Information for Crime Victims for Disciplinary Proceedings

In accordance with the Crime Awareness and Campus Security Act of 1990, the institution collects campus crime statistics and prepares this report for distribution to all students, employees, and applicants for enrollment or employment. This report is distributed annually in September to all current and prospective students and employees. All data in this report is information from the Memphis/Bartlett Police Department. In addition, the report is provided to all individuals during enrollment or employment orientation that is conducted with each start class or upon hiring of a new employee. At that time, students and employees review the report and receive a description of the campus security procedures and further information regarding the prevention of crimes. Any individual can request a copy of this report at any time.

The school encourages all students and employees to be responsible for their own security and the security of others. The school does not employ campus security officials. Therefore, the security of the campus is the direct responsibility of each employee and administrator. No such individuals have the authority to make arrests. All individuals are requested to report immediately any known criminal offense or other emergency occurring on campus to the school administration at the administration office. All individuals are encouraged to promptly report all crimes to appropriate police agencies. The campus administration will report all known criminal offenses to the local law enforcement authorities. The school has no policy or procedure regarding confidential crime reporting in relation to crime statistics reporting. Any off campus events are supervised by campus employees. Therefore, the school will monitor and report criminal activity at such events to local law enforcement authorities. No student will have access to the campus facility, other than the parking area, at any time unless supervised by a staff member.

Everyone should remember that personal safety begins with you. The following should be considered:

-When walking on campus, be aware of who and what is around you. Try not to walk alone.

-Do not carry large amounts of cash.

-Keep your motor vehicle in good running condition. Always lock your car and remove all packages and any valuables which are visible.

-Do not leave books or personal property unattended in the classroom.

(Campus is defined as any building or property owned or controlled by the school within the same contiguous geographic area and used by the school in direct support of or related to its educational purpose. There are no buildings or properties owned or controlled by the school’s student organizations which are recognized by this institution.)

CAMPUS SECURITY, CRIME AWARENESS, DRUG FREE WORKPLACE, ANTI-HARASSMENT AND DISCRIMINATION POLICY

In accordance with the Crime Awareness and Campus Security Act of 1990, the institution collects campus crime statistics and prepares this report for distribution to all students, employees, and applicants for enrollment or employment.

This report is distributed annually in September to all current and prospective students and employees. All data in this report is information from the Memphis/Bartlett Police Department. In addition, the report is provided to all individuals during enrollment or employment orientation that is conducted with each start class or upon hiring of a new employee. At that time, students and employees review the report and receive a description of the campus security procedures and further information regarding the prevention of crimes. Any individual can request a copy of this report at any time.

What is the Clery Act?

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act or Clery Act, signed in 1990, is a federal statute codified at 20 U.S.C. § 1092(f), with implementing regulations in the U.S. Code of Federal Regulations at 34 C.F.R. 668.46.

It is a federal law that requires colleges and universities who receive federal funding to disclose information on campus safety and requires basic requirements for handling incidents of sexual violence and emergency situations.

GEOGRAPHY:

Campus

  1. Any building or property owned or controlled by Gould’s Academy within the same reasonably contiguous geographic area and used by Gould’s Academy in direct support of, or in manner related to, Gould’s Academy’s education purposes; and
  2. Any building or property that is within or reasonably contiguous to the area identified in paragraph (1), that is owned by Gould’s Academy but controlled by another person, is frequently used by students, and supports institutional purposes.

 Non-Campus building or property

  1. Any building or property owned or controlled by a student organization that is officially recognized by Gould’s Academy; or
  2. Any building or property owned or controlled by Gould’s Academy that is used in direct support of, or in relation to, Gould’s Academy’s educational purposes, is frequently used by students, and is not within the same reasonably contiguous geographic area. 

Public Property

  1. All public property, including thoroughfares, streets, sidewalks, and parking facilities, that is within the campus, or immediately adjacent to and accessible from campus.

 III. CRIME STATISTICS:

Crime statistics that are provided in this annual report are based upon incidents reported by the local Police Departments or Administrators/Management. Each entity provides updated information on their educational efforts and programs to comply with the Act. This annual report is prepared by Gould’s Academy. Gould’s Academy annually reports statistics for the three most recent calendar years concerning the occurrence on campus and on public property. Campus crime, arrests, and referral statistics include those reported to the Police or one of the Administrators/Manager.

CAMPUS SECURITY AUTHORITIES:

Paul Gould,

Garrett Gerlach,

Procedure for Reviewing Crime Reports

  1. Crime reports are received in-person, phone, e-mail, and documented.
  2. Reports are reviewed by the administration/management to accurately record Clery category.
  3. Reports are compared for accuracy of reporting.
  4. Yearly process of reporting crimes is reviewed to improve reporting efforts.
  5. STATISTICS FROM LOCAL LAW ENFORCEMENT AGENCIES:

In addition to collecting crime reports from local law enforcement, Gould’s Academy makes a good faith effort in obtaining Clery crime statistics from local agencies within the geography of each campus as well.

