This handbook provides information and guidance to Emerson College faculty, employees, volunteers, and students who will supervise and interact with Minors who are guests of Emerson College and/or involved in our programs, whether they are programs hosted and sponsored by one of our College units or departments and whether they are held at Emerson College, housed in College facilities, and/or held offsite at other non-College locations.
Emerson College faculty, employees, volunteers, students, and non-college groups sponsored by an Emerson College unit or department, who are supervising and/or interacting with Minors, are expected to comply with the Policy on Minors in College Programs.
The Policy does not apply to registered Emerson College students who are Minors.
Required Process Steps
Program Administrator must register the program or activity at least 60 days prior to the program
Program Administrator must review the Background Check process and take the required steps
Program Administrator must read the Best Practices Handbook
Key Personnel and Authorized Adults must:
- Complete their portion of the background check process
- Read the Policy and Code of Conduct.
- Submit the Policy and Code of Conduct Acknowledgment Form
- Complete the online training course
Reporting Suspected Child Abuse or Neglect - Mandated Reporters
- Visit www.mass.gov/dcf for more information about Mandated Reporting in Massachusetts
- Visit http://www.mandatedreporterca.com/ for more information about Mandated Reporting in California
At Emerson College, all employees, including faculty and student employees, are Mandated Reporters. Reports must be made immediately to the Emerson College Police Department, as further outlined below.
State regulations require a Mandated Reporter to report suspected child abuse when the Mandated Reporter has “reasonable cause to believe” that a Minor is being or has been abused in some way. State regulations do not require the Mandated Reporter to provide conclusive proof that abuse occurred. Educators and other school personnel are neither expected to be nor should they act as, investigators. The benefit of the doubt is always given to the Minor. Waiting for conclusive proof may put a Minor at risk.
Failure to make a report can result in criminal penalties. Failure to make a report may also subject an Emerson employee to discipline up to and including termination of employment. Filing a mandated oral and written report in good faith protects the Mandated Reporter from civil and criminal action even if the report is deemed unfounded after investigation.
Massachusetts law allows Mandated Reporters who are members of public or private educational institutions to notify a “Designated Agent” at the institution who then becomes responsible for notifying the appropriate governing agency. Emerson College has designated all Officers of the Emerson College Police Department as our Designated Agent(s), and
Mandated Reporters should report suspected Child Abuse and Neglect immediately to the Emerson College Police Department Emergency Line 617-824-8888. The College will not retaliate or discriminate against any person who, in good faith, suspects and submits a report of Child Abuse or Neglect.
Recommended Orientation or Training
In addition to the online training for Authorized Adults and Key Personnel, the Office of Risk Management recommends that all Programs consider training about the following Emerson College administrative units:
- Emerson College Police Department – Campus Safety, Evacuation, Campus Access
- Department of Student Life – Housing Requirements and Protocol
- IT Help Desk – IT Security
- Title IX – Awareness Training
- Advocacy and Care
All Key Personnel and Authorized Adults should be:
- knowledgeable about how to request emergency services (e.g., injured Minor)
- how to report suspected child abuse
- aware of emergency locations in anticipation of weather-related events and general emergency procedures
- advised that if an allegation of inappropriate conduct has been made against an Authorized Adult participating in a program, they shall discontinue any further participation in the programs until such allegation has been satisfactorily investigated and resolved. The conduct shall be reported to the Office of Human Resources and/or, if the conduct is of a criminal nature, it will be reported to Emerson College Police Department.
Adequate Supervision of Minors
Some of the factors to consider in determining "adequate supervision" are the number and age of participants, the activity or activities involved, type of housing, if applicable, and age and experience of the counselors.
- All program activities, including housing, must be supervised by at least two (2) or more Authorized Adults, or by their parent(s) or legal guardian(s), at all times.
- Minimum requirements for resident programs are:
- One Authorized Adult for every 8 Minors ages 9 to 14;
- One Authorized Adult for every 10 Minors ages 15 to 17.
- Minimum requirements for day programs are:
- One Authorized Adult for every 10 Minors ages 9 to 14;
- One Authorized Adult for every 12 Minors ages 15 to 17.
