Annual Security Report and Annual Fire Safety Report (Clery Act)

Bryn Mawr College 2021 Annual Security Report and Annual Fire Safety Report

October 2021

Table of Contents






Message From the Director

This report is prepared in compliance with the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, as amended by the Violence Against Women Reauthorization Act of 2013. The statistics are maintained and compiled by the Campus Safety Department.

These laws require all institutions of higher education within the Commonwealth to provide students and employees with information pertaining to, but not limited, to crime statistics, security measures, fire statistics, fire safety measures, policies relating to missing persons, and penalties for drug use, on an annual basis. These acts also require that this information be available to prospective students and employees upon request. 

The primary purpose of the federal law is to create a national reporting system on crime and safety, as well as fire safety, for our nation's colleges and universities. Bryn Mawr College is located in Lower Merion Township, a quiet residential suburb of Philadelphia. Bryn Mawr has a strong crime-prevention and fire safety program that includes the entire community of students, staff and faculty. The entire report is available online, plus the link is disseminated via email and handout messages to the Bryn Mawr College Community by Oct. 1 every year as required by law.

Policy Statement Addressing Preparation of Disclosure of Crime Statistics

The procedures for preparing the annual disclosure of crime statistics include reporting statistics to the College community obtained from the following sources: the Lower Merion Police Department (LMPD), the Campus Safety Department, and other officials (as defined below). Crime statistics are recorded in the calendar year in which the crime was reported.

A written request for statistical information is made on an annual basis to all Campus Security Authorities (CSAs) (as defined by federal law). Statistical information is requested and provided to the Campus Safety Department by the employees at the College Counseling Services and the Student Health Center. Also, the Title IX Coordinator provides statistics to the Campus Safety Department about cases where the victim chose not to report the incident to the Campus Safety Department and/or to the Lower Merion Police Department.

All of the statistics are gathered, compiled, and reported to the College community in the Annual Security and Annual Fire Safety Report, which is published by the Campus Safety Department. Campus Safety submits the annual crime statistics published in this brochure to the Department of Education (DOE). The statistical information gathered by the Department of Education is available to the public through the DOE website. The College also sends this report to the Pennsylvania State Police for inclusion in the Federal Bureau of Investigation Uniform Crime Report and in the Department of Education, Security Annual Report. These statistics are also furnished to all members of the community and student applicants annually, and to applicants for employment.

About the Campus Safety Department

The Bryn Mawr College Campus Safety Department operates continuously to provide a safe environment for our faculty, staff, students, and visitors that is conducive to both academic achievement and social development. This report is prepared by the Campus Safety Department which is responsible for furthering the safety and security of the Bryn Mawr community from hazards, including crime. We all have a crucial role to play and we thank each of you for doing your part.

The Campus Safety Department is located in the John J. Maloney Building in the Campus Safety Parking Lot, also known as the Upper Science lot. The office provides 24-hour, seven-day-a-week services to the community that include security, fire safety, and parking. The department has a total of 22 staff members. There are 16 full-time staff members: one director, one captain, three sergeants, seven patrol officers, and three dispatchers. The Department also has a card access administrator who oversees access control. There are also six on-call and part-time officers/dispatchers.

Campus Safety reports to the Chief Financial Officer of the College and cooperates with a variety of campus offices and organizations to enhance community safety. Bryn Mawr College is located in Lower Merion Township and has a working relationship with the Lower Merion Police Department (LMPD), which is the local police department, in addition to other law enforcement agencies, like the Pennsylvania State Police. Although there is no written memorandum of understanding, both departments share information needed to provide professional service to the community.

The campus is bounded by Morris Avenue, New Gulph Road, Roberts Road, Wyndon Avenue, Merion Avenue and Yarrow Road, with one off-campus site—the Graduate School of Social Work and Social Research, located on Airdale Road in Bryn Mawr.

Bryn Mawr College has no officially recognized student organizations with non-campus locations.

While Campus Safety Officers do not have the power of arrest, are not sworn officers and do not carry any firearms, they are empowered to detain individuals whenever that is deemed appropriate. The Campus Safety Officers’ jurisdiction is limited to the property under the control of Bryn Mawr College. Additionally, Campus Safety must enforce all Bryn Mawr College policies and procedures. Campus Safety Officers have a broad range of experiences including First Responder Medical Training. In addition, Campus Safety Officers have received training on the Incident Command System (ICS), as well as other training relevant to the services they provide to the community. Training is very important to ensure that Campus Safety Officers respond appropriately and promptly to incidents that occur on campus.

All Patrol personnel are required to complete Cardiopulmonary Resuscitation (CPR), and, Automated External Defibrillation (AED) training. Emergency medical assistance and transportation to the Bryn Mawr College Health Center, which is open Monday through Friday from 9 a.m. to 5 p.m. and Saturday and Sunday from 9 a.m. to 2 p.m. during the academic year, or to Bryn Mawr Hospital, which is one-half mile away, are available by contacting Campus Safety.

An on-call transportation service called the Lantern Shuttle is available during the academic year to provide safe transportation across campus and to the Paoli/Thorndale Line (R5) Bryn Mawr Train Station, as well as the Norristown High Speed line (R100) from 7 p.m. to 1 a.m. daily. (Due to COVID-19, this service has been placed on hold.)

The College maintains a proactive approach to crime and its prevention. Campus Safety has instituted a variety of programs to support this philosophy. The programs include bicycle registration, crime prevention and R.A.D. (Rape Aggression Defense) self-defense seminars. Campus Safety also assists in grounds and building maintenance by reporting potential safety hazards discovered while patrolling the campus.

Reporting Crimes and Other Incidents

Although we encourage the reporting of crime directly to Campus Safety, in some instances members of the campus community may choose to file a report with one of the other Campus Security Authorities (CSA). They include any member of the College Deans; the Director or Associate Director of Residential Life in Guild Hall; Athletic Coaches, assistant Coaches and Trainers at Schwartz Gym; Title IX Coordinator in Cambrian Row: Aelwyd, 2nd floor; Director of Student Activities and Orientation in Guild; Hall Advisors and the Residential Life Coordinators. The Campus Security Authorities work closely with Campus Safety to ensure the safety of our community.

To report a crime or incident, call 610-526-7911 or (x7911). Dispatchers are available at this number 24 hours a day to answer your call. A report will be taken even if the caller refuses to give their name and follow-up will be conducted.

Allegations of a campus crime that community members are aware of and that were made in good faith must be reported to Campus Safety. “In good faith” means that there is a reasonable basis for reporting a suspected crime. 

In the event of a crime or medical emergency, community members, students, faculty, staff, and guests are encouraged to report all crimes and other safety related incidents to the Bryn Mawr College Campus Safety Department in a timely manner by dialing x7911 or 610-526-7911. Be prepared to stay on the line and provide as much information as possible. The request to call Campus Safety first is to better assist the local enforcement departments in locating the emergency. However, if 911 is called first, please call Campus Safety x7911 immediately afterwards.     

Campus safety is a shared responsibility. All are encouraged to report crimes and unusual activity to Campus Safety immediately. When an incident report is generated, it will be investigated promptly.

When an incident is reported, the appropriate support, usually a Campus Safety Officer, is immediately sent to investigate. The community is made aware of incidents that impact the entire community through the appropriate administrator, campus newspaper, or by College-wide posting of safety alerts.

Emergency phones are located in various areas on campus. These phones are painted yellow and do not require dialing. Press the large red button and wait for the Campus Safety dispatcher to answer. The phones are equipped with an enhanced system that identifies your location for the Campus Safety dispatcher.

Confidential Reporting

Bryn Mawr College is committed to protecting the privacy of all individuals. That said, confidential reporting can only be made to the Counseling and Health Services Department or to a licensed/ordained religious advisor. Victims or bystanders who do not want to pursue action within the College or the criminal justice system can make a private report on any crime. Bryn Mawr Campus Safety can file a report of the incident without revealing the identity of the victim. The Lower Merion Police Department will be notified as well. The College will guide victims through the available options and support the victims in their decision. Various counseling options are available at the College, and outside resources are available as well.

The purpose of such a report is to comply with the victim’s wishes to keep the matter private, while taking steps to ensure the future safety of the victim and others. With this information, the College can keep and disseminate accurate records of the number of incidents involving students, determine where there is a pattern of crime with regard to a particular location, method, or assailant, and alert the community to potential danger.

Reports filed on any crime, in this manner, are counted and disclosed in the annual crime statistics for the College. You can view the Annual Security Report (which includes statistics for the previous three years) as well as institutional policies concerning campus security by contacting Campus Safety 610-526-7911 (x7911) or by accessing the website.

Campus Security Authorities—CSAs responsible for reporting criminal activity include:

  • Campus Safety 
  • Deans 
  • Title IX Coordinator
  • Director and Assistant Director of Residential Life
  • Director of Student Activities and Orientation
  • Director and Assistant Directors of Athletics, Coaches, and Assistant Coaches and Trainers
  • Residential Life Coordinators
  • Hall Advisors 
  • Faculty members with counseling responsibilities 

Confidential reporting departments:

  • Counseling and Health Services 
  • Licensed/ordained religious advisors

Campus Emergency Notification System

Timely Warnings

The purpose of this policy is to outline procedures that Bryn Mawr College will use to issue Timely Warnings in compliance with the Clery Act.

The College will issue a Timely Warning Notice in the event that it receives notice of an alleged Clery Crime (defined below) occurring on campus, on public property within or immediately adjacent to the campus, or in or on non-campus buildings or property controlled by the College, where the College determines, in its judgment, that the allegations present a serious or continuing threat to the College community. For purposes of this policy, “timely” means as soon as reasonably practical after an incident has been reported to the Campus Safety Department or the Campus Security Authorities identified by Bryn Mawr College or local police agencies that have concurrent jurisdiction have reported the information to the College. The Director of Campus Safety is ultimately responsible for determining whether to issue a Timely Warning Notice and will typically consult with the Director of Operations for Campus Safety, the Associate Director for Investigations for Campus Safety and the Dean of the Undergraduate College in making the decision.

Whether to issue a Timely Warning Notice is determined on a case-by-case basis for Clery Act crimes: homicide, sex offenses (rape, fondling, incest and statutory rape), robbery, aggravated assault, burglary, motor vehicle theft, arson, domestic violence, dating violence, stalking and hate crimes, as defined by the Clery Act1. The Director of Campus Safety or designees may also issue a Timely Warning Notice for other crimes, as determined necessary.

In determining whether to issue a Timely Warning Notice, the College will consider any factors reflecting on whether the alleged crime represents a serious or continuing threat to the College community, including, but not limited to, (a) the nature of the incident; (b) when and where the incident occurred; (c) when it was reported; (d) the continuing danger to the campus community; and (e) the amount of information known by the Campus Safety Department. 

The Director of Campus Safety will make efforts to consult with the Director of Operations for Campus Safety, the Associate Director for Investigations for Campus Safety and the Dean of the Undergraduate College in making the decision, if available, to develop the content of the Timely Warning Notice. Time permitting, additional input may be garnered from additional members of the Emergency Response Team, including the Chief Financial Officer and the Provost. The College’s Title IX Coordinator may also be consulted in appropriate situations.

The reason why the College does or does not issue a Timely Warning Notice for any Clery Crime reported to the College will be documented on the Timely Warning Determination Form and maintained by the Campus Safety Department for a minimum of seven years. A copy of the documentation will be attached to the written copy of the incident report.

1 A hate crime is defined as: “A crime reported to local police agencies or to a campus security authority that manifests evidence that the victim was intentionally selected because of the perpetrator’s bias against the victim. [T]he categories of bias include the victim’s actual or perceived race, religion, gender, gender identity, sexual orientation, ethnicity, national origin, and disability. 

The Timely Warning Notice will include, to the extent known, the date, time and nature of the offense, a brief overview of its particular circumstances, a physical description of the actor(s), law enforcement’s immediate actions, a request and method for witnesses to contact law enforcement, and where applicable and appropriate, cautionary advice that would promote safety. In developing the content of the Timely Warning Notice, the College will take all reasonable efforts not to compromise ongoing law enforcement efforts. The “timely warning” withholds the names of victims as confidential and will aid in the prevention of similar occurrences. 

The College distributes Timely Warning Notices in various ways. Once the College determines that an alert will be issued, the Campus Safety Department emails the announcement, may post it on its website, and may post alerts on bulletin boards throughout campus. The College may also send text messages disseminating the notice to those who register their cell phone numbers.

Anyone with information about a serious crime or incident should report the circumstances to the Campus Safety Department by phone at (610-526-7911) or in person at the John J. Maloney Building. If a report is made to other College administrators, those administrators will immediately notify the Campus Safety Department.

Emergency Notification

The Bryn Mawr College Emergency Notification System allows the College to contact the community in the event of an emergency by sending messages via:
1) Text message
2) Voice message (mobile or landline)
3) Email
4) Audible siren and loudspeaker
5) Bryn Mawr website postings

When an emergency occurs that requires community attention or action, the emergency notification system will be activated, and you will be notified by the methods noted above using the personal information you have provided. The emergency notification system will continue to try to reach you until you confirm receipt of the message. 

All student email addresses and cell phone numbers are automatically uploaded into the system. Faculty, staff and other members of our community are strongly encouraged to provide their cell phone number to Human Resources to ensure that their information is also loaded in the system. All faculty and staff can update their personal information, including cell phone numbers, using BiONiC under “Self-Service." It is imperative that contact information is accurate and up-to-date in order for you to receive emergency notifications. All current Bryn Mawr College emails will be used in the Everbridge system.

In addition to these steps, a recorded message may be placed on the Emergency Hotline, extension x7310, and information may also be posted on the College homepage. In the event of an immediate hazard or a serious or ongoing threat to campus safety, a text message will be sent out via Everbridge, and a public alert siren will be sounded, if necessary. The siren will be followed by instructions. When the crisis has passed, an all-clear will be sounded. For more information please refer to the Bryn Mawr College Emergency Response Guide.

The emergency notification system will be tested once a semester. Additional testing may be conducted as part of drills and exercises, or as necessary.

Clery Crime Definitions

Definitions of Clery Act Crimes
 
The Annual Security Report contains statistical accounting of various crimes that have been reported to the Department of Campus Safety. The following definitions used to classify these incidents are required to come from the Federal Uniform Crime Reporting Program and the National Incident Based Reporting System and are as follows:

  • Murder and Non-Negligent Manslaughter: The willful (non-negligent) killing of one human being by another. Exclude deaths caused by negligence, suicide, or accident; justifiable homicides and attempts to murder.
  • Manslaughter by Negligence: The killing of another person through gross negligence.
  • Robbery: The taking or attempting to take anything of value from the care, custody, or control of a person or persons by force or threat of force or violence and/or by putting the victim in fear.
  • Aggravated Assault: An unlawful attack by one person upon another for the purpose of inflicting severe or aggravated bodily injury. This type of assault is usually accompanied by the use of a weapon or by means likely to produce death or great bodily harm. Attempts are included since it is not necessary that an injury result when a gun, knife, or other weapon is used which could and probably would result in serious personal injury if the crime were successfully completed. Exclude simple assaults.
  • Burglary: The unlawful entry of a structure to commit a felony or a theft. The use of force to gain entry is not required to classify an offense as a burglary. Burglary includes forcible entry, unlawful entry where no force is used, and attempted forcible entry.
  • Motor Vehicle Theft: The theft or attempted theft of a motor vehicle. Include the stealing of automobiles, trucks, buses, motorcycles, motor scooters, snowmobiles, and similar motor vehicles. Exclude motorboats, construction equipment, airplanes, and farming equipment.
  • Arson: Any willful or malicious burning or attempt to burn, with or without intent to defraud, a dwelling house, public building, motor vehicle or aircraft, personal property of another, etc. Includes fires determined to have been willfully or maliciously set. Excludes fires of suspicious or unknown origin.
  • Weapon Law Violations: The violation of laws or ordinances dealing with weapon offenses, regulatory in nature, such as: manufacture, sale, or possession of deadly weapons; carrying deadly weapons, concealed or openly; furnishing deadly weapons to minors; aliens possessing deadly weapons; and all attempts to commit any of the aforementioned.
  • Drug Abuse Violations: The violation of laws relating to the unlawful possession, sale, use, growing, manufacturing, and making of narcotic drugs. The relevant substances include: opium or cocaine and their derivatives (morphine, heroin, codeine); marijuana; synthetic narcotics (Demerol, methadone); and dangerous non-narcotic drugs (barbiturates, Benzedrine).
  • Liquor Law Violations: The violation of laws or ordinances prohibiting the manufacture, sale, transportation, furnishing, possessing of intoxicating liquor; maintaining unlawful drinking places; bootlegging; operating a still; furnishing liquor to a minor or intemperate person; using a vehicle for illegal transportation of liquor; drinking on a train or public conveyance; and all attempts to commit any of the aforementioned.

The following crimes are included in the annual statistics if the incident is related to a hate crime category (*):

  • Simple Assault: An unlawful physical attack by one person upon another where neither the offender displays a weapon, or the victim suffers obvious severe or aggravated bodily injury involving apparent broken bones, loss of teeth, possible internal injury, severe laceration, or loss of consciousness.
  • Larceny-theft: The unlawful taking, carrying, leading, or riding away of property from the possession or constructive possession of another. Include crime such as shoplifting, pocket picking, purse snatching, thefts from motor vehicles, thefts of motor vehicle parts and accessories, bicycle thefts, and similar thefts, in which no use of force, violence, or fraud occurs. Excludes embezzlement, confidence games, forgery, and worthless checks.
  • Intimidation: To unlawfully place another person in reasonable fear of bodily harm through the use of threatening words and/or other conduct, but without displaying a weapon or subjecting the victim to actual physical attack.
  • Destruction/Damage/Vandalism of Property: To willfully or maliciously destroy, damage, deface, or otherwise injure real or personal property without the consent of the owner or the person having custody or control of it.
  • (*) Hate Crime: If the victim/survivor was intentionally selected because of actual or perceived race, gender, gender identity, religion, sexual orientation, ethnicity, national origin or disability.

Bryn Mawr's Emergency Response Team (BERT)

Overview

Bryn Mawr’s approach to situations that have had a significant impact on an individual member, or the entire campus community has succeeded over the years because of the dedication and conscientiousness of various members of the College community. 

As is required, we test our emergency response and evacuation procedures, including the use of electronic and cellular communication, better known as the Everbridge system, once a semester. 

Tests may be announced or unannounced (Test is defined as a regularly scheduled drill or exercise, and appropriate follow-up activities, designed for assessment and evaluation of emergency plans and capabilities). 

Notification Process Scenario

Although there is no one "typical" response since there is much variety in the types of incidents that the Bryn Mawr Emergency Response Team (BERT) will respond to, there is a general template of response to a critical incident. Some examples of the kinds of incidents/events include hostile intruders or other criminal acts, hazardous materials incidents and lab accidents, disasters such as fires, storms, and more slowly unfolding events such as disease outbreaks and prevention measures. In incidents requiring immediate action, the BERT notification will typically be a Campus Safety dispatcher contacting the BERT "Command Group." If possible, the BERT Command Group will meet in one of the identified Emergency Operations Centers (EOC) to decide the appropriate actions to take in response to the emergency. Determinations of who will respond to the scene of an incident, to the hospital, to a police station, etc., will be communicated by the emergency notification system. 

The members of the Bryn Mawr College Emergency Response Team Command Group have been trained in Incident Command System (ICS) and the basics of this nationally standardized management approach will be employed. An Incident Commander will be the responder (not necessarily the BERT team member; police, fire, etc.) who takes control at the scene of an incident as it unfolds. Senior administrators are in charge of the campus and will be overseeing management of the impact of the incident on and off campus; the Incident Commander will be in charge of the incident scene itself. 

In this way, a clear chain of command will be established, prompt and more efficient communication will take place, and integration of the necessary responders will be more efficient.

 

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Crime Logs

Bryn Mawr College Campus Safety maintains a daily crime log that contains specific information pertaining to all crimes that occur within the patrol jurisdiction of Campus Safety and that are reported. The daily crime log may be viewed at the John J. Maloney Building, Bryn Mawr College.

Certain information may be withheld from the crime log under specified circumstances, primarily information that would jeopardize the success of an investigation or the safety of a person in the investigation. The Campus Safety Department makes the crime log for the most recent 60-day period open to public inspection during normal business hours, while crime logs containing material more than 60 days old are retained for seven years for public inspection upon two days’ notice.

Building Security

Campus Safety has responsibility for locking and unlocking campus buildings based on use, class schedule, and special events. Access to institutional facilities by employees is on an as-needed basis and incorporates strict key and access control procedures. Visitors to the campus seeking access to campus buildings and facilities for special events must do so through an individual host, a sponsoring department, or reservation.
The policy at Bryn Mawr College is to provide easy access to authorized individuals. That access must be consistent with safety and the security of community members’ property and that of the College. Questions or suggestions related to authorized access should be directed to the Card Access Coordinator, x7911. 

Facilities maintenance and landscaping are maintained in a manner that minimizes hazardous conditions. Bryn Mawr Campus Safety regularly patrols the main campus and the Graduate School of Social Work and Social Research and reports malfunctioning lights and other unsafe physical conditions to the Facilities Department for repair. Other members of the College community should promptly report safety problems to the Bryn Mawr College Campus Safety Department at 610-526-7911.

