If you have questions about this procedure:
Regarding student complaints, please contact Kerry Levett levettk@lanecc.edu in the Office of Academic and Student Affairs, and
Regarding staff complaints, please contact Dennis Carr carrd@lanecc.edu in the Human Resources department.
Purpose
Introduction
Reporting Discrimination or Harassment
Other Types of Complaints
Employee Options for Reporting
Confidentiality
Retaliation Complaints
Complaint Investigation Processes
Procedural Appeal Process
Impartial Decision Maker/Conflicts of Interest/Records
Purpose
The Lane Community College Board of Education policies prohibiting discrimination and harassment may be found at Board Policy D.020 "Harassment" and Board Policy D.060 "Equality of Opportunity." There are also administrative policies prohibiting discrimination and harassment, including Harassment Based on Race/Ethnicity or National Origin, Harassment Based on Sexual Orientation, Gender Identity, Gender Expression, Religion, or Disability, and Harassment, Sexual: General.
This procedure explains the reporting process if you believe an employee or student has violated any of the College's discrimination and harassment policies.
This discrimination and harassment complaint procedure is designed to provide all members of the College community with a process for reporting incidents of discrimination or harassment, and to provide for prompt and effective response to and resolution of reports of discrimination or harassment.
Introduction
The Lane Community College Board of Education policies prohibiting discrimination and harassment may be found at Board Policy D.020 "Harassment" and Board Policy D.060 "Equality of Opportunity." This procedure explains the reporting process if you believe an employee or student has violated the College's discrimination and harassment policies. This procedure outlines the complaint processes for the types of behaviors which are alleged to be violations of College and Board of Education discrimination and harassment policies. A violation includes acts of discrimination and harassment that are gender-based, race-based, based on ethnicity, national origin, gender identity and expression, sexual orientation, age, religion or disability, or reports of retaliation arising out of reports of discrimination, harassment or whistle-blowing.
Retaliation against the complainant is expressly forbidden. An individual who is subjected to retaliation (e.g. threats, intimidation, reprisals, damage to one's reputation, or adverse employment or educational actions) for having made a report of discrimination or harassment in good faith, who assisted someone with a report of harassment or discrimination, or who participated in any manner in an investigation or resolution of a report of harassment or discrimination, is encouraged to make a report of retaliation under these procedures. Retaliation claims should be initiated as a new complaint following this procedure.
This discrimination and harassment complaint process is designed to provide all members of the College community with a process for reporting incidents of discrimination or harassment; and to provide for prompt and effective response to and resolution of reports of discrimination or harassment. All members of Lane Community College are encouraged to contact one of the persons listed below if they observe or encounter conduct that may be subject to the College's policies Harassment Based on Race/Ethnicity or National Origin, Harassment Based on Sexual Orientation, Gender Identity, Gender Expression, Religion, or Disability, or Harassment, Sexual: General. Days as described in this procedure represent College business days.
Reporting Discrimination or Harassment
Reports of discrimination or harassment may be made to any of the following contact persons:
Employees: Employees should contact one of the following:
1. Contacts for Complaint Referrals:
- Human Resources Managers (541) 463-5586
- Office of Academic and Student Affairs (ASA) – Executive Deans (541) 463-5037
- Office of the Chief Diversity Officer (541) 463-3655
2. Complaint Process Guidance: Contact any of the following Complaint Resolution Administrators (CRAs):
- Chief Diversity Officer (541) 463-5037
- Any Executive Dean in the Office of Academic and Student Affairs (ASA) (541) 463-5037
- Associate Deans in Student Affairs who are the lead Judicial Advisors for ASA (541) 463-5037
- Chief Human Resource Officer (541) 463-5585
- Human Resource Manager(s) (541) 463-5586
Assistance is available for bilingual – Spanish
The role of the Complaint Resolution Administrator is primarily to assist in resolving informal harassment and discrimination complaints and to monitor and manage the formal complaint process. In addition, the President or their designee may, at their sole discretion, designate an administrator of their choice to be the Complaint Resolution Administrator for a particular matter.
Students: Students who have complaints about discrimination and harassment should contact one of the following student contact/support people:
1. Women's Center, Building 1, Room 202, (541) 463-5353;
2. Counseling Center, (541) 463-5178;
3. Multicultural Center, (541) 463-5144
Assistance is available for bilingual – Spanish
4. Office of Academic and Student Affairs, Executive Deans, (541) 463-5037
The role of the student contact personnel is to provide students with informal and formal options concerning the proper process by which to pursue their complaint.
