Gustavus Adolphus CollegePolicy for the Protection of Minors

Gustavus Adolphus College is committed to the safety of all individuals in its community. The Policy for the Protection of Minors (“the Policy”) establishes guidelines for all faculty, staff, students and volunteers 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. The Policy is applicable to College-affiliated programs. Non-College affiliated program requirements will be outlined in a facility use agreement (contract) with each respective program.

It is the policy of Gustavus Adolphus College that the behavior of all faculty, staff, students and volunteers of our community is expected to align, at all times, with the College’s mission and appropriate documents that guide our community life. Any Gustavus Adolphus College event with minors involved must be pre-approved by the appropriate Vice President. Any faculty, staff, student or volunteer participating in events with minors must complete an online Sexual Abuse Awareness Training. Any individual with potential to have one-on-one contact with minors must successfully pass a background check prior to the event occurring. This Policy does not apply when minors attend an event open to the public, with their parents or guardian, and who are not left in the care of Gustavus Adolphus College employees or students.

College faculty and staff on campus who only interact with Gustavus Adolphus College undergraduate students under the age of 18 in classes or other traditional academic settings are not required to undergo the training or background check required by the Policy. Faculty and staff affiliated with the College 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 this Policy.

Violations of this Policy may, but do not necessarily, implicate the College’s Title IX Policy or its Policy to Prevent Abuse of Minors. Gustavus Adolphus College’s Title IX Coordinator is responsible for determining whether Title IX applies. For more information regarding Gustavus Adolphus College Title IX policies and procedures please see the College’s Title IX Policy.

Faculty, staff, and volunteers affiliated with the College who host an event with minors in attendance must receive approval before hosting minors on campus or participating in a Gustavus Adolphus College event off campus with minors. The approval can be requested by submitting a Request to Host Minors Form. ^{* This does not apply to students who are hosting family members.} Whenever possible, the request should be submitted at least two weeks prior to the event.

1. All employees, students or volunteers participating in the event must complete the online Sexual Abuse Awareness Training prior to the event occurring.
2. Consistent with the College’s Policy to Prevent Abuse of Minors, at a minimum, the following categories of adults involved in a College-affiliated program or activity are required to undergo a background check prior to their participation in College activities or programs involving minors:
   1. Directors, supervisors and faculty members for programs involving minors, including those who are responsible for supervising those who interact with minors;
   2. Those who stay overnight with minors as part of their job responsibilities in a program or activity involving minors; and
   3. Those who regularly spend time with minors as part of their job responsibilities or role in a program involving minors.

   The Dean of Students and/or the Title IX Coordinator can request that a background check be performed on any faculty, staff, student or volunteer involved with a College affiliated program that does not fit in the aforementioned categories.

   The Office of Human Resources will oversee the processing of background checks for all College affiliated programs and activities involving minors. The cost of the background check will be the responsibility of the department hosting the event.

3. The program director/instructor is responsible for collecting the Parent Permission and Registration Form and Child Behavior Agreement for every minor left in Gustavus’s care for their program. If minors are participating as part of a group, such as a school, the Group Guest Policies & Behavioral Expectation Agreement should be completed by the group instead of filling out a form for each child. If minors are attending an event and will be under the care of their parent or guardian, neither form needs to be completed. (The completed forms should be turned in to the Dean of Students Office at least two (2) business days prior to the event).
4. An appropriate number of adult supervisors will be present at each event based upon the activity. At a minimum, the activity should be planned to ensure that there are at least two responsible adults to be present for circumstances such as taking a minor to the restroom or taking a minor aside if they get hurt.

• Consistent with the College’s Policy to Prevent Abuse of Minors, at a minimum, residential camp, conference and event staff must successfully complete an approved background check.
• Residential camp, conference and event staff must fully complete online Sexual Abuse Awareness training.
• Event staff with access to room keys must be in compliance with appropriate laws.
• Residences will be staffed at a ratio recommended by Gustavus Adolphus College. (staff ratio 20:1)
• Posted signs in each residence hall will give clear direction on how to contact staff or Campus Safety if a guest feels unsafe.
• Residence hall bathrooms will be assigned by age when appropriate, as well as gender.
• Campers and guests will be directed and expected to lock rooms at night.
• Residential areas will be off limits to anyone who is not a camper/guest or approved staff.
• Program leaders must include a safety session that specifically covers the protection of minors and reporting procedures during their event orientation meeting.

