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March 28, 2018

I. Introduction

The Sexual and Gender-Based Misconduct Policy for Staff (‘the Policy’) describes how Wheaton College (‘the College’) will address and investigate a report that a staff member has engaged in conduct that could constitute Sexual and Gender-Based Misconduct, as defined in the Policy and determine what, if any, safety measures and/or disciplinary sanctions are appropriate. For more information or to report Sexual and Gender-Based Misconduct, please contact Rachael Pauze, Director of Title IX Compliance, at (508) 286-3231, pauze_rachael@wheatoncollege.edu, or in person at her office, Room 227 in the Science Center.

Reports regarding Other Prohibited Forms of Sex Discrimination, as defined below, will generally be addressed under the College’s Unlawful Discrimination Policy in the Staff Handbook, a copy of which can be accessed here. For more information or to report such discrimination, please contact Omaira Roy, Title IX Coordinator for Staff, at 508-286-8206, roy_omaira@wheatoncollege.edu, or in person at her office, Hebe 105.

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II. Definitions

For purposes of the Policy, the following terms have the meanings indicated in this section.

Appellate Officer.  The Executive Vice President for Finance and Administration or a designee.

Complainant. A Complaining Individual who experienced the alleged Prohibited Conduct and who becomes a party to the conduct process under Section IV of the Policy.

Complaining Individual.  An individual who experienced the alleged Prohibited Conduct.

Confidential Resource Person. A College staff or faculty member or third-party partner who is not required to report allegations of Prohibited Conduct to the Title IX Director.

Effective Consent. Consent which is informed, freely and actively given through clear words or actions, and creates mutually understandable permission regarding the conditions of sexual activity. Effective Consent is achieved only where each party mutually understands what behavior the party’s partner consents to and what behavior the party’s partner does not consent to with regard to physical and sexual interactions. Effective Consent at one time does not imply Effective Consent at any other time. Effective Consent cannot be obtained: (1) through silence alone (absent a non-verbal action clearly demonstrating consent); (2) from minors (under the age of 16 in Massachusetts), individuals with mental disabilities, or incapacitated persons; or (3) through physical force, threat of physical force (by words, gestures, or non-verbal actions), coercion, fraud, intimidation, or incapacitation.

Non-Consensual Sexual Penetration. Any sexual penetration (anal, oral or vaginal), however slight, with any object or sexual intercourse, without Effective Consent.  Sexual intercourse

includes vaginal or anal penetration by a penis, object, tongue or finger and oral copulation by mouth to genital contact or genital to mouth contact.

Non-Consensual Sexual Touching, Disrobing or Exposure. Any intentional sexual touching, however slight, with any object without Effective Consent. Sexual touching includes any bodily contact with the breasts, groin, genitals, mouth or other body orifice of another individual or any other bodily contact in a sexual manner. It also includes ejaculating semen onto another individual without Effective Consent. Any disrobing of another individual, or intentional exposing of oneself to another individual without Effective Consent.

Order of No Contact. A written order issued by the College prohibiting contact between two or more parties and, when applicable, ordering restriction from one or more locations on campus.

Other Prohibited Forms of Sex Discrimination. Forms of adverse treatment on the basis of sex (including on the basis of sexual orientation, gender identity, and/or gender expression) that are not otherwise set forth as Prohibited Conduct, in Section III of this Policy.1

Procedural Advisors. Trained faculty members, staff or administrators who provide information and procedural advice regarding the Policy and process to the Complainant and the Respondent.

Relationship Violence. Any act of violence or threatened act of violence against a person who is, or has been involved in, a sexual or dating relationship with that person. Relationship Violence may involve one act or an ongoing pattern of behavior. Relationship Violence can encompass a broad range of behavior including, but not limited to, threats, assault, property damage, emotional abuse, violence or threat of violence to one’s self, one’s sexual or romantic partner or to the family members or friends of the sexual or romantic partner. Relationship Violence can occur with individuals of all genders, gender identities, gender expressions and sexual orientation and can occur across racial, cultural and socio-economic identities.

