The Gwinnett County Board of Education (“Board”) is committed to providing a school environment free of any form of sex discrimination and sexual harassment. The Board recognizes that it is important to provide our students an educational environment and our employees a work environment that is safe and secure. Gwinnett County Public Schools (“GCPS”) will respond promptly, and in a manner that is not deliberately indifferent, when it has been provided actual knowledge of any act that is prohibited by Title IX of the Education Amendments of 1972 (“Title IX”) and this Policy by a person within the United States, who is a student, employee, or third party. GCPS will diligently investigate formal complaints covered under sex discrimination and sexual harassment. As academic success is maximized while studying in an environment that is conducive to the learning process, sex discrimination and sexual harassment will not be tolerated.

Also, this Title IX Sex Discrimination/Sexual Harassment (Students and Employees) Policy (“Policy”) prohibits retaliation against any individual who, in good faith, submits a complaint under this Policy (including individuals who are third-party reporters), participates in an investigation as a complainant, respondent, reporter, witness, investigator, decision-maker (including appeal decision-maker), advocates for rights protected by Title IX and discrimination in employment based on sex, or protests alleged conduct that is prohibited by this Policy.
Complaints and/or reports of misconduct that fall outside the scope of this Policy, including discrimination or harassment that does not meet the definitions of sex discrimination and sexual harassment prohibited by Title IX and this Policy, should be addressed under other applicable Board policies, student conduct policies, personnel policies, or laws.

Gwinnett County Public Schools is required to comply with Title IX of the Education Amendments of 1972, which protects both students and employees from discrimination based on sex. Specifically, Title IX establishes that “no person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.” Title IX of the Education Amendments of 1972.

This Policy applies to all members of the Gwinnett County Public Schools District to include students, teachers, school administrators, staff, district leaders, school resource officers, counselors, the Board, and members of the community who have any affiliation with GCPS.

Gwinnett County Public Schools Title IX Sex Discrimination/Sexual Harassment (Students and Employees) Policy and Procedures applies to all reports and formal complaints of alleged misconduct that is submitted to the Title IX Coordinator, Assistant Title IX Coordinator, and/or an Employee Relations Director on or after May 16, 2024. Submitted complaints, prior to May 16, 2024, that have not been resolved will be investigated and adjudicated under the Board’s previous policy.

This Policy’s requirements and protections apply equally to every student/employee regardless of their race, age, ethnicity, religion, national origin, sex, disability status, veteran status, or any other protected class covered by federal and state laws. All requirements and protections are also provided equitably to individuals regardless of their status as a complainant, respondent, witness, or advisor, or support person. Any individual who wishes to file a complaint under this Policy, may do so by contacting the Division of Human Resources, Office of Employee Relations/Title IX, the local school Assistant Title IX Coordinator, or the District Title IX Compliance Office.

I. Introduction

Pursuant to Title IX of the Education Amendments of 1972, Gwinnett County Public Schools will ensure that it responds promptly, and in a manner that is not deliberately indifferent, when GCPS has been given actual knowledge of prohibited conduct that falls under the scope of this Policy, including sexual harassment, sexual assault, dating violence, domestic violence, and stalking that occurs in a GCPS education program or activity against a person within the United States, and the conduct is committed by a current student, employee, or third-party.

In addition, retaliation in any form is strictly prohibited by this Policy. The Policy protects against retaliation towards any individual, who in good faith:

·       submits a complaint under this Policy (including individuals who are third-party reporters);

·       participates in an investigation as a complainant, respondent, reporter, witness, investigator, decision-maker (including appeal decision-maker); or

·       advocates for rights protected by Title IX, against discrimination in employment based on sex, or protests alleged conduct that is prohibited by this Policy.

                        A. Definitions

1.    Sexual Harassment - means conduct on the basis of sex that satisfies one or more of the following:

(a)      An employee of the recipient conditioning the provision of an aid, benefit, or service of the recipient on an individual's participation in unwelcome sexual conduct;

(b)      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

(c)      Other conduct, specifically:

·       Sexual assault 20 U.S.C. 1092(f)(6)(A)(v) and the Uniform Crime Reporting System of the Federal Bureau of Investigation (FBI). - defined as “any sexual act including rape, sodomy, sexual assault with an object, or fondling directed against another person, without the consent of the victim, including instances where the victim is incapable of giving consent; also unlawful sexual intercourse, which includes statutory rape and incest”; or

