September 16, 2013
Equal Employment Opportunity/Affirmative Action Plan
Keystone Area Education Agency 1 1400 Second Street NW Elkader, IA 52043‐9564
p. 1 of 25
p. 2 of 25
Table of Contents Rationale .................................................................................................................................................................... 4 Executive Summary ................................................................................................................................................... 4 Administrative Statement from Chief Executive Officer ........................................................................................... 5 Equal Employment Opportunity/Affirmation Action Coordinator ............................................................................ 6 Distribution of Equal Employment Opportunity/Affirmative Action Plan ................................................................. 6 Work Force Analysis .................................................................................................................................................. 7 Keystone AEA 1 Organizational Display ................................................................................................................. 7 2013‐2014 Staff Equity List ........................................................................................................................................ 8 Non‐Management Licensed Staff .......................................................................................................................... 8 Classified Staff........................................................................................................................................................ 8 Management/Board Staff ...................................................................................................................................... 9 Auxiliary Staff ......................................................................................................................................................... 9 Organizational Support Staff ............................................................................................................................... 10 Quantitative Analysis Worksheets ........................................................................................................................... 10 Work Force by Occupational Category .................................................................................................................... 12 Keystone AEA Job Categories in Each EEO‐1 Occupational Category ...................................................................... 13 Relevant Labor Market ............................................................................................................................................ 13 Quantitative Analysis ............................................................................................................................................... 14 Quantitative Goals ................................................................................................................................................... 15 Qualitative Goals ..................................................................................................................................................... 16 Definitions ............................................................................................................................................................... 17 Appendix .................................................................................................................................................................. 18 Comprehensive Equity Policy (Policy) .................................................................................................................. 18 Affirmative Action Compliance Program (Rule) ................................................................................................... 19 Grievance Procedures for Non‐discrimination in Educational Programs and Employment (Rule) ..................... 21 Harassment (Policy) ............................................................................................................................................. 23 Educational Equity Statement (Policy)................................................................................................................. 24 Compliance Violation Form ................................................................................................................................. 25
p. 3 of 25
Rationale
The Keystone Area Education Agency Board of Directors recognizes the importance of recruiting highly‐skilled and talented individuals from diverse backgrounds to maintain and improve the quality of services which the Agency provides to the schools and children of Northeast Iowa. It is for this reason that the following Equal Employment Opportunity/Affirmative Action Plan has been developed. This plan is directed and implemented through the Keystone AEA1 board policies and rules listed at the end of this document.
Executive Summary This Affirmative Action/Equal Employment Opportunity Plan is designed to meet the statutory planning and reporting requirements for Keystone Area Education Agency’s affirmative action and equal employment opportunity efforts. This document outlines current quantitative and qualitative data and compares the quantitative data to external indicators. That data is then used to set both qualitative and quantitative goals for September 1, 2015, when this plan will next be revised. The document is organized according to the key affirmative action/equal employment requirements found in the Iowa Code 281‐95.1(256). The report outlines, in further detail, the following key findings: Persons with disabilities are underrepresented at Keystone AEA Minorities are underrepresented at Keystone AEA Males are underrepresented in both the Professionals group and the Administrative Support group at Keystone AEA The plan concludes with the following goals for September 1, 2015: Increase the overall percentage of minority employees within the Agency from 1.3% to 5.2% by September 1, 2015. o Increase the percentage of minority employees within the KEA bargaining group from 1% to 4.3% by September 1, 2015. o Increase the percentage of the minority employees within the KESSA bargaining group from 1% to 4.4% by September 1, 2015. o Increase the percentage of the minority employees within the management group from 0% to 9% by September 1, 2015. o Increase the percentage of the minority employees within the organizational support group from 0% to 8.3% by September 1, 2015. Increase the gender balance of employees within the KESSA bargaining group from 13% male to 17.9% male by September 1, 2015. Increase the gender balance of employees within the KEA bargaining group from 9% male to 16.4% male by September 1, 2015. Update EEO data including disability status through biennial survey to staff to increase accuracy of information. Complete professional development for managers and supervisors involved in the hiring process prior to January 1, 2014.
ToC
p. 4 of 25
Administrative Statement from Chief Executive Officer September 16, 2013 TO: KEYSTONE AREA EDUCATION AGENCY STAFF FR: PAT HEIDERSCHEIT, ADMINISTRATOR RE: EQUAL OPPORTUNITY EMPLOYMENT & AFFIRMATIVE ACTION Keystone Area Education Agency has been, and will continue to be, an equal opportunity employer. In all of our employment practices, we will: A. recruit, hire, and promote persons for all jobs based solely on qualifications without regard to race, color, national origin, gender, disability, age, religion, creed, sexual orientation or gender identity B. ensure personnel actions such as compensation, benefits, transfers, layoffs, return from layoffs, and company‐sponsored programs and activities are administered without regard to race, color, national origin, gender, disability, religion, creed, age, sexual orientation or gender identity C. not discriminate against any individual because of race, color, national origin, gender, disability, religion, creed, age (for employment), marital status (for programs), sexual orientation, gender identity or socioeconomic status (for programs). We will take affirmative action in the employment of qualified minorities, females, individuals with disabilities, and veterans. Reasonable accommodation will be provided whenever possible in our effort to advance employment opportunities for disabled individuals. Our commitment to equal opportunity and affirmative action shall remain strong. Your continued support of these important employment guidelines and goals is much‐appreciated. Thank you for your time.
