Youth Protection

Youth Protection Policy 

1.0 Introduction

California State University Dominguez Hills (CSUDH) has a wide range of activities including camps, clinics, workshops, and conferences, all of which may have persons under the age of 18 as the majority of participants or attendees. CSUDH strives to offer safe and enjoyable educational environments for youth. In support of that goal, CSUDH is committed to protecting youth who participate in CSUDH organized programs. CSUDH has zero tolerance for the abuse or mistreatment of youth.

2.0 Purpose and Scope

The purpose of these guidelines is to establish standards and protocols for the safety and protection of youth, to guide staff and volunteer conduct, and to facilitate the identification of high-risk interactions and program characteristics. These guidelines apply to University and Auxiliary sponsored activities which may take place on campus or off campus as well as to activities and events sponsored by a third party that take place on campus.

3.0 Definitions

• Care, Custody and Control: When an individual has primary responsibility for supervision of a youth at any given point throughout the activity or youth program.
• Chaperone: A person who accompanies and looks after a minor(s).
• Child Abuse or Neglect: Refers to physical injury or death inflicted by other than accidental means on a child; sexual assault or sexual exploitation of a child including sexual intercourse between a child under 16 years of age and a person 21 years of age or older, lewd or lascivious acts, and child molestation; negligent treatment or the maltreatment of a child by a person responsible for the child's welfare under circumstances indicating harm or threatened harm to the child's health or welfare; willful harming, injuring, or endangering a child; and unlawful corporal punishment.
• Live Scans: Live scans are to be conducted in accordance with CSU Technical Letter HR 2017-17.
• One-on-One Interaction: any intentional interaction where an Authorized Person is alone with a youth.
• Program Sponsor: The Program Sponsor is the appropriate University administrator or Third Party responsible for authorizing the Program and ensuring the Program follows the criteria set forth in these guidelines. The Program Sponsor will be identified as a central contact for Program information.
  • A Program Sponsor should be pre-designated for any program.
  • A Program Sponsor can delegate the management of certain components of a Youth Activity to a Program Director. The delegation is limited to the general oversight, day-to-day planning, coordination, and implementation of the Program and its essential components and does not alleviate the Program Sponsor from ultimate responsibility for applying these guidelines to their program.
• Program Staff: Authorized administrators, faculty, staff, and/or students over the age of 18 who work with, supervise, chaperone or otherwise oversee Minors on campus.
• Program Supervisor: The person responsible for planning the activities intended for minors whether for a university-affiliated program or a third-party entity. The Program Supervisor has the authority for making decisions concerning the program and is responsible for ensuring that protection of minors is the top priority.
• Third Party or Co-Sponsored Programs: A third party is an off-campus entity who is utilizing resources/facilities on campuses to operate a youth program. A Co-sponsored activity is a partnership between University and a Third Party.
• Program Director: The Program Director, e.g., Faculty, Director, provides general oversight of the program and manages day-to-day planning, coordination, and implementation of the program and its essential components, if so, delegated by the Program Sponsor.
• University Facilities: Facilities owned by, leased to, or under the direct control and supervision of the University or any of its Auxiliaries.
• Volunteers: Participants working with minors who are not Program Staff. Prior to participating in a campus activity involving minors, volunteers must read and sign the Volunteer Identification Form
• Youth/Minor: The term “youth,” utilized interchangeably with “minor” throughout these guidelines, represents any person under 18 years of age who is not a matriculated student of CSUDH. Matriculated students will include dual enrollments.
• Youth Program/Youth Activity: An activity or event conducted or organized by the University, Auxiliary or Third Party that includes youth during which the University, Auxiliary or Third Party assumes the responsibility for the care, custody and control of youth participants. "Youth Program or Youth Activity" does not include (1) activities or events which parents, guardians, affiliated program leaders (e.g., schoolteacher, counselor) are responsible for the care, custody, and control of youth participants, or (2) private, personal events (e.g., birthday parties, weddings) that occur at University facilities, or (3) events open to the general public (e.g., intercollegiate athletic events, concerts, class tours).
• Youth Program Types:
  • On-campus activities sponsored by campus departments: Activities involving youth that occur on campus and that are directed, sponsored, or overseen by a campus department or program involving campus employees and/or volunteers.
  • Off-campus activities sponsored by campus departments: Activities involving youth that occur off campus and that are directed, sponsored, or overseen by a campus department or program involving campus employees and/or volunteers.
  • On-campus activities sponsored by external third parties: Activities involving youth that occur on campus and that are directed, sponsored, or overseen by a non-campus entity.

