06.09.01 Child Protection Policy

Scope

This Policy applies to all faculty, staff, students, volunteers, and representatives as well as third-party vendors and their employees, representatives, or volunteers that contract for use of UAH facilities, with responsibilities that involve interaction with children.

Except for the exclusions listed in the next paragraph, all activities or programs for and that include children are within the scope of this Policy. This includes, but is not limited to:

• Activities or programs for or that include children that the University operates on campus or in University facilities, including, but not limited to: overnight camps, instructional programs, day camps, academic camps, and sports camps.
• Activities or programs for or that include children that are operated, conducted, or organized by third parties that take place on campus or in University facilities, including, but not limited to, facility rentals to third-party organizations.
• Activities or programs for or that include children that the University operates that do not take place on campus, including, but not limited to, outreach and community service activities.
• Faculty or staff who bring children to campus as interns or volunteers outside of a structured activity or program for or that include children (e.g., to intern in a laboratory).
• Student organizations or any other University affiliated organization operating, facilitating, or sponsoring activities or programs for or that includes children.

This Policy does not apply to:

• Undergraduate and graduate academic programs in which individuals under the age of 18 are enrolled for academic credit or have been accepted for enrollment.
• Events on campus open to the general public that children also attend.
• Medical care given to children in UAH patient-care setting.
• Children employed by the University.

These areas/programs are still subject to all other relevant UAH policies and procedures.

(Children with Disabilities who have not earned an Alabama High School Diploma and who have not reached their twenty-first birthday by August 1 are entitled to special education and related services up to age 21. See Rules of the Alabama State Board of Education Special Education Services, Chapter 290-8-9.04(3) (August 2015), https://www.alsde.edu/sec/ses/Policy/AAC%20290-8-9%2011-4-2013.pdf)

Definitions

Child - Any individual under the age of 18 or an individual under 21 years old who is incapable of self-care because of a mental or physical disability.

Activities or Programs for or that include Children Any: (I) event, operation, or endeavor operated, conducted, or organized by any unit or organization that is supported by or affiliated with the University or occurring on University property, (2) that includes children, and (3) during which parents or guardians are not expected to be responsible for the care, custody, or control of the children. These include Third-Party Activities and Programs (defined below).

Program Director - A Program Director is the individual on-site who is responsible for the day-to-day operations of the activity or program and who oversees Program Staff.

Program Contact - This individual represents the department, college, or student organization responsible for the direction or operation of the activities or programs. In the case of Third-Party Activities and Programs, this person serves as the liaison between UAH and the third-party personnel. The UAH Program Contact must be a full- time UAH employee and is responsible for registering the Third-Party Activities and Programs.

Program Participant - A Program Participant is a child who is attending an activity or program for or that includes children.

Program Staff - Program Staff consist of both paid and unpaid individuals who have direct contact with activity or program participants. This may be faculty, staff, students, student employees, graduate assistants, contractors, or volunteers. Program Staff are responsible for planning, teaching, coordinating, and carrying out activities and the supervision of participants in the activities or programs.

Third-Party Activities and Programs - Third-Party Activities and Programs are activities or programs for or including children that are offered by an individual or entity that is not affiliated with UAH and that have a participant group made up, in whole or in part, of individuals under the age of 18 or of individuals under 21 years old who are incapable of self-care because of a mental or physical disability. These programs complete all or part of their educational and/or business purpose on UAH property, and the third-party individual or entity assumes full responsibility for the supervision of the participants. These programs may or may not collect fees from participants.

Volunteer - Any individual working in an unpaid capacity in an activity or program for or including minors.

Policy and Procedures

This Policy applies to all UAH faculty. staff, students, volunteers, and representatives as well as third-party vendors and their employees, representatives, or volunteers that contract for use of UAH facilities, with responsibilities that involve interaction with children. If any University personnel are planning a program or activity that involves children or may involve children in any capacity, please contact the Director of Compliance for review and assessment of specific program requirements. All activities or programs for or including children will be subject to this Policy and to the more detailed instructions outlined in the Guidebook for Activities or Programs with Child Participants. All individuals must sign and agree to abide by the requirements outlined in the Guidebook before working in activities or programs for or including children. All individuals and requested activities/programs are expected to comply with all relevant policies and directives to the satisfaction of UAH. Any behavior or contact between Program Staff and Program Participants that violates approved program activities, established law, UAH's Child Protection Policy, or other relevant UAH policies is prohibited.