·       Dating violence 34 U.S.C. 12291(a)(11) - defined as “violence committed by a person - (A) who is or has been in a social relationship of a romantic or intimate nature with the victim; and (B) where the existence of such a relationship shall be determined based on a consideration of the following factors: (i) The length of the relationship. (ii) The type of relationship. (iii) The frequency of interaction between the persons involved in the relationship”; or

·       Domestic violence 34 U.S.C. 12291(a)(12) - defined as when violence occurs “by a person who- (A) is a current or former spouse or intimate partner of the victim, or person similarly situated to a spouse of the victim; (B) is cohabitating, or has cohabitated, with the victim as a spouse or intimate partner; (C) shares a child in common with the victim; or (D) commits acts against a youth or adult victim who is protected from those acts under the family or domestic violence laws of the jurisdiction” ; or

·       Stalking 34 U.S.C. 12291(a)(36) - defined as “engaging in a course of conduct directed at a specific person that would cause a reasonable person to- (A) fear for his or her safety or the safety of others; or (B) suffer substantial emotional distress.”

2.       Education program or activity – includes all locations and events for students, conduct within the workplace or in the performance of an employee’s duties, or circumstances to which GCPS exerts substantial control over the accused/respondent and:

                                        ·       any facility, property, or building owned, leased, or controlled by GCPS; or

                                        ·        any off-site areas, conferences, field trips where GCPS has substantial control; or

·       any activity that occurs on computer or telephone, digital platforms, internet networks, and computer software/hardware that is operated or owned by GCPS or that GCPS has substantial control.

3.       Consent – must be clear communication and mutual agreement to engage in the conduct to which the participants are involved.

·       Consent cannot be gained by the use of force, coercion, duress, manipulation, threats of violence, or intimidating behavior.

·       An incapacitated person is unable to give consent. A person is considered incapacitated it he/she is asleep, unconscious, have consumed alcohol/drugs, or has a physical or mental impairment. Incapacitation may result from sleep, unconsciousness, influence of drugs or alcohol, or a physical or mental impairment. This list is not exhaustive. When determining incapacitation, one must consider the person's ability to understand the circumstances surrounding them, the ability to make informed and rational judgments, or the ability to consent or not consent to the act.

4.       Actual Knowledge – when notice of sexual harassment, including allegations of sexual harassment, has been given to any GCPS employee, Assistant Title IX Coordinator, Title IX Coordinator, Director of District Title IX Compliance, or Employee Relations Director. Actual knowledge includes reports of sexual harassment from a victim or third-party. GCPS will not be deemed to have actual knowledge of allegations based on the respondent’s knowledge, even where the respondent is an employee.

5.       Assistant Title IX Coordinator – local school assistant principal who serves in the capacity as a coordinator of the Title IX process within the local school.

6.       Formal Complaint – a signed written statement from the victim that is received by hard copy or by electronic format that outlines conduct that is allegedly prohibited by this Policy. The district’s Title IX Coordinator may also bring forth a formal complaint, without the consent of the victim, if in the best interest of GCPS to do so.

7.       Complainant – an individual alleged to be the victim of sex discrimination and/or sexual harassment.

8.       Respondent - an individual who has been reported of engaging in conduct that would violate this Policy.

9.       Reporter – an individual who is not the victim and makes the report of sexual harassment based on what they observed or heard. A victim is not required to make the report of allegations of sexual harassment for Gwinnett County Public Schools to act under Title IX or this Policy.

10.   Inculpatory Evidence – information/evidence that tends to prove an allegation.

11.   Exculpatory Evidence - information/evidence that tends to disprove an allegation.

12.   Responsible Employee – includes GCPS teachers, administrators, supervisors, district leaders, school resource officers, counselors, and all other staff who must report any sex discrimination or sexual harassment complaints they receive or have knowledge of (whether direct or indirect) that is prohibited under Title IX and this Policy.

                        B. Role of District Title IX Coordinator and Director of District Title IX Compliance

Gwinnett County Public Schools has a coordinator who serves as the District Title IX Coordinator and ensures the administration of this Policy is conducted in a neutral and equitable manner for all students and employees. In addition, every elementary, middle, and high school has an appointed local Assistant Title IX Coordinator within the school building.

The Director of District Title IX Compliance is responsible for developing, implementing, coordinating, and conducting educational programs and initiatives designed to educate and support stakeholders regarding their rights and, where applicable, obligations under Title IX, including reporting options/responsibilities, support services, district policy and applicable disciplinary code, grievance procedures, confidential resources, etc.

