Required Annual Training

(Module 1)�2025 - 26 School Year��This training must be completed by

August 29, 2025 by all active employees

Telluride R-1 School District

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Contents

• Confidentiality (FERPA)

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• Cybersecurity and IT

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• Section 504 and IEP Plans

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• Expectations for Use of Social Media
• Mandatory Reporting for Known or Suspected Child Abuse or Neglect
• Title IX Sexual Discrimination
• Harassment, Bullying, and Hazing
• Employee Handbook
• Bloodborne Pathogens
• Certifying your completion of Module 1

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• We are legally and ethically obligated to protect the privacy interest of students and their families
• We are not permitted to share educational record information and/or personally identifiable information without the permission of parents or guardians
• The only staff with the right to see student information are those with a “legitimate educational interest”

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Confidentiality (FERPA)�Family Educational Rights and Privacy Act �Federal Law: 20 U.S.C. § 1232g; 34 CFR Part 99�

Confidentiality (FERPA)�Definitions�

"Personally Identifiable Information" includes, but is not limited to:

(a) The student’s name;

(b) The name of the student’s parent or other family members;

(c) The address of the student or student’s family;

(d) A personal identifier, such as the student’s social security number, student number, or biometric record;

(e) Other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name;

(f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or

(g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.

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“Educational Records” are defined as records which:

(a) Directly relate to a student; and

(b) Are maintained by an educational agency or institution or by a party acting for the agency or institution.

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FERPA: Situations to Remember�

• If outside services call to discuss a student, a parent/guardian must sign a “release of records form” before there is ANY conversation about the student.
• Do not discuss students in open areas of the school when others are around who do not have a legitimate educational interest.
• Do not discuss students in public places: grocery stores, restaurants, etc.

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FERPA: Email Is Not Confidential�

Although email may seem private, sometimes it isn’t!

• To the greatest extent possible, use student initials in emails, not names.�To the greatest extent possible, do not use email at all to discuss sensitive issues.�To the greatest extent possible, do not include disability or students’ �personal information in email.
• Fax is considered secure. Fax large documents or any documents with sensitive details (such as IEPs or transcripts)
• “Don’t put anything in an email that you do not want to see on the front page of the newspaper with your name attached!”

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FERPA: Policy JRCB�

Policy JRCB -

Privacy and Protection of Confidential Student Information

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Please review this policy in its entirety

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Additional Resources for Confidentiality and FERPA

Colorado Department of Education FERPA Resource Page

Family Education Rights and Protection Act (US-DOE)

Forum Guide to Protecting the Privacy of Student Information: State and Local Education Agencies (US-DOE)

TSD Policies JRA/JRC, JRCA, JRCB-R

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TSD Cybersecurity

Passwords & MFA

Did you know that eight-character passwords with uppercase and lowercase letters, numbers, and special characters can be cracked in 5 minutes?!

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A 12-character password of the same complexity? 226 YEARS!

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When making passwords, remember:

• Use a combination of numbers, letters, and special characters.
• Make it long! 12-20 characters is ideal.
• Never recycle or reuse passwords across accounts!
• Don’t use personal information or common words (password, admin, etc.) as passwords. Family names, pets, and birth years all make poor passwords.

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Also, keep your passwords safe by utilizing a tool like a password manager. Passwords are the lock and key that prevent cyber criminals from breaking into sensitive files. Do your best to keep your accounts safe, meaning:

• Don’t write down usernames and passwords
• Don’t give account information to your friends
• Don’t reuse credentials across multiple accounts

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Utilize an Authenticator Application for Extra Security

Your phone number is no longer secure enough as your only method of authentication. Because of this, teachers and staff will be required to use an authenticator app (starting Fall 2025). Follow the Microsoft Authenticator Instructions for early set up!

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TSD Cybersecurity

Sensitive Data

Telluride School District relies on YOU to keep its sensitive data safe; don’t let them down! If sensitive data gets in the wrong hands, it can be catastrophic for everyone. Remember the tips provided and keep those secrets safe!

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What is Sensitive Data?

Sensitive data includes PII, PHI, PCI, and data covered by COPPA and FERPA. These data security standards outline the types of information that must be protected, including personal identification numbers, medical records, credit card details, and information about children under 13 (COPPA) or 18 (FERPA), to ensure confidentiality and prevent unauthorized access.

Use Sensitive Information with Care!

Be thoughtful about how you work with sensitive data; one careless move and your whole organization could be compromised.

• Use the Need to Know Principle. Does this person need this information in order for them to do their job?
• Never discuss sensitive data where unauthorized ears can hear.
• Never leave sensitive data lying around unattended.
• Always lock your computer when leaving it unattended.
• Shred or lock away sensitive data when not in-use. Delete files you no longer need.

Is This Who I Think It Is?

Sometimes the easiest way for a cybercriminal to get access to sensitive information is simply by asking.

• Be skeptical of anyone contacting you using unusual methods or who claims to be a co-worker and asks for sensitive information.
• If you aren’t sure of a person’s identity, always cease communication and contact them via a method you know is legitimate.

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TSD Cybersecurity

Phishing

Phishing is when a cybercriminal uses email to trick you into giving them private information or taking a dangerous action. The consequences of falling for a phishing email can be catastrophic. Protect yourself and our organization by learning these signs of phishing emails!

Mysterious Messages

Phishing emails often appear to come from someone you know or trust. But they can also come from unknown senders. Always check the sender’s email address and make sure it matches the trusted source email address. If the email address matches a trusted source, but the message is still suspicious, report it. The account could be compromised, or the email address could have been spoofed.

Urgent Demands

Phishing messages often direct you to take action immediately, implying that something negative will happen if you don’t. These messages are meant to get you to react before you think. Always stop and think before taking an action. Does the request make sense?

Sneaky Links

One of the most common signs of phishing is the request to open an unexpected link or attachment. Malicious links or attachments can be used to steal your login info or other data. Never open links or attachments from unknown or suspicious senders. If you need to sign in to a website, go directly to the known, legitimate address.�

Before taking an action, stop, look, and think!

Does it seem suspicious, out of place, or just strange? Then report the message and delete it immediately!

