Health and Safety

  • Security and Safety Reports
  • Drug and Alcohol Policy

    See Nashotah House's Student Handbook Appendix C-1

    Standards of Conduct: In a good faith effort to comply with the Drug-Free Schools and Communities Act of 1989, Nashotah House Theological Seminary prohibits the unlawful possession, use, distribution, manufacture or dispensing of illicit drugs (“controlled substances” as defined in Ch. 161, Wis. Stat) by students on Seminary property or as part of Seminary activities.


    State: The laws of Wisconsin prohibit drug possession and delivery through the Uniform Controlled Substances Act, Wis. Stat. 161, and mandate stiff penalties that include up to 15 years of prison and fines up to $500,000. A person with a first-time conviction of possession of a controlled substance can be sentenced up to one year of prison and fined up to $5,000, Wis. Stat. 161.41 (2r) (b). The penalties vary according to the amount of drug confiscated, the type of drug found, the number of previous offenses by the individual and whether the individual intended to manufacture the drug, sell the drug or use the drug. (See Wis. Stat. 161.41.) In addition to the stringent penalties for possession or delivery, the sentences can be doubled when exacerbating factors are present, such as when a person distributes a controlled substance to a minor, Wis. Stat. 161.46 (1).

    Substantial restrictions against alcohol abuse also exist in Wisconsin. It is against the law to sell alcohol to anyone who has not reached the legal drinking age of 21, and there is a concurrent duty on the part of an adult to prevent the illegal consumption of alcohol on his/her premises, Wis. Stat.125.07 (1) (a) (1). Violation of this statute can result in a $500 dollar fine. It is against the law for an underage person to attempt to buy an alcoholic beverage, falsely represent his/her age, or enter a licensed premises. Violators of this law can be fined $500, ordered to participate in a supervised work program, and have their driver’s license suspended, Wis. Stat. 125.07(4) (3). Harsher penalties exist for the retailers of alcoholic beverages who violate it, including up to 90 days in jail and revocation of their retail liquor permit.

    Federal: The federal government has recently revised the penalties against drug possession and trafficking through its Federal Sentencing Guidelines. These guidelines reduce the discretion that federal judges may use in sentencing offenders of federal drug statutes. Under these guidelines, courts can sentence a person for up to six years for unlawful possession of a controlled substance, including the distribution of a small amount (less than 250 grams of marijuana). A sentence of life imprisonment can result from a conviction of possession of a controlled substance that results in death or bodily injury. Possession of more than 5 grams of cocaine can trigger an intent to distribute penalty of 10-16 years in prison, U.S.S.G, s. 2D2.1 (b) (1).

    Seminary: The Executive Staff (the Deans and Director of Student Life) will review all offenses and apply appropriate sanctions including counseling and/or appropriate disciplinary measures, up to and including termination or expulsion.

    Health risks: Drugs are a hidden habit, but they have visible effects on the user. Whether the drug of choice is alcohol, marijuana, a prescription drug or cocaine, the habit can lead to a change in personal or study habits, too. Some people may believe that drugs are harmless or even helpful. The truth is that drugs can have very serious, long-term physical and emotional health effects. And if drugs are mixed, the impact is even more detrimental. The following is a partial list of common drugs and some of the consequences of their use. Only some of the known health risks are covered, and not all legal or illegal drugs are included:

    Alcohol is the most commonly abused substance. It can lead to poor judgment and coordination, drowsiness and mood swings, liver damage and heart disease.

    Marijuana is an addictive drug, although many still believe that it is harmless. It can cause short-term memory impairment, slowed reaction time, lung disease and infertility.
While cocaine and crack can speed up performance, their effect is short-lived. More lasting risks are short attention span, irritability and depression, seizure and heart attack.

    Prescription drugs are often used to reduce stress. However, they are not safe either, unless they are taken as directed. If abused, they can lead to sluggishness or hyperactivity, impaired reflexes, addiction and brain damage.

    Other drugs, such as PCP, LSD, heroin, mescaline and morphine, have a wide variety of negative health effects – from hallucinations and mental confusion to convulsions and death.

    Resources and Treatment: Students who have problems with alcohol or controlled substances are encouraged to contact Student Services, located in St. John’s House for a list of Health Services.

    Summary: All students are strongly encouraged to help make the Seminary a drug-free place to live and learn. You can do this by learning about substance abuse (its dangers and warning signs), encouraging others to avoid substance abuse, and getting help if you need it – either for yourself or for someone you are concerned about.

    Statement on Chemical Dependencies

    Nashotah House recognizes that alcoholism and other drug dependencies are treatable diseases. We understand the pervasive nature of chemical dependencies; the destructive way these harm the body, soul and spirit of individuals; and how interpersonal relationships within the family, or communities, are impacted by dependent, abusive or inappropriate alcohol or drug use. We believe that the Church, as a redemptive fellowship of Christian believers, must be sensitive to the need for exercising a healing ministry to any individual suffering from alcoholism or any other drug addiction. The Dean, as chief pastor of the House, will support, assist, and encourage any such member of the Nashotah House community (faculty, staff, student body, and dependent members thereof) to seek treatment. Whenever intervention is warranted, the Dean will on a case-by-case basis be consulted about an appropriate course of action.

    Alcohol Use Policy

    The alcohol use policy of Nashotah House is intended to foster responsibility in the consumption of alcoholic beverages at all seminary-sponsored events or functions.