1. All activities or programs for or including children must submit an application and all requested documentation to the Director of Compliance for approval at least four weeks prior to the start date of the activity and/or program. An application submitted fewer than four weeks prior to the start of the requested activities or programs may not be approved. Activities or programs for or including children may not occur without appropriate UAH approval as outlined herein. Detailed information on required documentation is available in the Guidebook.
2. UAH departments sponsoring activities or programs for or including children must maintain an up-to-date listing of those programs. Such lists should include each program's dates, times, locations, attendance (including age range and number of participants), and the contact information for the UAH program sponsor and should include contact information for the Program Director where applicable.
3. Those working in activities or programs for or including children who witness child abuse or neglect, or have information that would lead a reasonable person to believe a child faces a substantial threat of such abuse or neglect. must follow reporting procedures established in this UAH Child Protection Policy.
4. Individuals working in activities or programs for or including children must successfully complete required background checks before working in such activities or programs. Detailed information on required background checks is available in the Guidebook.
5. All units must ensure that individuals working in activities or programs for or including children complete all required training as outlined in the Guidebook.
6. Children performing activities in laboratories or around research animals may have additional documentation, training requirements or restrictions imposed, depending on the specific nature of the hazards in the area.
7. Activities or programs for or including children may be subject to site visits coordinated by the Director of Compliance. Any suspected violation of approved program guidelines or UAH policy will be subject to investigation by the appropriate University officials. Colleges, units, and individuals must cooperate with investigations when they occur.
8. Safety awareness information, specific to program activities, must be provided to all staff or volunteers. Appropriate safety awareness information may include training on first aid and CPR, weather safety, campus resources. and personal safety recommendations. More detailed information on training requirements and available materials is included in the Guidebook.
9. UAH expects parents or guardians to provide supervision for children who are on campus unless the child is engaged in an activity or program for or that includes children. Parents or guardians should not leave children unsupervised on University property.
10. Third-Party Activities and Programs must:
    1. Establish a contractual relationship with the University for the use of facilities and/or resources;
    2. Provide evidence of insurance coverage in accordance with the requirements outlined by UAH's Office of Risk Management, unless the requirements are waived by the Office of Risk Management;
    3. Be sponsored by or affiliated with a UAH department, college or recognized student organization and have a designated UAH Program Contact;
    4. Designate an on-site Program Director, if not the UAH Program Contact;
    5. Operate under the administrative purview of a UAH department;
    6. Complete the same review and approval process as a UAH sponsored activity or program.
    7. Successfully complete appropriate background checks for all individuals working in activities and programs for and involving children, and who are likely to have responsibility for the care, custody, or control of a child as part of that activity or program.
11. Compliance with this Policy and the Guidebook is required as a condition of operating camps at UAH. Failure to comply with the requirements of this Policy or the requirements further outlined in the Guidebook can result in the loss of program privileges and other sanctions at UAH.

Reporting Procedures

If you know or suspect that a child is a victim of child abuse or neglect, you must report. In deciding whether or not to report an incident or situation of suspected abuse or neglect, it is not required that you have proof that abuse or neglect has occurred.

Any uncertainty in deciding to suspect abuse or neglect should be resolved in favor of making a good faith report.

In making a report, your actions should be as follows:

• Immediately report the information to: The University of Alabama in Huntsville Police Department at 256-824-6596. Your oral report should include all reasonably available information regarding the known or suspected abuse or neglect, including, but not limited to, the name of the child, his or her whereabouts, the names and addresses of the parents, guardian, or caretaker and the character and extent of the injuries. The report should also contain, if known, any evidence of previous injuries to said child and any other pertinent information that might establish the cause of such injury or injuries, and the identity of the person or persons allegedly responsible for the same.
• Do not directly question or solicit information from the child or from the person suspected of improper behavior. That is not your role; the role of investigation lies with University, city, county, and state officials.
• In addition to making an oral report, you must also complete a Child Abuse or Neglect Report Form found on https://www.uah.edu/compliance and deliver the same to the UAH Police Department.

