Student Policies

3.1 Anti-Discrimination, Anti-Harassment, and Title IX Policy

*The text below is a summary of COL’s Anti-Discrimination, Anti-Harassment and Title IX Policy (“Policy”).  For the full Policy, please visit www.collegesoflaw.edu or click HERE. 

Introduction

COL acknowledges its ethical and statutory responsibility to afford equal treatment and equal opportunity to all persons and thus complies with all applicable laws and directives regarding nondiscrimination and equality of opportunity. As required by Title VI, Title IX, Section 504 and all other applicable federal and state laws, COL does not discriminate and prohibits discrimination and harassment against its employees, students, and applicants based on race, ethnicity, color, sex, gender, gender identity, gender expression, genetic information,  religion, creed, age (40 years or older), national origin or ancestry, sexual orientation, physical or mental disability, marital or parental status, pregnancy, military or veteran status, political activities/affiliations or any other impermissible reason in its programs and activities.

COL is committed to creating and maintaining a safe learning and working environment that is free from unlawful discrimination, harassment and retaliation.  The Policy prohibits discrimination, harassment, and sexual misconduct, which includes Sexual Harassment, and all other forms of discrimination and harassment based on membership in any Protected Category.  The Policy also prohibits retaliation against anyone who exercises their rights under the Policy.

The Policy applies to all employees, students, and other COL Community Members.  COL has jurisdiction to investigate conduct occurring on COL’s campuses, in connection with its educational programs, activities, and services, or that puts COL community members at risk of serious harm or otherwise creates a hostile learning and/or working environment.

Discrimination

Discrimination is an adverse action taken against or harassment of an individual based on membership in any Protected Category. 

Harassment

Harassment refers to unwelcome behavior based on membership in any Protected Category. Harassment becomes impermissible where 1) enduring the offensive conduct becomes a condition for any academic-related purpose, or 2) the conduct is severe or pervasive enough to create an academic environment that a reasonable prudent person would consider intimidating, hostile, or abusive.

Sexual Harassment, as an umbrella category includes the offenses of sexual harassment, sexual assault, domestic violence, dating violence, and stalking, and is defined as:

Conduct on the basis of sex that satisfies one or more of the following: quid pro quo, sexual harassment, sexual assault, dating violence, domestic violence, stalking as defined in the full Policy.  Sexual Harassment may fall within or outside of the Title IX definition of Sexual Harassment found in Appendix B of the full Policy.

Petty slights, annoyances, and isolated incidents will not rise to the level of violation of a COL policy or rule. To be considered a violation, the conduct must create an environment that would be intimidating, hostile, or offensive to a reasonable person.

Offensive conduct may include but is not limited to jokes, slurs, epithets or name calling, physical assaults or threats, intimidation, ridicule or mockery, insults or put-downs, offensive objects or pictures, or interference with academic performance.

When discriminatory harassment rises to the level of creating a hostile environment, COL may also impose sanctions on the Respondent through the application of the appropriate grievance process set forth in the Policy.

The Policy includes a prohibition of online and cyber manifestations of any of the behaviors prohibited through this policy when those behaviors occur in or have an effect on COL’s education program and activities or use COL’s networks, technology, or equipment.

Retaliation

COL also bars retaliation against any person who exercises their rights under the policy, including filing a good faith report of discrimination or harassment, participating in the complaint resolution procedures relating to the same, supporting a Complainant or Respondent, or assisting in providing information relevant to an investigation.

Reporting Complaints of Discrimination, Harassment, or Retaliation

For the full Policy as well as additional resources, please visit www.collegesoflaw.edu or click HERE.

A student who believes they have been subject to unlawful discrimination, harassment or retaliation on the basis of a Protected Category, whether by faculty members, employees, training supervisors, visitors or other students, should report such matters to the Office of Student Services or the Title IX Coordinator.   Preparation of a written complaint may be required depending on the basis for the complaint. Complaints should include details of the incident or incidents, names of the individuals involved, names of any witnesses and any documents supporting the complaint.

Response to Complaints - Resolution Processes

When the Office of Student Services or Title IX Coordinator receives a complaint, they will take prompt and appropriate action.  The process used to address the complaint will depend on the subject matter of the complaint.  For complaints of Title IX Sexual Harassment, the Title IX Grievance Process, as described in Section C of the Policy will be used.  For all other complaints, the General Discrimination, Harassment and Retaliation Resolution Process, as described in Section B of the Policy, will be used.  In some instances, an informal resolution process may be used, if deemed appropriate.  Complaints and investigations will be handled on a confidential basis, to the extent possible, with regard for the rights of Complainants and Respondents. Information about the complaint and investigation will only be released on a need-to-know basis, or as otherwise required or permitted by law.

Other Reporting Options

Students may also decide to report to law enforcement, if applicable, although they are not required to do so.  Reporting of sexual assault, domestic violence, dating violence, and stalking to the police does not commit the Complainant to further legal action. However, the earlier an incident is reported, the easier it will be for the police to investigate if the Complainant decides to proceed with criminal charges. Early reporting makes it more likely that the police will be able to gather needed evidence before it is lost or destroyed, and that the Complainant will receive timely notice of potentially helpful victim/witness services.

In addition, students may contact a professional counselor, domestic violence counselor or pastoral counselor, not connected to COL, either through Student Solutions, or through other agencies or resources. Information about Student Solutions and other resources is available on the Gateway. COL encourages community members who have experienced sexual misconduct to immediately report the incident to the local police department or another area law enforcement agency. 

Supportive Measures

Complainants and Respondents may request supportive measures, including but not limited to academic support, extensions of academic deadlines, class schedule modifications, withdrawals, leaves of absence, no-contact order, student financial aid counseling and referral to counseling, medical or other healthcare services and visa and immigration assistance, which shall be provided, as deemed appropriate, in accordance with the Policy.  Supportive measures are non-disciplinary, non-punitive individualized services offered as appropriate, as reasonably available, and without fee or charge to the parties to restore or preserve access to COL’s Education Program or Activity, including measures designed to protect the safety of all parties or COL’s educational environment, and/or deter harassment, discrimination, and/or retaliation.

COL will maintain the privacy of the supportive measures, provided that privacy does not impair COL’s ability to provide the supportive measures. COL will act to ensure as minimal an academic impact on the parties as possible. COL will implement measures in a way that does not unreasonably burden any party.

Emergency Removal

In certain circumstances, the Office of Student Services or Title IX Coordinator may determine that an emergency removal is appropriate.  If that decision is made, the Respondent will be notified of the decision and be given the option to meet with the Office of Student Services or Title IX Coordinator prior to such emergency removal being imposed or as soon thereafter as reasonably possible to show cause why the action should not be implemented or should be modified.

