INTRODUCTION

Recipients of financial assistance from the Department of Homeland Security (DHS) are required to comply with laws and regulations relating to nondiscrimination and the nondiscriminatory use of federal funds. As a recipient of Federal financial assistance, the District must have a policy in place that ensures compliance with applicable provisions of laws and policies prohibiting discrimination in its public-facing programs.

CIVIL RIGHTS COMPLIANCE POLICY (PUBLIC-FACING)

PURPOSE AND SCOPE

The Quincy Fire Protection District is committed to providing services to the public without discrimination in accordance with federal civil rights laws. It is the purpose of this policy to establish a framework for taking reasonable steps to ensure equal public access to all services provided by the District, ensure nondiscrimination and the nondiscriminatory use of federal funds, and establish a method to receive and investigate allegations of discrimination from the public while ensuring compliance with reporting requirements related to this policy when receiving federal financial assistance

POLICY

It is the policy of the Quincy Fire Protection District to ensure compliance with applicable provisions of laws and policies prohibiting discrimination in its public-facing programs and services, including but not limited to:

·         Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin (including Limited English Proficiency (LEP)).

·         Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based on disability.

·         Title IX of the Education 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 on religion in social service programs.

Prohibition Against Retaliation

The District and its employees may not intimidate, threaten, coerce, or discriminate against any individual for the purpose of interfering with any right or access to services and programs because the individual has made a complaint regarding a violation of this policy, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing. This policy shall be made available to any individual alleging such harassment or intimidation, and the complainant shall be informed of their right to file a complaint with the District and given the contact information for the employee assigned to oversee compliance with the specific civil right alleged to have been violated

Public Notice/Meeting Planning

The District will ensure the consideration of Limited English Proficiency (LEP) and disabled populations when developing public notices and planning for public meetings or hearings.

1.    Notices will include language in English and Spanish for LEP and disabled populations to request reasonable accommodation at least 48 hours prior to the event;

2.    The District Secretary will maintain a list of LEP and other accessibility requests and the efforts made to provide reasonable accommodations.

3.    The District will provide reasonable accommodations for persons with disabilities or LEP. Quincy Fire will generally, upon a minimum 48-hour advance request, offer appropriate aids and services to provide meaningful access for qualified persons with disabilities in order for them to participate in District activities, including interpreters and other ways of making communications accessible to people who have speech, hearing, vision impairments or LEP.

4.    The District will not charge any fees to any person with, or group of individuals with disabilities, to cover the cost of providing auxiliary aids/services or reasonable modifications such as retrieving items from locations that are open to the public but are not accessible to persons relying on wheelchairs. Service animals will be permitted to accompany people with disabilities regardless of the policy that may prohibit animals from District facilities.

Information and Communications Technology Accessibility

1.    The District will follow Section 508 of the Rehabilitation Act, in addition to the Web Content Accessibility Guidelines (WCAG 2.1) to maintain digital content compatibility for assistive technology on its digital platforms. The District’s website provides links to digital accessibility tools.

2.    TTY and Telecommunications Relay Service: Staff can and will identify calls facilitated by a relay service, and communicate with the communications assistant.

Limited English Proficiency and Language Access

The District prohibits discrimination on the basis of national origin (including Limited English Proficiency (LEP)). The District takes reasonable steps to ensure that LEP persons have meaningful access to programs and services by:

1.    Maintain a log of LEP-specific requests;

2.    Provide a language translation feature on the District website; provide professionally translated material when available;

3.    Coordinate with appropriate staff members to provide interpretation services when available;

4.    Provide programming for LEP audiences when resources to do so are available;

5.    Provide educational and outreach material developed for LEP persons for distribution in schools and at events.

6.    Post content developed for LEP persons on social media when available.

Civil Rights Complaints

The District will provide a method to receive and investigate allegations of discrimination from the public.

Civil Rights Complaints

The District will provide a method to receive and investigate allegations of discrimination from the public.

1.    The District will create and maintain a Notice of Nondiscrimination along with a civil rights complaint form for the public on its website, and at the District’s Administrative Offices.

