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Policy on Safety and Well Being of Minors
If You Suspect Abuse or Neglect
In case of any emergency, dial 911 immediately.
In addition, you must:
1. Call the toll-free, 24-hour hotline for reporting child abuse and neglect: 800-792-5200
2. Call the Smith College Campus Police: 413-585-2490
Approved: April 13, 2015 by the President and Cabinet
Effective Date: May 9, 2015
Office/Administrator Responsible: Finance and Administration; Vice President of Finance and Administration
Important: To report suspected child abuse and neglect in MA, call 1-800-792-5200. This is a 24-hour number. Read more about this help line.
Smith College (Smith) is committed to safeguarding all children, young people, and vulnerable adults involved in our programs or on our campus. The following policy and procedures provide direction to employees, students and volunteers about expected codes of behavior and sound procedures. This policy and related procedures are intended to ensure that child protection concerns will be appropriately addressed and that our programs for children will be safe.
This policy covers all operations or programs of Smith College, including without limitation, educational, outreach, summer programs, theater and any other operations whether on or off the premises of Smith which involve minors and applies to all employees, students, volunteers and others who are under the direct control and supervision of Smith College faculty or staff.
EXCEPTIONS: This policy does not apply to Smith College matriculated students who may be under the age of 18. Admitted or prospective students who are participating in Smith College Admissions activities are not included in this policy. Students who are “dually enrolled” in Smith College credit-granting courses while also enrolled in elementary, middle and/or high school are not included in this policy unless such enrollment includes overnight housing in College facilities. This policy does not apply to minors who are employed by the College. The Smith College Campus School and Early Childhood Education Center are subject to state regulations and have policies and procedures specific to their operations. Any regulations which are stricter than this policy or in conflict with this policy or other Smith College procedures will supersede this policy or other Smith College procedures.
Smith College will not tolerate any abuse or neglect of a minor or other vulnerable person in any form (physical, sexual, or emotional) in any Smith program or on the Smith campus, and will take active steps to prevent any such abuse from occurring.
1) Mandated Reporting
Smith College employees covered under the Mandated Reporter rule are required by law to report any incident of suspected child abuse to appropriate authorities. All Mandated Reporters and Designated Persons must report suspected child abuse in accordance with State Rules. See the Mandated Reporter's Guide for more information.
Massachusetts law defines several professionals as mandated reporters; the following list includes those professions that a Smith College employee may work in:
- Physicians, nurses; emergency medical technicians,
- Public or private school teachers, educational administrators, guidance or family counselors;
- Early education, preschool, child care or after school program staff
- police officers;
- School attendance officers, allied mental health and licensed human services professionals;
- Psychiatrists, psychologists and clinical social workers, drug and alcoholism counselors;
- Clergy members
2) Report to the College
College policy requires that any incident of suspected child abuse or neglect also be reported to the college. If circumstances warrant suspicions or questions, an employee should immediately notify:
- Campus police
- And their supervisor, department or division head, or the Director of Human Resources, or an appropriate supervisor
- And the Director of Compliance and Risk Management.
Making a report to College administrators does not exempt the employee who is a Mandatory Reporter from making a report to the appropriate authorities
3) Program Registration Required
All Smith College “programs” involving minors must be registered through the Child Safety Certification website. Once registration is complete, the responsible Program Director will ensure the each authorized adult (staff and volunteers) who will have unsupervised contact with minors in the program are Child Safety Certified before permitting their participation in the program.
4) Child Safety Certification Required
All faculty members, staff, students, volunteers, and other members of the Smith community who may have direct and unsupervised contact with children in the course of their employment or service activity must pass the Smith Child Safety Certification prior to commencing their employment or service activity. There are two parts to the Child Safety Certification process: Background (CORI/SORI) checks and Child Safety Training. Successful completion of these parts will convey Child Safety Certification to the individual for a period of three (3) years and apply to all college programs.
a. Reference and Background Checks Required
The first and most effective means of preventing child abuse is screening out potential abusers before they come to the campus or participate in children’s programs.
All persons who may have direct and unmonitored contact with children in the course of their employment or service activity will be given thorough reference and background checks, including review of criminal and sexual offender records (CORI/SORI checks). The list of employee positions that require background checks is managed by the Office of Human Resources (for faculty/staff) and Dean of Students Office (for students). Other persons may include:
- faculty, staff, students, volunteers, and other members of the Smith community
- contractors (i.e., photographers, van drivers, and caterers) who provide services to Smith functions or activities where the contractor may have direct and unmonitored access to minors
- students working as volunteers either on or off campus (i.e., athletics programs, tutoring and mentoring programs, community service projects, research team members, and other Smith-sponsored activities that involve children)
- Student volunteers participating in short-term orientation or recruitment activities with older (high school-aged) students (admissions, athletics, pre-orientation groups, etc.) IF the program involves unsupervised contact (such as overnight stay in the student’s room).
