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Colchester Board of Education
A Board Member's Guide to Working With
the Superintendent and Stakeholders
Anne H. Littlefield January 14, 2021
© Shipman & Goodwin LLP 2016. All rights reserved.
Topics Addressed
I. Board Roles II. With whom does the
A. Rights and Responsibilities Board interact?
of Board members A. Personnel
B. Board vs. Superintendent B. The Public
duties
C. Parents
C. Freedom of Information
D. Students
1. Meetings
2. Records
D. Who speaks for the Board?
Board Roles
Legal Rights and Responsibilities of Board Members
I. Responsibilities of the II. Rights of Board
Board of Education members
A. Agent of the State A. Authority at meetings
B. Policy-maker for the only
district B. Otherwise same rights
C. Compare as other citizens
administration C. Role of committees
responsibility for day- D. Indemnification
to-day district
operations
Legal Rights and Responsibilities of Board Members
III. Duties of Board members
A. Confidentiality/Educational
need to know
B. Impartial judge
1. Expulsion hearings (Conn.
Gen. Stat. § 10-233d)
2. School accommodations
hearings (Conn. Gen. Stat. §
10-186)
3. Teacher tenure hearings
(Conn. Gen. Stat. § 10-151)
C. Statutory duties
D. Conflicts of Interest Issues
Legal Rights and Responsibilities of Board Members
IV. Meeting
Procedures
A. Role of Chair
B. Public Comment
Legal Rights and Responsibilities of Board Members
VI. Freedom of Information 5. Types of meetings
A. Records – presumption in a. Regular meetings
favor of disclosure b. Special Meetings
B. Meetings c. Emergency Meetings
1. FOI requirements triggered 6. Agenda
by quorum 7. Executive session
2. Committees a. 2/3 vote
3. Non-meeting b. Reasons
4. Electronic and telephonic c. Attendance
communications 8. Record of Votes
9. Minutes
Board vs. Superintendent General Duties
Superintendent
• Handles the district’s day-today operations
• Serves as the “face” of the district
• Typically serves as the district’s spokesperson
• Supervises district staff
Board of Education
• Represents the residents of the Town in carrying out legal mandates pertaining to
education
• Determines all questions of general policy to be employed in the conduct of the
schools. In doing so, it:
• Hears and considers facts and recommendations
• Adopts plans, policies, and courses of action, and
• Authorizes the Superintendent to carry out its policy
• Sets the budget
• Supervises the Superintendent
Board’s Specific Powers and Duties
A. Create, abolish, modify and maintain such positions, schools,
divisions and classifications as may be necessary for the
efficient administration of the educational enterprise
B. To elect a Superintendent of Schools in accordance with state
statutes
C. To consider and adopt an annual budget, prepared by the
Superintendent of Schools
D. To determine the number, classification, duties and
remuneration of employees
E. To establish policies for employment, promotion and
dismissal of personnel in accordance with the state statutes
Board’s Specific Powers and Duties
F. To provide for the appraisal of the efficiency of personnel
G. To initiate and approve the acquisition and disposition of
school sites, to initiate and approve plans for school
buildings
H. To consider any specific recommendations made by the
Superintendent of Schools
I. To keep the citizenry informed of purposes, values,
conditions and needs of public education in the Town
J. To consider, revise and adopt any changes in the
curriculum
K. To take any other actions required or permitted by law
Board’s Specific Powers and Duties
L. To make reasonable provision to implement the
educational interests of the State, as defined by law, so
that:
1. Each child shall have for the period prescribed in the General
Statutes equal opportunity to receive a suitable program of
educational experiences;
2. The school district shall finance at a reasonable level an
educational program designed to achieve this end;
3. The school district shall provide educational opportunities for
its students to interact with students and teachers from other
racial, ethnic and economic backgrounds;
4. The mandates in the General Statutes pertaining to education
within the jurisdiction of the State Board of Education shall be
implemented.
FOIA
• The Freedom of Information Act
(the "FOIA"), (Conn. Gen. Stat.
§§ 1-200 through 1-241 inclusive),
represents Connecticut's commitment
to open government and a strong
policy in favor of public access to meetings and records.