ToC
p. 5 of 25
Equal Employment Opportunity/Affirmation Action Coordinator The Keystone Area Education Agency 1 Board of Directors at its September 16, 2013, Board meeting appointed the following employee to develop, coordinate, and evaluate its Equal Employment Opportunity/Affirmative Action Plan: Teresa Shea‐Tajaran, Affirmative Action Coordinator Keystone Area Education Agency 1 1400 Second Street NW Elkader, IA 52043‐9564 Telephone: (563) 245‐1480 1‐800‐632‐5918 tshea‐
[email protected] Persons who have questions, concerns, or input should contact Ms. Shea‐Tajaran at the above address, telephone numbers or email address.
Distribution of Equal Employment Opportunity/Affirmative Action Plan The Keystone Area Education Agency Equal Employment Opportunity/Affirmative Action Plan shall be distributed to all local school district superintendents, the superintendent of the Archdiocese, all principals of approved nonpublic schools, Keystone AEA Board of Directors, Keystone AEA Administrative Leadership Team, each Keystone AEA office, the Keystone AEA Advisory Committee, and the president of the Keystone Education Association and the Keystone Education Support Staff Association. Electronic distribution will be the preferred delivery method. This policy will also be posted on the Agency’s website and on the intranet (known as the PLAZA). The plan is also available for inspection on the Agency’s web site at www.aea1.k12.ia.us or at the office of: Teresa Shea‐Tajaran, Affirmative Action Coordinator Keystone Area Education Agency 1400 Second Street NW Elkader, IA 52043‐9564 Telephone: (563) 245‐1480 1‐800‐632‐5918
ToC
p. 6 of 25
Work Force Analysis
Keystone AEA 1 Organizational Display
Keystone AEA Board of Directors Total: 9 2WF, 7WM
Administration Administrator, WM Total: 5 1WM, 1HM, 3 WF
Board Secretary (& Administrator’s Secretary) Total: 1 1WF
Sector I Coordinator, WF Total: 42 41WF, 2WM
Computer Center Manager, WM Total: 6 1WF, 5WM
Special Education Director, WM Total: 2 2WF
Instructional Services Directors, 2WF Total: 42 37WF, 5WM
ToC
Custodial Staff Supervisor, WM Total: 8 5WF, 3WM
Sector II Coordinator, WF Total: 31 27WF, 4WM, 1HF
Sector III Coordinator, WF Total: 28 27WF, 1HF
Sector IV Coordinator, WF Total: 57 52WF, 6WM
p. 7 of 25
2013‐2014 Staff Equity List
08/19/2013
Non‐Management Licensed Staff Division/Position Female Male Disability Instructional Services: School Improvement Facilitators 14 (92%) 1 (8%) 0 Media/Technology Consultant 1 (100%) 0 0 Technology Services Consultant 3 (100%) 0 0 Instructional Services Totals 18(95%) 1 (5%) 0 Special Education: Early Access Regional Coordinator 1 (100%) 0 0 ECSE Teachers 14 (100%) 0 0 Itinerant Teachers for Deaf and Hard‐of‐Hearing 2 (67%) 1 (33%) 0 Juvenile Home Teacher 0 2 (100%) 0 Occupational/Physical Therapist 10 (100%) 0 0 School Audiologist 4 (100%) 0 0 20(80%) 5 (20%) 0 School Psychologist School Social Worker 13 (87%) 2 (13%) 0 Special Education Consultant 10 (91%) 1 (9%) 0 Speech‐Language Pathologist 32 (97%) 1 (3%) 0 Assistive Technology Coordinator 1 (100%) 0 0 Transition Coordinator 1 (100%) 0 0 Special Education Totals 108(90%) 12(10%) 0 Total Non‐Management Licensed 126 (91%) 13 (9%) 0 Classified Staff Division/Position Administration: Custodian Part‐time Custodian Offices Assistants Instructional Services: Media Clerk Office Assistants Van Driver Special Education Services: Audiometrist COTA Communication Aides
ToC
Female
Male Disability
1 (33%) 3 (75%) 1 (100%)
2 (66%) 0 1 (25%) 0 0 0
8 (100%) 6 (100%) 0
0 0 0 0 4 (100%) 0
4 (100%) 6 (100%) 12 (100%)
0 0 0
0 0 0
p. 8 of 25
