Frequently Asked Questions – Protecting Minors Policy
Yes. USC’s updated Protecting Minors Policy still requires that all University Employees and Covered Activity Staff, regardless of mandated reporter status, immediately report reasonable suspicion of child abuse or neglect to the proper external agencies (Department of Children and Family Services at 800-540-4000) and University officials (the Office of Youth Protection and Programming).
In addition, some types of conduct that may implicate USC’s Policy on Prohibited Discrimination, Harassment, and Retaliation, prompt your Designated Employee reporting responsibilities to the Office for Equity, Equal Opportunity, and Title IX (EEO-TIX).
Reporting is required when there is “reasonable suspicion” that child abuse or neglect has occurred. Reasonable suspicion means that it is reasonable for a person to suspect based on the information, training, and experience the person has; it does not require certainty that an incident has occurred.
Yes. If you reasonably suspect that a minor experienced abuse in the past, you must follow the reporting steps outlined in the Protecting Minors policy. Even if there is an indication that an incident of child abuse or neglect has previously been reported, this does not relieve one of their obligation to report to both external authorities and university officials.
Incidents that occurred in the past where the minor involved at the time is now an adult (18 years of age or older) must be immediately reported to the Office of Youth Protection and Programming for review to determine whether further reporting (e.g., to DCFS) or action is necessary.
Maybe. Suspected child abuse, neglect, and other serious incidents or violations involving minors that are observed, known, learned about, or reasonably suspected to have occurred in connection with USC, or to have been perpetrated by a member of the University Community, require immediate reporting to the Office of Youth Protection and Programming regardless of the context in which information about the matter arises. However, if you suspect child abuse or neglect while volunteering for another organization outside of your employment with USC (e.g., while you are coaching little league baseball), and there is no connection to the University, you may not be required to report to USC, but you may have an obligation to report based on your volunteer role and/or the volunteer organization’s policies.
All inappropriate behavior involving a minor, including grooming behavior or boundary violations, must be reported immediately to the Office of Youth Protection and Programming. By doing so, you may be preventing a child from potential harm, or from experiencing further harm. If you are unsure whether to report, contact the Office of Youth Protection and Programming for guidance.
Callers can make a report to DCFS and remain anonymous, except for mandated reporters. And even though mandated reporters must provide their name when making a report, their identity and the content of the report is confidential and may only be disclosed to specified persons and agencies. Additionally, anyone who reports child abuse in good faith is protected by law from civil and criminal liability.
By reporting child abuse or neglect, you may prevent a child from experiencing abuse or further harm. Failure to make the required reports is a serious neglect of duty, which may subject an individual to University disciplinary action and/or criminal and civil penalties, including but not limited to fines and imprisonment.
When DCFS receives a report, they will determine whether an investigation is necessary. If DCFS concludes that an investigation is necessary, a thorough investigation will be conducted to assess child safety and ensure the well-being of the child. For more information about what happens after a call is made, visit: dcfs.lacounty.gov/parents/investigations/
The Office of Youth Protection’s website has training information and instructions on how to register for and access the required mandated reporter course which is currently provided by Praesidium (a third-party vendor). There are many courses currently available through Praesidium, but the only required course is entitled Duty to Report.
The Protecting Minors policy requires that training be completed annually (and recorded in the Covered Activity’s registration record) at least 7 days prior to the Covered Activity’s start date. Covered Activity Staff may not begin work in any Covered Activity or have direct contact with minors until this has been completed.
Covered Activity Administrators are responsible for ensuring their staff have completed the required youth protection training. While the Office of Youth Protection and Programming does not require Covered Activity Administrators submit actual proof/copies of completion certificates, staff training completion dates must be entered in the Covered Activity’s registration record at least 7 days prior to the start date in order for the activity to be approved. If you need assistance on how or where to record this information, reach out to email@example.com.
Mandated reporter training is required annually, and training approved and assigned by the Office of Youth Protection and Programming must be completed, regardless of whether one has received youth protection training elsewhere unless the training received previously is approved in writing by the Office of Youth Protection and Programming.
