Coraggio Consulting Loudoun County Public Schools, Human Resources and Talent Development (HRTD) Committee Meeting, Thursday, April 24, 2025 Date: Thursday, April 24, 2025 Place: LCPS Administration Building / School Board Room, Ashburn, Virginia Length: 19m (video) Official meeting video (Vimeo / LCPS-TV): https://player.vimeo.com/video/1078461056?rel=0 Machine transcript (speech-to-text) produced by Coraggio Consulting. Not an official county record. Names and numbers may be misspelled; check the video at the timestamp before quoting. Speech-to-text: whisper.cpp, model large-v3-turbo. Produced 2026-10-13. Timestamps are [HH:MM:SS] into the meeting video. ---------------------------------------------------------------------- [00:00:30] Thank you. May the HRTD meeting come to order, please. Thank you. My name is Dena Griffiths. This is the meeting for today, April 24th, 2025. I have Ms. Chandler and Ms. Donahue here today with me. There is no public comment, so we won't have any speakers today. We are going to move on to 3.1, approval of the March 27th, 2025 meeting draft minutes. Could I please have a motion to approve the March 27th meeting minutes. Thank you, Ms. Chandler. I move that we approve the March 27, [00:01:05] 2025 meeting minutes. Second. Thank you. The motion has been made by Ms. Chandler and seconded by Ms. Donahue. Is there any discussion? Okay. All those in favor, please raise your hand and say aye. And all those opposed, raise your hand and say nay. Aye. Let's move on to 4.01, revisions to policy 7306 personnel records. Ms. Boland, will you be speaking to that today? Thank you. Yes, thank you. [00:01:41] Tonight, we are bringing back policy 7306 personnel records and file for your review as an action item. We submitted the proposed revision for public feedback and did not receive any comments or suggested edits. While at first glance, personnel records may not seem directly related to our complaints or grievance policies, our experience has shown that employees sometimes attempt to use this policy to relitigate or appeal employment decisions made under those policies. As such, [00:02:16] our proposed revisions to this policy are part of a broader strategic effort to create clarity and consistency across policies governing employee complaints and grievances. And in particular, starting with this policy before we bring the suite of policies is particularly important so that we can continue that consistency and clear direction for employees to know which policy they are to follow when bringing forth concerns and complaints. Policy 7306 is a vital framework established by the Loudoun County School Board to ensure the proper maintenance, confidentiality, [00:02:55] and accessibility of personnel records for all employees. However, this policy is not intended as a mechanism for disputing disciplinary actions or policy interpretations. Instead, its primary purpose is to establish LCPS's duty to maintain accurate and complete employee records, provide employees with access to review their own personnel files, and allow for corrections in cases of factual inaccuracies. [00:03:27] To ensure alignment with this intent, the proposed revisions clarify that request to amend or remove records must be based on objective errors, such as incorrect dates or an incorrect level of discipline, not as an avenue to challenge past employment decisions. [00:03:46] It also explicitly directs employees to the appropriate grievance and appeals policies when seeking to contest a disciplinary action, ensuring each policy serves its intended purpose. Finally, these updates enforce LCPS's commitment to protecting the confidentiality and integrity of personnel records while complying with legal requirements. [00:04:10] And in simpler terms, we often get questions from employees about which policy they are to follow in regards to certain disciplinary actions or review. And so this language, again, seeks to help with that clarity and redirect employees. [00:04:30] At this time, I'd like to turn it over to Alex Smith, HRTD supervisor for grievance management, to highlight some of those additional proposed revisions. All right. Thank you, Ms. Boland. So as Ms. Boland mentions, we did not receive any public feedback, so we did not make any additional edits since our last meeting in April. [00:04:50] So just quickly, what I'll do for you all is I'll give you a refresher of the change that we spoke about in March. We are not proposing any changes to sections A through F. The changes we are proposing begin with section G, which is corrections to a request to remove personnel record documents, and that begins on line 64. In section G, on line 68 through 69 is where we clarified that requests for corrections or removal are limited to situations where there's factual inaccuracy. [00:05:23] And then in lines 72-74, we have included the standard by which requests from employees will be reviewed and that's the preponderance of the evidence which means more likely than not that the document in question is inaccurate or incomplete. [00:05:39] In lines 79-86, we have included verbiage that states an employee may ask that documentation related to their request be included in their personnel file along with the document in question if their