Title IX

Submit A Title IX Report

You can file a Title IX incident report of sexual harassment, misconduct, and sex/gender discrimination.

Title IX Policy Statement

Otis College adheres to all federal, state, and local civil rights laws prohibiting discrimination in employment and education. Otis College does not discriminate in its admissions practices, in its employment practices, or in its educational programs or activities on the basis of sex/gender. As a Otis College of federal financial assistance for education activities, Otis College is required by Title IX of the Education Amendments of 1972 to ensure that all of its education programs and activities do not discriminate on the basis of sex/gender. Sex includes sex, sex stereotypes, gender identity, gender expression, sexual orientation, and pregnancy or parenting status.

Otis College also prohibits retaliation against any person opposing discrimination or participating in any discrimination investigation or complaint process internal or external to the institution. Sexual harassment, sexual assault, dating and domestic violence, and stalking are forms of sex discrimination, which are prohibited under Title IX and by Otis College policy.

Any member of the institutional community, guest, or visitor who acts to deny, deprive, or limit the educational, employment, residential, or social access, opportunities and/or benefits of any member of the Otis College community on the basis of sex is in violation of the Otis College’s Title IX: Harassment and Non-Discrimination Policies.

Any person may report sex discrimination (whether or not the person reporting is the person alleged to have experienced the conduct), in person, by mail, by telephone, by video, or by email, using the contact information listed for the Title IX Coordinator (below). A report may be made at any time (including during non-business hours) by submitting the online Title IX Reporting Form.

Questions regarding Title IX, including its application and/or concerns about noncompliance, should be directed to the Title IX Coordinator. If you have questions, contact Otis College’s Title IX Coordinator, Jess Johnson Mills, at jjohnsonmills@otis.edu, and/or Deputy Title IX Coordinator, Helane Wilbourne at hwilbourne@otis.edu. 

View Full Title IX Policy

Rationale for Policy

Otis College is committed to providing a workplace and educational environment, as well as other benefits, programs, and activities, that are free from sexual harassment and retaliation for engaging in a protected activity. Otis College values and upholds the equal dignity of all members of its community and strives to balance the rights of the parties in the grievance process during what is often a difficult time for all involved.

To ensure compliance with federal, state, and local civil rights laws and regulations, and to affirm its commitment to promoting the goals of fairness and equity in all aspects of the education program or activity, Otis College has developed policies and procedures that provide a prompt, fair, and impartial process for those involved in an allegation sexual harassment or retaliation.

Jurisdiction

This Policy applies to the College’s education program and activities, to conduct that takes place on property owned or controlled by the College, and at college-sponsored events. The Respondent must be a member of Otis College’s community in order for this Policy to apply.

This Policy is also applicable to the effects of off-campus misconduct that effectively deprives a person of access to Otis College’s education program or activities. The College will extend jurisdiction to off-campus and/or to online conduct when the Title IX Coordinator determines that the conduct affects a substantial College interest.

Regardless of where the conduct occurred, the College will address notice/complaints to determine whether the conduct occurred in the context of its employment or education program or activity and/or has continuing effects on campus (including virtual learning and employment environments) or in an off campus sponsored program or activity. 

A substantial College interest includes:

1. Any action that constitutes a criminal offense as defined by law. This includes, but is not limited to, single or repeat violations of any local, state, or federal law.
2. Any situation in which it is determined that the Respondent poses an immediate threat to the physical health or safety of any student, employee, or other individual.
3. Any situation that significantly impinges upon the rights, property, or achievements of others, significantly breaches the peace, and/or causes social disorder.
4. Any situation that substantially interferes with the educational interests or mission of the College.

If the Respondent is unknown or is not a member of the Otis College community, the Title IX Coordinator, or designee, will assist the Complainant in identifying appropriate institutional and local resources and support options. If criminal conduct is alleged, the College can assist in contacting local or institutional law enforcement if the individual would like to file a police report.

Further, even when the Respondent is not a member of the College’s community, supportive measures, remedies, and resources may be provided to the Complainant by contacting the Title IX Coordinator.

