Protection of Minors on Campus

I. Purpose

Kenyon College is committed to the safety of all individuals in its community. This Policy establishes guidelines for those in the College community who may work or interact with individuals under 18 years of age, with the goal of promoting the safety and well-being of minors. This Policy is applicable to College affiliated programs operating on the Kenyon College Campus. Non-College affiliated program requirement will be outlined in a facility use agreement (contract) with each respective program.

II. Scope

College Affiliated Programs: College affiliated programs or activities include those programs and activities sponsored and approved for operation by the College. Generally, such programs have contracts with the College permitting use of campus facilities for a small or nominal fee, and the directors responsible for operating such programs or activities are employed by Kenyon in such capacity. This Policy provides guidelines that apply to interactions between minors and College students, faculty, staff and volunteers in College affiliated programs or activities.

All Kenyon College students, faculty and staff are responsible for understanding and complying with this Policy. Appendices to this Policy set forth specific requirements and the policy and related procedures and may be revised and/or updated from time to time.

III. Definitions

Abuse of minors for purposes of this Policy means physical, emotional or mental injury or death, inflicted other than by accidental means, the creation of a substantial risk to the health or safety by negligent treatment or maltreatment, or sexual abuse or exploitation of a person under age 18.

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 act to meet basic requirements for health and safety of, or to prevent the infliction of abuse upon, a person under age 18.

Campus for purposes of this policy means all buildings, facilities and properties that are owned, operated, managed or controlled by the College.

IV. Guidelines and Responsibilities

When participating in College affiliated programs and activities, all program-affiliated students, faculty and staff must:

Be vigilant in protecting the well-being and safety of minors with whom they interact on campus or elsewhere.
Review the informational material about the signs of abuse and neglect of minors in Appendix A.
Watch for signs of minor abuse or neglect and promptly report suspected instances of abuse or neglect, or violations of this policy or law, as provided in Section VII and Section VIII.
Ensure that the program or activity provides appropriate supervision for minors at all times. Supervision is to be provided by program-affiliated students, faculty and/or staff, and appropriate supervision includes compliance with the guidelines established by the American Camp Association.
Before engaging in any College affiliated program or activity involving contact with minors:
- meet the requirements of this Policy relating to training (Section V) and criminal background checks (Section VI and Appendix C);
- meet any additional requirements that relate to the specific program or activity.

College faculty and staff on campus who only interact with Kenyon College undergraduate students under the age of 18 in classes or other traditional academic settings are not required to undergo the training or background checks required by this Policy. Anyone covered by this Policy who knows or suspects that an undergraduate student under the age of 18 has been abused or neglected must, however, make reports as required by Section VII and Section VIII.

To the extent College faculty, staff or students are participating in programs or activities run by a non-College affiliated program or activity off campus, they should familiarize themselves with, and follow the policies of, the organization relating to interactions with minors and understand their legal obligations with respect to working with minors in the program setting.

V. Training for Those Participating in Programs and Activities

College students, faculty and staff who participate in College affiliated programs or activities involving minors must complete appropriate training. At a minimum, training must include:

Basic warning signs of abuse or neglect of minors.
Guidelines for protecting minors from mental, emotional, physical and sexual abuse and neglect.
Requirements and procedures for reporting incidents of suspected abuse or neglect or improper conduct.

Training may be expanded depending upon the program or activity and the person’s role in the program or activity.

VI. Criminal Background Checks

Age of Minor	Staff-to-Minor Ratio	Staff-to-Minor Ratio
	Overnight Program/Activity	Daytime Program/Activity
5 or younger	1:5	1:6
6-8 years	1:6	1:8
9-14 years	1:8	1:10
15-18 years	1:10	1:12

Certain categories of individuals will be required to clear a criminal background check prior to participation in College affiliated programs and activities involving minors. The categories of individuals who must undergo background checks are listed in Appendix C.

If a criminal background check reveals adverse information or unfavorable results, the College will conduct an individualized assessment using criteria designed to identify potential risk to minors. A prior conviction shall not automatically disqualify a person from participating in a program or activity. Except where required by law, criminal background checks of College faculty, staff and students that are conducted pursuant to this Policy will be used only for purposes consistent with this Policy and will otherwise be kept confidential. Records of background checks will be maintained separately from an individual’s personnel or student file.

Specific requirements and procedures for background checks appear in Appendix C.

