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General:

General:

The University of Washington is committed to the safety of all individuals who engage in university programs and activities. As UW hosts over 200 programs and activities involving over 200,000 youth annually, this policy is in keeping with the university’s commitment to ensure that all youth who engage with the university are protected from harm and have a high-quality experience. The requirements laid out in this policy serve as safeguards to protect the well-being of these youth.

This policy is effective as of its approval date, September 4, 2019.

Individual units and departments are responsible for maintaining compliance with the policy. The Office of the Youth Protection Coordinator provides support and conducts periodic monitoring with respect to policy compliance. There is not a specific enforcement entity (e.g., the compliance police), however the consequences of not maintaining the minimum requirements set forth in APS 10.13 might involve individual or departmental disciplinary action or liability to the University, or worst of all, harm to a youth.

This policy does not impose any new approval requirements. However, it is expected that any youth program has the full support of the responsible department or unit.

Policy scope:

 

Policy scope:

Yes, though your program may have been around for several years, all youth programs, new and pre-existing, are required to comply with all aspects of this policy.

This policy does not apply to events at which youth may be present, but that are not created for, or directed at, youth. View guidance on what types of programs, activities, events, and research are required to follow this policy.

 No, unless the workplace is also a program designed specifically for or directed at youth. Programs that employ youth must abide by the regulations in APS 44.3 and state and federal regulations for employing youth. 

Yes, programs specifically created for or directed at a youth audience must comply with this policy regardless of how many or how few youth are involved. A high school internship opportunity might be an example of this.

Yes, in this case the high school is a third party youth program and UW is simply allowing use of the facility. If the professor has a written agreement with the group, it should include reference to this policy. The responsibility is on the school group to meet the requirements of the policy. 

Yes. Even though this program takes place off campus in local schools, the program is operated by UW and must adhere to the requirements of this policy. See specific policy requirements

Yes, as this program is directed at a youth audience and uses UW property/facilities, the coach as a third party camp operator is required to meet or exceed the policy requirements. A representative of the hosting facility is required to register your program.

Research:

 

Research:

Yes. If your research activity involves youth (persons under the age of 18) as a primary subject population you must comply with this policy.

Yes. Your exemption granted by the IRB or the UW Human Subjects Division does not pertain to this policy. If your research involves youth (persons under the age of 18) as a primary subject population, you must comply with this policy.

Yes, you must register your research in the Youth Program Registration System (YPRS). The YPRS can import select data from the UW Zipline system used for UW IRB review. Thus:

  • If you will submit an application via Zipline, or have already done so, please follow instructions here to access a pre-populated YPRS registration based on your Zipline submission
    • This applies regardless of whether a determination by HSD has been made yet. 
    • Even if the determination made by HSD was that your study is considered “considered not research” you will need to complete a pre-populated form in YPRS.
    • Once you edit and submit your pre-populated registration form, you will be guided through the next required actions.
  • If you have not and will not submit an application via Zipline, please follow instructions here to begin YPRS registration from scratch
    • This is most common if the research is known to not need IRB review without Zipline submission having been made (e.g., researcher was advised via email or phone that IRB review is not needed).
    • Once you edit and submit your registration form, you will be guided through the next steps of policy compliance. 

Yes. When the YPRS pulls a study from Zipline and creates a draft registration form, our office reviews the form and Zipline information to ensure the study is in-scope of APS 10.13. If it is determined to be in-scope, we will send a notification via YPRS to the PI listed in Zipline, outlining next steps.

If another research team member, such as a research coordinator, will be doing the registration process, simply email us at uwminors@uw.edu and we will add that person to the registration form so they may edit, view and submit it. 

All research, including those studies deemed exempt from IRB approval or not considered research by the IRB (e.g., evaluations or quality improvement studies), should be registered in the Youth Program Registration System (YPRS) using the research registration form. The youth program registration form is intended for other youth-involved activities such as summer camps, outreach activities, and enrichment programs. Learn more about the YPRS.

Also, if you have submitted or will submit your research via Zipline, please see the question above regarding registering those projects in the YPRS.

Most likely, yes. If your project involves UW staff/researchers having interactions (in-person or virtually) with minors, those UW researchers must abide by requirements in APS 10.13.

No. If your research does not involve any in-person or virtual interactions with youth, you do not need to follow the requirements of this policy.

It depends. If you indicate any youth involvement (e.g., via Zipline), your study materials will be reviewed by our office. In review of your study, we may communicate to you that you are not subject to APS 10.13. This is a rare exception, however, as most studies involving youth to any extent will be subject to APS 10.13. If you have questions regarding APS 10.13 applicability given the involvement of youth in your project, please contact uwminors@uw.edu

Yes. APS 10.13 applies whether interactions are virtual or take place in person. There are special considerations and risks for virtual interactions: please also see University privacy guidance for virtual interactions.

