BRONTE 001-C - From Model to Deployment: A Turn-Key Conflict-of-Interest Fork for California State University (CSU) Office for Prevention of Harassment & Discrimination (OPHD) Intake Systems

This paper translates a first-principles systems model of conflict-of-interest handling in university civil rights intake into a turn-key implementation blueprint for the California State University (CSU) environment. Drawing on the existing CSU Interim Nondiscrimination Policy, which provides systemwide procedures for student and employee complaints, and the Cozen O’Connor systemwide assessment highlighting gaps in records management and oversight, we show how a conflict-of-interest “fork” can be inserted into existing Office for the Prevention of Harassment & Discrimination (OPHD) / Title IX intake systems without rewriting policy or replacing case-management software. The upgrade is designed to be configuration-level and platform-agnostic, leveraging typical features of commercial case-management tools (custom fields, routing rules, role-based permissions, queues, and audit logs). The result is a practical, “can-go-live-tomorrow” pattern that: (1) detects when compliance staff or their supervisors are implicated, (2) locks local intake decision-making, (3) transfers authority to a system-level or external decision node, and (4) leaves an auditable trail of all blocked actions and transfers. The paper concludes with a phased activation plan calibrated to CSU OPHD practice. Keywords: California State University (CSU), Title IX, Retaliation, Conflict of interest, Complaint intake, Case-management systems, Governance and internal controls, Civil rights compliance