VII. Reporting Potential Harm to Minors

1. Emergencies

In case of an emergency, one should immediately call Kenyon’s Campus Safety office at 740-427-5555 or the Knox County Sheriff at 911.

2. Reports of Known or Suspected Abuse or Neglect of Minors

ANY person participating in a College affiliated program or activity operating on the Kenyon College campus involving minors, who knows, suspects, or receives information indicating that a minor has been abused or neglected, MUST notify the Knox County Sheriff at 740-397-3333 and/or the Knox County Department of Jobs and Family Services, Children and Family Services Division 24-hour abuse hotline at 740-392- 5437 (KIDS).

3. Additional Information

Additionally, ANY reporter of known or suspected abuse or neglect of a minor shall inform the Office of Campus Safety, as well as the College’s Civil Rights/Title IX Coordinator, of their concern.

Campus Safety may be reached by calling 740-427-5000
The College’s Civil Rights/Title IX Coordinator may be reached at 740-427-5820.

Campus Safety with support from other appropriate offices as necessary will help determine appropriate next steps. In addition, program supervisors should be promptly notified once it is safe and appropriate to do so.

VIII. Addressing Reports of Abuse or Neglect

A. Upon receipt of a report of alleged abuse or neglect of a minor in a College affiliated program or activity, the College’s Civil Rights/Title IX Coordinator (or designee), shall:

Take immediate steps to prevent further harm to the alleged victim or other minors, including, where appropriate, removing the alleged abuser from the program or activity or limiting his or her contact with minors pending resolution of the matter.
Determine whether the Knox County Sheriff, Knox County Department of Jobs and Family Services, Children and Family Services Division, or both have already been notified and, if not, whether such notification is required or appropriate given the circumstances.
If the parents or guardians of the alleged victim have not been notified and are not the alleged abusers, notify the parents or guardians of the minor involved.
Investigate the report and resolve the matter in a way that safeguards the minor, protects the interests of victims and reporters, affords fundamental fairness to the accused, and meets applicable legal requirements.
Facilitate the College’s cooperation with any investigation conducted by the Knox County Sheriff, Knox County Department of Jobs and Family Services, Children and Family Services Division, or other governmental agency.

B. Whenever a report alleges that someone involved in an activity on campus who is not a member of the College faculty, staff, or student body has abused or neglected a minor, the person receiving the report shall immediately notify the College’s Civil Rights/Title IX Coordinator, even if they believe the Coordinator has already been notified. The College’s Civil Rights/Title IX Coordinator shall coordinate with the non-College affiliated organization or entity as necessary to see that the requirements of Part A. 1-5 of this Section are accomplished.

C. Upon being notified of a sexual misconduct or abuse incident involving a minor, the College’s Civil Rights/Title IX Coordinator shall notify the Kenyon College Risk Manager who will in turn notify the commercial general liability insurance company of the incident.

IX. Accidents, Incidents and Insurance

Any program or activity operating on the Kenyon College campus involving minors shall be required to provide the College with prompt and timely written notice of any incident and/or accident of which it has knowledge that in any way, directly or indirectly, contingently or otherwise, occurs at its program or activity on campus

X. Nondiscrimination

Any program or activity operating on the Kenyon College campus involving minors shall be required to review and train its personnel and agents on the College’s anti-discrimination policy. The College does not discriminate in its educational programs and activities on the basis of race, color, national origin, ancestry, sex, gender, gender identity, gender expression, sexual orientation, physical and/or mental disability, age, religion, medical condition, genetic information, veteran status, marital status, or any other characteristic protected by institutional policy or state, local, or federal law. Any College affiliated program or activity shall be non-discriminatory in hiring staff and/ or in enrolling/admitting minor attendees and shall comply with all applicable federal, state, and local laws and ordinances.

Any requests for accommodation received by any program or activity operating on the Kenyon College campus involving minors should be coordinated with College’s Manager of Summer Programming in consultation with other College offices, including Student Accessibility and Support Services (SASS), as appropriate.

XI. Enforcement

Sanctions for violations of this Policy will depend on the circumstances and the nature of the violation, but may include the full range of available College sanctions applicable to the individual including suspension, dismissal, termination, and, where appropriate, exclusion from campus. The College may also take necessary interim actions before determining whether a violation has occurred.

XII. Policy Implementation and Modification

Questions about the interpretation or application of this Policy should be raised with the College’s Manager of Summer Programs who will consult with other College offices as appropriate, shall update or modify the Appendices to the Policy as necessary and administer, and oversee the implementation of the Policy in a manner that best achieves its goals. This Policy may be modified as necessary.

