Policy for the Protection of Minors

Policy Number: #700

Responsible Executive(s):

VP Student Affairs

Responsible Office(s):

Auxiliary Services

Date Revised: 12-01-2020

A. Purpose

Regis University (“University”) seeks to conduct its operations and maintain its campuses so as to provide an academic environment that is safe and supportive of the pursuits of its students, faculty, staff and visitors, and consistent with its mission.

As part of its mission, the University offers programs that serve or include Minors. The Policy for the Protection of Minors (“Policy”) and the following procedures have been adopted by the University to protect Minors, as vulnerable members of society while they are using or on University Facilities or when participating in activities sponsored by the University. This Policy establishes guidelines for those in the University community who may work or interact with individuals less than 18 years of age, with the goal of promoting the safety and well-being of Minors.

B. Scope

This policy provides guidelines that apply broadly to University programs involving minors and External Organizations that operate programs for minors using University Facilities must also comply with this Policy. All Regis University students, faculty, and staff are responsible for understanding and complying with this Policy. The Policy and its Appendices which set forth specific requirements and procedures may be updated from time to time.

C. The Policy

Minors on Campus
1. Regis University welcomes minors on campus for a variety of specific reasons: as prospective students; as enrollees in a University-sponsored program or camp; as patients; other programs appropriate for minors (some of which may meet off-campus but still be sponsored by Regis University) and minors participating in program or activities run by an External Organization. Below are some guidelines for the presence of Minors on Campus:
  1. If a minor accompanies a parent or guardian to work, the parent or guardian must supervise the child at all times while on university property. Children may be restricted from access to certain areas due to safety concerns, and in no case should the presence of a child be allowed to disrupt another faculty, staff or students. Please refer to Human Resource Policy Manual, section 2.8.16.
  2. Resident students may not “babysit” minors in their rooms, including relatives.
  3. University faculty and others on campus who only interact in classes or other normal academic settings with Regis University undergraduate students under the age of 18 are not obligated to undergo the training or background checks required by this Policy.
  4. External Organization offering programs with minors at a University Facility must familiarize themselves with and follow this Policy and the policies of the External Organization relating to interactions with Minors.
Staff and Faculty Participating in Programs Involving Minors
1. When participating in Programs involving Minors, Program Staff, students, faculty, employees, and volunteers must:
  1. Always be vigilant in protecting the well-being and safety of Minors with whom they interact on campus or elsewhere.
  2. Review the informational material about the signs of Abuse or Neglect of Minors. Information about the signs of abuse and neglect of Minors appears in Appendix A.
  3. Watch for signs of Abuse or Neglect of Minors and promptly report suspected instances of abuse or neglect, or violations of this policy.
  4. Before engaging in any Program involving Minors, meet the requirements of this Policy
    - Complete working with minors training (Appendix B);
    - Complete a Background Check if required (Appendix C)
    - Meet any additional requirements that relate to the specific program or activity;
    - Meet the supervision requirements, and determine whether they are a mandated reporter under Colorado law (Appendix D).
  5. To the extent Personnel are participating in programs or activities run by an External Organization, they should familiarize themselves with and follow this Policy and the policies of the External Organization relating to interactions with Minors and understand their legal obligations with respect to working with Minors in the Program.
All university programs in which staff, faculty, volunteers or students work directly with non-matriculated minors must register the name of the program, including contact information, with the Auxiliary and Business Services (Risk Management). Programs must be able to identify all staff, faculty, volunteers, students, and contractors who work directly with minors; that list must be maintained by Program Director and Program Organizer within each program and be available for review by Auxiliary and Business Services (Risk Management). Program Registration form can be found in Appendix E. Training for Those Personnel in programs involving Minors
1. University students, faculty and staff who participate in Programs involving Minors must complete appropriate training. At a minimum, training must include:
  1. Basic warning signs of Abuse or Neglect of Minors. (See Appendix A)
  2. Guidelines for protecting Minors from emotional and physical abuse and neglect.
  3. Requirements and procedures for reporting incidents of suspected abuse or neglect or improper conduct.
  4. Training may be expanded depending upon the program or activity and the person’s role in the program or activity.
2. External Organizations that wish to operate programs or activities involving Minors on campus must provide documentation to the University 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 Appendix B.
Supervision
1. Program Organizers must ensure adequate supervision of Minors during Programs. At a minimum adequate supervision requires that all activities involving Minors are supervised by at least two or more Authorized Adults.
  1. Some of the factors to consider in determining “adequate supervision” are the number and age of participants, the activity (is) involved, type of housing if applicable, and age and experience of the counselors. Note - Children under the age of 9 are not permitted to participate in camps on Regis property.
2. Ratios:
  1. Overnight Ratios - The Program Staff to the Minor ratio for sleeping campers is 1 Authorized Adult when 6 or fewer Minors are in attendance and 2 Authorized Adults when 7 to 12 Minors are in attendance, plus one adult for each additional 6 or fewer Minors.
  2. Day Ratios - The minimum program Staff to Minor ratios during a day are as follows:
    
