UNITED STATES DEPARTMENT OF EDUCATION OFF ICE FOR CIVIL RI GHTS 32 OLD SLIP , 26TH FL OOR NEW Y ORK . N EW YOR K 10005 TIMOTHY C. J. BLA NCHARD D IR ECTO R NEW YO RK O FFICE January 8, 2015 Lee C. Bollinger President Columbia University 202 Low Library 535 West 116th Street, Mail Code 4309 New York, New York 10027 Re: Case No. 02-14-2332 Columbia University Dear President Bollinger: !~g( 6 l On the U.S. Department of Education , New York Office for Civil Rights (OCR) ),(b)(?) received the above-referenced complaint filed against Columbia University. The complainant alleged that the University discriminated on the basis of sex, by failing to promptly and equitably respond to complaints of sexual violence of which it had notice, including complaints of sexual assault filed by six University students (Students 1 through 6); and as a result, students, including Students 1 through 6, were subjected to a sexually hostile environment (Allegation 1). Additionally, the complainant alleged that the University retaliated against a student (Student 7) for providing support to another student during an investigation of a sexual assault complaint , by disciplining her in the fall !(b)(6! semester based on a false accusation that she revealed confidential information · about a sexual assault investigation (Allegation 2); and, the University retaliated against a another student (Student 8) for reporting in the campus newspaper about the climate of sexual harassment on campus, by issuing him a disciplinary warning and refusing to grant his requests for meetings as a reporter in spring 2014 (Allegation 3). OCR determined that these allegations are appropriate for investigation. OCR is responsible for enforcing Title IX of the Education Amendments of 1972 (Title IX), as amended, 20 U.S.C. § 1681 et seq. , and its implementing regulation at 34 C.F.R. Part 106, which prohibit discrimination on the basis of sex in programs and activities receiving financial assistance from the U.S. Department of Education (the Department). The University is a recipient of financial assistance from the Depai1ment. Therefore, OCR has jurisdictional authority to investigate this complaint under Title IX. The Departmentof Education'smission is to promote student achievementand preparation/or global competitivenessby fostering educationalexcellence and ensuringequal access. Page 2 of 7 -OCR Case Number 02-14-2332 The regulation implementing Title IX, at 34 C.F.R. § 106.71 incorporates by reference 34 C.F.R. § 100.7(e) of the regulation implementing Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq., which provides that: No recipient or other person shall intimidate, threaten, coerce, or discriminate against any individual for the purpose of interfering with any right or privilege secured by regulations enforced by OCR or because one has made a complaint, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing held in connection with a complaint. Because OCR has determined that it has jurisdiction and that the complaint was filed in a timely manner, it is opening the allegations for investigation. Please note that opening the allegations for investigation in no way implies that OCR has made a determination with regard to their merit. During the investigation, OCR is a neutral fact-finder, collecting and analyzing relevant evidence from the complainant, the recipient, and other sources, as appropriate. OCR will ensure that its investigation is legally sufficient and is dispositive of the allegation, in accordance with the provisions of Article III of OCR's Case Processing Manual. Enclosed is a document entitled provide you with an overview process. OCR will collect only proper precautions to protect the "OCR Complaint Processing Procedures." This document will of OCR's complaint evaluation, investigation, and resolution material needed to investigate this complaint and will take all identi ty of any individuals named in documents. To facilitate OCR's efforts to investigate this complaint, OCR requests that, within twenty (20) days of the date of this letter, you provide to OCR the information listed on the enclosed data request. If OCR does not receive the data in a timely manner, OCR may conduct a site visit to obtain the data. The regulation implementing Title VI of the Civil Rights Act of 1964, at 34 C.F.R. § 100.6 (b) and (c), requires that a recipient of federal financial assistance make available to OCR information that may be necessary for it to determine whether a recipient is in compliance with the regulations it enforces. This requirement is incorporated by reference in the regulation implementing Title IX, at 34 C.F.R. § l 06. 