Student Complaints:
Complaints by students against staff or third parties that allege violations of law or College policies regarding discrimination or harassment will be handled through this procedure. Complaints by students against other students that allege violations of law or College policies regarding discrimination or harassment will be handled through the Student Code of Conduct. The above-referenced contact/support personnel are also available to assist students with complaints about Student Code of Conduct violations.
Other Types of Complaints
1. Anonymous Complaints: The College will respond to the extent possible to anonymous reports of discrimination or harassment or reports made by third parties not directly involved in the discrimination or harassment. However, the response to such reports may be limited if information contained in the reports cannot be verified by independent facts.
2. Workplace Conflicts: Workplace conflicts that do not allege violations of employment laws, equal educational opportunity laws or affirmative action violations (or College policies related to these laws) will be referred to the College's workplace conflict resolution processes (see Workplace Conflict: Formal Complaint Process).
3. Employee Contracts: Complaint processes and time lines will be consistent with collective bargaining agreements of the represented employee group. Included in collective bargaining agreements are time lines governing the processing of complaints. Time lines must be adhered to unless extensions of time lines have been granted by the respective Union president or a designee; approval of requests for time line extensions shall not be unreasonably withheld. Complainants and accused employees who are subject to a collective bargaining agreement may consult with Union representatives for support, guidance and representation.
Employee Options for Reporting
1. Informal Reports: Informal reports are intended to resolve concerns at the earliest stage possible. The use of the informal reporting process serves the dual purpose of educating the College community about discrimination and harassment while working directly and confidentially with the parties involved. Resolution of informal reports may include discussions with the parties, making recommendations for resolution, and conducting a follow-up review after a period of time (see formal complaint step #7 below) to assure that the resolution has been implemented effectively. See below for more details regarding this process.
2. Formal Reports: The Formal Report process will generally be used when the informal report for early resolution is inappropriate (e.g. when the facts are in dispute regarding allegations of serious misconduct or there are reports of a pattern of inappropriate behavior/alleged criminal acts such as stalking, sexual assault or physical assault) or in cases where the informal process is unsuccessful. See below for more details regarding this process.
Confidentiality
The College will protect the privacy of individuals involved in a report of discrimination or harassment to the extent allowed by law and College policy. However, there may be times when disclosure of information is required. For example, when a written complaint is filed the accused will always receive a copy of the complaint including the name of the individual(s) who filed the complaint except when disclosure is prohibited by law or when grades are still pending for students. In all cases, efforts will be made to protect the privacy of individuals. An individual who has made a report of discrimination or harassment may be advised of sanctions imposed against the accused when the individual needs to be aware of the sanction in order for it to be fully effective (such as restrictions on communication or contact with the individual who made the report). However, information regarding disciplinary action taken against the accused shall not be disclosed without the accused's consent, unless it is necessary to ensure compliance with the action or the safety of individuals.
Retaliation Complaints
As noted above, retaliation against the complainant is expressly forbidden. The College will inform employees that the institution will make reasonable efforts to safeguard the complainant's rights against retaliation by taking prompt and appropriate corrective action when necessary. Retaliation claims should be initiated as a new complaint following this procedure.
Complaint Investigation Processes
Complaints from employees and students alleging violations of any of the College's policies Harassment Based on Race/Ethnicity or National Origin, Harassment Based on Sexual Orientation, Gender Identity, Gender Expression, Religion, or Disability, or Harassment, Sexual: General will be referred to applicable complaint investigation procedures. Conduct such as engaging in harassment or discrimination, retaliating against a complainant or those who report claims of discrimination or harassment, violating interim protections or terms of confidentiality, and filing intentionally false charges of harassment are all examples of a violation of the policy. Findings made pursuant to this policy may be used as evidence in subsequent complaint resolution and disciplinary proceedings as permitted by the applicable procedures.
1. The Informal Reporting Process
When is the informal reporting process appropriate? An informal report is appropriate when the parties desire to resolve the situation cooperatively. Informal reports may be appropriate for responding to anonymous reports and/or third party reports. The College encourages early resolution of a complaint. However, the formal report process will be used when the informal process for early resolution is inappropriate (e.g. allegations of serious misconduct, reports of a pattern of inappropriate behavior, alleged criminal acts such as stalking, sexual assault or physical assault). The Complaint Resolution Administrator may enlist any help she or he chooses to resolve a complaint on an informal basis.
