The University is committed to protecting the safety of the entire University community, including minors visiting our campuses. To protect minors on campus, the University encourages individuals interacting with minors to participate in an online training program, Recognizing and Reporting Child Abuse.
Because of the university's strong institutional interest in protecting minors, the University has established expectations and requirements pertaining to Activities involving minors on campus. Activities is defined to include, and is not limited to, camps, clinics, and programs.
This includes Activities that are owned or operated by the University as well as non-University-owned or -operated Activities taking place on our campuses.
In all cases, no Activity employee or volunteers are permitted to have contact with any minor in connection with an Activity until the appropriate responsibility center head or authorized designee has reviewed the required clearances and approved each such individual.
The following is a summary of the requirements for a responsibility center to most Activities involving minors on campus.
Process for the registration of activities involving minors
Responsibility centers which own or operate Activities and responsibility centers which host Activities owned or operated by third parties are required to register the Activities with the Office of Human Resources. The appropriate University responsibility center head or their designee (“Activity Facilitator”) is responsible for registration of the Activity as outlined below. In addition, no Activity workers/volunteers may be permitted to have Direct Contact or Direct Volunteer Contact, as applicable, with any minor in connection with an Activity until the Activity Facilitator has reviewed the required clearances and approved each such individual.
Registration of and Required Clearances for University Owned and Operated Activities
The Activity Facilitator is responsible for collecting, reviewing and approving the required clearances from each and every person who will or may have Direct Contact or Direct Volunteer Contact, as applicable, with minors in connection with the Activity. The required clearances are:
- Pennsylvania State Police Criminal Record Check,
- Pennsylvania Department of Human Services Child Abuse History Clearance, and
- FBI Criminal Record Check. A limited exception exists whereby, under certain conditions, volunteers who have lived in Pennsylvania for the past 10 years do not need to obtain the FBI Criminal Record Check if the volunteer instead signs and submits a properly completed form Disclosure Statement. Please see Keep Kids Safe website.
In the event the Activity worker is a University employee, the Activity Facilitator, using the on-line roster, can verify with the Office of Human Resources that all the required clearances are acceptable and on file with the University.
In the event the University employee does not have required clearances on file with the Office of Human Resources, the employee must complete the required clearances, following the Child Protection Clearance Instructions. In addition the employee must submit the completed clearances to the Office of Human Resources by using the Child Protection Clearance Upload.
The law permits unpaid volunteers to use clearances that are less than 60 months old (from the conclusion of the Activity) regardless of whether the clearance was previously obtained for the purpose of employment or volunteer service. However, prior to commencement of the Activity, an individual who relies upon a clearance originally obtained for another entity must sign a Portability Disclosure Statement to swear or affirm that they have not committed a disqualifying offense.
The law permits new and current employees to use clearances that are less than 60 months old (from the conclusion of the Activity) and that were not obtained for volunteer service. However, all employees who use clearances less than 60 months old that were originally obtained for another employer must also sign a Portability Disclosure Statement to swear or affirm that they have not committed a disqualifying offense.
Completion of the Roster and Submission of the Required Clearances:
In addition, prior to commencement of the Activity, the Activity Facilitator must:
- Prepare, review and submit the roster of all Activity workers/volunteers;
- Review the original clearance reports of all relevant volunteers and keep a copy of each clearance report;
- Confirm with the Office of Human Resources utilizing the on-line roster tool, each University employee working the Activity has the required clearances and portability disclosure statements, as applicable, on file in the Office of Human Resources;
- Document compliance by executing the attestation form found within the on-line roster and submitting it to the Office of Human Resources prior to the commencement of the Activity. This includes attaching copies of the clearances for all non-University volunteers; and
- Exclude from the Activity any such individual whose record indicates they are disqualified (please refer to the links below for guidance on this determination) or who does not have the required clearances.
Student Volunteers: Student volunteers who have Direct Volunteer Contact with minors and student employees who have Direct Contact with minors are subject to the same child protection clearance requirements as other volunteers and employees except as noted below for student volunteers. A student volunteer does not have to obtain the required clearances if all the following apply:
- The student is currently enrolled at the University
- The student is not a person responsible for the child’s welfare
- The student is volunteering for an event that occurs on campus
- The event is sponsored by the University
- The event is not for children who are in the care of a child-care service.
Registration of and required clearances for third party or non-University owned or operated Activities
The Activity Facilitator must require that the owner or operator “licensee” enter into an appropriate license agreements with the University for the use of the University’s facilities, including housing and food services, if applicable. Questions concerning the appropriate license agreements can be directed to the Office of General Counsel at 412-624-5674. The license agreements must obligate the owner or operator to obtain and review the same required clearances described above, dated within the immediately preceding 60 month period from the conclusion of the Activity, from all its workers/volunteers who will or may have direct contact with minors in connection with the Activity and obligate the owner or operator licensee to provide the University adequately in advance:
- A roster of all Activity workers, including volunteers and employees;
- Copies of their clearances and, where applicable, Portability Disclosure Statements;
- A written certification (attestation statement found within the automated roster) signed by an authorized representative of the owner or operator, in form and substance acceptable to the University, stating that the owner or operator has obtained and reviewed the clearances of all of their workers/volunteers and has concluded that none of those on the roster pose a risk to minors under the age of 18 or to others.
Completion of the Roster and Submission of the Required Clearances:
Prior to the commencement of the Activity the Activity Facilitator must:
- Prepare, receive and review the roster of all Activity workers/volunteers, including unpaid volunteers;
- Review the required clearance reports of all relevant Activity employee workers/volunteers;
- In the event the Activity worker is also a University employee, confirm with the Office of Human Resources, utilizing the on-line roster tool, that each University employee working the Activity has the required clearances on file in the Office of Human Resources and separately confirm receipt of the applicable Portability Disclosure Statement as discussed above;
- Document compliance by executing the attestation form found within the on-line roster and submitting it to the Office of Human Resources. This includes attaching copies of the clearances for all non-University Activity worker/volunteers; and
- Exclude from the Activity any such individual whose record indicates they are disqualified (please refer to the link below for guidance on this determination) or who does not have the required clearances.
If you have any questions, please contact Human Resources.