Comment #1: A commenter from UW-Madison recommended adding the language “state licensed daycare, preschool, childcare, and day camp programs” to Section 3.C.
Response #1: Revised Section 3.C to include, “Child care and day camps licensed under DCF 251 or DCF 252.”
Comment #2: A commenter from UW-Stevens Point requested clarification on what are considered “sleeping rooms” in Section 6.E.6.
Response #2: No change made to policy language. This is a question about procedure.
Comment #3: A commenter from UW-Madison recommended removing the extra parenthesis following “System,” or change the reference to “Universities of Wisconsin” in Section 1.
Response #3: Retained reference to the legal name “University of Wisconsin (UW) System,” removing unnecessary parenthesis in the draft.
Comment #4: A commenter from UW-Madison recommended adding “third-party youth activities” to the purpose of the policy in Section 1.
Response #4: Reference to “third-party youth activities” was added to Section 1.
Comment #5: A commenter from UW-Madison recommended removing the statement, “Additionally, each chancellor must designate an employee or unit with the authority and responsibility to oversee university compliance with this policy,” from the first paragraph of Section 3.
Response #5: This text was removed from Section 3, but it was retained in Section 6.A.
Comment #6: A commenter from UW-Madison recommended removing the parenthetical example, “(e.g., matriculated students)” from Section 3.B.I.
Response #6: The parenthetical example, “(e.g., matriculated students),” was removed from Section 3.B.I, as it is essentially redundant.
Comment #7: A commenter from UW-Madison recommended removing parenthetical “(NCAA)” from Section 3.B.1.
Response #7: The parenthetical was removed from Section 3.B.I, as the abbreviation was not used again in the policy.
Comment #8: A commenter from UW-Madison requested Sections 3.B.IV and VI be revised to either make employment status neutral, remove role-based language, or shift justification from job type to risk factors.
Response #8: Section 3.B.VI was changed to address this concern. It now states that minors who are, “employed by the university in a paid position, except where the compensation is provided for involvement in a covered activity” are outside of the scope of the policy. No change is needed in Section 3.B.IV.
Comment #9: A commenter from UW-Madison recommended the definition of “field trip” in Section 5 be expanded.
Response #9: The definition of a field trip in Section 5, was revised to read, “Field Trip: A visit conducted as part of a covered activity where youth participants travel to a location on or off campus (e.g., museum, recreational center) designed to provide them with firsthand educational, cultural, or recreational experiences.” Suggested language, including “base location,” was not included due to concerns about confusion.
Comment #10: A commenter from UW-Madison recommended that “licensed daycare or preschool” be changed to “state licensed childcare or day camp” in Section 3.C.
Response #10: Revised exceptions in Section 3.C to include, “Child care and day camps licensed under DCF 251 or DCF 252.”
Comment #11: A commenter from UW-Madison recommended a clarifying change to the definition of “grooming” in Section 5.
Response #11: The definition of grooming in Section 5 was revised to address concerns. It now reads, “Grooming: A deliberate process through which an individual builds a relationship, trust, and emotional connection with a minor for the purpose of abuse or exploitation.Grooming can occur through in-person, virtual, or any form of written contact/communication.” Updated definition reflects a definition of grooming published by the National Center for Missing & Exploited Children.
Comment #12: A commenter from UW-Madison recommended changing “before participating in the covered activity” to “before assuming their role or responsibilities in the covered activity” in Section 6.D.I.
Response #12: Language in Section 6.D.I was revised to read, “All adults (e.g., employees, volunteers, students, contractors) with significant access to youth participants must complete the following training, at minimum, before interacting with youth in the covered activity and every three (3) years thereafter.”
Comment #13: A commenter from UW-Madison questioned if there are reasons why all adults with significant access, but not assuming custodial care, to youth participants would not need to complete best practices in youth protection training in Section 6.D.
Response #13: Requirements in Section 6.D remain as written. All universities have the option of requiring additional training for adults with significant access who are not in custodial care roles.
Comment #14: A commenter from UW-Madison requested clarification in the definition of “significant access” in Section 5.
Response #14: The definition of significant access was rewritten to state, “Significant Access: Situations where an adult’s role creates direct and substantial interaction with minors. Examples include unsupervised, one-on-one, repeated, or prolonged interactions; supervision of or authority over minors; access to minors’ personal data or records; or direct and unsupervised control over physical or virtual environments minors use.”
Comment #15: A commenter from UW-Madison recommended changing “third-party covered activity” to “third-party youth activity” in Section 5.
Response #15: This term was changed to “third-party youth activity” in the definitions and used as such throughout the document.
Comment #16: A commenter from UW-Madison recommended removing “Universities may require additional training beyond these minimum topics” from Section 6.D.III.
Response #16: Statement in Section 6.D.III was removed from the policy.
Comment #17: A commenter from UW-Milwaukee noted that the term “sexual misconduct” as used in Section 6.E.I.1 is not defined in the policy.
Response #17: Referenced term in Section 6.E.I.1 was changed to align with the terms in the policies referenced.
SYS 625 Appendix A Comments
Comment #1: A commenter from UW-Madison recommended referencing Appendix Sections 8,9, and 10 in Appendix Section 6.ii.
Response #1: Appendix A, Section 6.ii was removed from the policy. The content was incorporated into current Sections E and G in Appendix A. Reference back to the main policy was removed.
Comment #2: A commenter from UW-Madison recommended referencing Appendix Section 6 in Appendix Section 7.iii.
Response #2: Reference to the main policy was removed. The information relevant to third parties is included in Appendix A.
Comment #3: A commenter from UW-Madison recommended changing language to “Incidents involving potential or actual risk of harm or injury to a minor involved in the third-party’s activity or damage to university property, shall be reported according to processes designated by the university as soon as….” in Appendix Section 10.
Response #3: Section G in Appendix A was revised to read, “Third parties must inform all adults of their obligation to report any incident involving potential or actual risk of serious harm or injury to a youth participant involved in the activity while on university property to the university as soon as practicably possible.”
Comment #4: A commenter from UW-Madison recommended removing Appendix Section 11 or heavily revising for clarity.
Response #4: Appendix A, Section 11 was removed from the document.
Comment #5: A commenter from UW-Milwaukee noted that the term “sexual misconduct” as used in the Appendix is not defined in the policy.
Response #5: Referenced term in Appendix was changed to align with the terms in the policies referenced.
Comment #6: A commenter from UW-Milwaukee noted that Appendix A section 6.2 obligates third parties to “Receive information on the prohibited behaviors (SYS 625 Section 6.E) and reporting obligations (SYS 625 Section 6.J) and agree to comply with those requirements”; however, there is no explanation of how third parties can comply with reporting obligations that are very specific to UW employees including where to report.
Response #6: References to SYS 625 6.E and SYS 625 6.J were removed from the Appendix.
Comment #7: A commenter from UW-Milwaukee questioned what “field trip” means in the context of third-party activities in Appendix Section 7.3.
Response #7: Reference to field trip requirements was removed from the Appendix.
