1. Why was this Policy created?

This Policy updates current guidelines and procedures and aligns with the requirements of the University System of Georgia Board of Regents Policy 12.9. The Policy also reflects the University’s ongoing commitment to providing a safe and healthy environment for minors.

2. What is the effective date?

The Policy was updated on February 10, 2021.  It originally came into effect May 1, 2017.

3. As a potential Program Administrator, how do I get started?

First, discuss the potential program/activity with your Department Head/Dean/Vice-President/Director. After you’ve received initial approval to proceed, additional resources, including a checklist on how to comply with the Policy can be found under the “Resources” tab at: programsforminors.uga.edu. Please work closely with your department/unit administration throughout the planning process.

4. Will implementation of the Policy require additional staff responsibility or administrative resources?

No, it should not. The Policy builds on work already in place at the University. It is intended to enhance safety and provide additional support and resources—not create barriers. Sample forms and additional resources to facilitate compliance can be found under the “Resources” tab at: programsforminors.uga.edu.

5. Who should I contact if I still have questions about this Policy or procedures?

After checking the resource page and FAQs for your issue, email programsforminors@uga.edu or contact Brian Stone at 706-542-7255.

1. What type of program/activity is covered under this Policy?

Any program/activity that includes the care, custody, control of a minor, and is:

• Offered by departments or units of the University; 
• Offered by the University’s registered student organizations; or
• Offered by outside groups utilizing a University facility,

2. What are examples of commonly covered programs/activities?

• Camps
• Clinics
• Conferences
• Competitions
• Group lessons
• Mentoring
• Internships or experiential learning
• Hands-on research or viewing research
• Pre-enrollment visits
• Seminars
• Tutoring
• Workshops
• After-school or other enrichment opportunities.

3. How do I determine if my program/activity falls under the Policy?

Consider:

A. Is it a program/activity sponsored and controlled by a University college, school, unit, department, student organization, OR held at a University facility?

B. Do you have care, custody, or control over minor participants during the program or activity?

If the answer to A and B is YES, then your program/activity falls under the Policy unless it meets one of the stated exceptions below.

4. What are the exceptions?

The Policy does not apply to the following: a. Minors enrolled in undergraduate or graduate academic programs; b. Events or visits to campus where minors are supervised by their parent/guardian; c. Events that are open to the general public or invited guests where parents/guardians are expected to provide supervision of minors; d. Minor employees; and e. University of Georgia employees or students hosting family members, friends, or other guests. Regardless of Policy applicability, programs/activities are expected to have procedures in place to ensure best practices are followed.

5. Do school field trips fall under the Policy?

Non-residential field trips where the minor is under the direct supervision of responsible adults from its school district or organization, and which do not involve overnight lodging, are not covered by the Policy. In that situation, the care, custody, and control of the minor does not pass to the University and the school district or organization remains responsible for child protection training and background checks.

6. Do I have to seek approval under the Policy if a school/teacher contacts me about bringing minors on campus for a program?

If a school district or organization arranges the program/activity and the teacher or responsible adult maintains physical presence and custodial responsibility at all times, then the Policy does not apply. The school district has care, custody, and control of the minor and is responsible for child protection training and background checks.

7. If parents/guardians are required to be present at all times during the program/activity, does this Policy still apply?

This Policy does not apply if parents/guardians or other responsible adult will be present at all times and maintain care, custody, and control of the minor.

8. What if “the neighbor’s kid” wants to work with me in my lab this summer?

One-on-one interactions and one-time activities are covered by this Policy.

9. Are outside groups utilizing University facilities subject to this Policy?

Yes. The Policy applies to all programs/activities on University property, whether University-sponsored or produced by a third party.

1. Who is subject to the background check requirements?

Background checks are required for all Program/Activity staff, whether paid or volunteer, who work in Programs/Activities serving minors and who are reasonably anticipated to have direct contact or interaction with minor participants. Background checks must be performed whether the Program/Activity is hosted by the University or an outside group. Outside groups must certify their compliance with the background check policies when reserving University facilities.

2. How do I arrange for background checks for program staff and volunteers in university-sponsored programs?

Background checks for university-sponsored programs are conducted by UGA Human Resources. See guidance on the Programs Serving Minors Background Checks page or contact your unit's HR Business Representative for guidance on submitting for background checks. To request a background check from University HR please call 706-542-2222 and request assistance for a background check.

3. How long does it take to process a background check?

Please allow at least 14 business days. 

