By Ruth Steinhardt
The Board of Trustees of the George Washington University approved on Friday a unified policy that puts in place a comprehensive review process for Title IX issues, which include sexual and gender-based harassment, sexual assault, sexual exploitation, intimate partner violence, stalking and retaliation. All processes related to these issues will now be administered by the Title IX Office.
Also approved was a separate policy on prohibited relationships with students, which provides guidance on prohibited sexual or amorous relationships, including between undergraduate or graduate students and faculty, administrators or other individuals, such as staff. It was based upon a draft policy crafted by the Faculty Senate’s Committee on Professional Ethics and Academic Freedom.
The new Sexual and Gender-Based Harassment and Interpersonal Violence Policy will be implemented July 1, 2018.
The new policy:
- presents the university’s policies and procedures applicable to all forms of sexual and gender-based harassment, interpersonal violence and retaliation in one unified document
- adopts unified procedures for resolving all complaints of prohibited conduct, by and against students, faculty, staff and all other persons to whom the policy applies
- encourages prompt reporting of incidents by providing to persons who make a good faith report of prohibited conduct, amnesty for other conduct in which they are engaged (at or near the time of the reported incident) that might constitute violations of the Code of Student Conduct
- identifies the categories of GW employees who are considered “responsible employees” under Title IX, and therefore required to report any incident of prohibited conduct of which they become aware to the Title IX Office
- lists confidential resources, including medical professionals, and the circumstances under which confidentiality can be expected
“This policy unifies our Title IX procedures and policies for all of our GW community members and places them all under the aegis of the Title IX Office,” said Caroline Laguerre-Brown, vice provost for diversity, equity and community engagement. “It also provides additional detail about the processes involved and the preparation that goes into the decision-making around those processes and gives more detailed guidance on questions that individuals may have as they are considering what is the best way for them to come forward.”
The university previously had three sets of policies covering Title IX issues: the Sexual Harassment and Sexual Violence Policy, the Threats and Acts of Violence Policy, and relevant sections of the Code of Student Conduct. These policies were enacted at different times, prompted by different regulatory requirements and overseen by different offices.
All complaints of prohibited conduct will now be covered by this new comprehensive policy and addressed by the Title IX Office.
Some of the most important aspects of the policy are its detailed explanations of university procedures, resources and terminology. For instance, the terms “consent” and “incapacitation” are precisely defined.
“Those are critically important concepts, and we want to make sure that students understand the definitions we use to analyze and make decisions about the facts and circumstances of incidents brought before the Title IX Office,” Ms. Laguerre-Brown said.
The new policy also places responsibility for any Title IX investigation in the hands of a professional investigator, who will be responsible for collecting, assessing and synthesizing evidence. The complainant and respondent in any investigation will have the opportunity to be part of the fact-gathering process, and both will have access to evidence that will be used to make a decision about their case.
“It’s comforting to know that trained Title IX investigators will be helping survivors navigate what can be a very challenging, scary and long process,” said senior Kalpana Vissa, co-president of GW Students Against Sexual Assault, who also sits on the Sexual Assault Prevention and Response Committee. “To have someone who understands the policy and whose job it is to support survivors is going to make a world of difference.”
Many individuals within the campus community, including SASA members, contributed to the university’s broad effort to review and improve the university’s Title IX policies and procedures. The review began in the summer of 2017, when GW retained a team of Title IX experts from the law firm Cozen O’Connor.
Outgoing Student Association President Peak Sen Chua said “improving and enhancing Title IX policies” was among the SA’s top priorities during his administration. “[Student] advocacy and partnership were critical to the university’s approach because we expressed and affirmed our community's collective responsibility to make our university a safer place,” he said.
Ms. Vissa said that her “hope is that this comprehensive policy will make it easier on survivors to report, and that they will have adequate support systems.”
“We [at SASA] hope that the language of the policy is easily understood by all students and that students feel comfortable reporting to the university,” she said.