SS 18.0 - Immigration Rights and Non-Discrimination Policy :

1. Appointment of Responsible Designee

The president of Edmonds College is the designee responsible for satisfying the obligations in the Keep Washington Working Act (KWW) and the Edmonds College Immigrant Rights and Non-Discrimination Policy.

In the event the president is not available, the following members of the leadership team will act as authorized designees, in the order listed below:

1. Vice President for Human Resources

2. President's Administrator in Charge (AIC)

The president or acting designee may consult with the college's legal counsel, the Assistant Attorney General (AAG), if needed.  

2. Applicability of Policies Related to Immigration Enforcement

1. Edmonds College adheres to all requirements of federal and state law.
2. The provisions of this policy shall apply to Edmonds College and all facilities and grounds, which include (but are not limited to) adjacent sidewalks, parking areas, sports facilities, and entrances and exits from said building spaces.
3. The provisions of this policy prohibit participation or aid in immigration enforcement and shall apply for enforcement activity against students and their families, staff, and volunteers.
4. Edmonds College personnel shall presume that activities by federal immigration authorities, including surveillance, constitute immigration enforcement.

3. Access to Education

1. Edmonds College does not exclude students from receiving an education or unlawfully discriminate against anyone because of their race, color, national origin, age, disability, gender identity, immigration or citizenship status, sex, creed, use of a trained dog guide or service animal by a person with a disability, sexual orientation, or on any other basis prohibited by federal, state, or local law.
2. Edmonds College shall ensure that all staff and volunteers are aware of the rights of immigrant students to an education. 
3. Edmonds College shall ensure that information reviewed to determine eligibility for in-state tuition or other benefits and any reporting requirements is limited only to the information necessary for residency determinations and in compliance with KWW and any other applicable state or federal laws.
4. Edmonds College shall separate all information on individuals with foreign student visa status (F, J, and M visas) retained for the purpose of reporting to the Student Exchange and Visitor Information System (SEVIS) as part of the Student and Exchange Visitor Program (SEVP), from general enrollment platforms or other directory information.

4. Immigration Enforcement on College Grounds and Facilities

1. Edmonds College does not grant permission to any person engaged, or intending to engage, in immigration enforcement, including surveillance, access to college grounds, facilities, or their immediate vicinity without verification of proper documentation by the president of the college or authorized designee. Edmonds College staff shall direct anyone engaging, or intending to engage, in immigration enforcement, including federal immigration authorities with official business that must be conducted on college grounds or facilities, to the Office of the President, prior to access. Edmonds College staff shall presume that activities by federal immigration authorities, including surveillance, constitute immigration enforcement.
2. If anyone attempts to engage in immigration enforcement on or near Edmonds College grounds or facilities, including requesting access to a student, employee, or college grounds:
   1. Staff shall immediately alert and direct the person to the Edmonds College Office of the President located in Gateway Hall.
   2. The president or authorized designee shall verify and record the person's credentials (at least, badge number and name), record the names of all persons they intend to contact, collect the nature of their business at the school, request a copy of the court order or judicial warrant for review.
   3. The president or authorized designee shall require that any person desiring to communicate with a student, enter school grounds, or conduct an arrest, first produce a valid court order or judicial warrant.
   4. The president of Edmonds College or authorized designee shall review the court order or judicial warrant for signature by a judge and its validity. For Edmonds College to consider it valid, any court order or judicial warrant must state the purpose of the enforcement activity, identify the specific search location, name the specific person to whom access must be granted, include a current date, and be signed by a judge.
   5. The president of Edmonds College or authorized designee shall review written authority signed by an appropriate level director of an officer's agency that permits them to enter Edmonds College property, for a specific purpose. If no written authority exists, the president of Edmonds College or authorized designee shall contact the appropriate level director for the officer's agency to confirm permission has been granted to enter Edmonds College property for the specific purpose identified.
   6. Upon receipt and examination of the required information, the president of Edmonds College or authorized designee will determine whether access shall be allowed to contact or question the identified individual.
   7. If the requestor is seeking access or information regarding a student under 18 years old, the president of Edmonds College or authorized designee shall make a reasonable effort, to the extent allowed by FERPA, to notify the parent/guardian of any immigration enforcement concerning their student, including contact or interview.
   8. The president of Edmonds College or authorized designee, shall request an Edmonds College representative to be present during any interview. Access to information, records, or areas beyond that specified in the court order or judicial warrant shall be denied.