    Age Day Camp Overnight Camp
    
    9-14 1:10 1:8
    
    15-17 1:12 1:12
Background Checks
1. Certain categories of Authorized Adults will be required to pass a background check prior to participation in a Program. The categories of individuals who must undergo background checks and the type of background check are identified in Appendix C.
2. Except where required by law, criminal background checks of University faculty, staff, and students that are conducted pursuant to this Policy will be used only for purposes consistent with this Policy and will otherwise be kept confidential. Records of background checks will be maintained separately from an individual’s personnel or student file.
3. External Organizations that operate programs or activities on campus involving Minors must conduct criminal background checks of their employees, volunteers, and representatives that meet University standards as identified in Appendix C. External Organizations are solely responsible for the cost of background checks and for informing their personnel and volunteers of the criminal records check requirements of this policy and ensuring that such requirements are met. The University may request any additional information it deems necessary to meet the requirements of this Policy.
Roster of Minor Participants, Emergency Protocols, and Program Registration
1. Each Program Director conducting a Program involving Minors shall collect and prepare in advance of each Program involving Minors the following:
  1. A list of all Minor participants and Program Staff members shall be maintained by the Program Director.
  2. The Program Director must obtain and have on-site medical release forms, liability waivers, and emergency contact information for each Minor participant (age, address, phone numbers, and guardians).
  3. External Organization’s Program Director shall provide the Sponsoring Unit with a list of all Minor Program participants including participant’s name; local room assignment (if applicable); gender, age, address, and phone number(s) of a parent or legal guardian, as well as emergency contact information.
  4. Each Program must have an emergency plan for notifying parents or legal guardians in the event of an emergency and communicate the same to the parents or legal guardians. In the event of an emergency, please call 911 (9-911 if on campus) and the University Campus Safety Office (303-458-4122).
  5. Each Program must be able to identify all staff, faculty, volunteers, students, and contractors who work directly with minors; that list must be maintained by Program Director and Program Organizer within each program, and a copy be provided to the Office of Auxiliary and Business Services (Risk Management). Program Registration form can be found in Appendix E.
Reports of Known or Suspected Abuse or Neglect of Minors
1. Anyone participating in a University-run, affiliated program or activity involving Minors or a non-University program or activity operating on campus involving Minors who knows, suspects, or receives information indicating that a Minor has been abused or neglected, or who has other concerns about the safety of Minors MUST take the following steps:
  1. Inform the Risk Manager by calling (303) 964-1638. The Risk Manager, with support from other appropriate offices as necessary, will help determine appropriate next steps. In addition, one should promptly notify his or her supervisor, program director, dean, or vice president, when it is safe and appropriate to do so.
  2. Anyone who knows or suspects abuse or neglect of Minors and it is an emergency should call 911 immediately. If it is not an emergency, call 1-844-CO-4-Kids or 1-844-264-5437 to report all concerns for a child's safety and well-being as described in Appendix A.
  3. Anyone who knows, suspects, or receives information indicating that a Minor has been sexually abused or exploited in a Program MUST inform the Regis University Title IX Coordinator at 303 458-4906.
2. Questions about one’s obligations or what one should do in a situation that makes one uncomfortable should be raised with the Regis University Risk Management at 303-458-4391.
3. All individuals are protected from retaliation when they make good faith reports about the suspected or actual abuse, neglect or sexual abuse or exploitation of a Minor.
Reporting: Additional Obligations for Mandated Reporters
1. In addition to the reporting obligations described that the University imposes on those participating in programs involving Minors, certain individuals are mandated reporters who have additional obligations under Colorado law. Colorado 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 professional or official capacity anyone witnessing a child in a life-threatening situation should call 911 immediately. If it is not an emergency, call 1-844-CO-4-Kids or 1-844-264-5437 to report all concerns for a child's safety and well-being. These hotlines are typically available 24 hours a day, seven days a week.
2. If you are a mandated reporter, please familiarize yourself with the obligations of mandated reports in Appendix D.
Addressing Reports of Abuse or Neglect
1. Whenever the University receives a report of alleged abuse or neglect of a Minor in a University-run or -affiliated program or activity:
  1. The person receiving the report shall immediately notify the Risk Manager, even if they believe the Risk Manager has already been notified.
  2. The Risk Manager, in consultation with Office of Campus Safety, the Office of University Legal 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 activity or limiting his or her contact with Minors pending resolution of the matter.
    - Determine whether the local police department, CDHS, 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 guardians of the Minor involved.
    - Investigate the report and resolve the matter in a way that safeguards Minors, protects the interests 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, CDHS, or other governmental agency.
Enforcement
1. 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 University sanctions applicable to the individual including suspension, dismissal, termination, and, where appropriate, exclusion from campus. The University may also take necessary interim actions before determining whether a violation has occurred. The University may terminate relationships or take other appropriate actions against External Organizations that violate this Policy.
False or Intentionally Misleading Reports
1. 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.
Policy Implementation and Modification
1. Questions about the interpretation or application of this Policy should be raised with the Risk Manager, which shall update or modify the Appendices to the Policy as necessary and administer and oversee the implementation of the Policy in a manner that best achieves its goals. The Policy may be modified with the approval of the University President to reflect changes in the law, standards relating to the protection of Minors, or University processes, or as otherwise necessary.