Appendix A

Child Abuse and Neglect Reference for Educators

The Ohio Department of Job and Family Services has created a reference for educators about child abuse and neglect. Download the document as a PDF.

Appendix B

Training Requirements for Those Involved with Minors

The following groups of persons are required to complete the training requirements delineated herein, as well as to certify completion of the same:

Kenyon Faculty, staff and students who are involved in College-affiliated programs or activities involving minors, and

College-Affiliated Programs of Activities: All individuals working with minors in College-affiliated programs or activities are required to review "Working with Minors: Information for Those Participating in College-Affiliated Programs Involving Minors" ("Working with Minors Guidelines") and sign the certification at the end of this document (PDF). In addition, individuals who are required to review the Working with Minor Guidelines are to submit the signed certification to the program or activity director or supervisor at least seven (7) days prior to the start date of any program or activity. The program or activity director or supervisor is responsible for collecting the certifications from the adult participants and promptly forwarding them to the College's representative overseeing the program or activity.

Appendix C

Criminal Background Checks for Those Interacting with Minors

The following categories of adults involved in a College Affiliated program or activity are required to undergo a criminal background check prior to their participation in College activities or programs involving minors:

Directors and supervisors of programs involving minors, including those who are responsible for supervising those who interact with minors;
Those who stay overnight with minors as part of their job responsibilities in a program or activity involving minors; and
Those who regularly spend time with minors as part of their job responsibilities or role in a program involving minors.

The Human Resource office will oversee the processing of criminal background checks for all affiliated program and activities involving minors. The cost of the background check will be borne by program or activity involving minors on campus.

Background checks shall consist of a social security number trace and address locator for seven years, a search of federal and state or county databases for criminal history for the past seven years, and a national sex offender registry check.

If a background check reveals adverse information or unfavorable results, an individualized assessment will be conducted. Consideration for staff will be given to the relationship between a conviction and the responsibilities of the position that is or will be held. A relevant job-related conviction may be grounds for termination of employment or non-selection of an applicant. The Office of the Provost will make determinations in cases where criminal background checks for faculty reveal adverse information that is relevant to one’s participation in a College affiliated program or activity covered by this Policy.

For College affiliated programs or activities, only a background check conducted by Kenyon College or an external source approved by Kenyon College will be accepted for purposes of this Policy.

Any faculty, staff, or student who is required by this Policy to have a background check is under a continuing obligation, for the duration of participation in programs or activities involving minors, to disclose immediately any new felony or misdemeanor conviction to the Human Resource office. Faculty or staff members who have a break in service of more than twelve (12) months (approved leaves of absence are not-subject to this renewal requirement), and students who withdraw are suspended or dismissed or who take leaves of absence of more than twelve (12) months, will be required to undergo a new background check upon returning to participation in College affiliated programs or activities involving minors.

Except where required by law, criminal background checks of College faculty, staff, and students will be used only for purposes consistent with this Policy and will otherwise be kept confidential. The record of information returned as a result of the background check will be maintained separately from an individual’s personnel or student file.

Working with Minors

Information for Those Participating in College Affiliated Programs or Activities Involving Minors

The Kenyon College community has a strong interest in how our society cares for children and the most vulnerable among us and wants to do what it can to prevent the victimization of child and adolescent minors and promote their safety. To further this goal, these Guidelines contain important information that individuals must review if they are participating in programs or activities involving minors that 1) the College operates; 2) that others operate in College facilities; or 3) that Kenyon students, faculty or staff are involved with in the community.

You are receiving this information because you have been identified as participating in a covered program or activity. You must review the information contained in the College’s Protection of Minors Policy, the rest of the information on this webpage, as well as these Guidelines and return the certification, the last page of this document (PDF), indicating that you have read the Protection of Minors Policy and these Guidelines and agree to comply with the requirements they describe.

You may also be required to review additional materials that are relevant to your specific situation. This informational packet is available online at [enter web address] and contains the following:

The College’s Protection of Minors Policy and accompanying Guidelines for working with minors that will help you to maintain safe and positive interactions and reduce the risk of mistaken allegations;
Steps to take if you suspect that a minor has been abused or neglected or is otherwise unsafe, including information about how to report your suspicions or ask questions;
Advice on the signs of child abuse and neglect from the Ohio Dept. of Job and Family Services (Appendix A); and
A Certification form that you must sign to certify that you have read and understood the information and will comply with your obligations under the Protection of Minors on Campus Policy and its related appendices.

