TITLE IX POLICY

A. Statement: The School does not discriminate on the basis of sex (including sexual orientation or gender identity), in its education programs or activities, and is required by Title IX of the Education Amendments Act of 1972, and its implementing regulations, not to discriminate in such a manner.  The requirement not to discriminate in its education program or activity extends to admission and employment.  The School is committed to maintaining an education and work environment that is free from discrimination based on sex, including sexual harassment.
The School prohibits Sexual Harassment that occurs within its education programs and activities. When Optima Classical Academy has actual knowledge of Sexual Harassment in its education program or activity against a person in the United States, it shall promptly respond in a manner that is not deliberately indifferent.
Pursuant to its Title IX obligations, The School is committed to eliminating Sexual Harassment and will take appropriate action when an individual is determined responsible for violating this policy. School employees, students, third-party vendors and contractors, guests, and other members of the School community who commit Sexual Harassment are subject to the full range of disciplinary sanctions set forth in this policy.  The School will provide persons who have experienced Sexual Harassment ongoing remedies as reasonably necessary to restore or preserve access to School education programs and activities.
 
B. Scope: This policy applies to Sexual Harassment that occurs within School’s education programs and activities and that is committed by a member of the School community (including students, employees, vendors) or a Third Party.
This policy does not apply to Sexual Harassment that occurs off School property, in a private setting, and outside the scope of School’s education programs and activities; such Sexual Misconduct/Sexual Activity may be prohibited by the student Code of Conduct if committed by a student, or by Board policies and administrative procedures, applicable State and/or Federal laws if committed by an School employee.
Consistent with the U.S. Department of Education’s implementing regulations for Title IX, this policy does not apply to Sexual Harassment that occurs outside the geographic boundaries of the United States, even if the Sexual Harassment occurs in School’s education programs or activities. Sexual Harassment that occurs outside the geographic boundaries of the United States is governed by the student Code of Conduct if committed by a student, or by Board policies and administrative procedures, applicable State and/or Federal laws if committed by a School employee.
 
C. Definitions:  The School shall use the following definitions when applying this policy.   Any words not specifically defined herein shall be given construed according to their plain and ordinary meanings.

1. Sexual Harassmentmeans conduct on the basis of sex that satisfies one or more of the following:
   1. An employee of School conditioning the provision of an aid, benefit, or service of the recipient on an individual's participation in unwelcome sexual conduct;
   2. Unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the recipient's education program or activity; or
   3. “Sexual assault” as defined in 20 U.S.C. 1092(f)(6)(A)(v), “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).
2. Complainant means an individual who is alleged to be the victim of conduct that could constitute sexual harassment.
3. Respondent means an individual who has been reported to be the perpetrator of conduct that could constitute Sexual Harassment.
4. Recipient means the entity responsible for implementing this policy, School.
5. Actual knowledge means notice of Sexual Harassment or allegations of Sexual Harassment to School’s Title IX Coordinator, or any School official who has authority to institute corrective measures on behalf of School, or any School employee. The mere ability or obligation to report Sexual Harassment or to inform a student about how to report Sexual Harassment, or having been trained to do so, does not qualify an individual as one who has the authority to institute corrective measures on behalf of School. “Notice” includes, but is not limited to, a report of Sexual Harassment to the Title IX Coordinator. This standard is not met when the only School official with actual knowledge is the Respondent.
6. Supportive measures mean non-disciplinary, non-punitive individualized services offered as appropriate, as reasonably available, and without fee or charge to the Complainant or the Respondent before or after the filing of a Formal Complaint or where no Formal Complaint has been filed. Such measures are designed to restore or preserve equal access to School’s education program or activity without unreasonably burdening the other party, including measures designed to protect the safety of all parties or School’s educational environment or deter Sexual Harassment. Supportive measures may include counseling, extensions of deadlines or other course-related adjustments, modifications of work or class schedules, school/campus escort services, mutual restrictions of contact between the parties, changes in work locations), leaves of absence, increased security and monitoring of certain areas of the campus (including school buildings and facilities), referral to an employee assistance program, and other similar measures.
7. Education program or activity refers to all operations of School, including but not limited to in-person and online educational instruction, employment, extracurricular activities, athletics, performances, and community engagement and outreach programs. The term applies to all activity that occurs on School property or on other property owned or occupied by School. It also includes locations, events, and circumstances that take place off-School property/grounds over which School exercises substantial control over both the Respondent and the context in which the Sexual Harassment occurs.
8. Day(s), unless otherwise expressly stated otherwise herein, shall mean business day(s) (i.e., a day(s) that School main administrative office is open for normal operating hours, Monday – Friday, excluding federal and State-recognized holidays and excluding those days designated in the School annual calendar as non-working days).
9. Formal Complaint refers to a document filed by a complainant or signed by the school-based Title IX Coordinator alleging sexual harassment against a respondent and requesting investigation of the allegation. The formal complaint may be filed in person, by mail, or by electronic mail.
10. Title IX Coordinator is responsible for coordinating Title IX compliance at the School.
11. The Investigator is responsible for conducting the investigation as required by Title IX and preparing the investigative report.  
12. The Decision-Maker reviews the evidence, determines responsibility for all formal complaints, and provides a written determination to the parties. The Decision-Maker cannot be the same person at the school-based Title IX Coordinator or the investigator.
13. The Appeals Decision-Maker is responsible for reviewing any appeals and the written determination of the Decision-Maker and issuing a separate written decision describing the result and rationale for the appeal.

