Student Handbook: Minors Policy

Minors On Campus Policy

POLICY STATEMENT

Fordham University (the “University”) is committed to the safety of all individuals in its community. The University has particular concern for those who are potentially vulnerable, including individuals under eighteen (18) years of age (also referred to herein as “Minors”), who require special attention and protection. This Policy establishes guidelines for those in the University community who may work or interact with Minors. The goal of this Policy is to promote the safety and well-being of Minors.

REASON FOR THE POLICY

This Policy provides guidelines that apply to interactions between Minors and University students, faculty, staff, and volunteers in University-operated or -affiliated programs or activities. This Policy also establishes requirements for Nonaffiliated Entities that operate Programs involving Minors on Campus, and University agreements with Nonaffiliated Entities shall reflect those requirements. Capitalized terms have the meaning described in the “Definitions” Section at the end of this Policy. Appendices to this Policy set forth specific requirements and procedures and may be updated from time to time.

RESPONSIBLE UNIVERSITY OFFICE/OFFICER

The Vice President for Administration, assisted by the Associate Vice President of Public Safety, Vice President for Human Resources and the Office of General Counsel. Questions about the interpretation and application of this Policy should be raised with the Office of General Counsel. Contact information for these offices and officers, along with the contact information for the offices and officers referenced herein, are provided in the “Contacts” Section at the end of this Policy.

APPLICABILITY OF THE POLICY

All University students, faculty (including adjunct faculty), staff, third-party contractors (such as consultants and temporary staffing agency employees who conduct operations on Campus), and volunteers who reasonably are expected to have contact with Minors (also referred to herein as “Covered Persons”) are responsible for reviewing, understanding, and complying with this Policy.

POLICY TEXT

I. GENERAL GUIDELINES AND RESPONSIBILITIES

Before engaging in any Program involving Minors, all Covered Persons must: (1) thoroughly review this Policy; (2) complete the required training; and (3) determine whether they are a mandated reporter under New York law.

University faculty and others on Campus who only interact in classes or other academic settings with University undergraduate students under the age of eighteen (18) are not obligated to undergo the training or background checks required by this Policy. However, all Covered Persons who know or suspect that an undergraduate student under the age of eighteen (18) has been abused or neglected must comply with the reporting requirements set forth below.

Nonaffiliated Entities that operate Programs involving Minors on Campus must be aware of, and comply with, this Policy and execute a Facilities Use Agreement—Minors

To the extent University faculty, staff, or students are participating in Programs covered by this Policy and operated by a Nonaffiliated Entity, they should review and follow the Nonaffiliated Entity’s policies relating to Minors and understand their legal obligations with respect to the Program.

II. PRIOR TO THE COMMENCEMENT OF MINORS PROGRAMS

Certain actions must be taken by Covered Persons prior to the commencement of any Program involving Minors. These actions include: (1) registration of the Program; (2) training; and (3) completion of all required documentation.

Registration of the Program

All Programs subject to this Policy must register with the University’s Department of Public Safety no later than thirty (30) days prior to the commencement of the Program, except Residential Programs must be registered sixty (60) days prior to commencement. This registration deadline allows sufficient time for the completion of the required training and background checks. The Department of Public Safety must provide authorization to proceed with the Program. Failure to timely register the Program may result in a refusal by Department of Public Safety to provide such authorization.

Registration must be completed using this Programs with Minors on Campus Form, which requires the following information to be provided:

  1. Description of the Program, including the location(s) at which it will be held;
  2. Date and time of the Program;
  3. Name(s) of the University staff member(s), Authorized Adult(s), and/or Nonaffiliated Entity(ies) responsible for the Program;
  4. Name(s) of the University staff member(s), Authorized Adult(s), and/or Nonaffiliated Entity(ies) staff member(s) participating in the Program; and
  5. Expected number of Minor participants.

Training

In addition to reviewing this Policy, Covered Persons must complete the New York State Mandatory Reporter Self-Directed Online Training found at: https://www.nysmandatedreporter.org/TrainingCourses.aspx. The required training must be completed prior to the commencement of any Program. Additional training may be necessary depending upon the nature of the Program.

Nonaffiliated Entities that seek to operate Programs involving Minors on Campus must provide an attestation to the University’s Department of Public Safety indicating that all individuals who will be interacting with Minors (and anyone who supervises such individuals) have received training that meets or exceeds the minimum requirements of this section.

Background Checks

All University employees who have direct contact with Minors in the course and scope of their employment are required to have a background check on record with the University at the time of hire and/or before commencing work involving contact with Minors. The three clearances required include:

  • Federal Criminal Records Databases, including the National Sex Offender Database
  • Social Security Number Trace
  • Social Security Number Validation

Prior to the commencement of any Program, the University department, unit, faculty, staff, or student responsible for the Program must ensure that copies of the final clearances have been submitted to the Department of Public Safety.

