I.  Purpose

Kenyon College is committed to the safety of all individuals in its community. This Policy establishes guidelines for those in the College community who may work or interact with individuals under 18 years of age, with the goal of promoting the safety and well-being of minors. This Policy is applicable to College-affiliated programs, as defined in the Scope of this policy. Non-College affiliated program requirements will be outlined in a facility use agreement (contract) with each respective program.

II.  Scope

College-Affiliated Programs: College-affiliated programs or activities include those programs and activities sponsored and approved for operation by the College. These programs will have a Program Supervisor that is employed by Kenyon and is responsible for operating such programs. Program Supervisors are responsible for ensuring that all guidelines and responsibilities in this policy are met. This Policy provides guidelines that apply to interactions between non-student minors and College students, faculty, staff and volunteers in College-affiliated programs or activities.

All Kenyon College students and faculty and staff are responsible for understanding and complying with this Policy. All College-affiliated programs that happen on campus and institution-sponsored activities off campus that involve direct contact with non-student minors in an unsupervised setting are subject to this policy.

Appendices to this Policy set forth specific requirements and the policy and related procedures and may be revised and/or updated from time to time.

III.  Definitions

Minors for the purpose of this policy means non-students under the age of 18.

Campus for purposes of this policy means all buildings, facilities and properties that are owned, operated, managed or controlled by the College.

Unsupervised Setting is defined as a circumstance where Kenyon College students, faculty, or staff are alone or in small groups with non-student minors without outside supervision (i.e. a non-Kenyon teacher, principal, or parent).

Abuse of minors for purposes of this Policy means physical, emotional or mental injury or death, inflicted other than by accidental means, the creation of a substantial risk to the health or safety by negligent treatment or maltreatment, or sexual abuse or exploitation of a person under age 18.  

Sexual abuse includes engaging in or attempting to engage in a sexual act or sexual contact with a minor, causing or attempting to cause a minor to engage in sexually explicit conduct or exposing the minor to sexually explicit conduct.

Neglect includes the failure to act to meet basic requirements for health and safety of, or to prevent the infliction of abuse upon, a person under age 18.

IV. Requesting a College-Affiliated Program

Before engaging in any College-affiliated program or activity involving contact with minors, Program Supervisors must complete the Working with Minors Program Roster annually and share it with Human Resources (hr@kenyon.edu) and the Office for Civil Rights (sherman2@kenyon.edu). If your program includes student workers, student volunteers or recent graduates, this should also be shared with Student Affairs (hartruthenbeck1@kenyon.edu) and (jackson1@kenyon.edu) for a reference check. 

Working with minors Program roster

V. Guidelines and Responsibilities

Before engaging in any College-affiliated program or activity involving contact with minors, all Program Supervisors must educate themselves, and their staff, faculty and students on the following requirements annually:

  • Be vigilant in protecting the well-being and safety of minors with whom they interact on campus or elsewhere.
  • Review the informational material about the signs of abuse and neglect of minors in Appendix A. An in-person training may be requested through the Office for Civil Rights. The training includes:
    • Basic warning signs of abuse or neglect of minors.
    • Requirements and procedures for reporting incidents of suspected abuse or neglect or improper conduct.
    • *Athletic teams will have this information included in their annual in-person Civil Rights training.
  • Watch for signs of minor abuse or neglect and promptly report suspected instances of abuse or neglect, or violations of this policy or law, as provided in Section VII and Section VIII.
  • Ensure that the program or activity provides appropriate supervision for minors at all times. Supervision is to be provided by program-affiliated students, faculty and/or staff, and appropriate supervision includes compliance with the guidelines established by the American Camp Association, as listed in Appendix B.
  • Meet the requirements of this Policy relating to criminal background checks as listed in Appendix C.
  • Run reference checks through Civil Rights and Student Affairs for programs involving current or recently graduated students.

Compliance with this policy doesn't excuse compliance with other College policies that may apply to a particular activity.

College faculty and staff on campus who only interact with Kenyon College undergraduate students under the age of 18 in classes or other traditional academic settings are not required to undergo the training or background checks required by this Policy. Anyone covered by this Policy who knows or suspects that an undergraduate student under the age of 18 has been abused or neglected must, however, make reports as required by Section VII and Section VIII.

To the extent College faculty, staff or students are participating in programs or activities run by a non-College affiliated program or activity off campus, they should familiarize themselves with, and follow the policies of, the organization relating to interactions with minors and understand their legal obligations with respect to working with minors in the program setting.

VI. Reporting Potential Harm to Minors

1. Emergencies

In case of an emergency immediately call Kenyon’s Campus Safety office at 740-427-5555 or the Knox County Sheriff at 911.

2. Reports of Known or Suspected Abuse or Neglect of Minors

ANY person participating in a College-affiliated program or activity involving minors, who knows, suspects, or receives information indicating that a minor has been abused or neglected, MUST notify the following:

  • Campus Safety may be reached by calling 740-427-5000 or

  • The College’s Title IX Coordinator may be reached at 740-427-5245 or 740-427-5820..

Reporting can also be made via the online Report an Incident form. Those experiencing neglect may report anonymously. Kenyon affiliated individuals may not report anonymously on behalf of another.

Campus Safety with support from other appropriate offices as necessary will help determine appropriate next steps. In addition, Program Supervisors should be promptly notified once it is safe and appropriate to do so.

