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I. INTRODUCTION.

Cedarville University is a Christ-centered institution of higher education that transforms lives through excellent education and intentional discipleship in submission to biblical authority. The University is committed to the biblical principle that all human beings are created in the image of God, to the physical, mental, and emotional health of all persons, and the sacredness of human sexuality. Children, in particular, are a gift from God and the University recognizes they are a valued part of the campus community. Therefore, the University is committed to providing appropriate supervision to Minors involved in University sponsored programs, both on and off campus, and to non-University sponsored programs held on the University’s campus.

II. SCOPE.

1. This Policy applies to all university and non-university activities and programs, both on campus and off campus, in which Minors will be physically present and/or participating.
2. This policy also applies to visitors, guests, and non-university groups using any university property and/or University equipment.
3. Exceptions to this Policy – This Policy does not apply to the following:
   1. To University students who are under the age of eighteen (18) years of age. Instead, University students under the age of eighteen (18) years of age will generally be treated the same as other undergraduate and/or graduate students unless federal, state, or local law requires different treatment, which may be described in other University policies such as the University’s Title IX Policy
   2. To general public events where Parents and/or Legal Guardians are invited to University property and are expected to accompany and provide supervision to Minors in their care.
4. EFFECTIVE DATE. This policy is effective October 1, 2024

