Policies and Procedures

• The University of Southern Mississippi is dedicated to the welfare and safety of all Minors who visit our campuses to participate in University-related programs or activities or any other event involving minors on the University campuses. To that end, in January of 2015, the University adopted a Minors on Campus policy.  The objective of this policy is to promote a safe environment for minors by fostering a University culture that is committed to preventing, recognizing, reporting, and addressing child abuse and child sexual abuse.  The University’s Minors on Campus policy does the following:

   

• Prohibits one-on-one contact with minors;
   
• Informs all University employees of their Duty To Report suspected neglect or abuse of a child
   
• Outlines a Code of Conduct for individuals who work in camps/programs;
   
• Sets forth the duties of University units that sponsor a program/camp and sets staff to participant ratios;
   
• Mandates training for program staff annually;
   
• Sets Rules of Conduct for programs/camps;
   
• Provides additional guidance for residential camps;
   
• Requires background checks for individuals who work in programs/camps;
   
• Provides guidance to non-university entities that use our facilities for programs/camps.
  UNIVERSITY POLICY
• If you offer, sponsor, or approve programs or activities involving minors, please review the University’s Minors on Campus policy here.

DUTY TO REPORT 

All University employees have a duty to report any suspected neglect or abuse of a minor.
All University employees have a duty to report any suspected neglect or abuse of a minor.  If any person has reason to suspect that a Minor has been subject to neglect or abuse, he or she must immediately do the following:

• Inform the University Police Department (Hattiesburg:601-266-4986; Gulf Coast:  228-234-2068 or other appropriate law enforcement agency, and if the suspected assault or abuse presents an imminent danger to a Minor, contact should occur immediately;
• Report the activity to the Mississippi Department of Human Services by calling the Abuse hotline 800-222-8000 and provide a written report to the Department of Human Services as soon thereafter as possible. See Miss. Code Ann. § 43-353;and If the Minor is a participant in a Program, notify the Title IX Coordinator 601-266-4466 or designee as well as the Program Director. If, however, the Program Director may be involved in the suspected assault or abuse, only report the suspected assault or abuse directly to the University’s Title IX Coordinator or designee.

PROGRAMS/CAMPS DIRECTED BY NON-UNIVERSITY ENTITIES
For questions relative to the use of University facilities by non-university affiliated entities, please contact Event and Conference Services at 601-266-5292.Non-university organizations that wish to operate programs or activities involving minors on Southern Miss campuses must ensure their programs are operated consistent with the guidelines of the Minors on Campus policy.   All contracts for the use of University facilities by non-university organizations for programs involving minors shall reference this requirement and provide a link to the policy.

Non-university organizations using University facilities for programs/camps involving minors shall be required to deliver the following before authorization of use of University facilities may be given:

• A signed Facilities Use Agreement setting forth the specific facilities to be used, the dates and hours of permitted access and other terms applicable to such use;
• A signed Safety of Minors Addendum wherein non-university organizations represent and certify that the program meets all the requirements for programs set forth in the Minors on Campus policy, including all provisions concerning training, staff to participant ratios, and background checks of all authorized adults;
• A signed Release and Indemnification Agreement in a form acceptable to the Office of General Counsel releasing the University from all liabilities and claims for damages from any cause whatsoever and defending and holding the University harmless against any and all claims arising from the actions of the non-university organization, its employees or volunteers, and from any failure to conform to the requirements of this policy; and
• An additional insured endorsement and a certificate of insurance written on an occurrence form issued by a carrier with an A.M. Best rating of at least A- (Excellent) Financial Size Category VII or higher which identifies The University of Southern Mississippi, its Board of Trustees, faculty, staff and agents as an “Additional Insured” and provides a minimum of one million dollars in liability coverage.  Due to the nature of some events, the University reserves the right to require additional limits of liability coverage.
• Non-university entities using University facilities for programs/camps involving minors are required to certify that they have provided training comparable to that required under this policy to their Program Staff.

