Private clubs run on hospitality — welcoming people, solving problems quickly, and keeping operations moving. That instinct is what makes clubs successful. But there are times when that same instinct can create risk, such as when federal immigration enforcement arrives at the workplace.

A club manager’s goal should not be to interfere with federal immigration enforcement. The goal is to respond calmly, preserve the club’s rights, protect employees, and avoid mistakes by front-line supervisors who may be the first people contacted.

1. Designate a Response Team

A practical response plan starts with a simple question: who is authorized to receive and evaluate legal papers? Clubs should identify a small response team — usually the General Manager, HR lead, and legal counsel. Reception, security, golf operations, food and beverage, housekeeping, maintenance, and department managers should all know who to contact and how to reach that team immediately. No one needs to debate the law at the front desk, kitchen door, cart barn, or maintenance yard.

2. Know Your Spaces

The second step is to distinguish public areas from nonpublic areas. In a club environment, public or member-accessible areas may include the lobby, dining room, pro shop, parking lot, or event space during normal operations.

Nonpublic areas may include offices, kitchens, back-of-house service areas, employee-only spaces, file rooms, maintenance shops, payroll offices, and HR offices.

If officers ask to enter a nonpublic area, the manager receiving the request should ask for identification and any warrant, subpoena, or notice supporting the request. They should also contact the club’s designated response team if they have not already done so.

3. Understand the Paperwork

Managers should understand the difference between a judicial warrant and other documents. A judicial warrant is signed by a judge and issued by a court. An administrative immigration warrant — including a warrant of removal or deportation — is not the same thing. A subpoena, notice of inspection, or agency request may carry separate obligations, but those documents should be reviewed by the response team before the club provides access to records or nonpublic areas.

4. Protect Employee Records and Meet Notice Deadlines

Employee records require special care. California law requires employers to provide notice to current employees and any authorized representative within 72 hours after receiving notice of an immigration agency inspection of I-9 forms or other employment records. If inspection results later identify affected employees, additional individualized notice obligations may apply. Clubs should maintain I-9 files, personnel files, payroll records, and emergency contact information in an organized, centralized manner so they can respond within statutory deadlines.

5. Update for the 2026 Workplace Know Your Rights Act

California’s 2026 Workplace Know Your Rights Act added another compliance layer. Employers must provide an annual workplace-rights notice to employees covering retaliation protections, workers’ compensation, immigration-related rights, labor organizing rights, emergency contact rights, and constitutional rights when interacting with law enforcement at work. Employers must also allow employees to designate an emergency contact and indicate whether that contact should be notified if the employee is arrested or detained at work. Clubs should confirm that onboarding packets, annual notice procedures, HRIS fields, and emergency contact forms have been updated.

6. Know What Not to Do

A club-specific plan should also address what managers should not do. Managers should not argue with officers, obstruct access, hide employees, instruct employees to leave, destroy records, or provide false information. They also should not voluntarily open file cabinets, provide passwords, escort officers into employee-only areas, or hand over employee records before the response team reviews the request. Equally important, clubs may not retaliate against any employee who exercises rights during a law enforcement encounter. The best answer in the moment is often the simplest: “I am going to contact the person authorized to handle this for the club.”

7. Train for the First Five Minutes

A written policy is useful, but the real risk sits with the first person who receives the request. A short script, a laminated response card, and a designated phone tree can prevent confusion during a stressful situation. Clubs may also want to conduct a tabletop exercise with the GM, HR, security, and key department heads.

Private clubs will be best served by a protocol that is simple and clear: identify the response team, confirm legal authority, preserve documents, meet notice deadlines, protect employees from retaliation, and document what occurred. A calm first five minutes is worth more than a complicated policy manual.