Report an Incident

VII. Addressing Reports of Abuse or Neglect

A. Upon receipt of a report of alleged abuse or neglect of a minor in a College-affiliated program or activity, the College’s Campus Safety Officer or Title IX Coordinator (or designee), shall:

  1. Take immediate steps to prevent further harm to the alleged victim or other minors, including, where appropriate, removing the alleged abuser from the program or activity or limiting their contact with minors pending resolution of the matter.
  2. Determine whether the Knox County Sheriff, Knox County Department of Jobs and Family Services, Children and Family Services Division, or both have already been notified and, if not, whether such notification is required or appropriate given the circumstances.
  3. If the parents or guardians of the alleged victim have not been notified and are not the alleged abusers, notify the parents or guardians of the minor involved.
  4. Investigate the report and resolve the matter in a way that safeguards the minor, protects the interests of victims and reporters, affords fundamental fairness to the accused, and meets applicable legal requirements.
  5. Facilitate the College’s cooperation with any investigation conducted by the Knox County Sheriff, Knox County Department of Jobs and Family Services, Children and Family Services Division, or other governmental agency.

B. Whenever a report alleges that someone involved in an activity on campus who is not a member of the College faculty, staff, or student body has abused or neglected a minor, the person receiving the report shall immediately notify the College’s Title IX Coordinator, even if they believe the Coordinator has already been notified. The College’s Title IX Coordinator shall coordinate with the non-College affiliated organization or entity as necessary to see that the requirements of Part A.1-5 of this Section are accomplished.

C. Upon being notified of a sexual misconduct or abuse incident involving a minor, the Title IX Coordinator shall notify the Kenyon College Risk Manager who will in turn notify the commercial general liability insurance company of the incident.

VIII. Accidents, Incidents and Insurance

Program Supervisors operating any College-Affiliated Program shall be required to provide the College with prompt and timely written notice of any incident and/or accident of which it has knowledge that in any way, directly or indirectly, contingently or otherwise, occurs in their program or activity.

IX. Nondiscrimination

Any program or activity involving minors shall be required to review and train its personnel and agents on the College’s anti-discrimination policy. The College does not discriminate in its educational programs and activities on the basis of race, color, national origin, ancestry, ethnicity, sex, gender, gender identity, gender expression, sexual orientation, physical and/or mental disability, age, religion, medical condition, genetic information, veteran status, marital status, or any other characteristic protected by institutional policy or state, local or federal law. Any College-affiliated program or activity shall be non-discriminatory in hiring staff and/ or in enrolling/admitting minor attendees and shall comply with all applicable federal, state and local laws and ordinances.

Any requests for accommodation received by any program or activity operating on the Kenyon College campus involving minors should be coordinated with College’s Campus Events Office in consultation with other College offices, including Student Accessibility and Support Services (SASS), as appropriate. 

X. Enforcement

Sanctions for violations of this Policy will depend on the circumstances and the nature of the violation, but may include the full range of available College sanctions applicable to the individual including suspension, dismissal, termination and, where appropriate, exclusion from campus. The College may also take necessary interim actions before determining whether a violation has occurred.

XI.  Policy Implementation and Modification

Questions about the interpretation or application of this Policy should be raised with the College’s Office for Civil Rights who will consult with other College offices as appropriate, shall update or modify the Appendices to the Policy as necessary and administer, and oversee the implementation of the Policy in a manner that best achieves its goals. This Policy may be modified as necessary.

Appendix A

Training Requirements

This Google Form houses the link to the online training video and an attestation that you have viewed it.

Protection of Minors Policy Training Form

Appendix B

American Camp Association Requirements for Staff to Minor Ratios

Age of Minor Staff-to-Minor Ratio Staff-to-Minor Ratio
  Overnight Program/Activity Daytime Program/Activity
5 or younger 1:5 1:6
6-8 years 1:6 1:8
9-14 years 1:8 1:10
15-18 years 1:10 1:12

Appendix C

Criminal Background Checks for Those Interacting with Minors

The following categories of adults involved in a College-affiliated program or activity are required to undergo a criminal background check annually and prior to their participation in College activities or programs involving minors:

  • Program Supervisors of programs involving minors, including those who are responsible for supervising those who interact with minors;
  • Those who stay overnight with minors as part of their job responsibilities in a program or activity involving minors;
  • Those who work in positions that the College has determined involve regular contact with non-student minors in an unsupervised setting.

The Office of Human Resources will oversee the processing of criminal background checks for all affiliated programs and activities involving minors. The cost of the background check will be borne by the program or activity involving minors.

Background checks shall consist of a social security number trace and address locator for seven years, a search of federal and state or county databases for criminal history for the past seven years, and a national sex offender registry check.

If a background check reveals adverse information or unfavorable results, an individualized assessment will be conducted. Consideration for staff will be given to the relationship between a conviction and the responsibilities of the position that is or will be held. A relevant job-related conviction may be grounds for termination of employment or non-selection of an applicant. The Office of the Provost will make determinations in cases where criminal background checks for faculty reveal adverse information that is relevant to one’s participation in a College-affiliated program or activity covered by this Policy.

For College-affiliated programs or activities, only a background check conducted by Kenyon College or an external source approved by Kenyon College will be accepted for purposes of this Policy.

Any faculty, staff or student who is required by this Policy to have a background check is under a continuing obligation, for the duration of participation in programs or activities involving minors, to disclose immediately any new felony or misdemeanor conviction to the Human Resource office. Except where required by law, criminal background checks of College faculty, staff and students will be used only for purposes consistent with this Policy and will otherwise be kept confidential. The record of information returned as a result of the background check will be maintained separately from an individual’s personnel or student file.