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Nondiscrimination Policy

1.0 POLICY: Equal Opportunity, Harassment and Nondiscrimination

Applicable Scope

Oklahoma City University (the “University”) affirms its commitment to promote the goals of fairness and equity in all aspects of the educational enterprise. All policies included herein are subject to resolution using Oklahoma City University’s Equity Resolution Process (ERP) as detailed below.  This policy applies to all University faculty, staff and students. This policy also applies to third parties (such as campus visitors or vendors) who may have contact with members of the University community either on the University’s campus or at other University events and programs. When the responding party is a

member of the Oklahoma City University community, the ERP is applicable regardless of the status of the reporting party who may be a member or non-member of the campus community, including students, student organizations, faculty, administrators, staff, guests, visitors, campers, etc.

Title IX Coordinator

The Chief Human Resources Officer serves as the Title IX Coordinator and ADA/504 Coordinator and oversees implementation of Oklahoma City University’s Nondiscrimination Policy and Equity Resolution Process. The Title IX Coordinator directs the Title IX Resource Team and acts with independence and authority free of conflicts of interest. To raise any concern involving a conflict of interest by the Title IX Coordinator, contact the University President at (405) 208-5032. To raise concerns regarding a potential conflict of interest with any other administrator involved in the ERP, please contact the Title IX Coordinator.

Inquiries about and reports regarding this policy and procedure may be made internally to:

Ms. Joey Croslin
Title IX Coordinator
Administrative Building Suite 205
Telephone: (405) 208-5075
Email:  jcroslin@okcu.edu 

Ms. Amy R. Ayres
Deputy Title IX Coordinator
University Center, Suite 257
Telephone: (405) 208-7900
Email:  aayres@okcu.edu

Inquiries may be made externally to:

Office for Civil Rights (OCR) U.S. Department of Education
400 Maryland Avenue, SW Washington, DC 20202-1100
Customer Service Hotline #: (800) 421-3481
Facsimile: (202) 453-6012
TDD#: (877) 521-2172
Email:  OCR@ed.gov
Web: www.ed.gov/ocr

Kansas City Office
U.S. Department of Education
One Petticoat Lane
1010 Walnut Street, Suite 320
Kansas City, MO 64106
Telephone: (816) 268-0550
Facsimile: (816) 268-0559
Email:  OCR.KansasCity@ed.gov

Equal Employment Opportunity Commission (EEOC) Oklahoma City Area Office
215 Dean A McGee Avenue
Suite 524
Oklahoma City, OK  73102
Telephone: (800) 669-6820
Facsimile: (405) 231-4140
ASL Video: (844) 234-5122 

Reporting Discrimination

Reports of discrimination, harassment, and/or retaliation may be made using any of the following options. There is no time limitation on the filing of allegations. However, if the responding party is no longer subject to Oklahoma City University’s jurisdiction, the ability to investigate, respond and provide remedies may be more limited:

  1. Report directly to the Title IX Coordinator or Deputy Title IX Coordinator

Ms. Joey C. Croslin
Title IX Coordinator
Administration Building
Suite 205 (405) 208-5075
jcroslin@okcu.edu

Ms. Amy R. Ayres
Deputy Title IX Coordinator
University Center
Suite 257
(405) 208-7900
aayres@okcu.edu

  1. Report online, using the reporting form posted here.
  2. Report to a University administrator or member of the Title IX Resource Team and/or
  3. Report using the using the Campus Conduct Hotline (866) 943-5787

If a reporting party would like the details of an incident to be kept confidential, the reporting party may speak with:

  • On-campus licensed professional counselors and staff
  • On-campus health service providers and staff
  • On-campus clergy, acting in their capacity as clergy
  • Off-campus (non-employees):


    • Licensed professional counselors
    • Local rape crisis counselors
    • Domestic violence resources
    • Local or state assistance agencies
    • Clergy/Chaplains

All reports made to the University are acted upon promptly. Every effort is made by the University to preserve the privacy of reports and information is shared only with individuals with a “need to know.” Reports may also be anonymous; however, this may impact the University’s ability to effectively proceed. Anonymous reports will be investigated to determine if remedies can be provided. Additionally, nearly all employees of Oklahoma City University are designated as mandated reporters and will share a report with the Title IX Coordinator promptly. Confidentiality and mandated reporting are addressed more specifically later in this policy. Reports of misconduct or discrimination committed by the Title IX Coordinator should be reported to the University President at (405) 208-5032. 

Jurisdiction

This policy applies to behaviors that take place: 

  • on the campus;
  • at Oklahoma City University-sponsored events; and
  • may also apply off-campus; and
  • to actions online. 

