UW-Eau Claire Sexual Violence and Sexual Harassment Policy

1. The University of Wisconsin-Eau Claire provides a teaching, learning, and working environment in which faculty, staff, and students can discover, examine critically, preserve, and transmit knowledge, wisdom, and values that will improve quality of life for all. To promote these institutional values, UW-Eau Claire is committed to creating and maintaining a community environment that is free from sexual violence and sexual harassment.

Purpose and scope of policy

This policy prohibits acts of sexual violence and sexual harassment on university property, at university-sanctioned or university-affiliated events, and where off-campus conduct affects a member of the university community. The university is committed to educating its community and to promptly and effectively responding to and redressing conduct that violates this policy. This policy provides the UW-Eau Claire community with information and resources to identify, report, and respond to sexual violence and sexual harassment including sexual assault, sexual exploitation, stalking, and dating and domestic violence. These efforts support the overall missions of UW-Eau Claire and the UW System.

This policy applies to:

1. University-sponsored and supported activities held both on and off campus, including those held in other municipalities, states, and nations.
2. All students while they are on campus or if their off-campus conduct meets any of the following criteria:
   -The conduct constitutes or would constitute a serious criminal offense, regardless of the existence of any criminal proceedings.
   -The conduct indicates that the student presented or may present a danger or threat to the health or safety of self or others.
   -The conduct demonstrates a pattern of behavior that seriously impairs the University’s ability to fulfill its teaching, research, or public service       missions.
3. All other members of the University community (including, but not limited to employees, volunteers, visitors, guests, contractors, and third-party vendors) while they are on campus or engaged in activities associated with university-sponsored and supported activities.

Title IX statement

Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq., prohibits discrimination on the basis of sex in any educational program or activity receiving federal financial assistance.

I. Definitions

Advisor. An individual who assists a complainant or respondent in any grievance proceeding or related meetings. This individual may or may not be an attorney.

Clear and convincing evidence. Information that would persuade a reasonable person to have firm belief that a proposition is more likely true than not true. It is a higher standard of proof than “preponderance of the evidence.”

Complainant. Any individual who is alleged to be the subject of sexual harassment, sexual assault, dating violence, domestic violence, stalking, or sexual exploitation, as defined in this policy.

Confidential Employee. Any employee who is a licensed medical, clinical, or mental health professional when acting in that role in the provision of services to a patient or client who is a university student or employee. A Confidential Employee will not report specific information concerning a report of sexual violence or sexual harassment received by that Employee in the Employee’s professional capacity unless with the consent of the reporting individual or unless required by the Employee’s license or by law.

Confidential Resource. Individuals or agencies in the community, whose professional license, or certification permits that individual or agency to preserve the confidentiality of the patient or client.

Consent. Words or overt actions by a person who is competent to give informed consent, indicating a freely given agreement to engage in sexual activity or other activity referenced in the definitions of sexual assault and sexual exploitation. A person is unable to give consent if the person is in a state of incapacitation because of drugs, alcohol, physical or intellectual disability, or unconsciousness.

Dating Violence. Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the complainant; and where the existence of such a relationship shall be determined based on a consideration of the following factors: the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship.

Domestic Violence. Felony or misdemeanor crimes of violence committed by a current or former spouse or intimate partner of the complainant, by a person with whom the complainant shares a child in common, by a person who is cohabitating with or has cohabitated with the complainant as a spouse or intimate partner, by a person similarly situated to a spouse of the complainant under the domestic or family violence laws of Wisconsin, or by any other person against an adult or youth complainant who is protected from that person’s acts under the domestic or family violence laws of Wisconsin as per ss. 813.12(1)(am) and 968.075, Stats.

Employee.  Any individual who holds a faculty, academic staff, university staff, limited, student employment, employee-in-training, temporary, or project appointment.  (See, e.g., UW System Administrative Policy 1225 (formerly GEN 0), General Terms and Definitions. (https://www.wisconsin.edu/uw-policies/uw-system-administrative-policies/general-terms-and-definitions/))

Education Program or Activity. For purposes of Title IX misconduct only, locations, events, or circumstances over which the university exercised substantial control over both the respondent and the context in which the relevant misconduct occurs, and also includes any building owned or controlled by a student organization that is officially recognized by the university.

