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Policy on Programs for Minors

A Central Registry for Programs for Minors has been established within the Office of Counsel/Risk Management (“Central Registry/Risk Management”). This Central Registry is where Programs for Minors should be registered, and it will also serve as a resource for information and forms related to these programs. If you have a question concerning the new Programs for Minors Policy, please first consult the policy and then check to see if the answer is provided in the answers to Frequently Asked Questions, below. If you still have a question related to a Program for Minors, please next direct the question to the designated Program Administrator or Program Sponsor within your school, division or department.

If you have a question that can’t be answered by either of these methods, please contact the Central Registry/Risk Management at 758-7600, or email Kristin McCann (kristin.mccann@rochester.edu) or Deirdre Flynn (deirdre.flynn@rochester.edu) with your question.

Complete registration

Frequently asked questions

Why was it necessary to create the Policy on Minimum Standards for Programs for Minors and Children?

Many schools and divisions of the University offer programs for minors and children, and the approaches to managing the related risks have been similarly diverse. The Policy balances the need for a uniform set of program requirements to protect minors under our care with the flexibility for schools and divisions to implement these requirements in a way that suits the particular needs of each program.

Does the Policy apply to every encounter with a child or minor on campus?

No. For example, the Policy does not apply to University events events that are open to people of all age groups in which children may be present such as fairs or festivals, or University events at which children will be accompanied at all times by a parent or legal guardian. Generally, the Policy applies to organized programs where the University is taking custody and control of minors as part of the program.

If I am a Dean or a Division Head, what do I need to do to be in compliance with this Policy?

By July 15, 2013, you must designate one or more program administrators who will be responsible for any Programs for Minors that currently exist within your school or division, and/or any Program that is expected to be offered during the 2013-14 academic year. If your school or division does not currently have any Programs for Minors and you do not anticipate offering such a program during the academic year, identifying one or more responsible program administrators at this time is optional. However, if you elect to defer naming an administrator, you as the Dean or Division Head are responsible for remembering to designate and identify an administrator later, in the event your school or division adds a Program for Minors. You may provide the name(s) of designated administrators by email to Kristin McCann or Deirdre Flynn.

If I have been designated as a responsible program administrator, what do I need to do to be in compliance with this Policy?

Program administrators should be prepared to meet the requirements of the policy beginning no later than September 1. The first step should be to determine whether your school or division is currently running any Programs for Minors and children covered by this Policy. If not, report to the Central Registry/ Risk Management that there are currently no covered programs within your school or division. If there are covered programs, proceed to the next steps.
For each covered program currently operating within your school or division, and any expected to be offered during the 2013-14 academic year, you must by September 1:

  • Register the program with the Central Registry/Risk Management;
  • Make arrangements to have background checks conducted on the employees who will work with minors as part of the program, as described in the Policy;
  • Develop a plan for supervision of minors consistent with the Policy; and
  • Train employees on the Policy and the plan.
How do I centrally register the program(s) I am responsible for?

Register all covered programs with the Central Registry/Risk Management through this registration form.

Which employees need to have a background check conducted, how often does the background check need to be repeated, and how do I arrange the background check?

All adult employees who will have direct, regular and frequent contact with minors as a part of performing their University jobs or assigned roles in connection with a Program for Minors are required to have a background check that has been done within the last three years on record with the University at the time of hire and/or prior to beginning work with minors. (See Policy § 5). An approved vendor should be used to conduct the background check. For a list of approved vendors contact your HR business representative.

Who will provide the training, and what needs to be included in the training that employees working in these programs receive?

Each school or division offering a Program for Minors is responsible for training its employees covered by the Policy, and is permitted the flexibility to design a method for training best suiting its needs. Employees working with minors as part of a Program for Minors must be made familiar with the requirements outlined in the Policy. For example, covered employees should be familiar with the requirements for appropriate supervision of minors, and the appropriate behavioral boundaries that must be observed, as outlined in the Policy.

Will any additional training materials be provided?

Pilot testing of the Policy and its new requirements is currently underway and will continue over the summer. If any helpful materials are developed during the pilot program testing will be disseminated to program administrators. However, schools and divisions wishing to offer these programs should get started on developing their own training programs based on the content of the Policy.

Registration form

The Program Sponsor is the employee of the School or Division who has been assigned responsibility for oversight of the Program by the Program Administrator (who will usually be the Dean of the responsible school, or another high level administrator within the School or Division sponsoring the program). The Program Sponsor should also be the person completing this Registration Form.

In my capacity as the responsible Program Sponsor I hereby confirm that:

  1. All minors who will be participating in the Program will be registered and written permission from a parent or guardian allowing the minor to participate will be on file prior to the minor being allowed to participate;
  2. All information required by the University Policy on Programs for Minors and any additional information required by this specific Program will be obtained and will be on file before each minor is allowed to participate;
  3. The parent or legal guardian of each participating minor will be provided with information explaining how to contact the participant, the Program Sponsor and Security during the Program;
  4. There is or will be prior to the start of the Program a procedure approved by the Program Administrator for notifying parents and legal guardians of participants in the event of emergency, and the parent or guardian will receive a description of that procedure, in writing;
  5. All supervision and contact with minors as part of this program will be limited to employees of the University*, who will have undergone background checks and will have been properly trained, as described in the University Policy on Program for Minors, prior to having any contact with minors as part of this Program.


* If the Program will involve any outside vendor or individual who is not an employee of the University different registration requirements will apply; contact Risk Management for details.

For the Program Sponsor:(Required)
I hereby confirm that that I have reviewed and I am familiar with the University’s Policy on Programs for Minors and that the Program being registered meets or exceeds the requirements as stated in the Policy. I also confirm that I have reviewed the plans for the Program with the responsible Program Administrator who approves and supports the plan.

For the Program Administrator:(Required)
I hereby confirm that I have reviewed the plans for this Program for Minors, found it to be in compliance with the University’s Policy on Programs for Minors, and I have approved the creation or continuation of the Program.
A University administrator authorized by the School or Division to evaluate the program and provide such approval.