The jurisdiction of this policy may apply to off-campus and/or online conduct when the Title IX Coordinator determines that the off-campus and/or online conduct affects a substantial University interest. A substantial University interest is defined to include:

  1. any action that constitutes a criminal offense as defined by law. This includes, but is not limited to, single or repeat violations of any local, state or federal law;
  2. any situation where it appears that the responding party may present a danger or threat to the health or safety of self or others;
  3. any situation that significantly impinges upon the rights, property or achievements of self or others or significantly breaches the peace and/or causes social disorder; and/or
  4. any situation that is detrimental to the educational interests of Oklahoma City University.
1.1 Oklahoma City University Policy on Nondiscrimination

Oklahoma City University adheres to all federal and state civil rights laws prohibiting discrimination in private institutions of higher education. The University will not discriminate against any employee, applicant for employment, student or applicant for admission on the basis of race, religion, color, sex, pregnancy, political affiliation, religion, creed, ethnicity, national origin (including ancestry), citizenship status, physical or mental disability, age, marital status, sexual orientation, gender, gender identity, gender expression, veteran or military status (including special disabled veteran, Vietnam-era veteran, or recently separated veteran), predisposing genetic characteristics, domestic violence victim status or any other protected category under applicable local, state or federal law, including protections for those opposing discrimination or participating in any resolution process on campus or within the Equal Employment Opportunity Commission or other human rights agencies.

This policy covers nondiscrimination in employment and access to educational opportunities. Therefore, any member of the campus community who acts to deny, deprive or limit the educational and/or employment access, benefits and/or opportunities of any member of the campus community, guest, or visitor on the basis of their actual or perceived membership in the protected classes listed above is in violation of this policy.  When brought to the attention of the University, any such discrimination will be appropriately addressed and remedied by the University according to the Equity Resolution Process described below. Non-members of the campus community who engage in discriminatory actions within University programs or on University property are not under the jurisdiction of this policy, but can be subject to actions that limit their access and/or involvement with University programs, services, and property as the result of their alleged misconduct. All vendors serving Oklahoma City University through third-party contracts are subject to these policies and procedures, to which their employer has agreed to be bound.

1.2 Oklahoma City University Policy on Accommodation of Disabilities

Oklahoma City University is committed to complying with the Americans with Disabilities Act of 1990 and the ADA Amendments Act of 2008 (hereafter referred to collectively as “ADA”) and Section 504 of the Rehabilitation Act of 1973, which prohibit discrimination against qualified persons with disabilities, as well as other federal and state laws pertaining to individuals with disabilities. Under the ADA, a person has a disability if they have a physical or mental impairment that substantially limits a major life activity. The ADA also protects individuals who have a record of a substantially limiting impairment or who are regarded as disabled by the institution whether qualified or not.  A substantial impairment is one that significantly limits or restricts a major life activity such as hearing, seeing, speaking, breathing, performing manual tasks, walking or caring for oneself.

The Chief Human Resources Officer has been designated as the ADA/504 Coordinator responsible for coordinating efforts to comply with these disability laws, including investigation of any allegation of noncompliance.

a. Students with Disabilities

Oklahoma City University is committed to providing qualified students with disabilities with reasonable accommodations and support needed to ensure equal access to the academic programs and activities of the University. 

All accommodations are made on a case-by-case basis. A student requesting any accommodation should first contact the Disability Services Coordinator who coordinates services for students with disabilities.  The Disability Services Coordinator reviews documentation provided by the student and, in consultation with the student, determines which accommodations are appropriate to the student’s particular needs and academic programs. 

Clic k  here  to  learn  more  about  Oklahoma  City  Unive rsi ty ’s student pol icy on ADA and Section 504.

b.  Employees with Disabilities

Pursuant to the ADA, Oklahoma City University will provide reasonable accommodation(s) to all qualified employees with known disabilities, where their disability affects the performance of their essential job functions, except where doing so would be unduly disruptive or would result in undue hardship.

An employee with a disability is responsible for requesting an accommodation in writing to the Employee Relations Manager and to provide appropriate documentation. The Employee Relations Manager will engage in an interactive process with the employee and work with the employee’s supervisor to identify which essential functions of the position are affected by the employee’s disability and what reasonable accommodations could enable the employee to perform those duties.

 Clic k  here  to  learn  more  about  Oklahoma  City  Unive rsi ty ’s student pol icy on ADA and Section 504.

1.3 Oklahoma City University Policy on Discriminatory Harassment

Students, faculty, staff, and administrators are entitled to an education and work environment free of discriminatory harassment. Oklahoma City University’s harassment policy is not meant to inhibit or prohibit the educational content or discussions inside or outside of the classroom that include germane, but controversial or sensitive subject matters protected by academic freedom.

