Youth Protection Policy

Northern Illinois University (NIU) sponsors events, programs and activities for minors and makes its facilities available for third parties to conduct events, programs and activities for minors. Against this backdrop, NIU is committed to promoting a safe and secure environment for all. This policy addresses special concerns when minors participate in university sponsored programs and other activities utilizing university facilities.

This policy applies to events, programs and activities designed for participation by minors, and any employee, student, volunteer, and/or third party who exercises care, custody, and control, or otherwise oversees minors in the course of their duties in a covered program.

This policy does not apply to the following programs and/or circumstances.

• Enrollment in a for-credit university course by a minor
• Events open to the general public
• Research activities
• State licensed preschool, childcare, day camp and daycare programs, to include the Child Development and Family Center
• Orientation and academic advising activities
• Minors employed by the university
• Medical care given to minors in a university patient care setting by a licensed health care provider
• Minors participating in pre-enrollment visitation or recruiting activities governed under the National Collegiate Athletic Association (NCAA)
• Occasional and special events that are not operated by the university where only family, friends, and people known to the hosts are invited to attend (e.g., birthday party, wedding, banquet)
• Events hosted by tenants with a lease agreement operating within their leased premises in university facilities

Care, Custody, and Control

When an individual has primary responsibilities for the supervision of minors at any given point throughout the youth activity.

Mandated Reporter

An individual who is required to report known or suspected instances of child abuse, neglect, or endangerment to Illinois Department of Children and Family Services (DCFS).

Minor

A person under the age of 18. A minor does not include admitted or enrolled students at the university.

Program Sponsor

The person responsible for the operational management, oversight, and registration of a youth activity. This person is also responsible for ensuring that the program staff complete required checks, training and certifications.

*There can only be one Program Sponsor.

Program Staff

Any person(s) responsible for the care, custody, and control of a minor at any point throughout a youth activity. Program staff may include employees, students, and volunteers.

*There is often more than one program staff.

Program Unit

The university’s school/college/division responsible for authorizing the operation of a youth activity.

Supervision Ratio

The minimum number of program staff per number of participants in a youth activity.

Third Party

A non-university entity contracted for the use of university facilities to host events, programs or activities involving minors.

Youth Activity

Any event, program or activity sponsored or operated by the university for any amount of time where minors are under the care, custody and control of university employees, university students, or university volunteers.

Youth Participant

Minors who are under the care, custody, and control of a youth activity.

Youth activities and other university-affiliated events, programs and activities involving minors must be registered in advance of their occurrence. The requirement to register includes events, programs and activities hosted by third parties in which minors are not under the care, custody and control of the university, i.e., Facilities Use Agreements and external camps hosted on campus, etc.

The university will maintain procedures for registration. Registration includes, at minimum, the dates of the activity, age of participants, and general description of types of activities that will be engaged in.

If a youth activity is not registered in advance, the university has the right to determine if the event, program or activity may proceed.

A Program Compliance Plan must be completed for all youth activities, as defined in this policy, in advance of its occurrence. The university will maintain procedures for completing a Program Compliance Plan. The Program Compliance Plan includes, at minimum, detailed information related to transportation (if applicable), emergencies, supervision ratio, incident reporting, and training.

If a Program Compliance Plan is not completed in advance of the youth activity, the university has the right to determine whether the event, program or activity may proceed.

If an event, program and/or activity is not under the care, custody and control of the university (i.e., Facilities Use Agreement or other external camps hosted on campus), a Program Compliance Plan is not required.

The responsibilities of the university Program Sponsor are as follows:

• Register the event, program or activity involving minors.
• Submit the Program Compliance Plan, if applicable.
• Verify all hiring requirements of Program Staff, as determined by Human Resource Services, are completed, to include an appropriate level of training and screening, and the completion of a background check.
• Ensure that any additional statutory requirements or contractual obligations are adhered to.
• Promptly report all actual or suspected crimes and instances of abuse or neglects to the Department of Police and Public Safety.
• Cooperate with any university, governmental, or law enforcement investigation into alleged crimes and child abuse or neglect.

The responsibilities of program staff are as follows:

• Always be vigilant in protecting the well-being and safety of youth participants and maintaining high standards of professional behavior.
• Complete the appropriate hiring documentation, as determined by Human Resource Services, prior to the start of the youth activity.
• Watch for signs of abuse or neglect.
• Immediately report all suspected or actual crimes and instances of abuse and neglect to the Department of Police and Public Safety.
• Cooperate with any university, governmental, or law enforcement investigations into alleged crimes and child abuse or neglect.

Minimum screening and training requirements and the completion of background checks vary by the level of interaction with minors during the youth activity (i.e., one-on-one interaction, guest speakers, etc.). The Program Unit is responsible for coordinating with Human Resource Services to ensure the appropriate level of screening and training is completed based on the level of interaction with minors, to include the completion of a background check. Program Staff involved in high-risk activities (e.g., overnight activities, involvement of hazardous chemicals, food preparation) may be required to complete training specifically related to that activity.

In accordance with the Illinois Abuse and Neglected Child Reporting Act, all university employees must complete an initial mandated reporter training within 3 months of their date of engagement in a professional or official capacity as a mandated reporter, and at least every 3 years thereafter.

All program sponsors and staff are required to report to the program unit any pending charges, convictions, orders, or legal restrictions,that prohibit or could prohibit their interactions with minors.

The Program Sponsor is responsible for ensuring that records and documents related to youth activities are stored in a secure location. The Program Sponsor must maintain records according to the appropriate record retention procedures.

The university is responsible for maintaining youth activity registrations and corresponding Program Compliance Plans.

Program Sponsors and program staff are only permitted to access data related to minors through the use of university-recognized accounts or software using the credentials assigned or instructed by the Program Sponsor. Program Sponsors and program staff are only permitted to access minor data to carry out the objectives of the youth activity and/or Program Compliance Plan.

Any unauthorized use of minor data is strictly prohibited and will result in an appropriate level of corrective action, to include loss of access, removal from youth activity, discipline, and/or termination from employment or volunteering.

If an individual is found responsible for violating this Policy, corrective action will be recommended and implemented by the appropriate Program Unit.

Corrective action against employees shall be commensurate with the severity of the policy violation and consistent with the university’s applicable personnel due process and grievance procedures, and standards set forth in the university constitution and applicable collective bargaining agreements. Corrective action may include, but is not limited to, cancellation of a planned or ongoing youth activity, prohibition from participating in future youth activities, and/or appropriate level of corrective action.