Youth Protection and Compliance

Original Issuance Date: March 10, 2022
Last Revised Date: February 19, 2026

1. Policy Purpose

The purpose of this policy is to establish minimum standards for the protection of minors engaged in covered activities and third-party youth activities throughout the University of Wisconsin (UW) System. This policy does not supersede any stricter standards set by universities or state and federal law.

2. Responsible UW System Officer

Chief Compliance and Risk Officer

3. Scope and Institutional Responsibilities

The scope of this policy is limited to covered activities and third-party youth activities. Each university may adopt their own youth protection policies or procedures that meet or exceed these standards.

The following activities and individuals are outside the scope of this policy:

Activities offered by a university (e.g., museum tours, competitions) where a chaperone (e.g., youth group leader, teacher) or parent/guardian retains responsibility for the care and control of the minors in their charge for the duration of the activity;
Minors who are:
1. Formally admitted to the institution and enrolled as a student;
2. Enrolled in for-credit courses as a nondegree or visiting student, including students enrolled through dual-credit programs;
3. Enrolled in noncredit courses designed for adults;
4. Participating in internships or other academic experiences as a matriculated student or through a for-credit course;
5. Participating in pre-enrollment visitation or recruiting activities, including those governed by the National Collegiate Athletic Association;
6. Employed by the university in a paid position, except where the compensation is provided for involvement in a covered activity;
Child care and day camps licensed under DCF 251 or DCF 252;
Medical care provided to minors in clinical settings;
Institutional Review Board approved research;
Public events; and
Private events

4. Background

In alignment with Wisconsin Executive Order 54, this policy expands on the UW System’s efforts to provide safe and positive experiences for youth participants in covered activities. This policy also meets the requirements contained in Regent Policy Document 23-3, Youth Protection, Compliance, and Data Collection.

5. Definitions

Adult: A person 18 years of age or older associated with a covered activity who is not a youth participant.

Bullying: An intentional, persistent, and repeated pattern of physical and/or non-physical behaviors that are intended to, or have the reasonable potential to, cause fear, humiliation, or physical harm in an attempt to socially exclude, diminish, or isolate.

Covered Activity: A program, event, operation, endeavor, or activity, regardless of location, that is organized, sponsored or operated by the university and during which the university assumes custodial care of minors.

Custodial Care: The temporary responsibility for supervision, care, or control of youth participants who are not accompanied by a parent, guardian, or other responsible adult. Custodial care may be continuous (for the full duration of a program or activity) or intermittent (for one or more periods within a program or activity).

Familial Relationship: Parent, stepparent, legal guardian, grandparent, or adult sibling to the youth participant.

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.

Grooming: A deliberate process through which an individual builds a relationship trust, and emotional connection with a minor for the purposes of abuse or exploitation. Grooming can occur through in-person, virtual, or any form of written contact/communication.

Minor: A person under the age of 18.

Observable and Interruptible: An interaction that takes place in such a way that another person can see, hear, or has knowledge of the interaction and can interrupt if a concern arises.

One-on-One Interaction: An adult and youth participant interacting or communicating in a physical, online, or virtual space without another person present.

Primary Contact: The designated staff member associated with the covered activity responsible for the activity’s compliance with this policy and any applicable university policies or requirements.

Private Event: An occasional and special event where only family, friends, and people known to the hosts attend (e.g., birthday party or a wedding).

Public Event: An activity open to attendance by the general public (e.g., athletic events, concerts, theatrical productions, and similar ticketed or open-admission events) where minors are attending as spectators or are incidentally present.

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.

Supervision Ratio: The minimum number of adults (meeting screening and training requirements) needed to supervise a specific number of youth participants in a covered activity as defined by policy or law.

Third Party: A non-university organization, individual, or entity. This includes employees of the institution who are engaged in private activities that are outside of the scope of their employment.

Third-Party Youth Activity: An event, operation, endeavor, or activity operated by a third-party that takes place on a university’s premises pursuant to an agreement with that university and involves the third party assuming custodial care of participating minors.

