522.72

STAFF COMMUNICATIONS WITH STUDENTS

 

Purpose

District staff members are expected to conduct themselves in a manner that promotes the health, safety, and well-being of students, including by establishing and maintaining role-appropriate communicative, physical, emotional, and social boundaries in their interactions with students.

As applied to communication between District staff members and any student(s), this means that staff members are expected to communicate with students in an appropriate manner, encompassing both (1) the content of the communication and (2) the method of communication.

This policy establishes certain standards for staff-student communications that occur when a staff member is interacting with a student in the staff member’s District-authorized capacity. 

Whether a communication occurs in a staff member’s District-authorized capacity is determined based on the totality of the circumstances and is not limited to any specific hours of the day. For example, a District employee can be acting in such a capacity when the reason(s) for or other circumstances of the communication arise directly from the employee’s District-assigned responsibilities, even though the communication occurs outside of established school hours, outside of the employee’s regular work hours, or both.

For purposes of this Policy, staff members include District employees and District-authorized volunteers (i.e., an individual who has been approved by the District to provide volunteer services for the benefit of the District in one or more specified capacities).  

Appropriate and Inappropriate Content of Communications

In addition to the basic expectation that the content of communication between a staff member and one or more students that occurs in the staff member’s District-authorized capacity will not violate any applicable law, District policy, or express supervisory directive, the following are general standards for appropriate content for such communications: 

• The communication has a legitimate educational, programmatic, safety, or supervisory purpose that is reasonably grounded in the staff member’s District-assigned role and responsibilities. 
• The staff member’s communication to the student(s) is respectful in its substantive message and tone. 
• The communication is consistent with the staff member’s role as an authority figure who is demonstrating due regard for the safety and welfare of the student(s) and maintaining role-appropriate boundaries in the staff member’s interactions with the student(s). 
• To the extent implicated by the specific situation, the communication is within the reasonable scope of the professional competencies that are part of the staff member’s District-assigned role and responsibilities. 
• The communication reasonably responds to an emergency situation. 
• The communication is age-appropriate for the relevant student(s). 
• The content of the communication is not in violation of any applicable (1) state or federal law, (2) District policy or rule, or (3) supervisory directive. 

The standards listed above are established with the recognition and understanding that (1) context-specific circumstances will be relevant to the application of the standards (i.e., not every standard will apply, or apply equally, to every staff-student interaction; some communication may be as simple and brief as showing a basic social courtesy); and (2) not all communication between staff and students will be excessively formal. 

The content of communication between a District staff member and a student when the staff member is acting in the staff member’s District-authorized capacity is inappropriate and a violation of this Policy if the communication fails to meet a standard for appropriate communication that applies to the specific situation. Without in any way attempting to be exhaustive of all possible examples, such communication is inappropriate if, for example, the content: 

• Ridicules, demeans, or threatens a student. 
• Would be viewed by a reasonable supervisor, administrator, or other District official with relevant oversight responsibility as communication by the staff member that:
  • Creates an intimidating, hostile, or offensive environment within a District school, program, or activity;
  • Manipulates, coerces, or grooms a student to engage in, or to consider engaging in, any inappropriate behavior. For the purposes of this Policy, grooming; 
    • Includes communications that are part of any course of conduct that a reasonable person would view as conditioning, seducing, soliciting, luring, or enticing a student to engage in, or to consider engaging in, inappropriate behavior.
    • Can occur, for example, by exploiting a student’s vulnerabilities, by creating inappropriate emotional dependence, or by normalizing or desensitizing the student to inappropriate conduct.
  • Exploits a power dynamic, such as by offering improper benefits or privileges or by inappropriately threatening to impose negative consequences in a quid pro quo posture; 
  • Encourages, condones, invites, or arranges (1) any unlawful conduct; (2) any conduct that would unreasonably endanger the safety or welfare of any person; or (3) any inappropriate staff-student interaction; 
  • Expresses sexual or romantic interest in a student or makes, accepts, or encourages sexual or romantic advances involving a student; or
  • Is sexualized in nature (e.g., sexually explicit or sexually suggestive) outside of any legitimate curricular purpose (e.g., in literature, biology, or health).
• Taken in context, engages any student(s) in: 

• The sharing of information at an inappropriate level of personal or emotional intimacy, such as through a staff member’s disclosure of inappropriate details of the staff member’s personal life with a student. 
• Inappropriately peer-like communication that could reasonably impair the staff member’s ability to be effective in the staff member’s District role(s). 