    1. Alcoholic beverages are not required to be served at any seminary function, except the Eucharist.
    2. When alcoholic beverages are served, non-alcoholic beverage alternatives must be present, attractively displayed and available in sufficient quantity and with ease of access.
    3. Beverages not in original containers must be clearly marked as to whether they are alcoholic or alcohol-free. The serving of distilled beverages is discouraged.
    4. Whenever alcohol is served, so should food.
    5. Access to alcoholic beverages is to be carefully controlled to insure that minors are never served alcoholic drinks.
    6. Intoxication is always considered inappropriate and potentially damaging behavior. Intoxicated persons are not to be served alcoholic beverages.
    7. Functions sponsored by groups outside of the Nashotah House community that take place on seminary property must conform to this policy.

    Policy Dissemination

    A copy of the policy will be provided to all students, faculty, and staff as well as all off-campus groups seeking to use seminary property.


    It will be the responsibility of the members of the Nashotah House community to promote compliance with all aspects of this policy, which will be administered by the Dean.

    Nashotah House Drug Policy

    It is prohibited for any student or employee of Nashotah House Seminary to possess, use, distribute, deliver or sell illicit drugs to anyone (including prescription drugs without a medical doctor’s consent).

    Any student found to be using, to have used, to have possessed or to possess illicit drugs while enrolled will be given a choice of entering a formal, recognized drug/alcohol abuse program or being dismissed from the seminary. The relevant facts will be reported to the local authorities.

    Any employee found to be using, to have used, to have possessed or to possess illicit drugs while employed by the seminary will be given a choice of entering a formal, recognized drug/alcohol abuse program or having their employment terminated, and the relevant facts will be reported to the local authorities.

    The Dean or a designee(s) will be responsible for examining the facts of each case and a recommendation for action will be made within ten calendar days.

Policies and Procedures

  • Privacy of Student Record: Family Educational Rights and Privacy Act (FERPA)

    “The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.

    Schools may disclose, without consent, “directory” information such as a student's name, address, telephone number, date and place of birth, honors and awards, and dates of attendance. However, schools must tell parents and eligible students about directory information and allow parents and eligible students a reasonable amount of time to request that the school not disclose directory information about them. Schools must notify parents and eligible students annually of their rights under FERPA. The actual means of notification (special letter, inclusion in a PTA bulletin, student handbook, or newspaper article) is left to the discretion of each school.”

    For additional information see Appendix C of the current Nashotah House Catalog. For technical assistance, you may call (202) 260-3887 (voice). Individuals who use TDD may call the Federal Information Relay Service at 1-800-877-8339.

  • Disability Services at Nashotah House

    Nashotah House is committed to treating all students with dignity and respect, and to providing equal access to all programs and services for students with disabilities.

    In keeping with federal law as articulated in Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (ADA) of 1990, and the Americans with Disabilities Act Amendments Act of 2008, we recognize as disabled an individual with a clinically documented condition or impairment that substantially limits one or more life activities (e.g., mobility, perception, articulation, learning, etc.).

    Individuals seeking academic accommodations due to a documented disability must apply and provide supporting documentation to the Associate Dean for Academic Affairs. It is the student’s responsibility to arrange for testing, provide documentation, and make this request. The Associate Dean for Academic Affairs will review the request and consult with the student about appropriate accommodation options. In the event the request is granted, the Associate Dean will communicate with members of the faculty regarding appropriate accommodations.

    Individuals seeking other (non-academic) forms of accommodation due to a documented disability must apply and provide supporting documentation to the Associate Dean for Student Affairs. It is the student’s responsibility to arrange for testing, provide documentation, and make this request. The Associate Dean will review the request and consult with the student about appropriate accommodation options. In the event the request is granted, the Associate Dean will communicate with appropriate members of the staff regarding accommodations.

  • Student Complaint Policy


Sexual Harrassment Policy

  • TITLE IX Overview

    Title IX of the Educational Amendments of 1972 to the 1964 Civil Rights Act states that:

    No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.

    This law prohibits gender discrimination based on sex in educational programs and activities of an institution of higher education that receive Federal financial assistance.  It also requires institutions to prevent discrimination and respond to concerns or allegations of discrimination including, but not limited to, harassment and assault.

    At Nashotah House, Title IX applies to all programs and activities available to students; these include but are not limited to the admissions process, academic programs, certificate programs, financial aid, residential life, and student services. The seminary’s policies and procedures relating to Title IX are founded on the federal and state laws, and they are guided by its mission. All students who matriculate at the seminary take the following Matriculation Oath and sign the record book:

    "I hereby promise on my conscience and honor to obey during the term of my residence the Statutes and Regulations of Nashotah House; to submit myself respectfully to its authorities, and in general, to conduct myself as becomes a Christian and, if it be the case, a Candidate for Holy Orders."

    In 1991, the General Convention of the Episcopal Church passed Resolution B052 in which it declared that sexual abuse, exploitation, coercion, and harassment of adults and minors by clergy and church employees are abuses of trust, a violation of the Baptismal Covenant, contrary to Christian Character, and are therefore wrong.  While laws related to paid staff and church volunteers differ between the two categories and differ from higher education laws, it is the policy of Nashotah House that those individuals preparing for service in the Church:

    • Understand definitions and the nature of prohibited behavior
    • Have available to them procedures for reporting violations
    • Receive training for preventing and responding to concerns or allegations of discrimination, not limited to harassment and assault.
  • A. General Definitions

    COERCION:  Coercion is unreasonable pressure for sexual activity. When someone makes clear to you that they do not want sexual contact, that they want to stop, or that they do not want to go past a certain point of sexual interaction, continued pressure beyond that point can be coercive.

