NON-DISCRIMINATION POLICY
Agency Introduction
Skyline Literacy is a private, not-for-profit organization committed to the improvement of literacy in the Harrisonburg-Rockingham County area. We believe that a well-trained and supported corps of volunteers can make a difference. To accomplish our goal, we train volunteer tutors to provide instruction in a student-centered, collaborative environment.
Mission & Vision Statement
“Our Mission is to provide instruction, based on need, in various literacies, for adults in Harrisonburg and Rockingham County, using trained, qualified instructors and volunteers”.
“Our Vision is a community where adults are empowered by literacy skills to be self-sufficient, navigate daily life, and participate in the workforce, education, and civic affairs.”
Statement of Non-Discrimination
“We believe in the value of diversity, consistent with our Non-Discrimination Policy, and are committed to inclusivity in all our endeavors. Our Policy bans discrimination on the basis of race, color, religion, sex, national origin, age, disability, political affiliation or belief, or any such category protected by law.”
This document outlines the basic elements of Skyline Literacy’s Equal Opportunity Policy Statement, the process for receiving and responding to complaints of discrimination from program beneficiaries.
NOTICE OF NON-DISCRIMINATION
Skyline Literacy complies with Federal civil rights laws and is committed to providing its programs and services without discrimination in accordance with:
● Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin (including language).
● Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based on disability.
● Title IX of the Educations Amendments Act of 1972, which prohibits discrimination based on sex in education programs or activities.
● Age Discrimination Act of 1975, which prohibits discrimination based on age.
● U.S. Department of Homeland Security regulation 6 C.F.R. Part 19, which prohibits discrimination based on religion in social service programs.
It is the policy of Skyline Literacy to:
● Prohibit unlawful discrimination on the following bases: against any individual in the United States, on the basis of race, color, religion, sex (including pregnancy, childbirth, and related medical conditions, sex stereotyping, transgender status, and gender identity), national origin (including limited English proficiency), age, disability, or political affiliation or belief, or, any such category protected by law. This includes discrimination against any beneficiary of, applicant to, or participant in programs financially assisted under the DHS-USCIS Citizenship Assimilation Grant.
● Comply with both the letter and the spirit of all applicable laws and regulations governing employment.
WHAT TO DO IF YOU BELIEVE YOU HAVE EXPERIENCED DISCRIMINATION
To File a Complaint
If you believe that you have been subjected to discrimination under a DHS-USCIS Citizenship and Assimilation Program or any agency or individuals from whom Skyline receives funds, we encourage you to promptly report such incidences, in writing, but no later than 30 days from the date of the alleged violation. The report can be in-person, email, or mail to one of the following individuals:
The Board President will receive each complaint and will address it consistent with the procedural steps below in consultation with any necessary party. A full and impartial investigation of any such complaint will be carried out promptly. Confidentiality will be maintained to the fullest extent possible. Skyline Literacy prohibits retaliation against individual who reports discrimination or harassment or participates in an investigation of such reports.
You can also file a civil rights complaint with the U.S. Department of Homeland Security Office for Civil Rights and Civil Liberties (CRCL):
E-mail: CRCLCompliance@hq.dhs.gov (fastest method to submit your complaint)
Fax: 202-401-4708
U.S. Mail:
U.S. Department of Homeland Security
Office for Civil Rights and Civil Liberties
Compliance Branch
245 Murray Lane, SW
Building 410, Mail Stop #0190
Washington, D.C. 20528
For additional information: www.dhs.gov/crcl Phone: 202-401-1474 Toll-Free: 1-866-644-8360
STEPS TO FILE A COMPLAINT
1. Skyline Literacy will provide the client, customer, program participant, or consumer with written acknowledgement of the complaint within 10 days of receipt.
2. Skyline Literacy will correspond with the complainant throughout the investigation by surface mail and/or email, or in person.
3. Within 10 days of receiving the complaint, Skyline Literacy will conduct an internal investigation of the complaint or will determine whether it will refer the complaint to an appropriate external agency for investigation, such as a local or state human rights commission, or CRCL.
4. The party against whom a discriminatory act is attributed will be promptly notified and given the opportunity to respond.
5. Skyline Literacy will provide a Notice of Final Action (that may include any corrective steps to be taken) within 30 days of the complaint.
6. If Skyline Literacy does not provide the Final Action within 30 days, the individual may file a complaint with CRCL if not already so filed.
7. If Skyline Literacy does provide a written Notice of Final Action, but the individual is dissatisfied with the decision or resolution, the individual may file a complaint with CRCL if not already so filed.
8. False/malicious complaints (as opposed to errors of those making good faith complaints) will be subject to appropriate disciplinary measures.
9. Skyline Literacy will track the status of complaints for our organizational records as required by law.
APPEAL PROCESS
A party who wishes to appeal the agency decision must do so in writing within 10 days after the agency's decision, by following the steps as outline above.
DUAL FILINGS
Subagencies[1] are required to share with each other complaints that have been received. If the individual has submitted dual-filings, Skyline Literacy will contact CRCL, CWS, and any other relevant agency to determine a coordinated approach in resolving the complaint.
MONITORING CIVIL RIGHTS COMPLIANCE ON SUBRECIPIENT
1. CWS agrees to provide monthly written reports, to Skyline Literacy, of any civil rights complaints, during that quarter. CWS will provide these reports whether or not a complaint has been filed during a given month.