III. DEFINITIONS.

1. Acceptable Background Check: Must meet one of the two following requirements:
   1. No arrests, indictments, or convictions for any criminal felonies and/or misdemeanors; OR
   2. A written clearance from the University’s Criminal Background Committee (which consists of the Associate Vice President of Human Resources, the Director of Campus Security, and the University’s General Counsel) for any person with an arrest, indictment, or conviction for any criminal felonies and/or misdemeanors. The members of the Criminal Background Committee must have completed “skillful screening” training. If an applicant for an Authorized Adult has any arrest, indictment, or conviction for any criminal felony and/or misdemeanor on his/her criminal background check, the background check will be provided to the AVP of Human Resources and the Criminal Background Check Committee will review the background check and determine, in its sole discretion, whether the applicant may be an Authorized Adult under this policy.
2. Adequate Supervision: Appropriate oversight and supervision, including an adequate adult-to-child ratio, that is tailored to the age, maturity, needs of the Minor(s), and activities of the Minor(s). Adequate Supervision may vary depending on the ages of the Minor(s), the location, and the activities involved. Adequate Supervision accounts for environmental factors such as potential hazards, the need to keep children from being in isolated locations, exits, and the location of equipment. Adequate Supervision includes active engagement and communication with Minor(s). If Line-Of-Sight supervision is not utilized, then regular visual checks of the Minor(s) are required. Unless specifically provided in this policy, for children who have not completed 5th grade, a minimum of two, or more, unrelated Authorized Adults must be within Line-Of-Sight of the child(ren) being supervised and for children having completed 5th grade, children must in groups of at least 3 people.
3. Authorized Adult: An individual, paid or unpaid, that is authorized to supervise, chaperone, and/or otherwise oversee Minors in University and/or non-University programs and must meet all of the following requirements:
   1. Must be at least 18 years of age or be enrolled as a student at Cedarville University;
   2. Must have completed the Minors Policy Training;
   3. Must have a completed a background check and the background check must result in an Acceptable Background Check;
   4. Reference Checks:
      1. Non-University must perform at least two reference checks for each proposed Authorized Adults, ask the references the questions provided in Appendix “D” or equivalent in scope and substance, and certify to the University that reference checks were acceptable for each Authorized Adult.
      2. For University Programs, the Division Leader for any University Program involving minors will review the program annually and determine whether reference checks (at least two references checked by asking the questions listed in Appendix “D”) will be performed for adults working with Minors. In determining whether reference checks will be performed, the Division Leader will consider the following factors:
         1. Whether adults will have minors staying overnight in the adults room; and
         2. The length of time of the relationship between the adult and the University.
   5. Must certify he/she satisfies the above requirements, has reviewed, understands, and will comply with this policy, and understands his/her responsibilities as a mandatory reporter.
      1. Non-University Programs must certify to the university director that each adult participating in the program satisfies these requirements, has reviewed, understands, and will comply with this policy, and understands his/her responsibilities as a mandatory reporter (see Appendix “B”).
      2. For University Programs, must have signed a Certification (see Appendix “A”) and provide it to the appropriate University Director stating that he/she satisfies these requirements, has reviewed, understands, and will comply with this policy, and understands his/her responsibilities as a mandatory reporter.
4. Background Check:
   1. Unless a different background check is permitted by the University’s Director, a background check must include, at a minimum, a screening consisting of the following:
      1. County criminal search for the last five years of the applicant’s address history;
      2. Search of county, municipal, and common pleas courts;
      3. Report of all reportable records including, but not limited to, any crime of a sexual nature and/or harm to a minor and all felonies, regardless of time;
      4. Report of all reportable non-convictions;
      5. The National Criminal Database;
      6. The National Sex Offender Registry;
      7. A Social Security Number trace and validation; and
   2. For all adults applying to be an Authorized Adult, the background checks must be completed within the time periods described as follows:
      1. For an adult that is not an employee of the University, the background check must have been conducted within the prior 24 months.
      2. For an adult that is an employee of the University, the background check must have been conducted within the prior 3 years.
   3. Non-University Programs are responsible to pay for all backgrounds checks for individuals working in the Non-University program.
