Hartford International prohibits discrimination, including discriminatory harassment, sexual assault, dating violence, domestic violence, stalking, sexual or gender-based harassment, complicity in any act prohibited by this Policy, retaliating against anyone for reporting a violation of this Policy or participating in any investigation or proceeding under this policy. These forms of prohibited conduct are unlawful and undermine the mission and values of the Hartford International.
All Hartford International employees are required to report sexual harassment to the Title IX coordinator. No paid Hartford International employee can guarantee confidentiality.
Title IX of the Education Amendments of 1972 protects both the complainants from sexual harassment, discrimination, and violence based on sex, and the respondents – who are in the United States – accused of sexual harassment, discrimination, and violence in education programs and activities that receive federal financial assistance. Education program or activity includes locations, events, or circumstances over which the Hartford International exercises substantial control over both the respondent and the context in which the sexual harassment occurred. Title IX applies to all of a school’s education programs or activities, whether such programs or activities occur on-campus, off-campus, or virtually. Hartford International may address sexual harassment affecting its students or employees that falls outside Title IX’s jurisdiction in any manner the Hartford International chooses, including providing supportive measures or pursuing discipline. This policy does not limit principles of academic freedom or freedom of speech even when such speech or expression is offensive, nor does it abridge the Hartford International’s educational mission.
Our Title IX Officer monitors compliance with this law and ensures that complaints of this nature are appropriately and equitably addressed. Any person can report sex discrimination including sexual harassment (whether or not the person reporting is the alleged target of the conduct that could constitute sex discrimination or sexual harassment), in person, by mail, or by email, using the contact information below at any time. Questions, concerns, and reports of violations can be brought to:
Michael P. Sandner, Esq.
Chief Business Officer
Title IX Officer
77 Sherman Street
Hartford, CT 06105
Sexual Harassment: Sexual Harassment is broadly defined as: (1) quid pro quo harassment by a school’s employee; (2) any unwelcome conduct that a reasonable person would find so severe, pervasive, and objectively offensive that it denies a person equal educational access; and (3) any instance of sexual assault (as defined in the Clery Act), dating violence, domestic violence, or stalking as defined in the Violence Against Women Act (VAWA).
Quid Pro Quo Harassment: A Hartford International employee conditioning an individual’s instruction, employment, or participation in Hartford International activities upon submission to unwelcome sexual conduct and/or a Hartford International employee explicitly or implicitly conditioning a student’s participation in an education program or activity or bases an educational decision on the student’s submission to unwelcome sexual advances, requests for sexual favors, or other verbal, nonverbal, or physical conduct of a sexual nature. Quid pro quo harassment is equally unlawful whether the student resists and suffers the threatened harm or submits and thus avoids the threatened harm.
Consent: An understandable exchange of affirmative words or actions, which indicate a willingness to participate in mutually agreed upon sexual activity. Consent must be informed, freely, and actively given. It is the responsibility of the initiator to obtain clear and affirmative responses at each stage of sexual involvement. Consent to one form of sexual activity does not imply consent to other forms of sexual activity. The lack of a negative response is not consent. An individual who is incapacitated by alcohol and/or other drugs both voluntarily and involuntarily consumed may not give consent. Past consent of sexual activity does not imply ongoing future consent.
Rape: Penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without consent of the victim.
Fondling: The touching of the private body parts of another person for the purpose of sexual gratification, without the consent of the victim, including instances, where the victim is incapable of giving consent because of his/her age and/or because of his/her temporary or permanent mental incapacity.
Incest: Nonforcible sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law.
Statutory Rape: Nonforcible sexual intercourse with a person who is under the statutory age of consent.
Stalking: Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for the person’s safety or the safety of others or suffer substantial emotional distress. Course of conduct means two or more acts, including, but not limited to, acts in which the stalker directly, indirectly, or through third parties, by any action, method, device or means, follows, monitors, observes, surveils, threatens, or communicates to or about, a person, or interferes with a person’s property. Substantial emotional distress means significant mental suffering or anguish that may, but does not necessarily, require medical or other professional treatment or counseling. Reasonable person means a reasonable person under similar circumstances and with similar identities to the victim.
Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with a victim. The existence of such a relationship shall be determined based on the reporting party’s statement and with consideration of the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship. Dating violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse. Dating violence does not include acts covered under the definition of domestic violence.
Domestic Violence: A felony or misdemeanor crime of violence committed by a current or former spouse or intimate partner of the victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with, or has cohabitated with, the victim as a spouse or intimate partner, by a person similarly situated to a spouse of a victim under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred or by any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred.
Bystander Intervention: Safe and positive options that may be carried out by an individual or individuals to prevent harm or to intervene when there is a risk of dating violence, domestic violence, sexual assault or stalking. Bystander Intervention includes recognizing situations of potential harm, understanding institutional structures and cultural conditions that facilitate violence, overcoming barriers to intervening, identifying safe and effective intervention options, and taking action to intervene.
All Hartford International employees are required to report sexual harassment to the Title IX coordinator. No paid Hartford International employee can guarantee confidentiality.
Notice to the Title IX Officer or to an official with authority to institute corrective measures on the recipient’s behalf, charges a school with actual knowledge and triggers the school’s response obligations.
Risk Reduction: Options designed to decrease perpetration and bystander inaction, and to increase empowerment for complainants in order to promote safety and to help individuals and communities address conditions that facilitate violence.
Complainant: An individual who is alleged to be the victim of conduct that could constitute sexual harassment. Legal guardians may act on behalf of the complainant in Title IX matters.
Respondent: An individual who has been reported to be the perpetrator of conduct that could constitute sexual harassment.
Formal Complaint: A document filed by a complainant or signed by the Title IX Officer alleging sexual harassment against a respondent and requesting that the school investigate the allegation of sexual harassment.
Document Filed By a Complainant: A document or electronic submission that contains the complainant’s physical or digital signature, or otherwise indicates that the complainant or their legal guardian is the person filing the formal complaint.
Supportive Measures: Individualized services reasonably available that are non-punitive, non-disciplinary, and not unreasonably burdensome to the other party while designed to ensure equal educational access, protect safety, or deter sexual harassment.
Grievance Process/Proceedings: Refers to the consistent, balanced, and transparent activities related to resolving formal complaints of sexual harassment including but not limited to independent fact-finding investigations, formal hearings, informal resolution, and appeals.
Determination: Any initial, interim, and final decision by a Hartford International official – who cannot be the same person as the Title IX Officer – or designated entity/task force authorized to resolve disciplinary matters within the institution.
- Students who are found responsible for sexual assault, dating violence, or domestic violence will be suspended or expelled.
- Students found in violation of sexual harassment or stalking will be either placed on disciplinary probation, suspended or expelled.
- Students that are placed on disciplinary probation or suspended may be sanctioned with intervention services, restrictions from accessing college or community buildings, and educational programs.
Procedures for Handling Complaints of Sexual Harassment and Violence
Hartford International utilizes the standard of evidence of “clear and convincing evidence” to determine responsibility. Hartford International will apply this standard of evidence consistently for all formal complaints of sexual harassment whether the respondent is a student or an employee (including faculty members).
- Clear and convincing evidence is highly and substantially more likely to be true than untrue; the fact finder must be convinced that the contention is highly probable.
Both complainants and respondents of sexual harassment, sexual assault, stalking, dating violence or domestic violence will receive a written explanation of their rights and options of supportive measures and related services available to them whether or not law enforcement has been notified. Fair, impartial, and formal hearings or informal proceedings – mediation or restorative justice – will occur as prescribed by Clery Act regulations.
Hartford International will resolve all Title IX proceedings (investigations, formal hearings, informal resolutions, and appeals) in a reasonable prompt time frame with the allowance for short-term good cause delays or extensions.
A Sexual Harassment/Violence Task Force will be appointed by the President of Hartford International within two (2) weeks of the beginning of each academic year to address any complaints of sexual harassment or violence, including stalking and dating/domestic violence that may arise. A list of the members of the task force will be distributed to all members of the Hartford International community within the first three weeks of the new academic year.
