Civil Rights and Title IX FAQs

The Office of Civil Rights and Title IX is responsible for the implementation and enforcement of the Sexual Misconduct Policy and the Interim Policy for the Prevention of Discrimination, Discriminatory Harassment, and Retaliation (the "Discrimination Policy").

A complainant is an individual who is reported to have been the victim of discrimination, discriminatory harassment, or sexual misconduct. A respondent is an individual who is reported to have engaged in discrimination, discriminatory harassment, or sexual misconduct.

In accordance with federal, state, and local laws, regulations, and ordinances prohibiting discrimination, protected characteristics include:

1. Age (40 years and over in the employment context)
2. Citizenship status
3. Color
4. Disability (physical or mental 
5. Gender identity/expression
6. Genetic information, including family medical history (in
   the employment context)
7. National origin (including shared ancestry or ethnic
   characteristics)
8. Pregnancy or related conditions
9. Race (including traits associated with race, including hair
   texture and protective hairstyles)
10. Religion (including religious creed)
11. Sex (including sex assigned at birth and differences in sex
    development)
12. Sexual orientation
13. Veteran status
14. Or any other protected characteristic under applicable
    federal, state, or local law

The Office of Civil Rights & Title IX can assist individuals with the facilitation of resolution options, coordination of supportive measures, connection to on- and off-campus resources, and education and training.

You can contact Cary Carr, Director of Civil Rights and Title IX, with questions or to make an appointment at ccarr1@brynmawr.edu or 610-526-7863. Her office is located in Guild Hall, Room 101.

Supportive measures are non-disciplinary, non-punitive, and individualized services designed to restore or preserve access to the College’s education programs and activities. Supportive measures are provided without fee or charge and can be provided to any individual impacted by alleged discrimination, discriminatory harassment, or sexual misconduct, including both complainants and respondents. Examples of supportive measures include, but are not limited to:

1. Referral to Counseling Services or Health Services
2. Extensions of deadlines or other course-related adjustments
3. Modifications of work or class schedules
4. No contact or limited contact directives
5. Changes in work or housing locations
6. Increased security and monitoring of certain locations on campus

No – both complainants and respondents have the right to receive supportive measures from the College regardless of whether a complaint has been filed. To inquire about supportive measures, contact the Director of Civil Rights & Title IX at ccarr1@brynmawr.edu or 610-526-7863.

A list of resources, including confidential resources, both on and
off campus can be found here.

If online conduct, including activity on social media, has the effect or purpose of creating or contributing to a hostile or abusive work or learning environment for a member of the College Community, then the College has a responsibility to take action according to its policies, regardless of whether the online platform is owned by the College.

When online conduct rises to the level of harassment under College Policy, such as targeted harassment on the basis of race, sex, or another protected characteristic, threats of violence, or the non-consensual sharing of intimate images, the College must stop the harassment from occurring, prevent the recurrence of harassment, and remedy the effects of the harassment on the individual and broader community.

Discriminatory harassment can occur in different contexts and locations, including in classrooms, residence halls, athletics facilities, off campus, on the internet, and on social media apps.

When off-campus conduct has a nexus to the campus environment and produces the effect of creating or contributing to a hostile or abusive work or learning environment for a member of the College community, the College has an obligation to respond.

Effective as of December 22, 2025, the Discrimination Policy supersedes and replaces all policies and procedures concerning discrimination and harassment outlined in the faculty, staff, and student handbooks.

When a report is made to the Office of Civil Rights and Title IX, the Director of Civil Rights and Title IX will evaluate the reported conduct to determine whether, as alleged, it meets one or more definitions of prohibited conduct under the Sexual Misconduct Policy or the Discrimination Policy. Some conduct may not rise to the level of discrimination, or discriminatory harassment, or sexual misconduct, but may nonetheless be disruptive to an individual’s education or employment experience. When this happens, the College seeks to offer support, resources, and interventions available through campus partners. If the alleged conduct, if substantiated, would not constitute a violation of the Sexual Misconduct or Discrimination Policies, the Director may refer the matter for action under a separate College policy.

