22 September 1998

Mr. Joseph Olchefske, for
Superintendent John Stanford
Seattle Public Schools
815 Fourth Avenue North
Seattle, WA 98109

Referral: Policy Recommendations, Commercial Activity in the Schools

Dear Mr. Olchefske

Our committee completed its work last week, and now refers its recommendations to you.

For the past twelve months we've examined the subject of commercial activity in public schools from many angles. We surveyed and discussed—at length—the policies adopted by other districts. I think we all learned to appreciate each other's differing positions on how commercial involvement can both enhance and threaten achievement of educational goals.

For the committee, I thank and commend Ron English and Larry Miller for their professional support and assistance—and their continuing good humor! We depended on their advice and counsel, and appreciated their attempts to provide administrative support for us when resources proved to be extremely scarce.

This referral contains our policy recommendations; statements and examples are intended to provide background on the committee's thinking. I hope the “laundry list” of ideas for implementation procedures will be useful to staff, but they should not be considered formal recommendations, since the committee did not have time to review them in detail.

I thank Mr. Stanford for this opportunity to participate in the district's policy making process. Please feel free to contact me, and other members of the committee, with questions about this referral.

Cordially

Mary S. Cutting
Chair, Commercial Activity Committee

Enclosures: 2

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COMMERCIAL ACTIVITY IN SCHOOLS

General Statement

The board adopts this policy to assure that commercial activity in the schools contributes to a healthy educational environment, and that district, site, and classroom decision-makers are provided a clear, practical framework within which to define acceptable school-centered commercial activities.

Commercial activity in the schools includes sponsorship (partnership), sponsored educational materials (SEM), fundraising and advertising.

Business and other organizations support schools in many ways and promote the welfare of youth.

Professional educators shall be the primary decision-makers regarding the acceptability and value of commercial activity in schools.

Parents and community members should be consulted in the decision-making process and be well-informed about the nature and extent of any commercial activities in the schools.

Site decision-makers may adopt more restrictive policies than those set forth below, but not less.

This policy will be reviewed one year after adoption, and every three years thereafter, by a committee appointed by the Superintendent. The committee will consist of District personnel, site administrators, parents and community members.

All commercial activities shall be consistent with Seattle School District policies prohibiting discrimination on the basis of race, color, national origin, religion, sex, handicap, age or sexual orientation, and shall not be permitted where they are misleading, inaccurate or not age-appropriate for the students involved.

  1. Sponsorships (Partnerships) and Sponsored Educational Material (SEM)

Commercial partnerships and sponsorships by companies and other organizations to support District programs are permitted within appropriate limits.

Healthy partnerships

  1. develop relationships which make students aware of the greater community, e.g., provide adult models and mentors or provide service learning opportunities or arrange for job shadowing, and
  2. increase the awareness within the business community of the educational needs of our students and encourage long term investment in their education, e.g., long-term partnerships, flex-time to allow employees to participate in student's education, matching funds, donations, promotion of school activities in workplace newsletters.

Sponsorships and Sponsored Educational Materials must

  1. permit educators, not sponsors, discretion in how or whether they integrate sponsor-provided material or program into their curriculum,
  2. promote equitable treatment across socioeconomic/ethnic groups, and
  3. support State, District and/or school learning objectives and other academic and strategic goals.

Commercial partnerships and sponsored educational materials must not

  1. require students to watch or see promotional advertising in schools in exchange for money or goods,
  2. require students to advertise a product or service, or
  3. permit access to students through the schools to develop demographic or marketing information.

Sponsor Recognition

  1. It is desirable that sponsors accurately inform the public about their contribution/activities in public schools. To this end, sponsors (underwriters, grantors, etc.) of curriculum and programs must be clearly disclosed. The name(s) of business, trade associations or individuals must be used. A means to contact the sponsor should be available. Logos should be used only for identification purposes.
  2. Sponsors of educational materials and programs must be made explicitly aware of the Seattle Public Schools District policy on commercialism (e.g., brochure available to sponsors, policy on web site).
  3. School activities should not be primarily about a sponsor, e.g., school children should not be compelled to make art projects or write essays primarily about sponsors.

Site decision-makers should use their best judgment in deciding
  1. whether direct sales by sponsors should be allowed during school hours, and
  2. whether to use staff or student time to promote products or sponsors.


  1. Fundraising

Schools have a rich tradition of site-based fundraising activities. These include sales of products for a commission, student labor activities, school directed rebates for purchased items, auctions, bake sales, yard sales, gifts and carnivals. At their best, these activities can be both educational and community building. At their worst, they can be exploitative of students' time and labor, and a poor return on effort.

School administrators should consider the following guidelines when considering fundraising activities.

  1. Fundraising activities should have an educational component or benefit.
  2. Fundraising activities should be structures to give equal opportunity for all students to participate.
  3. Promotion and execution of fundraising activities should take place outside of classroom time with intrusions kept to a minimum.
  4. Fundraising activities should discourage use of company provided incentives.
  5. Door to door sales are not permitted.
  6. Students shall not be required to participate in fundraising activities.
  7. Promotion and execution of fundraising activities should not take place during school assemblies.