Executive Order 54. Executive Order issued by Governor Walker in 2011 requiring that university employees report incidents of child abuse and neglect which they observe or learn of in the course of their employment. Such reports must be personally and immediately made to law enforcement or the county department of social services or human services. (https://docs.legis.wisconsin.gov/code/executive_orders/2011_scott_walker/2011-54.pdf)

Formal Title IX Complaint. For the purposes of Title IX misconduct only, a document filed by a complainant or signed by the Title IX Coordinator alleging sexual harassment, sexual assault, dating violence, domestic violence, or stalking against a respondent and requesting that the institution investigate the allegations. At the time of filing of the formal Title IX complaint, the complainant must be participating in or attempting to participate in an educational program or activity. A formal complaint may be filed in person, by mail, or by electronic mail, or any other method designated by the university. A formal Title IX complaint shall include a physical or digital signature of the complainant or the Title IX Coordinator.

Incapacitation. The state of being unable to physically or mentally make informed rational judgments and effectively communicate, and may include unconsciousness, sleep, or blackouts, and may result from the use of alcohol or other drugs. Where alcohol or other drugs are involved, evaluation of incapacitation requires an assessment of how the consumption of alcohol or drugs affects a person’s decision-making ability; awareness of consequences; ability to make informed, rational judgments; capacity to appreciate the nature and quality of the act; or level of consciousness. The assessment is based on objectively and reasonably apparent indications of incapacitation when viewed from the perspective of a sober, reasonable person.

Official with Authority. Any official of the university who has the authority to institute corrective measures on behalf of the university.

Office for Civil Rights.  The U.S. Department of Education office that is responsible for enforcing Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, and other education-based discrimination acts. http://www2.ed.gov/about/offices/list/ocr/complaints-how.html

Preponderance of the Evidence.  Information that would persuade a reasonable person that a proposition is more probably true than not true.  It is a lower standard of proof than “clear and convincing evidence” and is the minimum standard for a finding of responsibility.

Respondent. An individual who has been reported to be the perpetrator of sexual harassment, sexual assault, dating violence, domestic violence, stalking, or sexual exploitation, as defined in this policy.

Responsible Employee.  Any employee (other than a “confidential resource”) who has been given the duty of reporting incidents of sexual misconduct by students or employees to the Title IX coordinator or other appropriate school designee.

Retaliation. Intimidation, threats, coercion, or discrimination against any individual for the purpose of interfering with any right or privilege secured in, or because the individual has made a report or complaint, testified, assisted, or participated or refused to participate in any manner in an investigation, proceeding, or hearing under this policy.

Sex Discrimination.  Discrimination on the basis of sex or gender. Sexual harassment and sexual assault are forms of sex discrimination. [See 20 USC §§ 1681-1688]

Sexual Assault. An offense that meets any of the following definitions:

1. Rape: The penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of the complainant, without the consent of the complainant.
2. Fondling: The touching of the private body parts of the complainant for the purpose of sexual gratification, without the consent of the complainant, including instances where the complainant is incapable of giving consent because of the complainant’s age or because of the complainant’s temporary or permanent mental incapacity.
3. Incest: Sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law as per s. 944.06, Stats.
4. Statutory Rape: Sexual intercourse with a complainant who is under the statutory age of consent as per s. 948.02, Stats.

Sexual Exploitation. Attempting, taking, or threatening to take, nonconsensual sexual advantage of another person. Examples include:

1. Engaging in the following without the knowledge and consent of all participants:
   • Observing, recording, or photographing private body parts or sexual activity of the complainant.
   • Allowing another person to observe, record, or photograph sexual activity or private body parts of the complainant.
   • Otherwise distributing recordings, photographs, or other images of the sexual activity or private body parts of the complainant.
2. Masturbating, touching one’s genitals, or exposing one’s genitals in the complainant’s presence without the consent of the complainant, or inducing the complainant to do the same.
3. Dishonesty or deception regarding the use of contraceptives or condoms during the course of sexual activity.
4. Inducing incapacitation through deception for the purpose of making the complainant vulnerable to non-consensual sexual activity.
5. Coercing the complainant to engage in sexual activity for money or anything of value.
6. Threatening distribution of the following, to coerce someone into sexual activity or providing money or anything of value:
   • Photos, videos, or recordings depicting private body parts or sexual activity of the complainant.
   • Other information of a sexual nature involving the complainant, including sexual history or sexual orientation.