REQUIREMENTS

For University operated programs, each Authorized Adult/Program Staff member who will be participating in a program covered by the Minors on Campus policy is required to do the following:

1.  ANNUAL TRAINING
Complete the Compliance and Ethics module entitled Child Abuse Awareness: Minors on Campus Training Attend annual mandatory training* provided by the Responsible Unit/Program Director which will cover such things as: procedures under the policy appropriate crisis/emergency responses how to report suspected child abuse, etc.

• SUPPLEMENTAL TRAINING RESOURCES-

Handouts on child sexual abuse are available for use in this training as listed below:

• Preventing Child Sexual Abuse 

• What is Child Abuse and Neglect  

• Code of Conduct for Authorized Adults/Program Staff  

  Email compliance@usm.eduto request these resources.  

  2. REVIEW

• Read the Minors on Campus policy,

• Sign an Acknowledgement of Understanding: University Minors on Campus Policy certifying that you have read and understand the policy, and provide the signed Acknowledgment to the Program Director.   

  *This training must be approved by the Director of Compliance and Ethics.  To do so, Program Directors must complete the Training Approval Form for Minors on Campus and submit it to the Director of Compliance and Ethics at paul.walters@usm.edu.

  3. FORMS

• Employment Related Forms
  To comply with the Minors on Campus Policy, each of the following must be completed:

• Annual Background Check-Background Check Information/Form- HR  (*see number 4 below for additional information) 

• Acknowledgment Form-Acknowledgment form must be signed Volunteer Form (if you are volunteering, instead of being employed)-[see HR website for this form]

• Camper Related Forms (which are available upon request)
  The following forms may need to be filled out:

• Waiver of Consent for Medical Treatment Self-Administration of Prescription Medication and

• Over-the-Counter Medication and Medication Administration Record.

  Please email compliance@usm.edu to obtain access to the forms or call 601-266-4466.*-

  If you need a Travel and Off-site Activity Release, please contact our office as these are drafted on a case-by-case basis.  

4. BACKGROUND CHECK 

Each Authorized Adult/Program Staff member (whether paid, unpaid, affiliated with the University or not) who will be participating in a program covered by the Minors on Campus policy is required to have a criminal background check on file: these background checks must be completed on an annual basis-email to obtain a copy of a letter from HR.

The Program Director is responsible for coordinating the background checks with the Department of Human Resources through HR point of contact Moriah Rouse.  

To ensure more efficient processing of background checks, the following steps are suggested:

An email notice will be sent to the Program Director indicating the name of each Authorized Adult/Program Staff that has been cleared to work with minors.

Authorized Adults/Program Staff may not begin working with the Program until the background check has been completed and they have been cleared to begin by the Department of Human Resources.

It is suggested that the background check forms be submitted to the Department of Human Resources at least one month prior to the beginning of the program or camp. Keep in mind that summer is the busiest time for programs with minors, so submit the forms for your program staff EARLY!

If the facility is being used by another organization, they would need to fill out the Safety of Minors Addendum to Facility User Agreement (PDF)- See the section on PROGRAMS/CAMPS DIRECTED BY NON-UNIVERSITY ENTITIES

FREQUENTLY ASKED QUESTIONS (FAQ)  

POLICY RATIONALE

Why has Southern Miss adopted this policy?

The University has adopted the Minors on Campus Policy to provide guidance for those in the university community who participate in programs or activities that involve minors under the age of 18. The primary goal of the policy is to promote the well-being and safety of minors who participate in programs run by or associated with the University

Pursuant to the Minors on Campus policy, what must be completed before holding a camp/event on the campus of The University of Southern Mississippi?

APPLICABILITY OF POLICY TO PROGRAMS

What type of program is covered under this policy? 

All programs involving children and teens under age 18 fall under the new policy. Examples include:

• Specialty camps such as academic or athletic camps
• Workshops, conferences, and educational programs
• Sponsored student organization activities
• Programs and events involving children that take place in University facilities or on University property

APPLICABILITY OF POLICY TO CERTAIN SITUATIONS

Does the Policy apply to every encounter with a child or minor on campus?

