The first step in creating a response plan is to conduct a risk assessment. Every organization has different physical premises, activities, and areas of vulnerability. Conducting a risk assessment allows your organization to tailor a response plan designed to meet its unique needs.

Step 1. Assess your organization’s risk.

• Although there is no certainty, your organization’s risk exposure – and the likelihood of it experiencing an ICE encounter – will likely depend on where your organization is located (i.e., which county in Pennsylvania) and on the number of immigrants in your community, and the individuals served by your organization. See the legal landscape discussion above on sanctuary jurisdictions.
• Risk assessment is a team effort. In these challenging times, it is more important than ever to have open and ongoing communication with your team, and between your organization’s leadership staff and Board of Directors, to assess risk. It’s critical to get aligned on risk tolerance and to recognize that risk tolerances can vary widely within an organization (e.g., Board members who join on a volunteer basis, sometimes to build goodwill and broader networks, may have less of an appetite for risk).
• Establish open and ongoing communication between staff leadership and “front line” workers and volunteers to provide leadership and the Board – and your organization’s legal counsel –with information related to what team members are seeing/hearing/learning about.

Step 2. Conduct a review of the organization’s physical spaces, analyzing points of access, which areas are open to the public and which are private, and whether there is adequate and appropriate signage designating public and private space.

• Note: Depending on your organization’s facilities and activities, it may be challenging to strike a balance between distinct boundaries for private space and a welcoming environment for those you serve.

Step 3. Review the security of the organization’s records. Some things to consider: Have you confirmed that sensitive information is not accessible in public areas? Are physical records stored in locked cabinets? Are electronic records password-protected in systems with defenses against cyber incidents?

Step 4. Review and discuss insurance coverage and exclusions with your organization’s insurance advisor and assess the adequacy of coverage.

Step 5. Collaborate and communicate with peer organizations and associations of organizations to assist in identifying risks, observing patterns, and implementing strategies and solutions.

Step 6. Seek out guidance from advisors (legal, accounting, insurance, etc.) who are aware of the legal, practical, and psychological/emotional factors affecting your organization and those whom you serve.