The Office of Youth Protection and Programming is currently updating the University’s training for employees, including a youth protection course in Trojan Learn specifically for employees who have been identified as mandated reporters. In the meantime, all employees are welcome to take Praesidium’s mandated reporter course (instructions on how to access the course can be found here). Additionally, the California Department of Social Services has a mandated reporter training available for free, which can be accessed by visiting the following website: https://www.mandatedreporterca.com/
Yes. All members of the university community are expected to be role models for young people, and therefore maintain the highest standards of conduct when interacting with minors. This includes acting in a respectful and responsible manner that is consistent with the University’s Integrity and Accountability Code and the behavioral expectations set forth in USC’s guidelines for interacting with minors, which you can review here: https://protectingminors.usc.edu/policies/guidelines-for-interacting-with-minors/
Covered Activities – Registration & Approval
If you are planning a program, camp, activity or event involving one or more minors, it may be considered a Covered Activity if the care, custody, and/or supervision of the minor(s) involved is reasonably expected to be the responsibility of someone other than the minor’s parent or guardian. Covered Activities must register and meet specific requirements to help protect the safety and well-being of the minors involved. If you’re unsure about whether or not your program, camp, activity, or event meets the definition of a Covered Activity, complete this questionnaire and contact the Office of Youth Protection and Programming at firstname.lastname@example.org for additional guidance.
Your first step (aside from reviewing the Protecting Minors Policy) is to register your activity with the Office of Youth Protection and Programming. For a full list of next steps and requirements, the office has developed a Registration Roadmap for reference.
Covered Activities must be registered 60 days prior to the anticipated start date. This is to ensure that the Office of Youth Protection and Programming has adequate time to provide you support and assistance in meeting the requirements outlined in the Protecting Minors Policy.
Maybe. If your covered activity has concluded you do not need to reregister, but it is an annual requirement, so you will have to register again next year if you plan to hold activities again. Additionally, ongoing Covered Activities that have already been registered for the year may be asked to re-reregister so that staff can complete the new Live Scan process.
If your staff or participants change with each activity/event, or if they have different goals and initiatives, you would need to register each of them separately. However, if all of your activities and events involve the same staff and participants, you can register as one Covered Activity and just include the various dates and details/information in the notes when registering.
Covered Activities – both one-time/recurring and year-round activities – need to register at least annually. This provides the University with up-to-date, accurate information about Covered Activities (which may be helpful in the event of an emergency), and it also provides the office an opportunity to communicate any updates regarding policies or procedures that may have changed since the last time the Covered Activity was registered.
Most likely, yes. If your research involves direct contact with minors, it may qualify as a Covered Activity. While IRB approved research includes safeguards for “vulnerable populations,” including youth, the Protecting Minors Policy establishes additional critical safety and prevention measures that are not addressed by IRB requirements, such as background screening, training and conduct expectations for personnel who interact with minors, emergency preparedness and response measures, and more broadly-defined health and safety measures. Reach out to email@example.com if you have questions.
After submitting registration for a Covered Activity, you’ll receive an access link that will allow you to view your submission. You’ll also be able to monitor the status of your staff’s background checks, and enter their training completion dates. Once all staff background checks have been marked “eligible” and you’ve entered each of their training completion dates, the Office will review the information and either notify you that the activity has been approved, or advise whether there may be outstanding information needed for approval.
Covered Activities – Background Screening Requirements
All Covered Activity Staff – which includes all individuals reasonably expected to work with or otherwise come into direct contact with minors (care for, supervise, have authority over, etc.) in a Covered Activity – must undergo background screening. Covered Activity Staff that are not employed by USC must undergo additional screening measures.
Probably. However, involvement in a Covered Activity may fall outside the scope of an individual’s employment/appointment duties, their employment background check may be out of date, and/or the initial check may not have included all of the criteria required to determine one’s eligibility for working with minors. As such, everyone – including all USC employees – are required to undergo a Live Scan fingerprint-based background check before working with minors in a Covered Activity.
Live Scan background checks completed for other organizations, certifications, or licensures are not valid for this purpose, as results cannot be shared with USC. However, if any covered activity staff have completed and cleared a Live Scan background check to participate in a covered activity with USC in the past, they may not be required to complete it again and their eligibility (as well as the date on which they were deemed eligible) will reflect in your registration record.
If they will not have direct contact with minors, will only be present during the program for a short period of time, and interacting with minor participants only while under your supervision, they do not need to undergo background screening. However, it’s recommended that they review and agree to adhere to the USC guidelines for interacting with minors.
The Centralized Disciplinary Database (CDD) was designed specifically to inform the public if/when individuals participating in U.S. Olympic & Paralympic Movements have either been found to have engaged in—or are alleged to have engaged in—forms of misconduct that present a potential risk to other members of the sport community. To learn more, visit the Center’s website which includes this one-pager that has additional information about the CDD.