4.0 Program Registration

All programs engaging in youth activities must register prior to beginning any programming activities that involve youth.
To register, a Youth Activities Program Registration Form should be completed and submitted to Risk Management at riskmanagement@gafmacademy.com no later than 30 days prior to the projected start of program activities. Please find the registration procedure here.

5.0 Screening and Selection

Program Directors shall screen prospective employees using youth abuse protection best practice:

• A standard application designed to screen for abuse.
• Face-to-face interviews using behaviorally based, standardized questions designed to assess for potential risk to abuse.
• A minimum of three references, at least of one of which is personal. References must be asked behaviorally based questions that assess abuse risk.

6.0 Live Scans

All employees and volunteers working directly and having access to youth must complete a Live Scan prior to working in their role. Live Scan enrollment is completed by campus Human Resources for campus side employees and Toro Auxiliary Partners Human Resources for Toro Auxiliary Partners employees.

Risk Management will forward the list of personnel provided in the program application/registration form to both HR departments who will then work directly with the employee and/or their supervisor and notify Risk Management after the process is complete. Campus Human Resources can be reached at hrm@gafmacademy.com. Toro Auxiliary Partners Human Resources can be reached at auxiliarypartners.hr@gafmacademy.com.

7.0 Training

Training helps to ensure staff and volunteers have the knowledge and skills to keep youth safe and minimize the potential for abuse in the program. All employees and volunteers working with youth must complete youth abuse prevention training assigned in Praesidium Academy.

Program directors are responsible for forwarding the list of employees and volunteers working with youth and who are required to take training, to Risk Management. The training shall be assigned and completed annually and prior to the employee’s activities with youth. Toro Auxiliary Partners employees shall be assigned training by Toro Auxiliary Partners HR and Risk Management shall forward those employee names to Toro Auxiliary Partners HR.

8.0 Third Party Facility Leases

9.0 Mandatory Reporting

Pursuant to CSU Executive Order 1083 certain employees must report incidences of abuse as specified in the California Child Abuse and Neglect Reporting Act (CANRA).

All Management Personnel Plan (MPP) employees and all volunteers are considered Mandated (Limited) Reporters, unless they are in positions that require the General Reporter designation (e.g., employees whose duties involve regular contact with children or who supervise such employees). All Limited and General Reporters are Mandated Reporters which requires them to report observed, or suspected, child abuse and/or neglect.

General Reporters are legally required to report child abuse or neglect no matter where it occurs. Limited Reporters are legally required to report child abuse or neglect only if it occurs on CSU premises or at an official activity of, or program conducted by, the CSU.

Under CANRA, the following incidences must be reported:

• Physical injury inflicted by other than accidental means on a child.
• Sexual abuse meaning sexual assault or sexual exploitation of a child.
• Neglect meaning the negligent treatment or maltreatment of a child by a parent or legal guardian under circumstances indicating harm or threatened harm to the child’s health or welfare.
• Willful harming or injuring or endangering a child meaning a situation in which any person inflicts, or willfully causes or permits a child to suffer, unjustifiable physical pain or mental suffering, or causes or permits a child to be placed in a situation in which the child or child’s health is endangered.

Before making a report, a reporter does not need to conduct their own investigation or be certain that mistreatment has occurred. Their report of suspected child abuse must be made to University Police immediately or as soon as practically possible. University Police can be reached at (310) 243-3639. Mandated reporters are not civilly or criminally liable for their reports (Penal Code § 11167(d)).

After making the report to University Police, employees must complete and submit the Department of Justice form SS 8572 (Attachment D of Executive Order 1083) to University Police within 36 hours of coming into information regarding the incident of suspected abuse or neglect. Mandated Reporters must also report any suspicious or inappropriate behaviors on the part of other employees, volunteers or other youth, immediately, or as soon as practically possible by contacting the University Police Department (310) 243-3639. Individuals who knowingly or intentionally file a false report or provide false or misleading information in connection with an investigation may be subject to disciplinary action up to and including termination of employment, or expulsion. Failure to report may result in criminal penalties.