VII. EMERGENCY RESPONSE AND EVACUATION PROCEDURES:

Notification of an Emergency:

Gould’s Academy uses a variety of tools to keep students, staff and guests informed in the event of an emergency that could affect their health and safety. These tools contain the Gould’s Academy’s Emergency Notification System: text messaging, e-mail, social media, voice mail, and notification apps. Some or all of these tools may be used in a given emergency situation. Emergency notifications are sent when there is a confirmed emergency or dangerous situation occurring on campus that involves an immediate threat to the health or safety of the campus community and in situations requiring immediate action. The owner or manager on site is responsible for assessing all known information about an emergency situation on campus and determining the need for emergency notification and immediate actions, such as building evacuation. The owner or manager will, without delay, and taking into account the safety of the community, determine the content of the notification and initiate the notification system, unless issuing a notification will, in the professional judgment of the owner or manager, compromise efforts to assist a victim or to contain, respond to or otherwise mitigate the emergency.

Disseminating Emergency Information to the Larger Community:

Gould’s Academy disseminates emergency information to individuals and/or organizations outside of the campus community in the following ways:

  • Facebook Community Page
  • Electronic Communication

The administrator of Gould’s Academy is responsible for determining what relevant information to be disclosed.

Testing of Emergency Procedures:

Gould’s Academy emergency response and evacuation procedures will be tested at least one time in a calendar year. Annual testing may be either announced or unannounced and will be publicized on the Gould’s Academy website. Documentation of the testing, to include a description of the exercise, the date, time and whether it was announced or unannounced, will be maintained and retained in the Administrative Office.

VIII. TIMELY WARNINGS

In the event that a situation arises, either on or off campus, that, in the judgment of theadministrator/manager, constitutes an ongoing or continuing threat, a campus wide “timely warning” will be issued. The warning will be issued through the most effective and efficient means available and may include instant messaging to students and Gould’s Academy employees. Notices may also be posted in the common areas throughout the school. Anyone with information warranting a timely warning should report the circumstances to the administrator/manager by phone at 901-767-6647/901-842-1772.

Pastoral and Professional Counselors:

Gould’s Academy does not employee or have affiliation with Pastoral or Professional Counselors.

ANNUAL SECURITY REPORT:

Reporting Policies and Protocols:

Gould’s Academy strongly encourages all members of the school community to report information about any incident of crime or sexual misconduct as soon as possible, whether the incident occurred on or off campus. Reports can be made either to the administration/managers and/or to law enforcement.

Confidential Reporting:

Confidential reporting gives the victim the opportunity to speak confidentially with a professional who works in a health-care or counseling role.

  • University of Memphis Crime Victims and Rape Crisis Center:  901-222-3950
  • Tennessee Coalition to End Domestic and Sexual Violence:  1-800-289-9018800-289-9018
  • Tennessee Statewide Sexual Assault Hotline: 1-866-811-7473
  • State Domestic Violence Helpline: 1-800-356-6767

Non-Confidential Reporting:

Non-confidential reporting means that an investigation will occur with an outcome. Details of the report will only be shared with individuals with a need-to-know basis. Privacy will be protected to the extent possible. To file a non-confidential complaint, please use one of the following options:

-All victims are encouraged, but not required, to file a Police Report

911 or Memphis Police Department 901-545-2677/ Bartlett Police Department 901-385-5555

-Paul Gould, Title IX Coordinator

Email:

Phone: 901-767-6647

-Garrett Gerlach, Title IX Coordinator,

Email:

Phone: 901-842-1772

Preparing the Annual Disclosure of Crime Statistics:

Crime statistics that are provided in this annual report are based upon incidents reported by the local law enforcement and/or administration/management team. This annual report is prepared by Gould’s Academy. Gould’s Academy annually reports statistics for the three most recent calendar years concerning the occurrence on campus and on public property. Campus crime, arrests, and referral statistics include those reported to the Police or one of the administrators/managers.

This information is reviewed annually at staff meetings as well as made available to each incoming student as well as current students at any time.

Access to Campus Facilities and Security Considerations in the Maintenance of Campus Facilities:

Gould’s Academy is committed to maintaining an environment in which students, staff, and guests can work together free from all forms of harassment, exploitation and intimidation. Gould’s Academy will act as needed to discourage, prevent, correct, and, if necessary, discipline behavior that violates this standard of conduct. During business hours, Gould’s Academy is open to students, parents, staff, guests and invitees. During non-business hours access to all facilities is by key, if issued, or by admittance via an administrator, manager, or staff member.

Policy to Inform Students and Employees about the Prevention of Crime:

Gould’s Academy educates the incoming and current student and employee community about crime, sexual violence, violence prevention, and all relevant Gould’s Academy policies and procedures during all orientations held for new and current students at the onset of a class and at least annually.