Students, staff, and faculty at Bryn Mawr College, as well as any member of the public, can report discrimination, harassment, or sexual misconduct to the Office of Civil Rights and Title IX.Individuals can report incidents they experienced, observed, or learned about.

Individuals can make a report by completing the online reporting form or contacting the Director of Civil Rights and Title IX directly at ccarr1@brynmawr.edu or 610-526-7863.

A report is a notice to any responsible employee of conduct that may be prohibited under the Sexual Misconduct Policy and/or Discrimination Policy. A report can come from any individual (not only complainants), and not every report is or will result in a complaint. A formal complaint under the Sexual Misconduct Policy or a complaint under the Discrimination Policy is a signed document or electronic submission that indicates a request that the College formally investigate the allegations. To make a report, fill out the online reporting form or contact Cary Carr, Director of Civil Rights and Title IX at ccarr1@brynmawr.edu or 610-526-7863. She can also assist you with filing a complaint.

After receiving a report, the Director of Civil Rights and Title IX will make outreach, if possible, to any impacted individuals to offer an intake meeting and provide information on supportive measures, resources, and resolution options. The Director will also review the details of the report to assess safety concerns and whether a hostile environment may have been created.

There is no time limit on making a report or complaint, but individuals are strongly encouraged to report incidents of alleged discrimination, discriminatory harassment, or sexual misconduct as soon as possible.

Typically, the respondent will not be notified unless the report becomes a formal investigation, the complainant requests a supportive measure that requires the respondent be notified, such as a no contact directive, or if the complainant requests that the respondent is invited to participate in an educational conversation or training.

Under rare circumstances, the Director of Civil Rights and Title IX may determine that a complaint is necessary and sign a complaint on behalf of the complainant. The complainant would be notified of this decision in writing, and the respondent would receive notice of a formal investigation.

The Office of Civil Rights and Title IX is not a confidential resource. Information is shared on a need-to-know basis, such as to implement the Sexual Misconduct and Discrimination Policies, provide supporive measures, or otherwise address conduct that may reasonably constitute prohibited conduct. For a list of confidential resources, visit the Resources & Support section of this website.

Although often conflated, privacy and confidentiality are two distinct terms with distinct meanings. Privacy refers to the College’s commitment to sharing information related to any report, complaint, supportive measures, or procedures under the Sexual Misconduct and Discrimination Policies only:

1. To a person with a legal right to receive disclosures of information, or with prior written consent;
2. When necessary to effectuate the Sexual Misconduct and Discrimination Policies, or to otherwise address conduct which may reasonably constitute prohibited conduct;
3. As required by federal law or regulation, including by the terms and conditions of a federal award (e.g., a grant award or other funding agreement); and/or
4. When required or permitted by state or local law or the Family Educational Rights and Privacy Act (“FERPA”).

Confidential communications are those exchanged with individuals belonging to certain professions (such as healthcare providers, professional counselors, or pastoral counselors). Such individuals cannot disclose the content of those communications
to any third party without the disclosing individual’s prior written consent, or if permitted or required by law or relevant professional ethical obligations (such as “duty to warn”). Confidential resources can be found under “Resources & Support.”

Any individual other than a Responsible Employee making a required report may make an anonymous report. However, the College’s ability to respond and investigate is limited.

You are not required to report to law enforcement to receive support from the College. The College is strongly committed to providing resources and supportive measures to individuals regardless of whether they decide to take legal action.

The College seeks to prevent bad faith reporting by conducting thorough and neutral investigations. No disciplinary actions are taken against respondents on allegations alone. Further, the Sexual Misconduct and Discrimination Policies prohibit retaliation, including filing a report or complaint against an individual for the purpose of harassing or retaliating against them. The College may pursue disciplinary action against those who make materially false statements in bad faith over the course of a resolution process. However, a determination that a respondent was not responsible for a policy violation does not, without more, establish that a complainant or any other party or witness has made a false allegation or statement in bad faith.

