Sexual Violence Policy

Revised:  April 19, 2017

1.  Sexual Violence Policy

(a)  The Canadian School of Private Investigation and Security Ltd. is committed to providing its students with an educational environment free from sexual violence and treating its students who report incidents of sexual violence with dignity and respect.

(b)  The Canadian School of Private Investigation and Security Ltd. has adopted this Sexual Violence Policy, which defines sexual violence and outlines its training, reporting, investigative and disciplinary responses to complaints of sexual violence made by its students that have occurred on its campus, or at one of its events and involve its students.

(c)The person accused of engaging in sexual violence will be referred to as the“Respondent” and the person making the allegation as the “Complainant”.

2. Terms and Definitions

Sexual violencemeans any sexual act or other act targeting a person’s sexuality, gender identity or gender expression, whether the act is physical or psychological in nature, that is committed, threatened or attempted against a person without the person’s consent, and includes sexual assault, sexual harassment, stalking, indecent exposure, voyeurism and sexual exploitation.Sexual violence is a broad term which describes any physical or psychological violance carried out through sexual means or by targeting an individual’s sexuality. This violence takes different forms including sexual abuse and sexual assault.

Consent is defined as a voluntary and explicit agreement to engage in the sexual activity in question. It is the act of willingly agreeing to engage in specific sexual behaviour, and requires that a person is able to freely choose between two options: yes and no. This means that there must be an understandable exchange of affirmative words, which indicates a willingness to participate in mutually agreed upon sexual activity. It is also imperative that everyone understands the following:

  • Silence or non-communication must never be interpreted as consent and a person in a state of diminished judgment cannot consent.
  • A person is incapable of giving consent if they are asleep, unconscious or otherwise unable to communicate.
  • A person who has been threatened or coerced (involuntary behaviour) into engaging in the sexual activity is not consenting to it.
  • A person who is drugged is unable to consent.
  • A person is generally unable to give consent when under the influence of alcohol and/or drugs.
  • A person may be unable to give consent if they have a mental disability preventing them from fully understanding the sexual acts.
  • The fact that consent was given in the past to a sexual or dating relationship does not mean that consent is deemed to exist for all future sexual activity.
  • A person can withdraw consent at any time during the course of a sexual encounter.
  • A person is incapable of giving consent to a person in a position of trust, power or authority, such as a faculty member initiating a relationship with a student who they teach, an administrator in a relationship with anyone who reports to that position.
  • Consent cannot be given on behalf of another person.
  • It is the responsibility of the initiator of sexual activity to ensure clear and affirmative responses are communicated at all stages of sexual engagement. It is also the initiator’s responsibility to know if the person they are engaging with sexually is a minor.

Sexual Harassment is defined by section 10 of the Ontario Human Rights Code as “engaging in a course of vexatious comment or conduct that is known or ought to be known to be unwelcome.”  This definition is far from all encompassing.  Sexual harassment can include but not be limited to demanding hugs, invading one’s personal space, unnecessary physical contact including unwanted touching, etc., derogatory language or comments, leering or inappropriate staring, gender-related comments about a person’s physical characteristics or mannerisms.

3. Training, Reporting and Responding to Sexual Violence

(a)  The Canadian School of Private Investigation and Security Ltd. shall include a copy of the Sexual Violence Policy in every contract made between it and its students, and provide a copy of the Sexual Violence Policy to career college management (corporate directors, controlling shareholders, owners, partners, other persons who manage or direct the career college’s affairs, and their agents), instructors, staff, other employees and contractors and train them about the policy and its processes of reporting, investigating and responding to complaints of sexual violence involving its students.

Any company participating in offering student internships on their premises must provide an undertaking in writing that it is in compliance with all applicable legislation, including the Ontario Human Rights Code and the Occupational Health and Safety Act and will provide students access to those policies should they encounter issues relating to sexual violence in the workplace.

(b)The Sexual Violence Policy shall be published on its website.

(c)Thecollege management, instructors, staff, other employees and contractors of the Canadian School of Private Investigation and Security Ltd. will report incidents of or complaints of sexual violence to Edward Franco, Campus Administrator, upon becoming aware of them.

