Protection of Minors on Campus Policy

Purpose and Scope

The University of Massachusetts Amherst is committed to the health, safety and well-being of minors involved in programs on campus. The Protection of Minors Policy at the University of Massachusetts Amherst establishes the responsibilities of Program Directors/Staff supervising minors when on the University campus or while participating in University-sponsored activities off campus. This Policy applies to University-sponsored activities involving minors and programs for minors sponsored by non-University organizations that operate in University facilities.  This policy is not applicable to the University’s on-campus child care center which has established procedures following licensing regulations set forth by the Massachusetts Department of Early Education and Care.  

This Policy establishes:

  • Minimum standards of conduct for interacting with minors attending Programs;
  • Procedures for reporting and responding to suspicions of abuse or neglect of minors;
  • Guidelines for the operation of Programs that involve minors;
  • Minimum training requirements for Program Director/Staff who oversee Programs that involve minors; and
  • Background screening requirements for those who interact with minors in Programs.


A Minor is any person under the age of 18 but, as such term is used in this Policy, excludes those enrolled at the University as matriculated students, special status students or non-degree Continuing and Professional Education (CPE) students.  

Program Director shall refer to an adult who is authorized to supervise Programs involving minors.  All University students, employees, independent contractors or volunteers acting as Program Director must be in compliance with the requirements of the provisions of this Policy captioned “University Sponsored Programs Involving Minors.” Although a parent or legal guardian may supervise his or her own minor children and his or her guests who are minors while visiting the campus or using campus facilities, a parent or legal guardian may not act as a Program Director in a Program (including one in which his or her child participates) unless they are in compliance with the requirements outlined below under “University Sponsored Programs Involving Minors.”

Program Staff includes all students, employees and volunteers engaged in providing the Program.

A Program shall include any organized activity or event, including small group or informal activities, that are designed to include participants who are minors [1], offered by an academic or administrative unit of the University (including recognized student organizations and Athletics), whether on- or off-campus, or by non-University organizations using campus facilities.  Programs shall include workshops, summer camps and programs, and group visits, but shall exclude the following Exempt Programs:

  1. Performances or events open to the general public (such as athletic competitions, plays, concerts, lectures, weddings, etc.) or events for Program participants that are provided in a full group or assembly format;
  2. Tours and events for prospective students organized by the Office of Undergraduate Admissions and Financial Aid Services and Athletic recruitment covered by National Collegiate Athletic Association (NCAA);   
  3. Events or activities where parents or guardians are required to accompany Minors, or events or activities such as field trips to the campus where personnel from the sponsoring agency or education program are required to accompany Minors;
  4. Community outreach activities that Athletes, through their respective sports teams (“Teams”) participate in. These outreach activities generally take the form of players participating in sports drills or short clinics (up to 2 hours) with Minors at local schools and occasionally at campus facilities.   See Appendix A, Hosting or Offering Programming for Children for details on this exemption.
  5. Research protocols involving Minors as human subjects, which are subject to the requirements specified by the relevant Institutional Review Board (IRB)  
  6. Visits by Minors, including overnight stays in University housing facilities by prospective student-athletes, Provost sponsored prospective underrepresented students or siblings of enrolled students, when hosted by enrolled University students.  Residence hall guests must be at least 16 years of age and possess a valid ID.  Hosts of overnight visitors under the age of 16 must receive special permission from Residence Hall Security Staff.  The host all such visitors shall be held accountable for visitor’s compliance with University policies.    

[1] By this definition, programs designed for adults, even if a person under 18 may attend, are exempted.

Presence of Minors on Campus

The University reserves the right to condition, restrict or deny access to University facilities by Minors at its discretion. All Minors, including those participating in Programs, shall be subject to all University regulations while on campus, and may be asked to leave the campus if unable to comply.

University-Sponsored Programs Involving Minors

Unless they are Exempt Programs, all University-sponsored Programs involving the participation of Minors must comply with the following terms and conditions, as well as any other applicable requirements of federal, state or local laws or regulations.

Responsibilities of the Program Director

The Program Director or designee of all Programs in which Minors will participate, whether located on- or off-campus, shall enter program information into a centralized program database.  The responsibilities for granting access to the database, auditing compliance, review of policy and reporting will reside with the Associate Chancellor for Compliance. 