   4. University Programs are required to provide the names of Authorized Adults to Human Resources to ensure that current University employees have current background checks and training and so that employees and non-employees working in a University Program will have current background checks and training.
5. Inappropriate Conduct: includes any conduct prohibited by this Policy including, but not limited to, the following:
   1. Physical abuse, sexual abuse, and/or neglect of a Minor;
   2. An Authorized Adult having One-On-One contact with a Minor, unless specifically authorized by this Policy or if the Authorized Adult is the Parent or Legal Guardian of the Minor;
   3. An Authorized Adult entering a Minor’s overnight room (such as a dorm room), bathroom facility, locker room, or similar area without another Authorized Adult in attendance;
   4. Abusive conduct of any kind toward a Minor such as, but not limited to, striking, hitting, administering corporal punishment, or touching in an inappropriate or illegal manner.
6. Line-Of-Sight: The maintenance of constant visual contact. In this policy, it usually means supervision and oversight where an Authorized Adult maintains constant visual contact with the Minor(s) he/she is supervising.
7. Minor: A person under the age of eighteen (18) who is on University owned property, using University owned equipment, or is in a University or non-University Program. However, undergraduate University students are not considered to be a Minor under this policy.
8. Minors Policy Training: Training must include the following:
   1. A review and complete understanding of this Policy;
   2. Training regarding physical and sexual abuse/neglect of Minors, which must include, but not be limited to, general sexual abuse awareness training and peer-to-peer abuse awareness training (the University reserves the right to require a specific course regarding physical and sexual abuse/neglect of Minors);
   3. Requirements on when, and how, to report physical abuse, sexual abuse, neglect, and all conduct prohibited by this Policy; and
   4. Training in how to respond to an emergency situation and how to summon emergency and/or medical assistance while on University property or using University equipment.
9. Non-University Program(s): Activities that will potentially include Minors as participants that are offered by an entity other than the University that will take place on University property and/or use University equipment through a contract, license, or other agreement with the University. “Program” includes, but is not limited to, workshops, sports camps, academic camps, conferences, pre-enrollment visits, internships, and church camps. However, “Program” does not include a non-University entity that rents University property for no more than one day at a time. The use of the word “Program” in this policy includes leadership for the Program when used in that context.
10. One-On-One Contact: Personal, unsupervised interaction between an adult and a Minor participant without at least one other authorized adult, Parent, or Legal Guardian being present. For purposes of this definition, another adult is deemed “present” if the adult is within line-of-sight of the adult interacting with the Minor.
11. Program Director: An individual designated by the Program to be ultimately responsible for the activities of the Program, to be ultimately responsible for communicating with the University, and that the University will communicate with in the case of an emergency. All Program Directors must have completed “skillful screening” training.
12. Retaliation: Any action with the purpose of intimidating, threatening, coercing, or discriminating against any individual because the individual reported inappropriate conduct under this Policy.
13. University: Cedarville University, Cedarville, Ohio.
14. University Director: The University Director is determined by the following:
    1. If the Program is operated by, or through, the Academic Division, the University Director is designated by the Vice President for Academics;
    2. If the Program is operated by, or through, the Athletic Division, the University Director is designated by the Vice President for Athletics; and
    3. If the Program is a non-University Program, the University Director is the Director of Campus Experience, or his/her delegate.
15. University Equipment: Any equipment or item owned by, or under the control of, the University.
16. University Program(s): Activities that will potentially include Minors as participants that are offered by one of the various academic, athletic, or administrative units of the University, that will take place on University property, use University Equipment, or be officially sanctioned by the University regardless of the location. “Program” includes, but is not limited to, workshops, sports camps, academic camps, conferences, pre-enrollment visits, internships, and church camps. The use of the word “Program” in this policy includes leadership for the Program when used in that context. University Program does not include athletic events hosted by the University when Minors are not sleeping overnight on University Property such as, but not limited to, tournaments or track meets involving high schools and middle schools.
17. University Property: Any real property owned by, or under the control of, the University.
18. Vehicle: A vehicle authorized to operate on public roads such as cars, vans, trucks, and buses, but not including items such as golf carts.

