Type of Policy
Administrative
Effective Date:
Last Revised:
Review Date:
Policy Owner
Ethics, Compliance & Legal Affairs
Contact Name
Shawn Scott
Contact Title
Youth Programs Compliance Specialist
Contact Email
shawn.scott@carnegie.gatech.edu
Reason for Policy

Georgia Tech and third-parties utilizing Georgia Tech facilities organize many youth programs for non-student minors of various ages, both on- and off- campus. The intent of this policy and related procedures is to help those involved with youth programs to ensure the safety and well-being of non-student minors both on- and off- campus.

Policy Statement

2.1 Youth Programs Registration

All Georgia Tech youth programs (on or off campus) for non-student minors, including third-party youth programs utilizing Georgia Tech facilities, must register annually (beginning September 1st each year) with Georgia Tech. A non-registered youth program is subject to cancellation without advance notice. Youth programs must receive written approval from Youth Programs Compliance before starting the program.

2.2 Code of Conduct

Georgia Tech individuals or units organizing youth programs are responsible for ensuring that proper procedures are in place for all individuals working with minors through the program.

All individuals who work with non-student minors in those youth programs must follow the Youth Programs Staff & Volunteer Code of Conduct, in addition to any program-specific procedures for working with minors.

2.3 Background Checks, Pre-Screening, and Training

Georgia Tech individuals or units organizing youth programs are responsible for ensuring that all individuals who will have direct contact with non-student minors through their youth program have the following complete before being allowed to have direct contact with non-student minors:

  1. a criminal background check;*
  2. appropriate pre-screening; and
  3. training on mandatory reporting of child abuse.

*A criminal background check must have been run and the individual cleared to work with minors by the Georgia Tech Office of Human Resources in writing within the past 4 years and then every 4 years afterward. Please note, additional Office of Human Resources policies regarding background checks may apply outside of the Youth Programs Policy.

2.4 Third-Party Programs

Third-party youth programs that use Georgia Tech facilities must sign a Youth Programs Facilities Use Agreement / License Agreement. Such programs must comply with Georgia Tech policy requirements for background checks and training of program employees and volunteers, and must demonstrate that they have minimum insurance requirements as required by the Youth Programs Facilities Use Agreement/License Agreement.

Scope

This policy applies to all individuals involved in Georgia Tech youth programs, as well as third-party youth programs utilizing Georgia Tech facilities. Programs, activities, and/or research designed for non-student minors with IRB approval may also be subject to the Youth Programs Policy.

This policy does not apply to non-residential field trips to Georgia Tech supervised by a minor’s school or organization and that do not involve overnight lodging. Campus tours and athletics and admissions recruiting programs are not considered youth programs.

Policy Terms

Adult

Any person 18 years old or older.

Direct Contact

Direct Contact includes, but is not limited to:

  • Care, custody, and/control of the non-student minor, and/or;
  • Frequent or sustained contact, and/or;
  • Interactions with the intent to develop a mentoring relationship between an individual and non-student minor(s).

Generally, speakers, presenters, exhibitors, registration/logistics volunteers, exam proctors, scorekeepers, clock operators, competition judges, campus tour guides, and admission interviewers/admission events are not considered to have direct contact with minors.

Georgia Tech Organizer

For the purposes of this policy, a Georgia Tech Organizer includes a Georgia Tech College, School, Department, Office,  Georgia Tech Registered Student Organization, or a Georgia Tech employee within the scope of their employment.

Georgia Tech Facilities

Georgia Tech facilities shall include facilities owned by the Georgia Institute of Technology and facilities owned by Georgia Tech Affiliated Organizations.

Minor

Any person under the age of 18.

Non-Student Minors

Minors who are not Georgia Tech students.

Volunteer

A person who freely takes part in a youth program, or youth program task, without receiving monetary compensation.

Youth Program

A program or activity for non-student minors organized by Georgia Tech, or third-party entities utilizing Georgia Tech facilities. Some examples of youth programs include, but are not limited to

  • Day and overnight camps
  • Tutoring/mentoring in local schools
  • Internships for minors in labs/research facilities

Campus tours and athletics and admissions recruiting programs are not considered youth programs.

Procedures
5.1  Registration
Youth Programs Registration

Georgia Tech requires all youth programs to register annually (each year, beginning September 1) no later than 30 days before the program start date, unless there are extenuating circumstances that prevent the program from registering during that time frame. This includes third-party youth programs utilizing Georgia Tech facilities.

The Georgia Tech online Youth Program Registration Form is available here: https://youthprograms.gatech.edu/youth-programs-registration-form-instructions.

Program Considerations

Program administrators are required to certify compliance with this policy and that their youth program has considered and met the following criteria in the planning of the program (see http://youthprograms.gatech.edu/ for additional information about the below):

• Pre-screening, background checks, and training of individuals with direct contact with minors

• Appropriate staffing and supervision ratios by age range in accordance with American Camp Association standards

• Safety and security planning including but not limited to: knowledge of facility evacuation plans and shelter in place locations, participant check-in and check-out procedures, and enrollment of the on-site contact in the Georgia Tech Emergency Notification System

• Protocols for injury, illness, medication storage, missing participants, participant misconduct and staff misconduct

• Transportation and housing needs

• Participation registration forms including but not limited to waivers, pick-up authorization documentation, and emergency contact information.