  1. Advertising

Advertising is usually part of a sponsored or fundraising activity. It rarely occurs in schools all by itself.

For the decision maker, the primary issues will be whether the proposed sponsored or fundraising activity fits the district's fundraising or sponsorship guidelines.

If a proposed activity fits the district's fundraising or sponsorship guidelines, the decision maker should secondarily consider whether any advertising associated with the activity fits the guidelines below.

  1. Advertising should be carefully controlled during school hours.
  2. Schools should not grant advertisers access to captive student audiences in exchange for cash or non-cash (i.e., in-kind) payments. For purposes of the prior sentence, students are considered a captive audience while in classrooms during school hours. Site decision makers may extend “captive audience” status to common spaces (halls, lunchrooms, outdoors) in their buildings.
  3. Except for courses of study concerned with marketing and advertising, students should not be required to observe, listen to or read advertising in the classroom.
  4. Sponsored materials in curriculum related activities should contain only identification markings (i.e., sponsor name or logos).
  5. Athletic uniforms and athletic equipment may display the name or logo of the uniform or equipment manufacturer.
  6. Advertising is specifically permitted in Memorial Stadium.


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Commercial Activity in the Schools: Seattle Public Schools Advisory Committee

“This committee's goal is to recommend a policy that gives district, site, and classroom decision-makers a clear, practical framework within which to define acceptable school-centered commercial activities, consistent with program goals, that produce resources to enhance the learning experiences of Seattle students.”

Ideas for Implementation Procedures
(note: these are not formal recommendations of the committee)

sourcesuggestion
fundraising subcommittee 1. (proccedure) guidelines should be reviewed and revised as necessary within three (3) years of adoption
advertising subcommittee 2. (scope/general) the advertising policy should not limit the discretion of schools or staff in the selection or use of educational materials or programs

3. (scope/general) the advertising policy should not limit the ability of student organizations to plan and operate fundraising activities

4. (procedure) prior to consummating a public or private cooperative partnership proponants should be required to meet with a committee composed of parents, staff members, and at the high school level, students, to review the proposal and plan to disberse proceeds, if any, from the partnership

5. (procedure) implementation of the advertising policy should not require a length of contract longer than five (5) years, or provide for automatic renewals

6. (non-discrimination) all parties to a public or private sector cooperative partnership should support the Seattle School District's position prohibiting discrimination on the basis of race, color, national origin, religion, sex, handicap, age, or sexual orientation

committee chair 7. (scope/general) assume and rely on the professional judgment of its certified staff to allow only those commercial activities which support and enhance the district's goals. This policy should not abridge teachers' creative use of resources in their classrooms.

8. (scope/general) to reinforce commitment to site-based management, whenever possible decisions regarding acceptable commercial activity should be made at the lowest operational level, i.e. the classroom or building.

9. (procedure) when a decision regarding commercial activity is made at the district level, the designated decision-maker(s) should involve site-level managers in the process.

10. (procedure) a cross-discipline, multi-level media literacy curriculum should be developed and tested for required use as part of any commercial activity approved in the Seattle schools.

11. (procedure) the district should train principals and other staff in the application of its commercial activity policy and provide staff support to decision-makers as appropriate and useful; the superintendent will appoint a standing committee to oversee commercial activity in the Seattle schools.

12. (scope/general) recognizing that these three type of commercial activity will overlap, designated decision-maker(s) should first determine which definition will take precedence in the evaluation of a proposed activity. Relevant constraints identified in the other two definitions should be applied during the evaluation process.

13. (procedure) in order to assure that contracts and/or formal agreements with commercial entities active in the schools are uniform and consistent, all such agreements in which the economic benefit exceeds $2500 (funds or in-kind) should be reviewed by district legal staff and approved by the Board prior to signing and implementation.

14. (procedure) all moneys related to commercial activities in the schools should be accounted for according to rules and systems to be established by the district accounting office for this special purpose. The Board should review and approve a summary of these accounts annually. School district staff involved in commercial activities in the schools should avoid real or perceived conflict of interest in their use of funds generated by these activities.

15. (procedure) the superintendent should adopt enforcement procedures and authorize necessary enforcement resources concurrent with implementation of this policy.

sponsorship subcommittee

(note: these four (4) recommendations are revisions or additions to the district's existing set of guidelines which contain other information)

 16. (procedure) all materials to be sent home with students should be reviewed by the building principal or program manager to assure conformity with district commercial activity policy and approved prior to distribution.

17. (procedure) approved material to be distributed by school mail should be pre-counted, bundled, and labeled for each building.

18. (procedure) the list of supplementary instructional materials needs to be updated to include such materials as computer software, educational television, films and videos.

19. (procedure) all sponsored materials should be reviewed in accordance with the procedure established by the school in which it is to be used; this procedure must be available in writing for community review and include some form of peer review and a complaint resolution process