What is the informal reporting process?
Step 1: If an individual believes they have been the victim of discrimination or harassment, it is important to discuss the incident with a Complaint Resolution Administrator (CRA) or one of the student contact people listed above. The Complaint Resolution Administrators and student contact persons identified above have been trained in discrimination and harassment complaint procedures. Discussion of the incident(s) with a student contact person or Complaint Resolution Administrator can be arranged at a time and place on campus that is convenient for the complainant. See CRAs/Contact Persons (above) for information regarding who to contact.
All informal complaints will be resolved by or in collaboration with a Complaint Resolution Administrator.
Step 2: The complainant should carefully consider the informal options for early resolution that may be proposed by the Complaint Resolution Administrator. In some situations, it may be possible for the Complaint Resolution Administrator to resolve the concern without the direct involvement of the complainant. Early resolution of informal reports could encompass a full range of possible appropriate outcomes including, but not limited to, mediating an agreement between the parties; separating the parties; referring the parties to counseling programs; conducting targeted educational and training programs; or working with appropriate administrators to provide remedies acceptable to the complainant.
Step 3: Decide on the course of action. The assigned Complaint Resolution Administrator (CRA) is accountable for informing all parties to the complaint about applicable time lines, including complaint time lines outlined in union contracts. If a complainant chooses to attempt to informally resolve the problem, the complainant and CRA must decide how to proceed (see Step 2 for examples). After discussing the incident with the CRA and/or student contact person, the complainant may also decide to go no further with the complaint.
Step 4: Take the action decided upon with the assistance of the Complaint Resolution Administrator. The Complaint Resolution Administrator is accountable for informing the complainant and all parties with a right to know about the complaint concerning the actions taken to resolve the complaint through the informal process.
Step 5: If a complainant is not satisfied with the results of the informal resolution and decides to file a formal complaint, the Complaint Resolution Administrator may explain the formal complaint process to the complainant and may assist with the formal process. If a complainant chooses to file a formal complaint after engaging in the informal complaint process, the complainant must file the formal complaint no later than five (5) working days after the conclusion of Step 4, unless there is a new incident. The Complaint Resolution Administrator will provide guidance to the complainant, including guidance about the importance of compliance with time lines.
Step 6: The Complaint Resolution Administrator will review the informal complaint resolution at various post-complaint intervals described below under Step 7 in the Formal Complaint Procedure "Post-complaint Review of Informal and Formal Complaints."
Step 7: Record Keeping – The only college record that will be kept of informal unwritten discrimination or harassment complaint reports will be by type of incident, department and the relationship of those involved. The Complaint Resolution Administrator is accountable for assuring that all complaint records, including post-complaint review documentation (see formal step #7 below), are provided to the Human Resource Department so that all documentation of the complaint is maintained in the official confidential complaint record in the Human Resource Department. Records of student to student harassment complaints will be confidentially maintained in the Office of Academic and Student Affairs.
A discrimination/harassment incident report that summarizes all informal discrimination and harassment complaint reports, as well as formal discrimination and harassment complaints, will be forwarded by College Human Resources to the president, vice presidents and all executive dean and directors on a periodic basis. No information that would identify the parties to such complaints will be included in this report.
2. The Formal Reporting Process
When is the formal reporting process appropriate? The formal report process will be used when the informal report for early resolution is inappropriate (e.g. allegations of serious misconduct, reports of a pattern of inappropriate behavior, alleged criminal acts such as stalking, sexual assault or physical assault) or in cases where the informal process for early resolution is unsuccessful.
Before filing a formal complaint, the complainant should consult with a Complaint Resolution Administrator.
The Vice President is the decision-maker in the formal complaint process. In addition, the President may, at their sole discretion, designate an administrator of their choice to be the decision-maker for a particular matter. In that case the designated decision maker will take the role of the Vice President in the formal complaint process.
The Complaint Resolution Administrator will continue to provide administrative oversight to the process to ensure that all steps are followed.
Step 1: You must complete the written Formal Harassment Complaint Form. Copies of the form are available from Human Resources.
