Minors on Campus Policy

Revisions Adopted by President’s Cabinet 6/22/21; 3/30/23
Revisions Adopted by President’s Cabinet 1/29/21
Revisions Adopted by President’s Cabinet 1/27/20
Revisions Adopted by President’s Cabinet 12/18/18
Revisions Adopted by President’s Cabinet 11/27/18
Revisions Adopted by President’s Cabinet 3/30/18
Revisions Adopted by President’s Cabinet 2/28/17
Adopted by President’s Cabinet 12/20/16

I. Purpose

East Georgia State College (EGSC or the College) offers a variety of academic and athletic camps, programs, competitions, K-12 campus visitations, K-12 test administrations, recruitment visits, enrichment classes, and activities which bring non-student minors to campus. These programs, events, camps, and activities provide EGSC with the opportunity to challenge, educate, and mentor young people and to introduce them to campus in a meaningful way. The safety and well-being of these campus visitors is of the highest concern. This policy serves to provide guidance to the EGSC campus community and third parties, and to ensure compliance with federal and state laws and the Board of Regents (BOR) of the University System of Georgia (USG) policies and procedures. It also ensures the appropriate protection and supervision of minors participating in college sponsored programs or programs operated by third parties held on the EGSC campus. This policy applies to all programs that begin on or after May 1, 2020.

II. Scope

This policy applies broadly to all programs/activities serving one or more minors, including those:

• • Offered by departments or units of the College at a College facility or sponsored by the College at other locations;
  • Offered by the College’s registered student organizations at a College facility or at other locations; or
  • Offered by Third Parties utilizing a College facility.

This policy sets forth the procedures to be followed for planning, prescreening, and training of event leaders and event workers. The policy also sets forth the procedures for conducting programs, events, camps, and activities for non-student minors, managing third-party sponsored programs, events, camps, and activities, and record-keeping. Unless specifically excluded in Section III herein, academic camps, academic tutoring, athletic camps, after school programs, workshops, and similar activities which involve the custody and care of non-student minors which are conducted, hosted, or sponsored by EGSC or by an unaffiliated third-party sponsor.   This policy also applies to students completing internships and practicums at EGSC. See the EGSC Hosted Student Internships Policy  

III. Exclusions

The excluded events are considered a facility usage event and the EGSC department/unit responsible for the planning and execution of excluded programs/events should follow the college policies and procedures for event planning and facilities usage. 

This policy does not apply to:

1. 1. 1. Events or performances on campus that are open to the public and which minors attend at the sole discretion of their parents or guardians;
      2. Private events that occur on campus such as receptions, rehearsal dinners, birthday parties, etc.;
      3. Events where an EGSC employee, student, or non-employee serve as a volunteer judge or presenter such as high school academic or athletic practices or competitions, and National Science Olympiad;
      4. Targeted programs for minors where the non-student minor’s parent or adult family member (over the age of 18) provides supervision, such as Family Astronomy Night at the Fulford Center;
      5. Student recruitment activities including, but not limited to, Admissions visit and tours, Open Houses, and Financial Aid workshops. These activities are scheduled to last no longer than one day and do not include an overnight stay;
      6. National tests offered at the College including but not limited to SAT, ACT, etc.

IV. Definitions

Authorized Individual:  Individuals, paid or unpaid, who are authorized by EGSC officials to have direct contact with minors, including the responsibility for escorting, accompanying, or supervising. To qualify as authorized, the individual must comply with all applicable registrations, background check, and training requirements implemented with this policy. Authorized individuals include event leaders and event workers with supervisory capacity.

Abuse or Neglect of Minor(s):  For purposes of this policy, Abuse or Neglect of Minor(s) means infliction of physical or mental injury, sexual abuse or exploitation, negligent treatment, or maltreatment of a minor.  Sexual abuse includes engaging in or attempting to engage in a sexual act or sexual contact with a minor, causing or attempting to cause a minor to engage in sexually explicit conduct, or exposing the minor to sexually explicit conduct.  Neglect includes the failure to make reasonable efforts to prevent the infliction of abuse upon a person under the age of eighteen (18).  Mandatory reporting is required when there are suspicions of any of the above-named incidents involving a non-student minor.

Campus:  For purposes of this policy, campus includes all buildings, properties, facilities, and areas that are owned, leased, managed, operated, or controlled by East Georgia State College.

Contact/Interaction with Minor(s):  In the context of this policy, contact or interaction with minors is contact that is direct and reasonably anticipated.  The term does not include interaction that is merely incidental.

Criminal Background Screening or Criminal Background Check (CBC): A report including an individual’s criminal history and sex offender registry.

