RESOLUTIONAGREEMENT
Cisco College
OCR Compla int No . 06142269

JURISDICTION

The United States Department of Education, Office for Civil Rights (OCR)and Cisco College (the
College) enter into t his Agreement to resolve the allegation in the above-referenced comp laint.
This Agreement does not constitute an admission of liability, non-compliance, or wrongdo ing by
the College. The College assures OCRthat it w ill take the fo llowing actions to comp ly with the
requ irements of Tit le IX of the Education Amendments of 1972 (Tit le IX), 20 U.S.C. §§ 1681 et
seq., and its imp lemen t ing regulat ion, at 34 C.F.R. Part 106, wh ich prohibit discrimination on the
basis of sex by recipients of Federal financia l assistance.
Accordingly , to resolve the issues of th is invest igation, the College agrees to take the following
actions :
ACTION ITEMS AND REPORTING REQUIREMENTS

Action Item I: Titl e IX Policies and Grievan ce Procedur es

The College will draft proposed revised Title IX policies and grievance procedures, and adopt t he
revised policies and grievance procedures within 45 days after receiving approva l from OCR. The
College will revise its Tit le IX pol icies and grievance procedures as necessary to ensure that, to the
extent not already provided, the revised pol icies and procedures include, at a minimum, the
following:
1. Notice to students and employees of the procedure and how to file a complain t t hat is easily
understood, easily locat ed and w idely distributed; such not ice must include the contact
information (name or tit le, office address, email address and telephone number) for t he
ind ividual w ith whom comp laints may be filed;
2. Notice of applicat ion of the procedure to compla ints alleging all forms of sex discrim inatio n
(including sexual harassment) against employees, other students, and th ird part ies;
3. Provisions for the adequate, reliable, and impartia l investigation of complaints , including t he
opport unity to present witnesses and other evidence;
4. Designated and reasonably prompt t imeframes for the major stages of the complaint
process;
5. Notice of the outcome of th e comp laint to all parties, includ ing any appeals; and
6. An assurance that the College will take prompt and effective steps to prevent recurrence of
any sexual harassment and to correct its discrim inatory effects on the complainant and
others , if appropr iate.

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Action Item I: Reporting Requirements
1. By March 11 2018, the College will provide to OCR, for review and approval, its revised Title IX
policies and grievance procedures developed in accordance with Action Item I.

2. Within 45 calendar days of written notification from OCR of its approval of the revised Title IX
policies and procedures, the College will provide documentation to OCRdemonstrating that the
revised procedures were adopted and implemented, and that all faculty, staff and students were
provided with written notice regarding the revised Title IX policies and procedures for resolving
Title IX complaints, together with information on how to obtain a copy of the grievance
procedures. The College, at a minimum, will make this notification through the College's website;
email messages to faculty, staff and students; and any regularly issued newsletters (in print or
on line), as well as by any other additional means of notification the College deems effective to
ensure that the information is widely disseminated and easily located. The College will provide
OCRwith documentation sufficient to evidence the following actions have occurred: updating of
all printed publications and electronic publications on the College website with the revised
documents;1 a list of the titles of the publications in which the information appea rs (e.g.
College Catalog, Student/Employee Handbooks, Policy Manual, Website), as well as a copy of
any such publications, or College website links to electronic pub licat ions containing the
revised grievance procedures , or if not yet finalized , a copy of the insert/notice for printed
publications.
Action Item II: Data Maintenance and Record Keeping
In order to ensure that the College is providing prompt and equitable resolutions of Title IX
complaints by students, employees and third parties, the College will develop and submit to
OCR for its review a procedure to consistently document and maintain data for each incident
or complaint received by the College, whether formal or informal, written or verbal, which will
require , at a min imum, the following documentation:

a) a description of the inciden t or complaint, and a record of when and how the incident or
complaint was brought to the attention of the College;
b) evidence regarding any investigation conducted by the College, including: witnesses
interviewed, documents reviewed, transcripts , recordings and other info rmation considered,
e.g., third-party reports, College police reports, etc., related to the invest igat ion ;
c) records showing any interim measures provided to the complainant and respondent;
d) an explanation of the College's disposition of the complaint, which includes the date of the
disposition, the basis for the disposition and a description of any personal sanctions
imposed, remedies applied and/or College action taken;
e) proof that the College promptly prov ided all parties to the complaint notice of any
decisions, including any appeals, regarding the complaint.
f) confirmat ion of any remedies prov ided to individua ls found to have been subjected to
sexual harassment;
g) where sexual harassment is found to have occurred, documentation that the College
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Inserts and/or notices may be used pending reprinting of these College publications.

