PAP.7.8.210 Policy on Appropriate Personnel-Student Communication and Professional Boundaries

(a) Authority. This policy is enacted pursuant to the inherent sovereign authority of the Lac Courte Oreilles Band of Lake Superior Chippewa Indians in the implementation of Title XII, Chapter 3 of the Lac Courte Oreilles Band of Lake Superior Chippewa Indians Tribal Code of Law (LCOTCL) – Employment Code and Title VII, Chapter 7 of the LCOTCL – Education Code. This policy is not enacted as an acknowledgment that Wis. Stat. 118.07(7) governs the Tribe or its schools.

(b) Purpose. The School is committed to providing a safe, respectful, and culturally supportive educational environment where every student can learn free from abuse, exploitation, intimidation, or inappropriate influence. Consistent with the mission of the School and the Ojibwe values of respect, responsibility, and protecting our children, this policy establishes expectations for professional communication and conduct between individuals acting on behalf of the School and students.

(c) Scope. This policy applies to any personnel acting on behalf of the School who occupies a position of trust or authority with respect to a student or otherwise interacts with students in an official school capacity

(d) Definitions.

(1) "Boundary Violation" means conduct that blurs or exceeds professional expectations or creates an inappropriate personal relationship with a student.

(2) "Grooming" means a pattern of behaviors intended to gain a student's trust, isolate the student, reduce normal protective boundaries, or prepare the student for exploitation or abuse. Grooming behaviors may occur in person or through electronic communications and often involve attempts to establish secrecy, isolate a student, or blur professional boundaries.

(e) Approved Methods of Communication. Personnel shall use school-approved communication systems whenever reasonably possible.

(1) School Gmail;

(2) Google Chat using School accounts;

(3) Google Meet;

(4) Infinite Campus Messaging;

(5) School-approved athletic communication platforms;

(6) School-issued phones; and

(7) Other technologies approved by the School Superintendent;

Communications conducted through School systems may be retained, monitored, and reviewed in accordance with applicable law and School record-retention practices.

(f) Prohibited Communications. School Personnel shall not:

(1) Develop secret relationships with students;

(2) Ask students to keep communications secret;

(3) Engage in flirtatious or romantic communications;

(4) Share sexually explicit or inappropriate material;

(5) Request or send inappropriate photographs;

(6) Communicate through disappearing message applications;

(7) Engage in repeated personal conversations unrelated to professional roles or responsibilities; and

(8) Communicate in a manner intended to isolate a student from parents, guardians, or school personnel.

(g) Reporting Requirements. Personnel who observe, suspect, or receive information concerning grooming behavior, boundary violations, or inappropriate communications shall immediately report the concern to:

(1) The Superintendent, Principal, Human Resources Director, or other designated Administrator; and

(2) Appropriate child protection authorities when required by law.

Nothing in this policy limits mandatory reporting obligations under Tribal, State, or Federal law. Individuals making reports in good faith shall be protected from retaliation.

(h) Investigation. The School Superintendent or designee shall promptly investigate all reported violations. Investigations shall:

(1) Respect due process;

(2) Protect student privacy;

(3) Maintain confidentiality to the extent permitted by law; and

(4) Be documented.

Criminal allegations shall be immediately referred to the appropriate law enforcement agency.

(i) Discipline. Violations of this policy may result in disciplinary action including:

(1) Verbal counseling;

(2) Written reprimand;

(3) Mandatory retraining;

(4) Performance improvement plans;

(5) Removal from coaching or extracurricular duties;

(6) Suspension;

(7) Non-renewal;

(8) Termination of employment;

(9) Revocation of volunteer privileges;

(10) Referral to law enforcement; and

(11) Reporting to licensing authorities when required.

Discipline shall be based upon the seriousness of the violation, prior conduct, and applicable law. Nothing in this policy limits the School's authority to impose disciplinary action for conduct that violates other school policies or applicable law.

(j) Annual Training. Beginning with the 2026-2027 school year, all personnel shall complete annual training covering:

(1) Grooming behaviors;

(2) Professional boundaries;

(3) Appropriate Communication;

(4) Student Safety; and

(5) This policy.

Training records shall be maintained by Human Resources.