D. Definitions

Abuse or Neglect of Minors – Infliction of physical or mental injury, sexual abuse or exploitation, or negligent treatment or maltreatment of a person under age 18. Sexual abuse includes engaging in or attempting to engage in a sexual act or sexual contact with a Minor, causing or attempting to cause a Minor to engage in sexually explicit conduct, or exposing the Minor to sexually explicit conduct. Neglect includes the failure to make reasonable efforts to prevent the infliction of abuse upon a person under age 18.
Authorized Adult – Individuals, age eighteen (18) years of age and older, paid or unpaid, who interact with, supervise, chaperone, or otherwise oversee Minors in program activities or recreational and/or residential facilities. This includes, but is not limited to, faculty, staff, volunteers, graduate and undergraduate students, interns, employees of temporary employment agencies, and independent contractors/consultants. The Authorized Adults’ roles may include positions as counselors, chaperones, coaches, instructors, volunteers, etc.
Camps – Events held using University Facilities for the purpose of Minors developing a skill over the course of a day or several days. Camps may or may not include overnight stays by the Minors.
Direct Contact – Positions where there exists the possibility of care, supervision, guidance or control of Minor children and/or routine interaction with Minors requiring direct contact.
External organizations - Non-University organizations or individuals that use University facilities to conduct a program pursuant to an approved contract or other facilities use agreement with the University.
Minor – Minor includes all persons under the age of eighteen (18) years of age. For the purpose of the Policy, Minor does not include individuals under the age of 18 who are either
1. enrolled students at the University,
2. whom are visiting the University at the invitation of the admissions office,
3. whom are visiting a sibling in University housing,
4. involved in research studies approved by the Regis University Institutional Review Board, or
5. unaccompanied Minors over the age of 14 who visit the library or attend publicly ticketed or available lectures, performances or athletic events.
Program(s) – Programs and activities offered by various academic or administrative units of Regis University, or by External Organizations who rent or otherwise use University Facilities. This includes but is not limited to workshops, sports camps, academic groups, conferences, and similar activities. However, it does not include:
1. single performances or events open to the general public that are not targeted towards skill building for Minor (such as varsity athletic competitions, plays, concerts, etc.), or
2. regularly scheduled University classes or activities designed primarily for enrolled students who are age 17 and above.
Program Director - The official who has the on-site programmatic oversight and responsibility for a program conducted on or in University facilities or has the responsibility to supervise a University program. Within Regis, examples of Program Directors include, but are not limited to, the Director of Athletics, Academic or School Deans, the Director of University Ministry, and the Director of Residence Life, Housing and Event Services. For External Organizations, the program director is the main contact for the program, such as a coach or camp director.
Program Organizers - External Organizations, University faculty and staff, recognized student organizations, and the University’s departments and divisions that organize staff with Personnel or who or otherwise responsible for the overall administration of a Program.
Program Staff or Personnel – Includes all Authorized Adults, Program Directors, and volunteers, regardless of whether they have direct contact with program participants.
Sponsoring Unit – Is the academic or administrative unit of Regis University offering a program/event or giving approval for housing or use of facilities including, but not limited to, the Athletics Department, University Ministry, and Center for Service Learning, Institute on the Common Good, or Event Services. Event Services is the Sponsoring Unit for all External programs.
University Facilities – Facilities and property owned by, leased by or under the control of Regis University including University-owned vehicles.

