Overview
This page offers guidance on implementing University requirements in youth program settings that involve partnerships where responsibilities are shared between a UW youth program and a non-UW external partner organization.
Responsibility of UW Youth Programs
A UW led youth program must fully meet or exceed University youth safety requirements, including those responsibilities delegated to a third party partner. When responsibilities are delegated or transferred to a third party, equivalent safeguards are expected to be in place and the UW youth program is responsible for communicating these expectations to the third party. In some cases, a level of compliance monitoring is also necessary. Note: below statements such as “UW is responsible for…” refer to the UW youth program.
Types of partnerships
There are endless ways in which UW may partner with a third party. This guidance will address those scenarios in which the non-UW partner is providing a service on our behalf. Common examples include:
- UW asks a third party individual or organization to provide
- a workshop for youth participants or facilitate an activity;
- perform an assessment on youth; or
- any other type of service that is part of the youth program’s scope of services.
- UW may sub-contract with an individual or external organization to perform a set of activities, typically based on an agreed upon scope of work.
- In some cases, such as for large grants, sub-awards to an external organization may be processed through the Office of Sponsored Programs.
Keep in mind this is not an exhaustive list of partnership types. Contact OYPC for any additional questions or support.
Importance of written agreements
When the University is asking the non-UW partner to perform duties on our behalf, it is crucial to ensure that all parties have a clear shared understanding of roles, responsibilities, and expectations. Written agreements can serve as a record of this shared agreement. Written agreements will vary in the level of formality depending on the extensive nature of the partnership and the program.
Components of written agreements:
- At minimum, clarify roles and responsibilities between the organizations, regarding the interactions with youth;
- Descriptions of activities that will be carried out by UW and respective partner organizations;
- Statement of expectations of organizations and associated personnel youth for safety and custodial care, e.g., UW requirements being conferred upon the partner organization;
- Formal agreements may additionally need to include:
- A scope of work, e.g., for a grant subrecipient.
- Indemnification language addressing liability and insurance coverage.
University requirements
This section will outline specific partnership considerations for UW youth program within Administrative Policy Statement 10.13 Requirements for University and Third Party led Youth Programs.
Policy requirement: UW youth programs must be entered into the UW Youth Program Registration System (YPRS) prior to the start of the program. Third party youth programs must be registered in the YPRS by the hosting department or unit prior to the program start date.
Partner considerations
- UW programs working in partnership with external partners should register all activities in YPRS. External partners do not have access to YPRS and should therefore be reflected within the UW program’s registration.
- Any activities that take place as part of the partnership should be included. You may wish to register distinct activities as different ‘sessions’ under your registered program umbrella, as a way to differentiate among activities led by your program or the external partner.
- Authorized personnel from a non-UW entity may be reflected in YPRS, or may be otherwise managed, depending on agreements between UW and the non-UW organization.
| Policy requirements | Partner considerations |
| UW and third party youth programs must be entered into YPRS prior to the start of the program | Have all partnership activities involving youth been included in the YPRS registration?
See the Authorized Personnel section for considerations regarding who among the UW and external program teams should be listed in YPRS as ‘authorized personnel.’ |
| Certification of agreement by third party to ‘meet or exceed’ UW youth safety requirements | A UW youth program registering a program in YPRS must attest to meeting requirements of APS 10.13. This also includes the responsibility of the external partner to ‘meet or exceed’ UW’s youth safety requirements. In order to effectively attest to this you should have a written agreement in place. |
Policy requirement: Youth programs must designate and screen Authorized Personnel in accordance with the definition.
General Partner considerations:
- There may be shared responsibilities between UW and a third party partner whereby a combination of UW and partner personnel may have unsupervised interactions with youth. It is the responsibility of UW to ensure that all parties have a shared understanding of and commitment to fulfill prerequisite screening requirements set by UW.
