Table of Contents [hide]
- ST. OLAF COLLEGE POLICY PROHIBITING UNLAWFUL DISCRIMINATION,HARASSMENT & RETALIATION
- I. OVERVIEW, SCOPE OF POLICY AND POLICY STATEMENT OF SEXUAL HARASSMENT
- II. KEY INTERNAL AND EXTERNAL RESOURCES
- III. DEFINITIONS
- V. REPORTING ALLEGED SEXUAL HARASSMENT
- Overview
- VI. INITIAL STEPS AFTER A SEXUAL HARASSMENT REPORT IS RECEIVED BY THE COLLEGE
- VII. SUMMARY OF THE COMPLAINT RESOLUTION PROCESSES
- VIII. INFORMAL RESOLUTION PROCESS
- IX. COMPLAINT RESOLUTION PROCESS
- X. RECORDKEEPING
- XI. POLICY REVIEW
ST. OLAF COLLEGE POLICY PROHIBITING UNLAWFUL DISCRIMINATION,
HARASSMENT & RETALIATION
DOWNLOAD PDF VERSION OF POLICY
(updated January 21, 2025)
I. OVERVIEW, SCOPE OF POLICY AND POLICY STATEMENT OF SEXUAL HARASSMENT
A. Commitments
The mission of St. Olaf College is to challenge Students to excel in the liberal arts, examine faith and values, and explore meaningful vocation in an inclusive, globally engaged community nourished by Lutheran tradition. To advance this mission and its core values of educational excellence, spiritual well- being, community, and wholeness, St. Olaf is committed to providing a respectful, welcoming, safe, and healthy environment for all Students, staff, faculty, and guests. To that end, the College prohibits all forms of Sexual Harassment, sexual assault, domestic violence, sexual exploitation, dating violence, and stalking. These behaviors not only harm individuals, they also damage the St. Olaf community as a whole. In addition, some forms of these behaviors are crimes.
The College is committed to administering its policies and procedures in a manner that is fair and impartial and that treats all persons with dignity and respect. When the College determines that a violation of this Policy has occurred, the College will take prompt and appropriate measures aimed at stopping the Sexual Harassment, preventing its recurrence and remedying its effects.
B. Scope of Policy
The College will apply this Policy to address all concerns relating to unwelcome conduct of a sexual nature when alleged to have been committed by or directed toward a current or prospective student or employee, or any other individual participating or seeking to participate in a St. Olaf program or activity. It is the intent of St. Olaf College that this policy will apply to the following:
- Allegations of Sexual Harassment within the scope of Title IX pursuant to 34 C.F.R. Section 106;
- Allegations of sexual assault, dating violence, domestic violence and stalking involving members or prospective members of the St. Olaf community that may otherwise fall outside the scope of Title IX because the alleged incident(s) occurred outside of the United States, or occurred outside of a St. Olaf program or activity; and
- Any other allegations of unwelcome conduct of a sexual nature (NOTE: The College may not apply every aspect of the Complaint Resolution Process to allegations that do not fall within #1 and #2 above)
St. Olaf College is committed to addressing Sexual Harassment, and the College strongly encourages any individual who knows of or has been subject to Sexual Harassment to report the incident to appropriate College authorities in accordance with the College’s reporting procedures, even if the individual is not otherwise obligated to report, and even if the individual is uncertain whether an incident involves Sexual Harassment that falls within the scope of this policy.
C. Policy Statement on Sexual Harassment
The College expressly prohibits all forms of Sexual Harassment including sexual assault, sexual violence, sexual exploitation, dating violence, domestic violence, and stalking. Retaliation against a person who in good faith reports suspected Sexual Harassment or against an individual who assists in an Investigation into a report of Sexual Harassment is also strictly prohibited. Reports of retaliation are investigated under the College’s Policy Prohibiting Unlawful Discrimination, Harassment & Retaliation.
Questions or concerns regarding Sexual Harassment may be referred to St. Olaf’s Director of Equal Opportunity. St. Olaf’s Director of Equal Opportunity is Pamela McDowell, Tomson Hall 130B, mcdowell@stolaf.edu, 507-786- 3465. The Director of Equal Opportunity serves as the College’s Title IX Coordinator to oversee the College’s compliance with Title IX.
1. How does this Policy Differ from the College’s Consensual Relations Policy?
The College prohibits all unwelcome conduct of a sexual nature. In addition, the College deems sexual and romantic relationships between persons of unequal status as inherently problematic, even when they are or appear to be entirely consensual. To address these concerns, St. Olaf has a separate Consensual Relations Policy which:
- strongly discourages romantic or sexual relationships between staff and faculty members where there is a disparity in power or reporting relationships; and
- Prohibits any and all romantic or sexual relationships between a faculty or staff member and any student enrolled at the College.
If a report is brought to the College’s attention indicating that a prohibited relationship exists, the College will review such allegations under its Consensual Relations Policy. If the report also includes allegations of Sexual Harassment, the matter will also be reviewed under this Policy. Even in instances where a relationship appears to be completely consensual and does not involve allegations of Sexual Harassment, a violation of the Consensual Relations Policy is a serious breach of community standards and of College policy and will result in disciplinary action up to and including termination of employment.
2. Why are there separate policies for Sexual Harassment and other forms of discrimination?
There are unique obligations that the College must follow when responding to reports of Sexual Harassment. Because the College’s obligations are different with respect to Sexual Harassment, the College has a separate Policy Prohibiting Sexual Harassment. Questions relating to the College’s response to other forms of discrimination and harassment, including gender discrimination, are addressed in the Policy Prohibiting Unlawful Discrimination, Harassment & Retaliation. All forms of Sexual Harassment are addressed in this policy.
II. KEY INTERNAL AND EXTERNAL RESOURCES
A. St. Olaf Responsible Administrative Staff
1. Director of Equal Opportunity /Title IX and Section 504 Coordinator.
The Director of Equal Opportunity serves as the Title IX Coordinator and is responsible for coordinating all aspects of the College’s gender equity compliance efforts, including the College’s efforts to prevent Sexual Harassment. The Director of Equal Opportunity is knowledgeable and trained in St. Olaf’s policies and procedures, as well as the College’s legal obligations under state and federal laws including Title IX, the Violence Against Women Act, the Minnesota Human Rights Act, and the Minnesota Campus Sexual Harassment and Violence law.