E. Related Policies, Procedures, Forms and Other Resources (Optional)

Appendix A – Signs of Child Abuse and Neglect
1. Nationally and in Colorado, most reports and substantiations of child maltreatment are neglect. Followed by physical abuse and sexual abuse.
2. Neglect occurs when parents or caretakers do not provide proper supervision, control, subsistence, education as required by law, or other care necessary for healthy development. By itself, lack of financial means to provide for a child is not neglect.
  1. Physical signs of Neglect may include:
    - Poor hygiene.
    - Inappropriate or ill-fitting clothing.
    - Being left alone or with people unable to provide proper supervision.
    - Obvious lack of necessary medical treatment.
  2. Behavioral signs of Neglect may include:
    - Chronic hunger or sleepiness.
    - Delayed language development.
    - Clinging behavior or development of indiscriminate attachments.
    - Frequent complaints of feeling unwell.
    - Frequent tardiness or absence from school.
3. Physical abuse is a non-accidental injury of a child by a parent or caretaker.
  1. Physical signs of Physical Abuse may include:
    - Bruises, welts, or swelling.
    - Sprains or broken bones.
    - Burns.
    - Lacerations or abrasions.
    - Bite marks.
    - Unexplained or repeated injuries.
  2. Behavioral signs of Physical Abuse may include:
    - Attempts to hide injuries.
    - Difficulty sitting or walking.
    - Wariness of physical contact with adults.
    - Reluctance to go home.
    - Depression or self-mutilation.
    - Fear of parent(s) or caregivers.
4. Sexual Abuse is exploitation of a child for the sexual gratification of an adult, teenager or older child.
  1. Physical Signs of Sexual Abuse may include:
    - Difficulty walking or sitting
    - Torn, stained, or bloody clothing
    - Genital pain or itching
    - Sexually transmitted diseases
    - Pregnancy
  2. Behavioral Signs of Sexual Abuse may include:
    - Precocious sexual knowledge or behavior.
    - Extremes – hostile and aggressive or fearful and withdrawn.
    - Self-mutilation
    - Substance abuse
    - Running away
Appendix B – Training Requirements
1. Training members of the campus community about child abuse and endangerment is critical for preventing its occurrence and reducing an institution’s liability. Increasingly, state and federal regulations mandate that institutions train on sexual misconduct and harassment. The April 2011 “Dear Colleague” letter issued by the U.S. Department of Education’s Office for Civil Rights directs educational institutions to provide general training on Title IX sexual assault, which includes prevention of sexual misconduct of minors, to all students and employees. Regis University will provide training through United Educators.
2. The University has several United Educators Online Courses that train students, volunteers, faculty and staff working with programs involving Minors.
3. To receive this training, please contact:
  Auxiliary and Business Services (Risk Management)
  Main Hall 137
  303-458-4391
4. Guidelines for Those Working with or around Children
  1. Child abuse is a difficult and emotionally-charged subject. These guidelines are intended to provide information about your conduct in order to prevent abuse or unfounded allegations of abuse; define abuse and describe signs to look for, and explain how to respond to abuse or suspicions of abuse.
5. Code of Conduct for Working with Minors
  1. You have a duty to the children with whom you work, to the university and to yourself to prevent any abuse or improper behavior. You also have a duty to prevent unfounded accusations of abuse, by adhering to a proper code of conduct when working with minors.
  2. Never use any form of physical or emotional punishment to discipline children participating in the program
  3. Never engage in rough or sexually provocative games, including horseplay
  4. Do not allow children to sit on your lap
  5. Do not allow any inappropriate touching, including between children
  6. Be aware of the impact of your words and language on young children
  7. Do not swear, or use or respond to sexual innuendo; never make a sexually suggestive comment, even in fun
  8. Do not allow children to use inappropriate language unchallenged
  9. Be aware of situations in which actions can be misconstrued or manipulated by others (for example, being alone with the last child to leave a class); conduct all dealings with children in a public environment as much as possible, in order that all behavior can be readily observed
  10. Do not spend time alone with a child away from others; try to avoid being alone with a child, particularly in a restroom, changing area, or shower area (follow the "rule of three" and always make sure there is another person with you). Should you need to be alone with a minor in a changing or shower area, by no means should you be unclothed with a minor, and showering or bathing with minors, even when you are not alone with one, is never acceptable.