In addition, Gould’s Academy conducts new and current employee training on these topics at least annually. The Title IX Coordinator is responsible for training all Gould’s Academy current students and employees about Gould’s Academy policies regarding crime and sexual violence and for conducting the new student and employee training.

 Campus Law Enforcement:

Gould’s Academy does not employee campus law enforcement or security personnel.

Student Organizations with Non-Campus Locations:

Gould’s Academy does not have any officially recognized student organizations with non-campus locations.

Alcohol & Drug Prevention Program & Policy:

Under the “Drug Free Workplace Act of 1988” and the “Drug Free Schools and Communities Act Amendments of 1991” the college is required to notify all employees and students of its specific alcohol and drug policy program. The elements of the policy and program include consequences that may follow the use of alcohol and other drugs, and sanctions that may be applied both by the College and by external authorities. The law requires that individuals be notified of possible sources of assistance for problems that may arise as a result of use. The following material is provided to supplement the comprehensive policies that are being prepared in accordance with the Task Force report. This policy is intended to educate members of the College community about the health risks associated with the use and abuse of alcohol and other drugs and about the resources available for counseling and therapy. In addition, in order to assure a work and learning environment that promotes the College’s mission and proper function, the College prohibits unlawful possession, use, or distribution of alcohol or illicit drugs by faculty, staff, or students on College property or as a part of any College activity. Federal and state sanctions also apply to such conduct. Prevention strategies include efforts to change inappropriate community norms regarding alcohol and other drug use, to alter environmental factors that support inappropriate use, and to provide information and skills regarding sensible use.

Health Risks:

The use or abuse of alcohol and other drugs increase the risk for a number of health related and other medical, behavioral, and social problems. These include acute health problems related to intoxication or overdose (blackouts, convulsions, coma, death); physical and psychological dependence; malnutrition; long-term health problems, including cirrhosis of the liver, organic brain damage, high blood pressure, heart disease, ulcers, and cancer of the liver, mouth, throat, and stomach; contracting diseases, such as AIDS, through the sharing of hypodermic needles; pregnancy problems including miscarriages, still births and learning disabilities; fetal alcohol syndrome (physical and mental birth defects); psychological or psychiatric problems; diminished behavior (hangovers, hallucinations, disorientation, slurred speech); unusual or inappropriate risk-taking which may result in physical or emotional injury, or death; violent behavior towards others, such as assaults and rape; accidents caused by operating machinery while impaired; impaired driving resulting in alcohol and drug-related arrest, traffic accidents, injuries, and fatalities; negative effects on academic or work performance; conflict with co-workers, classmates, family, friends, and others; conduct problems resulting in disciplinary actions, including loss of employment; and legal problems including imprisonment.

Counseling and Treatment Programs:

The college encourages individuals with alcohol or other drug-related problems to seek assistance. The following is a list of resources:

-Tennessee Association of Alcohol, Drug & other Addiction Services, 1-800-889-9789

-Tennessee Statewide Crisis Phone Line, 1-855-274-7471

-Tennessee Department of Mental Health & Substance Abuse Services Helpline, 1-800-560-5767

College Sanctions:

Unlawful possession, use, manufacture, or distribution of alcohol or illicit drugs by faculty, staff, or students on College property or as a part of any College activity may lead to sanctions within the College, the severity of which shall increase as the seriousness of the violation increases. Sanctions include: A verbal or written reprimand; Completion of an appropriate rehabilitation program; A disciplinary warning, with notice that repetition of the offense or continuation of the offense may result in a more serious sanction; Suspension from the College (student) or from employment (employee) or from a specific College activity or facility for a fixed period of time or until completion of specified conditions, such as completion of an appropriate rehabilitation program; Expulsion from the College (student) or termination of employment (faculty and staff); and/or Other appropriate sanctions.

External Sanctions:

Unlawful possession, use, manufacture, or distribution of alcohol or illicit drugs may also lead to a referral to the appropriate local, state, and/or federal authorities for prosecution for a misdemeanor or felony, depending on the nature of the offense. The sanctions for such offenses may include fines and/or imprisonment.

Distribution of Policy:

A copy of this policy statement shall be distributed annually to all faculty, staff, and students.

Title IX Notice of Nondiscrimination:

Gould’s Academy does not discriminate on the basis of sex in its education programs or activities and is committed to ensuring an educational environment free of sexual harassment, including sexual violence, and to full compliance with Title IX of the Education Amendments Act of 1972 and other federal and state laws governing such conduct.