No.  There are some scenarios that are exempt from the policy.  Examples include:

• Events or performances on campus which are open to the general public (athletic competitions, plays, concerts);

• Services provided by the University Student Health Services Clinic, the University Psychology Clinic, the University Speech-Language-Hearing Clinic, the Dubard School for Language Disorders, and the University Clinic for Family Therapy. 

• These entities will follow separate policies that comply with the principles of this policy, but reflect their unique activities;

• Undergraduate and graduate academic programs in which minors are enrolled for academic credit;

• Campus tours or visits by minors considered to be prospective students;

• Non-residential field trips to campus supervised by a minor’s school or organization;

• Off-campus clinical, practicum or student teaching experiences supervised by a third party entity;

• Interaction with minors in the context of curricular, practical training supervised by University faculty;

• Tutoring and mentoring by University students who are registered in recognized organizations (e.g. Big Brother/Big Sister), or are participating in community service activities sponsored by an administrative or academic unit of the University provided that such activities take place only in public settings (such as libraries and dining halls) during normal operating hours;

• Private, personal events (e.g., birthday parties, weddings) that occur on campus;

• Other programs as may be designated from time to time by the appropriate University official in advance and in writing as exempted from this policy. 

• I’m not involved in any programs involving minors at Southern Miss.  Does the policy apply to me?

  If you are not involved in any programs or activities involving minors, many of the provisions of the policy will not apply to you. Everyone, however, is expected to do the following:  

  1) review the policy;  

  2) help to protect the safety and well-being of minors with whom they may interact; and

  3) report known or suspected abuse or neglect of a minor.

  The policy does not apply to personal activities that are apart from your role or responsibilities as a student, faculty member or staff member, but the guidance provided by the policy may be helpful and important in non-university contexts.

  I’m a student over the age of 18 who is working in a program involving minors as a camp advisor. Does the policy apply to me?

  Yes, all faculty, staff, and students who are involved in programs or activities involving minors that are sponsored by the University or occur on its campuses must comply with this policy.

  APPLICABILITY TO VOLUNTEERS
  Our department sponsors an enrichment camp on campus each summer.  We routinely have volunteers from outside the University come in to assist us with the camp as program staff. 

  Will our volunteers be subject to the background check requirements and training required by the policy?

  Yes.  The background checks and training requirements are applicable for all authorized adults or program staff which includes those persons who are merely volunteers.

  APPLICABILITY TO SPEAKERS
  In our program for minors, we frequently have guest speakers who present information to the children and interact with them. 

• Will this policy require our guest speakers to go through a background check and/or training?

  No.  The policy definition of an authorized adult excludes temporary guest speakers, presenters and other individuals who have no direct contact with the minor program participants other than short-term activities supervised by program staff.

  DROP-IN VISITS
  I am a faculty member and the director of a summer program for high school students.  Throughout the year, students frequently stop by my office to discuss various issues related to the program. 

• Are these drop-in visits prohibited under the policy?

  No, provided that the visit occurs during normal business hours and the inside of your office can be observed from common areas (e.g., leaving your office door open; having a window in the door of your office which would allow passersby the ability to observe your interactions). 

  The policy prohibits one-on-one contact with minors in non-public areas or those places that are not common areas, cannot be observed from a common area, and which are not monitored by video surveillance equipment approved by the University Police Department.  While your office is a non-public area, if your office can be observed from a common area (such as a hallway), then one-on-one contact is not prohibited, provided it is during business hours or such other times as one would reasonably anticipate others would be present.  

  If, however, the drop-in visit occurred at 7:00 p.m. on a Wednesday night, and you were the only employee working late in your department, then it would be prohibited.  The ability of passersby to observe your office from the common areas must occur during normal business hours or when one would reasonably anticipate others would be present.

