2.8.13.1 Scope

This policy provides the requirements for maintaining a safe environment for Minors who participate in College-Sponsored Programs or are involved in programs taking place on College property. This policy applies to all members of Ithaca College faculty, staff, students, contractors, volunteers, invitees, and visitors, including third parties.

2.8.13.2 Policy Statement

Ithaca College (“IC” or “College”) is committed to protecting and providing a safe environment for Minors who participate in College-Sponsored Programs and Non-College Sponsored Programs on College property. All members of the College Community, including, but not limited to, all employees and all External Entities operating programs at College Facilities, must comply with this policy. It is the responsibility of all College Community members to foster and maintain an appropriate and secure environment for Minors through appropriate background checks, training, reporting, supervision, and control of access to and use of College Facilities, in accordance with the guidelines contained in this policy. In addition, all members of the College Community are required to adhere to their obligation as stated herein to report any instances of known or suspected child abuse or neglect.

2.8.13.3 Who Should Read This Policy

All members of the College Community, including employees, students, volunteers, third-party entities, and others who will have direct control and/or supervision of Minors.

2.8.13.4 Definitions

Abuse of Minors:  Any act committed by a person legally responsible for the care of a Minor that results in physical or emotional injury or creates a substantial risk of physical or emotional injury.

Authorized Adult:  Individuals, age 18 and older, paid or unpaid, who, in the course of their duties, interact with, supervise, chaperone, or otherwise oversee Minors in program activities, recreational activities (camps are defined by New York State), and/or in 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 Adult’s roles may include positions such as counselors, chaperones, coaches, instructors, etc., or others.

Background Check:  A process and review that includes screening for criminal history and national sex offender registry.

Child Molestation:  Any actual or alleged illegal or otherwise wrongful sexual conduct with a Minor.

College Community:  Faculty (including visiting faculty); administrators and professionals; staff; students; other employees (including student employees); volunteers; invitees; interns; and others who are performing activities or providing services on behalf of the College or at the College, including consultants, vendors, contractors, and External Entities.

College Facilities:  All buildings and properties that are owned, operated, managed, or controlled through lease or other written agreement by IC.

College Reporting Officer:  A position equivalent to any of the below at Ithaca College who is required to report suspected abuse, molestation, neglect, misconduct or maltreatment involving Minors:

  • President
  • Provost
  • Vice Presidents
  • Chief Financial Officer
  • College Counsel
  • Title IX Coordinator
  • Director of Athletics
  • Director of Athletic Training
  • Director of Health Center
  • Director of Counseling and Psychological Services

College-Sponsored Program:  Any program or activity that IC operates or sponsors involving Minors offered by various academic and administrative units of the College, student organizations, athletics, etc. These programs include, but are not limited to, programs in which students who are dually enrolled in College credit-bearing courses while also enrolled in elementary, middle and/or high school; academic camps; athletics camps or other athletic programs; workshops; residential programs; commuter programs; conferences; College-sponsored overnight visits involving prospective students, including those involving prospective student athletes; mentoring activities; academic enrichment programs; internship placements at College Facilities; activities occurring in College laboratories; and recreational programs.

  • A “Program,” under this Policy, does not include:
    • General events open to the public where parents/legal guardians are invited/expected to accompany and provide supervision of their children at all times.
    • IC enrolled students who are under the age of 18 participating in College credit-bearing courses or College activities.
    • The undergraduate admissions application process and related information sessions or tours led by undergraduate student ambassadors.
    • The employment of persons under the age of 18 by the College.
    • Supervision of Minors who are involved in College research that is addressed by Institutional Review Board processes. See https://www.ithaca.edu/sponsored-research/irb/

Co-Program Director:  An employee of the College or External Entity that assists the Program Director with programmatic oversight and responsibility for a College-Sponsored Program or Non-College Sponsored Program involving a Minor(s).

External Entity:  An organization that is a separate legal entity from the College.

IC Sponsor:  Any academic, administrative, athletic, or other unit within the College (not to include External Entities) that offers a College-Sponsored Program or gives approval for the use of College Facilities for a College-Sponsored Program.

Institutional Review Board (IRB):  a standing committee at Ithaca College that is responsible for reviewing all research and teaching activities conducted by IC faculty, staff, and students that involve the use of human participants to ensure that these activities minimize the potential for risk.