Visits to the College by minors, including stays in College-owned student housing by candidates for admission, prospective student athletes on unofficial visits, siblings of enrolled students, and other minor guests are generally not considered College -affiliated programs or activities for purposes of the Protection of Minors Policy. The Student Affairs Guest Policy governs the hosting of minor guests in College-owned student housing.

This information describes requirements applicable to Kenyon undergraduate students, including those under the age of 18, who participate in programs involving minors.

Guidelines for Working with Minors

Those associated with programs or activities involving minors should observe the following "dos" and "don'ts" in order to maintain a safe and positive experience for program participants, encourage parental confidence, and avoid mistaken allegations.

DO:

Maintain the highest standards of personal and professional behavior at all times when interacting with minors, realizing one’s actions reflect on the program or activity.
Maintain professional boundaries with minors at all times and serve as a role model in your behavior.
Whenever possible, try to have another adult present when you are working with minors in an unsupervised setting. Conduct necessary one-on-one interactions with minors in a public environment where you can be observed.
Listen to and interact with minors and provide appropriate praise and positive reinforcement.
Treat all minors in a group consistently and fairly, and with respect and dignity.
Be friendly with minors within the context of the formal program or activity while maintaining appropriate boundaries.
Maintain discipline and discourage inappropriate behavior by minors, consulting with your supervisors if you need help.
Be aware of how your actions and intentions might be perceived and could be misinterpreted.
Encourage the use of positive and supportive language while discouraging the use of insulting, demeaning, or ridiculing language.
Consult with other adult supervisors or colleagues when you feel uncertain about a situation.

DON'T:

Don’t spend significant time alone with one minor away from the group or conduct private interactions with minors in enclosed spaces or behind closed doors.
Don’t engage in any sexual abuse, inappropriate touching, or have any physical contact with a minor in private locations.
Don’t disparage peers or other program personnel, use inappropriate language, tell risqué jokes, or make sexually suggestive comments around minors, even if minors themselves are doing so.
Don’t give personal gifts to, or do special favors for, a minor or do things that may be seen as favoring one minor over others.
Don’t share information with minors about your private life or have informal or purely social contact with minor program participants outside of program activities.
Don’t strike or hit, commit an act of cruelty against, endanger, or use corporal punishment or other extreme punishment involving physical pain or discomfort.
Don’t relate to minors as if they are peers, conduct private correspondence or take on the role of "confidant" (outside of a professional counseling relationship).
Don’t date or become romantically or sexually involved with a minor. Don’t show pornography to minors or involve minors in pornographic activities.
Don’t use technology, email, text, to engage with minors through social networking media unless there is a legitimate educational or programmatic reason to do so.
Don’t provide alcohol or drugs to minors or use them in the presence of minors.

Reporting: What to do if you suspect that a minor has been abused or neglected or is otherwise unsafe.

If you know, suspect, or receive information indicating that a minor has been abused or neglected, or if you have other concerns about a situation involving the safety of minors, follow the procedures described below

Emergencies
In case of an emergency, immediately call Kenyon’s Office of Campus Safety at 740-427-5555, or the Knox County Sheriff at 911.

Reports of Known or Suspected Abuse or Neglect of Minors

Anyone who has concerns about the safety of minors, should notify the Knox County Sheriff at 740-397-3333 and/or the Knox County Department of Jobs and Family Services, Children and Family Services Division 24-hour abuse hotline at 740-392- 5437 (KIDS).
Reports of Known or Suspected Abuse or Neglect of Minors: ANY person participating in a College-affiliated program or activity or a non-College affiliated program or activity operating on the Kenyon College campus involving minors, who knows, suspects, or receives information indicating that a minor has been abused or neglected, MUST notify the Knox County Sheriff at 740-397-3333 and/or the Knox County Department of Jobs and Family Services, Children and Family Services Division 24-hour abuse hotline at 740-392-5437 (KIDS).
Additionally, ANY reporter of known or suspected abuse or neglect of a minor shall inform the Director of Campus Safety, as well as the College’s Civil Rights/Title IX Coordinator, of the concern.

• Campus Safety may be reached by calling 740-427-5000
• The College’s Civil Rights/Title IX Coordinator may be reached at 740-427-5820.

Campus Safety, with support from other appropriate offices as necessary, will help determine appropriate next steps. In addition, supervisors should be promptly notified of concerns once it is safe and appropriate to do so.