The following individual[s] has [have] been designated as the Title IX Coordinator[s] by Gould’s Academy to handle inquiries regarding Gould’s Academy Title IX policies, including receiving and responding to information about any incident of sex discrimination:

Paul Gould

Email: , Phone: 901-767-6647

Garrett Gerlach

Email: , Phone: 901-842-1772

Information regarding sexual discrimination, including sexual harassment or sexual violence, may also be reported by anyone to: U.S. Office for Civil Rights by email at or at the addresses provided at the following website: http://www2.ed.gov/about/offices/list/ocr/docs/howto.html

“Sexual harassment” is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that may constitute sexual harassment when:

  • Submission to such conduct is made either explicitly or implicitly as a term or condition of an evaluation of a student’s academic performance, or a term or condition of participation in student activities or in other events or activities sanctioned by Gould’s Academy;
  • Submission to or rejection of such conduct by an individual is used as the basis for academic decisions or other decisions about participation in student activities or other events or activities sanctioned by Gould’s Academy; or
  • Such conduct otherwise has the purpose or effect of threatening an individual’s academic performance; or creating an intimidating, hostile, or offensive educational environment.

Forms of sexual harassment include, but are not limited to, sexist remarks or behavior, constant offensive joking, sexual looks or advances, repeated requests for dates, unwelcome touching, and promise of reward for sexual favors. Students, faculty, or staff who experience sexual harassment should be encouraged to make it clear to the alleged offender that such behavior is offensive. However, failure to comply with this provision does not defeat the Institute’s obligation to investigate the incident and take appropriate steps if sexual harassment has occurred.

Sexual violence includes, among other conduct, domestic violence, dating violence, sexual assault, and stalking. These acts will not be tolerated at Gould’s Academy as such acts are inappropriate and create an environment contrary to the goals and mission of Gould’s Academy.

Any such acts will be thoroughly investigated and will subject an individual to appropriate disciplinary sanctions and/or possible action by appropriate law enforcement agencies.

It is the responsibility of all persons within Gould’s Academy community to work to ensure an educational environment free from sex discrimination. Violations of this policy may be grounds for disciplinary action under Gould’s Academy’s policies and procedures [cross reference the procedures applicable to students and employees utilized by the School to investigate and discipline sexual discrimination (including sexual harassment and sexual violence) incidents].

All students and staff of Gould’s Academy are expected to report incidents of sexual discrimination (including sexual harassment or sexual violence) to the Title IX Coordinator.

 

Education Programs to Promote Awareness of Domestic Violence, Dating Violence, Sexual Assault, and Stalking:

Gould’s Academy educates the incoming and current student and employee community about sexual violence, violence prevention, and all relevant Gould’s Academy policies and procedures during all orientations held for new and current students at the onset of a class and at least annually.

In addition, Gould’s Academy conducts new and current employee training on these topics at least annually. The Title IX Coordinator is responsible for training all Gould’s Academy current students and employees about Gould’s Academy’s policies regarding sexual violence and for conducting the new student and employee training.

The new and current employee and student training sessions include:

  • A statement that Gould’s Academy prohibits crimes of dating violence, domestic violence, sexual assault, and stalking;
  • The definitions of those crimes under federal and state law;
  • The definition of consent, in reference to sexual activity, if available under state law;
  • A description of safe and positive options for bystander intervention;
  • Information on risk reduction;
  • Information contained in Gould’s Academy’s policies and procedures related to preventing, reporting, and responding to sexual offenses, including disciplinary procedures and victim rights; and
  • A description of Gould’s Academy’s ongoing prevention and awareness campaigns for students and employees.

Sanctions and Protective Measures:

Following a final determination of Gould’s Academy’s institutional disciplinary proceeding regarding domestic violence, dating violence, sexual assault, or stalking, Gould’s Academy may impose the following sanctions on the perpetrator and protective measures for the complainant:

  1. Sanctions

Sanction that may be imposed by Gould’s Academy include, but are not limited to:

  • Written warning;
  • Mandatory counseling;
  • Mandatory education and training;
  • No contact order;
  • Changes in academic, working, or living arrangements;
  • Revocation of certain campus privileges;
  • Suspension; or
  • Expulsion.

 Gould’s Academy has flexibility in the type and range of sanctions to impose on the perpetrator depending on the severity of the incident, but has a process in place to ensure that sanctions imposed are consistent with sanctions imposed in past incidents of similar conduct and are not imposed unequally based on gender or gender identity.

  1. Protective Measures

Protective measures that the school may utilize to protect the complainant include, but are not limited to:

  • An order of protection, a no contact order, restraining order or similar lawful order from the institution;
  • Changes to transportation, working, academic, and/or living situations;
  • Providing increased monitoring, supervision, or security at locations or activities where the misconduct occurred;
  • Providing an escort to ensure that the complainant can move safely between classes and activities;
  • Ensuring the complainant and perpetrator do not share classes or extracurricular activities;
  • Providing comprehensive, holistic victim services including medical, counseling, and academic support services, such as tutoring; or
  • Arranging for the complainant to have extra time to complete or re-take a class or withdraw from a class without an academic or financial penalty.

 When determining what protective measures to establish, Gould’s Academy will consider a number of factors including the specific needs and requests expressed by the complainant; the age of the students involved; the severity or pervasiveness of the conduct; any continuing effects on the complainant; whether the complainant and alleged perpetrator share the same residence hall, dining hall, class, transportation, or job location; and whether other judicial measures have been taken to protect the complainant (e.g., civil protection orders).