C. Training

The Director of District Title IX Compliance is responsible for taking steps reasonably calculated to ensure all investigators, coordinators, decision makers, and those involved with processing Title IX complaints are adequately trained in compliance with Title IX guidance.

D. Role of a Responsible Employee

All Gwinnett County Public School employees are considered “responsible employees.” Responsible employees are those employees who have authorization to address and remedy sex discrimination and sexual harassment and/or have a responsibility to report sex discrimination and sexual harassment to their supervisor, principal, local Assistant Title IX Coordinator, Employee Relations, Title IX Compliance Office, or other designated officials.

Title IX requires responsible employees to provide all information regarding the sex discrimination and sexual harassment when reporting allegations, to include the identity of the involved individuals (victim and accused if known) and the date, time, and location of the alleged misconduct. A responsible employee must not promise that they will keep Title IX allegations confidential. Responsible employees have an immediate duty to report such allegations.

                        E. Rights of the Parties

Gwinnett County Public Schools is committed to ensuring school and work environments that provide fair, prompt, and thorough investigations when formal complaints have been filed under this Policy. Additionally, GCPS will ensure that both Complainant and Respondent will be provided the following rights:

1.       Reasonable accommodations when a student or employee asks for an accommodation under the Americans with Disabilities Act.

2.       Thorough and prompt investigation of allegations/reports sex discrimination and sexual harassment under Title IX.

3.       Access to evidence, to include texts, emails, pictures, written documents, and other information used during the investigation that is directly related to the allegations raised in the formal complaint.

4.       Responsive action should an individual raise an allegation of Freedom from bullying, harassment, intimidation, or any type of retaliation during or after the resolution of the process.

                        F. Conflicts of Interest or Bias

Anyone participating as an Assistant Title IX Coordinator, Investigator, Initial

Decision-maker, and Appeals Decision-maker in a formal process or anyone serving as a

Facilitator in an informal process, must disclose all potential or actual conflicts of interests or biases towards any participating party. If anyone believes that someone participating in the process has a conflict or bias, they should notify the District Title IX Coordinator within two five (2 5) school days for students and two five (2 5) working days for employees in writing and request the individual be removed from participating in the process. Included in the request, there must be an outline of what the issue is and why a conflict or bias exists. If the District Title IX Coordinator makes a determination that in fact, a conflict or bias exists, the individual will be removed from participation in the process. If a request for removal of the District Title IX Coordinator is made due to bias or conflict, it should be made within two five (2 5) school days for students and two five (2 5) working days for employees to the Director of District Title IX Compliance.

G. Receipt of Information

Upon receipt of a report of sexual harassment, if the victim was a child at the time of the alleged sexual harassment at the outset of the report, immediately and in no case more than 24 hours, the local Assistant Title IX Coordinator, administrator, or Employee

Relations Director must notify the Georgia Division of Family & Children Services (“DFCS”). The receiver of the report should not wait or delay the report to DFCS until an investigation is completed. If information on abuse arises during an investigation, the investigator or administrator involved must notify DFCS immediately and within 24 hours.

DFCS should be notified of all incidents in which there is reasonable cause to believe that child abuse had occurred, including, but not limited to the following instances:

1.       Intentional contact with another person’s private area;

2.       Intentional nudity/exposure of private area(s) to another person(s); or

3.       Alleged misconduct is unique to the student’s age and suggests abuse.

In addition, the School Resource Officer (“SRO”) must be notified when the allegation involves any type of child abuse, sexual assault, dating violence, or stalking.

H. Reporting to the Office of Employee Relations /Title IX

All local Assistant Title IX Coordinators must notify the Division of Human Resources, Office of Employee Relations/Title IX of any report or allegation of sexual harassment. Each cluster has an assigned Employee Relations Director to whom the notification must be made within 24 hours. In addition, the local Assistant Title IX Coordinator must open a case file within the Title IX Case Management System (“CMS”) within 48 hours of receiving a report or allegation of sexual harassment. The local Assistant Title IX Coordinator must not wait until the investigation or case is completed to enter the initial report/case into the CMS. This will allow the District Title IX Coordinator, Employee Relations Director, and Director of District Title IX Compliance to monitor cases and ensure the process moves forward appropriately.

