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Responding to Sexual Harassment Complaints

How will St Andrews deal with a Complaint or Report of Sexual Harassment?

St. Andrews provides members of the academic community prompt, equitable, and reliable mechanisms for reporting incidents of sexual discrimination, including sexual harassment, sexual misconduct, sexual violence, harassment based on a protected category, retaliation, dating violence, domestic violence, stalking, and false accusations. A sexual discrimination report does not have to result in filing charges. However, a report or complaint of sexual discrimination must be investigated.

A report or complaint about sexual discrimination can be made to any St. Andrews employee. The employee who receives the report or complaint is then required, unless he or she is a designated Confidential Employee, to inform the Title IX Coordinator (see below, Duty to Report and Privacy Statement). Additionally, students, staff, and faculty, who are concerned they may be named as a Responding Party in a sexual discrimination report are also encouraged to contact the Title IX Coordinator.

Facilitated by the Title IX Coordinator, the university will promptly, equitably, and reliably support the rights of all St. Andrews community members-Reporting Party’s, Complainant’s, Responding Party’s, and witnesses. Reports and Complaints about acts of sexual discrimination, including sexual harassment, misconduct, violence, or acts of retaliation that are in violation of the Anti-Discrimination/Anti-Harassment policy will be taken seriously, will be investigated, and will be treated in a compassionate and discreet manner.

Duty to Report and Privacy Statement

All St. Andrews employees not designated as Confidential Employees, including faculty, staff, Resident Directors, and Resident Assistants are obligated to respond to reports and complaints of sexual discrimination, including sexual harassment, sexual violence, dating violence, domestic violence, and stalking, even if the individual reporting the incident requests that no action be taken. It is essential that employees make clear to those who may want to confide in them that they have a legal obligation to report anything they learn about potential sexual harassment to the Title IX Coordinator for investigation. They should tell a person who is looking for confidential advice to contact one of the designated Confidential Employees of the University.

St. Andrews understands that prompt, equitable, and reliable responses to Title IX and Campus SaVE harassment and discrimination reports often require obtaining sensitive information about members of the campus community. The privacy of reports will be strictly kept when possible, or tightly maintained among persons who have a need to know to keep the community safe when strict privacy is not possible. The identity of the Reporting Party, Complainant and/or the Responding Party will be disclosed only on a need-to-know basis to the extent feasible in light of the need to conduct an investigation and to promote community safety. Persons with whom St. Andrews may share investigation-related information include, but are not be limited to:

  • St. Andrews employees working in an official capacity who require information for the proper performance of their professional responsibilities, particularly in matters of conducting an investigation and/or protecting individual student and campus-wide safety.
  • A Reporting Party. Complainant or Responding Party of an investigation, when such information is necessary for the effectiveness of interim conditions (e.g., enforcing a “No Contact” directive, for example)
  • A Reporting Party, Complainant or Responding Party of an investigation, concerning the final results of the investigation i.e., a determination that discrimination did or did not occur, remedies being offered, and right to appeal; however, all disciplinary actions taken against a Responding Party will not necessarily be released to the Reporting Party without the Responding Party’s consent. These written notifications to the Reporting Party and Responding Party will occur in rapid succession of one another (i.e., as close to simultaneously as is reasonable)
  •  Appropriate persons in case of health or safety emergencies
  • Outside law enforcement officials, when St. Andrews deems this appropriate or necessary
  • Local, state, or federal entities that require reporting of sexual assault and other violent incidents e.g., Clery Act, Campus SaVE Act (personally identifiable information about the participants will be redacted whenever permissible). Students or employees may report any concern about sexual discrimination, including sexual assault, dating violence, domestic violence, or stalking, anonymously.

Reporting persons may decline to name themselves and St. Andrews will investigate the report, establish Interim Measures, refer any named parties to resources, and take other actions as possible. Anonymous reporters must realize St. Andrews will be limited in its ability to respond or investigate in such cases, but will do all it can with limited information to promptly investigate the report of sexual discrimination, stop the reported discrimination, and prevent its recurrence

St. Andrews seeks to adequately protect confidential Student Education Records while also conducting a prompt, equitable, and effective investigation. Determining which campus officials, Reporting Party, Complainant, Responding Party, witnesses, and other parties need to know about Title IX investigations, interim measures, final investigation outcomes, sanctions, remedial actions, and other details shall be decided in compliance with FERPA requirements.

