I. Policy Statement
This Interim Policy on Participation of Minors in WPI Programs is a revision to WPI’s existing Minors on Campus Policy. This interim policy includes necessary revisions to address the substantial increase in online interactions with minors (e.g., Zoom) resulting from the COVID-19 crisis. The sudden increase of online interactions with minors presents “compelling reasons” (as set forth in the Process for Creating and Revising Institutional Administrative Policies) for immediately implementing this interim policy. As provided in the APG process, within six months this policy will undergo the full APG review, community comment and approval process.
This policy applies to all events, activities, or programs on campus, off-campus, or online under the authority or direction of WPI (collectively, “Programs”) in which children under the age of 18 (“Minors”) participate.
With the exception of (i) Minors who are enrolled as full-time students at WPI (to which all other WPI policies apply) and (ii) Minors who are high school students enrolled at Massachusetts Academy of Math and Science (to which all Mass Academy policies apply), this policy applies to all instances in which Minors are on campus, off-campus or online or participating in Programs.
This includes all types of Programs, including without limitation:
- Athletic camps, academic camps, high school recruiting events, and other similar activities;
- Online programs or events run by WPI, as well as those run by others online or on WPI’s behalf; and
- In-person programs or events run by WPI, as well as those run by others on campus or off-campus or on WPI’s behalf.
This policy applies to all members of the WPI community, including without limitation:
- WPI faculty, staff and students; and
- Contractors and vendors working on campus or working for the university off-campus or online.
This policy applies at all times, including without limitation:
- Programs run before, during or after business hours, and overnight; and
- Programs that are for a single instance, over a period of time, or recurring.
All Programs must abide by the following requirements:
1. Register the Program
The person in charge of the Program or a designee of the Program (“Program Director”) must submit a Program Registration Form within sufficient time to meet the requirements of this policy.
2. Execute Appropriate Written Contract(s)
Third-party sponsors must execute a written contract with the university if the Program will make use of any university facilities, including but not limited to athletic, housing or dining facilities, in connection with a covered Program. If you have any questions about, or need assistance with, this requirement please contact the Office of the General Counsel at email@example.com.
3. Conduct Background Checks
The Program Director, whether the Program is sponsored by WPI or a third-party sponsor, must conduct a Criminal Offender Record Information (CORI) criminal background check on all adults, including but not limited to faculty, staff, students, and volunteers, who will have direct and unmonitored contact with Minors during the course of the Program. These criminal background checks will be conducted by an agency selected and approved by Talent & Inclusion If a criminal record history is revealed, the Program Director will refer the application to Talent & Inclusion for evaluation.
A background check must be completed and evaluated prior to an adult beginning work with Minors. The Program Director will be required to conduct annual criminal background checks on returning adults.
4. Provide Training
In recognition of the imperative of protecting Minors, WPI strongly suggests that all adults working with Minors be trained regarding policies and issues relating to interactions with Minors. This training should include:
- WPI policies regarding interactions with Minors;
- Setting up an online Program for Minors, including the appropriate use of Zoom, Canvas, and similar educational programs with Minors (where applicable);
- Use of background checks to screen adults working with Minors;
- Responsibility for modeling respectful behaviors;
- Consequences of conduct violations involving Minors;
- Behavioral signs that Minor victims may exhibit;
- Sexual abuse and sexual harassment;
- Laboratory safety for Minors (where applicable);
- Inappropriate behavior with Minors;
- Other appropriate topics; and
- Reporting requirements and procedures.
5. Establish Behavioral Expectations
Adults should be positive role models for Minors, and act in a caring, honest, respectful and responsible manner that is consistent with the mission and guiding principles of the university. Adults working in Programs covered by this policy must follow these expectations to avoid behaviors that could cause harm or be misinterpreted:
- Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material (or assist in any way to provide access to such material) with Minors in-person or online.
- Do not be alone with a single Minor in-person or online. If one-on-one interaction is required in-person, meet in open, well illuminated spaces or rooms with windows observable by other adults from the Program, unless the one-on-one interaction is expressly authorized by the Program Director, dean, department chair person or is being undertaken by a health care provider. If one-on-one interaction is required online, obtain written authorization from the parent/guardian unless the one-on-one interaction is expressly authorized by the Program Director, dean, department chair person or is being undertaken by a health care provider.
- Do not meet with Minors outside of established times for Program activities. Any exceptions require written parental authorization and must include more than one adult from the Program.
- Do not invite individual Minors to your home. Any exceptions require authorization by the Program Director and written authorization by a parent/guardian.
- Do not engage or allow Minors to engage you in sexual conversations, or related matters, unless required in the role of resident advisors, counselors, or health care providers.
- Do not engage or communicate with Minors through private email, text messages, social networking websites, internet chat rooms, or other forms of social media at any time except and unless there is an educational or programmatic purpose and the content of the communication is consistent with the mission of the Program and the university. Group messages and posts are acceptable for online Programs and must be viewable by all participants and the Program Director.
- Do not touch Minors in a manner that a reasonable person could interpret as inappropriate. Touching should generally only be in the open and in response to the Minor's needs, for a purpose that is consistent with the Program's mission and culture, and/or for a clear educational, developmental, or health related (i.e., treatment of an injury) purpose. Any resistance from the Minor should be respected.
- Do not engage in any abusive conduct of any kind toward, or in the presence of, a Minor, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. If restraint is necessary to protect a Minor or other Minors from harm, all incidents must be documented and disclosed to the Program Director and the Minor's parent/guardian.
- Do not use, possess or be under the influence of, or display any alcohol or illegal drugs while on duty, when responsible for a Minor's welfare, or when interacting with Minors online.
- When transporting Minors in a Program, more than one adult from the Program must be present in the vehicle, except when multiple Minors will be in the vehicle at all times through the transportation. Avoid using personal vehicles if possible.
- Possession, use or display of any type of weapon or explosive device is prohibited.
- Do not engage Minors in activities involving hazardous materials (chemical, biological, radiation) or work with mechanical tools at home during an online Program.
- Photographing, videotaping and/or audiotaping minors during an online Program is prohibited. Any exceptions require authorization by the Program Director and written authorization by a parent/guardian.
- Do not permit hazing, harassment, or any type of bullying behavior, including cyberbullying, during the Program.
All adults working with Minors may be required to sign an optional Minors on Campus Behavioral Expectations Acknowledgement Form at the discretion of the Program Director that reviews the behavioral expectations. There is a form for online Programs and a form for in-person Programs.
6. Report Allegation(s) of Inappropriate Behavior
“If you see something, say something”. Every member of the university community (“Member”) has an obligation to report immediately instances or suspected instances of the abuse of or inappropriate interactions with Minors to the WPI Police Department and to the Program Director. This includes information about suspected abuse, neglect, or inadequate care provided by a parent, guardian, or custodian/caretaker. The WPI Police Department can assist in determining whether additional reporting may be required and can assist in making such reporting. WPI will protect the anonymity of the member(s) making the report. Members making a report in good faith will be protected from criminal and civil liability for making the report. Further, it is the policy of the university that no Member making a good faith report of suspected abuse or neglect will be retaliated against in the terms and conditions of employment or educational program.
If you have any question regarding this policy, please contact the Office of the General Counsel at firstname.lastname@example.org.
* * *
Policy Sponsor: David Bunis
Responsible Department: Office of the General Counsel
Effective Date (i.e., date of Presidential Approval): April 14, 2020