Maltreatment:  Any failure of a person legally responsible for the care of a Minor to exercise the minimum degree of care in providing the child with any of the following: food, clothing, shelter, education or medical care when financially able to do so. Maltreatment also includes the abandonment of a Minor or not providing adequate supervision of a Minor.

Mandated Reporter:  An individual who is required to report suspected child abuse or maltreatment when, in a professional capacity, that individual is presented with reasonable cause to suspect child abuse or maltreatment.

https://ocfs.ny.gov/publications/Pub1159/OCFS-Pub1159.pdf

Minor:  A person under the age of eighteen (18) who is not: (a) under the immediate supervision of their parent or guardian at all times while at College Facilities; (b) admitted and matriculated as a student at the College; c) employed by the College; or (d) participating in activities that have been approved by the Institutional Review Board.
Neglect of a Minor:  Any failure of a person legally responsible for the care of a Minor to provide needed food, clothing, shelter, medical care, or supervision to the degree that the Minor's health, safety, and well-being are threatened with harm.
Non-College Sponsored Program:  External Entities using College Facilities for programs and activities involving Minors that are not sponsored by IC. Non-College Sponsored Programs do not include the following: public events and other activities where Minors are under the general care, custody, or supervision of parents or legal guardians.
Off-Site Program:  A College-Sponsored Program that takes place at a location off campus or at a site that is not a College Facility.
One-on-One Contact:  Interaction as part of a College-Sponsored Program between any Authorized Adult and a Minor without the presence of at least one other Authorized Adult, parent or legal guardian.

Overnight Stay:  A College-Sponsored Program in which Minors participating are intended to stay from evening through morning for one or more days in a College Facility or at a non-College Facility.
Program Director: An individual of the College Community or External Entity that has programmatic oversight and responsibility for a College-Sponsored Program or Non-College-Sponsored Program involving a Minor(s), is responsible for ensuring overall compliance of their respective College-Sponsored Program or Non-College Sponsored Program, and for following all requirements and procedures in the Protection of Minors Policy.
Serial Sexual Misconduct:  Any act or acts in violation of the College’s Policy on Sexual Misconduct, Dating/Domestic Violence and Stalking: a) with more than one victim; and b) committed by or alleged to have been committed by any perpetrator who is not a student of an included entity.
Sexual Abuse:  Any actual or alleged Child Molestation or Serial Sexual Misconduct with a Minor.
Sexual Performance:  Any photo, video, or other recording that includes sexual conduct by a Minor.
Virtual Online Course or Camp:  Online learning, or virtual classes, offered over the internet.
Volunteers:  An individual who performs services for, and directly related to, the business of the College without the expectation of compensation.

2.8.13.5 Office Responsibilities

Office of the College Counsel:  Provide guidance on state and federal laws and regulations pertaining to Minors.
Office of Human Resources:  Responsible for processing Background Checks with the College’s authorized third-party vendor. Ensure background checks are completed, with satisfactory results, before an Authorized Adult interacts or works with Minors.
Office of Public Safety:  Receive reports of injuries, suspected abuse, sexual abuse, molestation, neglect, misconduct or maltreatment involving Minors. Public Safety will investigate all such incidents involving Minors and report information to government offices as Mandated Reporters.

  • Public Safety (607) 274-3333

Office of Risk Management and Insurance:  Policy clarification and interpretation. Receive and review program registrations with consultation from the Offices of the College Counsel, Human Resources, and Environmental Health and Safety. Support College Reporting Officers and Mandatory Reporters in the fulfillment of their reporting obligations.
Title IX Office:  Receive and investigate reports of sex- and gender-based discrimination including gender-based harassment, sexual harassment, sexual assault, domestic and dating violence, stalking, and sexual exploitation involving Minors.

2.8.13.6 Requirements applicable for college-sponsored programs involving minors

College-Sponsored Programs involving Minors are expected to comply with the guidelines and principles stated in the subsections below, in addition to the guidelines and principles stated under REQUIREMENTS FOR ALL PROGRAMS.