71. This information also is being requested pursuant to 34 C.F.R. § 99.31 (a)(3)(iii). OCR' s goal is the prompt and appropriate resolution of the allegations contained in a complaint. OCR offers, when appropriate , an Early Complaint Resolution (ECR) process, similar to mediation, to facilitate the voluntary resolution of complaints by providing an early opportunity for the parties involved to resolve the allegation(s). Some information about the ECR process is in the enclosure to this letter entitled, "OCR Complaint Processing Procedures," and on OCR's website at http://www2.ed.uov/about/offices/list/ocr/docs/ocrcpm.html#II. Also , when appropriate, a complaint may be resolved before the conclusion of an investigation after the recipient expresses an interest to OCR to resolve the complaint. In such cases, OCR obtains a resolution agreement signed by the recipient. This agreement must be aligned with the complaint allegations or the information obtained during the investigation, and it must be consistent with applicable regulations. Additional information about this voluntary resolution Page 3 of 7 -OCR Case Number 02-14-2332 process may be found in the enclosure entitled, "OCR Complaint Processing Procedures," and on OCR's website at http://www2.ed.gov/about/offices/list/ocr/docs/ocrcpm.html#III. Please be advised that the University may not harass, coerce, intimidate, or discriminate against any individual because he or she has filed a complaint or participated in the complaint resolution process. If this happens, the complainant may file another complaint alleging such treatment. Under the Freedom of Information Act , 5 U.S.C. § 552, it may be necessary to release this document and rela ted correspondence and records upon request. In the event that OCR receives such a request, it will seek to protect, to the extent provided by law, personally identifiable information , which, if released, could reasonably be expected to constitute an unwarranted invasion of personal privacy. OCR staff will contact you within twen ty (20) days to discuss the allegation and the complaint resolution process. In the interim, if you have any questions, please contact Gary Kiang, Compliance Team Attorney, at (646) 428-3761 or garv.kiang@ed.gov; or James Moser , Compliance Team Attorney, at 646-428-3792 or james.moser@ed.gov; Genara Necos, Compliance Team Attorney at (646) 428-3828 or uenara.necos@.ed.gov: or me , at (646) 4283806 or folice.bowen@ed.gov. Sincerely ,. Felice A. Bowen Compliance Team Leade r Encl. Page 4 of7 OCR Case Number 0271472332 Dara Request Columbia University Case . Student 1 Student 2: Student 3: Student 4: Student 5: Student 6: Student 7: Student 8: DATA DUE: Jnnunry 28, 2015 Please provide [he i/L'lnx for academic yeni'x 2012-2013 and 2013-2014 or in iilriti'rig \t'he/hur mu exist 1. ct Copies of the University's Title 1X grievance procedures and sex discrimlnatioll/liarasslitent (including sexual assault) policies and procedures. Include a dctailcd description of the complaint process, including each level of the process, the length or the process, and the types of records maintained, Also, provide the names and titles ot'thc University's staff responsible for handling complaints on the basis of sex, at each level of the process Provide a written explanation of the means by which the policies and procedures are ptihlicizcd to students, stall, and parents Submit copies of all materials disseminated Copies of the University's Student Handbooks. Copies of publications that contain the University's nondiscrimination notice, the URL for any electronic postings of nondiscrimination notice, and a list of campus locations whcic ilic notice of nondiscrimination is physically posted, it'any, A copy ofthc University's policies and procedures, and/or a description ofits practices in effect in academic years 201172012, 2012720" and 2013--2014, governing disciplinary or corrective actions that may be taken to address sexual harassment/assault by students; and the provision of to the survivors of sexual harassment/assault, if any. Copies of all informal and formal complaints, including records of oral complaints, made lay or (in behalf of students, including those made by or on behalf of Students 1- 6, in academic years 2011~2012, 2012-20" and 2013-2014, alleging sexual harassment/assault, For cacli complaint, provide the nalitc(s) ilidtvidualts) to whom the complaint was made, and the date the complaint was made; a detailed description of the complaint processing procedures employed to resolve the complaint: Page 5 of7 -OCR Case Number 02-14-2332 (c) (d) (e) (f) (g) (h) the length of the process; the name(s) and title(s) of the individual(s) involved in the handling of the complaint; all actions taken by the University in response to the concerns raised; the final outcome(s) of all investigations/hearings/appeals ; any corrective action taken; and any notice of the findings provided to the complainant. 5. Copies of all documentation related to each complaint identified in response to Item 4, including but not limited to correspondence, internal and external memoranda, investigative reports, witness statements, logs, forms, letters, hearing transcripts, meeting minutes and notes generated for each complaint. 6. Copies of any media maintained involving Students l through 6 and from the Facebook accoun ts of the University community; print outs articles. by the University regarding the alleged incidents the individuals accused , including print outs of pages students, those accused, and/or other members of the of other social media; and University newspaper 7. Copies of all documentation related to any reports of sexual assault made by or on behalf of Student 1 through 6, including but not limited to, a copy of any written complaint(s) or record(s) of oral complaint(s) made by the students, investigative reports, witness statements, electronic mail messages (emails), telephone logs, documentation related to any appeals, and correspondence. 