  PRIVATE LESSONS
  I teach private violin lessons in University facilities. 

• Will this policy apply to me?

  Yes.  Anyone teaching private lessons of any kind to minors on University property must comply with this policy.  This means that a background check must be on file, the teacher must complete the mandatory annual training, and two Southern Miss authorized adults must be present during the instruction if the instruction will be conducted in a non-public area that cannot be observed from a common area. If two authorized adults cannot be present during a private lesson, we require the presence of a parent. In the case of a music lesson, the parent may sit in the hallway immediately outside the studio or classroom.  If this is not possible, parents may sign a waiver form giving consent for their child to be alone with an adult instructor.

  However, if the instruction is held in a room with a window in the door or the door is left open, then no second authorized adult will be required (assuming that the instruction is held during such times as other persons are present). Indeed, if the lesson takes place outside of normal business hours or during other times when others are not normally present, then the fact that the lesson is given in a room with a window or open door is of no consequence.  Another authorized adult or parent must be present.

  I give private tennis lessons to children on the University tennis courts.  Must I have another authorized adult present during the lessons?

  No. The policy prohibits one-on-one contact with minors in non-public areas.  Because the tennis court is located in an open and public area, a second authorized adult is not required.

  E-MAIL COMMUNICATIONS
  I am a counselor for a summer camp on campus.  Many times after the camp has ended, I will email the kids in my camp to see how they are doing. 

• Will I be able to continue doing this under the new Minors on Campus policy?

  Yes, as long as you include as a recipient to the email another authorized adult.  The one-on-one contact our policy prohibits includes electronic communication, such as social media, email, and texting.  However, as long as you always include another authorized adult, parent or legal guardian in any electronic communication you have with a minor, this is acceptable.

  REPORTING OBLIGATIONS

• When might I need to make a report under the Minors on Campus Policy?

  If you are participating in a program or activity involving minors and you know or have reason to suspect that a minor has been subject to abuse or neglect or is otherwise unsafe, you must make a report. 

  What if I’m not sure whether a minor I’m working with has been abused or neglected?

  If you have any suspicion that a child has been abused or neglected, report it.  Even when you have doubts, it is better to report your suspicions than to ignore them. Neither Mississippi law nor any University policy allows you to delegate the duty to report child abuse or neglect.

  How do I make a report to the University?

  To make a report of child abuse or neglect, you must do the following:

  a.         Inform the University Police Department or other appropriate law enforcement agency, and if the suspected assault or abuse presents an imminent danger to a Minor, contact should occur immediately;

  b.         Report the activity to the Mississippi Department of Human Services by calling the Abuse hotline and provide a written report to the Department of Human Services as soon thereafter as possible. See Miss. Code Ann. § 43-21-353; and

  c.         If the Minor is a participant in a Program, notify the Title IX Coordinator or designee as well as the Program Director.  If, however, the Program Director may be involved in the suspected assault or abuse, the person should report the suspected assault or abuse directly to the University’s Title IX Coordinator or designee.

  TRAINING REQUIREMENTS- Who Needs Training

• What training am I required to have in order to participate in a program involving minors?

  Program or activity directors, staff, volunteers and all authorized adults working with minors in university programs or activities are required to do the following annually:

  a.         Review the University’s Minors on Campus Policy and certify that they have done so;

  b.         Attend mandatory training provided by the sponsoring unit or program which will provide information about the responsibilities and expectations under the minors on campus policy, emergency response, reporting of suspected abuse, among other things; and

  c.         Contact compliance@usm.edu to discuss options for general child abuse training.  

  Who will provide the training?

  Each department or academic unit (Sponsoring Unit) offering a program for minors is responsible for training its program staff covered by the policy and is permitted the flexibility to design a method for training best suiting its needs. Additionally, online training is provided through Workplace Answers and SafeSport at no cost.

  I’m a student participating in a program involving minors. Do I need any training?

  Yes. All individuals working with minors in University programs or activities are required to complete the above training annually.