There are 12 residence halls on campus. All resident areas are locked 24 hours a day and have access control. Buildings that contain classrooms, offices and dining centers are opened and locked in accordance with a schedule. Visitors to the campus can enter most academic buildings during normal business hours from 8 a.m. to 6 p.m. Monday through Friday.

Access to housing facilities is limited to those with authorization. Resident students have card-access to their residence halls and keys to their individual rooms. Guests of a resident must be accompanied by the resident. 

All unauthorized persons on campus will be investigated by Campus Safety.

For further protection during low-occupancy periods, such as school breaks and vacations, residence hall access is restricted to authorized community members.

Crime Prevention and Safety Awareness Programs

Title IX Bystander Intervention

Bystander interventions may be carried out by an individual or individuals in a safe and positive way to prevent harm or intervene when there is a risk of dating violence, domestic violence, sexual assault or stalking. Bystander intervention includes recognizing situations of potential harm, understanding institutional structures and cultural conditions that facilitate violence, overcoming barriers to intervening, identifying safe and effective intervention options, and taking action to intervene. A training program is offered a couple of times during the academic year. (See How to be an Active Bystander on page 42.)

Student Awareness Programs

The director of Student Activities and Orientation is responsible for providing online courses for all incoming students and Dorm Leaders (DLT), including Alcohol Wise Prevention and Marijuana Wise. A Consent and Respect course is also provided, and includes information regarding consent and sexual assault, intimate partner violence, abusive behavior and stalking, bystander intervention, incident reporting and survivor support and healthy relationships. Additionally, during Customs (student orientation) all incoming students attend presentations from Campus Safety, Health and Counseling Center, and the Title IX Coordinator. 

During the Academic Year, all new employees attend a New Employee Orientation. Highlights of this orientation include: welcome by the President and presentations regarding Undergraduate Admissions; conflict resolution by the Chair of Diversity Leadership Group and Diversity Council, and Equal Opportunity Officer; safety awareness from the Environmental Health and Safety Officer; College Sexual Harassment and Non-Discrimination Policy review; Social Justice and Inclusion and Title IX; Campus Safety; Staff Association; and review of the College Drug and Alcohol Policy.

Dorm Safety Meetings/Hangouts

Formally known as “Safe-teas”. The dorm safety meetings/hangouts are ongoing prevention and awareness conversations specifically discussing initiatives and strategies and include Hall Advisors (HA’s) and the Dorm Leadership Team members (DLT). The dorm safety meetings are a great place where students meet Campus Safety Officers and exchange ideas and information. The meetings are requested to discuss safety issues such as alcohol awareness, dating violence, domestic violence, sexual assaults and stalking on campus or within the dormitory. Students are strongly encouraged to participate and contribute. Forming a partnership with the students is an essential goal of the Campus Safety Department and benefits the entire community. These meetings occur at least once a semester or when requested by the Hall Presidents. However, many meetings are scheduled each semester to deal with hot topics such as VAWA.

Safe Ride Program

The Safe Ride Program, in partnership with Main Line Taxi, ensures the safe return to campus in the event that a student is stranded off campus, at any time. Any Bryn Mawr College student who is stranded off campus simply contacts Campus Safety at 610-526-7911 and requests a transport. The Campus Safety Communications Officer will contact Main Line Taxi and authorize the transport. When the student is safely back on campus a voucher will be completed and the cost of the cab fare will be charged to the student’s account.

Lantern Shuttle Service

The Lantern shuttle, the student run escort service, runs Monday through Sunday between the hours of 7 p.m. and 1 a.m., during the academic year, except break periods. To request a ride, call the Lantern Shuttle Office at 610-526-7900. Student Drivers will be dispatched to pick-up from campus locations, the R-5 Train Station (Paoli/Thorndale Line) and the R-100 (Norristown High Speed Line) Train Station only. 

Bicycle Registration

Campus Safety also offers free bicycle registration for members of the Bryn Mawr College community. Once the form is completed a decal will be placed on the bicycle, which clearly marks the bike and is a deterrent to theft. A copy of the registration form will be on file with Campus Safety and the owner will retain a copy. Bicycle registration is an important prevention tool and in the unfortunate event that the bicycle is stolen the information can be shared with police. 

Self Defense Classes for Women

Campus Safety offers self-defense classes to the Bryn Mawr College community. Campus Safety provides certified instructors of the Rape Aggression Defense Systems (R.A.D.), which is an international program specifically designed for women. The program involves a two-fold process combining education and practical self-defense techniques for women only. This system is taught at more than 350 colleges and universities. The objective is to develop and enhance the options of self-defense, so they may become viable considerations to the woman who is attacked.

Though many of the programs are offered for students, they are recommended for all members of the College community. The R.A.D. program is offered multiple times a semester. Registration is with the Athletic Department. Three (3) R.A.D. basic technique courses are offered as a THRIVE electives (THRIVE is a mandatory class for all first-year students) to choose outside the regular mandatory sessions.

Missing Student

If a member of the College community has reason to believe that a student residing in on-campus housing is missing, contact Campus Safety immediately 610-526-7911. Campus Safety will generate a missing person report and initiate an investigation.

After investigating the missing person report, should Campus Safety determine that the student is missing and has been missing for 24 hours (or sooner if circumstances warrant it), Bryn Mawr College will notify the Lower Merion Police Department. A Dean will notify the student’s emergency contact no later than 24 hours after the student is determined to be missing.  

If the missing student is under the age of 18 and not emancipated, a Dean will notify the student’s custodial parent or guardian and the separate confidential missing contact person (if the student has identified one) immediately after Campus Safety has determined that the student has been missing for 24 hours. 

In addition to registering an emergency contact, students have the option annually to register a confidential contact person to be notified if the student is determined to be missing for 24 hours. Only authorized campus officials and law enforcement officials in furtherance of a missing person investigation may have access to this information. To register a confidential contact person, visit the Student link in BiONiC by clicking the Missing Persons Contact Information. Please remember that you must sign on to BiONiC to get to the sign-on page.

Sex Offender Registry and Access to Related Information

The federal Campus Sex Crimes Prevention Act, which went into effect in October of 2002, requires that colleges and universities issue a statement informing the community where state law enforcement agency information pertaining to registered sex offenders may be found.

Pennsylvania's Megan's Law requires that the State Police establish and maintain a registry of individuals who have either been convicted of, pled guilty to, or were adjudicated delinquent of certain sex offenses. In addition, the PA State Police are required to provide certain information on registered sex offenders to the public through a website.

Information regarding registered sex offenders on the Bryn Mawr College campus may be obtained from the following resources: Family Watchdog or at the Pennsylvania State Police Megan’s Law site.

Alcohol, Controlled Substances and Weapons

Bryn Mawr College complies with federal, state and local laws including those which regulate the: manufacture, sale, purchase, transportation, possession and use of alcoholic beverages, controlled substances, and weapons. Regulations will be enforced by Campus Safety and the Lower Merion Police Department (LMPD). A person less than 21 years of age commits a summary offense if engaging in:

  • Manufacture, sale, transporting, furnishing, possessing, etc. of intoxicating liquor
  • Maintaining unlawful drinking places
  • Bootlegging and operating a still
  • Furnishing liquor to a minor or intemperate person
  • Underage possession
  • Using a vehicle for illegal transportation of liquor
  • Drinking on a train or public conveyance
  • Attempts to commit any of the above

A person who is convicted of violating this section may be subjected to a fine, jail and/or license suspension.

Bi-College Alcohol, Drug and Weapons Policies

All students are responsible for acting in accordance with the College’s Alcohol and Drug Policies, which are distributed to students each year via calendar and Student Handbook. These policies assert that students are each responsible for conducting themselves in ways consistent with federal, state and local laws, for following College party rules and for assisting those impaired by alcohol or drug use in the interests of their health and well-being. Impairment due to alcohol or drug use is never an excuse for misconduct. The College will not contribute to the cost of a legal defense for those who violate drug or alcohol laws and rules. Alcohol or drug policy infractions may result in a Dean’s Panel, Honor Board proceeding, or other College or SGA disciplinary action.

The care and concern for other individuals which are embodied in the Social Honor Code should govern a student’s response to a violation of the Bi-College alcohol and drug policies. When students are concerned about other students’ alcohol or drug use or its self-destructive potential, they may express that concern and, if appropriate, encourage that student to seek confidential help from one of the counselors, nurses or physicians on either campus or from a professional off campus. A student with questions about how best to confront or intervene on behalf of another student may seek guidance from a drug and alcohol counselor, counselor or dean. Advice may be sought without revealing the identity of the student needing help, if that seems best.

Alcohol Policy

The Alcohol Policy, in conjunction with planned educational activities and support services, is designed to achieve the following goals:

  • to remind students of the laws of the Commonwealth of Pennsylvania and of the Social Honor Codes, both of which govern their behavior with respect to alcohol;
  • to stress moderation, safety and individual accountability for those who choose to drink;
  • to maintain a Bi-College social atmosphere that is free of coercion for those who choose not to drink and a climate in which alcohol is not the focus of parties or other social events;
  • to maintain a Bi-College community in which alcohol abuse and its effects are minimal;
  • to provide confidential and effective guidance for those with specific needs related to alcohol use and alcoholism; and
  • to provide information and education about the effects of alcohol for all students.

All members of the Bi-College community are expected to be familiar with and abide by the principles of the Alcohol Policy.

It is the duty of all students to conduct themselves in a manner consistent with the Honor Codes, in addition to helping others to do the same. With regard to the consumption of alcohol, students are responsible for their own well-being. Behavior that puts students at mental, physical and/or legal risk cannot be condoned.

Alcohol Effects

Alcohol consumption causes a number of marked changes in behavior. Even low doses significantly impair the judgment and coordination required to drive a car safely, increasing the likelihood that the driver will be involved in an accident. Low to moderate doses of alcohol also increase the incidence of a variety of aggressive acts, including spouse and child abuse. Moderate to high doses of alcohol cause marked impairments in higher mental functions, severely altering a person’s ability to learn and remember information. Very high doses cause respiratory depression and death. If combined with other depressants of the central nervous system, much lower doses of alcohol will produce the effects just described.

Repeated use of alcohol can lead to dependence. Sudden cessation of alcohol intake is likely to produce withdrawal symptoms, including severe anxiety, tremors, hallucinations and convulsions. Alcohol withdrawal can be life-threatening. Long-term consumption of large quantities of alcohol, particularly when combined with poor nutrition, can also lead to permanent damage to vital organs such as the brain and the liver.

Mothers who drink alcohol during pregnancy may give birth to infants with fetal alcohol syndrome. These infants have irreversible physical abnormalities and mental challenges. In addition, research indicates that children of alcoholic parents are at greater risk than other youngsters of becoming alcoholics.

1. Students who choose to consume, provide or serve alcohol, with an understanding of the responsibilities imposed by Pennsylvania law, should do so with a sense of responsibility and concern for themselves and others. Students also have the responsibility to confront others whose behavior under the influence of alcohol is inconsistent with their welfare and concern for others in the community. When community members lose their ability to reason and control their actions due to excessive alcohol consumption, it is threatening to them, to those around them, and ultimately to the community as a whole. Students are urged to accept responsibility for preventing themselves and others from ever reaching that point.

2. Since the majority of students are under 21, the legal drinking age in the Commonwealth of Pennsylvania, alcoholic beverages are not to be served or consumed at student parties open to and/or advertised in the College, Bi-College, or Tri-College community. Additionally, alcoholic beverages can neither be served nor consumed at open parties held in public spaces. These include:

  • At Bryn Mawr: Cambrian Row, the Campus Center, Guild Hall, Old Library, Goodhart, Applebee Barn, Schwartz Gymnasium, all corridors, stairwells, landings, basements, attics and courtyards, laundries, all dining halls, Arnecliff Studio, Pembroke Dance Studio, classroom buildings, the Dorothy Vernon Room, Canaday Library, Carpenter Library, Collier Library, and outdoors on College grounds.
  • At Haverford: Founders Great Hall and Common Room, the Dining Center, Lunt Party Room, the Alumni Field House, VCAM, Marshall Auditorium, Recital Hall, all corridors, stairwells, roofs and attics, Stokes Auditorium, classroom buildings, Magill Library, outdoors on College grounds. With special permission, parties at which only those 21 years of age and older are served alcohol may be held in public spaces.

3. Students who consume alcohol where it is forbidden under Section 2 of this Policy, and thereby place the hosts, the Colleges, and the students who administer party funds at risk and in jeopardy, should be asked to refrain from violating the Policy by the host or other party guests. In incidents where students feel that a violation of the Alcohol Policy has occurred and where the confronting party and the confronted individual fail to reach a resolution, they should follow the procedure of the campus on which the incident occurred. At Haverford, disregard for these Alcohol and other Party Policies should be brought to the attention of the joint Student-Administration Alcohol Policy Panel, composed of three members of Student Council, three members of Honor Council, two appointed members at large, and two deans. 

This panel will address strictly procedural violations of the Policy. Referrals can be made by the Honor Council. At Bryn Mawr, disregard for these Alcohol and other Party Policies should be dealt with under the procedures outlined in the Social Honor Code.

4. Inebriation shall not be seen as an acceptable or justifiable excuse for disruptive behavior and confrontation for such behavior shall be dealt with as in the realm of each campus’s Social Honor Code.

5. When confronting an individual does not or cannot lead to a satisfactory resolution of a problem, the individual whose behavior allegedly violates the Codes and expected conduct of the Colleges, in accordance with the procedures of the Social Honor Codes, shall ultimately be brought to the attention of the Honor Board or Honor Council.

6. The Honor Board/Council will bring a case to the attention of the Office of the Dean of the appropriate College if there is a threat to the lives or safety of individuals or of damage to College or private property resulting from inebriation or a violation of the Alcohol Policy. Flagrant or repeated violations of party guidelines could constitute such a case. Such behavior may result in separation or exclusion of the confronted person(s) from the Colleges.

7.  In some cases, the Honor Board/Council or the Office of the Dean will consult counselors who have expertise in alcohol abuse and alcoholism if such expertise is deemed relevant. Such consultation will take place only with the confronted person’s knowledge.

8. Coordinators of parties and other social events must abide by the Party Policy of the host campus.

9. It is expected that hosts will inform their guests of the provisions of the Honor Codes, including the Alcohol Policy. Should the provisions of this Policy be violated by non-Bi-College members, their further access to these campuses may be restricted.

10. Faculty and staff members who entertain students should be aware of the responsibilities and risks to the Colleges and to themselves as individual social hosts under the laws of the Commonwealth.

11. Groups sponsoring social events must abide by the host campus’ Party Policy. If party guidelines are not followed by guests or hosts, it is the responsibility of students aware of the violation to approach those in violation and seek a resolution.

Services and Referrals

Both Bryn Mawr and Haverford Colleges provide services and referral for individuals who need help with an alcohol-related problem. For confidential assistance, contact:

  • Beth Kotarski, Medical Director, Bryn Mawr College Health Services, the Health and Wellness Center, 610-526-7360.
  • Reggie Jones, LCSW, Associate Dean of Health And Wellness, Bryn Mawr College Health Services, the Health and Wellness Center, 610-526-7360.
  • Alcoholics Anonymous Information Center, 444 N. 3rd St., Suite 3E, Philadelphia, 215-923-7900.

Drug Policy

Drug Violations

  • Violations of laws prohibiting the production, distribution, and/or use of certain controlled substances and the equipment or devices utilized in their preparation and/or use.
  • Arrests for violations of state and local laws, specifically those related to the unlawful Possession, Sale, Use, Growing, Manufacturing or Making of narcotic drugs.
  • The unlawful cultivation, manufacture, distribution, sale, purchase, use, possession, transportation or importation of any controlled drug or narcotic substance, including opium or cocaine and their derivatives (morphine, heroin, codeine); marijuana; synthetic narcotics (Demerol, methadone) or dangerous nonnarcotic drugs (barbiturates, Benzedrine).

The drug policy, in conjunction with planned educational activities and support services, is designed to achieve the following goals:

  • to remind students that the Social Honor Codes, the federal laws and the laws of the Commonwealth of Pennsylvania do apply to their behavior with respect to the use of drugs;
  • to stress individual accountability for those who choose to use illegal drugs;
  • to maintain a Bi-College community where the harmful effects of drug use can be minimized;
  • to inform the members of the Bi-College community of the availability of confidential and effective guidance and resources for those with questions and concerns related to drug use, dependence and abuse; and
  • to encourage all members of the Bi-College community to become familiar with the physiological, psychological and legal aspects of drug use, dependence and abuse.

All members of the Bi-College community are expected to be familiar with and abide by the principles of the drug policy. This policy stresses prevention and concern; it charges the community with the responsibility for drug education, intervention and heightened awareness of campus resources for dealing with drug problems. It also asks us to consider the relationship between the individual and the community, and the question of responsibility to one’s peers. In many cases, choosing not to intervene in another person’s abuse of drugs is not a neutral position. By not interfering, we become an enabler. In claiming to allow abusers their individual freedom of choice, we may in fact be limiting their choices by reinforcing their attitudes and behavior. In summary, we have a responsibility not to withdraw from the community either by abusing drugs or by ignoring the abuse of drugs.

1. The illegal possession, use, sale or distribution of drugs is in violation of the law, and the Colleges will not protect students from prosecution under federal, state or local law.
2. Students have the responsibility to confront and/or intervene on the behalf of individuals whose use of drugs or actions under the influence of drugs presents a danger to themselves and/or to the community at large.
3. The Colleges as educational institutions, being concerned about the harmful effects of the illegal use, possession, sale or distribution of drugs on the individual, and on the integrity, safety and security of this academic community, do not condone the illegal use, possession, sale or distribution of drugs. The administrations of Bryn Mawr and Haverford Colleges reserve the right to act when they have reason to believe that involvement with drugs is having an adverse effect upon the life and/or academic performance of students or adversely affects or legally implicates others in the academic community. College action may take such forms as education, counseling, and referral to outside agencies, separation or exclusion, depending on the situation.

Procedures

A student’s response to a violation of the Bi-College drug policy should be governed, first of all, by the care and concern for other individuals which are embodied in the Social Honor Codes. The following guidelines are not meant to cover all situations. They are intended, instead, to remind students of the variety of resources available and to reassure them about the consequences of seeking help.

When students are concerned about another student’s drug use and its self-destructive potential, they should express their concern and, if appropriate, encourage that student to seek confidential help from one of the counselors, nurses or physicians on either campus or from a professional off-campus. If confrontation does not seem appropriate or proves ineffective, the concerned individual should turn to the drug and alcohol counselor, a counselor, the counseling director, the medical director or dean for advice on how to intervene and help. Advice may be sought without revealing the identity of the student needing help.

If a student’s behavior as a result of drug use has disturbed or harmed other individuals or the community in a more general sense, the behavior itself should be dealt with through the usual Honor Code procedure at either college, beginning with confrontation. If mediation is necessary, the members of the Bryn Mawr Honor Board or the Haverford Honor Council should be consulted. The drug use that may have caused the behavior should not be viewed as an excuse, but as a second problem for which the individual may be encouraged to seek help from a professional counselor. In cases where the Honor Council or Board is asked to intervene, they will deal with the specific behavior that has been brought to them and may recommend that the individual go to a counselor for evaluation and help with any underlying substance abuse. Problems with behavior related to drug use that involve Bryn Mawr graduate students or special students who are not bound by the Social Honor Code should be referred to the Deans of the Graduate Schools if they cannot be resolved by the individual concerned.

If an individual’s involvement with drugs is such that it, or behavior associated with it, is violent or life-threatening, it should be brought to the attention of a dean or College physician without delay by any member of the community who becomes aware of the situation. Thus, a counselor, peer educator, dean, physician, or Honor Board/Council member, working with students on any aspect of their involvement with drugs, as in any other life-threatening situation, is bound to report the problem to the appropriate Dean when the potential for violence or loss of life requires immediate administrative action.

Some cases, such as the sale or distribution of drugs, may not present immediate danger to life but may have legal implications which are administrative concerns, as well as social consequences which are student concerns. In these situations, joint action by the Dean and the Honor Board/Council may be necessary.

Policy on Drug-Free Schools

The Drug-Free Schools and Communities Act of 1989: A person of 18 years of age or older who is convicted in any court of the Commonwealth of Pennsylvania of a violation of the Controlled Substance, Drug, Device and Cosmetic Act, shall, if the delivery or possession with the intent to deliver the controlled substance occurred within 1,000 feet of a public, private, or parochial school or a college or university or within 250 feet of the real property on which is located a recreation center or playground or on a school bus, shall be sentenced to a minimum sentence of at least two years of total confinement (up to four years). 

The unlawful possession, use, or distribution of illicit drugs and alcohol poses a threat to the health and safety of all members of the Bryn Mawr College community and is not permitted.

The sanctions for the unlawful possession, use or distribution of illicit drugs and alcohol are defined in the Pennsylvania Controlled Substance, Drug, Device and Cosmetic Act (35P.S. Sections 780-101 to 780-144); Controlled Substances Forfeiture (42 Pa.C.S. Sections 6801-6802); the Pennsylvania Crimes Code (18 Pa. C.S. 6307-6314); the Pennsylvania Motor Vehicle Code (75 Pa. C.S. 1546-1547; 3715, 3731); and the Lower Merion Township Code (Article IV, Section 111-4). These statutes are on file at the reference desk in Canaday Library. A summary of federal law and relevant sanctions is also on file.