8. A detailed description of the steps and actions the University took in response to comp laints of sexual harassment/assault made by or on behalf of Students l through 6, including: (a) (b) (c) (d) (e) (f) (g) (h) a description of the procedures employed by the University to investigate the complaints; a description of interim remedial measures (academic or other) provided by the University to the complainants during the pendency of the investigation(s); the timeline for completion of each stage of the investigation process; the types of records maintained; the final outcome of all investigation(s); the name(s) and title(s) of University staff involved in the investigation process; and the evidentiary standard applied by the University to determine the outcome of the complainants' complaints; and copies of the University's Title IX grievance procedures and sex discrimination/harassment (including sexual assault) policies and procedures relied upon to respond to any complaints filed by the complainants. 9. Copies of all documentation, including but not limited to, letters , emails, reports, notes, logs, meeting minutes, hearing transcripts, discipline records, telephone records, campus police records, and other external law enforcement agency records related to: Page 6 of 7 -OCR Case Number 02-14-2332 (a) (b) (c) (d) (e) (f) (g) the University's processing of the students' complaint(s); the University's handling/investigation of the students' complaint(s), including any notices to the parties; the disciplinary hearings, including any notices to the parties; those accused's request(s) for an appeal, includ ing any notices to the parties; the rehearing regarding the students' complaints and/or those accused's appeals; communications between the University and the students (or anyone on their behalt) regarding the accused students; and communications regarding those accused student's standing at the University pending completion of the investigation, appeal, and rehearing of the students' complaints. 10. Copies of the University's Code of Student Conduct and/or Student Disciplinary Code. 11. State whether the University conducts focus groups/meetings and/or holds informational sessions with the student community (e.g., women's groups, athletes, residential assistants, fraternity and sorority leaders, etc.) and/or University staff regarding students' rights under Title IX, how to report possible violations of Title IX, and/or the University's obligation to promptly and equitably respond to Title IX complaints. If so, provide the dates of such events, a description of the attendees, and any materials presented and/or distributed. 12. The name, office address, and telephone A detailed description of any training harassment and sexual assault, provided University staff. For each such training, (a) (b) (c) (d) number of the University's Title IX Coordinator. regarding sex discrimination, including sexual to the University's Title IX Coordinator or other include: the date(s) the training was provided; the names and qualifications of the individuals who provided the training; a list of the names and titles of the individuals who attended the training ; and copies of any materials distributed at the training. 13. A detailed description of the incident involving Student 7 that led to her discipline in or about fall 2013. Include (a) a description of the conduct in which she allegedly engaged; (b) the code infraction she was charged with; (c) the sanction imposed and (d) the name(s) and title(s) of the individual(s) involved in determining the sanction. Provide copies of all relevant documentation including letters, emails, reports, notes , logs, meeting minutes, hearing transcripts, discipline records, and telephone records. 14. A detailed description of the incident involving Student 8 and Universi ty staff that led to his discipline in or about spring 2014. Include (a) a description of the conduct in which he allegedly engaged; (b) the code infraction he was charged with; (c) the sanction imposed and (d) the name(s) and title(s) of the individual(s) involved in determining the sanction. Provide copies of all relevant documentation including letters, emails, reports, Page 7 of7 - OCR Case Number 02-14-2332 notes, logs, meeting minutes, hearing transcripts, discipline records, and telephone records. 15. A detailed description of the University's responses to Student 8's requests for meetings, in his capacity as a student repo11er, with University staff during spring 2014. 16. Copies of guidelines/policies University administrators. governing student newspaper staffs interaction with 17. The name, title, address, telephone number, fax number and email address of a contact person for this complaint. 