This program details the guidelines that apply broadly to interactions between minors and GGU faculty, staff, students and volunteers in University-run or affiliated programs or activities whether on-campus or off-campus. When GGU schools or departments place students with external entities, or at external sites, students are obligated to comply with the external entity’s policies and procedures as well as all aspects of this program document.

The University’s Protection of Minors Program also follows the requirements mandated by the State of California Child Abuse and Neglect Reporting Act (CANRA).

Child Abuse and Neglect Reporting Act (CANRA) – The California Child Abuse and Neglect Reporting Act (CANRA) is a California mandate that was passed in 1980 to provide definitions and procedures for mandated reporting of child abuse. Over the years, numerous amendments have expanded the definition of child abuse and the persons required to report them. The purpose is to protect minors from abuse and neglect as well as from psychological harm.

Child Abuse – Includes any of the following:

• Physical Abuse- non-accidental injury which is intentionally inflicted upon a minor
• Sexual Abuse- any contact of a sexual nature that occurs between a minor and an adult. This includes any activity which is meant to arouse or gratify the sexual desires of the adult. Also called sexual molestation
• Emotional Abuse- mental or emotional injury to a minor that results in an observable and material impairment in the youth’s growth, development, or psychological functioning.
• Neglect- the failure to provide for a minor’s basic needs or the failure to protect the minor from harm
• Economic Exploitation-the deliberate misplacement, exploitation, or wrongful temporary or permanent use of a minor’s belongings or money without the consent of the parent or legal guardian of the minor.

Guardian – A guardian is a person lawfully invested with the power, and charged with the duty, of taking care of the person and managing their rights, who, for some peculiarity of status, or defect of age, understanding, or self-control, is considered in capable of administering their own affairs.

Mandated Reporter – Under CANRA, Mandated Reporters have a legal responsibility to report known or reasonably suspected child abuse or neglect.

Minor – A “minor” is a person who does not have the legal rights of an adult and is usually defined as someone who has not yet reached the age of majority. In California, and in most other states, a person reaches majority and acquires all of the rights and responsibilities of an adult when she or he turns 18 years of age.

Off-Campus (Remote) Interactions – Includes all contact that takes place between individuals that occurs electronically via the Internet to include all social-media platforms, or via other means of connectivity (i.e. telephone, cell phone, cable, etc.).

On-Campus (In-Person) Interactions – Includes all physical “in-person” interaction within all buildings, facilities and properties that are owned, operated, rented, leased, managed or controlled by Golden Gate University to include indoor and outdoor property and vehicles.

Parent – The term “parent” includes a legal guardian or other person standing in loco parent is (such as a grandparent or step-parent with whom the minor child lives, or a person who is legally responsible for the child’s welfare).

University Activities & Affiliated Programs – For the purposes of this program, these activities include: orientation programs; testing services; counseling services; student recruitment; student placements at internship or clinical sites; student teaching/field placement sites; and/or any other academic or non-academic credit-bearing activities that involve minors being physically present on-campus, or who are participating via an online format.

University Representative – This term includes all GGU employees (i.e. administrators, faculty, staff) whether full-time or part time, as well as all University Trustees, volunteers and students. And it includes any others who may be in a position to work, or interact, with minors for, or on behalf of, the University to include contractors and consultants. And the employees and representatives of non-GGU organizations and entities that conduct business on behalf of the University and engage with minors must also comply with this policy.

When participating in University run or affiliated programs involving minors, GGU faculty, staff, students, volunteers and third-party contractors must:

• Review these guidelines prior to engaging the minors in the planned program, event or activities. Adults on campus are expected to be role models for minors, and are expected to maintain the standards set forth in these guidelines.
• Ensure that minors are not left unsupervised when on-campus. It is the responsibility of those who bring minors onto campus to ensure appropriate supervision.
• Watch for signs of abuse or neglect and make an immediate report as required by this program.
• Before engaging in any University run or affiliated program or activity involving contact with minors, be thoroughly familiar with the guidelines and requirements of this program, and undergo a background check. the training and background check requirements of this policy.

