Protection of Minors and Vulnerable Adults in RISD Programs

Rhode Island School of Design (RISD) has a variety of events, activities, and programs that involve Minors. The safety of Minors involved in RISD programs is of the utmost importance to the college and in order to provide a safe, fun and productive environment, this policy is adopted to govern these experiences, whether they are sponsored by RISD or a third party. It is important to note that department-specific procedures exist for all programs and are in accordance with this policy. For procedural questions, please contact the appropriate department.

This policy applies to interactions between Minors and RISD students, faculty, staff and volunteers in RISD-run or RISD-affiliated programs or activities, regardless of location. All RISD students, faculty, and staff are responsible for understanding and complying with this policy. Every member of the college community has an obligation to immediately report instances or suspected instances of the abuse of or inappropriate interactions with Minors. Appendices to this policy set forth specific requirements and procedures and may be updated from time to time.

RISD is dedicated to the welfare and safety of all persons who participate in college-sponsored events. The majority of Minors take part in programs through the RISD Museum, Continuing Education and Project Open Door; however, there are also opportunities for third parties to run programs and camps with Minor participants on campus and under the authority and direction of the college at other locations. All staff, faculty, volunteers, student employees, and independent contractors who may interact with Minors on campus are governed by this policy. This reporting obligation also extends to information about suspected abuse, neglect, or inadequate care provided by a parent, guardian, or custodian/caretaker. Any Responsible Adult who violates this policy will be held accountable, personally and professionally, without exception and regardless of their status at RISD.

Please follow this link to access the Protection of Minors and Vulnerable Adults Policy Reporting Form.

Background checks will be completed on all employees, student employees and volunteers in positions with the possibility of care, supervision, guidance or control of minors. Click here for more information on RISD’s background screening policy.

Abuse or Neglect of Minors –means infliction of physical or mental injury, sexual abuse or exploitation, and/or negligent treatment or maltreatment of a person under age eighteen (18). Sexual abuse includes engaging in, or attempting to engage in, 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 make reasonable efforts to prevent the infliction of abuse upon a person under the age of eighteen (18).

Bullying -- for purposes of this policy, bullying shall mean the repeated use by one or more persons of written, verbal, or electronic expression, or a physical act or gesture, or any combination thereof, directed at a target perceived as vulnerable that:

1. causes physical or emotional harm
2. places the target in reasonable fear or harm to themself
3. creates a hostile environment for the target
4. infringes on the rights of the target while participating; or
5. materially and substantially disrupts the process or orderly operation of the Program.

Campus- means all buildings, facilities, and properties that are owned, operated, managed, or controlled by RISD.

DCYF – Department of Children, Youth and Families for Rhode Island. The Child Abuse hotline operates 24/7 and can be reached at https://dcyf.ri.gov/contact-us/report-child-abuse-or-neglect or by calling the state hotline at 1-800-RI-Child (1-800-742-4453).

Minor – all persons under the age of eighteen (18) who are involved in RISD programs but are not enrolled in a degree program at RISD, or employed by the College.

Program – any RISD-sponsored event or activity regardless of location, in-person or virtually, offered by an academic, administrative, or recognized student organization of RISD or RISD affiliated programs. This excludes programs for RISD enrolled students under the age of eighteen (18).

Program Director – anyone in a supervisory role associated with the organized event or activity offered by an academic, administrative, or recognized student organization of RISD or RISD-affiliated programs.

Responsible Adult – all persons working, volunteering, or acting on behalf of, or as a representative of RISD including without limitation: staff, faculty, students, student employees, temporary employees, casual employees, volunteers, docents, and vendors who participate in:

● Programs where the individual may have one-on-one contact with a Minor, or contact with a group of Minors without another adult present, in a non-public setting; or

● Programs that have a residential component and the individual has access to the residence(s); or

● Programs that involve physical contact and/or disrobing; or

● any athletics club or organization.

Vulnerable Adult - a person who (1) is admitted to a mental health facility or to a community-based or residential facility, or (2) is a resident of a long-term care facility, or (3) has a developmental disability, is incapacitated, or who has the functional, mental, or physical inability to care for themselves.

Title IX – a federal law that protects individuals from sex discrimination in educational programs and activities at institutions that receive federal financial assistance.

Any known or suspected case of abuse or neglect of a minor must be reported.
Any incident of a RISD community member (working, studying or volunteering at RISD) violating this policy, committing sexual harassment or engaging in sexual activity with a minor must be reported to your supervisor immediately; the supervisor is then required to report it to Public Safety within 24 hours. (Note: employees may bring the report directly to Public Safety; any complaints towards employees will be shared with HR, any complains toward students will go to their department head instead of Human Resources.)

