Internships Involving Minors

Human Resources (HR) Requirements:

IMPORTANT: All internship opportunities involving minors must be reviewed by HR to confirm appropriate classification (internship vs. employment in accordance with FLSA guidance) before recruiting, extending an offer, or allowing any work to begin.

HR review is required to ensure compliance with federal labor laws and must occur before any program planning proceeds.

• HR will:
  • Collect working papers where required
  • Appoint the intern in Workday prior to the start date (regardless of whether the internship is paid or unpaid)
  • Conduct background checks for faculty and staff involved (see below)

Note: The individual appointed as the intern’s supervisor in Workday must also be one of the individuals responsible for monitoring and supervising the minor intern (see Supervision and Program Registration sections below).

Environmental Health & Safety (EHS) Requirements: 

For internships in wet labs or environments involving potentially hazardous materials, equipment, or locations:

• Review Cornell's Youth in Labs Guidelines to determine whether the lab and proposed work are appropriate for minors. Note that there are specific restrictions for individuals under 18 working in labs.
• Supervisors are responsible for ensuring minor interns complete all required lab safety training prior to their start date. Retain documentation of all completed training.
• Contact askehs@cornell.edu with questions or to request access to lab safety training for individuals without a NetID.

These requirements do not apply to internships conducted in low-risk environments such as computer labs, offices, or museums.

Youth Protection Requirements: 

Supervision:

• In accordance with University Policy 8.8, minors may not be unsupervised while participating in Cornell programs, including internships
• Minors may arrive/depart independently with parental permission; however, they may not engage in internship activities without appropriate, on-site supervision 
• All individuals responsible for supervising the minor (including the appointed supervisor) or who will regularly interact with the minor must complete all required training and background checks (see below)
• Undergraduate students may not serve as primary supervisors of minors but may work alongside them
• Private one-on-one interactions should be avoided; interactions with the minor should be observable and interruptible. Please review additional supervision guidance

Program Registration:

Internship opportunities involving non-matriculated minors must be registered in the youth program registration system (Ideal-Logic). Required information includes:

• College or unit name
• The lab name (if applicable)
• Program location
• The names, NetIDs, and affiliations (faculty, staff, student) of all individuals supervising or regularly interacting with the intern, including the appointed supervisor
• A description of the intern's activities, including any potential hazards
• Required/provided personal protective equipment (PPE)
• Internship schedule (days, times, duration)
• Off-campus travel and transportation plans (i.e., for fieldwork)

Submission deadline: Materials must be submitted at least 30 days prior to the internship start date to allow sufficient time for review and completion of compliance requirements.

Background Checks:

• Required for all individuals supervising or regularly interacting with minors (defined as more than once or twice per semester). Please refer to Policy 8.8 for more details.
• For faculty and staff:
  • Initiated through unit HR
  • Valid for 3 years
  • Must include:
    • Criminal background check
    • Sex offender registry search
• Clearance dates must be emailed to youthprogramadministrator@cornell.edu.
• For undergraduate students:
  • Initiated by Youth Protection
  • Recorded directly in the registration system

Training Requirements: 

All individuals supervising or regularly interacting with the minor(s) must complete:

• Abuse prevention training
• Attestation to Cornell's Standards of Behavior for Working with Youth

Instructions will be provided following program registration. 

Note: Workday Learning is not integrated with the Youth Protection registration system. If training is completed in Workday Learning instead of the registration system, transcripts must be emailed to youthprogramadministrator@cornell.edu for manual recording.

Parental Consent: 

• A signed assumption of risk form is required for all internships involving minors
• Forms are generated by Youth Protection after registration and included in the approval email