A.  Registration

The IC Program Director is solely responsible for ensuring that a program is registered with the Office of Risk Management. In most cases, the Program Director will register the program directly into the Protection of Minors Registration System following the required registration procedures and deadlines below. For all College-Sponsored Programs, the Program Director must provide the following to the Office of Risk Management:

  1. A description of the program, including the location(s) at which it will be held;
  2. Dates on which the College-Sponsored Program will occur;
  3. Name, title and contact information, including emergency contact detail, for the Program Director and Co-Program Director of the program;
  4. Approximate number of Minors and age range of the Minors who will participate in program;
  5. Information regarding each Authorized Adult who will assist the Program Director(s) in a College-Sponsored Program;
  6. The appropriate minors-to-staff ratio that will be maintained throughout the program (outlined in Supervision Requirements below);
  7. Program transportation arrangements, if applicable;
  8. Additional information, as deemed necessary for proper record-keeping in collaboration with the Office of Risk Management.
  9. Information for all Minors who will participate in the College-Sponsored Program, including emergency contacts and phone numbers, unless a single-day visit where a visiting entity is providing supervision under parental consent for all Minors. (See the “Emergency Contact Worksheet” on the Forms for Protection of Minors Policy page.)
  10. Where appropriate: signed parental consent forms, medical information forms, photo/image use releases (when needed, depending on the specific characteristics and duration of the program), and other required forms, as appropriate. (See available forms on the Forms for Protection of Minors Policy page.) Program Director(s) should consult with the Office of Risk Management about the need to collect any such additional documentation.

B.  Registration Deadlines

Initial registration for all College-Sponsored Programs should be submitted at least three (3) months prior to the start date of the College-Sponsored Program (more time may be required if the Program Director needs to obtain a camp permit from the local New York State Health Department), to allow sufficient time for review of the program, conduct the hiring of Authorized Adults for the program (if required), and for Authorized Adults to complete the required background checks and training, including any specialized training. (See “Background Checks” and “Training” sections below.)

The IC Program Director or IC Sponsor must re-register a College-Sponsored Program annually through the Protection of Minors Registration System, in accordance with the registration requirements and deadlines above.

C.  Background Checks

  1. A Background Check is required for each Authorized Adult (defined under Definitions above) who will have direct contact with a Minor. Program Director(s) are responsible for (a) identifying and registering all Authorized Adults who will be involved in the program and (b) ensuring all Authorized Adults successfully complete a Background Check prior to the start date of the College-Sponsored Program. Individuals who refuse to submit to a Background Check may not participate in a College-Sponsored Program. A background check is valid for three years.
  2. Background Check will include criminal history record checks at the state and federal level and a national sex offender registry check.
  3. No one may participate in the program if an individual’s Background Check includes a record of sexually-based offenses or crimes against children. If a Background Check includes a record of other offenses, Human Resources will take into consideration whether the other offenses are related to their role in the program involving Minors and, if needed, will consult with the Office of College Counsel to determine if those offenses preclude participation.
  4. Background Checks will be conducted solely through the Office of Human Resources and the results are confidential and will not be distributed to College departments or the Program Director(s).
  5. Regardless of the outcome of a Background Check, any Authorized Adult, including the Program Director, is required to self-report to Human Resources any conviction or currently pending charge for sexually-based offenses or crimes against children prior to participation in any College-Sponsored Program involving Minors.
  6. If an Authorized Adult, including the Program Director(s), is charged with a sexually-based offense or crime against a Minor before or after they have commenced participation in the College-Sponsored Program, the individual is required to stop participating in the program immediately and must disclose this information in writing to Human Resources immediately upon being charged. The College will assess the circumstances surrounding the charge. Failure to report a charge of a sexually-based offense or crime against a Minor will disqualify the individual from further participation in any College program governed under this policy. Reporting a charge pursuant to this policy does not relieve an employee from any additional reporting obligations they may have.
  7. Program Director(s) must receive confirmation of a completed Background Check for every individual acting as an Authorized Adult in the program before the first day of the program and before working with Minors.

D.  Training

Prior to the first day of a covered program, the IC Program Director must ensure that, prior to participation in the program, Authorized Adults complete College training materials that cover, at a minimum, how to identify and respond to inappropriate interactions involving Minors. For most programs, the Program Director will submit to the Office of Risk Management an Attestation Form from each Authorized Adult, affirming that they have fulfilled all of the following training requirements:

  1. Successfully complete Protecting Children: Identifying and Reporting Sexual Misconduct available on the Office of Risk Management; and
  2. Review the content of this Policy; and
  3. Review the “Code of Conduct Working with Minors” section within this Policy; and
  4. Review the College’s “Emergency Readiness and Response Planning” and “Emergency Response Guide” materials; and
  5. Review the Program Director’s written safety plan.
  6. Authorized Adults working with Minors in labs, art or shop facility, or another setting where Minors may be exposed to hazardous materials, equipment (e.g., machinery or tools), or other health-related situations must contact Environmental Health and Safety (EH&S). Additional training may be required, including age restrictions. The training length and content is specific to the program and may be provided by EH&S or an Authorized Adult in the program, as appropriate. The training will be documented and maintained by EH&S and it must be completed before Minors can take part in a College-Sponsored Program. Additional requirements for laboratories may be found in the Minors in Laboratories Policy.
  7. If a Program Director plans on using chemicals or hazardous equipment, the Hazard Identification and Control Form must be completed. Other forms or training may also be required.