Research abroad varies widely. We recommend that you contact us at uwminors@uw.edu to discuss your specific circumstances.

Yes. You still need to register your study in the YPRS, however, when asked if any UW staff, students, faculty or volunteers will be collecting data from or interacting with youth (in person or online), you may select “No”. When you select “No”, you will not be required to list any Authorized Personnel or Other Personnel.

Third parties:

Third parties:

Third parties that are sited on UW property or that use UW facilities must meet or exceed the requirements outlined in APS 10.13. 

UW departments that host third parties in your facilities are responsible for completing the registration of the third party-led youth program in the Youth Program Registration System prior to the start date of the program. Additionally, they must communicate expectations that third party-led youth programs will meet or exceed the requirements of APS 10.13 in any written agreements with the third party. Ultimately the third party is responsible for their own compliance with the policy. Having a written agreement in place (e.g., contract, lease, etc.) allows you to state your expectations and confirm acknowledgment by the third party.

Note that UW-affiliated Registered Student Organizations (RSOs) are considered a third party under APS 10.13 and must follow the requirements for third parties.  

If you have concerns that youth may be at risk due to a third party not complying with this policy and its procedures, you may consult with the Office for Youth Programs Development and Support at uwminors@uw.edu. If you have immediate safety concerns, call 911.

Registering your youth program:

Registering your youth program:

Additional FAQs relevant to the registration system can be found under Background Checks FAQs and Training FAQs.

If your program meets the definition of a “UW Youth Program,” you are required by APS 10.13 to register your youth program with the UW Youth Program Registration System. For more guidance on what constitutes a UW Youth Program, please see our APS 10.13 Policy Resource Guide.

Youth Program directors themselves may enter information into this system, or, if they prefer, designate another staff member to enter information on their behalf. To do so, this designee will must be listed as a program director within the YPRS. Those listed as program directors have administrative access to view the records and compliance of all staff affiliated with their programs; given this, we recommend the program director role be reserved for those in oversight or leadership positions only. For instructions on how to add a designee to the program director role in the YPRS, please see our YPRS tutorial page.

For non-UW youth programs, i.e., third party-led youth programs using UW facilities or property, a UW representative of the host facility or department must register the program. Individuals outside of UW do not have access to the YPRS.

For UW Youth Programs, the YPRS guides program directors through a series of questions about general program and personnel information. Among other details, program directors will provide:

  • Purpose and scope of program/event/activity/research
  • Schedule and location of meetings 
  • Lists of personnel involved in youth program and with direct, unsupervised access to youth

A complete list of questions is available here [PDF]

Once programs are registered in the YPRS, the system will serve as a central mechanism for youth programs to track background check and required training completion data in real time for any personnel affiliated with their programs. 

For third party-led youth programs, the YPRS guides hosting representatives through a series of questions about general program information. No information about personnel for third party-led youth programs is collected.

The only information about youth participants entered into the YPRS is the number of participants in each session/program and the age range of participants. No information about individual youth is collected.

You may register your program in the YPRS here. Please see our How To page for step-by-step instructions for completing common tasks in the YPRS.

An accessible version of the YPRS is available and we welcome additional feedback about how to expand equitable access to the system and the registration process.

The Youth Program Registration System was built by our trusted external vendor, Ideal-Logic, and is managed by the Office for Youth Programs Development and Support. The system sends automated messages to notify staff and program directors of their compliance requirements; you may receive notifications sent from an @ideal-logic.com address.

For UW Youth Programs, you must (a) register your program via the YPRS and (b) confirm completion of both background checks and the two required trainings for all authorized personnel before the start date of your program. This is to ensure all personnel have met the training and screening requirements before interacting with youth. (You can track the completion of these items for all staff via the YPRS.) Completing these requirements can take some time, so youth programs are encouraged to begin the registration process at least 30 days prior to the program start date to allow for background checks and required trainings to be completed in time.

For third party-led youth programs, you must register the program your department or facility is hosting before the start date of the program.

Registration in YPRS is required of all UW youth programs and third party youth programs, so registering is itself the first step towards compliance with the policy. Additionally, for UW youth programs, YPRS asks programs to list authorized personnel for each session, and tracks those personnel’s completion of two UW-specific trainings and a background check.  Learn more about tracking compliance for staff. For a program to be compliant with the policy, all requirements must be completed by all authorized personnel before the start date of each affiliated session.