The Clery Act also requires individuals designated as Campus Security Authorities (CSAs) to immediately report any Clery crimes reported to them and that occur on campus Clery geography. Clery crimes should be reported to the campus Clery director using the Clery Incident Reporting Form.

All employees are also Responsible Employees under the Interim CSU Policy Prohibiting Discrimination, Harassment, Sexual Misconduct, Sexual Exploitation, Dating Violence, Domestic Violence, Stalking, and Retaliation, and have a duty to promptly report all information available about incidents falling under this policy to the Title IX Officer in the Office of Equity & Inclusion. Employees should report incidents at http://rogmkd.gafmacademy.com/equity/report-incident/ or (310) 243-1025.

10.0 Parent/Guardian Participation Agreement & Liability Waiver Form

For all campus programs that involve youth, the adult parent or legal guardian is required to sign and submit a university participation agreement and liability waiver prior to the youth participating in the program. The Program Director is responsible for ensuring the program retains the forms and keeps them on file for all applicable program participants.

The Program Director shall also submit the Liability Waiver via email to Risk Management at riskmanagement@gafmacademy.com.

11.0 Program Staff Code of Conduct

Employees and volunteers working with youth shall abide by the following conduct guidelines:

• Employees and volunteers shall not engage in inappropriate sexual touching, comments, jokes or sharing sexually explicit materials with youth including printed or online pornography.
• Employees and volunteers shall not touch youth in a manner that a reasonable person could interpret as inappropriate as outlined in this policy. Any touching should generally only be done in the open and in response to a youth’s needs.
• Employees and volunteers should never be alone with a single youth. Interactions should follow the “rule of three”, two youth and one adult is acceptable, but the preference is there be two adults whenever possible. If a one-on-one interaction is required, it must be authorized in writing by a program supervisor.
• Youth-to-youth and youth-to-adult meetings should be in open, well illuminated spaces or rooms with windows that are observable by other authorized program staff.
• Non-program contact with youth is not permitted under any circumstance unless approved in writing by the program sponsor to the program Director or approved in writing by the adult parent or legal guardian of the youth. Campus employees and volunteers must follow the same code of conduct for permitted non-program contact.
• Employees and volunteers will not use profanity or tell off-color jokes.
• Employees and volunteers will not discuss their sexual encounters or dating history with or around youth or in any way involve youth in their personal problems or issues.
• Employees and volunteers will not date or become romantically involved with youth.
• Employees and volunteers will not use or be under the influence of alcohol or illegal drugs in the presence of youth in programming, while supervising youth programming, or while youth are in the care, custody, or control of youth programming.
• Employees and volunteers will not have secrets with youth.
• Employees and volunteers will not stare at or comment on youth’s bodies.
• Employees and volunteers will not engage in inappropriate electronic communication with minors. Employees and volunteers will never share personal contact information with youth. Employees and volunteers will use university issued email for all correspondence with youth if necessary and follow the rule-of-three while engaging in correspondence with youth.
• Employees and volunteers are prohibited from having photos of youth on their personal cell phones or devices.
• Employees and volunteers are prohibited to have any contact with youth in the program outside of their youth program responsibilities. Employees and volunteers are not allowed to exchange personal contact information with youth or parents.
• Employees and volunteers are not allowed to communicate with youth via social media.

12.0 Procedures

12.1 Physical Contact

Physical contact can be essential to the youth’s well-being and self-esteem. This guide provides appropriate and inappropriate contact types. Appropriate touching should only be done if the youth is comfortable with it.

12.2 Verbal Interactions

Employees and volunteers should not speak to youth in a way that is, or could be construed by any observer, as harsh, coercive, threatening, intimidating, shaming, derogatory, demeaning, or humiliating.

Employees and volunteers may not initiate sexually oriented conversations with youth. The University’s guidelines for appropriate and inappropriate verbal interactions are:

12.3 Digital Communication

Email: Employees should only use University assigned email accounts for communicating with youth in youth programs and for program activities. Personal email accounts should not be used for program activities. The program supervisor must be copied on all correspondence sent to youth, and parents or guardians should be copied whenever possible.

Phones: University owned devices should be used to the greatest extent possible. If not available, the communication method should be changed to email as much as possible. Only if absolutely necessary and with approval of supervisor, text messages should be sent to parents or guardians and the program supervisor should be copied on all messages.

Social media: Only University sponsored, or owned accounts should be used to interact with youth. The use of personal accounts to interact with youth participants is prohibited.