 D. Reporting Sexual Harassment:  Any person may report sexual harassment, regardless of whether the reporting person is the alleged victim of the conduct. A report can be made in person, by mail, by telephone, or by electronic mail, using the contact information for the Title IX Coordinator. Reports may be made at any time, including during non-business hours. Any person with knowledge of sexual harassment is strongly encouraged to report the incident(s).
Reports should be made as soon as possible after the alleged incident, and the School shall be responsible for responding to complaints of which it has notice.  
All School employees are required to, and must, report, in writing, any allegations of sexual harassment or violations of this policy to the Title IX Coordinator.

E. Knowledge of Sexual Harassment:  When a school-based employee assigned to an elementary or secondary school has knowledge of sexual harassment or allegations of sexual harassment, Optima Classical Academy is obligated to respond.   

F. Response to Knowledge of Sexual Harassment: The School must respond to knowledge of sexual harassment in the school’s education program or activity against a person in the United States promptly and in a manner that is not “deliberately indifferent”, as that phrase is defined in 34 C.F.R. §106.44.  If the alleged sexual harassment might constitute a crime the matter shall immediately be reported to the School Resource Officer or the appropriate law enforcement agency. Any uncertainty regarding whether the alleged sexual harassment might constitute a crime must be resolved in favor of reporting the incident to law enforcement.

1. If the alleged sexual harassment might constitute child abuse the matter shall immediately be reported to the Florida Department of Children and Families. Any uncertainty regarding whether the alleged sexual harassment might constitute child abuse must be resolved in favor of reporting the incident.
2. When a School employee is the respondent, the Title IX Coordinator or school administrator shall immediately notify any applicable entity or agency dealing with professional standards.
3. Upon knowledge of sexual harassment, the Title IX Coordinator shall:
   1. Contact the complainant to discuss the availability of supportive measures;
   2. Consider the complainant’s wishes with respect to supportive measures;
   3. Inform the complainant of the availability of supportive measures with or without the filing of a formal complaint; and
   4. Explain to the complainant the process for filing a formal complaint.
   5.  

G. Filing of a Formal Complaint: 
The formal complaint may be filed by a complainant, parent or legal guardian, or signed by the Title IX Coordinator.  At the time of filing a formal complaint, the complainant must be participating in or attempting to participate in the school’s education program or activity.  Note that the Title IX Coordinator reserves the right to file a formal complaint if supportive measures would be inadequate to resolve the situation, even if the complainant desires not to file a formal complaint.

H. Response to Formal Complaint: When a Formal Complaint has been filed, School must immediately determine if:

1. The allegations meet the definition of sexual harassment, even if proved, as defined in this policy;
2. The conduct occurred in a School education program or activity; and
3. The allegations occurred against a person in the United States.

If School determines these requirements are met, the school must follow the grievance process outlined within this policy.
If School determines any of these requirements are not met, School must dismiss the formal complaint as outlined within this policy and written notice of said dismissal must be sent to the parent and/or legal guardian.

