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Policy 1070 Implementation Procedures - Protections and Supports for Foreign-Born Students

Policy Document

Implementation Procedures

Appendix A

I. Student Protections

  1. The Superintendent/designee will communicate to all Howard County Public School System (HCPSS) employees and third parties high expectations for the physical safety, emotional safety, and academic success of all students including foreign-born students and students perceived to be foreign-born.

  2. The Superintendent/designee will establish procedures to ensure that all HCPSS employees respond quickly and appropriately when employees are aware of students impacted by immigration enforcement related issues.

  3. Existing policies and procedures in the HCPSS Policy 1000 Series: Foundations and Basic Commitments category related to protecting the safety of all students will be followed to provide safety and protection for foreign-born students and students perceived to be foreign-born.

II. Information Collection and Record Keeping

  1. Any request from any agency seeking information about foreign-born students and their families should be referred to the principal or their designee.

  2. HCPSS employees will not request any information regarding immigration status/social security numbers for participation in any school system activity.

    1. The Superintendent/designee will maintain school enrollment/registration procedures that do not require immigration status information, including social security numbers.

    2. The principal/designee will ensure that participation in school activities does not require the reporting of immigration status unless the activity is a field trip and the immigration status is required by the field trip location.

    3. To allow families an opportunity to make informed decisions, the principal/designee will provide all families with adequate information about the criteria for participating in field trips that require immigration status reporting. Should families choose to decline participating, the principal/designee will not require them to give a reason for doing so and will ensure that declining the activity will not impact the student’s grade.

    4. The principal/designee will communicate information about school activities and immigration status expectations with Activities and Athletics Managers (AAMs), classroom teachers, and other HCPSS school-based employees, as appropriate.

  3. The Superintendent/designee will ensure adherence to Policy 3050 Records Management in the creation, maintenance and destruction of all HCPSS records to ensure no immigration status data, including social security number, is collected or required.

  4. The Superintendent/designee will ensure adherence to Policy 9050 Student Records for the security, management and access of HCPSS student records to ensure no immigration status data, including social security number, is collected or required.

  5. The Superintendent/designee will review all HCPSS policies and procedures on a regular basis to ensure no immigration status data, including social security number, is required, collected or maintained.

  6. As part of the student data governance and privacy program identified in Policy 3060 Student Data Governance and Privacy, the Superintendent/designee will collaborate with the HCPSS executive leadership to manage and maintain the program that will include an annual review of all HCPSS forms completed by students and families to ensure no immigration status data, including social security number, is collected or required.

  7. The Superintendent/designee will ensure adherence to Policy 9050 Student Records regarding the protection of directory information as defined in the implementation procedures Sections VI.A.9. and VII.A.4.b.

III. Family and Community Resources

  1. The Superintendent/designee will annually update a resource webpage on the HCPSS website to provide school-based and community resource information available for foreign-born students and families. School websites will be linked to the HCPSS resource webpage. The webpage will include:

    1. Translations of documents and information about interpreting services.

    2. Resources for academic, social, emotional, physical and mental health.

    3. Resources regarding the importance of school attendance and how to work with the school to support school attendance.

    4. Resources for parents and caregivers to better understand education in the United States and how to navigate the HCPSS.

  2. The principal/designee will identify a school point of contact and a team of trained HCPSS employees (including but not limited to a pupil personnel worker (PPW), school counselor, school nurse, school psychologist, and school-based administrator) who will:

    1. Respond quickly and appropriately to the needs of students and families affected by immigration enforcement actions.

    2. Maintain the confidentiality of the family’s immigration status when referring them to community organizations.

    3. Provide academic, social, emotional, physical, and mental health resources.

  3. School counselors and liaisons will receive training on the legal guidelines and legislation, culturally proficient responses to cultural differences, information about the unique needs of students and families entering the United States as refugees, and the transition to college for students with legal immigration status and those without legal immigration status.

  4. HCPSS will partner with organizations to provide information and resources to support foreign-born students and families entering into a new culture and school environment in order to support the transition.

  5. HCPSS will partner with private and public institutions of higher learning to provide information and resources on the transition to college for students with legal immigration status and those without legal immigration status.

IV. Communication and Dissemination

  1. The Superintendent/designee will communicate clear protocols to identify how HCPSS employees and third parties should interact with law enforcement including federal immigration authorities, on any property owned or leased by HCPSS and during school system activities.

  2. The Superintendent/designee will communicate to the community through various avenues, the development of this policy and the safeguards in place to ensure the handling of privileged information regarding all students, including foreign-born students and students perceived to be foreign-born.

  3. The Superintendent/designee will provide translations of this policy in languages which represent the HCPSS community.

  4. All communications to the community, students, and HCPSS employees regarding this policy, will be articulated in a manner that does not create anxiety or fear among stakeholders.

V. Professional Development

  1. The principal/designee will provide professional development with the goal of increasing employee understanding of the diverse experiences and backgrounds of foreign-born students, the legal rights of foreign-born students as well as those perceived to be foreign-born, and an awareness of the resources available to support them.

  2. The Superintendent/designee will include Policy 1070 in the professional development required for all volunteers.

  3. The Superintendent/designee will provide annual professional development for HCPSS employees and coaches on bullying, the responsibilities for bullying reporting, and implicit/explicit bias, including bias based on background and perceived immigration status.

  4. HCPSS student services employees, international liaisons, and/or school points of contact will receive training on the following:

    1. Resources and legal protections available for foreign-born students

    2. How to respond to requests by federal immigration agents (See Implementation Procedures Appendix)

    3. Understanding the confidentiality needs of students

    4. Available counseling services, and

    5. The potential psychosocial impact on students and families affected by immigration enforcement actions.

  5. The Superintendent/designee will provide professional development to school registrars, admission secretaries and pupil personnel workers that provide guidance regarding documentation required for enrollment. HCPSS employees will be trained to not ask for immigration status and/or social security numbers when registering new students.

VI. Violations of this Policy

Consequences related to violations of this policy and procedures will be administered using the appropriate HCPSS policy and implementation procedures including but not limited to those described in HCPSS Policy 1000 Series: Foundations and Basic Commitments.

VII. Definitions

Within the context of these implementation procedures, the following definitions apply:

  1. Confidentiality – The obligation of the school system or a HCPSS employee not to disclose or transmit information to unauthorized parties.

  2. Family – A group of two people or more (one of whom is the householder) related by birth, marriage, or adoption and residing together.

  3. Third Party – Parents, mentors, volunteers, vendors, contractors, School Resource Officers and others with whom students or HCPSS employees interact during school or school-related activities.

VIII. Monitoring

Policy 1070 implementation procedures will be overseen by the Division of Equity and Innovation.

IX. History

ADOPTED: October 2, 2018

REVIEWED: January 17, 2024

MODIFIED: January 29, 2026

REVISED:

EFFECTIVE: January 29, 2026

Policy History Key

  • Adopted-Original date the Board took action to approve a policy
  • Reviewed-The date the status of a policy was assessed by the Superintendent’s Standing Policy Group
  • Modified-The date the Board took action to alter a policy that based on the recommendation of the Superintendent/designee did not require a comprehensive examination
  • Revised-The date the Board took action on a that policy based on the recommendation of the Superintendent/designee needed a comprehensive examination
  • Effective-The date a policy is implemented throughout the HCPSS, typically July 1 following Board action.