- The Sexual Harassment/Violence Task Force shall be comprised of three appropriate parties – one member from the Board of Trustees, one member from the Faculty, and one member from the Staff. Each party would serve as the sole decision maker in a formal hearing or an informal resolution on a rotational basis. If either the complainant or respondent is a member of the task force, the party must recuse themselves and an alternate must be identified as a replacement.
- The Title IX Officer cannot serve on the Sexual Harassment/Violence Task Force.
- The Sexual Harassment/Violence Task Force must issue a written determination regarding responsibility with findings of fact, conclusions about whether the alleged conduct occurred, rationale for the result as to each allegation, any disciplinary sanctions imposed on the respondent, and whether remedies will be provided to the complainant. The written determination must be sent simultaneously to the parties along with information about how to file an appeal.
Training Requirements – All Title IX personnel must be free from conflicts of interest or bias for or against complainants or respondents. All Title IX personnel (officer, investigators, and decision-makers) must include training on the definition of sexual harassment, the scope of the school’s education program or activity, how to conduct an investigation and grievance process including hearings, appeals, and informal resolution processes, as applicable, and how to serve impartially, including by avoiding prejudgment of the facts at issue, conflicts of interest, and bias. The Sexual Harassment/Violence Task Force will also receive training on any technology to be used at a live hearing. All Title IX personnel shall receive training on relevance, including how to apply the rape shield protections provided only for complainants. All Title IX personnel must have a presumption that the respondent is not responsible for the alleged conduct until a determination regarding responsibility is made at the conclusion of the grievance process. All materials used to train Title IX personnel are posted on the Hartford International’s website.
Reporting, Response, and Remedy Requirements
The first step in the procedure is the reporting of a complaint/allegation to the Title IX Officer or the Title IX Officer receiving information about an allegation that would result in an official obligation for the Hartford International to respond to the alleged complainant and/or the alleged respondent.
- The complainant must be participating in or attempting to participate in the education program or activity of the school which which the formal complaint is filed.
- The respondent must be in the United States.
- The Hartford International must respond promptly to the Title IX sexual harassment allegation in a manner that is not deliberately indifferent, which means a response that is not clearly unreasonable in light of the known circumstances.
- The Title IX Officer must promptly contact the complainant confidentially to discuss the availability of supportive measures, consider the complainant’s wishes with respect to supportive measures, inform the complainant of the availability of supportive measures with or without the filing of a formal complaint, and explain to the complainant the process for filing a formal complaint.
- The Title IX Officer will respect the complainant’s wishes with respect to whether the Hartford International investigates a sexual harassment complaint unless the Title IX Coordinator determines that signing a formal complaint to initiate an investigation over the wishes of the complainant is not clearly unreasonable in light of the known circumstances.
- Where the Title IX Officer signs a formal complaint, the Title IX Officer must not be the complainant or a party during the grievance process, and must comply with requirements for Title IX personnel to be free from conflict or bias.
- The Hartford International must investigate sexual harassment allegations in any formal complaint, which can be filed by the complainant, or signed by the Title IX Officer.
- Title IX investigations may not be conducted by the Title IX Officer.
- Any provisions, rules, or practices that the Hartford International adopts as part of its grievance process for handling formal complaints of sexual harassment must apply equally to both parties.
- The Hartford International must follow a formal grievance process before the imposition of any disciplinary sanctions or other actions that are not supportive measures, against a respondent. The Hartford International may remove any individual from campus immediately without a hearing when an individual’s presence poses a safety threat to the campus community. In the event that an individual is removed under this exception, a disciplinary hearing will be help quickly while the removal order is still in effect.
- The Hartford International must not restrict the rights protected under the US Constitution, including the First Amendment, Fifth Amendment, and Fourteenth Amendment, when complying with the Title IX. The Hartford International must not use, rely on, or seek disclosure of information protected under a legally recognized privilege, unless the person holding the privilege has waived the privilege.
- If the allegations in a formal complaint do not meet the definition of sexual harassment, or did not occur in the Hartford International’s education program or activity against a person in the United States, the Hartford International must dismiss such allegations for purposes of Title IX. The Hartford International may still address the allegations in any manner the school deems appropriate under the school’s own code of conduct.
- The Hartford International will treat complainants equitably by providing remedies any time a respondent is found responsible, and treat respondents equitably by not imposing disciplinary sanctions without following the grievance process prescribed in the Title IX legislation.