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TSD Cybersecurity

Anti-Malware Software

There are different procedures for each device to scan for and detect malware. Regardless of which OS you have, general tips for protecting your device from malware are:

• Monitor your computer’s activity by using Task Manager (Windows OS), Activity Monitor (Mac OS), or the search and escape keys (Chrome OS)�
• Check browser extensions and Downloads: Review your browser extensions and downloads and remove any suspicious ones. �

Windows OS - Microsoft Defender

Microsoft Defender is a built-in Windows software that provides virus and threat protection, account protection, firewall and network protection, app and browser control, and device security.

Mac OS - XProtect

XProtect works silently in the background and does not have a user interface. XProtect is updated automatically and uses signature-based detection.

Chrome OS

Chrome OS has built-in antivirus protection, which includes sandboxing and verified boot, and makes it highly resistant to viruses and malware.

District Anti-Malware

The District uses its own anti-malware on all district-managed devices. The District has strong cybersecurity policies and practices in place to prevent data leaks and cyberattacks.

Always Look for Unusual Activity

Is your computer behaving abnormally? Then disconnect it from the network, and report it to IT.

TSD Cybersecurity

Clean Desk and Clear Screens

• Log off your computer when you are not in your workspace and at the end of the day
• Position your computer screen to protect the confidentiality of the Information. If moving your monitor is not possible, consider using a privacy screen or filter.
• Lock your screen when leaving your workstation. On Windows OS devices, use the Windows key + L. On Mac OS devices, use Control + Command + Q keys. On Chrome OS devices, you can use the Search + L keys.
• Lock your portable computing devices (e.g., laptops, tablets) in a drawer or cabinet when you are not at your workspace or at the end of the workday.
• Secure portable media (e.g., CDs, DVDs, unencrypted USB or external drives) containing sensitive information with encryption or store the media in a secure location (i.e., locked drawer, locked cabinet).
• Do not leave paper containing TSD Sensitive Data unattended on your desk, especially if you are going to be away from your desk for an extended period (e.g., lunch breaks, meetings).

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TSD Cybersecurity

Physical Security Guidelines

• Report suspicious persons on school grounds. This will prevent a stranger from installing rogue devices on the network or gaining access to our servers.

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• Keep server rooms secure. Lock rooms with servers and other available tech equipment.

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• Do not plug in unauthorized devices to the network (i.e. home printers). This protects our network from viruses that could be downloaded via un-updated software.

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• Keep student devices secure. Lock computer carts at the end of the day or when not in-use.

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• Keep accounts separate. Try to limit the accounts that you are logged into on your work device. Use your work device for work.

TSD Cybersecurity

Securing TSD WiFi Networks

Protect sensitive information, prevent unauthorized access and safeguard from cyber threats by utilizing the appropriate WiFi Network.

• TSD is for all school-managed devices.
• TSD-Staff is for staff mobile devices.
• TSD-Student is for 10th-12th grade students with a BYOD (Bring Your Own Device).
• TSD-Guest is only for 3rd party users, such as vendors, consultants, and sub-contractors with prior approval.

TSD Cybersecurity

BYOD (Bring Your Own Device)

BYOD devices can introduce new vulnerabilities to our system. Therefore, all BYOD devices are subject to the same IT and cybersecurity controls as school managed devices.

Permitted BYOD Users

• High School Students beginning in 10^th grade.
• Third Party users, such as vendors, consultants, select sub-contractors (with prior approval) are expected to bring their own device to perform services as directed by the school.
• Select Staff – Most TSD staff and teachers are not permitted to connect their non-school provided and non-school managed devices to campus or connect to school networks offsite (not including mobile devices). However, an exception to this standard can be pursued for pre-authorized staff and teachers through an Exception Request.

Acceptable Use Considerations

• No expectation of privacy when connecting to school networks
• Some web traffic will be blocked
• Any electronic communications (including personal ones) when sent on school networks are considered public records
• BYOD device staff users must adhere to Security, Unauthorized and Unacceptable Use, Confidentiality, Use of Social Media, Vandalism and Unauthorized Software terms

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TSD Cybersecurity

Safely Working Off School Grounds

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Identify and secure your physical workspace.

Find a space that allows you to maximize your productivity. It should be comfortable and have minimal distractions.

• Am I using a clean-desk policy where I secure work-related items like printed material or devices when not in use?
• Can I shred important documents I no longer need?

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Be Cautious of free Wi-Fi Connections

Coffee shops, libraries, and even public parks often offer Wifi connections that can be conveniently used to connect to the office as well as the internet. These Wifi connections are typically insecure, and a great way for hackers to see what you are doing online.

• Never connect to public Wifi unless you are using an organization-approved VPN, such as NordVPN. This technology creates a safe Internet connection that shields your online activity from criminals.
• VPNs and proxy servers should not be used on school campuses, and offenders may be faced with serious consequences.

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Keep your work and personal life separate.

This is easier said than done when you are working from home, especially if it’s because of an unexpected event. However, from a security standpoint, the more you can do this, the better.

• Am I making sure my work device isn’t used for personal activities?
• If I have to use my personal device for work, have I tried to keep things separate?
• Keep work and personal accounts separate (ex. Google)

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Notify the Tech Department if you are traveling, and follow our TSD Cybersecurity Safe Travel Tips

TSD Cybersecurity

Software Request Guidelines

Besides COPPA, CIPA, HIPAA, and FERPA, in Colorado, the primary law governing student data privacy is the Student Data Transparency and Security Act (HB 16-1423), which requires careful research for deciding which software vendors to use. The recent Colorado accessibility law, HB21-1110, also requires districts to ensure that the software they provide is accessible to students and staff.

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Student Data Privacy Guidelines��The IT Department initiates Data Protection Addendums (DPAs) with software vendors, and the IT team evaluates each software based on certain factors, such as:

• Types of information asked for
• Whether a software sells a user's data to third parties
• Whether marketing communications are sent to users are from an application or service that a user does not have a direct relationship with
• Whether advertisements are displayed to any users based on collected personal information
• Whether the company allows third-party companies to use cookies and whether users can opt-out of it
• Whether it enables a third party to display advertisements to the product's users on other apps and services across the Internet
• Whether or not a product creates an advertising profile�

Accessibility Guidelines��Software and other service providers are also evaluated for accessibility. Besides being checked with an accessibility checker, software vendors should show a commitment to accessibility through a statement, stated/included features on their website, and/or VPAT reports. The IT team may make recommendations for more accessible software in accordance with CO law as contract renewals come up.

TSD Cybersecurity

Software Request Guidelines

Because of the new requirements for the software used by Colorado school districts, software requests are evaluated in a few ways: by student data privacy, accessibility, and general IT and cybersecurity considerations.