- For restroom breaks, Authorized Adults should use discretion based upon the activity location. For example, if restrooms are not conveniently located nearby, the Authorized Adult should not allow one Minor to leave to use the restroom. It is suggested that a Minor be paired with another Minor (preferably identifying as the same gender if disclosed or known). An Authorized Adult may also escort one or more Minors to a restroom, but should wait outside the restroom area.
Depending on the age of Minors participating in the Program, a “buddy” system could be used when Minors take restroom breaks.
Programs should ensure that appropriate spaces and facilities are used.
All supervised Minors in a college-sponsored program, or a non-college sponsored program taking place on College property, are permitted in the general use facilities (e.g. athletic fields, public spaces, academic buildings) but may be restricted from certain areas of the facilities (e.g. storage rooms, equipment rooms, athletic training rooms, staff/faculty offices) or from utilizing certain equipment.
Minors and Authorized Adults must abide by all program regulations and may be removed from the program for non-compliance with rules.
Programs should also include a statement regarding peer-on-peer interaction standards. The following activities should be addressed in the program rules:
- The possession or use of alcohol and/or other drugs, tobacco, fireworks, guns, and other weapons is prohibited.
- The operation of a motor vehicle by Minors is prohibited during all program activities.
- No violence, including sexual abuse or harassment, will be tolerated.
- Hazing of any kind is prohibited. Bullying, including verbal, physical, and cyberbullying, is prohibited.
- No theft or vandalism of property, regardless of the owner, will be tolerated.
- Misuse or damage to Emerson College property is prohibited. Charges will be filed against those persons who are responsible for damage and/or misuse of college property.
- The use of cameras, imaging, and digital devices by Authorized Adults and/or Minors is prohibited in showers, restrooms, or other areas where privacy is expected.
Rules and procedures governing when, and under what circumstances, Minors may leave college property during the program.
Authorized Adults should be clear on the pickup procedure of Minors. Minors are to be released only to the parent(s), or legal guardian(s) or other authorized people listed on the Release Form.
The program should also have a designated drop-off and pick up schedule and location. If the Minor is not retrieved at the appropriate time, the program must have a procedure in place to ensure that said Minor is not left alone or with a non-Authorized Adult until picked up by an appropriate parent, legal guardian, or other authorized people.
Be sure that the program addresses how unsupervised activities and unstructured time will be handled. All unsupervised activities and any unstructured times should be well vetted and age-appropriate. This information should be made available to parents.
Code of Conduct
In accordance with the Policy, outlined below is Emerson College’s Code of Conduct relating to all programs involving Minors. All staff, faculty, volunteers, and student representatives working in programs involving Minors will:
- Understand and comply with the mandatory regulations and Emerson College’s policies and best practices relating to programs involving Minors;
- Commit to report suspected child abuse or neglect;
- Cooperate fully in any investigation of such;
- Use positive reinforcement rather than criticism, competition, or comparison when working with Minors;
- Treat all participants with respect, loyalty, patience, courtesy, dignity, and fairness;
- Maintain appropriate boundaries at all times, both physical and verbal;
- Never be alone with Minors at College activities without another adult being present;
- Never be the only adult in a restroom, shower room, locker room, or other dressing or housing area whenever Minors are using such facilities;
- If monitoring an area or dealing with an emergency or discipline of a Minor, ensure you are in an observable area (not an enclosed, private room) and ensure doors are ajar so that you can signal to another adult for assistance;
- Adhere to standards where safety is the priority and no physical or emotional abuse is tolerated, including but not limited to, profanity, striking, spanking, slapping, humiliating, ridiculing, threatening, or degrading behaviors;
- Limit the use of electronic media or devices to activities involving Emerson College business only;
- Do not exchange personal social media account information with Minors;
- If permission has been granted for photography, only photograph yourself with Minors in a way that reflects and is used for educational purposes;
- Do not be alone in a vehicle with a Minor and do not use a personal vehicle for transporting Minors;
- Do not use, be under the influence, or in possession of tobacco products, alcohol, or illegal drugs at any time during programs involving Minors.