The Director of Equal Opportunity’s responsibilities include:
- Ensuring the College’s compliance with all administrative requirements of Title IX, and other applicable state and federal laws including Title VI, Title VII, the Americans with Disabilities Act, the Rehabilitation Act, and the Minnesota Human Rights Act;
- Advising individuals about St. Olaf’s Policy and Reporting options;
- Providing assistance to Employees of the College about how to respond to Reports Sexual Harassment;
- Coordinating the College’s response to all Complaints alleging sex discrimination and/harassment;
- Explaining options, resources, and referrals to Reporting Parties regardless of whether their reports move to the Complaint Resolution Process;
- Coordinating the provision of support services and/or supportive measures;
- Communicating with the Reporting Party and Respondent about available supportive measures, both on and off campus;
- Identifying and removing barriers to Reporting Sexual Harassment; and
- Overseeing training, prevention and education efforts, and periodic reviews of the campus climate and culture.
The Director of Equal Opportunity leads the Equal Opportunity COordinated REsponse (“CORE”) Team and the Equal Opportunity Team as described below.
2. CORE Team.
The CORE Team is responsible for assessing all reports of Sexual Harassment and determining what actions the College will take in response to each report. The CORE team seeks to ensure the College’s response is prompt, fair, impartial and consistent with this Policy. The CORE Team seeks to ensure an equitable process for the individuals participating in a Complaint Resolution Process while also safeguarding the well-being of the College community. The CORE Team includes the following individuals:
St. Olaf College CORE Team | |||
Director of Equal Opportunity/Title IX and Section 504 Coordinator | Pamela McDowell | Tomson Hall 130 | 507-786-3465 |
Vice President for Community and Belonging | Eduardo Pazos | Tomson Hall 258 | 507-786-3334 |
Deputy Athletic Director | Kelly Mahlum | Skoglund 114G | 507-786-3258 |
Director of Public Safety | Derek Kruse | Tomson Hall 10D | 507-786-3258 |
Associate Dean of Students for Residence Life | Christopher Medley | Tomson Hall 148 | 507-786-3615 |
Director of Faculty Inclusion and Belonging | Susan Smalling | Holland Hall 601 | 507-786-3350 |
The responsibilities of the CORE Team include:
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- Conducting an initial assessment of Reports to determine whether alleged conduct falls within the scope of this Policy;
- Assessing whether a Formal Complaint should be dismissed and/or referred to a different College process;
- Evaluating whether and how the College will proceed under this Policy in a manner that provides a prompt, thorough, fair and equitable process for the individuals involved;
- Overseeing intake and Supportive Measures for individuals who Sexual Harassment;
- Confirming that Supportive Measures have been offered to all Parties involved in a response to each report of Sexual Harassment;
- Evaluating Supportive Measures for their effectiveness in restoring Party’s equal access to the ability to participate in or benefit from the College’s educational programs and activities;
- If a Reporting Party requests that the College not investigate and adjudicate a matter, the CORE Team will honor that request. Only under exceptionally rare circumstances would the CORE Team determine that further action is legally required;
- Overseeing the comprehensive, accurate, and equitable provision of relevant information on College policies, practices, supportive measures, and resources to Reporting and Responding Parties;
- Coordinating the work of the Dean of Students Office and the Office of Public Safety in responding to each report of Sexual Harassment;
- Determining whether notification to the St. Olaf community is necessary when a report of sexual assault, stalking, dating violence, or domestic violence has been received to comply with Clery Act or other legal obligations;
- Reviewing and recommending improvements to Title IX policies and protocols in light of the experiences of Reporting and Responding Parties; and
- Coordinating and overseeing data collection and Reporting in compliance with relevant federal and state statutes.
3. Equal Opportunity Team.
St. Olaf College Equal Opportunity Team | |||
Director of Equal Opportunity/ Title IX and Section 504 Coordinator |
Pamela McDowell | Tomson Hall 130 | 507-786-3465 |
Director of Public Safety | Derek Kruse | Tomson Hall 10D | 507-786-3636 |
Deputy Athletic Director | Kelly Mahlum | Skoglund Athletic Center 114G | 507-786-3258 |
Dean of Students | Rosalyn Eaton | Tomson Hall 148 | 507-786-3615 |
Associate Dean of Students | Justin Fleming | Tomson Hall 148 | 507-786-3615 |
Vice President for Community and Belonging | Eduardo Pazos | Tomson 258 | 507-786-3334 |
Associate Dean of Students | Chang Dao Vang | Tomson Hall 148 | 507-786-3615 |
Interim Director of the Smith Center for Global Engagement | Theresa Heath | Tomson Hall 380 | 507-786-3228 |
Associate Dean of Students | Christopher Medley | Tomson Hall 148 | 507-786-3615 |
Assistant Vice President for Human Resources | Tomson Hall 180 | 507-768-3068 | |
Vice President for Student Life | Hassel Morrison | Tomson Hall 148 | 507-786-3503 |
Director of the Taylor Center for Equity and Inclusion | Martin Olague | Buntrock Commons 111 | 507-786-3060 |
Associate Dean of Students | Tim Schroer | Tomson Hall 148 | 507-786-3615 |
Director of Faculty Inclusion and Belonging | Susan Smalling | Holland Hall 601 | 507-786-3350 |
Associate Director of Disability and Access | Laura Knobel-Piehl | Tomson Hall 151 | 507-786-3966 |
The responsibilities of the Equal Opportunity Team include:
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- Overseeing the content and implementation of this Policy;
- Overseeing and assisting with education and prevention efforts aimed at eliminating all forms of gender discrimination, including Sexual Harassment;
- Receiving Reports of Sexual Harassment and forwarding them to the Director of Equal Opportunity for intake and supportive measures;
- Overseeing efforts to educate the St. Olaf community concerning this Title IX policies and procedures;
- Overseeing efforts to assess the campus climate and ensure appropriate response to any findings;
- Ensuring College programs and activities are equitable for participants of all genders;
- Collaborating with the CORE Team;
- Overseeing the use of College resources in carrying out this Policy and achieving its purposes.
