Responding to Immigration Enforcement Actions

1. Policy

Issued: January 15, 2025
Last Revised: January 15, 2025
Last Reviewed: January 15, 2025

Applies to: This Policy applies broadly to the entire University community, including students who are registered or enrolled in University classes or in one of the University’s degree or non-degree programs (“Students”); all full-time and part-time faculty (“Faculty”); all non-faculty University employees, including University Staff, Keck Medicine employees, professional research staff, and post-doctoral fellows (“Staff”); and contractors, vendors, visitors, guests, or other individuals who are participating in or seeking to participate in the University’s education program or activities (“Third Parties”).

2. Policy Purpose

This policy outlines the university’s response to any immigration enforcement action involving a student or employee, related support, and impacts on the individual’s education and/or employment.

3. Scope and Application

This policy applies when immigration enforcement actions occur involving a USC student or employee.

4. Definitions

Term	Definition
Covered Personnel	All University Officials, Faculty and Staff, as well as Students and Third Parties who are assigned specific responsibilities by the University that grant them access to Non-Public Areas of University Buildings or Premises, or access to personnel records or Education Records other than their own, whether as a result of possession of physical keys or keycard access to locations containing physical copies of personnel or Education Records, or online credentials allowing access to digital copies of personnel or Education Records. This may include vendors providing security, housekeeping, or other building maintenance services; resident assistants; virtual peer mentors; designated student leaders, such as Trojan Marching Band squad leaders and section leaders and Student Athletic Academic Services (SAAS) tutors; or leaders and members of other student programs.
Education Records	As defined in the Student Records Policy.
University Building or Premises	Any building, property, or grounds owned, leased, and/or operated by the university, including at the University Park Campus, Health Sciences Campus, and all other locations.
Non-Public Areas	Spaces in University Buildings or Premises that are not open to the general public and that are restricted to authorized university officials, employees, students, and invited guests.
University Residence	Any room/apartment that a university student is assigned pursuant to a signed and confirmed Housing & Hospitality Services Contract & Living Agreement between the student and the university, or that an individual is assigned by the university in connection with a faculty or staff appointment, such as faculty-in-residence or residential staff.
Personal Information	Any information that identifies or describes a student or employee, including but not limited to, their immigration or citizenship status, physical description, home or work address, telephone number, education, financial matters, medical or employment history, and statements made by, or attributed to, them. This includes information that may be designated as Directory Information under the Student Records Policy.

5. Policy Details

If any Covered Personnel becomes aware or has reason to suspect that (1) a government official, including a law enforcement officer, engaged in immigration enforcement is expected to enter, will enter, or has entered University Premises for immigration enforcement purposes, or (2) a student or employee may have been taken into custody as the result of an immigration enforcement action, they shall immediately contact the main Department of Public Safety (DPS) phone line at (213) 740-6000 and provide a detailed explanation of the situation.
- DPS shall immediately inform the Senior Vice President for Administration, the Associate Senior Vice President for Safety and Risk, and the Office of the General Counsel (OGC).
- In the case of a suspected arrest, the individual’s emergency contact shall be promptly notified by Campus Support and Intervention (CSI) and provided with contact information for the USC Gould Immigration Clinic’s Emergency Arrest Hotline (213-740-7435).

USC has designated Niels W. Frenzen, Esq., Co-Director of the USC Gould Immigration Clinic’s Immigrant Legal Assistance Center (ILAC), as the point of contact for any student or employee who may or could be subject to an immigration order or inquiry. Urgent immigration enforcement matters should be reported to the Emergency Arrest Hotline at (213) 740-7435. Non-urgent inquiries should be made to ILAC at (213) 821-9627. Professor Frenzen may be reached by phone at (213) 740-8933 or email at nfrenzen@law.usc.edu.

ILAC is available to assist any student or employee who may be subject to an immigration order or inquiry, or who may face similar issues, and whose education or employment is at risk because of immigration enforcement actions.

All university support offices, including but not limited to the Office of the Vice President for Student Life, Campus Support and Intervention, the Ombuds Office, the WorkWell Center, the Office of Civil Rights Compliance (OCRC) (formerly the Office for Equity, Equal Opportunity, and Title IX or EEO-TIX), USC Student Health, the Office of Threat Assessment and Management, the Department of Public Safety, and the Office for Professionalism and Ethics, shall provide any student or employee, upon request, the information regarding ILAC that is listed below. Any record of the interaction that is made by the support office may indicate that information about university support resources was provided, but shall not specifically identify ILAC. General listings of university support resources shall include ILAC’s information.
- ILAC provides free, confidential consultations, legal assistance, and referrals to members of the USC Trojan Family, students, staff members, contract employees, faculty and immediate family members, who may be at risk of deportation, who may be eligible to apply for immigration status, or who have questions about their legal status and legal rights under the immigration laws. ILAC is supported by the Office of the Provost and USC Gould School of Law. ILAC can be reached by phone at (213) 821-9627, email at iclinic@law.usc.edu. The ILAC office is located in the Immigration Clinic at the Gould School of Law, 699 Exposition Blvd, Los Angeles, CA 90089-0071. ILAC publishes Know Your Rights information and operates an Emergency Arrest Hotline that can be reached at (213) 740-7435.