Yes. The criminal process and the Office of Civil Rights and Title IX’s reporting process are separate but can occur at the same time.

All employees of the College except those designated as confidential resources are considered Responsible Employees and are required to contact the Office of Civil Rights and Title IX as soon as they learn of potential prohibited conduct under the Sexual Misconduct and Discrimination Policies. Responsible Employees should make a report even if they are unsure that the incident occurred or whether it falls under College policies. This includes incidents that occur off campus or that occurred in the past.

Generally, student employees are not considered Responsible Employees. However, students in positions of leadership (i.e., Hall Advisors, Customs Persons, Peer Mentors, Community Diversity Assistants, and Peer Health and Wellness Educators)
and Graduate Teaching Assistants are considered Responsible Employees and therefore are required to inform the Office of Civil Rights and Title IX of any disclosures of prohibited conduct.

When an individual, whether a student or employee, discloses a possible incident of prohibited conduct, you should first inform that individual that you are a Responsible Employee who is required to report any information they shared with you to the Office of Civil Rights and Title IX. Contact the Director of Civil Rights and Title IX promptly and share all information you have, including the names of individuals involved, their contact information, and any other details. Please use the online reporting form (preferred method), email ccarr1@brynmawr.edu, or call 610-526-7863.

Offer support and compassion and thank the individual for coming to you. Avoid asking the individual questions about the details of the incident and do not ask “why” questions. Let the individual know as soon as possible in the conversation whether
you are a Responsible Employee, so that they can make an informed decision about what information they share. Remind the individual of resources available to them, including confidential resources for both students and employees of the College. If the incident involved a crime, alert the individual of their right to make a report to Campus Safety and/or the police. Inform the individual that you will be making a report to the Office of Civil Rights and Title IX and tell them that they can also reach out to the Office directly.

It is also important to share that the reporting individual can receive supportive measures and resources through the College regardless of whether they want to move forward with a resolution process. For victims of sexual assault, dating violence, and stalking, provide information on available community resources, including Laurel House Domestic Violence Center and Victim Services of Montgomery County. If an individual has experienced a sexual assault within the past 72-120 hours, ensure that they know they can receive a Sexual Assault Forensic Exam (i.e., a “rape kit”) at Bryn Mawr Hospital (individuals should call the Hospital or Victim Services Center of Montgomery County to ensure that the time window to receive an exam has not passed). 

If the individual is in crisis, please contact Campus Safety or Counseling Services to ensure they receive appropriate support.

Yes, any disclosure of alleged prohibited conduct under the Sexual Misconduct and Discrimination Policies, regardless of when or where it occurred, should be reported to the Office of Civil Rights and Title IX. This ensures that individuals can receive resources and supportive measures in a timely fashion.

Confidential resources (i.e., Counseling Services, Health Services, the OwlWell Program Director and Coordinator, and Interfaith Chaplains) are exempt from reporting. However, confidential resources must still provide contact information for the Office of Civil Rights and Title IX, explain how to report prohibited conduct, and inform the individual that the Director of Civil Rights and Title IX may be able to offer and coordinate supportive measures.

Also included in the category of confidential resources are individuals who conduct human subjects-research studies that have been approved by the Institutional Review Board (“IRB”), and which are designed to gather information about prohibited conduct, with respect to information disclosed in the course of conducting the approved study.

Reporting ensures that impacted individuals have access to resources and supportive measures and understand the resolution options available to them. This allows individuals to make informed choices for themselves regarding potential next steps. Further, reporting helps the Office of Civil Rights and Title IX assess patterns across campus, ensure the safety of all BMC community members, and address areas in need of additional education and programming on campus. Additionally, under Title VI, the College is required to respond when we become aware, or should have been aware, of a potential hostile environment.

Complainants may request an educational response, alternative resolution, or formal resolution process.

Educational responses are case-specific and may include but are not limited to an educational meeting with the respondent, training for an individual, group, or unit, or a facilitated discussion with another College resource. Educational responses are non-punitive, and the College must agree they are appropriate.

