Chapter 16 – University Programs with Minors

(12/1/17; amended 10/23/18; 3/20/19; 5/20/22)

16.1 Purpose of Policy

(Amended 10/23/18; 5/20/22)

The purpose of this policy is to promote the well-being and security of minors entrusted to the university’s care during their participation in university programs with minors. This policy is intended to facilitate a safe, inviting, and productive environment in which all members of the university community can meet their needs and achieve their goals within the primary mission of the university. 

16.2 Definitions

(Amended 10/23/18; 5/20/22)
  1. “University programs with minors”: all programs and activities offered by student organizations or various academic, athletic, or administrative units of the university for participants under the age of 18, including, but not limited to, the hosting of an individual minor by an individual faculty or staff member, subject to the exclusions detailed below in II-16.3
  2. “Adult”: an individual 18 years of age or older.
  3. “Direct contact”:  interacting with, supervising, chaperoning, or otherwise overseeing minors in program activities or in recreational and/or residential facilities on behalf of the University of Iowa.
  4. “Minor”: an individual under 18 years of age, subject to the exclusions detailed below in II-16.3.
  5. "Pre-college course": a course offered exclusively as part of a pre-college program of study.
  6. "Research laboratory”: a university facility that provides controlled conditions in which scientific or technological research, experiments, and/or measurement may be performed.
  7. “Visitor”: an individual, regardless of age, in a university facility as defined in III-32 Visitors in the Workplace.
  8. “Volunteer”: an individual, regardless of age, who provides services to, or on behalf of, the university and has no legal duty to do so, has no personal interest or gain from the activity, and receives no compensation or consideration (except expense reimbursement) for the services provided.

16.3 Scope of Policy and Exclusions

(Amended 10/23/18; 5/20/22)

This policy applies to all university programs with minors, with the exceptions of the following:

  1. Minors who are visitors in the workplace (see III-32);
  2. Minors working for the university as employees;
  3. Minors who are either admitted for enrollment or enrolled at the university for post-secondary education (this exclusion does not apply to minors admitted for enrollment in or enrolled in pre-college courses)
  4. Minors attending events on campus or events sponsored by the University that are open to the general public;
  5. Minors on school/organization trips accompanied throughout the trip by an adult chaperone for their school/organization;
  6. Minors attending official admission events hosted by the university Admissions Office, such as Hawkeye Visit Days;
  7. Minors participating in pre-enrollment visitation or recruiting activities governed by NCAA or US Department of Health and Human Services regulations; 
  8. Minors receiving medical care or treatment at the University of Iowa; and 
  9. Minors who are human subjects in research studies as research subjects which are approved by the university’s Institutional Review Board (IRB). 

16.4 Registration and Approval

(Amended 5/20/22)

All university programs with minors must complete the following registration and approval requirements prior to hosting minors, unless the program qualifies for the alternate approval process as defined herein (see II-16.5 below):

  1. Be proposed by a 50 percent time or greater faculty or staff member; and
  2. Register and be approved by the appropriate authority (Office of the Executive Vice President and Provost) as defined in the Youth Programs Manual, Sports Camps and Clinics Manual, and/or  Guidelines for Minors Interning in Research Laboratories.

16.5 (Reserved for future use)

16.6 Background Screening

(Amended 5/20/22)

The following criminal background screening requirements apply to students, faculty, staff, and volunteers who are anticipated to have direct contact with minors in the course of their university activities.

