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Northwest Nazarene University

Statement of University Policy

Title IX Compliance

THE FOLLOWING POLICY IS OFFICIALLY ADOPTED ON AUGUST 2014 BY NORTHWEST NAZARENE UNIVERSITY, BY ACTION OF THE PRESIDENT.

It shall be the policy of Northwest Nazarene University (“University”) to comply with the requirements of Title IX of the Education Amendments of 1972 (“Title IX”) and it is further the policy of the University that such compliance shall be consistent with the guidance as set forth in the Letter to “Colleague” issued by the U.S. Department of Education, Office for Civil Rights, April 4, 2011, signed by Russlyn Ali, Assistant Secretary for Civil Rights, and the document entitled “Questions and Answers on Title IX and Sexual Violence” issued by the U.S. Department of Education, Office of Civil Rights, April 29, 2014. Further, it shall be the policy of the University to extend protections and processes called for by such authority (to the extent appropriate) to all members of the immediate University community, including students, faculty and staff. Implementation by the University of such policy shall include the following:

  1. The University shall appoint a Title IX Coordinator (“Coordinator”). The Coordinator shall be a part-time compensated position which shall be filled by a person having skills in matters of compliance, investigation, training, and policy. The Coordinator shall be a person positioned to deal with staff, faculty and students. The Coordinator shall report directly to the President of the University, and shall consult with the General Counsel of the University. The Coordinator shall be provided a closed office (not an open cubical) in which confidential communications, reports and complaints can occur in an atmosphere of safety, security and confidentiality. The responsibilities of the Title IX Coordinator shall be as follows:

    • To receive any reports of violation of this policy or of any incident involving conduct prohibited hereby, including any complaints.

    • To conduct (with the use of any appropriate assistance) an initial investigation of any such alleged incident and to make and refer a report concerning the alleged incident (containing evidence and information obtained in the investigation, including witness statements, documents, interview notes and other information) to the appropriate decision-maker (pursuant to the appropriate Manual or Handbook) for a determination as to disposition.

    • To ensure that any and all investigation report includes, to the best of the Coordinator’s ability, a fair and balanced recitation of evidence, including the perspective and belief of both accuser and accused.

    • To assist the decision-maker in any further investigation.

    • To advise the decision-maker as to required elements of this Title IX Policy.

    • To ensure that any complainant and any alleged violator are advised of rights pursuant to this policy and to ensure that both are advised as to the outcome of the process.

    • To accomplish training as this policy and other policies adopted pursuant hereto on an on-going basis of faculty, staff and students.

    • To cause to be conducted any environmental scan or study required by this policy.

    • To ensure that all remedial measures determined in required post-incident evaluations are put forward as recommendations to the President and the General Counsel.

  2. The University shall adopt appropriate policies concerning reports, complaints, adjudication, process, disposition, discipline, remediation, and further policies to prevent violations concerning matters of sexual violence as defined in the authority recited above. Such polices may be integrated in other University Discipline polices, and shall be included in the Faculty Policy Manual, the University Staff Policy Manual, and the Student Handbook (collectively the “Manuals”). To the extent appropriate, such policies and processes shall be consistent across the three sectors (faculty, staff & students). Decisions and determinations regarding violation and disciplinary response shall be made according to and by the individuals set forth in the policies in such Manuals and pursuant to the processes provided therein. All rights of appeal set forth in those Manuals shall be applicable to matters resulting from this Title IX policy.

  3. The University President and all University Vice Presidents shall read the authority recited above (the Letter and the Questions and Answers) and shall become familiar with the contents of such authority.  Further, the Coordinator (with the assistance of the General Counsel) shall provide training to the President and Vice Presidents regarding the requirements of Title IX and the policy adopted by this Statement of Policy.

  4. In the event that a disciplinary proceeding shall occur pursuant to the provisions of the Manuals, after the conclusion of the matter the Coordinator shall evaluate the matter and determine whether any steps should be taken to prevent the recurrence of a similar matter in the future and to correct and effects on the complainant. The Coordinator shall make any resulting recommendations to the President or a Vice President (as appropriate) for consideration.

