POLICY OWNERS

This policy is owned jointly by the University Provost/Executive Vice President and the Vice President for Human Resources.

PURPOSE OF THIS POLICY

The purpose of this policy is to ensure Colorado State University’s compliance with Colorado Senate Bill 25-276 and C.R.S. § 24-74.1-102(3)(a), which prohibits institutions of higher education from collecting or disclosing certain Personal Identifying Information for the purpose of Federal Immigration Enforcement, except as required by law. This policy supports the privacy rights of students, Employees, and community members.

APPLICATION OF THIS POLICY

This policy applies to all Employees, students, contractors, and agents, including those acting on behalf of the University, and covers all University properties.

EXEMPTIONS FROM THIS POLICY

Student Legal Services is exempt from this policy.

DEFINITIONS USED IN THIS POLICY

Confidential Records: Records protected by the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g; 34 C.F.R. Part 99 (FERPA), or other applicable federal and state privacy laws.

Employee: Any individual employed by the University in a full-time, part-time, temporary, or contract capacity, including volunteers when acting on the University’s behalf.

Federal Immigration Enforcement: Efforts to investigate, enforce, or assist in the enforcement of federal civil or criminal immigration laws.

Personal Identifying Information: Includes place of birth, immigration or citizenship status, and data from passports, permanent resident cards, alien registration cards, and employment authorization documents.

POLICY STATEMENT

Colorado State University will not inquire into, collect, or disclose Personal Identifying Information related to immigration status, nor provide access to campus spaces or records to Federal Immigration Enforcement authorities, unless required or permitted by law or as necessary to perform university duties, activities, or programs, such as collecting information for student visa sponsorship and student financial aid eligibility. CSU is committed to fostering a safe and supportive environment that respects the privacy and rights of all individuals, regardless of immigration status.

POLICY PROVISIONS

1. Prohibited Data Collection

CSU Employees must not collect information about place of birth, immigration or citizenship status, or any data from federal immigration documents, unless:

• Required to comply with federal or state law;
• Necessary for lawful visa sponsorship, financial aid, or any other university program or activity; or
• Necessary to determine eligibility for government-funded programs.

2. Restrictions on Access to Information or Facilities
   CSU will not disclose Personal Identifying Information or allow Federal Immigration Enforcement access to non-public campus areas unless:

• A valid subpoena, court order, or judicial warrant signed by a federal judge or magistrate is presented; or
• The student or individual of interest provides informed, written consent.

3. Required Procedures and Designation
   The Office of General Counsel (OGC) is to be notified in the event of any federal request for information or access. In response to any such federal request, OGC will:

• Request and seek to document the identity and credentials of requesting federal officials, including name, agency, badge number, and any supporting legal documentation (e.g., subpoena, warrant, or court order issued by a federal judge or magistrate);
• Communicate with affected individuals or their families when appropriate about the nature and scope of the request;
• Review and approve any disclosure of Personal Identifying Information about a student, Employee, patient, or patron, as required by federal or state law;
• Review and approve any disclosure of Personal Identifying Information about a parent, guardian, or relative of a student, Employee, patient, or patron, as required by federal or state law.

4. Policy Distribution and Awareness

• All Employees, particularly those in forward-facing roles (e.g., Admissions, International Programs, Student Services, HR, and other high-interaction units), will be provided information on this procedure to ensure they can recognize and appropriately escalate any federal immigration-related requests.
• This policy will be made available on CSU’s University Policy Office website and through other regular communications.

 COMPLIANCE WITH THIS POLICY

Compliance with this policy is mandatory. Any Employee found to have intentionally violated this policy may be subject to disciplinary action and civil penalties as provided by state law. If approached by law enforcement, contact the CSU Police Department or the Office of General Counsel. For assistance with interpretation or application of this policy, contact the Office of the Provost or the Office of General Counsel.

REFERENCES

C.R.S. § 24-74.1-102(3)(a), as amended by SB25-276

CSU System Policy: FERPA

CSU Student Data Privacy Policy

CSU Federal Updates Federal law enforcement/U.S. Immigration and Customs Enforcement (ICE)

APPROVALS

Policy approved by Amy Parsons, President, on August 28, 2025.