Instructional Aide Paraprofessional ‐ Vision Office Assistants Totals
1 (50%) 1 (100%) 12 (100%)
1 (50%) 0 0
0 0 0
55(87%)
8 (13%) 0
Management/Board Staff Division/Position Administration: Board/Administrator's Secretary Administrator Business Manager Instructional Services: Director of Comprehensive Improvement Director of Instructional Services Special Education Services: Division Director Sector Coordinators Assistant Sector Coordinator Totals
Female
Male Disability
1 (100%) 0 0
0 1 (100%) 1 (100%)
0 0 0
1 (100%) 1 (100%)
0 0
0 0
0 4 (100%) 1 (100%)
1 (100%) 0 0 0 0 0
8 (73%) 3 (27%) 0
Auxiliary Staff Division/Position Female Male Disability Administration: Computer System Manager 0 1 (100%) 0 Computer Programming/Network Specialist 1 (50%) 1 (50%) 0 Human Resources Associate 1 (100%) 0 0 Agency Information Services Specialist 0 1 (100%) 0 Instructional Services: Librarian 1 (100%) 0 0 Total Auxiliary 3 (50%) 3 (50%) 0 ************************************************************************************
ToC
p. 9 of 25
Organizational Support Staff Division/Position Administration: Maintenance Supervisor Financial Clerks, Tech Specialists Instructional Services: Media Delivery Manager Production Leader Special Education Services: Division Secretary Financial Clerk Parent Coordinator Totals
Female
Male Disability
0 1 (100%) 2 (33%) 4 (67%)
0 0
1 (100%) 1 (100%)
0 0
0 0
1 (100%) 1 (100%) 1 (100%)
0 0 0
0 0 0
7 (58%) 5 (42%) 0
Grand Totals
199 (86%) 32 (14%) 0
Quantitative Analysis Worksheets Tables 1, 2, and 3, which follow, show the current work force of the Keystone Area Education Agency by its three major divisions, Special Education Services, Instructional Services, and Administration. Keystone Area Education Agency has combined the Media and Educational Services Divisions into one division, Instructional Services. Table 1 Keystone Area Education Agency Quantitative Analysis Worksheet Special Education Services Division
KAEA Job Categories
Gender Males
No.
Management
%
No.
Race/Ethnicity Asian Pacific American Island Indian No. % No. %
Hispanic No.
%
Disability Disabilities No.
%
0
0
0
0
0
0
0
0
0
0
Social Workers 15
2 13.33 13 86.67 15
100
0
0
0
0
0
0
0
0
0
0
Psychologists 25 Speech‐Lang. 33 Pathologists It. Tchrs. Deaf 3 & Hard of Hrin
5 20.00 20 80.00 25
100
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1 3.03
0
0
ToC
1
3.03 32 96.97 32 96.97
1 33.33 2 0
83.33
White Non‐Hisp. No. %
Black Non‐Hisp. No. %
100
4
1 16.67 5
%
6
Audiologists
6
No.
Females
0
4
66.67
3
100
0
0
0
0
0
0
0
0
0
0
100
4
100
0
0
0
0
0
0
0
0
0
0
p. 10 of 25
KAEA Job Categories
Gender Males Females
No.
No.
11
1
2
0
0
2
100
OT/PT 10 Early 15 Childhood‐SE Juvenile Home 2 School
0
0
10
0
0
0
Special Ed. Consultants Tran/Asst Tec Coordinators
Office Assist. 12 Financial Clerks 1 Para‐ 25 professionals Parent 1 Coordinators Division 1 Secretary
%
No.
%
White Non‐Hisp. No. %
9.09 10 90.91 11
Black Non‐Hisp. No. %
Race/Ethnicity Asian Pacific American Island Indian No. % No. %
Hispanic No.
%
Disability Disabilities No.
%
100
0
0
0
0
0
0
0
0
0
0
2
100
0
0
0
0
0
0
0
0
0
0
100
10
100
0
0
0
0
0
0
0
0
0
0
15
100
15
100
0
0
0
0
0
0
0
0
0
0
0
2
100
2
100
0
0
0
0
0
0
0
0
0
0
0
0
12
100
12
100
0
0
0
0
0
0
0
0
0
0
0
0
1
100
1
100
0
0
0
0
0
0
0
0
0
0
1
4.00
24 96.00 24 96.00
0
0
0
0
0
0
1
4.00
0
0
0
0
1
100
1
100
0
0
0
0
0
0
0
0
0
0
0
0
1
100
1
100
0
0
0
0
0
0
0
0
0
0
Table 2 Keystone Area Education Agency Quantitative Analysis Worksheet Instructional Services Division
KAEA Job Categories
Gender Males
Females
Black Non‐Hisp. No. %
Race/Ethnicity Asian Pacific American Island Indian No. % No. %
100
0
0
0
0
0
No.
%
No.