You will need to register programs in the YPRS:

  • Before beginning new sessions or programs;
  • When you hire new personnel or volunteers to staff your programs/sessions; and
  • For ongoing, continuous programs, once annually to ensure your program details, dates, locations and personnel are up-to-date. Some fields in the YPRS may be copied from one year to the next to streamline registration.

The calendar feature in the YPRS is designed to help you represent when you will be interacting with youth. The goal is to reflect your schedule as accurately as possible. For example, if you run a program in schools, it would be inaccurate to merely select a start and end date (e.g., September-June) unless you ran programming on weekdays, weekends, and holidays. Instead, use the calendar features to select only the days you will have contact with youth: 

  • If your session runs for more than one day you may use either ‘multiple days’ to indicate your session runs for multiple consecutive days, or ‘recurrence’ to indicate your session has multiple meetings that run on a regular schedule (e.g., every Thursday, the third Monday of the month, or the 16th of every month). 
  • If your session runs on a schedule that does not include regularity or consecutive days, select ‘multiple days,’ enter your start and end date, and click ‘off’/deselect the days your session is not meeting by clicking on each date. 
  • Use the ‘weekday only’ feature to filter out weekends from your activity dates.

The date and time feature will only allow you to specify a year’s worth of dates, starting from the start date of your session. This is most applicable to year-round programs and is due to the requirement to re-register annually. One year from your start date you will be required to ‘renew’ your registration in this system and enter in your next year of program dates at that time.

Yes. You may request administrative access to the YPRS for a designated department, unit, school, or college. This level of access will allow you to view data submitted by programs in the designated area and generate reports from that data.

Each program should be registered separately if it has a different purpose/goal, and/or different staff, groups of participants, or activities. If the programs contain the same activities and personnel, but simply have different youth involved during different points throughout the program, it should be registered as one program that contains multiple “sessions.” The registration process asks you to itemize different ‘sessions’ in order to accurately match staff with the time periods during which they will be interacting with youth. Learn more about defining programs and sessions with this tutorial [doc].

The YPRS tracks completion of these trainings via the Bridge LMS, which is linked to individual UW NetIDs (as of June 2019). If your staff took the training prior to that date, or if they watched the training as part of a group with only one person signed into Bridge, the YPRS will not recognize the training as complete. In this case, your staff may either retake the training via Bridge or you may contact us to discuss other options: uwminors@uw.edu or 206-616-5706.

Background screening:

Background screening:

Authorized personnel, which designates any university employee, volunteer, student, and intern, who in the course of their duties at the University supervise, chaperone, act as a caregiver for, or have unsupervised access to youth in educational programs, activities, events, and research.

Not necessarily. Employees only receive a background check if there is an indication in their job description or appointment letter that they have a security/safety/sensitive role. Involvement in a youth program often falls outside of duties listed in a job description or appointment letter.

Furthermore, the background screening may be out of date (i.e., older than 3 years) or were not been completed due to exemptions for employees hired before July 1, 2007. There are no exemptions for employees or volunteers involved in a youth program.

All authorized personnel must complete the UW’s standard background check process. Using a universal process ensures everyone receives the same level and rigor of screening, consistent with the requirements set by the University. If your program already has a screening process in place, consider whether the centralized process is sufficient to provide the information you need.

If your candidates are screened due to another affiliation, they may be subject to duplicate screenings to fulfill the requirements of both entities.

Currently, background checks for staff (including professional, classified, temporary, seasonal, student employees), academic personnel (including faculty, TAs and other academic student employee classifications), students (including employees and volunteers) and volunteers are done by UW HR. UW HR uses two vendors to complete the screening process: Washington State Patrol (WATCH) and A-Check Global.  

 

In order to maximize the 3 year period that background checks are valid for youth-facing work, we initiate background checks one month before your program start date. For example: If you are registering a program that will begin August 1st in March, the background check process will begin July 1st for that program. If you are registering a program that will begin April 1st in March, the background check process will be initiated immediately upon your submission of your registration form.

The Youth Program Registration System, which facilitates initiation and tracking of this screening process, was built by our trusted external vendor, Ideal-Logic, and is managed by the Office for Youth Programs Development and Support and UW HR. The system sends automated messages, using an @ideal-logic.com email address, to notify staff and program directors of their compliance requirements. Responses to these messages are directed to ypbc@uw.edu, which is managed by UW HR.

No. Third parties are required to conduct their own background screenings, using a process that meets or exceeds UW’s background screening standards.

Background screenings must be completed once every three years. If an authorized personnel does not have a background screening on file, or that background screening is over three years old, a background screening will be initiated prior to interaction with youth and once every three years thereafter. If an authorized personnel leaves employment at UW and returns, they must complete another background screening, even if it is within the three year timeframe.