The College’s policies on disciplinary sanctions for students are stated in the Bi-College Alcohol and Drug Policies and are also listed in the alcohol and drug policy in this report. Policies on sanctions for faculty and staff are stated in the handbooks appropriate to them.

This policy is instituted effective immediately, to comply with the Drug Free Schools and Communities Act of 1989 (P.L. #101-226). No institution will receive federal financial assistance of any kind after October 1, 1990, unless it has certified that it has “adopted and implemented a program to prevent the unlawful possession, use, or distribution of illicit drugs and alcohol by students and employees.”
The College will conduct a biennial review of its program to determine its effectiveness, implement needed changes, and ensure that it is consistently enforced.

Policy on a Drug-Free Workplace

The College, as an employer, and students as employees of the College have obligations under the Drug-Free Workplace Act of 1988 (41 U.S.C. Section 701). The College’s statement of compliance is reproduced here.

The use of illegal drugs poses a threat to the health and safety of members of the Bryn Mawr College community. Therefore, the illegal use, possession, dispensation, distribution or manufacture of controlled substances (as defined in federal statutes) by any faculty, staff or student employees in the workplace is not permitted.

As a condition of College employment, employees must abide by the terms of this policy, and they must notify their supervisors of any criminal conviction for a violation occurring in the College workplace no later than five days after such conviction.

Any employee found in violation of these prohibitions and regulations may be required to participate in a drug-abuse assistance or rehabilitation program and shall be subject to disciplinary action, which action might include dismissal. Information regarding such assistance or rehabilitation is available through the Health Center, the campus physician and Crossroads. All of the insurance programs offered to staff, faculty and students through the College provide some form of support to persons in various forms of treatment for substance-abuse problems.

This policy is instituted, effective immediately, to comply with federal laws and regulations. Federal agencies cannot legally award any contract over $25,000 or any grant monies without certification that the College has implemented a drug-free workplace program.

The College also complies with the Drug-Free Schools and Communities Act of 1989 (P.L. #101-226). Information on federal and state law imposing sanctions for unlawful possession, use or distribution of illicit drugs and alcohol is available at the reference desk of Canaday Library and in the Dean’s Office.

Information on counseling, treatment and rehabilitation programs is contained in the College’s drug and alcohol policies.

This Handbook’s statements on policies and procedures relating to alcohol and controlled substances form part of the College’s compliance with the Drug-Free Schools and Communities Act.

Commonwealth Law

Drugs: State law prohibits the unauthorized possession, use, manufacture, sale, delivery and possession of controlled substances. Persons may be subject to 30 days imprisonment and a $500 fine for simple possession of a small amount of marijuana (misdemeanor), a maximum of 15 years imprisonment and a $25,000 fine for the manufacture, delivery or possession of a Schedule I or II controlled narcotic drug such as cocaine, PCP and LSD (felony). Sentences can be doubled for second and subsequent convictions. Sentences can also be doubled for distribution of controlled substances to persons under the age of 18. Penalties range from a mandatory minimum sentence of (1) one year and a $5,000 fine for the first conviction to a mandatory minimum sentence of (7) seven years and a $50,000 fine for subsequent convictions for the manufacture, delivery or possession of 100 grams or more of a Schedule I or II controlled narcotic drug.

Health Risks Associated with the Use of Illicit Drugs 

Narcotics

Drugs Physical Dependence Psychological Dependence Possible Effects Effects of Overdose Withdrawal Syndrome
Heroin High High Euphoria, drowsiness, respiratory depression, constricted pupils, nausea Slow and shallow breathing, clammy skin, convulsions, coma, possible death Yawning, loss of appetite, irritability, tremors, panic, cramps, nausea, runny nose, chills and sweating, watery eyes
Morphine High High See above See above See above
Codeine Moderate Moderate See above See above See above
Hydrocodone High High See above See above See above
Hydromorphone High High See above See above See above
Oxycodone High High See above See above See above
Methadone, LAAM High High See above See above See above
Fentanyl and Analogs High High See above See above See above
Other Narcotics High-Low High-Low See above See above See above

Depressants

Drugs Physical Dependence Psychological Dependence Possible Effects Effects of Overdose Withdrawal Syndrome
Chloral Hydrate Moderate Moderate Slurred speech, disorientation, drunken behavior without the odor of alcohol Shallow respiration, clammy skin, dilated pupils, weak and rapid pulse, coma, possible death Anxiety, insomnia, tremors, delirium, convulsions, possible death
Barbituates High-Moderate High-Moderate See above See above See above
Benzodiazepines Low Low See above See above See above
Glutethimide High Moderate See above See above See above
Other Depressants Moderate Moderate See above See above See above

Stimulants

Drugs Physical Dependence Psychological Dependence Possible Effects Effects of Overdose Withdrawal Syndrome
Cocaine Possible High Increased alertness, euphoria, increased pulse rate and blood pressure, excitation, insomnia, loss of appetite Agitation, increased body temperature, hallucinations, convulsions, possible death Apathy, long periods of sleep, irritability, depression, disorientation
Amphetamine/Methamphetamine Possible High See above See above See above
Methylphenidate Possible High See above See above See above
Other Stimulants Possible High See above See above See above

Cannabis

Drugs Physical Dependence Psychological Dependence Possible Effects Effects of Overdose Withdrawal Syndrome
Marijuana Unknown Moderate Euphoria, relaxed inhibitions, excitation, increased appetite, disorientation Fatigue, paranoia, possible psychosis Occasional reports of insomnia, hyperactivity, decreased appetite
Tetrahydrocannabinol Unknown Moderate See above See above See above
Hashish and hashish oil Unknown Moderate See above See above See above

Hallucinogens

Drugs Physical Dependence Psychological Dependence Possible Effects Effects of Overdose Withdrawal Syndrome
LSD None Unknown Illusions and hallucinations, altered perception of time and distance Longer, more intense "trip" episodes, psychosis, possible death Unknown
Mescaline and Peyote None Unknown See above See above Unknown
Amphetamine Variants Unknown Unknown See above See above Unknown
Phencyclidine and Analogs Unknown High See above See above Unknown
Other Hallucinogens None Unknown See above See above Unknown

Summary of Pennsylvania Statutes Relating to Unlawful Sale, Possession, Use, Manufacture or Distribution of Illicit Drugs or Alcohol

Statute Offense Possible Sanctions
18 Pa. CS 6307 Misrepresentation of age to secure alcohol $500 and suspension of operating privileges
18 Pa. CS 6308 Purchase, consumption, possession or transportation of alcohol by a person under 21 years of age $500 and suspension of operating privileges
18 Pa. CS 6309

Representing that a minor (under 21) is of age

$300
18 Pa. CS 6310 Inducement of minors (under 21) to buy alcohol $300
18 Pa. CS 6310.1 Selling or furnishing alcohol to a minor (under 21) $1,000-$2,500
18 Pa. CS 6310.2 Manufacture or sale of false ID card $1,000-$2,500
18 Pa. CS 6310.3 Possession, carrying or use of false ID card $500 and suspension of operating privileges (or ineligibility to obtain a license)
18 Pa. CS 6310.4 Violation of 6307, 6308 or 6310.3 Suspension of operating privileges (or ineligibility to obtain a license)
18 Pa. CS 6314 Trafficking drugs to minors (under 18) Fines from $5,000-$50,000; imprisonment for a minimum of one year, depending on offense

35 PS 780-101 et seq.

Illicit manufacture, sale, delivery, possession of controlled substances Fines from $5,000-$250,000; imprisonment for a minimum of one year, depending on offense
42 Pa. CS 6801-2 Illicit manufacture, sale, delivery, possession of controlled substances Loss of property rights to Commonwealth of all controlled substances, paraphernalia, raw materials, conveyances, money, negotiable instruments and real property acquired in violation of the Controlled Substance, Drug, Device and Cosmetic Act
42 PS 4-491 Possession, sale or transportation of liquor within Pennsylvania unless purchased from a State Store in accordance with Liquor Control Board Regulations Fines of varying amount
75 Pa. CS 3715 Consumption of alcohol or drugs while driving Summary offense fine
75 Pa. CS 3731 Driving under the influence of drugs or alcohol $300-5,000 and imprisonment from 48 hours to 1 year; suspension or revocation of operating privileges
63 PS 390-8 Procuring drugs by fraud, forgery, alteration of Rx, etc. Imprisonment for 3 years, $5,000 fine, or both

Pennsylvania law imposes “social host” liability on persons who furnish alcohol to individuals under 21 years of age. The Pennsylvania Crimes Code defines “furnish” as “to supply, give, or provide to, or allow a minor to possess on the premises or property owned or controlled by the person charged.”

Federal Penalties and Sanctions for Illegal Trafficking and Possession of a Controlled Substance

Controlled Substances Act Schedule Drug Quantity First Offense Second Offense
I and II Others (law does not include marijuana, hashish, or hash oil) Any

Not more than 20 years; if death or serious injury, not less than 20 years, not more than life; fine $1 million individual, $5 million not individual

Not more than 30 years; if death or serious injury, life; fine $2 million individual, $10 million not individual

III
All (included in Schedule III are anabolic steroids, codeine and hydrocodone with aspirin or Tylenol® and some barbituates)
Any

Not more than 5 years; fine not more than $250,000 individual, $1 million not individual

Not more than 10 years; fine not more than $500,000 individual, $2 million not individual

IV All (included in Schedule IV are Darvon®, Talwin®, Equanil®, Valium®, and Xanax®) Any

Not more than 3 years; fine not more than $250,000 individual, $1 million not individual

Not more than 6 years; fine not more than $500,000 individual, $2 million not individual

V

All (over-the-counter cough medicines with codeine are classified in Schedule V)

Any

Not more than 1 year; fine not more than $100,000 individual, $250,000 not individual

Not more than 2 years; fine not more than $200,000 individual, $500,000 not individual

Controlled Substances Act  First Offense Second Offense Quantity Drug Quantity First Offense Second Offense
I and II Not less than 5 years. Not more than 40 years. If death or serious injury, not less than 20 years ore more than life. Fine of not more than $2 million individual, $5 million other than individual. 100-999g mixture. Not less than 20 years. Not more than life. If death or serious injury, not less than life. Fine of not more than $4 million individual, $10 million other than individual. 10-99g pure or 100-999g
_______
100-999g
_______
500-4,999g
_______
5-49g mixture
_______
10-99g pure or 100-999g 
_______
1-9g mixture
_______
40-399g mixture
_______
10-99g mixture

Meth-amphet-amine

________
Heroin

________
Cocaine

________
Cocaine Base
________
PCP

________
LSD

________
Fentanyl

________
Fentanyl Analogue

100g or more pure or 1kg or more mixture

__________
100-999g

___________
5kg or more mixture
___________
50g or more mixture
___________
100g or more pure or 1kg or more mixture

___________
10g or more mixture
___________
400g or more mixture
___________
100g or more mixture

Not less than 10 years. Not more than life. If death or serious injury, not less than 20 years or more than life. Fine of nor more than $4 million individual, $10 million other than individual. Not less than 20 years. Not more than life. If death or serious injury, not less than life. Fine of not more than $8 million individual, $20 million other than individual.

* The Controlled Substances Act (1970) places all substances regulated under federal law into one of five schedules based on the substance’s medical use, potential for abuse, and safety or dependence liability.

Description Quantity First Offense Second Offense
Marijuana 1,000 kg or more mixture; 1,000 or more plants

Not less than 10 years, not more than life; if death or serious injury, not less than 20 years, not more than life; fine not more than $4 million individual, $10 million other than individual

Not less than 20 years, not more than life; if death or serious injury, not more than life; fine not more than $8 million individual, $20 million other than individual

Marijuana
100 kg to 999 kg mixture; or 100-999 plants

Not less than 5 years, not more than 40 years; if death or serious injury, not less than 20 years, not more than life; fine not more than $2 million individual; $5 million other than individual

Not less than 10 years, not more than life; if death or serious injury, not more than life; fine not more than $4 million individual, $10 million other than individual

Marijuana

50 to 99 kg mixture; or 50 to 99 plants

Not more than 20 years; if death or serious injury, not less than 20 years, not more than life; fine $1 million individual, $5 million other than individual

Not more than 30 years; if death or serious injury, not more than life; fine $2 million individual, $10 million other than individual

Marijuana Less than 50 kg mixture

Not more than 5 years; fine not more than $250,000 individual, $1 million other than individual

Not more than 10 years; fine $500,000 individual, $2 million other than individual    

Hashish 10 kg or more See above See above
Hashish Oil 1 kg or more See above See above

Federal Penalties and Sanctions for Illegal Possession of a Controlled Substance

21 U.S.C. 844(A)
1st conviction: Up to 1 year imprisonment and fined at least $1,000 but not more than $100,000 or both.

After 1 prior drug conviction: At least 15 days in prison, not to exceed 2 years and fined at least $2,500 but not more than $250,000 or both.

After 2 or more prior drug convictions: At least 90 days in prison, not to exceed 3 years and fined at least $5,000 but not more than $250,000, or both.

Special sentencing provision for possession of crack cocaine: Mandatory at least 5 years in prison, not to exceed 20 years and fined up to $250,000, or both, if:

a. 1st conviction and the amount of crack possessed exceeds 5 grams,
b. 2nd crack conviction and the amount of crack possessed exceeds 3 grams,
c. 3rd or subsequent crack conviction and the amount of crack possessed exceeds 1 gram.

21 U.S.C. 853(A)(2) AND 881(A)(7)
Forfeiture of personal and real property used to possess or to facilitate possession of a controlled substance if that offense is punishable by more than 1 year imprisonment. (See special sentencing provisions re: crack)

21 U.S.C. 881(A)(4)
Forfeiture of vehicles, boats, aircraft or any other conveyance used to transport or conceal a controlled substance.

21 U.S.C. 844A
Civil fine of up to $10,000

21 U.S.C. 853A
Denial of Federal benefits, such as student loans, grants, contracts and professional and commercial licenses, up to 1 year for first offense, up to 5 years for second and subsequent offenses.

18 U.S.C. 922(G)
Ineligible to receive or purchase a firearm.

Miscellaneous
Revocation of certain Federal licenses and benefits, e.g., pilot licenses, public housing tenancy, etc., are vested within the authorities of individual Federal agencies.

Note: These are only Federal penalties and sanctions. Additional State penalties and sanctions may apply.

Weapons Law Violations

Laws and ordinances prohibit the manufacture, sale, purchase, transportation, possession, concealment, or use of firearms, cutting instruments, explosives, incendiary devices, or other deadly weapons. Weapons laws violation include weapons offenses that are regulatory in nature. Policies must include:

  • Manufacture, sale, or possession of deadly weapons;
  • Carrying deadly weapons, concealed or openly;
  • Using, manufacturing, etc. of silencers;
  • Furnishing deadly weapons to minors;
  • Aliens possessing deadly weapons; and
  • Attempts to commit any of the above

Penalties for Gun Carry Violations

In Pennsylvania, it is a third degree felony to carry a concealed weapon without a permit. Penalties include a fine of up to $15,000, up to seven years in prison, or both. (18 Penn. Rev. Stat. and Con. Stats. § 1101.)

It is a second degree felony for a person prohibited from carrying a weapon to do so. Penalties include a fine of up to $25,000, up to ten years in prison, or both. (18 Penn. Stat. and Con. Stat. § 6105.)

It is a misdemeanor in the first degree to carry a firearm into a court facility. Penalties include a fine of up to $10,000, up to five years in prison, or both. (18 Penn. Rev. Stat. and Con. Stats. § 913.)

§ 303.10. Guideline sentence recommendations: enhancements.

(a) Deadly Weapon Enhancement.

(1) When the court determines that the offender possessed a deadly weapon during the commission of the current conviction offense, the court shall consider the DWE/Possessed Matrix (§303.17(a)).

An offender has possessed a deadly weapon if any of the following were on the offender’s person or within his immediate physical control:

(i) Any firearm, (as defined in 42 Pa.C.S. § 9712) whether loaded or unloaded, or

(ii) Any dangerous weapon (as defined in 18 Pa.C.S. § 913), or

(iii) Any device, implement, or instrumentality designed as a weapon or capable of producing death or serious bodily injury where the court determines that the offender intended to use the weapon to threaten or injure another individual.    

Bryn Mawr College Weapon Policy 

  • Possession or use of weapons, including but not limited to air rifles, pellet guns, pistols, firearms, ammunition, hunting equipment, knives and swords, is expressly prohibited.
  • Possession or use of dangerous substances, including but not limited to gunpowder, fireworks, explosives, gasoline and kerosene, is expressly prohibited.

Violators will be subject to disciplinary action, including but not limited to fines, relocation, denial of College housing and exclusion from the College, as well as civil and criminal liability. If dangerous articles or substances are discovered in a room, they will be impounded.

Alcohol and Drug Awareness Training

In addition to separate Customs presentations (New Student Orientation) held annually for all new students by Campus Safety, Residential Life, and the Dean’s Office [which conducts separate training on “Staying Safe ” and bystander intervention to all new students and “Sexual Misconduct —Response and Support for Victims” to the DLT’s (Dorm Leadership Team members)], there are ongoing training/informational sessions which typically include discussions on sexual assault, and alcohol and other drugs prevention for all students throughout the year. 

Dorm Safety Meetings/Hangouts

In conjunction with working with the Hall Advisors (HAs) and the Dorm Leadership Team members (DLT) on many issues, the dorm safety meetings are a great place where students meet Campus Safety and exchange ideas and information. The meetings are requested to discuss safety issues such as alcohol awareness on campus or within the dormitory. Students are strongly encouraged to participate and contribute. Forming a partnership with the students is an essential goal of the department and benefits the entire community. These meetings occur at varies times during each semester or when requested by the Hall Presidents or other DLT members. 

Awareness Programs

There are many open forum discussions during the academic year aimed at awareness and providing safety information to students on topics such as sexual assault, domestic violence, stalking, bullying, bystander awareness, alcohol and other drugs awareness and identity theft.

Additional training is provided by the Title IX Coordinator to Faculty, Staff and Students, including but not limited to:

  • New staff orientation (approximately four times per year)
  • New faculty orientation (every August)
  • Athletics Staff training
  • Student Athletic Advisory Committee (SAAC) along with Title IX Training
  • Student Safety Planning program (Students Against Sexual Harm/SASH) held in Pensby
  • Dean’s Office and Student Life annual training (Fall semester)
  • Hall Advisor (HA) training
  • Customs Persons training
  • Dorm Leadership Team (Pre-service training in August and refresher in January)
  • First Year Students/Customs Consent and Title IX workshops (all first years)
  • Customs: Bystander Intervention training (all first years) 
  • THRIVE program (10-week non-academic course that provides information and activities to help students to get to know the College, themselves, and build community)
  • •    Faculty Meetings annually

Additional training also provided by the Health Center-Counseling Service. It includes drug prevention activities such as:

  • Counseling Staff provide outreach and programming on prevention and abuse to student groups — Customs, Hall Advisors (HAs), Dorm Leadership Team (DLT) and student affinity groups on campus.
  • Drug and substance abuse educational information, including handouts distributed during First-year THRIVE course (Helping first-year students in the transition to campus life).
  • Individual counseling and education for students, who are self-referred, referred by the Dean's Office, Residential Life, the Athletics department, faculty, staff and other students. 
  • Web-based College alcohol educational program for all new students and dorm leadership team members. 

Online Courses: (First year and DLT members)

  • Alcohol Wise Prevention
  • Marijuana Wise
  • Consent and Respect:
    Consent and Sexual assault
    Intimate partner violence
    Abusive behavior and stalking
    Bystander intervention
    Incident reporting and survivor support
    Healthy relationships

A written Statement about Standards of Conduct concerning Drug and Alcohol Education and Counseling Services is also included in the Student Handbook on page 49.

In addition, the Student Handbook has extensive information on both the Drug and Alcohol Policies:

  • Alcohol Policy: p. 53
  • Expectations of Students: p. 53
  • Drug Policy: p. 55
  • Policy on Drug Free Workplace: p. 56

The educational materials are included in the College's written policies instituted to comply with this legislation. 

Drug and Alcohol assessment, counseling and treatment within the scope of Bryn Mawr’s services are provided by the Health Center-Counseling Service. Students needing more intensive treatment are referred off-campus. During Counseling Service staff's orientation week, Dorm Leadership Team (DLT) members and first year students are encouraged to utilize the counseling services for consultation, education and/or treatment related to drug and alcohol concerns/issues. All students can receive up to six free sessions each academic year. 

A "report" is generated of students who have had an alcohol/substance incident that comes to the attention of Campus Safety. The Dean of the College is sent a copy of the report and refers students listed on the Campus Safety Report to a Residential Life Coordinator who personally meets with all students. Then may refer to the Health Center and Counseling Service to see the Drug and Alcohol Counselor for education, assessment, treatment and possible referral in accordance with our policy.

Additional information regarding these topics is included in the student, faculty and staff handbooks.
There is a Faculty Guide for Helping Students in Need. Information about working with students experiencing difficulties can be found on the Dean's Office website.

