords fundamental fairness to an accused member of the community, and meets relevant legal requirements.

e. Facilitate the College’s cooperation with any investigation conducted by GPD or other governmental agency. The College will try to avoid conflict with any criminal investigation into a reported incident. The College’s investigative process is separate from any active criminal investigation. DPS should be in ongoing contact with GPD or other investigating authority to establish the right timing for the College’s follow-up. Typically, the College would defer to law enforcement authorities for a period of 7-10 business days allowing law enforcement the opportunity for a criminal fact finding stage without any potential interference by a simultaneous administrative process.

IX. Enforcement

Sanctions for violations of this Policy will depend on the circumstances and the nature of the violation, but may include the full range of available College sanctions including suspension, dismissal, termination, and, where appropriate, exclusion from campus. The College may also, in its discretion, take interim actions before determining whether a violation has occurred. The College may terminate the relationships or take other appropriate actions against entities that violate this Policy.

X. Policy Implementation and Modification

Questions about the interpretation or application of this Policy should be raised with the Co-Director of Human Resources who shall update or modify the Appendices to the Policy as necessary and administer and oversee the implementation of the Policy in a manner that best achieves its goals. The Policy may be modified to reflect the changes in the law, standards relating to the protection of Children or Minors, or College processes, or as otherwise necessary.

Appendix A - Signs of Child Abuse and Neglect

https://www.childwelfare.gov/pubpdfs/whatiscan.pdf