Employees who regularly encounter minors (i.e. any person under 18 years of age) in the course and scope of their work are considered to fill “Critical Positions” and must be subject to background checks pursuant to the Systemwide Guidelines on Designating Critical Positions. 

A Live Scan screening and UBS screening should be completed for any adult, including faculty, staff, students, and volunteers, who regularly encounter minors during their participation in a UCLA program or activity. 

Private or secluded interactions between an adult and a minor are not permitted unless they are necessary to perform essential requirements of the program.

Activities involving minors should follow the “rule of three” (e.g. at least three people should be involved in all aspects of the activity). Although two minors and one adult is an acceptable combination, a combination of three consisting of two adults and one minor, with one of the adults being a campus employee, is much safer. 

When private interactions are necessary to perform essential requirements of the program, program administrators should implement controls that reduce the risk of harm to minors. Typical controls include but are not limited to: 

• Conducting interactions in plain sight of others, such as at an on-campus dining hall or café. 
• Conducting interactions in an office or other unlocked space with open doors and windows in a building open to the public at the time of the interaction. 
• Informing (in advance) at least one other adult connected with the activity (preferably the adult’s supervisor) that the adult will be alone with a minor. 
• Asking another adult to randomly drop in on the interaction. 
• Immediately documenting any unusual incident, including but not limited to behavioral problems, injuries, or interactions that might be misinterpreted. 
   

1. Respect

   Minors must be treated respectfully at all times, regardless of their actions or behavior. 

2. Nondiscrimination

   Minors must be treated fairly regardless of race, ethnicity, sex, gender identity, age, disability, sexual orientation, religion, or any other basis in accordance with the University’s Principles of Community and Nondiscrimination Policies. 

3. Appropriate age groups

   To discourage bullying and physical abuse, minors should be separated into groups according to age, and their interactions should be limited to other children of the same approximate age whenever possible. 

4. Personal conduct of adults

   Adults participating in a campus activity involving minors will refrain from conduct that negatively influences the minor’s behavior. Conduct to avoid includes but is not limited to: 

   • Use of profanity
   • Off-color jokes or suggestive banter
   • Discussing inappropriate personal problems or sexual experiences
   • Viewing sexually suggestive materials or making those materials available to minors
   • Comments about other people’s bodies
   • Use of alcohol or narcotics, and any offers of alcohol or narcotics to minors
   • Use of tobacco or smokeless cigarettes, and any offers of same to minors

5. Intervention

   Adults participating in a campus activity involving minors will intervene promptly to stop harmful activities and negative interactions between minors. These activities and interactions include but are not limited to: 

   • Bullying or hazing
   • Physical abuse
   • Derogatory name-calling
   • Ridicule or humiliation
   • Sexual activity

6. Bathroom use

   Adults should use staff-only bathrooms whenever possible. If staff-only bathrooms are not available, adults should use bathrooms when no minors are present. If adults must use a bathroom when a minor is present, the adult should follow the “rule of three” described above. 

   For minors aged 12 and under, adults should escort two or more minors to the bathroom for group bathroom breaks. The adult should monitor activity from outside the space and not send in more minors than the number of stalls and/or urinals available in the bathroom. 
   For minors 13 or older, a minor should have the permission of the adult supervising the activity in order to leave the activity and use the bathroom. The adult supervising the activity should confirm the return of the minor in a timely manner. During periods of transition from one activity to another, adults should randomly monitor the bathrooms to ensure minors are not lingering or acting inappropriately in them. 

7. Locker room use

   Programs involving the use of locker rooms should establish reasonable procedures to reduce the opportunity for undressed adults to encounter minors. Program supervisors should not use locker rooms and showers at the same time as the minors they supervise. Programs should establish supervisory methods that do not require direct observation of minors undressing or showering. For example, this may include but is not limited to, assigning multiple minors to the area and placing adults where they can hear the group. 

8. Inappropriate contact with minors

   Physical, Emotional, or Sexual Abuse- physical, emotional, or sexual abuse of minors is illegal and will not be tolerated. 

   Employees

   Employees who engage in physical, emotional, or sexual abuse of minors will not be entitled to defense and indemnification by the University in the event they are sued or criminally prosecuted. 

   Employees accused of engaging in physical, emotional, or sexual abuse of minors will be removed immediately from the activity involving minors, and their alleged behavior will be referred to appropriate agencies for investigation. If warranted by the investigation’s findings, they will be subject to disciplinary action up to and including dismissal in accordance with governing University policy and/or collective bargaining agreements. 

   Volunteers

   Volunteers who engage in physical, emotional, or sexual abuse of minors will not be entitled to defense and indemnification by the University in the event they are sued or criminally prosecuted. 

   Volunteers accused of engaging in physical, emotional, or sexual abuse of minors will be removed immediately from the activity involving minors, and their alleged behavior will be referred to appropriate agencies for investigation.  