An alternative resolution is a voluntary, flexible, and non-punitive process designed to restore complaints without a formal investigation. Typically, alternative resolution facilitators serve as intermediaries to help the involved parties reach a mutually agreed upon resolution. Examples of resolution terms that may be obtained through this process include written accountability statements, educational requirements, no-contact directives, changes in office, housing, or work hours, counseling, and connection with campus or community resources. All parties must agree to participate in an alternative resolution process, and the College must agree that it is appropriate.
 

In a formal resolution process (i.e., an investigation), a College- assigned investigator gathers facts about the allegations raised,interviews each party and relevant witnesses, objectively reviews the relevance of all evidence, and prepares an investigation report. For formal resolutions under the Discrimination Policy, a trained decisionmaker objectively evaluates the investigation report, which includes all relevant evidence, to reach a determination regarding responsibility. For formal resolutions under the Sexual Misconduct Policy, there is a live hearing in which the complaint is typically adjudicated by three-person panel.
 

Please ensure you reference the Sexual Misconduct and Discrimination policies for complete descriptions of the resolution options.

If there is a finding of responsibility, the decisionmaker(s) may issue sanctions. For students of the College, sanctions may include but are not limited to removal from organizations or teams, disciplinary probation, community service, required training or education, loss of campus housing or other privileges, suspension, or dismissal or expulsion from the College. For employees of the College, sanctions include but are not limited to verbal or written warnings, performance improvement plans, required training or education, demotion, transfer, reassignment, suspension/administrative leave, or termination.

No, there is no live hearing requirement under the Discrimination Policy. The assigned decisionmaker (see question “What are the possible options for resolving a concern?”) adjudicates the complaint by objectively evaluating all relevant evidence as provided in the investigative report to reach a determination of responsibility. The standard of evidence under both the Sexual Misconduct and Discrimination Policies is a preponderance of evidence, meaning that it is more likely than that, based on all
relevant evidence, the respondent engaged in the alleged prohibited conduct.

Following a report or complaint, the Office of Civil Rights and Title IX will promptly contact the complainant to offer an intake meeting. During this meeting, the Director or their designee will discuss the procedures available to the complainant. The complainant can request an educational response, alternative or formal resolution process, and/or ask for supportive measures and resources.

For every complaint, the Director will evaluate whether the conduct, as alleged, meets one or more definitions of prohibited conduct under the Sexual Misconduct and Discrimination Policies. If the conduct does not rise to the level of discrimination, discriminatory harassment, or sexual misconduct but may nevertheless be disruptive to an individual’s educational or employment experience, the Office of Civil Rights and Title IX can offer support, resources, and interventions available through
campus partners.

The Office of Civil Rights and Title IX seeks to prioritize complainants’ autonomy in what they would like to see happen next. However, in the absence of a complaint made by a complainant, the Director of Civil Rights and Title IX may initiate a
complaint if it is determined that the alleged conduct presents an imminent and serious threat to the health or safety of members of the College community or if the conduct as alleged prevents the College from ensuring equal access to its education programs or activities. When this is the case, the Director will notify the complainant and offer supportive measures and resources

There are several opportunities for employees to participate in the resolution processes under the Sexual Misconduct and Discrimination Policies.

Alternative resolution facilitators serve as intermediaries to help the involved parties reach a mutually agreed upon resolution. This can happen directly (facilitated dialogue) or indirectly (shuttle negotiation). The Office of Civil Rights and Title IX assigns facilitators to cases, screens for conflicts of interest, and assesses impartiality throughout the process. Prior to participating in this role, facilitators must complete extensive training grounded in restorative practices. In May 2026, 15 staff and faculty members attended a 3-day training to serve in this role; additional opportunities for the 2026-2027 academic year will be announced via the Office of Civil Rights and Title IX webpage.