- If a UW program fully transfers the responsibilities of Authorized Personnel to a third party, there should be a written agreement in place which articulates UW’s standards for screening, training and conduct.
| Policy requirements | Partner considerations |
| Determine which personnel should be designated as authorized personnel versus other personnel | Has either the UW or the third party partner designated which personnel will have supervisory, chaperoning, or caregiving responsibilities over youth, or who will have other close contact with youth?
The UW Youth Program should maintain a list of all personnel involved in your UW youth program. Employees and volunteers of partner organizations may be excluded from the YPRS list of authorized personnel if there are written agreements in place that communicate requirements for equivalent screening, training, and conduct expectations of these employees/volunteers to the partner organization. In some instances it may be more effective to have an individual or small group of people go through UW’s screening process. |
| Communicate differentiated roles and responsibilities clearly between authorized personnel and other personnel | Do both the UW and the third party partner personnel understand their roles and responsibilities — and any limits on their involvement with youth — and those of the rest of their team? |
| All authorized personnel have a valid, current background check completed and on file with UWHR before beginning to engage with youth | Do personnel with responsibility for youth undergo a background check including UW equivalent criteria, e.g., local and federal crimes search and national sex offender registry check?
If the responsibility for background screening employees or volunteers is transferred to the partner organization via a written agreement, UWHR will not run a background check and will not maintain those records. |
| Strategies in place to prevent other (non-authorized) personnel from being alone with youth | How is UW ensuring the equivalent controls are in place if a third party handles the interactions and environments? |
Requirement: Youth programs must sufficiently train all personnel to provide safe and developmentally appropriate program services.
General Partner considerations:
- There may be shared training responsibilities between UW and a third party partner for personnel interacting with youth. It is the responsibility of UW to confirm that all parties are trained as specified by UW.
- If a UW youth program fully transfers training responsibilities to a third party, there should be a written agreement in place that articulates UW’s minimum expectations for personnel training.
| Policy requirements | Partner considerations |
| All Authorized Personnel have completed both the Reporting Suspected Child Abuse and Neglect and the Promoting Safe Interactions with Youth trainings | Have UW and third party personnel with responsibility for youth been trained to safely interact with youth, and to respond if they suspect abuse or neglect? UW youth program personnel must take UW trainings. Third party personnel may be trained by their organization with equivalent content. |
| Clear position descriptions and duties articulate what skills and knowledge are necessary for staff to successfully execute their responsibilities | Whether the UW or the partner organization are responsible for personnel, it is vital that staff are informed about their job duties and skills. UW should assess whether external organizations set reasonable criteria for hiring personnel working on behalf of UW youth programs. |
| Pre-service training and onboarding correlates to and adequately develops skills and knowledge required by position descriptions | Whether UW or the partner organization are responsible for personnel, it is vital that staff are trained adequately and by the appropriate entity. UW should confirm that external personnel working in UW programs are trained adequately. |
| Pre-service training tracking system (i.e., training checklist) in place to ensure all employees and volunteers complete all required training and onboarding activities | This tracking system may be maintained by the UW or the partner organization, or both; the important thing is that all personnel are trained and completion of required training is documented and verified by program leadership. |
Requirement: University youth program personnel must acknowledge in writing (electronically or on paper) that they agree to abide by the University Standards for Interacting with Youth at all times during the course of fulfilling their duties with the youth program. Departments should keep records of such acknowledgments per University records retention requirements.
General Partner considerations:
- The University Standards for Interacting with Youth or equivalent conduct standards must be followed by third party programs that play a role in a UW youth program.
- UW should include these standards in a written agreement with external partners. If external partners have their own standards for interactions with youth, UW should assess whether it covers all University standards, and discuss how the external partner will address any differences to meet UW’s standards.
| Policy requirements | Partner considerations |
| All authorized personnel have acknowledged in writing that they reviewed and agree to abide by the Standards for Interacting with Youth | Have UW and third party personnel with responsibility for youth signed a conduct code? UW personnel must sign the UW’s Standards for Interacting with Youth. Third party personnel may agree to and abide by their organization’s conduct standards.
