Youth Protection and Compliance

UW-Eau Claire Policy 625

Original Issuance Date: March 1, 2023

Last Revision Date: October 8, 2025

1. Policy Purpose

This purpose of this policy is to establish minimum standards for the protection of minors engaged in covered activities at UW-Eau Claire. This policy does not supersede any stricter standards set by the Universities of Wisconsin and state or federal law.

2. Responsible UW-Eau Claire Officer

Director of Risk Management, Safety & Sustainability

3. Scope and Institutional Responsibilities

The scope of this procedure is limited to youth participants in covered activities. The policy only applies to events which are targeted towards youth participants in covered activities. Activities that are exempt from this policy include:

Events open to the general public,
For-credit courses,
Medical care provided to minors in in-patient or out-patient settings,
Institutional Review Board-approved research,
Daycare and preschool services operating under the direction of a licensed daycare or healthcare provider,
Private events, or
Minors participating in pre-enrollment visitation or recruiting activities governed by the NCAA.

Children brought into a campus workplace by an employee are covered under UWEC 239, Children in the Workplace.

4. Background

Minors come into contact with UW-Eau Claire through many programs and activities. UW-Eau Claire recognizes its fundamental responsibility for protecting the minors placed in its care and the value of identifying a multifaceted framework for youth protection.

In alignment with Wisconsin Executive Order 54, this policy expands on UW-Eau Claire’s efforts to provide safe and positive experiences for youth participants in covered activities. This policy also meets the requirements contained in Regent Policy Document 23-3, Youth Protection, Compliance, and Data Collection, which was approved on February 11, 2022, and Universities of Wisconsin Administrative Policy 625, Youth Protection and Compliance, which was approved on March 10, 2022.

5. Definitions

Terms included in this procedure are consistent with definitions included in SYS 625, Youth Protection and Compliance, and are defined for purposes of this policy and may not be consistent with definitions used in other settings.

6. Policy Statement

A. Institutional Oversight

I. The Office of Risk Management, Safety and Sustainability has the responsibility and authority to oversee and ensure that covered activities are conducted pursuant to SYS 625, Youth Protection and Compliance and applicable UW-Eau Claire policies and procedures.

II. The Director of Risk Management, Safety & Sustainability will designate a youth protection liaison to be the main point of contact with the Universities of Wisconsin for SYS 625, Youth Protection and Compliance.

All Covered Activities that are organized, sponsored, and/or operated by UW-Eau Claire must have a designated Institutional Sponsor (also known as a Sponsoring Unit).

C. Registration

I. Covered activities must register annually with the Office of Risk Management, Safety & Sustainability.

II. Covered activities providing custodial care which are organized, sponsored, and/or operated by UW-Eau Claire must have a designated Institutional Sponsor and require registration of youth participants. Registration information collected must include:

Name
Contact information, including emergency contact information

III. The Office of Risk Management, Safety & Sustainability must be granted access to Third Party contracts for covered activities upon request.

D. Screening

I. All designated individuals serving in covered activities through which UW-Eau Claire offers custodial care, regardless of employment status, must be screened through a reference check process in alignment with the minimum standards found in SYS 1275, Recruitment Policies.

II. All applicable data management and record retention policies must be followed for purposes of retaining this information.

E. Training

I. Prior to interaction with youth participants in Covered Activities, authorized adults must be trained on reporting responsibilities, including EO54 Mandated Reporting and sexual harassment/sexual violence reporting.

II. Prior to interaction with youth participants in Covered Activities, designated individuals must be trained on the following content:

Institutional youth protection best practices; and
Reporting responsibilities, including EO54 Mandated Reporting and sexual harassment/sexual violence reporting.

III. The Office of Risk Management, Safety & Sustainability may require additional training based on the individual’s role or level of risk associated with the covered activity (e.g., duration of program, type of activities) and applicable legal requirements.