The University reaffirms its commitment to academic freedom but recognizes that academic freedom does not allow any form of prohibited discrimination. It is recognized that an essential function of education is a probing of opinions and an exploration of ideas that may cause some students discomfort. It is further recognized that academic freedom insures the faculty’s right to teach and the student’s right to learn. Finally, nothing in these Policies and procedures shall be interpreted to prohibit bona fide academic requirements for a specific university program, course, or activity. When investigating prohibited discrimination complaints containing issues of academic freedom, the Compliance Coordinator will consult with a faculty member appointed by the Faculty Senate Executive Committee with respect to contemporary practices and standards for course content and delivery.

The sections below describe the specific forms of legally prohibited harassment that are also prohibited under University policy.

a.  Discriminatory and Bias-Related Harassment

Harassment constitutes a form of discrimination that is prohibited by University policy as well as the law. Oklahoma City University condemns and will not tolerate discriminatory harassment against any employee, student, visitor or guest on the basis of any status protected by policy or law. Oklahoma City University will address all forms of harassment when reported, whether or not the harassment rises to the level of creating a hostile environment.  When harassment rises to the level of creating a hostile environment, the University may also impose sanctions on the harasser through application of the Equity Resolution Process. This policy explicitly prohibits any form of harassment, defined as unwelcome conduct on the basis of actual or perceived membership in a protected class, by any member or group of the community.

A hostile environment may be created by harassing verbal, written, graphic, or physical conduct that is severe, persistent or pervasive, and objectively offensive such that it interferes with, limits or denies the ability of an individual to participate in or benefit from educational programs or activities, or employment access, benefits or opportunities.

The University reserves the right to address offensive conduct and/or harassment that 1) does not rise to the level of creating a hostile environment, or 2) that is of a generic nature not on the basis of a protected status. Addressing such behaviors shall not result in the imposition of discipline under the nondiscrimination policy, but will be addressed through respectful confrontation, remedial actions, education and/or conflict resolution mechanisms. For assistance with conflict resolution techniques, employees should contact the Chief Human Resources Officer and students should contact the Dean of Students.

b.  Sexual Harassment

The Department of Education’s Office for Civil Rights (OCR), the Equal Employment Opportunity Commission (EEOC) and the State of Oklahoma regard sexual harassment as a form of sex/gender discrimination and, therefore, as an unlawful discriminatory practice.  Oklahoma City University has adopted the following definition of sexual harassment to address the special environment of an academic community, which consists not only of employees but also students. 

Sexual harassment is: 

  • unwelcome,
  • sexual, sex-based and/or gender-based,
  • verbal, written, online and/or physical conduct.

Anyone experiencing sexual harassment in any Oklahoma City University program is encouraged to report it immediately to the Title IX Coordinator or the Deputy Title IX Coordinator. Remedies, education, and/or training will be provided in response.

Sexual harassment may be disciplined when it takes the form of quid pro quo harassment, retaliatory harassment and/or creates a hostile environment.

“Hostile environment” sexual harassment is where an individual is subjected to a hostile or intimidating environment in which conduct is:

  1. Severe, pervasive, or persistent in nature; and
  2. Objectively offensive, such that it unreasonably interferes with, denies, or limits someone’s ability to participate in or benefit from Oklahoma City University’s educational programs or employment.

Quid Pro Quo Sexual Harassment: 

Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature by a person having real or perceived power or authority over another constitutes sexual harassment when submission to such sexual conduct is made either explicitly or implicitly a term or condition of rating or evaluating an individual’s educational and/or professional development and/or performance. 

Some examples of possible Sexual Harassment include: 

  • Direct or implied threats that submission to sexual advances will be a condition of employment, promotion, grades or letters of recommendation. This is harassment regardless of whether the student or employee accedes to the request
  • A student repeatedly sends sexually oriented jokes around on an email list they created, even when asked to stop, causing one recipient to avoid the sender on campus and in the residence hall in which they both live.
  • Certain visual displays of sexually-oriented images outside of the educational context (e.g., explicit sexual pictures are displayed in a professor’s office or on the exterior of a student’s residence hall door).
  • Two supervisors frequently ‘rate’ several employees’ bodies and sex appeal, commenting suggestively about their clothing and appearance.
  • A professor engages students in her class in discussions about their past sexual experiences, yet the conversation is not in any way germane to the subject matter of the class.  She probes for explicit details and demands that students answer her, though they are clearly uncomfortable doing so.
  • A pattern of conduct that would discomfort or humiliate a reasonable person at whom the conduct was directed and includes one or more of the following: unnecessary touching; remarks of a sexual nature about a person’s clothing or body, whether or not intended to be complimentary; remarks about sexual activity or speculations about previous sexual experience; or other comments of a sexual nature.
  • Male students take to calling a particular brunette student “Monica” because of her resemblance to Monica Lewinsky. Soon, everyone adopts this nickname for her, and she is the target of relentless remarks about cigars, the president, and “sexual relations.”
  • A student intentionally brushed up another student and then groped her breast without her permission. While this is sexual harassment, it is also a form of sexual violence.