As applicable, the Program Director has responsibility to:

  1. ensure that all Program Staff engaged in Programs have completed background checks as described in this Policy;
  2. ensure all vendors and other agents comply with background checks as described in this Policy;
  3. contact the Assistant Director Environmental Health at 545-2682 when a Program meets the definition of a Camp under Mass Department of Public Health regulations for recreational camps for children (105 CMR 430).  The numbers of days, use of a swimming pool or other high risk activity, and/or calling the program camp qualifies the program as a Camp;
  4. complete and retain required forms;
  5. establish a procedure for notification of parents or legal guardians of all participants in the event of an emergency, and obtain and keep accessible contact information for participants’ parents or legal guardians, as well as emergency contacts in the event the parents or legal guardians are unavailable. All parents or legal guardians of participating Minors shall be provided with contact information in order to reach participants while the Program is in session;
  6. obtain: (i) authorization from all participants’ parents or legal guardians to permit transportation of Program participants to University Health Services or local hospitals as deemed necessary; (ii) authorization for emergency medical treatment in the event the parents or legal guardians or their designated emergency contact are not available; and (iii) disclosure of any allergies or other medical condition or physical limitation that might impact participation in the Program.  When a Program meets the definition of a Camp (see c. above for definition of a Camp) the Program Director must complete the health care forms.   When a program does not meet the definition of Camp, but has questions about administering medications or other health concerns, the Program Director can contact University Health Services Director at 413-577-5211 for  guidance;
  7. establish a plan for adequate supervision in light of the number and average age of participants, the Program activity and whether overnight accommodations are involved.  See c. above for Programs that meet the definition of a Camp.  All campus overnight accommodations for a Program when University is not in session must be coordinated through UMass Conference Services; and
  8. establish a procedure for the pick-up and drop-off of participants, specifying times and locations, and providing that no participant shall be released to any person other than his or her parent or legal guardian without specific written authorization from such parent or legal guardian. Any Program providing for transportation of participants by Program Staff after drop-off by parent or legal guardian to the campus or other site must have a valid driver’s license, a copy of which will be maintained by the responsible unit.  Under no circumstances shall Program Staff be permitted to be alone with a Minor in a car or other vehicle.

Background Check

Prior to their participation in a University Program involving Minors, Program Directors and Program Staff will be subject to background checks.  If they have not had an iCORI (Criminal Record Offender Information) in the last three years, an iCORI will be required.  Everyone is required to have a state sex offender registry search (SORI).  Thereafter, Program Directors and Program staff will be subject an iCori every three years and a SORI every year.  iCORIs will be provided by Human Resources.  SORIs can be requested from Creative Services, Inc (CSI), the University’s background check provider, or completed by the Program Director.  Program Directors are required to use CSI for their SORI check. See Appendix A, Hosting or Offering Programming for Children [PDF], for procedure. 

Requirements for Staff Participation

No person shall serve as a Program Director or participate as Program Staff in any University-sponsored Program, unless and until the following requirements have been met:

  • Completion of a successful background check;
  • Completion of a training program prior to involvement in the Program and on a three year cycle thereafter.  Training will include at a minimum the following topics:
    • University policies regarding interactions with Minors;
    • Background screening requirements;
    • Examples of appropriate and inappropriate behavior with Minors, as outlined in Prohibited Conduct;
    • Behavioral signs that a Minor may be a victim of abuse or neglect;
    • Reporting requirements and procedures for suspicion that a Minor may be a victim of abuse or neglect.

Non-University Programs

Non-University organizations that use University facilities to operate Programs shall be required to coordinate with the following University departments: Mt. Ida Campus of UMass Amherst, Conference Services, University Summer Programs, Athletics, Research or Student Engagement, as appropriate. Exceptions shall be directed to the Executive Director for Administration and Finance Operations.  Prior to operating a Program on campus, Non-University organizations operating Programs must have a signed agreement that includes:

  1. the specific facilities to be used, the dates and hours of permitted access and other terms applicable to such use;
  2. an affirmation that its employees, volunteers and other agents (“Personnel”) acting under the agreement have passed legally required background checks, including CORI and SORI and shall at minimum ensure that all Personnel who, as part of their duties, may come in contact with Minors have completed a SORI check and a standard access CORI.   In the event that any Personnel are from out of state, it shall also use its local jurisdiction’s equivalent to ensure compliance with the above minimum requirements;
  3. an affirmation that its Personnel comply with section 6 of this Protection of Minors policy
  4. an Indemnification Agreement in a form acceptable to the University General Counsel defending and holding the University harmless against any and all claims arising from the actions of the Non-University organization, its Personnel, and any failure to conform to the requirements of this Policy;
  5. contact the Assistant Director Environmental Health at 545-2682 when a Program meets the definition of a Camp under Mass Department of Public Health regulations for recreational camps for children (105 CMR 430).  The numbers of days, use of a swimming pool or other high risk activity, and/or calling the program camp qualifies the program as a Camp;
  6. adequate insurance coverage.