I. Consolidation of Formal Complaints:  Formal complaints involving allegations of sexual harassment arising from the same facts or circumstances may be consolidated against more than one (1) respondent, if multiple complainants file a complaint against multiple respondents, or if one (1) party files a complaint against the other party.
 
J. Dismissal of Formal Complaints: School shall evaluate allegations in any formal complaint and determine whether the dismissal of said complaint is either required or permitted.

1. Required Dismissal:  
   1. Formal Complaints are required to be dismissed if the alleged conduct:
      1. Does not constitute sexual harassment, even if proved, as within this policy; or
      2. Did not occur in any of School’s education programs or activities; or
      3. Did not occur against a person in the United States.
   2. Note that a dismissal does not prevent the School from taking action under any applicable provisions of any handbooks, policies, or codes of conduct, if School determines that such action is appropriate.    
2. Permitted Dismissal:  
   1. School may dismiss a formal complaint or any allegations during the investigation if:
      1. The complainant provides written notice to the school-based Title IX Coordinator of their intent to withdraw the formal complaint or any allegations; or
      2. The respondent is no longer enrolled or employed by Optima Classical Academy; or
      3. Specific circumstances prevent the school from gathering evidence sufficient to reach a determination.
3. Written Notice of Dismissal: Whenever a formal complaint is dismissed, School shall send written notice of the dismissal, and the reasons for said dismissal, simultaneously to all parties within five (5) business days.
4. Appeal of Dismissal:  Parties may request an appeal from a dismissal within two (2) school days of issuance of the dismissal. Requests for an appeal should be sent to the decision-maker, as outlined in this policy.

 K. Emergency Removal: School may remove a respondent from any education program or activity on an emergency basis, only after undertaking an individualized safety and risk analysis, and determining if an immediate threat to the physical health or safety of any student or other individual arising from the allegations of sexual harassment justifies removal, and providing the respondent with notice and an opportunity to challenge the decision within two (2) business days following the removal. Notice of emergency removal must be sent to the parent and/or legal guardian. This provision may not be construed to modify any rights under the Individuals with Disabilities Education Act, Section 504 of the Rehabilitation Act of 1973, or the Americans with Disabilities Act.
 
L. Grievance Process for Formal Complaints of Sexual Harassment: The School must, when responding to a formal complaint, provide written notice to all known parties (complainant and respondent) and follow a specified grievance process before the imposition of any disciplinary action against the respondent.  The School will follow the grievance procedures and standards as outlined in 34 C.F.R. §106.45, and as set forth herein and below.

1. Written Notice of Allegations:

School shall provide written notice of the allegations to all known parties upon receipt of a formal complaint within two (2) business days. Said notice shall be sent to the parent and/or legal guardian of the known parties involved and shall include the following:

1. The identities of the parties involved in the incident, if known;
2. The conduct allegedly constituting sexual harassment;
3. The date and location of the alleged incident, if known;
4. A statement that the respondent is presumed not responsible for the alleged conduct;
5. Information regarding School’s grievance process;
6. A statement that a determination regarding responsibility is made at the conclusion of the grievance process;
7. A statement informing the parties that they may have an advisor of their choice, who may be, but is not required to be, an attorney;
8. A statement advising parties that they may inspect and review evidence, as outlined within this policy; and
9. A statement informing the parties of any provision in the school’s Code of Student Conduct that prohibits knowingly making false statements or knowingly submitting false information during the grievance process.

2. Written Notice – Supplemental Allegations: If, during the course of an investigation, the School decides to investigate allegations about the complainant or respondent that are not included in the original notice, written notice of the additional allegations must be provided to the known parties within two (2) business days, pursuant to the requirements of written notice as outlined above.
3. Response to Complaint:  Parties shall have the opportunity, if they so desire, to prepare a response regarding the formal complaint and provide said response prior to, or during, the initial interview of the parties, which shall be conducted separately.
4. Basic Requirements for Grievance Process: School shall ensure that its grievance process and investigation of any formal complaint provides for the following basic requirements as set forth and more thoroughly described, in 34 CFR § 106.45:

1. Treat complainants and respondents equitably by providing remedies to a complainant where a determination of responsibility for sexual harassment has been made against the respondent, and by following a grievance process that complies with Section 106.45 before the imposition of any disciplinary sanctions or other actions that are not supportive measures as defined in § 106.30, against a respondent.
2. Provide remedies that are designed to restore or preserve equal access to the recipient's education program or activity. Such remedies may include the same individualized services described in § 106.30 as “supportive measures”; however, remedies need not be non-disciplinary or non-punitive and need not avoid burdening the respondent.
3. Require an objective evaluation of all relevant evidence—including both inculpatory and exculpatory evidence—and provide that credibility determinations may not be based on a person's status as a complainant, respondent, or witness.
4. Require that any individual designated by a recipient as a Title IX Coordinator, investigator, decision-maker, or any person designated by a recipient to facilitate an informal resolution process, not have a conflict of interest or bias for or against complainants or respondents generally or an individual complainant or respondent.
5. Ensure that Title IX Coordinators, investigators, decision-makers, and any person who facilitates an informal resolution process, receive training on the definition of sexual harassment in § 106.30, the scope of the recipient's education program or activity, how to conduct an investigation and grievance process including hearings, appeals, and informal resolution processes, as applicable, and how to serve impartially, including by avoiding prejudgment of the facts at issue, conflicts of interest, and bias.  Additionally, ensure that investigators receive training on issues of relevance to create an investigative report that fairly summarizes relevant evidence.
6. Include 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.
7. Include reasonably prompt time frames for conclusion of the grievance process, including reasonably prompt time frames for filing and resolving appeals and informal resolution processes if the recipient offers informal resolution processes, and a process that allows for the 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.  The School will endeavor to resolve any investigation/grievance process within sixty (60) days unless good cause exists to extend or delay said investigation as set forth above.
8. Describe the range of possible disciplinary sanctions and remedies or list the possible disciplinary sanctions and remedies that the recipient may implement following any determination of responsibility.
9. Notify the parties of the standard of evidence to be used to determine responsibility.   Note that School utilizes the preponderance of the evidence standard.
10. Include the procedures and permissible bases for the complainant and respondent to appeal.
11. Describe the range of supportive measures available to complainants and respondents.
12. Not require, allow, rely upon, or otherwise use questions or evidence that constitute, or seek disclosure of, information protected under a legally recognized privilege, unless the person holding such privilege has waived the privilege.

5. Investigation of Formal Complaint: When investigating a formal complaint, and throughout the grievance process School, shall:

1. Ensure that the burden of proof and the burden of gathering evidence sufficient to reach a determination regarding responsibility rest on the recipient and not on the parties.
2. Note that School cannot 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 School 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 CFR 99.3, then the School must obtain the voluntary, written consent of a “parent,” as defined in 34 CFR 99.3);
3. Provide an equal opportunity for the parties to present witnesses, including fact and expert witnesses, and other inculpatory and exculpatory evidence;
4. Not restrict the ability of either party to discuss the allegations under investigation or to gather and present relevant evidence;
5. Provide the parties with the same opportunities to have others present during any grievance proceeding, including the opportunity to be accompanied to any related meeting or proceeding by the advisor of their choice, who may be, but is not required to be, an attorney, and not limit the choice or presence of advisor for either the complainant or respondent in any meeting or grievance proceeding; however, the recipient 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.
6. Provide, to a party whose participation is invited or expected, written notice of the date, time, location, participants, and purpose of all investigative interviews, or other meetings, with sufficient time for the party to prepare.
7. Provide both parties an equal opportunity to inspect and review any evidence obtained as part of the investigation that is directly related to the allegations raised in the formal complaint, including the evidence upon which the recipient does not intend to rely in reaching a determination regarding responsibility and inculpatory or exculpatory evidence whether obtained from a party or other source, so that each party can meaningfully respond to the evidence prior to conclusion of the investigation.
8. Prior to completion of the investigative report, School must 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 must have at least ten (10) days to submit a written response, which the investigator will consider prior to completion of the investigative report.
9. Create an investigative report that fairly summarizes relevant evidence and, at least ten (10) days prior to any determination regarding responsibility, send to each party and legal guardian/parent and the party's advisor, if any, the investigative report in an electronic format or a hard copy, for their review and written response.
   1. Following the dissemination of the Investigative Report, and prior to any written determination, each party shall be given two (2) days to submit written, relevant question to be asked of any party or witness and provide each party with answers within two (2) days.  Parties shall then be allowed two (2) days to provide no more than (5) follow-up questions in total from all parties and witnesses.  Parties and witnesses shall have two (2) days to respond to any follow-up questions.
      1. The decision-maker, for any submitted questions must determine whether a question is relevant and shall explain to the proposing party any decision to exclude a question as not relevant.  
      2. Questions and evidence regarding a complainant’s sexual predisposition or prior sexual behavior are only relevant if offered to prove someone other than the respondent committed the alleged conduct, or if the questions and evidence concern specific incidents of the complainant’s prior sexual behavior with respect to the respondent and are offered to prove consent.

