Interactions with Non-Enrolled Minors

Purpose, Philosophy, and Applicability

The University of Arizona (University) is committed to promoting the safety and well-being of individuals who visit or use its campus or other facilities for any reason. The purpose of this Policy is to establish reasonable and flexible safeguards for official University programs or activities open for participation by Minors.

This Policy applies to organized University programs and activities (Programs) that are supervised exclusively by University employees or others authorized to act in a custodial capacity on behalf of the University (Authorized Representatives) for the benefit of individuals under the age of 18 (Minors).

The University will use all reasonable means to safeguard all Minors. This Policy does not apply to Minors who (a) are enrolled for academic credit or have been admitted as students at the University; (b) are employed by or volunteering at the University; (c) attend or participate in University activities while supervised by a parent, legal guardian, or official of a school or other non-University organization or group; (d) attend University events open to the public (e.g., museum tours, football games, etc.) for which a parent or legal guardian may give permission; or (e) participate in activities that have been given Institutional Review Board approval. This Policy also does not apply to health-care provider/patient or lawyer/client relationships.

A. Supervision of Minors

1. Authorized Representatives will avoid one-on-one interactions with Minors that cannot be observed by another Authorized Representative. There may be situations, however, in which such interactions are necessary. Examples may include off-site auditions, interviews, mentoring, and tutoring sessions. In-person one-on-one interaction with Minors is only allowed if indicated on the "Registration Form" (referenced in section A.3 under Compliance and Responsibilities - Recordkeeping). Programs must also obtain parent/legal guardian authorization on the "Disclosure of One-on-One Interaction with a Minor: Parent/Legal Guardian Authorization Form."

B. Duty to Report

1. Anyone who suspects a Minor is being abused or neglected on University owned or controlled property or during a Program must: (a) immediately call the University of Arizona Police Department; (b) immediately call the Arizona Child Abuse Hotline; (c) submit a "Child Abuse and Neglect Reporting Form," and (d) notify the Program supervisor of the Program the Minor is participating in.
2. A Program must immediately take steps to prohibit anyone whose conduct has resulted in a report under this section from having any further contact with Minors until it receives suitable assurances that the individual whose conduct resulted in the report has been absolved of any wrongdoing.

C. Multi-Media Consent

1. Programs planning to videotape, film, audio record, and/or photograph Minors, must obtain parent/legal guardian authorization on a University-approved multi-media consent and release form.

D. Communications with Minors

1. Virtual/electronic one-on-one interactions with Minors are prohibited. Any virtual/electronic communication with Minors must be accessible to and/or include other Program staff. While a Program is being conducted, Authorized Representatives may communicate with Minors by phone, social media, or other electronic means (e.g., e-mails, text messages) only to convey programmatic information, and may not have contact with Minors outside of official programmatic activities.

E. Medical Protocols

1. Depending upon a review of factors such as Program duration, location, and activities, Programs will, if appropriate, develop individualized protocols regarding medical contacts with Minors. Such protocols may include medical information to be collected about Minors, administration of medication to Minors, and use by Minors of health-care-provider-prescribed medical devices to treat emergency or chronic conditions (e.g., EpiPens and respiratory-related inhalers).
2. At least one Authorized Representative with current first-aid and CPR certifications must be reasonably accessible during all Program activities. Program staff must call 9-1-1 in the case of a medical emergency involving a Minor.

F. Training

1. The University will develop and maintain a training program for Authorized Representatives that includes information about responsibilities to safeguard Minors, applicable policies and procedures, and reporting requirements. Authorized Representatives will complete the training as directed by the University. The University will maintain a list of Authorized Representatives who have completed the training.

G. Criminal Background Checks

1. As may be required by University policies and procedures, Human Resources will conduct or cause to be conducted a criminal background check of all individuals who wish to serve as Authorized Representatives.  

H. Behavioral Expectations

1. Authorized Representatives must sign the “Authorized Representative Form” and abide by the behavioral expectations set forth in the form.
2. Parents/legal guardians must sign the “Parent/Legal Guardian Form” and inform Minors that they must abide by the behavioral expectations set forth in the form.

I. Program Forms

1. Forms referenced in this Policy are available on the Office of Youth Protection website. The forms provided by the Office of Youth Protection must be used unless otherwise indicated.

A. Recordkeeping

1. Programs must obtain contact information, including name, phone numbers, and street and e-mail addresses (if available), for the parents or legal guardians of all Minors on the "Parent/Legal Guardian Form." This information will be used to notify such individuals of any (a) significant health or safety issues affecting the Minor, including medical or behavioral problems; and (b) programmatic disruptions, including cancelations and time changes.
2. Programs must also obtain contact information for individuals (other than a parent or legal guardian) authorized to pick up the Minor, if applicable, and for one or more adults designated as emergency contacts on the "Parent/Legal Guardian Form." Programs will provide contact information for at least one Authorized Representative to the parents or legal guardians of each Minor.
3. As soon as such information becomes available, Programs will submit a "Registration Form" to the Office of Youth Protection containing a description of activities and their dates and locations.  Programs will supplement this information with the names of all Authorized Representatives as soon as such information becomes final. The Office of Youth Protection will maintain a master list of all programmatic information reported.

B. Consequences of Violations

1. Employees and others who violate this Policy may be subject to discipline, including but not limited to, dismissal or suspension from employment, dismissal from participation in current Programs, or ineligibility to participate in future Programs.
2. Units that violate this Policy may be prohibited from offering, sponsoring, hosting, or otherwise operating Programs or activities for Minors.
3. The University's Internal Audit Department shall, from time to time and pursuant to its policies and procedures, audit the compliance of Programs with this Policy and the effectiveness of this Policy.