(d)Students who have been affected by sexual violence or who need information about support services should contact:

Edward Franco

Campus Administrator

2828 Dufferin Street

Toronto, ON  M6B 3S3

(416) 785-5701

efranco@cspis.com

(e)Subject to Section 4 below, to the extent it is possible, The Canadian School of Private Investigation and Security Ltd. will attempt to keep all personal information of persons involved in the investigation confidential except in those circumstances where it believes an individual is at imminent risk of self-harm, or of harming another, or there are reasonable grounds to believe that others on its campus or the broader community are at risk. This will be done by:

(i)ensuring that all complaints/reports and information gathered as a result of the complaint/reports will be only available to those who need to know for purposes of investigation, implementing safety measures and other circumstances that arise from any given case; and

(ii)ensuring that the documentation is kept in a separate file from that of the Complainant,Student or the Respondent.

(f)The Canadian School of Private Investigation and Security Ltd. recognizes the right of the Complainant not to report an incident or make a complaint about sexual violence or not request an investigation and not to participate in any investigation that may occur.

(g)Notwithstanding (f) above, in certain circumstances, The Canadian School of Private Investigation and Security Ltd. may be required by law or its internal policies to initiate an internal investigation and/or inform police without the complainant’s consent if it believes the safety of members of its campus or the broader community is at risk.

(h)In all cases, including (f) above, The Canadian School of Private Investigation and Security Ltd.will appropriately accommodate the needs of its students who are affected by sexual violence. Students seeking accommodation should contact Edward Franco or Dora Hatzinikolaou.

In this regard, The Canadian School of Private Investigation and Security Ltd.will assist students who have experienced sexual violence in obtaining counseling and medical care, and provide them with information about sexual violence supports and services available in the community as set out in Appendix 1 attached hereto. Students are not required to file a formal complaint in order to access supports and services.

4. Investigating Reports of Sexual Violence

(a)Under this Sexual Violence Policy, any student of The Canadian School of Private Investigation and Security Ltd.may file a report of an incident or a complaint to Edward Franco in writing. The other officials, offices or departments who may be involved in the investigation are Dora Hatzinikolaou.

(b)Upon receipt of a report of an incident or a complaint of alleged sexual violence being made, Edward Franco will respond promptly and:

(i)determine whether an investigation should proceed and if the Complainant wishes to participate in an investigation;

(ii)determine who should conduct the investigation having regard to the seriousness of he allegation and the parties involved;

(iii)determine whether the incident should be referred immediately to the police;

In such cases or where civil proceedings are commenced in respect of allegations of sexual violence, The Canadian School of Private Investigation and Security Ltd.may conduct its own independent investigation and make its own determination in accordance with its own policies and procedures; and

(iv)determine what interim measures ought to be put in place pending the investigation process such as removal of the Respondent or seeking alternate methods of providing necessary course studies.

(c)Once an investigation is initiated, the following will occur:

(i)the Complainant and the Respondent will be advised that they may ask another person to be present throughout the investigation;

(ii)interviewing the Complainant to ensure a complete understanding of the allegation and gathering additional information that may not have been included in the written complaint such as the date and time of the incident, the persons involved, the names of any person who witnessed the incident and a complete description of what occurred;

(iii)informing and interviewing the Respondent of the complaint, providing details of the allegations and giving the Respondent an opportunity to respond to those allegations and to provide any witnesses the Respondent feels are essential to the investigation;

(iv)interviewing any person involved or who has, or may have, knowledge of the incident and any identified witnesses;

(v)providing reasonable updates to the Complainant and the Respondent about the status of the investigation; and

(vi)following the investigation, the campus administrator will:

(A)review all of the evidence collected during the investigation;

(B)determine whether sexual violence occurred; and if so

(C)determine what disciplinary action, if any, should be taken as set out in Section 5 below.

5. Disciplinary Measures

(a)If it is determined by The Canadian School of Private Investigation and Security Ltd.that the Respondent did engage in sexual violence, immediate disciplinary or corrective action will be taken. This may include:

(i)disciplinary action up to and including termination of employment of instructors or staff; or

(ii)expulsion of a student; and /or

(iii)the placement of certain restrictions on the Respondent’s ability to access certain premises or facilities; and/or

(iv)any other actions that may be appropriate in the circumstances.

6. Appeal

(a)Should the Complainant or the Respondent not agree with the decision resulting from the investigation, he or she may appeal the decision to the campus administrator, Edward Franco or to the president of the institution within 14 days by submitting a letter addressed to:

President,

Canadian School of Private Investigation and Security Ltd.

2828 Dufferin Street

Toronto, ON  M6B 3S3

advising of the person’s intent to appeal the decision.

7.Making False Statements

(a)It is a violation of this Sexual Violence Policy for anyone to knowingly make a false complaint of sexual violence or to provide false information about a complaint.

(b)Individuals who violate this Sexual Violence Policy are subject to disciplinary and / or corrective action up to and including termination of employment of instructors or staff or expulsion of a student.

