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The Office of Risk and Insurance Management (ORIM) will:

• Establish and oversee processes for policy implementation and program compliance with best practices.
• Facilitate programregistration, event documentation, and affiliated personnel compliance through the Protection of Minors Web Application.
• Maintain a database of individuals who have met the training and background clearance compliance requirements of the Protection of Minors Policy.
• Provide resources for training and education such as best practice guidelines and checklists for programs.
• Work with programs and departments to assist with policy compliance.
• Provide guidance on creating University Participation Agreementsto be completed by the parent/guardians of minor participants.
• Provide resources to and monitor feedback from programs affected by the Policy.
• Provide a point of contact for and coordinate any response to abuse concerns, abuse disclosures and inappropriate behavior with minors.

The Office of the General Counsel will:

• Advise on occurrence reports regarding issues identified as potentially harmful and known incidents of harm to minors at and in ¹ú²úÔ­´´ programs.
• Assist as needed with participation/release agreements when warranted by specific situations outside the scope of the standard general release.
• Set standards and recommended methods in document retention for related POM legal agreements and contracts.
• Review documents and legal language as needed related to POM issues.
• Update the document retention policy pages as needed to reflect POM documents.
• Participate in background clearance review teams, as designated by Human Resources and related academic Schools, or other university departments.
• Provide policy implementation guidance as needed in work groups and in other specific situations.
• Assist with investigations and management of allegations as needed.

The Office of Human Resources will:

• Complete criminal background clearance checks on all newly hired employees and all current employees whose position involves work with minors.
  • Fully investigate any criminal convictions.
  • Consult with review committee and POM Director on decisions to hire/retain a staff member with identified records or a disclosed or known history relating to abuse, neglect, inappropriate conduct with or exploitation of minors.
  • Consult with the Protection of Minors Director prior to approval of hire/retention of any staff member with specific types of criminal convictions and/or individuals who would not be permitted to work with minors as a result of a past criminal record or known inappropriate conduct with minors.
  • Communicate any change in the process, review and records retention of criminal background clearances with the Office of Risk and Insurance Management.
  • Complete criminal background rechecks every 4 years for those identified via POM report as actively working in programs with minors.
• Explore the feasibility in collaboration with the Oracle team to build an identifier as works with minors* to job codes/description in Oracle and, if executed, notify hiring managers and HCM staff of the definition and compliance requirements.
• In collaboration with the Protection of Minors Director, build in screening questions and/or procedures to the new hire process that address potential risks for child abuse.
• Facilitate automated or manual weekly file load of clearance dates, clearance types (fingerprint or non), and personnel identifiers from the HR records system into the Protection of Minors Web Application.
  • Notify the POM office for clearances completed for POM and the individual will/does not have an HR record with the university.
  • Work with the Office of Risk and Insurance Management to troubleshoot any issues with data and accuracy related to background clearances.
• Collaborate in the information distribution of training competencies and/or assignments of training to managers regarding the Protection of Minors training modules and policy requirements.
• Include Protection of Minors Policy reference and mandatory child abuse reporting law in all new hire orientation.
• Aid in any investigations alleging employee misconduct with minors.

*Working with Minors Definition: It reasonably anticipated this position will be interacting, working with, treating or caring for, and/or supervising minors less than 18 years of age (high school students, adolescents, children and/or infants) as a part of ¹ú²úÔ­´´ work. This does not include actions as related to currently enrolled VU students under the age of 18 or ¹ú²úÔ­´´ employees under 18 years old. This would include any lab experience, training, teaching, child/school care, recreational instruction, observational/shadowing, internship, research, tour or prospective student interaction, work/service in the community representing a ¹ú²úÔ­´´ department or program, summer experience or camp, lesson, treatment, etc. This would not include any public event with minors attending (such as an athletic event, concert or public lecture).

The Office of University Compliance will:

• Collaborate on and put forward language in the Standards of Conduct for the Protection of Minors.
• Include policy reference and/or links on the Compliance website.
• Educate as needed on the requirements for programs and personnel.
• Notify the Protection of Minors Director of all reports to the University Compliance Hotline related to minors and coordinate any responses.
• Coordinate with VUPD and other relevant offices on any required Clery reporting or campus notifications.

With regard to faculty affairs:

• In consultation with Office of General Counsel and relevant Dean/Department Chair, review decision to hire/retain a faculty member with identified criminal and/or misconduct records related to child abuse, exploitation, or endangerment and communicate before proceeding.
• Include risk related Protection of Minors Policy and mandatory reporting material in training/orientation for new faculty. Communicate updates in process and compliance as appropriate annually for all faculty.
• Provide information on policy compliance and instructions to access materials/annual training to faculty who have program interaction, research interaction, and/or oversight to minors.