• Subject to narrow exceptions, which are strictly
construed, the FOIA mandates that the public has access
to:
Meetings of public agencies
Records that are developed and/or
maintained by public agencies
“Public Agency” or “Agency” Means
• Any executive, administrative or legislative office of the
state or any political subdivision of the state and any
state or town agency, any department, institution,
bureau, board, commission, authority or official of the
state or of any city, town, borough, municipal
corporation, school district, regional district or other
district or other political subdivision of the state,
including any committee of, or created by, any such
office, subdivision, agency, department, institution,
bureau, board, commission, authority or official. . .
Conn. Gen. Stat. § 1-200.
Meetings
• The FOIA defines a meeting as follows:
• “Meeting” means any hearing or other
proceeding of a public agency, any convening or
assembly of a quorum of a multimember public
agency, and any communication by or to a
quorum of a multimember public agency,
whether in person or by means of electronic
equipment, to discuss or act upon a matter over
which the public agency has supervision,
control, jurisdiction or advisory power.
“Meeting” Does Not Include
• Any meeting of a personnel search committee for
executive level employment candidates;
• Any chance meeting, or a social meeting neither planned
nor intended for the purpose of discussing matters
relating to official business;
• Strategy or negotiations with respect to collective
bargaining;
• A caucus of members of a single political party
notwithstanding that such members also constitute a
quorum of a public agency;
• An administrative or staff meeting of a single-member
public agency; and communication limited to notice of
meetings of any public agency or the agendas thereof
Meetings
• In general, there is a meeting anytime a quorum of a
public agency convenes or engages in interactive
communication to discuss or act upon a matter for
which it has responsibility. There can even be a
statutory FOIA meeting where it is "anticipated" that a
quorum will be present.
• Note:
A quorum of the members of a public agency who are
present at any event which has been noticed and conducted
as a meeting of another public agency under the provisions
of the Freedom of Information Act shall not be deemed to be
holding a meeting of the public agency of which they are
members as a result of their presence at such event.
Conn. Gen. Stat. § 1-200(2)
Meetings
• A conference call or other communication by
means of electronic equipment may
constitute a meeting
• Agencies are cautioned to be particularly
careful that email exchanges may constitute a
meeting for FOIA purposes
Under FOIA
• Meetings fall into one of three categories:
Regular
Special
Emergency
Regular Meetings
• Regular meetings are those for which the public agency
must file a schedule with the Town Clerk, by January 31, for
the ensuing year. Conn. Gen. Stat. § 1-225(b)
• The agenda of a regular meeting of every public agency
must be posted at least 24 hours prior to the meeting in the
public agency's regular office or place of business
Other business may be added to the posted agenda by a
two-thirds vote of those members present and voting
Minutes of a regular meeting must be available for
public inspection within seven days of the meeting
Special Meetings
• Special meetings are those meetings that are not included
on the list of regular meetings filed with the Town Clerk.
Notice of a special meeting, including the time, place
and business to be transacted, must be posted at least
24 hours in advance. Conn. Gen. Stat. § 1-225(d). The
agenda for a special meeting must also be posted on
the agency’s website “if available.”
No business other than that on the posted agenda may
be discussed at a special meeting. Items cannot be
added to the agenda.
Minutes must be available for inspection within seven
days of the meeting.
Emergency Meetings
• Emergency special meetings may be called in an
emergency without advance notice (Note: The term
"emergency" will be strictly construed)
The meeting must be limited to the matter that
requires "emergency" attention
Minutes of an emergency special meeting must be
filed with the Town Clerk within 72 hours of the
emergency meeting and include a statement
setting forth the nature of the emergency
Conn. Gen. Stat. § 1-225(a)
Executive Sessions
Under circumstances narrowly prescribed by the
FOIA, a public agency may exclude the public
from a portion of its meeting by calling an
executive session. Executive sessions, are
defined in Conn. Gen. Stat. § 1-200(6) as follows:
Executive Sessions
• “Executive sessions” means a meeting of a public agency at
which the public is excluded for one or more of the
following purposes:
Discussion concerning the appointment, employment,
performance, evaluation, health or dismissal of a public
officer or employee, provided that such individual may
require that discussion be held at an open meeting;
Strategy and negotiations with respect to pending
claims or pending litigation to which the public agency
or a member thereof, because of the member’s conduct
as a member of such agency, is a party until such
litigation or claim has been finally adjudicated or
otherwise settled;
Executive Sessions
• Matters concerning security strategy or the deployment of
security personnel, or devices affecting public security;
• Discussion of the selection of a site or the lease, sale or
purchase of real estate by the state or a political subdivision
of the state when publicity regarding such site, lease, sale,
purchase or construction would adversely impact the price
of such site, lease, sale, purchase or construction until such
time as all of the property has been acquired or all
proceedings or transactions concerning same have been
terminated or abandoned; and
• Discussion of any matter which would result in the
disclosure of records that are exempt from disclosure under
Section 1-210(b)
Executive Sessions: Requirements
• There are specific requirements for
conducting business in executive session:
Two-thirds of those members of the public agency
present must vote at a public meeting to go into
executive session and state the reason(s) for such
executive session. Conn. Gen. Stat. § 1-225(a).