5. Gathering Immigration-Related Information

1. Edmonds College staff shall not inquire about, request, or collect any information about the immigration or citizenship status or place of birth of any person accessing services provided by, or in connection with, the college. Edmonds College staff shall not seek or require information regarding any person's citizenship or immigration status where other information may be sufficient for Edmonds College's purposes. This does not prohibit residency officers or related staff from reviewing information from students or others on a voluntary basis in order to determine that a student is qualified for in-state tuition rates.
2. Edmonds College policies and procedures for gathering and handling student information during enrollment or other relevant periods shall be made available in writing to students and their guardian(s) at least once per school year in a manner that Limited English Proficient (LEP) individuals will understand. 
3. If Edmonds College is required to collect and provide information related to a student's national origin (e.g., information regarding a student's birthplace, or date of first enrollment in a U.S. school) to satisfy certain federal reporting requirements for special programs, prior to collecting any such information or reporting it, Edmonds College shall (except with respect to reporting requirements necessary for compliance with the Student and Exchange Visitor Program):
   1. If feasible, consult with legal counsel regarding its options, including alternatives to the specific program or documents accepted as adequate proof for the program;
   2. Explain reporting requirements to the student and student's parent(s) and/or guardian(s), in their requested language, including possible immigration enforcement impact; 
   3. If moving forward with the collection of information, receive and collect written consent from the student, if over the age of 18, or the student's parent(s) and/or guardian(s); and
   4. Collect and maintain this information separately from the school/class enrollment process and student records in order to avoid deterring enrollment of immigrants or their children.
4. When Edmonds College reviews information related to immigration status in order to make residency determinations, the residency officer's written confirmation that a student meets any applicable immigration status requirement shall be considered sufficient written evidence that a student meets the requirements of RCW 28B.15.012. All other documents used to prove student or other individual immigration status, aside from those independently required by law to be kept, shall be designated as transitory and disposed of in accordance with the Edmonds College records retention policy. Any Edmonds College staff maintaining said information in any other way shall report their retention procedure and basis to the president of Edmonds College prior to collecting the information.

6. Responding to Requests for Information

1. Edmonds College staff, other than the president or authorized designee, shall not share, provide, or disclose personal information about any person for immigration enforcement purposes.
2. Edmonds College staff shall immediately report receipt of any information request relating to immigration enforcement to the president of Edmonds College or authorized designee, who shall document the request. 
3. Edmonds College shall, to the extent allowed by FERPA or as otherwise advised by legal counsel, notify the student's parent(s) and/or guardian(s) of the request for information at the earliest extent possible.

7. Use of College Resources

1. Edmonds College's resources shall not be used to engage in, aid, or in any way assist with immigration enforcement.
2. Edmonds College's resources and policies regarding immigration enforcement shall be published and distributed to students and their parent(s) or guardian(s) on an annual basis. These resources shall include, at minimum:
   1. Information about accommodations for limited English proficiency, disability accommodations, special education programs (if applicable), and tuition assistance grant or loan programs that may be available regardless of immigration or citizenship status;
   2. General information policies including the types of records maintained by Edmonds College, a list of the circumstances or conditions under which Edmonds College might release student information to outside people or entities, including limitations under FERPA and other relevant law;
   3. Policies regarding the retention and destruction of personal information;
   4. The process of establishing consent from students and their parent(s) or guardian(s), as permitted under federal and state law, prior to releasing a student's personal information for immigration enforcement purposes;
   5. Name and contact information for Edmonds College's designated point of contact on immigration-related matters; and
   6. "Know Your Rights" resources and emergency preparedness forms to have completed in the event of a family separation.