IV. GENERAL REQUIREMENTS FOR ALL MINORS ON CAMPUS EVEN IF NOT IN A PROGRAM.

1. Parents and/or Legal Guardians are responsible for all aspects of the Minor’s behavior at all times while the Minor is in a University Program, on University Property, and/or while using University equipment, which includes the following:
   1. The supervision and safety of the Minor;
   2. Being financially responsible and liable for any damages to University Property or equipment caused by their child; and
   3. Being financially responsible and liable for any damage to another person or property owned by another person.
2. Any Minor who has not completed 5th grade, including children of employees and/or students, must be supervised (Line-Of-Sight) by a Parent, Legal Guardian, or adult approved by the Minor’s Parent or Legal Guardian at all times while on University Property and/or while using University Property. Minors who have completed 5th grade may access public areas and spaces of University Property but should not enter private locations or dorms without supervision unless the presence on campus is part of an organized Program.
3. Minors who have completed 5th grade or older are to behave consistent with the same standards of conduct that apply to undergraduate students.
4. Pursuant to the conditions and responsibilities as described in this Policy, Minors are permitted at events and venues open to the public; however, the University reserves the right to determine, in its sole discretion, whether selected events or venues are inappropriate for Minors.
5. Minors under the age of 14 are not permitted to stay overnight on University Property unless the Minor is staying with a Parent or Legal Guardian or unless the Minor is staying on campus as part of a Program, in which case Minors must have completed 5th grade in order to stay overnight on University Property without a Parent of Legal Guardian.
6. Unless specifically provided by the University or a Program and under appropriate supervision, Minors are prohibited from being in laboratories, mechanical rooms, storage rooms, garages, food preparation areas, University-owned vehicles, and areas containing power tools and/or machinery with exposed moving parts.
7. A Coach(es) that accompanies his/her/their sports team to campus for a sports camp must be, or become, an Authorized Adult (satisfy all the requirements for an Authorized Adult).
8. Mandatory Reporting Requirements:
   1. If the circumstances may be life threatening, immediately dial 911.
   2. Every person is required to report to law enforcement and the University’s Title IX Coordinator (appropriate contact information is available and contained in Appendix “C”) any, and all, knowledge, or suspicions, that a child under the age 18, or a person under the age 21 with a developmental disability or physical impairment, has suffered, or faces a threat of suffering, any physical or mental wound, injury, disability, or condition of a nature that reasonably indicates abuse or neglect of a child. Abuse that must be reported includes, but is not limited to, the following:
      1. Physical Abuse: Acts or omissions that cause, or fail to prevent, a serious physical injury to a Minor.
      2. Sexual Abuse: Rape, sexual assault, molestation, incest, indecent exposure, or exploiting (tricking, forcing, manipulating, and/or coercing) a child in a manner in which the child is used for gratification or sexual enjoyment of another person.
      3. Emotional or Mental Abuse: Actions or omissions that have an actual or likely severe negative impact on a child’s emotional and/or behavioral development including those resulting from persistent or severe emotional mistreatment.
      4. Neglect: A severe or persistent failure to provide for a Minor’s physical, emotional, or basic needs; however, it is not neglect if the actual, or suspected, injuries result solely from economic or environmental factors that are beyond the Parent’s or Legal Guardian’s control.
   3. In addition, any person who witnesses any form of inappropriate conduct, or a violation of this Policy will immediately report the incident or violation to the University’s Director of Campus Security and to the Program’s Director. The University’s Director of Campus Security will report the incident, as appropriate, to Campus Experience, to the University’s Title IX Coordinator, and/or to any other appropriate official of the University.
9. Allegations of Inappropriate Conduct.
   1. If an incident and/or allegations involves Mandatory Reporting, as described in this Policy, then the person must make the Mandatory Report;
   2. If an allegation of inappropriate conduct has been made against an individual, that individual may not participate, or continue to participate, in any Program on University property or using University equipment whether as an Authorized Adult, Minor participating in the program, a spectator, or any other involvement, until such allegation has been resolved to the satisfaction of the University, unless the accused individual is a University student or employee and the processes and procedures of the University’s Title IX Policy apply and will be followed;
   3. Upon receiving an allegation of inappropriate conduct by an Authorized Adult, the University’s Director of Campus Security will, in consultation with the University’s General Counsel, refer the matter to an appropriate University Division, Department, and/or employee(s) for resolution; and
   4. Any, and all, allegations of sex discrimination, sexual harassment, and/or sexual abuse are subject to the University’s Title IX Policy; therefore, if the alleged inappropriate conduct and/or the accused individual is a University student or employee and the University’s Title IX Policy applies, then the University’s Title IX Policy will supersede this Policy, and the policies and procedures of the Title IX Policy will be followed. J. Retaliation against any person who reports inappropriate conduct is prohibited. The University may discipline or sanction any person that engages in retaliation.