Prohibition on Retaliation and Immunity from Liability

Any person who makes a good faith report of child abuse or neglect shall not be subjected to retaliation. Further, any person or entity that makes a good faith report of child abuse or neglect is immune under Alabama law from any liability—civil or criminal—that might otherwise be incurred or imposed.

Review

The Office of the Director of Compliance and Title IX Coordinator is responsible for the review of this policy every five years (or whenever circumstances require).

Guidebook for Activities or Programs with Child

The University of Alabama in Huntsville (UAH) is committed to providing a safe and welcoming experience for children. Faculty, staff, students, volunteers, and representatives as well as third-party vendors and their employees, representatives, or volunteers that contract for use of UAH facilities (collectively "UAH personnel") are therefore expected to hold themselves to the highest standards of conduct when interacting with children.

This Guidebook is designed to assist with the development of guidelines and practices to support compliance with University policy regarding activities and programs for or that include children. Terms defined in the University's Child Protection Policy carry the same definitions throughout this Guidebook. Except for the exclusions listed in the next paragraph. all activities and programs for and that include children are within the scope of this Guidebook. This includes, but is not limited to:

• Activities or programs for or that include children that the University operates on campus or in University facilities, including, but not limited to: overnight camps, instructional programs, day camps, academic camps, and sports camps.
• Activities or programs for or that include children that are operated, conducted, or organized by third parties that take place on campus or in University facilities, including, but not limited to, facility rentals to third-party organizations.
• Activities or programs for or that include children that the University operates that do not take place on campus, including, but not limited to, outreach and community service activities.
• Faculty or staff who bring children to campus as interns or volunteers outside of a structured activity or program for or that include children (e.g., to intern in a laboratory).
• Student organizations or any other University affiliated organization operating, facilitating, or sponsoring activities or programs for or that includes children.

This policy does not apply to:

• Undergraduate and graduate academic programs in which individuals under the age of 18 are enrolled for academic credit or have been accepted for enrollment.
• Events on campus open to the general public that children also attend.
• Medical care given to children in a UAH patient-care setting.
• Children employed by the University.

General Program Requirement

Activities and programs for or that include children must have in place, enforce, and make available upon request guidelines that address the following areas, as applicable to the particular program:

1. Transportation, including the transportation of children at the beginning and end of the program, to and from the program, and within the program, whether by parents, guardians, Program Staff or others. Transportation guidelines should outline any procedures required to be implemented to identify and manage who can or cannot pick up a participant at the close of a program or day. Programs that use University vehicles or drivers must also comply with UAH policies regarding drivers and vehicles;
2. Emergency plans, including guidelines for weather emergencies and for communicating and responding to Emergency Notifications;
3. Appropriate levels of access to and supervision of children, including Program Staff to participant ratios; and
4. Training for appropriate physical contact and communication by Program Staff with children based on the age of the child and the nature of the program activities.

In addition to these guidelines, each program participant and staff member must complete a Release of Liability, Assumption of Risk, and Indemnification form located on https://www.uah.edu/compliance.

Communications and Parent Information Package

Each program or activity must develop a communications and parent or guardian information package. These must include but are not limited to procedures for the notification of the child's parent/legal guardian in case of an emergency, including medical or behavioral problems, natural disasters, or other significant program disruptions. Participants and their parents/guardians must be advised of this procedure in writing prior to program participation.

Communication and parent information packages for programs that involve overnight stay or use of UAH housing by children must have guidelines that address all of the previously mentioned items as well as policies in place that appropriately address the following:

1. Personnel identification to be worn by Program Staff;
2. Curfews;
3. Code of conduct for participants;
4. Prohibitions on the use of alcohol, tobacco, and non-prescribed drugs;
5. Appropriate residential supervision, which, among other things, includes proper Counselor to Participant Ratios as describe in the Counselor to Participant Ratio section of this Guidebook.
6. Program contact information for parent/guardian use. Programs should request parent/guardian contact information for use in the event of an emergency.

