1.0 Policy Purpose
The purpose of this policy is to establish the requirements for the appropriate supervision and protection of Minors participating in Minors Activities.
2.0 To Whom the Policy Applies
This policy applies to all Brown University community members who interact with Minors in Minors Activities, as well as non-Brown individuals and organizations who interact with Minors in Brown and Non-Brown Activities (“Activity Adults” as defined in Section 4.0).
This policy does not apply to activities, programs, or events where parents, guardians, or specific other individuals (e.g., K-12 teachers) are expected to provide supervision of Minors at all times.
3.0 Policy Statement
Brown University is committed to fostering a safe environment for all Minors participating in Brown and Non-Brown Activities both on and off campus.
3.1 Minors Activity Requirements
Brown has established University-wide requirements for Minors Activities, including registration of the Minors Activity and background checks and training for all Activity Adults. Specific Minors Activities may have additional requirements not covered by this policy that Activity Adults must also meet.
Guest speakers whose role in a Minors Activity is limited to a short, one-time presentation during which another Activity Adult meeting the requirements of this policy is present at all times are exempted from Brown’s centralized background check and training requirements.
Activity Adults participating in specific Minors Activities that are hosted by external organizations and do not use Brown facilities may be exempt from Brown’s centralized requirements for background checks and training. In these cases, they are required to meet only the external organization’s standards for interacting with Minors.
The Minors Protection Office (MPO) will determine any exemptions to this policy.
3.1.1 Registration
All Minors Activities must be registered with the MPO a minimum of 30 calendar days prior to the Minors Activity start date, though Minors Activities are encouraged to register as early as practicable to ensure sufficient time for the required background checks and training to be completed. Recurring Minors Activities must be re-registered annually. The Activity Administrator must notify the MPO promptly of any changes to the Minors Activity registration information.
The MPO will review all Minors Activity registrations and advise on necessary steps prior to the Minors Activity being permitted to operate.
3.1.2 Background Checks
Background checks must be completed at the following frequency:
- Brown faculty, staff, Students (undergraduate, graduate, and medical), and Sponsored ID holders: Every three years
- Volunteer/Non-Brown individual: Annually
Any Activity Adult driving a vehicle containing Minors must also complete a Motor Vehicle Records Report at the same frequency.
All Activity Adults must have satisfactory results from their required background check(s), as determined by the Background Check Subcommittee, before engaging with Minors in the Minors Activity. Activity Adults must promptly notify the MPO of any subsequent conviction for a criminal offense.
These checks shall be in addition to any standard background check applicable to a Brown employee at the time of hire. Background checks will be conducted for the purposes of aiding in determining an individual’s suitability for engaging with Minors; however, in some cases Brown may have a duty to take employment action based on background check results.
3.1.2.1 Brown Activities
Background checks for Brown Activities are centrally managed by the MPO. The MPO may approve University Human Resources (UHR) to conduct background checks for Brown Activities that require hiring for the purpose of working with Minors.
3.1.2.2 Non-Brown Activities
Non-Brown Activities must conduct their own background checks in accordance with this policy. If any background check conducted by a Non-Brown Activity returns a conviction or other adverse information, the external organization must inform the MPO in writing. Brown may exclude any external employee, volunteer, or representative who does not pass a background check to Brown’s satisfaction.
3.1.3 Training
All Activity Adults must complete annual training on Minors protection that covers behavioral expectations when engaging with Minors and mandatory reporting responsibilities. Any individual designated a Campus Security Authority (CSA) under the Jeanne Clery Campus Safety Act must also complete CSA training. Additional mandatory training may be required by the specific Minors Activity and/or the MPO.
All required training must be completed before the individual will be permitted to engage with Minors.
3.1.3.1 Non-Brown Activities
Non-Brown Activities may use Brown’s training or provide their own comparable training in accordance with this policy. Training content and completion data must be provided to Brown upon request.
3.1.4 Collection of Releases and Other Applicable Forms
Activity Administrators for Brown and Non-Brown Activities are responsible for collecting and appropriately maintaining all required forms and/or documentation.
Brown Activities must collect the forms listed below as well as any additional forms/documentation required for their specific Minors Activity:
- Parental/Guardian Release Forms: Activity Administrators for Brown Activities must collect and maintain Parental/Guardian Release Forms for all Minors in their Minors Activity. Brown Activities must use either Brown’s standard release form or have their individualized version approved by the Office of the General Counsel (OGC).
- Media Consent Forms: Brown Activities that take photographs, videos, and/or voice recordings of Minors must also collect Media Consent Forms from participants.
- Health/Medical Forms: The MPO will advise Brown Activities on the required health/medical forms based on the Minors Activity registration.
3.1.5 Standards of Behavior
All individuals who interact with Minors must actively foster respectful and appropriate environments in which Minors are able to thrive. Activity Adults are expected to serve as positive role models for Minors, acting in a responsible, respectful, and caring manner.
3.1.6 Emergency Preparedness
Activity Administrators are expected to be familiar with and follow emergency preparedness best practices in their Minors Activity.