Third-Party and Vendor Arrangements
Emerson College’s Business Services Department coordinates all third-party arrangements.
Sponsoring Dean, Department Heads, or Program Administrators should contact Business Services to confirm all necessary third-party arrangements.
Non-college groups must:
- When college property is leased/rented a Facilities Usage Agreement must be executed when planning to use a college facility for a sponsored program.
- Seven days prior to the program’s start date, the sponsoring unit must provide the Business Office with a fully executed copy of the -- Facilities Usage Agreement.
The third-party usage agreement will ensure that third parties understand they are to:
- Have the primary responsibility for oversight of Minors;
- Have parental or guardian waivers and/or releases for all Minors;
- Adhere to the college’s Minors on campus policy (report obligations, background checks, and training).
These program operations are not required for all programs and they are coordinated and carried out at the discretion of the responsible department or department head and the Program Administrator.
A complete list of all Minors, including name, sex, age, parent, or legal guardian’s name and/or emergency contact name, and contact information, should be prepared. This document must be completed and maintained by the Program Administrator prior to the start of the program.
The Program Administrator must also maintain a directory of all Authorized Adults who will be interacting with the Minors during the program.
In the event of an emergency, a notification procedure should be established. Examples of events that could occur include: a Minor’s medical emergency; a Minor’s behavioral problems; emergency evacuation or natural disasters; or other significant program disruption. An Emergency Plan should be in place, which will include information on how the Minor’s parent or legal guardian can be contacted.
Program Administrators should ensure the program brochure or other information provided to parents and guardians includes information regarding Emerson College policies.
Medications for Minors should be managed as follows:
- Program staff shall never administer any medications to Minors.
- The designated adult shall allow the Minor(s) to self-administer the appropriate dose as shown on the container with the appropriate parental permission.
- Personal “epi” pens and inhalers may be carried by the Minor(s) during activities.
- Any medicine that the Minor(s) cannot self-administer will be administered by the Center for Health and Wellness
Program Administrators will obtain all releases that are required for a program as part of the Program’s process. All data gathered shall be confidential, subject to records retention guidelines, and shall not be disclosed, except as provided by law. Examples of standard releases:
- Medical information
- Food allergies
- Emergency contact information
- Media/press release authorization
- If a contracted transportation service (i.e., bus) is used by the program, an Authorized Adult must remain on the bus until the last Minor exits the vehicle(s).
- Emerson College strongly discourages the use of personal vehicles of Authorized Adults to transport Minors.
- Authorized Adults must not be alone in a vehicle with a Minor.
If applicable, rules and regulations for proper supervision of Minors while in Emerson College housing will be implemented. The following should be included:
- The Release Form must indicate the Minor will be staying in college housing.
- The program will establish and enforce a curfew time that is age-appropriate for the Minors, but in no case shall it be later than midnight.
- The program will monitor in-room visitation between Minors which will occur only with the door to the room open.
- The program will ensure that guests of Minors (other than a parent or legal guardian and other program Minors) are restricted to visitation in the building lobby and/or floor lounges, and only during approved hours specified by the program.
- The program must comply with all security measures and procedures specified by the Office of Housing and Residence Life.
- The Program Administrator must ensure a “head” Authorized Adult and a second Authorized Adult will be “on-call” and must be present in the building at all times to ensure Minors are secure in the rooms. The Authorized Adult will have all contact numbers for Minors and will not leave the premises once Minors are secure in their rooms. Any emergency involving a Minor will be reported immediately to the Program Administrator.
- If there are 10 or more Minors being housed (on- or off-campus), the program will ensure there will be two Authorized Adults present at all times.
- Complete the overnight Program-Emergency Plan & Worksheet.
- The program will ensure it has a bathroom plan and/or schedule in place for Authorized Adults and Minors. This would also apply to off-campus activities.
If a program will be housing Minors in an off-campus housing facility (e.g. hotel, motel, off-property residence hall, rental house), the Program Administrator must contact the Risk Management Office for additional housing procedures.
If requested by the program, the Office of Risk Management will conduct a walk-through of the program location(s) prior to the start of the program. Contact the Office of Risk Management at least seven (7) days prior to the start of the program for this service.