Recruiter Access

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THE CHIEF EXECUTIVE OFFICER RECOMMENDS:

That the Chicago Board of Education (“Board”) amend the Recruiter Access Policy, 08-0123-PO3. The policy was posted for public comment from November 16, 2020 to December 16, 2020.

PURPOSE:

This policy is being amended pursuant to federal and state laws that require school districts to grant military recruiters the same access they grant to colleges and other career recruiters. 10 U.S.C. 503 (Enlistments); 20 U.S.C. 7908 (Strengthening and Improvement of Elementary and Secondary Schools); and the Illinois School Code, 105 ILCS 5/10-20.5a, 5/34-18. It establishes the parameters for college recruiters, military recruiters, prospective employers, and other providers of career information to have access to high schools, high school students, or their directory information. It is meant to ensure that students have access to information about the range of educational and career options available to them so they can make informed decisions. By adopting this Policy, the Board does not intend to endorse the message of any particular recruiter or to designate its school buildings or any part thereof as a public forum.

POLICY TEXT:

I. Definitions

For the purpose of this Policy only, the following definitions apply:

“Recruiter” means an entity with information for high school students about a college or university; trade school or apprenticeship; scholarship, grant or loan; or other post-secondary-school vocational or career opportunity. Recruiters include college recruiters, prospective employers, military recruiters and entities that offer information on alternatives to military careers.
“Career Information” means factual material designed to help students make an informed decision whether or where to continue their education, seek job training, or get a job.
“Career Information Site” means a bulletin board in a counseling office or other area of the school that is accessible to students or a location on the school’s website where career information can be posted for viewing by students.
“Directory Information” means a high school student’s name, address and telephone number.

II. Release of Directory Information to Institutions of Higher Education and Military Recruiters

Requests for Directory Information: Institutions of higher education and military recruiters may request Directory Information on high school seniors and juniors only by submitting a written request to the Department of Policy and Procedures, 1 North Dearborn, 9th floor, Chicago, IL 60602. All requests by higher education and military recruiters for the release of Directory Information must be submitted to Department of Policy and Procedures for handling. Recruiters may not request individual high schools to release Directory Information on their students. Release of Directory Information will not occur prior to the completion of the opt-out process noted in Section II.B. below.
Opt-Out: Parents, guardians, and students age 18 and older must use the Directory and Recruiter Information Opt-Out Form if they would like to opt-out of the distribution of their student’s directory information. This form must be distributed by schools to parents/guardians. Parents, guardians, and students age 18 and older that want to opt-out of the distribution of their student’s directory information must submit the Directory and Recruiter Information Opt-Out Form to their school. School officials must enter the responses into the Student Information System when received. The opt-out request must include the student’s name, school, and CPS identification number.

Opt-out requests must be submitted before December 1st.

III. Recruiters Access to High Schools and District-Wide Events

Any Recruiter who seeks access to high school students at a school or school-sponsored event must obtain prior permission from the principal or designee. Principals may not permit recruiting at non-recruiting events such as health fairs and athletic contests. If the principal has granted permission to any Recruiter to provide career information to students in person during the school year, the principal must grant equal access to any other Recruiter, subject to the requirements of this policy, during that school year.

Recruiters must schedule dates and times for visits through the school Principal or designee. In no event may a Recruiter request a recruiting visit less than two business days prior to the date they wish to appear at school. If the school does not have adequate space to accommodate all interested Recruiters at a particular time, the principal or designee must ensure that Recruiters are provided equal access to students at other times during the school year.
The principal will determine the frequency of Recruiter visits, may identify a limit on the number of Recruiter visits per school year, and will assign public locations for Recruiters to provide career information to students. The principal or designee must maintain a building usage schedule and a log to record the name of the Recruiter and the date and time the Recruiter visited the school.
A Recruiter must register with the school principal or designee immediately upon arrival. A Recruiter granted permission to provide career information in person must comply with the restrictions described in Section IV below and the building usage schedule and other requirements established by the principal.

A Recruiter who seeks access to high school students at a district or area-wide career or college recruiting event must obtain prior permission from the Department of Policy and Procedure. A Recruiter granted permission to provide career information to students at a district or area-wide event must comply with the restrictions described in Section IV below, and the event schedule and other requirements established by the Department of Policy and Procedure.

Any Recruiter who seeks to post career information on the school’s Career Information Site must obtain prior permission from the principal or designee. If the principal has granted permission to any Recruiter to post career information on the school’s Career Information Site, the principal must grant equal access to any other Recruiter, subject to the requirements of this policy. The principal may impose reasonable restrictions on the size of the submission to be posted, and may reject any information that does not adhere to the tenets of this policy. For example, the principal may reject materials that do not offer career information for students.

The requirements of this section do not apply to visits by Recruiters to administrative offices solely for the purpose of meeting with school personnel provided they register with the principal or designee upon arrival. Recruiters must refrain from engaging in recruiting activities when making administrative visits to a school, unless otherwise authorized by the Principal pursuant to this Policy.

IV. Recruiter Conduct

Recruiters must not:

interfere with the educational process or create a nuisance that interferes with students’ peaceful enjoyment of school activities;
interact with students on school grounds or at school-sponsored events outside the area designated by the principal, and may provide materials only to those students who approach them to ask for information;
utilize or distribute interactive video games on school grounds;
require students to take predictive tests or career suitability assessments on school property;
sponsor drawings, lotteries or other chance activities, or provide gifts or prizes to students unless they are of nominal value not to exceed $5.00 (e.g. pens, pencils, key chains and water bottles);
move about the building unaccompanied by school staff;
engage in recruiting activities where students are not free to leave the Recruiter’s presence;
conduct recruiting activities at non-recruiting events such as health fairs and athletic contests; or
deviate from any other restriction imposed by the principal or the Department of Education Policy and Procedure.

V. Violations

Any violation of this Policy must be reported to the principal or the Department of Policy and Procedure.
Any employee who violates this Policy will be subject to discipline under the Employee Discipline and Due Process Policy.
If a principal finds that a Recruiter has violated this Policy, they must deliver written notice of the violation to the Recruiter, explaining that additional violations may result in the Recruiter’s exclusion from the school. In the event of repeated violations of this policy, the Principal may exclude the Recruiter, or any of their individual agents for the remainder of the school year.
If the principal determines that a Recruiter is interfering with the educational process or creating a nuisance that interferes with students’ peaceful enjoyment of school activities, the principal may withdraw permission for the Recruiter to access school facilities and/or direct the Recruiter to leave the premises. After taking either action, the principal must notify the Recruiter and the Department of Policy and Procedure, in writing, of the reason for the action.

VI. Appeal

Any Recruiter who is denied access to the school, or who disagrees with any restriction imposed by the principal, may make a written appeal to the Department of Policy and Procedure. The Department of Policy and Procedure must decide the appeal within five school days and that decision will be final.

Policy References

Amends/Rescinds	Amends 08-0123-PO3
Cross References
Legal References	10 U.S.C. 503, 20 U.S.C. 1232g-h, 7908; 105 ILCS 5/10-20.5a, 5/34-18(16), 10/6.
Public Comment	Pursuant to Board Rule 2-6 this Policy was subject to Public Comment from 11/16/20 – 12/16/20