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C26.0 Protection of Minors on Campus Policy

  1. Scope

This Policy applies to all departments, units and areas of the university, faculty, staff, volunteers, students, interns, employees of temporary employment agencies, independent contractors/consultants, and Third Parties who work on campus or in connection with any event, program, activity, or project sponsored or offered by the university, including study abroad trips.  These individuals and groups are responsible for understanding and complying with this policy and the any implementing guidance established by the Responsible Office.

This Policy does not apply to (1) single performances or events open to the general public not targeted toward children; or (2) events that may be attended by Minors who are accompanied by their parents/guardians.1

  1. Policy Statement

Rochester Institute of Technology (the “university” or “RIT”) is committed to the safety and protection of Minors while they visit the RIT campus, attend university-offered Programs and events that take place on an off RIT Facilities, or participate in Third Party Programs and activities with a connection to RIT.  Individuals within the scope of this Policy have a duty to report known and suspected violations of this Policy and must follow the requirements of this Policy as well as the implementing guidance established by the Responsible Office.

  1. Rationale

The purpose of this Policy is to take affirmative steps to safeguard and protect Minors from harm while visiting the RIT campus, attending university-offered programs and events, or participating in Third Party Programs and activities with a connection to RIT.

  1. Definitions

    1. "Adult" means an individual age eighteen (18) and older, paid or unpaid, who interacts with, supervises, chaperones, or otherwise comes into contact with Minors as part of a Program.
    2. “Child Abuse” means inflicting or allowing to be inflicted upon a Minor physical injury by other than accidental means that causes or creates a substantial risk of death, serious or protracted disfigurement, protracted impairment of physical or emotional health or protracted loss or impairment of the function of any bodily organ, including abuse that can be characterized as sexual in nature.  Typically, peer-to-peer physical (non-sexual) injury does not trigger the reporting obligations established in the Policy, but requires a case-by-case analysis.
    3. “Child Neglect” means impairment or imminent danger of impairment of a Minor’s physical, mental, or emotional condition as a result of the failure of his or her parent or other person legally responsible for his or her care to exercise a minimum degree of care.
    4. “Employees” means Regular Faculty, Regular Staff and Adjuncts as those terms are defined in RIT’s Employee Work Classification Policy (E01.0).
    5. "Mandated Reporter” means an individual required to report suspected child abuse or neglect to New York State.  The Policy does not alter a Mandated Reporter’s obligations established in New York state law, but rather establishes a policy-based reporting duty for members of the university community.
    6. “Minor” means a person under the age of eighteen (17 years old or younger), including any RIT student who is under 18 years of age, students who are “dually enrolled” in university Programs while also enrolled in primary or secondary schools, or students enrolled in an early college high school affiliated with the university.
    7. “Program” includes, but is not limited to, any program, activity, event, or other opportunity designed primarily to serve Minors that is:
      1. Sponsored by the university, regardless of whether it is held on or off campus;
      2. Sponsored by a Third Party in RIT Facilities; or
      3. Sponsored by a Third Party at an off-campus location in which Adults engage through their university roles.
      4. Examples of Programs include camps, laboratory experience or internship, research activities, clubs, workshops, projects, lessons, team practices, or tours.
    8. “Program Organizer” means the Adult with overall supervisory responsibilities for a Program involving Minors.  The Program Organizer is the Adult who oversees the day-to-day Program operations, which includes interacting with and supervising the Minors involved in the Program.  Examples of Program Organizers include, among others, a camp director, a staff member coordinating a tutoring program, or the faculty advisor of a student group sponsoring a youth-serving activity.
    9. “RIT Community” means any individual authorized to be on the RIT campus including administrators, faculty, staff, students and student organizations, alumni, and external organizations and individuals in their operations with RIT.
    10. “RIT Facilities” means any physical location owned or leased by the university, its subsidiaries or affiliates, wherever located.
    11. “RIT-sponsored Programs” means Programs that RIT operates or sponsors or in which RIT students, faculty, or staff engage through their university roles.
    12. “Sex Discrimination” has the same meaning as set forth in RIT’s Policy Prohibiting Discrimination and Harassment (Policy C.6.0) and the Student Gender-Based and Sexual Misconduct Policy - Title IX (Policy D.19).
    13. “Sexual Harassment” has the same meaning as set forth in RIT’s Policy Prohibiting Discrimination and Harassment (Policy C.6.0) and the Student Gender-Based and Sexual Misconduct Policy - Title IX (Policy D.19).
    14. “Students” means Undergraduate Students, Graduate Students, non-matriculated Students, and students in not-for-credit programs.
    15. “Third Party” means an external organization or individual not affiliated with the university, including but not limited to, contractors, vendors and other service providers with whom the university has an approved contract or other use agreement.  This includes, for example, contracted services for dining services, facilities operations, and the RIT Bookstore operations.
    16. “Volunteers” means individuals who are not RIT faculty, staff or students but provide uncompensated assistance to the university or to RIT faculty, staff or students as part of RIT-sponsored Programs involving Minors and are subject to some or all of the requirements of the Policy depending on their level of contact with Minors as defined by the Policy.
  2. Duty to Report