Title IX Advisors

The Complainant and Respondent are entitled to have a Title IX Advisor of their choosing accompany them to any meeting or proceeding within the Title IX Formal Grievance process, if they so choose.   The parties may select whoever they wish to serve as their Title IX Advisor as long as the Title IX Advisor is eligible and available. At the hearing, cross-examination is required and must be conducted by the parties’ Title IX Advisors. The parties are not permitted to directly cross-examine each other or any witnesses. If a party does not have a Title IX Advisor for a hearing, COL will appoint a trained Title IX Advisor for the limited purpose of conducting any cross-examination during the hearing.  Contact the Title IX Coordinator to obtain a list of those individuals available to serve as a Title IX Advisor.

Sanctions and Remedial Action

If COL determines that the Policy was violated, sanctions may be imposed and effective remedial action will be taken.  Individuals who violate the Policy will be subject to disciplinary action, up to and including removal from COL.  In addition, appropriate action will be taken to deter any future unlawful discrimination, harassment or retaliation.

For students, the sanctions that may be imposed include:

• Formal written warning;
• Performance Improvement Plan (a plan intended to require reflection and remediation of behavior found to have violated this Policy);
• No contact order pertaining to certain COL community members or physical locations;
• Probation (A written reprimand for violation of this Policy, providing for more severe disciplinary sanctions in the event that the student is found in violation of any institutional policy, procedure, or directive within a specified period of time. Terms of the probation will be articulated and may include denial of specified social privileges, exclusion from co-curricular activities, exclusion from designated areas of campus, no-contact orders, and/or other measures deemed appropriate);
• Suspension;
• Withholding of a degree;
• Referral to counseling services and/or Student Solutions for the Respondent; and/or
• Expulsion from COL.

Appeals

The parties have the right to appeal a decision made, in certain circumstances. The details of the appeals process depend on the subject matter of the complaint.  For appeals resulting from a report of Title IX Sexual Harassment, the Appeals process contained within the Title IX Grievance Process, as described in Section C of the Policy, will be used.  For all other appeals, the General Discrimination, Harassment and Retaliation Resolution Process, as described in Section B of the Policy, will be used. 

3.2 Commitment to Diversity

COL strives to foster an environment of mutual respect and inclusion in which all individuals will be valued for who they are and what they can contribute, as participatory members of professional communities that promote cultural awareness, freedom from bias, and appreciation of diversity. 

To further advance COL’s commitment to diversity, in October 2023, the Board approved a charter to establish the Access, Belonging, and Community (ABC) Council comprising of members of the COL community, including faculty, staff, students, and alumni. The mission of the ABC Council is to advance a culture of diversity, equity, and inclusion within COL’s community by fostering an inclusive environment and cultivating cultural competence and humility. 

3.3 Academic Freedom

1. Student Academic Freedom
   Academic freedom includes the freedom to lawfully express opinions, raise questions, and advocate positions in matters of academic or scholarly significance, in a civil and professional manner (see also Section 3.8, Student Code of Ethics and Conduct). COL supports academic freedom for students in academic settings, including classrooms, internship settings, and COL sponsored activities and events. Students will be evaluated based upon the merits of their responses or performance and their subject matter knowledge, not on extraneous considerations such as their ethnicity, political views, religious beliefs, or other personal beliefs or attributes.
    
2. Faculty Academic Freedom
   Academic freedom includes the freedom to lawfully express opinions, raise questions, and advocate positions in matters of academic or scholarly significance, as well as the general prerogative of an instructor to determine how to present the overall subject matter of an assigned course and the primary right to evaluate the performance of students enrolled in the course.
   
   Academic freedom is essential to the achievement of COl’s mission. It is COL’s policy, therefore, to encourage freedom of inquiry, discourse, teaching, research, and publication and to protect members of the faculty against influences that would restrict the exercise of these academic freedoms in areas of scholarly interest. COL subscribes to the principles of academic freedom formulated by the American Association of University Professors (AAUP) as generally summarized below¹:
   1. Each faculty member is entitled to full freedom in research and in the publication of the results, subject to the adequate performance of other academic duties; research for pecuniary return, however, should be based upon an understanding with COL’s administration.
   2. Each faculty member is entitled to freedom in the classroom in discussing a subject but should be careful not to introduce teaching of a controversial matter that has no relation to the faculty member’s subject. Limitations of academic freedom because of specific aims of the institution should be clearly stated in writing at the time of the appointment.
   3. Each faculty member is a citizen and a member of a learned profession. When an instructor speaks or writes as a citizen, the writing should be free from institutional censorship or discipline, but the instructor’s special position in the community imposes special obligations. As a person of learning and an institutional community member, the instructor should remember that the public might judge the instructor’s profession and the institution by the instructor’s utterances. Hence, the instructor should at all times be accurate, exercise appropriate restraint, show respect for the opinions of others, and make every effort to indicate that the teacher is not an institutional spokesperson.

¹By adopting the AAUP statement regarding academic freedom, COL does not adopt or endorse AAUP interpretive statements or other policies.

3.4 Educational Objectives

COL’s educational objectives are set forth as Institution-wide Competencies, Program Learning Objectives, and Student Learning Outcomes. For each program, the Student Learning Outcomes are defined generally and in the context of each course. Program Learning Objectives and Student Learning Outcomes specific to each program are set forth in sections entitled JD-Academic Program , and MBLT-Academic Program . The Institution-wide Competencies are as follows:

3.5 Student Learning Assessment Plan

Plan for Assessing Student-Focused Learning
The plan for Assessing Student Learning supports student development in COL’s institution-wide competencies of Knowledge of Law, Practice Skills and Ethical and Professional Values.  The plan identifies, for each program, the linkage between these goals, program learning objectives, and student learning outcomes.