  1. Criteria and process for determining who must be screened.
    1. Anyone, including but not limited to graduate/undergraduate student assistants, faculty, staff, volunteers, and consultants or contractors, who in the course of their university programs with minors duties or assigned responsibilities will or may have direct contact with minors is subject to criminal background screenings regardless of the supervision structure in place. 
    2. Colleges/departments/units and/or programs are responsible for determining who meets the criteria for undergoing a criminal background check. Each individual who meets the defined criteria shall be subject to the criminal background check, and its results will be evaluated for program participation by the appropriate dean, senior HR leadership representative, and direct supervisor. If the criminal background check reflects criminal history within the designated time period, the following offices will review the results and determine how to proceed: University Human Resources, Office of the General Counsel, and Office of the Executive Vice President and Provost. The Dean of Students will participate in any determination regarding a criminal background check report on a University of Iowa student. No adverse action will be taken without providing the individual a copy of the criminal background check report and an opportunity to respond to the report to correct errors and to provide context.
  2. Scope. 
    1. The senior HR leadership representative in each college or division shall use the designated university vendor to verify social security number and conduct a criminal background check for all university students, faculty, staff, and volunteers in compliance with the procedures set forth in III-9.3 Criminal Background Check at Point of Hire. As appropriate in individual instances, an alternate designated by the vice president or dean or, in the case of faculty, the Associate Provost for Faculty, may conduct the check.
    2. In the case of consultants or contractors, the criminal background check requirements shall be included in the contractual agreement between the university and the consultant or contractor.
  3. Timing/frequency. Screening must be done as follows:
    1. Initial screening:
      1. New employees at the point of hire.
      2. Returning/seasonal employees upon rehire.
      3. Consultants/contractors prior to commencing any project.
    2. Current employees: 
      1. All current employees determined to be subject to background screening will undergo a criminal background check and be required to complete a self-disclosure form upon implementation of this policy, unless an equivalent screening has taken place within the past year. 
      2. Internal job transfers or any change of duties that adds activities with direct contact with minors, prior to commencing those duties.
    3. Rechecks:
      1. All current employees determined to be subject to background screening will undergo a criminal background check at least every five years utilizing the designated university vendor.  
      2. A criminal background check will be conducted upon self-disclosure of criminal activity as discussed below in II-16.7.
      3. The university reserves the right to conduct background checks of current employees when it has reasonable grounds to do so (e.g., no recent check was performed, a workplace incident has occurred, upon self-disclosure of criminal activity, or upon the university being informed of such activity).
  4. Notice and authorization.
    1. Consistent with III-9.2 and III-9.3, job candidates are informed during the interview stage that employment at the university is contingent upon the successful completion of a background check and a check of their credentials. university students, faculty, staff, and volunteers are notified at the time they become subject to this policy’s background check requirements according to the criteria stated herein.  
    2. In accordance with federal law, the university must secure a signed authorization which permits the university to obtain background check results from a third-party reporting agency. Such authorization shall remain in effect for the duration of an individual’s employment with the university, unless or until employment duties no longer include contact with minors.

16.7 Self-Disclosure

(Amended 5/20/22)
  1. Self-disclosure form. Current university students, faculty, staff, and volunteers must complete a self-disclosure form at the time they are notified of background screening eligibility as defined above in II-16.6
  2. Ongoing self-disclosure requirement. Anyone whose work or volunteer duties/responsibilities as part of a university program with minors puts them in direct contact with minors must notify the unit’s/department’s senior HR leadership representative within 72 hours of any arrest or conviction of a serious misdemeanor or felony and/or any arrest or conviction that has or may have a nexus to their university activities involving minors. 

16.8 Training

(Amended 5/20/22)
  1. All university programs with minors staff whose job duties bring them into direct contact with minors must complete “Working with Minors” training at the time of hire and thereafter at least once every three years. This includes temporary/short-term program staff and volunteers.  
  2. University  programs with minors staff orientation must include discussions of the implications of these rules/guidelines specific to the operations of their program. 

16.9 Reporting

All University employees who in the course of employment receive information related to physical or sexual abuse of minors must immediately report such information in accordance with II-15 Physical and Sexual Abuse of Children.

16.10 Compliance

Violations of this policy may result in disciplinary action for a volunteer, employee, or college/unit/organization, up to and including probation, suspension, and/or termination of employment/volunteer duties, reassignment of duties to prohibit interaction with minors, or dissolution of any program involving minors. 

16.11 Minors on Campus Advisory Committee

(Amended 5/20/22)

The Minors on Campus Advisory Committee  monitors and provides guidance on the application of this policy to new and existing university programs with minors; creates operational procedures related to the registration, approval, and appeals processes for university programs with minors; and provides timely reviews of this policy in accordance with the requirements of this University of Iowa Operations Manual