9. Other physical contact

   Because the campus recognizes that physical contact between non-related adults and minors can be essential to the minor’s well-being and self-esteem, program administrators are encouraged to identify safe conduct that does not pose a risk to minors participating in their programs and would be context-appropriate. This includes but is not limited to: 

   • Handshakes
   • High-fives and hand slapping
   • Pats on the shoulder or back
   • Side hugs
   • Feeding or grooming of babies and toddlers (including diaper changes)
   • Holding hands while escorting children below the age of 8
   • Brief contact to comfort distressed children, and appropriate contact to aid an injured minor or a minor in imminent danger of physical harm (such as a struggling swimmer)

   Program administrators should also identify unsafe conduct and enforce the prohibition of high-risk behaviors between adults and minors. This includes but is not limited to: 

   • Frontal hugs
   • Kisses
   • Lap sitting
   • Massages or rubs
   • Piggyback rides
   • Tickling
   • Touches on the buttocks, chest, or groin (except when changing diapers)
   • Wrestling
   • Any intended affection unwanted by the minor
   • Any touching conducted in private (i.e. no other adults or children present)

10. Disciplining minors

    No adult associated with a campus activity involving minors may use physical punishment to manage a minor’s behavior. This prohibition includes spanking, slapping, pinching, hitting, or any other physical force. 

11. Non-program contact with minors

    In general, private meeting and telephonic or electronic communications with minors outside of the program’s normal activities are not permitted unless they are necessary as part of the program. Include other adults in the program or parents of affected minors in the discussions whenever possible. When outside meetings/communications are absolutely necessary, the program must implement controls that reduce the risks. This includes but is not limited to: involving multiple parties/entire groups, selecting public locations, keeping doors open, using rooms with windows during meetings, securing parental permission, etc. All activities must always abide by regulatory guidelines established for the specific activity (i.e. NCAA, American Camp Association, etc.)

    University employees and volunteers supervising minors should not initiate or respond to text messages, e-mails, and social media “posts” sent by individual minors to their personal devices. If a one-on-one message is initiated by a minor, the employee or volunteer should add an additional staff member or the minor’s parent/guardian to the communication prior to responding. The employees and volunteers should select university devices for all communications and develop program “community” bulletin boards or social networking sites to communicate with participants. All communication shall be conducted through official, transparent channels whenever possible.  

12. Gifts

    Individual adults participating in campus activities involving minors may not give gifts to the minors that participate in the program. Awards or gifts for these minors must come from the program in accordance with applicable university guidelines on gifts and expenditures. 
    Medical treatment of minors and emergency response
    Generally, all medical treatment of minors must be provided by personnel trained in accordance with the level of care required (first aid trained staff render basic first aid until professional assistance such as paramedics respond). 
    All minors participating in university programs must have Waiver of Liability Forms signed by their Parent or Guardian on file before participation begins. 

Generally, all medical treatment of minors must be provided by personnel trained in accordance with the level of care required (first aid trained staff render basic first aid until professional assistance such as paramedics respond).

All minors participating in university programs must have Waiver of Liability Forms signed by their Parent or Guardian on file before participation begins. 

Program administrators must implement effective controls to keep minors safe in situations involving vehicular traffic. When minors are pedestrians, consider controls that include but are not limited to: high visibility lanyards, vests or shirts, and assign adults leading and trailing assignments to keep the group under control while crossing streets or traversing sidewalks along busy streets. 

When minors are transported in vehicles, select the safest mode of transportation available. School buses, chartered buses, and university vehicles with professional drivers are considered the preferred, safest mode of transportation. Sufficient numbers of adults should also be assigned throughout each vehicle to provide effective supervision.  

1. California Child Abuse and Reporting Act (CANRA)

   UCLA Mandated Reporters include the following:

   • Employees, Officials, and other positions at UCLA who by virtue of their licensure or profession have a duty to report under CANRA; 
   • Individuals who, within the scope of their employment or other position at UCLA, have duties that bring them into regular and direct contact with a Child (this does not include faculty or instructors whose only contact with a Child is teaching a class); 
   • Other categories of Mandated Reporters can be found here: 

   Mandated Reporters must report suspected abuse or neglect of a minor. Abuse and neglect include, but are not limited to: 

   • Physical injury or death inflicted by other than accidental means
   • Emotional abuse
   • Sexual abuse, assault or exploitation
   • Willful endangerment
   • Unlawful corporal punishment
   • Neglect

   Each UCLA department identifies the Mandated Reporters on their staff. 

   Mandated Reporters must immediately,: 

   1. Call the Los Angeles County Child Abuse Protection Hotline at (800) 540-4000 560-2191 and one of the following local law enforcement agencies:
      1. UCLA Police Department: 911 or (310) 825-1491; or
      2. Los Angeles County Sheriff’s Department: 911 or (562) 946-7960 AND
   2. Submit Form 8572 within 36 hours to the County of Los Angeles, Child Protection Hotline using a web-based system link through the Mandated Reporter Application, which they will receive after making their phone report to the Child Protection Hotline. AND

   3. Report observed or suspected Child Abuse or Neglect internally to the University of California Whistleblower Hotline or to their supervisor. If reported to a supervisor, the supervisor must make the report to the University of California Whistleblower Hotline by:

      1. Telephone: (800) 403-4744
      2. Online: Whistleblower Hotline 

      The report may be anonymous; however, providing contact information for the Mandated Reporter may expedite the University’s ability to follow-up on the report. 

2. California Penal Code ss 152.3

   In addition to the CANRA regulations described above the campus will fully comply with California Penal Code ss 152.3, which has long required any person who reasonably believes that they have observed the murder, rape, abuse, or sexual assault of a child under 14 years old to notify a law enforcement official. Failure to notify is punishable by fines, imprisonment, or both. 

   Mandated reporters have immunity from criminal or civil liability for reporting as required by law. 

   1. Responding to Reports of Child Abuse and Neglect

      All reports of suspected child abuse or neglect will be taken seriously. The UCLA Police Department will respond to such reports immediately. 

      The campus may also respond to reports of suspected child abuse or neglect through its Office of Civil Rights and any other appropriate investigative office.