 

3.6 Family Education Rights and Privacy Act (FERPA)

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1. General
   For FERPA compliance, COL considers all students independent. Questions should be directed to the Office of the Registrar.
2. Right to Inspect and Revie​w
   Students may inspect and review their education records within forty-five (45) business days after COL receives a written request. Requests must be submitted in writing to the Office of the Registrar and identify the record(s) to be inspected. The Registrar or designee will arrange access and provide instructions. (If the Registrar does not maintain the requested record, the student will be directed to the appropriate office).
3. Right to Request Amendments
   Students may request correction of education records they believe are inaccurate or misleading by submitting a written request to the Registrar that clearly identifies the portion to be changed and explains why.
4. Right to Request a Hearing
   COL has the right to decide whether to amend a student’s education record as requested by the student. If COL decides not to amend the record as requested by the student, the Registrar will refer the request to the Dean, who will act as the hearing officer.  The hearing will be conducted according to the following procedures:
   1. The student may present evidence supporting the claim.
   2. A COL representative may present evidence supporting its position.
   3. Each party will be present during the hearing and may challenge information and materials of the other party.
   4. Students unable to attend in person may participate via phone or conference video. 
   5. A decision is typically issued within five (5) business days after the hearing. FERPA does not permit challenges to substantive academic judgments (e.g., disputing a grade simply because a higher grade is desired).
5. Right to Consent to Disclosures
   Students may consent to disclosure of personally identifiable information, except where FERPA allows disclosure without consent.
6. Right to File a Complaint
   Students may file complaints regarding alleged FERPA violations with:

Family Policy Compliance Office

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202-5920

   G. Right to Restrict Directory Information

Students may restrict the release of directory information (except to officials with legitimate educational interests and as otherwise permitted) by submitting a written FERPA Restriction Form to the Registrar. This restriction remains in effect until revoked in writing. 

COL Designates the following as directory information, which may be released publicly (e.g., verbally, in writing, electronically, or in publications):

1. Student name 
2. Mailing address(es) 
3. E-mail address(es) 
4. Telephone number(s) 
5. Major field of study 
6. Degree sought 
7. Expected date of completion of degree requirements and graduation 
8. Degrees and awards received 
9. Dates of attendance 
10. Full- or part-time enrollment status 
11. Previous educational agency or institution attended 
12. Participation in officially recognized activities 
13. Photograph(s) 

3.7 Student Code of Ethics and Conduct

1. This Student Code of Ethics and Conduct (Code) applies to all students. Each student’s admission to and continued enrollment at, COL is expressly conditioned upon such student’s good faith adherence to the provisions, intent, and purposes of this Code.
    
2. Students are subject to this Code at all times while enrolled at the School, while at campus, during class or while participating in any school activity. 
    
3. COL may take disciplinary action against any student whose conduct, in the administration’s judgment, calls into serious question the student’s fitness to remain in a professional legal institution, including conduct that falls short of the high ethical standards expected of future officers of the court, infringes on the rights of others, disrupts COL’s operations, or violates any COL policy; these standards are grounded in the California State Bar’s Attorney Guidelines of Civility and Professionalism (available at http://www.calbar.ca.gov/Attorneys/Conduct-Discipline/Ethics/Attorney-Civility-and-Professionalism). 

4. Examples of conduct and situations subject to disciplinary action include, but are not limited to, the following:

   1. Engaging in offensive, rude, or disruptive behavior or behavior that otherwise violates any COL announced policy. Such behavior includes, but is not limited to, attending class under the influence of alcohol or drugs, engaging in loud or boisterous conversation during class, and eating food in the classrooms except as part of a class or school activity.
   2. Using profanity; making obscene, vulgar, or intimidating gestures; or making threats directed at or to another person in person or by electronic or any other method or means.
   3. Engaging in academic dishonesty, including but not limited to plagiarism (use of others’ words, ideas or work product without appropriate recognition or citation); unauthorized collaboration with students or others; or using, giving, or receiving unauthorized aid, equipment, or materials during an examination or for any required writing or activity for any course.
   4. Students may not submit any content that was generated, in whole or in part, by Generative Artificial Intelligence tools unless explicitly authorized to use such tools by an instructor in writing.
   5. Engaging in self-plagiarism, including reusing work that you have already submitted for a class (either the same class or a previous class), such as re-submitting an entire paper or copying or paraphrasing passages from your previous work. Self-plagiarism misleads the instructor by presenting old work as completely new and original. If you want to include any text or ideas that already have appeared in a previous paper, you must notify and seek prior permission from your instructor.
   6. Failure to stop typing or writing an examination when told to do so by the proctor, or continuing an examination answer after time has been called.
   7. Defacing, vandalizing, stealing, or removing without proper authorization any property belonging to or leased by COL, including books or other materials from a library or classroom of COL.
   8. Engaging in unlawful harassment of any person (sexual harassment is covered under Section 3.2)
   9. Willfully committing acts that violate city, state, or federal laws or ordinances, including but not limited to unlawful possession, use, sale or distribution of illegal drugs or narcotics.
   10. Knowingly making false or misleading statements or entries in any COL application for admission or any other document affecting COL’s records.
   11. Using COL’s libraries, computers, wireless network or online legal research facilities or programs for any purpose other than completing COL course assignments and academic support exercises, or improving computer-based legal research skills, including commercial or personal purposes. (De minimus personal use, such as checking personal e-mail, is not prohibited.)
5. Disciplinary action for violating this Code may include, but is not limited to, one or more of the following:
   1. Reprimand, written or verbal, which may be noted in the student’s file.
   2. Cancellation of an examination, assignment or course grade, and/or denial of course credit.
   3. Probation.
   4. Suspension.
   5. Expulsion.
   6. Written report to the CBE as part of the Moral Character Determination process.
   7. Immediate dismissal from class or ejection from class or activity by the instructor or other person(s) in charge.
6. Conduct that involves potential violation(s) of COL’s Anti-Discrimination, Anti-Harassment and Title IX.  Please refer to COL’s Anti-Discrimination, Anti-Harassment and Title IX Policy.

3.8 Student Code of Ethics and Conduct Complaint Process

Any student, faculty or administrative staff member who believes that a students have violated the Code may report that conduct to the Dean and/or the Dean’s delegates, specifically the Registrar, Assistant Registrar, or the Student Services Coordinator.  The anonymity of those reporting Code violation(s) cannot be guaranteed.

1. When appropriate, parties should attempt to resolve the issue through civil and professional discussion of the matter.
2. The Dean and/or Dean’s delegates will first seek to address the matter using informal methods of resolution.
3. If the matter cannot be addressed informally, the Dean will appoint a disinterested staff or faculty member to investigate the alleged violation to make a determination about the student’s conduct, and to make a recommendation to the Dean regarding the appropriate sanction outlined in 3.9(B). Should the complaint have been made to other than the Dean, the Dean may investigate the complaint. 
4. The Dean’s Office will directly address all written complaints and COL will maintain a record of the complaint and its resolution.  COL is unable to provide complaining parties with the report or inform them about any disciplinary action against another student, staff, or faculty member.

