Some programs involving children are events or activities that involve a large number of volunteers and/or occur only once or infrequently, and it may not be feasible or necessary to obtain background checks on all volunteers involved.
The PIC policy allows such programs to conduct background checks on a subset of volunteers and to adopt other measures and safeguards to protect children.
You must first receive approval from IU Public Safety to have your program classified as “large, discrete, occasional.”
Even if your program type is listed as a possible example to qualify for a “large, occasional” event or performance in the policy (e.g., Science Olympiads, children’s reading/activity days), you must still obtain approval to operate your event under these guidelines. To request approval for your program to be classifield as a “large, occasional” event or performance you must:
IU Public Safety will respond indicating if your program qualifies or not.
Programs that IU Public Safety has approved to operate as “large, occasional” events or performances may be able to implement certain measures and safeguards in lieu of conducting background checks on all volunteers. The policy requirements below must be followed:
Due to the nature of research and the comingling of resources, it is often difficult to determine which entity has oversight for the activity.
Principle Investigators (PIs) may have dual roles with IU and another location (i.e., IU Health), or may share responsibility with another institution (co-PIs). In these situations, it is the IU PI’s responsibility to ensure all IU employees, students, and volunteers working with children have complied with the background check requirements of the PIC policy.
IU-funded research involving children under the control of IU, including research taking place at a third-party location, must comply with the requirements of the PIC policy. This includes background checks and the development of program guidelines, however program registration is not required if the research is governed and approved by the Institutional Review Board.
The program-specific guidelines should be tailored to address risks associated with your program/event, and you should consider consulting with your department/unit on specific topics that need to be addressed.
If your research has an Institutional Review Board’s approval, you do not need to register it in the PIC database.
Any person involved in a program operating under the control of IU and working with children—including employees, volunteers, students, residents, and fellows—must comply with the background check requirement in the PIC policy.
Working with children would include any activity where contact with children is made, including but not limited to, in-person contact and contact by phone, email, or online. If you have access to any personally identifiable information, this also falls under “working with children.”
External entities using IU space or occurring on IU property should sign a Facility Use Agreement. This agreement must include the requirement to comply with the PIC policy and provide the policy website for reference.
In this type of situation, it is the IU principle investigator’s (PI’s) responsibility to ensure all Indiana University employees, volunteers, students, residents, and fellows working with children have complied with the background check requirement for all research activities funded through IU but taking place at a third-party location.
Service learning allows students the opportunity to apply knowledge or skills they learn in the classroom to serve a community need. This may involve placement in an organization that serves minors. If the organization serves minors, then the PIC policy may apply.
Service learning that takes place on IU property must comply with the PIC policy requirements. If a service learning activity takes place off of IU property, the IU department/unit involved should determine what policies the external organization has in place regarding working with children and background checks. When the external organization has policies in place that address children and background checks, the organization’s guidelines should be followed. If it is determined policies are not in place at the external organization, the IU department/unit should ensure all IU employees, students, and volunteers have complied in full with the PIC policy, and the organization should be made aware of this compliance.
The IU department/unit should be transparent and notify the external entity that a student may not have been screened or background checked prior to participating in the program. This decision should be based on the specific program/event and situation, and discussion of it should also be documented and preserved for future reference.
Internships give high school students the opportunity to gain experience throughout all of Indiana University. Internships are not required to be registered as PIC programs. However, internships do need to follow the other requirements of the PIC policy. The supervisor(s) of the intern are required to have a background check through HireRight within the last five years which meets PIC standards. Program-specific guidelines should be established related to the intern’s activities, and the internship should always be conducted in accordance with the participating school corporation’s expectations and standards.
Any person, whether associated with a PIC program, research, service learning, or an internship, who suspects child abuse or neglect must report this information to the Department of Child Services (DCS), to their local law enforcement, or to the IU Police Department. A report of the suspected abuse or neglect must also be made to the Superintendent of Public Safety. The duty to report must be addressed in program-specific guidelines, and communicated to those who will be working directly with the intern.
Any questions related to the PIC policy or the types of programs/events listed above should be sent to IU Public Safety at iupic@iu.edu.