18. Any other information the University believes will assist OCR in this investigation. UNITED STATES DEPARTMENT OF EDUCATION OFF ICE FOR CIVIL RI GHTS 32 OLD SLIP , 26TH FL OOR NEW Y ORK . N EW YOR K 10005 TIMOTHY C. J. BLA NCHARD D IR ECTO R NEW YO RK O FFICE January 8, 2015 Lee C. Bollinger President Columbia University 202 Low Library 535 West 116th Street, Mail Code 4309 New York, New York 10027 Re: Case No. 02-14-2332 Columbia University Dear President Bollinger: On !(b)(6},(b)(7)( I, the U.S. Department of Education , New York Office for Civil Rights (OCR) received the above-referenced complaint filed against Columbia University. The complainant alleged that the University discriminated on the basis of sex, by failing to promptly and equitably respond to complaints of sexual violence of which it had notice, including complaints of sexual assault filed by six University students (Students 1 through 6); and as a result, students, including Students 1 through 6, were subjected to a sexually hostile environment (Allegation 1). Additionally, the complainant alleged that the University retaliated against a student (Student 7) for providing support to another student during an investigation of a sexual assault complaint , by disciplining her in the fall semester based on a false accusation that she revealed confidential information · about a sexual assault investigation (Allegation 2); and, the University retaliated against a another student (Student 8) for reporting in the campus newspaper about the climate of sexual harassment on campus, by issuing him a disciplinary warning and refusing to grant his requests for meetings as a reporter in spring~ (Allegation 3). OCR determined that these allegations are appropriate for investigation. OCR is responsible for enforcing Title IX of the Education Amendments of 1972 (Title IX), as amended, 20 U.S.C. § 1681 et seq. , and its implementing regulation at 34 C.F.R. Part 106, which prohibit discrimination on the basis of sex in programs and activities receiving financial assistance from the U.S. Department of Education (the Department). The University is a recipient of financial assistance from the Depai1ment. Therefore, OCR has jurisdictional authority to investigate this complaint under Title IX. The Departmentof Education'smission is to promote student achievementand preparation/or global competitivenessby fostering educationalexcellence and ensuringequal access. Page 2 of 7 -OCR Case Number 02-14-2332 The regulation implementing Title IX, at 34 C.F.R. § 106.71 incorporates by reference 34 C.F.R. § 100.7(e) of the regulation implementing Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq., which provides that: No recipient or other person shall intimidate, threaten, coerce, or discriminate against any individual for the purpose of interfering with any right or privilege secured by regulations enforced by OCR or because one has made a complaint, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing held in connection with a complaint. Because OCR has determined that it has jurisdiction and that the complaint was filed in a timely manner, it is opening the allegations for investigation. Please note that opening the allegations for investigation in no way implies that OCR has made a determination with regard to their merit. During the investigation, OCR is a neutral fact-finder, collecting and analyzing relevant evidence from the complainant, the recipient, and other sources, as appropriate. OCR will ensure that its investigation is legally sufficient and is dispositive of the allegation, in accordance with the provisions of Article III of OCR's Case Processing Manual. Enclosed is a document entitled provide you with an overview process. OCR will collect only proper precautions to protect the "OCR Complaint Processing Procedures." This document will of OCR's complaint evaluation, investigation, and resolution material needed to investigate this complaint and will take all identi ty of any individuals named in documents. To facilitate OCR's efforts to investigate this complaint, OCR requests that, within twenty (20) days of the date of this letter, you provide to OCR the information listed on the enclosed data request. If OCR does not receive the data in a timely manner, OCR may conduct a site visit to obtain the data. The regulation implementing Title VI of the Civil Rights Act of 1964, at 34 C.F.R. § 100.6 (b) and (c), requires that a recipient of federal financial assistance make available to OCR information that may be necessary for it to determine whether a recipient is in compliance with the regulations it enforces. This requirement is incorporated by reference in the regulation implementing Title IX, at 34 C.F.R. § l 06. 