  Our group is not affiliated with the University.  However, we are using the University facilities for a summer youth camp. Are we required to train our program staff?

  Yes.  All programs that involve minors occurring on University property must follow the training requirements in accordance with the Minors on Campus policy. 

  BACKGROUND CHECKS

• Why is the University requiring criminal background checks prior to participating in activities involving minors?

  The University is committed to promoting the well-being and safety of children who participate in University programs or activities and in programs that outside organizations deliver on campus. Criminal background checks may reveal prior convictions that would make it inappropriate for someone to participate in a program or activity with minors. 

  How often is a background check needed?

  Background checks are conducted annually as it relates to the “Minors on Campus” policy for all event and camp program staff/authorized adult supervisors - whether paid or unpaid - or regardless of affiliation with the university. 

  Who is required to have a criminal background check?

  All authorized adults/program staff are required to complete a criminal background check. Authorized adults are defined as individuals, paid or unpaid, 18 years or older, who interact with, supervise, chaperone, or otherwise oversee minors in program activities, or recreational, and/or residential facilities. This includes but is not limited to faculty, staff, volunteers, graduate and undergraduate students, interns, employees of temporary employment agencies, and independent contractors/consultants. The Authorized adults’ roles may include positions as counselors, chaperones, coaches, instructors, etc. 

  However, background checks are not required for temporary guest speakers, presenters or other individuals who have no direct contact with program participants other than short-term activities supervised by program staff.

  I am operating a program involving minors. How do I arrange for background checks for my staff?

  The Department of Human Resources oversees the processing of criminal background checks for University programs and activities.  You will need to fill out the background check form. 

  EXTERNAL PROGRAMS OPERATING ON UNIVERSITY CAMPUS

  We are an outside group not affiliated with the University that wants to hold a retreat on campus this summer. 

• What is a program not affiliated with USM required to do in order to do to hold a retreat on campus this summer?

  Non-University organizations that wish to operate programs or activities involving minors on campus must comply with the University’s Minors on Campus Policy, including requirements relating to reporting suspected abuse or neglect of minors, completing all relevant training, and background checks.

  Prior to the start of any program or activity involving minors, Non-University organizations must deliver the following before authorization of use of University facilities may be given:

  a.         A signed Facilities Use Agreement setting forth the specific facilities to be used, the dates and hours of permitted access and other terms applicable to such use;

  b.         A signed Safety of Minors Addendum wherein non-university organizations represent and certify that the program meets all the requirements for programs set forth in this policy, including without limitation, all provisions concerning training, staff to participant ratios, and background checks of all authorized adults;

  c.         A signed Release and Indemnification Agreement in a form acceptable to the Office of General Counsel releasing the University from all liabilities and claims for damages from any cause whatsoever and defending and holding the University harmless against any and all claims arising from the actions of the non-university organization, its employees or volunteers, and from any failure to conform to the requirements of this policy; and

  d.         An additional insured endorsement and a certificate of insurance written on an occurrence form issued by a carrier with an A.M. Best rating of at least A- (Excellent) Financial Size Category VII or higher which identifies The University of Southern Mississippi, its Board of Trustees, faculty, staff and agents as an “Additional Insured” and provides a minimum of one million dollars in liability coverage. 

  Additionally, liability waiver agreements of the organization should plainly state that the organization’s program or activity is neither endorsed nor sponsored by The University of Southern Mississippi.

  ASSISTANCE WITH POLICY

  My program has unique circumstances, and I’m not sure how to implement the policy. What should I do?

  The Office of General Counsel and the Director of Compliance and Ethics are committed to working with programs with unique circumstances to help them identify how best to comply with the policy. Those with questions are encouraged to contact Subrina Cooper, Associate General Counsel, at 601.266.4466 / Subrina.CooperFREEMississippi or Paul Walters, Director of Compliance and Ethics, at 601.266.4466 / Paul.WaltersFREEMississippi.