F. Prohibited Behaviors

All UW-Eau Claire employees and students are responsible for identifying, monitoring and reporting prohibited behaviors. Prohibited behaviors include, but is not limited to, the following:

Conduct that violates the law (e.g., child abuse, child sexual abuse, protected class discrimination, emotional abuse, hazing, indecent exposure, child pornography, neglect, physical abuse, sexual abuse, and sexual harassment);
Conduct that violates Universities of Wisconsin policies;
Actions that are found to constitute bullying or grooming;
Infringement on privacy of Youth Participants in situations where they are changing clothes or taking showers except in situations where health and safety require;
Adults showering, bathing, or undressing with or in the presence of youth participants;
Use of such devices capable of recording or transmitting visual images in shower houses, restrooms, or other areas where privacy is expected by participants; and
Use of alcohol when engaged in covered activities.

G. Measures to Maintain adequate Supervision of Youth Participants

I. Supervision ratios in covered activities must meet the minimum standards set through ATCP 78.25, with the exception of classroom settings, which allow for a 1:18 Adult to Youth Participant ratio. A minimum of two adults is required for all field trips. Designated individual status is required for all adults serving in supervision ratios.

II. One-on-one interactions between adults and youth participants is prohibited, unless the adult is a designated individual in a setting where one-on-one instruction occurs. In such settings, activities must be observable and interruptible.

III. The Office of Risk Management, Safety & Sustainability will review and may approve exceptions to supervision requirements, including where a familial relationship exists.

H. Overnight Covered Activities

I. Designated individual status is required to directly supervise youth in overnight covered activities.

II. Designated individuals must not enter the youth participant’s room, bathroom facility, or similar area without another designated individual in attendance except in emergency situations.

III. Designated individuals may not share a bed or sleeping bag with a youth participant during overnight covered activities.

I. Emergency Preparedness

All covered activities must document minimum emergency preparedness protocols based on the covered activity’s level of risk and as advised by the Office of Risk Management, Safety & Sustainability.

J. Insurance Coverage

All covered activities must be covered by Camps and Clinics Blanket Accident Insurance or other insurance product(s) as applicable and approved by the Office of Risk Management, Safety & Sustainability.

K. Reporting Obligations

I. Adults covered under this policy must immediately report any suspected physical abuse, neglect or sexual abuse of a minor pursuant to UW-Eau Claire’s Mandatory Reporting of Child Abuse and Neglect policy.

II. Adults covered under this policy must report the following incidents that occur within a covered activity to the Office of Risk Management, Safety & Sustainability:

Sexual harassment or sexual violence as defined by the UW-Eau Claire Sexual Violence and Sexual Harassment Policy;
Incidents resulting in serious physical harm requiring professional medical attention, and
Incidents of illegal or unauthorized drug use.

III. The Office of Risk Management, Safety & Sustainability may identify additional reportable incidents.

IV. The Office of Risk Management, Safety & Sustainability will publish an Escalation Matrix to guide decision-making around incidents that violate policy or trigger a reporting obligation.

L. Retaliation

Retaliatory actions against the following is prohibited:

Anyone acting in good faith to report a concern about possible violations of Universities of Wisconsin or UW-Eau Claire policy;
Individuals involved in investigating or responding to concerns; and
Anyone involved in enforcement of youth protection policy.

M. Consequences for Noncompliance

Violations of this policy and/or associated policies, protocols, or procedures may be subject to program termination, and/or disciplinary action, including removal from the role or authorization to work with minors, in accordance with UW-Eau Claire policies and procedures.

N. Third Parties

Third Parties engaged in Covered Activities must sign a contract that includes, at minimum, the following:

Clear allocation of responsibility for risks posed by the Covered Activity to the Third Party;
A statement that third parties are responsible for completing criminal background checks of all authorized adults, in alignment with Regent Policy Document 20-19, University of Wisconsin Criminal Background Check Policy, prior to the commencement of the covered activities.
A statement that Third Parties engaged in Covered Activities must meet the minimum requirements outlined in Section 6.P.III of Universities of Wisconsin Administrative Policy 625, Youth Protection and Compliance;
A statement that audits on requirements in this section may occur at any time within seven (7) years following the conclusion of the event.

O. Data Retention

Covered Activities must store protected health information and other confidential and sensitive data according to Regent Policy Document 25-5, Information Technology: Information Security.