Prior to participation in a University program involving minors, the program director/manager and applicable staff will be subject to a background check. And they are required to have a state sex-offender registry search. These checks are required to be completed every three years.

Retaliatory acts against members of the University Community who make good faith reports under this program and/or who cooperate in the investigation and handling of such reports, regardless of whether a violation has occurred, will not be tolerated. Any member of the University community who believes that he/she is the subject of retaliation or reprisal under this policy must contact the Human Resources Department. The University will promptly investigate all reports of alleged retaliation or reprisal.

“If you see something, say something”. Every member of the GGU community has an obligation to immediately report instances, or suspected instances, of abuse, inappropriate behavior or neglect. And Mandated Reporters are legally required by CANRA to comply with the reporting requirements detailed herein.

The CANRA identifies certain individuals as “Mandated Reporters”. These individuals have a duty to report known or suspected abuse or neglect relating to minors. Any University employee whose position is designated by the State as a Mandated Reporter must know what they are required to report, when it must be reported, and to whom. This is a partial list of mandated reporters:

• Teachers
• Instructional Aides
• Administrator or employee of an organization whose duties require direct contact and supervision of minors
• Social Workers
• Marriage, family and child therapist trainee or unlicensed intern.
• Physician, psychologist, intern, nurse, marriage, family and child counselor, clinical social worker, or other licensed health care professional.
• Employees and administrators of a postsecondary institution whose duties involve contact with minors on a regular basis.
• The supervisors of employees and administrators of a postsecondary institution whose duties involve contact with minors on a regular basis.

A Mandated Reporter must make the following reports when, in their professional capacity or within the scope of their employment, has knowledge of ,or observes, a person under the age of 18 years whom the Mandated Reporter knows or reasonably suspects has been the victim of child abuse of neglect.

• First Report – The Mandated Reporter shall make a verbal report immediately or as soon as practicable to any of the following: local law enforcement, child protective services, or county welfare departments.
• Second Report – The verbal report must be followed within 36-hours by a written report to the law enforcement, child protective agency, or welfare department that the initial report was made to and will be investigating the incident. Typically the reporting agency will ask you to complete and submit the State of California, Department of Justice, BCIA Form 8572, Suspected Child Abuse Report.
• Third Report – The Mandated Reporter must then make an internal report to either: their supervisor; Human Resources (HR); Student Services; or Business Services, Facilities and Administration (BSFA). This report can be made verbally or in writing, or anonymously via ETHICS POINT ( the GGU hotline). Supervisors who receive such reports must forward them immediately to Human Resources. This internal report is not a substitute for the external report identified above and as required under CANRA.

The University also requires all employees (without regard to Mandated Reporter status), as well as volunteers, students, and third-party contractors to immediately report in writing to HR or BSF, any known or suspected child abuse that occurs on-campus, or in any off- campus University owned or controlled property, or in conjunction with any University- related program or activity in a manner consistent with this program.

Under CANRA the following forms of abuse or neglect must be reported.

• Physical injury inflicted by other than accidental means.
• Sexual abuse, meaning sexual assault or sexual exploitation.
• Sexual exploitation, meaning depicting a minor in, or knowingly developing, duplicating, printing, downloading, streaming, accessing through any electronic or digital media, or exchanging, a film, photograph, videotape, video recording, negative, or slide in which a minor is engaged in an act of obscene sexual conduct.
• Neglect, meaning the negligent treatment, lack of treatment, or the maltreatment of a minor by a person responsible for the minor’s welfare under circumstances indicating harm or threatened harm to the minor’s health or welfare.