Each background check is manually verified by our HR representative, and as such, even if you have a valid background check on file it will not show up immediately as a green check mark. Additionally, if you are an authorized personnel for multiple programs, each time you are added to a program you will show up as red X until it is verified by our HR representative. The initial verification step may take a week or longer and you may be asked to complete a D&A form to provide your date of birth in order to be searched in UW HR’s background check database. 

The department hosting the youth program is responsible for the cost of the background screenings. The cost of the background screening process varies based on the individual, with $43 as the average cost. Screenings including international services (criminal records searches, employment or education verification, etc. conducted outside the United States) are more expensive, costing up to $150. 

We recommend initiating the background check process (via listing of authorized personnel in the YPRS) 4-6 weeks before your start date. While most reports are completed in 3-4 business days, they can take much longer. For example, background checks including international services (criminal records searches, employment or education verification, etc. conducted outside the United States) can take significantly longer. Delays do occur in a small percentage of background checks due to factors outside of A-Check Global’s control including:

  • Incomplete or inaccurate information provided to A-Check Global during the background check request submission
  • Unresponsive third parties (applicant, employers, references, educational institutions)
  • Holidays: courts and schools may be closed on holidays
  • Natural Disasters
  • Court, educational institution or employer procedural delays.
  • Court technical difficulties or furloughs

For more information on background check statuses in the YPRS and how you as program director can be up to date on your staff’s required actions, see the background screenings for authorized personnel webpage.

UW Human Resources will conduct background screenings and will be responsible for maintaining records. Programs will be able to access background screening completion dates in the UW Youth Program Registration System.

To notify HR that an authorized personnel needs to have a background screening completed, add them to your authorized personnel list in the Youth Program Registration System. When an individual is added to this list, the system will flag that they need to complete a background screening and HR will begin the process.

The Youth Program Registration System will flag an authorized personnel when their background screening has reached the three year mark and they need to complete another background screening. Program administrators are able to log in and see a list of employees that need to complete background screenings at any time.

On the application, check the box marked “No SSN to provide.” If you’ve already completed the application but are being contacted by an A-Check representative for SSN information, respond to their email to indicate that you do not have a SSN to provide.

Training:

Training:

Program directors are responsible for ensuring that their staff have taken the required “Promoting Safe Interactions with Youth” and “Reporting Suspected Child Abuse or Neglect” trainings. Starting in fall 2019 the Office for Youth Programs Development and Support will track completion of these trainings and note in the registration system when a program staff member has completed them. Program directors will be able to log in and view which staff have/have not completed the trainings.

All authorized personnel are required to complete the “Promoting Safe Interactions with Youth” training. Additional trainings are encouraged and up to department discretion, but may not be used in place of this required training. 

If you are having issues accessing the training in Bridge LMS please contact the UW-IT Service Center by phone at 206-221-5000 or by email at help@uw.edu.

At this time the trainings are only available in English.

Standards for Interacting with Youth:

Standards for Interacting with Youth:

No. You will be considered in compliance with this aspect of the policy when you have ensured that all authorized personnel:

  • have viewed the Standards for Interacting with Youth
  • understand the reporting requirements, 
  • agreed to abide by them, and
  • have certified all of the above by signing an acknowledgement form. 

Starting February 1st, 2021, authorized personnel will be required to digitally certify this in the Youth Program Registration System. Automatic notifications with instructions on how to complete this certification will be sent to authorized personnel in sessions beginning February 1, 2021 or later. When all authorized personnel have digitally signed the conduct code, your session will be considered compliant with this aspect of the policy. 

 The University Standards for Interacting with Youth represents the conduct expectations for authorized personnel in all youth programs. 

    • Authorized personnel for youth programs will electronically sign a version of this code of conduct. 
    • Authorized personnel for youth-involved research studies will sign a version of this code of conduct. This form is forthcoming.

If your session involves virtual interactions, authorized personnel affiliated with that session will also be required to sign the Addendum: Virtual Interactions with Youth. (Virtual interactions are indicated by answering “yes” to Session Attribute #13: “Online/virtual interactions (e.g. via Zoom)” or selecting “online/virtual” as a session location when registering in the YPRS.

You may impose more stringent standards on your staff that function to safeguard youth from harm based on your specific program. You may not change existing Standards for Interacting with Youth in any way that lessens the expectations of staff members in their interactions with youth. 

