My Iona

Part II: Title IX Policy Options for Resolution

There are multiple ways to resolve a complaint or report of sex discrimination. Whenever possible, the University will utilize the resolution method chosen by the complainant. During the resolution of a complaint, the Title IX Coordinator will determine whether to implement reasonable supportive measures designed to assist all parties (complainants and respondents) and community members in maintaining access to and participation in University programs, services and activities during the resolution of the complaint.

This section includes information on support-based resolution, agreement-based resolution, and investigation and decision-making procedures.

Support-Based Resolution
A support-based resolution is an option for a complainant who does not wish the University to take any further steps to address their concern, and when the Title IX Coordinator determines that another form of resolution, or further action, is not required. Some types of support that may be appropriate include: adjustments or changes to class schedules; moving from one residence hall room to another; adjusted deadlines for projects or assignments; adjustments to work schedule or arrangements; escorts to and around campus; or counseling.

A support-based resolution does not preclude later use of another form of resolution, for example if new information becomes available to the University and the Title IX Coordinator determines there is need for additional steps to be taken, or the complainant later decides to pursue a Resolution Agreement or investigation and decision-making.

Agreement-Based Resolution
Agreement-Based Resolution is an alternative to the investigation and decision-making procedures where the Parties each voluntarily agree to resolve the complaint in a way that does not include an investigation and does not include any finding of responsibility. Agreement-Based Resolution is a voluntary, structured interaction between or among affected parties that balances support and accountability. If the University offers Agreement-Based Resolution to the parties, and they voluntarily consent to engage in that process, the Title IX Coordinator must still take other prompt and effective steps as needed to ensure that sex discrimination does not continue or recur within the education program or activity. Parties and the Title IX Coordinator may agree to pause or exit the investigation and decision-making resolution procedures to explore Agreement-Based Resolution.

Any party may design the proposed agreement between the parties. The Title IX Coordinator must approve of the use of the Agreement-Based Resolution process, and approve the final agreement between the parties. Agreement-Based Resolution may be initiated at any time prior to the release of the final determination. Because Agreement-Based Resolution does not involve an investigation, there is not any determination made as to whether a respondent violated this policy.

The Title IX Coordinator has the discretion to determine that Agreement-Based Resolution is not an appropriate way to address the reported conduct, and that the matter must instead be resolved through an investigation and decision-making process.

Initiating the Agreement-Based Resolution Process

Prior to the initiation of Agreement-Based Resolution, the Title IX Coordinator will provide the Parties written notice that includes:

  • The specific allegation and the specific conduct that is alleged to have occurred;
  • The requirements of the Agreement-Based Resolution process;
  • Any consequences resulting from participating in the Agreement-Based Resolution process, including the records that will be maintained or could be shared, and whether the University could disclose such information for use in a future University resolution process, including an investigation and resolution process arising from the same or different allegations, as may be appropriate.
  • Notice that an agreement resulting from the Agreement-Based Resolution process is binding only on the parties and is not subject to appeal.
  • Notice that once the Agreement is finalized and signed by the Parties, they cannot initiate or continue an investigation procedure arising from the same allegations.
  • A statement indicating that the decision to participate in the Agreement-Based Resolution process does not presume that the conduct at issue has occurred.
  • A statement that the respondent is presumed not responsible for violating this policy, unless respondent admits to violations of this policy;
  • An explanation that all parties may be accompanied by an advisor of their choice , who may be a parent, colleague, friend, or attorney;
  • A statement that any party has the right to withdraw from the Agreement-Based Resolution process and initiate or resume resolution procedures at any time before agreeing to a resolution;
  • The date and time of the initial meeting with staff or the Title IX Coordinator, with a minimum of 3 days’ notice;
  • Information regarding Supportive Measures, which are available equally to the parties; and
  • The potential terms that may be requested or offered in an Agreement-Based Resolution agreement.

Facilitating an Agreement 
If all Parties are willing to explore Agreement-Based Resolution, the Title IX Coordinator will then meet separately with each party to discuss the Agreement-Based Resolution process and facilitate an agreement. If an agreement cannot be reached, either because the Parties do not agree, determine they no longer wish to participate in the Agreement-Based Resolution process, or the Title IX Coordinator does not believe that the terms of the agreement or continuing the Agreement-Based Resolution process is appropriate, the Title IX Coordinator may decide that the reported conduct will instead be addressed through the investigation and decision-making process. The Title IX Coordinator will inform the parties of such decision, in writing.