%
White Non‐Hisp. No. %
Management 2 School Improvement 15 Facilitators
0
0
2
100
2
1
6.67 14
93.33 15
100
0
0
0
0
Librarians Media/Tech. Consultant Technology Consultants
1
0
0
1
100
1
100
0
0
0
1
0
0
1
100
1
100
0
0
3
0
0
3
100
3
100
0
Media Clerks
8
0
0
8
100
8
100
Office Assist.
6
0
0
6
100
6
Van Drivers Media Managers
4
4
100
0
0
2
0
0
2
100
No.
Hispanic
Disability Disabilities
No.
%
No.
%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
100
0
0
0
0
0
0
0
0
0
0
4
100
0
0
0
0
0
0
0
0
0
0
2
100
0
0
0
0
0
0
0
0
0
0
ToC
p. 11 of 25
Table 3 Keystone Area Education Agency Quantitative Analysis Worksheet Administration
KAEA Job Categories
No.
Gender Males No.
%
Females No.
%
White Non‐Hisp. No. %
Black Non‐Hisp. No. %
Race/Ethnicity Asian Pacific American Island Indian No. % No. %
No.
Hispanic %
Disability Disabilities No.
%
Board/Manag 3
2
66.67 1
33.33 3
100
0
0
0
0
0
0
0
0
0
0
Auxiliary Financial Clerks, Tech Specialists
5
2
40.00 3
60.00 4
80.00 0
0
0
0
0
0
1
20.00 0
0
6
4
66.67 2
33.33 6
100
0
0
0
0
0
0
0
0
0
0
Office Assist 1 Chief of Maintenance 1
0
0
1
100
1
100
0
0
0
0
0
0
0
0
0
0
1
100
0
0
1
100
0
0
0
0
0
0
0
0
0
0
3
2
66.67 1
33.33 3
100
0
0
0
0
0
0
0
0
0
0
4
1
25.00 3
75.00 4
100
0
0
0
0
0
0
0
0
0
0
Custodians Part‐Time Custodians
Table 4 presents the number and percent of Keystone Area Education Agency Employees by gender, racial/ethnic group, and disability within EEO‐1 job categories.
Work Force by Occupational Category Table 4 EEO‐1 Work Force by Occupational Category by Gender, Racial/Ethnic Composite and Disability Occupational Group Officials and Managers Professionals Technicians Sales Workers Administrative Support Workers Skilled Craft Workers Operatives Service Laborers & Helpers Grand Total
Total Males Females Minority Disabled No. No. % No. % No. % No. % 10 3 30% 7 70% 0 0 0 0 147 19 12.9% 128 87.1% 1 .7% 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 61 2 3.3% 59 96.7% 2 3.3% 0 0 1 1 100% 0 0 0 0 0 0 5 4 80% 1 20% 0 0 0 0 7 3 43% 4 57% 0 0 0 0 0 0 0 0 0 0 0 0 0 231 32 13.9% 199 86.1% 3 1.3% 0 0
ToC
p. 12 of 25
Keystone AEA Job Categories in Each EEO‐1 Occupational Category Officials and Managers: Administrator, Director of Comprehensive Improvement, Director of Special Education, Director of Instructional Services, Sector Coordinators, Assistant Sector Coordinators, Business Manager Professionals: School Improvement Facilitators, Media/Technology Consultant, Technology Consultants, ECSE Teachers, Early Access Regional Coordinator, Teachers Deaf and Hard‐of Hearing, Juvenile Home Teachers, OT/PTs, Audiologists, Psychologists, Social Workers, Special Education Consultants, Speech & Language Pathologists, Assistive Technology Coordinator, Transition Coordinator, Computer System Manager, Computer Programmer/Network Specialist, Librarians, Technology Support Specialists Technicians: None Sales Workers: None Administrative Support Workers: Board Secretary, Division Secretary, Financial Clerks, Production Leader, Media Delivery Manager, Human Resources Associate, Agency Information Services Specialist, Parent Coordinators, Office Assistants, Media Clerks, Audiometrists, C.O.T.A.s, Communication Aides, Instructional Aides, Paraprofessionals – Vision, Staff Accommodation Aides Craft Workers: Maintenance Supervisor Operatives: Media Clerk‐Print Shop, Van Drivers Laborers and Helpers: None Service Workers: Custodians
Relevant Labor Market
The Keystone Area Education Agency recruits primarily in the state of Iowa for its Officials, Management positions and Professional positions. For Technicians, Administrative Support Workers, Skilled Craft Workers, Operatives, Service Workers, and Laborers and Helpers, the Agency recruits within Region 1, this is the same as the eight counties that the Agency serves. The following eight counties are included within the boundaries of the Keystone Area Education Agency and Region 1: Allamakee, Chickasaw, Clayton, Delaware, Dubuque, Fayette, Howard and Winneshiek. For purposes of comparing percentages available in the relevant labor market, data from Region 1 of the State of Iowa was determined most appropriate for Technicians, Administrative Support, Skilled Craft Workers, Operatives, Service Workers, and Laborers and Helpers.
