The university is committed to promoting the safety and wellbeing of students and others who are entrusted to our care or visit our campuses, especially those who are particularly vulnerable, including patients, volunteer subjects of research, and the children in our daycare and community outreach programs. We welcome minors on campus for a variety of specific reasons (see Minors on Campus policy), including as prospective students; as enrollees in a university-sponsored program or camp; as patients or interns; and as participants in other USC-sponsored programs appropriate for minors (some of which may meet off-campus).

This policy describes requirements placed on administrators, faculty, staff, students, volunteers and others working with minors—to promote their protection, to fulfill our obligations as mandated by law, and to provide the best possible experience for any child visiting our campuses or in university-related programs.

The behavior of all faculty, staff and students is expected to align with the university’s Code of Ethics. For more specific guidelines related to working with minors, see Guidelines for those working with or around children, which provide more detail in determining behavior that is and is not appropriate in situations involving minors.

I. Scope

All university students and employees must comply with this policy. Non-university organizations and entities that operate programs or activities involving minors on campus must also comply with this policy.

This policy provides guidelines that apply broadly to interactions between minors and university students, faculty, staff, and volunteers in university-run or affiliated programs or activities whether on or off campus. For purposes of this policy, university affiliated programs or activities includes student placements at internship or clinical sites, student teaching/field placement sites, and/or any other academic credit-bearing activities with external entities. When schools and/or departments place students at external entities, students are obligated to comply with the external entity’s policies and procedures as well as all aspects of this policy, aside from those requirements set forth in Sections VII and VIII on registration and program ratios.

Aside from the child abuse reporting requirements, which are always applicable, this policy does not apply to: (1) events on campus that are open to the public; (2) private events where minors attend under the supervision of a parent or legal guardian; and (3) activities or programs that only involve minors who are matriculated university students.

The following events and activities are only required to meet the certain requirements set forth in this policy as follows:

• One-time events and activities that are conducted by recognized student organizations are required to be registered as set forth in Section VII, and at least one adult who has cleared a criminal background check, as set forth in Section V, must be present at all times to supervise all participating students; and
• Charitable and/or community events lasting one day or less must still be registered as set forth in Section VII, and at least one adult staff member who has cleared a criminal background check, as set forth in Section V, must be present at all times to supervise the event.

Other exemptions from the requirements set forth in the policy may be provided only if approved in writing by the Associate Senior Vice President, Human Resources.

II. Definitions

Minor—Anyone under age 18

Child abuse—Includes any of the following:

• Physical injury or death inflicted by other than accidental means upon a child by another person
• Sexual abuse
• Neglect
• Willful harming or injuring of a child or the endangering of the person or health of a child
• Unlawful corporal punishment or injury

Abuse of a minor includes serious endangerment of a child’s physical or mental health due to injury by act or omission, including acts of sexual abuse. Sexual abuse includes contacts or interactions between a child and another person when the child is being used as an object of sexual gratification. A child is abused regardless of whether this activity involves explicit force, whether it involves physical contact, whether it is initiated by the child, and whether there is discernible harmful outcome. For more information on abuse and neglect, see Guidelines for those working with or around children*.

Campus—All buildings, facilities, and properties that are owned, operated, managed, or controlled by the university.

III. General guidelines and responsibilities

When participating in university-run or -affiliated programs involving minors, faculty, students, staff, volunteers, and third-party contractors must:

• Review Guidelines for those working with or around children. Adults on campus are role models for children, and are expected to maintain the standards set forth in those guidelines.
• Watch for signs of abuse or neglect as is set forth in Appendix A and promptly report suspected instances of abuse or neglect or violations of this policy. Those members of the university community covered by California’s Mandated Reporter laws must also review the university’s Mandated Reporters policy.
• Before engaging in any university-run or -affiliated program or activity involving contact with minors, meet the training and background check requirements of this policy; meet any additional requirements that relate to the specific program or activity; and determine whether they are a mandated reporter under California law. See the Mandated Reporters policy.

IV. Training requirements for those participating in programs and activities with minors

All faculty, staff, students, volunteers and third-party contractors who work in a program specifically designed for minors or who direct or supervise such a program are required to participate in targeted training designed to teach appropriate codes of conduct with minors; awareness of signs of possible abuse, molestation or neglect; and how to report such suspicions.  All new university employees receive this training within 60 days of hire; continuing employees receive refresher training every two years. All students, volunteers, and contractors must receive this training prior to starting work with minors. The training must be documented with the participant signing a statement indicating that s/he has completed training and received this policy. These training certifications are retained by the USC Employment Screening Services department. Non-university organizations and entities that operate programs or activities on campus involving minors must provide training to their staff consistent with the university’s requirements, and must complete a certification form attesting that such training has been completed.

Failure to successfully meet any of these requirements will preclude faculty, staff, students, volunteers or contractors from working with minors.

V. Criminal background checks

All faculty, staff, students, and volunteers who will be working directly with, supervising, chaperoning or otherwise overseeing minors in university-sponsored programs or activities are required to clear a criminal background check prior to participation in said programs or activities. Employees, volunteers, and students who work in seasonal programs and are not continuously employed by the university must clear another criminal background check prior to returning for a subsequent season. It is the responsibility of the program director of each covered program to ensure that each student, employee, or volunteer has cleared a criminal background check and been cleared to participate.

Non-university organizations and entities that operate programs or activities on campus involving minors must conduct criminal background checks of their employees, volunteers, and representatives that are consistent with the university’s requirements. As part of the agreement to operate on campus, non-university organizations and entities that operate programs or activities on campus involving minors are responsible for ensuring that the appropriate background checks are completed for their employees, and must complete a certification form attesting that such background checks have been completed.

The university may request any additional information it deems necessary to meet the requirements of this policy.

VI. Reporting requirements

All employees, students, contractors and volunteers have a personal responsibility to report any instances of known or suspected abuse, molestation or neglect relating to children. Two reports must be made:

First report – must be placed to the Department of Children and Family Services Child Protection Hotline at (800) 540-4000, or to the LAPD (or your local law enforcement agency if outside the city of Los Angeles).

Second report – USC’s Department of Public Safety (DPS) must be immediately notified. From all locations, call (213) 740-4321 (emergencies; immediate threat of danger) or (213) 740-6000. Those members of the university community covered by California’s mandated reporter laws should also review the university’s Mandated Reporters policy, which also covers obligations related to other issues (such as elder abuse and domestic violence). Both the university and California law impose additional obligations on mandated reporters. A list of those who are mandated reporters pursuant to California law can be found in Appendix A, and in the university’s Mandated Reporters policy.

Questions about one’s obligations or what one should do in a situation where child abuse is suspected should be directed to the Office of Compliance at compliance@usc.edu or (213) 740-8258.

VII. Registry requirements

All university programs in which staff, faculty, volunteers or students work directly with non-matriculated minors must register the following information with the Employment Screening Services department at least 30 days before the start of the program date:

• name of the program
• general nature of the activities to be undertaken or offered in the program
• name and contact information for those individuals running the program
• all staff, faculty, volunteers, students and contractors who work directly with minors

The registration form that must be completed and provided to the Employment Screening Services department – and maintained by each program director – is provided here.

VIII. Enforcement

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 non-university entities that violate this policy.

Responsible Office

Office of Culture, Ethics and Compliance
Compliance@usc.edu

Issued by

Michael Quick, Provost and Senior Vice President, Academic Affairs
Todd R. Dickey, Senior Vice President, Administration