POLICY EXPECTATIONS WITH RESPECT TO CONSENSUAL RELATIONSHIPS

There are inherent risks in any romantic or sexual relationship between individuals in unequal positions (such as faculty and student, supervisor and employee). These relationships may be less consensual than perceived by the individual whose position confers power. The relationship also may be viewed in different ways by each of the parties, particularly in retrospect. Furthermore, circumstances may change, and conduct that was previously welcome may become unwelcome. Even when both parties have consented at the outset to a romantic or sexual involvement, this past consent may not remove grounds for a later charge of a violation of applicable sections of this policy. Oklahoma City University does not wish to interfere with private choices regarding personal relationships when these relationships do not interfere with the goals and policies of the University. For the personal protection of members of this community, relationships in which power differentials are inherent (faculty-student, staff-student, administrator-student) are generally discouraged.

While no consensual relationships are prohibited by this policy, consensual romantic or sexual relationships in which one party maintains a direct supervisory or evaluative role over the other party are unethical and impermissible. Therefore, persons with direct supervisory or evaluative responsibilities who are involved in such relationships must bring those relationships to the timely attention of their supervisor, and will likely result in the necessity to remove the employee from the supervisory or evaluative responsibilities, or shift a party out of being supervised or evaluated by someone with whom they have established a consensual relationship. This includes RAs and students over whom they have direct responsibility. Failure to timely self-report such relationships to a supervisor as required can result in disciplinary action up to and including termination.

c. Sexual Misconduct

State law defines various violent and/or non-consensual sexual acts as crimes. While some of these acts may have parallels in criminal law, Oklahoma City University has defined categories of sex/gender discrimination as sexual misconduct, as stated below, for which action under this policy may be taken and sanctions imposed. The University reserves the right to impose any level of sanction, ranging from a reprimand up to and including suspension or expulsion/termination, for any act of sexual misconduct or other sex/gender-based offenses, including intimate partner (dating and/or domestic) violence, non- consensual sexual contact and/or stalking based on the facts and circumstances of the particular allegation. Generally speaking, Oklahoma City University considers Non-Consensual Sexual Intercourse violations to be the most serious of these offenses, and therefore typically imposes the most severe sanctions, including suspension or expulsion for students and termination for employees.  Acts of sexual misconduct may be committed by any person upon any other person, regardless of the sex, sexual orientation and/or gender identity of those involved. Violations include: 

i. Sexual Harassment (as defined in section b above)

ii. Non-Consensual Sexual Intercourse

Defined as: 

  • any sexual intercourse
  • however, slight
  • with any object
  • by a person upon another person
  • that is without consent and/or by force

Sexual intercourse includes:

  • Vaginal or anal penetration by a penis, tongue, finger or object, and oral copulation (mouth to genital contact or genital to mouth contact) no matter how slight the penetration or contact.

iii. Non-Consensual Sexual Contact

Defined as:

  • any intentional sexual touching
  • however, slight
  • with any object
  • by a person upon another person
  • that is without consent and/or by force

Sexual touching includes:

  • Intentional contact with the breasts, groin, or genitals, mouth or touching another with any of these body parts, or making another touch you or themselves with or on any of these body parts; or
  • Any other bodily contact in a sexual manner. 

iv. Sexual Exploitation

Sexual Exploitation refers to a situation in which a person takes non-consensual or abusive sexual advantage of another, and that behavior does not otherwise fall within the definitions of Sexual Harassment, Non-Consensual Sexual Intercourse or Non-Consensual Sexual Contact.

Examples of Sexual Exploitation include, but are not limited to:

  • Sexual voyeurism (such as watching a person undressing, using the bathroom, or engaged in sexual acts without the consent of the person observed)
  • Invasion of sexual privacy
  • Taking pictures or video or audio recording another in a sexual act, or in any other private activity without the consent of all involved in the activity, or exceeding the boundaries of consent (such as allowing another person to hide in a closet and observe sexual activity, or disseminating sexual pictures without the photographed person’s consent)
  • Forcing or coercing prostitution
  • Engaging in sexual activity with another person while knowingly infected with human immunodeficiency virus (HIV), a sexually transmitted disease (STD) or infection (STI) without informing the other person of the infection
  • Administering alcohol or drugs (such as “date rape” drugs) to another person without his or her knowledge or consent
  • Exposing one’s genitals in non-consensual circumstances
  • Sexually-based stalking and/or bullying

v. Force and Consent

Force: Force is the use of physical violence and/or imposing on someone physically to gain sexual access. Force also includes threats, intimidation (implied threats) and coercion that overcome resistance or produce consent (“Have sex with me, or I’ll hit you.” “Okay, don’t hit me, I’ll do what you want.”).