Employees can also serve as advisors for a complainant or respondent. Advisors may accompany parties to meetings and/or interviews, help them prepare for each meeting, and provide general assistance and support. Advisors do not participate directly in the procedures under the Sexual Misconduct and Discrimination Policies and cannot speak or write on behalf of a party. Complainants and respondents can choose any individual to serve in the role of an advisor. During the 2026-2027 academic year, the Office of Civil Rights and Title IX will be recruiting individuals to serve in this role and will provide training and resources to do so.

Employees may also be asked to serve on a hearing panel for formal resolutions under the Sexual Misconduct Policy. Hearing panels typically include two College employees, including faculty and staff. To serve in this role, employees must complete comprehensive training on definitions of prohibited conduct, impartiality and bias, relevance of evidence, the formal resolution process, and more. The Office of Civil Rights and Title IX will offer this training at least once annually.

Those interested in serving in any of these roles can contact the Director of Civil Rights and Title IX at ccarr1@brynmawr.edu or 610-526-7863.

Title VI of the Civil Rights Act of 1964 prohibits discrimination based on actual or perceived race, color, or national origin. This may include discrimination on the basis of:

1. Physical or cultural characteristics associated with a certain race or national origin, such as skin color, complexion, or hair texture.
2. The country, world region, or place where a person or their ancestors come from.
3. Limited English proficiency or English learner status.
4. Shared ancestry or ethnic characteristics.

The Office of Civil Rights (OCR), which enforces Title VI, applies the “severe or pervasive” standard when defining discriminatory harassment. The College has adopted this standard to meet its federal civil rights obligations fully and protect the campus community against discrimination and harassment. A single incident may be severe even if it is not repeated, and a pattern of conduct can constitute harassment even if no single instance would be characterized as severe. In either case, the College has an obligation to respond to ensure an educational and employment environment that is free from discrimination and discriminatory harassment.

Unwelcome verbal, physical, written, audio or visual conduct, or conduct using technology and/or social media based on protected characteristics, including race, color, and national origin, may constitute discriminatory harassment. Discriminatory harassment can occur in different contexts and locations, including in classrooms, residence halls, athletics facilities, off campus, on the internet, and on social media apps. Further discrimination against individuals or groups through adverse actions, including differential treatment, because of their actual or perceived protected characteristics, is prohibited under the Discrimination Policy.

Harassment need not be targeted at an individual to create a hostile environment. Even a single or isolated incident can, in some situations, create a hostile environment if the incident is sufficiently severe. The totality of circumstances is assessed in determining whether conduct has created a hostile environment. The totality of circumstances include the context, nature, scope, frequency, duration, and location of the incident(s); the relationships of the persons involved; whether the conduct would be objectively viewed as intimidating, hostile, or offensive; and whether the conduct would be protected by academic freedom. Examples of behaviors that could contribute to a hostile environment include, but are not limited to:

1. Racial or ethnic slurs directed at individuals.
2. Repeatedly mocking a person’s accent or manner of speaking.
3. “Jokes” that perpetuate negative stereotypes about an individual based on their Jewish ancestry.
4. Deliberately excluding someone from meetings, activities, or social groups based on their religion.
5. Applying rules or discipline unequally based on color.
6. Persistently requiring a Black student to remark on the beliefs or actions of the entire Black community.
7. Vandalism of personal property with hateful words or symbols.
8. Referring to a Muslim individual as a “terrorist” or mocking their hijab.

Title IX, a federal civil rights law enacted in 1972, prohibits discrimination based on sex. Title IX Sexual Harassment is a broad category that includes:

1. Unwelcome sex-based conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies the ability of an individual to participate in or benefit from the College’s programs or activities (i.e., Title IX hostile environment sexual harassment)
2. An employee of the College conditioning the provision of an aid, benefit, under the College's educational programs or activities on a person’s participation in unwelcome sexual conduct (i.e., quid pro quo)
3. Sexual assault, dating, violence, domestic violence, or stalking, as defined in the Sexual Harassment and Misconduct Policy

Other gender-based misconduct includes quid pro quo, sexual assault, dating violence, and stalking alleged to have occurred outside of the College’s education programs or activities, and/or alleged to have occurred outside of the United States. Including other gender-based misconduct is important in ensuring members of the College community have access to support services and promotes a safe and non- discriminatory educational and work environment.