Registration and Approval

UAH departments sponsoring activities or programs for or including children must maintain an up-to-date listing for those programs. Such lists should include each program’s dates, times, locations, attendance (including age range and number of participants), and the contact information for the Program Director. All activities and programs for or involving children must be completed annually prior to the beginning of the University academic year. Registration for other activities and programs for or involving children should be completed at least four weeks in advance, but must be completed and approved before an activity or program for or involving children begins. Required documentation to initiate the registration and approval process includes:

• An application to offer activities and programs for or involving children.
• A complete description of the activities and a planned itinerary must accompany the application. Include any additional documentation or waivers required for program activities.
• Insurance information for the program. Activities will be cross-referenced with the current program insurance policies to ensure adequate coverage.
• A complete listing of Program Staff with date of birth must accompany the application. Training completions and background checks will be verified to ensure compliance.
• Program applications should identify which Program Staff member will be responsible for keeping/administering medication or handling illness/injury.
• A copy of all previously mentioned guidelines and communication plans (see General Program Requirements).

Training Requirements

Colleges and units must ensure that individuals working in activities and programs for or including children complete all required training as outlined in this Guidebook as well as any other training that may be required by specific camps.

All UAH Personnel with care, custody, or control of children must complete the following training courses annually:

1. Training on the UAH Child Protection Policy.
2. Mandatory Reporting Training.
3. Campus Security Authority Training (Clery Act).

Colleges and units must ensure that faculty, staff, students, student employees, graduate assistants, and volunteers have completed all required training annually before they work in activities and programs for or including children.

Training records must include who attended, what was covered, when and where the training was presented, and participants must sign a roster indicating their understanding. Records of training must be submitted and stored via Google Sites/Drive.

Counselor to Participant Ratios

Counselor to participant ratios should conform to the ratios listed below. Programs or activities involving children should have a minimum of two individuals responsible for oversight. In large groups of participants, programs may need to provide additional oversight of campers, depending on the intended activities. Regardless of the number of participants, at least 80% of the counselors must be age 18 or older.

Standards for Overnight Campers are:

• One staff member for every 5 campers ages 5 and under.
• One staff member for every 6 campers ages 6 to 8.
• One staff member for every 8 campers ages 9 to 14.
• One staff member for even/ 10 campers ages 15 to 18.

Standards for day only camps are:

• One staff member for every 6 campers ages 5 and under.
• One staff member for every 8 campers ages 6 to 8.
• One staff member for every 10 campers ages 9 to 14.
• One staff member for every 12 campers ages 15 to 17.

Children Requiring Accommodations

Each camp or program for or including children must establish a set of standards for reasonably accommodating children requiring accommodations. These include, but are not limited to, the modification of policies, practices, and procedures, effective communication prior to and during the camp or program for children and the removal of physical or communication barriers to programs, activities, goods or services. Programs must provide ample time for participants to disclose any reasonable accommodations they may need during their participation in the program. Programs must communicate contact information for a specific individual responsible for the identification of reasonable accommodations.

For questions or assistance with securing reasonable accommodations, contact the Director of Compliance.

Illness, Injury, and Medication

Any incidents, accidents, or injuries occurring during a program or activity for or including children should be reported to UAHPD and the Director of Compliance according to established policies, including:

• Those involved should submit a General Incident Report using the General Incident Report Form.
• Employees who are injured during working hours should submit an On the Job Injury Form.
• Student/Non-Employee injuries should be submitted using the Student/Non- Employee Injury Report Form.
• Any issues that are not addressed under these policies should be reported to UAHPD (256-824-6596).