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IT General Considerations

• Does app exist in Google Play, Apple App or Microsoft Store?​
• Licensing agreement considerations​
• Does the app or website introduce a new cost to the organization?​
• Authentication Schema – Does request require a new authentication schema to be developed? If so, processing time may exceed 2 week completion time.​
• Does the app or website introduce new Cyber risk to the organization? If so, route to Cyber team.​
• Does business justification exist? If not, re-route to teacher through tech coach​
• Any business justification, licensing or cost considerations can be escalated to IT Director ​�

Cybersecurity General Considerations​

• Country of origin – Check embargoed countries list​
• Does the request introduce new or additional risk to the organization? If so, can additional mitigation mechanisms be put in place to remediate risk?​

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To request to use a new software app or software requiring sign-in, fill out the form linked on the TSD website.

TSD Cybersecurity

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By completing the Certification on the last slide of this training module, you agree to comply with Policy GBEE - Staff Use of Technology.

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By completing the Certification on the last slide of this training module, you also agree to comply with the cybersecurity policies and standards linked below:

• P-001 Account and Credential Management Policy
• P-002 Secure Configuration Management Policy
• P-002 Security Awareness Training Management Policy
• P-004 Enterprise Asset Management Policy
• P-005 Cybersecurity Exception Policy
• P-006 Enterprise Asset Management Policy

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TSD Cybersecurity

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Report an incident or

have a question?

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Email our help desk!

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Requirements for IEP and 504 Students

• Section 504 of the Rehabilitation Act of 1973 is a civil rights statute that is in place to protect the rights of qualified individuals with disabilities against discrimination in programs and activities that receive federal financial assistance. Specifically, a Section 504 Plan lists accommodations needed to allow a student with disabilities the opportunity receive educational services that are as adequate as the educational services provided to their nondisabled peers.
• Title II of the Americans with Disabilities Act (ADA) is part of a civil rights statute that is in place to protect the rights of qualified individuals with disabilities against discrimination in programs and activities provided by state and local governments. Specifically, under Title II of the ADA, a student with disabilities must be provided aids, benefits, and services which are as effective as the aids, benefits, and services provided to others. Aids, benefits, and services provided to students under Title II are listed as accommodations in the student’s 504 Plan.

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Requirements for IEP and 504 Students

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• The Individuals with Disabilities Education Act (IDEA) is a law that makes available a Free Appropriate Public Education to eligible children with disabilities throughout the nation and ensures special education and related services to those children. An Individualized Education Plan (IEP) is the vehicle through which those special education services are defined and delivered.
• Students who are eligible under IDEA are also eligible for accommodations under Section 504 and Title II, and their accommodations are usually incorporated into the IEP. For students who are not eligible under IDEA but meet the criteria under Section 504 and/or Title II, a Section 504 Plan is created.

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Requirements for IEP and 504 Students

• For any student, the “Other Alert” flag in PowerSchool will tell you if that student is on a 504, IEP, or other plan.
• Every staff member working with a student on a 504 or IEP Plan is responsible for knowing that student is on a plan and for being familiar with that plan, and is legally required to follow all accommodations and modifications in that plan.
• Any questions or concerns with an IEP or 504 Plan’s accommodations or modifications should be addressed with a student’s case manager immediately, while the plan continues to be followed.

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Requirements for IEP and 504 Students

If you believe any accommodation contained in a student’s IEP or Section 504 Plan is not necessary, or is not educationally best for the student, you still need to implement that accommodation unless and until the Plan document is formally changed in a Plan review meeting.

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Requirements for IEP and 504 Students

• The IEP or 504 case manager is responsible for:
• Making sure relevant staff have access to plans
• For IEPs, a hard copy of the “IEP Snapshot” will be provided
• For 504 Plans, download a copy from Educlimber
• Scheduling and facilitating IEP and 504 team meetings as required
• Making sure parents/guardians receive procedural safeguards as required
• Making sure plans are updated and distributed as required
• Reviewing staff service logs to ensure that student is receiving required services, or otherwise follow up with staff to verify that required accommodations are being provided
• Supporting staff with any questions or concerns they have
• Supporting students and families with any questions and concerns they have

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Section 504�Reference Information

• The Section 504 case managers are:
• TES School Counselor Grades K-2
• Cela White (970-369-7113; cwhite@telluride.k12.co.us)
• TIS School Counselor Grades 3-6
• Carley Jones (970-369-7243; cjones@telluride.k12.co.us)
• TMHS School Counselor Grades 7-9
• Alex Jones (970-369-1217; ajones@telluride.k12.co.us)
• TMHS School Counselor Grades 10-12
• Jenni Ward (970-369-7154; jeward@telluride.k12.co.us)
• TSD District Nurse for any Medical Plans
• Cat Morrison (970-369-7103; cmorrison@telluride.k12.co.us)

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• The Section 504 District Coordinator is the TSD Superintendent
• John Pandolfo (970-369-1213; jpandolfo@telluride.k12.co.us)

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Telluride School District Non-Discrimination webpage

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IEP and 504�Reference Information

related to Non-discrimination

The district will take appropriate action to promptly and impartially investigate allegations of unlawful discrimination and harassment, to end unlawful behavior, to prevent the recurrence of such behavior and to prevent retaliation against the individual(s) who files the complaint and/or any person who participates in the investigation. When appropriate, the district will take interim measures during the investigation to protect against further unlawful discrimination, harassment or retaliation. No student, employee or member of the public may be subject to adverse treatment in retaliation for any good faith report of unlawful discrimination or harassment.

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District Policy Section A Foundations and Basic Committments contains the important policies that address nondiscrimination, equal opportunity, and protection from harassment and discrimination for protected categories including students with disabilities.

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Expectations for use of social media(i)

1. Expectations for all use of social media
1. TSD employees’ behavior on social media should reflect the same standards of honesty, respect and consideration they are expected to adhere to in all forms of communications and interactions.
2. Do not submit or post confidential or protected information about the District, its students, alumni, or employees. You should assume that most information about a student is protected from disclosure by both federal law (the Family Educational Rights and Privacy Act (FERPA) and state law (Iowa Code Section 22.7(1). Disclosure of confidential or protected information may result in liability for invasion of privacy or defamation and result in disciplinary action up to, and including, discharge from employment.
3. Report, as required by law, any information found on a social networking site that falls under the mandatory reporting guidelines.
4. Do not use language that could be considered defamatory, obscene, proprietary, or libelous, or that constitutes an incitement to imminent violence or a true threat.
5. Do not post or otherwise publish content that is or could reasonably be perceived as bullying, discrimination, or harassment in violation of TSD policy.