Sexual Harassment. Conduct on the basis of sex that satisfies one or more of the following:

1. Quid pro quo sexual harassment.
   • An employee of the institution conditions the provision of an aid, benefit, or service of the institution directly or indirectly on an individual’s participation in unwelcome sexual conduct.
   • An employee of the institution either explicitly or implicitly conditions the provision of an academic, professional, or employment-related opportunity, aid, benefit, or service on an individual’s participation in unwelcome sexual conduct.
2. Hostile environment sexual harassment.
   • Unwelcome conduct of a sexual nature directed towards a student, an employee, or a person participating in a program or activity of the university that, when using the legal “reasonable person” standard, is so severe, pervasive, and objectionably offensive that it effectively denies the person equal access to the institution’s education program or activity.
   • Unwelcome conduct of a sexual nature directed towards an individual that, when using the legal “reasonable person” standard, is so severe or pervasive and objectively offensive that it has the purpose or effect of unreasonably interfering with an individual’s academic or work performance or participation in a university sponsored or supported activity.

Sexual Violence. The phrase, as used in this policy, refers to incidents involving sexual assault, dating violence, domestic violence, stalking, and sexual exploitation.

Stalking.  Engaging in a course of conduct directed at the complainant that would cause a reasonable person to fear for their safety or the safety of others; or suffer substantial emotional distress.

Student.  Any person who is registered for study in a University of Wisconsin System institution for the academic period in which the alleged act of sexual violence or sexual harassment occurred, or between academic periods for continuing students. [See Chapter UWS 17.02(14), Wis. Admin. Code.]

Title IX.  Title IX of the Education Amendments of 1972 (20 U.S.C. sec. 1681 et seq.; 34 C.F.R. Part 106)(as amended) is a federal law that states, “[n]o 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.” 20 U.S.C. § 1681(a).

Title IX Misconduct: A report of sexual harassment or sexual violence under this policy will be considered Title IX Misconduct when a formal Title IX complaint (as defined in this section) is either filed by a complainant or signed by the Title IX Coordinator and the alleged conduct meets the definition of sexual harassment, sexual assault, dating violence, domestic violence, or stalking as defined in 34 C.F.R. 106.30, occurred within a university “education program or activity” (as defined in this section) and occurred against the complainant while in the United States; and the complainant is participating in or attempting to participate in a university education program or activity at the time they file the formal complaint. Title IX misconduct cases will follow procedures as detailed in Chs. UWS 4.11-24 (faculty), UWS 11.13-26 (academic staff), UWS 17.16-21 (students), and Appendix (university employees other than faculty or academic staff).

Title IX Coordinator (and Deputies).  An employee designated to coordinate compliance with Title IX, who plays an important role in an institution’s efforts to ensure equitable opportunity for all students and employees, and who works with school officials to remind the school community that students and employees must have equal access to all programs.

Trauma-Informed Care.  Trauma-informed care reflects an understanding of trauma and emphasizes creating services and programs that are sensitive and directly responsive to the trauma that many victims and survivors experience following a violent crime.  Trauma-informed care programs identify and limit potential triggers to reduce their re-traumatization and protect their mental and emotional health. https://www.justice.gov/ovw/blog/importance-understanding-trauma-informed-care-and-self-care-victim-service-providers.

Trauma-informed care is an organizational structure and treatment framework that involves understanding, recognizing, and responding to the effects of all types of trauma.  Trauma-informed care also emphasizes physical, psychological and emotional safety for both consumers and providers, and helps survivors rebuild a sense of control and empowerment.  See also: http://www.traumainformedcareproject.org/resources/SAMHSA%20TIC.pdf; and http://www.nsvrc.org/sites/default/files/publications_nsvrc_guides_building- cultures-of-care.pdf

A process that employs trauma-informed care accounts for the impact of trauma but does not recognize symptoms of trauma as evidence that a particular incident did or did not occur.

Violence Against Women Act (VAWA).  Federal law enacted in 1994, which promotes the investigation and prosecution of violent crimes against women, among other objectives.  Recently, it enacted amendments to the Clery Act [42 U.S.C. §§ 13701-14040], through the Campus Sexual Violence Elimination Act (SaVE) provision, Section 304.

