Non-Enrolled Minors Policy (Interim)

A. Registration

1. Program must complete Program Registration with the Office of Youth Protection on an annual basis. All Programs must comply with all applicable Office of Youth Protection requirements and use Office of Youth Protection forms, unless otherwise authorized by the Office of Youth Protection.

B. Student Groups

1. Student groups recognized by the Associated Students of the University of Arizona (ASUA) must have their ASUA student organization advisor serve as the Program Supervisor to offer a Program.
2. Student groups not recognized by ASUA and student groups that do not need to comply with ASUA requirements must collaborate with a Unit to offer a Program and have a Program Supervisor from that Unit.

C. Laboratories or Handling Animals

1. Programs that include laboratories or handling animals must follow Environmental Health and Safety guidance for minors.

D. Transportation

1. Authorized Representatives that transport Non-Enrolled Minors must comply with the Fleet Safety Policy.

E. Criminal Record Background Checks

1. Authorized Representatives are subject to criminal record background checks by Human Resources per the Pre-Employment Screening Policy.
2. Program Supervisors must confirm, as part of Program Registration, that each Authorized Representative has completed a criminal record background check within the preceding three (3) years.

F. Training

1. Authorized Representatives must complete the University’s Child Abuse Prevention and Reporting Training every year they work or volunteer in a Program.
2. Program Supervisors must complete the University’s Child Abuse Prevention and Reporting Training and the Campus Security Authority Training every year they supervise a Program.

G. Communication with Minors

1. Authorized Representatives are prohibited from communicating with Non-Enrolled Minors outside of programmatic activities during the Program unless they have a prior familial or social relationship with the Non-Enrolled Minors. Authorized Representatives must disclose the relationship to the Program.
2. Authorized Representatives are permitted to communicate with Non-Enrolled Minors by electronic/virtual means only to convey programmatic information.
3. Electronic/virtual communication with Non-Enrolled Minors to convey programmatic information must be accessible to and/or include at least one other Authorized Representative. 

H. One-On-One Interaction

1. In-person One-On-One Interaction is only permitted:
   1. with Authorized Representatives who are Employees subject to fingerprint-based criminal record background checks;
   2. in places that are easily accessible, interruptible, observable, open, and well-lit;
   3. when parental/legal guardian authorization is provided; and
   4. when approved by the Office of Youth Protection.
2. Electronic/virtual One-On-One Interaction is prohibited. 

I. Behavioral Expectations

1. Authorized Representatives and Non-Enrolled Minors must abide by behavioral expectations set by the Office of Youth Protection and any additional behavioral expectations set by a Program. 

J. Recordkeeping

1. Program Supervisors must ensure that records are maintained per the University’s Record Retention and Destruction Policy and comply with Records and Archives requirements.

K. Information Security

1. Program Supervisors must ensure that information is classified and handled per applicable Information Security Policies and comply with guidelines established by the Information Security Office and the Office of Youth Protection.

L. Responsibility and Audit

1. Program Supervisors are responsible for ensuring compliance with this Policy.
2. Programs are subject to audit by the Office of Youth Protection to determine compliance with this Policy.
3. Programs that violate this Policy may be cancelled and may be prohibited from being offered in the future. 

M. Child Abuse Reporting

1. Mandated reporters are required by Arizona law, as defined by A.R.S. section 13-3620, to report child abuse or neglect to local law enforcement or the Arizona Department of Child Safety. Mandated reporters include, but are not limited to, peace officers, physicians, and any person who has responsibility for the care or treatment of a minor.
2. University Community members who reasonably believe that a Non-Enrolled Minor is being or has been abused or neglected in a University activity, event, or program, or on University Property must:
   1. immediately call the University of Arizona Police Department;
   2. immediately call the Arizona Child Abuse Hotline;
   3. submit a Child Abuse and Neglect Reporting Form to the Office of Youth Protection; and
   4. if known, notify the Program Supervisor or Unit offering, or which offered, the activity, event, or program.
3. Units, upon receiving notice of a report of suspected child abuse or neglect committed by a DCC, Employee, or Student, must immediately prohibit the DCC, Employee, or Student from having further contact with minors participating in their activities, events, or programs.

N. Non-University Programs

1. Non-University Programs conducted, operated, or organized on University Property must comply with the requirements applicable to Youth Programs hosted by third-party contractors. 

O. Exemptions

1. The following are exempt from Sections A-L of this Policy:
   1. University events that are open to the public (e.g., commencements, concerts, convocations, fairs, festivals, lectures, sporting events, talks, performances) where DCCs, Employees, or Students do not have Care, Custody, and Control of Non-Enrolled Minors;
   2. unscheduled campus tours or visits;
   3. Office of Undergraduate Admissions activities, events, or programs (e.g., fairs, high school visits, information sessions, interviews, office hours, tours);
   4. department/college admissions or recruitment activities, events, or programs (e.g., fairs, high school visits, information sessions, interviews, office hours, tours) open to the public;
   5. Intercollegiate Athletics Department activities, events, or programs for prospective student-athletes subject to NCAA regulations and/or Intercollegiate Athletics Department guidelines approved by the Office of Youth Protection;
   6. visits of Non-Enrolled Minors to University housing subject to Housing and Residential Life policies;
   7. incidental visits or single instances with faculty to discuss academic, career, or intellectual interests;
   8. curriculum activities, events, or programs (e.g., practicum activities, Student teaching) that involve Students interacting with Non-Enrolled Minors where parents, legal guardians, or third-party chaperones have Care, Custody, and Control of Non-Enrolled Minors;
   9. health care services and patient care activities provided by licensed health care professionals subject to licensure, state, and/or federal regulations;
   10. University activities, events, or programs with Institutional Review Board approval where Non-Enrolled Minors are human research subjects;
   11. University activities, events, or programs where parents, legal guardians, or third-party chaperones have Care, Custody, and Control of Non-Enrolled Minors;
   12. University activities, events, or programs for which Non-Enrolled Minors are Employees; and
   13. University activities, events, or programs intended for minors accepted for admittance, admitted, enrolled for academic credit, dually enrolled, or matriculated.