B. Governmental Authorities
The governmental authorities responsible for enforcing applicable federal and state laws relating to this Policy, are the following:
U.S. Department of Education / Office for Civil Rights
Citigroup Center
500 W. Madison Street, Suite 1475
Chicago, IL 60661-4544
312-730-1560 (phone)
877-521-2172 (TDD)
Email: OCR.Chicago@ed.gov
Minnesota Department of Human Rights
Freeman Building
625 Robert Street
North Saint Paul, MN 55155
800-657-3704 (phone)
877-521-2172 (TDD)
800-627-3529 (fax)
800-627-3529 (TDD)
http://mn.gov/mdhr/ Info.MDHR@state.mn.us
III. DEFINITIONS
A. General Policy Definitions
- Confidential Resources are individuals who can receive confidential communications, defined as communications which cannot be disclosed to another person without the authorization of the individual who provided the information, unless legally authorized or required, such as when the communications involve allegations of the physical or sexual abuse of a child or vulnerable adult, or an imminent threat of serious injury to any person. Among the College’s Employees, only those individuals designated by the College as Confidential Resources may receive such confidential communications without being required to Report the information they receive to the Director of Equal Opportunity or a member of the Equal Opportunity Team.
- Policy means the St. Olaf Policy Prohibiting Sexual Harassment.
- Report means information forwarded to the Director of Equal Opportunity or a member of the Equal Opportunity Team alleging Sexual Harassment. In most cases a Report does not initiate any action by the College beyond providing the individual alleged to have experienced Sexual Harassment with information about Supportive Measures and other resources and options for response if the individual so chooses. A Report is distinguished from a Formal Complaint which initiates the College’s Complaint Resolution Process.
- Retaliation under this policy means intimidation, threats, coercion, or discrimination against any individual because the individual has made a report, testified, assisted, or participated or refused to participate in any manner in an Investigation, proceeding, or Hearing under this Policy, for the purpose of interfering with any right or privilege secured by Title IX or this Policy.Retaliatory acts may include, but are not limited to: adverse changes in employment status or opportunities; adverse academic action; adverse changes to academic, educational and extra-curricular opportunities; harassment or intimidation; acts or comments intended to embarrass the individual; or seeking out or attempting to discover the Parties and witnesses involved in a report for the purpose of influencing their participation or statements, or taking adverse action against them.
- Required Referrals are Employees who are not Confidential Resources and who are expected to immediately share all known details about any incident of Sexual Harassment with the Director of Equal Opportunity or other member of the Equal Opportunity Team. Students who are employed with the College are also Required Referrals if they learn about an incident of Sexual Harassment as a result of their employment position.
- Student means any individual who has accepted an offer of admission, or who is registered or enrolled for credit or non-credit bearing coursework, and who maintains an ongoing educational relationship with St. Olaf College.
- Supportive Measures are non-disciplinary, non-punitive individualized services offered as appropriate, as reasonably available, and without fee or charge to the Reporting Party before or after the filing of a Formal Complaint and to a Respondent if and when notified of a Formal Complaint. Such measures are designed to provide support to each Party and to restore or preserve equal access to the College’s education program or activity. Supportive Measures may include measures designed to protect the safety of each Party and the College’s educational environment. Supportive Measures may not unreasonably burden a Reporting Party or Respondent.
B. Sexual Harassment Definitions
- Coercion or Force means conduct, intimidation, and expressed or implied threats of physical or emotional harm that would reasonably place an individual in fear of immediate or future harm and that are used in order to persuade or compel someone to engage in sexual contact. Any sexual contact occurring in response to coercion or force will be presumed non-consensual, even if the particular sexual contact that occurs is different from the form of sexual contact in which the individual was attempting to engage, and even if the other individual uses words or actions that would otherwise appear to convey consent.Examples of coercion or force include causing the deliberate incapacitation of another person; conditioning an academic benefit or employment advantage on submission to the sexual contact; threatening to harm oneself if the other Party does not engage in sexual contact; or threatening to disclose an individual’s sexual orientation, gender identity, gender expression, or other personally sensitive information if the other Party does not engage in the sexual contact.
- Consent means words or overt actions by a person clearly and affirmatively communicating a freely- given, present agreement to engage in a particular form of sexual contact. Words or overt actions clearly communicate Consent when a reasonable person in the circumstances would believe those words or actions indicate an interest and willingness to participate in the mutually agreed-upon sexual contact. Although Consent does not need to be verbal, verbal communication is the most reliable form of asking for and obtaining Consent.All Parties to a particular form of sexual contact must provide Consent, and such Consent must be present throughout the activity. It is the responsibility of the individual who is initiating each sexual contact to obtain Consent before proceeding to engage in the sexual contact.Even when Consent is given, it may be retracted at any time. When Consent is withdrawn, the sexual contact for which Consent was initially provided must stop immediately. Any words or overt actions can communicate withdrawal of Consent. As is the case with communicating the existence of Consent, verbal communication is usually the clearest way of communicating withdrawal of Consent.A person can only provide Consent when that person:
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- Acts freely and voluntarily, without coercion or force or otherwise feeling unduly pressured, threatened, or intimidated;
- Is informed about the nature of the sexual contact involved;
- Is not incapacitated, whether from alcohol, other drugs, or other causes, such that they cannot understand the fact, nature, or extent of the sexual contact;
- Is conscious;
- Is of legal age to Consent (16 years old in Minnesota with some exceptions for younger individuals who are close in age).These requirements for Consent mean that sexual contact with someone who is threatened, coerced, intimidated, uninformed, incapacitated, asleep or otherwise unconscious, or not of legal age, is, by definition, nonconsensual sexual contact.In addition, Consent to a particular sexual contact cannot be inferred from:
-
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- Consent to a different form of sexual contact;
- an existing or prior dating, sexual, romantic or marital relationship;
- silence that is not otherwise accompanied by overt actions indicating Consent;
- an absence of physical resistance or verbal protest; or
- prior sexual activity with other individuals.
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Examples of Verbal and Non-verbal Conduct that May or May Not Provide Consent Whether a sexual interaction is consensual will depend upon the circumstances. As such, it is difficult to provide definitive guidance on whether certain communications demonstrate Consent. The following are a range of communications that individuals might identify as a sign of Consent. Those in the column shaded green (left) are indicative of unambiguous affirmative Consent. Those in the column shaded yellow (middle) are less clear, and may or may not be a sufficient indication of Consent depending upon other circumstances. Those in the column shaded red (right) are, when viewed alone, highly unlikely to be deemed an expression of Consent. |
|||
“Yes!” “I would like…” “I want you to…” |
Nodding yes after being asked for Consent Giving a thumbs up in response to a request Smiling in response to a request |
“No” “I don’t know…” “Can you use a condom?” Silence or a lack of resistance |
|
Although consent does not need to be verbal, verbal communication is the most reliable form of asking for and obtaining consent
There are common signs that should alert a reasonable sober person as to whether an individual might be incapacitated. Typical signs may include incomprehensible speech, clumsiness, difficulty walking, combativeness, emotional volatility, vomiting, or incontinence. A person who is incapacitated may not be able to understand some or all of the following questions: “Do you know where you are?” “Do you know how you got here?” “Do you know what is happening?” “Do you know who I am?” If there is any doubt as to the level or extent of one’s own or the other individual’s intoxication or incapacitation, the safest course of action is to forgo or cease any sexual contact.