 Sexual Violence – Victim Procedures:

If you are victim of sexual violence, including sexual violence, dating violence, domestic violence, or stalking, your first priority should be to get to a place of safety. You should then obtain any necessary medical treatment. Information about the alleged offense should be provided to the Institute’s Title IX Coordinator as soon as possible. Time is a critical factor for evidence collection and preservation.

Gould’s Academy strongly advocates that a victim of sexual violence report the incident to police in a timely manner and, if requested to do so by the victim, Paul Gould/Garrett Gerlach will assist the victim in contacting the police. Filing a police report will not obligate the victim to prosecute, nor will it subject the victim to scrutiny or judgmental opinions from officers. The victim has the right at all times to decline to notify police of the incident.

Filing a police report will:

  • Ensure that a victim of sexual assault receives the necessary medical treatment and tests, at no expense to the victim;
  • Provide the opportunity for collection of evidence helpful in prosecution or establishing a no contact order, which cannot be obtained later (ideally a victim of sexual assault should not wash, douche, use the toilet, or change clothing prior to a medical/legal exam); and
  • Assure the victim has access to free confidential counseling from counselors specifically trained in the area of sexual assault crisis intervention. When a victim contacts the Police Department, the local Police Sex Crimes Unit will typically be notified as well. The victim may choose for the investigation to be pursued through the criminal justice system. The Title IX Coordinator will guide the victim through the available options and support the victim in his or her decision. Various counseling options are available through the Rape and Sexual Abuse Center and the Victim Intervention Program of the local Police Department. 

Procedures for Disciplinary Action in Cases of Sexual Violence:

Gould’s Academy Title IX Coordinator has primary responsibility for receiving, evaluating, and investigating allegations of sexual violence, including alleged domestic violence, dating violence, sexual assault, and stalking. The Title IX Coordinator is responsible for informing the School Director and the Campus Security Authority within 24 hours after receiving a sexual violence report, for purposes of maintaining accurate Clery Act crime statistics.

The Title IX Coordinator has primary responsibility for ensuring that any disciplinary proceeding involving an allegation of sexual violence is conducted promptly, fairly, and impartially and in accordance with these and other related institutional procedures.

Once the Title IX Coordinator receives a report of sexual violence, the following steps will be followed:

  1. The Title IX Coordinator will immediately assess whether the information in the report

warrants a timely warning and, if so, will contact the School Director immediately to execute that procedure in accordance with the institution’s timely warning procedures.  The Title IX Coordinator will immediately inform the victim of his/her right to “interim measures” during the pendency of an investigation of the alleged sexual violence, including obtaining an order of protection, a no contact order, restraining order or similar lawful order from the police or the institution. Gould’s Academy’s obligation is to protect the identity of the victim in any Clery Act report or in other publicly available recordkeeping. Gould’s Academy is also required to keep any interim measures provided to the victim confidential, to the extent that maintaining such confidentiality would not impair the ability of the institution to provide the accommodation or protective measure.

  1. The Title IX Coordinator will, within 24 hours of receipt of the report, provide to the individual making the report of an alleged sex offense:
  2. a) A copy of these procedures;
  3. b) Information on counseling, health, mental health, victim advocacy, legal assistance services, immigration assistance, student financial aid, and any other services available to the victim at Gould’s Academy or in the community;
  4. c) Information on the victim’s right to report the incident to local police and the fact that Gould’s Academy’s institutional investigation and disciplinary procedure and any criminal proceeding may occur simultaneously; and
  5. d) Options to facilitate changes to transportation, working, academic, and/or living situations, or additional protective measures, if requested, while the investigation is pending, even if the victim chooses not to report the crime to police.
  6. The Title IX Coordinator will investigate the incident by interviewing: the individual filing the report, the accused, Gould’s Academy employees, witnesses, and others as necessary to gather facts about the alleged incident. The Title IX Coordinator may be assisted by other employees after determining that such employees do not have a conflict of interest and have received training in Title IX and VAWA.
  7. The Title IX Coordinator will ensure that all individuals involved in the disciplinary procedure apply a “preponderance of the evidence” standard when evaluating sexual violence reports. Gould’s Academy does not provide for a formal hearing process but both parties may be assisted by a support person of choice, including an attorney.
  8. In all cases, the Title IX Coordinator will maintain regular communications with both the accuser and accused and provide both parties with equal opportunity to provide information, witness statements, evidence, and other information that may be necessary for Gould’s Academy to fully evaluate the alleged offense.
  9. The Title IX Coordinator will, barring extenuating circumstance, complete the investigation and make a determination regarding any necessary discipline of accused and remedies to accuser within 60 days of the date that the report is first received by the Title IX Coordinator.
  10. The Title IX Coordinator will inform both parties of its final determination. Gould’s Academy does not provide for an appeal of final determinations.
  11. The sanctions that may be imposed by Gould’s Academy following a determination that dating violence, domestic violence, sexual assault, or stalking occurred include, but are not limited to, counseling, education, changes in academic or living arrangements, no contact orders, suspension or expulsion of a student, or termination of employment.
  12. Both the accuser and accused shall be simultaneously informed in writing of:
  13. a) The outcome of any disciplinary proceeding that arises from an allegation of domestic violence, dating violence, sexual assault, or stalking;
  14. b) The institution’s procedures for the accused and victim to appeal the results of the institutional disciplinary proceeding (if any such appeal rights become available);
  15. c) Any change to the results that occurs prior to the time that such results become final; and
  16. d) When such results become final.
  17. The Title IX Coordinator will determine if the incident is indicative of a systemic issue and, if so, work with Gould’s Academy employees, including the Campus Security Authority and School Director, to recommend changes to Gould’s Academy policies, procedures, or training to prevent re-occurrence.  Gould’s Academy requires the Title IX Coordinator and all employees involved in the investigation and disciplinary process to receive training at least annually on issues related to dating violence, domestic violence, sexual assault, and stalking and on how to conduct an investigation and hearing process that protects the safety of victims and promotes accountability.