    COMPLAINANT:  Complainant refers to the individual who reported the incident of alleged Prohibited Conduct.

    CONSENT:  In order for individuals to engage in sexual activity of any type with each other, there must be clear, knowing and voluntary consent prior to and during sexual activity. Consent is the voluntary, clear, actively given, positive agreement between the participants to engage in a specific sexual act or activity. Previous relationships or consent does not imply consent to future sexual activity. Consent can be withdrawn at any time once given, so long as that withdrawal is clearly communicated.  Under Wisconsin law, the age of consent is 18. Consensual sexual intercourse with a person under 18 years of age is a criminal offense.

    FORCE: Force is the use of physical violence, and/or imposing on someone physically, to gain sexual access. Force includes hitting, kicking, restraining or otherwise exerting their physical control over another person through violence. Force also includes threats, intimidation (implied threats) and coercion that overcome resistance to produce consent.

    INCAPACITATION: Incapacitation is defined as a state in which a person cannot make rational, reasonable decisions because they lack the capacity to give knowing consent (e.g., to understand the “who, what, where, why or how” of their sexual interaction). Incapacitation can occur mentally or physically, from developmental disability, by alcohol or other drug use, or blackout.

    This policy also covers a person whose incapacity results from mental disability, sleep, involuntary physical restraint, or from the ingestion of “date rape” drugs. Possession, use and/or distribution of any of these substances, including Rohypnol, Ketamine, GHB, Burundanga, etc. is prohibited, and administering one of these drugs to another person is a violation of this policy.

    The use of alcohol or other drugs will never function as a defense for any behavior that violates this policy.

    PROHIBITED BEHAVIOR: Any action, verbal, physical, or otherwise, implicitly or explicitly covered in this policy that violates state laws, the Title IX of the Educational Amendments, and/or the matriculation oath of Nashotah House Students or code of conduct of faculty and staff.  See section B below for specifics.

    RESPONDENT:  Respondent refers to a student, employee, or faculty member who allegedly violated this policy.

  • B. Prohibited Behavior

    1. Sexual Harassment

    Sexual harassment is prohibited by this Policy. Sexual harassment includes unwelcome sexual advances and requests for sexual favors. Other unwelcome conduct which may constitute sexual harassment includes, but is not limited to, the following:

    a. Verbal:

    • repeated sexual innuendos, sexual epithets, derogatory slurs, off-color jokes (for example, jokes that include sexual language, innuendo, references, scenarios, etc.);
    • propositions, threats, or suggestive or insulting sounds (for example, comments about body, sexuality, etc., including insults and innuendo) even if the comment is about someone else;
    • inappropriate e-mail (for example, e-mail that includes sexual jokes or other references of a sexual nature about any person, gossip or speculation about a person’s sexuality, sexual practices, sexual health, pregnancy, virility, etc.). This includes e-mail that was sent accidentally, for example by hitting the “forward” button instead of “reply,” or forgetting that a particular individual or worker is on one of your group lists.

    b. Visual/Non-Verbal:

    • derogatory posters, cartoons or drawings (for example, cartoons and calendars that include nudity, sex acts, provocative poses, innuendo, sexual language, etc.);
    • suggestive objects or pictures (for example, photographs that include nudity, sex acts, provocative poses; wallpaper, Screensavers, or other electronic displays of a sexual nature);
    • graphic commentaries; leering; or obscene gestures (for example, vulgar gestures, gestures simulating sexual acts, “shooting the finger,” kissing the air toward someone or licking the lips in a sexually suggestive or provocative manner).

    c. Physical:

    • Unwanted physical contacts (including touching, interference with an individual’s normal work movement, unwelcome displays of romantic or sexual affection, aggressive physical contact or assault); and/or
    • Making or threatening reprisals to an individual who opposes, objects to or complains about sexual harassment; possession of inappropriate material of a sexual nature on the seminary grounds or its display, duplication, or transmission.

    Such verbal and physical conduct may constitute harassment when:

    • Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, enrollment or other work at the seminary;
    • Submission to or rejection of such conduct by an individual is used as a basis for employment, enrollment or other seminary work decisions affecting such individual;
    • Such conduct has the purpose or effect of unreasonably interfering with an individual’s work or academic performance or creating an intimidating, hostile or offensive working campus environment.

    2. Sexual Assault

    All members of the Nashotah House community have the right to be free from sex discrimination in the form of sexual harassment and unwanted sexual contact.  Sex discrimination, sexual harassment, sexual assault, dating violence, domestic/family violence, and stalking are prohibited by federal law, state law and Nashotah House policy.  The seminary is committed to appropriately addressing alleged acts of sexual harassment and sexual violence whether the behavior occurs on or off campus that impacts students, faculty, staff and/or visitors to the campus.  

    Please note the options below for assistance following any incident of sexual harassment or sexual assault. Remember that in cases of sexual assault, whether or not an individual chooses to formally report an incident, receiving immediate medical attention and/or counseling is vital to the person’s overall health and wellness.  Likewise, seeking immediate medical attention is vital to preserve evidence if an investigation is to follow.