Employees

To promote a safe and healthy campus environment, the College developed its Alcohol and Other Drug policies to assist community members in making decisions about alcohol or other drugs and to provide important information about resources available when addressing issues or situations involving alcohol or other drugs. These policies are contained within the student, faculty and staff handbooks, respectively, as well as on our Drug and Alcohol Prevention Program webpage. 
 
Additionally, the Staff Handbook provides information on and policies pertaining to drugs and alcohol (page 50). The Staff Handbook can be found on the Human Resources website. The College offers employees the benefit of an Employee Assistance Program (EAP) and its services, which include assistance with substance abuse. Employees are made aware of these polices and benefits in a meeting with Human Resources on their first day of employment and when they attend the mandatory New Employee Orientation.

Federal Clery Act Definitions of Domestic Violence, Dating Violence, Sexual Assault and Stalking/Violence Against Women Act (VAWA)

Bryn Mawr College prohibits the offenses of domestic violence, dating violence, sexual assault and stalking (as defined by the Clery Act) and reaffirms its commitment to maintaining a campus environment that emphasizes the dignity and worth of all members of the College community. Toward that end, Bryn Mawr College issues this statement of policy to inform the campus community of our programs to address domestic violence, dating violence, sexual assault and stalking as well as the procedures for institutional disciplinary action in cases of alleged dating violence, domestic violence, sexual assault, or stalking, which will be followed regardless of whether the incident occurs on or off campus when it is reported to a College official. 

The Clery Act defines the crimes of domestic violence, dating violence, sexual assault and stalking as follows:

Domestic Violence: 

i. A felony or misdemeanor crime of violence committed— 

  • By a current or former spouse or intimate partner of the victim;
  • By a person with whom the victim shares a child in common;
  • By a person who is cohabitating with, or has cohabitated with, the victim as a spouse or intimate partner;
  • By a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred; or
  • By any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred.

ii. For the purposes of complying with the requirements of this section and 668.41, any incident meeting this definition is considered a crime for the purposes of Clery Act reporting.

Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim.

i. The existence of such a relationship shall be based on the reporting party’s statement and with consideration of the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship.

ii. For the purposes of this definition—

  • Dating violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse.
  • Dating violence does not include acts covered under the definition of domestic violence.
  • For the purposes of complying with the requirements of this section and §668.41, any incident meeting this definition is considered a crime for the purposes of Clery Act reporting.

Sexual Assault: An offense that meets the definition of rape, fondling, incest, or statutory rape as used in the FBI’s Uniform Crime Reporting (UCR) program. Per the National Incident-Based Reporting System User Manual from the FBI UCR Program, a sex offense is “any sexual act directed against another person, without the consent of the victim, including instances where the victim is incapable of giving consent.”

  • Rape is defined as the penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the consent of the victim.
  • Fondling is defined as the touching of the private parts of another person for the purposes of sexual gratification, without the consent of the victim, including instances where the victim is incapable of giving consent because of their age or because of their temporary or permanent mental incapacity.
  • Incest is defined as sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law.
  • Statutory Rape is defined as sexual intercourse with a person who is under the statutory age of consent.

Stalking:
i. Engaging in a course of conduct directed at a specific person that would cause a reasonable person to— 

  • Fear for the person’s safety or the safety of others; or 
  • Suffer substantial emotional distress.

ii. For the purposes of this definition—

  • Course of conduct means two or more acts, including, but not limited to, acts which the stalker directly, indirectly, or through third parties, by any action, method, device, or means follows, monitors, observes, surveils, threatens, or communicates to or about, a person, or interferes with a person’s property.
  • Reasonable person means a reasonable person under similar circumstances and with similar identities to the victim.
  • Substantial emotional distress means significant mental suffering or anguish that may, but does not necessarily, require medical or other professional treatment or counseling.

iii. For the purposes of complying with the requirements of this section and section 668.41, any incident meeting this definition is considered a crime for the purposes of Clery Act reporting.

Jurisdictional Definitions of Domestic Violence, Dating Violence, Sexual Assault and Stalking

  • Domestic Violence: The state of Pennsylvania defines domestic violence as follows: “Domestic abuse” as one or more of the following acts (including the attempt to commit one or more the following acts) between family or household members:
    o    bodily injury, rape, or incest
    o    putting a protected person in reasonable fear of immediate, serious bodily injury
    o    false imprisonment
    o    physical or sexual abuse of a child, and
    o    other actions that repeatedly put a protected person in reasonable fear of serious bodily injury, such as stalking or harassment.
  • Dating Violence: The state of Pennsylvania does not have a definition of dating violence. However, the College follows the Clery Act definition: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim.

i. The existence of such a relationship shall be based on the reporting party’s statement and with consideration of the length of the relationship, the type of relationship and the frequency of interaction between the persons involved in the relationship.

ii. For the purposes of this definition—

  • Dating Violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse.
  • Dating violence does not include acts covered under the definition of domestic violence.

iii. For the purposes of complying with the requirements of this section and §668.41, any incident meeting this definition is considered a crime for the purposes of Clery Act reporting.

Sexual Assault: Rape (18 Pa. C.S. § 3121)

(a) Offense Defined – Offense Defined – A person commits a felony of the first degree when the person engages in sexual intercourse with a complainant:

  1. By forcible compulsion.
  2. By threat of forcible compulsion that would prevent resistance by a person of reasonable resolution;
  3. Who is unconscious or where the person knows that the complainant is unaware that the sexual intercourse is occurring.
  4. Where the person has substantially impaired the complainant's power to appraise or control his or her conduct by administering or employing, without the knowledge of the complainant, drugs, intoxicants or other means for the purpose of preventing resistance.
  5. Who suffers from a mental disability which renders the complainant incapable of consent.

Stalking: § 2709.1.  

(a) Offense defined.—A person commits the crime of stalking when the person either:

  1. engages in a course of conduct or repeatedly commits acts toward another person, including following the person without proper authority, under circumstances which demonstrate either an intent to place such other person in reasonable fear of bodily injury or to cause substantial emotional distress to such other person; or
  2. engages in a course of conduct or repeatedly communicates to another person under circumstances which demonstrate or communicate either an intent to place such other person in reasonable fear of bodily injury or to cause substantial emotional distress to such other person.

Consent:

The Commonwealth of Pennsylvania doesn’t specifically define consent. However, Bryn Mawr College follows this definition of consent: Consent is an affirmative, voluntary and knowing agreement to engage in sexual activity.

  • Consent is not equivalent to the absence of no. Silence or the absence of resistance does not imply consent.
  • Consent must be mutually and unambiguously communicated.
  • Past consent does not imply future consent.
  • Consent to engage in sexual activity with one person does not imply consent to engage in sexual activity with another.
  • Consent can be withdrawn at any time.
  • Coercion, force, or threat of either invalidates consent.
  • Consent is only possible if all parties involved are able to act under their own free will.
  • A person who is incapacitated cannot give consent. Incapacitation may result from the influence of alcohol or other drugs, when a person is asleep or unconscious, or because of a disability that prevents a person from having the capacity to give consent.

Pennsylvania State Law Definitions of Domestic Violence, Dating Violence, Sexual Assault and Stalking

Domestic Violence: The Commonwealth of Pennsylvania defines domestic violence as follows: “Domestic abuse” as one or more of the following acts (including the attempt to commit one or more the following acts) between family or household members, sexual or intimate partners, or people who have a child in common:

  • purposefully or recklessly causing or attempting to cause bodily injury, serious bodily injury, rape, involuntary deviate sexual intercourse, sexual assault, statutory sexual assault, aggravated indecent assault, indecent assault, or incest with or without a deadly weapon 
  • causing another person to reasonably fear imminent serious bodily injury
  • false imprisonment
  • physical or sexual abuse of a child, or
  • engaging in a course of conduct or repeatedly committing acts directed at another person under circumstances that place the person in reasonable fear of bodily injury.

“Family or household members” means current or former spouses, persons who live or have lived as spouses, parents and children, other persons related by blood or marriage, current or former intimate or sexual partners, or persons who have a child in common.

Dating Violence: The Commonwealth of Pennsylvania does not have a definition of dating violence. However, the College follows the Clery Act definition: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim.

Sexual Assault: The Commonwealth of Pennsylvania defines sexual assault as follows: Except as provided in section 3121 (relating to rape) or 3123 (relating to involuntary deviate sexual intercourse), a person commits a felony of the second degree when that person engages in sexual intercourse or deviate sexual intercourse with a complainant without the complainant’s consent.

Rape: The Commonwealth of Pennsylvania defines rape as follows:
a) Offense Defined – A person commits a felony of the first degree when the person engages in sexual intercourse with a complainant:

  1. By forcible compulsion.
  2. By threat of forcible compulsion that would prevent resistance by a person of reasonable resolution.
  3. Who is unconscious or where the person knows that the complainant is unaware that the sexual intercourse is occurring.
  4. Where the person has substantially impaired the complainant's power to appraise or control his or her conduct by administering or employing, without the knowledge of the complainant, drugs, intoxicants or other means for the purpose of preventing resistance.
  5. Who suffers from a mental disability which renders the complainant incapable of consent.

Involuntary Deviate Sexual Intercourse: The Commonwealth of Pennsylvania defines involuntary deviate sexual intercourse as follows: 
a) Offense defined – A person commits a felony of the first degree when the person engages in deviate sexual intercourse with a complainant:

  1. by forcible compulsion;
  2. by threat of forcible compulsion that would prevent resistance by a person of reasonable resolution;
  3. who is unconscious or where the person knows that the complainant is unaware that the sexual intercourse is occurring;
  4. where the person has substantially impaired the complainant’s power to appraise or control his or her conduct by administering or employing, without the knowledge of the complainant, drugs, intoxicants or other means for the purpose of preventing resistance;
  5. who suffers from a mental disability which renders him or her incapable of consent; or
  6. who is less than 16 years of age and the person is four or more years older than the complainant and the complainant and person are not married to each other.

Statutory Sexual Assault: The Commonwealth of Pennsylvania defines statutory sexual assault as follows:
a) Felony of the second degree – Except as provided in section 3121 (relating to rape), a person commits a felony of the second degree when that person engages in sexual intercourse with a complainant to whom the person is not married who is under the age of 16 years and that person is either: 

  1. Four years older but less than eight years older than the complainant; or
  2. Eight years older but less than 11 years older than the complainant.

b) Felony of the first degree –A person commits a felony of the first degree when that person engages in sexual intercourse with a complainant under the age of 16 years and that person is 11 or more years older than the complainant and the complainant and the person are not married to each other.

Indecent Assault: The Commonwealth of Pennsylvania defines indecent assault as follows:
a) Offense defined – A person is guilty of indecent assault if the person has indecent contact with the complainant, causes the complainant to have indecent contact with the person or intentionally causes the complainant to come into contact with seminal fluid, urine or feces for the purpose of arousing sexual desire in the person or the complainant and:

  1. the person does so without the complainant’s consent:
  2. the person does so by forcible compulsion;
  3. the person does so by threat of forcible compulsion that would prevent resistance by a person of reasonable resolution;
  4. the complainant is unconscious or the person knows that the complainant is unaware that the indecent contact is occurring;
  5. the person has substantially impaired the complainant’s power to appraise or control his or her conduce by administering or employing, without the knowledge of the complainant, drugs, intoxicants or other means for the purpose of preventing resistance;
  6. the complainant suffers from a mental disability which renders the complainant incapable of consent;
  7. the complainant is less than 13 years of age; or
  8. the complainant is less than 16 years of age and the person is four or more years older than the complainant and the complainant and the person are not married to each other.

Incest: The Commonwealth of Pennsylvania defines incest as follows:
A person is guilty of incest, a felony of the second degree, if that person knowingly marries or cohabits or has sexual intercourse with an ancestor or descendant, a brother or sister of the whole or half blood or an uncle, aunt, nephew, or niece of the whole blood. The relationships referred to in this section include blood relationships without regard to legitimacy, and relationship of parent and child by adoption.

Stalking: The Commonwealth of Pennsylvania defines stalking as follows:
a) Offense defined. —A person commits the crime of stalking when the person either:

  1. engages in a course of conduct or repeatedly commits acts toward another person, including following the person without proper authority, under circumstances which demonstrate either an intent to place such other person in reasonable fear of bodily injury or to cause substantial emotional distress to such other person; or
  2. engages in a course of conduct or repeatedly communicates to another person under circumstances which demonstrate or communicate either an intent to place such other person in reasonable fear of bodily injury or to cause substantial emotional distress to such other person.

b) Venue – 

  1. An offense committed under this section may be deemed to have been committed at either the place at which the communication or communications were made or at the place where the communication or communications were received.
  2. Acts indicating a course of conduct, which occur in more than one jurisdiction, may be used by any other jurisdiction in which an act occurred as evidence of a continuing pattern of conduct or a cause of conduct.

c)    Grading –

  1. Except as otherwise provided for subsequent offenses, a first offense under this section shall constitute a misdemeanor of the first degree.

Definitions—As used in this section, the following words and phrases shall have the meanings given to them in this subsection: 

“Communicates.”  To convey a message without intent of legitimate communication or address by oral, nonverbal, written or electronic means, including telephone, electronic mail, internet, facsimile, telex, wireless communication or similar transmission.

“Course of conduct.”  A pattern of actions composed of more than one act over a period of time, however short, evidencing a continuity of conduct. The term includes lewd, lascivious, threatening or obscene words, language, drawings, caricatures or actions, either in person or anonymously. Acts indicating a course of conduct which occur in more than one jurisdiction may be used by any other jurisdiction in which an act occurred as evidence of a continuing pattern of conduct or a course of conduct.

"Emotional distress." A temporary or permanent state of mental anguish.

"Family or household member." Spouses or persons who have been spouses, persons living as spouses or who lived as spouses, parents and children, other persons related by consanguinity or affinity, current or former sexual or intimate partners or persons who share biological parenthood.

Aggravated Indecent Assault: The Commonwealth of Pennsylvania defines aggravated indecent assault as follows:
a)    Offenses defined – Except as provided in sections 3121 (relating to rape), 3122.1 (relating to statutory sexual assault), 3123 (relating to involuntary deviate sexual intercourse) and 3124.1 (relating to sexual assault), a person who engages in penetration, however slight, of the genitals or anus of a complainant with a part of the of the person’s body for any purpose other than good faith medical, hygienic or law enforcement procedures commits aggravated indecent assault if:

  1. the person does so without the complainant’s consent;
  2. the person does so by forcible compulsion;
  3. the person does so by threat of forcible compulsion that would prevent resistance by a person of reasonable resolution;
  4. the complainant is unconscious or the person knows that the complainant is unaware that the penetration is occurring;
  5. the person has substantially impaired the complainant’s to appraise or control their conduct by administering or employing, without the knowledge of the complainant, drugs, intoxicants, or other means for the purpose of preventing resistance;
  6. the complainant suffers from a mental disability which renders them incapable of consent;
  7. the complainant is less than 13 years old;
  8. the complainant is less than 16 years of age and the person is four or more years older than the complainant and the complainant and the person are not married to each other.

Consent: 
The Commonwealth of Pennsylvania doesn’t specifically define consent. However, Bryn Mawr College follows this definition of consent: Consent is an affirmative, voluntary and knowing agreement to engage in sexual activity.

Consent to engage in sexual activity must be informed, knowing and voluntary; consent must exist from the beginning to end of each instance of sexual activity and for each form of sexual contact. Consent is demonstrated through mutually understandable words and/or actions that clearly indicate a willingness to engage freely in sexual activity. Consent is active, not passive.

Guidance for Consent: 

  • Prior to initiating a sexual encounter, one is expected to obtain consent to each act of sexual activity prior to initiating such activity. Consent to one form of sexual activity does not constitute consent to engage in all forms of sexual activity.
  • Either Party may withdraw consent at any time. Withdrawal of consent should be outwardly demonstrated by words or actions that clearly indicate a desire to end sexual activity. Once withdrawal of consent has been expressed, sexual activity must cease.
  • Consent consists of an outward demonstration indicating that an individual has freely chosen to engage in sexual activity. Relying on non-verbal communication can lead to misunderstandings. Consent may not be inferred from silence, passivity, lack of resistance, or lack of an active response alone. A person who does not physically resist or orally refuse sexual activity is not necessarily giving consent.
  • When consent is requested orally, absence of any explicit oral response constitutes lack of consent. An oral “no” constitutes lack of consent, even if it sounds insincere or indecisive.
  • If at any time during the sexual activity, any confusion or ambiguity arises as to the willingness of the other individual to proceed, both Parties should stop and clarify orally the other’s willingness to continue before continuing such activity.
  • Individuals with a previous or current intimate relationship do not automatically give either initial or continued consent to sexual activity. Even in the context of a relationship, there must be mutually understandable communication that clearly indicates a willingness to engage in each sexual activity.
  • Consent to engage in sexual activity with one person does not imply consent to engage in sexual activity with another person.
  • Consent is not effective if it results from the use or threat of physical force, intimidation, or coercion, or any other factor that would eliminate an individual’s ability to exercise their own free will to choose whether or not to have sexual contact.
  • An individual who is physically incapacitated from alcohol or other drug consumption (voluntarily or involuntarily) or is asleep, unconscious, unaware, or otherwise physically helpless is considered unable to give consent.
  • In the Commonwealth of Pennsylvania, the age of majority is 18. Under state law, consent cannot be given by minors under the age of 13 and can only be given by a minor under the age of 16, if the other Party is less than four (4) years older than the minor.

How to Be An Active Bystander

Bystanders play a critical role in the prevention of sexual and relationship violence. They are “individuals who observe violence or witness the conditions that perpetuate violence. They are not directly involved but have the choice to intervene, speak up, or do something about it.” We want to promote a culture of community accountability where bystanders are actively engaged in the prevention of violence without causing further harm. We may not always know what to do even if we want to help. Below is a list of some ways to be an active bystander. If you or someone else is in immediate danger, call (610-526-7911) from on campus or 911 while off campus. 

  1. Watch out for your friends and fellow students/employees. If you see someone who looks like they could be in trouble or need help, ask if they are okay. 
  2. Confront people who seclude, hit on, try to make out with, or have sex with people who are incapacitated.
  3. Speak up when someone discusses plans to take sexual advantage of another person.
  4. Believe someone who discloses sexual assault, abusive behavior, or experience with stalking.
  5. Refer people to on or off campus resources listed in this document for support in health, counseling, or with legal assistance. 

Risk Reduction

The following information will be helpful to all Bryn Mawr College students as they confront issues of sexual assault:

  1. It is never acceptable to use force in sexual situations, no matter what the circumstances.
  2. Sexual assault can happen between persons of any sexual orientation or gender identity.
  3. If a person says "no" to sexual contact, believe them and stop!
  4. Communicate your limits firmly and directly. Back up your words with a firm tone of voice and clear body language.
  5. Don’t make any assumptions about a person’s behavior.
  6. Don’t automatically assume that someone wants to have sex just because they drink heavily, dress in a certain way, or agree to go back to your room.
  7. Don’t assume that because a person has had sexual contact with you previously that they are willing to or will consent to having sex with you again.
  8. Everyone should be especially careful in situations involving the use of alcohol and other drugs. Alcohol and other drugs can interfere with one’s ability to assess situations and to communicate effectively.
  9. All students should beware that having sexual contact with someone who is mentally incapable of giving consent is sexual assault. If you have sex with a person who is drugged, intoxicated, "sleeping" or passed out, incapable of saying "yes" or "no" or unaware what is happening to them, then you may have committed a sexual assault.
  10. Be especially careful in group situations. Be prepared to resist pressure from friends to participate in violent or criminal activities.
  11. Get involved if you believe that someone else may be at risk for assault. If you see a person "in trouble" at a party or another person using force or coercion do not be afraid to ask questions and/or intervene. You may save someone from the trauma of sexual assault and/or from the ordeal of criminal prosecution.
  12. If you feel uncomfortable or think you may be at risk, leave the situation immediately and go to a safe place.
  13. Don’t be afraid to “make waves” if you feel threatened. If you feel you are being pressured or coerced into sexual activity against your will, don’t hesitate to state your feelings in order to get out of the situation. Better a few minutes of social awkwardness and embarrassment than the trauma of sexual assault.
  14. Voluntary consent cannot be given if a person is incapacitated, including incapacitated by alcohol. (Alcohol is a factor in a very high percentage of sexual assaults.)

Procedures Victims Should Follow if a Crime of Domestic Violence, Dating Violence, Sexual Assault and Stalking Occurs

Bryn Mawr College prohibits the offenses of domestic violence, dating violence, sexual assault and stalking (as defined by the Clery Act) and reaffirms its commitment to maintaining a campus environment that emphasizes the dignity and worth of all members of the College community. Toward that end, Bryn Mawr College issues this statement of policy to inform the campus community of our programs to address domestic violence, dating violence, sexual assault and stalking as well as the procedures for institutional disciplinary action in cases of alleged dating violence, domestic violence, sexual assault, or stalking, which will be followed regardless of whether the incident occurs on or off campus when it is reported to a College official. 