For purposes of comparing percentages of Management and Officials and professional positions, data from the state of Iowa was used. ToC
p. 13 of 25
Quantitative Analysis Table 5 Quantitative Analysis by EEO‐1 Occupational Categories State of Iowa WF–Work Force; A–Available in relevant labor market; DA–Disabled; NA‐Not Applicable
Occupational Group Officials and Managers
Professionals Technicians Sales Workers Administrative Support Workers Craft Workers
Operatives
Laborers & Helpers Service Workers
Under‐ Gender Minority Disability representation Males Females %WF %A %WF %A %WF %A %WF %A 30 67 70 33 0 2.6 0 5.0 Males, Minorities, Disabled 12.9 41.8 87.1 58.2 .7 5.3 0 5.0 Males, Minorities, Disabled NA 29.4 NA 70.6 NA 1.2 NA 5.0 NA NA NA NA NA NA NA NA NA NA 3.3 18.7 96.7 81.3 3.3 1.5 0 5 Males, Minorities Disabled 100 94.4 0 5.6 0 1.0 0 5.0 Females Minorities Disabled 80 71.7 20 28.3 0 4.1 0 5.0 Females Minorities Disabled NA 79.8 NA 20.2 NA NA NA NA NA 43 27.9 57 72.1 0 3.5 0 5 Females Minorities Disabled
ToC
p. 14 of 25
Quantitative Goals Job Category
Under‐ repre‐ senta‐ tion
All employees
All minorities and disabled
28 in the next 2 9 minorities To recruit 9 minori‐ years. 3 disabled ties Agency‐wide. To recruit 3 employees with a disability.
Officials and Managers
Minorities and Disabled
2 in next 2 years
Professionals
Males, 17 in the next 2 10 males, To recruit 10 males, Minorities, years. 5 minorities 5 minorities, and And 2 disabled 2 employees with a Disabled disability
Administrative Support Workers
Males, 6 in next two Minorities, years Disabled
4 males, 1 minority, 1 disabled
To recruit 4 males, 1 minority, and 1 employee with a disability
Skilled Craft Workers
Minorities, 1 in next two Disabled years
1 minority or 1 disabled
To recruit an individual who is either a minority or has a disability
Operatives
Minorities, 1 in next two Disabled years
1 minority or 1 disabled
To recruit an individual who is either a minority or has a disability
Service Workers
Minorities, 1 in next two Disabled years
1 minority or 1 disabled
To recruit an individual who is either a minority or has a disability
Projected Vacancy
Goal
Goal Statement
1 minority To recruit 1 1 disability minority and/or 1 employee with a disability.
Responsible Employee
Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel. Teresa Shea‐ Tajaran Affirmative Action Coordinator and all management personnel.
Time Line
July 1, 2015
July 1, 2015
July 1, 2015
July 1, 2015
July 1, 2015
July 1, 2015
July 1, 2015
ToC
p. 15 of 25
Qualitative Goals
Statement of Problem: Current employment practice does not discriminate because of race, gender, or disability. Race, gender, and disability need to become a selection criteria where under representation is identified if applicants are approximately equal. Nothing should prevent the Agency from hiring the most qualified candidate, however. Goal 1: Where applicants are relatively equal, race, gender, or disability shall be used as a selection criteria for vacancies in position categories in which under representation exists. Employee Responsible: Teresa Shea‐Tajaran, Human Resources Associate, Patrick Heiderscheit, Administrator and all employees who are responsible for screening applicants for position vacancies. Time Line: June 30, 2014 Statement of Problem: Although advertising for official and management positions is currently nationwide, and advertising for professional positions is primarily in the state of Iowa, a more aggressive approach to recruiting minorities, under‐represented genders and individuals with disabilities needs to be undertaken. Goal 2: To ensure that applicants nationwide understand the Agency’s policy on equal employment opportunity/affirmative action, the policy should be distributed on a nationwide basis utilizing available technology for maximum impact and minimum cost. Employee Responsible: Teresa Shea‐Tajaran, Human Resources Associate. Time Line: June 30, 2014 Statement of Problem: All hiring managers and supervisory personnel need uniform professional development on affirmative actions and other related equity issues. Goal 3: To provide professional development for all personnel responsible for screening, interviewing and supervising on the principles of affirmative action and equity. Employee Responsible: Patrick Heiderscheit, Administrator Time Line: January 1, 2014 Statement of Problem: Position descriptions and evaluation system needs to continue to reflect sensitivity to equity issues. Goal 4: To revise current position descriptions and evaluation instruments to continue to include equity issues including the identification of critical elements of each position. Employee(s) Responsible: Administrative Council Members Time Line: June 30, 2014 Statement of Problem: All employees need to be aware of the agency’s affirmative action plan. Goal 5: To provide access to the agency’s affirmative action plan to all employees by ensuring it is posted on the Agency’s website and intranet. Email communications will also go out to all staff notifying them of the location to the plans. Print copies will be provided upon request. Employee Responsible: Teresa Shea‐Tajaran, Human Resources Associate/Affirmative Action Coordinator. Time Line: October 1, 2013
ToC
p. 16 of 25