Vice President for Institutional Advancement or designee: The EGSC Vice President for Institutional Advancement or designee is the central coordinator for campus events, visitations, and camps. The Vice President for Institutional Advancement or designee is responsible for receiving inquiries and proposals for campus facilities usage, hosting non-student minors for testing, recruiting academic and athletic visitations, and events or similar proposals as covered under Section II of this policy. The Vice President for Institutional Advancement or designee is responsible for receipt of event proposals from the event leader or from third-party sponsor, reviewing, and approving proposals and consulting with the appropriate campus officials when necessary. The Vice President for Institutional Advancement or designee is responsible for all communications with the event leader or third-party sponsor.   The Vice President for Institutional Advancement or designee is responsible for maintaining the program registry.

Event Leader: The EGSC individual responsible for submitting to the Vice President for Institutional Advancement or designee an event proposal for an event targeting or including non-student minors. The Event Leader may or may not be the individual that manages and supervises the event.

Event Worker:  Any EGSC employee (faculty or staff), an EGSC student, intern, or volunteer paid or unpaid. Event workers can have (1) primary role as supervisor and direct contact with minors; or (2) secondary role and are supervised by an authorized individual.

Minor(s): Persons under the age of eighteen (18). EGSC minor students enrolled in Dual Enrollment (DE) programs are not covered by this policy.

Minors on Campus Training:  Expanded mandatory training will be provided by EGSC to authorized individuals conducting and working in events and programs covered by this policy. The appropriate screening and training must occur prior to participation in the programs covered under this policy. See Paragraph V3, section 3a herein.

Supervision: Defined as having the children/teens/ minor within your line of sight. Ensure that there is an appropriate chaperone(s)/supervisor(s) ratio. (as provided in paragraph V, section 1a herein)

Third-party: An individual, company, or organization sponsor of an event that is external to the College, to which the College allows use of its facilities to operate a program or activity. Examples: guests, volunteers, contractors, vendors, retirees, alumni.

V. Procedure:

1. Event Proposal:

1. 1. EGSC sponsored activities for non-student minors will be reviewed as provided herein, and if approved will be handled and scheduled according to college event planning and facilities scheduling procedures. Event Leaders must submit proposals for East Georgia State College events to the Vice President for Institutional Advancement or designee using the Programs Serving Non-Student Minors on Campus Event Proposal Form. Departments/Units with annual or recurring events for non-student minors must submit updated proposals for each event as applicable. The proposal must be submitted no less than ninety (90) days PRIOR to the proposal event start date. Proposals submitted less than 90 days PRIOR to the event start date will be denied.  The Vice President for Institutional Advancement or designee may waive this deadline only if extraordinary circumstances exist.  Event Leaders should begin the proposal process as early as possible to obtain quotes for third-party services (officials, instructors), event staff (paid or non-paid), clothing, supplies, materials, food, etc., no less than 30 days PRIOR to the event start date. This time will allow for all Event Workers to receive Minors on Campus Training, Criminal Background Screening or Criminal Background Check as applicable in paragraph V3 herein, and authorization to work or volunteer. A proposed budget including anticipated events revenue and costs, and a draft brochure, flyer or other proposed marketing material must be attached to the proposal. The proposal must designate volunteers, workers, temporary employees, and current employees serving as volunteers. Proposals submitted without all required documents will be denied. All proposals that include personal service payments for event workers must be sent to the Vice President for Business Affairs for approval PRIOR to approval of the event by the Vice President for Institutional Advancement or designee.

      Employee’s working an event must follow all applicable leave and travel policies. If EGSC provides transportation for non-student minors as part of the program, commercial transportation or fleet vehicles must be used. All EGSC vehicle drivers must be qualified drivers as defined in the EGSC Fleet Management and Motor Vehicle Policy. 

      The proposal must include appropriate event workers.  It is the responsibility of the event leader to ensure the minimum level of supervision consistent with the participant ratios for the event: Recommended Authorized Individual to program participant ratios are as follows.

      Day Programs for Minors:

      1. One Authorized Individual for every six participants ages 4 and 5;
      2. One Authorized Individual for every eight participants ages 6 to 8;
      3. One Authorized Individual for every 10 participants ages 9 to 14;
      4. One Authorized Individual for every 12 participants ages 15 to 17.

      At least 80 percent or more of the authorized individuals (event workers) must be at least 18 years old. Event workers must be at least 16 years old and be at least two years older than the campers with whom they work.

      Residential camps must use the current staffing ratios as determined by the American Camp Association.  See:  http://www.acacamps.org/

      When notified that a participant with a disability will attend a program, event, camp, or activity and will require accommodations, the disability will be accommodated whenever possible and in accordance with applicable state and federal laws, and EGSC and USG policies.  If the accommodation requires the participant to have a special chaperone or caregiver, then that chaperone or caregiver will be considered an Authorized Individual.