3.9 Review Rights-Student Code of Ethics and Conduct

1. This section does not apply to financial matters; complaints under the Anti-Discrimination, Anti-Harassment, or Title IX Policy; grade disputes subject to formal appeal; or ASC decisions on probation, readmission, or related conditions. See the applicable sections on Financial Information, Anti-Discrimination/Harassment and Title IX, JD and MBLT grade appeals, and Academic Probation or Readmission. This section also does not limit the authority of an instructor or other responsible official to require a student to leave a class, campus, or COL activity for offensive, rude, or disruptive behavior under Section 3.8 (Student Code of Ethics and Conduct). 
2. After receiving the investigator’s recommendation, the Dean may propose to cancel a student’s examination or course grade, deny course credit, or impose administrative probation, suspension, expulsion, or similar sanction (not including any verbal or written reprimand, whether or not it was noted in the student’s file) under Section 3.7 of this Catalog for disciplinary reasons based on  Code violation (and not due to financial, academic, or other matters excluded from the scope of this section) the following will occur:
   1. The Dean shall notify the student in writing of the specific charge or charges and the intended disciplinary action. The student is presumed to have received such notification, absent a showing by the student otherwise, as of the earlier of:
      1. The third day of regular postal delivery following the day on which COL mailed such notification by first class, registered or certified United States mail to the last furnished mailing address provided by the student to COL.
      2. The day on which notification is emailed to the student’s COL email address.
   2. If the student wishes to appeal the Dean’s decision, they must request a hearing by written notice to the Dean within 10 calendar days after the student’s actual or presumed receipt of the Dean’s written notification, whichever is earlier. During the 10-day appeal period, at the Dean’s discretion, a student may be unenrolled from classes pending submission of an appeal and resulting decision on an emergency basis.
      1. The Dean or designee may remove a student, in whole or in part, from COL programs or activities when they determine there is an immediate threat to the health or safety of others. The student will receive notice and may request a prompt meeting with the Dean or designee, either before removal, if feasible, or as soon as possible after, to show why the action should not be taken or should be modified. This meeting is not a merits hearing but a limited administrative review of the removal. Emergency removal decisions are final and not subject to appeal; the Dean has sole discretion over their use, scope, and duration. Violating a removal order may result in discipline up to expulsion or termination. The Dean may permit alternative coursework to minimize academic disruption.
   3. If the student does not request a hearing within the time and in the manner specified in Paragraph 2, COL may proceed to impose the intended disciplinary action of which the student was notified or any lesser action or sanction. The student will have no right of further appeal. The Dean will notify the student in writing of the disciplinary action taken.
       
   4. If the student requests a hearing in accordance with Paragraph 2 (above), the hearing will be held as soon as reasonably possible after the Dean receives the request. The hearing will be held before either an independent, qualified hearing officer or a panel of two or more disinterested members of the faculty and/or administration. The Dean will choose whether a hearing officer or members of COL faculty and/or staff will preside over the hearing and will choose the actual personnel. If the Dean chooses an independent hearing officer, the student will pay half the officer’s fees and COL will pay half the fees. If the student prevails, COL will reimburse the student’s share of the hearing officer’s fees. This right of reimbursement for the hearing officer’s fees does not apply to any other costs or expenses incurred by the student. The hearing officer or panel shall determine whether the evidence shows that the student charged with misconduct engaged in the misconduct. A “preponderance of the evidence” standard of proof shall apply.
       
   5. At the hearing, the student will be entitled to the assistance of counsel of the student’s own choosing and at their own cost. The student also will have the opportunity to call witnesses on their own behalf and to examine adverse witnesses.
       
   6. The hearing officer or panel will provide a final decision on the matter within three weeks of the hearing, or as soon thereafter as reasonably possible. The decision must:
      1. approve the intended disciplinary action as set forth in the written notification given to the student pursuant to Paragraph 1 above
      2. impose a lesser sanction or disciplinary action appropriate under Section 3.8
      3. determine that no disciplinary action is warranted in the circumstances.
   7. No other or additional decision, action, or remedy shall be made or imposed by the hearing officer or panel. The decision will be dated and in writing and will contain a statement of the facts found; conclusions and decision reached; and sanctions if any. This decision will be final and binding on both COL and the student. The student will have no further right of appeal within COL.
       
   8. The effective date of disciplinary cancellation of an assignment, examination or course grade; denial of course credit; probation; or similar sanction that does not terminate or interrupt the student’s right to continued enrollment at COL is:
      1. the date of the Dean’s written notification to the student of the disciplinary action intended if the sanction is imposed by COL pursuant to Paragraph 1 above, or
      2. the date of the hearing officer’s or panel’s written decision if the sanction is imposed pursuant to Paragraph 4 above.
   9. However, if the sanction is imposed pursuant to Paragraph 1, the Dean may select a later date, and if the sanction is imposed under Paragraph 4, the hearing officer or panel may select a later date.
       
   10. The effective date of any expulsion, suspension, or similar sanction that does terminate or interrupt the student’s right to continued enrollment at COL, whether imposed pursuant to Paragraph 1 or Paragraph 4 above, will be retroactive to the date of the Dean’s written notification of charges and intended disciplinary action under Paragraph 1 above. The student will not receive credit for any examinations or courses completed on or after that date, even though she or he may have successfully completed one or more examinations or courses.

3.10 Student Complaint and Grievance Procedure

1. Purpose and Applicability
   1. This procedure may be used whenever a student believes that their rights have been violated by an employee or agent of COL, by:
      1. violation of a duly adopted COL policy, excluding a disciplinary decision or assignment of a letter grade for which the student is seeking an appeal (Section 3.9, Review Rights-Student Code of Ethics and Conduct and Sections on 10. JD - Grading and Grades /14.0 MBLT - Grading and Grades    for each program, respectively).
      2. unethical conduct according to professional standards: or-
      3. a complaint from a member of the COL community relating to discrimination, harassment, domestic violence, dating violence, stalking or retaliation concerning faculty, staff or student(s) must be reported in accordance with the Anti-Discrimination, Anti-Harassment and Title IX Policy.
   2. An action or decision is subject to grievance only if it involves a misapplication or misinterpretation of COL policy, regulation, or rule, or a violation of state or federal law. This procedure may not be used to challenge policies or procedures of general applicability, including the following:
      1. The substance of any duly adopted policy or procedure;
      2. The substance that forms the basis for student performance evaluation or grade for a course; or
      3. A decision regarding a student’s academic status made by a duly designated administrative officer, or by (ASC).
   3. This procedure may be used by students currently enrolled at COL. The person filing the grievance must be the alleged victim of unfair treatment. A grievance may not be filed on behalf of another person.
   4. An individual may contact the Bureau for Private Postsecondary Education for review of a complaint. The Bureau may be contacted at 1747 North Market Street, Suite 225, Sacramento, CA 95834, http://www.bppe.ca.gov, Phone (916) 574-8900, Fax (916) 263-1897.
2. Time for Filing Grievance
   1. Either a written, hard copy (or e-mailed) grievance must be received by the Dean not later than forty-five (45) calendar days after the student first became aware of the facts which gave rise to the grievance.
   2. The formal resolution process must be initiated within 60 days of the decision, action, or events giving rise to the grievance. This time limit may be extended by the Dean if the student initiating the Student Grievance Procedure requests an extension within the 60-day period for good cause shown (e.g., an active effort at informal resolution, death in the family, etc.).
3. Process
   1. Prior to invoking the formal resolution procedures described below, the student is strongly encouraged, but is not required, to make active efforts to resolve matters through professional and direct discussions with the person or persons directly involved. These efforts should take place as soon as the student first becomes aware of the act or condition that is the basis of the grievance. If unsure of how to proceed, students should enlist the assistance of another member of the COL community (e.g., Assistant Dean, Associate Dean or designee) to help identify proper courses of action and/or to mediate problems if necessary.
       