Sexual exploitation is defined as any person taking non-consensual or abusive advantage of another for their own benefit or for the benefit of anyone other than the person being exploited. Examples of Sexual Exploitation include, but are not limited to:

1. Sexual voyeurism (e.g., observing a person undressing without their consent)
2. Distributing Authentic or Synthetic Non-Consensual Intimate Imagery (NCII)
3. Invasion of sexual privacy (e.g., doxxing)
4. Knowingly making an unwelcome disclosure of (or threatening to disclose) an individual’s sexual orientation, gender identity, or gender expression
5. Taking pictures, videos, or audio recordings of another person in a sexual act or sexually related activity when there is a reasonable expectation of privacy without their consent
6. Causing or attempting to cause the incapacitation of another person, including through alcohol or drugs, for the purpose of compromising that person’s ability to give consent to sexual activity.=

Consent is defined as one’s knowing, voluntary, clear permission by word or action to engage in sexual activity. Consent can be given by words or by clear, unambiguous action. What is essential is that the individual has affirmatively demonstrated their willingness to participate in sexual activity and, as such, consent may not be inferred from silence, passivity, or lack of response or resistance.

Consent must be present at all times. At any time, a person can communicate that they no longer consent to sexual activity, and sexual activity must immediately cease.

Consent should be sought before initiating additional sexual acts. Consent to some sexual activity (such as kissing) does not constitute consent to other sexual activity (such as intercourse), even if the person has previously agreed to engage in such
sexual activity.

Consent is not given if it results from the threat or use of physical force, intimidation, or any other factor that negates free choice.

Title VII of the Civil Rights Act of 1964 prohibits employment discrimination based on race, color, religion, sex, and national origin. It applies to employers and is enforced by the U.S. Equal Employment Opportunity Commission. Title VII protects employees and applicants for employment.

Title IX, on the other hand, prohibits sex-based discrimination, protects employees and students, and is focused on access to education programs and activities. Title VI prohibits discrimination based on race, color, and national origin, protects employees and students, and applies to any program or activity receiving federal financial assistance.

There is no expectation for community members to develop expertise in whether their concerns fall under Title VII, Title IX, or Title VI in order to report to the Office of Civil Rights and Title IX.

In addition to Title VII, Title IX, and Title VI, College Policy is compliant with the Americans with Disabilities Act, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, as well applicable state and local laws, including the Pennsylvania Human Relations Act and Pennsylvania Fair Educational Opportunities Act.

The Office of Civil Rights and Title IX provides in-person training for all new employees and students at the College. Training sessions cover definitions of prohibited conduct, how to make a report, what resolution options the College offers, available supportive measures and resources, and prevention education. Additionally, the Director of Civil Rights and Title IX provides annual training to departments and offices across campus, prevention training for all student-athletes, coaches, and athletic administrators in accordance with the National Collegiate Athletic Association (NCAA), and partners with OwlWell, BMC’s holistic wellness program, to provide bystander education.

Employees of the College are also required to complete annual online training modules, which can be found using the United Educators Learning Portal.

To request tailored training for you, your organization, department, or office, please contact the Director of Civil Rights and Title IX at ccarr1@brynmawr.edu or 610-526-7863.

BMC community members can provide feedback by utilizing the College’s Feedback Form on the Interim Discrimination, Discriminatory Harassment, and Retaliation Policy. They can also contact Cary Carr, Director of Civil Rights and Title IX, directly by emailing ccarr1@brynmawr.edu or calling 610-526-7863.

The College takes all community members’ feedback and questions into consideration. Further, the Sexual Misconduct and Discrimination Policies and associated procedures will be reviewed regularly to comply with recent changes to federal or state laws, implementing regulations, and enforcement guidance on nondiscrimination protections.