3.2 Mandatory Reporting
Rhode Island law requires any person who has reasonable cause to know or suspect that any child has been abused or neglected or is the victim of sexual abuse by another child to report it within 24 hours. To make a report,
- Contact the Rhode Island Department of Children, Youth and Family Services (RIDCYFS) Child Protection Hotline at 1-(800) RI-CHILD or 1-800-742-4453 (callers may remain anonymous); then
- Call Brown's Department of Public Safety (DPS) at 401-863-3322 and confirm the report was also made to RIDCYFS. Additionally, DPS will inform the University's Title IX Coordinator, if applicable, for the purposes of investigation and support.
Activity Administrators for Minors Activities held in states other than Rhode Island are responsible for reviewing and following reporting obligations in those states.
4.0 Definitions
For the purpose of this policy, the terms below have the following definitions:
- Activity Administrator:
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The individual who is the primary point of contact for all aspects of the Minors Activity and is responsible for planning and safely executing the Minors Activity in accordance with this policy, all other applicable University policies and procedures, and all applicable laws and regulations.
- Brown Activity: The Brown faculty member, staff member, or Student who is the primary point of contact for all aspects of the Minors Activity. The Activity Administrator must be employed/enrolled at Brown both when registering the Minors Activity and when it takes place.
- Non-Brown Activity: The individual representing the third-party organization who serves as the primary point of contact for all aspects of the Minors Activity.
- Activity Adults:
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Brown faculty, staff, Students, volunteers, and Sponsored ID holders who oversee, supervise, or engage in Minors Activities, as well as non-Brown individuals who oversee, supervise, or engage in Brown and Non-Brown Activities.
- Minor:
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An individual under the age of 18. This does not include Minors who are:
- participating in research approved by the Institutional Review Board (IRB)/Human Research Protection Program (HRPP);
- enrolled as Brown undergraduate Students;
- enrolled as non-degree students engaged in undergraduate credit-bearing coursework;
- employed by Brown acting within the scope of their employment; or
- receiving medical or therapeutic treatment conducted by Brown clinicians.
- Minors Activity:
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Any organized activity, program, or event in which one or more Minor(s) participate either in-person or virtually.
- Brown Activity: Any Minors Activity that Brown offers or operates.
- Non-Brown Activity: Any Minors Activity that uses Brown facilities but is not organized by a member of the Brown community in their Brown capacity. All Non-Brown Activities must have a signed agreement (e.g., Facilities Use Agreement) with the University and be contractually required to comply with this policy. Any Minors Activity that is co-sponsored or co-organized by Brown will be considered a Brown Activity for the purposes of this policy.
- External Organization-Hosted Activity: Any Minors Activity for which Brown helps facilitate placement of staff/volunteers but that is not offered by Brown and does not use Brown facilities (e.g., a mentorship program in the Providence Public School District (PPSD) in which Brown community members participate and are required to meet all PPSD requirements in order to interact with Minors).
- Minors Protection Committee:
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Includes representatives from the following offices: Minors Protection Office, University Human Resources, Dean of the Faculty (DOF), Office of Student Conduct and Community Standards (OSCCS), Swearer Center, Athletics, and Student Activities Office. Additional individuals may be included at the discretion of the Committee.
- Background Check Subcommittee: Includes representatives from the Minors Protection Office as well as the relevant office, if any, for the individual in question (i.e., UHR, DOF, or OSCCS). Additional individuals may be included at the discretion of the Subcommittee.
- Student:
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As defined in the Code of Student Conduct.
5.0 Responsibilities
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.
In addition to responsibilities already assigned in this policy, the following offices/individuals will accomplish additional actions.
Minors Protection Office: Manage the Minors Protection Program, including reviewing and approving Minors Activity registrations and Activity Adults, advising Activity Administrators on centralized requirements for their Minors Activity, initiating required background checks, monitoring and enforcing Minors Activity compliance (to include cancelling non-compliant Brown and Non-Brown Activities and removing non-compliant Activity Adults), convening the Minors Protection Committee and Background Check Subcommittee as needed, and providing updates as requested by senior leadership.
Minors Protection Committee: Advise on Minors Protection Program implementation and operations.
- Background Check Subcommittee: Support adjudication of background check results and support the MPO in determining individuals’ suitability for engaging with Minors.
Activity Administrator: Ensure all Activity Adults for their Minors Activity comply with this policy, including timely completion of all required background checks and training, in addition to any Minors Activity-specific requirements.
6.0 Consequences for Violating this Policy
Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures or for non-employees may result in the suspension or revocation of the user’s relationship with Brown University.
Individuals who fail to meet the requirements laid out in this policy prior to the start date of a Minors Activity will not be allowed to participate in the Minors Activity. Brown and Non-Brown Activities that fail to register and comply with all centralized Minors Activity requirements may be canceled. Student organizations that fail to comply with this policy may be derecognized.
Any Activity Adults who fail to or are suspected to have failed to actively foster a respectful and appropriate environment for Minors in accordance with this policy may be removed from the Minors Activity and subject to disciplinary action, as above.
7.0 Related Information
Brown University is a community in which individuals are encouraged to share concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.
7.1 Related Policies
7.2 Related Procedures
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7.4 Frequently Asked Questions
7.5 Other Related Information
Policy Owner and Contact(s)
Policy Owner: Provost
Policy Approved by: President
Contact Information:
Policy History
Policy Issue Date:
Policy Effective Date:
Policy Update/Review Summary:
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Webpage Updated May 30, 2025