   2. Since this procedure is an institutional process, not judicial, the presence of legal counsel for any party to the grievance is not allowed. This policy is not to be used in substitution for the grade appeal or other appeal processes.
       
   3. Step 1
      To invoke the formal resolution process, the student must submit the grievance to the Dean. The grievance must:
      1. be submitted as a dated and signed document, whether by delivery or emailed from the student’s COL email account;
      2. state how the decision or action is unfair and harmful to the student and list the COL policies or state or federal laws that have been violated, if known;
      3. name the person(s) against whom the grievance is filed;
      4. state how the person(s) against whom the grievance is filed are responsible for the action or decision; and
      5. state the requested remedy.
   4. Step 2
      Upon receipt of the written grievance, the Dean will determine whether the matter is grievable in accordance with the criteria set forth above. If the grievance has no merit, the Dean will dismiss it and submit a letter stating so to the student initiating the grievance. If the grievance does have merit, the Dean will appoint an ad hoc committee of two faculty members and one student to investigate the situation by gathering additional information from appropriate members of the COL community. The Dean will designate one of the faculty members as chairperson of the ad hoc committee. The chairperson will have the right to vote. At any time during the investigation of the grievance, the Dean and ad hoc committee may make further attempts to resolve the grievance informally.
      
      The ad hoc committee chair will send a copy of the grievance to the parties listed as having committed an alleged violation (“respondent”) within 10 business days of being appointed, giving the respondent(s) 10 business days to submit to the chair a written response to the allegations with any exhibits they wish to introduce as evidence. The chair will concurrently inform the student pursuing the grievance of that student’s right to, within 10 business days, submit to the chair copies of any exhibits the student wishes to introduce as evidence. The chair may extend the deadlines for submitting a response and for exchanging proposed exhibits upon a showing of good cause.
      
      If the student who has brought the grievance has good cause to believe that a given member of the ad hoc committee is unable to be impartial, the student may request that the Dean disqualify that member. Such a disqualification shall be granted only upon the demonstration of sufficient reason. The decision by the Dean to alter or preserve the composition of the ad hoc committee is final.
       
   5. Step 3
      In performing its functions, the ad hoc committee will have the right to call any witnesses and to require the introduction of any relevant data or information. The ad hoc committee will be the final judge of what testimony or data is relevant. While the presence of an attorney is prohibited, a student may have a member of COL community present during the hearing to provide advice and support. All deliberations of the ad hoc committee are confidential.
       
   6. Step 4
      Once all fact finding, questioning, and presentations are complete, the ad hoc committee will deliberate to evaluate the merits of the grievance and make findings of fact. Such deliberations are restricted to members of the ad hoc committee. The ad hoc committee’s decision must be based solely on material presented in the grievance. A majority vote of the ad hoc committee is required to make an affirmative decision on the grievance. Within five days of reaching a conclusion, the ad hoc committee will, via email and/or U.S. Postal Service, send its findings to the student bringing the grievance, the respondent(s), the Dean, and to the appropriate institutional individual(s) who shall implement the actions, if any, recommended by the ad hoc committee within 30 days after the ad hoc committee’s decision was postmarked.
4. Appeal Process
   1. Step 1
      Within 10 business days after the ad hoc committee’s decision is mailed, a student who is not satisfied with the decision of the ad hoc committee may seek further review by emailing, mailing or delivering the written notice of appeal, together with the committee’s written decision, to the Dean. Written notice of appeal must be signed and dated by the student and provide a brief statement of the grounds for appeal, which should contain a list of alleged errors in the decision or decision-making process and indicate what remedy is requested. Appeals emailed, mailed, or delivered more than ten business days after the ad hoc committee’s decision was communicated, will not be considered.
      
      The Dean’s action will be limited to a review of the basis for the ad hoc committee’s decision; they will render a decision based on review of the grievance record and the written notice of appeal. There is no right to a hearing or oral presentation in appeals. The Dean may delegate another administrator to act on their behalf.
       
   2. Step 2
      Within 15 calendar days of receipt of the request for review, the Dean will submit their decision in writing to the student and to the person alleged to have caused the grievance. The written disposition shall include the reasons for the decision, and it shall direct a remedy for the aggrieved student, if any. The Dean’s decision on the appeal is final and will not be subject to further review.
5. Record Keeping
   The chair of the ad hoc committee will compile an official record of the proceeding that includes a copy of all correspondence with the parties, all evidence submitted to the ad hoc committee, a summary of the ad hoc committee’s decision, and anything else considered by the ad hoc committee in reaching its determination. The chair of the ad hoc committee will be responsible for ensuring that a written report is prepared that addresses and resolves all material factual issues in dispute, that states a conclusion as to whether the student was subjected to misapplication or misinterpretation of COL policy or state or federal law, and if so, recommends remedies as appropriate. The report and official record will be kept in the student’s record; a copy of the grievance, any decision of the committee, and any decision of the Dean will be retained in accordance with retention requirements for the student’s file.
    
6. Confidentiality
   All grievance procedures and records are confidential in nature and will be treated accordingly, except to the extent disclosure is required by law or the requirements of accrediting bodies, including the State Bar of California.
    
7. External Complaint
   A student is expected to follow the internal grievance procedures above, before complaining to an external agency. A student who utilized the internal procedure and who is not satisfied with the outcome may wish to raise the issue with the relevant state agency or accreditor.
   
   Student Complaints to State Agencies
   
   For a list of state agency contact information for purposes of student complaints, please visit here.
   