4. How often must background checks be performed on program staff and volunteers?

At a minimum, background checks should meet Human Resources Administrative Practice Manual (HRAP) requirements. However, depending on the nature of the Program/Activity and the job responsibilities, more frequent checks may be advisable. For third party staff, or any staff or volunteers who do not work with minors on an ongoing basis, background checks at least every three years is recommended.

5. Who is responsible for ensuring that all background checks have been completed prior to the start of the program?

It is the responsibility of the Program Administrator to ensure that all criminal background checks have been completed.

6. If a program staff member or volunteer joins Program/Activity at the last minute for any reason, are they permitted to work before the background check is completed?

No. All program staff, including volunteers, must be cleared to work with minors before a Program or Activity starts. If the results are delayed, program staff cannot start working or volunteering until he/she is cleared.

7. If I have already had a background check, do I need another one under this Policy?

Program Administrators should work with Human Resources to evaluate the need for an additional background check. If you have already had a background check that meets HRAP requirements, then you may not need a second background check under this Policy. For example, a student who recently submitted to a criminal background check as part of his/her field placement, clinical experience, or student organization may be able to utilize the previous background check for the current Program/Activity. Record of a background check must be provided and verified before an individual can interact with minors. For third party staff, or any staff or volunteers who do not work with minors on an ongoing basis, a new background check may be required. UGA employees who enter into positions of trust as minors Program/Activity Staff, and whose last background check was more than 12 months ago, may require a new background check; confirm with your unit's HR Business Representative.

8. Who do I contact if I have questions regarding background checks?

A) See UGA Human Resources FAQ page; then

B) Contact UGA Human Resources at Talent Escalated Background team, University Human Resources, hrweb@uga.edu, 706-542-2222.

1. Who is required to have training?

Training is required for all Approving Officials and program staff, whether paid or volunteer, who are reasonably anticipated to have direct contact or interaction with minors. Training must be performed whether the program/activity is hosted by the University or an outside group.

2. What training is required?

All program staff and volunteers must be trained on mandatory reporter requirements, warning signs of sexual abuse and child molestation, the University’s Non-Discrimination and Anti-Harassment Policy, and must complete a Staff Code of Conduct. In addition, all program staff and volunteers must undergo training appropriate to the program/activity, including staff and participant codes of conduct; reporting requirements; disability and other accommodations; safety and security protocols; first aid guidelines and medication management; and activities, risks, and responsibilities specific to each program/activity. The Program Administrator is responsible for developing these trainings. More information, including links to training materials, can be found under the “Resources” and “Training” tabs at: programsforminors.uga.edu.

3. How often does the training have to be completed?

Program Administrators can determine how frequently training must occur, but at a minimum, training should be completed every two years.

4. Are program staff or volunteers permitted to work before taking the training?

No. All training must be completed before being allowed to work a program/activity with minors.

1.  Is there a separate policy for minors working in University laboratory settings?

Yes, a policy for minors protection in laboratories has been implemented.  The Policy on Minors (not Acting as Students/Employees) in Research Laboratories, Clinics, and Animal Facilities aims to help ensure the safety and security of minors by designating when they will be allowed to perform research in University laboratories, greenhouses, clinic areas, or animal facilities.  All employees who work with minors in laboratory settings need to review and follow this policy.

2.  Are there exceptions to the policy?

The policy is not required when the minor is a University student or employee.  Additionally, minors are allowed to participate in University programs or science fairs and access and utilize research spaces when specifically invited to do so by the University as part of the program or science fair. In these cases, minors must be made aware of and required to comply with all unit security and access policies and all safety and other directives of the program or science fair and its staff.

3.  Are there additional actions required under this policy?

A University employee desiring to request that a minor be allowed access to specific research spaces under this Policy must initiate the process by filling out the Minor’s Research Access Form.

4.  What are the most critical safety measures when minors are allowed to work in University laboratories?

All minors working in laboratories must:  complete any hazard-specific safety training; the minor must be provided and wear personal protective equipment specific to the hazard, along with instructions for proper use and disposal; and the minor must be supervised at all times while in the facility and never left alone. The intensity of the supervision is expected to increase with increased risk.

1. Are University students and volunteers subject to the training and background check requirements of the policy?

Yes. All program staff, including students and volunteers, must complete the training and background check requirements.

2. Are student organizations permitted to host a program/activity?

Yes, subject to the requirements of this Policy and any additional rules, regulations, or guidelines required by Student Affairs.

Are guests such as lecturers, speakers, etc. required to undergo a background check and training?

If the guest is simply speaking to a group, the program staff or volunteers will maintain care, custody, and control, and the guest does not have unsupervised access to minors, then a background check and training are not required.

Do outside groups using University facilities have to meet the same standards as University-sponsored programs?