With regard to Academic Schools who complete criminal background clearances for purposes of enrollment, participation, certification, licensing or other purposes will:

• Upon a criminal conviction returned; fully investigate any records found.
• Consult with appropriate review committee on decision to admit/retain individuals with identified records related to violence, abuse or exploitation of minors and evaluate with consideration on the direct and indirect interaction and access to minors at ¹ú²úÔ­´´.
• Consult with the Protection of Minors Director prior to approval or admission/retention of ANY individual pending enrollment/retention that would NOT be permitted to engage with, work, or perform service with minors.
• Provide Annual or more frequent clearance files to the designated record keeper to be included in the POM Web Application to support the RIM responsibility to maintain a clearance database.
• Follow applicable guidelines from the Provost’s office for the process, review and records retention of criminal background clearances.

Academic Schools Operating Any Programs or Events Which Include Non-enrolled Student Minors will designate a contact at the leadership level at each School* for consultation on POM programs and/or issues who:

• Reviews programs approved for operations in the Protection of Minors Web Application as needed.
• Understands best practice models for work with minors.
• Communicates training and policy guidelines and Protection of Minors Web Application function within the School/Office/Center to specific coordinators or to general audiences.
• Provides Department level (when appropriate) contact.
• Assists with troubleshooting compliance issues.
• Follows and/or educates the person managing room and facility reservations on all protection of minors policy requirements and procedures with regard to internal and third party use of space when departments host internal event or external agents reserve space for events with minors.
• Notifies Risk and Insurance Management on discovered risk issues related to minors in any program or operation.

*The designee will be jointly selected by the dean and business officer in the respective school.

The Office of Research will assure the Research Intern and Observer policy meets POM policy requirements and will communicate as appropriate with labs (and/or designated academic research deans) on compliance and additional safety requirements for placement of minors in a research lab. The Office will partner with the ORIM on appropriate communication to labs (and/or designated academic research deans) regarding IRB human subject and POM requirements for research with minors.

The Undergraduate Office of Admissions will educate all staff interacting with prospective students in the Protection of Minors policy requirements and assure all staff complete training and background clearance as required. The Office will also educate non-staff who interact with prospective students (such as alumni) on the Policy as appropriate and assure compliances have been met.

The Dean of Students Office overseeing registered student organizations (RSO) will identify organizations working with minors, communicate requirements to members, and work with RSO Coaches to confirm the compliance of student leaders, members, and coaches/ consultants. The Dean of Students Office responsible for accountability and overall student compliance will adjudicate compliance violations by registered student organizations, when referred. Additionally, any global VU student requirements for protection of minors training will be communicated and monitored for compliance.

The Dean of Students Offices managing space and facility rentals for both internal constituencies and third parties will follow all policy requirements and procedures when reservations include hosting events with minors.

¹ú²úÔ­´´ Athletics (Including the Recreation and Wellness Center) will:

• Educate all staff involved in athlete recruiting and operating youth programs in the Protection of Minors policy requirements.
• Assure student athletes interacting with minors in outreach and service are compliant with POM policies.
• Follow all policy requirements and procedures with regard to internal and third party use of space when hosting events with minors.

The Office of Title IX will:

• Initiate internal processes and complete an investigation of allegations of abuse of a minor including sexual misconduct involving a minor in a ¹ú²úÔ­´´ program or activity involving any minor on ¹ú²úÔ­´´ premises.
• Work concurrently (or as determined) with any law enforcement and/or DCS investigation resulting from an allegation.
• Communicate the results of any investigation related to the protection of a minor to the Office of Risk and Insurance Management, Protection of Minors Director or Executive Director.

The Office of Information Technology will:

• Provide support and enhancements for the Protection of Minors Web Application.
• Support the Web Application in reporting by report creation as requested in Oracle BI Publisher.
• Support Oracle Learn and training initiatives related to POM policy and education.

The Office of Purchasing and Payment Services will:

• Review contracts and related SOWs which include, reference or imply work involving minors or the presence of minors, clarify when terms are not clear if the service includes work with non-enrolled minors in VU programs, and incorporate background clearance and other university requirements where appropriate.
• Consult on additional POM compliance in contracts and agreements with the RIM office where prudent.
• Periodically perform monitoring of vendors’ contracts attesting to criminal background clearance to assure results meet minimum standards to ¹ú²úÔ­´´â€™s.