   Student Complaints to Accreditor
   
   An unresolved grievance may also be directed to WSCUC, which requires that a complainant attempt to resolve the underlying grievance with the institution prior to filing a complaint. WSCUC’s complaint procedures are for the purpose of addressing significant non-compliance with the Standards of Accreditation and WSCUC policies. Thus, WSCUC will not interpose itself as an adjudicatory or grievance-resolving body in individual matters including admission, granting or transfer of academic credit, grades, fees, student financial aid, student discipline, or collective bargaining, faculty or staff appointments, promotion, tenure, contractual rights and obligations, and dismissals or similar matters. WSCUC’s staff will investigate a complaint in order to determine whether it appears that a WSCUC Standard or Policy was violated and, if such is the case, it will take appropriate action within the range of options that are available to it under WSCUC Standards and Policies. The complaint form and process can be found under “Directory” at www.wascsenior.org. Inquiries may be directed to: Western Association of Colleges and Schools, Senior College and University Commission, 1080 Marina Village Parkway, Suite 500, Alameda, Ca 94501, Phone: (510) 748-9001.

3.11 Campus Security

Under the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act), COL is required to annually publish an Annual Security Report which discloses specific campus crime data, campus policies and procedures related to safety, and support provided to campus community victims of violence. COL must publish this Annual Security Report each year by October 1 and provide it to all students. The Annual Security Report is available online here: https://www.collegesoflaw.edu/emergency-information/.  Students may also request a paper copy of the report be mailed to them by emailing their request to: COLRegistrar@collegesoflaw.edu.  In addition, COL must provide a timely warning of campus crimes reported to campus security and local police agencies in a manner that is intended to prevent similar crimes from recurring and to protect the personal safety of students and employees.

3.12 Emergency Response and Evacuation

COL is committed to the safety and security of all members of its community. In times of emergency, COL will provide an appropriate campus-wide response to assure everyone’s safety and to minimize losses. Information about COL emergency response and evacuation procedures can be found in the Emergency Operations Plan, which is available on the Gateway and provided to all entering students. The guide is intended to assist all faculty, staff, and students in responding to emergencies that may occur while they are at COL. Such emergencies can occur at any time and without warning, but their effects may be minimized if proper emergency procedures are followed. Students are encouraged to read and become familiar with the contents of the Plan before an emergency occurs.

3.13 Drug Free Environment

1. Smoke-Free Environment
   Smoking is prohibited, including within 25 feet of building entrances, exits, windows that open, and ventilation intakes. This smoke-free policy includes cigarettes and electronic cigarettes, and it covers all areas owned or operated by COL. If a local law or ordinance provides greater protection for the rights of non-smokers, it shall apply.
    
2. Drug-Free Environment
   1. In compliance with the Drug Free Schools and Communities Act of 1986 (DFSCA) as amended in 1989, COL explicitly prohibits the unlawful possession, use, or distribution of illicit drugs by students or employees on COL premises or as part of any of its activities. In addition, COL prohibits the misuse of legal drugs including alcohol.
   2. Legal Sanctions Under Federal and State Law
      Federal penalties and sanctions for illegal possession of a controlled substance are as set forth below. 
      1. First conviction: up to one-year imprisonment or a fine of at least $1,000;
      2. After one prior drug conviction: at least 15 days in prison, not to exceed two years, and a fine of at least $2,500 but not more than $250,000, or both;
      3. After two or more prior drug convictions: at least 90 days in prison, not to exceed three years, and a fine of at least $5,000;
      4. Special sentencing provisions for possession of crack cocaine: mandatory sentencing of at least five years in prison, not to exceed 20 years, and a fine of up to $250,000, or both, if the first conviction and amount of crack possessed exceeds five grams, the second crack conviction and the amount of crack possessed exceeds three grams, the third or subsequent crack conviction and the amount of crack possessed exceeds one gram;
      5. Forfeiture of personal property used to possess or to facilitate possession of a controlled substance, if that offense is punishable by more than a one-year imprisonment;
      6. Forfeiture of vehicles, boats, aircraft, and any other conveyance used to transport or conceal a controlled substance;
      7. Civil penalty of up to $10,000;
      8. Denial of federal benefits, such as student loans, grants, contracts, and professional and commercial licenses, for up to one year for first offense or up to five years for second and subsequent offenses;
      9. Ineligibility to receive or purchase a firearm;
      10. Revocation of certain federal licenses and benefits, (for example, pilot licenses, public housing tenancy, etc.) as vested within the authorities of individual federal agencies; and
      11. Any person convicted of drug trafficking occurring within 1,000 feet of an academic institution is subject to prison terms and fines twice as high as listed above with a mandatory prison sentence of one year for each offense.

This list has been included for reference purposes only. The most current information can be found on the website of the U.S. Drug Enforcement Administration.

3. Institutional Policy on Alcohol
   Beverage alcohol may be served to and consumed by persons of legal drinking age on COL premises or internships sites only in conjunction with a specifically authorized COL function. Individuals consuming alcohol should do so in a responsible manner.
    
4. General State Laws of Alcohol Possession and Consumption
   Individuals younger than 21 years old may not purchase, accept as a gift, or possess alcoholic beverages on any street or highway or other public place. Consumption by minors is expressly prohibited. Licensees to sell alcoholic beverages are prohibited from selling, giving, or delivering alcoholic beverages to anyone under 21 years of age. It is unlawful for anyone of legal age to purchase or obtain alcoholic beverages and then sell, give, or deliver them to a minor.
    
5. Health Risks Associated with Use of Illicit Drugs, the Misuse of Legal Drugs, and Alcohol Abuse
   There are health risks associated with the use of illicit drugs and abuse of legal drugs and alcohol including impaired functioning of the following major organs: liver, kidneys, brain, and other aspects of the central nervous system including impaired immune functioning and impaired lung and pulmonary functioning. The effects are both immediate and long-term. Immediate effects include impaired judgment, impaired attention span, and impaired gross and fine motor control. Long-term effects include the risk of premature death. The use of needles to inject drugs into the blood stream engenders the risk of contracting HIV or hepatitis. These health risks may affect one’s daily life activities, as well as familial, social, and working relationships.

   Drug and alcohol abuse causes physical and emotional dependence, in which users may develop a craving for a particular substance. Thus, their bodies may respond to the presence of such substances in ways that lead to increased drug and alcohol use.

   Certain drugs, such as opiates, barbiturates, alcohol, and nicotine create physical dependence. With prolonged use, these drugs become part of the body chemistry. When a regular user stops taking the drug, the body experiences the physiological trauma known as withdrawal.

   Psychological dependence occurs when taking drugs becomes the center of the user’s life. Drugs have an effect on the mind and body for weeks or even months after drug use has stopped. Drugs and alcohol can interfere with memory, sensation, and perception. They distort experiences and cause loss of self-control that can lead users to harm others as well as themselves.