Only members of the public agency and those
persons whose presence is necessary to present
testimony or give opinions may be present during
the executive session. Conn. Gen. Stat. § 1-231(a).
Executive Sessions: Requirements
• Executive sessions may only be called for the limited
statutory purposes set out above
• Only discussion is permitted in executive session;
any votes must be taken in open session
There should not be a vote taken to come out of executive
session
• Minutes must include the vote to go into executive
session; the reason for the executive session; and,
the names of the persons in attendance at the
executive session (subject to limited exceptions)
Executive Session
• The Nutmeg Board was in a special budget meeting when it
learned of dire economic news that meant significant staffing
cuts were necessary. Knowing that the Board would need to
discuss and decide the elimination of specific positions, and
not wishing to needlessly distress or excite its employees,
the Chair added an executive session item to the agenda to
discuss “personnel matters.” With a 5-3 vote, the Board
entered executive session. After an hour of discussion, the
Board members agreed, without a vote, to direct the
Superintendent to cut 10 staff positions. So far, so good?
Executive Session
• Not an agenda item, but a means of dealing
with an agenda item
• Specify who is invited into executive session
• Board does not take action in executive
session
• Board members are not to disclose discussion
which occurs in executive session
• Be respectful of the public when scheduling
executive sessions
Meeting Requirements
• Minutes: Generally, minutes must be available for public
inspection within seven (7) days of session to which they
refer, Conn. Gen. Stat. § 1-225(a), and minutes should include:
When the meeting was convened;
Which members of the public agency were present;
A short description of the business transacted;
A listing of any action taken by the public agency,
specifying the votes of each member;
Any executive session held, with a statement of the
reason(s) for the executive session and who was in
attendance; and
When the meeting was adjourned
Meeting Requirements
• Agendas: - There is no specific guidance in the FOIA
as to the level of detail that is required in an agenda,
but, as a practical matter, the agenda should provide
reasonable notice of the business to be transacted
• Votes: - The votes (as distinguished from meeting
minutes) of all members of the public agency must
be reduced to writing and be available for public
inspection within 48 hours of the meeting
Who Can Call a Meeting?
• Board Member Mal Content has been after the Nutmeg Union
of Teachers for the last two years because they refused to give
salary concessions during these difficult times. He has been
asking to put an item on the agenda for a public meeting,
during which the Board would consider a formal censure of
the union and its membership. You, the Board Chair, have
been advised that such a vote could be problematic. But Mal
is persisting, and now he and two fellow Board members he
co-opted are threatening to hold a public meeting with or
without you. Can he do this?
Requirements for Calling a Meeting
• Conn. Gen. Stat. Section 10-218 provides in relevant part:
The chairperson of the board of education or, in case of
such chairperson's absence or inability to act, the
secretary shall call a meeting of the board at least once in
six months and whenever such chairperson deems it
necessary or is requested in writing so to do by three of its
members. If no meeting is called within fourteen days after
such a request has been made, one may be called by any
three members by giving the usual written notice to the
other members.
Board Member Conduct
• Board member, Mal Content, had been causing
issues for the Nutmeg Board. He would often visit
school buildings unannounced, demanding to be
able to visit classrooms to “check on
underperforming teachers.” But the last straw for
the Board was when he voted to approve the new
teachers’ contract, even though his wife was a
teacher in the district. In a special meeting, where
Mal was not in attendance, they voted 8-0 to oust
him from the Nutmeg Board. Valid?
