USC sent a schoolwide email Friday addressing the investigation results released by the Department of Education’s Office for Civil Rights about the university’s handle of sexual harassment claims.
USC has reached a Resolution Agreement with the OCR in February. The investigation, which began in May 2018, examined the conduct of George Tyndall, who was a gynecologist at USC for 27 years before being accused by hundreds of women of sexual abuse and discrimination.
The investigation uncovered that USC did not comply with Title IX, a federal civil rights law that prohibits discrimination on the basis of sex in educational institutions that receive federal funding, the school said.
OCR found that “the University failed to promptly and effectively respond to notice of potential sexual harassment by [Dr. Tyndall] and this failure may have allowed female students to be subjected to continuing sex discrimination,” according to the school. Systematic flaws, such as deficiencies in data and record-keeping, also inhibited the University’s response to sexual harassment claims.
USC is committed to improving its policies for preventing and responding to sexual harassment claims, according to a letter from USC’s Senior Vice President of Human Resources Felicia Washington Friday.
The university has agreed to reinforce the authority of the newly created Office of Equity, Equal Opportunity and Title IX to ensure it functions effectively, Washington states.
“The Deputy Title IX Coordinator is a new position that will serve as a bridge between the university’s Title IX programs and the university’s health care systems,” a university statement reads.
USC is also in the process of appointing a Deputy Title IX Coordinator and designating Health Care Title IX Investigators to make USC’s Title IX support systems as transparent as possible.
USC has begun to improve its data recordkeeping to address sexual and gender-based harassment in a faster manner, Washington urges in the letter.
“Similarly, since this investigation was opened in May 2018, the university has already taken steps to maintain complete and accurate data recordkeeping and management,” according to a university statement.
The university will conduct a self-assessment of the actions of current and former supervisors over Dr. Tyndall and other supervisors who were reportedly notified of complaints related to him, the letter says.
USC will also conduct a self-audit of all reported cases of sexual harassment or violence at the end of each semester, according to the summary of resolution for the direct investigation.
“In regard to the self-audit, the university is working with professional experts who have been approved by OCR to do this work at other institutions,” according to a university statement. “This requirement is a standard part of Resolution Agreements for colleges and universities across the country.”
The university will also “expand and enhance mandatory training for all students, faculty, staff and trustees on sexual harassment and sexual violence,” the summary of resolution states.
Here is the university’s full statement:
OCR identified deficiencies in policies and procedures that were in place in 2013 and 2016. The required actions outlined in Section V of the Resolution Agreement are part of current Title IX policies or practices. For example, current Title IX policies and internal protocols distinguish whether an individual is a reporting party or a witness, require specific notices and various points in the process and evaluate whether witnesses may have been subject to harassment as a third party.
Similarly, since this investigation was opened in May 2018, the university has already taken steps to improve the completeness and accuracy of data recordkeeping and management. The processes in place in 2013 have been updated, as have electronic personnel records management processes. OED and Title IX currently utilize a centralized case management system.
In addition to these changes, the Office of Equity, Equal Opportunity and Title IX will centralize all reporting and investigative processes for all forms of protected class discrimination and harassment, including sexual and gender-based harassment and violence for students, faculty and staff. Currently the university has two offices for responding to reports of sexual gender-based harassment and violence. The Office of Equity and Diversity which responds to reports against faculty and staff and the Title IX office which responds only to reports against students. In addition, the new Office of Equity, Equal Opportunity and the Title IX will also oversee equal opportunity functions, prevention and education, and university-wide training.
The Deputy Title IX Coordinator is a new position that will serve as a bridge between the university’s Title IX programs and the university’s health care systems. We are in the process of creating the job description, which will be posted later this semester, to ensure that we seek the most qualified candidates. The Health Care Title IX Investigators will primarily be external professionals and we will be seeking qualified individuals to be part of the resources available to the Office of Equity, Equal Opportunity and Title IX.
Finally, in regard to the self-audit, the university is working with professional experts who have been approved by OCR to do this work at other institutions. This requirement is a standard part of Resolution Agreements for colleges and universities across the country.