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Expectations for use of social media (II)

1. Expectations for all use of social media (continued)
1. Exercise caution with regards to exaggeration, colorful language, guesswork, copyrighted materials, legal conclusions, and derogatory remarks or characterizations.
2. Consider whether a particular posting puts your professional reputation and effectiveness as a TSD employee at risk.
3. Be cautious of security risks when using third-party applications within a social media site.
4. Run updated malware protection to avoid infections of spyware and adware that social media sites might place on your personal computer.
5. Be alert to the possibility of phishing scams that arrive through a social media site.

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Expectations for use of social media (III)

II. Expectations for the personal use of social media

In addition to Section I, above, employees using social media for personal (non-District- related) purposes are expected to:

• Refrain from accepting current TSD students as “friends” on personal social media sites.
• Be aware that people classified as “friends” have the ability to download and share your information with others.
• Remember that once something is posted to a social media site it may remain available online even if you think it is removed.
• Assume that anything you post to a personal social media site can be accessed by anyone and will be available forever.
• Sharing school or District social media posts to your personal social media page (i.e. re-sharing a TSD Facebook post) is acceptable and encouraged if it is something of interest to you.

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Expectations for use of social media (IV)

II. Expectations for the personal use of social media (continued)

In addition to Section I, above, employees using social media for personal (non-District- related) purposes are expected to:

• Set and maintain appropriate social media privacy settings. Be aware that social media sites can change their privacy policies and standards at any time, possibly exposing posts that employees believed were private to the public.
• Avoid using a social media site to post content which may be considered defamatory or obscene, and do not post content which violates copyright or other intellectual property laws.
• Never use a social media site to post information about a TSD student or employee in a way that is or could be reasonably perceived as discriminatory, harassing, or otherwise derogatory.
• Never use a social media site to post or otherwise publish confidential or protected information about the District, its students, or its employees. Disclosure of confidential or protected information may result in liability for invasion of privacy or defamation.

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Expectations for use of social media (V)

III. Expectations for the educational use of social media

In addition to Section I, above, employees using social media for educational (school or District-related) purposes are expected to:

• Comply with all District policies and state laws on the use of district-owned hardware, software and networks apply, as relevant, to the use of social media for a TSD school, class or program.
• Notify your supervisor and IT if you wish to establish a social media site for a school, class or program.
• Do NOT use a personal Facebook page for school-related purposes.
• Establish expectations for acceptable use on your social media site that are compliant with the District’s expectations for acceptable use (see student handbooks).

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Expectations for use of social media (VI)

III. Expectations for the educational use of social media

In addition to Section I, above, employees using social media for educational (school or District-related) purposes are expected to:

• Do not post anything on a school or District affiliated social media page that advocates for or against a political candidate or ballot initiative.
• Refrain from posting or otherwise publishing images that include students with parental “no permission” on file, which can be confirmed under “Other Alert” flag in PowerSchool.
• Pay close attention to the site’s security settings and allow only approved participants access to the site.
• Remember that behavior inappropriate in school or the classroom should be considered inappropriate online.
• Seek consent before using the TSD logo or school-specific logos or mascots. The use of the TSD logo should be approved by the Superintendent. The use of a school’s logo or mascot should be approved by the school principal.

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Expectations for texting with Students

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• In general, employees should avoid texting with students whenever possible.
• If a circumstance arises when texting with students is necessary, an employee should text as part of a group message and should never text directly with a single student .
• The same expectations outlined in the previous slides for social media should apply to texting.

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Mandatory reporting for known or suspected child abuse or neglect

Colorado Statute (C.R.S. 19-3-304) requires all public and private school officials and employees to report any known or suspected child abuse or neglect.

Please review the information linked below:

Reporting Child Abuse and Neglect

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Always contact your school administrator and/or school counselor immediately if you suspect or know of child abuse or neglect. They will help you with the mandatory reporting process.

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Mandatory reporting for known or suspected child abuse or neglect

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Child Abuse and Neglect Hotline: (800)-CO-4-kids

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Additional Resources for Mandatory Reporting:

Colorado Department of Education Child Protection Resources

Child Abuse and Neglect: An Introductory Manual for Professionals and ParaProfessionals

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TSD Policy JLF - Reporting Child Abuse/Child Protection

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Title IX Sex Discrimination

What is Sex Discrimination?

• Sexual Harassment – unwelcome conduct based on sex, including quid pro quo harassment, hostile environment harassment, sexual assault, dating violence, domestic violence, and stalking.
• Different Treatment – when an individual or group of individuals is treated differently because of their sex. For example, in the athletics context, if the girls’ basketball team has inferior equipment or fewer coaches than the boys’ basketball team, despite having a similar or greater number of players.
• Disparate Impact – when a facially neutral policy, rule, or practice has a disproportionate impact on students of a particular sex and the school does not have a substantial legitimate justification for using that policy, rule, or practice. For example, even if a school’s dress or grooming code is facially neutral, a particular aspect of it may result in a disproportionate amount of discipline toward one sex or the other. Or, a school might use a single criterion to identify students for a gifted program that results in many more female students being identified.

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Title IX Sex Discrimination

What is Sex Discrimination?

(continued)

• Failure to Accommodate – failure to provide a reasonable accommodation, such as breaks during class or changes in schedule, to a student who is pregnant or has a pregnancy-related condition.
• Retaliation – action by a peer or employee and aimed at interfering with a person’s rights under Title IX, including retaliation against any individual who, in good faith, makes a report or complaint, serves as a witness, or otherwise participates in an investigation or proceeding under your school’s Title IX grievance process. Title IX also prohibits retaliation against individuals for refusing to participate in your Title IX process but allows schools to require employees to participate in an investigation. Examples of retaliation include intimidation, threats, coercion, rumor spreading, ostracism, assaults, destruction of property, unjustified punishments, or unwarranted grade reductions.

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Scope of Title IX

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Sex Discrimination

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Disparate Treatment

Program Equity

Sexual Harassment

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Quid Pro Quo

Hostile Environment

Sexual Assault

Dating Violence

Stalking

Retaliation

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Title IX

Title IX Sex Discrimination

Reporting Requirements

As a school district, we must provide an educational environment free from discrimination and harassment based on sex

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All employees must report any information about conduct that may constitute sex discrimination. Your role is not to investigate or make any determinations on whether something is/is not sex discrimination.

