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It is the policy of ����vlog��Ʒ that all members of the College community have a right to a work and study environment that is safe and respectful, free from discrimination, hate and harassment including that which is related to any of the prohibited grounds in the Ontario Human Rights Code including race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, age, marital status, family status, disability, sexual orientation (and same sex partnership status) and record of offences, as these terms are defined and interpreted in and by the Ontario Human Rights Code. 

This policy applies to all members of the ����vlog��Ʒ community including students, employees, members of the Board of Governors, members of committees established by the College, volunteers, visitors and guests (including guest speakers) on campus. This policy covers incidents that occur both on and off College premises, in both physical and virtual environments, which affect the College working and/or learning environment. Incidents occurring off campus which have no likelihood of impact on the work/study environment are to be pursued through the Ontario Human Rights Commission or any other relevant legislation but will not be dealt with under this policy.

����vlog��Ʒ maintains a glossary of terms specific to the institution. The ones in use for this document are defined below.

As an important part of this policy, the accompanying procedures provide an internal mechanism for receiving complaints of discrimination or harassment and setting out a process by which the College will manage and respond to those complaints. Although the College’s procedures are written in the language of an individual complaint, group complaints may be brought under this policy. Similarly, there may be more than one respondent involved in a complaint. One procedure outlines the process for managing complaints against an Employee. A separate procedure outlines the process for managing complaints against a student. 

1. Complaints unrelated to the Human Rights Code protected grounds: Complaints unrelated to the Human Rights Code against students are to be made under the Student Rights and Responsibilities policy and procedure. Complaints unrelated to the Human Rights Code against employees should be made to the Human Resources Department. 
2. Intersectional Approach: The experience of discrimination when multiple grounds are involved may be complex. An intersectional approach, considering the uniqueness of experience recognizing that individuals have multiple identities and that these identities shape their experience of discrimination. 
3. Timelines: A complaint, either formal or informal, must be reported within six (6) months of the incident except in extenuating circumstances that would explain the delay. Should a late complaint be filed, the College will assess the extenuating circumstances against any prejudice to a respondent and/or to the College to determine if the matter should proceed through the complaint process. 
4. Procedural Fairness: No action will be taken against a person or group without their knowledge where there is an alleged breach of the Human Rights Code. It is intended that they be given reasonable notice, with a summary of the alleged breach and an opportunity to answer to the allegations made.
5. Confidentiality: ����vlog��Ʒ acknowledges that it may be difficult to come forward with a complaint of discrimination or harassment and recognizes a complainant’s interest in keeping the matter confidential. To protect the interests of the complainant, the respondent and any others who may be involved, the College will use its best efforts to maintain confidentiality to the extent practicable and appropriate under the circumstances; however, confidentiality does not mean anonymity. In the instance of a formal complaint, a fundamental principle is that the respondent must be informed of who has made the allegations at the earliest possible point in the process. Investigation documents will be stored in a confidential file held by Human Resources, in a location separate from the employee’s HR file. Investigation documents for complaints against students will be stored in a confidential location held by the Student Rights & Responsibilities Office. Disciplinary record documentation regarding substantiated acts of harassment will be maintained in secure locations which may include the Student Rights and Responsibilities Office and the Security Office. The file will be maintained in accordance with the College’s practices regarding document retention and may be retained indefinitely. 
6. Anonymous complaints: We accept anonymous reports including with respect to complaints regarding contravention of this policy, however, in accordance with the Confidentiality section noted above, anonymity may limit our ability to investigate such complaints. 
7. Exceptional Circumstances: The College has the right to act or direct procedures which diverge from sections of this policy when the safety of the individual and/or College community is at risk. 
8. Intersection with other policies: The protections within this policy exist in conjunction with other college policies and concepts including academic freedom, and policy statement on upholding free speech. Where the exercise of academic freedom and/or free speech crosses into the realms of Discrimination, Harassment, a threat, or Hate speech, this policy shall govern. 
9. Parallel Processes: It is recognized that complaints may be pursued under the Ontario Human Rights Code directly with the Ontario Human Rights Commission or by way of a grievance procedure outlined under the relevant collective agreement. 
10. Protection from Reprisals, Retaliation or Threats: It is contrary to this policy for anyone to retaliate, make reprisals or threaten to retaliate or reprise against a complainant or other individual for: 
1. Having pursued rights under this Policy or the Ontario Human Rights Code or other legislation; 
2. Having participated or co-operated in an investigation under this Policy or the Ontario Human Rights Code or other legislation; 
3. Having been associated with someone who has pursued rights under this Policy or the Ontario Human Rights Code or other legislation; 
4. Anyone engaged in such conduct may be subject to sanctions or discipline.
11. Balance of Probabilities: This represents the standard of proof that must be met in order to draw the conclusion that it is more likely than not that the allegation or fact asserted is true, based on sufficient, relative, probative and credible evidence. 
12. Unsubstantiated Complaints: If a person, in good faith, files a harassment complaint that is not supported by evidence gathered during an investigation, that complaint will be dismissed and no record of it will be placed on file. 
13. Frivolous, vexatious or bad faith conduct: Allegations of harassment or discrimination are serious matters. Complaints made without sufficient grounds to purposely annoy, embarrass or harm the respondent are considered frivolous, vexatious, or bad faith complaints and may result in sanctions or discipline against the complainant. 
14. Right to Withdraw a Complaint: A complainant has the right to withdraw a complaint at any stage of the process. However, the College may continue to act on the issue identified in the complaint in order to comply with its legal obligations under the Ontario Human Rights Code or other legislation. 
15. Referrals: Any complaint not addressed through college processes may be referred by the complainant to the Ontario Ombudsman. 
16. Annual Reporting: A report shall be provided to the Board of Governors each year, posted to the college website, and submitted to the Minister by January 31st. Protecting the confidentiality of all individuals, the report shall include the number and type of complaints, category of complaint, associated Code group as applicable, and outcome. 
17. Review: This review cycle for this policy shall be as often as necessary, but at least annually.