Protection of Confidentiality of Victim of Sexual Violence:

There are no pastoral or professional counselors on campus. Confidential crisis, mental health, and victim resource hotline numbers are posted on campus, should students need to contact these agencies. Victims of sexual violence reported to the Title IX Coordinator will be provided with information regarding local rape crisis centers and other counseling services.

Reports about sexual violence or other crimes may be provided informally and in confidence to Gould’s Academy’s Title IX Coordinator, who will make every attempt to maintain privacy of the information in accordance with your request and Family Educational Rights and Privacy Act of 1974 (FERPA) regulations unless Gould’s Academy is under an obligation to disclose your identity to protect the safety of others. You will be informed if Gould’s Academy cannot maintain the requested confidentiality of the information.

Gould’s Academy strongly encourages persons who are victims of sexual violence who do not want to report the incident to police or file a complaint using Gould’s Academy’s institutional procedures to report the incident to the Title IX Coordinator voluntarily and on a confidential basis solely to permit the inclusion of that information in Gould’s Academy’s annual crime statistics. With such information, Gould’s Academy can keep an accurate record of the number of similar incidents, determine where there is a pattern of crime with regard to a particular location, method, or assailant, and alert the campus community to potential danger. Gould’s Academy will make best efforts to maintain the privacy of that information and to comply with FERPA.

Gould’s Academy is required to, and will, keep the identity of victims of sexual violence private in any public report of Clery Act crimes. Reporting to the institution will also enable the victim to receive protective measures. At the victim’s request, Gould’s Academy will maintain as confidential any protective measures provided to the victim, to the extent that making such information confidential does not impair the ability of the institution to provide those protective measures. The victim will be informed by the institution if providing a protective measure may reveal the identity of the victim.

Gould’s Academy encourages reporting of sexual violence to the police. Filing a police report will:

  • Ensure that a victim of sexual assault receives the necessary medical treatment and tests, at no expense to the victim;
  • Provide the opportunity for collection of evidence helpful in prosecution, which cannot be obtained later (ideally a victim of sexual assault should not wash, douche, use the toilet, or change clothing prior to a medical/legal exam); and
  • Assure the victim has access to free confidential counseling from counselors specifically trained in the area of sexual assault crisis intervention. Police reports are public records under state law, and therefore Gould’s Academy cannot guarantee the absolute confidentiality of reports of crime obtained from police records but will make every effort to maintain the confidentiality of such information to the greatest extent permitted by law.

Victim Support Services:

Once the Title IX Coordinator receives a report of sexual violence, the Title IX Coordinator will provide the individual making the report with written information regarding existing counseling, health, mental health, victim advocacy, legal assistance, and other services available for victims, both on campus and in the community.

Interim Measures:

Within 24 hours of a Title IX Coordinator receiving a report of sexual violence, the Title IX Coordinator will provide written notification to the victim about options for, and available assistance in, changing academic, living, transportation, and working situations, if so requested by the victim and if such accommodations are reasonably available, regardless of whether the victim chooses to report the crime to campus police or local law enforcement.