C. Complaint Resolution Process Definitions
V. REPORTING ALLEGED SEXUAL HARASSMENT
This section addresses Reports of known or suspected incidents of Sexual Harassment, and the ways in which such Reports may be made. While Required Referrals are the only individuals required to make Reports, everyone is encouraged to Report any incident of Sexual Harassment so that those who experience such conduct can understand their options and access Supportive Measures. There are no time limitations on when a Report to the College may be made; but delaying a Report may impact the College’s ability to access evidence, investigate the claims, and/or adequately respond.
Notwithstanding the foregoing, Employees who themselves experience Sexual Harassment are not required to Report their own experience as a Required Referral. While these employees are not required to Report such incidents, they are encouraged to Report their experience so that the College can assist them in accessing Supportive Measures and understanding their rights.
While Employees are obligated to Report any information they may have regarding Sexual Harassment, they should respect the confidentiality of the individuals involved by not further disclosing information to other individuals without the Reporting Party’s authorization.
Counseling Center
Even if Reporting Parties are not interested in or uncertain about initiating the Complaint Resolution Process, they are strongly encouraged to Report to the Director of Equal Opportunity so that they can better understand and readily access the Supportive Measures and other options available to them under this Policy. Reporting to the Director of Equal Opportunity does not obligate the Reporting Party to initiate or participate in a Complaint Resolution Process. The College will honor an individual’s preferences about whether to proceed with the Complaint Resolution Process, and will only take additional measures in the rare instances when the College believes further action is legally required or absolutely necessary for safety purposes. Resources and Supportive Measures are available regardless of whether a Complaint Resolution Process is initiated.
The College’s ability to respond to an anonymous Report may be limited depending upon the information it receives. If a Reporting Party is identified in an anonymous Report, the Director of Equal Opportunity will contact the Reporting Party to offer information and Supportive Measures. Because a Formal Complaint must be initiated by an individual who experienced the conduct or by the Director of Equal Opportunity under certain circumstances, an anonymous Report will not necessarily trigger the Complaint Resolution Process.
Meetings can normally be arranged on campus or at the Northfield Police Department depending upon the wishes of the Reporting Party. In most instances, Reporting to the police does not require filing criminal charges, and the individual Reporting to the police maintains control over whether and when criminal charges will be pursued. If the Reporting Party would like an advocate, Advisor, or parent to attend the meeting with the Northfield Police, assistance with these arrangements will also be made. Rights of Crime Victims in MinnesotaMinnesota law provides certain rights to individuals who Report crimes to law enforcement. These rights pertain to responsibilities of police and prosecutors when a crime is Reported. This is separate and apart from the process St. Olaf uses when a Report is made to the College. The following is a brief description of the rights guaranteed to individuals who Report crimes to law enforcement:
Protection. Individuals who Report crimes are entitled to:
Rights in Criminal Cases Involving Allegations of Domestic Violence, Sexual Assault, or Harassment. Individuals who Report crimes involving allegations of domestic violence, sexual assault or Harassment are entitled to:
Other rights. Individuals who Report crimes are also entitled to:
For further information, consult the Crime Victims Bill of Rights, a publication of the Minnesota Department of Public Safety, or Minnesota Statute 611A.
St. Olaf is committed to providing Reporting options through multiple avenues which are broadly accessible to all members of the St. Olaf community. Any person may Report Sexual Harassment (whether or not the person Reporting is the person alleged to be the victim of such conduct), in person, by mail, by telephone, or by email, to the Director of Equal Opportunity. Reports may be submitted at any time of day and at any point during the year. Reports may be made by completing the College’s on-line Reporting form which is automatically delivered to the Director of Equal Opportunity. Individuals can also contact the Director of Equal Opportunity or another member of the Equal Opportunity Team in person, by mail, telephone, or by email.
The willful filing of a false Report is a violation of this Policy, as well as the Student Code of Conduct. Charging an individual with a violation of the Code of Conduct for making a materially false statement in bad faith in the course of a Report, Formal Complaint, or Complaint Resolution Process under this Policy does not constitute Retaliation.
A person who Reports an incident to the College will be provided access to their Report upon request, consistent with state and federal laws governing privacy of and access to education records. A request for access to a Report should be made to the Director of Equal Opportunity. VI. INITIAL STEPS AFTER A SEXUAL HARASSMENT REPORT IS RECEIVED BY THE COLLEGEA. Initial Contact with Director of Equal OpportunityAfter receiving notification of conduct that may reasonably constitute Sexual Harassment, the Director of Equal Opportunity will promptly contact the Reporting Party to explain the options for addressing a Report.
Generally, the options available to a Reporting Party include but are not limited to one or more of the following:
The Reporting Party has the right to decide whether to take any action to address the alleged conduct, whether to seek Supportive Measures, and whether to be involved in an Informal Resolution Process or a Complaint Resolution Process addressing the conduct. Under some circumstances, as described in Section VIII B Phase 1 below, the Director of Equal Opportunity may determine that the College will initiate a Formal Complaint and Complaint Resolution Process to address the Sexual Harassment even if the Reporting Party decides not to participate in the Complaint Resolution Process. B. Availability of Supportive MeasuresAt any time after a Report of Sexual Harassment is received, the College will arrange for reasonable and appropriate Supportive Measures aimed at protecting the well-being and safety of each Party. Supportive Measures are actions taken to restore or preserve equal access to the College’s education program or activity without unreasonably burdening the other Party. They include measures designed to protect the safety of all Parties and the College’s educational environment. Supportive Measures foster a comfortable and safe educational, residential and working environment. Supportive Measures may be requested by a Reporting Party at any time after a Report is received, or by a Respondent at any time after being made aware of a Report. Supportive Measures may also be initiated by the College. Supportive Measures are available regardless of whether a Report proceeds to the Complaint Resolution Process.