Reporting Individual. An individual who did not experience Prohibited Conduct but who becomes aware of it and reports it to the College.

Respondent. An individual who is alleged to have committed Prohibited Conduct and who becomes a party to the conduct process under Section IV of the Policy.

Responsible Employees. All College employees, including residential advisors and student academic advisors. While residential advisors are Responsible Employees at all times, student academic advisors are Responsible Employees only when receiving disclosures from or about the students whom they advise.  Responsible Employees do not include persons with a statutory privilege (licensed psychologists, mental health counselors, social workers, clergy and designated medical personnel) who are acting within that privileged role, and individuals the College explicitly designates as Confidential Resource Persons.

Retaliation. Any acts or words that constitute intimidation, threats, or coercion because of that person’s: (1) report of Prohibited Conduct; (2) assistance in reporting of Prohibited Conduct; (3) participation in any proceeding under the Policy; or (4) protest of Prohibited Conduct, and that would also deter a reasonable person from reporting or assisting in reporting a violation of the policy, participating in any proceeding under the Policy, or protesting of Prohibited Conduct.

Retaliation does not include minor annoyances or another’s lack of good manners as those actions will not deter a reasonable person from engaging in the process.

Sexual and Gender-Based Misconduct. Sexual Harassment, Sexual Exploitation, Sexual Misconduct by Inducement of Incapacity, Stalking, Relationship Violence, Non-Consensual Sexual Penetration, Non-Consensual Sexual Touching, Disrobing or Exposure, Sexual Misconduct by Incapacity, or any other sexual contact or activity that occurs without Effective Consent.

Sexual Exploitation. Taking non-consensual, unfair, or abusive sexual advantage of another for that individual’s own advantage or benefit, even where that behavior does not constitute other Prohibited Conduct.

Sexual Harassment. Any unwelcome sexual advance, request for sexual favors, or other unwelcome conduct of a sexual nature, whether verbal, physical, graphic, or otherwise. Sexual harassment may occur between opposite sex or same sex individuals and is not limited by gender or gender identity. In general, Sexual Harassment can be divided into two types of conduct:

  • Tangible Employment or Educational Action. This type of Sexual Harassment occurs when the terms or conditions of employment, educational benefits, academic grades or opportunities, living environment or participation in a University activity is conditioned upon, either explicitly or implicitly, submission to or rejection of unwelcomed sexual advances or requests for sexual favors, or such submission or rejection is a factor in decisions affecting that individual’s employment, education, living environment, or participation in a University program or activity.
  • Hostile Environment Harassment. This type of Sexual Harassment exists when the conduct is sufficiently serious (i.e., severe, pervasive, or persistent) so as to deny or limit a person’s ability to participate in or benefit from the University’s programs, services, opportunities, or activities or when such conduct has the purpose or effect of unreasonably interfering with an individual’s employment. In determining whether a hostile environment exists, consideration will be made as to whether a reasonable person in a similar situation would have also perceived the conduct as objectively offensive.

Sexual Misconduct by Incapacity. Any sexual interactions with someone a person knows, or reasonably should know, to be incapacitated by alcohol, drugs, sleep, or other type of incapacitating condition, such that they cannot give Effective Consent.

Sexual Misconduct by Inducement of Incapacity. The inducing of incapacitation through the provision of alcohol or drugs to another individual, with or without that individual’s knowledge, for the purpose of causing impairment or intoxication and taking advantage of that individual’s impairment or intoxication to engage in sexual activities.

Sexual Violence. Any sexual act committed against someone without that person’s Effective Consent.

Stalking.  An intentional course of repeated conduct or behavior over a period of time, directed at a specific person, which causes the person to feel alarm, annoyance, emotional distress or fear and would cause the reasonable person to feel the same and which may include persistent calling, texting or posting on a social networking site as well as in-person conduct, where the content of the messages or the nature of the in-person conduct is gender-based or of a sexual nature.