Because there is no federal database for this information, background checks will include a multi-state search, especially of those states where the applicant previously resided and worked. Human Resources will process and manage all CORI/SORI checks for employees, non-Smith-affiliated volunteers and contractors. The Dean of Students office will process and manage all CORI/SORI checks for matriculated Smith students.
Smith reserves the right to conduct additional background screening any time after employment or volunteer service has begun. All individuals subject to the requirements of this policy, and who enter into employment or volunteer service with the College, will undergo periodic background checks. Any misrepresentations, falsifications, or material omissions in the information provided by the applicant, whenever discovered, may result in disqualification from, or termination of employment or volunteer service with the College.
All background screening accomplished by or on behalf of Smith will comply with the Fair Credit Reporting Act and other relevant privacy laws.
For more information, see Background Checks and Child Safety Certification.
b. Child Safety and Molestation Prevention Training Required
For any child abuse prevention policy to be effective, the people implementing the policy and providing services to minor children must have adequate education and training.
All faculty, staff, students, volunteers, and other members of the Smith community who work or volunteer in Smith programs with children are required to participate in the child abuse prevention education and training course(s) determined appropriate by Smith at least once every three years and prior to commencing their employment or service activity.
The training will raise awareness of the nature of child abuse and its prevalence in all segments of society, and will include training in abuse prevention strategies; how to identify situations of abuse, neglect or similar endangerment; how to respond to a disclosure of abuse by a minor; how to report those situations to civil and school authorities; and what actions to take to prevent abuse of children (or minimize further harm) on Smith property and at Smith-sponsored events and activities. No person required to take the training will be allowed unsupervised access to children until the training is accomplished.
Students who are participating in community service activities through an independent host entity (e.g., Big Brothers/Big Sisters) and who are CORI/SORI checked by their host are required to take the Child Safety Training but are not required to be CORI/SORI checked by the college.
5) Limitations on Gifts and Interactions
Faculty, staff, students and volunteers are strictly prohibited from:
- giving gifts as individuals to minors or vulnerable adults or their families outside of the specific requirements of the program or the specific requirements of their job,
- meeting with minors or vulnerable adults individually or with their families outside of the specific requirements of the program or the specific requirements of their job, or
- interacting with minors or vulnerable adults individually or with their families through electronic communications such as email or on personal social media sites such as Facebook, Twitter, or other similar sites outside of the specific requirements of the program or the specific requirements of their job.
6) Emergency Response Planning Required
Every college-sponsored program which involves minors shall establish an appropriate Emergency/Crisis Response Plan.
See Procedures for details.
Under the following circumstances, Smith Campus Police will conduct a prompt and thorough internal investigation in accordance with its procedures:
- If the alleged abuse of a child has taken place on campus or at a Smith-sponsored event, or if the alleged perpetrator is employed by or associated with Smith College and Smith Campus Police have made the required oral and written report to DCF.
- If the allegations are against a person who is no longer employed by or associated with Smith College, but occurred while the accused was affiliated and Smith Campus Police have ensured that the required oral and written report has been filed with the appropriate civil authority.
All members of the Smith community are required to cooperate fully and truthfully with the investigation. In the interests of safety for all involved, Smith will take appropriate action regarding an accused faculty member, staff, other employee, student, or volunteer until the investigation is completed.
Other incidents involving accident or injury may be investigated by Campus Police, the Office of Compliance and Risk Management or other safety personnel, as may be necessary or appropriate.
8) College Sponsored Programs for Minors – Other Requirements
In addition to the other terms of this policy, every college-sponsored program which involves minors shall follow College Procedures for such programs.
9) Ad-hoc Day Care
No Program or college department shall establish an ad-hoc day care program (e.g., for an adult conference or meeting) without first obtaining approval from the Office of Compliance and Risk Management.
10) Programs Involving Minors Operated by Outside Parties on Smith College Property
Any program involving minors operated by outside parties on Smith property must be operated consistent with the guidelines of this Policy. All contracts for the use of College facilities by outside parties for programs involving minors must reference this requirement and provide a link to this Policy and its related Procedures.
Any person found to be in violation of this policy will be subject to disciplinary action, including termination of employment, enrollment or services. If Smith determines that a report of misconduct against an individual currently affiliated with Smith has been substantiated, the perpetrator may further be banned from all Smith campuses and barred from participating in any Smith programs or activities. If the perpetrator is a contractor or vendor, the contract or business relationship may be cancelled. Violations may also lead to civil or criminal liability.
Periodic Review and Audit
To ensure ongoing compliance with federal and state laws, this policy will be reviewed annually and updated to reflect any changes in those laws. A periodic internal audit will also be conducted to ensure that all Smith personnel responsible for the processes described above are applying these policies in a consistent and standard manner as intended.
This policy commenced on May 9, 2015. There are no earlier versions.
Policy was updated by Cabinet approval September 14, 2015.