Coercion is unreasonable pressure for sexual activity. Coercive behavior differs from seductive behavior based on the type of pressure someone uses to get consent from another. When someone makes clear to you that they do not want sex, that they want to stop, or that they do not want to go past a certain point of sexual interaction, continued pressure beyond that point can be coercive.

NOTE: Silence or the absence of resistance alone is not consent. There is no requirement on a party to resist the sexual advance or request, but resistance is a clear demonstration of non-consent. The presence of consent is not demonstrated by the absence of resistance. Sexual activity that is forced is by definition non-consensual, but non-consensual sexual activity is not by definition forced.

Consent: Consent is knowing, voluntary, and clear permission by word or action to engage in mutually agreed upon sexual activity. Since individuals may experience the same interaction in different ways, it is the responsibility of each party to make certain that the other has consented before engaging in the activity. For consent to be valid, there must be a clear expression in words or actions that the other individual consented to that specific sexual conduct. Consent can be withdrawn once given, as long as the withdrawal is clearly communicated.

Consent to some sexual contact (such as kissing or fondling) cannot be presumed to be consent for other sexual activity (such as intercourse). A current or previous dating relationship is not sufficient to constitute consent. The existence of consent is based on the totality of the circumstances, including the context in which the alleged incident occurred and any similar previous patterns that may be evidenced.

Incapacitation: Incapacitation is defined as a state where someone cannot make rational, reasonable decisions because they lack the capacity to give knowing/informed consent (e.g., to understand the “who, what, when, where, why or how” of their sexual interaction).

A person cannot consent if they are unable to understand what is happening or is disoriented, helpless, asleep or unconscious for any reason, including due to alcohol or other drugs. An individual who engages in sexual activity when they know or should have known, that the other person is physically or mentally incapacitated has violated this policy.

It is not an excuse that the responding party was intoxicated and, therefore, did not realize the incapacity of the reporting party. 

This policy also covers a person whose incapacity results from mental disability, involuntary physical restraint and/or from the consuming of incapacitating drugs.

In Oklahoma, a minor (meaning a person under the age of 16 years) cannot consent to sexual activity. This means that sexual contact by an adult with a person younger than 16 years old may be a crime, and a potential violation of this policy, even if the minor wanted to engage in the act or voluntarily participated in the act.

Examples of lack of consent:

  • Amanda and Bill meet at a party. They spend the evening dancing and getting to know each other. Bill convinces Amanda to come up to his room. From 11:00pm until 3:00am, Bill uses every line he can think of to convince Amanda to have sex with him, but she adamantly refuses. He keeps at her, and begins to question her religious convictions, and accuses her of being “a prude.” Finally, it seems to Bill that her resolve is weakening, and he convinces her to give him a "hand job" (hand to genital contact). Amanda would never had done it but for Bill's incessant advances. He feels that he successfully seduced her, and that she wanted to do it all along, but was playing shy and hard to get.  Why else would she have come up to his room alone after the party? If she really didn't want it, she could have left. Bill is responsible for violating the University’s Nondiscrimination Policy. It is likely that campus decision-makers would find that the degree and duration of the pressure Bill applied to Amanda are unreasonable. Bill coerced Amanda into performing unwanted sexual touching upon him. Where sexual activity is coerced, it is forced. Consent is not valid when forced. Sex without consent is sexual misconduct.
  • Jiang is a junior at the university. Beth is a sophomore. Jiang comes to Beth’s residence hall room with some mutual friends to watch a movie. Jiang and Beth, who have never met before, are attracted to each other. After the movie, everyone leaves, and Jiang and Beth are alone. They hit it off, and are soon becoming more intimate. They start to make out. Jiang verbally expresses his desire to have sex with Beth. Beth, who was abused by a baby- sitter when she was five, and has not had any sexual relations since, is shocked at how quickly things are progressing. As Jiang takes her by the wrist over to the bed, lays her down, undresses her, and begins to have intercourse with her, Beth has a severe flashback to her childhood trauma. She wants to tell Jiang to stop, but cannot. Beth is stiff and unresponsive during the intercourse. Is this a policy violation? Jiang would be held responsible in this scenario for non-consensual sexual intercourse, which is a violation of this policy. It is the duty of the sexual initiator, Jiang, to make sure that he has mutually understandable consent to engage in sex. Though consent need not be verbal, it is the clearest form of consent. Here, Jiang had no verbal or non-verbal mutually understandable indication from Beth that she consented to sexual intercourse.  Of course, wherever possible, it is important to be as clear as possible as to whether or not sexual contact is desired, and to be aware that for psychological reasons, or because of alcohol or drug use, one’s partner may not be in a position to provide as clear an indication as the policy requires. As the policy makes clear, consent must be actively, not passively, given.
  • Kevin and John are at a party. Kevin is not sure how much John has been drinking, but he is pretty sure it’s a lot. After the party, he walks John to his room, and John comes on to Kevin, initiating sexual activity. Kevin asks him if he is really up to this, and John says yes. They remove their clothes, and end up in John’s bed. Suddenly, John runs for the bathroom. When he returns, his face is pale, and Kevin thinks he may have thrown up. John gets back into bed, and they begin to have sexual intercourse. Kevin is having a good time, though he can’t help but notice that John seems pretty groggy and passive, and he thinks John may have even passed out briefly during the sex. When Kevin runs into John the next day, he thanks him for the wild night. John remembers nothing and decides to make a report to the Dean.  This is an example of non-consensual sexual intercourse and a violation of this policy. Kevin should have known that John was incapable of making a rational, reasonable decision about sex. Even if John seemed to consent, Kevin was well aware that John had consumed a large amount of alcohol, and Kevin thought John was physically ill, and that he passed out during sex.  A person cannot consent if they are unable to understand what is happening or are unconscious for any reason, including due to alcohol. An individual who engages in sexual activity when they know or should have known that the other person is physically incapacitated, has violated this policy.
1.4 Other Civil Rights Offenses