Investigation and Resolution of Sexual Discrimination or Harassment Reports and Complaints

The Process and Timeline

Every effort will be made to adhere strictly to the timetables in this document. However, if investigations extend to when school is out for prolonged periods or if there are unavoidable challenges in communications or evidence-collection with the Complainant and Responding Party, or others involved in an investigation, the University may require extensions to the below timetables.

Immediately upon notification (orally or in writing) of a report or complaint of Sexual Discrimination or Harassment, the Title IX Coordinator will determine whether further action is required. An investigation will be initiated, if the report or complaint conforms with the following criteria:

  • The allegations in the report or complaint fit the definition of sexual discrimination or sexual harassment as defined in this policy;
  • The allegations in the report or complaint are within the jurisdiction of the university’ authority to investigate. The 2024 changes to Title IX regulations have broadened the jurisdiction of the university beyond the limits or university programs and property. Therefore, the key jurisdictional issue is not where or when the alleged Sexual Discrimination took place, but whether the respondent is currently a student, faculty, or staff of the university. If the respondent is not a student, faculty, or staff, the Title IX coordinator will support the complainant in determining how to get appropriate redress to their complaint.
  • Whether the report or complaint regards something that happened a significant time in the past is not considered in determining whether to proceed with an investigation. Though the sooner a report or complaint is received the more likely a successful investigation and resolution can occur, there is no statute of limitations and any allegation that fits the first two criteria will be taken seriously and investigated thoroughly.

Steps After Receiving a Report of Alleged Sexual Discrimination or Harassment:

As soon as reasonably practicable, and no longer than forty-eight hours, after receiving a credible report of sexual discrimination or harassment and determining that the allegation is within the jurisdiction of the university, the Title IX Coordinator will initiate an investigation in the following manner:

  • Determine whether the Title IX Coordinator him or herself has any bias or conflict of interest. If so, the Title IX Coordinator must recuse him or herself from this process and assign supervision of the investigation and resolution of the report to a delegated, trained member of the Title IX team
  • Inform the parties, in writing, that a report of sexual harassment or discrimination has been received by the Title IX coordinator and that an investigation has been initiated;
  • Inform the Dean of Students, Human Resources, Campus Safety, and any other offices that need to know in order to protect the safety of the parties involved and the campus as a whole;
  • Select a trained investigator, making certain the investigator does not have any conflict of interest or bias for or against any of the parties involved, provide the investigator with information contained in the report, and ask him or her to submit a written investigative report within ten days (if at all practicable);
  • On the basis of interviews with the reporter, the complainant, and the respondent, determine what Interim Supportive Measures (which might include but are not limited to counseling services, excused absence from class, a no contact order, room or dormitory reassignment) may be necessary to support the well-being and safety of those involved and the campus as a whole;

The Investigation

Upon receipt of the request from the Title IX Coordinator, the Investigator will initiate an investigation, working diligently to complete it and write a report within ten days. If the investigation is taking longer, the Investigator will inform the Title IX Coordinator of the reason for the delay and propose an alternative completion date. The Title IX Coordinator will inform the parties involved of the delay, the reason, and the likely completion date.

The investigation will include steps such as:

  • Conducting interviews with the Reporter, the Complainant, the Respondent, and third party witnesses (including expert witnesses, where applicable) and summarizing the interviews in written form;
  • Visiting, inspecting, and taking or reviewing photographs at relevant sites where applicable; and
  • Collecting and preserving relevant evidence (in case of corresponding criminal complaints, this step may be coordinated with law enforcement agencies) where applicable.

Throughout the investigation the Investigator will remain neutral and unbiased.

Parties’ Ability to Gather and Submit Relevant Evidence

The University will not restrict the ability of the Complainant or Respondent to submit inculpatory and exculpatory evidence to the investigators, including from fact and expert witnesses of their own choosing.

Parties’ and Witnesses Expectation of Privacy

The University will take reasonable steps to protect the privacy of the parties and witnesses during the investigation, resolution process, and afterwards. The safety of the campus, the well-being of the parties, and the integrity of due process may, however, sometimes make absolute protection of privacy impossible.