In addition, the College may take other actions as appropriate to protect the Complainant against third parties, such as barring individuals from Otis College property and/or events.

All vendors serving the College through third-party contracts are subject to the policies and procedures of their employers and/or to these Policies and procedures to which their employer has agreed to be bound by their contracts.

When the Respondent is enrolled in or employed by another institution, the Title IX Coordinator can assist the Complainant in liaising with the appropriate individual at that institution, as it may be possible to pursue action under that institution’s policies.

Similarly, the Title IX Coordinator may be able to assist and support a student or employee Complainant who experiences discrimination in an internship, travel study program, or other environment external to the College where sexual harassment or nondiscrimination policies and procedures of the facilitating or host organization may give the Complainant recourse.

You may file a formal complaint at any time by using the online Title IX Reporting Form. You may also file a complaint by email, or in person.

Applicable Scope

The core purpose of this policy is the prohibition of sexual harassment and retaliation. When an alleged policy violation is reported, the allegations are subject to resolution using Otis College’s formal resolution process (“Process A”) or informal alternative resolution process  (“Process B”),[1] as determined by the Title IX Coordinator, and as detailed below.

When the Respondent is a member of the Otis College community, a Formal Complaint may be filed and a grievance process may be available regardless of the status of the Complainant, who may or may not be a member of the Otis College community. This community includes, but is not limited to, students, student organizations, faculty, administrators, staff, and third parties such as [guests, visitors, volunteers, vendors, contractors, invitees, and campers]. The procedures below may be applied to incidents, to patterns, and/or to the institutional culture/climate, all of which may be addressed and investigated in accordance with this Policy.
 
Otis College recognizes that reports and/or Formal Complaints under this Policy may include violations of other Otis College policies; may involve various combinations of students, employees, and other members of the Otis College community; and may require the simultaneous attention of multiple Otis College departments. Accordingly, all Otis College departments will share information, combine efforts, and otherwise collaborate, to the maximum extent permitted by law and consistent with other applicable Otis College policies, to provide uniform, consistent, efficient, and effective responses to alleged sexual harassment or retaliation.

Title IX Coordinator

The Assistant Dean of Student Affairs serves as the Title IX Coordinator and oversees implementation of this Policy. The Title IX Coordinator has the primary responsibility for coordinating Otis College’s efforts related to the intake, investigation, resolution, and implementation of supportive measures to stop, remedy, and prevent sexual harassment and retaliation prohibited under this Policy.

All parties will be provided with a comprehensive electronic brochure detailing options and resources, which the Title IX Coordinator may also review with the parties in person.

Duties of Title IX Coordinator

• Responsible for oversight of the investigation and resolution of all reports of sexual harassment, sexual assault, stalking and relationship violence involving students, staff and faculty;
• Knowledgeable and trained in College policies and procedures and relevant state and federal laws;
• Responsible for monitoring compliance with all procedural requirements, record keeping and time frames outlined in this policy;
• Responsible for overseeing training, prevention and education efforts, and regular reviews of climate and culture;
• Responsible for identifying and addressing any pattern or systemic problems that arise;
• Available to advise any individual, including a complainant, a respondent or a third party, about the courses of action available at the College, both informally and formally; and
• Available to provide assistance to any College employee regarding how to respond appropriately to a report of sexual harassment, sexual assault, or relationship violence.

Independence and Conflict of Interest

The Title IX Coordinator manages the Title IX Team and acts with independence and authority free from bias and conflicts of interest. The Title IX Coordinator oversees all resolutions under this Policy and these procedures. The members of the Title IX Team are vetted and trained to ensure they are not biased for or against any party in a specific complaint, or for or against Complainants and/or Respondents, generally.

To raise any concern involving bias, conflict of interest, sexual harassment, or retaliation by the Title IX Coordinator, contact the Vice President for Student Affairs, Dr. Nicholas Negrete, at nnegrete@otis.edu or the Vice President for Human Resources and Development, Karen Hill, at khill@otis.edu. Concerns of bias, sexual harassment, retaliation, or a potential conflict of interest by any other Title IX Team member should be raised with the Title IX Coordinator.