University: A university governed by the Board of Regents of the University of Wisconsin System as defined by Wis. Stat. Ch. 36.

Volunteer: An adult who performs duties related to a covered activity without compensation, under the direction/control of employees of the university.

Youth Participant: An individual who is registered or enrolled in a covered activity or third-party youth activity.

6. Policy Statement

Each university must comply with the following requirements.

A. University Oversight

Each chancellor must designate an employee or unit with the authority and responsibility to oversee university compliance with this policy. Any exceptions or waivers to this policy shall be documented in writing by the chancellor or designee.

B. Recordkeeping

1. The primary contact shall document the following information for their covered activity:
  1. Date(s)/time(s) of activity;
  2. Name(s) of primary contact(s) and contact information;
  3. Information on adults (e.g., employees, volunteers, students, contractors) with significant access to youth participants, including their:
    1. Legal first and last name;
    2. Contact information; and
    3. Dates of completion for all applicable screening and training requirements; and
  4. Information about youth participants, including their:
    1. Legal first and last name; and
    2. Parent/guardian contact information.
2. The primary contact is responsible for providing this information to the employee or unit designated by the chancellor to oversee this policy.

C. Screening

The primary contact and all adults (e.g., employees, volunteers, students, contractors) with significant access to youth participants in covered activities must:
1. Complete a criminal background check that meets Regent Policy Document 20-19, University of Wisconsin Criminal Background Check Policy minimum standards; and
2. Promptly report any arrests, charges, or convictions (excluding misdemeanor traffic offenses) to human resources, or to whomever the university designates as the appropriate individual to receive a report within 24 hours, or at the earliest possible opportunity. Failure to report may result in disciplinary action, up to and including dismissal or prohibition from future participation in covered activities.
Promptly report any arrests, charges, or convictions (excluding misdemeanor traffic offenses) to human resources, or to whomever the university designates as the appropriate individual to receive a report within 24 hours, or at the earliest possible opportunity. Failure to report may result in disciplinary action, up to and including dismissal or prohibition from future participation in covered activities.

D. Training

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:
1. Prohibited behavior outlined in Section 6.E; and
2. Mandated reporter requirements.
The primary contact and all adults (e.g., employees, volunteers, students, contractors) who assume custodial care, including those counted in supervision ratios, must complete the following training before interacting with youth in the covered activity and every three (3) years thereafter:
1. Best practices in youth protection;
2. Prohibited behavior outlined in Section 6.E;
3. Mandated reporter requirements;
4. Title IX sexual misconduct reporting; and
5. How to report other incidents outlined in the universities reporting and escalation plan.
The primary contact is responsible for ensuring that all training requirements are completed and documented prior to the first day of the adult’s interaction with a youth participant in a covered activity and reporting compliance to the employee or unit designated by the chancellor to oversee this policy.

E. Prohibited Behaviors

The behaviors listed within this section are expressly prohibited. Additional behaviors may also be prohibited under applicable laws or university policies.
1. Sexual harassment and sexual violence defined in Regent Policy Document 14-2;
2. Child abuse and neglect as defined in university policy and state law;
3. Bullying, grooming, and other predatory behavior;
4. Adults infringing on youth participants’ privacy in situations where privacy is expected (e.g., changing clothes, taking showers) except when a health or safety exception is necessary and appropriate;
5. Adults showering, bathing, or undressing with or in the presence of youth participants;
6. Adults sharing sleeping rooms with youth participants except in the case of familial relationships;
7. Adults entering sleeping rooms assigned to youth participants except for room checks with at least two (2) adults or in health or safety emergencies;
8. Photographing or recording in shower houses, restrooms, or other areas where privacy is expected by participants; and
9. Using or being impaired by alcohol, unauthorized drugs, or tobacco products when engaged in covered activities.
One-on-one contact between adults and youth participants is prohibited except in the following circumstances:
1. When one-on-one instruction is necessary to effectively conduct the covered activity (e.g., music lessons, tutoring, competitions, mentoring), as long as it is observable and interruptible, and the minor’s parent(s)/guardian(s) are informed in advance that the activity will include one-on-one interactions.
2. There is a familial relationship between the adult and youth participant.
3. A personal aid or other assistant has been approved by the university as a reasonable accommodation. Youth protection screening and training requirements may be satisfied through the individual’s employing agency or through the university, as determined by the university.
4. An emergency warrants it (e.g., accompanying a youth participant to the emergency room, locating a missing youth participant, youth reporting personal concerns to a trusted adult).

