Number: CW 050
Effective: September 22, 2016
Department: Risk Management
Last Revision: April 28, 2017

Purpose

To establish guidelines for observing and reporting Minor Abuse for those individuals who may work or interact with Minors at CWI, with the goal of promoting the safety and wellbeing of Minors on campus.

Scope

Applies to all employees, students, contractors, subcontractors, and volunteers who interact with Minors through College-sponsored or affiliated programs or activities. College faculty and others on campus who only interact in classes or other normal academic settings with students who may be Minors are not obligated to undergo the training or background checks required by this Policy.

Definition

Minor Abuse: The infliction of physical or emotional injury, sexual abuse or exploitation of a Minor (whether by an adult or another Minor); negligent treatment or maltreatment of a Minor; or abandonment of a Minor. This includes the failure to make reasonable efforts to prevent Minor Abuse as well as emotional injury. See Section II: Signs of Abuse and Neglect for more detail.

Minor: Any person under the age of eighteen (18). CWI students who are under the age of eighteen (18) are treated by this Policy similarly to all other students for purposes of their interactions with Minors in College sponsored or affiliated programs, and are subject to the requirements that apply to other students.

CWI-Sponsored or Affiliated Programs or Activities (Programs): Programs or activities that CWI operates or sponsors specifically intended for minors, whether on or off College owned or controlled property, or in which CWI students and employees engage through their College roles.

Employee: Any individual currently employed by CWI and compensated through its payroll system.

Student: Anyone enrolled as a student at CWI. For purposes of this policy, “student” includes all student employee positions.

Volunteer: a person who performs services and/or engages in activities on behalf of or for the benefit of CWI without promise, expectation or receipt of compensation. The term “volunteer” does not include CWI students participating in activities that are part of a course or program in which the student is enrolled.

Campus: All CWI locations and premises, field and research areas, vehicles, grounds, buildings, commercial operations and residences under College ownership or control.

Policy

The College is committed to the shared values of caring, citizenship, and responsibility. Under this umbrella of shared values, all employees, students, contractors, subcontractors, and volunteers will prevent Minor Abuse when possible and report it when suspected.

Guidelines

Reporting Minor Abuse

  • When to Report Minor Abuse
    • Under this policy and state law, all employees, students, contractors, subcontractors, and volunteers who suspect Minor Abuse are required to report the abuse within 24 hours. There is no need to investigate or ensure that evidence exists before reporting.
    • Any doubt as to whether or not to report should be resolved in favor of making the report to ensure that appropriate professionals in law enforcement and/or child protective services can assess the report and evaluate the safety of the Minor.
  • Where to Report Minor Abuse
    • All reporting options below allow anonymous or confidential reporting.
      • Idaho law requires anyone who suspects Minor Abuse to report it immediately to law enforcement or the Idaho Department of Health and Welfare.
      • If a Minor may be in imminent harm, dial 9-1-1 or activate a blue emergency phone located on campus.
      • Otherwise, immediately report the incident to:
        • Campus Security 
        • The Child Protection Division at the Idaho Department of Health and Welfare at (208) 334-5437, or using Idaho Department of Health and Welfare’s Care Line by dialing 2-1-1. 
  • Additional Reporting Requirements
    • Any person designated as a Responsible Employee under the College’s Respectful Community Policy must follow established reporting requirements.

Additional Guidelines and Responsibilities

  • Participation in CWI Sponsored or Affiliated Programs or Activities
    • Employees, students, contractors, subcontractors, and volunteers must:
      • Always be vigilant in protecting the well-being and safety of Minors with whom they interact on campus or elsewhere.
      • Review and commit to the principles in Sections I: Code of Conduct for Interacting with Minors; Section II: The Signs of Abuse and Neglect of Minors; and Section III: Training Requirements for those who work with Minors below.
      • Watch for signs of Minor Abuse (as outlined in Section II below) and promptly report suspected instances of Minor Abuse, or violations of this policy or law, as previously provided.
      • Before engaging in any CWI sponsored or affiliated program or activity involving contact with Minors: meet the requirements of this Policy related to training and criminal background checks.