Supportive Measures

Otis College will offer and implement appropriate and reasonable supportive measures to the parties upon notice of alleged sexual harassment and/or retaliation.

Supportive measures are non-disciplinary, non-punitive individualized services offered as appropriate and as reasonably available. They are offered, without fee or charge to the parties, to restore or preserve access to Otis College’s education program or activity, including measures designed to protect the safety of all parties and/or Otis College’s educational environment and/or to deter sexual harassment and/or retaliation.

The Title IX Coordinator promptly makes supportive measures available to the parties upon receiving notice or a complaint. At the time that supportive measures are offered, Otis College will inform the Complainant, in writing, that they may file a Formal Complaint with Otis College either at that time or in the future, if they have not done so already. The Title IX Coordinator works with the Complainant to ensure that their wishes are considered with respect to any planned and implemented supportive measures.

Otis College will maintain the confidentiality of the supportive measures, provided that confidentiality does not impair the college’s ability to provide those supportive measures. Otis College will act to ensure as minimal an academic/occupational impact on the parties as possible. The college will implement measures in a way that does not unreasonably burden the other party.

These actions may include, but are not limited to:

• Referral to counseling, medical, and/or other healthcare services
• Referral to the Employee Assistance Program
• Referral to community-based service providers
• Visa and immigration assistance
• Student financial aid counseling
• Education to the institutional community or community subgroup(s)
• Altering campus housing assignment(s)
• Altering work arrangements for employees or student-employees
• Safety planning
• Providing campus safety escorts
• Implementing contact limitations (no contact orders) between the parties
• Academic support, extensions of deadlines, or other course/program-related 
•  Adjustments
• No Trespass, No Contact,  or Be-On-the-Lookout (BOLO) orders
• Timely warnings
• Class schedule modifications, withdrawals, or leaves of absence
• Increased security and monitoring of certain areas of the campus
• Any other actions deemed appropriate by the Title IX Coordinator

Violations of no contact orders or other restrictions may be referred to appropriate student or employee conduct processes for enforcement or added as collateral misconduct allegations to an ongoing complaint under this Policy.

Promptness

Once Otis College has received notice or a Formal Complaint, all allegations are promptly acted upon. Complaints typically take 60-90 business days to resolve. There are always exceptions and extenuating circumstances that can cause a resolution to take longer, but Otis Collegewill avoid all undue delays within its control.

Any time the general timeframes for resolution outlined in Otis College’s procedures will be delayed, Otis College will provide written notice to the parties of the delay, the cause for the delay, and an estimate of the anticipated additional time that will be needed as a result of the delay.

Confidentiality/Privacy

Every effort is made by the College to preserve the confidentiality of reports.Otis College will not share the identity of any individual who has made a report or Formal Complaint of sexual harassment or retaliation; any Complainant; any individual who has been reported to be the perpetrator of sexual harassment or retaliation; any Respondent; or any witness, except as permitted by the Family Educational Rights and Privacy Act (FERPA) or its implementing regulations;or as required by law; or to carry out the purposes of 34 C.F.R. Part 106, including any investigation, hearing, or grievance proceeding arising under these policies and procedures.

Otis College reserves the right to determine which college officials have a legitimate educational interest in being informed about incidents that fall under this Policy, pursuant to the Family Educational Rights and Privacy Act (FERPA).

Only a small group of officials who need to know will typically be told about the complaint, including but not limited to: Division of Student Affairs, Student Conduct/Dean of Student Affairs Office, Otis College Campus Safety and Security, and the Behavioral Intervention/Threat Assessment Teams. Information will be shared as necessary with Investigators, Decision-makers, witnesses, and the parties. The circle of people with this knowledge will be kept as tight as possible to preserve the parties’ rights and privacy.

The College may contact parents/guardians of students to inform them of situations in which there is a significant and articulable health and/or safety risk but will usually consult with the student first before doing so.