If a criminal background check reveals adverse information or unfavorable results, the University will conduct an individualized assessment using criteria designed to identify potential risk to Minors. A prior conviction shall not automatically disqualify a person from participating in a Program. Except where required by law, criminal background checks of University employees that are conducted pursuant to this Policy will be used only for purposes consistent with this Policy and will otherwise be kept confidential. Records of background checks will be maintained separately from an individual’s personnel or student file.

Nonaffiliated Entities that operate Programs involving Minors on Campus must conduct criminal background checks of their employees, volunteers, and representatives that meet University standards. Nonaffiliated Entities must produce background checks upon request. For Nonaffiliated Entities that are legally required to conduct background checks, i.e. New York City Department of Education, an attestation that background checks have been completed will suffice.

Documentation

Prior to the commencement of the Program, any University department, unit, faculty, staff, or student as well as Nonaffiliated Entities operating a Program involving Minors on Campus, including Residential Programs, shall:

  1. Obtain contact information for the parent(s)/legal guardian(s) of each participating Minor, to be used in case of an emergency, including medical or behavioral problem, natural disasters, or other significant program disruptions and
  2. Provide written notice to the parent(s)/legal guardian(s) of each participating Minor that they will be contacted in the event of an emergency.
  3. For Residential Programs, provide a list of all Minor participants and Program staff to the University’s Department of Public Safety. This list shall include the (1) Minor participant’s name; (2) local room assignment (if applicable); (3) gender, age, address, telephone number(s) of parent(s)/legal guardian(s); and (4) emergency contact information.
  4. Provide information to each participating Minor’s parent(s)/legal guardian(s) about the manner in which the Minor can be contacted during the Program.
  5. Obtain authorization for provision of emergency medical treatment. For Non-affiliated Entities, obtain written attestation that such group has obtained such authorizations and require such authorizations be available for presentation at Program;
  6. Obtain all media and liability releases as part of the Program registration process for each participating Minor. Media Consent and Release Form. Media and liability releases must be maintained for a period of no less than three years following the completion of the event.

III. CONDUCT OF MINORS PROGRAMS

Covered Persons must maintain high standards of personal integrity and professionalism when working with Minors. They must treat Minors fairly and with respect while maintaining discipline and discouraging inappropriate behavior.

Under no circumstances should Covered Persons:

  1. Engage in one-on-one contact with a Minor in a closed/private area without the presence of at least one other adult member of the University community or parent/legal guardian;
  2. Engage in sexual or romantic activity with a Minor;
  3. Make sexual comments or tell jokes of a sexual nature to or in the presence of a Minor;
  4. Engage in physical contact with a Minor in a manner that could be reasonably interpreted as inappropriate;
  5. Engage in conversations regarding inappropriate subject matter (including but not limited to lewd, sexual, romantic topics, as well as use of alcohol or illegal substances), unless such conversations occur for purposes of providing healthcare, counseling, or academic instruction to the Minor;
  6. Communicate with a Minor through any medium (email, text message, telephone, social media, etc.) except for academic, medical, or Program-related purposes;
  7. Use, possess, or be under the influence of alcohol or illegal substances while in contact with a Minor and/or responsible for a Minor’s welfare;
  8. Engage in any other behavior prohibited under applicable University policy;
  9. Leave Minors without adequate supervision;
  10. Abuse or neglect a Minor; or
  11. Fail to report suspected abuse or neglect of a Minor.

Covered Persons must ensure adequate supervision of Minors while they are on University property. Unless supervision is being provided by the participating Minors’ parent(s)/legal guardian(s), Programs involving Minors must be supervised by at least two or more Authorized Adults at all times. Factors to consider when determining whether a Program involving Minors is adequately supervised include, but are not limited to: (1) the number and age of participants; (2) the activity(ies) involved; (3) the type of housing (if applicable); and (4) the age and experience of the Program’s adult staff. Specific staffing requirements can be found in the Minors on Campus Policy Addendum—Day and Overnight Programs.

Any University department, unit, faculty, staff, or student operating a Residential Program involving Minors shall develop and make available to the Minor participants the rules and disciplinary measures applicable to the Program. Nonaffiliated Entities must develop and provide similar rules and disciplinary measure for the programs they operate on campus.

Regardless of whether a Program is operated by the University or a Nonaffiliated Entity, the Minor participants and Program staff must abide by all University regulations and may be removed from the Program for noncompliance. Similarly, anyone participating in any Program subject to this Policy must follow appropriate safety measures approved by the University’s Director of Environmental Compliance & Occupational Safety for laboratory and research work.

IV. REPORTING POTENTIAL HARM TO MINORS

University Reporting Requirements

Anyone participating in a University-operated or -affiliated program or activity involving Minors or a Nonaffiliated-Entity-operated Program involving Minors who knows or has reasonable cause to suspect that a Minor has been abused or neglected, or who has other concerns about the safety of Minors must inform the University’s Department of Public Safety. For the purposes of this Policy, “reasonable cause to suspect that a Minor has been abused or neglected” means a suspicion, based on rational observations, professional training, and experience, that a parent, legal guardian, or caregiver of a Minor is abusing or neglecting that Minor.

