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Individuals and offices wishing to conduct a survey that is covered by this Policy must complete and submit a written application to the appropriate area vice president, associate vice president, or committee/board as applicable (e.g. student surveys must be approved by the vice president for student affairs; alumni surveys approved by the vice president for institutional advancement; employee surveys by the associate vice president for human resources and compliance; human research subject surveys by the IRB; etc.).  Information required includes but is not limited to: a description of the survey project, including the purpose and intended use of results; the specific respondent population receiving the survey; the method of survey distribution (e.g. online or hard copy, via email, in class, at event, etc.); the time frame for administering the survey, including beginning and end dates; evidence of IRB approval (if necessary); description of any planned incentive program for respondents; and a current draft of the survey and all invitation and cover letters.

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• If the accused is an administrator/staff member or volunteer, the matter will be referred to the associate vice president for human resources and compliance (see Volume III of the Canisius University Policy Manual);
• If the accused is a faculty member, the matter will be forwarded to the vice president for academic affairs for resolution pursuant to procedures set forth in the Faculty Handbook;
• If the accused is a student, the matter will be forwarded to the vice president for student affairs for formal resolution under the Community Standards procedures set forth in Volume VI of the Canisius University Policy Manual; and
• If the accused is a vendor or contractor, the vice president for finance and administration will enact appropriate corrective action, which may include removal from the campus(es) and termination of any applicable contractual or other arrangements.

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1. This Policy applies to the following persons regardless of immigration status:  all employees, applicants for employment, interns (paid or unpaid), and contractors, subcontractors, vendors, consultants and other persons providing services in the workplace pursuant to a contract with Canisiusor any of their employees who are providing services in the workplace.[2]  (All of these persons are referred to in the remainder of this Policy singularly as “Covered Person” and collectively as “Covered Persons.”)
2. Sexual harassment is prohibited and will not be tolerated.  Any Covered Person who engages in sexual harassment will be subject to remedial and/or disciplinary action (e.g., counseling, suspension or termination).  Any Covered Person who believes he or she has been a target of sexual harassment should report it using the procedures explained below in the section titled “Reporting Sexual Harassment and Retaliation.” 
3. Retaliation is prohibited.  Canisius will not tolerate any retaliatory adverse action against any Covered Person who, in good faith, reports sexual harassment or who provides information, testifies or otherwise assists in any investigation of or proceeding involving sexual harassment.  Any Covered Person who engages in such retaliation will be subject to disciplinary action, up to and including termination.  Any Covered Person who believes he or she has been a target of retaliation should report it using the procedures explained below in the section titled “Reporting Sexual Harassment and Retaliation.”   
4. Sexual harassment and retaliation are unlawful and a violation of this Policy and may subject Canisius to liability for harm to targets of such conduct.  Persons who engage in sexual  harassment and retaliation may also be subject to individual liability.  Covered Persons of every level who engage in sexual harassment and/or retaliation, including managers and supervisors who engage in such conduct or who knowingly allow such conduct to continue, will be penalized for such misconduct.   
5. All Covered Persons are encouraged to report any sexual harassment, retaliation or behaviors that violate this Policy.  Canisius will provide a complaint form for reporting such conduct and filing complaints. 
6. Managers and supervisors are required to report any complaint of sexual harassment or retaliation that they receive or any sexual harassment that they observe or become aware of to the Associate Vice President for Human Resources & Compliance in the Human Resources Department.
7. Canisius will conduct a prompt and thorough investigation that ensures due process for all parties whenever management receives a complaint about sexual harassment or retaliation or otherwise knows of possible sexual harassment or retaliation occurring.  Canisius will keep the investigation confidential to the extent possible.  Effective corrective action will be taken whenever sexual harassment or retaliation is found to have occurred. All employees, including managers and supervisors, are required to cooperate with any internal investigation.
8. This Policy applies to all Covered Persons and all must follow and uphold it.  This Policy must be provided to all employees and will be provided to employees upon hiring.

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Preventing sexual harassment and retaliation is everyone’s responsibility. Canisiuscannot prevent or remedy sexual harassment and retaliation unless it knows about them. Any Covered Person who has been subjected to behavior that may constitute sexual harassment or retaliation should report such behavior to his or her supervisor or manager or to the Associate Vice President for Human Resources & Compliance in the Human Resources Department. Anyone who witnesses or becomes aware of potential instances of sexual harassment or retaliation should report such behavior to his or her supervisor or manager or to the Associate Vice President for Human Resources & Compliance in the Human Resources Department.

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All supervisors and managers who receive a complaint or information about suspected sexual harassment or retaliation, observe what may be sexually harassing behavior or retaliation or for any reason suspect that sexual harassment or retaliation is occurring, are required to report such suspected sexual harassment or retaliation to the Associate Vice President for Human Resources & Compliance in the Human Resources Department.

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All allegations of sexual harassment occurring within the university’s education programs and activities as defined by the university’s Sexual and Gender-Based Misconduct (Title IX) Policy will be handled exclusively pursuant to the investigation and grievance procedures outlined in that policy.  When the alleged sexual harassment conduct does not meet the university’s Sexual and Gender-Based Misconduct (Title IX) Policy definition of sexual harassment, then the university’s investigation and resolution efforts will be conducted in accordance with the university’s Anti-Discrimination and Harassment Policy.  The determination of which policy will govern is in the sole discretion of the Title IX officer and the Associate Vice President for Human Resources & Compliance. 

The university's investigation, regardless of which policy governs, will be kept confidential to the extent possible. Moreover, all persons involved, including complainants, witnesses and alleged harassers will be accorded due process, as outlined below, to protect their rights to a fair and impartial investigation.

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