Time Limits on Reporting

There is no time limitation on providing notice/complaints to the Title IX Coordinator. However, if the Respondent is no longer subject to the College’s jurisdiction and/or significant time has passed, the ability to investigate, respond, and/or provide remedies may be more limited or impossible.

Acting on notice/complaints significantly impacted by the passage of time (including, but not limited to, the revocation or revision of policy) is at the discretion of the Title IX Coordinator, who may document allegations for future reference, offer supportive measures and/ or remedies, and/or engage in informal or formal action, as appropriate.

Note: When notice/complaint is affected by significant time delay, the College will typically apply the policy in place at the time of the alleged misconduct and the procedures in place at the time of notice/complaint. Typically, this Policy is only applied to alleged incidents that occurred after August 14, 2020. For alleged incidents that occurred prior to August 14, 2020, previous versions of this Policy will apply. Those versions are available from the Title IX Coordinator.

Online Sexual Harassment and/or Retaliation

Otis College policies are written and interpreted broadly to include online manifestations of any of the behaviors prohibited below, when those behaviors occur in or have an effect on the College’s education program and activities or when they involve the use of College networks, technology, or equipment.

Although Otis College may not control websites, social media, and other venues through which harassing communications are made, when such communications are reported to the College, it will engage in a variety of means to address and mitigate the effects.

Members of the community are encouraged to be good digital citizens and to refrain from online misconduct, such as feeding anonymous gossip sites; sharing inappropriate content via social media; unwelcome sexual or sex-based messaging; distributing, or

threatening to distribute, nude or semi-nude photos or recordings; breaches of privacy; or otherwise using the ease of transmission and/ or anonymity of the Internet or other technology to harm another member of the Otis College community.

Any online posting or other electronic communication by students, including cyber-bullying, cyber-stalking, cyber-harassment, etc., occurring completely outside of the College’s control (e.g., not on College networks, websites, or between Otis College email accounts) will only be subject to this Policy when such online conduct can be shown to cause a substantial in-program disruption or infringement on the rights of others.

Otherwise, such communications are considered speech protected by the First Amendment. Supportive measures for Complainants will be provided, but legally protected speech cannot be subjected to discipline.

Off-campus harassing speech by employees, whether online or in person, may be regulated by the College only when such speech is made in an employee’s official or work-related capacity.

Administrative Contact Information

Individuals who believe they have experienced sex discrimination, harassment, and/or retaliation in violation of Otis College policy should contact the following:

Jess Johnson Mills
Title IX Coordinator
Ahmanson Hall 205
9045 Lincoln Ave.
Telephone: 310-846-2554
Email: jjohnsonmills@ototis.edu

A person may also file a complaint with the appropriate federal, state, or local agency within the time frame required by law. Depending upon the nature of the complaint, the appropriate agency may be the federal Equal Employment Opportunity Commission (EEOC), the U.S. Department of Education Office for Civil Rights (OCR), the Department of Justice, and/or the EEOC Los Angeles District Office.

EEOC Los Angeles District Office
Roybal Federal Building
255 East Temple St., 4th Floor
Los Angeles, CA 90012
Phone: 213-785-3090
Fax: 213-894-1118
TTY: 1-800-669-6820
ASL Video Phone: 844-234-5122

California Civil Rights Regional Office - Los Angeles
320 West 4th Street, Suite 1000, 10th Floor
Los Angeles, CA 90013
Monday to Friday: 8am to 5pm
Phone: (800) 884-1684

Assistant Secretary for Civil Rights
Office for Civil Rights, National Headquarters
U.S. Department of Education
Lyndon Baines Johnson Dept. of Education Building
400 Maryland Avenue, SW
Washington, DC 20202-1100
Telephone: 800-421-3481
Fax: 202-453-6012; TDD: 800-877-8339
Email: OCR@ed.gov

For complaints involving employee-on-employee conduct: Equal Employment Opportunity Commission (EEOC) 

Within any Resolution Process related to this Policy, Otis College provides reasonable accommodations to persons with disabilities and religious accommodations, when that accommodation is consistent with state and federal law.