Rights and Options of Victims of Sexual Violence:

Within 24 hours of a Title IX Coordinator receiving a report of dating violence, domestic violence, sexual assault, or stalking, whether the offense occurred on or off campus, the institution will provide the student or employee with a written explanation of the student’s or employee’s rights and options. That notice will contain the following information:

This document outlines your rights under Title IX. You may have additional rights under other federal and state laws. Title IX of the Education Amendments of 1972 prohibits sex discrimination—which includes sexual violence—in educational programs and activities. All public and private schools, school districts, colleges, and universities receiving federal funds must comply with Title IX. If you have experienced sexual violence, here are some things you should know about your Title IX rights:

  1. Your School Must Respond Promptly and Effectively to Sexual Violence:
  • You have the right to report the incident to your school, have your school investigate what happened, and have your complaint resolved promptly and equitably.
  • You have the right to choose to report an incident of sexual violence to campus or local law enforcement, but, a criminal investigation does not relieve your school of its duty under Title IX to respond promptly and effectively.
  • Your school must adopt and publish procedures for resolving complaints of sex discrimination, including sexual violence. Your school may use student disciplinary procedures, but any procedures for sexual violence complaints must afford you a prompt and equitable resolution.
  • Your school should ensure that you are aware of your Title IX rights and any available resources, such as victim advocacy, housing assistance, academic support, counseling, disability services, health and mental health services, and legal assistance.
  • Your school must designate a Title IX coordinator and make sure all students and employees know how to contact him or her. The Title IX coordinator should also be available to meet with you.
  • All students are protected by Title IX, regardless of whether they have a disability, are international or undocumented, and regardless of their sexual orientation and gender identity. 
Your School Must Provide Interim Measures as Necessary
  • Your school must protect you as necessary, even before it completes any investigation. Your school should start doing this promptly once the incident is reported.
  • Once you tell your school about an incident of sexual violence, you have the right to receive some immediate help, such as changing classes, dorms, or transportation. When taking these measures, your school should minimize the burden on you.
  • You have the right to report any retaliation by school employees, the alleged perpetrator, and other students, and your school should take strong responsive action if this occurs.
  1. Your School Should Make Known Where You Can Find Confidential Support Services:
  • Your school should clearly identify where you can go to talk to someone confidentially and who can provide services like advocacy, counseling, or academic support. Some people, such as counselors or victim advocates, can talk to you in confidence without triggering a school’s investigation. Because different employees have different reporting obligations when they find out about sexual violence involving students, your school should clearly explain the reporting obligations of all school employees.
  • Even if you do not specifically ask for confidentiality, your school should only disclose information to individuals who are responsible for handling the school’s response to sexual violence. Your school should consult with you about how to best protect your safety and privacy.
  1. Your School Must Conduct an Adequate, Reliable, and Impartial Investigation
  • You have the right to be notified of the time frames for all major stages of the investigation.
  • You have the right to present witnesses and evidence.
  • If the alleged perpetrator is allowed to have a lawyer, you have the right to have one too.
  • Your school must resolve your complaint based on what they think is more likely than not to have happened (this is called a preponderance-of-the-evidence standard of proof). Your school cannot use a higher standard of proof.
  • You have the right to be notified in writing of the outcome of your complaint and any appeal, including any sanctions that directly relate to you.
  • If your school provides for an appeal process, it must be equally available for both parties.
  • You have the right to have any proceedings documented, which may include written findings of fact, transcripts, or audio recordings.
  • You have the right not to “work it out” with the alleged perpetrator in mediation. Mediation is not appropriate in cases involving sexual violence. 
Your School Must Provide Remedies as Necessary
  • If an investigation reveals that sexual violence created a hostile environment, your school must take prompt and effective steps reasonably calculated to end the sexual violence, eliminate the hostile environment, prevent its recurrence, and, as appropriate, remedy its effects.
  • Appropriate remedies will generally include disciplinary action against the perpetrator, but may also include remedies to help you get your education back on track (like academic support, retaking a class without penalty, and counseling). These remedies are in addition to any interim measures you received.
  • Your school may also have to provide remedies for the broader student population (such as training) or change its services or policies to prevent such incidents from repeating.

If you want to learn more about your rights, or if you believe that your school is violating federal law, you may contact the U.S. Department of Education, Office for Civil Rights, at (800) 421-3481 or (800) 421-3481 or . If you wish to fill out a complaint form online, you may do so at:

http://www.ed.gov/ocr/complaintintro.html

Registered Sex Offenders:

In accordance with the federal Campus Sex Crimes Prevention Act (CSCPA) a notice must be given of registered sex offenders to institutions of higher education if the offender is employed, carries on a vacation, or is a student at the institution. This information is available upon request in the administrative office. A Registered Offender search may also be conducted at

http://www.communitynotification.com/cap_office_disclaimer.php?office=54438 For additional information on the Jacob Wetterling Crimes Against Children and Sexually Violent Offender Registration Act, visit http://ojp.gov/smart/legislation.htm.

Crime Statistics:

In compliance with the Campus Security Act, we are sharing the following crime-related statistics.

