Title IX Review, Investigation, and Resolution

Overview | Title IX Coordinator Role | Time Frames for Resolution |
Title IX Review and Assessment | Investigation | Remedies-based Resolution | Judicial Resolution

Although a report may come in through many sources, the College is committed to ensuring that all reports of sexual assault or harassment are referred to the Title IX assessment team, which ensures consistent application of the Interim Sexual Assault and Harassment Policy to all individuals and allows the College to respond promptly and equitably to eliminate the harassment, prevent its recurrence, and eliminate its effects. This team, led by the Title IX coordinator, assists in the review, investigation, and/or resolution of the report. Members of this interdepartmental team include the Title IX coordinator, deputy Title IX coordinators, the dean of students, senior class dean and judicial affairs coordinator, and the director of public safety. Depending on the relationship of the complainant and the respondent to the College (student, staff, faculty, or other) and the nature of the report, additional team members may include the Equal Opportunity officer, the vice president for human resources, and provost, and others as may be necessary. The members of this team oversee the resolution of the reported harassment or misconduct through the College’s complaint processes.

A. Overview of Procedural Options

Upon receipt of a sexual misconduct report, the College’s Title IX team will conduct an initial Title IX assessment. The goal of this assessment is to provide an integrated and coordinated response to reports of sexual harassment or sexual assault. The assessment will consider the nature of the report, the safety of
the individual and of the campus community, and the complainant’s expressed preference for resolution.

Following this assessment, the College may seek
a remedies-based resolution that does not involve disciplinary action against a respondent. Alternately, the matter may be referred for investigation. The goal of the investigation is to gather all relevant facts and determine if there is sufficient information to refer the report for disciplinary action using the College’s judicial resolution procedures.

The process followed will be determined by the relationship of the respondent to the College:

  • Complaints against a student will be resolved by the Procedures for Resolution of Complaints against Students, which is set forth as Appendix A to this Policy.
  • Complaints against a staff member will be resolved by the College policy governing staff and related grievance procedures, which can be found in Chapter 11 of the Employee Handbook.
  • Complaints against a member of the instructional staff, including faculty, will be resolved by the College policy governing instructional staff and related grievance procedures, which can be found in section II.C.1. of the Handbook for Instructional Staff [pdf, on-campus access only].

Each process is guided by the same principles of fairness and respect for all parties. Resources are available for both students and employees, whether as complainants or respondents, to provide support and guidance throughout the investigation and resolution of the complaint.

B.  Role of the Title IX Coordinator

Title IX Coordinator Kaaren Williamsen oversees the College’s centralized review, investigation, and resolution 
of reports of sexual assault and harassment. The coordinator also coordinates the College’s compliance with Title IX. The Title IX coordinator is:

  • responsible for oversight of the investigation and resolution of all reports of sexual assault and harassment;
  • knowledgeable and trained in relevant state and federal laws and College policy and procedure;
  • available to advise any individual, including a complainant, a respondent, or a third party, about the courses of action available at the College, both informally and formally;
  • available to provide assistance to any College community member regarding how to respond appropriately to reports of sexual assault and harassment;
  • responsible for monitoring full compliance with all requirements and timelines specified in the complaint procedures; and
  • responsible for compiling annual and semi-annual reports.

Trained Deputy Title IX Coordinators who can also offer assistance are available in the following offices:

Dean’s Office Deputy Title IX CoordinatorLili Rodriguez
Associate Dean of Diversity, Inclusion, and Community Development
Parrish Hall 140 | 610-690-5767

Provost’s Office Deputy Title IX CoordinatorPatricia Reilly
Associate Provost for Faculty Development and Outreach and Associate Professor of Art History 
Beardsley Hall 205 | 610-690-3730

Human Resources Deputy Title IX CoordinatorZenobia Hargust
Human Resources Manager
Pearson Hall 010│610-328-8398

Athletics Deputy Title IX CoordinatorNnenna Akotaobi
Associate Athletics Director and Senior Woman Administrator
Athletics Fieldhouse 161 │610-328-8222

C.  Time Frames for Resolution

The College seeks to resolve all reports of sexual misconduct within sixty (60) days. All time frames expressed in this policy are meant to be guidelines rather than rigid requirements. Circumstances may arise that require the extension of time frames, including extension beyond sixty (60) days. Such circumstances may include the complexity of the allegations, the number of witnesses involved, the availability of the parties or witnesses, the effect of a concurrent criminal investigation, any intervening school break or vacation, or other unforeseen circumstances.

In general, a complainant and respondent can expect that the process will proceed according to the time frames provided in this policy. In the event that the investigation and resolution exceed this time frame, the College will notify all parties of the reason for the delay and the expected adjustment in time frames. Best efforts will be made to complete the process in a timely manner by balancing principles of thoroughness and fundamental fairness with promptness.