  5. The Coordinator shall also evaluate all matters to determine whether any protective interim measures ought to be taken to provide protection to the persons making a complaint or the person who is the target of sexual violence as defined in the Manuals. Any resulting recommendations shall be referred to the Vice President responsible for the pending matter, and that Vice President shall implement any protective interim measures that are called for. Possible interim or long-term remedial measures may be addressed to the needs of the complainant, or to University compliance with Title IX.

  6. Remedial measures pursuant to the foregoing sections may include but are not limited to providing escorts, ensuring that complainant and perpetrator are not assigned to the same class, moving residence hall assignments, counseling services, medical services, academic support or tutoring, academic adjustments including retaking of courses or permitted withdrawals, review of disciplinary or academic actions against the complainant, or other remedial measures as appropriate. Preventative university-wide remedial measures might include but not be limited to measures identified in the authority recited above. In the event that the Coordinator makes a recommendation, the University shall respond in a manner consistent with this Statement of Policy.

  7. Within 180 days of the adoption of this Statement of Policy, the Coordinator shall cause a survey and environmental scan to be conducted to determine any factors that ought to be known to the University in order to implement this Policy and ensure the prevention of sexual violence as defined in the Manuals. The results of such survey and scan shall be reported to the President, together with any recommendations that arise from the survey and scan. In the event that the Coordinator makes a recommendation, the University shall respond in a manner consistent with this Statement of Policy. A survey and environmental scan as described herein shall be conduct at least once every five years or at lesser intervals if the University perceives a need to evaluate the environment in this manner.

  8. The Coordinator shall within 180 days of the adoption of this Statement of Policy design and implement an on-going, continual and regular program of training regarding rights, definitions, processes and other aspects of this Statement of Policy and the relevant sections of the Manuals. The training shall occur in cooperation with the Office of Human Resources and shall reach to all Faculty, Staff and Students, as appropriate, and shall be included in new employee training. The Vice Presidents shall cooperate in facilitating and making mandatory attendance at any such training. The Coordinator shall cause a record and proof of attendance to be created for each employee or student attending training. When designing training content, the Coordinator shall consider subjects identified in the authority recited above.

  9. The Coordinator shall cause to be continually and regularly published a notice of nondiscrimination as described in the referenced Dear Colleague Letter.

  10. The Coordinator shall cause to be published to all Faculty, Staff and Students notice of procedures and the place to which complaints may be filed as described in the Dear Colleague Letter, and shall cause such notice to be continuously and regularly given and maintained.

  11. If the Coordinator has cause to believe that an incident has occurred that violates the prohibitions contained in the Manuals and Title IX, the Coordinator shall investigate such incident and shall cause to be initiated a disciplinary proceeding as described in the respective Manuals. The appropriate Manual and disciplinary proceeding shall be determined by status of the person alleged to have committed an act of harassment or similar Title IX violation. The alleged violator is either a graduate student or an undergraduate student, discipline shall proceed pursuant to the Student Handbook. If the alleged violator is staff or administration, discipline shall proceed pursuant to the University Staff Policy Manual. If the alleged violator is faculty, discipline shall proceed pursuant to the Faculty Policy Manual.

  12. When the Coordinator commences an investigation, such investigation phase will be completed within sixty (60) days of the receipt of the complaint or the date on which the University becomes aware of a suspected violation of this policy. Within ten (10) days of the conclusion of the investigation, the Coordinator shall provide information acquired in the investigation to the complainant, any accused, and the appropriate University decision-maker pursuant to the Manuals.

  13. An employee of the University shall promptly report to the Coordinator any information (including any complaint) which he or she obtains by any means which indicates that a violation of this policy might have occurred.

  14. The Coordinator shall recommend any reports to the Office of Civil Rights as may be required by the authority recited above. Such recommendations shall be submitted to the President and to the General Counsel. The University will comply with mandatory reporting requirements.

  15. The Coordinator shall, in consultation with the General Counsel, report any alleged violations of criminal law pursuant to the Idaho Code to appropriate governmental and law enforcement officials.

  16. The University shall provide reasonable resources as necessary to effectuate this policy.
NNU's Title IX Coordinator is Mollie Sweet, Ph.D. She can be contacted by emailing title9@nnu.edu or by calling (208) 467-8421.