                        I. Title IX Applicability

Following a report or allegation of sexual harassment, the local Assistant Title IX

Coordinator and/or Employee Relations Director must first make a determination if Title IX is applicable. The report or allegation falls under Title IX, if the conduct described would be a Title IX violation if the facts of the case were considered true. A non-Title IX case does not absolve an administrator, local Assistant Title IX Coordinator, or Employee Relations Director from reporting alleged child abuse to the Georgia Division of Family &

Children Services within 24 hours. If the alleged conduct is also in violation of the Georgia Code of Ethics for Educators, a report of the breach of one or more of the Standards within the Code of Ethics must be reported to the Georgia Professional Standards Commission.

Discussions or impositions of discipline must not occur prior to the completion of the Title IX process until a determination of responsibility has been made. Also, informal resolution discussions must not occur prior to the filing of a formal Title IX complaint.

If a determination is made that a report or allegation does not fall under Title IX, the case may be reviewed and processed under other applicable Board, personnel, or student policies, federal and/or state laws, or professional ethic standards.

 

                        J. Case Processing

Based on the whether the victim and accused is a student, employee, or third-party, the Title IX case will be processed in the following manner:

1.       Student against Student – For cases where the victim and accused are both students, the local Assistant Title IX Coordinator and Title IX Investigator will administer the Title IX Grievance Procedure/Process.

2.       Student against Employee/Third-Party – For cases where the victim is a student and the accused is an employee or third-party, the Employee Relations Director will administer the Title IX Grievance Procedure/Process. The Employee Relations Director may receive assistance from the local Title IX Coordinator and Title IX Investigator as needed.

3.       Employee against Employee/Third-Party - For cases where the victim and accused

are both employees or the accused is a third-party, the Employee Relations Director will administer the Title IX Grievance Procedure/Process.

In some instances, the Division of Human Resources, Office of Employee Relations/Title

IX, the District Title IX Coordinator, the Director of District Title IX Compliance, or the Chief Human Resources Officer (“CHRO”) may make a determination that a case may need to be processed in a different manner or by an outside vendor.

        II. Sexual Harassment Grievance Process

                        A. Initial Intake Meeting

After a determination of Title IX applicability, the local Assistant Title IX Coordinator or Employee Relations Director should send a Notice of Intake Meeting to the alleged victim. If the victim is a student, notice must also be sent to the student’s parents, even if the victim is a student who is eighteen (18) years or older. In addition, all notices must continue to be sent to the parents of student victims and accused individuals throughout the Title IX Grievance Process. This should occur, even if the student is eighteen (18) years or older.

During the Intake Meeting, the local Assistant Title IX Coordinator or Employee Relations Director must do the following:

1.       Explain to the victim his/her rights under Title IX.

2.       Explain to the victim the different options available such as how to file a formal complaint under Title IX or in the case of an employee, the right to file a formal complaint under Title VII instead.

3.2 Explain the full Title IX process to the victim.

4.3.Assess and address any immediate safety concerns the victim may have.

5.4.Discuss and offer supportive measures to the victim.

In addition, the local Assistant Title IX Coordinator or Employee Relations Director must provide the victim a hard copy of Gwinnett County Public Schools Title IX Sex Discrimination/Sexual Harassment (Students and Employees) Policy and Procedures.

                        B. Non-Investigation Matters

Before the filing of a formal complaint, the Assistant Title IX Coordinator and/or Employee Relations Director may need to provide the victim and the accused with supportive measures or process an emergency removal or administrative leave.

1.       Supportive measures are non-disciplinary and non-punitive services that are made on an individual basis and offered to the parties. These measures are created to preserve and/or restore equal access to education activities and/or programs, deter sexual harassment, and protect the safety of the parties, while not being unreasonably burdensome to the other party. These measures must be reasonably available and at no charge/cost/fee to either party. GCPS will maintain confidentiality as it relates to the supportive measures provided but may need to engage certain people for implementation. It is the responsibility of the Assistant Title IX Coordinator and/or Employee Relations Director to ensure supportive measures are appropriately implemented.

Supportive measures may include, but are not limited to the following:

(a)    Counseling

(b)    Extension of deadlines

(c)    Modification of work or class schedules

(d)    Schedule changes

(e)    Increased security or monitoring of parts of the school or work environment

(f)      Mutual restrictions on contact between the parties (such as a “no-contact order”)

(g)    Leaves of absence

2.       Change of school or administrative leave may be implemented by Gwinnett County Public Schools. Students (either the victim or accused or both) may be placed in a different educational setting as deemed appropriate based on the facts of the case. The educational setting may not modify or change any rights a student may have under IDEA, Section 504, or ADA. However, there is nothing that precludes GCPS from placing an employee respondent on administrative leave during the Title IX Grievance Process, as long as it is in accordance with applicable laws, Board policies, and all other practices.