Stalking may involve individuals who are known to one another or have an intimate or sexual relationship, or may involve individuals not known to one another.

Timely Warning. A warning issued by the Director of Public Safety to the campus community to notify the community of a serious crime that constitutes an ongoing or continuing threat.

Title IX.  Title IX of the Education Amendments of 1972 (20 U.S.C.A. § 1681).

Title IX Coordinator for Staff.  The College Title IX Coordinator for Staff or a designee.

Title IX Director.  The College Director of Title IX Compliance or a designee.

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III. Prohibited Conduct

The following conduct is prohibited under the Policy:

  1. Sexual and Gender-Based Misconduct is prohibited. Such prohibitions include:
  1. Sexual Exploitation;
  2. Sexual Harassment;
  3. Sexual Misconduct by Inducement of Incapacity;
  4. Stalking;
  5. Relationship Violence; and
  6. Any sexual contact or activity that occurs without the Effective Consent of any individual involved including but not limited to:
  1. Non-Consensual Sexual Penetration;
  2. Non-Consensual Sexual Touching, Disrobing or Exposure; and
  3. Sexual Misconduct by Incapacity
  1. Retaliation is prohibited.
  1. Attempting to commit Sexual and Gender-Based Misconduct is prohibited.
  1. Aiding the commission of Sexual and Gender-Based Misconduct is prohibited.

Allegations regarding Other Prohibited Forms of Sex Discrimination, as defined above, are not subject to this Policy unless otherwise determined by the College, through the Title IX Director and in consultation with the Title IX Coordinator for Staff and/or other appropriate College administrators.2

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IV. Process for Resolving Complaints

This section outlines how the College will investigate a report of conduct that could constitute a violation of the Policy and determine what, if any, interim measures and disciplinary action is appropriate.