Definitions "Affirmative action" means action appropriate to overcome the effects of past or present practices, policies, or other barriers to equal employment opportunity. "Agency" means a local school district, an area education agency or a community college. "Availability" means the extent to which members of a racial/ethnic group, women, men or persons with disabilities are present within the relevant labor market. "Director of education" means the director of the Iowa department of education. "Equal employment opportunity" means equal access to employment, training and advancement, or employment benefits regardless of race, creed, color, religion, sex, age, national origin and disability. "Person with a disability" means any person who has a physical or mental impairment which substantially limits one or more major life activities, has a record of such impairment or is regarded as having such an impairment, as defined by civil rights commission subrule 161—8.26(1). "Racial/ethnic minority person" means any person who is African‐American, Hispanic, Asian or Pacific Islander, American Indian or Alaskan Native. "Relevant labor market" means the geographic area in which an agency can reasonably be expected to recruit for a particular job category. "Underrepresentation" means having fewer members of a racial/ethnic group, women, men or persons with disabilities in a particular job category than would be reasonably expected based on their availability in the relevant labor market. "Work force" means an agency’s full‐time and part‐time employees.
ToC
p. 17 of 25
Appendix Comprehensive Equity Policy (Policy)
Chapter: Section: Number:
Personnel Employment of Personnel 4100
Comprehensive Equity Policy Keystone Area Education Agency shall be free of any form of discrimination in its employment practices, educational programs, and work environment. The Agency shall provide equal employment opportunity to all qualified job applicants regardless of race, color, national origin, gender, disability, age, religion, creed, sexual orientation or gender identity. Additionally, the Agency will affirmatively recruit women and men, members of diverse racial/ethnic groups, and persons with disabilities for job categories where those populations are under‐represented. The Agency shall provide equal access to its educational programs to all individuals regardless of race, color, national origin, gender, disability, religion, creed, marital status, sexual orientation, gender identity or socioeconomic status. The Agency shall provide a fair, supportive, and harassment‐free work environment for all employees regardless of their age, color, creed, national origin, race, religion, marital status, sex, sexual orientation, gender identity, physical attributes, physical or mental ability, ancestry, political party preference, political belief, socioeconomic status, or familial status. Inquiries or grievances related to this policy may be directed to Educational Equity Coordinator, Keystone AEA Administration, 1400 Second Street N.W., Elkader, Iowa 52043‐9564, telephone 563‐245‐1480, to the director of the Iowa Civil Rights Commission, to the Director of the Region VII Office of the United States Equal Employment Opportunity Commission in Milwaukee, Wisconsin, or to the Region VII Office of Civil Rights within the United States Department of Education in Milwaukee, Wisconsin. References: Titles VI and VII of the Civil Rights Act of 1964 (42 U.S.C. Section 2000d and 2000e), The Equal Pay Act of 1973 (29 U.S.C. Section 206, et seq), Title IX (Educational Amendments, 20 U.S.C. Sections 1681—1688, Section 504), Rehabilitation Act of 1973 (29 U.S.C. Section 794), Americans with Disabilities Act (42 U.S.C. Section 12101, et seq.) Iowa Code, Sections 19B.11, 216.9 Adopted: May 21, 1990 Amended: May 17, 2004 October 18, 2010 September 17, 2012 September 16, 2013
ToC
p. 18 of 25
Affirmative Action Compliance Program (Rule)
Chapter: Section: Number:
Personnel Employment of Personnel 4100.R1
Affirmative Action Compliance Program The Keystone Area Education Agency has an established policy of equal employment opportunity with respect to race, color, national origin, gender, disability, age, religion, creed, sexual orientation or gender identity. The Agency has an established policy of taking affirmative action in recruitment, appointment, assignment, and advancement of women, minorities and disabled persons. The Board expects administration to know of and fully accept the equal opportunity and affirmative action policies and to make certain that no employee or applicant for employment shall suffer any form of discrimination because of race, color, national origin, gender, disability, religion, creed, age (for employment), marital status (for programs), sexual orientation, gender identity or socioeconomic status (for programs). In order to effectively communicate and interpret the Agency’s policies to all levels of the administration and to all other employees, community and educational agencies, and the public in general, the following will be undertaken: A. Dissemination of policy 1) Employees will be reminded annually of the Agency’s written statement of policy by: a) Description of policy by publication or reference in all issues or re‐issues of personnel handbooks. b) When appropriate, publicize the EEO policy and such activities through news stories or other articles in Agency publications. c) Detailed discussions at administrative conferences and staff meetings. 2) Employment advertisements will contain assurance of equal employment opportunity. 3) All employment and recruiting sources where jobs are listed by the Agency will be reminded of our policy, both verbally and in writing. 4) Notices will be posted on bulletin boards and in locations where applicants are interviewed. These will inform employees and applicants of their rights under federal and state civil rights laws. B. Responsibility for implementing the Affirmative Action Program 1) Responsibility is assigned to the affirmative action coordinator, who will render full assistance and support for those seeking help and assistance in taking affirmative action. C. Recruiting 1) Additional emphasis will be given to seeking and encouraging applicants from minority groups, women’s groups and disabled groups where such applicants with the necessary qualifications or potentials are available.
