Protection of Minors Policy

Protection of Minors Policy

POLICIES
OF: The Royal Alberta College
(hereinafter shall be referred to as “the college”
and/or as “college” and/or The “Royal Alberta College”)

1.0 POLICY STATEMENT

1.1 The Royal Alberta College (the “College”) is dedicated to the welfare and safety of Minors who visit the College, participate in College programs, or interact with Members of the College
Community. This policy sets out the obligations and responsibilities of Members of the College
Community with respect to protection of such Minors.

2.0 PURPOSE

2.1 In accordance with the College Pillar of Students First, in order to focus on student growth,
opportunity and achievement, the College is committed to providing student’s with the
opportunity to engage and work with Minors to cultivate learning and skill development.

2.2 In accordance with the College Pillar of an engaged College, in order to create a connected
culture where students, faculty, staff and the community are linked, the College is committed to
providing programs to engage and support Minors, and to provide facility use for Third Party
Programs to that end.

2.3 The protection and safety of Minors participating in College programs held by the College, or by third party organizations which use College facilities for programs, is of the highest priority of the College. Members of the College Community must comply with applicable laws and policy regarding abuse and neglect of Minors.

3.0 APPLICABILITY

3.1 All Members of the College Community must comply with this policy.

3.2 This policy applies to all Programs which involve Minors, but does not include:

3.2.1 events open to the general public; and

3.2.2 social functions that may be attended by Minors who are accompanied by their
parents/guardians.

4.0 DEFINITIONS

Abuse – Abuse is the physical or psychological mistreatment of a Minor and includes Neglect, Emotional Abuse, Physical Abuse, and/or Sexual Abuse.

Background Check – A criminal records check and a vulnerable sector search.

Course – A course which confers recognition that be applied to the completion of a certificateawarded by the College under the Ministry Authority through the PVT Act.

Emotional Abuse -Emotional abuse is verbal attacks on a Minor’s sense of self, repeated humiliation or rejection. Exposure to violence, drugs, alcohol abuse or severe conflict in the home, forced isolation, restraint or causing a Minor to be afraid much of the time may also cause emotional harm.

External Program – An activity or program involving Minors that is organized, supervised or run by a person or organization external to the College, not held on College premises, but participated in by Members of the College Community.

Members of the College Community- Those persons involved in conducting College affairs including all students, employees, volunteers, contractors and members of the Board of Governors of the College while they are either on or using College property or facilities or participating in College programs and activities, on or off College premises.

Minor- A person under the age of 18 years, who is not a Student of the College enrolled in a Credit Course, College Preparation, or English as an Additional Language or employed by the College where permitted pursuant to the applicable legislation.

Minors’ Program -Services, programs or activities that the College operates, approves or sponsors, or in which Members of the College Community engage in through their College roles and during which the Minor is not supervised by a parent, guardian or any other non-College party.

Neglect – Any lack of care that causes serious harm to a Minor’s development or endangers a Minor in any way. Failure to meet the Minor’s day to-day physical needs includes not providing adequate nutrition, clothing, shelter and health care; appropriate supervision; and protection from harm. Emotional neglect is not meeting the Minor’s ongoing emotional needs for affection and a sense of belonging.

Physical Abuse– Physical abuse is the intentional use of force on any part of a Minor’s body that results in injuries. It may be a single incident or a series or pattern of incidents.

Programs – An External Program, Minors’ Program or Third Party Program.

Program Coordinator – An employee of the Sponsoring Unit who is responsible for managing and coordinating the Sponsoring Unit’s obligations under this Policy.

Report – A statement disclosing suspected Abuse of a Minor supported by reasonable and probable grounds.

Retaliation – Any adverse action taken against a Member of the College Community because that person has, in good faith, filed a report, supported the filing of a report, disclosed information to the College about a report, and/or participated in an investigation of such report, and includes threats of Retaliation.

Sexual Abuse – Sexual abuse is the exposure of a Minor to sexual contact, activity or behaviour. It includes any sexual touching, intercourse or exploitation and can be perpetrated by anyone, including a parent or guardian, caregiver, extended family, friend, neighbor or stranger.

