Policy Regarding the Collection and Restricted Release of Protected Personal Information

Policy Number: #903

Responsible Executive(s):

  • Office of the President

Responsible Office(s):

  • Legal Affairs

Date Adopted: 02-17-2026

A. Purpose

The purpose of this policy is to establish clear guidelines regarding the collection and restricted release of specific personal information concerning place of birth, immigration status and certain identification documents in fulfillment of CRS 24-74.1-102.

B. Scope

This policy applies to all employees, agents and volunteers of Regis University, including student employees.

C. Policy

  1. General Limitations on Information Collection: The Entity and its employees shall not collect the following categories of information, except under specific, legally defined exceptions:
    1. Place of birth
    2. Immigration or citizenship status
    3. Information from the following documents:
      1. Passports
      2. Permanent resident cards
      3. Alien registration cards
      4. Employment authorization documents
  2. Exceptions to Collection Prohibition: Information listed above may only be collected if one or more of the following conditions are met and documented:
    1. Required by existing federal law.
    2. Required by existing state law.
    3. Necessary to perform essential job duties or functions.
    4. Necessary to verify a person's eligibility for a government-funded program, where such verification is a required condition of funding or participation.
  3. Authorized Release of Protected Information: The release of any record that includes information restricted by this policy is not considered a violation of this policy if it is released pursuant to valid legal authorization:
    1. A subpoena issued by a federal judge or federal magistrate.
    2. An order issued by a federal judge or federal magistrate.
    3. A warrant issued by a federal judge or federal magistrate.
    4. The express written consent of the individual who is the subject of the information (student, patient, or patron) via a valid release of information form.
    5. The express written consent of the child's, student's, patient's, or patron's parent or guardian via a valid release of information form.
  4. Required Procedures for Information and Access Requests:
    1. Procedures for General Information Provision:
      1. Regis University complies with its FERPA policy to provide personal identifying information about enrolled children/students, as required by state and federal law, which is available at regis.edu/policies/ferpa.
      2. Regis University complies with lawfully issued subpoenas for personal identifying information about a parent, guardian, or relative, as required by state and federal law that may be retained in the normal course of business for housing, financial services, and FERPA or HIPAA releases.
    2. Procedures for Facility Access:
      1. The use of Regis University property adheres to its Campus Access Policy.
    3. Procedures for Federal Immigration Authorities Requests:
      1. In the event an employee receives a subpoena, order, or warrant issued by a federal judge or magistrate, or receives an in-person visitor presenting the same, all employees will:
        1. Greet the officer/agent in a polite and courteous fashion.
        2. Refer the officer/agent to Campus Safety at 303.458.4122.
        3. Contact Campus Safety and make them aware of the referral to the office.
        4. Do not identify the student or employee or provide any information or details about the student or employee.
      2. Upon receiving a referral, Campus Safety will:
        1. Contact Regis University legal counsel.
        2. If an in-person visitor, will complete the Federal Immigration Enforcement Encounter Form.
        3. Evaluate whether the order is an administrative order or a judicial order in consultation with legal counsel:
          1. Administrative: does not need to be followed
          2. Judicial (signed by a judge): does need to be followed
        4. If a judicial order, in consultation with legal counsel, will accompany ICE/DHS/FBI in fulfillment of the order, ensuring ICE/DHS/FBI does not stray from the terms of the warrant.
        5. If an administrative order, in consultation with legal counsel, will advise ICE/DHS/FBI to return with a judicial warrant.
        6. Provide a campus update via Campus Safety alerts.
      3. Upon receiving a referral, Legal Counsel will:
        1. Contact Campus Safety.
        2. Contact HR for employees, or PDSO/DSO for students, and other need-to-know individuals.
        3. With Campus Safety, evaluate whether the order is a judicial order or an administrative order.
        4. Advise Campus Safety on whether Regis will comply with the warrant or request that ICE/DHS/FBI returns with a judicial warrant.
      4. Upon receiving a referral, PDSO/DSO will (for students):
        1. Proactively provide a fact sheet with what to be aware of in light of STEM OPT checks and Operation Twin Shield immigration efforts.
        2. PDSO will provide list of resources (as described below), since getting an attorney right away may be advantageous or necessary:
          1. List of free immigration consultations
          2. List of pre-screened immigration attorneys
          3. Safety Planning considerations: If you are concerned about deportation (know your risk from your immigration attorney) you may want to share your location with a trusted individual and communicate how you would want to report you are detained
          4. Know Your Rights trainings: For training, reach out to Know Your Rights — Colorado Immigrant Rights Coalition (Regis University will not provide training as this information is constantly being updated)
      5. Upon receiving a referral, Human Resources will (for employees):
        1. Advise the employee to contact Palmer Polanski for Regis-sponsored immigration assistance.
      6. Regis University Designated Contact for: Campus Safety, 303.458.4122
      7. Requirements for documenting the federal immigration enforcement encounter:
        1. Regis University Campus Safety must request and document the following information from the agent leading the enforcement action:
          1. First and last name
          2. Employer
          3. Badge number
          4. A physical or electronic copy of the valid subpoena, warrant, or order
        2. Employees are expected to complete this documentation using the “Federal Immigration Enforcement Encounter Form” included in this policy under Related Forms.
    4. Regis University will notify the student, patient, or visitor of the information request as appropriate under FERPA, HIPAA, and permitted by law.
  5. Policy Availability: This policy shall be made readily available to employees, students, patients, visitors, parents, guardians, and relatives via posting on the regis.edu/policies page.

D. Definitions

  1. Publicly Supported Library: Any library that is supported by public funds.
  2. Valid Release of Information: A signed, written consent form meeting all applicable state and federal legal requirements for the disclosure of private information.

E. Related Policies, Procedures, Forms and Other Resources

Campus Access Policy | Regis University
Federal Immigration Enforcement Encounter Form
Record Retention Policy | Regis University
FERPA | Regis University

F. End Notes

This policy is derived directly from the language contained in Colorado Revised Statutes (C.R.S.) § 24-74.1-102, as enacted by the State of Colorado General Assembly.