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Title IX Compliance Coordinators Policy

The University prohibits discrimination and harassment against applicants, students, faculty, or staff on the basis of race, religion, national or ethnic origin, age, sex, sexual orientation, gender identity, gender expression, disability, status as a veteran or any classification protected by local, state or federal law.

The University is committed to ensuring compliance with Title IX of the Education Amendments of 1972 (hereinafter "Title IX"), which prohibits discrimination on the basis of sex in any education program or activity receiving federal financial assistance.  The purpose of this policy is to identify the individuals responsible for overseeing and coordinating the University's compliance with Title IX (the "Title IX Coordinators") and to set forth the roles and responsibilities of the Title IX Coordinators.

Scope

This policy applies to the University of Richmond (the "University") and all of its schools and departments.

Policy

A. General Policy

The University shall appoint one individual to serve as the Title IX Coordinator and four individuals to serve as Deputy Title IX Coordinators. Such appointments shall be made by the President of the University and individuals appointed as Title IX Coordinators shall continue to serve in such roles until they resign or are replaced by the President.  The Title IX Coordinators shall have the responsibilities set forth in this policy.

B. Title IX Coordinator and Director of Compliance

The Title IX Coordinator and Director of Compliance shall have primary responsibility for coordinating the University’s efforts to comply with and carry out its responsibilities under Title IX. 

1. Designation. The University's Title IX Coordinator and Director of Compliance shall serve as the Title IX Coordinator.   The President of the University may change this designation from time to time.

2. Responsibilities. The Title IX Coordinator’s responsibilities shall include the following:

  • Overseeing the development and implementation of all University policies designed to foster and enhance compliance with Title IX;
  • Overseeing the complaint and grievance processes relating to reports or allegations of sex discrimination, harassment and sexual misconduct for the campus community;
  • Ensuring the prompt and thorough investigation of any complaint or allegation of discrimination on the basis of sex, sexual harassment, sexual misconduct, or other complaints relating to Title IX (hereinafter “Title IX complaints”);
  • Establishing processes to identify and address patterns or systemic problems that may arise during the investigation of a Title IX complaint;
  • Coordinating the compliance activities of all Deputy Title IX Coordinators;
  • Ensuring that the University has in place all policies and procedures reasonably necessary to foster compliance with Title IX, including, but not limited to grievance procedures providing for the prompt and equitable resolution of student and employee Title IX complaints;
  • Ensuring that the University notifies its students, faculty, and staff of the name and contact information of all Title IX Coordinators;
  • Ensuring that the University notifies its students, faculty, and staff that it does not discriminate on the basis of sex and how to contact the Title IX Coordinators to file Title IX complaints or to ask questions regarding Title IX;
  • Ensuring that appropriate school officials, including members of the University’s police department, receive training regarding Title IX, including reporting and responding to possible incidents of discrimination, sexual harassment, or sexual misconduct;
  • Meeting with students, faculty or staff members who wish to file a Title IX complaint or raise a question relating to Title IX;
  • Working collaboratively with other University officials to assess the campus climate regarding Title IX issues through surveys and other instruments and to analyze collected data; and
  • Providing periodic updates to the President of the University, the Board of Trustees Audit and Compliance Committee, and the University’s Compliance Oversight Committee regarding the University’s compliance with Title IX and the initiatives underway to prevent, detect or remedy possible violations of Title IX.

In fulfilling his or her obligations, the Title IX Coordinator and Director of Compliance may delegate certain responsibilities or tasks to the Deputy Title IX Coordinators and to other University employees, as warranted.

C. Deputy Title IX Coordinators

1. Designation.  The Associate Vice President for Human Resources is designated as the Deputy Title IX Coordinator for Title IX complaints involving faculty and staff.  The Associate Dean for Westhampton College and the Associate Dean for Richmond College/Coordinator for Substance Abuse Prevention are designated as the Deputy Title IX Coordinators for Title IX complaints involving students.  The University also designates the Associate Athletic Director/Senior Women Administrator as Deputy Title IX Coordinator for Athletics.  The Title IX Coordinator and Director of Compliance may designate one or more interim Deputy Title IX Coordinators in the absence of the individuals listed above.  Additionally, the Title IX Coordinator and Director of Compliance may designate one or more Title IX investigators to assist the Title IX Coordinators in investigating Title IX complaints.