II. Role and duties of university officials and employees

A. Title IX Coordinator

The duties of the UW-Eau Claire Title IX Coordinator are described in the institutional position description. Those duties include:

• receiving reports of sexual violence and sexual harassment
• maintaining appropriate records
• providing or supporting the provision of appropriate education and training; maintaining ongoing communication with any Deputy Title IX Coordinators and the Title IX Committee
• overseeing and/or investigating allegations of sexual violence and sexual harassment, as appropriate
• coordinating the effective implementation of supportive measures
• ensuring that applicable policies, resources, and other information is up-to-date and properly disseminated.

The duties of the Title IX Coordinator will be guided by principles of trauma-informed care and ensuring equity and due process for complainants and respondents.

B. Title IX Committee

The Title IX committee at UW-Eau Claire meets on a regular basis to

• discuss policy implementation and revision
• assess the effectiveness of trainings and educational programming
• address campus climate issues
• provide guidance to the Title IX Coordinator.

The following are offices represented on this committee: Affirmative Action, Dean of Students, Human Resources

C. Responsible Employees

UW-Eau Claire has designated individuals with the following titles as “Responsible Employees” under this policy: 

• Chancellor,
• Provost,
• Vice Chancellors,
• Assistant Chancellors,
• Associate Vice Chancellors,
• Deans,
• Department Chairs,
• Unit Directors,
• Title IX Coordinator and Deputy Title IX Coordinators,
• Dean of Students (including Assistant Dean of Students and Student Assistance Coordinator)
• Supervisors of Student Employees,
• Academic Advisors,
• Head and Assistant Coaches of athletic teams,
• Hall Directors,
• Resident Assistants,
• Faculty Advisors to Student Organizations,
• Blugold Beginnings College Coaches, and
• University Police officers.

Responsible Employees are not necessarily “Officials with Authority” to institute corrective measures on behalf of the university. These individuals should be properly trained to do the following:

• Be familiar with definitions of sexual violence and sexual harassment.
• Be familiar with this and other related policies.
• Be prepared to respond should an individual report an incident of sexual violence or sexual harassment.
• Be familiar with resources on campus to which to refer a reporting individual.

D. Official with Authority

UW-Eau Claire has designated individuals with the following titles as “Officials with Authority,” under this policy, as they have the authority to institute corrective measures on behalf of the university. All Officials with Authority are also Responsible Employees. 

E. All Employees

Regardless of whether they are a “Responsible Employee” or an “Official with Authority,” all employees are required to comply with the following reporting obligations.

In accordance with § 36.11(22), Wis. Stats., employees who witness an act of sexual assault, or who receive a first-hand report of sexual assault from an enrolled student, must report that information to the Office of the Dean of Students or designee. “Confidential Employees”, described below, are only required to report the occurrence of the sexual assault without any personally identifying information about the complainant or respondent.

All employees must comply with Executive Order 54 (https://docs.legis.wisconsin.gov/code/executive_orders/2011_scott_walker/2011-54.pdf), which requires that university employees report incidents of child abuse and neglect that they observe or learn of in the course of their employment. Such reports must be personally and immediately made to university law enforcement or the county department of social services or human services.

III. Reporting an incident of sexual violence or sexual harassment

A. Reporting options

Those who have been subjected to an incident of sexual violence or sexual harassment have several options for reporting the incident:

• Elect not to report (unless the individual is an employee who has information about a sexual assault as described in II.D. above)
• Report to a confidential employee:

Center for Awareness of Sexual Assault
(715) 836-HELP (4357)
casa@uwec.edu | 311C, Hibbard Humanities Hall

Counseling Services
(715) 836-5521
Counsl01@uwec.edu  2122, Vicki Lord Larson Hall (Old Library)

Student Health Services
(715) 836-5360
shs@uwec.edu | 150, Crest Wellness Center

• Report to the campus Title IX Coordinator or Deputy Title IX Coordinator:

Director of Affirmative Action and Title IX Coordinator
 (715) 836-2387
affirm01@uwec.edu | 101, Schofield Hall

Dean of Students and Deputy Title IX Coordinator
 (715) 836-5626
dos@uwec.ecu | 204, Schofield Hall

• Report to campus law enforcement:

University Police
(715) 836-2222
police@uwec.edu  119, Crest Wellness Center

• Report to local law enforcement:

Eau Claire Police                                 Eau Claire County Sheriff
(715) 839-4972                                    (715) 839-4709

Individuals have the option to file a complaint with the U.S. Department of Education, Office for Civil Rights: http://www2.ed.gov/about/offices/list/ocr/docs/howto.html

Note:  An individual may make a report to one or more of the offices or individuals noted above.