E.  Communicating with Minors

For all College-Sponsored Programs, communications by Authorized Adults and other facilitating College employees with Minors is only allowed for the purpose of conducting Ithaca College business or otherwise furthering the Program-related objectives. The key safety concept is transparency. The following steps will reduce the risk of private or otherwise inappropriate communication:

  1. Communication with a Minor that is outside the role of the Authorized Adult (or other facilitating College employee) in the College-Sponsored Program is strictly prohibited. Authorized Adults who use any form of electronic communications to communicate with Minors, including social media and text messaging, may only do so for activities involving College business and must use an Ithaca College address or site. Before any online communications are sent, the Program Director must first inform the Minor’s parent or legal guardian which Authorized Adults may communicate through the use of such electronic tools. The preferred approach is to include the parent/legal guardian or another College-affiliated adult in electronic communications with a Minor.
  2. Authorized Adults must not “friend or follow” a Minor(s) on social networking sites or communicate via social media messaging systems, send personal emails or text messages, share personal or intimate information with Minors, and/or use any other communication platform to personally communicate with a Minor(s). Programs should not be designed to utilize any such prohibited methods of communication. Cyber harassment and online bullying is strictly prohibited.
  3. An Authorized Adult teaching a Virtual Online Course or Camp to a Minor(s) must involve a third party to monitor the session (e.g., a second Authorized Adult or the Minor’s parent/guardian).
  4. Refer to the College’s Technology Use Policies 2.10.

F.  Photos, Filming and Release Waivers

Never photograph, film, or otherwise record a Minor without the prior written consent of the Minor’s parent or guardian. Obtain all photo, media, and liability releases as part of the program registration process. All data gathered shall be confidential and shall not be disclosed, except as provided by law. Forms are located on the Office of Risk Management website.

G.  Housing

All overnight programs involving Minors staying in College residence halls must be registered and approved by the Office of Residential Life.
NOTE: Ithaca College student(s) hosting Minors in College housing as part of a College-sponsored overnight visit involving prospective students, including those involving prospective student athletes, are considered Authorized Adults under this Policy.

H. Transportation

  1. Only Ithaca College drivers who are approved College drivers and have permission to operate College vehicles (see “Driving College Owned and Rented Vehicles”) are authorized to transport Minors during College-Sponsored Programs.
  2. Refer to the “Supervision Requirements” (below) to determine the appropriate ratios (number of Minors per Authorized Adult) during transportation.
  3. An Authorized Adult is strictly prohibited from transporting (pick-up or drop-off) a Minor alone in a vehicle to/from any location, unless the Minor is the Authorized Adult’s child(ren).
  4. If a third-party provider (e.g., charted bus, school bus, etc.) will be hired to transport Minors to/from the College or to/from a different location other than the College, consult with the Office of Risk Management at the beginning of the program planning stage.
  5. Minors are NOT allowed to be transported in personal vehicles, golf carts, utility vehicles (gators), all-terrain vehicles (4-wheeler), etc.

2.8.13.7 Requirements for Non-College Sponsored Programs Involving Minors

Any program involving Minors operated by External Entities at College Facilities must be operated consistent with the guidelines and principles stated in the subsections below, in addition to the guidelines and principles stated under Section 2.8.13.8 REQUIREMENTS FOR ALL PROGRAMS.

A. Registration

Organizations seeking to host a Non-College Sponsored Program involving Minors at College Facilities must register the program with the Office of Conference & Event Services (CES) at least three (3) months prior to the start date of the program. CES will arrange housing accommodations if program requires Minors to stay overnight in a residence hall(s).

