Program Operations and Standards

Duke University has developed the following operational guidelines and standards (“Standards”) that all Programs operating under the Youth Protection at Duke University Policy, where applicable, must follow. Any deviations, once approved by Director of Youth Protection, must be clearly detailed in Program materials, including in the Program Description of the relevant Participation Agreement.

Program Registration
Document Retention and Privacy
Screening and Training
Supervision Policies
Health and Medication Policies
Program Operation Policies and Procedures
Compliance and Disciplinary Action

Program Registration & Approval

Each Program involving minors must be registered with the Office of Youth Protection. All staff must have a cleared background check and completed training prior to interacting with minors. In order to register, Program Directors must first obtain approval for the Program from their designated Dean or Vice President (or a designee who has been designated in writing). University system Programs require approval from the Provost's Office after a recommendation from the relevant Dean.

Program Directors are responsible for registering their program including designating program staff who have a cleared background check and completed training prior to interacting with minors. Programs should be registered at least four weeks prior to the anticipated program start date. Program Description should list all activities during the registration process.

Program approval is at the discretion of the Director of Youth Protection in conjunction with AVP of Academic Affairs, Duke's Office of Audit, Risk and Compliance and Office of Counsel, and Central HR.

Document Retention and Privacy

The Program Director should not allow any Minors to participate in the Program without a Duke approved Participation Agreement signed by the parent/ legal guardian and acknowledged by the Minor, and, where needed, signed Duke approved Health Forms. Participation Agreement and forms can be kept electronically. Programs must retain and safeguard as appropriate copies of completed Participation Agreements and Health Forms in their own department records for at least three years after the Minor turns 18.

Screening and Training

The Program Director will ensure all staff are uploaded in the Youth Protection database. Prior to interacting with minors all staff must complete both the background check and training.

Supervision Policies

A. Ratios

The following supervision ratios recommended by the American Camp Association are to be maintained at all times. If the Program has Minor participants from different age ranges, the lowest age range should be used to determine the appropriate supervision ratio. If the program is virtual, there must be a minimum of two adults present at all times.

Age of Minor	Ratio for Day Programs	Ratio for Overnight Programs
5 years and younger	1:6	1:5
6-8 years	1:8	1:6
9-14 years	1:10	1:8
15-17 years	1:12	1:10

B. Appropriate Supervision

Minors should be supervised with line-of-sight supervision at all times, including when travelling to different locations or off-campus. To determine if some flexibility in supervision is permissible for a Program and develop specific procedure and boundaries, please consult with the Director of Youth Protection Any such flexibility in supervision shall be granted only in express written authorization from the Director of Youth Protection.

C. Prohibition of One-on-One Interaction

Program staff should not be permitted to have one-on-one interactions with Minors, and Programs should employ at minimum the principle of "two deep leadership" which includes the presence of a second adult at all times. This is also known as the rule of three or more, meaning there should be two adults and one minor at all times. In rare instances, granted by the Director of Youth Protection, it may be permitted that two students and one adult can be present.

If one-on-one interaction happens during the Program, assure the meeting or activity is in a public space, in a place containing windows with clear visibility into the room, or in a space where the door can be left open. All interactions with minors should be open, observable, and interruptible.

D. Code of Conduct for Program Staff

Adults interacting with Minors must follow these expectations to avoid behaviors that could cause harm or be misinterpreted. Programs must educate their program staff on these requirements.

Do not be alone with a single Minor, either in person or virtually. If one-on-one interaction is required, meet in public space, in a place containing windows with clear visibility into the room, or in a space where the door can be left open.
Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material (or assist in any way to provide access to such material) with Minors.
Do not shower, bathe, or undress with or in the presence of Minors.
Do not engage or allow Minors to engage you in romantic or sexual conversations, or related matters, unless required in the role of counselors, or health care providers.
Do not meet with Minors outside of established times for Program activities.
Do not invite individual Minors to your home.
Do not engage or communicate with Minors through email, text messages, social networking websites, internet chat rooms, or other forms of social media at any time except and unless there is an educational or programmatic purpose and the content of the communication is consistent with the mission of the Program and the University. In such events, two adults must participate in the communication or be copied on the correspondence. Whenever possible use applications or emails that can track communication between program staff and minor participants.
Do not touch Minors in a manner that a reasonable person could interpret as inappropriate.
Do not engage in any abusive conduct of any kind toward, or in the presence of, a Minor, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. All incidents involving such conduct, whether or not required to protect a Minor or others from harm, must be documented and disclosed promptly to the Program Director and the Minor's parent/guardian.
When transporting Minors in a Program, more than one adult from the Program must be present in the vehicle, except when multiple Minors will be in the vehicle at all times through the transportation (Please review the Transportation Guidelines for additional information.)
Do not use, processes, or be under the influence of tobacco, alcohol, or illegal drugs, including marijuana and its derivatives (synthetics, vapes, waxes, edibles, oils, etc.), while assisting in the Program, in the presence of minors, or at a Program site. Do not provide directly to or assist in obtaining such substances for minors.
Possession of or use of any type of weapon or explosive device is prohibited.
Do not give out information about a minor such as housing location, to anyone (other than parents, legal guardian, applicable University staff, or law enforcement).
Do not take or post photos/videos of minors on social media, except as otherwise authorized by Program Director and on official Program social media accounts and then only if a signed photo/video release has been obtained from the parent/guardian.
When transporting Minors, more than one adult from the Program must be present in the vehicle, except when multiple Minors will be in the vehicle at all times through the transportation. Personal vehicles, 12-15 passenger vans, and rideshares cannot be used to transport minors.
Do not provide gifts to individual minors.
Do not tell Minors “this is just between the two of us” or use similar language that encourages Minors to keep secrets from their parent/guardians, other adults, or peers.