- Remedies must be designed to maintain the complainant’s equal access to education and may include the same individualized services as supportive measures; however, remedies need not be non-disciplinary or non-punitive and need not avoid burdening the respondent, when found responsible.
- Remedies require objective evaluation of all relevant evidence, inculpatory and exculpatory, and avoid credibility determinations based on a person’s status as a complainant, respondent, or witness.
- The Hartford International must list the possible remedies a school may and might impose on a respondent, following determinations of responsibility, as well as the range of supportive measures available to complainants and respondents throughout the grievance process.
- The grievance process will not use, rely on, or seek disclosure of information protected under a recognized privilege, unless the person holding such privilege has waived the privilege.
Investigation Requirements – The Hartford International must investigate the allegations in any formal complaint and send written notice to both parties of the allegation upon receipt of a formal complaint. The burden of gathering evidence and burden of proof remains on the Hartford International, not on the parties. Investigators may not be the school’s Title IX Officer.
- The Hartford International must provide equal opportunity for the parties to present fact and expert witnesses and other inculpatory and exculpatory evidence during the investigation process.
- The Hartford International will not restrict the ability of the parties to discuss the allegations or gather evidence.
- The Hartford International must afford each party the same opportunity to select an advisor of the party’s choice who may be, but need not be, an attorney.
- The Hartford International must send written notice to each party of any investigative interviews, meetings, or hearings.
- The Hartford International must send the parties, and their advisors, evidence directly related to the allegations, in electronic format or hard copy, with at least 10 days for the parties to inspect, review, and respond to the evidence.
- The Hartford International must send the parties, and their advisors, an investigative report that fairly summarizes relevant evidence, in electronic format or hard copy, with at least 10 days for the parties to respond.
- The Hartford International must dismiss allegations of conduct that do not meet the definition of sexual harassment or did not occur in a school’s education program or activity against a person in the United States. This dismissal is only for Title IX purposes and does not preclude the school from addressing the conduct in any manner the Hartford International deems appropriate.
- A complainant can withdraw the formal complaint and allegation as long as the party gives voluntary, informed, written consent to do so.
- The Hartford International may, in their discretion, dismiss a formal complaint or allegations therein if the respondent is no longer enrolled or employed by the school, or if specific circumstances prevent the school from gathering sufficient evidence to reach a determination.
- The Hartford International must give the parties written notice of a dismissal (mandatory or discretionary) and the reasons for the dismissal.
- The Hartford International may, in its discretion, consolidate formal complaints where the allegations arise out of the same facts.
- To protect the privacy of each party, the Hartford International may not access or use any medical, psychological, and similar treatment records unless the school obtains the party’s voluntary, written consent to do so.
Informal Internal Resolution
- The Hartford International, in its discretion, may choose to offer and facilitate informal resolution options as appropriate, i.e., arbitration, mediation or restorative justice, before a neutral third party, so long as both parties give voluntary, informed, written consent to attempt informal resolution.
- Any party has the right to withdraw from the informal resolution process and resume the grievance process with respect to a formal complaint at any time, in which case the Hartford International will revert to its formal grievance procedures.
- Informal resolutions are not available if allegations involve an employee (faculty or staff) sexually harassing a student.
- The informal resolution process will be equitable to both parties. Both parties will be notified, in writing, of the informal resolution process, and what elements of the process will remain confidential (or not).
Live Hearings Requirements
- The Hartford International must provide for a formal live hearing if a Complaint is not dismissed in the investigation phase.
- All decision makers must be trained in all technology to be used at the live hearing.
- At a live hearing, the decision makers (the Task Force) must permit each party’s advisor to ask the other party and any witnesses all relevant questions and follow-up questions, including those challenging credibility.
- Cross-examination at a live hearing must be conducted directly, orally, and in real time by the party’s advisor of choice and never by a party personally.
- At the request of each party, the recipient must provide for the entire live hearing (including cross-examination) to occur with the parties located in separate rooms with technology enabling the parties to see and hear each other.