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followed up with the complainant(s) to ensure the harassment has not recurred, and
that the discriminatory effects of the harassment have been remedied.
Action Item II: Reporting Requirements

1. By March 1, 2018, the College will submit the procedure to OCRfor its review and approval
in accordance with Action Item II.
2. Within 45 calendar days of OCR'sapproval of the procedure, the College will formally adopt
the procedure as part of its Title IX complaint processing procedures and provide OCRwith
information or documentation confirming that the procedure has been distributed to all
College officials designated to process Title IX complaints, and the procedure is being utilized
in the College's processing of Tit le IX complaints.
Action Item Ill: Title IX Training for College Officials

Upon OCR's approval of the revised Tit le IX poli cies and grievance procedures under Action Items
I and 11,the College will begin prov iding annual, mandatory Title IX tra ining to its responsible
employees, including its Title IX coordinator, assistant Title IX coordinators, and all other College
officials involved in the processing of Title IX complaints, regarding recognizing, reporting, and
responding to incidents of sexual harassment. During the training, the College will provide copies
of its revised Tit le IX policies, grievance procedures, and complaint processing procedures to all
attendees, or refer them to their location within the existent publications or on the College's
website. The training, at a minimum, will cover:
a) the College's revised Title IX policies and grievance procedures;
b) the role and duties of t he Tit le IX coordinator and assistant coordinators;
c) how to recognize and identify sex discrimination and sexual harassment;
d) the obligation to report sexual harassment, including where and with whom to report such
incidents;
e) the College's responsibil ities under Title IX to address such allegations;
f) the student's right to both file a complaint with the College and make a criminal report to
campus of local law enforcement;
g) information on the student's option to request confidentiality;
h) the student's right to be free from retaliation for filing a sexual harassment complaint; and
i) relevant resour ces available to students, employees and third parties.
Action Item Ill: Reporting Requirements

1. Within 45 calendar days of OCR's approval of the Title IX policies and procedures revised
under Action I and II, the College will provide documentat ion to OCRdemonstrating that the
initial train ing was provided by the College in accordance with Action Ill. The
documentation will include, at a minimum, the name(s) and credentials of the trainer(s); the
date(s) and time(s) of the training(s); a description of each training; the type of audience;
sign-in sheets for each session with the names and titles of those attending; and copies of
any training materials distributed.

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Action Item IV: Redress for the Student Identified in the Complaint

The College needs to address the remain ing effects, if any, the Student may have suffered due to its
failure to promptly and equ itably respond to the Student's complaint of sexual harassment.
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Ithe College will offer the Student, in writing, an indiv idual meeting

with the Title IX Coord inator in person or via telephone, or through correspondence or any
other means preferred by the Student, to discuss the College's hand ling of the investigation
intorn:::1complaint, and identify any possible remaining effects. The letter to the Student will
state that any such meeting or other commun ication is voluntary on the part of the Student,
and will acknowledge and apologize for the College' s de lay and failure in processingrn::J
complaint in accordance with Title IX. The letter will also providelm!B with notice of the
outcome ofrn:lcompla int, including any steps that were taken by the College, as well as the
results of any appeals. The letter will explain that the College is revising its Title IX pol icies and
procedures to ensure that comp laints of sex discrimination, including sexual harassment, are
timely processed, that comp lainants are kept informed of the status of the investigat ion and
any appeals, and that when a violat ion of Title IX is found, the complainants are timely
provided w ith remedies to ensure their needs are addressed and to prevent further
discrimination or harassment. In addition, the letter will specifically include the following
offer to the Student:

a)

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b)

c)

Action Item IV: Reporting Requirements
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Lthe College will provide the following documentat ion to OCR
demonstrating its implementation of Action IV: copies of the lette r issued to the Student,
copies of any responses received to the letter and documentation of any actions taken by the
College as a result; and wr itten verification that the College prov ided

Action Item V: Student Outreach

To ensure the College is prov iding prompt and equitable resolutions of Title IX complaints by
students, employees and third parties, the College will offer on line training educating students on
Title IX topics related to sex discrim ination, including sexual harassment, to its matriculat ing
freshman, transfer, and underg raduate. This train ing will include informat ion regarding the ro le
and dut ies of the Title IX coordinator/assistant coordinators; the College's revised Title IX policies
and grievance procedures (once they have been approved by OCR); how to recognize incidents
of sex discrim ination (including sexual harassment); how and where to report incidents of sex

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discrimination; the consequences for violating the College's policy against sex discrimination;
and resources available to students and employees who have been subjected to sex
discrimination, including sexual harassment.
Action Item V: Reporting Requirements
1. By December 7. 2018. the College will provide OCRsufficient documentation demonstrating
compliance with Action V, including a copy of the student training; information or
documentation demonstrating that annual training is offered to all students; and
documentation regarding the consequences for violating the College's policies against sex.

MONITORING: GENERALPRINCIPLES
The College understands that by signing this Agreement, it agrees to provide the foregoing
information in a timely manner in accordance with the reporting requirements of this
Agreement. Further, the College understands that during the monitoring of this Agreement, if
necessary, OCR may visit the College, interview staff and students, and request such additional
reports or data as are necessary for OCRto determine whether the College has fulfilled the terms
of this Agreement and is in compliance with Title IX and its implementing regulation at 34 C.F.R.
Part 106. Upon completion of the obligations of this Agreement, OCRshall close and dismiss this
case.
The College understands and acknowledges that OCR may initiate administrative enforcement or
judicial proceedings to enforce the specific terms and obligations of this Agreement. Before
initiating administrative enforcement (34 C.F.R.§§ 100.9, 100.10), or judicial proceedings to
enforce this Agreement, OCRshall give the College written notice of the alleged breach and sixty
(60) calendar days to cure the alleged breach.
This Agreement will become effective immediately upon the signature of the College's
representative below.

Or. Thad J. Anglin
Cisco College

resident

Date'

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