request for a correction or removal is denied. [00:05:54] And they would have 30 calendar days from receipt of the denial to make that request. And the proposed revisions do change the scope of what can be requested under this policy. Meaning under this policy, employees can only ask for a correction or removal of the document. [00:06:10] So as a result of that, we did add a Section H, which is Restrictions on Requests to Remove Disciplinary Documents. And that begins on line 88. So in that section we have clarified the avenues by which an employee can rebut or challenge a disciplinary action. [00:06:28] So again, separate from just correcting an inaccuracy, if someone disputes that I was issued a letter of reprimand and they want to rebut or rebut the contents within it. So the options they have to rebut or challenge are through policy 7310 and that's staff discipline and that provides employees the opportunity to submit a written or oral rebuttal for the reasons for the disciplinary action within 30 calendar days of receipt of that action. [00:06:56] And employees may also grieve their disciplinary action through two other policies. Policy 7018 is the procedure for adjusting grievances, and that provides employees with the right to grieve a disciplinary action, including a dismissal. So in practical terms, what that means is if an employee receives a letter of reprimand that they feel is unwarranted or a misapplication of policy, they may initiate a grievance under Part 2 of Policy 7018. If an employee wants to grieve their dismissal, that can be grieved under Part 3 of that policy. Similarly, Policy 7024 is specifically for classified employee dismissal [00:07:32] and demotion grievances, and that provides non-exempt employees with the right to grieve disciplinary action that results in a demotion or a dismissal. So summarizing and reiterating what Ms. Boland shared. The goal of our revisions to this policy are to ensure that personnel records are maintained accurately, confidentially, and in compliance with legal requirements, while also protecting employee rights and providing employees with a fair process for correcting legitimate errors. [00:07:58] Our goal is to enhance the clarity and consistency for employees in their understanding of the multiple policies governing employee complaints and grievances, and to bring an overall transparency and efficiency to the management of personnel records. Thank you. Thank you. [00:08:14] Any discussion? Yes, Ms. Donoghue. Thank you very much, Chair Griffiths. Thank you, Ms. Smith. Two questions. I see that the last revision of this policy was in 2022. [00:08:31] So I was curious what the motivation was to revise it now. So many times I've mentioned that we're going to bring a suite of policies. And that suite of policies includes both grievance policies for licensed or certified and non-licensed employees. [00:08:53] And so we anticipate that this suite of policies will take some time in committee and involve much discussion. This policy is one of those policies that Ms. Smith has been looking at as part of that suite of policies to ensure a few things. [00:09:15] The most important of which is that all employees have an avenue by which to have a discipline or employment matter concern grieved or brought forth to discuss. [00:09:33] And this was one of those policies. And if we are changing the rest of those policies, it was necessary to make sure that this policy was also clarified and clear and directed them to the correct policies to grieve. [00:09:49] - That makes sense, thank you. - And to be honest with you, we actually thought why bring this with the other ones when we could actually, we didn't feel this would be as, there wouldn't be as much discussion needed and we would be able to move this along while we spent more time on the other policies. [00:10:07] makes sense thank you and then my other question has nothing to do with the proposed edits but for section a no c2 on page one of the policy lines 30 to 34 which I did not really spend a lot of time thinking about when this is on for information since it's not part of the proposed revisions it seems to suggest that the school board can authorize the superintendent to disclose information about an employee's, about employee personnel matters under certain circumstances. And I [00:10:44] wanted to ask the appropriate person to talk a little bit about that because we've frequently heard that we can't, the superintendent can't publicly discuss personnel matters. And it seemed to be an absolute we can't discuss. So I was just curious about how to interpret this [00:11:09] paragraph. So I think I'm going to have to get a legal review, but I'm going to give you what I believe and what's been communicated to me. I do not believe, it's my understanding, [00:11:42] and Christy, feel free to jump in if I'm incorrect, that you are legally bound in some regards to some information that you could potentially release. However, there is significant risk for you to release that information. And we have been given legal advice to avoid that risk [00:12:14] unless there is extreme misinformation provided that we have to counter. And at that time, the school board could, with legal advice, authorize or direct the superintendent