All programs must obtain authorization to administer any medication, including prescription and non-prescription medications, from the participant's parent or legal guardian in a written, signed and dated format using a completed Authorization for Dispensing Medical Information Form found on https://www.uah.edu/compliance. This form expires one year after its original date. The participant's parent or legal guardian may not authorize administering medication in excess of the medication's label instructions or the directions of the child's healthcare professional. A parent or guardian authorization is not required for administering a medication to a participant in a medical emergency to prevent the death or serious bodily injury of the participant, provided that the medication is administered as prescribed, directed, or intended. If the program chooses not to administer any medication, parents or guardians must be notified prior to the participant's enrollment in the program.

Medication given must be given from the original container to the individual for whom the medication was prescribed within the expiration date. Over-the-counter medication must be labeled with the individual's name along with an Authorization for Dispensing Medical Information Form. When a staff member or volunteer administers the medication, they must record the full name of the participant, name of medication, date and time medication was given, and full name of staff member or volunteer who administered the medication.

If a participant requires specialized medical assistance, any staff member or volunteer at the program is required to provide the specialized medical assistance as recommended or ordered by a healthcare professional. Programs must maintain a written copy of the healthcare professional's recommendations or orders in the participant's record for at least three years after the program date. Retention may be longer if advised by University Health Services, University Counsel, or Director of Compliance.

All medication must be stored out of reach of all participants or locked in storage in a manner that does not contaminate food, or refrigerated, if required, separate from food. Medication must be returned to the participant's parent or guardian or upon completion of the program or upon participant dismissal from the program.

All documentation associated with illness, injury, or medication should be submitted to the Director of Compliance.

Reporting of Incidents or Accidents

Incidents and accidents can include such things as: minor to major physical injuries of participants and/or counselors; behavioral issues among participants, counselors, or visitors; hospital/doctor visits; violent or potentially violent behavior; the possession or use of alcohol or other drugs; inappropriate physical contact; or violations or potential violations of UAH policy.

Emergencies, including emergency medical situations, should be reported to UAHPD at 256.824.6596.

In addition to any other reporting or incident documentation, the UAH Program Contact or Program Director should report any accidents/incidents to the Director of Compliance as soon as possible. The Director of Compliance will forward information to relevant offices on campuses including but not limited to University Counsel and Office of Risk Management. If consultation regarding reporting is needed, or if there are questions on the process or other support needed, please contact the Director of Compliance.

Abuse or Neglect of a Child

No form of child abuse, whether physical, emotional or sexual, will be permitted or tolerated under any circumstances whatsoever. Child abuse is morally and legally wrong. It can come in many forms. Harm or threatened harm to a child's health or welfare can occur through non-accidental physical or mental injury, sexual abuse or attempted sexual abuse or sexual exploitation or attempted sexual exploitation. "Sexual abuse" may be perpetrated by an adult or another child and includes the employment, use, persuasion, inducement, enticement, or coercion of any child to engage in, or having a child assist any other person to engage in, any sexually explicit conduct or any simulation of the conduct for the purpose of producing any visual depiction of the conduct; or the rape, molestation, prostitution, or other form of sexual exploitation of children, or incest with children as those acts are defined by Alabama law. Sexual abuse also includes any activity that is meant to arouse or gratify the sexual desires of the perpetrating adult or child. Sexual abuse may or may not involve touching. "Sexual exploitation" includes allowing, permitting, or encouraging a child to engage in prostitution and allowing, permitting, encouraging or engaging in the obscene or pornographic photographing, filming, or depicting of a child for commercial purposes. "Negligent treatment" or "maltreatment of a child" includes the failure to provide adequate food, medical treatment, supervision, clothing, or shelter.

If you know or suspect that a child is a victim of child abuse or neglect, you must act. In deciding whether or not to report an incident or situation of suspected abuse or neglect, it is not required that you have proof that abuse or neglect has occurred. Any uncertainty in deciding to report suspected abuse or neglect should be resolved in favor of making a good faith report. In making a report, your actions should be as follows:

First, immediately report the information to: The University of Alabama in Huntsville Police Department at 256-824-6596. Your oral report should include all available information regarding the known or suspected abuse or neglect, including, but not limited to, the name of the child, his or her whereabouts, the names and addresses of the parents, guardian, or caretaker and the character and extent of the injuries. The report should also contain, if known, any evidence of previous injuries to said child and any other pertinent information that might establish the cause of such injury or injuries, and the identity of the person or persons responsible for the same. Second, do not directly question or solicit information from the child or from the person suspected of improper behavior. That is not your role; the role of investigation lies with University, city, county, and state officials. Third, in addition to making an oral report, you must also complete a Child Abuse or Neglect Report Form and deliver the same to the UAH Police and Director of Compliance.