It is only to report the conduct to the Title IX Coordinator(s):

• John Pandolfo - Superintendent
• Sue Kunz - HR Coordinator

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Title IX Sex Discrimination

Rights Related to Pregnancy

When a pregnant student informs any employee of concerns about their rights related to their pregnancy, the employee may inform the student of the Title IX Coordinator's contact information and supports available through the district:

• John Pandolfo - Superintendent
• Sue Kunz - HR Coordinator

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Supports include reasonable accommodations or modifications following an interactive process similar to the disability accommodation process. Beyond Title IX, the PUMP Act, the Pregnant Workers Fairness Act, the Pregnancy Discrimination Act, and state law have overlapping and additional requirements related to prohibited discrimination and accommodations for pregnant or parenting students and employees.

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Title IX Sex Harassment

of Employees

Sex Harassment of Employees is covered by

Policy GBAA

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Sex harassment of employees is also covered by Title IX and follows a similar grievance process.

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Name Changes

per 2024 Colorado Statute c.r.s. 22-1-145

and Policy ACA

• Students may inform the school/district of their preferred first name without altering their official name in school records
• The school/district has established procedures for making the preferred first name part of the student’s educational record and communicating this to staff
• The district may deny a preferred first name if it is vulgar, offensive, obscene, or used for misrepresentation
• All district staff must strive to use a student’s preferred first name
• Intentional or knowing refusal to use a student’s preferred first name is prohibited by law
• District staff will work with transgender students and families to maintain confidentiality of Personally Identifiable Information (PII) related to gender identity (including gender identity, legal name, or sex assigned at birth) in accordance with state and federal privacy laws

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Harassment, Bullying and Hazing

Harassment, Bullying, and Hazing are three very distinct negative actions that each have their own legal definition and reporting requirements.

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Identifying �Discrimination and Harassment in Schools

�SB23-296 Training for All School Employees

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Why we do this work

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Strong systems to prevent and respond to discrimination and harassment ensure that every student feels welcome, safe, and valued – allowing them to learn, thrive, and grow.

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Discrimination and harassment disrupts and undermines that vision for all students.

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I’m Jasmine and I’ve been dealing with harassment from a group of boys at school. They make inappropriate comments about my body, spread rumors, and follow me in the halls. Then it got even worse: a boy created a fake AI picture of me naked and texted it to his friends. I can’t sleep, I can’t focus on my classes, I am too embarrassed to tell anyone. Sometimes it feels easier to not get out of bed and just pretend I am sick. Some days, I have even darker thoughts.

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Seeing the impact

through individual narratives.

I am Carlos, and this is my brother Luis. We just got here last year and the one thing we were really excited about was joining our middle school soccer team. We went to the tryouts, and I think we did great. We’ve learned enough English that we don’t have any problems interacting with the other players. At the end, the coach typed something into his Google translate and showed us in Spanish. It said: “You boys are playing well. But come try out next year when you are fluent in English so it will be easier to communicate.”

The kids weren’t any better. There was this one kid who would walk the halls and point at any kid who looked Hispanic, tap them on the head, and say: “you’re deported,” and “you’re deported.” Another kid had a sign where he wrote “ICE” and then he’d point at us and make a pretend calling sign with his hand. It’s so hard to focus and stay motivated in school when we feel scared, anxious, and excluded.

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Seeing the impact

through individual narratives.

I’m Sean, and I’m in fifth grade. I’m one of the few Black kids in the school. When I was younger, kids said stuff they didn’t realize was offensive. Now I feel like they are learning what has the most impact on me and they are doing it intentionally. They’ve been calling me the N-word, touching my hair because they know it annoys me, and blaming me for things that I didn’t even do. The worst part is that my teacher always believes them. When I told my teacher about the N-word, he apologized but made excuses for kids, saying they don’t really know what it means. I got so angry last week, I pushed one of the bullies and I was the one that ended up with a suspension for a day.

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Seeing the impact

through individual narratives.

Why we do this work: ��Because you play a role in what happens next in each of these stories.

• Building culture in your school to make students feel safe, welcome, and valued.
• Responding in the moment to show that bullying, discrimination, and harassment are not ok.
• Reporting potential discrimination or harassment to the designated individual in your school or district and cooperating with any future investigation.
• Ensuring that a student does not experience retaliation for reporting discrimination or participating in an investigation.
• Supporting students through this process to eliminate the disruptions and harms caused by discrimination and harassment.

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And this work is required by law.

• In 2023, the Colorado legislature passed SB23-296.
• It sets a specific definition for discrimination and harassment in Colorado public schools.
• Schools must have a policy and procedure on how discrimination and harassment is reported, investigated, and remediated.
• Students and their families can file a complaint with the school or district if they are experiencing discrimination or harassment from other students or from the employees and contractors working in schools.
• It requires this training!
• These definitions and legal obligations live in Colorado Revised Statutes 22-1-143. You’ll see that citation a lot in this training.
• There are other state and federal laws on discrimination. However, this training focuses on the definitions and obligations in this state law focused on schools.

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What did the legislature require for this training?

• Recognizing harassment or discrimination, including indicators of grooming and child sexual abuse
• The appropriate immediate response when harassment or discrimination is reported to or witnessed by an employee
• Reporting harassment or discrimination to the public school or school district

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What did the legislature require for this training?

If the employee has direct supervision of students, the following:

• The public school’s procedure for responding to allegations of harassment or discrimination
• The difference between the public school’s harassment or discrimination policy adopted pursuant to this section and other federal civil rights laws as well as mandatory reporting requirements in state law
• Best practices for avoiding victim-blaming; the effect of trauma on victims of harassment or discrimination; communicating with victims sensitively, compassionately, and in a gender-inclusive and culturally responsive manner; and the impact of harassment or discrimination on students with disabilities
• The types of supportive measures available to students and the provision of effective academic, mental health, and safety accommodations for students who report harassment or discrimination

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Identifying Discrimination and Harassment

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Let’s start with the basic concept from C.R.S. § 22-1-143

[Offensive Unwelcome Conduct or Communication]

+

[Connected to a Protected Class]

+

[Meeting a Defined Standard of Harm or Impact to the Student]

=

Discrimination or Harassment under C.R.S. § 22-1-143

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Offensive Unwelcome Conduct or Communication

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Unwelcome Conduct or Communication

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Objectively Offensive

The unwelcome conduct or communication must be “objectively offensive to a reasonable individual who is a member of the same protected class.” C.R.S. § 22-1-143(1)(d)(I).