E. Identification of Program Staff and Participants

Program staff and participants must distinguish themselves at all times for easy identification. For residential camps, Program Staff should wear shirts or differentiating lanyards identifying the assigned Program they are working with at all times. Participants may wear lanyards, badges, t-shirts, name tags, etc. Whichever identification method is chosen for participants, it must be clearly displayed at all times throughout the Program.

Health and Medication Policies

A. Review Health Forms

For athletic, residential, and multi-day Programs, all participants must submit completed health forms. Program Director or designee must review submitted Health Forms before the Program begins to ensure Minors have completed all requirements, a licensed health care provider has signed off on any medications a Minor will bring to the Program, and that the parent/legal guardian and a licensed health care provider have verified the Minor's ability to participate in the Program.

B. Medication Management

Minors are not allowed to hold any medications. (The only exceptions will be for acne creams and urgent-need medication such as insulin, rescue asthma inhalers, epinephrine and glucagon devices, which a Participant may keep with them if approved by a physician in the signed Health Forms.) Medications includes any substance a Participant takes to maintain and/or improve their health, including vitamins and natural remedies.

Program staff must develop a procedure for securely housing medications and accurately tracking which medications have been distributed to Minors, using the parameters below to be approved by the Director of Youth Protection and/or contracted agency. For overnight camps, medications should be checked-in as part of the arrival day check-in procedure. Day camps should also be prepared to handle medications as needed or create a plan with the parent/guardians for the medication to administered.

A prescription or nonprescription medication may be accepted only in an original container. The medication must remain in the container in which it was received. The label must identify the names of the medication and the child for whom the medication is intended.
Medication shall be stored in a locked area of the facility or in an area that is out of the reach of children. Further, medication shall be stored in accordance with the manufacturer's or health professional's instructions on the original label.
Designated staff shall provide medication to a Participant only if written instructions are provided from a licensed health care provider. Instructions provided in the Participant's completed Health Forms are sufficient.
Program staff should establish and maintain a medication log if prescription or nonprescription medication is distributed. Medications should not be distributed in advance of need. A log must include the following minimum information:
1. The name of the medication.
2. The name of the child receiving the medication.
3. The amount of medication administered.
4. The date of administration.
5. The time of administration.
6. The initials of the staff person who administered the medication.
7. Special notes related to problems of administration.

Programs may request epi-pens from Duke Student Health to have on hand in case of emergencies. Programs are required to have all Program staff trained by Duke Student Health on use of epi-pens prior to receipt.

C. Immunizations

Immunizations for all athletic, residential, and multi-day programs must be obtained and reviewed prior to the start of programming and be in line with the North Carolina requirements. Religious exemptions will be granted on a case-by-case basis by the Director of Youth Protection. Immunization requirements apply to Programs with participants from international countries.

D. Nurses

Each residential program is required to have a registered nurse. Nurses are recommend for larger day programs, high risk, and athletic programs.

Program Operation Policies and Procedures

A. Incident Reporting Criteria

Please report all Program incidents to the Director of Youth Protection. For purposes of reporting, an incident is any event involving:

Instances covered in the Minors Policy Reporting Requirements (for any such instances, additional reporting requirements may apply, as set forth in the Policy);
Other illness, serious harm or risk of serious harm to a Minor;
Possibility for Minor to be sent home from the Program;
Inappropriate behavior by a staff member towards a Minor by a Minor towards another Minor;
Possibility for terminating employment of a staff member;
Involvement of police or law enforcement;
Complaint from parents as it relates to the safety of a Minor;
Reported occurrence of sexual behavior by Minor participant or staff member;
Any instance in which a parent/guardian needs to be contacted.

If you are unsure whether an incident needs to be reported, please contact the Director of Youth Protection.