B. Amnesty

Individuals, including complainants, respondents, and witnesses, who have made a complaint, testified, assisted, or participated in an investigation, proceeding, or hearing regarding incidents of sexual harassment or sexual violence generally will not be issued citations by campus law enforcement or subject to disciplinary sanctions for alcohol violations arising out of the same facts and circumstances of the alleged incident unless the institution determines that the violation was egregious, and/or placed the health or safety of any person at risk, and was beyond the amnesty provided by state law. (See https://www.doj.state.wi.us/sites/default/files/ocvs/act279/Sexual%20Assault%20Victim%20Amnesty%20What%20You%20Should%20Know.pdf.)

C. Confidentially

Individuals, including complainants, who report to any of the offices or individuals noted above, or to any other university employee, except confidential employees or resources as defined in Appendix B, cannot be assured absolute confidentiality. However, information provided in the report and in any subsequent, related proceeding will only be shared with those individuals who have a need to know to fulfill obligations consistent with university policies or laws.

D. Resources and Supportive Measures

Resources

The university offers a variety of resources that are available to individuals involved in incidents of sexual violence or sexual harassment, including the following:

Center for Awareness of Sexual Assault
(715) 836-HELP (4357)
casa@uwec.edu | 311C, Hibbard Humanities Hall

Counseling Services
(715) 836-5521
Counsl01@uwec.edu  2122, Vicki Lord Larson Hall (Old Library)

Gender & Sexuality Resource Center
(715) 836-2693
speakout@uwec.edu | 220M, Davies Student Center

Student Health Services
(715) 836-5360
shs@uwec.edu | 150, Crest Wellness Center

Supportive Measures

1. The university will work with individuals involved in alleged incidents of sexual violence and sexual harassment to undertake appropriate measures to assist in their safety and wellbeing.  These may include no-contact directives, academic or work modifications, and relocation of living or working space. Supportive measures are available to complainants and respondents. 

E. Procedures

1. University Procedures:
   1. When a report is made to the Title IX Coordinator alleging that a student has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply. 
   2. When a report is made to the Title IX Coordinator alleging that a faculty member has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply. Chapters UWS 4 and 7, Wis. Admin. Code and UWS 6, Wis. Admin. Code.
   3. When a report is made to the Title IX Coordinator alleging that a member of the academic staff has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply. Chapters UWS 11 and 13, Wis. Admin. Code. 
   4.  When a report is made to the Title IX Coordinator alleging that a member of the university staff has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply. 
   5.  When a report is made to the Title IX Coordinator alleging that any other university employee who does not fall into any of the above categories has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply. 

2. Title IX Misconduct Informal Resolution Procedures

   At any time prior to reaching a determination regarding responsibility for Title IX misconduct, the university may facilitate an informal resolution process, such as mediation, that does not involve a full investigation and adjudication, provided that the university:

   1. Provides to the parties a written notice disclosing:
      1. the allegations
      2. the requirements of the informal resolution process including the circumstances under which it precludes the parties from resuming a formal complaint arising from the same allegations
      3. at any time prior to agreeing to a resolution any party has the right to withdraw from the informal resolution process and resume the grievance process with respect to the formal complaint
      4. any consequences resulting from participating in the informal resolution process, including the records that will be maintained or could be shared
         1. Obtains the parties’ voluntary, written consent to the informal resolution process
         2. Does not offer or facilitate an informal resolution process to resolve allegations that an employee sexually harassed a student.

   The university may not require as a condition of enrollment or continuing enrollment, or employment or continuing employment, or enjoyment of any other right, waiver of the right to an investigation and adjudication of Title IX misconduct. Similarly, the university may not require the parties to participate in an informal resolution process to address Title IX misconduct and may not offer an informal resolution process for Title IX misconduct unless a formal complaint is filed. The requirements of this section do not apply to allegations of sexual harassment and sexual violence that do not constitute Title IX misconduct.