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Example: If the communication is directed toward a Jewish student, you would consider whether most individuals identifying as Jewish would agree that the communication was offensive.

Example: If the conduct is directed toward students with disabilities, you would consider whether it was objectively offensive to individuals with disabilities.

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Connected to a Protected Class

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A protected class is a group of people who are legally protected from discrimination and harassment under federal or state civil rights laws because of specific characteristics they have.

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Protected Classes Covered in

§ 22-1-143

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Meeting a Defined Standard of Harm or Level of Impact to the Student

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Harm Category #1:��Unreasonably interferes with access to a service, opportunity or benefit.

• Focus on the impact to the student.
• Did the conduct or communication have the purpose or effect of unreasonably interfering with the student’s access to their educational service, opportunity, or benefit?
• Example: Student decides not to join the robotics club after some students repeatedly make comments like: “This club isn’t for girls.” “And especially not Mexican girls.”
• Protected classes: sex, national origin.
• Harm or impact: student loses out on the opportunity to participate in the school’s robotics club.

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Harm Category #2:

Hostile Environment

• Focus on the impact to the student.
• Did the conduct or communication have the purpose or effect of creating an intimidating, hostile, or offensive educational environment?
• Note: “Petty slights, minor annoyances, and lack of good manners” do not generally constitute harassment or discrimination.

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I’m Sarah, and I’m a junior in high school. I posted on social media about freeing the hostages because I care deeply about what’s happening in Israel — my family is Jewish, and we have family and friends in Israel. I just wanted to express my feelings. But after that post, some classmates started making comments at school. It was particularly bad with one student. She told me that Hitler was justified in targeting my people. She called me names like ‘baby killer’ and told me to ‘go back to Israel.’ It has been really scary. One day she confronted me at an afterschool event, got in my face and said some truly horrible things. I had to leave. I am afraid to tell my parents or any of my teachers. I am pretending to be fine, but I am not fine. My parents are asking me why my grades have dropped. I don’t know what to do.

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Consider a hypothetical about Sarah..

What do you see and hear?

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•Conduct:

•Unwelcome and objectively offensive verbal harassment.

•Protected classes:

•Antisemitism, anti-Zionism, and anti-Israel bias can include elements of religion, national original, and ancestry discrimination.

•Meeting Standard of Harm or Impact:

•Feelings of fear and anxiety at school. She’s not ok.

•Her grades are dropping as a result.

•Had to leave an afterschool event.

•The environment is intimidating, hostile, and offensive. And it is interfering with her access to education and educational opportunities.

Harm

Category

#3:

• Was submission to, objection to, or rejection of the conduct used against the student or threatened to be used as a basis for educational decisions affecting the student?
• Was submission to the conduct or communication explicitly or implicitly made a term or condition of the student’s access to an educational service, opportunity, or benefit?

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Harm Category #3: Examples

• Retaliation is prohibited.
• A student files a complaint about a teacher repeatedly using stereotypes of the student’s protected class. Afterward, the teacher lowers the student’s participation grade and calls them “disruptive.”
• Includes “quid pro quo” discrimination. You do this for me, I will do this for you.
• A student with ADHD is told by a teacher that if they agree to not use their extra time accommodations, they can stay in the honors program.

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Now that you know more about each category, let’s loop back to the standard one more time.

[Offensive Unwelcome Conduct or Communication]

+

[Connected to a Protected Class]

+

[Meeting a Defined Standard of Harm]

=

Discrimination or Harassment under C.R.S. § 22-1-143

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What about federal laws?

• Yes! There are federal laws that prohibit discrimination and harassment in schools too.
• Title VI of the federal “Civil Rights Act of 1964” – prohibits discrimination on the basis of race, color, and national origin or ancestry
• Title VII of the federal “Civil Rights Act of 1964” – prohibits discrimination in employment
• Title IX of the Education Amendments of 1972 -- prohibits discrimination on the basis of sex
• Section 504 of the federal “Rehabilitation Act of 1973” and Title II of the Americans with Disabilities Act and the Individuals with Disabilities Act (IDEA) – prohibit discrimination against students with disabilities

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To simplify all this:

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Know our local policies!

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Both state and federal laws are incorporated into our district policies on discrimination and harassment. If you are following our policies, you should be following the law. You can always go back to our policies to remind yourself of the protected classes and the definitions and standards for discrimination and harassment under all the laws.

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To simplify all this:

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Consider: Is this a potential Title IX violation?

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This is not intended to be a Title IX training. However, it is important that you always consider first whether something could be a Title IX issue – discrimination or harassment based on sex. Get that to your Title IX Coordinator right away because the procedures to be followed under Title IX are very specific and need to be followed from the very beginning.

To simplify all this:

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Consider: Do I reasonably suspect child abuse? If yes, report first to law enforcement as a mandatory report of child abuse.

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There is some overlap between harassment and child abuse. This shows up most commonly in allegations of unlawful sexual behavior. Stop and report this to law enforcement first. Then immediately contact your Title IX coordinator if the abuse is sexual.

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Reminder: a discrimination and harassment investigation must proceed after the law enforcement investigation, even if the report to law enforcement does not result in criminal charges.

To simplify all this:

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Use your designated local experts!

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This training is designed for all employees. Some employees should have additional training on or experience with the differences between all the state and federal nondiscrimination laws and the standards and procedures associated with all those laws. Your primary role is to get the right information to the right people (always start with your administrator). Let them help you implement all the nuances.

Examples Based on Protected Classes

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Sexual Harassment: Student to Student

• Think back to our first example with Jasmine.
• Unwelcome conduct:
• Inappropriate comments about her body, spreading rumors, and making her uncomfortable by following her in the halls.
• Another student created a fake AI picture of her naked and texted it to his friends.
• Protected class: Sex
• Meeting Standard of Harm or Impact:
• Hostile, intimidating, and offensive environment.
• Can’t focus in class. Intentionally not going to school and missing out on educational opportunities and benefits. Impacting her mental health.

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Sexual Harassment: Adult to Student

A school employee has been sending an increasing number of text messages to a student. One of the texts says that a kiss might help bring the student’s grade up.