- Only relevant cross-examination and other questions may be asked of a party or a witness. Before a complainant, respondent, or witness answers a cross-examination or other question, the decision-maker must first determine whether the question is relevant and explain to the party’s advisor asking cross-examination questions any decision to exclude a question as not relevant.
- If a party does not have an advisor present at a live hearing, the school must provide, without fee or charge to that party, an advisor of the school’s choice who may be, but is not required to be, an attorney to conduct cross-examination on behalf of that party.
- If a party or witness does not submit to cross-examination at the live hearing, the decision-makers must not rely on any statement of that party or witness in reaching a determination regarding responsibility; provided, however, that the decision-makers cannot draw an inference about the determination regarding responsibility based solely on a party’s or witness’s absence from the live hearing or refusal to answer cross-examination or other questions.
- Live hearings may be conducted with all parties physically present in the same geographic location, or at the school’s discretion, any or all parties, witnesses, and other participants may appear at the live hearing virtually.
- Hartford International must create an audio or audiovisual recording, or transcript, of any live hearing.
- Hartford International must provide rape shield protections for complainants deeming irrelevant questions and evidence about a complainant’s prior sexual behavior unless offered to prove that someone other than the respondent committed the alleged misconduct or offered to prove consent.
- The decision-makers must make a written determination regarding responsibility with findings of fact, conclusions about whether the alleged conduct occurred, rationale for the result as to each allegation, any disciplinary sanctions imposed on the respondent, and whether remedies will be provided to the complainant. The written determination must be sent to the parties along with information about how to file an appeal
- In the event that the decision-makers determine that sexual harassment/violence has occurred, disciplinary sanctions imposed on the respondent may include one or more of the following:
- a formal reprimand, with defined expectations for changed behavior;
- recommending or requiring remedial action such as but not limited to psychological or psychiatric assessment, counseling or treatment, education and so forth;
- probationary standing, with the terms of the probation clearly defined;
- suspension or dismissal from the Hartford International
- Hartford International must offer both parties an appeal from a determination regarding responsibility, and from a school’s dismissal of a formal complaint or any allegations therein, on the following bases: procedural irregularity that affected the outcome of the matter, newly discovered evidence that could affect the outcome of the matter, and/or Title IX personnel had a conflict of interest or bias, that affected the outcome of the matter.
- The request for an appeal must be made in writing within 30 days to the chair of the Board of Trustees. The Chair of the Board shall refer the matter to the Executive Committee of the Board within 30 days and said committee will resolve the matter, with discretion to take any further evidence that it may deem necessary before making its final determination.
- The Hartford International expressly prohibits retaliation against any person for reporting any conduct under this policy or participating in any investigation or proceeding.
- The Hartford International must keep confidential the identity of complainants, respondents, and witnesses, except as may be permitted by FERPA, as required by law, or as necessary to carry out a Title IX proceeding.
- Charging an individual with code of conduct violations that do not involve sexual harassment, but arise out of the same facts or circumstances as a report or formal complaint of sexual harassment, for the purpose of interfering with any right or privilege secured by Title IX constitutes retaliation.
- Charging an individual with a code of conduct violation for making a materially false statement in bad faith in the course of a Title IX grievance proceeding does not constitute retaliation; however, a determination regarding responsibility, alone, is not sufficient to conclude that any party made a bad faith materially false statement.
- Complaints alleging retaliation may be filed according to the Hartford International’s prompt and equitable grievance procedures.
- The exercise of rights protected under the First Amendment does not constitute retaliation.
Educational Materials to Promote Awareness and Prevention of Sexual Offenses and Dating/Domestic Violence
Hartford International has educational materials to promote awareness and prevention of sexual offenses and dating/domestic violence. Staff and students may request copies of these materials at any time. Pertinent materials are available on our website as well. However, it is recommended that those interested contact the following qualified agencies for professional information and services that include crisis counseling, a 24-hour hotline, referrals, support groups and education. All services are free and confidential.
The Hartford International community can obtain information about registered sex offenders in the State of Connecticut via the website: www.communitynotification.com.
Getting Help, on Campus
The Hartford International Title IX Officer oversees the review, investigation, and resolution of reports of sexual harassment, sexual violence and intimate partner violence. The Officer also oversees overall compliance with Title IX and is supported by the Area Coordinator. You can contact any of the following people. If you are the victim of a sexual assault, or are helping a victim, please read the Resources for Victims section of this page.