Prohibition on Retaliation and Immunity from Liability

Any person who makes a good faith report of child abuse or neglect shall not be subjected to retaliation. Further. any person or entity that makes a good faith report of child abuse or neglect is immune under Alabama law from any liability civil or criminal that might otherwise be incurred or imposed.

Background Checks

Any faculty, staff, appointee, student, student employee, graduate associate, volunteer, or third-party vendor working in activities and programs for and involving children, and who are likely to have responsibility for the care, custody. or control of a child as part of that activity or program, must successfully complete annual background checks. Criminal record and sex offender background checks are required of all individuals hired or assigned to any employee or volunteer position(s) involving contact with children.

College and unit activities and programs for and involving children can require background checks on broader categories of individuals than those who are likely to have responsibility for the care, custody, or control of a child as part of an activity or program, provided there is a business justification, that checks are made consistently across specific positions and that the process and the results of individual background checks have been approved.

Individuals must have a federal, state, and municipality background check. Individuals who have a break in service for fewer than 12 months must disclose any convictions that occurred during the break within three weeks (21 calendar days) of the beginning of participation in activities and programs. If a break in service is longer than 12 months, individuals must have a new background check before working in activities and programs for and including children.

• A background check must be completed to remain eligible to work in activities and programs for and including children.
• College and unit activities and programs for and including children must have background checks on applicable individuals performed more frequently if required by law.
  • New hires are required to complete the University background check process at the time of, and as a condition of, hire.
  • All other program staff members must complete the background check process. This includes current employees working with children who have not previously had a background check completed within the previous 12 months, and all other individuals working with children whether paid or unpaid.
• College and unit activities and programs for and including children must contact the Office of Human Resource and request a background check on any faculty, staff, appointee, student, student employee, graduate associate, volunteer, or third-party vendor working in activities and programs for and involving children, and who are likely to have responsibility for the care, custody, or control of a child as part of that activity or program.
  • For those activities and programs that charge a participant fee, the fee must be at least sufficient to cover the cost of the background checks required.
  • For those activities and programs that are part of a Sponsored Programs activity or program, the budget submitted to the supporting agency must include the cost of the background checks required.
  • For those activities that do not charge a participant fee and are supported financially by UAH and/or gift funds provided through the UAH Foundation or provided directly to UAH through University Advancement, the cost of the background checks will be covered through the Office of the Director of Compliance.
  • The results of the background checks will be received by the Office of Human Resources and will subsequently be shared with the Director of Compliance.
• It is the responsibility of the person in charge of the program or activity at the University to assure that each program staff member and volunteer has completed a background check and received clearance to participate from the Director of Compliance.
• Background checks must include a statewide criminal history search in the State of Alabama, and county-by-county criminal history searches for any location outside of Alabama in which the program staff member indicates they have lived, worked, or attended school within the past seven (7) years. The background check will be limited to criminal offenses for which an individual has been convicted, pled guilty or nolo contendere to a felony or misdemeanor, or where such charges are currently pending. In addition to criminal records searches, UAH also conducts a sex offender registry search and an ID Trace via the program staff member's social security number, which reports any locations in which the social security number has been used for credit purposes so that these locales can be checked if not disclosed. In the event the program staff member will be driving during the course of the activity, a driving record will be required in compliance with the UAH's Fleet Safety Policy.
• Volunteers under age 19 are not subjected to a background check; however, a personal reference check is performed by the same vendor who does the background checks. Parental or guardian consent must be given when an individual is under the age of 19.
• Records must be kept consistent with the unit's record keeping and the University Records Retention Schedule.
• Every third-party contract will contain a provision that the third party understands it must comply with the Guidebook and Policy regarding background checks and will provide proof to UAH that it is in compliance.