71. This information also is being requested pursuant to 34 C.F.R. § 99.31 (a)(3)(iii). OCR' s goal is the prompt and appropriate resolution of the allegations contained in a complaint. OCR offers, when appropriate , an Early Complaint Resolution (ECR) process, similar to mediation, to facilitate the voluntary resolution of complaints by providing an early opportunity for the parties involved to resolve the allegation(s). Some information about the ECR process is in the enclosure to this letter entitled, "OCR Complaint Processing Procedures," and on OCR's website at http://www2.ed.uov/about/offices/list/ocr/docs/ocrcpm.html#II. Also , when appropriate, a complaint may be resolved before the conclusion of an investigation after the recipient expresses an interest to OCR to resolve the complaint. In such cases, OCR obtains a resolution agreement signed by the recipient. This agreement must be aligned with the complaint allegations or the information obtained during the investigation, and it must be consistent with applicable regulations. Additional information about this voluntary resolution Page 3 of 7 -OCR Case Number 02-14-2332 process may be found in the enclosure entitled, "OCR Complaint Processing Procedures," and on OCR's website at http://www2.ed.gov/about/offices/list/ocr/docs/ocrcpm.html#III. Please be advised that the University may not harass, coerce, intimidate, or discriminate against any individual because he or she has filed a complaint or participated in the complaint resolution process. If this happens, the complainant may file another complaint alleging such treatment. Under the Freedom of Information Act , 5 U.S.C. § 552, it may be necessary to release this document and rela ted correspondence and records upon request. In the event that OCR receives such a request, it will seek to protect, to the extent provided by law, personally identifiable information , which, if released, could reasonably be expected to constitute an unwarranted invasion of personal privacy. OCR staff will contact you within twen ty (20) days to discuss the allegation and the complaint resolution process. In the interim, if you have any questions, please contact Gary Kiang, Compliance Team Attorney, at (646) 428-3761 or garv.kiang@ed.gov; or James Moser , Compliance Team Attorney, at 646-428-3792 or james.moser@ed.gov; Genara Necos, Compliance Team Attorney at (646) 428-3828 or uenara.necos@.ed.gov: or me , at (646) 4283806 or folice.bowen@ed.gov. Sincerely ,. Felice A. Bowen Compliance Team Leade r Encl. Page 4 of7 OCR Case Number 0271472332 Dara Request Columbia University Case . Student 1 Student 2: Student 3: Student 4: Student 5: Student 6: Student 7: Student 8: DATA DUE: Jnnunry 28, 2015 Please provide [he i/L'lnx for academic yeni'x 2012-2013 and 2013-2014 or in iilriti'rig \t'he/hur mu exist 1. ct Copies of the University's Title 1X grievance procedures and sex discrimlnatioll/liarasslitent (including sexual assault) policies and procedures. Include a dctailcd description of the complaint process, including each level of the process, the length or the process, and the types of records maintained, Also, provide the names and titles ot'thc University's staff responsible for handling complaints on the basis of sex, at each level of the process Provide a written explanation of the means by which the policies and procedures are ptihlicizcd to students, stall, and parents Submit copies of all materials disseminated Copies of the University's Student Handbooks. Copies of publications that contain the University's nondiscrimination notice, the URL for any electronic postings of nondiscrimination notice, and a list of campus locations whcic ilic notice of nondiscrimination is physically posted, it'any, A copy ofthc University's policies and procedures, and/or a description ofits practices in effect in academic years 201172012, 2012720" and 2013--2014, governing disciplinary or corrective actions that may be taken to address sexual harassment/assault by students; and the provision of to the survivors of sexual harassment/assault, if any. Copies of all informal and formal complaints, including records of oral complaints, made lay or (in behalf of students, including those made by or on behalf of Students 1- 6, in academic years 2011~2012, 2012-20" and 2013-2014, alleging sexual harassment/assault, For cacli complaint, provide the nalitc(s) ilidtvidualts) to whom the complaint was made, and the date the complaint was made; a detailed description of the complaint processing procedures employed to resolve the complaint: Page 5 of7 -OCR Case Number 02-14-2332 (c) (d) (e) (f) (g) (h) the length of the process; the name(s) and title(s) of the individual(s) involved in the handling of the complaint; all actions taken by the University in response to the concerns raised; the final outcome(s) of all investigations/hearings/appeals ; any corrective action taken; and any notice of the findings provided to the complainant. 5. Copies of all documentation related to each complaint identified in response to Item 4, including but not limited to correspondence, internal and external memoranda, investigative reports, witness statements, logs, forms, letters, hearing transcripts, meeting minutes and notes generated for each complaint. 6. Copies of any media maintained involving Students l through 6 and from the Facebook accoun ts of the University community; print outs articles. by the University regarding the alleged incidents the individuals accused , including print outs of pages students, those accused, and/or other members of the of other social media; and University newspaper 7. Copies of all documentation related to any reports of sexual assault made by or on behalf of Student 1 through 6, including but not limited to, a copy of any written complaint(s) or record(s) of oral complaint(s) made by the students, investigative reports, witness statements, electronic mail messages (emails), telephone logs, documentation related to any appeals, and correspondence. 