Do not respond to unsolicited contact from a program youth’s personal account, email or phone. Use the protocols described above in that scenario. If contact by youth via electronic communication, notify supervisor.

12.4 Bathroom Use

For minors aged twelve and under, an adult chaperone should escort two or more minors to the bathroom for group bathroom breaks. The adult should not send in more minors than the number of stalls and/or urinals in the bathroom. As one student exits the bathroom, another may enter. The supervising adult should stand by the doorway and ensure students are leaving the bathroom in a timely manner. If a minor under age twelve must use a bathroom alone, the minor should use a single-stall bathroom. If the only bathroom available has multiple stalls, the adult should assign a classmate to stand outside the bathroom and wait for the minor to finish. If the minor needing the bathroom, the classmate, or both do not return in a timely manner, the adult in charge of the activity should promptly check on them.

For minors aged thirteen and older, an adult supervising the activity should give permission for the minor to leave the activity to use the bathroom. The adult should note when the minor left for the bathroom and when the minor returned. If the minor does not return in a timely manner, the adult in charge of the activity should promptly check on the minor. During periods of transition from one activity to another, minors do not need permission to use bathrooms, but adults should randomly monitor bathrooms to ensure minors are not lingering or acting inappropriately in them.

In both protocols for the different age groups, bathrooms shall not be shared with adults at the time the youth are inside the bathrooms.

12.5 Locker Room Use

At least one adult in charge of the activity should stand within earshot of the youth at all times to ensure the safety of the youth. This can mean being inside the locker room or standing in the doorway but out of view of the youth using the lockers, in which case more than one adult should be present.

Employees and volunteers are required to check inside the locker room, so users know the locker room is monitored intermittently and briefly.

Adults should not change clothing or shower in locker rooms at the same time as minors, nor should they watch minors undress or shower.

While minors shower, at least one adult in charge of the activity should stand within earshot of the minors to ensure that no adults are showering with them and that the minors are respectful of one another.

12.6 Post Program Release

Program Directors are responsible for developing and implementing written protocols for the release of youth at the end of the activity. Youth should be supervised until they are picked up by an adult parent, legal guardian or individual/adult previously authorized to take custody of the youth. Youth may be released to the custody of others or youth may be released to their own custody with advance written consent of parents/guardians.

12.7 Youth Facility Check-In and Out

For programs where the University assumes the responsibility for supervising youth, the following guidelines are offered to assist with checking youth into and out of Program Facilities:

• When anyone (youth participants, guests, residents, other, etc.) enters the facility during operational hours, they must check in with a pre-established program check in individual.
• When possible, create a single point of entry and exit in the facility.
• If there is more than one entrance or exit, ensure all points of access are consistently monitored.
• Establish a protocol for documenting how youth arrive (i.e., with parent, other, on their own) and who is authorized to pick the youth up. The Pick-Up, Drop-Off, and Commuter Permission form must be submitted prior to the start of the CSUDH Youth Program/Event by the parent/guardian to the Program Director via email. The Program Director is responsible for ensuring the program retains the form and keeps them on file for all applicable program participants.

12.8 Youth Transportation

Transporting youth in a personal vehicle is prohibited. Programs may use campus vans or, rent vehicles such as vans, or buses through the Procurement department to transport youth.

All program youth participants must have their parents or legal guardians sign a liability waiver prior to transportation. The waiver is required for program activity participation and should be on file if other program activities were underway prior to transportation.

• Observe the “rule of three” when transporting youth in vehicles. At least two adults are required to transport a single youth. At least two youth must be present if transported by a single adult.
• Youth are not to be transported without written permission from a parent or legal guardian.
• Youth are only to be transported directly to their destination (i.e., no unauthorized stops made).
• Document beginning and ending time and mileage, the names of youth and employees or volunteers who are involved in transportation, purpose of the trip, and destination.
• Avoid unnecessary physical contact with youth while in vehicles.
• Employees shall not use cell phones or electronic devices while transporting youth unless it can be used hands free and is necessary for navigation.

12.9 Supervision/Chaperone Ratios

Source: The American Camp Association:

12.10 Overnight Activities

Overnight stays present unique risks to youth, employees, and volunteers. They often involve changing clothes, groupings of youth of all genders and different ages in a more intimate atmosphere than usual, and more structured activities. Given these factors they require increased supervision. Programs with overnight activities should:

• Determine the appropriate supervision ratio and schedule employees and volunteers accordingly.
• Appoint a “lead” employee or volunteer to supervise the overnight stay and to observe overnight activities.