6. Counseling, Treatment, or Rehabilitation Programs
   Any student who fails to abide by the terms of the Alcohol and Drug-Free provisions may be required to participate satisfactorily in drug abuse assistance or rehabilitation program approved for such purposes by a federal, state or local health, law enforcement, or other appropriate agency.  Specific programs of counseling or rehabilitation are available within the Santa Barbara and Ventura communities.

7. Substance Abuse Resources
   Student Solutions: COL is proud to partner with ComPsych to offer Student Solutions, a free, confidential, around-the-clock counseling service.
   
   855-460-6668
   www.guidanceresources.com
   Web Identifier: COLLEGESOFLAW
   
   The Other Bar, a California Non-Profit Corporation
   Toll free confidential hotline: 800-222-0767
   
   Employee Assistance Program (EAP): COL employees also receive counseling services through the EAP, which is available 24 hours a day, 7 days a week.
   
   800-272-7255
   https://www.guidanceresources.com
   Your company web ID: COM589

8. Sanctions to Be Imposed on Students Who Violate Regulations and Policies
   As a condition of matriculation to COL, students agree to abide by the terms of these regulations and policies and agree to notify COL of any criminal drug statute conviction for a violation occurring on campus no later than five (5) business days after such conviction. COL will take appropriate action (consistent with local, state, and federal law) against a student who violates the standards of conduct contained herein, pursuant to the Code, up to and including dismissal from the institution and referral for prosecution.
    
9. Distribution
   This policy is distributed annually to all students and employees pursuant to DFSCA. COL will regularly review the terms of this policy to:

   1. determine its effectiveness;
   2. implement changes, as needed; and
   3.ensure that sanctions are consistently reinforced.

3.14 Accommodation for Students with Disabilities

1. It is COL’s policy to provide reasonable accommodations for students with disabilities including, but not limited to, learning disabilities and physical impairments. Students whose disabilities may require some type of accommodation, including exam-testing accommodation, are encouraged to discuss these with the Accommodations Coordinator as early as possible.
    
2. It is acceptable for COL to require documentation of disabilities when the individual with the disability puts the disability at issue. Proper documentation must be submitted on COL’s form or in some cases for JD students, on forms provided by the State Bar. When medical/physical disabilities are at issue, a physician’s statement will usually be sufficient, so long as that statement describes both the disability and the limitations that the disability poses for the student. For students with learning disabilities, the following is ordinarily considered reasonable for required documentation:
   1. The documentation must be prepared by a professional, such as a licensed physician, learning disability specialist, or psychologist, who is qualified to diagnose a learning disability.
   2. The documentation must describe the testing procedures followed, the instruments used to assess the disability, the test results, and an interpretation of the test results. If the disability requires additional time for taking examinations, it must state the specific amount of time needed.
   3. The documentation must reflect the individual’s present achievement level, be as comprehensive as possible, and be dated no more than three years prior to the student’s request for accommodation, unless, in the opinion of the Dean, extenuating circumstances justify reliance on older documentation. 
   4. The documentation must include test results for at least the following characteristics: intelligence, vocabulary, reading rate, reading comprehension, spelling, mathematical comprehension, memory, and processing skills. The diagnosis should conform to federal and state guidelines, including, for JD students, those issued by the CBE. 
3. At COL’s discretion, documentation different from or in addition to that described above may be required, including documentation more current than that described in item 3 above. Documentation from one or more additional physicians or other professionals may be required. All statements, opinions, and recommendations of physicians and other professionals, while accorded great weight by COL, will be considered advisory only; they are for use by COL in working with the student to develop appropriate accommodations and are not, per se, binding upon COL.
    
4. Completed requests for Accommodations must be submitted no sooner than 30 days prior to the examination period. If submitted beyond that deadline, COL will make its best effort to process a student’s request for accommodation. However, applications received less than two weeks prior to these times may be denied if there is insufficient time to gather and review the appropriate documentation, evaluate possible accommodations, or to implement an accommodation.
    
5. A student seeking accommodations must file a petition with COL detailing the exact nature of the disability and the accommodation sought along with documentation from appropriate professional(s) confirming the existence of the disability, explaining the exact accommodation needed and supporting the need for the accommodation sought. Upon receiving the student’s accommodations request, the Disabilities Coordinator will meet with the student to discuss the request. After reviewing the student’s petition, COL will grant or deny the request for accommodation. COL reserves the right to select the specific aids and services it provides, as long as it deems they will be effective for the student and do not fundamentally alter the program or academic standards. Such aids and services are determined on a case-by-case basis in consultation with the student who has identified the need for accommodation.
    
6. In some circumstances, a student may be required to file updated documentation to show the need for continued accommodations.
    
7. Students who have been approved for accommodations, but seek to change or alter their accommodations must submit new paperwork to the Disabilities Coordinator.
    
8. JD students receiving accommodations at COL are not guaranteed accommodations with the State Bar. Students must contact the State Bar directly. The State Bar will determine what accommodations the student is entitled to, independent of any decision by COL. Our understanding is that the State Bar generally makes decisions about accommodations closer to the examination.  JD students with disabilities should check with the State Bar on these issues and should be aware that the State Bar may offer more limited accommodations on exams than provided by COL.
    
9. Since students receiving testing accommodations will be taking examinations in a format different from that of other students, it will be necessary for those students to take their exams at other than the regularly scheduled time.  In addition, if a student’s accommodations require a private room, any such student may be asked to either leave their personal belongings (purse, backpack, etc.) with Administration Office staff or to submit their belongings for inspection before the start of the exam.

3.15 Reproduction of Copyrighted Materials

The photocopying or reproduction by other means of copyrighted materials is a right granted under the federal Copyright Act that defines the rights of a copyright holder and how they may be enforced against an infringer.  The unauthorized reproduction and distribution of copyrighted material is strictly prohibited.  Students identified as having violated this policy may be subject to disciplinary action, up to and including but not limited to expulsion from the institution, or legal action as appropriate, or both.

Copyright infringement is the act of exercising, without permission or legal authority, one or more of the exclusive rights granted to the copyright owner under section 106 of the Copyright Act (Title 17 of the United States Code). These rights include the right to reproduce or distribute a copyrighted work. In the file sharing context, downloading, or uploading substantial parts of a copyrighted work without authority constitutes an infringement.

Penalties for copyright infringement include civil and criminal penalties. In general, anyone found liable for civil copyright infringement may be ordered to pay either actual damages or “statutory” damages affixed at not less than $750 and not more than $30,000 per work infringed. For “willful” infringement, a court may award up to $150,000 per work infringed. A court can, in its discretion, also assess costs and attorneys’ fees. For details, see Title 17, United States Code, Sections 504, 505.

Willful copyright infringement can also result in criminal penalties, including imprisonment of up to five years and fines of up to $250,000 per offense. For more information, please see the website of the U.S. Copyright Office at (www.copyright.gov).