    3. Stalking

    Stalking can be defined in one of two ways:

    • A course of conduct (two or more acts), including any action, method, device or means to follow, monitor, observe, surveil, threaten or communicate about a person
    • Directed at a specific person, or indirectly through a third party
    • On the basis of actual or perceived membership in a protected class
    • That is unwelcome, AND
    • Would cause a reasonable person to feel fear

    Or stalking can be:

    • Repetitive and menacing (purposely or knowingly causes emotional distress)
    • Pursuit, following, harassing and/or interfering with the peace and/or safety of another

    4. Sexual Exploitation

    Sexual exploitation laws and regulations govern pastoral relationships or relationships between adults of unequal power, such as doctor/ patient, therapist/client, or professor/student. Wisconsin law[1] expressly prohibits clergy from developing exploitative relationships with members of their congregations or with other adults over whom they have influence by virtue of their position or role. Nashotah House does not tolerate sexual exploitation in any form. Sexual exploitation is the development or attempted development of a sexual relationship between a person in any ministerial position, lay or ordained, and an individual with whom he or she has a Pastoral Relationship.

    A Pastoral Relationship is a relationship:

    • Between any clergy person and any person:
    • who attends a congregation or other ministry setting (e.g. the seminary) in which the clergy person serves;
    • who seeks ministry from the clergy person
      • OR
    • Between any clergy person or any duly-appointed lay person, whether employee or volunteer, who is authorized to provide and does provide: counseling; pastoral care; spiritual direction or spiritual guidance; ministration of any Sacrament (other than the distribution of the Bread and Wine by a lay person at a public service of Holy Communion); life/leadership/peer coaching; hearing  a person’s confession, in the course of the duly-authorized ministry
      • OR
    • The following ministers licensed under Canon III of the Episcopal Church .4: Pastoral Leaders, Worship Leaders, Preachers, Eucharistic Visitors, and Catechists and those they serve in the course of these ministries.

    Sexual exploitation includes but is not limited to the following actions:

    • Verbal: such as sexual innuendo, indecent proposals, sharing sexual stories, jokes or fantasies, or making inappropriate comments about someone’s appearance.
    • Behaviors: such as inappropriate touching, sending or posting communications with sexual content (correspondence, email, text messages, instant messages, photographs, attachments, phone conversations, voice mail, etc.)
    • Sexualizing a Pastoral Relationship or relationship between a clergy or lay person and anyone to whom he or she provides ministry (e.g., requesting dates, giving unwanted attention, etc.).

    5. Retaliation

    Nashotah House will not take any action in retaliation against any seminary personnel or student who, in good faith and with a genuine belief that he/she has been sexually harassed, brings or voices a complaint pursuant to this Policy or otherwise opposes sexual harassment.  In addition, Nashotah House will not tolerate any retaliatory acts by other individuals.     

    Retaliation is a serious violation of seminary policy and applicable law. If you believe you have been subjected to retaliation in violation of this Policy, you should report your complaint immediately in the manner specified in below.  Individuals will be subject to discipline, up to and including termination if they are found to have retaliated against an individual because such individual (1) in good faith and with a genuine belief that he/she has been subjected to sexual harassment, made an honest complaint about such conduct, (2) participated honestly and in good faith in any investigation into a sexual harassment complaint, and/or (3) in good faith opposed acts of sexual harassment.  

  • C. Procedures for Reporting Suspected Title IX Violations

    If you believe that the actions or words of a faculty member, student, supervisor/manager, co-worker, customer, vendor, volunteer, or other individual in the Nashotah House Seminary community constitutes illegal or prohibited sexual harassment, you have a responsibility to promptly report that behavior to Seminary administration. Prompt reporting enables the Seminary to stop the sexual harassment, before it becomes severe or pervasive. 

    If you believe you have been the victim of any form of sexual harassment or retaliation, you must promptly give notice of your complaint to one or more of the following persons:

    1. Title IX Coordinators

    The individuals listed below make up Nashotah’s Title IX team. The Title IX Coordinator is the designated agent of the Seminary responsible for overseeing Seminary policy, procedures and compliance with Title IX legislation, regulation and case law. The Title IX Coordinator shall document all reports of incidents of sexual harassment.

    The Deputy Title IX Coordinator work with the Title IX Coordinator and may act on their behalf when so designated. Additionally, the Deputy Coordinator serves as a person to whom reports or complaints may be reported, and can investigate complaints. Reports to Nashotah’s Title IX Coordinator and Deputy Title IX Coordinator may be made via email (, phone or in person as set forth below:

    The Title IX Coordinator – Fr. Jason Terhune 262-646-6518 (office)

    The Title IX Deputy Coordinator– Mrs. Robin Little 202-306-5352

    2. Confidential Resources and Reporting

    In order to make informed choices, it is important to be aware of confidentiality and mandatory reporting requirements when consulting campus resources. On campus, some resources may maintain confidentiality, meaning they are not required to report actual or suspected Prohibited Conduct to other Seminary officials, thereby offering options and advice without any obligation to inform an outside agency or individual unless you have requested information to be shared. Other resources must take action when you report an alleged violation to them. The following describes the confidential reporting options :

    a.On-Campus Confidential Reporting Options:

    • Cou nseling Services—local psychologists who have agreed to be available to Nashotah House Students can provide counseling upon request. Contact Student services for a list of available counselors and services.
    • Any member of Nashotah House’s Chaplain Corp—Ordained clergy are also considered to be a confidential reporting option, when providing pastoral counseling in their role as priests. Contact student services for a current copy of the available clergy.
    1. Off-Campus Confidential Reporting Options:

    All of the above resources will maintain confidentiality except in extreme cases of immediate threat or danger, or abuse of a minor.