The abuse of a minor does not include “mutual affray” between minors (e.g. fighting)

As defined under CANRA, this means that it is objectively reasonable for a person to entertain a suspicion, based upon facts that could cause a reasonable person in a like- position to, drawing, when appropriate, on their training and experience, to suspect child abuse or neglect. “Reasonable suspicion” does. It require certainty that child abuse or neglect has occurred, or does it require a specific medical indication of child abuse or neglect, any “reasonable suspicion” will suffice.

The University is committed to the safety and protection of minors. This Code of Conduct applies to all GGU employees (full-time and part-time), student workers, volunteers, Trustees, alumni, and anyone else who represents GGU and who interacts with minors.

The conduct of those who are acting on behalf of GGU can inspire and motivate those with whom they interact, or can cause great harm if inappropriate. We must, at all times, be aware of the responsibilities that accompany these interaction. Specifically:

• We must be aware of our own and other’s vulnerability, especially when working alone with minors, and be particularly aware that we are responsible for maintaining physical, emotional, and sexual boundaries in such interactions. We must avoid any covert or overt sexual behaviors. This includes seductive speech or gestures as well as physical contact that exploits, abuses or harasses. We are required to provide safe environments for minors at all times while at or on any University owned, leased, rented, hired or controlled property, facility, or vehicle.
• We must show prudent discretion before touching another person, especially minors. And be aware of how physical touch will be perceived or received, and whether it would be an appropriate expression of greeting, care, concern, or celebration. Golden Gate University personnel are prohibited at all times from physically disciplining a minor.
• Physical contact with minors can be misconstrued both by the recipient and those who observe it, and should only occur when completely nonsexual and otherwise appropriate, and never in private. One-on-one meetings with a minor are best held in a public area; in a room where the interaction can be observed; or in a room with the door left open and another staff member or supervisor is notified about the meeting.
• We must intervene when there is evidence of, or there is reasonable cause to suspect, that a minor is being abused in any way. Suspected abuse or neglect by be reported immediately and as detailed in the “reporting” section of this policy.
• Individuals who interact with minors, either formally or informally, must refrain from the use or possession of alcohol, tobacco products (including marijuana) and illegal drugs when working around minors. Adults must never buy alcohol, drugs, tobacco products (including marijuana) and videos, or reading material that is inappropriate and give it to minors. And gifts must not be given to, or received from, minors without the knowledge of the applicable parent or guardian.
• Do not “friend” minors on social-media platforms, and do not participate in any online forums or groups with the minors with whom you interact unless it is for an academic program or requirement.
• Communication with minors by GGU personnel is only allowed for official University business. And for the protection of all concerned, the key safety concept that will be applied to these interactions is transparency. The following steps will reduce the risk of private or otherwise inappropriate communications:

  • Communication between GGU personnel (includes employees, students and volunteers) and minors that is outside of the role of professional or volunteer relationship (i.e. teacher, host, coach, etc.) is strictly prohibited.

  • Where possible, email exchanges between a minor and a person acting on behalf of the University are to be made using the GGU.edu email address.

  • Communications (emails) between a University representative and a minor must also include a “copy” to the parent/guardian.

  • Electronic communication that takes place over a GGU network or platform may be subject to periodic monitoring.

  • Those who use text messaging, or any form of online communications including social media (Facebook, Twitter, etc.) to communicate with minors may only do so for official GGU business activities.

  • Do not tell a minor that the communication is “just between the two of us” or use similar language that encourages minors to keep the secrets of their parent/guardian.

  • If the minor makes an inappropriate comment towards a University representative, or another minor, it must be reported immediately to the Dean of Student or Human Resources as soon as possible with notice to the minor’s parent/guardian.

• If you are ever unsure about what is appropriate, seek advice from HR, Student Services or BSFA, and always err on the side of caution.

The Protection of Minors program is designed to protect this vulnerable group of individuals, and to better enhance their experiences when participating in University programs or when interacting with University representatives.

Questions or comments about the program should be directed to the Chief Human Resources Officer, the Dean of Students or to the Executive Director of Business Services, Facilities & Administration.