8. Reprisal

(a)It is a violation of this Sexual Violence Policy to retaliate or threaten to retaliate against a complainant who has brought forward a complaint of sexual violence, provided information related to a complaint, or otherwise been involved in the complaint investigation process.

(b)Individuals who violate the Sexual Violence Policy are subject to disciplinary and /or corrective action, up to and including termination of employment of instructors or staff or expulsion of a student.

9.Review

(a)The Canadian School of Private Investigation and Security Ltd.shall ensure that student input is considered in the development of its Sexual Violence Policy and every time it is reviewed or amended.

(b)The Canadian School of Private Investigation and Security Ltd.shall review its Sexual Violence Policy 3 years after it is first implemented and amend it where appropriate. The upcoming review of this policy will be in April, 2020.

10.Collection of Student Data

(a)The Canadian School of Private Investigation and Security Ltd.shall collect and be prepared to provide upon request by the Superintendent of Private Career Colleges such data and information as required according to Subsections 32.1 (8), (9), (10) and (11) of Schedule 5 of the Private Career Colleges Act, 2005 as amended.

This document is intended to be a Sexual Violence and Harassment Policy Guideline and does not constitute legal advice.

 

Appendix 1

 

The following list of Provincial Rape Crisis Centrescan provide counseling, information or assistance:

 

Canadian Association of Sexual Assault Centres

 

Assaulted Women’s Helpline

Toll Free: 1-866-863-0511

#SAFE (#7233) on Bell, Rogers, Fido or Telus mobile

TTY: 416-364-8762

www.awhl.org

 

Français

Fem’aide

Telephone Toll-Free: 1-877-336-2433

ATS: 1 866 860-7082

www.femaide.ca

 

The following link is to Sexual Assault/Domestic Violence Treatment Centres who may provide 24/7 emergency care to women:  hospital-basedcentres that provide 24/7 emergency care to women.

 

To locate the Sexual Assault/Domestic Violence Treatment Centre nearest you, follow this link

Or contact the facilities below:

 

Alliston, Barrie, Collingwood, Midland and Orillia

Huronia Transition Homes operates La Maison Rosewood Shelter (Midland) & Athena’s Sexual Assault Counselling and Advocacy Centre

 

24-Hour Crisis Line:

Barrie: 705-737-2008 or 1-800-987-0799 Midland: 705-526-4211 or 1-800-461-175 Office: 705-526-3221 www.huroniatransitionhomes.ca

 

Belleville

Sexual Assault Centre for Quinte and District Toll-Free: 1-877-544-6424

Office: 613-967-6300 www.sacqd.com

 

Bracebridge

Muskoka/Parry Sound Sexual Assault Services

Parry Sound District Office

Office: (705) 774-9083 or 1-877-851-6662 www.daphnewymn.com

Muskoka District Office

Office: (705) 646-2122 or 1-877-406-1268 www.daphnewymn.com

 

 

Brantford

Sexual Assault Centre of Brantford

Crisis: 519-751-3471

Office: 519-751-1164 sexualassaultcentre@sacbrant.ca http://sacbrant.ca/

 

Brockville

Assault Response & Care Centre

Office: (613) 345-3881 or 1-800-567-7415 arcc@bgh-on.ca

www.arc-c.ca

 

Chatham

Chatham-Kent Sexual Assault Crisis Centre 24-Hour Crisis Line: 519-354-8688 Office/TTY: 519-354-8908 http://cksacc.org/

 

Cornwall

Sexual Assault Support Services for Women Office:613-932-1755 http://sassforwomen.ca/

Iethinisten:ha Women’s Shelter

Akwasasne Family Violence Program

24-Hour Crisis: 1-800-480-4208

Phone: 613-937-4322

www.akwesasne.ca/iethinistenha-women’s-shelter

 

Durham Region

Durham Rape Crisis Centre Crisis: 905-668-9200 Office: 905-444.9672 info@drcc.ca

www.drcc.ca

 

Eganville

Women’s Sexual Assault Centre of Renfrew County

24-Hour Crisis: 1-800-663-3060 Office: 613-735-5551 www.wsac.ca

 

Guelph

Guelph-Wellington Women in Crisis Crisis: 519-836-5710 1-800-265-7233

Office: 519-823-5806 www.gwwomenincrisis.org

 

Hamilton

Sexual Assault Centre (Hamilton and Area)

Crisis: (905) 525-4162

Office (905) 525-4573 TTY: 905-525-4592 www.sacha.ca

 