Supportive Measures are offered by the College based upon the information gathered during the Report or made available to the College thereafter. They are not intended to be punitive. Such measures will vary based on the particular facts and circumstances, including but not limited to the specific need expressed by the Party, the age of the individual(s) involved, the severity and pervasiveness of the allegations, any continuing effects on the other Party, whether the Reporting Party and the Respondent share the same residence hall or assigned work location, and whether other measures have been taken to protect the Reporting Party and Respondent. C. Opportunity to Change or Challenge Supportive MeasuresA Reporting Party or Respondent may contact the Director of Equal Opportunity to seek modification or termination of Supportive Measures if circumstances warrant change. If modification or termination of Supportive Measures is not made upon request, the Reporting Party or the Respondent may request the Director of Equal Opportunity to assign an impartial Employee to review their request to modify or reverse the College’s decision to provide, deny, modify, or terminate any or all Supportive Measures applicable to them. Upon receipt of such request by either Party, the Director of Equal Opportunity will designate an impartial Employee to decide whether to grant the modification or reversal request. The impartial Employee will not be the same Employee who made the challenged decision and will be an Employee who has the authority to modify or reverse the decision. The decision will be modified or reversed if the impartial Employee determines that the decision to provide, deny, modify, or terminate the supportive measure was inconsistent with this Policy. D. Measures for avoiding contact with other involved Parties
The College does not issue harassment restraining orders or orders for protection, but one can be obtained through making an application to the Rice County District Court. Paperwork to petition the court for an order for protection or harassment restraining order is available from the Public Safety Office or the Northfield Police Department. These forms may be submitted to the Court Administrator in the Rice County Courthouse, 218 3rd Street NW, Faribault, MN 55021 during business hours. Free assistance filling out these forms is available by contacting the HOPE Center at 507-332-0882 (business line) or at 800-607-2330 (24/7 SafeLine) to get in touch with a legal advocate.
To achieve a safe and secure campus environment, all members of the campus community are encouraged to promptly Report any suspicious or criminal activity observed directly to Public Safety at 507-786-3666 and the Northfield Police Department. Employees (including Student employees) designated as Campus Security Authorities as defined by the Crime Awareness and Campus Security Act (Clery Act) are required to Report all known or suspected crimes to Public Safety for possible inclusion in the College’s crime logs, campus notices, and annual campus security Report pursuant to the Clery Act. These Campus Security Authorities include Advisors to Student organizations; coaches of athletic teams; members of the Public Safety Department; members of the Dean of Students Office; members working for Residence Life; and other community members who have responsibility for Student and campus activities.
Serious crimes and other reportable offences under the Clery Act include murder, sexual assault, robbery, burglary, hate crimes, aggravated assault and hazing.
Regardless of whether a Reporting Party decides to file a Formal Complaint, they will be notified of the importance of preserving evidence as may be necessary to aid in a future proceeding such as if the Reporting Party decides to initiate a Complaint Resolution Process or a criminal Investigation, or the Reporting Party seeks to obtain a protective order.
For their health and safety, to preserve their options and for other reasons, victims of sexual assault are strongly encouraged to immediately obtain medical attention and a medical forensic examination. A medical forensic examination is an exam performed by a specially-trained forensic nurse, called a Sexual Assault Nurse Examiner (or “SANE”). SANEs are contracted to work with physicians in the Emergency Department at the Northfield Hospital. Medical forensic examinations are available to anyone who is a victim of sexual assault regardless of gender or gender identity. Medical forensic examinations are conducted up to 240 hours (10 days) after the occurrence of a sexual assault; however, there may be circumstances that warrant an examination even after that period of time has expired.
Regardless of whether a Formal Complaint is filed, the College retains the right to remove a Student Respondent from the College’s education program or activity on an emergency basis. Before doing so, the College will perform an individualized safety and risk analysis, evaluating whether an imminent and serious threat to the physical health or safety of a Reporting Party, any Students, Employees, or other individual arising from the allegations of Sexual Harassment exists that justifies removal. The College will provide the Respondent with an opportunity to challenge the decision immediately following the removal.
The College may place an Employee or Student employee on administrative leave from employment responsibilities during the pendency of a Complaint Resolution Process.
The College will respect and safeguard the privacy of individuals who Report Sexual Harassment, and the privacy of other individuals involved in the process. Consistent with the College’s need to carefully assess allegations of Sexual Harassment, information will be shared with College officials who have a need to know in order to assist in the review of a Report and the determination of appropriate responses. For matters that are reviewed under the Complaint Resolution Process, information will also be shared as is required by law and as is deemed necessary for conducting a fair, impartial and thorough Complaint Resolution Process and/or Informal Resolution Process. VII. SUMMARY OF THE COMPLAINT RESOLUTION PROCESSESIn furtherance of St. Olaf’s commitment to providing a safe and non-discriminatory environment for all students, staff, faculty and other members of our campus community, this Complaint Resolution Process is available when a Reporting Party provides a Formal Complaint requesting the College to initiate an Investigation into allegations of Sexual Harassment. Upon receipt of a Formal Complaint from a Reporting Party, the College will issue a Notice of Allegations to the Parties involved. After issuing a Notice of Allegations, and providing the Parties a reasonable opportunity to prepare in advance of any meeting to discuss the allegations, the College will commence an Investigation into the allegations raised in the Formal Complaint. The goal of the Investigation and Hearing is to determine whether it is more likely than not that the Respondent engaged in Sexual Harassment. The Respondent is presumed not responsible for violating this Policy and the burden of proof and the burden of gathering evidence sufficient to reach a determination is on the College.
The Complaint Resolution Process includes the opportunity for the Parties to participate in mediation to attempt to reach a mutually agreeable resolution to the allegations raised in the Formal Complaint. This optional part of the Complaint Resolution Process is called the Informal Resolution Process. The Informal Resolution Process is used with the Reporting Party and Respondent each agree to attempt to mediate a resolution, and involves the voluntary crafting of an agreement between the Parties, which the College must also approve, designed to resolve the Formal Complaint. Pursuing the Informal Resolution Process does not require the Parties to ever be in the same room with each other or to speak to one another directly. While the Informal Resolution Process normally occurs prior to commencing an Investigation, the College reserves the right to initiate it at any point prior to a final determination of the Formal Complaint. The Informal Resolution Process is completely voluntary to all Parties involved, and once commenced, any Party or the College can decide to withdraw from participation at which point the Investigation and Hearing Process will resume. The Informal Resolution Process is described in more detail below in Section VII.