In addition to the forms of sexual misconduct described above, the following behaviors are also prohibited as forms of discrimination when the act is based upon the reporting party’s actual or perceived membership in a protected class.

  1. Threatening or causing physical harm, extreme verbal abuse, or other conduct which threatens or endangers the health or safety of any person;
  2. Discrimination, defined as actions that deprive, limit or deny other members of the community of educational or employment access, benefits or opportunities;
  3. Intimidation, defined as implied threats or acts that cause an reasonable fear of harm in another;
  4. Hazing, defined as acts likely to cause physical or psychological harm or social ostracism to any person within the university community, when related to the admission, initiation, pledging, joining, or any other group-affiliation activity (as defined further in the Hazing Policy);
  5. Bullying, defined as
    1. Repeated and/or severe
    2. Aggressive behavior
    3. Likely to intimidate or intentionally hurt, control or diminish another person, physically or mentally
  6. Intimate Partner Violence, often referred to as dating violence, domestic violence or relationship violence. Intimate partner violence includes any act of violence or threatened act of violence against a person who is, or has been involved in, a sexual, dating, domestic, or other intimate relationship with the responding party. Intimate partner violence can encompass a wide range of behavior including, but not limited to, physical violence, sexual violence, and psychological abuse.  It may involve one act or an ongoing pattern of behavior. Intimate partner violence may take the form of threats, assault, property damage, violence or threat of violence to one’s self, one’s sexual or romantic partner or to the family members or friends of the romantic or sexual partner. 
    • Examples:
      1. A boyfriend shoves his girlfriend into a wall upon seeing her talking to a male friend. This physical assault based on jealousy is a violation of this policy.
      2. An ex-girlfriend shames her female partner, threatening to out her as a lesbian if she doesn’t give the ex another chance. Psychological abuse is a form of Intimate Partner Violence.
      3. A student repeatedly calls his ex-boyfriend to indicate that if he doesn’t get back together with her she will kill herself and he will be to blame.
      4. Married employees are witnessed in the parking garage, with one partner slapping and scratching the other in the midst of an argument.
  7. Stalking
    1. A course of conduct
    2. Directed at a specific person
    3. On the basis of actual or perceived membership in a protected class
    4. That is unwelcome, AND
    5. Would cause a reasonable person to feel fear and may be
      • repetitive and menacing, or include
      • pursuing, following, harassing and/or interfering with the peace and/or safety of another.

Examples of Stalking

  • A student repeatedly shows up at another student's on-campus residence, always notifying the front desk attendant that they are there to see the resident. Upon a call to the resident, the student informs residence hall staff that this visitor is uninvited and continuously attempts to see them, even so far as waiting for them outside of classes and showing up to their on-campus place of employment requesting that they go out on a date together.
  • A graduate student working as an on-campus tutor received flowers and gifts delivered to their office. After learning the gifts were from a student they recently tutored, the graduate student thanked the student and stated that it was not necessary and would appreciate if the gift deliveries stop. The student then started leaving notes of love and gratitude on the graduate assistant's car, both on-campus and at home. Asked again to stop, the student stated by email: “You can ask me to stop, but I’m not giving up. We are meant to be together, and I’ll do anything necessary to make you have the feelings for me that I have for you.” When the tutor did not respond, the student emailed again, “You cannot escape me. I will track you to the ends of the earth. We are meant to be together.”
  • Any other University policies may fall within this section when a violation is motivated by the actual or perceived membership of the reporting party’s sex or gender.