• All overnight admission guests must adhere to and comply with the College’s behavioral expectations and rules. These shall be provided to prospective students in advance of their visit.
• All overnight admission guests must complete an emergency contact form.
• Guests will be given clear direction on how to contact staff or Campus Safety if they feel unsafe.
• The Dean of Students Office must approve that a student can serve as a residential host, following a check of College records.
• All residential hosts must complete the online Sexual Abuse Awareness training prior to serving as a residential host.

• All College employees or students who are giving lessons, instruction or tutoring to minors on campus must submit the Request to Host Minors Form for approval prior to starting lessons. If the lessons are approved, the Instructor must complete and satisfactorily pass an approved background check and complete the online Sexual Abuse Awareness Training.
• Rooms or studios used for instruction or tutoring must have a window that allows unobstructed views into the space. If no window is available, the door must remain open throughout the session.
• Tutoring should be conducted in a public area such as open library areas. Tutoring, lessons, or private instruction of minors should NEVER be conducted in a residence hall, off-campus home or other area that would be considered inappropriate to host a minor.
• Parents or guardians will not be restricted from attending sessions with their minor children.

The Dean of Students is the primary point of contact for this Policy. The following individuals are responsible for oversight of minors on campus in their applicable areas:

• Associate Vice President of Auxiliary Services: Events involving minors that run through the Summer Programs Office
• Vice President for Enrollment: Admission events and prospective student visits
• Provost of the College: Any academic department event involving minors
• Director of Campus Activities: Any student organization or event involving minors
• Director of Community Engagement: Related programs involving minors
• Church Relations: Related programs involving minors
• Director of Athletics: Any event related to athletics involving minors
• Dean of Students: All other Gustavus Adolphus College events involving minors that are not listed above

• Approving or denying Requests to Host Minors
• Ensuring that online training is complete for all required individuals
• Ensuring any necessary background checks are completed and approved through the Office of Human Resources.
• Retaining all documents.

Faculty, staff, students and volunteers affiliated with the College who are participating in a program or activity that involves minors, who know, suspect, or receive information indicating that a minor has been abused or neglected, are required to make a report.

Any reporter of known or suspected abuse or neglect of a minor must promptly inform the College’s Title IX Coordinator by phone at 507-933-6360 or email at titleix@gustavus.edu. If the minor is in imminent danger contact local law enforcement and then contact the Title IX Coordinator. A written report must also be submitted to Nicollet County within 72 hours of the oral report. The Title IX Coordinator will assist the reporter in this process. For more information on reporting requirements or definitions of physical abuse, sexual abuse or neglect, please see the Minnesota Department of Human Services website

• Take immediate steps to prevent further harm to the alleged victim or other minors.
• Facilitate the College’s cooperation with any investigation conducted by the Nicollet County Sheriff, Nicollet County Department of Human Services, or other governmental agency.
• Determine if the College’s Title IX procedures for fact-finding and decision-making should be invoked. If the College’s Title IX procedures do not apply, the Title IX Coordinator shall determine the steps to investigate the report and resolve the matter in a way that safeguards the minor, protects the interests of victims and reporters and affords fairness to the accused.

If a report identifies/alleges that someone involved in an activity on campus who is not a member of the College faculty, staff, volunteer or student body has abused or neglected a minor, the person receiving the report shall report to the Title IX Coordinator, even if they believe the Coordinator has already been notified. The College’s Title IX Coordinator will coordinate with the reporting party the appropriate reporting structure as outlined above to ensure that all reporting obligations are accomplished.

Upon being notified of a sexual misconduct or abuse incident involving a minor, the College’s Title IX Coordinator shall notify the Gustavus Adolphus College Risk Manager who will in turn notify the liability insurance company of the incident.

Any report of abuse of a minor by any faculty, staff, volunteer or student of the Gustavus Adolphus College community will be investigated by the appropriate College campus authority consistent with the appropriate procedures as may be set forth in in other policies. 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.

Nicollet County Department of Human Services
507-386-4528

Nicollet County Sheriff
507-931-1570

Title IX Coordinator
titleix@gustavus.edu
507-933-6360