Title IX Sexual Harassment Policy
Strayer University (SU) is committed to maintaining education programs and activities that are free of sex based
discrimination, as defined in Title IX of the Education Amendments of 1972 (Title IX). SU prohibits
sexual harassment of any members of the university community and any retaliatory behavior related to
reports of such conduct. This policy was adopted to ensure the safety of students and personnel, a
healthy and thriving workplace and learning environment, and compliance with Title IX in SU’s education
programs and activities.
Since the University is committed to providing an environment free of sexual harassment, this policy
establishes the definitions, procedures, prohibited conduct, and sanctions necessary for maintaining the
Community includes all Strayer University students, faculty, administrators, staff, contracted workers, and
others who participate in any University-related activities, including but not limited to fieldwork, practicum,
Complainant means an individual who is participating in or attempting to participate in a Strayer University
Education Program or Activity and is alleged to be the victim of conduct that could constitute a violation of
this policy if proved.
Education Program or Activity
Education Program or Activity includes locations, events, or circumstances over which Strayer University
exercises substantial control over both the Respondent and the context in which the Sexual Harassment
Formal Complaint means a document filed by a Complainant or signed by the Title IX Coordinator
alleging Sexual Harassment against a Respondent and requesting that the institution investigate the
allegation of Sexual Harassment.
A Hostile Environment is an objectively hostile or abusive Strayer University setting caused by sexual
harassment that is so severe, persistent, and pervasive that it effectively denies a person equal access to
an Education Program or Activity.
Prohibited Conduct includes Sexual Harassment and Retaliation, as defined in this policy, provided that
the conduct either
a) occurs in the context of a Strayer University Education Program or Activity; or
b) creates a hostile environment in a Strayer University Education Program or Activity.
The Respondent is the person alleged to have engaged in Prohibited Conduct.
Retaliation is an adverse action taken in retribution for one’s reporting, supporting, or participating in an
investigation related to an allegation of Prohibited Conduct.
A Sanction is a disciplinary action that may result from Prohibited Conduct. Disciplinary action may
include one or more of the following:
a) formal written warning;
b) mandated remedial activity;
c) suspension from Strayer University;
d) dismissal from a program;
e) dismissal from Strayer University; or
f) cancellation of a previously-awarded academic credit or degree.
This list of possible sanctions is neither progressive nor exhaustive, and Strayer University reserves the right to assess sanctions on a case-by case
Sexual Harassment means conduct that occurs within an Education Program or Activity, on the basis of
sex, and satisfies one or more of the following:
- A Strayer University employee, or contracted worker, conditioning the provision of a Strayer University
aid, benefit, or service on an individual’s participation in unwelcome sexual conduct;
- Unwelcome conduct that results in what a reasonable person would deem to be a Hostile Environment; or
- “Sexual assault” as defined in the Clery Act at 20 U.S.C. 1092(f)(6)(A)(v); and “dating violence” as
defined in 34 U.S.C. 12291(a)(10), “domestic violence” as defined in 34 U.S.C. 12291(a)(8), or “stalking”
as defined in 34 U.S.C. 12291(a)(30). (34 C.F.R. 106.30(a) (2020); commonly known as the Violence
Against Women Act or “VAWA”).
Summary Suspension is the immediate suspension of a Student. Summary Suspension is a temporary
status during which a student is prohibited from engaging in identified Strayer University activities while
an evaluation of alleged Prohibited Conduct is being completed. When Summary Suspension is imposed
on a Respondent, that individual will be provided with notice and an opportunity to challenge the decision
immediately following the imposition of Summary Suspension under the procedures outlined in Section V
Supportive Measures means non-disciplinary, non-punitive individualized services offered as appropriate
and reasonably available, without fee or charge. Supportive Measures may include counseling,
extensions of deadlines, course-related adjustments, modifications of class schedules, campus escort
services, mutual restrictions on contact between the parties, changes in work or housing locations, leaves
of absence, increased security and monitoring of certain areas, and other similar measures. Strayer
University will maintain as confidential any supportive measures provided to a Complainant or
Respondent, to the extent that maintaining such confidentiality does not impair the ability of Strayer
University to provide the Supportive Measures.
Suspension is a Strayer University-initiated temporary status during which a student is denied access to
the course room and prohibited from engaging in Strayer University activities until stated conditions have
A University Administrator is a Strayer University employee who holds a position of responsibility at a
supervisory or managerial level, or higher. For purposes of faculty, “University Administrator” refers to a
faculty member holding the position of faculty chair or higher.