F. Supervision of Youth Participants

Each covered activity shall maintain supervision ratios appropriate to the average age of youth participants and the nature of the youth activity as follows:
1. Day-only covered activities:
  1. Age three (3) to four (4) years, 1:4
  2. Age four (4) to five (5) years, 1:6
  3. Age five (5) to six (6) years, 1:12
  4. Age seven (7) and older, 1:18
2. Overnight covered activities:
  1. Age six (6) and under, 1:4
  2. Age seven (7) and older, 1:10, unless an alternative ratio is authorized through a variance to the applicable license
At least two (2) adults authorized to provide custodial care of minors shall accompany youth participants on all field trips offered by the covered activity; supervision ratios referenced above must also be maintained.

G. Overnight Covered Activities

Universities may not operate overnight covered activities without applicable state or county licenses.
All covered activities subject to a license held by the university shall comply with the requirements of this policy and the applicable license. If the applicable license imposes additional or more stringent requirements, those requirements take precedence and must be followed in addition to this policy.

H. Emergency Preparedness

Covered activities shall comply with applicable university emergency operations plans.
Programs must prepare additional emergency response plans to address risks specific to the covered activity (e.g., lost or missing youth participant, water rescue) if such procedures are not included in university plans.

I. Insurance Coverage

Covered activities are required to have insurance (e.g., participant accident insurance) as directed by the university’s risk management authority.

J. Reporting and Response Obligations

All adults (e.g., employees, volunteers, students, contractors) with significant access to youth participants are required to take appropriate action when and if they witness or receive credible evidence of an alleged violation of this policy. This includes, but is not limited to, reporting incidents outlined below to the appropriate university individual or unit in accordance with university procedures, relevant policy, or applicable law.
1. Any suspected physical abuse, neglect, or sexual abuse of a minor pursuant to the university’s EO54 reporting procedures;
2. Sexual harassment or sexual violence as defined by the university’s Title IX policy;
3. Incidents resulting in serious harm requiring professional medical attention;
4. Incidents involving a missing or unaccounted for youth participant; and
5. Illegal or unauthorized use of alcohol, drugs, or tobacco products.
The primary contact is responsible for documenting the covered activity’s response to all violations of Section 6.E and providing such documentation to the employee or unit designated by the chancellor to oversee this policy upon request.

K. Consequences for Violations of Policy

Violations of this policy may result in university action, which may include but is not limited to:
1. Covered activities: cancellation of the activity and/or restrictions on operating future covered activities.
2. Adults: disciplinary action, termination of employment, revocation of volunteer status, and prohibition from participation in future covered activities.
3. Youth participants: disciplinary action, dismissal from the covered activity, and prohibition from participation in future covered activities.
Any action that may constitute illegal conduct is subject to being reported to the appropriate law enforcement or regulatory authorities in accordance with university procedures or applicable law.

L. Third-Party Youth Activities

Universities shall require individuals, groups, or entities seeking to conduct third-party youth activities on property owned, rented, or managed by the university to execute a written contract that includes, at minimum, the provisions outlined in Appendix A whether or not funds are exchanged.
Failure to execute a contract or comply with these requirements may result in restrictions on or cancellation of the current activity and/or prohibition of future activities conducted by the third party or its agents.
Copies of executed third-party youth activity contracts shall be made available to the employee or unit designated by the chancellor with the authority and responsibility to oversee university compliance with this policy, or to other university offices responsible for contract management, review, or retention, as applicable.