After an incident of sexual assault, dating violence, or domestic violence, the victim should consider seeking medical attention as soon as possible at Bryn Mawr Hospital (Bryn Mawr Hospital is located at: 130 South Bryn Mawr Avenue, Bryn Mawr, PA 19010 (484) 337-3000) where a Rape Kit can be used to collect physical evidence or forensic evidence. A sexual assault nurse examiner (SANE) is a registered nurse (RN) who has specialized forensic training in treating sexual assault victims. They are usually available at Bryn Mawr hospital or on call 24-hours a day to help victims of sexual assault. They not only examine a victim as a health professional, but they approach their work with special sensitivity and knowledge about sex crimes, and they also assess, document, and preserve evidence for the legal aspects of their cases. Their work is vital to adequately serving victims of sexual assault, and their job is multi-faceted and specialized beyond typical medical examinations or emergency care. 

In Pennsylvania, evidence may be collected even if you chose not to make a report to law enforcement. (Lower Merion Police Department will be called by Bryn Mawr Hospital in all cases of sexual assault.)

It is important that a victim of sexual assault not bathe, douche, smoke, change clothing or clean the bed/linen/area where they were assaulted if the offense occurred within the past 96 hours so that evidence may be preserved that may assist in proving that the alleged criminal offense occurred or is occurring, or may be helpful in obtaining a protection order. In circumstances of sexual assault, if victims do not opt for forensic evidence collection, health care providers can still treat injuries and take steps to address concerns of pregnancy and/or sexually transmitted infections. Victims of sexual assault, domestic violence, stalking, and dating violence are encouraged to also preserve evidence by saving text messages, instant messages, social networking pages, other communications, and keeping pictures, logs or other copies of documents, if they have any, that would be useful to College Dean’s/investigators or police. 

As time passes, evidence may dissipate or become lost or unavailable, thereby making investigation, possible prosecution, disciplinary proceedings, or obtaining protection from abuse orders related to the incident more difficult. If a victim chooses not to make a complaint regarding an incident, the victim should consider speaking with Campus Safety or other local law enforcement to preserve evidence in the event that the victim decides to report the incident to law enforcement or the College at a later date to assist in proving that the alleged criminal offense occurred or that may be helpful in obtaining a protection order.

Involvement of Law Enforcement and Campus Authorities

Although the College strongly encourages all members of its community to report violations of this policy to law enforcement (including Campus Safety or local police), it is the victim’s choice whether or not to make such a report. Furthermore, victims have the right to decline to notify law enforcement. However, the College’s Investigator will assist any victim with notifying law enforcement if the victim so desires. Lower Merion Police Department may also be reached directly by calling (911) or 610-642-4200, or in person at 75 East Lancaster Avenue, Ardmore, PA 19003-2323.

Reporting Incidents of Domestic Violence, Dating Violence, Sexual Assault and Stalking

If you have been the victim of domestic violence, dating violence, sexual assault, or stalking, you should report the incident promptly to the Bi-Co Title IX Coordinator, Kimberly F. Taylor, located in Cambrian Row: Aelwyd, 2nd floor at Bryn Mawr College and in Founders 027 at Haverford College. Kimberly can be reached by calling at Bryn Mawr (610) 526 -7863 or Haverford at (610) 896-1234 or email titleix_coordinator@brynmawr.edu. Any victim may also go into the Dean’s Office and/or Campus Safety to report in person.

Reports of all domestic violence, dating violence, sexual assault and stalking made to Campus Safety will automatically be referred to the Title IX Coordinator for investigation regardless of if the complainant chooses to pursue criminal charges. Also, Campus Safety will inform the Dean of the College that an assault has occurred. If it is necessary to alert the community at large that an assault has taken place, both the Campus Safety Department and the Dean’s Office will make every effort to protect your privacy. If it is necessary to disclose confidential information (in cases involving legal requirements, requirements of the College’s Sexual Misconduct Policy, or if personal safety is at issue), the College will inform you that this is taking place.

As a reminder, Lower Merion Township Police can also provide transportation to Bryn Mawr Hospital and emergency medical care if necessary. If you do decide to report the assault to the police, the College will make every effort to provide a support person if you would like help through the process. Making a police report concerning the assault does not mean that you must prosecute the assailant.

Rights of Victims and the College’s Responsibilities for Protection From Abuse, “No Contact” Orders, Restraining Orders, or Similar Lawful Orders Issued by a Criminal, Civil, or Tribal Court or by the College

Bryn Mawr College complies with the Pennsylvania Protection from Abuse Act, which is the law in Pennsylvania recognizing protection from abuse (PFA) cases. Montgomery County, where Bryn Mawr College is located, is where you can obtain a PFA or take your State protection from abuse order to add Bryn Mawr College, Lower Merion Township to the order. By updating your existing protection from abuse or no contact order, it can be shared with Campus Safety, the Title IX Coordinator and the Lower Merion Police Department. You may then meet with Campus Safety to develop a Safety Action Plan, which is a plan for Campus Safety and the victim to reduce risk of harm while on campus or coming and going from campus. Some examples of arrangements are: escorts, special parking arrangements, changing classroom location, etc. The College cannot apply for a PFA on behalf of a victim.

The victim is required to apply directly for a Protection From Abuse (PFA) order at:

Montgomery County Courthouse
Norristown, PA 19404-0311
Phone: 610-278-3000

You must appear in person any day Monday through Friday from 8:30 a.m. to 1:30 p.m. To qualify for a PFA order, there must be either a family relationship or an intimate relationship with the person you want to file for protection from. The Protection from Abuse Department is located on the first floor of the Montgomery County Courthouse.

Accommodations and Protective Measures Available for Victims

Upon receipt of a report of domestic violence, dating violence, sexual assault or stalking, Bryn Mawr College will provide written notification to students and employees about accommodations available to them, including academic , living (change dorm or room), transportation (providing escorts) and working situations (changes in work location and or time). The written notification will include information regarding accommodations and obtaining protective measures. 

Other Resources

Protection from Abuse (PFA) department - 610-278-5977 or 610-292-5031
Women’s Center of Montgomery County - 610-279-1548
Women’s Center of Montgomery County 24-hour Hotline - 1-800-773-2424
Montgomery County Emergency Operation Center - 610-275-1222 (for after-hours requests) 
Laurel House 24/7 hotline - 800-642-3150

Confidentiality

Victims may request that directory information on file with the College be withheld. Please email the Registrar’s Office at registrar@brynmawr.edu if you have such a request.

The College does not publish the name of crime victims or other identifiable information regarding victims in the Daily Crime Log or in the annual crime statistics that are disclosed in compliance with the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act. Furthermore, if a Timely Warning Notice is issued on the basis of a report of domestic violence, dating violence, sexual assault or stalking, the name of the victim and other personally identifiable information about the victim will be withheld.


Title IX Introduction

Title IX of the Educational Amendments of 1972 prohibits any person in the United States from being discriminated against on the basis of sex in seeking access to any educational program or activity receiving federal financial assistance. The U.S. Department of Education, which enforces Title IX, has long defined the meaning of Title IX’s prohibition on sex discrimination broadly to include various forms of sexual harassment and sexual violence that interfere with a student’s ability to equally access educational programs and opportunities.

U.S. Department of Education Final Rule under Title IX

On May 19, 2020, the U.S. Department of Education issued a Final Rule under Title IX of the Education Amendments of 1972 that:

  • Defines the meaning of “sexual harassment” (including forms of sex-based violence),
  • Addresses how an institution must respond to reports of misconduct falling within that definition of sexual harassment, and
  • Mandates a grievance process that an institution must follow to comply with the law in these specific covered cases before issuing a disciplinary sanction against a person accused of sexual harassment.

See, 85 Fed. Reg. 30026 (May 19, 2020). The full text of the Final Rule and its extensive Preamble are available here: https://www.govinfo.gov/content/pkg/FR-2020-05-19/pdf/2020-10512.pdf.

Bryn Mawr College (“the College”) remains committed to addressing any violations of its policies, even those not meeting the narrow standards defined under the new Title IX Final Rule, and retains authority to investigate and adjudicate allegations under the policies and procedures defined within this Bryn Mawr College Sexual Misconduct Policy. 

Bi-College Policy Development

Bryn Mawr and Haverford Colleges (“the Colleges”) have a long-standing collaborative relationship which offers students comprehensive access to academics, student organizations, residence hall and dining facilities and social activities on both campuses. A free “Blue Bus” shuttle service makes regular stops at each campus every 30 minutes, providing easy and frequent access to all community members. Some academic programs and departments are provided only on one campus or structured to share resources between the two institutions. In 2016, the Colleges codified the Bi-College (“Bi-Co”) relationship with a Memorandum of Understanding to provide a formalized framework for ongoing collaboration.  Due to the complexity of the Title IX requirements, specific language in the Final Rule, and the sometimes overlapping nature of the Colleges’ Education Program and Activities, Bryn Mawr and Haverford Colleges will implement Sexual Misconduct Policies which are substantially the same, effective August 14, 2020.  The Colleges will jointly administer the procedures set forth in the Resolution Process of these Policies, as mutually agreed by the Colleges, if a Complainant is a student or employee of one College and the Respondent is a student or employee of the other College, if the Complainant is a student or employee of one College and the location of the alleged Sexual Misconduct is the other College, or if other facts and circumstances set forth in a Formal Complaint or in the investigation of such Formal Complaint suggest the need for joint administration of the Resolution Process.

Sexual Misconduct Policy

Bryn Mawr College is committed to ensuring that all members of the College community have a learning and working environment that is free from sexual misconduct. For purposes of this policy, the College defines Sexual Misconduct as acts described in one or both of the following broad categories:

1. “Title IX Sexual Harassment,” in accordance with the U.S. Department of Education Final Rule, includes any conduct on the basis of sex that is alleged to have occurred in a College Education Program or Activity, and is alleged to have been perpetrated against a person in the United States. The conduct alleged, if true, must satisfy one or more of the following conditions:

a. A College employee conditions the provision of an aid, benefit, or service on an individual’s participation in unwelcome sexual conduct;

b. Unwelcome conduct a reasonable person would determine to be so severe, pervasive, and objectively offensive such that it effectively denies a person equal access to the College’s Programs or Activities;

c. Sexual Assault, as defined in 20 U.S.C. § 1092(f)(6)(A)(v), meaning any sexual act directed against another person, without the consent of the victim, including instances where the victim is incapable of giving consent (such as incapacitation, age, family relation to the other party, or intellectual or other disability).  Sexual Assault can be committed by or against individuals of any sex or gender and can occur between individuals of the same sex/gender or different sexes/genders.  As required by the Title IX Final Rule, the College will rely on the following definitions of Sexual Assault:

i. sexual intercourse with another person, including oral or anal sexual intercourse, or the use of any body part or an object or instrument to unlawfully penetrate, however slightly, the genital or anal opening of the body of another person, without consent of the victim, including instances where the victim is incapable of giving consent  because of their age or because of their temporary or permanent mental or physical incapacity;

ii. touching of the private body parts of another person for the purpose of sexual gratification, without the consent of the victim, including instances where the victim is incapable of giving consent because of their age or because of their temporary or permanent mental or physical incapacity;

iii. sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law; or

iv. sexual intercourse with a person who is under the statutory age of consent.

d. Dating Violence, as defined in 34 U.S.C. § 12291(a)(1)), meaning any act of violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim and where the existence of such a relationship is determined based on a consideration of the length, type, and frequency of interactions between the persons involved in the relationship.

e. Domestic Violence, as defined in 34 U.S.C. § 12291(a)(8), meaning a felony or misdemeanor crime of violence committed by a current or former spouse or intimate partner of the victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, by a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant monies, or by any other person against an adult or youth victim who is protected from that person's acts under the domestic or family violence laws of the jurisdiction. 

f. Stalking, as defined in 34 U.S.C. 12291(a)(30), meaning engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for their safety or the safety of others or suffer substantial emotional distress.

2. “Other Gender-Based Misconduct,” defined as acts which do not meet the narrow definition of “Title IX Sexual Harassment,” as defined above, but nevertheless could constitute discrimination on the basis of sex. Other Gender-Based Misconduct, which is alleged to have occurred by or against any member of the College community, regardless of the location of the alleged action, includes: 

a. Sexual Assault, Dating Violence, Domestic Violence, and Stalking as defined in 1c, d, e, and f (above).

b. Unwelcome conduct of a sexual nature, including but not limited to unwelcome sexual advances, requests for sexual favors, or other verbal or nonverbal conduct of a sexual nature that is sufficiently serious, pervasive, or persistent as to create an intimidating, hostile, humiliating, demeaning, or sexually offensive working, academic, residential, or social environment under both an objective and subjective standard. 

c. Sexual exploitation, defined as occurring when a person abuses or exploits another person’s sexuality for the purpose of sexual gratification, financial gain, personal benefit or advantage, or any other non-legitimate purpose without that person’s consent. The act or acts of sexual exploitation are prohibited even though the behavior does not constitute one of the other sexual misconduct offenses.

Examples of sexual exploitation include:

  • observing another individual’s nudity or sexual activity or allowing another to observe consensual sexual activity in a place where that person would have a reasonable expectation of privacy, without that person’s consent;
  • recording, and/or distributing (including streaming) of images, photography, video, or audio recording of sexual activity or nudity, or distribution of such without that person’s consent; 
  • prostituting another individual; 
  • exposing one’s genitals in non-consensual circumstances; 
  • knowingly exposing another individual to a sexually transmitted disease or virus without that individual’s knowledge; and 
  • inducing incapacitation for the purpose of making another person vulnerable to non-consensual sexual activity.

General Rules of Application

The above-referenced acts are considered sexual discrimination. Title IX of the Educational Amendments of 1972, 20 U.S.C. §§1681-1688 (“Title IX”), prohibits discrimination on the basis of sex in Education Programs and Activities operated by recipients of federal financial assistance, including Bryn Mawr College.   This Policy is intended to meet the College’s obligations under Title IX; the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (“Clery Act”), as amended by the Violence Against Women Reauthorization Act of 2013 (“VAWA”), with respect to its application to sex-based misconduct; and other applicable law and regulations.

Consistent with Title IX requirements, Bryn Mawr College does not discriminate on the basis of sex in its Education Programs or Activities (including in admissions and employment).  College community members have the right to be free from all forms of sexual harassment and violence. All College community members are expected to conduct themselves in a manner that does not infringe upon the rights of others. The College has zero tolerance for sexual misconduct, and this Policy applies to all employees and students. Non-members of the campus community who engage in discriminatory actions within College programs or on College property are not under the jurisdiction of this policy, but can be subject to actions that limit their access and/or involvement with College programs as the result of their misconduct.

Reports of Sexual Misconduct committed by any student or employee (including faculty and staff) of the Bryn Mawr community will be resolved according to the procedures outlined in this Policy, unless otherwise noted.

Effective Date

This Sexual Misconduct Policy is effective on August 14, 2020 and will apply to Formal Complaints of Sexual Misconduct brought on or after August 14, 2020. Formal Complaints brought prior to August 14, 2020 will be investigated and adjudicated according to previous College policies.

Non-Discrimination in Application

The requirements and protections of this Policy apply equally regardless of sex, sexual orientation, gender identity, gender expression, or other protected classes covered by federal or state law. All requirements and protections are equitably provided to individuals regardless of such status or status as a Complainant, Respondent, or Witness. Individuals who wish to file a complaint about this Policy or processes set forth herein may contact the Department of Education’s Office for Civil Rights using contact information available at https://ocrcas.ed.gov/contact-ocr

Disability Accommodations

This Policy does not alter any College obligations under federal disability laws including the Americans with Disabilities Act of 1990, and Section 504 of the Rehabilitation Act of 1973. Parties may request reasonable accommodations, that do not fundamentally alter the Resolution Process, for disclosed disabilities to the Title IX Coordinator at any point before or during the Process. The Title IX Coordinator will not affirmatively provide disability accommodations that have not been specifically requested by the Parties, even where the Parties may be receiving accommodations in other College programs and activities. 

Alcohol and Drug Use Amnesty

The health and safety of every student is of utmost importance. The College recognizes that students who have been drinking and/or using drugs (whether such use is voluntary or involuntary) at the time Sexual Misconduct occurs may be hesitant to report such incidents due to fear of potential consequences for their own conduct. The College strongly encourages students to report incidents of Sexual Misconduct. An individual who experiences Sexual Misconduct, or a Witness to such Sexual Misconduct, acting in good faith, who discloses any incident of Sexual Misconduct to College officials or law enforcement will not be sanctioned under College codes of conduct for violations of alcohol and/or drug use policies occurring at or near the time of the incident(s) of Sexual Misconduct. The College may request that the individual attend an approved alcohol or drug education program, without assessing any charges for such program. This amnesty provision also applies to student groups making a report of Sexual Misconduct. Amnesty does not preclude or prevent action by police or other legal authorities pursuant to relevant state or federal criminal statutes.

Policy Definitions

Advisor: An Advisor is any individual who has been chosen by a Party or designated by the College to provide support and guidance during the resolution process. The specific role of the Advisor is explained under the Resolution Process section of the Policy.

Complainant: A Complainant is any individual who has reported being or is alleged to be the victim of conduct that could constitute Sexual Misconduct as defined under this Policy.

Confidential Resource: A Confidential Resource is a College employee who is not required to report notice of sexual harassment to the Title IX Coordinator.  References made to confidentiality refer to the ability of identified confidential resources to not report crimes and violations to law enforcement or College officials without permission, except for extreme circumstances, such as a health and/or safety emergency or child abuse. Lists of Confidential Resources are available on the Bryn Mawr College webpage.

Consent: Consent to engage in sexual activity must be informed, knowing and voluntary; consent must exist from the beginning to end of each instance of sexual activity and for each form of sexual contact. Consent is demonstrated through mutually understandable words and/or actions that clearly indicate a willingness to engage freely in sexual activity. Consent is active, not passive. 

Guidance for Consent

  • Prior to initiating a sexual encounter, one is expected to obtain consent to each act of sexual activity prior to initiating such activity. Consent to one form of sexual activity does not constitute consent to engage in all forms of sexual activity. 
  • Either party may withdraw consent at any time. Withdrawal of consent should be outwardly demonstrated by words or actions that clearly indicate a desire to end sexual activity. Once withdrawal of consent has been expressed, sexual activity must cease. 
  • Consent consists of an outward demonstration indicating that an individual has freely chosen to engage in sexual activity. Relying on non-verbal communication can lead to misunderstandings. Consent may not be inferred from silence, passivity, lack of resistance, or lack of an active response alone. A person who does not physically resist or orally refuse sexual activity is not necessarily giving consent. 
  • When consent is requested orally, absence of any explicit oral response constitutes lack of consent. An oral “no” constitutes lack of consent, even if it sounds insincere or indecisive. 
  • If at any time during the sexual activity, any confusion or ambiguity arises as to the willingness of the other individual to proceed, both parties should stop and clarify orally the other’s willingness to continue before continuing such activity. 
  • Individuals with a previous or current intimate relationship do not automatically give either initial or continued consent to sexual activity. Even in the context of a relationship, there must be mutually understandable communication that clearly indicates a willingness to engage in each sexual activity. 
  • Consent to engage in sexual activity with one person does not imply consent to engage in sexual activity with another person. 
  • Consent is not effective if it results from the use or threat of physical force, intimidation, or coercion, or any other factor that would eliminate an individual’s ability to exercise their own free will to choose whether or not to have sexual contact. 
  • An individual who is physically incapacitated from alcohol or other drug consumption (voluntarily or involuntarily) or is asleep, unconscious, unaware, or otherwise physically helpless is considered unable to give consent. 
  • In the Commonwealth of Pennsylvania, the age of majority is 18. Under state law, consent cannot be given by minors under the age of 13 and can only be given by a minor under the age of 16, if the other party is less than four (4) years older than the minor. 

Education Program or Activity includes:

  • Any Bryn Mawr College on-campus premises
  • Any off-campus premises over which the College has substantial control over the Respondent and the context in which the Sexual Misconduct occurred. This includes buildings or property owned or controlled by a recognized student organization.
  • Any activity occurring within computer and internet networks, digital platforms, and computer hardware or software owned or operated by, or used in the operations of College programs and activities over which the College has substantial control.

Formal Complaint 

A Formal Complaint is a document – including an electronic submission—filed by a Complainant with a signature or other indication that the Complainant is the person filing the Formal Complaint, or a document signed by the Title IX Coordinator, alleging Sexual Misconduct against a Respondent within the College’s Education Program or Activity and requesting initiation of the College’s Resolution procedures consistent with this Sexual Misconduct Policy to investigate the allegation of Sexual Misconduct. 

Hearing Panel 

The Hearing Panel is the group of individuals appointed by the College with authority to determine responsibility and sanctioning (if applicable) for violation of this Sexual Misconduct Policy.

Investigator

The Investigator is the individual or individuals appointed by the College to gather evidence and facts related to the allegation of Sexual Misconduct. The Investigator(s) will provide an investigative report summarizing all relevant evidence for review by both the Complainant and Respondent.

Privacy

References made to privacy mean the actions of College employees, who cannot guarantee confidentiality, to maintain privacy to the greatest extent possible. Information disclosed will be relayed only as necessary to investigate and/or seek a resolution and to notify the Title IX Coordinator or designee, who is responsible for tracking patterns and spotting systemic issues. The College will limit disclosure as much as practicable, even if the Title IX Coordinator determines that a request for confidentiality cannot be honored. The privacy of student education records will be protected in accordance with the Family Educational Rights and Privacy Act (FERPA), as outlined in the Bryn Mawr College FERPA policy. Employee privacy will be protected in accordance with Bryn Mawr Faculty and Staff Handbooks.