C. Formal Resolution by Filing a Formal Complaint

In order to initiate the Title IX Grievance Process, a victim must submit a formal complaint in writing with their signature. Once a formal complaint is filed, the victim will be referred to as the “Complainant” and the accused referred to as the “Respondent.” The identity of the parties involved will remain confidential and only revealed to those who need to know to conduct their duties or carry out their responsibilities and/or to comply with any applicable policy or law. Parties’ identities may be shared with investigators, coordinators, GCPS executive administrators, witnesses, and those who may need to be involved to implement, sanctions, disciplinary actions, or supportive measures.

If a victim does not wish to file a formal complaint, the District Title IX Coordinator will make a determination if a formal complaint should be initiated by the Office of Employee Relations/Title IX. Factors to consider are:

-          Whether there is independent evidence of the allegations other than the testimony of the victim.

-          Whether the nature of the allegations rise to the level that the district should act on the allegations based on the risk to the school community.

-          Whether there have been similar or other complaints involving the same accused/respondent.

Should the District Title IX Coordinator choose to file a formal complaint, the victim will be notified. However, the victim cannot be compelled to participate in the process as a witness but will still receive all procedural notices throughout the Title IX Grievance Process.

If allegations involve multiple complainants and respondents and the conduct rises out of the same facts or circumstances, GCPS may choose to consolidate the complaints and investigations.

D. Notice of Allegations

Once a formal complaint has been filed, the Assistant Title IX Coordinator and/or Employee Relations Director must provide the Respondent with a Notice of Allegations. Notice should occur within five (5) school days for students and five (5) working days for employees after receipt of a formal complaint. If there are extenuating circumstances, notice should be given as soon as possible.

All parties, including the parents of students involved with the matter, will be contacted by the email given to the Assistant Title IX Coordinator and/or Employee Relations Director. It will be the responsibility of each party to regularly check and respond to notices sent.

Once the Notice of Allegations has been sent, Respondent will be given adequate time to review the notice and provide a response back before any initial interviews take place.

After reviewing the formal complaint and sending the Notice of Allegations, the Assistant Title IX Coordinator and/or Employee Relations Director will make a determination whether all or part of the formal complaint must or should be dismissed based on the initial information submitted. If a determination is made to dismiss a part or all of the formal complaint, the Assistant Title IX Coordinator and/or Employee Relations Director will send all parties a Notice of Dismissal.

                                1.    Notice of Allegations

The Notice of Allegations will include the following information:

·       A copy of the GCPS Title IX Sex Discrimination/Sexual Harassment Policy and Procedures.

·       The allegations that fall under sexual harassment to include sufficient information to allow the Assistant Title IX Coordinator and/or Employee Relations Director and Complainant and Respondent to prepare for the initial interviews. The allegations must include the names of the parties involved (including Complainant’s name), the conduct that allegedly falls under sexual harassment, and the date, time, and location of where the conduct occurred.

·       A statement that Respondent is presumed “not responsible” for the alleged conduct and no determinations will be made prior to the Decision-maker’s determination as to “responsible” or “not responsible” at the end of the Title IX Grievance Process.

·       A statement that Complainant and Respondent may have a support person of their choice present throughout the Title IX Grievance Process.

·       A statement that Complainant and Respondent may choose an advisor to assist them through the Title IX Grievance Process, and that the advisor may be an attorney, but is not required to be an attorney.

·       A statement, informing the Complainant and Respondent, that they have a right to discuss the allegations under investigation with others, gather and present evidence, and inspect and review all evidence gathered as part of the investigation that is directly related to the allegations raised in the formal complaint, including evidence that proves or disproves the allegations.

·       A statement that Gwinnett County Public Schools strictly prohibits anyone knowingly and intentionally making a false report, stating false information, or providing altered/fake/false information during the Title IX Grievance Process.

                                        ·       A list of possible student code or employee policy/ethical violations.

                                2.    Updated Notices

During an investigation, additional allegations may arise that were not included in the initial Notice of Allegations. If this occurs, Assistant Title IX Coordinator or Employee Relations Director will update the Notice of Allegations to include the new allegations and send out to all parties. Adequate time will be given for the parties to review the new allegations and Respondent to prepare a response before interviews resume.