Board Member Conduct
• Board members cannot be removed from
their elected position on the Board by a
vote of the Board
• Board officers can be removed from their
office by a vote of the Board
• The Board can vote to “censure” a Board
member
Conflict of Interest
• Board members cannot be employed by the
school district
• No statutory provision against a relative
being employed by the school district
• Board member actions may be governed by
Board policies or ethics provision in local
charter
• Board members may need to recuse
themselves from impartial BOE hearings
Board Member Conduct
• Board member, Pamela Parent, has concerns that
her child is being bullied at Charter Oak Elementary
School. She visits her daughter’s school
unannounced, demanding to be able to visit her
daughter’s classroom, cafeteria and playground to
“check on schoolyard bullies.” She regularly refers
to the specific observations she has made in her
public statements made to the Board as part of
Board discussions of school climate. Concerns?
Board Member Conduct
• Concerned that her daughter may have a social
communication disability, and this is making her
vulnerable to the “bullies” at Charter Oak, Pamela
Parent emails Peter Principal and requested an
evaluation of her child for a disability. After the
evaluation is complete, the Planning and Placement
Team determines that Pamela’s daughter does not
qualify for special education and Pamela threatens
to sue the Board. Concerns?
Records: A Brief Overview
• The FOIA defines “public record” broadly as follows:
A public record or file is defined as any recorded data
or information relating to the conduct of the public's
business prepared, owned, used, received or retained
by a public agency, whether such data or information
be handwritten, typed, tape-recorded, printed,
photostatted, photographed or recorded by any other
method. Conn. Gen. Stat. §1-200(5).
Records
• Except as otherwise provided by any federal or
state law, all records maintained or kept on file by
any public agency shall be public records.
• The FOIC has no authority to order a public agency to
create records where none exist
• The FOIA does not require a pubic agency to conduct
legal research or to respond to questions. However,
“research” or searching to locate public records is
always required!
Responding to Records Requests
• There should be a clear process in place for processing and
responding to FOI requests (including a designation of the
individual(s) responsible for responding).
• Disclosure must be made "promptly." “Promptness” will turn on
the nature and extent of the specific request.
• A person making a request is generally entitled to a response
within four business days. (If the request involves employee
personnel or medical files and the agency reasonably believes an
invasion of privacy would occur, a response must be made within
ten business days, and special notice requirements apply).
• However, that does not mean the public agency automatically has
four days to respond to a request. If a record is readily available
for inspection or copying, it is an FOI violation to make the person
requesting the record wait four days.
FOIA Exemptions from Disclosure
There are several specific exemptions to the general
rule requiring disclosure of public records. See Conn.
Gen. Stat. § 1-210(b). The following are examples from
the complete list of exemptions:
• Records exempt from disclosure under federal or
state law (e.g. Section 10-151c of the Connecticut
General Statutes, which exempts teacher evaluation
records from disclosure)
• Education records not subject to disclosure under
the federal Family Educational Rights and Privacy Act
(FERPA)
FOIA Exemptions from Disclosure
• Personnel or medical files and similar files, the disclosure of
which would constitute an invasion of personal privacy.
• Note: The legal standard for invasion of privacy is very strict:
1) the record at issue does not pertain to a matter of public
concern, and; 2) disclosure of the record would be highly
offensive to a reasonable person.
• Communications privileged by the attorney/client relationship
• Records, reports and statements of strategy or negotiations
with respect to collective bargaining
• Records pertaining to strategy and negotiations with respect to
pending claims or litigation to which the public agency is a party
until such litigation or claim is finally adjudicated or settled
FOIA Exemptions from Disclosure
• Test questions, scoring keys and other data used to administer a
licensing examination, examination for employment or academic
examinations
• Responses to any request for proposals or bid solicitation issued by
a public agency, or any record or file made by a public agency in
connection with the contract award process, until such contract is
executed or negotiations for such award have ended, whichever is
earlier, provided the chief executive officer of such public agency
certifies that the public interest in disclosure of such records is
outweighed by the public interest in the confidentiality of such
records
• Preliminary drafts or notes provided that the public agency has
determined that the public interest in withholding such documents
clearly outweighs the public interest in disclosure
FOIA Exemptions from Disclosure
• However, “disclosure shall be required of: interagency or intra-
agency memoranda or letters, advisory opinions, recommendations
or any report compromising part of the process by which
governmental decisions and policies are formulated, except
disclosure shall not be required of a preliminary draft of a
memorandum, prepared by a member of the staff of the public
agency, which is subject to revision prior to submission to or
discussion among the members of such agency.”
