Covered Person | Policies and Procedures for Programs with Minors

Covered Person (CP) Guidelines & Requirements

As a Covered Person (CP), you are responsible for the custody, control, or supervision of minors participating in a University of Hawaiʻi (UH) Covered Program.

Below are the definitions, background check requirements, classification distinctions, and legal obligations set forth in University policy.

Definition of a Covered Person

A Covered Person is any individual responsible for the custody, control, or supervision of minors in a Covered Program who falls into one of the following categories:

University Community Members (including faculty, staff, and students).
Non-UH Volunteers assisting with a Covered Program.
Members of Non-University Organizations that operate programs for minors in University facilities under an official agreement (e.g., a facilities use agreement), including their employees, agents, and volunteers.
Contractors, including independent contractors, external consultants, workers from outside employment agencies, and service vendor employees working on campus.

Classifications: UH Community Members vs. Volunteers

To ensure proper policy application, Covered Persons are classified into two categories to determine what type of background check they will be screened for. This classification will be on the Participant List Form after RCO approval of the Covered Program:

UH Community Member (UH Participant)	Non-UH Volunteer (Non-UH Participant)
Officers, officials, employees (faculty, lecturers, staff), students, and academic appointees (post-doctoral fellows, research fellows, TAs) of UH or affiliated organizations. A staff member or employee of the University or a University-affiliated organization A University academic appointee, whether paid or unpaid (including post-doctoral fellows, research fellows, and teaching assistants).	Any individual who is not a UH Community Member but is applying for or has been deemed suitable to interact with minors in a Covered Program. Research Corporation for the University of Hawai‘i (RCUH) employees those with temporary hawaii.edu accounts and/or UH IDs (such as visiting PhD students)

UH Community Member (UH Participant)

Non-UH Volunteer (Non-UH Participant)

Officers, officials, employees (faculty, lecturers, staff), students, and academic appointees (post-doctoral fellows, research fellows, TAs) of UH or affiliated organizations.

A staff member or employee of the University or a University-affiliated organization

A University academic appointee, whether paid or unpaid (including post-doctoral fellows, research fellows, and teaching assistants).

Any individual who is not a UH Community Member but is applying for or has been deemed suitable to interact with minors in a Covered Program.

Research Corporation for the University of Hawai‘i (RCUH) employees

those with temporary hawaii.edu accounts and/or UH IDs (such as visiting PhD students)

Volunteer participation in a University-sponsored program, including minors, should be in accordance with Administrative Procedure 9.041, Utilization of Volunteer Services of the University of Hawaii.

Background Check & Submission Requirements

Before participating in any Covered Program, prospective UH Community Members and Non-UH Volunteers must complete a background screening process:

Submission Process

Data Submission: You must submit your Background Clearance Request/Consent for Participants Interacting with Minors Form (also referred to as the Consent Form) through OnBase to initiate the Background Check screening by the Background Check Coordinator (BCC). This form requests personally identifiable information and, if applicable, criminal history confidentially.
Screening Checks: The BCC will conduct:
- A fingerprint-based background check through FBI records via Fieldprint. (Only required for UH Community Members.)
- A criminal history check via the Hawaiʻi Criminal Justice Data Center.
- A Sex Offender Registry check.
- A review of driving records (only if your role in the program requires driving).
Determination: Once evaluated, the BCC will issue an official determination regarding your suitability for the program via email.

Note on FCRA Compliance: Background checks are conducted in compliance with federal law. For details on your rights, please review the Fair Credit Reporting Act (FCRA) and Credit reporting requirements outlined by the Consumer Financial Protection Bureau.

Mandated Reporter Obligations

All Covered Persons—including University employees, contractors, and volunteers—are legally recognized as Mandated Reporters.

If, in your professional capacity, you have reason to believe that child abuse and/or neglect has occurred, or that a substantial risk of abuse/neglect exists in the foreseeable future, you are required to immediately make an oral report to at least one of the following agencies:

The Department of Human Services (Child Welfare Services)
The local police department

For comprehensive instructions on your legal duties, please consult the Department of Human Services Guide for Mandated Reporters.