Agreement-Based Resolution processes are managed by facilitators who do not have a conflict of interest or bias in favor of or against complainants or respondents generally or regarding the specific parties in the matter. The Title IX Coordinator may serve as the facilitator, subject to these restrictions. The investigator or Decisionmaker(s) for the matter may not facilitate an Agreement-Based Resolution in that same matter.

Any party may craft or create the terms of their agreement and will be asked for their suggestions or ideas. Examples of agreements may include but are not limited to:

  • an agreement that the respondent will change classes or housing assignments;
  • an agreement that the Parties will not communicate or otherwise engage with one another;
  • an agreement that the Parties will not contact one another;
  • completion of a training or educational project by the respondent;
  • completion of a community service project by the respondent;
  • an agreement to engage in a restorative justice process or facilitated dialogue; and/or
  • discipline agreed upon by all parties.

In order to facilitate Agreement-Based Resolution, information shared by any party will not be used in any related resolution process of the same complaint under this policy. No evidence concerning the allegations obtained within the Agreement-Based Resolution process may be disseminated to any outside person, provided that any party to the Agreement-Based Resolution process may generally discuss the allegations under investigation with a parent, advisor, or other source of emotional support, or with an advocacy organization. An admission of responsibility made during an Agreement-Based Resolution process, however, may not be incorporated into the investigation and adjudication proceeding.

Finalizing the Resolution Agreement 
Once the final terms of the Resolution Agreement have been agreed upon by all parties, in writing, and approved by the Title IX Coordinator, the matter will be considered closed, and no further action will be taken. Once signed, no appeal is permitted. The Agreement-Based Resolution process is generally expected to be completed within thirty (30) days and may be extended by the Title IX Coordinator as appropriate. All parties will be notified, in writing, of any extension and the reason for the extension.

Records of an Agreement-Based Resolution process can be shared with other offices as appropriate.

Any violations of the terms of the Resolution Agreement may result in disciplinary action.

Investigation & Administrative Resolution
These procedures are applicable to all Prohibited Conduct. An investigation and administrative resolution process consists of five stages: written notice of investigation; evidence gathering; evidence review; investigation report; determination. Then the parties both have the option to appeal.

All parties have the option to participate in the investigation, and each have the same rights during the resolution process including the right to an advisor, to submit relevant witness names and evidence, and to review the evidence gathered by the investigator prior to the investigator providing the final report to the Decisionmaker(s).

Acceptance of Responsibility
If a respondent accepts responsibility for all or part of the Prohibited Conduct alleged, the Coordinator or designated sanctioning officer will issue an appropriate sanction or responsive action as to those violation(s) and continue processing any remaining allegations of Prohibited Conduct, if any.

Assignment of the Investigator
The University will assign a trained investigator to conduct an adequate, reliable, and impartial investigation and determination, as applicable, in a reasonably prompt timeframe. The investigator will establish deadlines for submission of names of relevant witnesses and submission of evidence and communicate those deadlines to the parties in writing.

Timeline
The University strives to complete the investigation process within ninety (90) business days from the date of the Notice of Investigation.

The timeline for any part of the resolution process may be extended for good cause by the Title IX Coordinator. All parties will be notified, in writing, of any extension to the timeline that is granted, the reason for the extension, and the new anticipated date of conclusion of the investigation and/or hearing. Good cause reasons for extension may include ensuring availability of witnesses and other participants and ensuring participants have sufficient time to review materials.

The University will not unreasonably deny a student party’s request for an extension of a deadline related to a complaint during periods of examinations or school closures.

The investigator and/or Title IX Coordinator will provide the Parties with periodic status updates, in writing.

Burden and Standard of Review
The University has the burden of conducting an investigation that gathers sufficient evidence to determine whether Prohibited Conduct occurred. This burden does not rest with any party, and any party may decide to limit their participation in part or all of the process, or to decline to participate. This does not shift the burden of proof away from the University and does not indicate responsibility. The standard of proof used in the investigation and decision-making process is the preponderance of the evidence standard, which means more likely than not.

Notice of Investigation
Prior to the start of an investigation, the Parties will be provided a written Notice of Investigation communicating the initiation of an investigation. Should additional allegations be brought forward, or information regarding location or date of the incident(s), a revised written Notice of Investigation will be provided to all parties.

