-- December 5, 2017
Last Reviewed -- October 12, 2018
Chief Ethics and Compliance Officer tel. (202) 319-6170
I. Policy Statement
At times, staff and faculty members may receive requests for information or documents from people, organizations, or governments outside the University. Such requests may come in the form of notices of external audits or investigations, subpoenas or other legal documents, requests pursuant to background checks or employment verifications, or contacts from the News Media. Some requests may be time sensitive.
Employees who receive external inquiries should forward them immediately to the individuals and offices set forth in this policy in order to coordinate timely, appropriate, and consistent responses, to protect privacy and confidentiality, and for coordinated tracking.
Employees should not respond to external inquiries unless they have been determined by the University to be the appropriate point of contact, or as otherwise set forth in this policy.
A. External Review means an independent examination, inspection, or review of University operations, accounts, or records undertaken to determine accuracy or compliance with applicable requirements. For purposes of this policy the term External Review includes audits, site reviews, desk reviews, accreditation proceedings, and inspections. Audits may be undertaken by auditing or accounting firms (e.g. Grant Thornton, PwC, KPMG), by federal or local governments (.e.g. National Science Foundation, D.C. Department of Energy & Environment, DC Fire Marshal), or by other external entities acting on behalf of a governmental entity. These requirements apply regardless of whether the inquiry is scheduled or routine or on a specific complaint.
B. External Investigation means an independent inquiry undertaken to determine the facts in a given situation. Such investigations may be undertaken by federal, state, or local governments or divisions of the government (e.g. the DC Office of Human Rights, the D.C. Office of the State Superintendent of Education, the U.S. Department of Education, the Equal Employment Opportunity Commission (EEOC), the Department of Homeland Security (DHS), the Federal Bureau of Investigation (FBI), the U.S. Citizenship and Immigration Service (USCIS) or the Occupational Safety and Health Administration (OSHA)).
C. Legal Matter means any document or request for information that has legal bearing or relevance, or has the potential to have legal bearing or relevance to the University. Legal Matters include, but may not be limited to, the following:
- Legal Documents: any complaint, summons, subpoena, interrogatories, requests for production of documents, court notice, demand letters, or letter or email from any attorney;
- Legal Information: any request for information or documents from an attorney engaged in representation of a client, any request for information or documents from an individual working for an attorney (such as an investigator), or any request for information or documents from an individual that has retained counsel or might retain counsel.
D. Background Check means the process by which an external entity evaluates an individual's employment history, criminal or disciplinary history, or academic history. Background Checks are undertaken by external entities in order to evaluate an individual's fitness for employment, and may pertain to staff, faculty or students. For the purposes of this policy, Background Checks include requests to verify employment.
E. News Media mean entities or mechanisms for delivering news to the general public or to a targeted audience. News Media include but are not limited to: newspapers; magazines or journals; television or radio stations or networks; online media; and Social Media.
F. Reference means speaking about an individual's character, reliability, ethic, or other abilities based on observation or interaction with that individual. References may be personal or professional in nature.
III. External Requests for Information
A. External Reviews and Investigations
Direct all notices of External Reviews or External Investigations to the Chief Ethics and Compliance Officer at tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU. The CECO will coordinate with the General Counsel, the Finance division, and other relevant University personnel to determine the appropriate point of contact for the review or investigation.
B. Legal Matters
Direct all Legal Matters to the Office of General Counsel. If a member of the University community receives any request relating to a Legal Matter, contact the Office of General Counsel by telephone as soon as possible. The Office of General Counsel is located in Leahy Hall, Suite 280, and can be reached at CUA-OGC@CUA.EDU or tel. (202) 319-5142.
1. Service of Legal Documents
a. Legal Documents in which The University is named and no individual employee or agent is named
Receipt by Mail: If a member of the University Community receives a Legal Document in the mail, bring that Legal Document and any packaging (including any envelopes or certified mail return receipts) to the Office of General Counsel as soon as possible. Do not date-stamp or otherwise mark the document.
In-Person Service of Legal Documents: Individuals wishing to serve the University with Legal Documents must go through the Office of General Counsel. Members of the University community may not accept service of Legal Documents not addressed to them personally. Direct individuals and process servers to the Office of General Counsel and do not consent to accept service. If there are any issues, call either the Office of General Counsel at CUA-OGC@CUA.EDU or tel. (202) 319-5142 or the Department of Public Safety, at tel. (202) 319-5111, as appropriate. If a member of the University signs for a document on behalf of the University without authority to do so, please contact the Office of General Counsel immediately.
b. Legal Documents Naming the University and also naming one or more individual employees or agents of the University
Individuals wishing to serve members of the University Community on the University's campus with Legal Documents must go through the Office of General Counsel and the Department of Public Safety. Individual employees of the University should not accept service on behalf of the University. Only the General Counsel may accept process on behalf of the University.
If a member of the University Community accepts service of a Legal Document addressed to them personally (and with potential legal bearing or relevance to the University), contact the Office of General Counsel as soon as possible.
c. Legal Documents naming an individual but not naming the University
An individual employee who is served who believes the action giving rise to the legal process took place in the course of the performance of the duties of his or her position should contact the Office of General Counsel as soon as possible and then forward a copy of the document(s) received.
d. Legal Service of Documents on the University's Campus Unrelated to the University
Individuals are not permitted on University property to serve legal documents on members of the University community unless prior authorization is received from the Office of General Counsel and the Department of Public Safety.
2. Requests for Legal Information
Members of the University community may not provide Legal Information except at the direction of the Office of General Counsel.
If a member of the University Community is asked to provide Legal Information, direct the requesting individual to the Office of General Counsel and then contact the Office as soon as possible.
3. Background Checks and Employment Verifications
Forward inquiries regarding an individual's employment status or history (e.g. employment verification) to the Office of Human Resources at tel. (202) 319-5050. This includes inquiries that pertain to staff, faculty or student employment. Human Resources is the University unit responsible for responding to employment inquiries. Employees may, however, respond directly to an external entity if the inquiry is a references regarding an individual's suitability for a job (see IV. below).
Inquiries from government agencies or other employers where a security clearance is required may request records held by the Department of Public Safety. These requests may be forwarded directly to the Public Safety Customer Service Center (121 leahy Hall, tel. 202-319-6058).
Forward all inquiries regarding student disciplinary matters or records to the Office of the Dean of Students at CUA-DEANOFSTUDENTS@CUA.EDU or tel. (202) 319-5619.
All inquiries regarding academic records should be forwarded to the Office of Enrollment Services at tel. (202) 319-5300 or tel. (800) 787-0242 (toll free), or at the following e-mail addresses:
4. News Media Requests
Per the University's Speaking to the News Media Policy and Press Releases Policy, University communications with the News Media, and issuance of all press releases pertaining to the University, are managed by the Office of Marketing and Communications. Forward all News Media inquiries to the Office of Marketing and Communications at (202)-319-5600.
The University does not provide References for employees or students. The University will, through the office of Human Resources, confirm or provide the following information with the written consent of the requestor: official job title(s), department(s), salary verification, and dates of service. If a University employee receives a request for this information, forward that request as soon as possible to the Office of Human Resources.
University employees, on their own volition, may provide References for external entities for employees or for students. It is strongly recommended that the employee obtain written consent from the individual making the request for a reference. Employees seeking guidance regarding protocols and best practices for providing references may contact the Office of Human Resources at tel. (202) 319-5050, the Office of General Counsel at tel. (202) 319-5142, or the Chief Ethics and Compliance Officer at CUA-COMPLIANCE@CUA.EDU or tel. (202) 319-6170.