• Informal advice from the FOIC staff indicates that if the personal
notes are an agency member’s own notes, thoughts, etc., and are
not disseminated to other members of the agency, they may not
be subject to disclosure
General Confidentiality Considerations
• The district must comply with all legal requirements
concerning confidentiality (e.g., FERPA)
• Matters discussed in executive session should be
maintained as confidential unless the Board authorizes
disclosure of the information
• Disclosure of confidential information can have
significant consequences for the district (e.g., legal
violations, increased liability, compromised position
regarding negotiations)
• When in doubt, treat the information as confidential
until a proper determination has been made regarding
confidentiality vs. disclosure
Electronic Communications
• It was time for the Nutmeg Board to elect officers. In the
week leading up to the annual meeting, the internet was
full of e-mails among Board members soliciting support
from other members. In addition, Board members had
caucused with their respective party Chairs to decide on
who would be the next chair. At the meeting, Mal Content
nominated Penny Pincher as the next Chair. Infuriated, Bob
Bombast sent an angry text message to Mal saying, “What
gives, I thought we had a deal?” Mal responded, “Sorry,
Penny is supporting me for Vice-Chair. Snooze you lose.”
Any issues?
Which statement is correct?
1. It is improper for Board members to
commit support on an issue before
the actual meeting
2. A majority of Board members
cannot discuss Board business via e-
mail
3. E-mail communication between
Board members is okay as long as it
is one-on-one
4. Board members cannot caucus to
discuss Board issues
Electronic Communications
• Email communication on Board business by
Board members to each other (or to or from
the Superintendent to Board members) is
permissible.
• Such emails will typically be subject to public
disclosure unless exempt (personally
identifiable student info, attorney/client
information). Even if on personal computer or
personal email.
Electronic Communications
• Where email communication is unilateral, it
will likely not be considered a “meeting” that
would trigger FOIA concerns.
• Where such a communication generates
responses that are shared with a quorum of
the Board, it is possible that a “discussion”
(and hence a “meeting” in violation of the
FOIA) will be found
Who Speaks for the Board?
• Each Board’s bylaws should state who the
Board’s spokesperson is
• Generally, it is the Board’s chairperson
• Board members do not lose their first
amendment rights
Handling Personnel Matters
Impartial Hearing
• Under Connecticut General Statute 10-151, all teachers have
certain due process rights, including to a hearing before an
impartial hearing panel
• The Board may serve as that panel
• As a result, to preserve the impartiality of the Board
members, they should not become involved in the details of
an individual employee’s performance
• Connecticut General Statute 10-222 provides due process
protections to athletic coaches who have coached a sport for
at least 3 consecutive seasons
• They may appeal any decision not to renew, or to terminate,
their contracts to the Board of Education. The Board must
conduct a hearing and sit as an impartial panel.
Due Process Violations
• A Board may violate an employee’s due process
right to an impartial hearing by reviewing a
personnel file prior to a hearing.
• Obtaining other evidence of an employee’s
performance prior to the hearing.
• Discussing the employee’s performance with
other Board members outside of the context of
a termination or non-renewal proceeding.
Communication with the Public
General Preparedness
• Districts should have procedures/practices for handling
sensitive communications.
• The district may want to develop a “response team” that
designates who is responsible for:
Speaking on the district’s behalf
Coordinating with outside agencies if necessary
• The district should establish clear lines of communication
for decision-making for various situations, such as
Responding to law enforcement investigations
Closing of a building
Shutting down of a computer system
Handling onsite medical emergencies
General Preparedness
Districts may also want to include directions for
Board members on:
• When and how to communicate with the
community at large, the press, parents, and/or
staff
• Developing steps for dealing with the press
and public
Dealing with Parents and Staff
• Determine whether the Board should make a statement
at all, or whether the matter should be left to an
administrator
• Determine the subset of persons, if any, who should be
notified of an event/crisis
• Promptly address immediate safety and educational
concerns
Be sure not to reveal any FERPA or IDEA-protected or other
confidential information
Consider what resources, if any, may be necessary to assist
with student needs and parental concerns
Consider the appropriateness of a school community
meeting
Dealing with Parents and Staff
• Communicate, as appropriate, the school
district’s next steps
• Identify and provide contact information of a
school or district-based contact person to
address follow-up concerns and questions
• Prepare staff to deal with media inquiries
Dealing with the Press
• Investigative reports and related documents must
be disclosed, if requested, when the investigation
is complete
• Personnel records are pubic records unless they
fall under a specific exception
• Maintain a positive relationship with local press
and work with local media prior to a crisis
• Designate an individual to handle media inquiries
• Fulfill FOI requests promptly if possible
Handling Student Issues
Family Education Records Privacy Act
• While the Board is ultimately responsible for setting
policy that will affect each student within the district,
individual students have privacy rights guaranteed by
FERPA
• Federal law that applies to recipients of federal funds
(e.g. public schools, colleges and universities)
• Protects the confidentiality of student education
records/limits disclosure to 3rd parties without parental
consent
• Provides parents/guardians with a right to access
student records of their children
What is an Education Record?