Sponsoring Unit- The academic or administrative area or unit of the College that sponsors, operates, gives approval for, or participates in a Minors’ Program or gives approval for, or monitors, use of College facilities.

Third Party Program -An activity or program involving Minors that is organized, supervised or run by a person or organization external to the College, but held on College premises.

5.0 POLICY ELEMENTS

5.1 Minors’ Use of Facilities

5.1.1 Minors are permitted in the general-use College facilities (public spaces, academic buildings, food services areas, etc.), but may be restricted from certain areas of the facilities or from utilizing certain equipment to avoid inappropriate one-on-one contact with adults or other potentially dangerous situations.

5.1.2 Minors not participating in a Minors’ Program are prohibited from entering laboratories or other areas where increased safety precautions are required.

5.1.3 Minors using College facilities in a way which poses a risk to themselves, others, or College assets, or which causes a disruption to the College learning environment will result in intervention by Security Services.

5.2 Interacting with Minors

5.2.1 The College will not tolerate Abuse of Minors.

5.2.2 Without limiting the scope of what constitutes Abuse, Members of the College Community must not:

5.2.2.1 engage in abusive conduct of any kind toward, or in the presence of, Minors;

5.2.2.2 strike or touch in an inappropriate or illegal manner any Minor;

5.2.2.3 provide alcohol or illegal drugs to a Minor; or

5.2.2.4 make sexual materials available in any form available to a Minor or assist them in any way in gaining access to such materials.

5.2.3 No Member of the College may use cameras, imaging or digital devices in areas where privacy is reasonably expected by Minors.

5.3 Incidents of Abuse

5.3.1 Any Member of the College Community who has reasonable and probable grounds to believe that a Minor, or any Student under the age of eighteen (18), has been subject to Abuse must make a Report to the Edmonton Police Service or the Royal Canadian Mounted Police and must promptly notify Security Services when the suspected Abuse occurred on College premises or was perpetrated by a Member of the College Community.

5.3.2 No Member of the College Community will undertake, participate in, direct or threaten to retaliate, against a person for filing, intending to file, or supporting a Report, where such Report is made in good faith.

5.3.3 No Member of the College Community will knowingly and willfully fail to make a Report, prevent another person from making a Report, or make a false Report.

5.3.4 The College will cooperate with any external investigation of allegations of Abuse conducted by children services agencies and/or law enforcement agencies. The College will follow its internal investigatory procedures to investigate possible breaches of this policy.

5.3.5 The College will maintain information on the number of Reports, the number and results of investigations, and the corrective actions taken in response to recommendations arising out of investigations.

5.3.6 The Office of General Counsel or an office designated by the Alberta Licensee is responsible for maintaining records related to Reports including, without limitation, investigation reports and any alternative resolution process reports. Subject to any records retention obligations under College policy, collective agreements or applicable law, records related to discipline or sanctions arising out of Complaints will be maintained by the Human Resources department for employees and the Office of the Registrar for students.

5.3.7 Human Resources or the Office of the Provost will maintain any records related to discipline or sanctions arising out of complaints as per requirements under College policy, collective agreements or applicable laws.

5.3.8 Records will be maintained in accordance with the College’s Records Retention and Disposition Schedule.

5.4 Minors’ Programs

5.4.1 Each Minors’ Program must be registered with Security Services, prior to operation.

5.4.2 Each Sponsoring Unit must implement and maintain written protocols and standards for the protection and safety of Minors for each Minors’ Program.

5.4.3 Each Sponsoring Unit must appoint a Program Coordinator and provide the name and
contact information of that individual to Security Services.

5.4.4 The Program Coordinator is responsible for:

5.4.4.1 registration of each Minors’ Program under their associated Sponsoring Unit;

5.4.4.2 maintaining appropriate records of written protocols and standards for the protection and safety of Minors for each Minors’Program; and

5.4.4.3 maintaining appropriate records of Background Checks required to be obtained under this Policy for those Minors’ Programs under their associated Sponsoring Unit.

