Protection of Minors Policy

Criminal Background Checks

All personnel are required to undergo background checks prior to working with minors. Program organizers shall ensure that all personnel working with a minor have undergone criminal records checks within the past two (2) years. Criminal records checks shall include, at a minimum, an electronic background check that reviews county, state, and federal criminal records searches, the national criminal supplemental database search, an expanded national criminal supplemental database search, and a Missouri Medicaid sanctions list, and a check of the National Sex Offender Registry.

Program organizers shall not allow their personnel whose criminal records checks include a conviction, or pending charges, for a sex-related offense or crime against a minor, or who appear on the National Sex Offender Registry, to participate in any activity that is subject to this policy.  The offenses that may serve to disqualify someone from working with minors are not limited to sex offenses and crimes against minors.

SLU's Office of University Compliance and Ethics will provide program organizers from within the University with criminal records check information and request forms. A registry of University personnel and volunteers who have undergone criminal records checks is maintained by University Compliance and Ethics. 

Training for Those Personnel in Programs Involving Minors

University Personnel who participate in Programs involving minors, must complete appropriate training. At a minimum, training must include:

• Basic warning signs of abuse/sexual abuse/neglect.
• Guidelines for protecting minors from emotional and physical abuse/sexual abuse/neglect.
• Requirements and procedures for reporting incidents of suspected abuse or negligence or improper conduct.
• Understanding of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act), and with knowledge of the procedures required in reporting crime on campus.

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

Supervision

Program organizers must ensure adequate supervision of minors during Programs. Some of the factors to consider in determining “adequate supervision” are the number and age of minors, the activity involved, type of housing if applicable, and age and experience of the Personnel.

Program organizers shall ensure that the parent or guardian of each minor has completed any and all required authorizations, releases, and other required forms prior to the start of a program.

Personnel working with minors shall take affirmative measures to avoid putting themselves in positions where an allegation of abuse could be made against them. All work with minors shall be in an open environment, never behind closed doors or completely out of view of others, except where the purposes or nature of the interaction with the minor requires that degree of privacy. Unless required by the nature of the activity (for example, counseling or therapy sessions), at least two persons, one of whom meets the criminal records check requirements of this policy, shall be present at all times during activities involving minors.

Separate accommodations are required for adults and minors, unless the adult is a parent or guardian of the minor. Signed written permission from a parent or guardian is required for a minor to stay overnight on University premises. All in-room visits with program participants staying in University housing are restricted to persons of the same gender, except for visits by a parent or guardian. All guests and visitors of program participants staying in University housing are restricted to building lobby and lounge areas and only during the hours specified by the program organizer, which in no case shall be later than 12:00 am.

When the nature of a program so requires, University personnel may travel with, and transport minors to and from program activities with the prior written approval of the appropriate University Vice President or Dean. University programs must comply with University policies regarding drivers and vehicles.

The University will utilize the Campus Emergency Alert System to notify parents or legal guardians of emergencies that affect the campus community.

Program organizers shall maintain an up-to-date list of program times and dates, location, attendance (age range and number of participants), and a program contact, so that in the event of an emergency, appropriate measures may be taken. A copy of this list must be provided at least ten days prior to the start of the program to the University division responsible for the facilities being used by the program and to the Department of Public Safety. Any subsequent amendments to the list shall be provided to the University division responsible for the facilities being used and the Department of Public Safety. Program organizers shall maintain a list of the names, ages, and contact information of all minors participating in the program.

Program organizers shall provide a copy of this policy and any additional program-specific measures and required policies and procedures to all personnel.

Program organizers shall have specific policies and procedures addressing the following and will make them available to all participants and to the University upon request:

• Incident follow-up, including situations that arise at camp such as an injury, altercation between campers or an illness.
• In such situations, parents must be notified immediately; an incident report with Department of Public Safety must also be made after parents are notified.
• Transporting minors during, before and after the program, including by parents and guardians.
• Weather emergencies: if the program is outside, designation of a suitable indoor facility that is prepared to be available if necessary.
• Appropriate levels of access to and supervision of minors.
• Appropriate behavior, including physical contact and communications which consider the age of minors and the nature of the program. Forms, specifically parental or guardian authorizations for participation, authorizations for medical treatment and dispensing medication, student health history, emergency contact information, pick-up and drop-off documentation and a photo release form.
• If campers note certain allergies, including food allergies, camp staff should contact DineSLU to ensure that Grand Hall has taken the necessary precautions. and emergency contact information.