  1. Reporting Prohibited Conduct. Responsible Employees must, within twenty-four (24) to forty-eight (48) hours, disclose to the Title IX Director incidents of Prohibited Conduct that come to their attention.
  1. Response to reports of Prohibited Conduct. The College will respond to all reports of Prohibited Conduct in a prompt, equitable, and effective manner.
  1. Initial Assessment; Interim Measures. After receiving notice of conduct that could constitute a violation of the Policy, the Title IX Director will take a number of initial steps. These initial steps are not an investigation. Rather, these initial steps will enable the College to assess the need to take any immediate action to address the safety and health needs of the Complaining Individual and the College community and to determine the next steps for investigating the reported conduct and the need for any interim measures. These initial steps may include, but are not limited to, the following:
  1. Contact with the Complaining Individual. The Title IX Director will promptly contact the Complaining Individual and encourage the individual to meet to discuss the nature and circumstances of the reported conduct, review relevant documentation that is available, and address the Complaining Individual’s immediate physical safety and emotional needs, including the need for any interim measures. Examples of possible interim measures may include interim Orders of No Contact, requests for academic adjustments or other accommodations, access to additional support services, changes to living, transportation and working situations, and other actions to address the situations and concerns raised on an interim basis. The Title IX Director will notify the Complaining Individual about the Policy and of the available resources for seeking medical treatment, counseling, spiritual guidance, or other interim measures. These resources can be found on this page: How to Help a Friend. A formal complaint is not necessary to trigger this part of the College’s process.
  1. Disclosures Regarding Law Enforcement. The Title IX Director will notify the Complaining Individual, in appropriate circumstances, about the right to report (or decline to report) the matter to Public Safety and/or to local law enforcement and that a report to law enforcement will not change the College’s duty to respond to the matter but it may briefly delay the timing of any investigation if a law enforcement agency requests that the College delay its process for a reasonable amount of time to allow it to gather evidence of criminal conduct.
  1. Policy on Retaliation. The Title IX Director will inform the Complaining Individual about the policy regarding retaliation. Moreover, the College will respond to any reports of retaliation immediately.
  1. Threat Assessment. The Title IX Director will assess the reported conduct to determine whether the circumstances pose a threat to the health or safety of the College community and warrant the issuance of a Timely Warning, an interim Order of No Contact for any persons, or any other interim protections.
  1. Determining Application of the Policy. If the Title IX Director determines, after speaking with the Complaining Individual, that the reported conduct would not implicate the Policy, the Title IX Director will advise the Complaining Individual of such in writing and, if appropriate, refer the reported conduct to the appropriate administrator for handling consistent with pertinent College policy. If new information is subsequently provided, the decision whether or not to investigate under the Policy will be reevaluated. If the Title IX Director determines the reported conduct could violate the Policy, the Title IX Director will contact the Complaining Individual to discuss that determination. If, at this time, the Complaining Individual requests that the process not move forward, the College, in accordance with Section V(6) of the Policy, will weigh that request and the reasons for it against the College’s obligation to address any risk of harm to the Complaining Individual or other individuals in the community and the nature of the incident or conduct at issue. Mediation is not an option for resolving allegations involving any form of Sexual Violence.
  1. Optional Alternative Resolution Procedure: At any time in this process, a party may request an alternative resolution of a complaint rather than an investigation by contacting the Title IX Director. The Title IX Director will assess the request for alternative resolution against the severity of the alleged violation and the potential risks to campus community members. If the Title IX Director determines that alternative resolution is appropriate, the Title IX Director will notify the parties.  The Title IX Director may designate a College representative to facilitate a dialogue with the parties in an attempt to reach a resolution. A resolution under this section must be approved by the Title IX Director in consultation with other appropriate College administrators. Both parties must voluntarily agree to take part in the Alternative Resolution Procedure and either party may withdraw from the alternative resolution process at any time. The Title IX Director may remove a complaint from the Alternative Resolution Procedure and initiate an investigation at any time that it is deemed appropriate in his or her sole discretion. This Alternative Resolution Procedure will not be available in cases involving allegations of sexual violence.
  1. Investigation. If, during the Initial Assessment, it is determined that the reported conduct implicates the Policy and the Complaining Individual initiates the conduct process or the College otherwise determines that it must move forward, the formal investigation phase will commence and include the steps outlined
  1. Notice of Investigation. The Title IX Director, in consultation with the Title IX Coordinator for Staff, will provide a written notice to the Respondent that will include a description of the allegations, the portions of the Policy that are alleged to have been violated, and any interim measures in place about which the Respondent must be made aware. This written notice does not constitute a finding or a determination of responsibility, but it will re-affirm to both parties that they are not to retaliate against each other, as that term is defined in the Policy.