Resolution Process 

The Resolution Process is a formal resolution process to address reported conduct that may be a violation of this Sexual Misconduct Policy.

Respondent 

A Respondent is any individual who has been reported to be the perpetrator of conduct that could constitute Sexual Misconduct as defined under this Policy.

Reporting Sexual Misconduct to the College

Any person may report Sexual Misconduct in person, by mail, by telephone, or by electronic mail, using the contact information listed for the Title IX Coordinator, or by any other means that results in the Title IX Coordinator receiving the person’s oral or written report. 

Such a report may be made at any time (including during non-business hours) via the Bryn Mawr Online Reporting Form, or by mail to the office address listed for the Title IX Coordinator. The Online Reporting Form will provide a link to this Policy, as well as encourage individuals to review this Policy for more information about procedures and resources.

Individuals who report Sexual Misconduct in Pennsylvania will also be informed of their rights as a victim of crime under Pennsylvania law.

Once an individual provides a report of Sexual Misconduct, the report will be reviewed by the Title IX Coordinator. At this stage, only the Title IX Coordinator will have access to the report, and they will share the information on a limited basis as required to take the appropriate next steps. Using the information gathered through the Online Reporting Form, the College will promptly contact the Complainant to discuss appropriate Supportive Measures and to explain the process for filing a Formal Complaint and that Supportive Measures are available with or without the filing of a Formal Complaint. Complainants are not required to respond to outreach from the College and the College will respect this decision, with limited exceptions where it is obligated by law or to act in the safety interest of the community. 

Only individuals authorized by the College may enter, update, access, share, or disseminate the electronic data collected, created, or maintained from the Online Reporting Form. 

Anonymous Reports 

An individual may make a report of Sexual Misconduct to the Title IX Coordinator, and if preferred, may do so without disclosing one’s name using the online reporting form listed above and here.

Bryn Mawr Online Anonymous Reporting Form

Depending on the level of information available about the incident or the individuals involved, the College’s ability to respond to an anonymous report may be limited. The College will, however, take whatever steps it deems appropriate and in the best interest of the overall College community, consistent with the information available. The College will never refuse to respond on the grounds that a report was made anonymously. 

Information collected through the anonymous reporting line will be shared only with necessary College officials in order to respond to the reported concern. Information is kept confidential and no personally identifiable information is shared, except as necessary to follow this Policy, without the reporting party’s consent.

Title IX Coordinator

The Title IX Coordinator provides supervision and management of the College’s efforts to address and resolve incidents of sexual and gender-based discrimination.  The Bi-College Title IX Coordinator is:

Kimberly F. Taylor
Bi-Co Title IX Coordinator
Haverford and Bryn Mawr Colleges
ktaylor4@haverford.edu
Office location: Bryn Mawr College, Cambrian Row: Aelwyd, 2nd floor; Phone: 610-526-7863

At Bryn Mawr College, the Title IX Coordinator has reporting responsibilities to: 

Jennifer Walters
Dean of the College
Bryn Mawr College
jlwalters@brynmawr.edu

Support and Resources

Supportive Measures

Supportive Measures are non-disciplinary, non-punitive, and individualized services that the College offers and may put in place, without fee or charge, after receiving notice of possible violations of this Policy.  Supportive Measures are designed to restore or preserve access to the College’s Education Program and Activity, protect the safety of all Parties and the College’s educational environment, and/or deter Sexual Misconduct, while not being punitive in nature or unreasonably burdening any Party. 

Both Complainants and Respondents have the right to receive Supportive Measures from the College regardless of whether a Formal Complaint has been filed.  The Title IX Coordinator will contact a Complainant after receiving notice of possible violation of this Policy (1) to discuss the availability of Supportive Measures and (2) to explain that Supportive Measures are available with or without the filing of a Formal Complaint of Title IX Sexual Harassment.  The Title IX Coordinator will consider the Complainant’s wishes with respect to implementation of Supportive Measures.  

To determine the appropriate Supportive Measure(s) to be implemented, the College will conduct an individualized assessment based on the unique facts and circumstances of a situation.   Whether a possible Supportive Measure would unreasonably burden the other Party is a fact-specific determination made by the College in its discretion that takes into account the nature of the Education Program and Activity, opportunities and benefits in which an individual is participating.    
Examples of Supportive Measures may include, as appropriate and as reasonably available: 

  • referral to counseling or medical services
  • extensions of deadlines or other course-related adjustments
  • modifications of work or class schedules
  • campus escort services
  • restrictions on contact between the Parties (no contact orders)
  • changes in work or housing locations
  • leaves of absence
  • increased security and monitoring of certain areas of the campus

Supportive Measures will remain private to the extent possible. Some College officials will be notified of Supportive Measures as needed for implementation.

The Title IX Coordinator will ultimately serve as the point of contact for any individual requesting Supportive Measures. 

Supportive Resources  

On-Campus Resources

Counseling Services
Reggie Jones, Associate Dean of Health and Wellness | rjones@brynmawr.edu
610-526-7360 (M-F, 9 a.m.-5 p.m.) | 610-526-7778 (After hours counselor on call)

Health and Wellness Center
Beth Kotarski, Medical Services Director | bkotarski@brynmawr.edu | 610-526-7360

Campus Safety | 610-526-7911
 
Dean’s Office Staff | 610-526-5375

Visa and Immigration Assistance

Patricia Lausch, Assistant Dean of International Student and Scholar Advising, The Pensby Center | plausch@brynmawr.edu | 610-526-7390

Regional Resources

National Resources

Emergency Removal 

The College may remove a Respondent from the College’s Education Program or Activity on an emergency basis, where the College (1) undertakes an individualized safety and risk analysis and (2) determines that an immediate threat to the physical health or safety of any student or other individual arising from the allegations of Sexual Misconduct justifies a removal.

If a College official determines such removal is necessary, the Respondent will be provided notice and an opportunity to appeal the decision immediately following the removal.  

Administrative Leave

The College retains the authority to place a non-student employee Respondent on administrative leave during the pendency of the Resolution Process, consistent with Bryn Mawr Faculty and Staff Handbooks.  An employee will not be placed on administrative leave unless and until a Formal Complaint of Sexual Misconduct has been filed with the College.

Resolution Process

Filing a Formal Complaint

The timeframe for the College’s Resolution Process begins with the filing of a Formal Complaint. The Resolution Process will be concluded within a reasonably prompt manner, and in ordinary cases no longer than ninety (90) business days after the filing of the Formal Complaint. The phrase “business days” shall refer to those days ordinarily recognized by the College’s administrative calendar as workdays. The Process may be extended for a good reason, including but not limited to 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. Parties may submit a written request for an extension to the Title IX Coordinator.  

To file a Formal Complaint, a Complainant must provide the Title IX Coordinator a written, signed complaint describing the facts alleged. If a Complainant does not wish to make a Formal Complaint in connection with a report of Sexual Misconduct, the Title IX Coordinator may, in their discretion, determine a Formal Complaint is necessary and sign the Formal Complaint.  When the Title IX Coordinator signs a Formal Complaint, the Title IX Coordinator is not the Complainant or otherwise a Party.  The Title IX Coordinator will inform the Complainant of this decision in writing, and the Complainant need not participate in the process further, but the Complainant will still be treated as a Party entitled to inspect and review evidence and to receive all notices, including the notice of allegations, the notice of Hearing, and the notice of outcome. At no time will the College coerce or retaliate against a Complainant or any Party or Witness in order to convince the Complainant or any Party or Witness to participate in the Resolution Process.

Nothing in this Sexual Misconduct Policy prevents a Complainant from seeking the assistance of state or local law enforcement alongside the appropriate on-campus process.

A Complainant who files a Formal Complaint may elect (if all Parties and the College agree), at any time, to address the matter through an Alternative Resolution Process.

Multi-Party or Multi-Allegation Situations

In its discretion, the College may consolidate Formal Complaints alleging Sexual Misconduct against more than one Respondent, or by more than one Complainant against one or more Respondents, or by one Party against the other Party, where the allegations arise out of the same facts or circumstances. In addition, the College has discretion to consolidate allegations of other forms of misconduct should they occur in the same incident.  If Formal Complaints involving multiple Complainants, multiple Respondents, or multiple allegations are consolidated, each Party will have access to all of the information being considered including as provided by all involved Complainants, all involved Respondents, and all involved Witnesses. The decision to consolidate Formal Complaints is not subject to appeal.

Determining Jurisdiction and Mandatory Title IX Dismissal

The Resolution Process will apply to a Formal Complaint if, in the reasonable determination of the Title IX Coordinator, the alleged conduct fits the definition of Sexual Misconduct as defined in this Policy, i.e., the alleged conduct is “Title IX Sexual Harassment” and/or “Other Gender-Based Misconduct,” as defined herein. In addition, a Complainant filing a Formal Complaint of Title IX Sexual Harassment must be participating, or attempting to participate, in the College’s Education Programs and Activities at the time the Formal Complaint is filed in order for the Formal Complaint to be considered Title IX Sexual Harassment for purposes of the Resolution Process. If the Complainant is not participating or attempting to participate in a College Education Program or Activity, the College will dismiss the Complaint for Title IX purposes and treat the Formal Complaint as one of Other Gender-Based Misconduct.

If the alleged conduct does not meet these definitions, the Title IX Coordinator will, in consultation with the Dean of the Undergraduate College (for student-related Complaints) or the Director of Human Resources (for employee-related Complaints) determine the appropriate process for resolution. 

Discretionary Title IX Dismissal of Complaint

The Title IX Coordinator may, in their discretion, dismiss a Formal Complaint brought under this Sexual Misconduct Policy, or any specific allegations raised within that Formal Complaint, at any time during the Investigation or Hearing, if:

  • A Complainant notifies the Title IX Coordinator in writing that they would like to withdraw the Formal Complaint, or any allegations raised in the Formal Complaint;
  • The respondent is no longer enrolled or employed by Bryn Mawr College or,
  • If specific circumstances prevent the College from gathering evidence sufficient to reach a determination regarding the Formal Complaint or allegations within the Formal Complaint.

The College retains discretion on a case-by-case basis to dismiss a Formal Complaint based on any of the above reasons.  Just because one or all of the conditions above are satisfied, does not mean the College will automatically dismiss the Formal Complaint.  Instead, the College will determine if such a decision is appropriate under the circumstances. 

Notice of Dismissal

Upon reaching a decision that the Formal Complaint will be dismissed, the College will promptly send written notice of the dismissal of the Formal Complaint or any specific allegation within the Formal Complaint, and the reason for the dismissal, simultaneously to the Parties through their College email accounts if they are a student or employee, and by other reasonable means if they are neither. It is the responsibility of Parties to regularly check their email accounts.

Any Party may appeal a dismissal determination using the process set forth in “Appeals” section of this Policy.

Withdrawal or Resignation While Charges are Pending 

Should a student withdraw from the College or refuse to participate in the Resolution Process, the College reserves the right to continue with the Formal Complaint in the student’s absence. A determination of responsibility that results in a student’s suspension or expulsion will be noted on that student’s official transcript.

Should an employee resign with unresolved allegations pending, Human Resources records will reflect that status, and the College reserves the right to continue with a Formal Complaint in the employee’s absence.

Notice of Allegations

The Title IX Coordinator will draft and provide the Notice of Allegations to any Party to the allegations of Sexual Misconduct. Such notice will occur as soon as practicable after the College receives a Formal Complaint of the allegations if there are no extenuating circumstances.

The Parties will be notified simultaneously by their College email accounts if they are a student or employee, and by other reasonable means if they are neither. The College will provide sufficient time for the Parties to review the Notice of Allegations and prepare a response before any initial interview.

Contents of Notice

The Notice of Allegations will include the following:

  • Notice of the College’s Sexual Misconduct Policy and a hyperlink to a copy of the Policy.
  • Notice of the allegations potentially constituting Sexual Misconduct, and sufficient details known at the time the Notice is issued, such as the identities of the Parties involved in the incident, if known, including the Complainant, the conduct allegedly constituting Sexual Misconduct, and the date and location of the alleged incident, if known.
  • A statement that the Respondent is presumed not responsible for the alleged conduct and that a Determination Regarding Responsibility will be made at the conclusion of the Resolution Process.
  • A statement that the Parties may have an Advisor of their choice, who may be, but is not required to be, an attorney.
  • A statement that before the conclusion of the Investigation, the Parties may inspect and review 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 College does not intend to rely in reaching a Determination Regarding Responsibility, and evidence that both tends to prove or disprove the allegations, whether obtained from a Party or other source.
  • Information regarding the availability of support and assistance through College resources and the opportunity to meet with the Title IX Coordinator in person to discuss resources, rights, and options.
  • A statement that the College explicitly prohibits Retaliation by or against the Complainant, the Respondent, and Witnesses, that the College will take prompt action if Retaliation is reported, and instructions regarding how to report acts of alleged Retaliation.

Advisors

Parties participating in the Formal Resolution Process as a Complainant or Respondent may be accompanied by an Advisor to any meeting or hearing to which they are required or are eligible to attend. The Advisor is not an advocate. Except where explicitly stated in this Policy, as consistent with the Department of Education’s Final Rule, Advisors shall not participate directly in the process. 

The College will reasonably attempt to accommodate meetings and hearings on dates when Advisors are available, provided that an Advisor acts reasonably in providing available dates and works collegially to find dates and times that meet all schedules. 

The College’s obligation to investigate and adjudicate in a prompt timeframe under Title IX and other College policies apply to matters governed by this Policy, and the College cannot agree to extensive delays solely to accommodate the schedule of an Advisor. The determination of what is reasonable shall be made by the Title IX Coordinator or designee. The College will not be obligated to delay a meeting or Hearing under this process more than five (5) days due to the unavailability of an Advisor, and may offer the Party the opportunity to obtain a different Advisor or utilize one provided by the College.

The College will provide the Parties equal access to Advisors and support persons; any restrictions on Advisor participation will be applied equally.

Alternative Resolution 

Parties who do not wish to proceed with an Investigation and live Hearing, and instead seek the College’s assistance to resolve allegations of Sexual Misconduct, may elect to enter the Alternative Resolution Process. Generally speaking, these resolution options are less time intensive than an Investigation and Hearing, while still affording an opportunity to actively participate in a process for resolution of Complaints.

Parties may elect to enter an Alternative Resolution Process at any time after the filing of the Formal Complaint and prior to a Determination Regarding Responsibility through an informed written consent. This informed written consent will include all terms of the elected alternative process, including a statement that any agreement reached through the process is binding on the Parties.

All Parties must agree on the form of Alternative Resolution, and the Title IX Coordinator or designee must approve the decision to commence an Alternative Resolution Process and may determine that Alternative Resolution is not appropriate under the circumstances. Factors in considering the appropriateness of the Alternative Resolution Process include, but are not limited to, the gravity of the allegations, whether there is an ongoing threat of harm or safety to the campus, whether the Respondent is a repeat offender, and whether the Parties are participating in good faith. This determination is not subject to appeal. 

Alternative Resolution is only permitted to address allegations of student-on-student sexual harassment and is never allowed as an option to resolve allegations that an employee sexually harassed a student. 

At any time after the commencement of the Alternative Resolution Process, the College may determine that the Alternative Resolution Process is not an appropriate method for resolving the matter and may require that the matter be resolved through the Formal Process. This determination is not subject to appeal. In addition, either Party may elect to leave the Alternative Resolution Process at any point prior to reaching a resolution. If a Party elects to leave the Alternative Resolution Process, the Formal Resolution Process may recommence, if necessary. 

Role of the Alternative Resolution Facilitator

Alternative Resolution Processes are managed by Facilitators, who must not have a conflict of interest or bias in favor for or against Complainants or Respondents generally or regarding the specific Parties in the matter.

Facilitators have training in the definitions of Sexual Misconduct, the scope of the College’s Education Program or Activity, how to conduct Alternative Resolution Processes, and how to serve impartially, including by avoiding prejudgment of the facts at issue, conflicts of interest, or bias.

Confidentiality 

In entering the Alternative Resolution Process, the Parties agree that any testimony and evidence (including admissions of responsibility) they share or receive during the Alternative Resolution Process concerning the allegations of the Formal Complaint is confidential. No evidence concerning the allegations obtained within the Alternative Resolution Process may be disseminated to any person, provided that any Party to the Alternative Resolution Process may generally discuss the allegations under investigation with a parent, friend, advisor, or other source of emotional support, or with an advocacy organization. As a condition of entering the Alternative Resolution Process, any evidence shared or received during the Alternative Resolution Process may not be used in any subsequent Formal Resolution Process or College Appeal. 

Alternative Resolution Options

The College offers the following Alternative Resolution options for addressing Formal Complaints of Sexual Misconduct:

Administrative Resolution

Should the Parties mutually determine to enter the Alternative Resolution Process, and the Respondent elects to accept responsibility for the allegations of the Formal Complaint at any point during the Alternative Resolution Process, the College may administratively resolve the Formal Complaint. 

Where the Respondent admits responsibility, the Parties will receive simultaneous written notification of the acceptance of responsibility, and a Hearing Panel will convene to determine the Respondent’s sanction and other remedies, as appropriate and consistent with College policy. The Parties will be given an opportunity to be heard at a sanctions hearing, including but not limited to the submission of impact statements. Parties may be accompanied by their Advisor but questioning of Parties or Witnesses will not be permitted. The Parties will receive simultaneous written notification of the decision regarding sanctions and remedies, which may be appealed according to the Appeal Process.

Facilitated Resolution

The purpose of Facilitated Resolution is for the Parties who are in conflict to identify the implications of a student’s actions and, with the assistance of a trained Facilitator, identify points of agreement and appropriate remedies to address them. Either Party can request Facilitated Resolution to seek resolution; however, Facilitated Resolution will be used only with the consent of both Parties. The Parties will be instructed not to contact one another during the process. The Title IX Coordinator will review any request for Facilitated Resolution and may, in their discretion, decline to mediate based on the facts and circumstances of the particular case. Either Party has the right to terminate the Facilitated Resolution process and choose or resume another option for resolution at any time. 

During Facilitated Resolution, any potential Investigation will halt, and calculations for time frames will be stayed. If the Facilitated Resolution results in a resolution, the disciplinary process will be concluded, and the matter will be closed. If a resolution cannot be reached, the matter will be referred back to the Title IX Coordinator to re-evaluate other options for resolution, including Investigation.

During Facilitated Resolution, a Facilitator will guide a discussion between the Parties.  In circumstances in which the Parties do not wish to meet face-to-face, either Party can request “caucus” Facilitated Resolution, and the Facilitator will conduct separate meetings. Whether or not the Parties agree to meet face-to-face, each Party will be permitted to bring an Advisor of their choice to any meetings. The Advisor may provide private guidance during the Facilitated Resolution but may not actively participate in the discussion between the Complainant and Respondent.

At the conclusion of the Facilitated Resolution, the Facilitator will memorialize the agreement that was reached between the Parties.  The Title IX Coordinator maintains records of any resolution that is reached, and failure to abide by the resolution can result in appropriate enforcement actions.

Formal Resolution Process

Notice of Meetings and Interviews

The College will provide, to a Party whose participation is invited or expected, written notice of the date, time, location, participants, and purpose of all Hearings, investigative interviews, or other meetings with a Party, with sufficient time for the Party to prepare to participate.

Request for Delay

Each Party may request a one-time delay in the Resolution Process of up to five (5) days for good cause (granted or denied in the judgment of the Title IX Coordinator, in consultation with the Dean of the College or Director of Human Resources, as appropriate), provided that the requestor provides reasonable notice and the delay does not overly inconvenience other Parties.

The Title IX Coordinator shall have sole judgment to grant further pauses in the Process. 

Investigation 

General Rules of Investigations

The Investigator(s) will perform an Investigation under a reasonably prompt timeframe of the conduct alleged to constitute Sexual Misconduct after issuing the Notice of Allegations. 

The College, and not the Parties, bears the burden of proof and the burden of gathering evidence, (i.e., the responsibility of showing a violation of this Policy has occurred). This burden does not rest with either Party, and either Party may decide not to share their account of what occurred or may decide not to participate in an Investigation or Hearing. This does not shift the burden of proof away from the College and does not indicate responsibility. 

The College cannot access, consider, or disclose medical records without a waiver from the Party (or parent, if applicable) to whom the records belong or of whom the records include information. The College will provide an equal opportunity for the Parties to present Witnesses, including fact and expert Witnesses, and other inculpatory and/or exculpatory evidence (i.e., evidence that tends to prove or disprove the allegations, respectively), as described below.

Ongoing Notice 

If, in the course of an Investigation, the College decides to investigate allegations about the Complainant or Respondent that are not included in the original Notice of Allegations and otherwise fall within this Sexual Misconduct Policy, the College will notify the Parties whose identities are known of the additional allegations by their College email accounts or other reasonable means.

The Parties will be provided sufficient time to review the additional allegations to prepare a response before any initial interview regarding those additional charges.