Step 2: You must deliver the completed Formal Harassment Complaint Form to Human Resources, to the Office of Academic and Student Affairs or to the Office of the Chief Diversity Officer.
Step 3: Within five (5) working days of the date the complaint was received by Human Resources, the Office of Academic and Student Affairs, or the office of the Chief Diversity Officer, the Vice President, in consultation with the Complaint Resolution Administrator, will determine whether the complaint may be credible such that an investigation is necessary. Complaints will be deemed to be credible if they allege violations of the College's Discrimination and Harassment policies, or allege violations of state or federal discrimination and harassment laws and administrative rules. Where complaints are determined by the Vice President or their designee to be credible the Vice President or their designee will provide that a timely investigation of the complaint is completed. Once it is determined that an investigation is necessary, the Vice President or their designee will also provide the complainant and the accused with written notice of receipt of the complaint, a copy of the formal complaint procedure, and a copy of the complaint.
The Vice President's notification will include the name(s) of the assigned complaint resolution administrator(s) and the name(s) of the investigators. The Vice President or their designee will provide written notice of the complaint to the department supervisors for any College employee named in the complaint. If the complainant or the accused are represented employees, the Vice President or their designee will also provide written notice of the complaint to the respective Union that represents the complainant and the accused.
Complainants and accused employees who are subject to a collective bargaining agreement have a right to have a Union representative present during investigatory meetings/interviews.
The Complaint Resolution Administrator will meet individually with the complainant and the accused in order to assess and facilitate complaint process compliance as well as make recommendations regarding next steps to the Vice President for further action before proceeding to Step 4.
During the investigation process, the complainant and the accused are not to contact each other about the complaint. All parties to a complaint are expected to fully cooperate with any investigation in a timely manner. If the complainant refuses to cooperate, the complaint may be deemed withdrawn at the sole discretion of the Vice President. If the accused refuses to cooperate, the failure to cooperate may be considered in the College's decision.
Step 4: The Vice President, in consultation with the Complaint Resolution Administrator, will undertake a timely investigation of the complaint. The investigation may be conducted by the Vice President, other College administrators, or an outside investigator, to be determined by the Vice President. The Vice President will determine the scope of the investigation. The Vice President will notify the complainant and the accused in writing concerning the name of the investigator and the time frame during which the investigation process will take place. The investigator's function is fact-finding. Decisions about findings will remain the responsibility of the investigating Vice President.
Process: The Vice President or an investigator designated by the Vice President will conduct a fact-finding investigation, which will include interviewing individuals having first-hand knowledge of the incident, including both the complainant and the accused. Complainants and accused employees who are subject to a collective bargaining agreement have a right to have a Union representative present during investigatory meetings/interviews. Accused employees may respond to the complaint or not, but are advised that failure to respond to the allegations and evidence may be considered in the College's decision. Other evidence will be reviewed as determined appropriate by the investigator and the Vice President. Disclosure of facts to parties and witnesses shall be limited to what is reasonably necessary to conduct a fair and thorough investigation. Participants in an investigation will be advised that maintaining confidentiality is essential to protect the integrity of the investigation. The statements of witnesses contained in the investigator's report will be kept as confidential as possible. The investigator, if it is someone other than the Vice President, will prepare an executive summary of the facts for the Vice President. All persons interviewed by the investigator will be provided the opportunity to review the investigator's record of their own statements before the final report is prepared. If the Vice President determines that additional investigation is required, the Vice President will inform the parties to the complaint in writing of the extension of timelines, the names of any additional witnesses to be interviewed, and the Vice President will advise the complainant and the accused concerning any other timeline changes that will be necessary as the result of this extension.
Step 5: Within thirty (30) working days of the date of receipt of the Formal Complaint Form, the Vice President will provide written notice of findings to all parties to the complaint. The notice of findings will include an explanation of the Vice President's findings and will be kept as confidential as possible. The Vice President will inform the complainant whether there were findings that the harassment and discrimination policy was violated and any actions taken that are directly related to the complainant (such as an order of no contact). In compliance with the College's policies protecting individuals' privacy, the complainant may generally be informed that the matter has been referred for disciplinary action, but shall not be informed of any disciplinary action without the consent of the accused, unless such information is necessary to the complainant in order to assure compliance with the findings and recommendations. Either the complainant or the accused may request a meeting with the Vice President and/or the Complaint Resolution Administrator following receipt of the Vice President's written notice of findings.
