Title IX Policies & Procedures
Title IX Defined:
"No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance..."
(Title IX of the Educational Amendments of 1972)
Success For All, Takes Us All
The Grand Haven Area Public Schools are committed to the expectation that all students will learn.
It is our obligation to provide each student in our community a positive environment for learning so they will experience success and realize their fullest potential. This school district accepts the responsibility to work in partnership with the community to provide an excellent education that will prepare all learners for the challenges of a changing global society.
Sex Discrimination Complaints
Complaints can include:
- Sexual Harassment
- Sexual Violence
- Gender Identity
- Failure to Conform to Stereotypical Notions of Masculinity or Femininity
- Sexual Orientation or Perceived Sexual Orientation
Grand Haven Area Public Schools believes providing a safe and supportive atmosphere for all students is vital for learning to occur at the highest levels. We are committed to ensuring this happens through universal measures that all schools in our district participate in. These include:
Capturing Kids' Hearts
Positive Behavior Interventions and Supports and Multi-Tier System of Supports
One Page Strategic Plan
GHAPS Administrative Title IX Comprehensive Training
Harassment Complaint Form
Harassment Complaint Form
All complaints of harassment and discrimination shall be reported using either of the following forms. Hard copy forms need to be reported to the building administrator immediately. Building administrators shall forward received forms to the Title IX coordinator immediately after reviewing.
- A school investigations is separate from a police investigation. The school is not obligated to wait for a conclusion to a police investigation. Ideally, they should be run concurrently and cooperatively.
- Document all interviews and a summary of evidence in the district Title IX investigation Google Drive folder
- Maintain all records of a Title IX investigation for six years after the student graduates
Steps from start to finish:
- Collect information
- Examine documents
- Interview witnesses
- Review files
- Review law enforcement documents
- Identify disputed facts and follow up
- Have appeal process
- Written notice of outcome
Interim measures provide support and relief for the complainant prior to the final summary. It is important to document and communicate all interim measures taken to parents, teachers, and the Title IX coordinator.
- Minimize burden on complainant
- Avoid contact with alleged perpetrator
- Allow complainant to change academic or extracurricular activities
- Provide support services
- Increase monitoring and supervision at locations where alleged misconduct occurred
The burden of proof for a school Title IX investigation is a preponderance of the evidence. The school should not wait for a police investigation to be completed prior to promptly completing its' own investigation. The building administrator should work cooperatively with the police through this process. Do not announce consequences on the spot during an interview. If necessary, use a summary suspension for a student, or paid administrative leave for an employee.
Written Notice of Outcome
This is the final summary to the families involved in the investigation. They should be individualized to the complainant, witnesses, or perpetrator. Do not put in writing consequences, or other private information, to families other than the one that it directly involves.
- Give to all parties
- Summarize allegations and response
- Summarize evidence reviewed
- Reference meeting dates and participants
- Do not put perpetrator’s discipline in writing, but ok to do verbally
- Designate a school counselor as primary responsible harassment coordinator
- Train all employees
- Develop/distribute materials
- Conduct prevention programs
- Issue policy statements
- Conduct climate check
- Training for specific students
- Develop protocol for working with local law enforcement
Flowchart is adapted from Hampden/Wilbraham Regional School District Procedures for Addressing Discriminatory Harassment Behavior
Investigation steps are adapted from the Thrun Law Group Presentations by Broaddus, Gardner, Martin, and Swem.
Broaddus, K., Martin, D., Swem, L. (2015). Title IX Compliance Training (PDF). Grand Haven, MI June 24, 2015.
Gardner, T. (2015). Title IX Compliance Training (PDF). Retrieved from http://mybb.gvsu.edu on June 25, 2015
The two cited presentations were prepared by the Thrun Law Group and presented on two separate days, June 24, 2015 in Grand Haven, MI and June 25, 2015 in Grand Rapids, MI. The PDF presentations covered current legislation, case law, and case studies to implement compliant Title IX practices and procedures for public school districts in Michigan.
Buzuvis, E., & Newhall, K. (n.d.). In Equality, sports, and Title IX. Retrieved July 19, 2015, from http://ed.ted.com/lessons/equality-sports-and-title-ix-erin-buzuvis-and-kristine-newhall
Ted Ed is a site that has integrated videos with lessons for educators to use. This video is fully animated with a narration by the author to explain the history and current practices of Title IX and how they apply to sports.
Hampden/Wilbraham Regional School District, . (n.d.). In Procedures for Addressing Discriminatory Harassment Behavior. Retrieved July 26, 2015, from http://www.sde.ct.gov/sde/lib/sde/pdf/equity/discriminatory_flow_chart.pdf
This resource was from a regional school district that would be similar to an intermediate school district in Michigan. They offered this resource as a baseline for districts to work from to ensure compliance from the schools they serve. It served as the basis for the flowchart that I created for our district.
Rose, Kolb, Barra-Zumman, The Equitable School Continuum, Vol. 3.2 (Andover, MA: The NETWORK, Inc., 1991).
This resource helps with the basics of creating a compliance checklist targeted for a district's Title IX coordinator. There are many intricacies to Title IX compliance, which can be overwhelming to an individual that serves as a coordinator for a large district.