    3. Non-Confidential Reporting and Resource Options:

    • A “Responsible Individual” – all Nashotah House Staff and Faculty are known as “Responsible Individuals,” which means that they are mandatory reporters of violations of this policy.  You may report complaints to any staff or faculty of Nashotah House
    • Delafield Police Department – 115 Main St, Delafield, WI 53018  Phone: 262-646-6240

    Note: An employee is not required to complain to your supervisor or within your chain of command. In addition, to reporting the offending behavior to one of the people listed above, you are encouraged to speak directly to the individual whose conduct you find objectionable. You are not required to do this and it is suggested for you to consider doing only if you are comfortable doing so. If you decide to speak directly to the person involved, you may find that clear communication can sometimes resolve an issue immediately, as well as build greater understanding between individuals in the Seminary and Church.

    All supervisors and decision-makers are required to report all formal and informal complaints, as well as any suspected or known policy violations, immediately to the Title IX Coordinator, even if you ask the supervisor or decision-maker to keep the complaint confidential, or indicate that you do not wish to file a formal complaint. Seminary personnel are required to report immediately any suspected or known policy violations to the Title IX Coordinator.

    All supervisors and decision-makers are expected to act promptly and appropriately to prevent (1) sexual harassment in the seminary, and (2) retaliation against those who make a good faith complaint of sexual harassment, or those who participate honestly and in good faith in either an investigation of a complaint or oppose illegal or prohibited sexual harassment in the seminary.

    All complaints of sexual harassment will be reviewed and investigated promptly and impartially by the seminary’s management and/or its designee. Complaints may be made verbally or in writing. Once seminary management receives notice of any complaint of sexual harassment it will swiftly determine whether or not a fact-finding investigation is necessary.  If it is determined that a fact-finding investigation is necessary, it will be launched promptly. If necessary, intermediate measures may be taken before completing the investigation to ensure that further sexual harassment does not occur.

    Moreover, Nashotah House will protect the confidentiality of the allegations to the extent possible; however, no individual can be promised or guaranteed strict or absolute confidentiality. For example, information may have to be disclosed to those officials and/or seminary employees and students with a need to know in order to carry out the purpose and intent of this Policy.

    Corrective or disciplinary action will be taken against any seminary student or employee found to have engaged in sexual harassment.  Such action may include counseling and/or appropriate disciplinary measures, up to and including termination or expulsion.

    As the complaining party, you will be given notice, in a timely fashion, of the outcome of the investigation of any formal or informal complaint

  • D. Reporting Options

    The Seminary’s primary concern is the safety of its students, faculty and staff, and to encourage reporting of Prohibited Conduct. All Seminary employees have a duty to report actual or suspected Prohibited Conduct to appropriate officials, though there are some limited exceptions for those with “legal privilege.” Reporting parties may want to consider carefully whether they share personally identifiable details with employees who have a duty to report, as those details must be shared by the employee with the Title IX Coordinator and/or Deputy Title IX Coordinator(s), and/or Delafield PD. To be clear, employees with a duty to report must share all details of the reports they receive.

    1. Complainant may request confidentiality

    If a Complainant does not wish for their name to be shared, does not wish for an investigation to take place, or does not want a formal resolution to be pursued, the reporting party may make such request to the Title IX Coordinator and/or Deputy Title IX Coordinator(s), who will evaluate that request in order to ensure the safety of the campus, in compliance with federal law. In cases indicating pattern, predation, threat, weapons and/or violence, the Seminary may be unable to honor a request for confidentiality. In cases where a Complainant requests confidentiality and the circumstances allow the Seminary to honor that request, the Seminary will offer interim support and measures to a Complainant and the community, but will not otherwise pursue formal action.

    2. Complainant has the right to be taken seriously

    A Complainant has the right and can expect to have complaints taken seriously by the Seminary when reported, and to have those incidents investigated thoroughly and properly resolved through the procedures set forth below. The Seminary will promptly act on any complaint or notice of violation of this Policy when received by the Title IX Coordinator or any Deputy Title IX Coordinator, subject to Complainant’s request for confidentiality. The Seminary will not discipline a student who makes a good faith report of Prohibited Conduct.

    3. Expectations of privacy for Complainant

    Reporting still affords some privacy to the reporter. Information will be shared only as necessary with people who need to be told (e.g., investigators, witnesses, and the responding party/parties). The number of people with this knowledge will be kept as small as possible to preserve a reporting party’s rights and privacy.

    Reports regarding any form of sexual harassment, discrimination or sexual misconduct may be reported to the Title IX Coordinator or Deputy Title IX Coordinator.

    Complainants must be aware that an investigation conducted by the Seminary is distinct from a criminal investigation and flows from the Seminary’s obligation under Title IX and related laws to ensure that it is providing a safe environment for all community members.

    4. A Complainant has the option to do the following:

    1. File a criminal complaint with the Delafield Police Department or, other appropriate law enforcement agency; or  File a complaint under this Policy (Sexual Harassment, Discrimination, and Sexual Misconduct Policy) and request a Seminary Title IX investigation; or
    2. Pursue both processes simultaneously, even if a criminal proceeding is ongoing. The Seminary will conduct its own Title IX investigation and will not wait for the conclusion of the criminal proceeding to begin its Title IX investigation; or
    3. Choose not to pursue any of the aforementioned processes.

