YMCA of Central Ohio

U.S. Immigration and Customs Enforcement 

Rapid Response Plan

Overview:

The YMCA of Central Ohio is committed to providing safe spaces for all individuals and families we serve. Recent Executive Orders have implications for YMCA operations and programs, including the rescission of policies that previously protected certain areas – such as churches, schools, and hospitals – from immigration enforcement. This means that U.S. Immigration and Customs Enforcement (ICE) may now take enforcement action in these locations, potentially affecting YMCA programs in schools or churches.

Our first priority is providing an environment where all our members and staff feel safe and supported. This document is intended to help team members navigate unplanned visits from U.S. Immigration and Customs Enforcement (ICE) officials while ensuring we can continue to support our communities and fulfill our mission.

This document is intended to help any team member navigate an unplanned visit from U.S. Immigration and Customs Enforcement (ICE) officials. As organizational policy, we do not allow law enforcement officials, including ICE agents, on to the premises and into areas not considered public without a valid search warrant. In the event an employee is the first to engage with ICE, they should be kind but firm, requiring proper documentation for entry to our facilities be produced, and immediately contacting the Rapid Response Leader.

Our Position:

The YMCA of Central Ohio is committed to providing safe spaces for all individuals and families we serve. We do not:

• Ask families or members about their immigration or citizenship status

• Share personal information with federal immigration agencies without a court order

• Release participants to anyone not on their authorized pick-up list unless presented with a court order

• As always, we will allow access to law enforcement under court orders and warrants only, or when providing direct care for emergency services to our staff, members, and participants. If law enforcement arrives at your site for whatever reason, please contact your supervisor and the Level One Emergency Hotline, 513-580-THE-Y.

Emergency Contact Information:

If law enforcement arrives at your location for any reason:

1. Contact your immediate supervisor

2. Call the Level One Emergency Hotline: 513-580-THE-Y

Rapid Response Team:

Our Rapid Response Team is a group of committed employees who are well informed on our response practices, and ready to take swift action. See below for the list of staff on the YMCA’s Rapid Response Team. It is the duty of every staff member that if anyone enters a YMCA facility or program, staff are to immediately contact the YMCA’s Risk Management Team via their Level 1 reporting procedures (calling 1-513-580-THE-Y).

Contacts:

Understanding ICE Visits:

ICE may visit YMCA facilities for:

• I-9 Audits (requiring documentation within 3 days)

• Execution of warrants

• Enforcement actions

I-9 Audit Process

• Must produce requested documentation within 3 days

• If unauthorized workers are identified, there is a 10-day window to provide legitimate work authorization

• Without proper authorization, affected workers must be terminated immediately

Types of Valid Warrants:

Judicial Warrant Requirements:

• Must be signed by a judge or magistrate

• Must accurately describe the location to be searched

• Must specify persons or items to be seized

• Must be dated within the past 14 days

• If the warrant is missing one or more of these requirements, it is invalid. So, for example, if the warrant does not have the facility’s correct address, the officers cannot conduct a search or make an arrest in the facility. And all warrants must be signed by a judge or magistrate, not an officer or ICE agent, or they are not valid.
  
  

Search Warrant Guidelines:

• Only permits search of specifically listed areas

• Staff should direct officers only to areas listed in the warrant

• Deny access to areas not specified in the warrant

• If officers request access to unlisted areas, state: "No. You are not authorized to search [requested area] and it is our policy not to allow searches without warrants."
  
  

Arrest Warrant Guidelines:

• Permits detention of specific individuals

• Only grants access to areas specified in the warrant

• Administrative warrants do not permit facility access

• Staff are not required to identify anyone

• For unauthorized areas, state: "I'm sorry but this is private property, and we do not consent to your searching our facility."
  
  

Rapid Response Procedures:

• ICE Agents may visit a site for several reasons. These events are often very fast and targeted actions, relying on the element of surprise. Our organizational policy does not allow uninvited Law Enforcement Officers onto our premises without a valid search warrant. Should ICE arrive, be kind but firm while staying as calm as possible throughout the interaction.
  
  

Public vs. Private Areas:

• In general, areas open to the public (for example, a reception area) are open to immigration agents, and agents may enter these spaces without a warrant. 

• ICE agents must have a valid judicial search or arrest warrant to lawfully access private or non-public areas (for example, private spaces, areas only open to members, or areas in a shelter where people sleep).
  
  

When ICE Agents Arrive:

• Please keep in mind that Immigration Control Enforcement agents may be dressed in various attire: Vests, police uniforms, may show badges, or be dressed in professional attire. Regardless, proper ID should be displayed.
  
  

Front Desk/First Contact Staff:

1. Remain calm and professional. We want to avoid increasing anxiety and confusion

2. Immediately contact YMCA leadership via Level 1 Reporting Procedures

3. Greet agents professionally and ask their purpose

4. For facility entry requests, use this script: "This is a private area. You cannot enter without a judicial warrant signed by a judge. Do you have a judicial warrant?"

5. If a warrant is presented:

   1. Request a copy

   2. Use this script: "I am contacting our Risk Management team who has the authority to review the warrant and grant you further access."

6. Law enforcement officers generally may not enter private areas of the facility without a warrant signed by a judge or an invitation by a facility supervisor, staff, or administrator. Exceptions for police officers may include circumstances such as in the event of an emergency. 

7. Police can search without a warrant if they believe that evidence may be destroyed, or someone may be in danger if they wait to get a warrant.
   
   

DO NOT:

• Physically interfere with enforcement

• Help individuals hide or flee

• Sort individuals by immigration status, birth country, or national origin

• Sign any documents without consulting YMCA leadership

• *You are not required to report employee work status or location

• *Requesting to see a warrant, asking for identification, informing officers of facility policies, and denying access to non-public, private spaces is not interfering with law enforcement. 

During an ICE Visit:

Supervisor Responsibilities:

1. Immediately contact YMCA leadership through Level 1 Reporting Procedures

2. Verify warrant validity:

   1. Judge's signature

   2. Correct facility address

   3. Current date (within 14 days)

   4. Scope of search

3. Document the encounter:

   1. Number of agents present

   2. Agent appearance and conduct

   3. Areas accessed

   4. Any concerning interactions

4. Help communicate employee or participant needs (medication, childcare)
   
   

Child Safety Measures:

• Designate and maintain secure children's areas

• Escort children away from enforcement areas

• Ensure proper staffing of restricted-access zones
  
  

If an Arrest Occurs:

• Document where the individual is being taken

• Notify People & Culture team immediately

• Do not sign any documents without YMCA leadership approval
  
  

Documentation Requirements:

Record the following details for your YMCA Incident Report:

• Number of agents (inside and outside)

• Agent appearance (uniforms, POLICE/FBI vests, weapons)

• Agent conduct and interactions

• Movement restrictions (Was any guidance provided on who may come and go from the facility?)

• Any mistreatment or concerning treatment
  
  

Legal Compliance Notes:

• ICE agents may enter public areas without a warrant

• Private areas require a valid judicial warrant

• Staff may request identification and warrants

• Staff may inform officers of facility policies

• Staff may deny access to private spaces without proper documentation

• Police may search without a warrant if they believe evidence may be destroyed or someone is in immediate danger
  
  

Remember: Stay calm, be professional, and follow these procedures while protecting the rights and safety of our members and staff.

Frontdesk Reference Sheet

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