  1. Procedural Advisors. The Title IX Director, in consultation with the Title IX Coordinator for Staff, will offer the Complainant and the Respondent an opportunity to use a Procedural Advisor. Parties may elect not to utilize a Procedural Advisor, and may select another person to serve as an advisor-of- choice. Parties may also elect to participate in the conduct process without utilizing a Procedural Advisor or an advisor-of-choice. Procedural Advisors or advisors-of-choice may be present during any meeting or interview held pursuant to the Policy.Individuals participating in the conduct process as a Procedural Advisor or as an advisor-of-choice must comply with the Policy in performing their respective roles. Procedural Advisors and advisors-of-choice may not speak on behalf of the individual they are advising while present at any meeting or interview, although they may ask to suspend any meetings or interviews briefly and in a reasonable and non-disruptive manner to provide private consultation related to the matter in progress. They may also ask clarifying questions on a limited basis that do not interfere with the proceeding in question. Procedural Advisors or advisors-of- choice are subject to the same confidentiality expectations applicable to others in attendance. Accommodations, including scheduling of meetings or interviews, will not be made for any advisers if they unduly or unnecessarily delay the process.
  1. Designation of Investigator. The Title IX Coordinator for Staff will serve as an internal investigator to conduct a prompt, fair, equitable and impartial investigation of the reported conduct. At the College’s discretion, an external investigator may be assigned in place of the internal investigator. The College may also exercise discretion in assigning an additional external investigator to conduct the investigation with the College’s internal investigatorAll investigators – internal or external – will be qualified and trained individuals employed by the College or engaged by the College for the purpose of conducting investigations under the Policy. If an internal Investigator other than the Title IX Coordinator for Staff is assigned, the Title IX Director will provide the parties with the name of the Investigator. As soon as possible, but no later than three (3) business days after receiving notice of the identity of the investigator, the parties should inform the Title IX Director (in writing) of any conflicts or potential conflicts of interest with regard to the selected investigator. The Title IX Director will consider the nature of the conflict and determine if different individuals should be assigned as Investigator. The Title IX Director’s decision regarding any conflicts is final.
  1. Nature of the Investigation. The investigation will include separate interviews with the Complainant, the Respondent, and any witnesses whom the investigator believes will provide necessary and relevant information. The investigation may include the review of documentation or other items relevant to the reported conduct. The investigator will provide the parties with written notice of meetings at which their presence is required. The investigator will provide a statement to each party participating in an interview that explains the applicable rules of privacy. The investigator will also explain that the Director of Title IX Compliance will be available to provide support should a party wish to discuss anything learned during the course of the investigation or have any questions regarding the level of privacy expected of both parties.
  1. The Parties’ Identification of Potential Witness(es) and Documentation. The parties have the opportunity (and are expected) to provide the investigator with the identities of potential witnesses who have specific information about the reported conduct and with whom they would like the investigator to speak. The parties also have the opportunity (and are expected) to provide the investigator any documentation or other evidence they would like to be considered. All information described in this section must be presented to the investigator in writing and include a brief description as to how the persons, documents, and/or evidence are relevant to the reported conduct. This information must be provided to the investigator during the investigation phase and without delay upon becoming aware of it. The investigator will exercise discretion in their determination of what information to consider and which potential witnesses identified by the parties can provide relevant information to the investigation.
  1. Investigative Report. At the conclusion of the investigation, the investigator will prepare an Investigative Report, which should include a summary of the factual information presented during the investigation and the determination of responsibility.
  1. Determination of Responsibility. The investigator will determine, using use the preponderance of the evidence standard, if a Respondent is responsible for the alleged violation(s) of the Policy.
  1. Sanctions. If the investigator determines the Respondent is responsible for violation(s) of the Policy, the investigator will determine the sanction(s) to be imposed unless the investigator is external, in which case the Title IX Coordinator for Staff will decide sanctions based on the Investigative Report. Pertinent records of previous disciplinary action may be used in determining an appropriate sanction. Sanctions may include but are not limited to the following: termination; suspension; probation; reprimand; warning; restitution; education/counseling; Order of No Contact; loss of privileges, restriction from or loss of leadership opportunity or positions in activities.
  1. Notice. The Title IX Coordinator for Staff will promptly present the determination to the Complainant and Respondent.  The Title IX Director will send written notice of the same to the Complainant and Respondent. Notice to the Respondent will include the sanctions. Notice to the Complainant will include only the sanctions that impact that individual.3
  1. Appeals of Decisions. At the conclusion of the investigation and determination phase, either party may file an appeal. The appeal process includes the steps outlined
  1. Filing an Appeal. Within five (5) business days of receiving written notice of the determination on responsibility and sanctions, either the Complainant or the Respondent may appeal the decision by submitting to the Title IX Director a letter stating why the party requesting the appeal believes the determination of responsibility and/or the sanctions were inappropriate.
  1. Content for Appeal. A party may appeal only on the following grounds:
  1. newly discovered material information that was not known to the appellant party during the investigation and which likely would have changed the finding of responsibility or the sanction imposed had it been available; or
  1. substantial procedural error that materially prejudiced the appellant party.

