The Programs Involving Children (PIC) policy was the result of an internal procedures review in 2012, during which former IU President Michael A. McRobbie declared the safety of children on campus “must be our highest priority.”
The PIC policy was created to ensure the overall protection and safety of children involved in Indiana University programs through the use of:
a mandate for program-specific guidelines
an emphasis on the legal duty to report suspected child abuse and neglect
IU Public Safety has created resources for departments and programs to use to increase understanding and implementation of the university's policy on programs involving children.
General PIC training course
The Programs Involving Children general training course was created by IU’s Public Safety staff and the University Compliance Office to provide a quick way to familiarize yourself with PIC and what is required to comply with this important policy.
Training course on child abuse recognition, reporting, and prevention
In light of IU’s COVID-19 social distancing policy, PIC offers the following training for recognizing child abuse in an online format. (Note: Online programs still need to follow the PIC policy regarding background checks and program registration.
For the near future, visitors to IU who have not, or cannot, be vaccinated should continue to mask indoors and practice physical distancing. The Centers for Disease Control and Prevention (CDC) and the Indiana Department of Health allow for distancing as short as three feet for children (preschool, K-12), as long as everyone is masked and facing the same direction (i.e., classroom-type setting). Any adult caregivers/instructors should be strongly encouraged to be fully vaccinated prior to working with children. Protocols like creating “cohorts” can limit the interaction and potential exposures to others.
PIC recommends all youth programming continue to follow CDC guidance for camps, schools, and childcare.
State and federal sex and violent offender registries
Zachary’s Law in Indiana requires sheriff departments to jointly establish and maintain the Indiana Sex and Violent Offender Registry to provide detailed information about individuals who register as sex or violent offenders at Indiana sheriff departments (or, in Marion County, at the Indianapolis Metropolitan Police Department).
The purpose of the registry is to inform the general public about the identity, location, and appearance of sex and violent offenders who live, work, or study in Indiana.
The Dru Sjodin National Sex Offender Public Website (NSOPW), established by the federal Adam Walsh Child Protection and Safety Act, provides information to the public on the location of registered sex offenders regardless of state boundaries.
Find answers to frequently asked questions about programs involving children at IU.
Program administration and compliance
Everyone, whether associated with a program or not, has the duty to report suspected abuse or neglect of a minor to the Indiana Department of Child Services (1-800-800-5556), local law enforcement (911), and to the Indiana University Police Department.
Anyone associated with the program who works with children must have a background check at least every five years (including staff, temporary/hourly employees, students, academic, faculty, and volunteers).
Someone from your department must complete the online registration form to provide information about the program. This must be done at least 14 days prior to the start of a new program. The form can be found by searching "Programs Involving Children" in One.iu.edu. It is important that program information be re-entered or updated annually when aspects of the program change.
Academic and administrative supervisors, such as deans, directors, and vice presidents, are responsible for ensuring that the programs in their areas are in compliance with the policy. IU Public Safety will work with Internal Audit to review compliance with the policy.
A child, or minor, is anyone under 18.
Although those students are minors, this policy is concerned with programs designed to include children through high school, not with regular IU classes or activities for enrolled students.
However, the duty to report suspected abuse or neglect is applicable for every person under 18, including IU students.
No. State law requires that you inform either the Indiana Department of Child Services (1-800-800-5556) or local law enforcement (911), which includes the IU Police Department.
At Indiana University, you must also inform the University Superintendent of Public Safety, who is the designated agent under state law.
While it is not necessary to background check every individual who may have incidental contact with the minor, primary supervisors/mentors of the minor and any individual that will have close contact with the minor must undergo a background check.
The best contact for specific policy questions is firstname.lastname@example.org.
Anyone with access to One.iu.edu can register a program. Events should have the names of supervisors and/or the head of the program listed.
Student-led programs can be registered by a student but an IU faculty or staff member should be listed as a point of contact.
For external programs, at least one IU personnel should be listed as a point of contact.