The Notice will include, at a minimum:

1. The University's investigation procedures, including the applicable determination procedure that will be used in this investigation and resolution, and a link to the relevant policies; 
2. Information about the agreement-based resolution process, with a link to the full procedures. 
3. Sufficient information available at the time to allow the parties to respond to the allegations, including the identities of the parties involved in the incident(s), a description of the facts alleged to constitute Prohibited Conduct, the type of Prohibited Conduct, and the date(s), time(s), and location(s) of the alleged incident(s); 
4, A list of possible sanctions. 
5. A statement that retaliation is prohibited; 
6. Expected length of the major stages of the resolution process, as well as any applicable deadlines. 
7. The Notice will inform the parties that the investigator will establish and communicate, in writing, all investigation deadlines, including the final deadlines for submitting names of witnesses, evidence, and relevant questions to ask a party or witness. These deadlines may be extended by the Title IX Coordinator for good cause, and any changes will be provided, in writing, to the parties, along with the rationale for the revised deadline(s). 
8. The name of the investigator, and the process for raising a challenge to the appointed investigator, Decisionmaker(s) or Title IX Coordinator, and the deadline for doing so. 
9. A statement that the respondent is presumed not responsible for Prohibited Conduct until a determination is made at the conclusion of the resolution process. Prior to such a determination, the parties will have an opportunity to present relevant and not otherwise impermissible evidence to a trained, impartial investigator and Decisionmaker(s); 
10. A statement that the parties may have an advisor of their choice who may be a friend, parent, therapist, colleague, or attorney; 
11. The parties are entitled to an equal opportunity to access an investigation report that accurately summarizes this evidence. The parties are entitled to an equal opportunity to access the relevant and not impermissible evidence upon the request of any party; and 
12. The University prohibits knowingly making false statements or knowingly submitting false information during the resolution procedures. 
13. The Decisionmaker(s) will be identified, if known. If the University assigns a different Decisionmaker(s), an updated notice will be provided to the parties. 
14. The date and time of the initial interview with the Investigator, with a minimum of five (5) days’ notice.

Conflict of Interest or Bias
After a Notice of Investigation is issued to all parties, any party may object to the participation of the Title IX Coordinator or designated investigator on the grounds of a demonstrated bias or actual conflict of interest. All parties will have three (3) days from the date of the Notice of Investigation to object to the selection of the investigator or the Title IX Coordinator. Objections to the Title IX Coordinator are to be made, in writing, to the Vice President for Human Resources. Objections to the appointment of the investigator are to be made in writing, to the Title IX Coordinator. All objections will be considered, and changes made as appropriate. If the objection is substantiated as to either the Title IX Coordinator or the Investigator, that individual will be replaced. Any change will be communicated in writing.

Written Notice of Meetings
The University will provide to a party or witness whose participation is invited or expected, written notice of the date, time, location, participants, and purpose of all meetings or proceedings with sufficient time to prepare to participate.

Evidence Gathering

Interviews 
The investigator will hold individual interviews with parties and witnesses to ask relevant and not otherwise impermissible questions and follow-up questions related to the allegations in the complaint, including questions exploring credibility. The investigator will gather relevant evidence from interviewees and request from interviewees the names of relevant witnesses. Evidence will include inculpatory evidence (that tends to show it more likely that someone committed a violation) and exculpatory evidence (that tends to show it less likely that someone committed a violation). The investigator ultimately determines whom to interview to determine the facts relevant to the complaint.

Interviews may be conducted in person, or via video conference. Only the investigator and the party or witness may attend each individual interview, and a party may be accompanied by their advisor. All interviews will be recorded, and either an audio or audiovisual record, or transcript of these meetings will be provided to the parties during evidence review. Additional attendees may be permitted at the discretion of the Title IX Coordinator in connection with an approved disability-related accommodation. All persons present at any time during any part of the investigation or resolution process are expected to maintain the privacy of the proceedings and not discuss or otherwise share any information learned as part of the resolution process. 

At the initial interview with each party, the investigator will invite the parties to provide, in writing and in advance of the individual interviews, questions to ask of the parties and witnesses that are relevant and not otherwise permissible, including questions exploring credibility. Upon receiving the question list, the investigator will determine whether a proposed question is relevant and not otherwise impermissible and will explain, in writing in advance of the individual interview, any decision to exclude a question as not relevant or otherwise impermissible. Questions that are unclear or harassing of the party or witness being questioned will not be permitted.  The investigator must give a party an opportunity to clarify or revise any question that the investigator has determined is unclear or harassing and, if the party sufficiently clarifies or revises a question, the question will be asked.