B. Background Checks
An appropriate Background Check is required for each Authorized Adult who will have direct contact with a Minor. If a background investigation indicates a record of sexually based offenses, crimes against Minors, or any other adverse information, the External Entity is responsible for prohibiting that individual from acting as an Authorized Adult for the program or individually interacting with Minors in any other manner as part of the Non-College Sponsored Program.
C. Training
Appropriate training is required to be completed by each Authorized Adult who will have direct contact with a Minor. The External Entity is solely responsible for determining the appropriate level of training for its participating employees, volunteers, and agents. At a minimum, the training must cover how to identify and respond to inappropriate interactions involving Minors and how to report suspected child abuse and/or maltreatment as outlined in the Duty to Report section of this policy.
The College reserves the right to require proof of compliance with the above noted policy requirements.
D. Contract and Insurance Requirements

  1. A contractual agreement between the External Entity and the College for the use of College Facilities to host Minors must include compliance with this policy as a material term of the contract. Such contracts must also include an indemnification provision in which the College is held harmless for acts or omissions arising from or related to the External Entity’s use of College Facilities. Program Director of External Entity is responsible for ensuring that the Ithaca College Office of Conference and Events Services Agreement is in effect prior to the use of College Facilities.
  2. External Entities seeking to host a Non-College-Sponsored Program at College Facilities must ensure they obtain the appropriate insurance coverage, as stated in the written Agreement, prior to the start date of the program and provide a Certificate of Insurance to Ithaca College. Note: The College reserves the right to require higher coverage limits depending on the exposures on the program.

2.8.13.8 REQUIREMENTS FOR ALL PROGRAMS (COLLEGE-SPONSORED and NON-COLLEGE SPONSORED)

The following sections contain requirements that may be applicable to both College-Sponsored Programs and Non-College Sponsored Programs:
A. Medical Emergencies, Medication, and Procedures

Program Director(s) participating in a College-Sponsored Program involving Minors or External Entities taking part in a Non-College Sponsored Program at College Facilities involving Minors must ensure that all Authorized Adults comply with the following requirements:

  1. Programs must consider and prepare for emergency medical services to be able to access and respond to all locations. Any medical care appropriate for the nature of the program/activities needs to be reviewed prior to the start of the program, including expected attendance and other variables that should be taken into consideration. Direct questions to the Office of Public Safety.
  2. When utilized, authorization for medical treatment forms (including consent to release medical information and authorization for emergency treatment) and general medical liability releases/waivers must be completed and signed by a parent/legal guardian for each Minor. College-Sponsored Programs may use the Medical History and Consent for Treatment Form and Immunization History Form, or other forms approved by the Office of Risk Management, and IC Program Director(s) must ensure that completed forms are reviewed by a medical professional prior to the start of the program. Any updates to a Minor’s information on any medical/health forms must be reviewed by a medical professional prior to the Minor’s continued participation in the program.
  3. All covered programs must adhere to guidance from the College concerning communicable diseases.
  4. Authorized Adults shall keep medication in a secure location, and at the appropriate time for distribution shall allow the Minor to self-administer the appropriate dose as stated on the container. A log must be maintained to document when medication was distributed to the Minor.
  5. Medication may be distributed only (not administered) to the Minor by an Authorized Adult, unless exceptions are made for specific medications, based on New York State and federal regulations and only in accordance with written authorization from the Minor’s parent or legal guardian. All such medication must be provided in its original pharmacy container labeled with the Minor’s name, name of the medication, dosage, and timing of consumption. Over-the-counter medications may only be accepted by program staff from Minors or their parents in the manufacturer’s original container.
  6. Any medication that the Minor cannot self-administer must be stored and administered by a licensed healthcare professional associated with the College or External Entity. If no one is available, arrangements must be made with another health care professional in advance of the Minor’s arrival.

B. Emergency and Safety Planning
Authorized Adults participating in a College-Sponsored Program and External Entities taking part in a Non-College Sponsored Program involving Minors at College Facilities must follow the requirements below prior to the start of the Program, except where noted:

  1. Programs involving Minors must maintain safeguards and precautions appropriate for the Minors in their care. Where appropriate, Programs Director(s) must develop a written safety plan to include how the program will respond to an emergency event, communicate and notify parents/legal guardians in case of an emergency, including medical, behavioral problems, or other significant program disruption (see information below on the emergency notification system). All Authorized Adults in the program, as well as Minors’ parent/legal guardian, must be advised of these procedures in writing. Program Director for College-Sponsored Programs should provide a copy of their safety plan to the Office of Risk Management.
  2. In the event of an emergency requiring evacuation of a College Facility or shelter-in-place involving Minors, all members of the College Community shall comply with instructions received from College officials including the Office of Public Safety. All Program Director(s) and all Authorized Adults participating in a covered program must review “Emergency Readiness and Response Planning” and the “Emergency Response Guide.” Direct questions to the Office of Public Safety.
  3. Program Director(s) and all Authorized Adults must register in the Ithaca College emergency notification system.
  4. Program Director must provide instructions to parent/legal guardian on (a) how they can register in the College emergency notification system and (b) how their child can be contacted during the program.
  5. For College-Sponsored Programs, the IC Program Director(s) or IC Sponsor(s), must provide program detail, names of Minors, and emergency contacts for all Minors to the Office of Public Safety and the Office of Risk Management. (See the “Emergency Contact Worksheet” on the Forms for Protection of Minors Policy page.)
  6. All covered programs must follow appropriate safety measures approved by the Office of Environmental Health & Safety for work conducted in a laboratory or for an environment/activities considered hazardous to Minors that require specialized training (See “Training” section). Note: External Entities involving Minors are NOT permitted to use College laboratories or other areas the College deems hazardous.
  7. Program Director(s) for all covered programs must provide information to parent/legal guardian on location of program, check-in/check-out procedures, and behavior expectations & consequences.
  8. For College-Sponsored Programs, IC Program Directors must maintain appropriate procedures to verify the attendance of all registered Minors.
  9. On first day of check-in at registration for multiple-day programs, the Program Director(s) must obtain a current photo of each Minor from parent/legal guardian. Program Director(s) must be able to provide a photo(s) at any time during the program to the Office of Public Safety in the event of an emergency.

C. Supervision Requirements
Program Director(s) participating in a College-Sponsored Program involving Minors or External Entities taking part in a Non-College Sponsored Program at College Facilities involving Minors must ensure that all Authorized Adults comply with the following requirements:

  1. Program Director(s) must ensure adequate supervision of Minors and standards for maintaining appropriate ratios (number of Minors per Authorized Adult, by age and type of activity). Unless alternative adequate arrangements are developed in Consultation with the Office of Risk Management, all Program activities involving Minors must be supervised by at least two or more Authorized Adults or by their parent(s) or legal guardian(s) at all times. Some of the factors to consider in determining "adequate supervision" are keeping the Minors together within appropriate age levels, when possible; the number of Minors participating in the program; the activities involved; type of housing (if applicable); gender distribution; transportation in a vehicle (refer to “Transportation” above for additional information); and age and experience of the Authorized Adults.
  2. Ratios. External Entities operating Non-College Sponsored Programs must comply with the age and supervision standards and ratios required by state and local law. College-Sponsored Programs require the following age and supervision ratios (the Office of Risk Management may adjust a program’s required supervision if needed):
    1. For College-Sponsored Programs not defined as a camp under the New York State Department of Health:
      • Program Director(s) for day programs must be at least 21 years of age. Authorized Adults who assist the Program Directors must be at least 18 years of age for day and/or overnight programs, with at least one Program Director or Authorized Adult who is at least 25 years of age to be accessible to Minors in College housing at all times during an overnight program
      • During passive activities (defined as activities that take place in a defined area, where Minors are spectators or have limited mobility and use no tools or equipment other than computers), the Minor to Authorized Adult ratio will be 12:1. A smaller ratio may be necessary depending on the type of program and ages of Minors.
      • During non-passive activities for day programs the ratio will be 12:1. A smaller ratio may be necessary depending on the type of program and age of Minors.
      • Overnight programs require the ratio be: 1) 10:1 for Minors ages 8 years and older, and 2) 8:1 for Minors under the age of 8.
      • Swim activities require the ratio be: 1) 10:1 for all swimmers ages 8 and older, 2) 8:1 for all swimmers ages 6&7, 3) 6:1 for all swimmers under the age of 6, and 4) 1:1 for non-swimmers and Minors with special needs. Swim tests are required and appropriate lifeguard coverage is needed.
      • Off-site swim activities require the ratio to be: 1) 8:1 for all swimmers ages 6 years and older, 2) 6:1 for all swimmers under the age of 6 years, and 3) 1:1 for non-swimmers and Minors with special needs. Swim tests are required and appropriate lifeguard coverage is needed.
    2. For College-Sponsored Programs defined as a camp under New York State Department of Health:
      • Minors to Authorized Adult ratios will remain at 8:1 for water activities, passive activities, during transportation, between activities, and during sleeping. There is to be a ratio of 8:1 for swimmers ages 8 and older, a ratio of 6:1 for swimmers ages 6 & 7, a ratio of 3:1 for non-swimmers and the Authorized Adult must be in the water with the non-swimmer, and 1:1 with a swimmer that has been diagnosed with seizures or special needs. There will always be a swimmer to lifeguard ratio of 25:1 for swim camp.
  3. If the program involves overnight housing, the Program Director(s) must adopt and implement rules and regulations for proper supervision of Minors. The following must be included:
    1. Written permission signed by the parent/guardian for the Minor to reside in College housing.
    2. A curfew time which is age-appropriate for the participants, but in no case shall it be later than midnight.
    3. In-room visitation to be restricted to participants of the same gender.
    4. Guests of Minors (other than a parent/legal guardian and other Minors who are participating in the program) are restricted to visitation in the building lobby and/or floor lounges, and only during approved hours specified by the Program Director(s). Guests need to be approved in writing by parent/legal guardian and provided to Program Director.
    5. The program must comply with all security measures and procedures specified by the Office of Residential Life and the Office of Public Safety.
  4. Develop and make available to Minors and parent/legal guardian the rules and discipline measures applicable to the program. Minors and Authorized Adults must abide by all College regulations, including the rules below, or they will be removed from the program for non-compliance. The following must be included in program rules:
    1. The possession or use of alcohol and other drugs, fireworks, guns and other weapons are prohibited.
    2. The operation of a motor vehicle by Minors is prohibited while attending and participating in the program.
    3. The parking of Authorized Adults and Minors’ personal vehicles must be in accordance with College parking regulations.
    4. Rules and procedures governing when and under what circumstances Minors may leave the College property during the program.
    5. No violence, including sexual abuse or harassment, will be tolerated.
    6. Hazing of any kind is prohibited. Bullying including verbal, physical, and cyber bullying are prohibited.
    7. No theft of property, regardless of owner, will be tolerated.
    8. No use of tobacco products, illegal drugs, or controlled substances.
    9. Misuse of, or damage to, College property is prohibited. Charges will be assessed against those Minors who are responsible for damage or misuse of College property and will be responsible for damage expense.
    10. The inappropriate use of cameras, imaging, and digital devices is prohibited, including use of such devices in showers, restrooms, or other areas where privacy is expected by Minors.
  5. Responsibilities of the Authorized Adults must include, at a minimum, informing Minors who are participating in a program about safety and security procedures, College rules, rules established by the program, and behavioral expectations. Authorized Adults are responsible for following and enforcing all rules and must be able to provide information included herein to Minors and be able to respond to emergencies.

D. Code of Conduct Working with Minors

  1. Authorized Adults participating in a College-Sponsored Program or an External Entity taking part in a Non-College Sponsored Program involving Minors at College Facilities must NOT:
    1. Engage in One-on-One contact with a Minor in a closed/private area without the presence of at least one other adult member of the College Community, additional minor, or parent or legal guardian.*
    2. Enter a Minor's room, bathroom facility, or similar area when that Minor is staying overnight in College housing, or if overnight occurs off campus, without another Authorized Adult in attendance, except under emergency circumstances.*
    3. Sleep in the same room as a Minor(s). Separate accommodations for Authorized Adults and Minors are required other than for the Minors’ parents or legal guardians.*
    4. Engage in sexual activity with a Minor.
    5. Make sexual comments or tell jokes of a sexual nature to or in the presence of a Minor.
    6. Touch a Minor in a manner that could be reasonably interpreted as inappropriate.
    7. Engage in conversations regarding romantic, sexual or related manners unless in the role of a provider of health care or counseling, or faculty academically addressing materials of a sexual nature as part of a course, training, or classroom experience (i.e., consistent with academic freedom).
    8. Use, possess, or be under the influence of drugs or alcohol while on duty or responsible for a Minor’s welfare (as defined in Section 2.8.8 of the Drug and Alcohol Policies).
    9. Engage in any other behavior prohibited under applicable College policies.
      • Engage in abusive conduct of any kind toward, or in the presence of, a Minor.
      • Transport (pick-up or drop-off) a Minor alone in a vehicle to/from any location, unless the Minor is the Authorized Adult’s child(ren). (See “Transportation” section)
      • Provide alcohol, illegal drugs, or other controlled substances to any Minor.
      • Expose Minors to sexually explicit materials, such as pornography.
      • Leave Minors without proper supervision.
      • Abuse or Neglect a Minor.
      • Photograph, film, or otherwise record a Minor without the prior written consent of the Minor’s parent or guardian.

