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Protection of Minors at Columbia: Reporting Suspected Abuse and Maltreatment of Minors

Effective Date: March 2013  

Revised: July, 2018

Policy Statement

This policy creates an independent duty for members of the Columbia University community who interact with, supervise, chaperon, or otherwise oversee minors in University sponsored programs, activities, and/or residential facilities to be trained by the University, and to report immediately suspected cases of abuse and maltreatment of individuals under the age of 18. Any member of the Columbia University community may report a concern if they have reasonable suspicion that a child has been abused or maltreated. This policy also describes the registration, training, and background check requirements for University programs and activities with minors.

Reason(s) for the Policy

Columbia welcomes minors to our campus every day. They are part of our academic programs and activities, athletic programs, summer camps, the (K-8) School at Columbia University, medical clinics and practices, and affiliated childcare centers. 

Although some University employees, as “NYS mandated reporters”*, are required by law to report suspected child abuse and maltreatment, we have implemented these procedures to ensure that we protect minors who are on our campus or participating in University programs and activities.

*NYS mandated reporters are required to report cases of suspected child abuse and maltreatment under New York State Law and include physicians, registered nurses, social workers, and mental health professionals, among others. Additional information is available in the reference section of this policy.

Primary Guidance to Which This Policy Responds

Title 6 of Article 6 of the New York State Social Services Law, §§411-428 define child abuse and maltreatment.

Article 10 of the New York State Family Court Act, §1012 further defines child abuse, maltreatment and other key terms.

Title IX of the Education Amendments of 1972 (“Title IX ”) is a Federal Civil Rights law that prohibits discrimination on the basis of sex and gender in any education program or activity receiving federal funds. The “Dear Colleague Letter on Sexual Violence,” dated April 2011, emphasizes that sexual violence is the most egregious form of sexual harassment under Title IX.

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, 20 U.S.C. §1092(f) (the “Clery Act”) requires all colleges and universities that participate in federal financial aid programs to keep and disclose information about crime on and near their campuses with penalties for infractions.

 

Responsible University Office & Officer

•    Department of Public Safety, 212-854-5555 (Morningside), 212-853-3333 (Manhattanville), 212-305-7979 (Medical Center).

•    Marjory Fisher, Associate Vice President & Title IX Coordinator, 212-853-1276

•    Ursula Bollini, Director HR Compliance & Protection of Minors, 212-851-9636

•    Office of Equal Opportunity and Affirmative Action

•    Office of University Compliance

 

Who Is Governed By This Policy

All University employees are governed by this policy.  In addition, all volunteers, contractors, and consultants who interact with supervise, chaperone, or otherwise oversee minors in programs or activities at the University or sponsored by the University are also governed by this policy.

  

Policy Text

Columbia University requires all members of the University community who interact with, supervise, chaperone, or otherwise oversee minors in programs or activities at the University or sponsored by the University to report immediately if they have reasonable cause to suspect abuse or maltreatment of individuals under the age of 18.  This duty to report is not delegable to a colleague or supervisor. Any members of the Columbia University community may report a concern of child abuse or maltreatment.

The University does not tolerate retaliation against individuals who report concerns in good faith.


Responsibility

Report of Suspected Abuse

  • If a child is in immediate danger or if you require emergency assistance, call 911.

If you have reasonable cause to suspect child abuse or maltreatment, you must take the following steps:

1.    Call the New York State Child Abuse & Maltreatment Hotline: 800-342-3720 When calling the NY State Child Abuse & Maltreatment Hotline, make sure to obtain an ID number and the name of representative contacted.

2.    Call the Department of Public Safety: 212-854-5555 (Morningside), 212-853-3333 (Manhattanville), 212-305-7979 (Medical Center).  You will be asked to Public Safety with the ID number and the name of the Hotline representative.

3.    Notify the appropriate program director or your supervisor, Chair, or Dean.

4.    If the report involves abuse by a member of the Columbia community, file a report with the University’s Office of Equal Opportunity and Affirmative Action by going online to http://eoaa.colummbia.edu/ and clicking on “File a Report.”

Reporters may speak with a supervisor, the Title IX Coordinator, and/or a Public Safety representative prior to making the report, and may be accompanied by any of these individuals while making the report.

 

Special Circumstances

Other State Agencies 

In some situations, the New York State Child Abuse & Maltreatment Hotline might decline to take a report for reasons including because the alleged abuse or maltreatment occurred in a different state or because the NYPD Special Victims Bureau or another law enforcement agency may be a more appropriate agency for receiving the report.  In these situations, the Title IX coordinator and Public Safety are available to assist in identifying the appropriate external agencies to contact next.

 

Exclusions

The duty to report may not apply to certain confidential communications to attorneys or members of the clergy in cases where a recognized legal duty of confidentiality applies. 

Physicians, psychiatrists, licensed therapists, and other clinicians who are NYS mandated reporters and are reporting suspected child abuse or maltreatment in connection with their clinical care to patients are not required to notify Public Safety of the report if doing so would breach a patient’s legal rights to confidentiality. 

 

Requirements for Protection of Minors Programs at Columbia University:  Registration, Training and Background Checks.