Step 6: After the complainant and the accused have been notified of the Vice President's findings, the Complaint Resolution Administrator will forward the official complaint file to the President's Office pending notice of appeal. If there is no notice of appeal submitted within five (5) working days of the Vice President's notification (read above), the Vice President will confirm the findings of the official complaint file to the College President for final action (read step #4 at the end of the appeal procedure below).
When a violation of discrimination and harassment policies is substantiated in a final decision, the Vice President's findings will include a recommendation for appropriate remedial action.
Step 7: Post-complaint Review of Informal and Formal Complaints
Following the closure of a formal or an informal complaint, the college will review the actions it has taken. When there are findings of violations of discrimination or harassment policies (Harassment Based on Race/Ethnicity or National Origin, Harassment Based on Sexual Orientation, Gender Identity, Gender Expression, Religion, or Disability, or Harassment, Sexual: General) the Complaint Resolution Administrator involved will review the effectiveness of any remedial action imposed as a result of the complaint at the following post-complaint intervals.
1) Two to Four Weeks after a finding of fault in the Vice President's Written Notice of Findings or resolution of the informal complaint the Vice President, a designee, or the CRA will meet with complainant and accused employee(s) or student(s) to confirm that the resolution, if any, has been implemented as intended by the parties and/or that neither the complainant nor the accused has experienced any new problematic conduct that is of concern and that neither the accused nor any other employee has engaged in conduct towards the complainant that is motivated by retaliation.
2) Three months after a finding of fault in the Vice President's Written Notice of Findings or resolution of the informal complaint the Vice President, a designee, or the CRA will meet with complainant and accused to confirm that no new problematic conduct has occurred and that neither the accused nor any other employee has engaged in conduct towards the complainant that is motivated by retaliation.
The Complaint Resolution Administrator is accountable for documenting the post-complaint review procedures. All documentation developed by the CRA in the post-complaint review process must be timely delivered to the Human Resource Department for inclusion in the confidential official complaint file.
The Complaint Resolution Administrator will document the post-resolution review findings. For employee complaints, all documentation is to be maintained in the official complaint file in Human Resources.
Procedural Appeal Process
Either the complainant or the accused may file an appeal of the Vice President's written notice of findings. An appeal on the record of the Vice President's findings is limited in scope to whether the College followed its own process. ANY APPEAL MUST BE SUBMITTED IN WRITING TO THE PRESIDENT WITHIN FIVE (5) WORKING DAYS OF THE DATE OF THE VICE PRESIDENT'S WRITTEN NOTICE OF FINDINGS. This appeal must allege a procedural violation. THE APPEALS PROCESS IS NOT FOR THE PURPOSE OF DISPUTING THE VICE PRESIDENT'S FINDINGS. It is the President's responsibility to make sure that the process was followed and the investigation was conducted fairly for all parties involved. No new evidence may be submitted through the appeals process.
Step 1: Upon receipt of the written request for an appeal, the President or their designee will contact the chair of the Harassment /Discrimination Hearings Committee. In consultation with the President or their designee, the chair of the Harassment/Discrimination Committee will first assess whether the appeal documents procedural concerns that if substantiated would be violations of, or exceptions to, the complaint procedure. If the chair confirms the appeal poses credible procedural concerns, the chair will convene the Harassment/Discrimination Committee for an administrative review hearing within 10 working days of receipt of the written request for appeal.
Step2: The hearings committee conducts a confidential administrative review hearing. Normally, the official record will include the following items: the original complaint; the investigator's report (including statements of witnesses) and the Vice President's notice of findings and remedies.
Before adjourning to executive session for its deliberations, the hearings committee may invite brief written or verbal statements from the complainant and the accused. The hearings committee will not hear new witnesses or statements from other parties. Both the complainant and the accused may bring one representative or support person (eg. a union representative if the complainant or the accused are represented by a union) to the administrative review hearing for support and advice. Confidentiality will be maintained with regard to the hearing and the complaint in order to protect the due process rights of both parties.
The hearings committee may develop additional procedural guidelines that are not in conflict with this procedure of which the complainant and the accused will be notified in advance.
Step 3: The hearings committee submits a written report of findings and recommendations to the College President.