Sanctions for the above-listed “Other Civil Rights Behaviors” behaviors range from a reprimand through expulsion (students) or termination of employment.

1.5 Retaliation

Retaliation is defined as any adverse action taken against a person participating in a protected activity because of their participation in that protected activity. Retaliation against an individual for alleging harassment or discrimination, supporting a party bringing an allegation, or for assisting in providing information relevant to a claim of harassment or discrimination is a serious violation of Oklahoma City University policy and will be treated as another possible instance of harassment or discrimination. Acts of alleged retaliation should be reported immediately to the Title IX Coordinator and will be promptly investigated. Oklahoma City University is prepared to take appropriate steps to protect individuals who fear that they may be subjected to retaliation.

Examples of Retaliation

  • Student-athlete A files an allegation against a coach for sexual harassment; the coach subsequently cuts the student-athlete’s playing time in half without a legitimate justification.
  • A faculty member complains of gender inequity in pay within her department; the department chair then revokes his prior approval allowing her to attend a national conference, citing the faculty member’s tendency to “ruffle feathers.”
  • Student A from Organization Alpha participates in a sexual misconduct hearing against Student B – also a member of Organization Alpha; Student A is subsequently removed as a member of Organization Alpha because they participated in the hearing.
1.6 Remedial Action

Oklahoma City University will implement initial remedial, responsive and/or protective actions upon notice of alleged harassment, retaliation and/or discrimination. Such actions could include but are not limited to: no contact orders, providing counseling and/or medical services, academic support, living arrangement adjustments, transportation accommodations, visa and immigration assistance, student financial aid counseling, providing a campus escort, academic or work schedule and assignment accommodations, safety planning, referral to campus and community support resources. 

The University will take additional prompt remedial and/or disciplinary action with respect to any member of the community, guest or visitor, upon a finding that they have engaged in harassing or discriminatory behavior or retaliation.

The University will maintain as confidential any accommodations or protective measures, provided confidentiality does not impair the University’s ability to provide the accommodations or protective measures.

Procedures for handling reported incidents are fully described below.

1.7 Confidentiality and Reporting of Offenses Under This Policy

All Oklahoma City University employees (faculty, staff, administrators) are expected to report actual or suspected discrimination or harassment to appropriate officials immediately, though there are some limited exceptions. In order to make informed choices, it is important to be aware of confidentiality and mandatory reporting requirements when consulting campus resources. On campus, some resources may maintain confidentiality — meaning they are not required to report actual or suspected without any obligation to inform an outside agency or campus official unless a reporting party has requested information to be shared. Other resources exist for reporting parties to report crimes and policy violations, and these resources will take action when an incident is reported to them. The following describes the reporting options at Oklahoma City University:

Confidential Reporting

If a reporting party would like the details of an incident to be kept confidential, the reporting party may speak with:

  • On-campus licensed professional counselors and staff
  • On-campus health service providers and staff
  • On-campus clergy, acting in their capacity as clergy
  • Off-campus (non-employees):


    • Licensed professional counselors
    • Local rape crisis counselors
    • Domestic violence resources
    • Local or state assistance agencies
    • Clergy/Chaplains

All of the above-listed individuals will maintain confidentiality except in extreme cases of the immediacy of threat or danger or abuse of a minor. Campus counselors and the Employee Assistance Program are available to help free of charge and can be seen on an emergency basis during normal business hours. University employees listed above will submit anonymous statistical information to the Campus Police Department in order to comply with the University’s Clery Act reporting requirements, unless they believe it would be harmful to their client, patient, or parishioner.

Formal Reporting Options

All Oklahoma City University employees have a duty to report unless they fall under the “Confidential Reporting” section above. Reporting parties may want to consider carefully whether they share personally identifiable details with non-confidential employees, as those details must be shared with the Title IX Coordinator. Employees must promptly share all details of the reports they receive. Generally, climate surveys, classroom writing assignments or discussions, human subjects research, or events such as Take Back the Night marches or speak-outs do not provide notice that must be reported to the Title IX Coordinator by employees, unless the reporting party clearly indicates that they wish a report to be made. Remedial actions may result from such disclosures without formal University action.