 

Registration:  Protection of Minors Programs

Columbia Programs involving minors must register their program with the Protection of Minors Office (pomtraining@columbia.edu) in accordance with the Registration Deadlines below.Registration requires applicable organizations to provide:1.    A description of the Program, including the location or locations at which it will be held;

2.    Dates on which the Program will occur;

3.    Name, title and contact information for the Director of Program;

4.    Approximate number and age range of the minors who will partake in the Program;

5.    Information regarding members of the University community who have been offered to take part in a Program

Registration for Columbia programs that involve overnight stays for minors in Columbia residence halls must be submitted no later than one month prior to the date when the Program will begin so as to allow sufficient time for members of the University Community to complete required training and undergo background checks. (See “Training” and “Background Checks” sections, below).

Registration for all non-residential programs involving Minors, including using or touring Columbia laboratories must be submitted no later than two weeks prior to the date when the Program will begin (so as to allow sufficient time for members of the University Community to complete required training and undergo background checks, if necessary. (See “Training” and “Background Checks” sections, below).

 

Training

Members of the Columbia University community, who interact with, supervise, chaperone, or otherwise oversee minors in programs or activities at the University or sponsored by the University are required to take a course designed to familiarize members of the Columbia community with University policy and relevant law on reporting suspected child abuse and maltreatment of minors. The course includes definitions of child abuse and maltreatment, possible signs and indicators, appropriate responses, how to report a concern, and appropriate interactions with minorsThe Protection of Minors Training is available online and can also be completed through an in-person training session organized by the sponsoring program. These training sessions are available after a program has been registered with the Office of the Protection of Minors (pomtraining@columbia.edu),

 

Who is Required to Take This Training?

Any member of the Columbia University community, who interacts with, supervises, chaperones, or otherwise oversees minors in programs or activities at the University or sponsored by the University (the latter includes activities held off-campus) must take the training.

 

Background Checks

Members of the Columbia University community who interact with, supervise, chaperone, or otherwise oversee minors in programs or activities at the University or sponsored by the University, and who have the potential to have unsupervised contact with minors in such programs or activities, must undergo a criminal background check at least every two years. Please see the Columbia University Background Check Policy for more information.  

• New York State Child Abuse & Maltreatment Hotline: 800-342-3720

• Mandated Reporter Hotline: 800-635-1522
• Department of Public Safety: 212-854-5555 (Morningside) or 212-305-7979 (Medical Center)

• Office of Equal Opportunity and Affirmative Action: 212-854-5511

• Columbia University Compliance Hotline: 866-627-3768 or compliance.columbia.edu

 

Additional Resources

For those interested in further information, please go to the Columbia Compliance Web site. This information includes resources for those working with minors, including NYS mandated reporters, parents or guardians, and those seeking care for an abused or maltreated minor.

 

Definitions

“Child Abuse” includes physical abuse, physical neglect, sexual abuse, and emotional abuse. New York law defines these types of abuse as follows:

•    Physical abuse: Non-accidental physical injury of a child that ranges from superficial bruises and welts to broken bones, burns, serious internal injuries and in some cases, death. It includes actions that create a substantial risk of physical injury to the child.

•    Physical neglect: Withholding, or failing to provide, adequate food, shelter, clothing, hygiene, medical care, education, or supervision, such that the child’s physical, mental or emotional condition is impaired or at imminent risk of being impaired.

•    Sexual abuse: When an individual commits a sexual offense against a child or allows a sexual offense to be committed, such as rape, sodomy, or engaging a child in sexual activity or in a sexual performance.

•    Emotional abuse: Acts or omissions that cause or could cause serious conduct, cognitive, affective, or other mental disorder such as torture, close confinement, or the constant use of verbally abusive language. This may include emotional neglect, such as withholding physical and emotional contact to the detriment of the child's normal emotional or even physical development.

The duty to report may not apply to certain confidential communications to attorneys or members of the clergy in cases where a recognized legal duty of confidentiality applies. 

Physicians, psychiatrists, licensed therapists, and other clinicians who are NYS mandated reporters and are reporting suspected child abuse or maltreatment in connection with their clinical care to patients are not required to notify Public Safety of the report if doing so would breach a patient’s legal rights to confidentiality.“Independent Duty” means that you must report your reasonable suspicion of child abuse or maltreatment and that you may not delegate this duty.

“Maltreatment” (includes Neglect) means that a child’s physical, mental, or emotional condition has been impaired, or placed in imminent danger of impairment, by the failure of the child's parent or other person legally responsible to exercise a minimum degree of care by:

•    failing to provide sufficient food, clothing, shelter, education; or

•    failing to provide proper supervision, guardianship, or medical care (refers to all medical issues, including dental, optometric, or surgical care); or

•    inflicting excessive corporal punishment, abandoning the child, or misusing alcohol or other drugs to the extent that the child was placed in imminent danger.

“Minor” means an individual under the age of 18.

“Reasonable cause to suspect child abuse or maltreatment” means that, based on your rational observations, professional training and experience, you have a suspicion that a parent, a guardian, or a caregiver of a child is abusing or maltreating that child.  Under University policy, reasonable suspicion of child abuse or maltreatment also includes situations where you reasonably suspect that an adult who interacts with, supervises, chaperones, or otherwise oversees minors in a University program or activity is abusing or maltreating a child.  It is enough that you have a suspicion, backed by a reason, that a child with whom you work is being harmed.  Your reasonable suspicion can be based upon:•    witnessing a single incident

•    what a child says

•    what an adult with a reasonable suspicion tells you about a child

•    an explanation of an injury that makes no sense.

•    a combination of warning signs