All Covered Personnel shall follow the University and Health System Protocol When Presented With a Warrant or Government Subpoena issued by OGC if presented with a request by government officials, including law enforcement officers and immigration officers, for Personal Information about a student or employee or for physical access to a University Residence or to Non-Public Areas of University Buildings or Premises.¹
- As noted in the OGC Protocol, government officials, including immigration officers, should be politely referred to OGC. However, if a government official, including an immigration officer, demands to enter a University Residence or Non-Public Area, Covered Personnel should not physically block or interfere with the government official and should immediately contact DPS at (213) 740-6000. Covered Personnel also shall not take any action to intentionally conceal or harbor an individual in violation of the Immigration and Nationality Act (8 U.S.C. § 1324 et seq.) or other federal immigration laws or to intentionally obstruct lawful immigration enforcement activities.

Protecting Information About Immigration and Citizenship Status
- Covered Personnel shall not create or maintain a list of student or employee names linked to their immigration or citizenship status.²
- DPS shall not inquire into an individual’s immigration status for immigration enforcement purposes. DPS shall not aid any effort to create a registry containing individuals’ country of birth or based on any other protected characteristics of victims, witnesses, or suspects of crimes unless required by law for specified purposes.
- Any information maintained in Education Records (including information shared in a student’s application for admission) that reflects or could be used to determine a student’s immigration or citizenship status, including their social security number or their parent’s or guardian’s social security number, shall be maintained only for as long as necessary and used only for the purpose collected. Such information shall not be disclosed except as authorized under the Student Records Policy.
- Unless required by federal or state law, Covered Personnel shall not inquire specifically about a student’s citizenship or immigration status or the citizenship or immigration status of a student’s parents or guardians; nor shall Covered Personnel seek or require, to the exclusion of other permissible documentation or information, documentation or information that may indicate a student’s immigration status, such as a green card, voter registration, a passport, or citizenship papers.
- Where any law contemplates submission of immigration status or citizenship status information to satisfy the requirements of a special program, Covered Personnel shall not use that documentation or information for decisions related to admissions or enrollment in courses or degree programs.
- It is the policy of the university not to use immigration status, citizenship status, or national origin information disclosed in personal statements submitted as part of admissions applications outside the application process, other than for legitimate educational interests, including the provision of a service or benefit relating to the student, such as health care, counseling, job placement or financial aid.
- Applicants for admission may elect not to provide immigration or citizenship status information to the university, and this election shall not impede admissions or enrollment in educational programs. To the extent information is provided that that could indicate immigration or citizenship status, it shall not be considered in admissions decisions or determining access to educational courses or degree programs.
- All Covered Personnel shall refrain from disclosing or revealing, formally or informally, Personal Information, including immigration or citizenship status information, regarding any student or employee, to anyone, unless they have been given permission to do so by that individual, are authorized to do so under university policy, including the Student Records Policy, or have been directed to do so by OGC.
  - As a general rule, Covered Personnel should assume they are not authorized to disclose or reveal any student’s or employee’s immigration or citizenship status information to others, including government officials, unless they have been instructed by an appropriate university official that they are authorized to do so.

Supporting Detained and Deported Students
- If a student is detained or deported, or is unable to attend to his or her academic requirements because of an immigration order, it is the policy of the university to make all reasonable efforts to assist that student in retaining or preserving eligibility for financial aid, fellowship stipends, funding for research or other educational projects, housing stipends or services, or other benefits the student has been awarded or received, subject to, and in compliance with, all applicable university policies and federal, state, and municipal laws.
- It is the policy of the university to permit a student who has been subject to an immigration detention or removal order to reenroll if and when the student is able to return to the university, subject to, and in compliance, with all applicable university policies and federal, state, and municipal laws. The university will make reasonable and good-faith efforts to provide for a seamless transition in the student’s reenrollment and reacquisition of campus services and support.
- The university has designated the Office of Campus Support and Intervention to provide assistance to students in navigating these circumstances.

The following information shall be posted on the university’s Report & Response website and shared with all students and employees by email each fall and spring semester:
- A link to this Policy.
- Links to the Policies, Procedure, and Protocol listed in Section 9 of this Policy.
- The information regarding ILAC listed in Section 5.D of this Policy.

7. Forms

N/A

8. Responsibilities

POSITION or OFFICE	RESPONSIBILTIES
Department of Public Safety	1. Upon being notified that (1) a government official engaged in immigration enforcement is expected to enter, will enter, or has entered university premises for immigration enforcement purposes, or (2) a student or employee may have been taken into custody as the result of an immigration enforcement action, immediately inform the Senior Vice President for Administration, the Associate Senior Vice President for Safety and Risk, and OGC.
Campus Support and Intervention	1. Upon notification by DPS or OGC that a student or employee may have been taken into custody as a result of an immigration enforcement action, promptly notify the individual’s emergency contact and provide contact information for the USC Immigration Clinic’s Emergency Arrest Hotline (213-740-7435). 2. Assist students who have been detained or deported in navigating potential reenrollment at the university if/when that is possible.
University Support Offices	1. Provide any student or employee, upon request, information regarding the USC Gould Immigrant Legal Assistance Center (ILAC).
Co-Director, USC Gould Immigration Clinic’s Immigrant Legal Assistance Center	1. Point of contact for any student or employee who may or could be subject to an immigration order or inquiry.