ToC
p. 19 of 25
D. Training 1) All training and in‐service programs supported or sponsored by the Agency will continue to be equally open to minority, female and disabled employees on the basis of qualifications. E. Hiring, placement, transfer, layoff, and recall 1) The Agency recognizes that to accomplish the long‐range objectives of its equal employment opportunity policy, continued affirmative action must be taken to ensure that job opportunities of all kinds are called to the specific attention of members of minority groups, women, and disabled persons and that qualified members of such groups should be offered positions on the same basis as all other applicants or employees. To assure achievement of the objectives, the Agency will periodically review its practices in hiring job applicants. F. Compensation 1) All employees, including women, minority groups and disabled employees, will receive compensation in accordance with the same standards. Opportunities for performing overtime work or otherwise earning increased compensation will be afforded to all qualified employees without discrimination based on race, color, national origin, gender, disability, religion, creed, age, sexual orientation, or gender identity. This Affirmative Action Program will be reviewed and updated biannually. Inquiries by employees or applicants for employment regarding compliance with equal employment opportunity and affirmative action shall be directed to the affirmative action coordinator, Teresa Shea‐ Tajaran, Keystone Area Education Agency, 1400 Second Street N.W., Elkader, Iowa 52043. Inquiries may also be directed, in writing, to the Iowa Civil Rights Department, to the Director of the Region VII Office of Civil Rights, Department of Education, Milwaukee, Wisconsin, or to the director of the Region VII Office of the United State Equal Employment Opportunity Commission in Milwaukee, Wisconsin. Such inquiry or complaint to the state or federal office may be done instead of, or in addition to, an inquiry or complaint at the local level.
Further information and copies of the procedures for filing a complaint are available in the Agency’s administration office. Reference: Policies 4100 and 4102 Adopted: May 21, 1990 Amended: September 16, 2013
ToC
p. 20 of 25
Grievance Procedures for Non‐discrimination in Educational Programs and Employment (Rule)
Chapter: Section: Number:
Personnel Employment of Personnel 4100.R3
Grievance Procedures for Non‐discrimination in Educational Programs and Employment Students, parents of students, applicants for employment, publically and approved nonpublic schools and their personnel, and employees of the Keystone Area Education Agency shall have the right to file a formal complaint alleging noncompliance with federal and state regulations requiring nondiscrimination in educational programs and employment. Level One‐Immediate Supervisor (Informal and Optional‐may be bypassed by the grievant) Employees with a grievance of discrimination on the basis of race, color, national origin, gender, disability, religion, creed, age, sexual orientation or gender identity may first discuss it with their immediate supervisor, with the objective of resolving the matter informally. A student or a parent with a complaint of discrimination on the basis of race, color, national origin, gender, disability, religion, creed, marital status, sexual orientation, gender identity or socioeconomic status may discuss it with the Agency educational equity/affirmative action coordinator. An applicant for employment with a complaint of discrimination on the basis of race, color, national origin, gender, disability, age, religion, cred, sexual orientation or gender identity may discuss it with the Agency educational equity/affirmative action coordinator. Level Two—Educational Equity/Affirmative Action Coordinator If the grievance is not resolved at level one and the grievant wishes to pursue the grievance, they may formalize it by filing a complaint in writing on a “compliance violation form,” which may be obtained from the educational equity/affirmative action coordinator. The complaint shall state the nature of the grievance and the remedy requested. The filing of the formal, written complaint at level two must be within 15 working days from the date of the event giving rise to the grievance or from the date the grievant could reasonably become aware of such occurrence. The grievant may request that a meeting concerning the complaint be held with the educational equity/affirmative action coordinator. A minor student may be accompanied at that meeting by a parent or guardian. The educational equity/affirmative action coordinator shall investigate the complaint and attempt to resolve it. A written report from the compliance officer regarding action taken will be sent within 15 working days after receipt of the complaint.