The party submitting the appeal must set forth in detail the grounds for review and must attach all materials that the party wishes to have considered in the appeal process. The Title IX Director will provide a copy of the appeal submitted by one party to the other party, usually within three (3) business days.

  1. Appellate Officer. The Appellate Officer will decide the merits of any appeal and in so doing, may consult with the investigator and any other individual that the Appellate Officer deems appropriate. The purpose of the appeal is not to rehear the case; rather, it is to determine if there is sufficient information presented to allow a reconsideration of the investigator’s decision.
  1. Enforcement of Decision. Any action assessed or recommended by the investigator may be enforced, in whole or in part, pending the outcome of the appeal at the sole discretion of the Title IX Director including a removal or suspension.
  1. Appeal Determinations. The Appellate Officer will review the appeal and render a decision usually within ten (10) business days.

The Appellate Officer may affirm all or part of the decision (which includes the sanction, as well as the determination of responsibility) or may refer the matter to the investigator for further consideration or investigation.

If the Appellate Officer initially determines, in the Appellate Officer’s sole discretion, that any part of the decision should be further considered or investigated, the Appellate Officer will convey that, in writing, to both parties within three (3) business days of reaching this initial determination. The communication to the parties will briefly state the reason(s) for the potential need for further consideration or investigation so that the non-moving party can understand the initial determination.  The non-moving party will then have five (5) business days to provide a written response that will be considered before issuing a final decision to the parties with regard to the appeal.

If the matter is referred back to the investigator, the Appellate Officer will provide specific instructions with the referral. In the event of a referral, the Appellate Officer may mandate such further proceedings as the Appellate Officer deems appropriate under the circumstances, consistent with the Policy.

The decision of the Appellate Officer will be provided in writing and is final. The Title IX Director will inform the parties simultaneously and in writing of the outcome of the appeal.