No. Currently only the standard code of conduct reflecting the University Standards for Interacting with Youth and the Addendum for virtual interactions with youth are available via the YPRS. If you wish to add additional conduct expectations, you may do so, but you should communicate those expectations, and receive confirmation of your staff’s commitment to abide by them, via another method outside of the YPRS. 

Authorized personnel will be required to sign the youth program conduct code and/or the research study conduct code once annually. (If personnel are involved in both research and youth programs, they will sign both.) If they are affiliated with a session that will involve virtual interactions, they will also be required to sign the Addendum: Virtual Interactions with youth once annually. 

If they are involved in multiple youth programs or multiple sessions of a youth program during that time, they will not be required to sign the form for each instance. (Likewise, if a researcher is involved in multiple registered youth-involved research studies or multiple sessions of a study, they will not be required to sign the form for each instance.) Once the year has elapsed, the next time the person is listed as affiliated with an active session of either a youth program or research study, they will be asked to re-sign the form.

Only authorized personnel involved in sessions indicating virtual interactions will be asked to sign the Addendum. If personnel have not yet signed the Addendum and are added to a session using virtual methods, they will be asked to sign the Addendum at that time.

 The YPRS will send notifications to any authorized personnel who have not yet signed the relevant code(s) of conduct and/or addendum and those whose signature has expired. The email notification will include a link to access the appropriate code/addendum via the YPRS. The YPRS is accessible using your UW NetID and password. Non-NetID holders will create or activate a “community login” account through Ideal-Logic, our trusted YPRS vendor, to sign the form. (Note that this same “community login” is required, and can be used, to sign other required forms, including the Self-Disclosure and Authorization used to initiate the required background check.)

Currently, only authorized personnel can access and sign the conduct code in the YPRS. We hope to make this form available for digital signature by others in the future. Please stay tuned.

Reporting behaviors of concern:

Reporting behaviors of concern:

If you believe a staff member involved in a UW youth program has violated the Standards for Interacting with Youth you must report it to SafeCampus at 206-685-7233 within 48 hours. If you believe that they have violated the standards in a way that causes concern that abuse or neglect may have occurred, you must additionally contact either DCYF Child Protective Services or law enforcement. View more information about reporting suspected child abuse and neglect.

If you are unsure if someone’s behavior is a violation of the Standards, you can first review the accompanying Behaviors of Concern continuum [PDF] which further defines behaviors of concern and can help guide which action to take. (For help using the Continuum, view our mini-module on the topic.) Additionally, you can contact SafeCampus or the Office for Youth Programs Development and Support at uwminors@uw.edu for guidance.

You can not be retaliated against for reporting concerns to SafeCampus as part of your obligations under this policy. As part of UW APS 46.3 you are protected when making a complaint about a University employee and can not be retaliated against. Additionally, SafeCampus and the Office for Youth Programs Development and Support will work with you to protect your identity as best as they are able, while taking steps to address the violations you have reported.

Safe Environments:

Safe Environments:

The policy requires that you adhere to all relevant state, federal, and UW regulations and requirements in order to provide a safe environment for youth. Your compliance is evidenced by ongoing adherence to these regulations and requirements.

UW Environmental Health and Safety provides guidelines for making STEM environments safe for youth. Additionally, University APS 10.9: Visitors and Children in University Laboratories and Shops, regulates how and when youth may be in labs and shops at UW.

Emergency/Safety Planning/Response:

Emergency/Safety Planning/Response:

Yes, your program must have its own emergency preparedness plan and be sure that staff are able to implement if necessary.

Sample plans are available here to provide guidance for developing a plan for your youth program. Additionally, if you have unique circumstances or considerations and want to consult with someone in order to develop a plan, you can contact the Office for Youth Programs Development and Support at uwminors@uw.edu.

Programs operating off-site should follow the emergency response protocols of the host location when there. Program directors should make sure all staff/volunteers receive a copy of the host location’s emergency plan and are able to review it and ask questions to an appropriate source before beginning work at that location. Additionally, contracts with the host location should include clear provisions and procedures for youth program staff/volunteers (if different from that of host program staff) in the event of emergencies, and clearly outline responsibilities of the host location and the youth group.

Example procedures are in development by the Office for Youth Programs Development and Support. Complete procedures should include plans for medication management, handling a health crisis/emergency and handling known health conditions disclosed by a youth participant or their parents.

Privacy:

Privacy:

Help please!

Help please!

If you have questions about APS 10.13, please view the APS 10.13 Policy Resource Guide for comprehensive policy implementation guidance. If you have remaining questions, contact the Office of the Youth Protection Coordinator at uwminors@uw.edu.

If you have questions about the background screening process, please view UW HR’s FAQ page first. If you have remaining questions, contact ypbc@uw.edu.