To protect the health and safety of participating minors and to ensure that Northwestern University can continue organizing and accommodating youth programs, adult supervisors in covered programs must observe reasonable health and safety guidelines. These guidelines may not apply to all programs and reasonable judgment should be used when managing any programs that involve children. If you have any questions about how to apply these guidelines to your program, please contact the Office of Risk Management.
The Sponsoring Unit is responsible for inspecting the area to be used prior to the activity to confirm that it is free of potential hazards and suitable for children.
Supervision ratios for program staff
It is essential that programs involving minors be supervised at all times. Supervision should be in place from the time the program begins until all participants return to their guardians. It’s important to be clear when a program begins and ends.
Day Programs: Northwestern recommends following the Staffing Ratios set by the American Camp Association, which are based on the age of the children participating.
Overnight Programs: For residential programs that use Northwestern Housing, the supervision ratio is one staff member for every 10 participants. Minors residing in the residence halls must be at least 14 years of age, unless accompanied by a parent or legal guardian.
In addition to supervision ratios, we recommend implementing the following for overnight programs:
- Clear disclosure in program materials that minors will be participating in an overnight program
- Curfew time
- Restrictions on guest access
- Program should comply will all security measures and procedures specified by University Residential Services
Program staff should always be sure a parent/guardian grants written permission for the program to provide transportation to the minor. If University vehicles will be used for this transportation, the adult driving the University vehicle needs to be authorized to do so by taking the Defensive Driving Course administered by the Office of Risk Management.
When transporting minors, more than one program staff from the program must be present in the vehicle, except when multiple minors will be in the vehicle at all times through the transportation. Avoid using personal vehicles if possible and comply with the program’s transportation guidelines.
Research in labs
In keeping with the institution’s mission of education and outreach, Northwestern provides opportunities to minors to gain experience in research laboratories for educational purposes. Program staff are responsible for the health and safety of minors in his/her laboratory. This includes appropriate safety training, use of laboratory equipment, laboratory supplies, and personal protective equipment.
Programs should establish and maintain emergency response procedures including but not limited to evacuation procedures, shelter in place procedures, and communications procedures with contact lists. An active, accurate roster should be maintained at all times. Evacuation procedures should incorporate familiarity with at least two exit pathways as well as designate a predetermined area outside and away from the building where program participants can gather and wait for further instruction from emergency response personnel.
Northwestern University utilizes a multi-tiered approach for emergency notification and information dissemination incorporating mass notification via phone, text messaging, and email, an outdoor alert system, in-building alarm systems, and homepage “Breaking News” banners.
Program staff should develop a plan for communicating with parents and guardians in the event of an emergency.
Communications procedures should minimally include internal Northwestern University contacts (i.e. Sponsor, School or Department Dean/ Director/ Vice President, University Police, etc.) as well as a current contact list detailing participant’s parent/guardian and an alternate contact’s home phone number, work phone number, mobile phone number, and email address. Written information regarding emergency communication procedures and the program’s emergency pick-up plan should be provided to parents either with program registration materials or on the first day of the program. An example of this can be found by reviewing Safety and Notification Procedures.
Medical care and treatment
In the event of an injury of a participant, program staff must establish a process for reporting any injury and document the nature, cause, and treatment administered for any injury. Parents and/or guardians should also be made aware of any injury to a child in their program. Program staff should obtain a Youth Program General Information Form and Youth Program Medication Release Form for each program participant.
Certain programs may be eligible for and benefit from utilizing the Northwestern University Health Service. To coordinate access for your program, contact Brian Druley at firstname.lastname@example.org or 847-491-2133.
Regulatory compliance related to minors in programs
There are a number of applicable federal compliance areas that programs serving minors should be familiar with. This includes the following:
- Federal Education Rights Privacy Act (FERPA)
- Title IX
- Child Online Privacy Protection Act
- Clery Act
- HIPPA (medical records, notification, and patient care)
Mandated Reporters are required by state law to make a report to the appropriate state agency when they have a reasonable suspicion that a child is being abused and/or neglected. Please review the Quick Reference Guide – Mandated Reporters for helpful responses to frequently asked questions, including who classifies as a Mandated Reporter and associated reporting obligations.
Records storage and retention
Programs should consult with the Office of the Provost on guidance on storage, retention, and destruction of documentation for programs serving minors. Various policies may apply depending on the data that is collected at the onset of the program. It is not recommended that documents be discarded until at minimum seven years and waivers should be held until participant reaches age of majority. Electronic storage of records may be permitted in some cases. Please review the Retention of University Records Policy for further information.
Participation agreements, contracts and waiver forms for third party contracts
Third party organizations hosting events with minors on Northwestern property or facilities should employ the use of participation agreements/liability waivers and note the location as Northwestern University. Third party programs bringing minors to Northwestern locations that are neither affiliated with or operated by Northwestern are required to demonstrate evidence that personnel have cleared a background check, received training, and reviewed Northwestern’s Minors in Programs at Northwestern Policy. The Northwestern Facility-Use and Services Agreement can be found on the resources section of the website.
All contracts should include the appropriate amounts of required liability insurance. Please refer to Independent Contractor Insurance Requirements or consult with the Office of Risk Management (Elizabeth.email@example.com) for more information on appropriate amounts. This may include naming Northwestern University as an additional insured and verification of molestation coverage.
Contents of University participation agreements
At a minimum, the University program agreements should include the following, which all can be found on the resources section of the website:
- Informed consent, release and assumption of risks forms, and voluntary waivers holding Northwestern and its affiliates harmless
- Medical release and permission to treat in the event of an emergency
- Photo release – permission to photograph a child for Northwestern media postings and/or releases
- Affirmation of sound medical health and explanations
- Listing of allergy conditions directly related to the program (if applicable)
- Statement on dispensing medication if participant required prescribed medication
- Rules of conduct for participants