Any known or suspected cases of abuse or neglect by a minor’s caregiver must also be immediately reported to a supervisor who is required to report it to Public Safety within 24 hours. Public Safety will ensure that DCYF is notified. (Note: employees may call DCYF directly, however, they must still notify Public Safety.)

Reporting Procedure Regarding a RISD community member
These complaints can be reported verbally to a supervisor or Public Safety, but a “Protection of Minors Reporting Form” must also be completed and submitted to Public Safety for record and review. This form will be shared with the Office of Equity & Compliance and Risk Manager. RISD will conduct an inquiry, as appropriate under the circumstances.

Reporting Procedure for any Incident Involving a Caregiver
These complaints can be reported verbally to supervisor or Public Safety, but a “Protection of Minors Reporting Form” must also be completed and submitted to Public Safety for record and review. This form will be shared with the Office of Equity & Compliance and Risk Manager. RISD will conduct an inquiry, as appropriate under the circumstances and all instances will be reported to DCYF.

Assessment, Investigation, and Resolution
The college will address all reports of suspected abuse, neglect or policy violations. In all instances, the College will—at a minimum—conduct an initial assessment of the report. The initial assessment will include a determination of any immediate, emergency, and/or interim steps that should be taken to reduce the risk of harm to individuals or to the campus community pending final resolution of the matter. The safety and well-being of the affected Minor(s) or Vulnerable Adults will be given priority when determining any such interim steps.

If a report contains allegations that would constitute abuse or neglect by a caregiver, the college will refer the matter to law enforcement.

If a report contains violations of this policy, the college will determine the appropriate investigative division to lead a review of the matter, utilizing the policies and protocols relevant to investigations of misconduct. These divisions include Equity & Compliance and the Office of Human Resources. Depending on the nature of the report and the circumstances involved, these Offices may conduct joint investigations. Unless appropriate College personnel are specifically instructed otherwise by law enforcement, the College will conduct its assessment and review regardless of whether a criminal investigation is also pending. In the event that the College is directed by law enforcement not to pursue an internal investigation, the College will continue to fully cooperate with the law enforcement investigation.

Retaliation is Prohibited
It is the policy of the college that retaliation against anyone making a good faith report of suspected abuse or neglect is strictly prohibited.

Anonymous Reporting
Individuals who wish to remain anonymous are encouraged to utilize the college’s confidential EthicsPoint hotline. A report can be filed in two ways: 1) through the RISD/EthicsPoint web page hosted on an EthicsPoint secure server: http://www.risd.ethicspoint.com; or (2) dial the toll‐free EthicsPoint phone number 1‐866‐877‐5386. Phone lines are open 24/7 and multi-language operators are available. Please also refer to RISD’s Whistleblower Policy for additional information.

Failure to Report
Employees who fail to notify their supervisor or report directly to the appropriate RISD Office (HR or Public Safety as outlined in the procedure above) is considered a violation of this policy and may be subject to corrective action in accordance with RISD’s Corrective Action Process up to, and including, termination of employment.

Behavioral Expectations
Adults should be positive role models for Minors, acting in a caring, honest, respectful, and responsible manner that is consistent with the mission and guiding principles of the college. Any failure to fulfill these obligations will have personal and professional consequences for those involved. Adults are expected to avoid behaviors and situations that could cause harm or be misinterpreted and are cautioned as follows:

● Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually prurient material (or assist in any way to provide access to such material) with Minors. This does not include material or discussion that is appropriately related to course subject matter or curriculum pursuant to RISD’s policies on academic freedom.

● Adults should not be alone with a single Minor unless it is essential to the activities of the program or activity (e.g., private lessons). If there is a situation that requires confidentiality, one-on-one interactions should be conducted in an observable space.

● Do not meet with Minors outside of established times for Program activities or employment responsibilities. Any exceptions require written parental authorization and must include more than one adult from the college.

● Adults will not invite Minors to their home. Any exceptions require authorization by the Program Director and written authorization by a parent/guardian.

● Do not engage Minors or allow Minors to engage you in romantic or sexual conversations, or conversations about personal romantic or sexual issues or situations, unless required in the professional staff member’s role.

● Do not engage or communicate with Minors through email, text messages, social networking websites, internet chat rooms, or other forms of social media at any time except and unless there is an educational or programmatic purpose. At all times, the content of the communication must be consistent with the mission of the Program and the college such as administrative information (i.e. housing assignments and move-in information).