I. Reporting of Suspected Prohibited Conduct
A. Anyone may report an instance of alleged prohibited conduct to:
1. The faculty member or official directly associated with the activity or event;
2. A university administrator
3. The Title IX Coordinator; or
4. Student Affairs.
B. Strayer University strongly encourages the prompt reporting of sexual misconduct to allow the
University to respond promptly and effectively. If the reported respondent is not a member of
the Strayer community or is no longer associated with the University at the time of the report
or at the time a resolution process is initiated, Strayer may be unable to conduct an
investigation or take disciplinary action. Upon receipt of an allegation, a faculty member,
official, or administrator will notify the Title IX Coordinator and/or Student Affairs.
C. Student Affairs may be contacted at:
1. Email: firstname.lastname@example.org ;
2. U.S. Postal Service: 1133 15th St. NW, Washington, DC 20005; (please note that hardcopy
reports filed by mail may additional time for the University’s initial response and all
reporters are encouraged to also submit a report electronically or to notify the Title IX
Coordinator via email or telephone that they have submitted a hard copy report)
3. Phone: 1-877-261-6908; or
4. By submitting a report (including anonymous reports) http://titleix.cusu.ethicspoint.com/
D. Upon receipt of an allegation, Student Affairs will document reports of prohibited conduct
under this policy and will maintain such documentation as dictated by the applicable document
E. Upon receipt of an allegation, Student Affairs will promptly contact the Complainant 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 the Title IX complaint resolution
process, including which members of the University may have access to – and for what
purpose – information obtained during this process.
F. An allegation of prohibited conduct under this policy must include:
1. The individual(s) against whom the alleged prohibited conduct is directed.
2. A brief description of the alleged prohibited conduct, including the date(s), time(s), and
place(s) if known.
3. The corrective action the Student or member of the Strayer Community is seeking.
G. In the event of a factual dispute at any stage of these procedures, and which follows the report
of alleged prohibited conduct, the burden is on the alleged victim to establish that their version
of the events in question is more likely true than not true, also known as preponderance of the
evidence, which shall serve as the evidentiary standard in such cases.
H. If at any state of these procedures the Complainant requests in writing (may be written or
electronic writing) that the complaint not be pursued, that request will be honored 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.
I. If at any stage of these procedures the Complainant requests anonymity, good faith efforts will
be undertaken to act consistently with that request. However, the student is advised that the
ability to maintain anonymity while pursuing a claim under this policy may be limited by law or
regulation in certain circumstances.
J. The Complainant maintains the right to notify law enforcement at any time or to refrain from
contacting such authorities. The Complainant also maintains the right to seek an order of
protection, no-contact order, restraining order, or similar lawful order from any court with
jurisdiction. Upon the Complainant’s request, Strayer will assist the alleged victim(s) in
notifying law enforcement. Strayer at all times retains the right to notify law enforcement, at its
discretion, to protect its students and/or employees or when required by law or regulation.
II. Initial Resolution Process
A. The Initial Resolution Process shall be administered by Student Affairs. Student Affairs will
consult with Human Resources when a faculty member or employee is involved.
B. Upon receipt of an allegation, Student Affairs will determine whether the allegation as shared
constitutes an allegation of prohibited conduct under this policy. A complaint will be dismissed
in the event that, at any time during the investigation or hearing any of the following occur:
a) the alleged conduct does not meet the definition of sexual harassment under this policy even
b) the conduct did not occur in an Educational Program or Activity; or
c) specific circumstances prevent the institution from gathering evidence sufficient to reach a
determination as to the formal complaint or allegations therein.
C. Only after a Formal Complaint has been filed, Student Affairs may offer both parties the
opportunity to attempt an informal resolution of the matter. In order for any kind of informal
resolution process to occur that forecloses the procedures contained in this policy, the
following must occur:
1. Both parties must give voluntary, informed, written consent to attempt informal resolution.
2. Both parties must be informed of any consequences of participating in an informal
3. Parties must be notified that they can withdraw from any informal resolution process at
any time and resume the formal grievance process.
4. Informal Resolution is not available where allegations involve employee sexual
harassment of a Student.
5. If informal resolution is not reached, the allegation will be sent back to the formal
grievance process as defined in this policy (or to Human Resources as appropriate) for
investigation and review.