Appropriate and Inappropriate Methods of Communication

For purposes of this Policy, a method of communication is comprised of the following components:

1. A means of communication (e.g., in-person, paper-based, telephone, or through the use of a particular electronic account, application, system, or platform).

2. The timing of the communication.
3. The location of the communication.
4. Other relevant characteristics (e.g., whether the communication is group-based or occurs on a one-to-one basis, and whether other appropriate District officials/staff and/or the student’s parent(s) or guardian(s) are included as recipients). 

The selection of an appropriate method of communication is often routine and based on commonly applied practices. In some situations, a District policy, procedure, or supervisory rule or directive will directly dictate one or more aspects of the method to be used. However, particularly in non-routine situations, a staff member is expected to apply sound judgment in selecting an appropriate method of communication, giving consideration to context-dependent factors such as the purpose of the communication, the age(s) of the student(s), and the staff member’s specific role and responsibilities.

The following additional standards apply to the methods that are used for communication between a District staff member and one or more students that occurs when the staff member is acting in the staff member’s official, District-authorized capacity:

1. Concealment Prohibited. Notwithstanding any other provision of this Policy, a method of staff-student communication is always prohibited if the staff member selects or uses a means, time, or location of communication to conceal an inappropriate communication or inappropriate interaction from persons who have a legitimate interest in the information or conduct (e.g., by a supervisor or by the student’s parent or guardian). 
2. Electronic Communications through District-Approved Means. Unless an administrative official with relevant authority has given the staff member an express directive to the contrary that applies to the particular staff-student communication, electronic communication that occurs by voice, video, electronic messaging (including email), or other electronic media will generally be an appropriate means of communication if all of the following apply:
   1. The staff member uses an account, application, system, or platform that the District has provided for the relevant purpose or that the District has expressly approved for use for staff-student communications in the specific context (e.g., approval by a District supervisor or administrator with relevant oversight authority).
   2. Other aspects of the method of communication (e.g., the timing of the electronic communication) are reasonable in the specific context. 
3. Inappropriate Means of Electronic Communications. Subject to the limited exceptions identified below, it is inappropriate and a violation of this Policy for a staff member to engage in electronic communication with a student if:
   1. The staff member uses an (1) internet-based communications account or service (e.g., an email or social media account); (2) phone account; (3) virtual phone account; or (4) other electronic messaging, voice communication, or video communication account, application, system, or platform that is neither District-provided nor expressly District-approved for use for the specific purpose. 
   2. Not including any large group, non-personalized messages or system-generated alerts that a student has elected to receive, the staff member communicates with one or more students by electronically messaging the student(s) through (1) a student’s personal social media account or some other non-District personal internet account that is known to be accessed by the student; (2) a non-District email account used by the student; or (3) a student’s personal text messaging account associated with the student’s actual or virtual personal phone number. 
   3. The limited exceptions to the rules established in the two preceding paragraphs are as follows: 
      1. The staff member is reasonably addressing emergency/exigent circumstances of an imminent and serious nature, and the staff member promptly communicates their reliance on this exception to an appropriate supervisor or other District official with relevant oversight responsibility. 
      2. The communication is limited to a reasonably necessary safety-related contact or a brief, logistics-related communication that is time-sensitive and for which no District-provided account, application, or system or specific pre-approved communication arrangement is reasonably available for the purpose, and the staff member promptly communicates their reliance on this exception to an appropriate supervisor or other District official with relevant oversight responsibility. 
      3. Situations in which an administrator has granted approval for such communication for a limited purpose, including establishing a protocol for the retention of any relevant records and identifying any appropriate accountability practices the staff member will be expected to implement. No staff member may approve such an exception that applies to himself/herself. 