Review of Evidence

Prior to the completion of the Investigative Report, the Parties and their Advisors will have an equal opportunity to inspect and review the evidence obtained through the Investigation. The purpose of the inspection and review process is to allow each Party the equal opportunity to meaningfully respond to the evidence prior to conclusion of the Investigation.
Evidence that will be available for inspection and review by the Parties will be any evidence that is directly related to the allegations raised in the Formal Complaint. It will include any:

  1. Evidence that is directly related to the allegations in the Formal Complaint, even if that evidence does not end up being relied upon by the College in determining responsibility;
  2. Inculpatory or exculpatory evidence that is directly related to the allegations, whether obtained from a Party or other source.

All Parties must submit any evidence they would like the Investigator to consider prior to when the Parties’ time to inspect and review evidence begins. 

The College will send the evidence made available for each Party and their Advisors to inspect and review. The College is not under an obligation to use any specific process or technology to provide the evidence and shall have the sole discretion in terms of determining format and any restrictions or limitations on access.

The Parties will have ten (10) business days to inspect and review the evidence and submit a written response by email to the Investigator. The Investigator will consider the Parties’ written responses before completing the Investigative Report. 
Any evidence subject to inspection and review will be available at any Hearing, including for purposes of questioning.
The Parties and their Advisors must sign an agreement not to disseminate any of the evidence subject to inspection and review or use such evidence for any purpose unrelated to the Resolution Process. 

Evidence obtained in the Investigation that is determined in the reasoned judgment of the Investigator not to be directly related to the allegations in the Formal Complaint will be included in the appendices to the Investigative Report and may be appropriately redacted before the Parties’ inspection to avoid disclosure of personally identifiable information of a student. 

Investigative Report

The Investigator will create an Investigative Report that accurately summarizes relevant evidence. The Investigative Report is not intended to catalog all evidence obtained by the Investigator, but only to provide an accurate summary of the relevant evidence.

Only relevant evidence (including both inculpatory and exculpatory) will be referenced in the Investigative Report. 

The Investigator may redact irrelevant information from the Investigative Report when that information is contained in documents or evidence that is/are otherwise relevant.

Hearing

General Rules of Hearings

The College will not issue a disciplinary sanction arising from an allegation of Sexual Misconduct without holding a Hearing and permitting an Appeal, unless otherwise resolved through an Alternative Resolution Process.

The Hearing may be conducted with all Parties physically present in the same geographic location, or, at the College’s discretion, any or all Parties, Witnesses, and other participants may appear at the Hearing virtually through video conference. This technology will enable participants simultaneously to see and hear each other. At its discretion, the College may delay or adjourn a Hearing based on technological errors not within a Party’s control. 

Continuances or Granting Extensions

The College may determine that multiple sessions or a continuance (i.e., a pause on the continuation of the Hearing until a later date or time) is needed to complete a Hearing. If so, the College will notify all participants and endeavor to accommodate all participants’ schedules and complete the Hearing as promptly as practicable.

Participants in the Hearing

Hearings are not public, and only the following individuals are permitted to participate:

Complainant and Respondent (“the Parties”)

  • The Parties cannot waive the right to a Hearing except by participating in an Alternative Resolution.
  • The College may still proceed with the Hearing in the absence of a Party and may reach a Determination Regarding Responsibility in their absence, including through any evidence gathered that does not constitute a “statement” by that Party. 

    For example, an oral or written statement constituting part or all of the Sexual Misconduct itself is not a “prior statement” that must be excluded if the maker of the statement does not submit to questioning about that statement. In other words, a prior statement would not include a document, audio recording, audiovisual reading, and digital media, including but not limited to text messages, emails, and social media postings, that constitute the conduct alleged to have been the act of sexual harassment under the Formal Complaint. 
     
  • The decision-maker cannot draw an inference about the Determination Regarding Responsibility based solely on a Party’s absence from the Hearing or refusal to answer questions. 
  • Advisors shall be subject to this Policy’s Rules of Decorum and may be removed in the discretion of the Hearing Panel upon violation of those Rules.

The Hearing Panel

  • The Hearing Panel will consist of three (3) trained decision-makers, a Panel Chair and two Panel members. The Panel Chair may be a College administrator or an outside consultant, contracted by the College. Panel members will be appointed administrators or faculty members.
  • No member of the Hearing Panel will also have served as the Title IX Coordinator, Title IX Investigator, Advisor to or Witness for any Party in the case. 
  • No member of the Hearing Panel may serve on the Appeals body in the case.
  • No member of the Hearing Panel will have a conflict of interest or bias in favor of or against Complainants or Respondents generally, or in favor or against the Parties to the case.
  • The Hearing Panel will be trained on topics including how to serve impartially, issues of relevance, how to apply the rape shield protections provided for Complainants, and any technology to be used at the Hearing. 
  • The Parties will have an opportunity to raise any objections regarding a Hearing Panel member’s actual or perceived conflicts of interest or bias at the commencement of the Hearing. 

Advisors

  • The Parties have the right to select an Advisor of their choice, who may be, but does not have to be, an attorney. 
  • The Parties’ Advisors may accompany the Parties to any meeting or hearing they are permitted to attend, but may not speak for the Party, except for the purpose of questioning during a Hearing, where appropriate. (See Questioning Procedure #1).
  • If a Party does not select an Advisor, the College will select an Advisor to serve in this role at the Hearing at no fee or charge to the Party.
  • The Advisor is not prohibited from having a conflict of interest or bias in favor of or against Complainants or Respondents generally, or in favor or against the Parties to the case.
  • If a Party does not attend the Hearing, the Party’s Advisor may appear and ask questions on their behalf. 
  • If neither a Party nor their Advisor appears at the Hearing, the College will provide an Advisor to appear on behalf of the non-appearing Party. 
  • Advisors shall be subject to this Policy’s Rules of Decorum and may be removed upon violation of those Rules.

Witnesses

  • Witnesses cannot be compelled to participate in the Hearing and have the right not to participate in the Hearing, free from retaliation. 
  • If a Witness does not submit to questioning, as described below, the Hearing Panel cannot rely on any statements made by that Witness in reaching a Determination Regarding Responsibility, including any statement relayed by the absent Witness to a Witness or Party who testifies at the Hearing. 
  • Witnesses shall be subject to this Policy’s Rules of Decorum and may be removed upon violation of those Rules.

Hearing Procedures

Any Hearing conducted under this Resolution Process will follow the procedure below:

  • The Panel Chair will open and establish rules and expectations for the Hearing.
  • The Parties will each be given the opportunity to provide opening statements. 
  • Panel members will ask questions of the Parties and Witnesses. 
  • Parties or their Advisors, as applicable, will be given the opportunity to ask questions of the other Party and Witnesses after the Panel members conduct their initial round of questioning. 
  • During the Parties’ questioning, the Panel Chair will have the authority to pause at any time for the established Rules of Decorum.
  • Should a Party or the Party’s Advisor choose not to question the other Party or any Witness, that Party shall affirmatively waive their right to questioning through a written or oral statement to the Panel Chair. A Party’s waiver of questioning does not eliminate the ability of the Hearing Panel to use statements made by the Party.

Questioning Procedure

The questioning procedure may differ according to the allegations presented at the Hearing.  

Procedure #1

At a Hearing convened to resolve allegations of “Title IX Sexual Harassment,” as defined above in this Policy, each Party’s Advisor will conduct questioning of the other Party or Parties and Witnesses. During this questioning, the Advisor may ask the other Party or Parties and Witnesses relevant questions and follow-up questions, including those that challenge credibility directly, orally, and in real time. Parties are not permitted to ask questions of the other Party or Witnesses in Hearings convened under this Procedure #1.

Before any question is answered, the Panel Chair will determine if the question is relevant. The Panel Chair retains the discretion to determine what constitutes a “relevant” question.  For example, questions that are duplicative of those already asked may be deemed irrelevant if they have been asked and answered.

If a Party does not submit to questioning during Procedure #1, the Hearing Panel cannot rely on any prior statements made by that Party in reaching a Determination Regarding Responsibility, but may reach a Determination Regarding Responsibility based on evidence that does not constitute a “statement” by that Party.

Procedure #2

For all other Hearings, Parties, and not their Advisors, must conduct any questioning of Witnesses. With respect to questioning of the other party, the Panel Chair will conduct the questioning based upon written questions submitted by the Party. The Panel Chair will only ask the written questions submitted by the other party if they determine, in their discretion, that the question is deemed “relevant.” Irrelevant questions will not be asked at the Hearing.   

Hearing Recording and Transcript

All Hearings will be recorded, and a transcript will be available to the Parties for inspection and review. Requests to review the recording and/or transcript must be made in writing to the Title IX Coordinator. Prior to obtaining access to a Hearing transcript, the Parties and their Advisors must sign an Agreement not to disseminate any of the testimony heard or evidence obtained in the Hearing or use such testimony or evidence for any purpose unrelated to the Resolution Process. Once signed, this Agreement may not be withdrawn. Hearing transcripts will be available within 7 business days of the conclusion of the Hearing unless there are extenuating circumstances.

Determination Regarding Responsibility

Standard of Proof

The College will use a “preponderance of the evidence” standard in deriving conclusions for its Determination Regarding Responsibility for Formal Complaints brought under this Policy. This standard means that the facts uncovered during the Investigation and Hearing determine whether it is more likely than not that a violation of the Policy occurred.

Considerations for Evaluating Testimony and Evidence

Determinations Regarding Responsibility for an allegation of Sexual Misconduct may be based in part, or entirely, on documentary, oral, audiovisual, and digital evidence, as warranted in the reasoned judgment of the Panel Chair.
Hearing Panel members shall not draw inferences regarding a Party’s or Witness’ credibility based on the Party’s or Witness’ status as a Complainant, Respondent, or Witness, nor shall they base their judgments in stereotypes about how a Party or Witness would or should act under the circumstances.

Generally, credibility judgments will rest on the demeanor of the Party or Witness, the plausibility of their testimony, the consistency of their testimony, and the reliability of the testimony considering corroborating or conflicting testimony or evidence.

Conversely, credibility judgments will not rest on whether a Party’s or Witness’ testimony is non-linear or incomplete, or if the Party or Witness is displaying stress or anxiety. 

Decision-makers will afford the highest weight relative to other testimony to first-hand testimony by Parties and Witnesses regarding their own memory of specific facts that occurred. Both inculpatory and exculpatory evidence will be weighed in equal fashion.

Except where specifically barred by the Title IX Final Rule, a Witness’ testimony regarding third-party knowledge of the facts at issue will be permitted, but generally will be accorded lower weight than testimony regarding direct knowledge of specific facts that occurred.

Parties may call “expert witnesses.” While the expert witness will be permitted to testify and be questioned, the Hearing Panel will be instructed to afford lower weight to non-factual testimony of the expert relative to fact witnesses, and any expert testimony that is not directed to the specific facts that occurred in the case will be afforded lower weight than testimony of fact witnesses, regardless of whether the expert witness testimony is the subject of questioning and regardless of whether both Parties present experts as Witnesses.

Parties may call character witnesses to speak on their behalf. While the character witness may testify and be questioned, the Hearing Panel will be instructed to afford very low weight to any non-factual character testimony of any Witness.

Where a Party’s or Witness’ conduct or statements demonstrate that the Party or Witness is engaging in retaliatory conduct, including but not limited to Witness tampering and intimidation, the Hearing Panel may draw an adverse inference as to that Party’s or Witness’ credibility.

Written Determination Regarding Responsibility

The written Determination Regarding Responsibility (“the Determination”) will be issued simultaneously to all Parties through their College email account, or other reasonable means, as necessary. The Determination will include:

1. Summary of the allegations of Sexual Misconduct.

2. A description of the procedural steps taken from the receipt of the Formal Complaint through the Determination, including any notifications to the Parties, interviews with Parties and Witnesses, site visits, methods used to gather other evidence, and Hearings held.

3. Findings of fact supporting the Determination.

4. Conclusions regarding which section of the Sexual Misconduct Policy, if any, the Respondent has or has not been found to have violated.

5. For each allegation:
a.    A statement of, and rationale for, the Determination Regarding Responsibility.
b.    A statement of, and rationale for, any disciplinary sanctions the College imposes on the Respondent; and 
c.    A statement of, and rationale for, whether remedies designed to restore or preserve equal access to the College’s Education Program or Activity will be provided to the Complainant; and

6. The College’s procedures and the permitted reasons for the Complainant and Respondent to appeal the Determination (described below in “Appeal”). 

Timeline of Determination Regarding Responsibility

If there are no extenuating circumstances, the Determination Regarding Responsibility will be issued by the College within ten (10) business days of the completion of the Hearing. 

The Determination becomes final either on the date that the College provides the Parties with the result of any Appeal, if such Appeal is filed consistent with the procedures and timeline outlined in “Appeals,” below, or if an Appeal is not filed, the date on which the opportunity to file an Appeal expires.

Sanctions 

When a Respondent accepts or is found responsible for violating this Sexual Misconduct Policy, factors considered when determining a sanction/responsive action may include, but are not limited to: 

  • The nature of, severity of, and circumstances surrounding the violation(s) 
  • The Respondent’s conduct history 
  • Previous allegations against or allegations involving similar conduct by the Respondent
  • The impact on the Parties
  • Any other information deemed relevant by the Hearing Panel

The sanctions will be implemented as soon as feasible, either upon the outcome of any Appeal or the expiration of the Appeal window. Possible sanctions described in this Policy are not exclusive of, and may be in addition to, other actions taken, or sanctions imposed by external authorities. 

The following sanctions may be imposed upon any member of the College community found to have violated the Sexual Misconduct Policy:

  • Permanent separation
  • Time-limited separation
  • Deferred separation 
  • Performance improvement plan
  • Loss of campus housing or other privileges
  • Removal from organization, team and/or committee
  • Revocation of leadership or supervisory position 
  • Disciplinary probation
  • Community service or other work assignments
  • Writing assignment
  • External program attendance or facilitation
  • Warning – Written or oral
  • Revocation of degree 
  • Withholding of diploma and/or transcripts
  • Prohibition from participation in Commencement and/or Senior Week activities

Appeals

Each Party may appeal (1) the Dismissal of a Formal Complaint or any included allegations and/or (2) a Determination Regarding Responsibility. A Party must submit a written Appeal within five (5) business days of being notified of the Dismissal of a Formal Complaint or Determination Regarding Responsibility, indicating the grounds for the Appeal.
The grounds for Appeal are limited to:

  • Procedural irregularity that affected the outcome of the matter (i.e., a failure to follow the College’s own procedures).
  • New evidence that was not reasonably available at the time the Determination Regarding Responsibility or dismissal was made, that could affect the outcome of the matter.
  • The Title IX Coordinator, Investigator(s), or decision-maker(s) had a conflict of interest or bias for or against an individual Party, or for or against Complainants or Respondents in general, that affected the outcome of the matter.

The submission of an Appeal stays any sanctions for the pendency of the Appeal. Supportive Measures and remote learning opportunities remain available during the pendency of the Appeal.

If a Party appeals, the College will as soon as practicable notify the other Party in writing of the Appeal; however, the time for Appeal shall be offered equitably to all Parties and shall not be extended for any Party solely because the other Party filed an Appeal.

Appeals should be submitted in electronic form to the President of the College (of the campus on which the hearing was held). 

The outcome of an Appeal will be provided in writing simultaneously to both Parties and will include the rationale for the decision.  The Appeal decision is final, and no subsequent Appeals are permitted.

Retaliation 

The College will keep the identity of any individual who has made a report or complaint of Sexual Misconduct confidential, including the identity of any individual who has made a report or filed a Formal Complaint of Sexual Harassment under this Sexual Misconduct Policy, any Complainant, any individual who has been reported to be the perpetrator of Sexual Misconduct under this Policy, any Respondent, and any Witness, except 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 under this Sexual Misconduct Policy. 

No person may intimidate, threaten, coerce, or discriminate against any individual for the purpose of interfering with any right or privilege secured by Title IX of the Education Amendments of 1972 or its implementing regulations.

No person may intimidate, threaten, coerce, or discriminate against any individual 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 under this Sexual Misconduct Policy. 

Any intimidation, threats, coercion, or discrimination, for the purpose of interfering with any right or privilege secured by Title IX or its implementing regulations, constitutes retaliation. This includes any charges filed against an individual for code of conduct violations that do not involve Sexual Misconduct under this Policy, but that arise from the same facts or circumstances as a report or complaint of Sexual Misconduct under this Policy. 

Record Retention

The College shall retain for a period of seven years after the date of case closure: the official file relating to a formal resolution, including any Investigation, Hearing, Determination Regarding Responsibility, sanctioning, and/or Appeal processes involving allegations of Sexual Misconduct.  In cases in which a Respondent was found to have violated the Policy and was separated from the College, the College may retain such official case files indefinitely.

Appendix I: Rules of Decorum for Resolution Process Hearings

Purpose of the Rules of Decorum

Title IX Hearings are not civil or criminal proceedings and are not designed to mimic formal trial proceedings. They are primarily educational in nature, and the U.S. Department of Education (“the Department”), writing about Title IX in the Final Rule, “purposefully designed these final regulations to allow recipients to retain flexibility to adopt rules of decorum that prohibit any party advisor or Hearing Panel Chair from questioning witnesses in an abusive, intimidating, or disrespectful manner.” 85 Fed. Reg. 30026, 30319 (May 19, 2020). The Department has determined that institutions “are in a better position than the Department to craft rules of decorum best suited to their educational environment” and build a hearing process that will reassure the Parties that the institution “is not throwing a party to the proverbial wolves.” Id. 

To achieve this purpose, Colleges may provide for reasonable rules of order and decorum, which may be enforced through the removal of an Advisor who refuses to comply with the rules. Id., at 30320. As the Department explains, the removal process “incentivizes a party to work with an advisor of choice in a manner that complies with a recipient’s rules that govern the conduct of a hearing, and incentivizes colleges and universities to appoint advisors who also will comply with such rules, so that hearings are conducted with respect for all participants.” Id.

At base, these Rules of Decorum require that all Parties, Advisors, and College staff treat others who are engaged in the process with respect.

The Rules of Decorum and processes set forth herein apply equally to all Parties and their Advisors regardless of sex, gender, or other protected class, and regardless of whether they are in the role of Complainant or Respondent.

Rules of Decorum

The following Rules of Decorum (“the Rules”) are to be observed in the Hearing and applied equally to the Parties (meaning the Complainant and Respondent) and Advisors:

1. Questions must be conveyed in a neutral tone. 

2. Parties and Advisors will refer to other Parties, Witnesses, Advisors, and College staff using the name and gender used by the person and shall not intentionally mis-name or mis-gender that person in communication or questioning.

3. No Party may act abusively or disrespectfully during the Hearing toward any other Party or to Witnesses, Advisors, or Hearing Panel members.

4. The Advisor may not yell, scream, badger, or physically “lean in” to a Party or Witness’ personal space. Advisors may not approach the other Party or Witnesses without obtaining permission from the Hearing Panel Chair.

5. The Advisor may not use profanity or make ad hominem attacks upon a Party or Witness. Questions must be interrogative statements used to test knowledge or understand a fact; they may not include accusations within the text of the question.

6. The Advisor may not ask repetitive questions. When the Hearing Panel Chair determines a question has been “asked and answered” or is otherwise not relevant, the Advisor must move on.

7. Parties and Advisors may take no action at the Hearing that a reasonable person in the shoes of the affected Party would see as intended to intimidate that person (whether Party, Witness, or official) into not participating in the process or meaningfully modifying their participation in the process.

Warning and Removal Process

The Hearing Panel Chair shall have sole discretion to determine if the Rules have been violated. The Chair will notify the offending person of any violation of the Rules.

Upon a second or further violation of the Rules, the Hearing Panel Chair shall have discretion to remove the offending person or allow them to continue participating in the hearing or other part of the process. 

Where the Chair removes a Party’s Advisor, the Party may choose a different Advisor, or (in cases involving Title IX Sexual Harassment) accept an Advisor provided by the College for the limited purpose of questioning at the Hearing. Reasonable delays, including temporary adjournment of the Hearing, may be anticipated should an Advisor be removed. A Party cannot serve as their own Advisor in this circumstance.

The Hearing Panel Chair shall document any decision to remove an Advisor in the Determination Regarding Responsibility.

For flagrant, multiple, or continual violations of the Rules, in one or more proceedings, Advisors may be prohibited from participating in future proceedings at the College in the Advisor role, on a temporary or permanent basis. Evidence of violation(s) of the Rules will be gathered by the Title IX Coordinator and presented to the Dean of the College for proceedings involving students or to the Director of Human Resources for cases involving employees. The Advisor in question may provide an explanation or alternative evidence in writing to appeal the prohibition from participation.  This appeal must be submitted to the appropriate Dean or Director within fifteen (15) calendar days of receipt. There shall be no right to a hearing, oral testimony, or questioning. 

The Dean of the College or Director of Human Resources shall consider the evidence, using a preponderance of the evidence standard, and issue a finding in writing regarding removal. The finding shall be issued in writing to all Parties and Advisors (if there is a current case pending) within thirty (30) days, unless extended for good cause. There is no appeal of this finding. 