This Policy creates an independent duty for members of the University community who interact with, supervise, chaperone, or are otherwise responsible for the wellbeing of Minors to report immediately in situations where they have reasonable cause to suspect abuse or neglect of a Minor. An “independent duty” is one that cannot be delegated to a subordinate, colleague, or supervisor. The employee with a reasonable suspicion of abuse or neglect of a Minor must personally and promptly comply with these reporting requirements.

The University’s Department of Public Safety, with support from other appropriate offices as necessary, will help determine appropriate next steps. In addition, the reporting party should promptly notify their supervisor, program director, dean, or vice president, when it is safe and appropriate to do so.

Anyone who knows or suspects abuse or neglect of Minors may also notify the New York Police Department (“NYPD”), the West Harrison Police Department, and/or the New York Statewide Central Register of Child Abuse and Maltreatment.

In addition to the reporting obligations described in Section IV that the University imposes on those participating in Programs involving Minors, certain individuals are mandated reporters who have additional obligations under New York law.

Mandated Reporters and Their Legal Obligations

New York law designates individuals in certain occupations and professions as mandated reporters. Mandated reporters must report known or suspected mental or physical abuse or neglect of a Minor known to them in their professional or official capacity to either the New York Police Department or the West Harrison Police Department and to the New York State Office of Children and Family Services (“OCFS”) through the New York Statewide Central Register of Child Abuse and Maltreatment at (800) 635-1522, which is available 24 hours a day, seven days a week.

Mandated Reporters Under New York Law

Mandated reporters include physicians, psychologists, medical examiners, dentists, chiropractors, nurses, law-enforcement officers, school officials, teachers, athletic coaches, social service workers, day care workers, mental health professionals, and others. Authorized Adults, as defined by this Policy, are mandated reporters under New York law. University faculty, staff, or students who are working with Minors in their professional or official capacity and who have questions about whether they may be considered mandated reporters under New York law should contact their supervisor, program director, dean or vice president. The Office of General Counsel is also available to provide advice and can be reached at (718) 817-3110.

Even those who are not mandated reporters may report known or reasonably suspected abuse or neglect of Minors to the NYPD, OCFS, and/or the University’s Department of Public Safety.

V. 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 Nonaffiliated Entities that violate this Policy.

DEFINITIONS

Abuse or Neglect of Minors. Infliction of physical or mental injury, sexual abuse or exploitation, or negligent treatment or maltreatment of a Minor. Sexual abuse includes engaging in or attempting to engage in a sexual act or sexual contact with a Minor, causing or attempting to cause a Minor to engage in sexually explicit conduct, or exposing the Minor to sexually explicit conduct. Neglect includes the failure to make reasonable efforts to prevent the infliction of abuse upon a Minor.

Authorized Adults. Individuals, age eighteen (18) and older, paid or unpaid, who interact with, supervise, chaperone, or are otherwise responsible for the wellbeing of Minors in any Program governed by this Policy. This includes but is not limited to faculty, staff, volunteers, students, interns, employees of temporary employment agencies, and independent contractors/consultants. The Authorized Adults’ roles may include positions as counselors, chaperones, coaches, instructors, etc. Authorized Adults are mandated reporters under New York law.

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

Covered Persons. All University students, faculty (including adjunct faculty), staff, third-party contractors (such as consultants and temporary staffing agency employees who conduct operations on University premises), and volunteers who reasonably are expected to have contact with Minors.

Minor. Any person under the age of 18. University undergraduate students who are under the age of 18 are treated by this Policy similarly to all other students for purposes of their interactions with Minors in University-operated or -affiliated Programs and are subject to the requirements that apply to other students.

Nonaffiliated Entities. Entities that are neither affiliated with a major administrative or academic unit nor a registered student organization. For example, persons who are University faculty or staff acting in their personal capacity (e.g., not acting within the course and scope of their employment responsibilities), individuals with no connection to the University, private companies and corporations, non-profit organizations, and unincorporated associations.

Programs. Programs or activities that the University operates or sponsors or in which University students, faculty or staff engage through their University roles. This term does not include programs or activities in which one may engage that are unrelated to one’s status as a member of the University’s faculty, staff, or student body.

Residential Programs. All Programs governed by this Policy involving Minors that involve overnight stays for Minors on Campus.

 

CONTACTS

Department of Public Safety
Rose Hill Campus: 718-817-2222 or x2222
Lincoln Center Campus: 212-636-6076 or x6076
Westchester Campus: 914-367-3001 or x3001

Department of Human Resources
718-817-4930
[email protected]
Rose Hill Campus: Faculty Memorial Hall, Room 506

Office of General Counsel
Phone: 718-817-3110
Fax: 718-817-3115
Rose Hill Campus: 441 E. Fordham Rd., Cunniffe House, Rm. 111

University Health Services
[email protected]
Rose Hill Campus: O’Hare Hall (Lower Level)
Phone: 718-817-4160
Fax: 718-817-3218
Nurse Fax: 718-817-2221

Lincoln Center: 140 W 62nd St., G-16
Phone: 212-636-7160
Fax: 212-636-7164

Updated: January 6, 2026