V. PROGRAM (UNIVERSITY PROGRAM AND NON-UNIVERSITY PROGRAM) REQUIREMENTS FOR MINORS ON CAMPUS.

1. The Program must provide “adequate supervision” of all Minors in the Program while they are on University property or using University equipment, including having an adequate number of Authorized Adults to operate the Program and to provide “adequate supervision.”
2. Programs will not allow any adult that is not an Authorized Adult to work in, volunteer in, or be in any way involved in the Program. Adults who are not Authorized Adults may be spectators at a Program but are not permitted to be alone with a Minor unless he/she is the Parent or Legal Guardian of the Minor.
3. All Authorized Adults participating in a Program are required to, at all times, comply with the following:
   1. Must report any violations of this policy, inappropriate conduct, and/or child abuse/neglect to the University’s Director of Campus Security and the Program Director.
   2. Must be on the lookout for, and report, any Peer-To-Peer physical and/or sexual abuse to the University’s Director of Campus Security and the Program Director, and, if appropriate, to the University’s Title IX Coordinator.
   3. Not have One-On-One Contact with a Minor, unless specifically authorized by this Policy or if the Authorized Adult is the Parent or Legal Guadian of the Minor.
   4. When a Minor is present, do not enter a Minor’s overnight room (such as a dorm room), bathroom facility, locker room, or similar area without another Authorized Adult in attendance.
   5. Not take photograph(s), digital image(s), or video(s) of Minors without prior written permission from the Minor’s Parent(s) or Legal Guardian(s).
   6. Not engage in private communication (telephone, email, text message, social media, etc.) with a Minor unless there is a clear purpose related to the Program.
   7. Not meet with a Minor(s) outside of established times for the Program unless:
      1. There is a prior written consent from the Minor’s Parent or Legal Guardian; or
      2. There is a prior relationship between the Authorized Adult and the Minor that is well known to, and accepted by, the Minor’s Parent or Legal Guardian.
   8. Not engage in abusive conduct (such as striking, hitting, administering corporal punishment, or touching in an inappropriate/illegal manner) toward, or in the presence of, a Minor.
   9. Not possess fireworks, firearms, knives with blades over 3 ½ inches, and/or other weapons unless expressly permitted by the University.
   10. Not engage in the use, or consumption, of alcohol, tobacco, or the non-medical use of drugs and will not be under the influence of alcohol or drugs while on University property and/or using University equipment.
   11. Not engage in vaping while on University property and/or using University equipment.
   12. Not assist Minors in obtaining or gaining access to alcohol or recreational drugs.
   13. Not possess, have within reach, and/or share sexually oriented or morally inappropriate printed or computerized or portable materials (magazines, cards, videos, films, pictures, clothing, smartphones, etc.) in any form available to Minors and will not assist Minors in any way in gaining access to such materials.
4. Prior to a Minor participating in the Program, the Program must have, for each Minor involved in the Program, the following:
   1. Personal information for the Minor including, but not limited to, the Minor’s legal name, age, and address;
   2. Emergency contact information for the Minor;
   3. A waiver or release form signed by a Parent or Legal Guardian; and
   4. An authorization signed by a Parent or Legal Guardian allowing Program personnel to obtain and authorize medical treatment for the Minor.
5. Use of the University’s Computer Network or Software.
   1. If a Program will be granting Minors access to the University network, the Parent of Legal Guardian of the Minor must sign a release and permission form granting the Minor permission to use the University network.
   2. If a Program will allow Minors to use a third-party software, then the Program must review the applicable terms and conditions of the software to determine whether additional permission from a Parent or Legal Guardian is required and, if so, obtain said written permission from a Parent or Legal Guardian.
6. Minors on campus are only permitted to use the facilities allowed by the Program and are prohibited from being in facilities not related to the Program. In addition, unless there is prior permission and adequate supervision Minors are prohibited from using equipment without permission and from being in areas such as, but not limited to, laboratories, mechanical rooms, storage rooms, garages, weight rooms, food preparation areas, University-owned vehicles, and areas containing power tools and/or machinery with exposed moving parts.
7. When Minors are using the bathroom or locker room, the following apply:
   1. Unless authorized by this policy, Authorized Adults are prohibited from being in a bathroom and/or locker room with Minors from the Program;
   2. If a Minor needs assistance for using the bathroom or if an incident occurs in a bathroom/locker room requiring adult intervention, an Authorized Adult may be in the bathroom/locker room solely to assist the Minor or intervene in the incident and only with another unrelated Authorized Adult that is in the line-of-sight of the Authorized Adult;
   3. When Minors from the Program are using bathrooms and/or locker rooms, the door(s) should be open, and an Authorized Adult should be located outside the bathroom and/or locker room to provide verbal supervision from outside the bathroom and/or locker room;
   4. Bathroom stalls and showers should never have more than one person in them at a time.
8. Minors are not permitted to “hang out” or loiter in bathrooms, locker rooms, or showers.
9. For transportation of Minor(s) from the beginning of the Program until the end of the Program on campus in a vehicle by a non-University Program and for all transportation, on or off campus, by a University Program, then the following is required:
   1. A Minor will not be transported in a vehicle other than a vehicle operated by the Minor’s Parent or Legal Guardian except as specifically authorized in writing by the Minor’s Parent or Legal Guardian or in the case of an emergency.
   2. Only Authorized Adults operating with a valid driver’s license may transport a Minor in a motor vehicle (vehicle authorized to operate on public road such as cars, van, trucks, and busses, but not including items such as golf carts);
   3. Any driver of a University owned vehicle must be authorized by the University to operate said vehicle;
   4. An Adult is never allowed to be alone in a vehicle with one or two Minors;
   5. If transportation is being completed by using one vehicle, then there must be at least two Authorized Adults in the vehicle whenever a Minor is in the vehicle; and