At the request of law enforcement, the College may agree to defer its fact-gathering until after the initial stages of a criminal investigation. The College will nevertheless communicate with the complainant regarding Title IX rights, procedural options, and the implementation of interim measures to ensure safety and well-being. The College will promptly resume its fact-gathering as soon as law enforcement has completed its initial investigation.

D. Initial Title IX Review and Assessment

In every report of sexual assault or harassment, the Title IX coordinator, along with the director of public safety and the dean of students, will make an immediate assessment of any risk of harm to individuals or to the campus community and will take steps necessary to address those risks. These steps may include interim protective measures to provide for the safety of the individual and the campus community. One or more of the deputy Title IX coordinators may also be included in the initial assessment.

The initial review will proceed to the point where a reasonable assessment of the safety of the individual and of the campus community can be made. Thereafter, the investigation may continue depending on a variety of factors, such as the complainant’s wish to pursue disciplinary action, the risk posed to any individual or the campus community by not proceeding, and the nature of the allegation.

E. Investigation

Where the Title IX assessment concludes that College judicial or disciplinary action may be appropriate, the College will initiate an investigation. The College may designate an investigator of its choosing, provided that the investigator has specific training and experience investigating allegations of sexual assault and harassment. The College will provide annual training for all investigators, and any investigator chosen to conduct the investigation must be impartial and free of any conflict of interest. The investigator may be an employee of the College, an external investigator engaged to assist the College in its fact- gathering, or a team of investigators that pairs an external investigator with a College employee related to the roles of the parties on campus (student, staff, or faculty).

The investigator will conduct the investigation in a manner appropriate in light of the circumstances of the case, which will typically include interviews with the complainant, the respondent, and any witnesses. As part of the investigation, the College will provide an opportunity for the parties to present witnesses and other evidence. The interviews will be supplemented by the gathering of any physical, documentary, or other evidence, as appropriate and available. The investigation is designed to provide a fair and reliable gathering of the facts. The investigation will be thorough, impartial, and fair, and all individuals will be treated with appropriate sensitivity and respect. The investigation will be conducted in a manner that is respectful of individual privacy concerns.

The College will seek to complete the investigation within 30 (thirty) business days of receiving the complaint, but this time frame may be extended depending on the complexity of the circumstances of each case.

At the conclusion of the investigation, the investigator will prepare a report setting forth the facts gathered, which will be forwarded to the Title IX coordinator and the College administrator responsible for initiating judicial resolution proceedings. Upon receipt of the investigation report, the College will notify all parties that the investigation is complete and provide information about next steps in the process.

Information gathered during the review or investigation will be used to evaluate the responsibility of the respondent, provide for the safety of the complainant and the College campus community, and impose remedies as necessary to address the effects of the alleged conduct. Where there is sufficient information alleged, if proven, that would constitute a violation of policy, the College will have the discretion to institute judicial resolution proceedings against the respondent.

Based on the information gathered in the initial Title IX assessment and/or investigation, the College
 will take appropriate measures designed to end the misconduct, prevent its recurrence, and address its effects.

The Title IX coordinator will document each report or request for assistance in resolving a case involving charges of sexual assault or harassment, whether by the complainant, a third party, or anonymously, and will review and retain copies of all reports generated as a result of investigations. These records will be kept confidential to the extent permitted by law.

F. Remedies-based Resolution

Where the Title IX assessment concludes that remedies-based resolution may be appropriate, the College will take immediate and corrective action through the imposition of individual and community remedies designed to maximize the complainant’s access to the educational and extracurricular activities of the College. Examples of potential remedies are provided in policy Section IX: Interim Measures. Other potential remedies include targeted or broad-based educational programming or training. In cases that do not involve sexual violence, mediation and other restorative justice programming may be an appropriate form of remedies-based resolution.

The College will not compel a complainant to engage in mediation, to directly confront the respondent, or to participate in any particular form of remedies-based resolution. Mediation, even if voluntary, may not be used in cases involving sexual violence or assault. The decision to pursue remedies-based resolution, which may occur at any time, will be made when the College has sufficient information about the nature and scope of the conduct. Participation in remedies-based resolution is voluntary, and a complainant can request to end remedies-based resolution at any time.

G. Judicial Resolution

Disciplinary action against a respondent may only be taken through judicial resolution procedures. Because the relationship of students, staff, and faculty to the College differ in nature, the procedures that apply when seeking disciplinary action necessarily differ as well. Each of the procedures, however, is guided by the same principles of fundamental fairness and respect for all parties, which require notice, an equitable opportunity to be heard, and an equitable opportunity to respond to a report under this Interim Sexual Assault and Harassment Policy.   

The Procedures for Resolution of Complaints Against Students are provided as part of this policy. The College policy governing staff and related grievance procedures can be found in Chapter 11 of the Employee Handbook.  The College policy governing faculty and related grievance procedures can be found in section II.C.1. of the Faculty and Instructional Staff Handbook [pdf, on-campus access only].