      The proposal must indicate the Authorized Individual responsible for conducting the event, if different from the Event Leader submitting the proposal. The Event Leader, or his/her designee, is responsible for conducting the event, including snacks and meals, supervision of participants and administering an Event Evaluation Form. The Event Leader must submit all completed Event Evaluation Forms to the Vice President for Institutional Advancement or designee.

   2. Third-party Sponsored Event:

      Unaffiliated third-party sponsors must request facilities usage through the college’s Vice President for Institutional Advancement or designee or Fulford Center Director, as appropriate, and the usage will be reviewed as provided herein. If approved, the unaffiliated third-party sponsor must sign a Facilities License Agreement requiring the third-party sponsor to comply with EGSC’s Programs Serving Non-Student Minors on Campus policy, program/activity operational procedures (including the provision of documentation of criminal background screening/checks and training of its personnel) and meet minimum insurance requirements required by the University System of Georgia (USG).  This policy must include Sexual Assault and Molestation Insurance (SAMS Insurance) coverage.  Documentation provided must indicate such coverage on the certificate.  No carve-outs.

      All third-party sponsored programs must meet Rule 591-1-1-.46 of the Georgia Department of Early Care and Learning license requirements, unless exempt. Camps and programs that are owned and operated by any department or agency of a state, county or municipal government are exempt. Third-party sponsors must include a copy of the license or proof of exemption to the college’s Vice President for Institutional Advancement or designee. A copy of the license or exemption must be displayed during the program. Requests by unaffiliated third-party sponsors to use the campus for non-student minor programs will be shared with the EGSC Legal Counsel and EGSC Vice President for Business Affairs for review.

2. Receipt and Review of Proposal:

The college’s Vice President for Institutional Advancement or designee is the first point of contact for all activity and event proposals covered under this policy.  The Vice President for Institutional Advancement or designee will maintain a registry of all authorized programs. The Event Leader or Third-Party Sponsor is responsible for obtaining and completing the Programs Serving Non-Student Minors on Campus Event Proposal Form and submitting it to the Vice President for Institutional Advancement or designee. The Vice President for Institutional Advancement or designee will confirm that the requested facilities, support, and special requests are available on the proposed dates. Additional review is necessary for all third-party sponsored events as stated previously. The Vice President for Institutional Advancement or designee will communicate with the Event Leader or Third-party Sponsor when additional information is needed, and once obtained, will review, gather the necessary information, and approve or deny the event.  The Vice President for Institutional Advancement or designee will communicate to the Event Leader or Third-party Sponsor whether the event is approved or denied and communicate training and criminal background screening requirements to the Event Leader or Third-party Sponsor and to the Director of Human Resources. The Vice President for Institutional Advancement or designee will handle registration, waiver, medical, and other forms, collect event fees, pay all expenses associated with the event from the event funds, retain all event receipts and documentation, and maintain and house the permanent event file per USG record retention guidelines. 

3. Screening, Training, and Insurance:

1. 1. EGSC Event Workers:

      All EGSC employees are required to annually complete Programs Serving Non-Student Minors on Campus and Mandatory Reporting of Child Abuse and Neglect Policy training. All EGSC Event Workers covered under this policy must also attend all the EGSC Minors on Campus expanded training and consent to and pass a criminal background check (CBC) prior to the event start date. (See Minors on Campus Training Agenda – Attachment A) EGSC employees working a minors on campus event will be deemed to have fulfilled the CBC requirement with their pre-employment CBC as long as there are no subsequent disqualifying arrests or convictions. Per EGSC Employment Selection Process and Criteria for Employment Policy, employees are under a continuing duty to report arrests and convictions (other than minor traffic offenses) to the Department of Human Resources and failure to do so may result in disciplinary action up to and including termination. See policy: http://qfg.alexblog.net/about/at-a-glance/policies-and-procedures-of-the-college/08-employment-selection-process-and-criteria-for-employment.html

      EGSC employees desiring to use volunteer staff must follow the EGSC Volunteer Program Policy which requires making a request to the Department of Human Resources for use of volunteers with identifying information and dates of event using the Volunteer Request Form. See policy http://qfg.alexblog.net/about/at-a-glance/policies-and-procedures-of-the-college/08-volunteer-program-policy.html

      See form: http://qfg.alexblog.net/about/at-a-glance/policies-and-procedures-of-the-college/files/08-2023-12-08-request-for-volunteer-services-form.pdf