to disclose information. [00:12:35] Does that help? In cases, for example, in cases if we had an employee who was making legal allegations publicly against the school division, there could potentially be the opportunity for a release of certain information. [00:12:59] But I'm going to ask Christy to help me out a little bit. Thank you, Ms. Boland. Ms. Boland is correct. From a legal perspective, there's a delicate balance that, of course, needs to be taken into account with regard to the disclosure of information, along with other laws that might apply. [00:13:26] So this provision provides some discretion in the event that there is certain information that's disclosed. But I believe the school division tends to take a more conservative view that unless there's potentially legal action that might result or something that we basically maintain the confidentiality of information so that we avoid the legal risk of, for example, a defamation claim if the information is disputed and is subject to potentially being changed. [00:13:57] Because, for example, there may be a hearing on a dismissal or adverse action that could possibly, once it reaches board vote, go away that allows that information to be clarified or removed from the personnel record. That helps to clarify. [00:14:13] It does. Thank you. Thank you. Any other discussion? I actually had a question. And maybe I missed it. [00:14:28] I think I thought, I saw 30 days, the employee has 30 days to reach out to you to get their information, is that correct? Let me find that section. Please don't ask me the line number. [00:14:45] I know, I'm trying to find that myself. Hold on. 83. Okay. Yes, so they have 30 calendar days. So what happens is they have requested, they've made their request that I think there's a factual inaccuracy in my personnel file. [00:15:00] If we say, if we reply, no, we believe this is accurate, they have 30 days from receiving the denial to make that correction to then request that their original request be included in the personnel file also. [00:15:15] So there's a record in the personnel file that I disputed or I asked for this correction. And with that, do they have to pay for their information to get their files before 30 days or after? [00:15:32] No, we have not had a practice of charging for your personnel. Okay, so you have not charged for that. Also, as far as getting public feedback, I don't want to say I'm surprised or anything that nobody's responded to this, but who exactly do we reach out to for feedback on all these policies? [00:15:52] If you could just clarify that for me. So there is a wide range. It goes out. We work closely with the Department of Communications and Community Engagement. And it goes out to the community, to parents, staff. [00:16:12] I know that it also goes to advisory committees such as SEAC, MSAC. There is a list. I do not have the entire list, but we work with the Department of Communications. It's the same for all policies. [00:16:31] All policies go out to the same group of individuals for feedback. As a parent, I've never asked for feedback on policies. As a parent, I've never seen emails or anything or any communication, so I was just curious. [00:16:47] And I can talk to communications about that. But to be perfectly honest, for every policy, for us to send a million emails, it would get lost. You wouldn't really, I don't know that you'd get the feedback that you're looking for. but I do want to find out what the methods are for getting this feedback, because we didn't have any this time. [00:17:10] Yes, Ms. Chandler. - I was just gonna clarify. My understanding in terms of the policy is the LCPS has a very wide net for collecting community feedback, and that anyone could use the website to provide feedback if they should so choose, because it is posted on the policies and regulations page. [00:17:35] when a policy is up for feedback. And there's a form. - So with that, so parents would have to go onto the website and look? 'Cause they wouldn't know normally. - There's several avenues. It goes out in the superintendent's newsletter. [00:17:52] There is sort of like peach jar type emails that also go out. And like Ms. Chandler said, it is posted on the website as well. So they do try to not inundate one-offs, but they try to condense all policies that are going out into these variety of avenues, the major one being the superintendent's memo. [00:18:21] Yeah, it's funny because for this particular policy, you probably don't care about it too much until it happens to you. And then you want to make changes to it after maybe you had a grievance or something to that effect. But anyway, is there any other discussions? [00:18:39] No other discussions. So do we want to send this to the school board meeting, consent agenda? Yes, Ms. Chandler. I move that we put forward policy 7306 for consideration by the full school board. [00:18:55] Second. We will be putting this policy, there is a motion here for 7306 to put it to the full school board. I don't know if that will be at the next school board meeting. Unanimous. Aye. Well, all those in favor say aye. [00:19:11] Aye. So let's move on to new business. Do we have any? And I guess we'll adjourn. 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