* Ithaca College student(s) hosting Minors in College housing as part of a College-sponsored overnight visit involving prospective students, including those involving prospective student athletes, are NOT subject to prohibitions 1a., 1b., and 1c. above in this subsection.

*
2. Authorized Adults participating in College-Sponsored Programs or an External Entity taking part in a Non-College Sponsored Program at College Facilities must:

  1. Watch for and report any of the behavior not allowed (above) or consult with appropriate person(s) of authority when uncertain about a situation involving a Minor (see “Reporting” section of this policy);
  2. Maintain high standards of personal behavior when working with Minors;
  3. Treat all Minors consistently and with respect; and
  4. Maintain discipline and discourage inappropriate behavior.

E. Duty to Report
All Authorized Adults participating in a College-Sponsored Program involving Minors or, where applicable, External Entities taking part in a Non-College Sponsored Program involving Minors must comply with the following reporting requirements:

  1. Reporting Medical Emergencies and Injuries

    • If a Minor participating in a College-Sponsored Program or Non-College Sponsored Program is in immediate danger of bodily harm or otherwise requires emergency medical assistance, an Authorized Adult or any member of the College Community or of the External Entity must call 911 immediately (and must also contact Ithaca College Public Safety at 607-274-3333).

    • Immediately report any and all physical injuries to Minors to Ithaca College Public Safety at 607-274-3333.

  2. Reporting Suspected Child Abuse or Neglect
    1. Mandated Reporters are required to comply with New York State Mandated Reporter requirements: https://ocfs.ny.gov/main/publications/Pub1159.pdf
      • Members of the College Community and members of External Entities who are considered Mandated Reporters pursuant to New York State law are also required to report suspected child abuse and/or maltreatment to the New York State Office of Children and Family Services (“OCFS”) Hotline at 1-800-342-3720. OCFS is located at https://ocfs.ny.gov/main/cps/faqs.asp#report
    2. College Reporting Officers are required to report suspected abuse, sexual abuse, molestation, neglect, misconduct or maltreatment involving Minors in College-Sponsored Programs or Non-Sponsored programs at College Facilities to the Office of Public Safety at (607) 274-3333.
    3. In addition to those persons required to report suspected child abuse and/or maltreatment, all College employees, volunteers, and independent contractors (including all External Entities participating in Non-College Sponsored Programs) who receive a specific disclosure from a person that an identifiable child is a victim of child abuse and/or maltreatment, or that a person has abused a child, are also required by the College to make a report as outlined in this policy. Whenever an individual makes a report, that person shall also make an internal report to the Office of Public Safety at (607) 274-3333.
    4. Responsible Employee Reporting to Title IX Coordinator. Where the suspected behavior towards a Minor participating in a College-Sponsored Program is sexual in nature, a Responsible Employee (as defined in Section 2.1.4 of the Policy Manual) must report the incident to the College’s Title IX Office at (607) 274-7761. Please see the College Policy 2.1, Sexual Misconduct, Domestic/Dating Violence and Stalking.
    5. Office of Risk Management & Insurance. Where consistent with applicable confidentiality obligations, the Office of Public Safety, Title IX Office and/or any other unit of the College must immediately alert the Office of Risk Management and Insurance of a complaint under this Policy.
    6. Other. All other prohibited behavior must be reported in a manner that is consistent with the applicable College policy and procedures.

2.8.13.9 VIOLATION OF THIS POLICY

The College will enforce this Policy in conjunction with the appropriate offices of the College. Violations of this Policy may result in the non-approval or immediate termination of a College-Sponsored Program or Non-College-Sponsored Program, and disciplinary action against members of the College Community (up to and including termination of employment or services, as applicable), consistent with College policies. In accordance with applicable law and College policy, the College reserves the right to check and monitor compliance with this Policy by conducting site visits, requesting documentation, and/or conducting a formal audit.

2.8.13.10 ANTI-RETALIATION

The College prohibits retaliation against any member of the College Community who makes a report or complaint under this Policy.

Approved: April 27, 2021