If any Party opts not to participate in the Informal Resolution process, or the Informal Resolution Process fails to result in a mutually agreeable resolution to the Formal Complaint, the College will proceed with the Investigation and Hearing Process. As its name indicates, there are two phases to this process. The first stage is an Investigation aimed at gathering all relevant evidence and summarizing it in an Investigation Report prepared by a trained Investigator retained by the College. During this phase the Parties have the same opportunity to participate in the Investigation by meeting with the Investigator, providing whatever evidence the Party believes is relevant, identifying witnesses that should also be interviewed, and suggesting questions that should be asked of other witnesses and Parties. Once the evidence has been gathered by the Investigator, the Parties have the same opportunity to access, review and comment on the evidence that will be summarized by the Investigator in the Investigation Report. This process described in more detail below in Section VIII B Phase 4.
After the Investigator issues the Investigation Report, the Investigation phase is complete and the process moves into the Hearing phase. No sooner than 10 days after the issuance of the Investigation Report, a Hearing Panel comprised of trained personnel will convene a Hearing at which time the Parties will be provided an equal opportunity to address the evidence with the Hearing Panel, including the opportunity to, through their Advisor, ask questions of any other Party or witness. If a Party does not have an Advisor, the College will provide a representative to ask the Party’s questions on the Party’s behalf.
Any Party who believes the Hearing Panel created an error in its decision may file a timely appeal of the decision to an Appeal Adjudicator. The Appeal Adjudicator will be an individual who played no prior role in the matter and who is free of any bias or conflict of interest. All Parties will be provided notice of an appeal and will have an opportunity to submit a position statement relating to the appeal. The Appeal Adjudicator will issue a determination of the appeal which may affirm the decision of the Hearing Panel, overturn the decision, and/or direct the Hearing Panel to conduct further proceedings to resolve a concern raised in an appeal. If no Party files an appeal of the Hearing Panel’s decision, or if the Appeal Adjudicator affirms the Hearing Panel’s decision, the College’s process will end and any sanctions imposed by the Hearing Panel will immediately go into effect. Once the time to appeal has expired or an appeal is decided, no Party will have an ability to seek further recourse from the College relating to the allegations raised in the Formal Complaint. This process described in more detail below in Section VIII B Phase 8 VIII. INFORMAL RESOLUTION PROCESS
At any time prior to reaching a determination regarding responsibility for Sexual Harassment through the Complaint Resolution Process, the Parties may choose to enter into an Informal Resolution Process. The College encourages the use of the Informal Resolution Process, recognizing that Parties’ participation is entirely voluntary and will only be implemented with their full written consent in accordance with the requirements of this section.
All Parties must provide voluntary, written consent to participate in the Informal Resolution Process. The College will not require Parties to participate in an Informal Resolution Process, or require a Party to waive the right to Investigation and adjudication of a Formal Complaint as a condition of enrollment, continued enrollment, employment, continued employment, or provision of any other right.
Generally, an Informal Resolution Process will be completed within 30 calendar days from the Parties’ written agreement to participate in the Informal Resolution Process. This timeline may be extended if necessary, including a temporary delay or the limited extension of time for good cause. The Parties will be notified simultaneously in writing of any extension of the timeframe and the reasons for such extension.
Before initiating an Informal Resolution Process, the College will provide written notice to the Parties that explains the following:
The facilitator for the Informal Resolution Process will be a trained person designated by the Director of Equal Opportunity. A facilitator designated by the Director of Equal Opportunity may be an Employee or may be an external consultant. The facilitator will not be the same person as the Investigator or a Hearing Panel Member or Appeal Adjudicator in the Complaint Resolution Process.
Each Party has the right to choose and consult with an Advisor during an Informal Resolution Process. The Advisor may be any person, including an attorney, who is not otherwise a Party to the Reported incident.
The facilitator, in consultation with the Director of Equal Opportunity, will work with the Parties to determine a structure for the Informal Resolution Process that all Parties agree to. Working with the facilitator, the Parties generally have latitude to determine the structure of the Process. In most cases the process will entail the facilitator attempting to mediate a resolution by meeting separately with the Parties.
The Parties have the right to withdraw from an Informal Resolution Process at any time up until an agreement is reached and signed by the Parties. The College may also declare an impasse or discontinue the Process for any reason. If the Process concludes without a resolution reached, the Reporting Party will determine whether to move forward with a Formal Complaint, and may initiate a Complaint Resolution Process, or continue with an existing Complaint Resolution Process.
At the conclusion of an Informal Resolution Process, the College will prepare and the Parties will sign an Informal Resolution agreement. IX. COMPLAINT RESOLUTION PROCESSThe College has adopted this Complaint Resolution Process to provide for a prompt and equitable resolution of all Complaints of Sexual Harassment made by Students, Employees, or other individuals who are participating or attempting to participate in the College’s education programs and activities. In certain circumstances a Complaint Resolution Process may also be initiated by the Director of Equal Opportunity. A. General Information Applicable to All Sexual Harassment Complaints
When the College receives a Report involving allegations of Sexual Harassment by a third Party (an individual who is not a Student, faculty, or staff member) that is outside the scope of this Complaint Resolution Process, the CORE Team may exercise discretion to determine an appropriate resolution process based on the facts and circumstances of the matter. The Director of Equal Opportunity will document any Report received, the process used, and the outcome. If it is determined that it is more likely than not that a third Party violated this Policy, appropriate Disciplinary Sanctions may include but are not limited to: conditions upon presence on campus or at College events, no-trespass and limited-contact directives, or other steps deemed necessary to protect the Reporting Party and the campus community. Any Party with concerns about the process or outcome should consult with the Director of Equal Opportunity.
If a Reporting Party or Respondent has any concern that an individual acting for the College under the Complaint Resolution Process has a conflict of interest, such concern should be Reported to the Director of Equal Opportunity no later than either two (2) business days after receiving the notice of the identity of the individual(s) assigned to the matter; or, in the case of a conflict of interest that arises after an individual is assigned to the matter, within two (2) business days after a conflict of interest arises. The CORE Team will review the concerns and take appropriate steps to ensure that no conflicts of interest exist on the part of anyone involved in mediating, investigating, or adjudicating a Formal Complaint under the Complaint Resolution Process.