• Licensing requirements of state and federal agencies

5.2 Code of Conduct

Code of Conduct

Georgia Tech youth programs are responsible for having all individuals working with minors read and sign the Youth Programs Staff & Volunteer Code of Conduct. The Youth Programs Staff & Volunteer Code of Conduct is provided here: http://youthprograms.gatech.edu/code-conduct-youth-programs, and in the Protect Children mandatory training.

5.3 Background Checks

Background Checks

Criminal background checks for individuals with direct contact with non-student minors through Georgia Tech youth programs must have been run and the individual cleared to work with minors by the Georgia Tech Office of Human Resources within the past 4 years and then every 4 years afterward. Offenses dealing with domestic abuse, drugs, violence, crimes against the elderly, infirm, etc. must be assessed carefully. The youth program will be charged the vendor fee for the criminal background check. Proof of the clearance must be obtained by the program organizer prior to allowing the individual to have direct contact with non-student minors. The Office of Human Resources background screening website can be found here: http://ohr.gatech.edu/screening. Additional Office of Human Resources policies regarding background checks may apply.

5.4 Pre-Screening

Pre-Screening

Youth program staff in charge of screening individuals should be aware of the inherent limitations of background checks and should seek to utilize other screening methods, when possible, to include application questions, in-person interviews, and personal and professional reference checks.
Missing application information and any personal or professional reference issues must be resolved by the youth program before an individual is allowed to have direct contact with non-student minors within the program.

5.5 Training

Training

Individuals with direct contact with non-student minors through Georgia Tech youth programs must complete the Georgia Tech online Protect Children training annually, in addition to any program specific training. Proof of completion of the training must be obtained by the program organizer prior to allowing the individual to have direct contact with minors. The Georgia Tech online training is available here: https://youthprograms.gatech.edu/training-requirements.

 

5.6 Third-Party Programs

Third-Party Programs

Third-party youth programs that use Georgia Tech facilities must sign a Youth Programs Facilities Use Agreement / License Agreement contractually agreeing to comply with Georgia Tech policy requirements for background checks and training of program employees and volunteers, and must demonstrate that they have minimum insurance requirements. Third-party programs should utilize their own background check vendor, training, and code of conduct.

The example Youth Programs Facilities Use / License Agreement for third-party youth programs is available here: http://youthprograms.gatech.edu/forms

Georgia Tech entities managing the facility reservation should contact Youth Programs Compliance before executing a Youth Programs Facilities Use/ License Agreement with a third-party youth program. Verification that the Certificate of Insurance meets minimum coverage limits, and execution of the Youth Programs Facilities Use Agreement / License Agreement is required prior to third-party youth program approval.

5.7 Minors in Labs

Minors in Labs

All Georgia Tech youth programs, and third-party youth programs using Georgia Tech facilities must follow the Minors in Laboratories, Hazardous Areas and Animal Facilities Policy and use the Minors in Labs forms available here: https://www.ehs.gatech.edu/minors

Confirmation of Minors in Laboratories, Hazardous Areas and Animal Facilities policy compliance is required prior to youth programs approval.

5.8 Mandatory Reporting Procedures

Mandatory Reporting Procedures

All Georgia Tech employees and volunteers acting in the course of their employment or service to Georgia Tech must comply with Georgia Tech’s Mandatory Reporting of Child Abuse Policy.

5.9 Documentation and Record Retention

Documentation and Record Retention

Georgia Tech youth program organizers are responsible for keeping documentation about their program, employees, volunteers, and youth participants, and retaining the documentation for the proper records retention period – until 3 years after youth program participants reach the age of 18. These documents must include: proof of an individual’s background check clearance, training completion certificates which include code of conduct attestations, application/registration forms, parental consent forms, activity records, incident reports, and attendance records for participants and individuals working with the youth program. Additional documentation may also include, but is not limited to: IRB approval, Minors in Labs approval, Youth Programs Facilities Use /License Agreements, COI verification, and youth program registration approval.

The Georgia Tech Office of Human Resources is responsible for retaining documentation of background checks and training for Georgia Tech employees who have direct contact with non-student minors. Georgia Tech individuals or units sponsoring youth programs are responsible for retaining proof they received written clearance from the Georgia Tech Office of Human Resources prior to allowing individuals to have direct contact with non-student minors.

The University System of Georgia Records Retention Schedule for Child and Youth Program Participant Records is available here: http://www.usg.edu/records_management/schedules/925

Contact the Office of the General Counsel, or Youth Programs Compliance for more information on statute of limitations and records retention.

Enforcement

Georgia Tech and the Board of Regents of the University System of Georgia may periodically audit youth programs for compliance with this policy. Violations of this policy could result in disciplinary action for Georgia Tech employees, students, and volunteers in accordance with Institute procedures. A non-registered youth program is subject to cancellation without advance notice.

Failure of a mandatory reporter to report suspected child abuse is a violation of state law and the mandatory reporter may be subject to criminal penalties.

To confidentially report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/media/en/gui/7508/index.html

Policy History
Revision Date Author Description
October 2023 Office of Ethics and Compliance Editorial Update to modify the start of registration from January 1 to September 1 to align with the academic year
November 2021 Office of Ethics and Compliance Editorial Update
July 2019 Ethics Compliance & Legal Affairs Updated Policy
May 2017 Legal Affairs and Risk Management Updated Policy
December 2016 Legal Affairs and Risk Management Compliance with New Board of Regents Policy 6.9
June 2015 Legal Affairs and Risk Management Background Check and Training Time Period
May 2014 Legal Affairs and Risk Management New Policy