  11. Children should use a "buddy system" or otherwise be encouraged to stay together when going to the bathroom, on field trips, or when leaving the classroom area
  12. Do not give any child a ride in a car or van unless you have express permission from the parents
  13. Do not appear to favor one child more than another; do not give gifts to anyone child in a program; do not accept expensive gifts from any child in the program
  14. Be professional and maintain the highest standards of personal behavior at all times; do not drink alcohol or smoke when working with minors
  15. Do not tell children "this is just between the two of us" or use similar language that encourages children to keep secrets from their parent/guardians
6. What is Child Abuse?
  1. "Child abuse" is a term used to describe ways in which children are harmed, often by adults they know and trust.
  2. The effects of child abuse can be devastating, especially if children are left unprotected or do not receive help to cope with the abuse. The most serious effect is that children can (and do) die as a result of abuse. Children suffering from abuse may also develop behavioral difficulties, problems at school, delays in development, and emotional problems like depression and withdrawal.
7. Different forms of child abuse include physical abuse, neglect, sexual abuse, and emotional abuse.
  1. Physical Abuse
    - Intentionally hurting or inflicting physical injury on a child -this includes behaviors such as hitting a child, giving a child alcohol, inappropriate drugs or poison; attempting to suffocate or drown a child; and in sports, allowing the nature and intensity of training to exceed the capacity of the child's immature and growing body.
    - In its more common forms, physical abuse may be detected by signs such as:
      - Bruising which is recurrent and on parts of the body where accidental injury would be unlikely to occur
      - Injuries - marks, burns, scalds
    - These marks may be difficult for the child to explain and may have not been treated. They may also be covered by clothing and only noticed if the child removes clothing during exercise. Be aware of reluctance of a child to remove clothing in warm weather.
  2. Neglect
    - Failing to meet a child's basic physical needs (e.g., food, shelter, clothing)
    - Leaving children alone and unsupervised
    - Failing or refusing to give children love, affection or attention
    - Neglect may be a long-term problem, so in addition to awareness of a lack of care, it is important to notice physical and behavioral signs, such as failure to attain age-appropriate development.
  3. Sexual Abuse
    - Using children to meet adult sexual desires (sexual intercourse, masturbation, oral sex, fondling)
    - Showing children pornographic books, photographs or videos; or photographing or videotaping them for pornographic purposes
    - Children often feel responsible and ashamed and may find it difficult to reveal what has happened. Indicators may be physical (pain, discomfort) or behavioral -the child can seem inappropriately sexually aware for his/her age, or exhibit fear of a particular adult.
    - Also, be aware that in sports situations which involve physical contact (e.g., supporting or guiding child's body) there is the potential for situations where sexual abuse may go unnoticed.
  4. Emotional Abuse
    - Shouting, taunting or making cutting remarks directed at child
    - Persistent lack of love or affection
    - Constant and intense overprotection which prevents child from functioning normally
8. What if a Child Tells Me He or She is Being Abused?
  1. Stay calm; ensure that the child is safe and feels safe.
  2. Assure the child that you are taking what s/he says seriously
  3. Be honest; explain you will have to tell someone else to help stop the abuse. Avoid making promises you cannot keep.
  4. Make a note of what the child has said as soon as possible. Do not confront the alleged abuser.
  5. Do not investigate on your own.
  6. ALWAYS REPORT.
Appendix C – Background Checks for Those Interacting with Minors
1. Whom:
  1. The Program Organizer, whether the Program is sponsored by the University or an External Organization, will be required to conduct a criminal background check on all adults, including but not limited to faculty, staff, students and volunteers, who work with, instructor otherwise come into contact with Minors as defined in paragraph 3 below. These criminal background checks will be conducted by an agency selected by Human Resources. If a criminal record is revealed, Human Resources will contact the Program Organizer for appropriate action.
  2. Background checks must be completed and evaluated prior to the adult beginning work with Minors. The Program Director will be required to conduct criminal background checks on returning adults at least every four (4) years.