Impermissible Evidence
The following types of evidence, and questions seeking that evidence, are impermissible. This means this information will not be accessed or considered, except by the University to determine whether one of the exceptions listed below applies. This information will not be disclosed or otherwise used, regardless of relevance:  

  • Evidence that is protected under a privilege recognized by Federal or State law, unless the person to whom the privilege or confidentiality is owed has voluntarily waived the privilege or confidentiality;
  • Evidence provided to an employee designated by the University as exempt from internal reporting under this policy, unless the person who made the disclosure or otherwise provided evidence to that employee has voluntarily consented to re-disclosure;
  • A party’s or witness’s records that are made or maintained by a physician, psychologist, or other recognized professional or paraprofessional in connection with the provision of treatment to the party or witness, unless the University obtains that party’s or witness’s voluntary, written consent for use in its resolution procedures; and
  • Evidence that relates to the complainant’s sexual interests or prior sexual conduct, unless evidence about the complainant’s prior sexual conduct is offered to prove that someone other than the respondent committed the alleged conduct or is evidence about specific incidents of the complainant’s prior sexual conduct with the respondent that is offered to prove consent to alleged sex-based harassment. The fact of prior consensual sexual conduct between the parties does not by itself demonstrate or imply the complainant’s consent to other sexual activity or preclude a determination that Prohibited Conduct occurred.
  • In matters  of sexual assault, domestic violence, dating violence, and stalking, all parties have the right to exclude their own prior sexual history with persons other than the other party in the investigation and decision-making process or their own mental health diagnosis and/or treatment from admittance in the institution disciplinary stage that determines responsibility. The limit does not exclude evidence of prior sexual history with the other party in the investigation that is relevant to an allegation or defense of an allegation.

Investigator Determination of Relevance 
The investigator will determine whether parties and witnesses are likely to provide relevant information about the allegations and has the sole discretion to determine which parties and witnesses to call to individual follow-up meetings. 

The investigator will review all evidence gathered through the investigation and determine what evidence is relevant and what evidence is impermissible regardless of relevance. Character evidence that is not relevant will not be considered. The Decisionmaker(s) is not bound by the investigator’s determinations about relevance.

Evidence Review 
At the conclusion of all fact-gathering, the investigator will provide each party and their advisor the opportunity to review all relevant and not otherwise impermissible evidence gathered.

The purpose of the inspection and review process is to allow each party the equal opportunity to meaningfully respond to the evidence prior to conclusion of the investigation and to submit any additional relevant evidence, questions for parties or witnesses, or the names of any additional witnesses with relevant information. This is the final opportunity to offer evidence or names of witnesses. Evidence not provided during the investigation process will not be considered by the Decisionmaker(s). Given the sensitive nature of the information provided, the University will facilitate this review in a secure manner. None of the parties nor their advisors may copy, remove, photograph, print, image, videotape, record, or in any manner otherwise duplicate or remove the information provided. Any student or employee who fails to abide by this may be subject to discipline. Any advisor who fails to abide by this may be subject to discipline and/or may be excluded from further participation in the process.

The parties will have a minimum of five (5) business days to inspect and review the evidence and submit a written response in writing to the investigator. The Title IX Coordinator has the discretion to extend the evidence review period based on the volume and nature of the evidence.  
When deemed appropriate by the investigator, the investigator will then conduct any additional fact-gathering as may be necessary. If new, relevant evidence was submitted as part of evidence review, or is gathered during this second fact-gathering period, the new relevant evidence will be made available for review by the parties and their advisors. The parties will have five (5) days to provide a response to the newly-gathered evidence. No new evidence will be accepted as part of any response, except that the investigator has the discretion to accept relevant evidence that was not previously available or known to exist, and that was not previously discoverable with the exercise of reasonable diligence.

The investigator will consider the parties’ written responses and will draft and/or finalize an investigation report. The investigation report will be objective and thorough and will summarize the investigation and all relevant evidence.  

Impact Statement 
The parties may each submit a written impact statement prior to the conclusion of the resolution process. The impact statement is not evidence, and will be reviewed during the sanctioning phase only after a determination of responsibility is reached.

Decisionmaking 

The Title IX Coordinator will designate a Decisionmaker(s). The Decisionmaker(s) will evaluate the relevant and not impermissible evidence and make a factual determination regarding each allegation. 

The Decisionmaker(s) may choose to place less or no weight upon statements by a party or witness who refused to respond to questions deemed relevant and not otherwise impermissible, or who was not available, despite reasonable diligence, for a follow-up interview. The Decisionmaker(s) will not draw an inference about whether Prohibited Conduct occurred based solely on a party’s or witness’s refusal to respond to the investigator’s questions.