6. Live Hearings: The School does not offer live hearings pursuant to Title IX for grades K-12.  
7. Written Determinations:  At the conclusion of the grievance process/investigation, the Decision-Maker will apply the preponderance of the evidence standard to reach a determination of responsibility and issue a written determination report to the parties simultaneously.  The Title IX Coordinator will be responsible for implementing the remedies stated in the written determination.  Said written determination shall include:

1.  Identification of the allegations potentially constituting sexual harassment, pursuant to the definition in this policy;
2. A description of the procedural steps taken from the receipt of the formal complaint through the written determination, including any notifications to the parties, interviews with parties and witnesses, site visits, methods used to gather other evidence, and hearings;
3. Findings of fact supporting the determination;
4. Conclusions regarding application of the Code of Student Conduct to the facts; (v) The result and rationale as to each allegation;
5. A determination regarding responsibility as to each allegation;
6. Any disciplinary sanctions imposed on the respondent by the school;
7. Whether remedies will be provided by the school to the complainant; and
8. Permissible procedures and grounds for the complainant and respondent to appeal.

8. Appeals:   Each party has the right and opportunity to appeal from both a written determination or dismissal of any formal complaint.  A request for an appeal must be made in writing within two (2) days of issuance of the dismissal or written determination, and should be sent to the decision-maker in each instance.   

1. If an appeal is not filed, the determination regarding responsibility becomes final on the date after the two (2) school days to file an appeal has passed. If an appeal is filed, the determination regarding responsibility becomes final on the date the School provides the written appeals decision.
2. Grounds for Appeal. The grounds for an appeal are limited.  Appeals may take place for the following reasons:
   1. Procedural issues affected the outcome;
   2. New evidence that was not reasonably available at the time the written determination or dismissal was made becomes available that could affect the outcome; or
   3. There was a conflict of interest or bias by the school-based Title IX Coordinator, investigator, or decision-maker, against any complainant or respondent that affected the outcome.
3. Notification of an Appeal:  the School must notify the other party in writing when an appeal is filed and implement appeal procedures equally for both parties.  Parties must be given three (3) days to submit a written statement in support of, or challenging, the outcome of the written determination. If a written statement is not received within three (3) school days, the appeals decision-maker will deem the non-response as a waiver and continue with the appeals process.
4. Appeals Decision-Maker:  The appeals decision-maker may not be the same person as the investigator, school-based Title IX Coordinator, or decision-maker who reached the initial determination of responsibility or dismissal. The appeals decision-maker must not have a conflict of interest or bias for or against any complainant or any respondent.
5. Written Appeals Determination: The written appeals determination describing the result and rationale for the decision must be provided simultaneously to both parties within five (5) days.

 M. Retaliation: No school or other person may intimidate, threaten, coerce, or discriminate against any individual for the purposes of interfering with any right or privilege secured by Title IX, or because the individual has made a report or complaint, testified, assisted, or participated or refused to participate in any manner in an investigation, proceeding, or hearing.

1. Definition of Retaliation.
   1. Intimidation, threats, coercion, or discrimination, including against an individual for code of conduct violations that do not involve sex discrimination or sexual harassment, but arise out of the same facts or circumstances as a report or complaint of sex discrimination, or a report or formal complaint of sexual harassment, for the purpose of interfering with any right or privilege secured by Title IX, constitutes retaliation.
   2. The exercise of rights protected under the First Amendment does not constitute retaliation.
   3. A Code of Student Conduct violation for making a materially false statement in bad faith during the course of the grievance process does not constitute retaliation. A determination regarding responsibility alone is insufficient to conclude that any party made a materially false statement in bad faith.
2. Filing of Retaliation Complaints. Complaints alleging retaliation may be filed according to the same grievance procedures for sex discrimination as outlined in this policy.