  3. The following categories of adults are required to undergo a criminal background check prior to their participation in University activities or programs involving Minors:
    - Program Directors for programs involving Minors, including those who are responsible for supervising volunteers, faculty and staff who interact with Minors;
    - Those who stay overnight with Minors as part of their job responsibilities in a program or activity involving Minors; and
    - Those who regularly spend time alone with Minors as part of their job responsibilities or role in a program involving Minors.
  4. Human Resources will oversee the processing of background checks for Regis University Employees. Auxiliary and Business Services (Risk Management) will cover the processing of background checks for students and student workers.
  5. The cost of the background checks for personnel associated with the University will be borne by the Program Director’s University’ Department or External Organization.
  6. Auxiliary and Business Services (Risk Management) will publish procedures by which University-run Programs involving Minors can request background checks.
  7. A background check performed by Rueckert-Hartman College for Health Professionals that otherwise meets the requirements of this policy may be used to meet the Policy’s requirement for a background check.
2. Type of Background Check:
  1. Background checks shall consist of a
    - social security number trace
    - address locator for seven years,
    - a search of the federal bureau of investigations
    - 50 state criminal history for the past seven years
    - National sex offender registry check.
  2. Background checks must be submitted, and results returned to the Program Sponsor before the personnel can work in a Program that has Minors.
3. Assessment of Background Check Results
  1. Any individual, who has been convicted of a violation of a Colorado statute enumerated below, or its equivalent in another state is prohibited from working in a Program that has Minors. The statutes are as follows:
    - Child abuse, as specified in Section 18-6-401, C.R.S.
    - A crime of violence, as defined in Section 18-1.3-406, C.R.S.
    - Any felony offenses involving unlawful sexual behavior, as defined in Section 16-22-102(9), C.R.S.
    - Any felony, the underlying factual basis of which has been found by the court on the record to include an act of domestic violence, as defined in Section 18-6-800.3, C.R.S.
    - Any felony involving physical assault, battery, or a drug-related/alcohol-related offense within the five years preceding the date of application for a license or certificate;
    - Has shown a pattern of misdemeanor convictions within the ten (10) years immediately preceding submission of the application. "Pattern of misdemeanor" shall include consideration of Section 26-6- 108(2), C.R.S., regarding suspension, revocation and denial of a license, and shall be defined as:
      - Three (3) or more convictions of 3rd-degree assault as described in Section 18-3-204, C.R.S., and/or any misdemeanor, the underlying factual basis of which has been found by any court on the record to include an act of domestic violence as defined in Section 18-6-800.3, C.R.S.; or,
      - Five (5) misdemeanor convictions of any type, with at least two (2) convictions of 3rd degree assault as described in Section 18-3-204, C.R.S., and/or any misdemeanor, the underlying factual basis of which has been found by any court on the record to include an act of domestic violence as defined in Section 18-6-800.3, C.R.S.; or,
      - Seven (7) misdemeanor convictions of any type.
    - A finding of mental insanity or incompetency by any court; or
    - Registration on a sex offender registry
  2. If a background check reveals adverse information or unfavorable results, an individualized assessment will be conducted, taking into account the following:
    - the nature of the finding;
    - the job for which the applicant is being considered;
    - the underlying event(s) that occurred;
    - the time elapsed since the finding;
    - the applicant’s employment history and other evidence of his or her activities in the intervening time since the finding; and other relevant information.
  3. Human Resources will oversee the review of background checks for Regis University faculty, staff, student employees, and volunteers, in consultation with appropriate departmental representatives and the Office of University Legal Counsel and, will make determinations in cases where the crime is not identified above, but a criminal background check reveals adverse information that is relevant to one’s participation in a program or activity covered by this Policy.
  4. For University-sponsored or affiliated programs or activities, only a background check conducted by the University or an external source approved by the University will be accepted for purposes of this Policy.