Third party conduct requirements should be equivalent to UW’s standards. It is the responsibility of the UW to assess equivalency and discuss how the external partner will address any differences to meet UW’s standards. |
| Conduct expectations are reiterated (e.g., through training, discussion, staff handbook, performance reviews) to personnel to further their understanding of how the Standards for Interacting with Youth may be applied in your youth program. | If the partner organization is responsible for conduct expectations, are that organization’s conduct expectations reiterated to and enforced with staff?
It is the responsibility of the UW to assess equivalency and discuss how the external partner will bolster understanding of conduct expectations. |
| Supervision and monitoring of staff interactions are in place to ensure staff abide by the Standards for Interacting with Youth | Are staff supervised or monitored, either by UW program staff or by the partner organization? Adequate supervision of those working with youth is vital, regardless of the setting and responsible entity.
It is the responsibility of the UW to initiate a conversation to ensure adequate supervision takes place. |
Requirement: If a youth program representative becomes aware of behaviors of concern that represent clear violations of the University Standards for Interacting with Youth, they must notify SafeCampus within 48 hours.
General Partner considerations:
- Any behavior of concern involving a University led youth program must be reported to SafeCampus, regardless of setting or location.
- UW should communicate these expectations to external partners and jointly develop a plan for reporting conduct violations.
| Policy requirements | Partner considerations |
| Supports are in place to educate, encourage and facilitate reporting of behaviors of concern (e.g., supervisors are available for consultation; educational materials from OYPC are shared with staff) | As applicable, third party personnel should be aware of requirements to report behaviors of concern to the proper recipient in the given setting.
Regardless of the setting, reporting should be supported and encouraged, and barriers should be mitigated. |
| Barriers to reporting are removed/mitigated | UW should confirm with an external partner the method and expected timeframe that reporting a behavior of concern will be communicated to UW. |
Requirement: Youth programs must adhere to state and federal workplace and environmental safety regulations and protect the health and safety of youth while in our care.
General Partner considerations:
- Relevant environmental hazards, and prevention and response plans, should be discussed with external partners as part of a joint planning process.
| Policy requirements | Partner considerations |
| Environmental hazards have been assessed prior to program start and hazards/risks have been mitigated in program design | Hazards in all environments where youth will be present should be assessed and mitigated. This responsibility may be co-owned by both partnering organizations, or may be the responsibility of one or the other entity. This should be clearly outlined in written agreements. |
| Personnel are trained in mitigation and response steps in response to hazards/risks | Personnel responsible for youth should be trained in the hazard mitigation steps unique to the environments where they will work with youth. |
Requirement: Specifically, youth programs must follow University guidance for Youth in STEAM Environments when hosting youth in labs, shops, makerspaces or other facilities with certain hazards present.
| Policy requirements | Partner considerations |
| Best practice guidelines and hazard reduction strategies as outlined in EHS guidance are followed by youth programs in STEAM environments (N/A for non-STEAM environments) | This document is specific to the University of Washington-based STEAM environments. State and federal safety regulations also apply to non-UW environments. Confer with a partnering organization hosting youth to discuss applicable hazards and ensure that they are following state and federal regulations for such environments. |
Requirement: Youth programs must have an emergency preparedness plan in place in the case of a natural disaster, active shooter, or other emergencies as well as maintain everyday safeguards to minimize safety risks and protect youth in their programs. Youth programs must be included in their department/unit’s fire safety and evacuation plan.
General Partner considerations:
- Emergency preparedness and response plans should be discussed with external partners as part of a joint planning process.
- UW should confirm that partner organizations have emergency preparedness plans in place, and communicate them to stakeholders (eg., participants, parents, UW).
| Policy requirements | Partner considerations |
| Comprehensive emergency plan (specific to the program and youth audience) has been created and is reviewed/updated periodically (at least 1x/year) | An emergency plan may be created and maintained by either the UW program or the partner organization, depending on where youth activities are held and how responsibilities are allocated among the two organizations.