Relevant Questions Asked in Violation of the Rules of Decorum

Should an Advisor ask a relevant question in a manner that violates the Rules, such as yelling, screaming, badgering, or leaning-in to the Witness’ or Party’s personal space, the question will not be deemed irrelevant by the Hearing Panel Chair simply because of the manner in which it was delivered. Under that circumstance, the Hearing Panel Chair will notify the Advisor of the violation of the Rules, and, if the question is relevant, will allow the question to be re-asked in a respectful, non-abusive manner by the Advisor (or a replacement Advisor, should the Advisor be removed for violation of the Rules). 

Acknowledgement

Policy adapted from the Model Grievance Policy for Addressing Formal Complaints of Sexual Harassment Under the Title IX Regulations provided by:

SUNY Student Conduct Institute
The State University of New York
State University Plaza
Albany, NY 12246

Created: August 14, 2020
Revised: August 25, 2020


Bi-Co Investigator Training

In 2020, the Investigator for Bryn Mawr and Haverford Colleges received the following training on the issues related to domestic violence, dating violence, sexual assault, and stalking, as well as how to conduct an investigation:

  • The Use of Technology in Stalking Cases
  • Threat Assessment in Domestic Violence, Dating Violence and Stalking Cases
  • Investigating Domestic Violence, Dating Violence and Stalking Complaints
  • Assessing Credibility in Sexual Assault Cases
  • Ensuring Equitable Civil Rights Investigations
  • International Student Victims of Sexual Assault
  • Community College of Philadelphia, Judicial Affairs- Best Practices – Attended sessions on Title IX, Sexual Assault - Medical and Forensic Issues, Online Predators, Sexual Violence and the LGBTQ Community
  • Thirteenth Annual NJ CUPSA & IACLEA Conference Mid Atlantic & North Atlantic Regions – Attended sessions on Federal Compliance (Clery and Title IX) and “Giving a Voice to Crime Victims”
  • Investigating & Prosecuting Campus Sexual Assault – Pennsylvania Coalition Against Rape
  • Symposium on Sexual Misconduct Prevention and Awareness: An Inclusive Training @ Rosemont College – Policies and Laws about Sexual Misconduct, Men’s Role in Ending Sexual Violence, Gender Identity, Sexual Orientation & Sexual Assault: Perspectives of Those Who Are Not Heterosexual, Attitudes and Empathy, Bystander Intervention

In 2019, the Investigator for Bryn Mawr and Haverford Colleges received the following training on the issues related to domestic violence, dating violence, sexual assault and stalking, as well as how to conduct an investigation:

  • 14th Annual NJ CUPSA and IACLEA Conference - Clery Act, PTSD (Post Traumatic Stress Disorder)
  • Everfi - Child Abuse and Molestation Awareness and Prevention
  • Everfi - Discrimination and Harassment Prevention for Higher Education
  • Everfi- Preventing Discrimination and Sexual Violence - Title IX, VAWA and Clery Act for Faculty and Staff
  • Trauma Informed Sexual Assault Investigations Training
  • 11th Annual Conference on Student Conduct and Judicial Affairs - Clery Act
  • Advanced Investigation of Sexual Misconduct
  • Webinar - Clery Act Requirements in Light of New Title IX Regulations
  • Webinar - A First Look at the Title IIX Regulations - Summary of Key Provisions and Practical
  • Implementation Considerations
  • Webinar - Unpacking the Final Title IX Regulations    

Bi-Co Title IX Coordinator Training

2020 Training

  • NACUA (National Association of College and University Attorneys) Briefing: Title IX: The Department of Education Final Rule on Sexual Harassment
  • EVAWI (End Violence Against Women International) Training Institute: Building Your Trainer Toolbox Part 1: Using and Citing Research; Building Your Trainer Toolbox Part 2: Training Materials and Professional Tools
  • Pepper Hamilton LLP Webinar: New Title IX Regulation: A Seismic Shift During a Pandemic
  • Clery Center Webinar: Keeping Focus: Reviewing Clery Act Requirements in Light of New Title IX Regulations
  • CUPA-HR (College and University Professional Association for Human Resources – May 2020: Title IX Final Rule Released: What You Need to Know Now
  • Cozen O’Connor Law Firm Webinar: A First Look at the Title IX Regulations: Summary of Key Provisions and Practical  Implementation Considerations
  • United Educators Webinar with Saul Ewing Arnstein & Lehr: Unpacking the Final Title IX Regulations: Q & A with an Expert
  • Student Conduct Institute Online Training Modules: Title IX Final Rule Basics; Pennsylvania State Law Basics; CAS Standards: Sexual Violence Related Programs & Services; The Neurobiology of Trauma; Trauma-Informed Practice; Cultural Relevance, Inclusiveness, and Responding to Sexual and Interpersonal Violence; Supportive Measures in Response to Reports of Sexual and Interpersonal Violence; No Conduct Orders, Emergency Removal, & Interim Measures; Recognizing and Responding to Stalking: Trauma Informed Best Practices; Online Harassment; Evidence in the Student Conduct Process; Privacy, Confidentiality, and Privilege in Disclosures of Sexual and Interpersonal Violence; Law and the Hearing Panel; Pre-Hearing Preparations; Accountability; Appeals in Student Conduct; Virtual Hearing Technology

2019 Training

  • January 18, 2019 Adjudicators Training 
  • March 14, 2019 Facilities and Housekeeping  
  • June 13, 2019 New Staff Orientation 
  • August 16, 2019 Dining Staff Orientation 
  • August 27, 2019 Custom Person Training 
  • August 27, 2019 New Faculty Orientation training 
  • August 29, 2019 Hall Adviser Training 
  • August 30, 2018 New Student Orientation 
  • October 3, 2019 Deans Office annual training 
  • October 2019 various THRIVE discussions and workshops

2018 Training

  • February 12, 2018 New Staff Orientation
  • March 14, 2018 Facilities and Housekeeping
  • June 13, 2018 New Staff Orientation
  • April 18, 2018 Faculty Meeting
  • August 16, 2018 Dining Staff Orientation
  • August 28, 2018 Hall Adviser Training
  • August 29, 2018 Custom Person Training
  • August 30, 2018 New Faculty Orientation training
  • August 30, 2018 New Student Orientation
  • September 12, 2018 Deans Office annual training
  • October 12, 2018 Athletics Department annual training
  • Week of October 1 – 6, 2018 THRIVE discussions and workshops conducted with all first-year 
  • students
  • November 30, 2108 NCAA Sexual Violence Prevention Training (Bystander) for athletes
  • December 7, 2018 Training for Deans Panelists

Policy Concerning Sexual Relationships Between Students and Faculty or Staff Members

Fulfilling the mission of Bryn Mawr College to provide a rigorous education and to encourage the pursuit of knowledge as preparation for life and work depends upon the existence of a relationship of trust, respect and fairness between faculty or staff members and students. Romantic and/or sexual relationships between faculty or staff members (including teaching assistants) and students threaten this relationship. Further, the unequal nature of their respective roles calls into question a student’s ability to fully consent to a romantic and/or sexual relationship with a faculty or staff member. The College considers such a relationship, even if believed to be consensual, to violate the integrity of the student/faculty or student/staff relationship, and to be unethical and unacceptable.

In acting on complaints regarding sexual relationships that come to the College’s attention, it will be presumed that any complaint by a student against a faculty or staff member is valid if sexual relations have occurred between them. In addition, third parties, including other students, parents, and other faculty/staff members, may report suspected violations of this policy. All complaints will be investigated and should allegations of such a relationship be substantiated, the College will take appropriate disciplinary action against the involved faculty or staff member, up to and including termination of employment.


Crime Statistics

Crime statistics for the past three calendar years are shown here.

Total Students and Employees 2018 2019 2020
Students 1,690 1,719 1,635
Full-Time Employees (not including part-time faculty and staff) 611 587 568

Murder/Non-Negligent Manslaughter

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Manslaughter by Negligence

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Sexual Offenses, Total

Location 2018 2019 2020 Unfounded Crimes
On Campus *10 4 *2 0
** Residential Facilities 6 4 1 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 10 4 2 0

Rape

Location 2018 2019 2020 Unfounded Crimes
On Campus *3 1 *2 0
** Residential Facilities 3 1 1 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 3 1 2 0

Fondling

Location 2018 2019 2020 Unfounded Crimes
On Campus *7 *3 0 0
** Residential Facilities 3 3 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 7 3 0 0

Incest

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Statutory Rape

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Robbery

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Aggravated Assault

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Burglary

Location 2018 2019 2020 Unfounded Crimes
On Campus 6 2 0 0
** Residential Facilities 6 2 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 6 2 0 0

Motor Vehicle Theft

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 1 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 1 0 0

Arson

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Liquor Law Arrests

Location 2018 2019 2020 Unfounded Crimes
On Campus 8 5 3 0
** Residential Facilities 8 5 3 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 8 5 3 0

Liquor Law Violations and Intoxication

Location 2018 2019 2020 Unfounded Crimes
On Campus 17 14 11 0
** Residential Facilities 17 14 11 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 17 14 11 0

Drug Law Arrests

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Drug Law Violations

Location 2018 2019 2020 Unfounded Crimes
On Campus 10 12 1 0
** Referred for Further Action
Residential Facilities
9 12 1 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 10 12 1 0

Illegal Weapons Possession Arrests

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Illegal Weapons Possession

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

 

Violence Against Women Act (VAWA)

Dating Violence

Location 2018 2019 2020 Unfounded Crimes
On Campus 1 1 2 0
** Residential Facilities 1 1 1 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 1 1 2 0

Domestic Violence

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 0 0 0
** Residential Facilities 0 0 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 0 0 0

Stalking

Location 2018 2019 2020 Unfounded Crimes
On Campus 0 1 0 0
** Residential Facilities 0 1 0 0
Non Campus 0 0 0 0
Public Property 0 0 0 0
Total 0 1 0 0

*Sexual Assault Caveats:

  1. One sexual assault (rape) occurred in 2017 but reported in 2018.
  2. One sexual assault (fondling) occurred in 2017 but reported in 2018.
  3. One sexual assault (fondling) occurred in 2018 but reported in 2019.
  4. One sexual assault (rape) occurred in 1978 but reported in 2020.
  5. One sexual assault (rape) occurred in 2019 but reported in 2020.

Hate Crimes

In 2018, 2019, and 2020 there were none of the crimes listed above that manifested evidence of prejudice based on race, gender, gender identity, national origin, religion, ethnicity, disability or sexual orientation as outlined by the Hate Crime Statistics Act.

Note: Crime offenses on public property that are within the reasonably contiguous area of Bryn Mawr College reported by local law enforcement are included in these statistics. 

(**) Crimes reported in the Residential Facilities column are included in the On-Campus Category.

Unfounded Crimes

No reported crime may be considered unfounded unless a determination of such has been made by the Lower Merion Township Police Department.

There were no crimes or reported incidents that were unfounded by investigation in the above reporting years (2018, 2019. and 2020).


Annual Fire Safety Report

Fire and smoke detection equipment is installed in all campus buildings. These alarms are monitored by Campus Safety and, as a fail-safe, an independent monitoring company. Sprinkler systems and smoke detectors are checked annually, to ensure proper working order. Fire drills are held a minimum of once a semester, to evaluate evacuation procedures. 

Fire safety is a major concern of the Campus Safety Department and affects all members of the Bryn Mawr community. Each residence hall is equipped with automatic smoke detection systems that report to the Campus Safety Office. Fire Exit Drills are conducted in each residence hall each semester so that students become familiar with proper building evacuation procedures. The Campus Safety Department works with the Residential Life Office, Hall Advisors and Facilities Services to identify and correct any fire, safety, or security hazards.

Fire Alarms

It is a violation of the Lower Merion Township Fire Code and College Policy to interfere with the operation of any fire alarm system. This includes covering or otherwise preventing the proper operation of any smoke detector or fire alarm system.

Fire Protection Systems

Effective fire prevention occurs only when individuals are aware of the principal causes of fires and take certain simple steps to eliminate them.

For residents’ safety, individual rooms are equipped with individual smoke detectors. All common areas in residence halls are equipped with smoke detectors and manual-pull stations, both of which set off alarms (horns and strobes) located throughout the building. Activation of common area smoke detectors or pull stations sends an alert electronically to the dispatcher at Campus Safety. If the smoke detector in a student’s room activates, the building alarms will not sound unless the student uses the pull-station or the smoke from the student’s room activates a smoke detector in a common area, or a sprinkler is activated.

Automatic Sprinkler Systems  

The majority of College buildings, including most dormitories, are equipped with automatic sprinkler systems. Sprinkler heads are placed throughout the building and are designed to activate individually when exposed to the heat of a fire. The heads typically activate within minutes of the start of a fire and direct a generous spray of water over an area or room. In a typical situation, a fire starts in a single location, activates one or two nearby sprinkler heads, and the fire is contained or extinguished where it started. A series of pipes connects sprinkler heads in all areas to a major water line and is always on. When water flows through any sprinkler head, the building evacuation alarms are sounded, and an alert is automatically sent to Campus Safety. 
 
Since the sprinkler system is always charged and sprinkler heads are relatively delicate, it is important to never hang objects from sprinkler heads and to protect them from mechanical damage.

Fire Alarm Misuse

It is illegal to interfere with the operation of any fire alarm system. This includes covering or otherwise preventing the proper operation of any smoke detector or fire alarm system.

Fire Prevention

Effective fire prevention occurs when individuals are aware of the principal causes of fires and take reasonable steps to eliminate them. 

Fire can exist wherever there are combustible materials, and some means of bringing them to kindling temperature. Frequent causes of fires at colleges include candles, careless smoking, over-loaded electrical outlets, cooking in dorm rooms, halogen lamps.

Smoking is prohibited in all College buildings. The burning of candles, use of halogen lamps, except those with safety guards, and the use of cooking or heating appliances, except those provided by the College in pantry kitchens, are prohibited in College housing.

The use of hot-plates, large refrigerators (in dorms without kitchens), and other major electrical appliances can easily overload the electrical system. Only safe, low-wattage appliances may be used in College-housing: lamps, radios, televisions, stereos, computers, electric blankets, thermostatically controlled coffee makers and the like.

Fire Evacuation Drills

Fire Evacuation Drills are supervised and conducted by the Campus Safety Officers once per semester. Hall Advisors assist by informing their residents about the procedures, closest evacuation doors and meeting locations when the building is evacuated. Self-evacuation by all occupants is mandatory whenever the fire alarm system activates.

Fire Safety Education and Training

Fire Safety Education and Training is provided by the Environmental Health and Safety Officer to all first-year students as part of their Customs Week orientation. Hall Advisors (students with oversight responsibility in residence halls) receive additional training regarding their responsibilities in fire safety and building evacuation. Faculty and students who work in science laboratories also receive training by the Environmental Health and Safety Officer in fire prevention, extinguishing, and evacuation. Fire safety is an ongoing agenda item in the Deans Safety Meeting and Residence Counsel and is included in all presentations to new employees.

Fire Evacuation Instructions for Residential Buildings

  • If you discover a fire or smoke condition, notify the Campus Safety Department by telephone x7911 or 610-526-7911 or campus emergency phone from a safe area. Give the Dispatcher your name, location and nature of the fire. If the building fire alarm system is not sounding, activate the nearest fire alarm pull station. Fire alarm pull stations are located within 5 feet of an exit door.
  • Upon activation of a fire alarm all occupants should exit the building at once. 
  • Feel the door to your room before opening it. If the door feels hot or smoke is seeping in, do not open it. Seal off the cracks in the door with a coat or blankets and open outside windows for ventilation. Call Campus Safety and explain your situation, giving your name and location. Signal your location by waving a towel or bed sheet out of your window.
  • If the door feels cool, open it slowly. Be prepared to slam the door if the hall is full of smoke or heat. If the hall is clear, proceed to the nearest stairs and exit the building. Should you encounter heavy smoke while exiting the building, turn back and find a room that provides a safe area of refuge. Contact Campus Safety immediately. Become familiar with two escape routes from the building.
  • If you get caught in smoke or heat, crawl on the floor and take short breaths through your nose until you reach an area of safe refuge.
  • Remember to assist any physically challenged persons in your area to safety in the event of an emergency.
  • Once you have left the building, do not return for any reason. Someone from Campus Safety will notify you when it is safe to return to the building.
  • Students evacuating the residence halls should meet in their Designated Meeting Area.

Building Fire Prevention Information

In case of fire, alert the residents, evacuate the building: call 610-526-7911. All addresses are located in Bryn Mawr, PA 19010.

Fire Statistics

Location/Address Monitored Alarm Fire Sprinkler Systems Fire Alarm and Smoke Detection Evacuation Drills
Brecon Hall/320 N. Roberts Rd.  Yes All Areas Yes 2
Denbigh Hall/800 New Gulph Rd. Yes All Areas Yes 2
Enid Cook Center (ECC)/815 Yarrow Yes All Areas Yes 2
Erdman Hall/150 Morris Ave. Yes Not in All Areas Yes 2
New Dorm/815 Yarrow St. Yes All Areas Yes 2
Merion Hall/804 New Gulph Rd Yes All Areas Yes 2
Pembroke East/220 N. Merion Ave.  Yes All Areas Yes 2
Pembroke West/218 N. Merion Ave. Yes All Areas Yes 2
Radnor Hall/820 New Gulph Rd. Yes All Areas Yes 2
Rhoads Hall/210 N. Merion Ave. Yes All Areas Yes 2
Rockefeller Hall/200 N. Merion Ave. Yes All Areas Yes 2
Batten House/330 N. Roberts Rd. Yes None Yes 2

2018

Residential Facilities Total Fires in Each Building Fire Number Cause of Fire Number of Injuries Required Treatment Number of Deaths Related to Fire Value of Property Damage by Fire
Brecon Hall/320 N. Roberts Rd.  0 0 N/A 0 0 N/A
Denbigh Hall/800 New Gulph Rd. 0 0 N/A 0 0 N/A
Enid Cook Center (ECC)/815 Yarrow 0 0 N/A 0 0 N/A
Erdman Hall/150 Morris Ave. 0 0 N/A 0 0 N/A
New Dorm/815 Yarrow St. 0 0 N/A 0 0 N/A
Merion Hall/804 New Gulph Rd 0 0 N/A 0 0 N/A
Pembroke East/220 N. Merion Ave.  0 0 N/A 0 0 N/A
Pembroke West/218 N. Merion Ave. 0 0 N/A 0 0 N/A
Radnor Hall/820 New Gulph Rd. 0 0 N/A 0 0 N/A
Rhoads Hall/210 N. Merion Ave. 0 0 N/A 0 0 N/A
Rockefeller Hall/200 N. Merion Ave. 0 0 N/A 0 0 N/A
Batten House/330 N. Roberts Rd. 0 0 N/A 0 0 N/A

2019

Residential Facilities Total Fires in Each Building Fire Number Cause of Fire Number of Injuries Required Treatment Number of Deaths Related to Fire Value of Property Damage by Fire
Brecon Hall/320 N. Roberts Rd.  0 0 N/A 0 0 N/A
Denbigh Hall/800 New Gulph Rd. 0 0 N/A 0 0 N/A
Enid Cook Center (ECC)/815 Yarrow 0 0 N/A 0 0 N/A
Erdman Hall/150 Morris Ave. 0 0 N/A 0 0 N/A
New Dorm/815 Yarrow St. 0 0 N/A 0 0 N/A
Merion Hall/804 New Gulph Rd 0 0 N/A 0 0 N/A
Pembroke East/220 N. Merion Ave.  0 0 N/A 0 0 N/A
Pembroke West/218 N. Merion Ave. 0 0 N/A 0 0 N/A
Radnor Hall/820 New Gulph Rd. 0 0 N/A 0 0 N/A
Rhoads Hall/210 N. Merion Ave. 0 0 N/A 0 0 N/A
Rockefeller Hall/200 N. Merion Ave. 0 0 N/A 0 0 N/A
Batten House/330 N. Roberts Rd. 0 0 N/A 0 0 Off-line

2020

Residential Facilities Total Fires in Each Building Fire Number Cause of Fire Number of Injuries Required Treatment Number of Deaths Related to Fire Value of Property Damage by Fire
Brecon Hall/320 N. Roberts Rd.  0 0 N/A 0 0 N/A
Denbigh Hall/800 New Gulph Rd. 0 0 N/A 0 0 N/A
Enid Cook Center (ECC)/815 Yarrow 0 0 N/A 0 0 N/A
Erdman Hall/150 Morris Ave. 0 0 N/A 0 0 N/A
New Dorm/815 Yarrow St. 0 0 N/A 0 0 N/A
Merion Hall/804 New Gulph Rd 0 0 N/A 0 0 N/A
Pembroke East/220 N. Merion Ave.  0 0 N/A 0 0 N/A
Pembroke West/218 N. Merion Ave. 0 0 N/A 0 0 N/A
Radnor Hall/820 New Gulph Rd. 0 0 N/A 0 0 N/A
Rhoads Hall/210 N. Merion Ave. 0 0 N/A 0 0 N/A
Rockefeller Hall/200 N. Merion Ave. 0 0 N/A 0 0 N/A
Batten House/330 N. Roberts Rd. 0 0 N/A 0 0 N/A
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Contact Us

Campus Safety Department

John Maloney Memorial Building
Phone: (610) 526-7911

Lil Burroughs
Bi-Co Executive Director, Campus Safety
Phone: (610) 526-7911