Loyola University Chicago

Human Resources

Sexual Harassment

Purpose
Loyola University Chicago (“Loyola” or “the University”) is committed to maintaining an environment which respects the dignity of all individuals. Additionally, under the Illinois Human Rights Act and Federal civil rights law, all students and employees have the right to study and work free from unlawful discrimination or sexual harassment.

Accordingly, under the Comprehensive Policy and Equitable Resolution Procedures for Discrimination, Sexual Misconduct, and Retaliation (“Comprehensive Policy”), Loyola prohibits sexual harassment by or of its Faculty, Staff, Students, Guests, and Individuals (including Volunteers) who perform services for the University. The University’s response to reports and complaints of sexual harassment will be coordinated by the Office for Equity & Compliance (“OEC”).

Policy
Article 1, subsection VIII(B) of the Comprehensive Policy, in relevant part, provides (all references herein are to the Comprehensive Policy, which is available in full here):

  1. Sexual Misconduct
  2. Sexual Harassment

Consistent with Loyola’s mission and identity, the University maintains the highest standards for respectful sexual interactions between consenting individuals. Although Illinois law defines various violent and/or non-consensual sexual acts as crimes, for the purposes of the Comprehensive Policy, Loyola applies its own definitions and standards for the various ways in which sexual and/or gender-based misconduct are prohibited. When allegations of sexual misconduct meet the definitional and jurisdictional requirements of Title IX sexual harassment, the requirements for Grievance Process complaints and the Grievance Process will apply (see Article 1, subsection X(A) and Article 3).

Certain forms of sexual misconduct are among the most harmful violations that any individual can undertake against the safety and dignity of our University community; the University therefore reserves the right to impose any level of assigned outcome, up to and including suspension or expulsion/termination, for any sexual violation based on the facts and circumstances of the particular case.

Acts of sexual misconduct may be committed by any person upon any other person, regardless of the sex, sexual orientation, and/or gender identity or expression of those involved. Specific violations include:

[…] 

Sexual harassment is broadly defined as:

  • unwelcome and objectively offensive,
  • sexual,
  • verbal, written, online, and/or physical conduct.

(footnote: Harassment based on sex, sexual orientation, gender identity, or gender expression are also prohibited as forms of discriminatory harassment, in compliance with Title VII (see Article 1, subsection VIII(A)(3)).)

Sexual harassment occurs without regard to the respondent’s intent to cause harm and is based on the totality of the circumstances. Loyola may remedy any form of sexual harassment when reported, whether or not the behavior constitutes quid pro quo or hostile environment sexual harassment. 

  1. Quid Pro Quo Sexual Harassment
  2. unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature,
  3. by a person having power or authority over another,
  4. when submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment or academic status or participation in other University programs or activities, or
  5. when submission to or rejection of such conduct by an individual is used as the basis for employment or academic decisions adversely affecting the individual.

        Quid pro quo sexual harassment is defined as:

  1. Hostile Environment Sexual Harassment
  2. severe or persistent or pervasive; and
  3. objectively offensive, such that it
  4. unreasonably interferes with, denies, or limits an individual’s or group’s ability to participate in or benefit from the University’s educational, employment, residential, or social program.

            A hostile environment is created when sexual harassment is:

Unwelcomeness and objective offensiveness are evaluated based on the totality of the circumstances from the perspective of a reasonable person in the same or similar circumstances. Other forms of sexual misconduct (as defined in Article 1, subsection VIII(B)), when substantiated, may be considered in determining whether the sexual misconduct also contributed to a hostile environment. 

  1. Title IX Sexual Harassment
  2. A Supervisor granting a promotion to a subordinate because the subordinate agrees to have unwanted sexual relations with the Supervisor;
  3. A Supervisor firing a subordinate because the subordinate refuses to have sexual relations with the Supervisor;
  4. A Faculty member providing an undeserved failing grade to a student because the student refuses to have sexual relations with the Professor;
  5. A Faculty member giving an undeserved high grade to a student because the student agrees to have unwanted sexual relations with the Professor;
  6. A Faculty member providing positive references or evaluations for another student in exchange for sexual favors;
  7. A Student providing positive references or evaluations for another student in exchange for sexual favors. 

In certain circumstances specifically defined under Title IX, some allegations of sexual harassment (including some instances of quid pro quo sexual harassment, hostile environment sexual harassment, sexual assault, dating violence, domestic violence, and stalking, as defined by law) may constitute Title IX sexual harassment.

For the purpose of addressing formal complaints of Title IX sexual harassment, the University must comply with a specific, prescribed administrative process, which is provided for in the Comprehensive Policy as the Grievance Process (see Article 3). As described in Article 1, subsection X(B), the Grievance Process will be followed for all formal complaints of Title IX sexual harassment.

All other reports and formal complaints of “non-Title IX” sexual harassment may be addressed according to the Equitable Resolution Procedures (see Article 2). 