Even if UW will not be hosting an event, it is the responsibility of the UW to initiate a conversation to ensure adequate emergency plans are in place by the host organization. |
| Program is included in the department/unit’s fire safety & evacuation plan | The “Fire Safety & Evacuation Plan” is unique to the UW. An equivalent fire safety and evacuation plan may be created and maintained by the partner hosting organization.
It is the responsibility of the UW to initiate a conversation to ensure adequate fire safety and evacuation plans are in place. |
| All staff are trained in emergency response procedures upon hire and periodically (e.g., once annually) | Staff who are responsible for youth should be trained on the applicable emergency protocols for the program and setting. Training may be conducted by the partner organization or by the UW, depending on the setting.
UW should confirm that external personnel working in UW programs are trained adequately on emergency response. |
| Families and participants are provided basic information about the program’s emergency response protocols (e.g., reunification and communication plans) | Families should be informed about how the organization(s) will respond to emergencies. This communication can come from either the UW or the partner organization, but it should be shared in a consistent manner (for example, at the start of each school year, the start of a new program session, etc.). Families should know who to contact with questions, and what communication to expect in the case of an emergency. |
Requirement: Youth programs must process personal data in accordance with applicable University privacy policies and frameworks, including the Privacy Policy for UW Youth Programs.
General Partner considerations:
- The Privacy Policy for UW Youth Programs has clear instructions as to which youth programs fall under this specific policy. See the applicability section on the following webpage for assistance in determining if this policy is applicable in your setting: https://privacy.uw.edu/take-action/support-specific-data/youth/. If you are not sure, contact uwprivacy@uw.edu.
- UW Youth programs must inventory your data processing activities with the UW Privacy Office. This may include business processes undertaken by a non-UW entity on your behalf.
| Policy requirements | Partner considerations |
| Data collection practices (e.g., registration forms, work samples, photo/video images) are reviewed, and collection of youth’s personal information is minimized so information that is not necessary for program operations is not collected. | A clear agreement should be in place, articulating personal data processing practices. As applicable, use the Data Processing Agreement developed by the UW Privacy Office |
| The Privacy Notice for UW Youth Programs is provided to all parents, guardians and consenting youth prior to data collection occurring. | When UW is processing youth data, develop a plan that ensures that the program’s privacy notice (either the Privacy Notice for UW Youth Programs or an equivalent) is given to parents, guardians and consenting youth. |
| Consent is obtained from parents, guardians and consenting youth for each relevant circumstance indicated in the Privacy Notice for UW Youth Programs. | Depending on applicability, UW must work with the third party to obtain consent from parents and guardians in accordance with the Privacy Notice for UW Youth Programs. |
General Partner considerations:
- Whether UW or an external party is hosting the virtual program/platform, UW should ensure that proper safeguards are in place to prevent inappropriate use of technology, or harm to youth through these platforms.
- If UW is delegating the hosting of a virtual activity to a third party, include the expectations in a written agreement with the third party.
| Policy requirements | Partner considerations |
| When possible, youth program utilizes UW licensed technology platforms and apps (e.g., G-Suite, Office 365, Zoom) | Use only those technologies that are vetted by UW or the third party organization that have children’s online security safeguards in place. |
| Personnel are trained in and aware of security features that minimize risk of technology-related exploitation of youth (e.g., trolling, cyberbullying, malware) | UW should confirm that all relevant personnel using the technology are trained in applicable security features. |
| Codes of conduct (for personnel and youth participants) and Acknowledgments of Risk reflect virtual environments when applicable | As applicable, virtual program safety expectations should be included in staff and participant conduct codes. UW should ensure that parents and guardians are being made aware of and consent to use of technology in the UW program. |