Any member of the RIT Community who has knowledge of or reasonable suspicion to believe that a Minor has been Abused, Neglected, or Sexually Harassed as part of any Program must immediately report the known or suspected Abuse, Neglect, or Sexual Harassment.  All known or suspected Abuse, Neglect, or Sexual Harassment shall be promptly reported to Public Safety at 585-475-3333 (V/TTY).  Public Safety shall promptly notify law enforcement and/or any governing agency required to receive such reports.

Nothing in this Policy shall prevent any individual from also:

  1. Notifying the Program Organizer if appropriate;  or
  2. Filing an Anonymous Report to (866) 294-9358, (866) 294-9572 (TTY); or https://secure.ethicspoint.com/domain/media/en/gui/11003/index.html
  3. Contacting local law enforcement or the following external reporting agencies:
    1. New York Statewide Central Register of Child Abuse and Maltreatment at 800.342.3720, 800.638.5163 (TDD/TTY) or 800.342.3720 (Video Relay System)
    2. Monroe County Child Protective Services at 585-461-5690

This Policy does not alter any Mandated Reporter’s legal duty to directly report suspected Child Abuse pursuant to New York State law.

  1. Duty to Cooperate with Investigations of Abuse of Minors

All members of the RIT Community shall cooperate with investigations of alleged Abuse, Neglect, or Sexual Harassment of Minors, including government-initiated, law enforcement-initiated, and/or internal RIT investigations.  All members of the RIT Community shall also cooperate with investigations of alleged violations of this Policy and any applicable campus procedures.

  1. Enforcement of Policy; Sanctions for Violations

In addition to any sanction required by local, state, or federal laws or regulations, failure to comply with the provisions of this Policy may result in disciplinary action up to and including termination of employment.  Other sanctions may include dismissal from the university, cancellation of a Program, and/or, issuance of a campus ban, disqualification from participation in future volunteer activities, or the commencement of student conduct proceedings.  Failure to comply by any Third Party may lead to consequences, including but not limited to immediate termination of the university’s contractual or other relationship with the Third Party.  The university may also take necessary interim actions before determining whether a violation has occurred.

  1. Non-Retaliation Protection for Good Faith Reports

Retaliation shall not be tolerated.  Retaliatory acts against anyone acting in good faith who has reported suspected inappropriate conduct in accordance with this Policy, or who has been involved in reporting, investigating, or responding to inappropriate conduct, is a violation of this Policy.  Retaliatory acts may include, but are not limited to:

  • Employment actions affecting salary, promotion, job duties, work schedules, and/or work locations;
  • Actions negatively impacting a student’s academic record or progress; or
  • Any action, including harassment and intimidation, affecting the campus environment.

Any member of the RIT Community who believes they are the subject of retaliation or reprisal for making a good faith report under this Policy may report such allegations of retaliation to Human Resources.  Individuals may also file a report through the anonymous, independently operated Ethics and Compliance Hotline by calling (866) 294-9358 or (866) 294-9572 (TTY), or going online to file the report. See also, RIT’s Whistleblower Policy.

  1. Temporary Measures after Allegations of Inappropriate Conduct

If an allegation of inappropriate conduct has been made against an Adult who is participating in a Program, the allegation will be reviewed pursuant to applicable university procedures and guidelines.  The university may also take necessary interim actions before determining whether a violation has occurred, including removing the Adult or any other individual from any further participation in the Program until such allegation has been resolved to the university’s satisfaction.

  1. Protection of Minors Guidance

This Policy expresses the university’s approach to the protection of minors, but should be implemented in conjunction with the guidance and procedures set forth by the Responsible Office.

  1. Exceptions

Program Organizers and/or faculty and staff hosting such Programs or activities should consult with Human Resources and the Responsible Office for advice and guidance regarding adjustments and exceptions.  Examples when adjustments or exceptions may be appropriate include when Minors are accompanied by their parents, guardians, or school teachers, or activities that are spontaneous, brief, and involve small numbers of Minors.

Responsible Office:

Office of the Vice Provost, University Center for Engaging K-12

Approved:  April 1, 2019 (Interim approval)

Effective:  April 1, 2019

Policy History:

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