Kenora

Kenora Sexual Assault Centre

Crisis: (807) 468-7233 or 1-800-565-6161 Office: (807) 468-7958 www.kenorasexualassaultcentre.com

 

Kingston

Sexual Assault Centre Kingston

Crisis: 613-544-6424 or 1-877-544-6424 Office: 613-545-0762 sack@sackingston.com www.sackingston.com

 

Kitchener-Waterloo

Sexual Assault Support Centre of Waterloo Region

Crisis: 519.741.8633

Office: 519.571.0121 info@sascwr.org www.kwsasc.org

 

London

Sexual Assault Centre London

Crisis: 519-438-2272

Office 519-439-0844

TTY: 519-439-0690 sacl@sacl.ca www.sacl.ca

London Abused Women’s Centre

Office: 519-432-2204

E-Mail: info@lawc.on.ca

http://lawc.on.ca/

 

Peel Region

Hope 24/7 (formerly the Sexual Assault/Rape Crisis Centre of Peel)

Crisis:1-800-810-0180

Office: (905) 792-0821

http://hope247.ca/

 

Newmarket

Women’s Support Network of York Region

Crisis: 1-800-263-6734 or 905-895-6734 Office: (905) 895-3646 www.womenssupportnetwork.ca

 

North Bay

Amelia Rising Women’s Sexual Assault Centre of Nipissing/centred’aggressionssexuelles de

Nipissing

Crisis: 705-476-3355

Office: 705-840-2403

TTY: (705) 840-5877 info@ameliarising.ca www.ameliarising.ca

 

Oakville

Sexual Assault & Violence Intervention Services of Halton

Crisis: 905-875-1555 or 1-877-268-8416

Office: 905-825-3622 www.savisofhalton.org

 

Orangeville

Family Transition Place

Crisis: 1-800-265-9178

Office: 519-942-4122 www.familytransitionplace.ca

 

Ottawa

Sexual Assault Support Centre

Crisis: 613-234-2266

Phone: 613-725-2160

TTY: 613-725-1657

info@sascottawa.com http://sascottawa.com

 

Ottawa Rape Crisis Centre

Crisis: 613-562-2333

Office: 613-562-2334

http://orcc.net/

 

Peterborough &Kawarthas

Kawartha Sexual Assault Centre

Crisis: (705) 741- 0260 or 1-866-298-7778 Office/TTY: (705) 741-0260 www.kawarthasexualassaultcentre.com

YWCA Peterborough Haliburton

Crisis: 1-800-461-7656

Office: 705.743.3526 x 130 www.ywcapeterborough.org

 

Sault Ste Marie

Women in Crisis (Algoma) Inc.

Crisis: 705-759-1230 or 1-877-759-1230 www.womenincrisis.ca

Sarnia-Lambton

Sexual Assault Survivors Centre Sarnia-Lambton

Crisis: 519 337-3320 or 1-888-231-0536

Office: (519) 337-3154 www.sexualassaultsarnia.on.ca

 

Simcoe

Haldimand& Norfolk Women’s Service

Crisis: 1-800-265-8076

TTY: 1-800-815-6419

Office: 519-426-8048 hnws@hnws.on.ca www.hnws.on.ca

 

St. Catherines

Niagara Region Sexual Assault Centre

Crisis: (905) 682-4584

Office: (905) 682-7258 carsa@sexualassaultniagara.org http://sexualassaultniagara.org/

 

Thunder Bay

Thunder Bay Sexual Assault and Sexual Abuse Crisis and Counselling Centre

Office: (807) 345-0894 or 1-866-311-5927 tbcounselling@tbsasa.org www.tbsasa.org

 

Timmins

Timmins and Area Women in Crisis

Crisis: 1-877-268-8380 (sexual assault)

Crisis: 1-855-827-7233 (shelter)

Office: (705) 268-8381

info@tawc.ca http://www.tawc.ca/

 

Toronto

Oasis Centre des Femmes

Téléphone : 416-591-6565

Courriel :services@oasisfemmes.org

http://oasisfemmes.org/

 

Toronto Rape Crisis Centre: Multicultural Women Against Rape

Crisis: 416-597-8808

Office: 416-597-1171 info@trccmwar.ca crisis@trccmwar.ca www.trccmwar.ca

 

Windsor

Sexual Assault Crisis Centre of Essex County

Crisis: 519-253-9667

www.saccwindsor.net

 

Woodstock

Domestic Abuse Services Oxford

Crisis: 519 539-4811 or 1-800-265-1938

info@daso.ca

www.daso.ca