      The Director of Human Resources is responsible for obtaining consent for Criminal Background Screening and ordering the screening using USG approved background check vendor.  Students completing practicums and internships are covered under the EGSC Internship’s policy http://qfg.alexblog.net/about/at-a-glance/policies-and-procedures-of-the-college/08-egsc-hosted-student-internships-policy.html  The screening must be conducted no less than 30 days PRIOR to the event start date.  The cost of the criminal background screening is the responsibility of the individual or department and handled by the Director of Human Resources.  The Director of Human Resources will review the criminal background screening using the guidelines provided by the Board of Regents’ Human Resources Administrative Practice Manual and determine if the  Event Worker is cleared to work the event as an authorized individual. Human Resources personnel are aware of the inherent limitations of the criminal background checks and should seek to utilize other screening methods, when possible, to include in-person interviews and reference checks. The Director of Human Resources will communicate his/her determination to the  Event Worker. Any CBC failures will be handled by the Director of Human Resources in accordance with the above Board of Regents Policy. CBC’s for non-EGSC employee Event Workers will be valid for a period of one year. The Director of Human Resources will maintain a Central Repository of all training and criminal  background screenings  conducted under this policy. Teachers employed by any of the area school systems who volunteer to assist with EGSC and/or Fulford Center sponsored programs, events, or camps will need to provide a letter verifying that they had a criminal background screening, along with the vendor name.   The Vice President for Institutional Advancement or designee and Director of Human Resources will coordinate the screening and training of all Programs Serving Non-Student Minors on Campus event workers to ensure that all are properly screened and trained prior to direct contact or interaction with minors.  The Minors on Campus training must be conducted PRIOR to start of event.

   2. Third-party Sponsors:

      All third-party sponsors conducting programs, events, camps, and activities serving non-student minors on the college’s campus must sign the EGSC Facility License Agreement which is USG approved and in accordance with Board of Regents Policy 6.14.2. The agreement shall indicate that minors are involved, show evidence of adequate liability insurance naming EGSC and the Board of Regents of the University System of Georgia as an additional insured, be inclusive of Sexual Assault and Molestation (SAMS) insurance, provide certification that its personnel assigned to the program, event, camp, or activity have attended a EGSC Minors on Campus training, and have been pre-screened with criminal background checks that at a minimum, satisfy USG Human Resource Administrative Practice Manual.

      In addition, transportation and housing needs should be addressed in the program proposal. Third-party Sponsors must provide transportation in its own vehicles, or rental vehicles, as appropriate, and provide evidence of regular screening of vehicle drivers to ensure the safety and security of non-student minor passengers.

      Housing requests must abide by the American Camp Association’s camp – staff ratio according to the age of the non-student minor.  See www.acacamps.org

4. Fees:

Facility fees are generally paid by the participant and included in the event participant fee. Housing fees will be quoted per day per person based on current rates.  Participants using Bobcat Villas will be allowed access to the Strange Clubhouse during normal operating hours. Meal fees will be negotiated with the Dining Services based on specific event needs. Events held after hours may incur additional facility, service, and support costs. After hours usage will be computed using the Facility Rental rates for the facility as published on the EGSC website. Please inquire with the Vice President for Institutional Advancement or designee about all fees when preparing a proposal.

5. Program and Activity Procedures:

The Event Leader or the Third-party Sponsor shall do the following:

• • Operate the program or activity in a reasonably safe manner.
  • Use all appropriate forms related to the operation of the program/activity such as registration form, medical information and emergency treatment form for each participant, camper pick up authorization, minor child release and waiver, and photo release.
  • Screen and coordinate with EGSC’s Department of Human Resources to conduct / provide evidence of criminal background checks which includes a state and federal criminal history check covering a minimum of seven (7) years and a search of the National Sex Offender Registry, on all event workers interacting with the non-student minors during the program, event, camp, or activity.
  • Every non-student minor must always be properly supervised in the immediate presence of at least one authorized individual while participating in the program, event, camp or activity. See paragraph V1 for ratios.
  • All event workers assisting with the program/activity must receive training that includes mandatory reporting requirements, appropriate contact with minors including the Staff and Volunteer Code of Conduct and the Camper Code of Conduct (Attachment B, Attachment C), safety and security procedures including EGSC weather and other campus emergency response, injury, or illness response protocols and staff or participant misconduct.
  • Ensure the safety and protection of program participants using protocols for reporting injuries, accidents, staff misconduct, participant misconduct, and procedures for secure pick up and drop off for program participants. Communicate with program participants concerning security measures such as weather alerts, missing persons, and where to meet and where to go if lost.
  • In case of an emergency or to report criminal activity, an Authorized Individual or program participant should immediately call the EGSC Campus Police Department at 478-289-2090. Individuals may also call 9-1-1.
  • Authorized Individuals or any persons listed in O.C.G.A. 19-7-5(c)(1), also known as a Mandatory Reporter, must report safety concerns on behalf of a non-student minor or suspicions or known instances of abuse or neglect as defined within this policy of a non-student minor to EGSC Police Department at 478-289-2090 and to the Georgia Department of Human Services at 1-855-GACHILD (422-4453). The Event Leader should also be notified. Reports must be made as soon as possible but no later than 24 hours after the event giving rise to the concern.