2. Responsibilities.  The Deputy Title IX Coordinators shall assist the Title IX Coordinator with fulfilling the responsibilities outlined in Section B(2) of this policy. In addition, the Deputy Title IX Coordinators shall have the responsibilities set forth below.

a. Deputy Title IX Coordinator for Faculty and Staff Title IX Complaints.  The Deputy Title IX Coordinator for Faculty and Staff Title IX Complaints shall have responsibility for:

  • Ensuring the prompt and thorough investigation of any Title IX complaint or question involving a faculty or staff member at the University; 
  • Establishing processes to identify and address patterns or systemic problems that may arise during the investigation of a Title IX complaint from a faculty or staff member;
  • Ensuring that the University has in place policies and procedures reasonably necessary to foster compliance with Title IX, including, but not limited to grievance procedures for Title IX complaints from faculty and staff members;
  • Ensuring that appropriate school officials receive training regarding Title IX, including reporting and responding to possible incidents of discrimination or sexual harassment;
  • Implementing educational programs and communication plans designed to inform faculty and staff of their rights under Title IX and how to file a Title IX complaint; and
  • Meeting with faculty and staff members who wish to file a Title IX complaint or raise a question relating to Title IX.

b. Deputy Title IX Coordinators for Student Title IX Complaints.  The Deputy Title IX Coordinators for Student Title IX Complaints shall have responsibility for:

  • Ensuring the prompt and thorough investigation of any Title IX complaint or question from a student at the University;
  • Establishing processes to identify and address patterns or systemic problems that may arise during the investigation of a Title IX complaint from a student;
  • Ensuring that the University has in place policies and procedures reasonably necessary to foster compliance with Title IX, including, but not limited to grievance procedures for Title IX complaints from students;
  • Ensuring that appropriate school officials, including members of the Student Development Division, receive training regarding Title IX, including reporting and responding to possible incidents of discrimination or sexual harassment;
  • Implementing educational programs and communication plans designed to inform students of their rights under Title IX and how to file a Title IX complaint; and
  • Meeting with students who wish to file a Title IX complaint or raise a question relating to Title IX.

c. Deputy Title IX Coordinator for Athletics. The Deputy Title IX Coordinator for Athletics shall have primary responsibility for the following:

  • Implementing policies and procedures designed to foster the University’s compliance with Title IX regulations relating to athletics, specifically 34 C.F.R. § 106.41;
  • Monitoring participation opportunities, operating budgets, coaching staff, and athletic benefits within the University’s varsity athletic program to ensure continued compliance with Title IX;
  • Investigating Title IX complaints relating to athletics; and
  • Meeting with students, faculty, or staff who have a Title IX complaint or question relating to athletics.
D. Training for Coordinators

The Title IX Coordinators shall attend appropriate training sessions relating to Title IX compliance on a regular basis.  Such training shall include the following:

  • Overall compliance with Title IX;
  • What constitutes sexual misconduct, including sexual violence; 
  • How to administer the University’s non-discrimination and sexual misconduct policies, student conduct policies and procedures and faculty and staff conduct policies and procedures;
  • How to investigate reports of sexual misconduct, including sexual violence;
  • How to effectively work with and interview people who may have been subject to sexual misconduct;
  • Particular types of conduct that would constitute sexual misconduct, including same-sex sexual violence;
  • The proper standard of review for sexual misconduct complaints (preponderance of the evidence);
  • Information on consent and the role drugs or alcohol can play in the ability to consent;
  • The effects of trauma, including neurobiological change; and
  • Cultural awareness training regarding how sexual violence may impact students differently depending on their cultural backgrounds.