If a program involves an overnight stay in University facilities, the program organizer shall have policies in-place to address the following:

• Identification to be worn by personnel, and participants
• Curfew (Which in no case shall be later than 12:00 am)
• Room checks to ensure that participants are in the residence hall by the required time and are meeting curfew.
• Code of conduct for participants
• Overnight supervision
• In-room visits by program participants, personnel and others

Certain discrete or occasional programs for which a large number of one-time volunteers are essential may adopt reasonable measures and safeguards, other than criminal records checks for volunteers, to protect minors participating in such programs. Program organizers must submit a description of the measures and safeguards they will take to the Department of Public Safety for review at least forty-five (45) days prior to the start of the program.  In addition to all other measures and safeguards to be taken, the following requirements must be met:

• Program organizers must compile a list of all volunteers’ names and addresses and check the names against the National Sex Offender Registry.
• All volunteers who will have unsupervised access to minors as a part of their assigned duties must undergo a criminal records check.
• Volunteers who have not undergone a criminal records check may work with minors only in an environment open to public view; never alone.
• Program organizers must provide all volunteers with a copy of this policy and the additional measures and safeguards established for the program in advance of the program.
• Volunteers must sign in to the program with the program organizer or his or her designated representative before they may participate in the program. The process of signing in requires that volunteers present one of the following forms of photo-identification: valid state driver’s license or state identification card; valid U.S. Passport; valid U.S. Military I.D.; or a valid college, university, or high school I.D. card with another form of identification bearing the student’s name (e.g. credit or bank card, Social Security Card, voter identification card, utility bill) is required. The form of identification presented by each volunteer shall be recorded by the program organizer.
• When signing in to the program, volunteers will be required to acknowledge by their signature that they have received copies of this policy and information about any additional measures and safeguards, and have read and fully understand this information. Additional copies of this policy and any additional measures and safeguards shall be made available at the time of sign-in.
• If requested by the University, program organizers must provide to the University proof of compliance with this policy.
• Upon signing in, each volunteer will be issued an identification badge bearing his or her name, the name of the program and program dates. Volunteers must display their identification badges while participating in any part of the program.

External organizations are solely responsible for informing their personnel and volunteers of the criminal records check requirements of this policy and ensuring that such requirements are met. 

External organizations are responsible for reviewing the results of criminal records checks performed on their personnel and shall not allow their personnel whose criminal records checks include a conviction, or pending charges, for a sex-related offense or crime against a minor, or who appear on the National Sex Offender Registry to participate in any activity that is subject to this policy.  The types of offenses that may serve to disqualify someone from working with minors are not limited to sex offenses and crimes against minors.

External Organizations that wish to operate programs or activities involving minors on campus must provide documentation to the University indicating that all personnel who will be interacting with minors have received training that meets or exceeds the minimum requirements of this policy.

An External Organization, at its sole cost and expense, shall procure and maintain general and professional liability insurance or self-insurance covering the acts and/or omissions of its employees and agents for acts or omissions related to the programs or activities in minimum amounts of $1,000,000 per occurrence, and $3,000,000 annual aggregate.  Saint Louis University may require an External Organization to provide, upon request, a copy of its general liability insurance policy certificate specifically reflecting coverage for sexual abuse or a separate sexual abuse policy certificate reflecting the policy number, term, and coverage limits.

Reporting Potential Harm to Minors

A. Emergencies

In case of an emergency, Personnel must immediately contact the Department of Public Safety by calling (314) 977-3000 or by contacting the local police department by dialing 911.