2.    The District’s website will provide a notice of the District’s procedures for prompt processing, investigation, and disposition of public complaints made against the District.

       a.    The bases for filing the complaint (race, color, or national origin (including limited English proficiency), sex, age, disability, religion, or alleging retaliation);

       b.    Timeframe for filing the complaint;

       c.    Procedures for filing the complaint;

       d.    Information on how a person with a disability or Limited English Proficiency (LEP) can file a complaint.

3.    The designated employee will for the district process the complaint as follows:

a.    Provide written acknowledgment of the claim within 10 days of receipt with directions on how the complainant should correspond with the designated employee throughout the investigation;

b.    Determine if the individual has filed a complaint with another agency to prevent duplicate investigations;

c.    If appropriate, initiate an investigation, schedule an interview, and provide the claimant with a timeline;

d.    Track the complaint to ensure timelines are met;

e.    If the preliminary inquiry indicates an investigation is not warranted, notify the complainant in writing of the reasons why and the factors considered;

f.     If an investigation is warranted, the results of the investigation will be provided to the Fire Chief for review;

g.    Notify the complainant in writing of the results of the investigation along with actions taken or planned to be implemented in response to the complaint, including a timeline to request review;

h.    Maintain records and files in accordance with the District’s Record Retention Policy.

Compliance Reporting to the Department of Homeland Security Office for Civil Rights & Civil Liberties

The District will complete and submit the Civil Rights Evaluation Tool to the Office for Civil Rights & Civil Liberties within 30 days of the Notice of Award of federal funding. So long as the District is receiving such funding, the policy will ensure the tool will be updated and submitted every two years thereafter.

Reporting Complaints

1.    Provide the total number of complaints or lawsuits against the District during the past three (3) years alleging discrimination on the basis of race, color or national origin (including Limited English Proficiency (LEP)), sex, age, disability, religion, or alleging retaliation. For each complaint or lawsuit, state the following:

    a.    Employment or non-employment (public-facing service/access) related;

     b.    Basis (race, color or national origin (including limited English proficiency), sex, age, disability, religion, or     alleging retaliation);

     c.    Status (pending, closed with findings, closed with no findings, settled, etc.);

     d.    Identify complaint vs. lawsuit

2.    For reporting purposes, there is no distinction between complaints labeled as informal or formal. Complaints are any and all allegations of discrimination that articulate one or more covered basis.

3.    If a court or administrative agency made a finding of discrimination in a non-employment complaint for the above three (3) years, include a copy of the complaint and findings.

4.    Responses should not include personally identifiable information (PII) that is outside of public record.
       a. Examples of PII include names, email addresses, home addresses, and phone numbers.

Reporting Civil Rights Compliance Reviews

1. Describe any civil rights compliance reviews conducted by any external agency (such as a federal agency or human rights commission) within the last two years.

    a.    If there were no reviews conducted during the period, report “no reviews.”

    b.    If there were reviews conducted for the reporting period, include in the description:

             i.    Findings

             ii.     Compliance recommendations

             iii.    Corrective actions

             iv.    Ongoing monitoring as a result of the review

     c.    Provide a statement affirming that staff has been designated to coordinate and carry out the responsibilities for compliance with civil rights laws, and a description of the responsibilities of any such staff.

Subrecipient Civil Rights Compliance and Monitoring

1.    Subrecipients of federal funding have obligations to comply with applicable civil rights requirements, although federal reporting is not required of them. The District is responsible for monitoring subrecipients for compliance. When the District enters into an agreement with a sub-recipient, the District will:

    a.    Designate a staff member to coordinate compliance monitoring;

    b.    Provide a copy of this policy to the subrecipient;

    c.    Obtain a copy of the subrecipient’s nondiscrimination policy;

   d.    Establish compliance procedures for the subrecipient;

   e.    Develop a compliance review instrument appropriate for the services provided;

   f.     Inform program beneficiaries of their civil rights protections, along with procedures for filing a complaint.