    5. Methods of Reporting

    You may formally or informally complain to any of the above personnel via any of the following:

  • E. Relevant Resources (contact information for help)

    1. Sexual Assault

    2. Sexual Abuse

    The Healing Center (Milwaukee)
    414-671-4325 Crisis line

  • F. Nashotah House Training Requirements for Title IX

    1. Students

    Nashotah House students are required to review this policy at the start of each academic year. New students will be require to complete Safe Guarding Gods Children and Safe Guarding God’s People (or their equivalent) prior to the start of classes. Students will also be expected to participate in any refresher courses, seminars, or training that may be deemed necessary by the administration.

    2. Employees

    Nashotah House employees are required to take training on sexual harassment and the seminary’s sexual harassment policy. New seminary employees must be trained before they start work in their seminary position. If that is not possible, the Policy must be reviewed and discussed with them before they start work and the training must be completed within three (3) months of starting.

    3. Supervisors and Decision-Makers

    Supervisors and decision-makers must complete training on sexual harassment, including preventing and responding to sexual harassment, within three (3) months of the effective date
    of this Policy, or of becoming a supervisor or decision-maker.

  • G. Title IX Incident Investigation

    The Title IX Coordinator and Deputy Title IX Coordinators may serve as an investigator and are trained in Title IX, all aspects of the complaint process, and can serve in any of the following roles:

    • To provide sensitive intake of complaints.
    • To investigate complaints, write reports with findings, conclusions and determination for discipline.

    All persons serving as investigators have received annual training approved by the Title IX Coordinator, including a review of Seminary policies and procedures, so that they are able to perform thorough, impartial investigations and provide accurate information to members of the Seminary community.

    1. Intake/Preliminary Investigation:

    Following receipt of a complaint, the Title IX Coordinator or Deputy Coordinator will promptly work with and interview the Complainant and coordinate the Seminary’s response. If the complaint does not allege a Policy violation, or if other resolution options are appropriate, or if a Complainant does not wish to pursue further action, then the complaint will not proceed to a Seminary Title IX investigation, barring extenuating circumstances.

    2. Investigation:

    If the Title IX Coordinator determines a full investigation should proceed, the Seminary will conduct a prompt, fair, and impartial investigation. A Seminary Title IX investigation will normally be completed within 60 calendar days after the Seminary begins its investigation. The Title IX Coordinator may extend this time frame for good cause with written notice to the Complainant and Respondent. Good cause for extensions includes, but is not limited to, the following: 1) the complexity of the case requires additional time; 2) there are multiple parties involved; 3) the witnesses or parties are unavailable or uncooperative; 4) Seminary closure or academic breaks; 5) if a Seminary investigation would compromise a law enforcement investigation.

    The Seminary may briefly delay its investigation to allow evidence collection by law enforcement.

    The process set forth in this policy is separate and distinct from any criminal investigation or proceeding and is a result of the Seminary’s obligation under Title IX to ensure it is providing a safe environment. The Seminary reserves the right to conduct its own Title IX investigation when it has reason to believe that the Respondent may be an imminent threat to the safety of the Complainant and/or the Seminary community.

    3. Advisor/Support Person:

    Both the Complainant and Respondent in the Seminary Title IX investigation process may have the assistance of an advisor or support person of their choosing throughout the process. This individual may be a friend, faculty/staff member, family member, or an attorney. The role of the advisor/support person is limited. Complainants and Respondents are expected to ask and respond to questions on their own behalf. The advisor/support person may consult with the advisee quietly or in writing, or outside the meeting during breaks, but may not speak on behalf of the advisee to the investigator. If the advisor or support person is an attorney the investigator may reschedule the time and or date of the interview(s) so that Nashotah House legal counsel may be present.

    4. Interim Measures:

    The Title IX Coordinator or Deputy Coordinator may enact interim measures intended to address the short or long-term effects of Prohibited Conduct and to prevent further harassment or violations. To the extent reasonable and feasible, the Seminary will consult with the Complainant in determining appropriate interim measures. Interim measures may include, but are not limited to, the following:

    • Housing reassignments
    • Rescheduling exams or other academic work
    • Arranging for an incomplete in a class
    • Modifying class schedules
    • Providing counseling, medical and/or mental health services
    • Offering assistance with alternative course completion options
    • Providing safety escorts to and from campus and nearby locations
    • Issuing a “Stay Away” directive
    • Instituting a work suspension

    5. Potential actions in the event the complainant chooses not to pursue an investigation:

    If the Complainant requests confidentiality or asks that the complaint not be pursued, the Seminary will take all reasonable steps to investigate and/or respond to the complaint consistent with the request for confidentiality or request not to pursue an investigation. If a Complainant insists that their name or other identifiable information not be disclosed to the alleged perpetrator, the Seminary’s ability to respond may be limited and the Seminary shall inform Complainant of this fact. Regardless of a Complainant’s request for confidentiality or that an investigation not take place, the Seminary will still provide interim measures and resources to the Complainant.

    Title IX prohibits retaliation, and the Seminary will not only take steps to prevent retaliation but also take strong responsive action if it occurs, even if a formal investigation is not pursued.

    The Seminary will not require a student, faculty or staff, who complains of harassment to work out the problem directly with the Respondent.