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V. Additional Matters

  1. Request for Delay of Proceedings. If the Complainant, the Respondent, or law enforcement agencies request that the College conduct proceeding be delayed because the conduct in question is also being addressed in a civil or criminal court, the College will review the request, but it retains the right to conduct the processes described in the Policy before, after, or during the same time period as the civil or criminal case, and to implement appropriate action (including but not limited to interim Orders of No Contact, removal from campus, interim removals, or suspensions).
  1. Duty of Honesty. All parties and witnesses are obligated to be completely honest during the course of the entire process set forth in the Policy. Any person who knowingly makes a false statement – either explicitly or by omission – in connection with any part of the process may be subject to separate College disciplinary action.
  1. Duty of Cooperation. All parties and witnesses are obligated to cooperate with the Title IX Director and any persons charged with implementing the Policy. Any person who knowingly interferes with the actions taken to implement the reporting, investigation, or resolution of matters under the Policy may be subject to separate College disciplinary action.
  1. Prohibitions. Neither party will be permitted to directly question or cross-examine the other party during the investigation. Moreover, the investigator generally will not consider information related to either party’s character or sexual history outside of the conduct in question. However, where there is evidence of pattern of conduct similar in nature by the Respondent, either prior to or subsequent to the conduct in question, regardless of whether there has been a finding of responsibility, this information may be deemed relevant and probative to the investigator’s report and determination of responsibility or sanction. In those instances, the Title IX Director will determine whether the previous incident was substantially similar to the conduct cited in the report and/or indicates a pattern of behavior and substantial conformity with that pattern by the Respondent. The Title IX Director may choose to provide this information to the investigator, with appropriate notice to the parties. Additionally, either party or an identified witness may seek to provide to the investigator: (1) information concerning the prior relationship of the parties; or (2) information indicating that a person other than the Respondent is responsible for the misconduct alleged. The investigator will review any such information and determine if it is relevant and probative to the investigator’s report and determination of responsibility or sanction. In no case will the sole fact of a current or previous consensual dating or sexual relationship between the parties imply consent to the reported conduct or preclude a finding of responsibility for a Policy violation.
  1. Amnesty for Students Reporting Misconduct by Staff. The College encourages reporting under the Policy and seeks to remove barriers to reporting. The College generally will not hold a student who reports conduct or is a witness during an investigation under the Policy accountable for disciplinary violations of the College’s Community Standards prohibiting use of drugs or alcohol. Under limited circumstances, a person who reports conduct under the Policy may be held accountable for his or her own misconduct if, in the College’s discretion, it is determined that the behavior placed the health and safety of any person at risk, or if it created a danger to the College community. The College retains the right to require students to attend counseling or drug/alcohol related courses even in circumstances in which disciplinary conduct will not be pursued under the Policy.
  1. Respect for Privacy. The College values the privacy of individuals involved in the reporting, investigation, and/or resolution of matters subject to the Policy and will balance these privacy concerns with the College’s legal obligations.
    There are situations in which it may be necessary for an institution to override a request for privacy in order to meet its Title IX obligation. In the event circumstances result in the College overriding a request for privacy or confidentiality to meet its Title IX obligation, the College will do so with the utmost sensitivity and respect for the circumstances and the individuals involved.The factors considered in determining whether it can grant a request for privacy include circumstances that suggest there is an increased risk of the alleged perpetrator committing additional acts of Sexual Violence or other violence (e.g., whether there have been other Sexual Violence complaints about the same alleged perpetrator, whether the alleged perpetrator has a history of arrests or records from a prior school indicating a history of violence, whether the alleged perpetrator threatened further Sexual Violence or other violence against the student or others, and whether the Sexual Violence was committed by multiple perpetrators), circumstances that suggest there is an increased risk of future acts of Sexual Violence under similar circumstances (e.g., whether the student’s report reveals a pattern of perpetration, whether the Sexual Violence was perpetrated with a weapon, the age of the student subjected to the Sexual Violence, and whether the school possesses other means to obtain relevant evidence (e.g., security cameras or personnel, physical evidence).
  1. Special Situations. In limited circumstances, when the safety of the College community is at risk, if the material facts are undisputed, if there are extenuating circumstances involving either of the parties, or if the Title IX Director, in consultation with appropriate administrators, determines it is in the best interest of the College and/or the community, the College retains the right to determine, in its sole discretion, if it will address a report of conduct that falls under the Policy administratively and outside of the process described in the Policy. Whenever the College determines that it will exercise this provision, its actions will be in accord with Title IX and it will stay true to the processes described in the Policy to the extent possible.  The College will also clearly explain to the parties any alternate processes it will take in the given situation.

1 Reports regarding Other Prohibited Forms of Sex Discrimination will generally be addressed under the College’s Unlawful Discrimination Policy in the Staff Handbook, a copy of which can be accessed here: https://wheatoncollege.edu/about-wheaton-college/offices-services/human-resources/info/. For more information or to report such discrimination, please contact Omaira Roy, Title IX Coordinator for Staff, at 508-286-8206, roy_omaira@wheatoncollege.edu, or in person at her office, Hebe 105.

2 Reports regarding Other Prohibited Forms of Sex Discrimination will generally be addressed under the College’s Unlawful Discrimination Policy in the Staff Handbook, a copy of which can be accessed here: https://wheatoncollege.edu/about-wheaton-college/offices-services/human-resources/info/. For more information or to report such discrimination, please contact Omaira Roy, Title IX Coordinator for Staff, at 508-286-8206, roy_omaira@wheatoncollege.edu, or in person at her office, Hebe 105.

3 The College will comply with 34 CFR 668.46(k)(3)(IV) with regard to notice in cases involving dating violence, domestic violence, sexual assault, or stalking.

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