Parties can expect the following:
Both the Reporting Party and the Respondent have the right to be assisted by an Advisor of their choice as long as the Advisor is not a Party in the case, does not have some other conflict of interest, and observes the following protocols:
Violations of confidentiality or other forms of interference with the resolution procedure by the Advisor may result in disqualification of an Advisor.
Retaliatory acts may include, but are not limited to: adverse changes in employment status or opportunities; adverse academic action; adverse changes to academic, educational and extra-curricular opportunities; harassment or intimidation; acts or comments intended to embarrass the individual; or seeking out or attempting to discover the Parties and witnesses involved in a report for the purpose of influencing their participation or statements, or taking adverse action against them. B. Complaint Resolution Process for Sexual Harassment Formal ComplaintsSt. Olaf has adopted this Complaint Resolution Process to provide for the prompt and equitable resolution of Sexual Harassment Complaints made by Students, Employees, or other individuals who are participating or attempting to participate in its education program or activity, or by the Director of Equal Opportunity. This Complaint Resolution Process will be used to resolve all Sexual Harassment Formal Complaints in which a Student is either a Reporting Party, a Respondent or both. Phase 1 – Initiation of Formal ComplaintThe following people have a right to make a Formal Complaint requesting the College investigate and make a determination about alleged Sexual Harassment involving a Student:
If a Formal Complaint is not initiated or is withdrawn, and if the Informal Resolution Process is not initiated or is terminated for any reason, the Director of Equal Opportunity may determine whether to initiate a Formal Complaint of Sexual Harassment after considering various factors including the following:
The Director of Equal Opportunity may initiate a Formal Complaint if, after considering these and other relevant factors, it is determined that the conduct alleged presents an imminent and serious threat to the health or safety of the Reporting Party or other person, or that the alleged conduct prevents the institution from ensuring equal access to its education program or activity. Phase 2 – Notice of AllegationsUpon receipt of a Formal Complaint and initiation of the Complaint Resolution Process, the Director of Equal Opportunity will provide a written Notice of Allegations that will apprise the Parties of the following:
If, in the course of an Investigation, the Director of Equal Opportunity learns of additional allegations of Sexual Harassment by the Respondent toward the Reporting Party that are not included in the Notice of Allegations previously provided or that are included in a Formal Complaint that is consolidated, the Director of Equal Opportunity will notify the Parties of the additional allegations in an amended Notice of Allegations. Phase 3 – Complaint Dismissal AssessmentWithin 10 business days of receipt of a Formal Complaint, the CORE Team will review the Formal Complaint and may dismiss or refer the matter to a different College office if:
In addition to the initial Complaint Dismissal Assessment, the CORE Team reserves the right to review a dismissal assessment at any time during the Complaint Resolution Process if circumstances change that may warrant dismissal. For example, if a Reporting Party voluntarily withdraws allegations, or a Respondent is no longer participating in a program or activity or employed with the College, the CORE Team may, but is not required to, determine that dismissal of the Formal Complaint is appropriate.
If the dismissal is appealed, the Director of Equal Opportunity will:
When a Formal Complaint is dismissed, the Director of Equal Opportunity will, at a minimum:
Phase 4 – InvestigationThe College will conduct an adequate, reliable, and impartial Investigation of the Formal Complaint. The Parties will have an equal opportunity to present fact witnesses and other inculpatory and exculpatory evidence that is relevant and not otherwise impermissible. The Investigator will review all evidence gathered through the Investigation and determine what evidence is relevant and what evidence is impermissible regardless of relevance. Phase 5 – The HearingFollowing the completion of the Investigation phase a Hearing will be scheduled. The Hearing is an opportunity for the Parties to address the Hearing Panel in person and to question the other Party and/or witnesses. It also provides the Hearing Panel an opportunity to obtain information following the Investigation that is necessary to make a determination of whether a Policy violation occurred.
The Hearing Panel will be impartial and free from bias or conflict of interest. If any Hearing Panel member has concerns that they cannot conduct a fair or unbiased review, the Hearing Panel member may report those concerns in advance of the pre-Hearing conference to the Director of Equal Opportunity and a different Hearing Panel member will be assigned. Similarly, a Reporting Party or a Respondent who has concerns that an assigned Hearing Panel member cannot conduct a fair and unbiased Hearing may report those concerns to the Director of Equal Opportunity who will assess the circumstances and whether a different Hearing Panel member should be assigned. The Hearing Panel has broad discretion to determine the Hearing format. The Hearing Panel is responsible for maintaining an orderly, fair, and respectful Hearing and has broad authority to respond to disruptive or harassing behaviors, including adjourning the Hearing or excluding the offending person. The Hearing Panel will also have discretion to call for breaks or recesses as deemed necessary during the Hearing.
The Hearing Panel has absolute discretion to decide upon the format for the Hearing and to determine which witnesses are relevant to their outcome determination. The Hearing Panel may decline to hear from a witness where they conclude that the information is not relevant for their outcome determination or unduly duplicative of other testimony already provided at the Hearing. A typical Hearing may include brief opening remarks by a member of the Hearing Panel; questions posed by the Hearing Panel to one or both of the Parties or witnesses; follow-up questions by one Party to the other (typically with the Respondent’s Advisor questioning the Reporting Party first); questions by the Hearing Panel to any witness; and follow-up questions by the Parties (through their Advisors) to any witness. The Hearing Panel will also afford the Parties an opportunity at the end of the Hearing to offer brief closing remarks. A decision whether to offer closing remarks is completely voluntary.
The Respondent will be deemed responsible only where the Hearing Panel concludes that a preponderance of the evidence supports a determination that the Respondent engaged in Sexual Harassment. Neither Party is required to participate in the Investigation or any form of resolution under this Complaint Resolution Process, and the Hearing Panel will not draw any adverse inference from a decision by either of the Parties not to participate.
Prior or subsequent conduct of the Respondent may be considered in determining pattern, knowledge, intent, motive, or absence of mistake. For example, evidence of a pattern of Sexual Harassment by the Respondent, either before or after the incident in question, regardless of whether there has been a prior finding of Sexual Harassment, may be deemed relevant to the determination of responsibility for the Sexual Harassment under Investigation. The determination of relevance of pattern evidence will be based on an assessment of whether the previous or subsequent conduct was substantially similar to the conduct under Investigation or indicates a pattern of similar Sexual Harassment. Such prior or subsequent conduct may subject the Respondent to additional sanctions. The Hearing Panel will determine the relevance of this information and both Parties will have access to information regarding this information in the same manner they are provided access to all evidence gathered during the Investigation.