University departments contracting with Non-University organizations shall comply with all procedures as defined in Hosting or Offering Programming for Children, attached as Appendix A.

Department-Specific Minors Policy

The following University departments have policies related to Minors. These are included in this Policy by reference and attached in the Appendices as described below.  In the event there is a discrepancy between this Policy and those listed, this Policy shall take precedence.

  1. Appendix B: User Behavior and Library Building Policies;
  2. Appendix C:  Guidelines For Children And Unauthorized Persons In Labs And Other Potentially Hazardous Areas;
  3. Appendix D: Recreation Policy on Minors - participants must be 18 or older to use the recreation center unless enrolled at the University.
  4. Appendix E: Policies and Procedures related to Academic Summer Programs.

Prohibited Conduct

Program Directors and Program Staff should avoid unobserved or unsupervised one-on-one contact with a minor.  No Program or Exempt Program for Minors shall involve any of the following:

  1. Corporal punishment, inappropriate touching
  2. Hazing or bullying of any kind;
  3. Presence or consumption of tobacco, alcohol, or illegal or prohibited drugs;
  4. Presence or use of or sexually explicit literature or other media of any kind;
  5. Presence or use of firearms or weapons of any kind;
  6. Inappropriate use of audio, video or photographic devices or accessing or displaying inappropriate materials or content;
  7. Any private communication not pertaining to Program matters from Program Director/Staff to Minors by email, text messaging or social media; or
  8. Transportation of Minors by Program Director/Staff except in conformance with a transportation plan.

Reporting of Inappropriate Activity

A) All persons serving as Program Director, whether voluntary or paid, or employees serving as Program Staff in Programs are mandated reporters of child abuse under Massachusetts law and must report to the Department of Children and Families (DCF) all instances where they have reasonable cause to believe a child is suffering physically or emotionally from abuse, including sexual abuse, or neglect.

B) All mandated reporters must immediately report to the Massachusetts Department of Child and Family Services if they have reasonable cause to believe a child known to them in their official capacity may be abused or neglected. In the alternative, a mandated reporter may promptly make such a report to the Associate Chancellor for Compliance, who shall become responsible for notifying the DCF as outlined above.

  1. During regular business hours (8:45am-5:00pm M-F) call the DCF area office that serves the city or town where the child lives. Otherwise, dial the Child-at-Risk Hotline at 800-792-5200. Gather as much information as you can about the suspected abuse or neglect before calling.
  2. In addition to calling, mandated reporters must also complete a written report within 48 hours of their call to DCF. This written report can be completed online. A written report can also be sent via fax or mail.
  3. The University of Massachusetts Police Department (UMPD) is available to assist mandated reporters with the DCF notification process. Contact UMPD at 413-545- 2121

C) If a mandated reporter makes such a report directly to DCF, notify the Associate Chancellor for Compliance that a report has been made, as well as the underlying circumstances that compelled the report, and memorialize in writing that the report has been made.

D) While not mandated reporters per Massachusetts law, volunteers serving as Program Staff in Programs are required by this Policy to notify Associate Chancellor for Compliance who will then notify DCF.

E) Associate Chancellor for Compliance will contact the University Police in the event they become aware of or concerned about such abuse or neglect which occurred.

F) Questions regarding reporting obligations or the circumstances under which a report is required may be addressed to Office of General Counsel Office or for immediate assistance, contact UMPD at 413-545-2121. Substantive educational content may obtained at

Retaliation Will Not Be Tolerated

Retaliatory acts against members of the University community who make good faith reports of inappropriate activities under this Policy and/or who cooperate in the investigation and handling of such reports, regardless of whether a violation of this policy has occurred, will not be tolerated. Any member of the University community who believes that he or she is the subject of retaliation or reprisal under this policy should contact the Associate Chancellor for Compliance.  The University will promptly investigate all reports of alleged retaliation or reprisal.

Sanctions for Violation of Policy

Failure to comply with the provisions of this policy and any related campus procedures may result in cancellation of a Program or event and/or discipline in accordance with campus and University policies. Knowingly making a false report under this Policy, or knowingly providing false or intentionally misleading information during an investigation, may also result or discipline in accordance with campus and University policies and in accordance with the relevant collective bargaining agreement.