4. Camps
  1. In addition to conducting background checks, all Programs running a “Camp” for Minors using University Facilities must perform reference checks and conduct personal interviews. In addition, all Program Staff must sign an “Acknowledgment of Compliance with the University’s Minor Policy” form, Exhibit F.
5. Frequency
  1. Background checks for University employees and students who participate in University-sponsored or affiliated programs or activities involving Minors must be renewed every four (4) years.
  2. Employees who have a break in service of more than one (1) year and students who withdraw, are suspended or dismissed, or who take leaves of absence of more than one (1) year, will be required to undergo a new background check if they re-engage in University programs or activities involving Minors and would otherwise be required to undergo a background check pursuant to this policy.
  3. Except where required by law, criminal background checks of University faculty, staff and students will be used only for purposes consistent with this Policy and will otherwise be kept confidential. The record of information returned as a result of the background check will be maintained separately from an individual’s personnel or student file.
  4. Any employee or student who is required by this Policy to have a background check is under a continuing obligation, as long as he/she continues to participate in programs or activities involving Minors, to disclose immediately any new felony or misdemeanor conviction to the Program Organizer and Risk Management.
6. External Organizations
  1. Regis University requires all External Organizations to conduct Regis Required criminal background checks on all Program Staff working with Minors in accordance with this policy as well as provide additional insurance coverage for sexual misconduct.
  2. External Organizations shall review background checks of all Program Staff to determine if each staff member is eligible to work at an event involving Minors in accordance with these policies. External Organizations shall maintain the results of the background checks for five years and make them available to University at its request. If any background check conducted by an External Organization returns a conviction or other adverse information of any kind, the external program must inform the Sponsoring Unit in writing. The University, at its sole and absolute discretion, may exclude any Program Staff. External organizations must also submit a certification of compliance with the background check rules described herein, including that they have conducted background checks as set forth in this Policy and that they have disclosed all convictions revealed by background checks, prior to the start of any program or activity.
Appendix D – Obligations of Mandated Reporters
1. Certain individuals are mandated reporters who have additional obligations under Colorado law. Colorado 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 professional or official capacity anyone witnessing a child in a life-threatening situation should call 911 immediately. If it is not an emergency, call 1-844-CO-4-Kids or 1-844-264-5437 to report all concerns for a child's safety and well-being. These hotlines are typically available 24 hours a day, seven days a week.
2. Mandated Reporters Under Colorado Law (C.R.S. 19-3-304) include but are not limited to: physicians, psychologists, pharmacists, clergy, licensed professional counselors, licensed marriage and family therapists, nurses, law enforcement officers, school officials, registered nurses, physical therapist, athletic program coaches and personnel, social service workers, daycare workers and others. University faculty, staff or students who are working with Minors in their professional or official capacity and who have questions about whether they may be considered mandated reporters under Colorado law should contact their supervisor, program director, dean or vice president. The Office of University Legal Counsel is also available to provide advice and can be reached at (303) 964.5387.
3. If you are a mandated reporter, please familiarize yourself with the obligations of mandated reporter as follows:
  1. Training. Colorado law also requires mandated reporters to complete the Mandated Reporter Training offered by the CDHS Child Welfare Training System at www.coloradocwts.com
  2. 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. 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.
  3. Regardless of whether an individual is a mandated reporter, anyone can make good faith reports of known or reasonably suspected child abuse to their local police department, CDHS, or both.
Appendix E – Registration of Internal Regis Programs and Activities Involving Minors Form
Appendix F – Acknowledgement of Compliance with the Institution's Minor Protection Policies

Age	Day Camp	Overnight Camp
9-14	1:10	1:8
15-17	1:12	1:12