Overnight stays on campus:

• Physical boundaries within the housing facility and program must be clearly defined and explained to the youth.
• Assign each employee or volunteer to a specific group of youth to supervise. Each employee or volunteer should then maintain a roll sheet that lists all the youth in his or her group. Head counts and roll checks should be conducted routinely throughout the evening.
• Assign employees and volunteers to high-risk areas in the facility, such as the bathrooms, entrances and exits, hallways, elevators, etc. If it is not possible to assign specific employees and volunteers to these areas, assign specific employees and volunteers to conduct periodic facility “walk-throughs.”
• Separate individuals into separate rooms based on their gender identity and post employees or volunteers at the entrances and exits to these rooms. If this is not feasible, separate individuals by their gender identity by as much space as possible.
• When performing overnight checks, employees and volunteers should always go in pairs.

Overnight stays off campus:

• Overnight stays at private homes are prohibited.
• Physical boundaries at the off-site location must be clearly defined and explained to the youth.
• Assign each employee or volunteer to a specific group of youth to supervise. Each employee or volunteer should then maintain a roll sheet that lists all the youth their group. Head counts and role checks should be conducted routinely throughout the event.
• When applicable, employees and volunteers should be placed in bunks to maximize supervision around the cabin and in a way that decreases the chances of youth sneaking out (such as by the door).
• In hotel rooms, assign youth to rooms based on gender identity and age. Employees and volunteers should have their own rooms. If employees and volunteers must share rooms with minors, employees and volunteers must have their own beds and never change or shower in front of minors.
• Employees and volunteers should be on duty in the halls or cabins at night until an hour after lights out and all rooms are quiet.

12.11 Transition and “Free” Times

• Require youth to always remain in line of sight of employees and volunteers.
• Specify the adult-to-youth ratio.
• Specify narrow authorized areas in the program areas.
• Ensure that all employees and volunteers are assigned specific areas to supervise (“zone monitoring”).
• Specify bathroom procedures.
• Require periodic roll calls for each age group.
• Require supervisors to conduct periodic check-ins and sweeps of the entire activity area.

12.12 Missing Youth

The Program Director must develop and implement procedures for program staff to follow if a youth has been separated from the group or is missing. The procedures should be immediately activated once it is discovered that there is a missing youth. At a minimum:

• Assemble all youth in a secure place under supervision.
• Notify supervisor.
• Institute a systematic search, beginning with high-risk areas (streets, locker rooms, bathrooms etc.)
• If the youth has not been located within 10 minutes, contact law enforcement.
• Maintain communication with supervisor and other employees.
• Notify parents or legal guardians.

12.13 Reporting incidents

It is the responsibility of program staff or volunteers to report any situations of concerns, complaints, or violations of this Policy to the Program Supervisor, Program Director, University Police, Office of Equity & Inclusion, and/or other appropriate departments including Risk Management and the program sponsor.

1. Complete an incident/accident report that records the details of the incident and involved parties and forward a copy to the program supervisor, Director, University Police, Office of Equity& Inclusion, or another appropriate department.
2. Contact Program Director – In addition to reporting to the program supervisor, the reporting staff must also notify the Program Director if that is not their program supervisor.

Program Directors must notify Risk Management immediately of any incidences reported to them by program staff. Program Directors must submit the Youth Program Accident/Incident Report Form to Risk Management via email at riskmanagement@gafmacademy.com.

12.14 Document Retention

All Program Directors must retain all forms, incident reports, and supporting documentations for a minimum of 5 years.

13.0 Forms Attachment

Attachment A. Consent for Medical Treatment of Minor Form 

Attachment B. Pick-up, Drop-off, and Commuter Permission Form

Attachment C. Protection of Minors Code of Conduct Form 

Attachment D. Visual, Audio, and Image Release Form 

Attachment E. Youth Protection Program Accident/Incident Report Form 

Attachment F. Youth Protection Program Facility Risk Assessment Form 

Attachment G. Youth Protection Program Registration Form 

Attachment H. Parent/Guardian Participation Agreement

Attachment I. Liability Waiver

Attachment J. Praesidium Academy Quick Start Guide