Yes. All Covered Activity Staff must be screened through the Center’s CDD. It is possible (and fairly common) for someone to work in youth sports as well as other types of youth programming, and we want to help confirm that the staff participating in Covered Activities at USC are suited to work with minors – and have not been found to have engaged in disqualifying misconduct elsewhere that could put minors’ safety and well-being at risk.
To screen your staff, visit the Center’s website and search by each staff person’s first/ last name to confirm they are not included in the CDD. If someone is flagged, contact the Office of Youth Protection and Programming for guidance.
Covered Activities must obtain a written application, conduct a live interview, and complete at least two reference checks (non-family members) for all non-USC staff to assess their suitability for working with minors. During registration, you’ll be required to attest that all selected non-USC Covered Activity Staff have undergone this screening and, although you will not submit documentation to the Office of Youth Protection and Programming, you’ll want to make sure you’re keeping their screening documents as part of your overall program records in the event they are requested.
No. You may continue using documents/procedures you have already developed, but if you are looking to enhance your materials, or develop a new set to meet this requirement, you are encouraged to review USC’s Protecting Minors Background Screening Guide which includes suggestions on key elements/questions to include, as well as potential candidate answers that may require follow-up or further explanation to help make sure you’re not overlooking potential concerns.
No. Third parties are required to conduct their own background checks that meet or exceed the requirements outlined in USC’s Protecting Minors Policy, and then certify the results by completing this certification form and uploading it to their registration record.
Covered Activities – Education for Minors & Parents/ Legal Guardians
As long as you provide all of the information required by the policy to participants and their parents/ guardians, you may do this however you’d like. To make this easier for Covered Activities, the Office of Youth Protection and Programming has created a dedicated webpage for parents, guardians and caretakers that includes the majority of this information, and you are welcome to include this link in your registration materials, on your website, etc. You will still need to provide parents specific safety and security procedures, including the process for notifying parents/legal guardians of an emergency and how parents/legal guardians can contact their children during the Covered Activity, as well as a description of how rules or conduct violations by youth will be handled.
Full link: https://protectingminors.usc.edu/resource-library/information-for-parents-guardians-and-caretakers/
Covered Activities – Supervision Ratios
Yes. All minor participants in Covered Activities must be supervised at all times by Covered Activity Staff. If you are incorporating free time or non-programmatic activities into your participants’ itineraries, be sure to plan for appropriate supervision based on the ages/number of participants that will be present.
No. Staff employed to run recreational facilities do not undergo the same level of screening and training as Covered Activity Staff who are specifically trained to help prevent, recognize and respond to signs of inappropriate conduct or abuse.
Covered Activities – Emergency Preparedness
Covered Activities operating off-campus should follow the emergency procedures and protocols of the host location/worksite. It is a good idea to receive a copy of the host site’s emergency plan in advance, so that it can be reviewed, and questions can be asked before activities begin.
USC Student Health has requested that Covered Activities either enroll their participants in the Student Health Fee or collect and store medical information via CampDoc – a tool that allows Covered Activities to issue, collect and store various forms electronically and securely.
Yes. It is recommended that Covered Activities issue, collect and store all forms via CampDoc given it is the most secure way to keep sensitive information in one centralized location. There are also many useful features, including the ability to email participants/families, pull reports (e.g., participants with nut allergies), etc. Here is a one-pager with more information.
Depending on the type of Covered Activity you’re conducting, the forms you use may vary. However, most Covered Activities should use the following:
· Parental Consent (liability waiver)
· COVID-19 Informed Consent and Release of Liability
· Medical Authorization; Information & Insurance
· Pickup/Dismissal Authorization
· Use of Technology
· Program Rules; Standards of Behavior for Participants
· Photo and Media Release
All of these forms are available for you to issue participants/families via CampDoc.
When you register with the Office of Youth Protection and Programming, you will have the option to initiate the setup of an account for your Covered Activity. You’ll indicate the forms you’d like to issue your participants’ parents/guardians and which Covered Activity Staff should be given access to oversee the forms. When you submit your registration, a ticket will automatically be generated with Provost IT who will work with you to get you started. Alternatively, you may submit a ticket by emailing firstname.lastname@example.org
If you are not making edits to any forms, your CampDoc account can be set up and ready to go in about one week. If you need to customize or edit any of the forms, it can take up to 4 weeks.
Yes. The forms are available in both English and Spanish.
Covered Activities – Data Privacy
Yes, but not publicly. The policy requires that these authorized images, videos, etc. not be shared publicly until the conclusion of the Covered Activity in order to help safeguard minors by not publicly providing identifying information – including information about their locations, programs they are participating in, etc. – but they can be shared with parents/guardians if it’s done securely.