To access the complete Comprehensive Policy and other related information, please visit the Office for Equity & Compliance website at www.luc.edu/equity.

It should also be noted that people of all sexes and genders, including people that do not identify with a sex and/or gender identity, are protected from sexual harassment, whether that harassment is perpetrated by a member of the same or another a/sex or a/gender.

Examples of Sexual Harassment
Examples of quid pro quo sexual harassment include, but are not limited to, the following:

Examples of hostile environment harassment include, but are not limited to, the following:

  • Persistent sexual slurs;
  • Sexual stalking;
  • Repeated requests for an unwelcome sexual relationship;
  • Continual sexually suggestive jokes, gestures or sounds directed toward another;
  • A pattern of widespread favoritism based on sexual relationships;
  • The open display of pornography or suggestive and objectively offensive sexual materials;
  • Unwelcome sexual touching, such as fondling or pinching of private body parts.

Reporting Sexual Harassment
Any individual may report sexual harassment (among other forms of discrimination, sexual misconduct, and/or retaliation) using any of the following methods. There is no time limitation on reporting allegations. However, if the respondent is no longer subject to the University’s jurisdiction or if substantial time has passed since the underlying incident occurred, the University’s ability to investigate, respond, and/or provide remedies may be limited. 

  1. (PREFERRED OPTION)Report concerns directly to the OEC using the publicly available online reporting form (powered by Maxient™) available at www.luc.edu/equity. Online reporting is available year-round, 24 hours a day, seven (7) days a week (including University holidays). 
  2. (For concerns about a student only)Report online or in person to the Center for Student Assistance and Advocacy, under the Office of the Dean of Students. The Office of the Dean of Students will in turn notify the OEC.

2. Report to the OEC via email at equity@luc.edu or by emailing the Title IX Coordinator or any Deputy Title IX Coordinator at the contact information provided below. 

3. Report to the OEC via phone, in person, or by postal mail using the directory information for the office provided below. The OEC office is open year-round, Monday through Friday, from 8:30AM – 5:00PM CST (except for University holidays). 

  1. (For concerns about a Faculty or Staff employee only) Report in-person, by phone, or electronically to Human Resources. Human Resources will in turn notify the OEC.
    • Loyola Sexual Assault Advocates:Available during certain hours via the Loyola Sexual Assault Advocacy Line or call 773-494-3810.
    • Pastoral Counselors: A pastoral counselor is a person who is associated with a religious order or denomination, recognized by that religious order or denomination as someone who provides confidential counseling, and functioning within the scope of that recognition as a pastoral counselor. (In the Catholic faith, this would mean a priest from whom a person has sought private spiritual counsel.) Campus Ministers are generally not confidential resources, but Campus Ministry can help you locate a pastoral counseloror call 773-508-2200. 

Anonymous Reporting
Any individual may report an incident anonymously using the online reporting form (powered by Maxient™) posted at www.luc.edu/equity. Depending on the nature of the anonymous report and the information provided, anonymous reports may still prompt the Executive Director for Equity & Compliance to file a formal complaint and investigate according to the Equitable Resolution Procedures or the Grievance Process. However, it should be noted that the University’s ability to offer and/or provide supportive measures, investigate the alleged incident(s), impose sanctions, provide appropriate remedies, and otherwise respond to a report is limited in cases where no affected party or complainant is identified.

More information about anonymous reporting can be found in the Comprehensive Policy.

Obligation of Responsible Campus Partners to Report Disclosures of Sexual Misconduct Involving Students or Minors

With very limited exceptions (see subsections (a) and (b) below), all Loyola Faculty and Staff employees must report any known, disclosed, alleged, or otherwise reported (formally or informally) incidents of sexual misconduct that satisfy any of the following criteria:

a. Sexual misconduct against any individual who is currently a minor (under 18 years old) by any individual

b. Sexual misconduct against an individual who is or was a student at the time of the incident

c. Sexual misconduct by an individual who is or was a student or employee (Faculty or Staff) at the time of the incident

Faculty and Staff employees and others with such a duty are referred to as “responsible campus partners,” and are to report such incidents within 24 hours of becoming aware of the incident. In order not to betray the trust of any student or other affected party, responsible campus partners should be forthright and transparent about this obligation at all times.

Reporters and/or affected parties may therefore want to consider carefully whether they share personally identifiable details with responsible campus partners, as responsible campus partners must promptly share all details of such reports they receive – including the identities of all known parties – preferably via the online reporting form (powered by Maxient™) available at www.luc.edu/equity.

Failure of a responsible campus partner, as described in this section, to report an incident of sexual misconduct of which they are aware is a violation of the Comprehensive Policy and may subject the responsible campus partner to disciplinary action. Note that this obligation is for reports and disclosures of sexual misconduct only, and does not apply to reports of discrimination or retaliation – although Faculty and Staff employees are strongly encouraged to report such incidents as well to ensure that appropriate resources and support may be provided to affected parties.