2. CWS, to ensure the complaint process is accessible to all stakeholders, agrees to post notices at key locations in its office that describes the complaint process. These notices will be in Arabic, Kurdish, Russian, Swahili, Spanish, Tigrinya, with translations in other languages as necessary.
3. CWS agrees to take and share, with Skyline Literacy, photographs of these notices, should DHS request certain compliance information that visuals may best capture.
4. CWS agrees to promptly share any changes to its complaint procedure with Skyline Literacy. Skyline Literacy will review CWS’ complaint process, or any changes made to it, to ensure it complies with DHS requirements.
5. Skyline Literacy will compile and incorporate the CWS complaint reports (whether or not complaints were made) in her Report to the Board that is distributed before each meeting of the Skyline Literacy Board.
6. In the event a complaint is filed, CWS agrees to immediately contact Literacy, who will then follow the steps as outlined in Skyline Literacy’s Non-Discrimination Policy.
7. An auditor, on a quarterly basis will review both CWS’ monthly reports to Skyline Literacy, as well as Skyline’s recordation of those reports.
ACCOMODATIONS PROCESS FOR PEOPLE WITH DISABILITIES
Skyline Literacy is committed to complying with all DHS-USCIS reasonable accommodation policy requirements. Skyline Literacy will make reasonable accommodations for the physical limitations of qualified employees, volunteers, students, or applicants with disabilities upon request and at no cost to the individual.
Notifying Program Beneficiaries
Skyline Literacy will provide the client, customer, program participant, or consumer with information of the accommodations on its website, poster in the facility, and all public relation materials.
Accepting and Responding to Request for Accommodations
1. Skyline Literacy staff (either Program or Tutor Manager) will correspond with the request of accommodation by phone and/or email, or in person.
2. The standard procedure is as follows:
a) Notice to member to the public as described above.
b) A form will be available on the website to fill out the request of accommodations. Skyline Literacy will inform to individuals of this form via phone or email.
c) Staff will submit the request of accommodation to the Executive Director to evaluate the need and resources available to provide the proper accommodation requested.
d) The Executive Director will address the request in a 1-2 business days.
e) Staff will notify the individual making the request, in 2-3 business days, of any provision for providing interim accommodations if a requested accommodation cannot be provided immediately.
3. Skyline Literacy will provide appropriate auxiliary aids and services, such as, but not limited to, qualified sign language interpreters and written information in other formats (large print, audio, accessible electronic formats, etc.), to communicate effectively with persons with disabilities. Skyline Literacy will contact the agency that most appropriately meet the need of each individual.
4. Skyline Literacy will keep the accommodation request confidential and will appropriately secure any personally identifiable information (PII) in a lock cabinet.
5. Staff will provide the approved accommodations for eligible individuals during the time that he/she receives services from Skyline.
Monitoring the Provision of Reasonable Accommodations
Skyline Literacy will keep in spreadsheet the following information to monitor the accommodations provided:
1. Type of request for accommodations received annually.
2. Request that was denied and reason(s) for denial.
3. Type of alternate accommodations, if any that were provided.
4. A summary of circumstances regarding any denial based upon a determination of fundamental alteration or undue burden to Skyline Literacy.
LANGUAGE ACCESS
Skyline Literacy is committed to complying with all DHS-USCIS language access policy requirements.
Identifying LEP individuals who need language assistance
Skyline Literacy provides English instruction for adults in Harrisonburg and Rockingham County. Ninety five percent of Skyline’s program beneficiaries are Limited English Proficient (LEP). The four top languages served are: Spanish, Kurdish, Arabic, and Tigrinya.
Skyline Literacy will provide the client, customer, program participant, or consumer with information of the language access on its website, poster in the facility, and all public relation materials.
Language Assistance Measures and Available Resources
All new program beneficiaries are administered CASAS, a standardized assessment test (approved by the U.S. Department of Education’s National Reporting System for Adult Education) to determine their current level of knowledge and proficiency.
a. Skyline Literacy will provide appropriate writing material to ensure meaningful access to programs and activities, by translating all promotional material in Spanish, Arabic, and Kurdish.
b. At the time of first contact, via mail, email, phone, text messages, LEP will be contacted in their own language by qualified bilingual staff.
c. Skyline Literacy will provide quarterly informational sessions about the services provided (ESL and Citizenship classes) and contract the Area Health Education Center with the Interpreter Services (AHEC) for languages of participants such Spanish, Kurdish, Arabic, Russian, Tigrinya, and Swahili.
Distribution of Plan and Training for Staff
Skyline Literacy’s staff are certified ESL teachers, and bilinguals in Spanish, Kurdish, and Arabic.
NON-DISCRIMINATION POLICY AVAILABLE
Skyline Literacy provides this Non-Discrimination policy in Spanish, Kurdish, Arabic, Russian, Tigrinya, and Swahili. Skyline Literacy will make this policy available in other languages, as necessary.
Skyline Literacy includes this Non-Discrimination Policy in its Operational Manual, on the Skyline Literacy program information board and in the student package.
Skyline Literacy will make available this Non-Discrimination policy on its website www.skylineliteracy.org
[1] Subagencies are of DHS USCIS citizenship grants recipients. Skyline Literacy's subagency, with which it would share a complaint, is Church World Service, Harrisonburg, Virginia. Subagencies must ensure confidentiality with the complaint received.