University Policies and Procedures Manual (previously Business Policies and Procedures Manual)

Internal Investigations

UPPM 10.17

For more information contact:
    See Section 4.0 for policy owners

1.0   Policy

WSU is committed to conducting internal investigations fairly, promptly, and in accordance with standards established by WSU policy and state and federal laws. To ensure adherence to these principles, the University requires training of investigators and documentation of investigation procedures and outcomes.

2.0   Applicability

This policy applies to investigations conducted by University departments whose duties include interviewing witnesses, obtaining documents, or otherwise gathering information that may be used in enforcement or disciplinary actions or proceedings and/or where there is potential for civil or criminal remedies or penalties to be imposed. This policy also applies to University offices responsible for investigating accidents or workplace safety in accordance with SPPM 2.26.

The requirements in this policy do not apply to commissioned law enforcement officers investigating criminal conduct, employees conducting checklist inspections or reviewing application materials for eligibility purposes, employees whose investigative duties involve simply obtaining documents, or supervisors engaging in routine employee corrective action or performance evaluation not specifically limited to an investigative unit in Section 4.0.

3.0    Requirements

University units and personnel are not permitted to conduct investigations absent involvement and approval from the University department having jurisdiction in the identified area of investigation. (See Section 4.0.)

3.1      Procedures

Each University investigative unit is required to develop and maintain internal investigative procedures. These procedures should, at a minimum, include:

  • Investigating unit’s scope of authority;
  • Process for complaint intake and review;
  • Protocols for referrals to or cooperation with other WSU units (for example, when the issue is outside the unit’s scope of authority, extends across authority of multiple units, or presents a potential conflict of interest);
  • Process for communicating the outcome of the investigation;
  • Standards for documenting the investigation process and complying with any reporting obligations; and
  • Practices to maintain security of data and information obtained through the investigation.

Investigative units adhere to additional procedures as required by law or other University policy.

3.2     Training and Documentation

Each investigative unit must ensure that at least one supervisory level employee is trained through the Washington State Department of Enterprise Services Investigator Training Program (Investigator Core Training and Investigator Advanced Training) or other training program appropriate to the type of investigations the unit conducts.

The scope of investigation activities for some units may require additional, specific training and certification.  All employees or contractors engaged in conducting internal investigations must undergo any training required by law or other University policy.

Each investigative unit is responsible for ensuring:

  • Employees complete appropriate and required trainings prior to engaging in investigations;
  • Employee trainings and certifications are up to date; and
  • Records documenting trainings and certifications are maintained in accordance with the University records retention schedule (UPPM 90.01).

4.0   Investigative Units

The following units have investigative functions and are responsible for complying with this policy. Other unlisted units meeting the requirements indicated under Section 3.0 are also responsible for policy compliance. Links to related procedures are provided when available.

The University’s Chief Compliance and Risk Officer (CCRO) provides advisory guidance on the University’s compliance obligations. The CCRO may request reports and policy documentation regarding University investigations to ensure policies and procedures align with compliance obligations but does not directly participate in or observe active investigations unless specifically requested by the investigative unit or the University President.

Center for Community Standards

Compliance and Civil Rights

  • Discrimination and harassment – UPPM 10.60
  • Information privacy incidents — UPPM 88.05
  • Other matters authorized by or required by law and/or University policy, as directed by the University’s Chief Compliance and Risk Officer

Environmental Health and Safety

Human Resource Services

Information Technology Services – Security Unit

Internal Audit

Office of the Provost

Office of Research

Risk Management

5.0   Other Resources

Reporting at WSU – a list of primary WSU-related reporting options

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Revisions:  Dec. 2025 (Rev. 649); Nov. 2024 (editorial); Jan. 2020 (Rev. 88); Sept. 2006 (Rev. 24)