Additional information about the obligation of responsible campus partners to report (including exceptions to this requirement) can be found in the Comprehensive Policy.

University’s Response to Reports
Immediately upon electronic submission of a report by any individual (whether reported by the affected party or a third party reporter) using the online reporting form (powered by Maxient™), the reporter is automatically directed to concise information, written in plain language, concerning the rights and resources available to affected parties. These resources are also publicly available on the OEC website, at www.luc.edu/equity.

Unless a report is anonymous, upon receiving the report, a representative of the OEC (or Office of the Dean of Students for students) will contact the affected party and/or third party reporter to communicate the availability of supportive measures (available regardless of whether or not they choose to file a formal complaint) and to explain the process of filing a formal complaint, as applicable to the circumstances of the reported incident. The affected party will be invited to meet with a representative of the OEC (and/or Office of the Dean of Students, for students) to consider the affected party’s wishes with respect to supportive measures and any formal complaint, and to answer any questions concerning the University’s applicable policies or procedures. Affected parties will be informed that supportive measures are available regardless of whether they choose to file a formal complaint.

Formal complaints of sexual harassment (or other forms of discrimination, sexual misconduct, or retaliation) can be submitted via the appropriate online complaint form (powered by Maxient™) from among the options here. Different forms are required depending on whether the allegations meet the definitional and jurisdictional requirements of Title IX sexual harassment. All formal complaints of sexual misconduct will be promptly, thoroughly, and impartially investigated by the OEC according to the procedures described in the Comprehensive Policy.

Resources for Students and Employees

For Students:

For Employees:

Federal, State, and City of Chicago Resources

Title IX Notification
Loyola University Chicago does not discriminate on the basis of sex in any education program or activity that the University operates, and is required by Title IX of the Educational Amendments of 1972 and 34 CFR Part 106 (collectively referred to as “Title IX”) not to discriminate in such a manner. This requirement extends to admission and employment.

The University’s Title IX policies are published within the Comprehensive Policy and Equitable Resolution Procedures for Discrimination, Sexual Misconduct, and Retaliation (“Comprehensive Policy”), which includes information and instructions on how to submit a report or file a formal complaint of sex discrimination, including sexual harassment. Inquiries about the application of Title IX at Loyola can be directed internally to the Title IX Coordinator and/or externally to the Assistant Secretary for Civil Rights in the United States Department of Education.

The Title IX Coordinator for Loyola University Chicago is the Executive Director for Equity & Compliance, in the Office for Equity & Compliance. Any person may report sex discrimination, including sexual harassment, by using the online reporting form (powered by Maxient™), or in-person, by mail, by telephone, or by email, using the contact information listed below. 

Loyola University Chicago Office for Equity & Compliance
6439 N. Sheridan Rd.
Granada Center Suite 403
Chicago, IL 60626
(773) 508-7766
equity@luc.edu

Such a report may be made at any time, including during non-business hours, by using the online reporting form (powered by Maxient™), telephone number, or email provided above.

Inquiries may be made externally to:

Office for Civil Rights (OCR)
U.S. Department of Education
400 Maryland Ave., SW, Washington, DC
20202-1100
(800) 421-3481
TDD (877) 521-2172
OCR@ed.gov
www.ed.gov/ocr 

OCR Chicago Office
U.S. Department of Education
Citigroup Center
500 W. Madison St., Suite 1475, Chicago, IL 60661-4544
(312) 730-1560
OCR.Chicago@ed.gov

Equal Employment Opportunity Commission (EEOC)
Chicago District Office
JCK Federal Building,
230 S. Dearborn St., Chicago, IL 60604
(800) 669-4000
ASL Video Phone: (844) 234-5122
www.eeoc.gov

Loyola is fully compliant with Title IX and related laws and regulations but considers them to be a minimum standard for ensuring a safe and inclusive University environment. Accordingly, Loyola reserves the right to address any allegation of sexual misconduct (including non-consensual sexual penetration, non-consensual sexual contact, sexual harassment, sexual exploitation, intimate partner and/or domestic violence, and stalking), even if the alleged conduct does not meet the definitional and jurisdictional requirements for Title IX sexual harassment, or if the conduct occurs off campus.

To raise any concern or conflict of interest regarding the Executive Director for Equity & Compliance/Title IX Coordinator (“EDEC”), or to report any alleged misconduct or discrimination committed by the EDEC, contact the Vice President for Human Resources/Chief Human Resources Officer (“Chief Human Resources Officer”) at
(312) 915-6175 or HR-WTC@luc.edu. To raise concerns regarding a potential conflict of interest with or allegation of misconduct by any other administrator involved in the administration of the Comprehensive Policy, please contact the EDEC.

Revised: 6/9, 6/13, 9/21/15, 12/29/15, 10/12/20, 1/11/23, 1/26/23, 2/23/24