• Any documented information directly
relating to a student and maintained by the
educational institution
• May include documents, video, audio, film,
photographs or computer records
• School districts must maintain the
confidentiality of any personally
identifiable student information contained
in educational records
The Interaction Between FOI and FERPA
• The Freedom of • The Family Educational
Information Act Rights and Privacy Act
(“FOIA”) (“FERPA”)
• State law • Federal law
• Mandate: records must • Mandate: records are
be disclosed, unless confidential, unless
there’s an applicable parent consents or
exception there’s an applicable
exception
The Interaction Between FOI and FERPA
• FOI Statute: Except as otherwise provided by
any federal or state law, all records
maintained or kept on file by any public
agency shall be public records
• Records protected by the Family Educational
Rights and Privacy Act (FERPA) are exempt
from disclosure under the FOIA
Personally Identifiable Student Information
• Personally identifiable student information
also includes information that is linked or is
linkable to a specific student that would allow
a reasonable person in the school community
to identify the student with reasonable
certainty
Targeted Requests
• Even if the request or disclosure does not
include explicit personally identifiable student
information, a district may not release
information if requested by someone who the
district “reasonably believes knows the
identity of the student to whom the
education record relates”
Confidentiality
• As a general rule, all personally identifiable
information in educational records must be kept
confidential unless a parent/guardian or eligible
student consents, in writing, to disclosure
• Written consent must:
Specify which records are being disclosed
Specify the purpose of disclosure
Identify the recipient
• Exceptions to this general rule are outside the
scope of this presentation but can be found at
www.ct.gov/foi/.
When is Prior Written Consent Not Required?
• When disclosure is to a school official, where that person
has a legitimate educational interest in the information
Who is a school official?
Must be under direct control of district
Must perform an institutional service/function
Access only to information needed; and used only for that
purpose
Annual notification requirements
District must use reasonable methods to ensure that
school officials have access only to those records in
which they have a legitimate educational interest
Consent Not Required
• When a student moves to another school
district, records may be sent to the receiving
district
• In a health or safety emergency
May consider “totality of circumstances”
Must have an articulable and significant threat to
the health/safety of the student or others
May disclose to “appropriate parties,” including
parents
Recording requirement
Consent Not Required
• For directory information
District must give public notice of what qualifies
as directory information
Right to opt out
May include: name, address, tel. #, email
address, photo, DOB, participation in athletics
etc.
May NOT include social security numbers
• In response to a court order or subpoena
Consent Not Required
• Records that have been de-identified (i.e. the
personally identifiable student information
has been removed) may also be released
without prior written consent
(Reminder: personally identifiable information includes
information that alone, or in combination, is linked or linkable
to a specific student that would allow someone in the school
community without personal knowledge to identify the
student with reasonable certainty)
Consent Exception
• To parents of an eligible student (18 yrs +) if
the parents still claim the student as a
dependent for tax purposes
• To representatives of a child welfare agency
(DCF) if it is legally responsible for the
care/protection of the student
Communications Regarding Student Matters
• FERPA significantly restricts the district’s
ability to communicate on student matters
FERPA prohibits disclosure/discussion of matters
identifiable to an individual student
Comment by the parent of a student does not
permit the district to comment on matters related
to that student
Communications Regarding Student Matters
• Importance of centralized communication
• General statements regarding district’s
commitments to student safety/wellbeing
• No communications regarding identifiable
students
Questions?