Managing Programs for Protection of Minors

  • Program Registration
    • The College sponsored or affiliated program or activity organizer, director, dean, or department chair will register all on-going or one-time Programs with Risk Management. Risk Management will keep an online database of these Programs. Contact Risk Management for related forms and deadlines.
  • Background Checks
    • A background check shall be required of each adult prior to his or her interaction or participation with Minors in CWI sponsored or affiliated programs. This includes but is not limited to:
    • Non-CWI organizations and entities that operate programs or activities on campus involving Minors must conduct criminal background checks that meet CWI standards on their employees, volunteers, and representatives. The College may request any additional information it deems necessary to meet the requirements of this policy.
  • Mandatory Training on the Prevention, Recognition, and Reporting of Minor Abuse
    • CWI students, employees and volunteers who participate in programs 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 emotional and physical abuse and neglect.
      • Requirements and procedures for reporting incidents of suspected abuse, neglect, or improper conduct.
    • Training may be expanded depending upon the program or activity and the trainee’s role in the program or activity. Employees, students, contractors, subcontractors, and volunteers must:
    • Non-CWI organizations and entities that wish to operate programs involving Minors on campus must provide documentation to Risk Management indicating that all individuals who will be interacting with Minors (and anyone who supervises such individuals) have received training that meets or exceeds the minimum requirements of this section. Specific requirements and procedures for training appear in Section III. Employees, students, contractors, subcontractors, and volunteers must:
  • Oversight and Responsibilities
    • Risk Management will track program information and written agreements, while ensuring compliance with this policy and best practices in the prevention of Minor abuse. 
    • Risk Management in conjunction with Human Resources will track background checks, to be performed by Human Resources, and training completion on the prevention of Minor abuse.
    • Program organizers or designees shall register programs involving Minors with Risk Management with sufficient advance notice to meet the requirements and intentions of this policy. (Minimum 1 month).
  • Enforcement
    • Violations of this Policy may include the full range of corrective actions available including suspension, expulsion, dismissal, termination, and exclusion from campus. The College may also take necessary interim actions before determining whether a violation has occurred. The College may terminate relationships or take other appropriate actions against non-CWI entities that violate this Policy. Any violations of law will be reported to the proper authorities.
  • Policy Implementation and Modification
    • Questions about the interpretation or application of this Policy should be raised with Risk Management, which shall update or modify this Policy as necessary and administer and oversee the implementation of the Policy in a manner that best achieves its goals.

Section I.

Code of Conduct for Interacting with Minors

  • All employees, students, contractors, subcontractors, and volunteers who interact with Minors through programs are required to comply with the following code of conduct when interacting with Minors.
    • Do not spend time alone, either on or off campus, with a Minor away from others.
      • If one-on-one interaction is required, meet in open, well-lit rooms or spaces with windows observable by other adults from the Program.
      • It is expected that activities where Minors are present will involve two or more authorized adults.
      • When it is not possible to comply with the above, parents/guardians of Minors must sign a specific waiver acknowledging that they understand their Minor is engaged in a program that requires a one-on-one interaction (Minor to Adult) such as a private lesson or medical exam.
    • Do not engage in any behavior of a sexual nature with, or within the vicinity of Minors, including but not limited to: engaging in sexual actions, making sexual comments, telling sexual jokes, or sharing or viewing sexually explicit material with or within the vicinity of Minors, except as necessary for Program relevant, academic content or providing competent medical services.
    • Do not touch Minors in a manner that a reasonable person could interpret as inappropriate, including but not limited to:
      • Contact with a Minor’s breasts, buttock, groin, or genitals, or touching a Minor with any of these body parts;
      • Making a Minor touch himself/herself or another person with or on the breasts, buttock, groin, or genitals;
      • Other bodily contact in a sexual manner, though not involving contact with breasts, buttocks, groin or genitals, for example back or shoulder massages.
        • Bodily contact required to provide competent medical services is explicitly exempted from this section.
    • Do not shower, bathe, or undress with or in the presence of a Minor.
    • Do not engage in any abusive conduct of any kind toward, or in the presence of a Minor, including but not limited to verbal abuse, hitting, punching, poking, or inappropriate restraining, except as required to protect a Minor or others from harm. All incidents involving such conduct, whether or not required to protect a Minor or others from harm, must be documented and disclosed promptly to the Program Director and the Minor’s parent/guardian.
    • Be aware of the impact of words and language upon Minors.
    • Do not use, possess, share, or be under the influence of alcohol or illegal drugs while on duty or when responsible for a Minor’s welfare. The misuse of prescription medications shall be determined to be a violation. Refer to the CWI Drug & Alcohol Policy for additional information.
    • Do not distribute any medication or dietary supplement to a Minor without prior written approval of the Minor’s parent/guardian, except in case of emergency.
    • Do not meet with Minors outside of established times for Program activities. Any exceptions require prior written parental authorization and must include more than one adult from the Program.
    • Do not engage or converse with Minors through email, text messages, social networking websites, or other forms of social media at any time except and unless there is an educational or programmatic purpose for the communication and the content of the communication is consistent with the mission of the Program and the College.
    • When transporting Minors in a Program, more than one adult from the Program must be present in the vehicle, except when multiple Minors will be in the vehicle at all times during the transportation. Use of personal vehicles is not permitted. When it is not possible to comply with this guideline, parents/guardians of Minors must sign a specific waiver acknowledging that they understand their Minor is engaged in a Program that requires one-on-one interaction (Minor to Adult).
    • Do not tell Minors “this is just between the two of us” or use similar language that encourages Minors to keep secrets from their parent/guardians.