The Decisionmaker(s) will then conduct pre-decision conferences with the primary parties and their advisor of choice. All pre-decision conference meetings will be recorded and parties will be provided with a transcript of the meetings.

The Decisionmaker(s) will then determine, based upon the factual findings, whether a violation of University policy occurred.  The Decisionmaker(s) will prepare a report that includes:

  • A description of the sex-based harassment;
  • A reference to the policies and procedures used to evaluate the allegations;
  • Description of all procedural steps taken to date;
  • The Decisionmaker(s)’s evaluation of the relevant evidence along with the finding of facts;
  • Determinations for each allegation, with the rationale;
  • Sanction determination (if applicable);
  • Whether remedies will be provided;
  • The procedures for an appeal.

This report will be provided to the Title IX Coordinator.  In the event that the Decisionmaker(s) has determined that a violation of University policy has occurred, the Title IX Coordinator will then provide the report to the appropriate Sanctioning Officer to determine the sanction, and the Title IX Coordinator will then determine the appropriate remedy(ies) for the Complainant and any impacted parties. Past  findings of responsibility relating to this policy or any other policy are admissible in the sanctioning stage only.

  • Sanctioning Officer or Designee for Student Respondents: Associate Dean of Students
  • Sanctioning Officer or Designee for Staff Respondents:  Human Resources
  • Sanctioning Officer or Designee for Faculty:  Human Resources 

The Title IX Coordinator will then provide the parties and their advisors, if any, with a written Notice of Outcome and a copy of the Decisionmaker(s)’s report.  The Notice of Outcome will include any disciplinary sanctions for the respondent, whether remedies will be provided, and the procedures for appeal.  In addition, the complainant will be informed of any remedies that apply to the complainant.

The Title IX Coordinator will provide each party, and their advisor, written communication regarding the decision, the sanction determination, and the procedures for appeal, along with a copy of the Investigation Report. The Title IX Coordinator will also provide written communication to the Complainant regarding any appropriate remedies.

APPEALS
Dismissals of complaints and determinations made in the investigation and decision-making processes may be appealed in writing by either party. Appeals will be sent to the Title IX Coordinator, who will then send the appeal to the Appeals Panel assigned to conduct a written review of the appeal(s) and to make a final determination. Appeals must be in writing and filed within ten (10) days following the issuance of the outcome letter.

When an appeal is filed, the other party will be notified and provided with a copy of the filed appeal within one (1) day, and have five (5) days to respond to the appeal in writing. Any party’s decision not to submit a reply to an appeal is not evidence that the non-appealing party agreed with the appeal.

Within three (3) days of an Appeals Panel being assigned, either party may provide written objection to the Appeals Panel on the basis of an actual bias or conflict of interest of a panelist. Any objection is to be sent to the Title IX Coordinator. Should the Title IX Coordinator determine that there is an actual bias or conflict of interest, the Title IX Coordinator will appoint a different panelist(s).

Appeals may be filed only on the following three grounds:

  • Procedural Error:A procedural error occurred would change the outcome. A description of the error and its impact on the outcome of the case must be included in the written appeal; or,
  • New Evidence:New evidence or information has arisen that was not available or known to the party during the investigation or hearing, that would change the outcome. Information that was known to the party during the resolution process but which they chose not to present is not considered new information. The new evidence, an explanation as to why the evidence was not previously available or known, and an explanation of its potential impact on the investigation findings must be included in the written appeal; or
  • Actual Conflict of Interest or Demonstrated Bias: The Title IX Coordinator, investigator, or others with a role in the process with an actual conflict of interest or demonstrated bias for or against complainants or respondents generally, or the individual complainant or respondent, that would change the outcome. Any evidence supporting the alleged conflict of interest or demonstrated bias must be included in the written appeal.

The Appeals Panel will make a determination regarding the appeal and communicate that decision, along with a rationale for the decision to the Title IX Coordinator who will communicate the Appeals Panel’s decision to the parties. The decision of the Panel is final.

Failure to Complete Sanctions/Comply with Responsive Actions
 All responding parties are expected to comply with conduct sanctions/responsive actions/ corrective actions within the timeframe specified by the University. Responding parties needing an extension to comply with their sanctions must submit a written request to the Title IX Coordinator stating the reasons for needing additional time. 