  • H. Complaint Resolution

    When it is determined that a formal investigation is necessary, the Title IX Coordinator will open a case file and the investigation will proceed as follows:

    1. Determine the identity of the Complainant (if not already known), contact information, any witnesses, and the Respondent, if he/she can be identified.
    2. Specify policies allegedly violated.
    3. Send a Notice of Investigation and Potential Violation to the Respondent (Complainant will receive a copy).
    4. The written notification may be sent to the Complainant and Respondent’s respective residences or may be sent to them via email to their Nashotah House email account. Complainants and Respondents are expected to check their email on a frequent and consistent basis and act in a timely manner as outlined in the official use of email to communicate with students’ policy, or Employee Handbook.
    5. The investigator will review statements obtained from all parties, conduct interviews with both Complainant and Respondent, conduct witness interviews, identify, locate and review other relevant information.
    6. The Complainant and Respondent will have the same opportunity to identify witnesses for the investigator to interview. The investigator has the right to forgo interviewing a witness if the investigator determines that the person does not have information that is relevant to the investigation. The investigator will not meet with character witnesses as part of the investigation process if they have no relevant factual information about the incident
    7. Throughout the investigation, both the Complainant and Respondent must provide information to the investigator if they remember, or learn of, additional information
    8. The Complainant and Respondent have the right to an advisor of their choosing present for an investigation interview with the designated investigator.
    9. Preponderance of Evidence Standard. The standard of proof for determining a violation of this Policy is that of a preponderance of the evidence—meaning that it is more likely than not that a violation of the Policy occurred.
    10. At the conclusion of the investigation, the investigator will forward their full Investigative Report and Determination of Sanction to the Title IX Coordinator for review and approval. The Report will contain the information obtained in the investigation, an analysis of the information, findings and determination of sanction.
    11. The Title IX Coordinator will inform the Complainant and the Respondent of the investigator’s finding by issuing a Decision Notification Letter. The Decision Notification Letter will include findings of fact and a determination of sanction(s), if applicable.
    12. If a Respondent is found responsible for violating this Policy, and whether or not the Respondent accepts the findings, the report will be sent to the appropriate Seminary official(s) for action on the sanctions. Once the appropriate Seminary official implements the sanction/action, the same shall be communicated to the Title IX Coordinator. See below for more information on sanctions.

    The Seminary will, where appropriate, take reasonable steps to remedy the harm to the affected individual(s) of the sexual harassment, including counseling to those who have been subjected to or who have engaged in sexual harassment.

  • I. Withdrawal or Decision not to Participate in Investigation
    1. If an alleged Respondent withdraws from the Seminary before the investigation and/or complaint resolution process have been concluded or the Respondent chooses not to participate in the process, the Respondent will still be informed that he or she is alleged to have violated Seminary policy, that an investigation will be conducted, and that the resolution process will continue.
    2. The Respondent may respond in one of three ways: 1) participate in the investigation, 2) waive the right to be interviewed by the investigator, thereby acknowledging that the complaint resolution process may go forward in his or her absence (this also waive his or her right to appeal an outcome), or 3) waive the right to appear and send a written, signed statement to be considered on his or her behalf as part of the investigation and complaint resolution process.
    3. For withdrawals, a letter will be sent to the Seminary Registrar indicating that such proceedings are pending. If the student attempts to re-enroll before the matter is resolved, the registrar will notify the Office of the Dean. The matter must be fully resolved before the student may re-enroll at Nashotah House.
  • J. Sanctions

    Nashotah House reserves the right to impose differing sanctions, depending on the severity and/or pervasiveness of the violation. In determining sanctions, the Seminary will consider the concerns and rights of both the Complainant and the Respondent.

    The following sanctions may be imposed upon any member of the community found to have violated this Policy. In determining the appropriate sanction(s), the Seminary must examine and consider a number of factors, including, but not limited to: 1) level of risk or harm to the community; 2) the nature and seriousness of the offense; 3) use of drugs or alcohol; 4) motivation underlying the Respondent’s behavior; 5) the Respondent’s disciplinary history, including prior violations of the same or similar type; 6) cooperation with the investigation.

    Note: sanctions will not generally be implemented until after the appeal deadline has passed or, if an appeal is filed, until after the appeal has concluded. However, Nashotah House reserves the right to keep in place interim measures, or to implement additional measures, on a case-by-case basis, at any time.

    1. Student Sanctions

    • Warning
    • Probation
    • Suspension
    • Expulsion
    • Withholding Diploma
    • Withholding Degree
    • Transcript Notation
    • Organizational Sanctions
    • Other Actions

    2. Employee Sanctions

    • Corrective counseling including but not limited to warning through termination
    • Performance Improvement Plan
    • Required training or education
    • Suspension with or without pay
    • Termination

    3. Sanctioning for Sexual Misconduct

    • Any person found responsible for violating this Policy as it relates to Non-Consensual or Forced Sexual Contact (where no intercourse has occurred) will likely receive a sanction ranging from probation to expulsion, or termination, depending on the severity of the incident, and taking into account any previous disciplinary violations.
    • Any person found responsible for violating the policy on Non-Consensual or Forced Sexual Intercourse will likely face a sanction of suspension or expulsion (student) or suspension or termination (employee).
    • Any person found responsible for violating the policy on Sexual Exploitation or Sexual Harassment will likely receive a sanction ranging from warning to expulsion or termination, depending on the severity of the incident, and taking into account any previous disciplinary violations.
    • In the event a Respondent is suspended or expelled as a result of a finding of responsibility under the Policy, a notation will appear on his or her transcript.

    Note: Violations not falling within this policy may be referred for review/possible action under other Seminary policies/procedures (e.g., the Student Conduct Code, Employee Handbook, or Faculty Handbook).

  • K. Appeals

    The original finding and sanction(s) will stand if the decision is not appealed or if an appeal is not timely.