ToC
p. 21 of 25
Level Three—Administrator If the complaint is not resolved at level two, the grievant may process it to level three by presenting a written appeal to the administrator within ten working days after the grievant receives the report from the educational equity/affirmative action coordinator. The grievant may request a meeting with the administrator or his/her designee. The administrator or his/her designee has the option of meeting with the grievant to discuss the appeal. A decision will be rendered by the administrator or his/her designee within 10 working days after receipt of the written appeal. Level Four—Impartial Third‐party Hearing If the complaint has not been satisfactorily resolved at level three—administrator, the grievant(s) may request in writing an impartial third‐party hearing. The written request shall be filed with the administrator/designee within 30 calendar days of the receipt of the administrator’s decision at level three. The impartial hearing shall be conducted by a hearing officer to be selected by the Agency and the person(s) filing the complaint. The hearing officer shall be an administrative law judge or another third‐party hearing officer that is qualified to hear complaints related to alleged non‐compliance with federal and state regulations requiring non‐discrimination in educational programs and employment. The impartial third‐ party hearing officer selected shall set the date and time of the hearing. This procedure in no way denies the right of the grievant to file formal complaints with the Iowa Civil Rights Commission, the federal Office of Civil Rights or the Equal Employment Opportunity Commission for mediation or rectification of civil rights grievances, or to seek private counsel for complaints alleging discrimination. The educational equity/affirmative action coordinator is: Teresa Shea‐Tajaran Keystone Area Education Agency 1400 2nd Street N.W. Elkader, Iowa 52043‐9564 563‐245‐1480 Office Hours– 8 a.m. to 4:30 p.m. Adopted: Amended:
October 29, 1979 (F‐1) June 26, 1984 May 17, 2004 September 16, 2013
ToC
p. 22 of 25
Harassment (Policy)
Chapter: Section: Number:
Personnel General Personnel Considerations 4506
Harassment All forms of harassment of employees will not be tolerated in Keystone AEA. The Agency includes all Agency‐ utilized facilities, Agency premises, and non‐Agency property if the employee is at any Agency‐sponsored, Agency‐approved or Agency‐related activity or function, such as professional development activities, performing job‐related functions at school or where the employee is engaged in Agency business. The Board prohibits harassment or any other victimization of employees based upon any of the following actual or perceived traits or characteristics, including but not limited to, age (actual or perceived), color, creed, national origin, race, religion, marital status, sex, sexual orientation, gender identity, physical attributes, physical or mental ability or disability, ancestry, political party preference, political belief, socioeconomic status or familial status. Harassment by board members, administrators, employees, parents, students, vendors, and others doing business with the Agency is prohibited. Employees whose behavior is found to be in violation of this policy will be subject to the investigation procedure which may result in discipline, up to, and including, discharge or other appropriate action. Other individuals whose behavior is found to be in violation of this policy will be subject to appropriate sanctions as determined and imposed by the administrator or Board. Reference: Meritor Savings Bank v. Vinson, 477 U.S. 57 ( 1986). Hall v. Gus Const. Co., 842 F2d 1010 (8th Cir. 1988). Lynch v. City of Des Moines, 454 N.W. 2d 827 (Iowa 1990). 42 U.S.C. §§ 2000e et seq. (1988) Adopted: October 18, 1982 Reviewed: May 17, 2004 October 18, 2010 Amended: September 16, 2013
ToC
p. 23 of 25
Educational Equity Statement (Policy)
Chapter: Section: Number:
Programs and Services General Principles 5000.1
Educational Equity Statement The Keystone Area Education Agency does not discriminate on the basis race, color, national origin, gender, disability, religion, creed, age (for employment), marital status (for programs) sexual orientation, gender identity or socioeconomic status (for programs) in its educational programs, activities, or employment policies as required by Title VI and VII of the 1964 Civil Rights Act, Title IX of the 1972 Education Amendments, and Section 504 of the Federal Rehabilitation Act of 1973. The content of Keystone AEA’s curriculum and instructional materials must reflect the cultural and racial diversity present in the United States and the variety of careers, roles, and life styles open to women as well as men in our society. Harassment of a sexual nature or with demeaning intent related to but not limited to age (actual or perceived), color, creed, national origin, race, religion, marital status, sex, sexual orientation, gender identity, physical attributes, physical or mental ability or disability, ancestry, political party preference, political belief, socioeconomic status or familial status, made from an employee of the Agency to a student in an Agency program, from a student in an Agency program to another student in an Agency program, or from a student in an Agency program to an Agency employee, is a violation of this policy. Inquiries regarding compliance with this policy may be directed to Teresa Shea‐Tajaran, Educational Equity Coordinator, 1400 2nd Street N.W., Elkader, Iowa 52043‐9564, to the director of the Iowa Civil Rights Commission in Des Moines, Iowa, to the director of the Region VII Office of Civil Rights, Department of Education, Milwaukee, Wisconsin, or to the director of the Region VII Office of the United States Equal Employment Opportunity Commission in Milwaukee, Wisconsin. Adopted: March 18, 1985 Amended: December 16, 1996 October 18, 2010 September 16, 2013
ToC
p. 24 of 25
Compliance Violation Form
ToC
p. 25 of 25