Title IX Officer
Michael Sandner, Esq.
Chief Business Officer
3rd Floor, 77 Sherman
Executive Assistant to the President & Human Resource Manager
3rd Floor, 77 Sherman
Getting Help, off Campus
YWCA of New Britain Sexual Assault Crisis Hotline, 24 hours per day:
New Britain: 860-223-1787
Connecticut Alliance to End Sexual Violence (formerly CONNSACS)
96 Pitkin Street
East Hartford, CT 06108
Hotline (English) 1-888-999-5545 (24/7)
Hotline (Espanol) 1-888-568-8332 (24/7)
Connecticut Coalition Against Domestic Violence
(Support for victim/survivors of domestic or dating violence and stalking)
Statewide Hotline: 1-888-774-2900 (24/7)
Interval House: 24 Hour domestic violence hotline 860.527.0550 or 1.888.774.2900
Hartford Police Department: 860.757.4000, or 911
Victims are encouraged to report sexual offenses and acts of violence to the Hartford Police Department using the “911” phone number for immediate notification, or the (860) 757-4000 direct phone line to the department.
If you have been sexually assaulted, it is important that you seek medical attention as soon as possible after the assault.
- To treat physical injuries
- To ascertain the risk of sexually transmitted diseases or pregnancy and intervene accordingly
- To gather and preserve evidence that could aid prosecution. Evidence should be collected immediately. After the first 24 hours, the quality of evidence usually decreases, but can be collected up to 72 hours after the assault. The evidence collection can be performed at any of the area hospital emergency rooms, usually takes about four hours, and you may have a support person present during the exam. You are encouraged not to bathe, brush your teeth, use the toilet, douche, or change clothing.
St. Francis Hospital
Connecticut General Statute 19a-112a (e): No costs incurred by a healthy care facility shall be charged directly or indirectly to such victim for the examination of a victim of sexual assault, when such examination is performed for the purpose of gathering evidence as prescribed in the protocol, including the costs of testing for pregnancy and sexually transmitted diseases and costs of prophylactic treatment as provided in the protocol. Any such costs shall be charged to the Office of Victim Services within the Judicial Department.
If you seek treatment at a local hospital and the police are contacted, this does not mean you have to proceed with criminal charges.
Hartford International University requires ALL EMPLOYEES to complete Title IX training through Safe Colleges/Vector Solutions - https://www.vectorsolutions.com/solutions/vector-lms/higher-education/sexual-assault-prevention/. This is a one-time online training incorporated in a new employee’s onboarding experience. The training does contain sensitive material involving sexual and interpersonal violence. While trigger warnings and resources are provided throughout the program, we understand such programming may be problematic for some viewers. Please contact Michael Sandner, Title IX Officer, at firstname.lastname@example.org for support and/or to discuss alternatives for training.
Those directly responsible for and connected to cases of sexual misconduct (Title IX Officer, Decision Makers) are trained via Title IX Solutions. The training materials can be found here.
Those directly responsible for and connected to cases of investigating Title IX formal complaints are trained via ATIXA and are outsourced via Robinson & Cole. The training materials can be found here - https://www.atixa.org/2020-regulations-requirement-posting-of-training-materials/.
Hartford International University requires ALL INCOMING STUDENTS to complete Title IX training through a power point presentation and quiz through a CANVAS New Student Orientation course site. All students must score at least 80% on the accompanying quiz or a registration lock will be placed on their account. Students can re-take the quiz as many times as they need.
Please note – waivers will not be granted to students based on a high level of knowledge of this topic or previous training participation.
These materials are the exclusive property of Title IX Solutions, LLC. All rights reserved, ©2020. The publishing of these materials on this website is authorized by Title IX Solutions, LLC solely for use by this institution in compliance with Regulation 34 CFR §106.45(b)(10)(i)(D). No other use or dissemination by this institution or any third party is authorized without the prior written consent of Title IX Solutions, LLC. The information and materials provided during this program were for educational purposes only and not intended to be legal advice. Attendees should seek independent legal advice concerning the issues presented.