The IU department/unit working with the external organization is responsible for entering all the necessary information and registering the program/event.
All students have access to the “Record of Programs Involving Children” registry, which can be located by searching "Programs Involving Children" in One.iu.edu.
Please see the background checks page to learn more about the background check process and the designated IU vendors. If you have questions regarding which vendor to use please email IU Public Safety at email@example.com.
Types of programs and events
These are events that are not specifically intended for children/minors and are open to attendance by individuals of any age from the general public.
Examples of such events include single performances, varsity athletic competitions, plays, concerts, community-wide volunteer events, races, and competitions.
The important thing to remember is that it is not always the content of the event that matters, For instance a children’s play in the IU Auditorium that is open to the general public would not automatically be considered a program involving children.
However, it is possible for certain aspects of events to be directed toward children even though the event as a whole is not. An example is a large IU tailgating event that includes a face painting station for children. In this case, the face painting station would need to comply with the PIC policy, but the tailgating event as a whole would not.
The same rules for programs apply to tours and recruiting efforts. If a tour is targeted toward children or the recruitment is for high school students and/or incoming IU students, any individual working with minors must have a background check prior to the activity.
Yes. All three of these activities are included in the policy and must comply with the policy requirements if the activity is directed toward or involves children.
A written agreement must be entered into with the third-party (external) organization. Most campuses have a standard facility use agreement template that should be used and a designated campus official identified to sign those agreements. If your IU organization is not already using a facility use agreement or you have questions regarding the facility use agreement, including who may sign, you must contact the Office of the Vice President and General Counsel.
The facility use agreement or any other agreement should include the following language: "Licensee acknowledges that the University has adopted a policy entitled Programs Involving Children (“Policy”) (copy must be attached) and that compliance with this Policy is an express condition of this Agreement. By executing this Agreement, Licensee is confirming that it has read and understands the Policy and that it accepts compliance with the Policy as an express condition of this Agreement. Additional resources and information concerning this Policy may be found at PIC Policy."
Any leases or agreements to use IU facilities must include a clause requiring compliance with this policy. Please see above for information on facility use agreements.
For external organizations already operating under a current lease, the Office of the Vice President and General Counsel has suggested language about providing the policy and having the organization sign off on compliance. Please contact the Office of the Vice President and General Counsel whenever a facility use agreement is required.
It is not expected that your department/unit will “police” or control the external organization to ensure compliance. The organization has signed a written agreement promising to do so. However if you become aware of a clear policy violation you should contact IU Public Safety at firstname.lastname@example.org immediately.
If the program or event is happening on IU property, full compliance with the policy is required. This can be achieved by the IU component of the program ensuring complete compliance for its personnel and the external organization formally, in writing, agreeing to comply with the policy.
If the program or event will take place off of IU property, then the IU component should determine what policies the external organization has in place and follow those guidelines. If there is no policy in place, the IU component should ensure that its personnel have complied with the PIC policy in full.
Please contact IU Public Safety at email@example.com for assistance in reviewing responsibilities in a joint program.
The IU department/unit working with the outside organization is responsible for entering all the necessary information and registering the program/event.
Indiana University’s policy states: “The IU unit shall ascertain whether the external entity has its own policy, and if so, the parties shall work cooperatively to decide which policy should apply to the particular event.”
For events/programs that are not hosted by IU, the preference of the Office of the Vice President and General Counsel is to have the external organization’s policies on working with children apply if they have them.
If the external organization does not have any policies regarding background checks, then the IU unit can follow IU background check procedures or inform the external organization that IU is not responsible for any background checks or verification of students participating in that program.
That decision should be based on the particular program and situation (i.e., how many students, how many times are they participating, on what basis -- a class/credit requirement, what is the nature of the event, what is the expectation of the unit and the organization, etc.). Most importantly, there should be documentation of the discussion that could be referenced in the future. If the organization is taking the students because they are from IU, the organization should be aware of the background check status of the IU students.