   6. If transportation is being completed using more than one vehicle, the Program may permit one Authorized Adult to be present in the vehicle as long as there is at least three other people in the vehicle, at least one Authorized Adult in each vehicle, and at least two Authorized Adults involved in the transportation.
10. The Program must provide the University Director with contact information for the Program Director.
11. The Program must have a procedure for the notification of a Minor’s Parent or Legal Guardian in the case of an emergency including, but not limited to, medical issues, behavioral issues, or program changes or disruptions. The program must communicate to parents or guardians how they may reach their minor in the event of an emergency.
12. The program must maintain a protocol regarding steps to take in the event of an emergency on campus (e.g., fire, tornado, etc.), including shelter in place locations within each facility used by the program.
13. The program must maintain a protocol regarding response to behavioral health crises, including response to threats to self or others.
14. The Program must give the Parent(s) and/or Legal Guardian(s) of each Minor the name and contact information of the Program Director.
15. The Program must provide the University Director with a written certification stating that all Authorized Adults have completed the Minor’s Policy Training and Acceptable Background Check. The certification to be provided is attached as Appendix “B”.
16. The Program must establish a procedure for the pick-up and drop-off of Minors involved in the Program.
    1. The said Procedure will specify times and locations for pick-up and drop-offs;
    2. No Minor who has not completed 5th grade will be released to any person other than the Minor’s Parent or Legal Guardian without prior authorization allowing the Minor to be released to another person; and
    3. The Authorized Adults overseeing the pick-up and drop-off of the Minors in the Program will remain at the specified location until all Minors have been properly released.
17. If Minors in a Program are permitted to leave University property, the Program must give the Minors specific instructions on the locations that Minors may go to, and Minors must be adequately supervised (as provided in the definitions) just as though the Minors are on University property.
18. The Program must have a method for administering medications to the Minors that will comply with the following:
    1. The need for medication must be documented in writing and the parent or Legal Guardian must sign an authorization allowing the administration of any medication, both prescription and over the counter;
    2. Any prescription medication must be prescribed by a licensed physician and there must be details for administration including the name of the medication, dosage, and administration schedule;
    3. All prescribed mediation must be provided to the Program in its original container labeled with the Minor’s name, medicine name, dosage, and administration schedule;
    4. Over the counter medications must be provided in the manufacturer’s original container;
    5. All medications, both prescription and over the counter, must be stored by the Program in a locked container or area that is not accessible to children;
    6. If a medication requires refrigeration, it should be sorted in a secure, temperature-controlled refrigerator, separate from food items;
    7. Medication must be administered only by a nurse or Program staff member that is trained in proper medication and administration procedures, which includes understanding dosage, timing, and recognizing potential side effects;
    8. The Program must maintain a written log of all medications administered, including the time, dosage, and name of the staff member administering the medication;
    9. The Program must have a plan for administering emergency medications, such as epinephrine (EpiPen) or asthma inhalers;
    10. The Program must, as soon as possible, ensure parents and/or Legal Guardians are informed of any medication administration issues, such as missed doses or adverse reactions;
    11. All unused medication must be returned to the parent and/or Legal Guardian; and;
    12. Minors may possess “epi” pens and inhalers.
19. If the Program has received a report, or has any knowledge of, any person including, but not limited to an adult or a Minor in the program, engaging in inappropriate conduct or violating this Policy in any way, the Program is to immediately report it to the University’s Director of Campus Security.
20. Exceptions only to this Section regarding “Program Requirements For Minors On Campus” include the following:
    1. Programs offered by Enrollment Management and offered to Prospective Students including, but not limited to, siblings of current students. If Enrollment Management offers a Program to Prospective Students that includes a Minor(s) staying overnight on University property, then Enrollment Management and the Program are responsible for establishing procedures for adequately supervising Minors on University property and reducing the opportunity for a Minor to be the victim of physical and/or sexual abuse.
21. Programs that are primarily directed to, and primarily involving families, do not have to comply with this Section (Program Requirements for Minors on Campus); however, said program is still directly responsible for adequate supervision of all Minors on University property or using University equipment.

VI. UNIVERSITY PROGRAMS USING UNIVERSITY EMPLOYEES AND/OR STUDENTS.

1. Music Instruction. For music lessons provided to a Minor on University Property or using University Equipment, the following apply:
   1. The person providing the music lessons must meet all the requirements of an Authorized Adult.
   2. A person providing music lessons is exempted from the prohibition of one-on-one contact with the Minor receiving lessons; however, individual musical instruction should only occur in a faculty member’s office, practice rooms, or studios that have doors with windows that are not covered or otherwise creating an obstructed view.
   3. Other than as provided in this sub-section, all other provisions of this policy apply to music lessons.
2. University Employees and/or Students Working with Minors Off of University Property. On a regular basis, University Employees and Students work with Minors off of, or away from, University Property, such as, but not limited to, students at a church, music teams at camp, or GO Teams. Any time a University Employee or a University Student is significantly working with Minors away from University Property under the authority of the University, any University Employee and/or Student must meet all the requirements of an Authorized Adult. Significantly working with Minors does not include a short term event (a few hours and not including an overnight) where Minors are present, such as Employees and/or Students performing a concert, speaking, or participating in a seminar.