Failure to follow through on conduct sanctions/responsive actions/corrective actions by the date specified, whether by refusal, neglect or any other reason, may result in additional sanctions/responsive actions/corrective actions, such as suspension, expulsion, termination, or a transcript notation. Students who fail to comply will be referred to the Dean of Students office in accordance with the University's Code of Conduct.

Transcript Notations  
The University has a policy of making a notation on a transcript related to outcomes for crimes of violence as defined by the Clery Act. Upon conclusion of any appeal process, a transcript notation will be indicated on the respondent’s record for cases resulting in suspension, expulsion or in cases where the respondent withdraws from the University during the investigation and decision-making process. Notations on transcripts will be indicated as follows:

  • “suspended after a finding of responsibility for a code of conduct violation”
  • “expelled after a finding of responsibility for a code of conduct violation” or
  • “withdrew with conduct charges pending.”

Transcript notations for a student who is suspended or who chooses to withdraw with a pending investigation will remain on a transcript for a minimum of one year. After one year's time, a student may request to have the transcript notation removed by filing an appeal with the Vice President for Enrollment and Student Affairs. 

Transcript notations for students expelled are permanent and cannot be removed. 
If a finding of responsibility is vacated for any reason, any such transcript notation will be removed.

Sanctions
Sanctions are disciplinary steps listed that may be imposed on a respondent who is found responsible for a violation of the University's policies. Sanctions or disciplinary steps not listed here may be imposed in consultation with the Title IX Coordinator.

The form of sanction or discipline used will depend on the nature of the violation, as well as any prior disciplinary history. Such discipline or sanction will be imposed pursuant to and in accordance with any and all applicable University rules, policies, and procedures. Factors considered when determining a sanction/responsive action may include:

  • The nature, severity of, and circumstances surrounding the violation.
  • An individual's disciplinary history.
  • Previous resolutions or allegations involving similar conduct.
  • The need for sanctions/responsive actions to bring an end to the sex discrimination or retaliation.
  • The need for sanctions/responsive actions to prevent the future recurrence of sex discrimination or retaliation.
  • The need to remedy the effects of the sex discrimination or retaliation on the victim and the campus community.

Student sanctions imposed are implemented when the decision is final (after an appeal, or, if there was no appeal, after the appeals period expires).

Faculty found responsible for violating this policy may be referred to the appropriate academic official for any other applicable processes.

Possible sanctions and disciplinary steps for student respondents include, but are not limited to the following:

  • Reprimand or warning
  • Changing the Respondent’s academic schedule
  • Disciplinary probation
  • Postponement of degree conferral
  • Revocation of honors or awards
  • Restricting the Respondent’s access to College facilities or activities
  • Community service
  • Issuing a No Contact Order to the Respondent or requiring that such an order remain in place
  • Dismissal from or restricting or reassignment of College employment
  • Suspension (limited time or indefinite)
  • Expulsion

Possible sanctions and disciplinary steps for staff and faculty respondents include a range from warning or reprimand to termination.

E. RECORD RETENTION

In implementing this policy, records of all reports and resolutions will be kept by the Coordinator in accordance with the applicable University records retention schedule. All records will be afforded the confidentiality protections required by law, including but not limited to the Family Educational Rights and Privacy Act governing confidentiality of student information.  

F. ADDITIONAL ENFORCEMENT INFORMATION
The U.S. Equal Employment Opportunity Commission (EEOC) investigates reports of unlawful harassment and discrimination, including sex-based harassment, in employment.

The U.S. Department of Education, Office for Civil Rights (OCR) investigates complaints of unlawful discrimination and harassment of students and employees in education programs or activities.

For more information, contact the nearest office of the EEOC or OCR.

US Department of Education
Office for Civil Rights
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, D.C. 20201
(800) 368-1019

U.S. Equal Employment Opportunity Commission (EEOC)
https://www.eeoc.gov/contact-eeoc

NYS Division of Human Rights (DHR): 1 Fordham Plaza, 4th Floor, 
Bronx, NY 10458
(718) 741-8400.

G. POLICY REVIEW & REVISION
These policies and procedures will be reviewed and updated regularly by the Title IX Coordinator. The Title IX Coordinator will submit modifications to this policy in a manner consistent with institutional policy upon determining that changes to law, regulation or best practices require policy or procedural alterations not reflected in this policy and procedure. Procedures in effect at the time of its implementation will apply. The policy definitions in effect at the time of the conduct will apply even if the policy is changed subsequently, unless the parties consent to be bound by the current policy. 

This policy may be revised at any time without notice. All revisions supersede prior policy and are effective immediately upon posting to the University website.