Consequences for Inappropriate Staff-Student Communications

Staff members who communicate with a student in violation of the law, this Policy, other District policies or rules, or applicable supervisory directives are subject to a range of disciplinary and non-disciplinary consequences that will be determined based on the District’s assessment of the nature and seriousness of the violation/misconduct.

Examples of possible non-disciplinary consequences include a notice of performance expectations and the provision of evaluative feedback. Examples of possible disciplinary consequences include a formal reprimand, a disciplinary reassignment, a suspension, termination of a specific District-authorized role, termination of employment, and/or the termination or non-renewal of an applicable contract. 

Unless prohibited by law, consequences for a District student who violates this Policy while serving in the capacity of a District employee or District volunteer may include school-related consequences. 

Nothing in this Policy alters any person’s mandatory reporting obligations or parent notification obligations, as established under any law. 

Definitions and Policy Application

1. In this Policy, “student” means an individual who is any of the following: 
   1. An individual who is enrolled in or who attends any public, private, or tribal school at the secondary (i.e., high school) level or lower (e.g., an elementary school), whether the school is within or outside of the District and regardless of the individual’s age. 
   2. An individual who is enrolled in or who attends a home-based private educational program, as defined under state law.
   3. Under age 18 and a participant in any District-sponsored class, program, or activity that is offered for children and other school-age youth.
2. A student is considered a student under this Policy, rather than a District-authorized volunteer, If the student is enrolled in the District and engages in service opportunities within the District which are not generally available to non-students and during which time the student is subject to District supervision as a student. 
3. If an individual is both a current student (as defined above) and a current District employee or District-authorized volunteer, then for purposes of applying this Policy, such an individual is considered a student in connection with the content of any communication that occurs between that individual and any non-student District staff member (i.e., even if the communication occurs in connection with such individual’s employment or volunteer capacity). 
4. It is not a violation of this Policy for a District staff member to merely receive an unsolicited inappropriate communication from a student, provided that the staff member takes prompt and reasonable steps to attempt to prevent future instances of such improper student-initiated communications, such as by redirecting the student to an appropriate method of communication and by promptly reporting inappropriate content for administrative follow-up when warranted and to outside authorities when required by any applicable law. 

Communications with Students when Not Acting in a District-Authorized Capacity 

The standards and expectations that this Policy establishes for staff-student communications that occur when a staff member is acting in the staff member’s official, District-authorized capacity do not directly apply to communications that occur entirely outside of that official capacity and that are based on a legitimate non-District connection to the student.

For example, a staff member may have a non-District connection to a student as a relative or through a non-District civic, social, recreational, or religious organization, and such a staff member is not bound by this Policy when communicating with the student in such non-District capacity (e.g., a staff member who is a parent of a student certainly may communicate with their own child regarding highly personal matters, by using personal accounts, etc.). 

However, and very importantly, communications and other interactions between a student and a District staff member that occur outside of the staff member’s official, District authorized capacity are subject to the limitation that where there is a sufficient nexus between the circumstances surrounding the staff member’s conduct and the staff member’s District-authorized role(s) and responsibilities, the District retains substantial interests as an employer and may still impose lawful consequences for the conduct to the fullest extent permitted by law. 

 

Cross References:  Student Harassment, 411.1   

Student Conduct, 443 

Student Use of Electronic Communication Devices. 443.5

Bullying Policy, 443.71

Safe Schools: Policy and Prevention Strategies, 443.9

Reporting Suspected Child Abuse and Neglect, 454 

Photographing and Videotaping in the Schools, 492

Staff Use of Information Technology and Communication Resources, 522.7

Staff Use of Social Media, 522.71

Employee Use of Mobile Phones and Other Data Devices, 522.72

Professional Boundaries and Staff-Student Relationships, 528

 

Legal References: Wisconsin State Statutes 48.981, 115.31(b), 118.07(6), 118.07(7), 175.32, 948.072, 948.098, and 995.55

Federal Laws:  47 U.S.C. §§254(h) and 254(l) and 47 C.F.R. §54.520]

 

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Adoption Date: August 10, 2026