B. All Other Reports of Known or Suspected Abuse or Neglect of Minors

Any Personnel engaged in Programs who has reason to believe that a minor has been abused, is at risk of abuse, or receives a report of alleged abuse that he or she has reason to believe to have been made in good faith, shall immediately inform the program supervisor (where appropriate) and the Vice President of Compliance and Ethics at 314-977-5774.  As an alternative, Personnel may also contact the SLU Integrity Hotline, the University’s anonymous reporting line, at 877-525-5669.

C. Any Personnel who knows, suspects, or receives information indicating that a minor has been sexually abused or exploited in a Program must also inform the Saint Louis University Title IX Coordinator at 314-977-3886.

D. Suspected abuse by a Jesuit must follow the steps above and are encouraged to contact the Coordinator of Pastoral Support and Outreach for the Jesuits, Carol Zarinelli Brescia, MSW, LCSW at 314-915-7168 or ucsoutreach@jesuits.org.

E. Any Personnel who believes they have knowledge, or a reasonable suspicion, of abuse must not seek to investigate the suspected abuse. They must not question, or attempt to solicit information from, the alleged victims of abuse, or persons suspected of being responsible for the abuse.

A reporting party need not have proof or evidence of abuse to make a report.  If the individual has any uncertainty about whether to report suspected abuse, the person should decide in favor of making a report.

No action will be taken against a member of the University community who in good faith raises a legitimate concern of suspected minor abuse which, upon investigation proves to be unfounded. False, intentionally misleading, or malicious accusations of minor abuse will be cause for disciplinary action, and possible legal action by the University, as well as possible criminal prosecution.

Additional Reporting Obligation for Mandated Reporters

In addition to the reporting obligations described in this policy that the University imposes on those participating in programs involving Minors, certain individuals are mandated reporters who have additional obligations under Missouri Law.

Missouri law designates individuals in certain occupations and professions as mandated reporters. Mandated reporters must report known or suspected mental, sexual or physical abuse or neglect of a child known to them in their profession or official capacity to either the Department of Public Safety by calling (314) 977-3000, the police at 911, or The Children’s Division Child Abuse and Neglect Hotline by calling 1-800-392-3738 or through the online system at https://apps.dss.mo.gov/OnlineCanReporting/default.aspx.

Missouri state law mandates reporting “When any physician, medical examiner, coroner, dentist, chiropractor, optometrist, podiatrist, resident, intern, nurse, hospital or clinic personnel that are engaged in the examination, care, treatment or research of persons, and any other health practitioner, psychologist, mental health professional, social worker, day care center worker or other child-care worker, juvenile officer, probation or parole officer, jail or detention center personnel, teacher, principal or other school official, minister as provided by section 352.400, peace officer or law enforcement official, or other person with responsibility for the care of children has reasonable cause to suspect that a child has been or may be subjected to abuse or neglect or observes a child being subjected to conditions or circumstances which would reasonably result in abuse or neglect, that person shall immediately report to the division in accordance with the provisions of sections 210.109 to 210.183.” See R.S.Mo. 210.115.1

Addressing Reports of Abuse or Neglect

Whenever the University receives a report of alleged abuse or neglect of a minor in a Program:

The person receiving the report shall immediately notify the Vice President of the Office of Compliance and Ethics, even if they believe the Vice President has already been informed. The Vice President for Compliance and Ethics, in consultation with the Department of Public Safety, the Office of General Counsel and appropriate senior University leadership, 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 limiting his or her contact with minors pending resolution of the matter.
• Determine whether the local police department, the Children’s Divisions Child Abuse and Neglect hotline (1-800-392-3738) 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 guardian of the minor involved
• Investigate the report and resolve the matter in a way that safeguards minors, protects the interest of victims and reporters, affords fundamental fairness to the accused, and meets relevant legal requirements.
• Facilitate the University’s cooperation with any investigation conducted by the local police department, Missouri Department of Social Services or other governmental agency.

Individuals who believe they have knowledge, or a reasonable suspicion, of abuse should not seek to investigate the suspected abuse.  They should not question, or attempt to solicit information from, the alleged victims of abuse, or persons suspected of being responsible for the abuse.

Minors who are not accompanied by an adult or a student enrolled at the University are not permitted on University premises for University programs or external organization sponsored programs, except as provided in this policy, the Saint Louis University Policy on Minors in Laboratories or with the express approval of the appropriate Vice President.