The hearings committee will have up to 5 working days from the date of the hearing to submit a written report of its findings to the President. The findings will address the Vice President's application of harassment/discrimination policies and law to the facts of the situation. The review by the hearings committee is limited to whether or not the College properly followed the complaint procedure. If the hearings committee finds that the complaint procedure was not followed, the hearings committee may recommend that the investigation be corrected. The hearings committee will not conduct this procedural correction. Procedural corrections will be implemented by the Vice President or the designated investigator consistent with Step 4 (read above).
The Vice President will consider the hearings committee's recommendation and either confirm the need for a correction or verify that the original process was completed properly. If the Vice President confirms the need for a process correction and the accused employee is a member of a represented work group then the Vice President or a designee will request an extension of the contractual complaint time lines from the appropriate Union; approval of such requests for time line extensions will not be unreasonably withheld. The Vice President will also inform the complainant and the accused concerning the need for procedural corrections. The Vice President will notify the complainant and the accused when any such procedural corrections are completed, and before referring the decision to the College President. The Vice President may either confirm the original decision or submit an addendum for the decision to the College President within 10 days from the date the hearings committee recommends the correction.
The hearing committee's report may include both majority and dissenting opinions.
Step 4: The College President notifies the complainant and the accused of the decision.
The President has up to 10 working days to review the hearing committee's report, review the Vice President's decision and addendum (if any), make a final decision about the complaint and send written notification of that decision to the complainant and the accused. The College President shall assure delivery of the final decision to the complainant and the accused.
Notification of the President's decision may be delivered to the complainant directly by a representative of the college or by the US Postal Service, depending upon the circumstances and the complainant's location.
If no procedural appeal is filed after the initial decision from the Vice President is delivered to the complainant and the accused consistent with step #6 (see above), or no further action is recommended after appeal, the College President will return the official complaint file to Human Resources after delivery of the final decision to the complainant and the accused..
Impartial Decision Maker/Conflicts of Interest/Records
Impartial Decision Maker: Anyone involved in the processes described above who believes that the Vice President, a Complaint Resolution Administrator or an investigator cannot be impartial should immediately notify the College President of his or her concerns and the reasons for his or her belief that bias or prejudice exists. Allegations of bias should be based on the party's belief that either the assigned Vice President, the Vice President's designee, the Complaint Resolution Administrator or the assigned investigator has had contact or prior significant involvement with any party named in the complaint and that such contact or involvement prevents the individual from assessing the facts without bias or, that the Vice President, the Vice President's designee, the Complaint Resolution Administrator or the investigator may personally benefit or avoid detriment from the outcome of the investigation. This notice must be received in the Office of the College President within five (5) working days of the date of the notice of findings concerning the complaint from the Vice President or their designee (see Formal Complaint Process step #3 above). If the College President believes the objection has merit, the decision making will be promptly assigned to another Vice President, an appropriate Complaint Resolution Administrator, a designated administrator or an alternative investigator.
Conflicts of Interest: The College is committed to objective evaluation of complaints and will take affirmative steps to avoid any actual or apparent conflict of interest in the investigatory process. Conflicts of interest may arise or appear to arise if the Vice President, their designee, a Complaint Resolution Administrator or an investigator is simultaneously involved in the formal complaint process and another process that either party has engaged in to resolve the issues. If any of the parties believe that there is a real or potential conflict of interest for any Complaint Resolution Administrator, the Vice President, the Vice President's designee or the investigator involved in the complaint, they should bring their concerns to the notice of the College President, the Vice President or other designated decision maker for resolution. If a real or apparent conflict of interest exists then the College President, the Vice President or other designated decision maker will assign another Complaint Resolution Administrator or investigator to assist in the process. No Complaint Resolution Administrator or investigator in a given complaint process will be assigned an advisory or decision making role in another process such as the grievance process that has been initiated based on that complaint.
Records: The only College record that will be kept of an informal complaint for early resolution will be by type of incident, department and the relationship of those involved. All records of the formal complaint process, including the complaint form and all reports and findings as well as all documentation concerning the post-complaint review processes, will be delivered to the Human Resource Department for compliance review and placement in the secured and confidential complaint file.
A Discrimination or Harassment Incident Report that summarizes all informal reports and formal complaints and resolution by type of incident and the relationship of those involved is summarized and presented to the Lane Board of Education annually in the Treatment of Staff and Treatment of Learners Reports. No information that would identify the parties involved will be included in this report.