Criminal convictions, deferred adjudications and/or sex offender background checks that return any offense could potentially disqualify a person from being employed by or assigned to a program or activity involving children. Any areas of concern must be forwarded to the Director of Compliance.

Faculty, staff, students. student employees, graduate assistants, contractors, or volunteers must self-disclose felony or misdemeanor convictions that occur after hire/appointment within three (3) business days after conviction, according to UAH Policy.

Camps Directed by Non-UAH Entities

From time to time, non-university camps (Third-Party Vendors) and other educational programs or activities will be hosted on UAHs campus. The non-university party must secure a UAH host in order to utilize campus facilities. The relationship of the non- university party and UAH host must be captured in an agreement signed by both parties.

The agreement must include the following requirements from the non-university entity to ensure compliance and quality program experience for the participants:

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1. Provide at least one administrative Program Director with responsibility for satisfactory operation of the camp, including:
   1. maintaining discipline among the participants and compliance with University rules, including overseeing the care of residence hall property and observance of curfews;
   2. arranging for medical treatment in all cases of illness and injury occurring during the camp, including transportation to from a medical facility, and seeing that appropriate insurance forms and information are provided;
   3. maintaining regular and open communication with the host office at the University, sponsors, residence hall residents, and residence hall personnel in order to avoid problems;
   4. maintaining daily contact with the host office liaison to ensure that dining hall and program schedules are coordinated and observed;
   5. maintaining regular daily liaison with the university host office to keep that office informed of the progress of the program and to receive messages and mail; and
   6. being on call 24 hours a day while the program is in session.
2. The parties must contractually agree that the third party is an independent contractor using the facilities of UAH to conduct a program. Nothing contained in the agreement or in the activities conducted shall constitute either party to be the agent, servant, or employee of the other party, nor create a partnership or joint venture relationship between the parties, and each party shall be fully and solely responsible for its own activities and obligations. Third parties must not hold themselves out or be or give the appearance of being an agent, servant, or employee of UAH.
3. Provide a list of all program staff and participants to the Director of Compliance prior to the start of program activities. The list should include all names, addresses, phone numbers and emergency contact information for staff and participants.
4. Conduct appropriate training consistent with the Child Protection Policy on protecting participants from abusive emotional and physical treatment, and on appropriate or required reporting of incidents of improper conduct to the proper authorities including, but not limited to, appropriate law enforcement authorities.
5. Submit the university host entity all printed materials used in advertising camps held at the university.
6. Submit to the university host entity, at least one month prior to the start of the program, a certificate of insurance that requires a minimum of one million dollars in liability coverage. Sexual Assault and Molestation insurance coverage is required for all third-party groups conducting camps or events involving children on the UAH campus. The policy must meet the minimum coverage limits currently in effect as outlined in The University of Alabama in Huntsville Insurance Requirements Policy, and The Board of Trustees of the University of Alabama.

One-on-one interactions

One-on-one interactions are prohibited unless authorized by the Director of Compliance. Approved one-on-one interactions may take place only in open, well-illuminated spaces or rooms observable by other adults from activity or program.

Accountability

Individuals violating this UAH policy or the requirements of this Guidebook will be held accountable for their actions, which may include, but are not limited to:

• Volunteers are subject to reprimand or loss of volunteer status; Students are subject to the Code of Student Conduct;
• Faculty, staff and student employees are subject to corrective action up to and including termination;
• Unit level sanctions, and;
• Third-party providers are subject to punitive actions under the terms of their contract agreement, up to and including termination of contract.

Site visits may be coordinated by the Director of Compliance to promote compliance. Colleges, units, and individuals must participate in site visits as required.

Reporting and Investigations

Reporting of known or suspected cases of child abuse or neglect must be reported in accordance with the UAH Child Protection Policy and UAH Police must be contacted. Investigations of allegations of child abuse or neglect will be conducted in accordance with the investigatory protocols of children service agencies. local law enforcement agencies, and/or the University.