    1. General Information

    Once a Decision Notification Letter is issued under this Policy, the Complainant and the Respondent shall each have the right to submit an appeal to the Title IX Coordinator within five (5) business days of receiving the written Decision Notification Letter from the Title IX Coordinator. The Decision Notification Letter will be provided in person and/or emailed to the parties’ Seminary-issued email account. Once the Decision Notification Letter is provided in person and/or sent via email, it will be deemed presumptively delivered.

    Any party who files an appeal must do so in writing and submit it to the Title IX Coordinator who will determine if the appeal is timely. If the appeal is timely, the Title IX Coordinator will assign the appeal to an appropriate Appeal Officer (e.g., The Dean or an Associate Dean). A copy of the appeal will be promptly provided to the non-appealing party.

    The appeal process is not a hearing or a review of the entire matter; rather, it is a review of the record and process only. Appeal decisions are to be deferential to the original investigative findings and determination, remanding only when there is clear reason to do so. Further, modification of the sanction(s) shall only occur if there is a compelling justification to do so.

    The Appeal Officer may take one of three possible actions on appeal:

    1. Dismiss the appeal as having no merit, upholding the initial findings and sanction(s).
    2. Remand to the original investigator for further investigation or fact-finding.
    3. Modify the outcome and/or sanction(s).

    2. Criteria for Appeals

    Procedural or substantive error occurred that significantly impacted the outcome of the hearing (e.g., substantiated bias, material deviation from established procedures.)

    To consider new evidence, unavailable during the original investigation, that could substantially impact the original finding or sanction. A summary of this new evidence and its potential impact must be included.

    The sanction(s) imposed fall outside the range of sanctions designated for this offense and the cumulative conduct history of the responding party.

    The Appeals Officer will typically render a written decision on the appeal to the Title IX Coordinator within five (5) business days from receipt of the appeal. The Title IX Coordinator will forward the written decision of the Appeals Officer to the parties.

    The Appeals Officer’s decision is final and there are no further appellate options.

  • L. Maintenance of Data

    Nashotah House shall maintain documents and other data relating to specific complaints or other reports of sexual harassment of students, faculty and staff, regardless of sanction, including the following:

    • A copy of all written reports, and a narrative of all verbal reports of incidents involving allegations of sexual harassment of any kind;
    • Copies of all Stay-Away Directives and documentation of receipts of the same;
    • Documentation establishing that the Seminary provided notice that the Complainant could elect to pursue criminal charges, Title IX complaint and investigation through the Seminary, or both processes simultaneously;
    • A narrative of all actions taken in response to the reports by Seminary personnel, including any written documentation;
    • A copy of any and all disciplinary sanctions issued to students, faculty or staff for violations of this policy;
    • Documentation demonstrating any interim measures offered and provided to the Complainant, the Respondent and/or witnesses of the incident(s) such as counseling or other appropriate services;
    • A narrative of all action taken to prevent recurrence of any harassing incident(s), including any written documentation.
  • M. Amendments and Termination of this Policy

    Nashotah House Theological Seminary reserves the right to modify, amend, or terminate this Policy at any time. Students, faculty and staff are encouraged to check online for the most current version of all policies and procedures. If government regulations change in a way that impacts this document, this document will be construed to comply with government regulations in their most recent form. This policy is effective as of  August 1, 2018. This policy supersedes all previous Nashotah House policies with respect to Title IX and related discrimination matters. (Previous versions of this policy are available upon request.)

  • N. Rights of Parties

    In addition to the rights set forth in this policy, Complainants and Respondents have the following rights:

    a. Complainant’s Rights

    1. The right to a thorough, impartial and prompt investigation, by an impartial decision maker, and appropriate resolution of all credible complaints of Prohibited Conduct made in good faith to the Seminary
    2. The right to be fully informed of the Seminary’s relevant policies and procedures
    3. The right to be treated with respect by Seminary officials
    4. The right to be informed of the option to file criminal charges in addition to pursuing a complaint through the Seminary’s process, or to do neither
    5. The right to experience a safe living, educational and work environment
    6. The right to have one advisor or support person during this process
    7. The right to request to have his/her identity or personally identifiable information withheld during the investigation
    8. The right not to be charged for minor student misconduct (such as alcohol or drug violations) that is ancillary to the incident
    9. The right to request interim measures from the Seminary intended to restore a sense of safety and/or ability to participate in Seminary programs and activities
    10. The right to be free from retaliation
    11. The right to be given equal opportunity to access, and present evidence to the investigator
    12. The right to be kept informed of the complaint status and anticipated resolution timeline
    13. The right to be informed in writing of the outcome/resolution of the complaint, sanctions where permissible and the rationale for the outcome where permissible
    14. The right to information about the appeals process and how to appeal an outcome

    b. Respondent’s Rights

    1. The right to a thorough, impartial and prompt investigation, by an impartial decision maker, and appropriate resolution of all credible complaints of Prohibited Conduct made in good faith to the Seminary
    2. The right to be fully informed of the Seminary’s relevant policies and procedures;
    3. The right to be treated with respect by Seminary officials
    4. The right to one advisor or support person during this process
    5. The right to be given equal opportunity to access, and present evidence to the investigator.
    6. The right to be kept informed of the complaint status and anticipated resolution timeline
    7. The right to be informed, in writing of the outcome/resolution of the complaint and the rationale for the outcome
    8. The right to information about the appeals process and how to appeal an outcome

    c.Witness Rights

    1. The right to be treated with respect by Seminary officials
    2. The right to be free from retaliation
    3. The right to not to be charged for minor student misconduct (such as alcohol or drug violations) that is ancillary to the incident