Enrolled Students Participating in Campus Activities

This policy shall not apply to minors (1) enrolled in University undergraduate or graduate academic programs, dual credit programs, such as the 1818 Advance College Credit Program or the Visiting Young Scholars program, or who participate in such programs by virtue of being in enrolled in another college or university, or (2) who participate in student activities previously authorized by the appropriate University Vice President or Dean. This exception shall not apply if such programs or activities include minors who are not enrolled students of the University or not enrolled in another college or university participating in such program or activity.

Campus Visits

This policy shall not apply to University students hosting high school students at least fourteen (14) years of age or older, who are on campus as part of a preadmission visit to the University, who are a registered guest of a residential student in accordance with established policies of the department of Housing and Residence Life.

Performances, Exhibits and Facilities Generally Open to the Public

Unaccompanied minors fourteen (14) years of age or older may attend University theater, performing arts and athletic events for which tickets are sold or made available to the public.

Unaccompanied minors fourteen (14) years of age or older may visit campus galleries, museums and other campus facilities which are open to the public.

University Libraries

Unaccompanied minors fourteen (14) years of age or older may visit University libraries.

Minors as Subjects in Research Studies

Unaccompanied minors who are subjects in research studies approved by a Saint Louis University Institutional Review Board are exempted from this policy.

This policy applies to all operating units of Saint Louis University, with the exception of SLU Madrid, including all faculty, staff, students, volunteers and other workforce members not otherwise identified.

Procedures include the following:

• Background check email
• Training Requirements
• Signs of Minor Abuse and Neglect

Links to the above procedural documents can be found at the bottom of this page.

Individuals who fail to comply with this policy and the procedures associated with it may be subject to disciplinary actions guided by the University's Staff Performance Management Policy, SLU Faculty Manual (St. Louis Campus), or Student Handbook. Non-compliance with this policy may result in disciplinary action, up to and including separation from the University.

All community members: All University students, faculty, and staff have an obligation to be alert to the possibility that a minor has been abused or may be at risk of abuse, and to immediately report this information to the Department of Public Safety (“DPS”) at (314)977-3000, or by contacting the police.

University policies including but not limited to:

• Policy on Minors in Laboratories (PDF)
• Reporting Concerns of Misconduct

University resources including but not limited to:

• Link to SLU Integrity Hotline

External resources including but not limited to:

• Clery Center Website
• Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act

Abuse: means the endangerment of a minor’s physical or mental health due to injury by act or omission, including sexual abuse.  A minor is abused regardless of whether the activity involves force or physical contact, whether or not it is initiated by the minor, whether or not the minor is aware of what is taking place, and whether or not there is a discernible harmful outcome.

External Organizations: are organizations or individuals from outside of the University community that are not sponsored by the University and use University facilities to conduct a program pursuant to an approved contract or other use agreement with the University.

Mandated Reporters: under Missouri Law (V.A.M.S. 210.115) include but are not limited to: physician, medical examiner, nurse, social worker, teacher, principal, or other school official, minister as provided by section 352.400, daycare workers or other person with responsibility for care of minors.

Minor: includes all persons under the age of eighteen (18) years who are not enrolled as students at the University.

Neglect: for the purpose of this policy means the failure to make reasonable efforts to prevent the infliction of abuse upon a person under age 18.

Personnel: for the purpose of this policy means any person, including without limitation, University faculty and staff, students, and volunteers, and External Organizations’ employees, staff and volunteers who work with minors in conjunction with a Program.

Program: for the purpose of this policy means any activity which serves or includes minors, and is under the direction or control of the University, regardless of its location, or an activity under the direction or control of an External Organization using University facilities pursuant to an agreement with the University.

Program Organizers: are external organizations, University faculty and staff, recognized student organizations, and the University’s departments and divisions that organize or who are responsible for the overall administration of a program.

Sexual Abuse: is an interaction between a minor and adult when the minor is an object of sexual gratification. Non-contact sexual abuse may include activities such as involving minors in viewing sexually explicit materials, or encouraging sexual behavior.