If the student shows you this text, what are your next steps.

1. Listen actively, but don’t ask the student for the whole story yet because the student will have to tell it again to a Title IX investigator.
2. You recognize this as a type of harassment under Title IX (conditioning a benefit on unwelcome conduct, a kiss). You tell the student that you are going to report this to the Title IX coordinator so they can take some immediate steps to address this.
3. Both A and B.

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Sexual Harassment: Adult to Student

A school employee has been sending an increasing number of text messages to a student. One of the texts says that a kiss might help bring the student’s grade up.

If the student shows you this text, what are your next steps.

1. Listen actively, but don’t ask the student for the whole story yet because the student will have to tell it again to a Title IX investigator.
2. You recognize this as a type of harassment under Title IX (conditioning a benefit on unwelcome conduct, a kiss). You tell the student that you are going to report this to the Title IX coordinator so they can take some immediate steps to address this.
3. Both A and B.

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Grooming can be sexual harassment

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National origin discrimination

Protects individuals based on the country they (or their family) come from, or their ethnic background. These protections extend to students who are or are perceived because of their shared ancestry or ethnic characteristics to be Jewish, Israeli, Muslim, Arab, Sikh, South Asian, Hindu, Palestinian, or any other faith or ancestry.

• Example: A group of middle school Muslim girls are being called terrorists and students are attempting to remove their hijabs.
• Example: Jewish students are exposed to swastikas on whiteboards at school and the bathroom stalls had white supremacist slogans stating conspiracy theories about Jewish people.

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National Origin: Let’s go back to the experience of Carlos and Luis.�

Coach tells the boys that they can’t join the middle school soccer team because they don’t speak English fluently.

Other kids are making comments about kids that look Hispanic getting deported. Telling Carlos and Luis that they are going to call ICE and get them deported.

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Let’s go back to the experience of Carlos and Luis.�

National origin is a protected class that covers a student’s ethnicity, ancestry, country of origin, or language background.

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The treatment of Carlos and Luis is connected to a protected class, their national origin. Why? Because the unwelcome conduct seems connected to the fact that they come from outside the United States and their first language is not English.

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Let’s go back to the experience of Carlos and Luis.�

Yes. An educational service, benefit, or opportunity includes anything offered or sponsored by a school that contributes to a student’s learning, growth, or development. It includes sports and extracurriculars.

Carlos and Luis weren’t allowed to participate on the soccer team even though they knew enough English to participate safely and meaningfully.

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Let’s go back to the experience of Carlos and Luis.�

Yes. This is the result of unwelcome conduct where kids are being tapped on the head and told they will be deported if they look Hispanic. And other kids are threatening to call ICE on Carlos and Luis.

Carlos and Luis are feeling scared, anxious, and excluded.

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Sex, gender identity, and gender expression are protected classes under Colorado law.

Title IX and Colorado state laws protect students from discrimination on the basis of the biological characteristics of sex.

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Colorado law also covers discrimination and harassment based on sexual orientation, gender identity and gender expression.

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Gender Identity

• Gender identity: “Gender identity” means an individual's innate sense of the individual's own gender, which may or may not correspond with the individual's sex assigned at birth. § 24-34-301(10), C.R.S. Transgender means the individual’s gender identity is different from their sex assigned at birth. Cisgender means the individual’s gender identity and their sex assigned at birth are the same.
• Example: A transgender student is physically assaulted and injured by students who told the student to “stop pretending you are something you are not.” They call the transgender student by the name the student used before transitioning (called “deadnaming”) and intentionally use the wrong pronouns with the student (“misgendering”).

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Gender Expression

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• Gender Expression: “Gender expression” means an individual’s way of reflecting and expressing the individual’s gender to the outside world, typically demonstrated through appearance, dress, and behavior. § 24-34-301(9), C.R.S.
• Example: A student who identifies as male and was assigned male at birth is mocked by students because he paints his nails and keeps his hair long. Some students shoved him into a locker and told him to “stop looking like a girl.”

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Sexual Orientation

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• Sexual orientation: “Sexual orientation” means an individual's identity, or another individual's perception thereof, in relation to the gender or genders to which the individual is sexually or emotionally attracted and the behavior or social affiliation that may result from the attraction. § 24-34-301(24), C.R.S.
• Example: A student is harassed because they are dating someone of the same sex.

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Religion

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• Religion: Protects individuals because of religious beliefs, practices, or lack of religion.

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• Example: A school refuses to make a reasonable accommodation for a Muslim student who asks for a space to pray during the day.

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Race and Color

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• Race: Protects against discrimination or harassment because of racial identity or characteristics.

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• Color: Protects against discrimination based on skin tone or complexion, even within the same racial group.

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• Example: A darker-skinned Latina student is harassed by her lighter-skinned peers.

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Race: Let’s go back to the experience of Sean�

Kids have been calling Sean by racial slurs. They are touching his hair because they know it bothers Sean. They blame Sean for things that happen at school and the teacher doesn’t believe Sean when he says he wasn’t responsible.

When he told his teacher about kids calling him the N-word, the teacher apologized but made excuses for kids, saying they don’t really know what it means.

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Let’s go back to the experience of Sean�

Yes. The behavior of the other students created a hostile and offensive environment for Sean at school.

The lack of action and response by the educator allowed the hostility to continue and escalate.

The choice to suspend Sean without understanding the root of Sean’s behavior only deepened the harm and deprived Sean of access to instructional time.

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Disability

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Harassment versus Bullying

What’s the difference?

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Bullying

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School bullying researchers typically define bullying by highlighting three components that differentiate it from other forms of aggression:

• the behavior is unwanted,
• repeated or likely to be repeated, and
• marked by an observed or perceived imbalance of power

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CHECK IT OUT!

CDE Bullying Prevention Model Policy:

https://www.cde.state.co.us/mtss/bullying

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“Bullying” defined in Colorado law

“Bullying” means any written or oral expression, or physical or electronic act or gesture, or a pattern thereof, that is intended to coerce, intimidate, or cause any physical, mental, or emotional harm to any student.

Bullying is prohibited against any student for any reason, including, but not limited to, any bullying behavior that is directed toward a student on the basis of the student's academic performance; any bullying behavior that is directed toward a student [based on their disability, race, creed, color, sex, sexual orientation, gender identity, gender expression, national origin, religion, ancestry, or need for special education services]; or a pattern of bullying behavior that is directed toward a student on the basis of the student's weight, height, or body size.