All COL students are subject to the restrictions imposed by the Copyright Act.  The copyright law applies to all forms of photocopying, whether it is undertaken at a commercial copying center or at COL’s copying machines.  Students must exercise prudent judgment when reproducing the works of others so as to not violate the copyright law.  Any concern about a student’s reproduction of materials should be brought to the attention of the Dean. 

3.16 Photography and Other Recording

COL may, in its discretion, use photography, videography, or other recording of students in the classroom, on campus or at School activities for educational or promotional purposes.

3.17 Use of Electronic Devices

During exams, students may not use cell phones or other electronic devices, except for ExamSoft-protected laptop computers. 

3.18 Preferred Name Policy

It is COL’s policy that any student may choose to identify themselves within the COL community with a preferred first and/or middle name that differs from their legal name.  The preferred name will appear instead of the person’s legal name in the Student Information Systems and on documents, as more specifically described below, except where the use of the legal name is required by law or other applicable policies. 

Definitions:

Legal name: A student’s name as it appears on a legal or government issued document such as a birth certificate, social security card, court order, passport, etc.

Preferred name: A name commonly used that differs from an individual’s legal first name.

A student’s preferred name will be used for class rosters, on student identification cards and in student email.  A student’s preferred name may also be disclosed as directory information unless the student declines to permit such disclosure.  For further information on disclosure of directory information, please refer to the COL Academic Catalog Section 3.7:  http://santabarbaralaw.catalog.acalog.com/content.php?catoid=66&navoid=4157#3.7-family-education-rights-and-privacy-act-(ferpa).  All official documents, including but not limited to transcripts, diplomas, payroll records, and financial aid documents, will include a student’s legal name.

To request the use of a preferred name, please access the Student Portal via the Gateway at http://my.collegesoflaw.edu, then click on My Records, then Change Student Contact Information.  Please allow three business days for processing.

Generally, students can use any preferred name, but COL reserves the right to deny or remove, with or without notice, a preferred name if it is used for inappropriate purposes, including but not limited to, misrepresentation, avoiding legal obligation, offensive or derogatory language, or to perpetrate fraud.  A preferred name must consist of alphabetical characters, hyphens, and spaces.

Note that using a preferred name is not the same as legally changing a name through the court system. 

3.19 Electronic Communications Guidelines

Electronic Communication Etiquette

Learning and working online means that communication often lacks the benefit of visual support of body language and tone of voice. This can easily lead to misunderstandings or unintentional offense.  Reviewing what is written in an email, text, or posted in a discussion forum will serve to better support a student’s successful online participation.

A student is advised to observe the below guidelines when participating in an online course or communicating virtually with others. Encouraging professional behavior is an institutional learning goal, and all students are expected to behave as professionals in all aspects of communication.

• Be respectful, professional, and careful about what is said and how it is said.
• Be aware of the image being projected online. Use clear writing and good form.
• As message recipients cannot read non-verbal cues such as facial expressions or easily interpret the tone of written communication, words and manners of expression must clearly indicate the intended meaning. This is particularly important when using humor (e.g. sarcasm may not be apparent in words alone).
• Respect the time of others. Keep communication short, to the point, and on topic.
• With disagreeing, be polite and gracious.
• On message boards or in discussion forums, use the subject line appropriately, employing meaningful and succinct labels so that recipients may immediately grasp the topic being advanced.
• When someone else errs and/or does not follow proper protocol, consider whether it is necessary to provide correction. If correction is in order, be polite and, if discretion is advised, address the issue privately rather than in a public way.
• Avoid using ALL CAPS, especially when disagreeing. This is perceived as shouting and considered rude.
• Comply with all copyright laws.
• Be mindful of compatibility concerns. Be sure that files uploaded to online platforms can be viewed by others.
• Be aware of issues that might arise due to cultural and languages differences.
• Do not violate the privacy of others. Do not send commercial advertisements or SPAM to other students, faculty members, or staff.

3.20 Audio and Visual Recording Limitations Policy

Except as permitted under the ADA accommodations policy, students may not record class lectures or presentations without the professor’s prior knowledge and written consent. Written permission must be obtained by submitting a completed Audio or Video Recording Permission form, signed by the professor, to the Program Manager, Student Services Coordinator, or Registrar at the student’s home campus. Once approved, the professor will notify the class that recording is taking place. Approved recordings may be used only for the student’s own educational purposes and for students enrolled in the class, may not be shared, distributed, sold, file-shared, or posted online without the professor’s express written consent, and may be used only while the course is being offered. All recordings must be destroyed when no longer needed for academic purposes. 

Outside of class lectures, students are prohibited from making a video recording, audio recording, taking photographs, or streaming audio/video of any person on campus, including in the classroom during breaks, without that person’s express knowledge and consent.

3.21 Student Location Policy

COL requires all students to provide the address where they will be located while enrolled at the institution and actively attending classes. Each student is required to provide this address information in their enrollment application.  Post Office Boxes will not be accepted. This address will be maintained as the “Student Location” and will be used by COL to send official correspondence and ensure regulatory compliance. Each student is responsible for keeping their Student Location current and for notifying the COL Registrar’s Office of any address change.

A student who is considering relocating, or has relocated to another state, territory, or outside of the United States during their program, whether relocation is permanent or temporary, must contact the COL Registrar’s Office within 14 calendar days to process a change to their Student Location.

To initiate a change in a Student Location, access the Gateway under “My Contact Information.” The request will then be sent to the Registrar’s Office to update the Student Location. Additionally, students may contact the Registrar’s Office for more information regarding their options to update their Student Location.

3.22 Financial Aid Code of Conduct

The following Financial Aid Code of Conduct was last updated by a vote from NASFAA’s Board of Directors in November 2020 and published in January 2021. Subject to enforcement procedures that went into effect July 1, 2015, NASFAA institutional members of NASFAA will ensure that:

1. No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.

1. Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
2. If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publicly disclosed. Borrowers will not be auto-assigned to any particular lender.
3. A borrower’s choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution’s preferred lender list.
4. No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or their family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).

2. Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.

3. Institutional financial aid offers and/or other institutionally provided materials shall include the following:

• breakdown of estimated individual Cost of Attendance components, including which are direct (billed by the institution) costs vs. indirect (not billed by the institution) costs
• clear identification and proper grouping of each type of aid offered indicating whether the aid is a grant/scholarship, loan, or work program
• estimated net price 
• standard terminology and definitions, using NASFAA’s glossary of terms; and
• renewal requirements for each aid type being offered as well as next steps and financial aid office contact information

4. All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found, and labeled as “Consumer Information.”

5. Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.