Section II.

Signs of Minor Abuse and Neglect

There are often certain recognizable physical and behavioral indicators of Minor abuse or neglect. The following signs, by themselves, may not be conclusive evidence of a problem, but serve as indicators of the possibility that a problem exists.

  • Signs of Physical Abuse
    • Bruising, welts or burns that cannot be sufficiently explained; particularly bruises on the face, lips, and mouth of infants or on several surface planes at the same time;
    • Withdrawn, fearful or extreme behavior;
    • Clusters of bruises, welts or burns, indicating repeated contact with a hand or instrument;
    • Burns that are insufficiently explained; for example, cigarette burns; and
    • Injuries on children where children don’t usually get injured (e.g., the torso, back neck buttocks, or thighs).
  • Signs of Sexual Abuse
    • Difficulty walking or sitting;
    • Pain or itching in the genital area;
    • Torn, stained or bloody underclothing;
    • Frequent complaints of stomachaches or headaches;
    • Sexually transmitted infection;
    • Bruises or bleeding in external genitalia; 
    • Feeling threatened by physical contact;
    • Inappropriate sex play or premature understanding of sex;
    • Frequent urinary or yeast infections; and
    • Direct statements the Minor was sexually abused.
  • Signs of Emotional Injury
    • Speech disorders;
    • Inability to play as most children do;
    • Sleeping problems;
    • Anti-social behavior or behavioral extremes;
    • Delays in emotional and intellectual growth;
    • Sudden loss of self-confidence or self-esteem;
    • Avoidance of certain situations/activities; and
    • Desperate seeking of affection.
  • Signs of Neglect
    • Lack of medical or dental care;
    • Chronically dirty or unbathed;
    • Lack of adequate school attendance;
    • Lack of supervision; for example young children left unattended or with other children too young to protect or care for them;
    • Lack of proper nutrition;
    • Lack of adequate shelter;
    • Self-destructive feelings or behavior;
    • Alcohol or drug abuse; o Taking food or money without permission;
    • Eating a lot at one sitting; and
    • Hiding food for later consumption.

Each case of minor abuse or neglect is individual. The child who has been hurt is always the victim. If you believe a child may be the victim of abuse or neglect, contact the Idaho Department of Health and Welfare at (208) 334- 5437 or the Care Line at 2-1-1. Additionally, CWI Campus Security and Services can be reached at (208) 562-3333. Dial 9-1-1 in case of an emergency.

Section III.

Training Requirements for Those Involved with Minors

  • CWI employees and students who are involved in Programs involving Minors, as well as employees, volunteers and other representatives of non-College organizations or entities that operate programs or activities involving Minors on campus, are required to satisfy specific training and certification requirements.

CWI-Sponsored or Affiliated Programs or Activities

  • All individuals working with Minors in CWI sponsored or affiliated programs or activities are required to review this Policy and sign a certification confirming that they understood and will comply with the terms of this Policy. In general, individuals who participate in programs or activities involving Minors are required to review Sections I and II of this Policy and sign a certification for each program and activity. For programs with multiple regular activities involving Minors, the program or activity director or supervisor should contact Risk Management to determine whether repeat certifications are required. In addition, individuals who are required to read and sign are to submit the signed Certification to the program or activity director or supervisor at least thirty-six (36) hours 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 Risk Management.
  • In addition, all individuals who are required to obtain a background check pursuant to this Policy, including program or activity directors, supervisors and individuals who work one-on-one, stay overnight, or are working with Minors, must complete an online training course. The training course is designed to assist employees, contractors, volunteers, and students who work with Minors in establishing a comprehensive program for protecting Minors from sexual misconduct by addressing prevention strategies and reporting abuse. This online training course should be completed at least forty-eight (48) hours prior to the start date of the program or activity involving Minors. Individuals required to do the online training must repeat the course annually, provided they continue as program or activity directors, supervisors or individuals who work one-on-one, stay overnight, or are regularly alone with Minors.

Non-CWI Programs or Activities on Campus

  • Employees, volunteers and representatives of non-CWI organizations or entities that operate programs and activities involving Minors on campus are required to comply with the training and certification requirements that apply to CWI sponsored or affiliated programs and activities. Non-CWI organizations or entities must also submit to Risk Management, a certification of compliance with the training requirements described herein at least forty-eight (48) hours prior to the start of any program or activity involving Minors on campus.