 N. Confidentiality:  

1. Schools must keep confidential the identity of the following individuals
   1. Any individual who has made a report or complaint of sex discrimination;
   2. Any individual who has made a report or filed a formal complaint of sexual harassment;
   3. Any complainant;
   4. Any individual reported to be the perpetrator of sex discrimination;
   5. Any respondent; and
   6. Any witness.
2. Exceptions to Confidentiality. School may release confidential information as permitted by the FERPA statute, 20 U.S.C. 1232g, or FERPA regulations, 34 CFR part 99, or as required by law, or to carry out the purposes of 34 CFR part 106, including the conduct of any investigation, hearing, or judicial proceeding arising thereunder.

O. Training: All materials used to train school-based Title IX Coordinators, investigators, decision-makers, and appeals decision-makers must not rely on sex stereotypes and must promote impartial investigations and adjudications.

1. (a) School-based Title IX Coordinators, investigators, decision-makers, hearing officers, and appeals decision-makers must receive training on:
   1. The definition of sexual harassment as defined in (1)(a);
   2. The scope of the school’s education program or activity;
   3. How to conduct an investigation and grievance process, including hearings and appeals; and
   4. How to serve impartially by avoiding prejudgment of the facts, conflicts of interest, and bias.
2. Decision-makers and hearing officers must receive training on:
   1. Relevance of questions and evidence, including the relevance of the complainant’s sexual predisposition or prior sexual behavior as noted in this policy.
3. Investigators must receive training on:
   1. Issues of relevance to create an investigative report that fairly summarizes relevant evidence; and
   2. Sending the investigative report, in an electronic or hard copy, to each party and their advisor ten (10) days prior to a hearing for their review and written response.

P. Recordkeeping:  The School will retain records as set forth in 34 CFR § 106.45.  

1. Required Recordkeeping:  Schools must create records of any actions, including supportive measures, taken in response to a report or formal complaint of sexual harassment. If supportive measures are not provided, the school must document the reasons why such a response was not clearly unreasonable in light of the known circumstances.
2. Maintaining Records. Schools must maintain records related to any sexual harassment investigation for seven (7) years, including records of:
   1. Any actions taken in response to a report of sexual harassment;
   2. Any actions taken in response to a formal complaint of sexual harassment;
   3. Any supportive measures provided;
   4. Each sexual harassment investigation;
   5. Any determination regarding responsibility;
   6. Any audio or audiovisual recording or transcript;
   7. Any disciplinary sanctions imposed on the respondent;
   8. Any remedies provided to the complainant;
   9. Any appeal and written appeal decision; and
   10. All materials used to train school-based Title IX Coordinators, investigators, decision-makers, hearing officers and appeals decision-makers.

 Q. Notification of Policy/Coordinator:  

1. School must notify students, parents, legal guardians or elementary and secondary school students, employees, and applicants for admission and employment, the name, address, phone number or contact information of the Title IX Coordinator.   This may be accomplished by the posting or publication of this information on the School’s website.  
2. School must notify students, parents, legal guardians or elementary and secondary school students, employees, and applicants for admission and employment of this Title IX policy.  Specifically, School hereby provides notification of the following:
   1. The School does not discriminate on the basis of sex in any education program or activity;
   2. The School is required by Title IX not to discriminate on the basis of sex;
   3. The requirement to not discriminate on the basis on sex extends to admission and employment; and
   4. Inquiries about Title IX are referred to the Title IX Coordinator.
3. Publication:   The School must not use or distribute a publication that states the School treats applicants, students, or employees differently on the basis of sex, except as permitted by Title IX.  School will prominently display information regarding this policy, as well as the identification and contact information for its Title IX Coordinator on its website or any relevant handbook, employee handbook, or code of conduct.  School will also make publicly available any training materials on its website.  

 R. FERPA:  School should interpret Title IX and FERPA in a manner to avoid any conflicts. Where a true conflict exists, the obligation to comply with Title IX is not obviated or alleviated by the FERPA statute, 20 U.S.C. 1232g, or FERPA regulations, 34 CFR part 99. 
Adopted: 03/05/2024