If a reporting party does not wish for their name to be shared, does not wish for an investigation to take place, or does not want a formal resolution to be pursued, the reporting party may make such a request to the Title IX Coordinator, who will evaluate that request in light of the duty to ensure the safety of the campus and comply with the law. Note that the University’s ability to remedy and respond to a reported incident may be limited if the reporting party does not want the institution to proceed with an investigation and/or the Equity Resolution Process.

In cases indicating pattern, predation, threat, weapons and/or violence, Oklahoma City University will likely be unable to honor a request for confidentiality. In cases where the reporting party requests University will offer interim support and remedies to the reporting party and the community, but will not otherwise pursue formal action. A reporting party has the right and can expect, to have allegations taken seriously by the University when formally reported, and to have those incidents investigated and properly resolved through these procedures.

Formal reporting still affords some privacy to the reporting party. Only a small group of University officials who need to know will be told, including but not limited to personnel in: Student Affairs, University Police, and the Behavioral Intervention Team, if applicable. Information will be shared as necessary with investigators, witnesses, and the responding party. The circle of people with this knowledge will be kept as tight as possible to preserve a reporting party’s rights and privacy. Additionally, anonymous reports can be made by victims and/or third parties using the online reporting form, or the reporting hotline at (866) 943-5787. Note that these anonymous reports may prompt a need for the University to investigate.

Failure of a non-confidential employee (i.e., any employee not designated above for confidential reporting purposes), to report an incident or incidents of sex/gender harassment or discrimination of which they become aware is a violation of University policy and can be subject to disciplinary action up to and including employment termination for failure to comply.

1.8 Federal Timely Warning Obligations

Parties reporting sexual misconduct should be aware that under the Clery Act, Oklahoma City University administrators must issue timely warnings for incidents reported to them that pose a substantial threat of bodily harm or danger to members of the campus community. The University will ensure that a victim’s name and other identifying information is not disclosed, while still providing enough information for community members to make safety decisions in light of the potential danger.

1.9 False Allegations

Deliberately false and/or malicious accusations under this policy, as opposed to allegations which, even if erroneous, are made in good faith, are a serious offense and will be subject to appropriate disciplinary action.

1.10 Amnesty for Alcohol and Other Drug Use

The University encourages the reporting of misconduct and crimes by reporting parties and witnesses. Sometimes, reporting parties or witnesses are hesitant to report alleged misconduct to University officials or participate in resolution processes because they fear that they themselves may be accused of policy violations. For example, a student who has been drinking underage might hesitate to help take a sexual misconduct victim to the Campus Police. It is in the best interests of this community that reporting parties choose to report to University officials, and that witnesses come forward to share what they know. To encourage reporting, Oklahoma City University pursues a policy of offering reporting parties and witnesses amnesty from minor policy violations related to the incident.  An individual who reports harassment, discrimination or misconduct implicating this policy, either as a reporting party or third-party witness will not be subject to disciplinary action by the University for personal consumption of alcohol or drugs or other violations of the conduct policy (not including this policy) at or near the time of the incident, provided that any such violations did not and do not place the health or safety of any other person at risk and do not involve academic dishonesty. 

While policy violations cannot be overlooked, the University will provide educational remedies, rather than punishment, to those who offer their assistance to others in need.

Being intoxicated by drugs or alcohol is no defense to any violation of this policy and does not diminish one’s responsibility to obtain consent.

1.11 Parental Notification (allegations involving students)

Oklahoma City University reserves the right to notify parents/guardians of dependent students regarding any health or safety risk, change in student status or conduct situation. Where a student is non-dependent, the University may contact parents/guardians to inform them of situations in which there is a significant and articulable health and/or safety risk. Oklahoma City University also reserves the right to designate which University officials have a need to know about incidents that fall within this policy, pursuant to the Family Educational Rights and Privacy Act.

1.12 Federal Statistical Reporting Obligations

Certain campus officials – those deemed Campus Security Authorities - have a duty to report sexual assault, domestic violence, dating violence and stalking for federal statistical reporting purposes pursuant to the Clery Act. All personally identifiable information is kept confidential, but statistical information must be passed along to campus law enforcement regarding the type of incident and its general location (on or off-campus, in the surrounding area, etc.) for publication in the University’s Annual Security Report. This report helps to provide the community with a clear picture of the extent and nature of campus crime, to ensure greater community safety. Mandated federal reporters include: student affairs/student conduct, campus law enforcement, local police, coaches, athletic directors, residence life staff, student activities staff, human resources staff, advisors to student organizations and any other official with significant responsibility for student and campus activities. The information to be shared includes the date, the location of the incident (using Clery location categories) and the Clery crime category. This reporting protects the identity of the victim and may be done anonymously.

PART 2: EQUITY RESOLUTION PROCESS

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