5.4.4 A Member of the College Community may participate in a Minors’ Program only after successfully completing Background Check screening.

5.4.5 Except where required by law, the results of the Background Checks are kept confidential by the College.

5.5 External Programs

5.5.1 Where a Member of the College Community is participating in an External Program, the Program Coordinator will ascertain whether the External Program has a policy regarding protection of Minors, or Background Checks, and if so, will direct the participating Member of the College Community to that policy.

5.5.2 Members of the College Community will follow policies of the External Program regarding
protection of Minors, or Background Checks.

5.5.3 In the event an External Program does not have a policy regarding protection of Minors, or Background Checks, the Member of the College Community will comply with the Background Check requirement for Minors’ Programs.

5.6 Third Party Programs

5.6.1 Each Third Party Program must be registered with Security Services, prior to operation.

5.6.2 Contracts concerning personnel or facilities related to a Third Party Program must include compliance with this policy, associated procedures and all applicable laws as a term of the contract. Where appropriate, such contracts must also include an indemnification provision in which the College is held harmless for the acts or omissions of other Third Party Program participants or the third party’s employees, agents or volunteers.

5.6.3 The Sponsoring Unit must ensure that Third Party Program operators confirm that Background Checks have been completed for its employees, agents and volunteers before a Third Party Program is held on College premises.

5.7 Education and Training

5.7.1 All Members of the College Community are expected to be aware of, understand and
comply with all laws in relation to the protection of Minors.

5.7.2 Training on the protection of Minors is required for the following Members of the College
Community:

5.7.2.1 all Security Services personnel;

5.7.2.2 all Program Coordinators; and

5.7.2.3 all Members of the College Community participating in Minors’ Programs.

5.7.3 The College is committed to supporting ongoing education and awareness initiatives for Members of the College Community about protection of Minors on campus and about responding to the reporting of harm or potential harm to Minors. The College will implement preventative strategies with respect to harm of Minors on campus.

5.7.4 All Members of the College Community are responsible for contributing to the prevention
of, intervention in, and effective response to, harm to Minors on campus through compliancewith this policy and associated procedures.

5.8 Violations of Policy

5.8.1 Violations of this Policy or associated Procedures or of applicable laws may result in removal from participation in the Minors’ Program, suspension, termination, other corrective action, and, where appropriate exclusion from College campus. The College may also take necessary interim actions before determining whether a violation has occurred.

5.8.2 The College may terminate relationships with Third Party Program operators based on violations of the Policy or associated Procedures.

5.9 Information Tracking and Retention of Records

5.9.1 The College will maintain information on the number of Complaints, the number and results of investigations and the corrective actions taken in response to recommendations arising out of investigations.

5.9.2 The Office of General Counsel and or the Office of the Alberta Licensee’s designate shall be responsible for maintaining records related to Complaints including, without limitation, investigation reports and any alternative resolution process reports. Subject to any records retention obligations under College policy, collective agreements or applicable law, records related to discipline or sanctions arising out of Complaints maybe also maintained by the Office of the Registrar.

5.9.3 Records will be maintained in accordance with the College’s Records Retention and Disposition Schedule

5.9.4 All records involving a Complainant and subsequent investigation of Complaints, but not including records related to discipline or sanctions arising out of Complaints, will be kept in a file separate from student academic records and/or employee personnel files, however all
such records may be used for purposes of future disciplinary processes.

6.0 Disclosure of information:

6.1 Upon the request of any law enforcement agency formal inquiry on a College Community member regarding the treatment of a minor, the College shall willfully without hesitation provide such requested materials at its ability for the benifit of the minor, and shall comply with the agency throughout the investigation.

References:
1 Human Services Alberta, Child Abuse Prevention Month Fact Sheet, 2015-09-22
2 Adapted from Human Services Alberta, Child Abuse Prevention Month Fact Sheet, 2015-09-22
3 Adapted from Human Services Alberta, Child Abuse Prevention Month Fact Sheet, 2015-09-22
4. Adapted from Human Services Alberta, Child Abuse Prevention Month Fact Sheet, 2015-09-22