B. Emergency Preparedness Plan

Each Program must develop site-specific emergency procedures to respond to natural disasters typical of the area, active shooter, and other reasonably foreseeable emergencies such as chemical spills or utility failures in conjunction with the Duke University Emergency Management Plan. These procedures should include guidelines on immediate actions to take such as specific evacuation routes, lockdown procedures, or first aid steps to safeguard participants and staff, and a communications plan. Consider DukeAlert as the official emergency plan activation.

Emergency procedures must be documented in the Program handbook for all Program staff and participants. Staff and participants must be trained on their program specific emergency procedures to ensure understanding and readiness. Specify that during evacuations, timely communication with guardians is crucial. Establish a protocol for notifying guardians about the evacuation, current status, and where they can reunite with their minors. Include provisions for guardians to provide a 24/7 contact available for emergencies.

C. Transportation

Program Director is responsible for ensuring that all guidelines in the Transportation Requirements for Minors are followed.

Program staff who perform transportation activities must complete an approved motor vehicle background check prior to transporting Minors or operating a Duke vehicle and meet all other requirements in the Transportation Requirements. Program staff are not allowed to transport Minors in their own personal vehicles or any non-Duke vehicle.

Large passenger vans (such as 12 or 15 passenger vans) should not be used to transport Minors.

Minors are not allowed to arrange their own transportation to and from Program sites. If the Program desires to allow older participants to drive themselves to and from Program sites, please consult with the Director of Youth Protection Coordinator to develop clear check-in and check-out procedures.

Minors are not allowed to use rides arranged via transportation network companies (e.g., Uber or Lyft) or similar ride-share arrangements, even if requested by the parent/legal guardian.

D. Visitors and Observers

Visitors are typically not allowed during Programs involving Minors except in extreme circumstances and with prior approval by the Director of Youth Protection. Any permitted visitors must be over 21 years old and approved in advance in writing by the parent/legal guardian. Visitors must check in and check out when they arrive and depart and must verify their identity with Program staff by showing a driver's license or other official identification. Visitors are not permitted in residence halls after move-in has been completed.

Programs that permit parent and guardians to observe their children during certain activities should designate an area for observers to remain and share that information with all Program staff, parents/guardians and any other University personnel as appropriate.

Please be mindful that we must ensure the safety and well-being of minors in our Programs. And while Program staff have been screened and trained, visitors and observers have not.

E. Drop-off and Pick-Up Procedures

Where applicable, Programs should develop a procedure for drop-off and pick-up from their Programs, including policies for where cars can drive/park, who is authorized to collect a Minor, and what to do in the event a parent/legal guardian is late to collect a Minor. All coordination must go through Duke Parking and Transportation.

F. Use of Photographs, Recordings, and Participant Work

Per the Participation Agreement, Duke may make use of photos, videos and audio recordings, or participant work in Duke products and publications, websites, and social media accounts. However, Programs should be mindful of postings online or in print and ensure that they do not post any identifying information about the Minor participant, such as first and last name.

G. Program Fee, Refund, and Withdrawal Costs Information

Programs should develop written policies for how to handle requested refunds of program fees and make this information available to parents/legal guardians, e.g. by posting it on the Program website or including in Program materials.

H. Code of Conduct and Written Handbook

All programs are required to have a Code of Conduct for every Participant.

Programs are required to include these Standards, the Code of Conduct, and all other relevant information in a written handbook for participants, their parent/guardian, and program staff. Programs must also:

Develop staff training covering important information including but not limited to:
- drop-off/pick-up procedures,
- supervision ratios & procedures,
- bathroom policies,
- program operation,
- schedule including on-call scheduling for residential programs,
- incident reporting,
- staff code of conduct including applicable Duke policies,
- emergency preparedness procedures,
- participant code of conduct.
Provide pertinent information during orientation for Program participants.
Provide pertinent Information, including the program handbook, to parents/guardians prior to the start of the program.

I. Aquatic Activities

Generally, Program participants are not permitted to swim in any Duke pool without prior approval of the Director of Youth Protection. All aquatic programs involving minors at Duke University or in a Duke sponsored program must have the following:

All minor participants must complete a swim test
1. Swim 25 yards (or the length of the pool being used the Program) with:
  1. Their face in the water
  2. Without goggles
  3. Using some sort of a stroke without stopping and hanging on the wall or putting their feet on the ground
2. Tread water for 1 minute
3. Jump into water over their head and resurface
4. Extricate themselves from the pool
Nationally certified Lifeguard and brown water certified where pertinent. Examples include American Red Cross, Y-Guards, and Ellis.
Established Locker Room/Bathroom Policy the separates minors and adults. This may include clearing the locker room/bathroom while minors are present. Age-appropriate supervision in locker rooms and bathrooms should be provided.
Restrictions for non-swimmers:
- Life jackets provided for non-swimmers, or
- Single-adult per child within arm's reach of every non-swimmer, and
- Restricting to chest-height water

Swim lesson participants do not need to pass the swim test.