D. At any time during any portion of the procedures contained in this policy, either party may
request a temporary delay of the grievance process or the limited extension of time frames for
good cause with written notice to the complainant and the respondent of the delay or
extension and the reasons for the action. Good cause may include considerations such as the
absence of a party, a party’s advisor, or a witness; concurrent law enforcement activity; or the
need for language assistance or accommodation of disabilities. Strayer University reserves
the right, in its sole discretion, to deny such requests if they are made merely to delay or
impede the prompt resolution of such matters.
III. Investigation and Review
A. Allegations of prohibited conduct under this policy will be investigated by an independent
review panel if the Respondent is a Student. Allegations will receive a prompt, fair, and
impartial investigation and resolution. The process will be conducted by school officials who
receive annual training under this policy, which includes but is not limited to training on issues
related to domestic violence, dating violence, sexual harassment, and stalking, and how to
conduct an investigation and hearing process that protects the safety of victims and promotes
B. Allegations of prohibited conduct under this policy will be investigated by Strayer University’s
Human Resources department if the respondent is a Strayer University employee or
contractor. Allegations will receive a prompt, fair, and impartial investigation and resolution.
C. Throughout the investigation and review process, there shall be 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.
D. Investigations of alleged prohibited conduct will include:
1. Notification to the respondent of the allegation of prohibited conduct and that respondent
is presumed not responsible for the alleged conduct and that a determination regarding
responsibility is made at the conclusion of the grievance process.
2. An opportunity for both parties to submit any writing, information, evidence, and/or
witnesses supporting or refuting the allegation. Both parties shall have the ability to review
any such information available at that time that was provided by another party prior to any
interviews, meetings, or hearings, so long as such information is directly related to the
allegations. Note that prior to a live hearing, both parties must have at least ten (10) days
to make corrections, provide context, and prepare responses to such information or
3. For all hearings, investigative interviews, or other meetings, the provision of written notice
to a party whose participation is invited or expected, which notice shall include the date,
time, location, participants, with sufficient time for the party to prepare to participate.
4. Prior to completion of the investigative report, Strayer University will send to each party
and the party’s advisor, if any, the evidence subject to inspection and review in an
electronic format or a hard copy, and the parties will have at least 10 calendar days to
submit a written response, which the investigator will consider prior to completion of the
investigative report. The institution shall make all such evidence subject to the parties’
inspection and review available at any hearing to give each party equal opportunity to
refer to such evidence during the hearing, including for purposes of cross-examination.
5. Strayer University will create an investigative report that fairly summarizes relevant
evidence and, at least 10 calendar days prior to a hearing (if a hearing is required) or
other time of determination regarding responsibility, send to each party and the party’s
advisor, if any, the investigative report in an electronic format or a hard copy, for their
review and written response.
6. Strayer University shall not access, consider, disclose, or otherwise use a party’s records
that are made or maintained by a physician, psychiatrist, psychologist, or other
recognized professional or paraprofessional acting in the professional’s or
paraprofessional’s capacity, or assisting in that capacity, and which are made and
maintained in connection with the provision of treatment to the party, unless the institution
obtains that party’s voluntary, written consent to do so for a grievance process under this
section (if a party is not an “eligible student,” as defined in 34 C.F.R. 99.3, then the
institution must obtain the voluntary, written consent of a “parent,” as defined in 34 C.F.R.
E. Role and Appointment of Advisors
1. During the course of any grievance proceeding, parties’ advisors may be, but are not
required to be, attorneys. Strayer University will not limit the choice or presence of an
advisor for either the complainant or respondent in any meeting or grievance proceeding;
however, the institution may establish restrictions regarding the extent to which the
advisor may participate in the proceedings, as long as the restrictions apply equally to
both parties. During the investigative phase, advisors will only be allowed to interact with
Strayer University personnel and shall not have direct contact with adverse parties or
witnesses. During a live hearing, advisors will conduct cross-examination.
2. If a party does not have an advisor present at the live hearing, Strayer University will
provide, without fee or charge to that party, an advisor of the institution’s choice solely for
the purpose of conducting cross-examination on behalf of that party. The institutionally provided
advisor may be, but is not required to be, an attorney. Only advisors may cross examine
another party or adverse witness. To be clear, under no circumstances will one
party be allowed to directly cross-examine another party or an adverse witness.