● Do not touch Minors in a manner that a reasonable person could interpret as inappropriate.

● Do not tell or use language that encourages Minors to keep secrets from their parent/guardian.

● Do not engage in any abusive conduct of any kind toward, or in the presence of, a Minor, including but not limited to verbal abuse, striking, hitting, punching, poking, or spanking. Restraint is acceptable only if, and only to the extent that is necessary, to protect a Minor or others from harm. Such incidents must be documented and disclosed to Public Safety within 24 hours after the incident.

● Do not use, possess or be under the influence of alcohol or illegal drugs while on duty or when responsible for a Minor's welfare.

Extenuating Circumstances
Any Minor visiting or studying at RISD who is not picked up at the appropriate time will be brought to Public Safety where they will await pick up by a parent/guardian. Children in the workplace must always be under the direct supervision of their parent or guardian. Additional information can be found in RISD’s Children in the Workplace Policy.

Virtual Programming Guidelines

Students engaged in remote learning are expected to abide by RISD’s Code of Student Conduct and Academic Code of Conduct.

● Virtual programming is not offered to children under ten (10) years of age, unless a parent or guardian is present for the full Program.

● Employees and participants may not share ZOOM link/sign in information with anyone not connected to the class.

● Employees are not to share any program participant’s contact information with other participants before, during, or after the program dates.

● Unless the session is pre-recorded or openly accessible at any time by administration, faculty, staff, students and volunteers are never allowed to be alone in virtual spaces with Minor or Vulnerable Adult participants in a Program. This includes small group or break-out sessions.

Disability Considerations
Rhode Island School of Design attempts to make its classes, programs, events, and services accessible by providing reasonable and appropriate accommodations. If you need accommodations to participate in any class, program, or event offered by RISD, please contact the Office of Disability Support Services at disabilitysupportservices@risd.edu. Requests for accommodations should be made at the time of registration.

Reporting Allegations of Sexual Misconduct
At RISD, the Office of Equity & Compliance is responsible for overseeing the resolution of complaints and addressing issues of gender-based discrimination and sexual misconduct. Contact information for the Title IX Coordinator, Deputy Coordinators, and other Equity & Compliance support staff can be found here. Their responsibilities include tracking and monitoring incidents including sex discrimination and sexual misconduct, ensuring that RISD responds effectively to each complaint, and, where appropriate, conducting investigations of particular situations. The Equity & Compliance support staff is knowledgeable about and will provide information on all options for complaint resolution.

When Should I Contact Equity & Compliance Support Staff?
Contact a Title IX Coordinator if you:

• think you may have encountered sex discrimination or sexual misconduct and wish to understand your options;
• learn of a situation that you feel may warrant a college investigation;
• need help on how to handle a situation by which you are indirectly affected;
• seek guidance on possible informal remedies or administrative measures to de-escalate or alleviate a difficult situation;
• have any other questions about RISD’s Title IX and sexual misconduct policies and procedures.
  
  Support staff can also facilitate a formal or informal complaint through Public Safety, located at 30 Waterman Street, Providence, Rhode Island 02912

Privacy and Process
Conversations with Equity & Compliance and other Title IX support staff are kept as private as possible, but information about incidents of sexual misconduct must be shared with relevant administrators if the college needs to act for reasons of broader campus safety. In all cases, the wishes of the person initiating the conversation are given full consideration. The investigation process involves interviewing the parties involved and any witnesses and also gathering documentary or other evidence. In cases involving alleged criminal conduct, Public Safety will assist a complainant in making a criminal complaint if the individual wishes, and any criminal complaint will be forwarded to local law enforcement. A complainant need not pursue a criminal complaint in order to seek to hold the respondent responsible through the Code of Student Conduct or Employment process. As soon as possible, the complainant and the accused will be offered appropriate assistance from one or more of the following areas: Counseling Center, Day One (off campus advocacy center), Health Services, Residence Life (if a move is required), the Employee Assistance Program, and Academic Affairs (if course adjustments are required).

Other resources are available on the Equity & Compliance website.

This policy was approved as of: November 2015.

This policy was last reviewed/modified on: 4/11/24

Next scheduled review: Biennially in November or as required by law.

Issuing Office

Office of Risk and Emergency Management

Responsible Officer

Vice President of Campus Services

Individuals/offices required for review and changes

Director of Risk and Emergency Management

Director of Residence Life

Executive Director, Equity & Compliance

Director, Employment

Director, Office of Public Safety

Office of the General Counsel