The provost’s office and general counsel are seeking a Title IX and Clery Act compliance officer, a newly created administrative position. The new hire will be responsible for implementing a program to educate campus safety personnel, faculty, staff and students on the College’s sexual assault policies and ensure that Dartmouth complies with federal guidelines.
The position will entail several facets of handling and preventing sexual assault on campus, including improving reporting mechanisms, augmenting support structures and fortifying enforcement, general counsel Robert Donin said.
The task of managing Title IX compliance issues, as well as monitoring and tracking incidents of sexual discrimination and misconduct, previously fell to the Office of Institutional Diversity and Equity.
Evelyn Ellis, vice president of Institutional Diversity and Equity and Dartmouth’s current Title IX coordinator, said the decision to create the position resulted from a 2011 “Dear Colleague” letter from the Department of Education’s Office of Civil Rights clarified how Title IX applied to sexual assault.
The letter detailed institutions’ responsibilities when dealing with sexual harassment and assault. Institutions must publish a non-discrimination notice for students and staff, designate a Title IX coordinator to manage potential issues and publicize clear grievance procedures.
Ellis said these federal regulations required a large amount of time and training in addition to her primary responsibilities as Institutional Diversity and Equity vice president. As she studied the regulations, compliance issues in need of redress continued to arise, she said.
“The more I read them and the more I was trained, the longer the list got,” she said. “It was turning into a full-time job, especially when combined with the Clery Act.”
Last May, students filed a Clery Act complaint against the College, documenting violations of sexual assault, discrimination, hate crimes, bullying and hazing. The Department of Education also launched an unprompted investigation into Title IX compliance at the College relating to sexual assault.
The strain on the six-person office led to some sleepless nights, Ellis said.
“We came to realize that someone needs to do that,” she said. “It couldn’t be spread out among the staff.”
Donin acknowledged the constraints that were placed on the office in light of the federal guidelines, but said the decision to hire a compliance officer emerged primarily from College President Phil Hanlon’s November report to the faculty, which highlighted the need for the administration to better prevent and respond to sexual assault.
Donin said the new administrator will collaborate with several departments, responding primarily to the provost while working with Institutional Diversity and Equity, Safety and Security and sexual assault prevention groups.
Others see the decision as an attempt to mitigate liability rather than to tackle systemic issues revolving around sexual assault and reporting on campus.
Susy Struble ’93, the founder of Dartmouth Change, a non-profit organization that advocates for the reform of sexual assault policies and campus culture, said she questions the effectiveness of the new position. She pointed out that the College decided to create the position only after receiving a Clery Act complaint.
“This person is not expected to have a positive influence on the College on the issue of sexual assault, except toeing the legal line,” she said. “It shows how little they thought about civil rights on campus.”
Struble said she is ultimately optimistic about the potential for the role, though she believes Dartmouth lacks a coherent institutional strategy for dealing with sexual assault compliance issues.
“The people are working within a framework that’s broken,” she said. “They’re not resourced, they’re not empowered. It’s like moving the deck chairs on the Titanic.”