J. Trips and Travel

Single Bed Occupancy must be followed at all times. Room Checks should be performed at varying intervals and the program leaders performing room checks should not enter any room unless there is an emergency. There should be a documented supervision plan in place during the night.

Programs are not permitted to take Minors away from campus without prior approval from the Director of Youth Protection and parent/guardian as noted in the signed Duke approved participation agreement. Programs are not permitted to take Minors out of state or on an airplane without prior approval from the Director of Youth Protection.

Generally, Programs may not take Minors outside of North Carolina or the United States, without prior approval and clearance from the Director of Youth Protection and other departments at Duke.

K. Age Requirements

No one under the age of 13 may participate in a residential program at Duke, any Duke facilities, or Duke sponsored program.

Whether a participant is a minor and must adhere to these requirements is based on the biological age of the participant at the time of registration. All policy requirements and standards must be followed for the entirety of the program, even if the minor turns 18 after the program has begun.

If a minor turns 18 during your program they must be treated like a minor for the entirety of the program.

Minors under the age of 16 are not permitted to work (this includes internships, work study, volunteers, etc.) at Duke or in a Program covered by this Policy, or participate in lab placements, except when participating in an approved and supervised tour. These age restrictions apply regardless of whether the work is performed in a paid or non-paid status, whether the event is classified as a Duke sponsored event, or whether the work occurs pursuant to a third-party agreement.

L. Residential Programs

Minors are only permitted to reside in the program specific Duke provided housing when they are registered in a Program.

Program Directors interested in hosting a Residential Program must meet with the Director of Youth Protection prior to registering any residential program.

Residential Programs are required to adhere to all of the requirements within these Standards, including but not limited to the creation of written handbook and program. staff training covering important information such as bathroom/showering procedures, supervision, and procedures for room checks.

Where possible separate restrooms or times should be provided for adults and minors.

M. Third Party Programs

The majority of Programs for minors are hosted on Duke's campus and by Duke staff. However, Duke occasionally permits third parties to host a program on its campus or in its facilities. Any third party interested in hosting a program for minors at Duke must be approved by the Director of Youth Protection. Only approved third parties will be permitted to operate on campus, in any Duke facility, or represent Duke.

Any third-party program must have a contract in place. Contracts must be reviewed and approved by Director of Minors Protection, Corporate Risk Management, Office of Counsel, and Conference & Event Services. Contracts may only be signed by individuals who have the authority to sign on behalf of Duke as maintained in Duke's Authority to Execute Contracts and Other Legal Documents | Policies (duke.edu).

N. Labs

Some programs operate in unique spaces such as labs or where there may be sensitive data. In such Programs there may be additional departmental polices or other governing bodies at Duke that require approval. Program Directors must check with compliance within those departments or schools to best understand their own policies regarding minors. This includes, but is not limited to, the Occupational & Environmental Safety Office (Minors in Work Areas), and School of Medicine (Minors working with De-Identified Data).

O. Mentoring Programs

Many mentoring programs include a key component of one-on-one interactions and relationship building with mentee and Mentors, even if minors. However, one-on-one interactions are prohibited at Duke. Exceptions may be granted on a limited basis by the Director of Youth Protection.

P. Minors Not Participating in University-Sponsored Activities

Duke, as a research university, is generally not a proper environment for Minors unless they are participating in an authorized program or activity and adequately supervised by adults who have the appropriate training and credentials. Accordingly:

Duke students who have a Minor relative, friend, or other guest stay with them on campus must comply with the Guest Policy under the Housing & Residence Life Policies.
Daycare or babysitting services are not permitted except if provided by one of Duke's Early Education and Childcare centers, or by a licensed vendor who complies with all state licensing requirements and is authorized by Duke to offer those services. In-home childcare arrangements in private residences located on Duke lands are permitted.
Pursuant to other university policies and applicable Federal or State laws and regulations, Minors should not be present in certain facilities and environments.

In general, Minors should not be left unsupervised on Duke's campus. It is the responsibility of those who bring Minors to campus (including Program Directors or third-party organizations) to ensure appropriate supervision at all times.

Compliance and Violations of Policy

The Office of Audit, Risk and Compliance as well as the Director of Youth Protection will conduct periodic monitoring and reviews of registered programs to assure compliance with this and other University policies and Minors Program policy guidelines.

Violations of these Standards may result in disciplinary action, up to and including dismissal from employment, suspension or expulsion from further study, revocation of authority to act as a Program Director, and termination or suspension of a Program.