8. A detailed description of the steps and actions the University took in response to comp laints of sexual harassment/assault made by or on behalf of Students l through 6, including: (a) (b) (c) (d) (e) (f) (g) (h) a description of the procedures employed by the University to investigate the complaints; a description of interim remedial measures (academic or other) provided by the University to the complainants during the pendency of the investigation(s); the timeline for completion of each stage of the investigation process; the types of records maintained; the final outcome of all investigation(s); the name(s) and title(s) of University staff involved in the investigation process; and the evidentiary standard applied by the University to determine the outcome of the complainants' complaints; and copies of the University's Title IX grievance procedures and sex discrimination/harassment (including sexual assault) policies and procedures relied upon to respond to any complaints filed by the complainants. 9. Copies of all documentation, including but not limited to, letters , emails, reports, notes, logs, meeting minutes, hearing transcripts, discipline records, telephone records, campus police records, and other external law enforcement agency records related to: Page 6 of 7 -OCR Case Number 02-14-2332 (a) (b) (c) (d) (e) (f) (g) the University's processing of the students' complaint(s); the University's handling/investigation of the students' complaint(s), including any notices to the parties; the disciplinary hearings, including any notices to the parties; those accused's request(s) for an appeal, includ ing any notices to the parties; the rehearing regarding the students' complaints and/or those accused's appeals; communications between the University and the students (or anyone on their behalt) regarding the accused students; and communications regarding those accused student's standing at the University pending completion of the investigation, appeal, and rehearing of the students' complaints. 10. Copies of the University's Code of Student Conduct and/or Student Disciplinary Code. 11. State whether the University conducts focus groups/meetings and/or holds informational sessions with the student community (e.g., women's groups, athletes, residential assistants, fraternity and sorority leaders, etc.) and/or University staff regarding students' rights under Title IX, how to report possible violations of Title IX, and/or the University's obligation to promptly and equitably respond to Title IX complaints. If so, provide the dates of such events, a description of the attendees, and any materials presented and/or distributed. 12. The name, office address, and telephone A detailed description of any training harassment and sexual assault, provided University staff. For each such training, (a) (b) (c) (d) number of the University's Title IX Coordinator. regarding sex discrimination, including sexual to the University's Title IX Coordinator or other include: the date(s) the training was provided; the names and qualifications of the individuals who provided the training; a list of the names and titles of the individuals who attended the training ; and copies of any materials distributed at the training. 13. A detailed description of the incident involving Student 7 that led to her discipline in or about fall 2013. Include (a) a description of the conduct in which she allegedly engaged; (b) the code infraction she was charged with; (c) the sanction imposed and (d) the name(s) and title(s) of the individual(s) involved in determining the sanction. Provide copies of all relevant documentation including letters, emails, reports, notes , logs, meeting minutes, hearing transcripts, discipline records, and telephone records. 14. A detailed description of the incident involving Student 8 and Universi ty staff that led to his discipline in or about spring 2014. Include (a) a description of the conduct in which he allegedly engaged; (b) the code infraction he was charged with; (c) the sanction imposed and (d) the name(s) and title(s) of the individual(s) involved in determining the sanction. Provide copies of all relevant documentation including letters, emails, reports, Page 7 of7 - OCR Case Number 02-14-2332 notes, logs, meeting minutes, hearing transcripts, discipline records, and telephone records. 15. A detailed description of the University's responses to Student 8's requests for meetings, in his capacity as a student repo11er, with University staff during spring 2014. 16. Copies of guidelines/policies University administrators. governing student newspaper staffs interaction with 17. The name, title, address, telephone number, fax number and email address of a contact person for this complaint. 18. Any other information the University believes will assist OCR in this investigation.