Prohibition of Submission of Privileged Information and Medical Records

The Investigator will not allow submission of, rely on questions about, or seek disclosure of, information protected by a legally recognized privilege, unless the holder of such privilege voluntarily waived the privilege. The Investigator cannot access, consider, disclose, or otherwise use a party’s records that are made or maintained in treatment by a physician, psychiatrist, or psychologist, without the voluntary, written consent of the party in question.

The Investigative Report

The Investigator will submit a written, signed report that includes a summary of the evidence, an assessment of the strength and trustworthiness of the evidence, an analysis of discrepancies in the various witness reports and evidence, and factual claims for which there is no evidence or insufficient evidence. Throughout the Investigator Report, the Investigator will remain neutral and unbiased with regard to responsibility and appropriate remedy.

  • The Investigator will submit the report to the Title IX Coordinator, who will share it with the Complainant and the Respondent.
  • The Complainant and Respondent must submit a signed response to the Investigative Report within ten days of receiving it, if they wish to dispute or add to any of the information contained in Investigative Report.
  • The written responses of the Complainant and Respondent will be added as a supplement to the Investigative Report and be included in the overall record of the Investigation.

A Formal Complaint and Resolution of a Formal Complaint

Upon receiving a report of alleged sexual discrimination or harassment or an oral or written complaint of the same, the Title IX Coordinator will, as soon as practicable, meet with the Complainant in person (or virtually, if necessary) to discuss the report or complaint, the investigative process is being initiated, interim supportive measure that are available, and possible avenues for resolution. If the investigation was provoked by a third-party reporter, the Title IX Coordinator will have an initial discuss about whether the Complainant wants to file a formal Complaint, which can be done at any time in the investigative process.

Upon completion of the Investigative Report, the Title IX Coordinator will meet with the Complainant again to review the report, determine whether the Complainant wants to lodge a formal Complaint, and, if so, the preferred avenue for resolution. If the Complainant declines to make a formal written complaint, the respondent and the relevant campus officials will be informed of the decision, and the Investigative Report will be filed in the Office of the Title IX Coordinator with no further action.

If the Complainant declines to make a Formal Complaint or withdrawals a Formal Complaint prior to a resolution of the complaint, the Title IX Coordinator may initiate a Formal Complaint on behalf of the University if warranted. In determining whether such a complain is warranted, the Title IX Coordinator will consider, at minimum, the following:

  • The Complainant’s request not to proceed with the Complaint and the reasons offered for not proceeding;
  • The risk that additional acts of sexual discrimination may occur if a Complaint is not initiated;
  • The severity, scope, and duration of the alleged sexual discrimination and the likelihood of its persistent impact of the Complainant, Respondent, University community, and wider society;
  • The strength of the evidence that sexual discrimination occurred; and
  • Whether the University could end the alleged sexual discrimination and prevent its recurrence without initiating a Title IX Complaint.

A Formal Versus an Informal Resolution Process

The Complainant has the right to choose either a formal or informal resolution process. An informal resolution process is the equivalent of mediation and requires the two parties to work together with a mediator to come to a mutually agreeable resolution to the matter. If the parties cannot come to a mutually agreeable resolution, the complainant always reserves the right to initiate the formal, judicial process.

The formal process requires a written complaint, a formal investigation, a Title IX Hearing with both the complainant and respondent present, and a decision by the Title IX Hearing committee concerning responsibility and appropriate sanctions regarding the complaint.

The Complainant also always retains the right, at any time, to report the complaint to the local police and seek a legal resolution to the problem. If and when the legal process is initiated, the university process can continue side by side with it or be put on hold until the legal process is completed depending on the situation. The university will always continue to provide the necessary interim support services whether the university’s resolution process is continuing or on hold.

 Title IX Hearing

When the Complainant selects a formal resolution process and the investigative report has been received by the Title IX Coordinator, a Title IX Hearing will be scheduled. The purpose of a Title IX Hearing is to put the formal resolution of the Title IX complaint in the hands of a neutral committee of faculty and staff who will hear the evidence, deliberate regarding the complaint, and make a final decision concerning its resolution.