3. Law Enforcement Procedures:
   • When a report is made to University Police alleging that an individual has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply: http://www.uwec.edu/Police/
   • When a report is made to Eau Claire City Police or Eau Claire County Sheriff alleging that an individual has engaged in an act of sexual violence or sexual harassment, the procedures linked here apply: https://www.eauclairewi.gov/government/our-divisions/police-department

F. Prompt Resolution

The university offices and employees that receive a report of sexual violence or sexual harassment will endeavor to resolve the matter in a timely manner, with consideration to available information and context.

1. Time Frames

Best efforts will be made for the university to complete an informal resolution process or an investigation of a complaint within 90 calendar days. The 90 calendar day timeframe and any other time frame set by the university related to appeals and conclusion of the grievance process may be extended for good cause. Good cause may include but is not limited to considerations such as:

• the absence of a party or party’s advisor or witness
• concurrent law enforcement activity
• the need for language assistance or accommodation of disabilities.

The complainant and the respondent will be notified in writing of an extension for good cause.

2. Potential Sanctions

The procedures identified above provide for disciplinary action against employees and students who are found responsible for violating a university policy. For students, such sanctions include those listed in UWS 17. Employee sanctions may include measures that range from a written reprimand through dismissal. Vendors and guests may be subject to other sanctions.

3. Notice of Outcome

Both the complainant and the respondent will be provided with notice of the outcome of the final resolution. 

G. Prohibition Against Retaliation

Prohibited retaliation includes intimidation, threats, coercion, or discrimination against any individual for the purpose of interfering with any right or privilege secured by this policy or because the individual has made a report or complaint, testified, assisted, or participated or refused to participate in any manner in an investigation, proceeding, or hearing under this policy.

Those who believe they have been subjected to retaliation under this section may report the allegations to the Title IX Coordinator or Deputy. Those who believe they have been subjected to retaliation that would also constitute a crime may report to campus law enforcement or campus safety office. (See contact information above.) 

F. False Information

Any person who knowingly makes false statements or knowingly provides false information when reporting a violation of this policy or during the course of any investigation or disciplinary proceeding pursuant to this policy may be subject to disciplinary action. The fact that a complaint of sexual harassment or sexual violence did not result in a finding of wrongdoing in a law enforcement or University disciplinary proceeding will not, by itself, be a basis for determining that this provision has been violated. 

IV. Education and training

The Title IX Coordinator will be primarily responsible for facilitating the training and educational programs for the campus community. At a minimum, all students and employees will be required to complete the campus-supported on-line training covering issues of sexual violence and sexual harassment.

The Chancellor or designee will identify and offer more in-depth training for employees who are Officials with Authority, Responsible Employees, Title IX Personnel, and those connected with the disciplinary process.

All Title IX personnel, including the Title IX Coordinator, any investigator, any decision-maker, and any person who facilitates an informal resolution, shall receive training on the definitions of sexual violence and sexual harassment, scope of the institution’s program or activity, how to conduct an investigation and grievance process, how to serve impartially, and how to avoid conflicts of interest and bias. All decision-makers shall receive training on any technology to be used at a live hearing, and on issues of relevance of questions and evidence. All investigators shall receive training on issues of relevance and how to create an investigative report that fairly summarizes relevant evidence. 

V. Record keeping and data collection

As noted above, the Title IX Coordinator will maintain records of reports and resolution of sexual violence and sexual harassment consistent with the institutional records-retention policy, which must be at least seven (7) years. In addition, the Title IX Coordinator will track compliance with mandatory training programs and maintain a list of training and education offered on campus.

The institution will post a link to all training materials for Title IX Personnel (including the Title IX Coordinator, any investigator, any decision-maker, and any person who facilitates an informal resolution), whether developed internally or purchased externally, on their website for public viewing. All materials used to train Title IX Personnel will be maintained for at least seven (7) years.

The UW-Eau Claire Police Department or other appropriate office will collect, maintain, and submit the Annual Security Report, consistent with the federal Clery Act.

The Office of the Dean of Students, or other appropriate office, will collect appropriate data and compile the state report required under § 36.11(22), Wis. Stats.

VI. Assessment

UW-Eau Claire will integrate assessment into sexual violence and sexual harassment prevention and awareness programs to measure whether they are achieving the intended outcomes. The Title IX office will work to design methods for effectively evaluating the outcomes of campus training and educational programming.