6. Response Protocol for Missing Participants:

Event Leaders and other Authorized Individuals are expected to maintain adequate supervision of all event participants. Head counts at regular, frequent intervals should be conducted to ensure that participants do not stray from the group. If at any time you cannot account for all of your event participants, you should:

• • Contact the event leader or other designated representative on site.
  • Secure all participants in a designated area. Do not let participants begin a search for the missing participant.
  • Determine the identity of the missing participant. Obtain a physical description of this person (height, weight, hair color, clothing description, any photos taken of this person during the event).
  • Determine the last known location of the participant. Search the perimeter of the last known location of the participant.
  • Contact East Georgia State College Police Department and request assistance.
  • The EGSC Police Department will notify Vice President of Institutional Advancement or designee and the President.
  • The event leader, at the direction of Vice President of Institutional Advancement or designee or EGSC Police Department, is responsible for all communications with the parent/guardian to provide a consistent, known source for information.
  • The EGSC Police Department will provide a written report of the incident.
  • The event leader will notify Legal Counsel/Chief of Staff who serves as the Risk Management Coordinator of the incident, who will obtain the written report and maintain that report with the event documentation. If a child is separated from the group and is found by someone not affiliated with the event, that person should take the child to an open area so they are not alone with the child and where they can be easily seen. They should immediately call EGSC Police Department at 478-289-2090 to report the found child. EGSC Police Department will identify the event the child should be attending and notify the event leader.

7. Medication Protocol:

Parents/legal guardians are asked to notify the event leader during the registration period of any medications the participant may need during the event. Parents will be asked to sign a medication authorization form detailing the times and/or indications for medication and releasing the College and its personnel from responsibility for the use of all medications.

To prevent medication mishaps, participants must surrender all prescription and over-the-counter medications at the beginning of the event. Controlled substances, such as ADHD medications, should be counted and recorded in a Medication Log at the time of drop-off and at pick-up to provide accountability. All medications and the Medication Log must be stored in a secure location, such as a locked cabinet or small security safe (preferred), that is accessible only by an event leader.

The ONLY exception is that participants should keep emergency medications such as EpiPens® or inhalers on their person at all times, with notification to event workers about the existence and location of these medications. Participants should be able to self-administer any such emergency medication(s). All medications must be returned to the parent or participant at the end of each day (end of the program for residential activities).

Medications must be in the originally labeled container. Medication(s) will be placed in a sealable plastic bag (Ziploc® or similar bag) with the participant’s name, event name, and time(s) of required administration. Event workers should not provide medication “as needed” as they are not trained to recognize those needs. It is the participant’s responsibility to request medication(s) at the appropriate time(s). At the designated time, the event worker will provide the bag to the participant to allow the participant to take the proper medication. At no time will event workers handle the actual medication directly; nor will any event worker provide guidance on how or what medications to take. If the participant is unsure of the medication to take or the correct dosage, the parents will be contacted for clarification.

Each time medication is provided to a participant, the event worker must record it in the Medication Log. The Medication Log becomes part of the participant’s registration information and must be maintained for the legally required retention period.

8. Record Retention Requirements:

The Vice President for Institutional Advancement or designee is responsible for record retention for activities covered under this policy. Child and Youth Participant Records must be kept for 3 years after the participant reaches the age of 18. These are records that document the participation of children and youth in programs sponsored by the institution. Not all records associated with a youth program must be kept until the participant reaches the age of 18 + 3. Other records should be kept in accordance with the retention schedule for that document. The retention schedule for all USG records can be accessed from the below link: http://www.usg.edu/records_management/schedules/

9. Violations:

Any East Georgia State College employee found responsible for violating this policy may be subject to disciplinary action up to and including the possibility of dismissal.  Violations of state and federal statutes may be subject to criminal penalties or fines.

10. Review Schedule:

The Programs Serving Non-Student Minors on Campus Policy will be reviewed annually by the Vice President for Institutional Advancement or designee, Director of Human Resources, and EGSC Legal Counsel in coordination with the President’s Cabinet.