Their standard of evidence will be the preponderance of evidence, namely that the evidence points to it being more likely than not that the complaint is true and accurate. They will also decide on appropriate sanctions based on the guidelines in the Saltire and their knowledge of the situation. After receiving the completed Investigative Report (including written responses from the Complainant and Respondent, if they wish) and the Formal Complaint, the Title IX Coordinator will schedule a Title IX Hearing and communicate the date and time to the members of the Title IX Hearing Committee, the Complainant and the Respondent not less than one week from the date of the hearing. Both the Complainant and the Respondent will have access to the Investigative Report at least five days before the hearing. The report, however, must remain confidential and not be provided to any parties not involved in the Hearing process. If the Title IX Coordinator is concerned that one or both of the parties may not abide by the confidentiality requirement, access to the Investigative Reports may be limited to physical copies kept in the Title IX Coordinators’ office.

Both the Complainant and the Respondent are allowed and encouraged to have an Advisor (who may be a lawyer but need not be a lawyer) present during the Hearing to offer advice and provide support. The Complainant and Respondent must inform the Title IX Coordinator about who will serve as their Advisor at least two days before Hearing. The Title IX Coordinator will serve as the Moderator of the Title IX Hearing, supervising the process and adjudicating any disputes about the process. At the Hearing, each party, the Complainant and Respondent, with have an opportunity for an Opening Statement and a Closing Statement. The Title IX Hearing Committee will have the right to ask questions of both the Complainant and the Respondent relevant to the case at hand. In case of a dispute concerning whether the question is relevant, the Title IX Coordinator will decide.

The Complainant and Respondent will have the opportunity to ask questions of one another themselves or through their Advisors, that are relevant to the case at hand. In case of a dispute concerning whether the question is relevant, the Title IX Coordinator will decide. Both the Complainant and the Respondent have the right to dispute witness statements in the investigative report through in-person cross-examination conducted by their Advisors. However, in order to have witnesses present at the Hearing, the Complainant and Respondent must provide a list of any witnesses they would like present at the Hearing to the Title IX Coordinator at least five dates before the Hearing itself. The Title IX Coordinator will invite the witnesses to attend the Hearing and coordinate their presence at the Hearing.

Title IX Hearing will normally take place in person, with both the complainant and respondent present in the same room at the same time. However, the Title IX coordinator may determine that it would be better to conduct the Hearing remotely for the Hearing Committee, the Complainant, the Respondent, or the integrity of the process. At the end of the Hearing, the Complainant and Respondent (as well as their advisors) will be placed in separate, private rooms, while they await the Title IX Hearing Committee’s decision.

The Title IX Committee must determine if the Respondent is responsible or not responsible. Once the Title IX Hearing Committee has made a determination, the Title IX Coordinator will invite both the Complainant and Respondent back into the room and communicate the decision and inform them of the appeal process. Immediately after the end of the Hearing, the Title IX Hearing’s decision will be written up, signed by the Title IX Coordinator, and sent to members of the Title IX Hearing Committee, the Complainant, the Respondent, and any additional campus personnel who are responsible for enforcing any sanction(s) that may have been determined.

Sanctions

Sanctions are issued based upon the St. Andrews University Saltire. Individuals found to have engaged in illegal sexual activity or behavior constituting sexual discrimination (including sexual harassment, sexual misconduct, sexual violence, retaliation, dating violence, domestic violence, or stalking) based on a preponderance of the evidence¨ standard (i.e., it is more likely than not that sexual discrimination occurred) as defined in this policy, will be disciplined, up to and including discharge, removal, suspension, or expulsion from the University. The range of possible sanctions includes, but would not be limited to, the following:

  • Ongoing “No Contact” remains in place
  • Written warnings
  • Educational interventions
  • Targeted community service
  • Social, housing, or other probations
  • Suspension (for varying lengths of time)
  • Expulsion

Appropriate student sanctions will be a unanimous determination by the Dean of Students and Title IX Coordinator.

Right to Appeal

Both the Compliant and the Responding Party have the right to appeal the decision of the Title IX Hearing outcome within ten (10) business days, in writing, to the St. Andrews University Campus President. There are two grounds upon which to base an appeal

  • Significant new information that was not available at the time of the initial investigation, which could reasonably alter the facts and outcome of the investigation. A written appeal must delineate these new facts and explain how they could impact the outcome;
  • There was a procedural error that significantly affected the outcome. A written appeal must describe the procedural error and support how that error affected the outcome.

Both the Complainant and the Respondent will be notified of the decision of the Campus President regarding the appeal within 30 days.

Spring classes begin January 7th!