Yes. Outside groups must comply with the same standards as University-sponsored programs.

1. What is the state law regarding child abuse reporting?

O.C.G.A. §19-7-5 (https://oca.georgia.gov/mandated-reporting).

2. What are the reporting obligations of program staff and volunteers under the Policy?

Any program staff or volunteer who has reasonable cause to believe that child abuse has occurred, must immediately report the suspected abuse to 1.) the Program/Activity Administrator, Supervisor, or other responsible University Official, 2.) the UGA Police Department AND 3.) the Department of Family and Children Services (DFCS). 

3. How quickly must I report?

Program staff and volunteers should report immediately, but in no case later than 24 hours after first developing reasonable cause to suspect abuse.

4. How do I make a report?

Report to 1.) your Program Administrator, 2.) the UGA Police Department at 706-542-2200, AND 3.) the Department of Family and Children Services (DFCS) at 1-855-GACHILD.

Calling UGA Police ensures that the University is notified of any incident even when programs/activities are not on main campus or when they do not occur during normal business hours.

5. How do I determine if I need to make a report?

Do not attempt to investigate a matter further or gather additional information before reporting. If child abuse is in any way suspected, report immediately. As trained professionals, UGA Police and DFCS officials will decide whether further action is required.

A Mandatory Reporter must ensure that the Division of Family and Children Services is notified of the suspected abuse immediately and in no case later than 24 hours after the Program/Activity Staff (or other reporter) first had reasonable cause to suspect the abuse.

1. Who is responsible for registering a program/activity?

The Program Administrator should register the program. Programs can be registered under the “Program/Activity Registration” tab at: programsforminors.uga.edu.

2. How far in advance must a program/activity be registered?

Programs/activities should be registered at least 60 days in advance. In all cases, a program/activity may not be held unless it is registered prior to the start date. Annual registration is required.

3. Do outside parties utilizing University facilities need to register?

Yes. It is important for the University to have a central record of all programs/activities occurring at University facilities as well as 24-hour contact information for the Program Administrator.

What are the requirements for outside groups wishing to utilize University facilities?

Outside groups must complete an approved Facilities Use agreement, which includes a certification that they have performed background checks and agree to comply with the requirements of the Policy.

1. How is the Policy enforced?

Each University Dean, Director, Vice-President and Department Head, as applicable, has responsibility for ensuring that their units implement the Policy. Public Service and Outreach and the Director of Compliance will have general oversight with the assistance of a standing oversight committee.

2. What if my program is not in compliance?

Possible sanctions for violating the policy include suspension of University funding, non-renewal or termination of the program/activity, suspension, dismissal, or termination of University employment or program staff/volunteer status. In addition, University programs/activities that are not approved and registered pursuant to this Policy will not be eligible for payment, repayment, or reimbursement by University Business & Accounting Services.

Outside groups who violate the Policy may be removed or barred from University facilities.

1. Who maintains program/activity paperwork?

Copies of all forms should be kept by Program Administrators through the duration of the program/activity for quick reference. Thereafter, records should be kept in accordance with the Policy’s records retention requirements.

Program Administrators should work with their Dean/Director/Vice-President to figure out who is best positioned to be responsible for maintaining relevant documentation.

2. Where are forms supposed to be kept and for how long?

Consult with your Dean/Director/Vice-President to determine where documentation should be kept. Records pertaining to minors must be retained for a period of three years after the minor reaches the age of eighteen. Records pertaining to program/activity staff must be retained for five years.

1. Where can I find guidance on operating my program/activity in compliance with this Policy?

A checklist on how to comply with the Policy can be found under the “Resources” tab at: programsforminors.uga.edu.

2. What is the appropriate ratio of program staff/volunteers to participants?

The appropriate supervision ratio varies depending on the age of the participants, the nature of the program, and whether the program has an overnight component. Please refer to the American Camp Association guidelines for advisable supervision ratios (www.acacamps.org).

3. What behavior is expected under a program/activity Code of Conduct?

A complete explanation of expected staff/volunteer behavior is available on the sample Code of Conduct form under the “Resources” tab at: programsforminors.uga.edu. Minor participants should also abide by a Code of Conduct, which is also available under the “Resources” tab at: programsforminors.uga.edu.

4. What is the Two-Adult rule?

Generally, at least two program staff or volunteers should always be present with a minor. Approved “one-on-one interactions” may only take place in open, well-illuminated spaces or rooms observable by other adults. If internship interactions take place in labs or offices that other people can access or observe, and other people are in and out of, then department/unit leadership may approve these on a case-by-case basis.