C.R.S. 22-32-109.1(1)(b)

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Examples of Bullying

• Name-calling and verbal taunts

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• Physical threats or actual physical harm

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• Deliberately and systematically excluding someone from activities

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• Off-campus text messages or social media posts that ridicule or intimidate to the extent that the targeted student is not able to fully access the school’s programs

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GREEN HIGHLIGHTS: BULLYING

• Bullying doesn’t implicate a student’s protected class.
• Not harassment.
• Follow your local policies to respond to bullying.

RED HIGHLIGHTS: POTENTIAL DISCRIMINATION OR HARASSMENT

• Treatment of the student is connected to the student's protected class.
• Could rise to the level of harassment.
• Follow your local policies on responding to harassment.

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It’s a lot, but don’t stress. The most important part is to spot the harm occurring and connect with your experts.

When you see that a student is experiencing a harm from other students or from the adults at school and it seems like they are being targeted or treated that way because of their identity, share that information with your designated school or district expert who is trained in the nuances.

Your local expert can bring into focus whether a protected class is implicated, what laws might apply, and the specific steps that need to occur to comply with those laws.

The most important thing you can do is spot the issue and elevate it. This seems like this might be discrimination or harassment based on a protected class!

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By identifying discrimination and harassment and elevating to your designated experts, you make a difference.

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A reminder on our basic concept from C.R.S. § 22-1-143

[Offensive Unwelcome Conduct or Communication]

+

[Connected to a Protected Class]

+

[Meeting a Defined Standard of Harm or Impact to the Student]

=

Discrimination or Harassment under C.R.S. § 22-1-143

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Responding in the Moment

Best Practices for

Responding in the Moment

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Best Practices for

Responding in the Moment

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Blaming vs. Supporting

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Best Practices for

Responding in the Moment

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Best Practices for

Responding in the Moment

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Core message

“In our school, everyone deserves respect. If we see or hear discrimination or harassment, we take action — every time.”

Supportive Measures and Other Concrete Actions

Supporting students after a report of discrimination or harassment.

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A note of caution…

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•Some supportive measures can be provided immediately. Others should only be implemented after an investigation and finding is made.

•Consult with your designated contact on the appropriate timing for supportive measures.

Supportive Measures

1. Safe Environment Adjustments

• Classroom Seating Changes: Move students away from each other in shared classes.
• Schedule Adjustments: Change class schedules, lunch periods, or bus routes to reduce contact.
• Safe Entry/Exit Plan: Allow the student to arrive early or leave late to avoid interactions.

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Supportive Measures

2. Academic Support

• Assignment Extension: Provide flexibility for assignments or tests if the situation has affected their focus.
• Tutoring Services: Offer extra academic help to keep the student on track.
• Quiet Spaces: Provide access to a quiet room for breaks if the student is feeling overwhelmed.

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Supportive Measures

3. Counseling and Emotional Support

• School Counselor Sessions: Regular check-ins with a counselor or psychologist.
• Peer Support Programs: Connect the student with safe peer groups or mentoring programs.
• Crisis Intervention: Immediate access to mental health support if needed.

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Supportive Measures

4. Communication Supports

• Designate a Point of Contact: Designate a staff member the student can check in with regularly.
• Regular Updates: Keep the student and their family informed (within privacy limits) about the school’s steps and any changes.
• Interpretation: For families with limited English proficiency, ensure availability of interpreters and translation of documents. Don’t rely on student to translate for family.

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Supportive Measures

5. Monitoring and Safety Measures

• Increased Adult Supervision: Add supervision in hallways, cafeterias, or other areas of concern.
• Behavioral Contracts: Use agreements to reinforce boundaries and safety expectations.
• Threat Assessments: When there is a potential ongoing threat to the student or school, convene a multi-disciplinary team to conduct a threat assessment and evaluate risk and what is needed to mitigate risk.
• Safety Plans: Develop a formal safety plan tailored to the student’s specific needs.

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Supportive Measures

6. Restorative Options (if appropriate)

• Mediation (voluntary): Facilitate conversations to address harm and promote understanding.
• Community Circles: Bring in supportive conversations to rebuild a sense of belonging.
• Community Service or Required Learning for the Student that was Found to have Caused the Harm: Assigned learning or other required actions to ensure that student learns about the impact of their actions.

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With each concrete action you take to respond to the harm caused by discrimination and harassment, you make a difference.

Hazing�As defined by Colorado revised statutes 18-9-124

"Hazing" means any activity by which a person recklessly endangers the health or safety of or causes a risk of bodily injury to an individual for purposes of initiation or admission into or affiliation with any student organization; except that "hazing" does not include customary athletic events or other similar contests or competitions, or authorized training activities conducted by members of the armed forces of the state of Colorado or the United States.

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Examples of hazing

• Forced and prolonged physical activity

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• Forced consumption of any food, beverage, medication or controlled substance, whether or not prescribed, in excess of the usual amounts for human consumption or forced consumption of any substance not generally intended for human consumption

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• Prolonged deprivation of sleep, food, or drink

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Reporting Harassment, Bullying and Hazing

Harassment, bullying and hazing can have serious legal implications for all involved

If a student is somehow intimidating another student, and you suspect it may fall under one of these categories, your safest course of action is to take immediate appropriate steps to address the behavior, then you must report to a building administrator or the Superintendent.

The Superintendent is the designated Title IX Coordinator for non-discrimination (for Harassment)

Additional Resources:

TSD Policies JBB and JICDE

TSD Policy AC

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Employee Handbook

Many of our policies, procedures, forms, and other information can be found in the Employee Handbook.

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Please keep a link to this handbook or a hard copy close by, as it will be a valuable reference. You are responsible for following the expectations outlined in the handbook.

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If you have any questions, please see Sue Kunz in

Human Resources

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Nurse Training topics

Please view the following video:

Bloodborne Pathogens

(Note: you only need to view the initial 7 minute video, not any additional videos that come up on youtube)

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If you have any questions, please see the nurse in your school

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The District Nurse (Cat Morrison) may contact you with additional training modules for you to complete if you have particular students with specific health needs

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Proof of Completion of Training�Every employee must e-sign a form stating that they understand the requirements presented in this training and agree to abide by them

Please click the link below to sign that you have completed this training module:

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Certificate of Completion, Module 1

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Please complete this training module and form by August 29, 2025

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Thank you!

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