3. A party must notify Strayer University at least seven (7) days prior to any hearing or
proceeding at which an advisor may participate with the contact information for that
advisor. If a party does not have their own advisor but will need to have one provided by
Strayer University, that party must also notify Strayer University at least seven (7) days
prior to any hearing or proceeding at which an advisor may participate so that the
University can arrange for advisor to be present and to have time to prepare for such
hearing or proceeding.
F. Live Hearings, Examination, Cross-Examination, Relevance, Sexual History
1. Both parties will have an opportunity to participate in a live hearing. At the University’s
discretion, the hearing may be conducted virtually with technology enabling participants to
simultaneously see and hear each other or
with all parties physically present in the same geographic location. The University may
also conduct the live hearing with some participants in the same geographic location, and
others virtually, so long as both parties are provided the same opportunity (if any) to be
present in the same geographic location..
2. During the live hearing, the decision-maker(s) will make an objective evaluation of all
relevant evidence – including both inculpatory and exculpatory evidence – and ensure
that credibility determinations may not be based on a person’s status as a complainant,
respondent, or witness.
3. The decision-makers shall not draw an inference solely based upon a party’s or witness’s
failure or refusal to appear at live hearing or submit to cross-examination.
4. At the live hearing, the decision-maker(s) 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 the live hearing must be conducted
directly, orally, and in real time by the party’s advisor of choice and never by a party
5. Only relevant cross-examination and other questions may be asked of a party or witness.
Before a complainant, respondent, or witness answers a cross-examination or other
question, the decision-maker(s) may issue a determination as to relevance and explain
any decision to exclude a question as not relevant.
6. Questions and evidence about the complainant’s sexual predisposition or prior sexual
behavior are not relevant, unless such questions and evidence about the complainant’s
prior sexual behavior are offered to prove that someone other than the respondent
committed the conduct alleged by the complainant, or if the questions or evidence
concern specific incidents of the complainant’s prior sexual behavior with respect to the
respondent and are offered to prove consent.
7. Strayer University will create an audio or audiovisual recording, or transcript, of any live
hearing and make it available to the parties for inspection and review, without charge or
fee, within a reasonably prompt timeframe.
8. During the course of the hearing, the decision-maker(s) may consult with Strayer
University’s legal counsel by telephone or in person.
G. Determination of Responsibility
1. The decision-maker(s), who shall not be the same person(s) as the Title IX Coordinator or
the investigator(s), will issue a written determination regarding responsibility.
2. The standard of proof shall be a preponderance of the evidence.
3. The decision-maker(s)’ written determination will include:
• The identification of the allegations potentially constituting Title IX Sexual
Harassment as noticed.
• A description of the procedural steps taken from the receipt of the formal
complaint through the determination, including any notifications to the parties,
interviews with parties and witnesses, site visits, methods used to gather other
evidence, and hearings held.
• Findings of fact supporting the determination.
• Conclusions regarding the application of the institution’s code of conduct to
• A statement of, and rationale for, the result as to each material allegation,
including a determination regarding responsibility, any disciplinary sanctions
the institution imposes on the respondent, and whether remedies will be
provided by the institution to the complainant.
• The institution’s procedures and permissible bases for the complainant and
respondent to appeal the determination of responsibility.
• The institution will provide the written determination to the parties
simultaneously. The determination regarding responsibility becomes final
either on the date that the institution provides the parties with the written
determination of the result of the appeal, if an appeal is filed, or if an appeal is
not filed, the date on which an appeal would no longer be considered timely.
This constitutes the conclusion of the Title IX complaint resolution process.
IV. Appeal Process
A. Both parties shall have the opportunity to appeal, via written request to Student Affairs within
ten (10) calendar days of being sent notice of the outcome, on the following basis:
1. Procedural irregularity that affected the outcome of the matter.
2. New evidence that was not reasonably available at the time the determination regarding
responsibility or dismissal was made, that could affect the outcome of the matter.
3. The Title IX Coordinator, investigator(s), or decision-maker(s) had a conflict of interest or
bias for or against complainants or respondents generally or the individual complainant or
respondent that affected the outcome of the matter.
B. If either party chooses to appeal the initial decision on any other basis, they must submit a
formal, written appeal request to Student Affairs. The appeal request must be submitted via
mail or email and within 10 calendar days of being sent notification of the panel’s decision.