The Investigator will determine what evidence is relevant to include in the Investigation Report. The Parties and their Advisors will have an equal opportunity to inspect and review any evidence obtained as part of the Investigation that is directly related to the allegations raised in the Formal Complaint even if deemed immaterial or irrelevant by the Investigator.
When expertise on a topic is needed in order to achieve a fuller understanding of the issues under Investigation, the Investigator may consult medical, forensic, technological or other experts. Information and opinions from experts may be sought by the Investigator or proffered by any of the Parties. When expert opinion information is directly related to the allegations raised in the Formal Complaint, the Parties will be apprised of the information and provided an opportunity to submit additional expert information.
Phase 6 – The Notice of DecisionFollowing the Hearing, the Hearing Panel will consider all of the evidence and make a determination, by a preponderance of the evidence, whether the Respondent has violated the Policy. The Hearing Panel will simultaneously issue to both Parties a written Notice of Decision within ten (10) business days of the Hearing.
The determination regarding responsibility becomes final either on the date that the College provides the Parties with the written determination of the result of the appeal, if an appeal is filed, or if an appeal is not filed, the date on which an appeal would no longer be considered timely. Phase 7 – Disciplinary Sanctions and RemediesWhere there is a finding of responsibility, the Hearing Panel is responsible for determining appropriate remedies and sanctions. Remedies will be designed to restore or preserve the Reporting Party’s equal access to St. Olaf’s education programs and activities. Remedies may include sanctions imposed upon a Respondent who is found responsible for violating the College’s Policy Prohibiting Sexual Harassment. Such sanctions may include a variety of institutional responses or requirements, including, but not limited to, the following:
The propriety of any particular Disciplinary Sanction is reviewed on an individual basis based on the unique facts and circumstances. In keeping with the College’s commitment to foster an environment that is safe, inclusive, and free of Sexual Harassment, the Complaint Resolution Process provides the Hearing Panel with wide latitude in the imposition of Disciplinary Sanctions tailored to circumstances of each unique matter.
The Director of Equal Opportunity is responsible for implementation of any Remedies and Disciplinary Sanctions imposed by the Hearing Panel. Disciplinary Sanctions become effective either after the time for appeal has expired, or, if a Party appeals the Hearing Panel’s decision, after the Appeal Adjudicator issues a determination affirming the Hearing Panel’s decision. If the Appeal Adjudicator’s decision results in further proceedings, the Disciplinary Sanctions imposed may be modified by the Hearing Panel, and will not become final until the conclusion of all further proceedings and any appeals. If the Appeal Adjudicator’s decision results in reversing a determination that the Respondent engaged in Sexual Harassment, no Disciplinary Sanctions will be imposed.
Phase 8 – Appeal
A Party wishing to appeal a decision by the College to dismiss a Formal Complaint or any allegations, may do so by submitting a written letter of appeal to the Director of Equal Opportunity within three (3) business days of when the Director of Equal Opportunity sent the Notice of Dismissal to the Parties. A decision denying a request to dismiss a Formal Complaint or any allegations cannot be the subject of an appeal. The letter of appeal should state the grounds for appeal. The non-appealing Party will have an opportunity to review and respond to the letter of appeal. A non-appealing Party’s response to an appeal must be received within three (3) business days of notice of the appeal letter. The Director of Equal Opportunity will provide the Formal Complaint, Notice of Dismissal and any other information relevant to the appeal to the Appeal Adjudicator for review.
If a Party appeals the Notice of Dismissal, the Appeal Adjudicator will review the appeal, the Formal Complaint, the Notice of Dismissal and other relevant information to determine whether the appeal has merit. In reviewing any appeal, the Appeal Adjudicator has the ability to affirm the Equal Opportunity CORE Team decision, or overturn the decision and remand the matter for further Investigation and adjudication. The Appeal Adjudicator will simultaneously issue to both Parties a written decision describing the result of the appeal and the rationale for the result within three (3) business days after receipt of all appeal documents.
A Party wishing to appeal a decision by the Hearing Panel may do so by submitting a written letter of appeal to the Director of Equal Opportunity within three (3) business days of when the Director of Equal Opportunity sent the Hearing Panel’s Notice of Decision to the Parties. The letter of appeal should state the grounds for appeal. The non-appealing Party will have an opportunity to review and respond to the letter of appeal. A non-appealing Party’s response to an appeal must be received within three (3) business days of notice of the appeal letter. The Director of Equal Opportunity will provide the Investigation Report, the Hearing Panel’s Notice of Decision, the appeal letters, and any other information relevant to the appeal to the Appeal Adjudicator for review.
If either of the Parties appeals the Hearing Panel’s determination, the Appeal Adjudicator will review the appeal, the Investigation Report, the Notice of Decision and other relevant information to determine whether the appeal has merit. In reviewing any appeal, the Appeal Adjudicator has the ability to affirm the Hearing Panel’s decision, overturn the Hearing Panel’s decision, or remand the matter for further Investigation and adjudication. The Appeal Adjudicator will simultaneously issue to both Parties a written decision describing the result of the appeal and the rationale for the result within three (3) business days after receipt of all appeal documents.
X. RECORDKEEPINGThe College will maintain for a period of seven (7) years, records of the following:
XI. POLICY REVIEWA. Ongoing internal Policy reviewThis Policy is maintained by the Equal Opportunity Team and subject to ongoing review and improvement. The Equal Opportunity Team will review this Policy on at least an annual basis. To assist the Equal Opportunity Team in its review of its policies and practices, St. Olaf College has established a Title IX Advisory Group that is tasked with gathering information from the St. Olaf community and providing recommendations on Policy revisions and enhancements. The Title IX Advisory Group is appointed by St. Olaf’s President and is composed of Student, faculty and staff members. B. External recourseNothing in this Policy or Complaint Resolution Process is intended to interfere with the right of any individual to pursue other avenues of recourse which may include, but are not limited to, filing a complaint with the United States Department of Education, Office for Civil Rights (OCR). Any individual who has made a Report of Sexual Harassment and/or initiated the Complaint Resolution Process, and who believes the College’s response did not comply with this Policy and the College’s legal obligations, or who otherwise believes they have been discriminated against, may file a complaint with the Office for Civil Rights (OCR) of the U.S. Department of Education. The OCR office that oversees institutions in Minnesota, including St. Olaf, is: U.S. Department of Education |