                        E. Jurisdiction

Gwinnett County Public Schools has established jurisdiction over a Title IX matter when:

1.       The alleged conduct occurred within the United States;

2.       The alleged conduct occurred during a GCPS activity or program within the educational or employment scope; and

3.       The alleged conduct would fall under sexual harassment as outlined under GCPS Policy.

                        F. Formal Complaint Dismissals

If the Assistant Title IX Coordinator or Employee Relations Director makes a decision that a formal complaint should be dismissed, Assistant Title IX Coordinator or Employee Relations Director will expeditiously send a written Notice of Dismissal to all parties via their previously specified email address. The Notice of Dismissal must state the reason for the dismissal and provide parties with information on the process to appeal the dismissal.

1.       Mandatory dismissal – A formal complaint must be dismissed if the one or more elements are not met under the Jurisdiction section (Section II(E)).

2.       Discretionary dismissal – A formal complaint may be dismissed if:

(a)    Complainant notifies the Assistant Title IX Coordinator or Employee Relations Director, in writing, they wish to withdraw their formal complaint;

(b)    Respondent is no longer enrolled or employed by GCPS; or

(c)    Circumstances arise that prevent GCPS from being able to gather sufficient evidence to make a determination on the formal complaint or the allegations within the formal complaint.

3.       Appeal of Dismissals - Either party may appeal a mandatory or discretionary dismissal or a partial dismissal of allegations. Once a Notice of Dismissal has been sent, either party may file a written appeal within five (5) school days for students and five (5) working days for employees to an Appeals Officer within the Office of District Title IX Compliance, Human Resources or to a designee. The Appeals Officer would not have served as the role of Assistant Title IX Coordinator, Employee Relations Director, Title IX Investigator, or Title IX Initial Decision- maker in the same matter. The Appeals Officer must not have a bias or a conflict of interest in order to serve over the appeal.

An appeal of a dismissal may only be initiated if:

(a)    The party filing the appeal shows that the Assistant Title IX Coordinator or Employee Relations Director, who issued the Notice of Dismissal, has exhibited some type of bias or that a conflict of interest exists; or

(b)    The party filing the appeal shows the formal complaint does not fall under the scope of GCPS’s policy.

The Title IX Appeal Officer will issue a decision within five (5) school days for students and five (5) working days for employees. The decision will be issued to all parties. Should there be a finding that there was a conflict or bias, a new Assistant Title IX Coordinator or Employee Relations Director will be assigned to handle the case and review the formal complaint.

If there is a determination by the Title IX Appeal Officer that the formal complaint does fall under the scope of GCPS’s policy, the investigation will proceed forward.

4.       Investigation Under Other Policies

If a case is dismissed under Title IX or a victim chooses not to move forward with a formal complaint, GCPS has the right to review the allegations and determine if other GCPS and/or state policies were violated and act accordingly.

G. Advisors and Support People

Gwinnett County Public Schools does allow for parties to have an advisor or support person to be with the participating party during the Title IX Grievance Process. However, advisors and support people are not permitted to speak on behalf of the student, employee, or any party during the process.

1.       Advisors

The parties may select anyone to be an advisor to assist them, with the exception of current employees of GCPS. The advisor can be an attorney, though it is not required. An advisor is allowed to attend initial interviews, investigatory interviews, and meetings with their respective party. However, the advisor is not permitted to speak for the party, unless circumstances under the ADA or due to a language barrier necessitates such. Prior authorization from the Assistant Title IX Coordinator or Employee Relations Director will be required.

2.       Support People

In addition to an advisor, a party may choose to have a person who provides support during the process and may attend all initial interviews, investigatory interviews, and meetings. This person can also be the party ’s advisor. However, the support person cannot speak on behalf of the party, unless circumstances under the ADA or due to a language barrier necessitates such. Prior authorization from the Assistant Title IX Coordinator or Employee Relations Director will be required.

3.       2.Advisors’ and Support People ’s Availability

GCPS will make reasonable efforts to schedule interviews and meetings at a time an advisor or support person is able to attend. GCPS has an obligation to promptly investigate and adjudicate Title IX allegations in a timely manner; therefore, GCPS will not grant delays solely due to an advisor’s or support person ’s conflicting schedule. The Assistant Title IX Coordinator or Employee Relations Director will have latitude in determining what is considered “reasonable” under this Policy. However, no interview or meeting will be delayed past five (5) school days for students and five (5) working days for employees, unless there are extenuating circumstances.