1. The president or president’s designee will receive and review the record developed at the
investigation and review stage.
2. Following the review, the president or president’s designee will issue a decision and
report. The president or president’s designee may affirm or reverse the decision, in whole
or in part, or may issue a new decision.
3. The decision of the president or president’s designee is final and will be communicated in
writing to the alleged victim and respondent simultaneously.
4. A record of the final decision and all related materials will become part of the respondent’s
official academic record and, upon request, will be made available to all Strayer University
boards and any appropriate regulatory bodies.
5. Strayer University employees and contractors are ineligible to appeal final decisions
rendered by the university’s Human Resources staff pursuant to this policy, except to the
extent their appeal is made in their capacity as a Strayer University Student.
V. Summary Suspension Procedures
A. Where the respondent is a Student and the alleged prohibited conduct is deemed to be
egregious or to give rise to a perceived threat of danger or hostile environment for any Strayer
faculty, staff, employee, contractor, or Student, a respondent may be immediately suspended
by use of this summary suspension process if it initially appears that the allegation of
prohibited conduct is substantiated. The university administrator directly associated with the
course, activity, or event in which the prohibited conduct occurs will have the discretion to
determine, consistent with this section, when summary suspension is appropriate.
B. If summary suspension is issued, the university administrator directly associated with the
activity or event during which the alleged prohibited conduct occurred will promptly notify the
respondent of their summary suspension and their right and opportunity to be heard by
submitting a written response and/or appearing by telephone within seven calendar days from
the date said notification is issued.
C. The university administrator directly associated with the activity or event during which the
prohibited conduct occurred will complete the procedures set forth in section III within 10
calendar days of the date of issuance of the notification of summary suspension.
D. The respondent may submit a written request for extension of time for their written response
or appearance by telephone beyond the seven calendar day deadline set forth in section IV.B.
Such extensions shall be automatically granted up to a maximum of 30 calendar days.
However, in the event the respondent should exercise this right to an extension, the deadline
for the university official’s decision under section III will be extended by the length of the
Student’s extension, with the summary suspension remaining in effect the entire time.
1. In the event that the university administrator finds that the summary suspension was
justified, the process continues as described in section III, with the suspension remaining
in place unless and until reversed on appeal.
2. In the event that the university administrator finds that the evidence reviewed does not
justify the summary suspension, or in the event that no decision is issued by the university
administrator within the time constraints described in sections IV.C and IV.D, the
summary suspension will expire. The process will continue as described in section III, but
the respondent will return to the status previous to the summary suspension:
• In this instance, the respondent will have an opportunity to complete the
missed coursework within 10 calendar days of returning to the course room
• If the respondent was in the last two weeks of the course, they have the option
of receiving an Incomplete (“I”) grade; in that case, the coursework must be
completed and submitted no later than two weeks after the course ends; or
• The respondent may choose to withdraw from the course and retake the
course without financial penalty or any penalty for reusing work previously
submitted to fulfill assignments for that specific course.
VI. Alcohol and Drug Use Amnesty
The health and safety of every Student at Strayer is of utmost importance. Strayer recognizes that
students who have been drinking and/or using drugs (whether such use is voluntary or involuntary) at the
time sexual misconduct occurs may be hesitant to report such incidents due to fear of potential
consequences for their own conduct. Strayer strongly encourages students to report incidents of sexual
misconduct. A witness to or individual who experiences sexual misconduct, acting in good faith, who
discloses any incident of sexual misconduct to University officials or law enforcement will not be
sanctioned under Strayer’s code of conduct for violations of alcohol and/or drug use policies occurring at
or near the time of the incident(s) of sexual harassment or sexual violence. Strayer may request the
individual attend an approved alcohol or drug education program and without assessing any charges for
such program. This amnesty provision also applies to student groups making a report of sexual
misconduct. Amnesty does not preclude or prevent action by police or other legal authorities pursuant to
relevant state or federal criminal statutes.
VII. Additional Procedures for Reporting a Consensual Relationship
A. Any reported cases of a consensual relationship involving an employee will be reported to
B. If Strayer University determines a prohibited consensual relationship exists, the university
employee’s position of authority with respect to the specific Student at issue will be adjusted to
eliminate the existence of the prohibited consensual relationship. Resolution of any
discrimination, harassment, or assault resulting from the consensual relationship will be
handled according the procedures contained in this policy.