The figures include reports of crimes occurring on campus, non-campus buildings or properties, and public property. These geographic areas are defined as follows:

Offense on Campus: 2018/2019/2020

Murder/Non Negligent Manslaughter: 0/0/0

Rape (Includes sodomy and sexual assault with an object: 0/0/0

Fondling: 0/0/0

Incest: 0/0/0

Statutory Rape: 0/0/0

Robbery: 0/0/0

Aggravated Assault: 0/0/0

Burglary: 0/0/0

Motor Vehicle Theft: 0/0/0

Arson: 0/0/0

Simple Assault: 0/0/0

Larceny Theft: 0/0/0

Intimidation: 0/0/0

Destruction/damage/vandalism of property: 0/0/0

Domestic Violence: 0/0/0

Dating Violence: 0/0/0

Stalking: 0/0/0

Liquor Law Arrests: 0/0/0

Drug Law Arrests: 0/0/0

Weapon Law Arrests: 0/0/0

Liquor Law Violations Referred for Disciplinary Action: 0/0/0

Drug Law Violations Referred for Disciplinary Action: 0/0/0

Weapons Law Violations Referred for Disciplinary Action: 0/0/0

Reported Hate Crimes Arrests and Disciplinary Action Referrals:

The following information pertains to the number of each type of primary crime (above) that was determined to be a hate crime, as well as larceny-theft, simple assault, intimidation, and destruction/damage/vandalism of property that were determined to be hate crimes

In 2018, 2019 & 2020 there were no hate crimes reported.

 Unfounded Crimes:

In 2018, 2019 & 2020 there were no unfounded crimes reported. 

Offense Non- Campus: 2018/2019/2020

Murder/Non Negligent Manslaughter: 0/0/0

Rape (Includes sodomy and sexual assault with an object: 0/0/0

Fondling: 0/0/0

Incest: 0/0/0

Statutory Rape: 0/0/0

Robbery: 0/0/0

Aggravated Assault: 0/0/0

Burglary: 0/0/0

Motor Vehicle Theft: 0/0/0

Arson: 0/0/0

Simple Assault: 0/0/0

Larceny Theft: 0/0/0

Intimidation: 0/0/0

Destruction/damage/vandalism of property: 0/0/0

Domestic Violence: 0/0/0

Dating Violence: 0/0/0

Stalking: 0/0/0

Liquor Law Arrests: 0/0/0

Drug Law Arrests: 0/0/0

Weapon Law Arrests: 0/0/0

Liquor Law Violations Referred for Disciplinary Action: 0/0/0

Drug Law Violations Referred for Disciplinary Action: 0/0/0

Weapons Law Violations Referred for Disciplinary Action: 0/0/0

Reported Hate Crimes Arrests and Disciplinary Action Referrals:

 The following information pertains to the number of each type of primary crime (above) that

was determined to be a hate crime, as well as larceny-theft, simple assault, intimidation, and destruction/damage/vandalism of property that were determined to be hate crimes.

In 2018, 2019 & 2020 there were no hate crimes reported.

Unfounded Crimes:

In 2018, 2019 & 2020 there were no unfounded crimes reported.

Offense Public Property: 2018/2019/ 2020

Murder/Non Negligent Manslaughter: 0/0/0

Rape (Includes sodomy and sexual assault with an object]: 0/0/0

Fondling: 0/0/0

Incest: 0/0/0

Statutory Rape: 0/0/0

Robbery: 0/0/0

Aggravated Assault: 0/0/0

Burglary: 0/0/0

Motor Vehicle Theft: 0/0/0

Arson: 0/0/0

Simple Assault: 0/0/0

Larceny Theft: 0/0/0

Intimidation: 0/0/0

Destruction/damage/vandalism of property: 0/0/0

Domestic Violence: 0/0/0

Dating Violence: 0/0/0

Stalking: 0/0/0

Liquor Law Arrests: 0/0/0

Drug Law Arrests: 0/0/0

Weapon Law Arrests: 0/0/0

Liquor Law Violations Referred for Disciplinary Action: 0/0/0

Drug Law Violations Referred for Disciplinary Action: 0/0/0

Weapons Law Violations Referred for Disciplinary Action: 0/0/0

Reported Hate Crimes Arrests and Disciplinary Action Referrals:

The following information pertains to the number of each type of primary crime (above) that

was determined to be a hate crime, as well as larceny-theft, simple assault, intimidation, and destruction/damage/vandalism of property that were determined to be hate crimes.

In 2018, 2019 & 2020 there were no hate crimes reported.

 Unfounded Crimes:

In 2018, 2019 & 2020 there were no unfounded crimes reported.

The school encourages all students and employees to be responsible for their own security and the security of others. The school does not employ campus security officials. Therefore, the security of the campus is the direct responsibility of each employee and administrator. No such individuals have the authority to make arrests. All individuals are requested to report immediately any known criminal offense or other emergency occurring on campus to the school administration at the administration office. All individuals are encouraged to promptly report all crimes to appropriate police agencies. The campus administration will report all known criminal offenses to the local law enforcement authorities. The school has no policy or procedure regarding confidential crime reporting in relation to crime statistics reporting. Any off campus events are supervised by campus employees. Therefore, the school will monitor and report criminal activity at such events to local law enforcement authorities. No student will have access to the campus facility, other than the parking area, at any time unless supervised by a staff member.